{"database": "mytown-research", "table": "audit_findings", "rows": [[39, "wa-sao", "1021323", "2017-001", null, "WA", "Puyallup School District No 3", "School District", "1994", null, "no_match", "Washington State Auditor's Office", "Financial and Federal audit \u2014 Puyallup School District No 3", "Financial and Federal", 2017, "2015-09-01", "2017-08-31", "2018-05-31", "federal_award_compliance", "material_weakness", 0.0, "Questioned Cost Amount: $0", "The District did not have adequate internal controls to ensure it complied with Title I grant requirements for highly qualified paraprofessionals. CFDA Number and Title: 84.010 \u2013 Title I Grants to States 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 (OSPI) Pass-throu", "Background \nThe federal Title I program\u2019s objective is to improve the teaching and learning of \nchildren who are at risk of not meeting state academic standards and who reside in \nareas with a high concentration of low-income families. During fiscal year 2017, \nthe District spent $2,538,387 in Title I program funds. \nFederal regulations require federal money recipients to establish and follow internal \ncontrols to ensure compliance with program requirements. These controls include \nknowledge of grant requirements and monitoring of program controls. \nEach paraprofessional the District charges to the Title I program must have \nobtained either a high school diploma or its recognized equivalent . The District \nmust verify that all paraprofessionals it charges to the program have met this \nrequirement. \nDescription of Condition \nThe District \u2019s procedures for verifying paraprofessionals it hired met the \nqualification requirements during the period of the audit were not effective in \nensuring compliance. The District relied on each applicant\u2019s certification that he \n \n \nWashington State Auditor's Office\n___________________________________________________________________________________________________________________\n \n \nor she obtained a high school diploma or its equivalent, without always physically \nverifying and documenting that they did. \nWe consider this internal control deficiency to be a material weakness. \nThis issue was not reported as a finding in the prior audit. \nCause of Condition \nThe District relied on paraprofessionals\u2019 certification that they acquired a high \nschool diploma or equivalent on their employment application to demonstrate the \nfederal requirement was met, without always performing further verification and \ndocumenting it. \nEffect of Condition and Questioned Costs \nWithout adequate internal controls in place , such as (maintaining evidence the \nDistrict verified the paraprofessional had obtained a high school diploma or \nequivalent, the District cannot demonstrate paraprofessionals met the requirement \nand, therefore, that costs charged to the grant were allowable. \nOur audit found the District did not have evidence of a high school diploma on file \nfor four of the 25 paraprofessionals it charged to the program. \nSubsequently, the District obtained copies of transcripts and high school diplomas \nfor the four paraprofessionals to show each met the requirement. Therefore, we are \nnot questioning costs the District charged to the grant. \nRec ommendation s \nWe recommend the District establish and follow internal controls to ensure every \nparaprofessional provides evidence of a high school diploma or its equivalent and \nto keep a copy of this evidence in the employee file. \nDistrict\u2019s Response \nThe Puyallup School District does not concur with the finding of a material \nweakness in internal controls with regard to the highly -qualified status of Title I \nparaprofessionals. The District was aware of the requirement that Title I \nparaprofessionals mus t have a high school diploma or GED and performed \nverification of this by either reviewing an employee\u2019s actual diploma/transcript; or \nthrough an employee\u2019s certification on their application form. We have found no \nwritten documentation requiring the Dist rict to maintain a file copy of a \nparaprofessional\u2019s high school diploma/GED or transcripts. Written guidance \nprovided by OSPI (Title I, Part A Guide to Paraeducator Requirements issued \n \n \nWashington State Auditor's Office\n___________________________________________________________________________________________________________________\n \n \nAugust 2017), explicitly states that districts must maintain a file c opy of official \ntranscripts as verification of college credentials (for which the District was 100% \ncompliant on this greater indicator of qualifications) but is silent on any such \nrequirement for verification of a paraeducator\u2019s high school diploma/GED or \ntranscripts. The District\u2019s reliance on the employee\u2019s certification of high school \ndiploma/GED or transcripts was not an internal control weakness, rather a \nreasonable assumption based on the insignificance of a high school diploma in \nrelation to the co llege/ETS test requirements and lack of written documentation \nrequiring a file copy be maintained. \nBased on the new ESSA legislation, the District anticipated that a copy of the high \nschool diploma/GED or transcripts would be required to be maintained starting in \nSeptember 2018 and had been proactively contacting Title I paraprofessional staff \nwho had not already provided us with a copy. Also at this time we began requiring \nthis documentation for new hires as well. Prior to the end of the audit all high \nschool diplomas or transcripts for Title I paraprofessionals had been obtained. \nThe District