Agenda Item
b. Approval of the FY 2021 Audit Corrective Action Plan
Summary: Presented by: Mr. Charles A. Burbridge, Chief Financial Officer, Division of Finance
Request: It is requested that the Board of Education approve the FY 2021 audit corrective action plan developed in response to Senate Bill 68 requirements. FY 2021 audit results stipulate the District’s designated risk level as being moderate. The District’s corrective action plan must be presented at a regular board meeting, signed by each board member, and submitted to the State Board of Education no later than 120 days from receiving audit results (May 27, 2022).
Why: Approval of the corrective action plan in accordance with the provisions of Senate Bill 68.
Details: Senate Bill 68 stipulates that the Department of Audits and Accounts designate a risk level for each school system. The FY 2021 audit contained four significant deficiency findings and one prior year partially resolved significant deficiency finding. These five items result in the School District’s designated risk level as being moderate. With this designation, the School District is required to submit to the State Board of Education, within 120 days of the date of the Audit Committee Letter, a detailed corrective action plan. The corrective action plan should be presented at a regular board meeting and signed by each board member.
Financial impact: None.
Contact: Mr. Charles A. Burbridge, Chief Financial Officer, Division of Finance, 678.676.0289
Ms. Masana Mailliard, Deputy Chief Financial Officer, Division of Finance, 678.676.0446
Mr. Lance McConkey, Comptroller, Division of Finance, 678.676.0445
Effective: Upon Board approval.
Status: Approved by General Counsel.
Mrs. Vickie B. Turner, Board Chair
Mr. Diijon DaCosta, Vice Chair
Mrs. Anna Hill
Mr. Marshall D. Orson
Mrs. Deirdre Pierce
Mrs. Allyson Gevertz
Dr. Vasanne S. Tinsley, Interim Superintendent Dr. Joyce Morley
FS 2021-001 Strengthen Oversight of the Information System Conversion
Internal Control Impact: Significant Deficiency
Compliance Impact: None
Description:
The DeKalb County Board of Education (School District) should strengthen oversight of its information system
conversion from its legacy human resources/payroll (HR/Payroll) and financial system to its new financial system.
Corrective Action Plan:
The District has time-lined multiple corrective actions and increased efforts to fully implement the Financial
Management Information System (FMIS), and strengthen Information Technology General Controls (ITGS). Full
payroll implementation is scheduled for the first quarter of 2023.
Planned actions include:
• Time-lined objectives: As of June 29th, 2022 a detailed timeline with key implementation milestones has
been created, which includes beginning payroll parallel run validation September 2022. Planned
completion of payroll parallel validation is anticipated November 2022, with transition to live payroll and
scheduled cut-off of the legacy system anticipated on or before March 2023.
• Continued Process Transition: Subsequent to the effective dates of the FY21 audit, several transaction
balances previously processed in the legacy system have been successfully transitioned, including QBE
revenue, SPLOST revenue, and bond principal and interest payments.
• Continued Monitoring: To help facilitate timely transition to the new financial software, beginning May
2022 Finance leadership began generating and reviewing a monthly listing of all remaining financial
transactions still processed in the legacy software.
• Improved Segregation of Duties: To improve segregation of duties and increase assurance over
monthly data transfers, an additional financial review of the monthly data transfer will be completed
separate from the initial processing employee, with an anticipated implementation month of July 2022.
Estimated Completion Date: March 2023
Contact Person: Chief Financial Officer and Chief Human Resource Officer
Telephone: 678-676-0133
Email:
Robert R. Freeman Administrative Complex
1701 Mountain Industrial Blvd. | Stone Mountain, GA 30083
678.676.1200 | www.dekalbschoolsga.org
FS 2021-002 Strengthen Information Technology General Controls
Internal Control Impact: Significant Deficiency
Compliance Impact: None
Description:
The DeKalb County Board of Education (School District) should strengthen information technology general
controls over its financial and human resource/payroll (HR/payroll) systems.
Corrective Action Plan:
The DeKalb County School District’s Division of Information and Instructional Technology (DIIT) has made
corrective actions to ensure logical access control procedures and recertification processes operate appropriately.
To support this effort, the Division of Information and Instructional Technology will:
• Assume control for all system governance, management and configuration, as well as access control
responsibilities related to the new ERP system-related implementation.
• Reestablish access for all users based on division management approval and user role-based fiduciary
responsibility.
• Implement a quarterly User Access Recertification Process for both the legacy and new ERP system.
• Update and strengthen Logical Access Policy and Procedures which includes enhanced management
approval/verification as well as appropriate oversight by the district’s Finance Division and Audits and
Compliance Department.
• Develop ongoing, coherent, and clear communication to district leadership and impacted staff regarding IT
policies and procedures related to logical access control.
• Expand staffing model to facilitate ongoing ERP system governance, support, and sustainability.
• Update Change Control policies to ensure appropriate monitoring for system integrity.
• Update, communicate, and implement currently developed Information Technology policies and
procedures to ensure adoption by all users.
The district will continue to work aggressively to sunset the legacy ERP system and completely migrate to the new
ERP system. Considering the legacy ERP system has technical limitations that prevent some of the recommended
controls, the district will implement manual processes on a quarterly basis to help with risk mitigation.
