Sierra Sands Unified School DistrictLocal Government

2019-002 50000 (Significant Deficiency) Federal Program Affected Child Nutrition Cluster CFDA: 10.553, 10.555, 10.556 Pass-Through Entity: California Department of Education Federal Agency: U.S. Department of Agriculture Program Name: Community Investment CFDA Number: 12.600 Direct Award Federal Agency: U.S. Department of Defense Criteria or Specific Requirements Title 2, Code of Federal Regulations, Part 180, Subpart C, Section 180.300 provides procedures that must be followed by recipients and subrecipients of Federal awards to avoid entering into covered transactions with certain parties that are debarred, suspended, or excluded from participation in Federal assistance programs. These procedures include searching for such exclusions on the System of Award Management (SAM), collecting a certification from such parties, or adding a clause or condition to the covered transaction with those parties. Condition Out of three covered transactions tested, two did not contain documentation to support the District's compliance with required procedures identified in Title 2, Code of Federal Regulations, Part 180, Subpart C, Section 180.300. Specifically, the District did not maintain supporting records for these covered transactions to indicate the District's search for exclusions on the SAM in the current fiscal year. Questioned Costs There were no questioned costs identified, as the parties involved in these covered transactions were neither suspended nor debarred. Context The condition was identified as a result of inquiry with the District's Business Services personnel and through review of supporting documents. Effect The District has been engaging in procurement activities without verifying if parties are suspended or debarred from participation in Federal assistance programs. The District currently assumes all the risk of non-compliance with requirements stated under Title 2, Code of Federal Regulations, Part 180, Subpart C, Section 180.300 due to the lack of implemented review and monitoring procedures. Cause The condition identified appears to have materialized due to the District's lack of awareness of requirements under Title 2, Code of Federal Regulations, Part 180, Subpart C, Section 180.300. Repeat Finding (Yes or No) No Recommendation The District should review the requirements stated in Title 2, Code of Federal Regulations, Part 180, Subpart C, Section 180.300 and implement a procedure to address the deficiency currently identified with the District's procurement process. Corrective Action Plan Procurement processes have been reviewed and updated to include looking up vendors in SAM.gov to ensure they are eligible to be paid using Federal dollars.

2019-003 Code 50000 (Material Weakness, Noncompliance) Federal Program Affected Child Nutrition Cluster CFDA: 10.553, 10.555, 10.556, 10.559 Pass-Through Entity: California Department of Education Federal Agency: U.S. Department of Agriculture Program Name: Community Investment CFDA Number: 12.600 Direct Award Federal Agency: U.S. Department of Defense Criteria or Specific Requirements Title 2, Code of Federal Regulations, 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, Code of Federal Regulations, Part 200, Subpart D, Section 200.318. Condition Through inquiry with the District's Business Services personnel, documented procurement procedures have not been developed or maintained by the District to comply with standards identified in Title 2, Code of Federal Regulations, Part 200, Subpart D, Section 200.318. Questioned Costs There were no questioned costs identified. Context The condition was identified as a result of inquiry with the District's Business Services personnel and review of District policies. Effect The District has not maintained documented procurement procedures to demonstrate compliance with the requirements of Title 2, Code of Federal Regulations, Part 200, Subpart D, Section 200.318. The District currently assumes all the risk of non-compliance with requirements stated under Title 2, Code of Federal Regulations, Part 200, Subpart D, Section 200.318 due to the lack of documented procurement procedures. Cause The condition identified appears to have materialized due to the District's lack of awareness of requirements under Title 2, Code of Federal Regulations, Part 200, Subpart D, Section 200.318. Repeat Finding (Yes or No) No Recommendation The District should review the requirements stated in Title 2, Code of Federal Regulations, Part 200, Subpart D, Section 200.318 and implement a procedure to address the deficiency currently identified with the District's documentation of procurement processes. Corrective Action Plan The District is reviewing and compiling appropriate procurement processes to ensure compliance with all areas of funding.

2019-004 Code 50000 (Material Weakness) Federal Program Affected Child Nutrition Cluster CFDA: 10.553, 10.555, 10.556, 10.559 Pass-Through Entity: California Department of Education Federal Agency: U.S. Department of Agriculture Special Education Cluster CFDA: 84.027, 84.027A, 84.173, 84.173A Pass-Through Agency: 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)(vii), charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect cost activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition The District did not have sufficient controls in place to allow for all necessary reviews and preapprovals of employees charged to Federal awards. The District implemented hiring procedures for federally-funded employees in the 2019 fiscal year, which state that such funding approvals must be documented by a Federal Program Administrator and the Director of Finance and Budget. Through testing of six newly hired employees charged to Federal awards, none were supported by documentation that indicated review and approval by these personnel. 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 noncompliance or unallowable expenditures as a result of the finding. Context The condition was identified through gaining our understanding of the internal controls of the Child Nutrition and Special Education payroll expenditures, through our review of the payroll charged to the program, and review of supporting documentation. Effect Although we did not identify any noncompliance with the Activities Allowed/Allowable Costs Principles, the findings results in a material weakness in internal controls. Cause The identified condition appears to have materialized due to the District's insufficient monitoring of approval procedures required when hiring employees charged to Federal awards. Repeat Finding (Yes or No) Yes Recommendation The District should establish procedures that are consistently implemented when hiring employees. Most common controls include the use of a personnel requisition to document the authorization to hire and budget authorization for the program/account to be charged. Corrective Action Plan Procedures were implemented in the prior year. Steps will be taken to ensure thorough implementation.

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