Bishop Unified School DistrictLocal Government

Federal Agency: U.S. Department of Agriculture Pass-Through Entity: California Department of Education Program Name: Child Nutrition Cluster Federal Financial Assistance Listing: 10,553, 10.555 Award Year: 2024-2025 Fiscal Year Compliance Requirement: Procurement, Suspension and Debarment Type of Finding: Significant Deficiency and Non-Compliance Criteria Title 2, Code of Federal Regulations (CFR), Part 200, Subpart D, Section 200.318(a) requires recipients and subrecipients of Federal awards to maintain and use documented procurement procedures that conform to standards identified in Title 2, CFR, Part 200, Subpart D, Section 200.318. This includes the retention of all procurement related documents in connection with federal awards. Condition The District was unable to provide procurement documents, including copies of bid documents and contracts for a sampled covered transaction. Cause The condition appears to have materialized due to the District not adhering to its federal procurement policy. Effect The District did not comply with general procurement standards required by Title 2, CFR Section 200.318(a), and the District policy. Questioned Costs There were no questioned costs identified related to the condition identified above. Context/Sampling Total population of 4 transactions were identified and 3 samples were selected haphazardly. Tested resulted in a 100% exception rate which resulted in the remaining 1 transaction from the population being selected for testing. Additional testing of the remaining 1 transaction also resulted in an exception. Repeat Finding No. Recommendation The District should ensure that all federal procurement transactions are aligned with its procurement policy. As required under the District’s procurement policy, the District should retain all procurement related documents.

Federal Agency: U.S. Department of Education Pass-Through Entity: California Department of Education Federal Program: Education Stabilization Fund Assistance Listing Number: 84.425U Compliance Requirement: Reporting Type of Finding: Significant Deficiency and Non-Compliance Criteria or Specific Requirements Per Title 2, Code of Federal Regulations, Part 200, Subpart D, Section 200.334, records and supporting documents pertinent to a Federal award must be retained for a period of three years from the date of submission of reports to the awarding agency or pass-through entity. Condition The District did not properly prepare two annual reports for the Elementary and Secondary School Emergency Relief Fund.  The District was unable to provide supporting documentation that agreed to the expenditures reported to the California Department of Education.  The District was unable to provide supporting documents that agreed to the fulltime equivalent (FTE) information reported to the California Department of Education. Cause It appears that the condition has materialized due to the District not properly entering program expenditures from their financial system into the quarterly reports for each reporting date. Effect The District has not complied with the requirements identified in Title 2, Code of Federal Regulations, Part 200, Subpart D, Section 200.334. Questioned Costs None reported. Context/Sampling Annual report required to be filed with the California Department of Education was revenues. There was no sampling involved since the population subject to testing was a single report. Repeat Finding Yes, see prior year finding 2023-004. Recommendation The District should ensure that all federal program reports are supported by adequate records. These records should be maintained for a period of three years from the date of submission of the reports to the awarding agency or pass-through entity. Corrective Action Plan and Views of Responsible Officials Moving forward, the District will ensure that all supporting documents are retained for reporting elements related to grants. Additionally, the District will add additional review procedures for any reporting items related to grants.

50000 – Equipment and Real Property Management (Material Weakness in Internal Control over Compliance, Material Noncompliance) Federal Agency: U.S. Department of Education Pass-Through Entity: California Department of Education (CDE) Program Name: Education Stabilization Fund Federal Financial Assistance Listing: 84.425U Compliance Requirement: F. Equipment and Real Property Management Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria or Specific Requirements Title 2, Code of Federal Regulations, Part 200, Subpart E, Section 200.439 requires the District to obtain written approval from the California Department of Education (CDE) prior to purchasing equipment for which the per unit costs exceeds $5,000. Condition The District expended $142,790 of ESSER III, ESSER III State Reserve Learning Loss and ESSER III State Reserve Emergency Needs funds on capital expenditures that were not preapproved by the pass-through agency, as required. The District did not have a preapproval from CDE. Cause The condition identified appears to have materialized due to oversight related to the requirements under Title 2, Code of Federal Regulations, Part 200, Subpart E, Section 200.439. Effect The District currently assumes all the risk of non-compliance with requirements stated under Title 2, Code of Federal Regulations, Part 200, Subpart E, Sections 200.439 due to the lack of preapproval from the pass-through agency, as required. Questioned Costs As a result of the condition identified above, a total of $142,790 in questioned costs were identified. Context/Sampling The condition was identified as a result of inquiry with the District’s personnel and review of ESSER III, ESSER III State Reserve Learning Loss and ESSER III State Reserve Emergency Needs expenditures and related invoices. We have reviewed the entire population which is comprised of two transactions. The District did not have a preapproval from CDE for one of the transactions tested. Repeat Finding No. Recommendation The District should ensure all equipment purchases are subject to the pre-approval process as stated in Title 2, Code of Federal Regulations, Part 200, Subpart E, Section 200.439 and implement procedures to address the deficiencies currently identified. Corrective Action Plan and Views of Responsible Official The purchase of all equipment will follow the pre-approval process stated in the Title 2, Code of Federal Regulations, Part 200, Subpart E, Section 200.439 and implement procedures to address the deficiencies currently identified.

Federal Agency: U.S. Department of Education Pass-Through Entity: California Department of Education Federal Program: Education Stabilization Fund Assistance Listing Number: 84.425U Compliance Requirement: Reporting Type of Finding: Significant Deficiency and Non-Compliance Criteria or Specific Requirements Per Title 2, Code of Federal Regulations, Part 200, Subpart D, Section 200.334, records and supporting documents pertinent to a Federal award must be retained for a period of three years from the date of submission of reports to the awarding agency or pass-through entity. Condition The District did not properly prepare two annual reports for the Elementary and Secondary School Emergency Relief Fund.  The District was unable to provide supporting documentation that agreed to the expenditures reported to the California Department of Education.  The District was unable to provide supporting documents that agreed to the fulltime equivalent (FTE) information reported to the California Department of Education. Cause It appears that the condition has materialized due to the District not properly entering program expenditures from their financial system into the quarterly reports for each reporting date. Effect The District has not complied with the requirements identified in Title 2, Code of Federal Regulations, Part 200, Subpart D, Section 200.334. Questioned Costs None reported. Context/Sampling Annual report required to be filed with the California Department of Education was revenues. There was no sampling involved since the population subject to testing was a single report. Repeat Finding Yes, see prior year finding 2023-004. Recommendation The District should ensure that all federal program reports are supported by adequate records. These records should be maintained for a period of three years from the date of submission of the reports to the awarding agency or pass-through entity. Corrective Action Plan and Views of Responsible Officials Moving forward, the District will ensure that all supporting documents are retained for reporting elements related to grants. Additionally, the District will add additional review procedures for any reporting items related to grants.

