{"database": "mytown-research", "table": "audit_findings", "rows": [[40, "wa-sao", "1021330", "2017-001", null, "WA", "Shelton School District No 309", "School District", "1970", null, "no_match", "Washington State Auditor's Office", "Financial and Federal audit \u2014 Shelton School District No 309", "Financial and Federal", 2017, "2016-09-01", "2017-08-31", "2018-05-17", "federal_award_compliance", "material_weakness", 0.0, "Questioned Cost Amount: $0", "The District lacked adequate internal controls to ensure compliance with requirements regarding suspension and debarment and graduation rate reporting for the Title I grant program. CFDA Number and Title: 84.010, Title I Grants to Local Agencies Federal Grantor Name: United States Department of Education Federal Award/Contract Number: Not applicable Pass-through Entity Name: Office of Superintende", "Background \nThe objective of the Title I program 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 high concentrations of low-income families. During fiscal year 2017, the \nDistrict spent $1,178,952 in Title I program funds. \nFederal regulations require federal -money recipients to establish and follow \ninternal controls to ensure compliance with program requirements. These controls \ninclude knowledge of grant requirements and monitoring of program controls. \nSuspension and debarment \nFederal requirements prohibit grant recipients from contracting with or making \nsub-awards to parties suspended or debarred from doing business with the federal \ngovernment. The District must verify that all contractors receiving $25,000 or more \nand all sub-awards have not been suspended or debarred. This verification may be \naccomplished by collecting a written certification from the party, or adding a clause \n \n \nWashington State Auditor's Office\n___________________________________________________________________________________________________________________\n \n \nor condition into the contract. Alternatively, the District may review the federal \nExcluded Parties List issued by the U.S. General Service Administration. The \nDistrict must meet one of these requirements before entering into contracts with \ncontractors or sub-recipients. \nGraduation rate reporting \nDistricts must report graduation -rate data for all public high schools to OSPI \nannually. Among other purposes, this information is u sed to determine if the \nDistrict has met adequate yearly progress requirements for Title I funding. The \nDistrict reports this information in a Graduation Rate Report that indicates the \nstudent\u2019s enrollment status: graduated, transferred out, dropped out, m igrated to \nanother country or deceased. The District must retain adequate support for each \nstudent\u2019s reported status and for changes to a student\u2019s status. Students identified \non the report as transferred are excluded from that District\u2019s graduation rate. To \nconfirm that a student transferred out, the District must have official written \ndocumentation that the student enrolled in another school or in an educational \nprogram that culminates in the award of a regular high school diploma. \nDescription of Condition \nSuspension and debarment \nThe District did not have internal controls in place to ensure contractors were not \nsuspended or debarred from participating in federal programs before entering into \ncontract. \nThis issue was not reported as a finding in the prior audit. \nWe consider this control deficiency to be a significant deficiency. \nGraduation rate reporting \nWe found the District did not adequately design or follow controls to ensure \ncompliance with the Title I graduation reporting requirements. Specifically, the \nDistrict did not have official written documentation to support all reports of \nstudents transferred out of the District. \nThis issue was reported as a finding in the prior audit as finding 2016-002. \nWe consider this control deficiency to be a material weakness. \n \n \n \nWashington State Auditor's Office\n___________________________________________________________________________________________________________________\n \n \nCause of Condition \nSuspension and debarment \nEmployees responsible for ensuring compliance with requirements regarding \nsuspension and debarment for the Title I grant program were not aware of the \nrequirements. \nGraduation rate reporting \nDistrict staff were not aware of the requirement to obtain and r etain written \ndocumentation for students transferring to another district. \nEffect of Condition and Questioned Costs \nSuspension and debarment \nThe District did not ensure two contractors were not suspended or debarred before \nentering into contract. Without proper controls, the District increases the risk of \nawarding grant funds to contractors and sub -recipients that are excluded from \nparticipating in federal programs. Any payments made to an ineligible party are \nunallowable and would be subject to recovery by the funding