ISBE State Audits: Most Common Mistakes. Illinois Association of School Business Officials 2011 Annual Conference

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1 ISBE State Audits: Most Common Mistakes Illinois Association of School Business Officials 2011 Annual Conference

2 Your Presenters Jeremy Davis O Fallon Township High School District #203 davisj@oths.k12.il.us Melissa Oller Illinois State Board of Education moller@isbe.net Mark Ribelin Illinois State Board of Education mribelin@isbe.net Matt Geerdes Crowe Horwath LLP matt.geerdes@crowehorwath.com 2

3 Agenda Discussion of ISBE audits from 3 perspectives: School District Official Perspective ISBE Perspective External Auditor Perspective Q&A 3

4 Audit Notification OK, you just received a notice from the ISBE that they will be monitoring/auditing specific programs. What to do now? Don t panic! 4

5 Audit Notification OK, you just received a notice from the ISBE that they will be monitoring/auditing specific programs. What to do now? Inform your superintendent, other key administrators and school personnel. Schedule a time with the ISBE when you and your key district employees will be available. 5

6 Audit Notification OK, you just received a notice from the ISBE that they will be monitoring/auditing specific programs. What to do now? Review your available files. Is the necessary documentation available for review? Will you be able to explain potential questions about grant documentation to auditors? If not, will the appropriate school personnel be available to explain the documentation? 6

7 When the auditor arrives Be proactive. Ask if there is any additional information the auditor needs. Periodically check on the auditor. It is appropriate to ask the auditor if he/she is finding the necessary information and associated documentation. It also is appropriate to ask how the audit is going. If the auditor indicates a problem, ask if you can offer assistance. If there is documentation missing, ask if other available documentation could suffice.

8 Closing Conference Understand: Your district probably will be cited for non-compliance on some issue(s). If the audit findings are going to be unpleasant, it might be a good idea to involve the superintendent or other necessary individuals. Ask questions if you are unclear. The closing conference is for your district s benefit.

9 If you have to communicate bad news Communicate and explain the situation in as much detail as necessary. If citations do not involve fiscal or adverse penalties, be sure to say so. Often times, if mistakes have been made on grant or reimbursement claims, the consequence is giving money back that your district should not have received in the first place.

10 The best defense in the event of an audit is excellent documentation. Save source documentation. Make notes on the source data if necessary. If you use a number on a claim, be able to produce and explain the source of that number.

11 Example of Good Documentation

12 Example of Good Source Documentation

13 Example of Good Source Documentation

14 An example of documentation for costs claimed on the transportation claim.

15 Tips for filling out claims Use common sense. Allow more time for bigger & more important claims. Transportation General State Aid Document, document, document!

16 Tips for the Transportation Claim Read the instructions. They are very detailed, so make use of them. Allow plenty of time to fill out the claim. The transportation claim can take a long time to complete properly. Ask yourself: Am I correctly allocating mileage? Am I claiming only allowable expenditures? Am I calculating depreciation correctly?

17 Tips for the General State Aid Claim Again, read & follow the instructions. Use an electronic spreadsheet for totals & calculations. Remember to account properly for half-day attendees. One of the most common errors is overstating kindergarten attendance.

18 Tips for the General State Aid Claim Remember to subtract non-claimable pupils. Remember to include all your claimable tuition pupils. Tuition pupils are residents of your district, but receive their education from another source. Try graphing your Average Daily Attendance (ADA) by month. Look at the graph. Does the graph make sense? Is there an unexplained peak or trough? Graphing the ADA can help you identify large errors in an individual month.

19 ADA by month an example graph Aug/Sept Oct Nov Dec Jan Feb March Apr May/June

20 ADA graph with an obvious error! District counted 500 kindergarten half-day students attendance as full days in November. Aug/Sept Oct Nov Dec Jan Feb March Apr May/June

21 Common Findings of Field Staff Transportation General State Aid Accounting Issues Personnel Issues Other Issues

22 Transportation Bus Lease Agreements Lease Purchase Agreements Must Include: Invoices that establish the fair market values Lease Agreements must define lease structure/s Amortization schedules must outline principal and interest payments. Lease Agreements should not be held as Lease Trust this increases the potential for errors in the capitalization process.

23 Transportation Bus Lease Agreements Lease payments and interest are not direct expenses and must not be claimed as such. They must be capitalized and costs recovered through the depreciation allowance cost recovery process.

24 General State Aid Local Education Agencies (LEA) must maintain attendance data for the General State Aid Computation by Grade Levels and by Schools. The Pre-Kindergarten At-Risks Pupil s attendance days are non-claimable attendance for GSA attendance purposes since these are covered on other grants and therefore cannot be duplicated. Track all non-claimable attendance data for whom the LEA received tuition from i.e. Special Ed Orphanage Pupils.

25 Accounting Issues All Accounting must be done in accordance with the Illinois Program Accounting Manual deviation will result in an audit adjustment. For all programs be aware of the Project Begin Date and the Project End Date, claimed items must be within the grant period or they will be disallowed. Do not expend funds prior to any anticipated budget amendments. All Journal Entries must be supported by verifiable source documents.