50000 – Equipment and Real Property Management (Material Weakness in Internal Control over Compliance, Material Noncompliance) Federal Agency: U.S. Department of Education Pass-Through Entity: California Department of Education (CDE) Program Name: Education Stabilization Fund Federal Financial Assistance Listing: 84.425U Compliance Requirement: F. Equipment and Real Property Management Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria or Specific Requirements Title 2, Code of Federal Regulations, Part 200, Subpart E, Section 200.439 requires the District to obtain written approval from the California Department of Education (CDE) prior to purchasing equipment for which the per unit costs exceeds $5,000. Condition The District expended $142,790 of ESSER III, ESSER III State Reserve Learning Loss and ESSER III State Reserve Emergency Needs funds on capital expenditures that were not preapproved by the pass-through agency, as required. The District did not have a preapproval from CDE. Cause The condition identified appears to have materialized due to oversight related to the requirements under Title 2, Code of Federal Regulations, Part 200, Subpart E, Section 200.439. Effect The District currently assumes all the risk of non-compliance with requirements stated under Title 2, Code of Federal Regulations, Part 200, Subpart E, Sections 200.439 due to the lack of preapproval from the pass-through agency, as required. Questioned Costs As a result of the condition identified above, a total of $142,790 in questioned costs were identified. Context/Sampling The condition was identified as a result of inquiry with the District’s personnel and review of ESSER III, ESSER III State Reserve Learning Loss and ESSER III State Reserve Emergency Needs expenditures and related invoices. We have reviewed the entire population which is comprised of two transactions. The District did not have a preapproval from CDE for one of the transactions tested. Repeat Finding No. Recommendation The District should ensure all equipment purchases are subject to the pre-approval process as stated in Title 2, Code of Federal Regulations, Part 200, Subpart E, Section 200.439 and implement procedures to address the deficiencies currently identified. Corrective Action Plan and Views of Responsible Official The purchase of all equipment will follow the pre-approval process stated in the Title 2, Code of Federal Regulations, Part 200, Subpart E, Section 200.439 and implement procedures to address the deficiencies currently identified.

Federal Agency: U.S. Department of Education Pass-Through Entity: California Department of Education Federal Program: Education Stabilization Fund Assistance Listing Number: 84.425U Compliance Requirement: Reporting Type of Finding: Significant Deficiency and Non-Compliance Criteria or Specific Requirements Per Title 2, Code of Federal Regulations, Part 200, Subpart D, Section 200.334, records and supporting documents pertinent to a Federal award must be retained for a period of three years from the date of submission of reports to the awarding agency or pass-through entity. Condition The District did not properly prepare two annual reports for the Elementary and Secondary School Emergency Relief Fund.  The District was unable to provide supporting documentation that agreed to the expenditures reported to the California Department of Education.  The District was unable to provide supporting documents that agreed to the fulltime equivalent (FTE) information reported to the California Department of Education. Cause It appears that the condition has materialized due to the District not properly entering program expenditures from their financial system into the quarterly reports for each reporting date. Effect The District has not complied with the requirements identified in Title 2, Code of Federal Regulations, Part 200, Subpart D, Section 200.334. Questioned Costs None reported. Context/Sampling Annual report required to be filed with the California Department of Education was revenues. There was no sampling involved since the population subject to testing was a single report. Repeat Finding Yes, see prior year finding 2023-004. Recommendation The District should ensure that all federal program reports are supported by adequate records. These records should be maintained for a period of three years from the date of submission of the reports to the awarding agency or pass-through entity. Corrective Action Plan and Views of Responsible Officials Moving forward, the District will ensure that all supporting documents are retained for reporting elements related to grants. Additionally, the District will add additional review procedures for any reporting items related to grants.

50000 – Equipment and Real Property Management (Material Weakness in Internal Control over Compliance, Material Noncompliance) Federal Agency: U.S. Department of Education Pass-Through Entity: California Department of Education (CDE) Program Name: Education Stabilization Fund Federal Financial Assistance Listing: 84.425U Compliance Requirement: F. Equipment and Real Property Management Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria or Specific Requirements Title 2, Code of Federal Regulations, Part 200, Subpart E, Section 200.439 requires the District to obtain written approval from the California Department of Education (CDE) prior to purchasing equipment for which the per unit costs exceeds $5,000. Condition The District expended $142,790 of ESSER III, ESSER III State Reserve Learning Loss and ESSER III State Reserve Emergency Needs funds on capital expenditures that were not preapproved by the pass-through agency, as required. The District did not have a preapproval from CDE. Cause The condition identified appears to have materialized due to oversight related to the requirements under Title 2, Code of Federal Regulations, Part 200, Subpart E, Section 200.439. Effect The District currently assumes all the risk of non-compliance with requirements stated under Title 2, Code of Federal Regulations, Part 200, Subpart E, Sections 200.439 due to the lack of preapproval from the pass-through agency, as required. Questioned Costs As a result of the condition identified above, a total of $142,790 in questioned costs were identified. Context/Sampling The condition was identified as a result of inquiry with the District’s personnel and review of ESSER III, ESSER III State Reserve Learning Loss and ESSER III State Reserve Emergency Needs expenditures and related invoices. We have reviewed the entire population which is comprised of two transactions. The District did not have a preapproval from CDE for one of the transactions tested. Repeat Finding No. Recommendation The District should ensure all equipment purchases are subject to the pre-approval process as stated in Title 2, Code of Federal Regulations, Part 200, Subpart E, Section 200.439 and implement procedures to address the deficiencies currently identified. Corrective Action Plan and Views of Responsible Official The purchase of all equipment will follow the pre-approval process stated in the Title 2, Code of Federal Regulations, Part 200, Subpart E, Section 200.439 and implement procedures to address the deficiencies currently identified.

Federal Agency: U.S. Department of Education Pass-Through Entity: California Department of Education Federal Program: Education Stabilization Fund Assistance Listing Number: 84.425U Compliance Requirement: Reporting Type of Finding: Significant Deficiency and Non-Compliance Criteria or Specific Requirements Per Title 2, Code of Federal Regulations, Part 200, Subpart D, Section 200.334, records and supporting documents pertinent to a Federal award must be retained for a period of three years from the date of submission of reports to the awarding agency or pass-through entity. Condition The District did not properly prepare two annual reports for the Elementary and Secondary School Emergency Relief Fund.  The District was unable to provide supporting documentation that agreed to the expenditures reported to the California Department of Education.  The District was unable to provide supporting documents that agreed to the fulltime equivalent (FTE) information reported to the California Department of Education. Cause It appears that the condition has materialized due to the District not properly entering program expenditures from their financial system into the quarterly reports for each reporting date. Effect The District has not complied with the requirements identified in Title 2, Code of Federal Regulations, Part 200, Subpart D, Section 200.334. Questioned Costs None reported. Context/Sampling Annual report required to be filed with the California Department of Education was revenues. There was no sampling involved since the population subject to testing was a single report. Repeat Finding Yes, see prior year finding 2023-004. Recommendation The District should ensure that all federal program reports are supported by adequate records. These records should be maintained for a period of three years from the date of submission of the reports to the awarding agency or pass-through entity. Corrective Action Plan and Views of Responsible Officials Moving forward, the District will ensure that all supporting documents are retained for reporting elements related to grants. Additionally, the District will add additional review procedures for any reporting items related to grants.

