Monrovia Unified School District

This section identifies the audit findings required to be reported by the Uniform Guidance, Section 200.516 (e.g.,significant deficiencies, material weaknesses, and instances of noncompliance, including questioned costs).FINDING 2021-002: DIRECT COST ALLOCATION (50000)Program Identification:Federal Agency: U.S. Department of AgriculturePass-through Entity: California Department of EducationProgram Names: Child and Adult Care Food Program (AL No. 10.558)Child Nutrition Cluster:National School Lunch Program (AL No. 10.553, 10.555)Criteria: The District does not charge expenditures or payroll directly to the Child and Adult Care Food Program(CACFP), but instead utilizes a direct cost vending agreement. All costs are coded to National School LunchProgram (NSLP) and then CACFP is charged for its cost. The reimbursement rate to CACFP is determined annuallybased on cost experience. Current year rate was based on fiscal year 2020-21 actual costs.Condition: Although the use of a vending agreement is allowable, the District did not allocate the cost of theprogram properly.Effect/Questioned Costs: The cost split between CACFP and NSLP was incorrectly allocated. The amount of thevariance was $106,775, which was overcharged to CACFP.Cause: The District did not use consistent data while doing the calculation for the allocation.Recommendation: We recommend that the District review the cost allocations and insure that all inputs tie back toadequate supporting data.District?s Response: Based upon the recommendation of an auditor from the California Department of EducationNutrition Services Division, this year the District began using a new cost allocation method for Food Serviceprogram expenditures. This method is simpler and more accurate than the method previously used by the District.This new cost allocation method was approved by our audit firm of Nigro & Nigro. However, when performing thecalculation this year incorrect meal counts and meal prices were used. This resulted in an inaccurate cost allocationbetween Food Services programs. The incorrect 2020-21 cost allocation has been corrected via a journal entry in2021-22. The cost allocation calculation will be checked more thoroughly in 2021-22 and future years.

FINDING 2021-003: Coronavirus Relief Fund - Period of Performance (50000)Program Identification:Federal Agency: U.S. Department of TreasuryPass-through Entity: California Department of EducationProgram Names: Coronavirus Relief Funds (CRF): Learning Loss Mitigation (AL No. 21.019)Criteria: Coronavirus Relief Fund (CRF) is to provide payments to cover (1) necessary expenditures incurred to thepublic health emergency with respect to the Coronavirus Disease 2019 (COVID-19); (2) costs that were notaccounted for in the governments most recently approved budget as of March 27, 2020; and (3) costs that wereincurred during the period that begins on March 1, 2020; and ends on December 31, 2021 (CDE as pass throughentity approved through May 31, 2021). Federal Register Vol. 86, No.10/Friday, January 15, 2021/Notices.Condition: The District utilized CRF to purchase a three-year license for the years 2020-21, 2021-22, and 2022-23.This exceeds the period that the funding is allowable for expenditures in connection with the pandemic.Context: The purchase occurred in one of a sample population of 16 expenditures tested. Two of the three years inthe contract fall outside of the period of performance. The finding was isolated and not representative of thepopulation.Cause: A purchase for three years was made using the CRF.Questioned Cost: The total contract cost is $92,420. Prorated for 2 years the cost is $61,614 which should not useCRF as the funding source.Recommendation: The cost of the 2021-22 and 2022-23 contract years should use other allowable funding. Werecommend the District return the funding or reallocate this expenditure to an alternate allowable resource.Views of Responsible Officials: The entire contract cost of $92,420 was reallocated retroactively in 2021-22 fromCoronavirus Relief Funds (CRF) to the Expanded Learning Opportunities Grant (ELO), which has a September 30,2024 expenditure deadline. Offsetting expenditures of $92,420 incurred in March and April of 2021 for thereopening of in-person instruction were reallocated retroactively from ELO to CRF.