is confident that our students were well served by the quality \nparaprofessionals that were employed in the Title I program. We will continue our \ncurrent practice of ensuring that a copy of an employee\u2019s high school diploma/GED \nor transcript will be maintained on file for all Title I paraprofessionals. \nAuditor\u2019s Remarks \nWe thank the District for its cooperation and assistance during the audit and the \nsteps it is taking to address this issue. \n In the OSPI website and the OSPI Title I, Part A, Guide to Paraeducator \nRequirements: \nParaeducator Qualifications \nA. All paraeducators must have the first, essential credential \u2014 a high school \ndiploma or GED (General Educational Development). Paraeducators can provide a \ncopy of their high school diploma \u2014 transcripts are not necessary. \nB. With this credential in place, there are three educational pathways and one \nevaluation option a potential paraeducator can take to meet federal requirements. \n1. Two years of study at an institution of higher education. The institution you \nchoose must meet five criteria of the Higher Education Act, Section 101(a). All \nclasses must be at level 100 or higher. See Appendix A for a list of public and \nprivate institutions OSPI determined meet the five criteria. \n2. Associate degree or higher. All associate degrees are acceptable. \n \n \nWashington State Auditor's Office\n___________________________________________________________________________________________________________________\n \n \n3. Pass the ETS ParaPro Assessment. The assessment measures skills, and content \nknowledge related to reading, writing and math. Contact ETS 800-772-9476 or visit \nETS ParaPro Assessment. \n4. Washington paraeducator portfolio or apprenticeship program \u2014 completed \npreviously. Those meeting the apprenticeship requirements must present a \njourneycard or certificate. The portfolio and apprenticeships are no longer offered \nfor enrollment, however OSPI will continue to honor this pathway.\u2026 \nExceptions to a High School Diploma \n(1) In some states, students can enter community college without a high school \ndiploma or its equivalent. Districts are allowed to accept these colleges, if the first \ncriterion is absent. OSPI will waive the high school diploma requirement if the \nparaeducator has official college transcripts documenting at least two years of study \nat an instit ution of higher education. The institution you choose must meet five \ncriteria of the Higher Education Act, Section 101(a). All classes must be at level \n100 or higher. See Appendix A for a list of Washington public and private \ninstitutions OSPI determined meet the five criteria. \n(2) There may be extenuating circumstances when a paraeducator is cannot access \nan official copy of the high school diploma or transcripts. OSPI may grant a waiver \non a case-by-case basis. Contact the Title II, A office. \nWe have ve rified with the pass through agency, OSPI, certification from the \nemployee of a high school diploma is not sufficient evidence. It is the District\u2019s \nresponsibility to ensure it is hiring only qualified paraprofessionals. When the \ndistrict is unable to obtain a copy of the diploma, OSPI will evaluate on a case-by-\ncase basis and may grant a waiver. \nWe reaffirm our audit finding and will review the status of the District\u2019s corrective \naction during our next audit. \nApplicable Laws and Regulations \nThe American Institute of Certified Public A ccountants defines significant \ndeficiencies and material weaknesses in its Codification of Statements on Auditing \nStandards, section 935, Compliance Audits, paragraph 11. \nTitle 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative \nRequirements, Cost Principles, and Audit Requirements for Federal Awards \n(Uniform Guida nce), section 516 Audit findings, establishes r eporting \nrequirements for audit findings. \n \n \nWashington State Auditor's Office\n___________________________________________________________________________________________________________________\n \n \nTitle 2 CFR Part 200Uniform Guidance, section 303 Internal controls, describes \nthe requirements for auditees to maintain internal controls over federal programs \nand comply with federal program requirements. \nTitle 34CFR Part 200, Title I \u2013 Improving the Academic Achievement of the \nDisadvantaged, section 58 \u2013 Qualifications of paraprofessionals, requires all Local \nEducation Agencies (LEA) to ensure that each paraprofessional hired by the LEA \nwho works in a program supported by the funds of the grant must h ave earned a \nsecondary school diploma or its recognized equivalent. \nOffice of Superintendent of Public Instruction (OSPI) Title I, Part A, Guide to \nParaeducator Requirements, establishes the high school diploma or its equivalent \nas the \u201cessential requirement\u201d and considers a copy of the paraeducator\u2019s high \nschool diploma in lieu of a transcript as adequate in demonstrating the credential \nis in place. \n \n \n \nWashington State Auditor's Office\n___________________________________________________________________________________________________________________", "https://portal.sao.wa.gov/ReportSearch/Home/ViewReportFile?arn=1021323&isFinding=false&sp=false", "2026-07-30 13:24:54"]], "columns": ["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"], "primary_keys": ["rowid"], "primary_key_values": ["39"], "units": {}, "query_ms": 0.7227019814308733, "source": "MyTown", "source_url": "https://mytown.theboringparts.com", "license": "CC BY 4.0", "license_url": "https://creativecommons.org/licenses/by/4.0/"}