50000 – Equipment and Real Property Management (Material Weakness in Internal Control over Compliance, Material Noncompliance) Federal Agency: U.S. Department of Education Pass-Through Entity: California Department of Education (CDE) Program Name: Education Stabilization Fund Federal Financial Assistance Listing: 84.425U Compliance Requirement: F. Equipment and Real Property Management Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria or Specific Requirements Title 2, Code of Federal Regulations, Part 200, Subpart E, Section 200.439 requires the District to obtain written approval from the California Department of Education (CDE) prior to purchasing equipment for which the per unit costs exceeds $5,000. Condition The District expended $142,790 of ESSER III, ESSER III State Reserve Learning Loss and ESSER III State Reserve Emergency Needs funds on capital expenditures that were not preapproved by the pass-through agency, as required. The District did not have a preapproval from CDE. Cause The condition identified appears to have materialized due to oversight related to the requirements under Title 2, Code of Federal Regulations, Part 200, Subpart E, Section 200.439. Effect The District currently assumes all the risk of non-compliance with requirements stated under Title 2, Code of Federal Regulations, Part 200, Subpart E, Sections 200.439 due to the lack of preapproval from the pass-through agency, as required. Questioned Costs As a result of the condition identified above, a total of $142,790 in questioned costs were identified. Context/Sampling The condition was identified as a result of inquiry with the District’s personnel and review of ESSER III, ESSER III State Reserve Learning Loss and ESSER III State Reserve Emergency Needs expenditures and related invoices. We have reviewed the entire population which is comprised of two transactions. The District did not have a preapproval from CDE for one of the transactions tested. Repeat Finding No. Recommendation The District should ensure all equipment purchases are subject to the pre-approval process as stated in Title 2, Code of Federal Regulations, Part 200, Subpart E, Section 200.439 and implement procedures to address the deficiencies currently identified. Corrective Action Plan and Views of Responsible Official The purchase of all equipment will follow the pre-approval process stated in the Title 2, Code of Federal Regulations, Part 200, Subpart E, Section 200.439 and implement procedures to address the deficiencies currently identified.

Federal Programs Affected Federal Agency: U.S. Department of Agriculture Pass‐Through Entity: California Department of Education Federal Program: Child Nutrition Cluster ALN: 10.555, 10.553 Compliance Requirement: Procurement, Suspension and Debarment Type of Finding: Significant Deficiency and Non‐Compliance Criteria or Specific Requirements Title 2, Code of Federal Regulations (CFR), Part 200, Subpart D, Section 200.318(a) requires recipients and subrecipients of Federal awards to maintain and use documented procurement procedures that conform to standards identified in Title 2, CFR, Part 200, Subpart D, Section 200.318. This includes the retention of all procurement related documents in connection with federal awards. Condition The District was unable to provide procurement documents, including copies of bid documents and contracts for a sampled covered transaction. Questioned Costs There were no questioned costs identified related to the condition identified above. Context The condition was identified during the course of our review of supporting documents and our inquiry with District’s personnel. Effect The did not comply with general procurement standards required by Title 2, CFR Section 200.318(a) and the District board policy number 3230. Cause The condition appears to have materialized due to the District not adhering to its federal procurement policy. Repeat Finding Yes. See prior year finding 2022‐001. Recommendation The District should ensure that all federal procurement transactions are aligned with its board policy number 3230. As required under the District’s procurement policy, the District should retain all procurement related documents. Corrective Action Plan and Views of Responsible Officials The finding originally identified in the 2021‐2022 audit was in relation to projects that carried into the 2022‐2023 school year. All current and future projects have been implemented using proper procedures including bidding and project checklists

Federal Agency: U.S. Department of Agriculture Pass‐Through Entity: California Department of Education Federal Program: Child Nutrition Cluster Assistance Listing Number: 10.555, 10.553 Compliance Requirement: Eligibility Type of Finding: Significant Deficiency and Non‐Compliance Criteria or specific requirement The District is reimbursed for meals served to students eligible for free or reduced pricing. The reimbursement rates depend on how the student is classified. (7 CFR sections 245.2, 245.3, and 245.6; section 9(b)(1) of the NSLA (42 USC 1758 (b)(1)); sections 3(a)(6) and 4(e) of the CNA (42 USC 1772(a)(6) and 1773(e))). A child’s eligibility for free or reduced price meals under a Child Nutrition Cluster program may be established by the submission of an annual application. Children belonging to households meeting income eligibility requirements may receive meals at no charge or at reduced price. Children who have been determined ineligible for free or reduced price school meals pay the full price, set by the District, for their meals. (7 CFR sections 225.15(f), 245.1(a), and 245.3(c); definition of “subsidized lunch (paid lunch)” at 7 CFR section 210.2). Condition Single student’s eligibility was misclassified as being reduced, but the student’s eligibility should have been classified as pay since the student did not provide supporting income documentation during the District's verification process at Home Street Middle School. Questioned Costs Questioned costs associated with this condition was identified as $900, which represents the excess reimbursement received by the District that is associated with the unsupported audit samples. Likely questioned costs are $4,502. Context We selected a sample of 27 and a single exception was identified. Effect The monthly meal claims were inaccurately prepared. Cause The District lacked sufficient procedures for maintaining income verification forms or direct certification information, leading to a deficiency in ensuring that students meeting the income eligibility requirements were retained for audit support. Repeat Finding No. Recommendation Personnel responsible for compliance in this area should ensure that all student records are updated timely based on the review of income eligibility forms or direct certification information. Corrective Action Plan and Views of Responsible Officials The District continues to be diligent in collecting Free‐ Reduced applications. The reporting staff responsible for processing the applications is aware of the miscalculation and has been trained to be efficient and report accurately.

Criteria or Specific Requirements Per Title 2, Code of Federal Regulations, Part 200, Subpart D, Section 200.333, financial records and supporting documents pertinent to a Federal award must be retained for a period of three years from the date of submission of expenditure reports to the awarding agency or passthrough entity. Condition The District was unable to provide financial records or supporting documents for twenty-eight out of sixty expenditures charged to ESSER and GEER resources. Questioned Costs The condition identified above resulted in known questioned costs of $76,440 and likely questioned costs of $65,937. Context The condition was identified by reviewing 60 sample transactions. Our review resulted in 28 transactions where the District was unable to provide supporting documents which resulted in a known quested costs of $76,440. The likely questioned costs $65,937 were attributed to fringe benefits that were associated with employee salaries charged to the program. Effect The District has not complied with the requirements identified in Title 2, Code of Federal Regulations, Part 200.333. Cause The identified condition appears to have materialized due to insufficient procedures related to the retention of financial records. Repeat Finding No. Recommendation The District should ensure that all federal expenditures are supported by financial reports. These records should be maintained for a period of three years from the date the expenditure is incurred. Corrective Action Plan and Views of Responsible Officials The District will maintain financial records used to report federal dollars for a minimum of 3 years.