agency. \nWe confirmed the contractors were not suspended or debarred; therefore, we are \nnot questioning costs. \nGraduation rate reporting \nThe District did not retain appropriate, official written documentation to support \nthe transfer status for eight of 18 students tested. As a result, t he District is at risk \nof incorrectly calculating graduation rates. \nRecommendations \nWe recommend the District improve internal controls to ensure: \n\uf0b7 Staff responsible for ensuring compliance with federal requirements receive \nappropriate training \n\uf0b7 Verification that all contractors receiving $25,000 or more and all \nsub-awardees are not excluded from doing business with the federal \ngovernment \n\uf0b7 Accurate reporting of graduation rate data to OSPI and retention of records \nto support the data reported \n \n \nWashington State Auditor's Office\n___________________________________________________________________________________________________________________\n \n \nDistrict\u2019s Response \nSuspension and Debarment \nThe Executive Director of Finance has contacted all staff in the district that \nreceives Federal Funds to remind them of the Suspension and Debarment rules. \nThe rules are listed in the district\u2019s board policy no. 6220 procedures. This board \npolicy will also be updated this year in the district\u2019s board policy review. \nAn e-mail was sent to all district staff involved in f ederal funds on April 12, 2018 \ndirecting them to District Board Policy no. 6220 for purchasing with federal funds. \nGraduation Rate Reporting \nThe CHOICE High School principal has instructed the school registrar on proper \nprocedures as far as only indicating that a student transferred if we received written \nconfirmation from the sending school, or could verify in CEDARS (and then printed \nthe verification for the file). In addition, the CHOICE registrar printed all students \nwith a withdraw code for the 2017 -2018 school year to review all transfers and \nmake sure we have the necessary written documentation. \nThe Executive Director of Finance also sent guidance to all district registrars \noutlining appropriate written confirmation that a student is enrolled at anoth er \ndistrict, instructing them to ensure this documentation is in place before removing \nthem from the cohort as a transfer out. \nAuditor\u2019s Remarks \nWe appreciate the District\u2019s response and recognize that the District is committed \nto ongoing quality improvement and working to improve its internal controls and \nensure compliance. \nWe also wish to thank District management and staff for their cooperation and \nassistance throughout the audit. We look forward to working with the District on \nthis issue and will review the District\u2019s corrective action during our next audit. \nApplicable Laws and Regulations \nThe American Institute of Certified Public Accountants defines significant \ndeficiencies and material weaknesses in its Codification of Statements on Auditing \nStandards, section 935, 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 \n \nWashington State Auditor's Office\n___________________________________________________________________________________________________________________\n \n \n(Uniform Guidance), section 303, Internal controls, establishes internal control \nrequirements for management of Federal awards to non-Federal entities. \nTitle 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative \nRequirements, Cost Principles, and Audit Requirements for Federal Awards \n(Uniform Guidance), section 516, Audit findings, establishes reporting \nrequirements for audit findings. \nTitle 2 U.S. Code of Federal Regulations (CFR) Part 180, OMB Guidelines to \nAgencies on Governmentwide Debarment and Suspension , section 220, Are any \nprocurement contracts included as covered transactions?, defines covered \ntransactions. \nTitle 2 U.S. Code of Federal Regulations (CFR) Part 180, OMB Guidelines to \nAgencies on Governmentwide Debarment and Suspension, section 300, What must \nI do before I enter into a covered transactions with another person at the next lower \ntier?, outlines suspensio n and debarment requirements and methods of ensuring \ncompliance. \nTitle 34, U.S. Code of Federal Regulations (CFR) Part 200, Title I \u2013 Improving the \nAcademic Achievement of the Disadvantaged, section 19, Other academic \nindicators, establishes requirements for calculating and reporting graduation rates \nto the State levels. \n \n \n \nWashington State Auditor's Office\n___________________________________________________________________________________________________________________", "https://portal.sao.wa.gov/ReportSearch/Home/ViewReportFile?arn=1021330&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": ["40"], "units": {}, "query_ms": 73.33919999655336, "source": "MyTown", "source_url": "https://mytown.theboringparts.com", "license": "CC BY 4.0", "license_url": "https://creativecommons.org/licenses/by/4.0/"}