audit_findings: 27

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rowid source report_number finding_number muni_id state entity_name entity_type entity_ext_id place_geoid match_method auditor report_title audit_type fiscal_year period_start period_end published_date finding_category severity questioned_cost cost_basis finding_title finding_text report_url fetched_at
27 wa-sao 1021263 2017-001   WA Clover Park School District No 400 School District 2002   no_match Washington State Auditor's Office Financial and Federal audit — Clover Park School District No 400 Financial and Federal 2017 2016-09-01 2017-08-31 2018-05-10 federal_award_compliance material_weakness 0.0 Questioned Cost Amount: $0 The District did not have adequate internal controls in place to ensure compliance with the federal Title I grant requirements for highly qualified paraprofessionals. CFDA Number and Title 84.010 – Title I Grants to Local Educational Agencies Federal Grantor Name: U.S Department of Education Federal Award/Contract Number: NA Pass-through Entity Name: Office of Superintendent of Public Instruction Background The federal Title I program’s objective is to improve the teaching and learning of children who are at risk of not meeting state academic standards and who reside in areas with high concentrations of children from low -income families. During fiscal year 2017, the District spent $5,284,367 in Title I program funds. Federal regulations require recipients of federal money to establish and follow internal controls to ensure compliance with program requirements. These controls include knowledge of grant requirements and monitoring of program controls. To meet the requirements for highly qualified status, all paraprofessionals charged to Title I must have a high school diploma or its recognized equivalent. The District is responsible for ensuring all paraprofessionals it charges to the program meet this requirement. Washington State Auditor's Office ___________________________________________________________________________________________________________________ Description of Condition The District did not verify and maintain document ation demonstrating that paraprofessionals it charged to the program had received a high school diploma or its recognized equivalent. We consider this deficiency in internal controls to be a material weakness. This issue was not reported as a finding in the prior audit. Cause of Condition The District relied on employees certifying they acquired the high school diploma or equivalent on their employment application to determine whether the federal requirement was met. Effect of Condition and Questioned Costs Without adequate controls in place, the District cannot ensure costs charged to the grant are allowable. The District charged salary and benefit costs of 70 paraprofessionals to the program in 2017. Our audit found t he District was unable to initially demonstrate that four of the 14 paraprofessionals we tested had received either a high school diploma or its equivalent. We are not questioning costs. The District subsequently verified that each paraprofessional met the requirement, showing that two had evidence of a high school diploma and two attended a college requiring a high school diploma or its equivalent as a condition of enrollment. Recommendation We recommend the District establish and follow internal controls to ensure it has documentation demonstrating it verified every paraprofessional it hires has a high school diploma or its equivalent. District ’s Response Request for reconsideration of finding: On February 8, 2018, Clover Park School District’s assigned auditor provided Human Resources a list of seventeen (17) employees for the purpose of auditing highly qualified paraprofessional document requirements. Of the seventeen (17) personnel files audited, fifteen (15) employees met the highly qualified paraprofessional document requirement s. Of those fifteen (15) personnel files, thirteen (13) employees had documented diploma/high school transcripts and two Washington State Auditor's Office ___________________________________________________________________________________________________________________ (2) employees had met the document requirements through their BA transcripts. The two (2) remaining employee personnel files were from employees that had resigned June 14, 2017 to move out -of-state. One (1) of those paraprofessionals earned her AA degree from the University of Phoenix, which required a high school diploma or GED equivalent in order to enter their program (see attached admissions requirements). The other paraprofessional attended Chattahoochee Valley Community College which required a high school diploma or GED equivalent in order to enter their program (see attached admissions requirements). We accepted these transcript s as verification of high school diploma/GED equivalent. It was our understanding these transcripts would be an allowable form of verification of high school diploma/GED equivalent. The auditor suggested that we pursue obtaining a copy of the high school diploma/GED equivalent via form number SPI 1581 HEA Veri (3/04). These forms were mailed to the respective college and university; however, they were returned to us by the college and university requiring an original signature from the former employee(s) . We made several attempts to contact the two (2) former employees via telephone and to date have not received a return call from either of the former employees. We request your reconsideration of the finding by accepting the transcripts along with the admissions requirements we have on file for the two (2) paraprofessionals in question. As an outcome of this audit, we have added some other measures to include: additional communication regarding requirements for employment, and verification of requirements through the existing internal audit process. Specifically, in addition to the highly qualified requirements listed on our job announcements, we have posted the requirements on the employment web page and have added a communication about these specific requirements prior to new employee orientation. Also, in addition to our existing hiring checklist, we are currently re -auditing all district paraprofessional employment files to ensure compliance with highly qualified requirements. On April 19, 2018 the auditor notified us that three (3) employee files were removed from the audit due to being partially funded by Title. The action reduced the audit list from seventeen (17) to fourteen (14). Auditor’s Remarks We thank the District for its cooperati on and assistance during the audit and the steps it is taking to address this issue. Washington State Auditor's Office ___________________________________________________________________________________________________________________ We reiterate that we are not questioning costs. However, auditing standards require us to issue a finding regarding lack of internal controls, regardless of whether any costs are questioned. We have verified with the pass through agency, OSPI, certification from the employee of a high school diploma is not sufficient evidence to meet the highly qualified paraprofessional requirement. It is the District’s responsibil ity to ensure it is hiring only qualified paraprofessionals. When the district is unable to obtain a copy of the diploma, OSPI will evaluate on a case -by-case basis and may grant a waiver. The District did not obtain a waiver for the employees in question. We reaffirm our audit finding and will review the status of the District’s corrective action during our next audit. Applicable Laws and Regulations The American Institute of Certified Public A ccountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 2 Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guida nce), section 516 – Audit findings, establishes r eporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303 – Internal controls, describes the requirements for auditees to maintain internal controls o ver federal programs and comply with federal program requirements. Title 34, CFR Part 200, Title I – Improving the Academic Achievement of the Disadvantaged, Subpart A – Improving Basic Programs Operated by Local Education Agencies, section 58 – Qualifications of paraprofessionals, requires all Local Education Agencies (LEA) to ensure that each paraprofessional hired by the LEA who works in a program supported by the funds of the grant must have earned a secondary school diploma or its recognized equivalent. Washington State Auditor's Office ___________________________________________________________________________________________________________________ https://portal.sao.wa.gov/ReportSearch/Home/ViewReportFile?arn=1021263&isFinding=false&sp=false 2026-07-30 13:24:54