Federal Agency: U.S. Department of Education Pass‐Through Entity: California Department of Education Federal Program: Education Stabilization Fund Assistance Listing Number: 84.425 Compliance Requirement: Reporting Type of Finding: Significant Deficiency and Non‐Compliance Criteria or Specific Requirements Per Title 2, Code of Federal Regulations, Part 200, Subpart D, Section 200.334, records and supporting documents pertinent to a Federal award must be retained for a period of three years from the date of submission of reports to the awarding agency or pass‐through entity. Condition The District did not properly prepare two annual reports for the Elementary and Secondary School Emergency Relief Fund. The District was unable to provide supporting documentation that agreed to the expenditures reported to the California Department of Education. The District was unable to provide supporting documents that agreed to the full‐time equivalent (FTE) information reported to the California Department of Education. Questioned Costs There are no questioned costs associated with the condition identified. Context The condition was identified through inquiry with District personnel and through review of available supporting documentation. Effect The District has not complied with the requirements identified in Title 2, Code of Federal Regulations, Part 200, Subpart D, Section 200.334. Cause It appears that the condition has materialized due to the District not properly entering program expenditures from their financial system into the quarterly reports for each reporting date. Repeat Finding No. Recommendation The District should ensure that all federal program reports are supported by adequate records. These records should be maintained for a period of three years from the date of submission of the reports to the awarding agency or pass‐through entity. Corrective Action Plan and Views of Responsible Officials The District CBO in place for the majority of the 2022‐2023 school year did not follow the district guidelines and recommendations regarding the expenditure of the one‐time federal funds. There is a new CBO in place and more familiar with federal requirements and proper documentation.

Criteria or Specific Requirements Per Title 2, Code of Federal Regulations, Part 200, Subpart D, Section 200.333, financial records and supporting documents pertinent to a Federal award must be retained for a period of three years from the date of submission of expenditure reports to the awarding agency or passthrough entity. Condition The District was unable to provide financial records or supporting documents that agreed to the expenditure information and full-time equivalent positions required by the ESSER annual report. In addition, the District was unable to provide financial records or supporting documents that agreed to the expenditure information required by the Expanded Learning Opportunities (ELO) Grant: GEER II quarterly report for the period of April 1, 2023 to June 30, 2023. Questioned Costs There were no questioned costs associated with the identified condition. Context The condition was identified by reviewing 4 out of 8 quarterly reports to the State and 1 out of 2 annual reports submitted to the State. Based on our review of the sampled reports, we have determined that all sampled reports did not have adequate support. Effect The District has not complied with the requirements identified in Title 2, Code of Federal Regulations, Part 200.333. Cause The identified condition appears to have materialized due to insufficient procedures related to the retention of financial records. Repeat Finding No. Recommendation The District should ensure that all federal expenditures and full-time equivalent positions are reported accurately on the ESSER and GEER annual and quarterly reports, and that supporting documentation is maintained to support the amounts reported. Corrective Action Plan and Views of Responsible Officials The District will maintain supporting documentation for the use of federal funds.

Criteria or Specific Requirements Per Title 2, Code of Federal Regulations, Part 200, Subpart D, Section 200.333, financial records and supporting documents pertinent to a Federal award must be retained for a period of three years from the date of submission of expenditure reports to the awarding agency or passthrough entity. Condition The District was unable to provide financial records or supporting documents for all expenditures charged to Special Education resources. Questioned Costs The condition identified above resulted in known questioned costs of $50,735 and likely questioned costs of $35,099. Context The condition was identified by reviewing all 6 expenditures charged to the program which included 2 non-payroll expenditures, 1 transfer of expenditures, and 3 employee salaries. We have determined that the District was unable to provide support for all transactions and noted a known questioned costs of $50,735. The likely questioned costs $35,099 were attributed to fringe benefits that were associated with employee salaries charged to the program. Effect The District has not complied with the requirements identified in Title 2, Code of Federal Regulations, Part 200.333. Cause The identified condition appears to have materialized due to insufficient procedures related to the retention of financial records. Repeat Finding No. Recommendation The District should ensure that all federal expenditures are supported by financial reports. These records should be maintained for a period of three years from the date the expenditure is incurred. Corrective Action Plan and Views of Responsible Officials The District will maintain supporting documentation for the use of federal funds.

Federal Programs Affected Federal Agency: U.S. Department of Agriculture Pass‐Through Entity: California Department of Education Federal Program: Child Nutrition Cluster ALN: 10.555, 10.553 Compliance Requirement: Procurement, Suspension and Debarment Type of Finding: Significant Deficiency and Non‐Compliance Criteria or Specific Requirements Title 2, Code of Federal Regulations (CFR), Part 200, Subpart D, Section 200.318(a) requires recipients and subrecipients of Federal awards to maintain and use documented procurement procedures that conform to standards identified in Title 2, CFR, Part 200, Subpart D, Section 200.318. This includes the retention of all procurement related documents in connection with federal awards. Condition The District was unable to provide procurement documents, including copies of bid documents and contracts for a sampled covered transaction. Questioned Costs There were no questioned costs identified related to the condition identified above. Context The condition was identified during the course of our review of supporting documents and our inquiry with District’s personnel. Effect The did not comply with general procurement standards required by Title 2, CFR Section 200.318(a) and the District board policy number 3230. Cause The condition appears to have materialized due to the District not adhering to its federal procurement policy. Repeat Finding Yes. See prior year finding 2022‐001. Recommendation The District should ensure that all federal procurement transactions are aligned with its board policy number 3230. As required under the District’s procurement policy, the District should retain all procurement related documents. Corrective Action Plan and Views of Responsible Officials The finding originally identified in the 2021‐2022 audit was in relation to projects that carried into the 2022‐2023 school year. All current and future projects have been implemented using proper procedures including bidding and project checklists