Finding 2020-001: Title I ? Compliance Requirement for Cohort Graduation Rate Not Met (30000) (50000)CFDA #84.010?Title I, U.S. Department of Education, California Department of EducationCriteria34 CFR, section 200.19(b) states, in part:High schools ? (1) Graduation rate. Consistent with paragraphs (b)(4) and (b)(5) of this section regardingreporting and determining AYP, respectively, each State must calculate a graduation rate, defined as follows,for all public high schools in the State:(i) (A) A State must calculate a ?four-year adjusted cohort graduation rate,? defined as the number ofstudents who graduate in four years with a regular high school diploma divided by the number ofstudents who form the adjusted cohort for that graduating class.(B) For those high schools that start after grade nine, the cohort must be calculated based on the earliesthigh school grade.(ii) The term ?adjusted cohort? means the students who enter grade 9 (or the earliest high school grade) andany students who transfer into the cohort in grades 9 through 12 minus any students removed from thecohort.(A) The term ?students who transfer into the cohort? means the students who enroll after the beginningof the entering cohort's first year in high school, up to and including in grade 12.(B) To remove a student from the cohort, a school or LEA must confirm in writing that the studenttransferred out, immigrated to another country, or is deceased.(1) To confirm that a student transferred out, the school or LEA must have official writtendocumentation that the student enrolled in another school or in an educational program thatculminates in the award of a regular high school diploma.(2) A student who is retained in grade, enrolls in a General Educational Development (GED)program, or leaves school for any other reason may not be counted as having transferred out forthe purpose of calculating graduation rate and must remain in the adjusted cohort.Condition: During our review of the District?s Title I program, we noted that the District did not maintain writtendocumentation supporting that a student has enrolled in another school or in an education program that culminates inthe awarding of a regular high school diploma. The District is required to maintain official written documentationsupporting that a student has enrolled in another school or in an educational program that culminates in the awardingof a regular high school diploma. A student who is retained in-grade or leaves school for any other reason may notbe counted as having transferred out for the purpose of calculating graduation rates, and must remain in the adjustedcohort.Context: The CDE uses the student-level data maintained in CALPADS to calculate the four-year adjusted cohortgraduation rate for all LEAs in the state. We selected three students who were identified in CALPADS as transferstudents who withdrew from the District. The District was unable to provide any written documentation to confirmthat two of these students transferred out of the District and emigrated to another county or enrolled in anotherschool or in an educational program that culminates in the award of a regular high school diploma.Effect/Questioned Costs: We were unable to determine whether the District implemented policies and proceduresfor documenting the removal of students from the regulatory adjusted cohort. There are no questioned costs as aresult of this finding.Cause: The District did not maintain adequate documentation to support the removal of a student from theregulatory adjusted cohort.Recommendation: We recommend that the District implement appropriate controls necessary for documenting theremoval of students from the regulatory adjusted cohort, and ensure that the supporting documentation ismaintained.Views of Responsible Officials: Our high schools have a process in place to document the communication theyhave with parents/guardians and the new school of attendance for high school students who have checked out of theDistrict and left for a high school in another state or country. When the name of the receiving high school is known,official documentation is kept from the receiving High School confirming the students enrollment, and the student isremoved from the cohort. If the District is unable to determine the name of the receiving high school, and/or isunable to receive official documentation from the receiving high school, the student will be left in the cohort as adropout.

Finding 2019-001: Procurement Policy (30000, 50000)CFDA# 84.027, 84.173 ? U.S. Department of Education, California Department of Education,Individuals with Disabilities Education Act (IDEA) Special Education ClusterCriteria: Non-Federal entities other than States, including those operating Federal programs assubrecipients of States, must follow the procurement standards set out at 2 CFR sections 200.318 through200.326. They must use their own documented procurement procedures, which reflect applicable state andlocal laws and regulations, provided that the procurements conform to applicable Federal statutes and theprocurement requirements identified in 2 CFR part 200.Condition: The District's written procurement and purchasing procedures and board policies do not reflectthe requirements identified in 2 CFR part 200.Questioned Cost: N/AContext: N/AEffect: Failure to adopt a clear written policy that conforms to applicable Federal statutes and theprocurement requirements could lead to a lack of control over procurement transactions.Cause: The District was unaware of the requirement to maintain a documented policy that conforms toapplicable Federal statutes and the procurement requirements.Recommendation: We recommend that the District update the written policy to reflect applicable state,local, and Federal statutes and the procurement requirements identified in 2 CFR part 200. In addition, it isrecommended that the District update the detailed administrative regulation or procedures manualaddressing the mandated components.Views of Responsible Officials: The District will update its written purchasing policy to incorporaterequirements identified in the Uniform Guidance.