26 Personnel Reporting Post Salaries and Benefits Timely pro rata share for any grant must be posted evenly in harmony with efforts rendered and services provided. Time Distribution Sheets, Teachers Schedules, Time Studies, Time Sheets and other verifiable documentation must be maintained were the compensation is funded from grants. This is also important where multiple grants are involved.

27 Time and Effort Reporting The federal law requires all employees, including teachers, paraprofessionals, and other staff that are paid with federal funds to document the time and effort they spend within that program. The portion of the federally paid salary should be reflective of the time and effort the individual has put forth for that federal program.

28 Time and Effort Reporting Time and effort reporting guidelines are specified in the U.S. Office of Management and Budget OMB) Circulars A-87 and A-133. The circulars provide instructions to auditors performing Single Audits of states, local governments, and non-profit organizations. OMB-87 establishes standards for charging employee compensation for federal grants. OMB A-133 lists the compliance requirements for federal education programs, including Title I Part A. Districts that receive other federal funds, such as Reading First, Migrant, Homeless, Neglected and Delinquent, Title II A, Title II D, Title III, Title IV A, Title V, Coordinated School Health, etc., must also ensure their employees are documenting their time and effort.

Other Issues Policies in general Maintain Required Documentation that includes each of the required components Continuing Compliance with each of the Requirements The following are examples of

29 Other Issues Policies in general Maintain Required Documentation that includes each of the required components Continuing Compliance with each of the Requirements The following are examples of policies that have these requirements Parental Involvement School Wide Programs Targeted Assistance Programs Gun-free Regulations Private Schools Continual - Collaboration and Participation Equitable Distribution of Grant Funds

30 Contacting ISBE Please contact ISBE Staff with questions as they arise, do not wait for audit staff to visit. If you are having problems and need assistance from the Division of External Assurance please contact us at

31 External Auditor s Perspective External Auditor s consideration Why do external auditors consider ISBE audits Planning and reporting considerations Regulatory Reports or Reports issues by others Impact timing and extent of audit procedures 31

32 External Auditor s Perspective External Auditor s consideration Issues to be documented below would include: misstatements whether caused by errors or fraud observed weaknesses in control designs and deviations in their operation Documented in audit footnotes if material Auditor s judgment is used 32

33 External Auditor s Perspective ISBE Audit Areas of Interest for External Auditors General State Aid (ISBE funded portion) Attendance calculations by month and by grade level for certain years in question Adjustment may be made to GSA payments in future years if errors are found 33

34 External Auditor s Perspective ISBE Audit Areas of Interest for External Auditors General State Aid (ISBE funded portion) Attendance calculations by month and by grade level for certain years in question Orphans Out of District Tuition Students Preschool Kindergarten Home School Part Time Students Hospital 34

35 External Auditor s Perspective ISBE Audit Areas of Interest for External Auditors Grant-specific Review ARRA GSA Revenue correctly recorded on trial balance Separate account per ARRA requirements Expense review Review 100% of ARRA expenditures if used for payroll Review 25% of ARRA expenditures if used for vendor vouchers 35

36 External Auditor s Perspective ISBE Audit Areas of Interest for External Auditors Grant-specific Review ARRA GSA Review if interest needs to be repaid Review period of availability 36

37 External Auditor s Perspective ISBE Audit Areas of Interest for External Auditors Title grants subject to ISBE audits Title I Low Income Title II Teacher Quality Title III Immigrant Education or LIPLEP Title IV 21st Century Transportation subject to ISBE audits Target is 3 year rotating schedule for grants 37

38 External Auditor s Perspective Common mistakes found and primary causes and impact on Financial Statement Audit General State Aid (ISBE funded portion) Exclusions from full day count for attendance Orphans Students paying tuition Preschool Kindergarten Counted as ½ day if a half day program 38

39 External Auditor s Perspective Common mistakes found and primary causes and impact on Financial Statement Audit General State Aid (ISBE funded portion) Other adjustments considered on a case by case basis Home school Part time Hospital Adjustment may be made to GSA payments in future years Accrual considerations for the Fund statements Receivable or payable depending on error Possible Government Auditing Standards finding if not corrected by year end Compliance 39

40 External Auditor s Perspective Common mistakes found and primary causes and impact on Financial Statement Audit ARRA accounts not in correct account ARRA requires ARRA funding to be tracked in separate accounts ARRA interest on cash not calculated or repaid ARRA Period of Availability not followed Funds spent too early Possible Single Audit finding if not corrected by year end 40

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Monitoring of Title I, IDEA, ARRA-Title I, ARRA-IDEA, SFSF (GSF, ESF) and Discretionary Grants Revised 11/24/2009

Monitoring of Title I, IDEA, ARRA-Title I, ARRA-IDEA, SFSF (GSF, ESF) and Discretionary Grants Revised 11/24/2009 On Site Review: Elements Reviewed Citation Comments During Audit Program Elements Title I: 1 Describe uses of Title I and ARRA Title I funds 2 Are the monies being spent for projects that benefit students?