Federal Agency: U.S. Department of Agriculture Pass‐Through Entity: California Department of Education Federal Program: Child Nutrition Cluster Assistance Listing Number: 10.555, 10.553 Compliance Requirement: Eligibility Type of Finding: Significant Deficiency and Non‐Compliance Criteria or specific requirement The District is reimbursed for meals served to students eligible for free or reduced pricing. The reimbursement rates depend on how the student is classified. (7 CFR sections 245.2, 245.3, and 245.6; section 9(b)(1) of the NSLA (42 USC 1758 (b)(1)); sections 3(a)(6) and 4(e) of the CNA (42 USC 1772(a)(6) and 1773(e))). A child’s eligibility for free or reduced price meals under a Child Nutrition Cluster program may be established by the submission of an annual application. Children belonging to households meeting income eligibility requirements may receive meals at no charge or at reduced price. Children who have been determined ineligible for free or reduced price school meals pay the full price, set by the District, for their meals. (7 CFR sections 225.15(f), 245.1(a), and 245.3(c); definition of “subsidized lunch (paid lunch)” at 7 CFR section 210.2). Condition Single student’s eligibility was misclassified as being reduced, but the student’s eligibility should have been classified as pay since the student did not provide supporting income documentation during the District's verification process at Home Street Middle School. Questioned Costs Questioned costs associated with this condition was identified as $900, which represents the excess reimbursement received by the District that is associated with the unsupported audit samples. Likely questioned costs are $4,502. Context We selected a sample of 27 and a single exception was identified. Effect The monthly meal claims were inaccurately prepared. Cause The District lacked sufficient procedures for maintaining income verification forms or direct certification information, leading to a deficiency in ensuring that students meeting the income eligibility requirements were retained for audit support. Repeat Finding No. Recommendation Personnel responsible for compliance in this area should ensure that all student records are updated timely based on the review of income eligibility forms or direct certification information. Corrective Action Plan and Views of Responsible Officials The District continues to be diligent in collecting Free‐ Reduced applications. The reporting staff responsible for processing the applications is aware of the miscalculation and has been trained to be efficient and report accurately.

Criteria or Specific Requirements Per Title 2, Code of Federal Regulations, Part 200, Subpart D, Section 200.333, financial records and supporting documents pertinent to a Federal award must be retained for a period of three years from the date of submission of expenditure reports to the awarding agency or passthrough entity. Condition The District was unable to provide financial records or supporting documents for twenty-eight out of sixty expenditures charged to ESSER and GEER resources. Questioned Costs The condition identified above resulted in known questioned costs of $76,440 and likely questioned costs of $65,937. Context The condition was identified by reviewing 60 sample transactions. Our review resulted in 28 transactions where the District was unable to provide supporting documents which resulted in a known quested costs of $76,440. The likely questioned costs $65,937 were attributed to fringe benefits that were associated with employee salaries charged to the program. Effect The District has not complied with the requirements identified in Title 2, Code of Federal Regulations, Part 200.333. Cause The identified condition appears to have materialized due to insufficient procedures related to the retention of financial records. Repeat Finding No. Recommendation The District should ensure that all federal expenditures are supported by financial reports. These records should be maintained for a period of three years from the date the expenditure is incurred. Corrective Action Plan and Views of Responsible Officials The District will maintain financial records used to report federal dollars for a minimum of 3 years.

Federal Agency: U.S. Department of Education Pass‐Through Entity: California Department of Education Federal Program: Education Stabilization Fund Assistance Listing Number: 84.425 Compliance Requirement: Reporting Type of Finding: Significant Deficiency and Non‐Compliance Criteria or Specific Requirements Per Title 2, Code of Federal Regulations, Part 200, Subpart D, Section 200.334, records and supporting documents pertinent to a Federal award must be retained for a period of three years from the date of submission of reports to the awarding agency or pass‐through entity. Condition The District did not properly prepare two annual reports for the Elementary and Secondary School Emergency Relief Fund. The District was unable to provide supporting documentation that agreed to the expenditures reported to the California Department of Education. The District was unable to provide supporting documents that agreed to the full‐time equivalent (FTE) information reported to the California Department of Education. Questioned Costs There are no questioned costs associated with the condition identified. Context The condition was identified through inquiry with District personnel and through review of available supporting documentation. Effect The District has not complied with the requirements identified in Title 2, Code of Federal Regulations, Part 200, Subpart D, Section 200.334. Cause It appears that the condition has materialized due to the District not properly entering program expenditures from their financial system into the quarterly reports for each reporting date. Repeat Finding No. Recommendation The District should ensure that all federal program reports are supported by adequate records. These records should be maintained for a period of three years from the date of submission of the reports to the awarding agency or pass‐through entity. Corrective Action Plan and Views of Responsible Officials The District CBO in place for the majority of the 2022‐2023 school year did not follow the district guidelines and recommendations regarding the expenditure of the one‐time federal funds. There is a new CBO in place and more familiar with federal requirements and proper documentation.

Criteria or Specific Requirements Per Title 2, Code of Federal Regulations, Part 200, Subpart D, Section 200.333, financial records and supporting documents pertinent to a Federal award must be retained for a period of three years from the date of submission of expenditure reports to the awarding agency or passthrough entity. Condition The District was unable to provide financial records or supporting documents that agreed to the expenditure information and full-time equivalent positions required by the ESSER annual report. In addition, the District was unable to provide financial records or supporting documents that agreed to the expenditure information required by the Expanded Learning Opportunities (ELO) Grant: GEER II quarterly report for the period of April 1, 2023 to June 30, 2023. Questioned Costs There were no questioned costs associated with the identified condition. Context The condition was identified by reviewing 4 out of 8 quarterly reports to the State and 1 out of 2 annual reports submitted to the State. Based on our review of the sampled reports, we have determined that all sampled reports did not have adequate support. Effect The District has not complied with the requirements identified in Title 2, Code of Federal Regulations, Part 200.333. Cause The identified condition appears to have materialized due to insufficient procedures related to the retention of financial records. Repeat Finding No. Recommendation The District should ensure that all federal expenditures and full-time equivalent positions are reported accurately on the ESSER and GEER annual and quarterly reports, and that supporting documentation is maintained to support the amounts reported. Corrective Action Plan and Views of Responsible Officials The District will maintain supporting documentation for the use of federal funds.

Criteria or Specific Requirements Per Title 2, Code of Federal Regulations, Part 200, Subpart D, Section 200.333, financial records and supporting documents pertinent to a Federal award must be retained for a period of three years from the date of submission of expenditure reports to the awarding agency or passthrough entity. Condition The District was unable to provide financial records or supporting documents for all expenditures charged to Special Education resources. Questioned Costs The condition identified above resulted in known questioned costs of $50,735 and likely questioned costs of $35,099. Context The condition was identified by reviewing all 6 expenditures charged to the program which included 2 non-payroll expenditures, 1 transfer of expenditures, and 3 employee salaries. We have determined that the District was unable to provide support for all transactions and noted a known questioned costs of $50,735. The likely questioned costs $35,099 were attributed to fringe benefits that were associated with employee salaries charged to the program. Effect The District has not complied with the requirements identified in Title 2, Code of Federal Regulations, Part 200.333. Cause The identified condition appears to have materialized due to insufficient procedures related to the retention of financial records. Repeat Finding No. Recommendation The District should ensure that all federal expenditures are supported by financial reports. These records should be maintained for a period of three years from the date the expenditure is incurred. Corrective Action Plan and Views of Responsible Officials The District will maintain supporting documentation for the use of federal funds.

