South Whittier School District

50000-Federal Programs ? Approval of Automatic Payroll System (Noncompliance and Material Weakness in Internal Controls over Compliance) Federal Programs Affected Title I, Part A, Basic Grants Low-Income and Neglected Assistance Listing Number: 84.010 Pass-Through Entity: California Department of Education Federal Agency: U.S. Department of Education COVID-19 Education Stabilization Fund Assistance Listing Numbers: 84.425C, 84.425D, 84.425U, 84.425W Pass-Through Entity: California Department of Education Federal Agency: U.S. Department of Education Criteria or Specific Requirements Per Title 2, Code of Federal Regulations, Part 200, Subpart E, Section 200.430(i)(1), charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition Through review of wages charged to the federal programs, it was noted that employee timecards are not consistently reviewed and approved by supervisors and department heads. Questioned Costs This finding represents a material weakness in internal control over federal compliance. However, there were no questioned costs associated with this finding as we did not identify any unallowable expenditures as a result of the finding. Context A significant amount of the federal expenditures related to these programs are derived from payroll costs. While the wages appear to be reasonable and necessary for the program objectives, the District did not provide documentation that indicates review and approval of the charged earnings. Effect The District has not complied with the requirements identified in Title 2, Code of Federal Regulations, Part 200, Subpart E, Section 200.430 (i)(1). Cause The identified condition appears to have materialized due to ineffective monitoring of timecard approval statuses within District?s automated payroll processing system. Repeat Finding No. Recommendation The District should monitor the status of timecard approvals within the automated payroll system and procedures should be implemented to ensure that all timecards have been reviewed and approved prior to processing payroll.

Corrective Action Plan and Views of Responsible Officials The Director of Fiscal Services and payroll staff will collaborate with site administrators to ensure all timecards relating to federal programs are pre-approved before submitting them to payroll for processing. In addition, payroll will not process timecards without prior approval.

50000-Federal Programs ? Inventory Control (Noncompliance and Material Weakness in Internal Controls over Compliance) Federal Programs Affected COVID-19 Emergency Connectivity Fund Program Assistance Listing Number: 32.009 Pass-Through Entity: N/A ? Direct Award Federal Agency: Federal Communications Commission Criteria or Specific Requirements In accordance with Federal Communications Commission (FCC) Report and Order 21-58, paragraphs 116-118, Emergency Connectivity Fund (ECF) Program participants are required to maintain asset and service inventories of the devices and services purchased with ECF Program support. Asset inventories are required to contain the following elements: (a) device type, (b) device make/model, (c) equipment serial number, (d) the name of the person to whom the device was provided, and (e) the dates the device was loaned out and returned to the school. Service records must include the following elements: (a) type of service provided, (b) broadband plan details, including: upload and download speeds and monthly data cap, (c) the name(s) of the person(s) to whom the service was provided, and for fixed broadband service; (d) the service address, and (e) the installation date of service, and (f) the last date of service (as applicable). Condition The District did not maintain adequate inventory records for assets and services purchased with ECF funds. The inventory records were not adequately updated to reflect when and to whom the purchased items and services were provided, certain items did not contain indication of the associated serial number and make/model, and the total number of inventoried items could not be reconciled to the number of items purchased with ECF funds. Questioned Costs There were no questioned costs associated with this finding. Context The condition was identified through inquiries with District management and review of program records. Effect The District is not in compliance with the device and service inventory requirements of the program. Cause Due to the time-sensitive need to maintain connectivity for student learning, the District did not prioritize adequate record-keeping in accordance with program requirements. Repeat Finding No. Recommendation The District should ensure that program requirements are reviewed and adequate controls over compliance are in place prior to commencing program activities under federal programs.

Corrective Action Plan and Views of Responsible Officials The Director of Technology will purchase an inventory software system to assist with tracking all equipment purchases with federal and non-federal funding. All equipment purchases will be tagged and recorded into the system by their serial number and category. Scanners will be used when entering a room to assist with determining the location of the equipment, and a computer log will be used to track the assigning out and in of equipment.

50000-Federal ? Program Implementation (Noncompliance and Material Weakness in Internal Controls over Compliance) Federal Programs Affected COVID-19 Emergency Connectivity Fund Program Assistance Listing Number: 32.009 Pass-Through Entity: N/A ? Direct Award Federal Agency: Federal Communications Commission Criteria or Specific Requirements In accordance with FCC Report and Order 21-58, paragraph 5, Emergency Connectivity Funds (ECF) Program support shall be used by schools to meet the otherwise unmet connectivity needs of students and school staff during the COVID-19 pandemic. Additionally, FCC Report and Order 21-58, paragraph 54 states that ECF Program support shall not be used to fund more than one connected device and more than one Wi-Fi hotspot per students or school staff member during the COVID-19 emergency period. Condition As the District?s asset and service inventories were not complete and did not contain all required elements, a determination could not be made regarding the total number of students and staff members who were provided with assets or services purchased with ECF support. We were therefore unable to verify the District?s compliance with program requirements related to unmet connectivity needs and per-user limitations. Questioned Costs This finding represents a material weakness in internal control over federal compliance. However, there were no questioned costs associated with this finding as we did not identify any unallowable expenditures as a result of the finding. Context The condition was identified through inquiries with District management and review of program records. Effect The District is not in compliance with program requirements related to unmet connectivity needs and per-user limitations. Cause Due to the time-sensitive need to maintain connectivity for student learning, the District did not prioritize adequate record-keeping in accordance with program requirements. Repeat Finding No. Recommendation The District should ensure that program requirements are reviewed and adequate controls over compliance are in place prior to commencing program activities under federal programs.

Corrective Action Plan and Views of Responsible Officials The District has implemented a team comprised of the Associated Superintendents of Business and Education Services and Directors of Fiscal and Technology Services to implement a need assessment before any spending takes place. This group will review and evaluate all processes associated with the program before implementation. All items purchased will be tracked using the new inventory software, and a log with be kept to maintain a record of the assigned in and out of equipment. Implementing this new process will eliminate this finding from re-occurring.