Federal Programs Affected Federal Agency: U.S. Department of Agriculture Pass‐Through Entity: California Department of Education Federal Program: Child Nutrition Cluster ALN: 10.555, 10.553 Compliance Requirement: Procurement, Suspension and Debarment Type of Finding: Significant Deficiency and Non‐Compliance Criteria or Specific Requirements Title 2, Code of Federal Regulations (CFR), Part 200, Subpart D, Section 200.318(a) requires recipients and subrecipients of Federal awards to maintain and use documented procurement procedures that conform to standards identified in Title 2, CFR, Part 200, Subpart D, Section 200.318. This includes the retention of all procurement related documents in connection with federal awards. Condition The District was unable to provide procurement documents, including copies of bid documents and contracts for a sampled covered transaction. Questioned Costs There were no questioned costs identified related to the condition identified above. Context The condition was identified during the course of our review of supporting documents and our inquiry with District’s personnel. Effect The did not comply with general procurement standards required by Title 2, CFR Section 200.318(a) and the District board policy number 3230. Cause The condition appears to have materialized due to the District not adhering to its federal procurement policy. Repeat Finding Yes. See prior year finding 2022‐001. Recommendation The District should ensure that all federal procurement transactions are aligned with its board policy number 3230. As required under the District’s procurement policy, the District should retain all procurement related documents. Corrective Action Plan and Views of Responsible Officials The finding originally identified in the 2021‐2022 audit was in relation to projects that carried into the 2022‐2023 school year. All current and future projects have been implemented using proper procedures including bidding and project checklists

Federal Agency: U.S. Department of Agriculture Pass‐Through Entity: California Department of Education Federal Program: Child Nutrition Cluster Assistance Listing Number: 10.555, 10.553 Compliance Requirement: Eligibility Type of Finding: Significant Deficiency and Non‐Compliance Criteria or specific requirement The District is reimbursed for meals served to students eligible for free or reduced pricing. The reimbursement rates depend on how the student is classified. (7 CFR sections 245.2, 245.3, and 245.6; section 9(b)(1) of the NSLA (42 USC 1758 (b)(1)); sections 3(a)(6) and 4(e) of the CNA (42 USC 1772(a)(6) and 1773(e))). A child’s eligibility for free or reduced price meals under a Child Nutrition Cluster program may be established by the submission of an annual application. Children belonging to households meeting income eligibility requirements may receive meals at no charge or at reduced price. Children who have been determined ineligible for free or reduced price school meals pay the full price, set by the District, for their meals. (7 CFR sections 225.15(f), 245.1(a), and 245.3(c); definition of “subsidized lunch (paid lunch)” at 7 CFR section 210.2). Condition Single student’s eligibility was misclassified as being reduced, but the student’s eligibility should have been classified as pay since the student did not provide supporting income documentation during the District's verification process at Home Street Middle School. Questioned Costs Questioned costs associated with this condition was identified as $900, which represents the excess reimbursement received by the District that is associated with the unsupported audit samples. Likely questioned costs are $4,502. Context We selected a sample of 27 and a single exception was identified. Effect The monthly meal claims were inaccurately prepared. Cause The District lacked sufficient procedures for maintaining income verification forms or direct certification information, leading to a deficiency in ensuring that students meeting the income eligibility requirements were retained for audit support. Repeat Finding No. Recommendation Personnel responsible for compliance in this area should ensure that all student records are updated timely based on the review of income eligibility forms or direct certification information. Corrective Action Plan and Views of Responsible Officials The District continues to be diligent in collecting Free‐ Reduced applications. The reporting staff responsible for processing the applications is aware of the miscalculation and has been trained to be efficient and report accurately.

Criteria or Specific Requirements Per Title 2, Code of Federal Regulations, Part 200, Subpart D, Section 200.333, financial records and supporting documents pertinent to a Federal award must be retained for a period of three years from the date of submission of expenditure reports to the awarding agency or passthrough entity. Condition The District was unable to provide financial records or supporting documents for twenty-eight out of sixty expenditures charged to ESSER and GEER resources. Questioned Costs The condition identified above resulted in known questioned costs of $76,440 and likely questioned costs of $65,937. Context The condition was identified by reviewing 60 sample transactions. Our review resulted in 28 transactions where the District was unable to provide supporting documents which resulted in a known quested costs of $76,440. The likely questioned costs $65,937 were attributed to fringe benefits that were associated with employee salaries charged to the program. Effect The District has not complied with the requirements identified in Title 2, Code of Federal Regulations, Part 200.333. Cause The identified condition appears to have materialized due to insufficient procedures related to the retention of financial records. Repeat Finding No. Recommendation The District should ensure that all federal expenditures are supported by financial reports. These records should be maintained for a period of three years from the date the expenditure is incurred. Corrective Action Plan and Views of Responsible Officials The District will maintain financial records used to report federal dollars for a minimum of 3 years.

Federal Agency: U.S. Department of Education Pass‐Through Entity: California Department of Education Federal Program: Education Stabilization Fund Assistance Listing Number: 84.425 Compliance Requirement: Reporting Type of Finding: Significant Deficiency and Non‐Compliance Criteria or Specific Requirements Per Title 2, Code of Federal Regulations, Part 200, Subpart D, Section 200.334, records and supporting documents pertinent to a Federal award must be retained for a period of three years from the date of submission of reports to the awarding agency or pass‐through entity. Condition The District did not properly prepare two annual reports for the Elementary and Secondary School Emergency Relief Fund. The District was unable to provide supporting documentation that agreed to the expenditures reported to the California Department of Education. The District was unable to provide supporting documents that agreed to the full‐time equivalent (FTE) information reported to the California Department of Education. Questioned Costs There are no questioned costs associated with the condition identified. Context The condition was identified through inquiry with District personnel and through review of available supporting documentation. Effect The District has not complied with the requirements identified in Title 2, Code of Federal Regulations, Part 200, Subpart D, Section 200.334. Cause It appears that the condition has materialized due to the District not properly entering program expenditures from their financial system into the quarterly reports for each reporting date. Repeat Finding No. Recommendation The District should ensure that all federal program reports are supported by adequate records. These records should be maintained for a period of three years from the date of submission of the reports to the awarding agency or pass‐through entity. Corrective Action Plan and Views of Responsible Officials The District CBO in place for the majority of the 2022‐2023 school year did not follow the district guidelines and recommendations regarding the expenditure of the one‐time federal funds. There is a new CBO in place and more familiar with federal requirements and proper documentation.

Criteria or Specific Requirements Per Title 2, Code of Federal Regulations, Part 200, Subpart D, Section 200.333, financial records and supporting documents pertinent to a Federal award must be retained for a period of three years from the date of submission of expenditure reports to the awarding agency or passthrough entity. Condition The District was unable to provide financial records or supporting documents that agreed to the expenditure information and full-time equivalent positions required by the ESSER annual report. In addition, the District was unable to provide financial records or supporting documents that agreed to the expenditure information required by the Expanded Learning Opportunities (ELO) Grant: GEER II quarterly report for the period of April 1, 2023 to June 30, 2023. Questioned Costs There were no questioned costs associated with the identified condition. Context The condition was identified by reviewing 4 out of 8 quarterly reports to the State and 1 out of 2 annual reports submitted to the State. Based on our review of the sampled reports, we have determined that all sampled reports did not have adequate support. Effect The District has not complied with the requirements identified in Title 2, Code of Federal Regulations, Part 200.333. Cause The identified condition appears to have materialized due to insufficient procedures related to the retention of financial records. Repeat Finding No. Recommendation The District should ensure that all federal expenditures and full-time equivalent positions are reported accurately on the ESSER and GEER annual and quarterly reports, and that supporting documentation is maintained to support the amounts reported. Corrective Action Plan and Views of Responsible Officials The District will maintain supporting documentation for the use of federal funds.

Criteria or Specific Requirements Per Title 2, Code of Federal Regulations, Part 200, Subpart D, Section 200.333, financial records and supporting documents pertinent to a Federal award must be retained for a period of three years from the date of submission of expenditure reports to the awarding agency or passthrough entity. Condition The District was unable to provide financial records or supporting documents for all expenditures charged to Special Education resources. Questioned Costs The condition identified above resulted in known questioned costs of $50,735 and likely questioned costs of $35,099. Context The condition was identified by reviewing all 6 expenditures charged to the program which included 2 non-payroll expenditures, 1 transfer of expenditures, and 3 employee salaries. We have determined that the District was unable to provide support for all transactions and noted a known questioned costs of $50,735. The likely questioned costs $35,099 were attributed to fringe benefits that were associated with employee salaries charged to the program. Effect The District has not complied with the requirements identified in Title 2, Code of Federal Regulations, Part 200.333. Cause The identified condition appears to have materialized due to insufficient procedures related to the retention of financial records. Repeat Finding No. Recommendation The District should ensure that all federal expenditures are supported by financial reports. These records should be maintained for a period of three years from the date the expenditure is incurred. Corrective Action Plan and Views of Responsible Officials The District will maintain supporting documentation for the use of federal funds.

2022-001 50000 Federal Program Affected Federal Agency: U.S. Department of Agriculture Pass-Through Entity: California Department of Education Federal Program: Child Nutrition Cluster ALN: 10.555, 10.553 Compliance Requirement: Procurement, Suspension and Debarment Type of Finding: Significant Deficiency and Non-Compliance Criteria or Specific Requirements Title 2, Code of Federal Regulations (CFR), Part 200, Subpart D, Section 200.318(a) requires recipients and subrecipients of Federal awards to maintain and use documented procurement procedures that conform to standards identified in Title 2, CFR, Part 200, Subpart D, Section 200.318. This includes the retention of all procurement related documents in connection with federal awards. Condition The District was unable to provide procurement documents, including copies of bid documents and contracts for a sampled covered transaction. Questioned Costs There were no questioned costs identified related to the condition identified above. Context The condition was identified during the course of our review of supporting documents and our inquiry with District?s personnel. Effect The did not comply with general procurement standards required by Title 2, CFR Section 200.318(a) and the District board policy number 3230. Cause The condition appears to have materialized due to the District not adhering to its federal procurement policy. Repeat Finding No. Recommendation The District should ensure that all federal procurement transactions are aligned with its board policy number 3230. As required under the District?s procurement policy, the District should retain all procurement related documents.

2022-002 50000 Federal Program Affected Federal Agency: U.S. Department of Education Pass-Through Entity: California Department of Education Federal Program: Education Stabilization Fund ALN: 84.425C, 84.425D, 84.425U Compliance Requirement: Special Tests and Provisions Type of Finding: Significant Deficiency and Non-Compliance Criteria or Specific Requirements As required by Title 2, Subtitle A, Chapter II, Part 200, Appendix II to Part 200, Section (D), all prime construction contracts in excess of $2,000 awarded by non-federal entities must require contractors to pay rates that are not less than the prevailing wages specified in a wage determination made by the Secretary of Labor (Davis-Bacon Act). To comply with this requirement, contractors or subcontractors are required to submit weekly copies of the payroll records and statements of compliance to the nonfederal entity. Condition The District does not have a procedure in place to ensure compliance with the prevailing wage requirement (Davis-Bacon Act). As a result, the District was unable to provide supporting documents. Questioned Costs There were no questioned costs identified related to the condition identified above. Context The condition was identified during the course of our review of supporting documents and our inquiry with District?s personnel. Effect Since the District does not have a procedure in place to ensure compliance with the prevailing wage requirement (Davis-Bacon Act), the District has a higher risk of non-compliance with this requirement. Additionally the District was unable to demonstrate it?s compliance with the prevailing wage requirement. Cause The condition appears to be attributed to the District?s lack of procedures that are in place to ensure compliance. Repeat Finding No. Recommendation The District should adopt and implement procedures that are aligned with requirements outlined in Title 2, Subtitle A, Chapter II, Part 200, Appendix II to Part 200, Section (D). Failure to adopt and implement these procedures will increase the likelihood of the District?s noncompliance with this requirement.

2022-001 50000 Federal Program Affected Federal Agency: U.S. Department of Agriculture Pass-Through Entity: California Department of Education Federal Program: Child Nutrition Cluster ALN: 10.555, 10.553 Compliance Requirement: Procurement, Suspension and Debarment Type of Finding: Significant Deficiency and Non-Compliance Criteria or Specific Requirements Title 2, Code of Federal Regulations (CFR), Part 200, Subpart D, Section 200.318(a) requires recipients and subrecipients of Federal awards to maintain and use documented procurement procedures that conform to standards identified in Title 2, CFR, Part 200, Subpart D, Section 200.318. This includes the retention of all procurement related documents in connection with federal awards. Condition The District was unable to provide procurement documents, including copies of bid documents and contracts for a sampled covered transaction. Questioned Costs There were no questioned costs identified related to the condition identified above. Context The condition was identified during the course of our review of supporting documents and our inquiry with District?s personnel. Effect The did not comply with general procurement standards required by Title 2, CFR Section 200.318(a) and the District board policy number 3230. Cause The condition appears to have materialized due to the District not adhering to its federal procurement policy. Repeat Finding No. Recommendation The District should ensure that all federal procurement transactions are aligned with its board policy number 3230. As required under the District?s procurement policy, the District should retain all procurement related documents.

2022-002 50000 Federal Program Affected Federal Agency: U.S. Department of Education Pass-Through Entity: California Department of Education Federal Program: Education Stabilization Fund ALN: 84.425C, 84.425D, 84.425U Compliance Requirement: Special Tests and Provisions Type of Finding: Significant Deficiency and Non-Compliance Criteria or Specific Requirements As required by Title 2, Subtitle A, Chapter II, Part 200, Appendix II to Part 200, Section (D), all prime construction contracts in excess of $2,000 awarded by non-federal entities must require contractors to pay rates that are not less than the prevailing wages specified in a wage determination made by the Secretary of Labor (Davis-Bacon Act). To comply with this requirement, contractors or subcontractors are required to submit weekly copies of the payroll records and statements of compliance to the nonfederal entity. Condition The District does not have a procedure in place to ensure compliance with the prevailing wage requirement (Davis-Bacon Act). As a result, the District was unable to provide supporting documents. Questioned Costs There were no questioned costs identified related to the condition identified above. Context The condition was identified during the course of our review of supporting documents and our inquiry with District?s personnel. Effect Since the District does not have a procedure in place to ensure compliance with the prevailing wage requirement (Davis-Bacon Act), the District has a higher risk of non-compliance with this requirement. Additionally the District was unable to demonstrate it?s compliance with the prevailing wage requirement. Cause The condition appears to be attributed to the District?s lack of procedures that are in place to ensure compliance. Repeat Finding No. Recommendation The District should adopt and implement procedures that are aligned with requirements outlined in Title 2, Subtitle A, Chapter II, Part 200, Appendix II to Part 200, Section (D). Failure to adopt and implement these procedures will increase the likelihood of the District?s noncompliance with this requirement.

2022-001 50000 Federal Program Affected Federal Agency: U.S. Department of Agriculture Pass-Through Entity: California Department of Education Federal Program: Child Nutrition Cluster ALN: 10.555, 10.553 Compliance Requirement: Procurement, Suspension and Debarment Type of Finding: Significant Deficiency and Non-Compliance Criteria or Specific Requirements Title 2, Code of Federal Regulations (CFR), Part 200, Subpart D, Section 200.318(a) requires recipients and subrecipients of Federal awards to maintain and use documented procurement procedures that conform to standards identified in Title 2, CFR, Part 200, Subpart D, Section 200.318. This includes the retention of all procurement related documents in connection with federal awards. Condition The District was unable to provide procurement documents, including copies of bid documents and contracts for a sampled covered transaction. Questioned Costs There were no questioned costs identified related to the condition identified above. Context The condition was identified during the course of our review of supporting documents and our inquiry with District?s personnel. Effect The did not comply with general procurement standards required by Title 2, CFR Section 200.318(a) and the District board policy number 3230. Cause The condition appears to have materialized due to the District not adhering to its federal procurement policy. Repeat Finding No. Recommendation The District should ensure that all federal procurement transactions are aligned with its board policy number 3230. As required under the District?s procurement policy, the District should retain all procurement related documents.

2022-002 50000 Federal Program Affected Federal Agency: U.S. Department of Education Pass-Through Entity: California Department of Education Federal Program: Education Stabilization Fund ALN: 84.425C, 84.425D, 84.425U Compliance Requirement: Special Tests and Provisions Type of Finding: Significant Deficiency and Non-Compliance Criteria or Specific Requirements As required by Title 2, Subtitle A, Chapter II, Part 200, Appendix II to Part 200, Section (D), all prime construction contracts in excess of $2,000 awarded by non-federal entities must require contractors to pay rates that are not less than the prevailing wages specified in a wage determination made by the Secretary of Labor (Davis-Bacon Act). To comply with this requirement, contractors or subcontractors are required to submit weekly copies of the payroll records and statements of compliance to the nonfederal entity. Condition The District does not have a procedure in place to ensure compliance with the prevailing wage requirement (Davis-Bacon Act). As a result, the District was unable to provide supporting documents. Questioned Costs There were no questioned costs identified related to the condition identified above. Context The condition was identified during the course of our review of supporting documents and our inquiry with District?s personnel. Effect Since the District does not have a procedure in place to ensure compliance with the prevailing wage requirement (Davis-Bacon Act), the District has a higher risk of non-compliance with this requirement. Additionally the District was unable to demonstrate it?s compliance with the prevailing wage requirement. Cause The condition appears to be attributed to the District?s lack of procedures that are in place to ensure compliance. Repeat Finding No. Recommendation The District should adopt and implement procedures that are aligned with requirements outlined in Title 2, Subtitle A, Chapter II, Part 200, Appendix II to Part 200, Section (D). Failure to adopt and implement these procedures will increase the likelihood of the District?s noncompliance with this requirement.

2022-001 50000 Federal Program Affected Federal Agency: U.S. Department of Agriculture Pass-Through Entity: California Department of Education Federal Program: Child Nutrition Cluster ALN: 10.555, 10.553 Compliance Requirement: Procurement, Suspension and Debarment Type of Finding: Significant Deficiency and Non-Compliance Criteria or Specific Requirements Title 2, Code of Federal Regulations (CFR), Part 200, Subpart D, Section 200.318(a) requires recipients and subrecipients of Federal awards to maintain and use documented procurement procedures that conform to standards identified in Title 2, CFR, Part 200, Subpart D, Section 200.318. This includes the retention of all procurement related documents in connection with federal awards. Condition The District was unable to provide procurement documents, including copies of bid documents and contracts for a sampled covered transaction. Questioned Costs There were no questioned costs identified related to the condition identified above. Context The condition was identified during the course of our review of supporting documents and our inquiry with District?s personnel. Effect The did not comply with general procurement standards required by Title 2, CFR Section 200.318(a) and the District board policy number 3230. Cause The condition appears to have materialized due to the District not adhering to its federal procurement policy. Repeat Finding No. Recommendation The District should ensure that all federal procurement transactions are aligned with its board policy number 3230. As required under the District?s procurement policy, the District should retain all procurement related documents.

2022-002 50000 Federal Program Affected Federal Agency: U.S. Department of Education Pass-Through Entity: California Department of Education Federal Program: Education Stabilization Fund ALN: 84.425C, 84.425D, 84.425U Compliance Requirement: Special Tests and Provisions Type of Finding: Significant Deficiency and Non-Compliance Criteria or Specific Requirements As required by Title 2, Subtitle A, Chapter II, Part 200, Appendix II to Part 200, Section (D), all prime construction contracts in excess of $2,000 awarded by non-federal entities must require contractors to pay rates that are not less than the prevailing wages specified in a wage determination made by the Secretary of Labor (Davis-Bacon Act). To comply with this requirement, contractors or subcontractors are required to submit weekly copies of the payroll records and statements of compliance to the nonfederal entity. Condition The District does not have a procedure in place to ensure compliance with the prevailing wage requirement (Davis-Bacon Act). As a result, the District was unable to provide supporting documents. Questioned Costs There were no questioned costs identified related to the condition identified above. Context The condition was identified during the course of our review of supporting documents and our inquiry with District?s personnel. Effect Since the District does not have a procedure in place to ensure compliance with the prevailing wage requirement (Davis-Bacon Act), the District has a higher risk of non-compliance with this requirement. Additionally the District was unable to demonstrate it?s compliance with the prevailing wage requirement. Cause The condition appears to be attributed to the District?s lack of procedures that are in place to ensure compliance. Repeat Finding No. Recommendation The District should adopt and implement procedures that are aligned with requirements outlined in Title 2, Subtitle A, Chapter II, Part 200, Appendix II to Part 200, Section (D). Failure to adopt and implement these procedures will increase the likelihood of the District?s noncompliance with this requirement.