Estimated Completion Date: March 2023
Contact Person: Monika Davis
Telephone: 678-676-1000
Email: monika_davis@dekalbschoolsga.org
Robert R. Freeman Administrative Complex
1701 Mountain Industrial Blvd. | Stone Mountain, GA 30083
678.676.1200 | www.dekalbschoolsga.org
FS 2021-003 Strengthen Controls over Employee Compensation
Internal Control Impact: Significant Deficiency
Compliance Impact: None
Description:
The School District’s policies and procedures were insufficient to provide adequate internal controls over the
employee compensation process.
Corrective Action Plan:
Management is currently developing and finalizing a plan to strengthen internal controls relative to the issuance of
supplements and other compensation, improve document retention and availability, and improve the precision of
leave reporting.
Planned actions include:
• Compensated Absences: The vacation leave accrual process and relevant policy GBRI has been reviewed
for appropriateness with reporting guidelines to ensure that no employees accrue more than the maximum
allowable leave. This review was completed June 28 th, 2022, from which it was determined that clarifying
communication may need dispersed to applicable employees regarding the leave accrual process, including
the timeframe in which employees have to utilize vacation leave before forfeiture occurs. Furthermore, all
employees with negative vacation leave balances have been identified, and are under review with any
necessary adjustments in process.
• Supplement Issuance: Procedures regarding supplement issuance are being reviewed for potential
additions or alterations, with a projected completion date of December 31 st, 2022. All doctoral supplements
have been reviewed to ensure recipients have a qualifying doctoral degree. Furthermore, practices have been
clarified such that no Division management is allowed to unilaterally approve supplements for employees
within their own division or school. The Chief Human Resource Officer in place during the effective dates of
the FY21 audit has been removed from Human Resources effective May 23, 2022.
• Frozen-Scale Employees: Limited cases of employee base salary in excess of published salary scales has
taken place due to the impacts of prior salary studies, whereby the top range of salary scales was reduced
year-over-year. In some instances, this leaves employees at the previous highest step “frozen” above the new,
reduced scale. Management will review the current practice of frozen-scale employees to ensure policy is
followed and appropriate approvals are completed. Any exceptions that remain due to impacts of prior salary
studies will be clearly communicated, documented, and approved.
Estimated Completion Date: December 2022
Contact Person: Chief Human Resources Officer
Telephone: 678-676-0094
Email:
Robert R. Freeman Administrative Complex
1701 Mountain Industrial Blvd. | Stone Mountain, GA 30083
678.676.1200 | www.dekalbschoolsga.org
FA 2021-001 Strengthen Controls over Expenditures
Compliance Requirement: Activities Allowed or Unallowed
Allowable Costs / Cost Principles
Internal Control Impact: Significant Deficiency
Compliance Impact: Nonmaterial Noncompliance
Federal Awarding Agency: U.S. Department of Education
Pass-Through Entity: Georgia Department of Education
School Emergency Relief Fund
AL Number and Title: COVID-19 84.425D – Elementary and Secondary
School Emergency Relief Fund
Federal Award Number: S425D210012 (Year: 2021)
S425D20012 (Year: 2020)
Questioned Costs: $29,094
Description:
A review of expenditures charged to the Elementary and Secondary Emergency Relief Fund programs (Assistance
Listing Number 84.425D) revealed that the School District’s internal control procedures were not operating to
ensure that expenditures were appropriately documented to support allowability.
Corrective Action Plan:
The School District will review current internal controls related to ESSER program expenditures. Additionally, the
School District will develop and/or modify procedures to ensure that expenditures are appropriately documented
and reflect the connection to the purpose of the ESSER program funds. Furthermore, the School District will
provide on-going training to all ESSER fund users and increase monitoring.
Planned actions include:
• On-going Technical Assistance Training: The School District will increase compliance training to all
ESSER fund users. Training will cover program implementation, budgets, use of funds, and prior approval
requirements with emphasis on federal compliance requirements from Uniform Guidance, Section 200.403 –
Factors Affecting Allowability of Costs and Unform Guidance, Section 200.430 – Compensation-Personal
Services. Furthermore, increased emphasis will be placed on Title VIII of the Cares Act, Section 18003(d),
which details allowable uses of ESSER funds by School Districts.
• Workflow Improvements: Practices have been clarified such that no Division management is allowed to
unilaterally approve supplements for employees within their own division. Furthermore, established District
procedures require prior approval from ESSER grant leadership for the issuance of any supplements to be
paid with ESSER funding.
• Improved Reconciliations: To ensure the ESSER programs are more prepared for external audits, a full
salary reconciliation will be performed whereby all salary expenditures for ESSER reflected in the District’s
accounting records are properly identified by person and type of expenditure, with a planned implementation
month of October 2022.
Robert R. Freeman Administrative Complex
1701 Mountain Industrial Blvd. | Stone Mountain, GA 30083
678.676.1200 | www.dekalbschoolsga.org
• Improved Monitoring Controls: In FY 2023, the School District will implement monthly monitoring
meetings to ensure program compliance with relevant Uniform Guidance. This increased monitoring will
ensure proper internal controls are maintained and policies and procedures are followed.
Estimated Completion Date: October 2022
Contact Person: Office of Federal Programs
Telephone: 678-676-0219
Email:
Robert R. Freeman Administrative Complex
1701 Mountain Industrial Blvd. | Stone Mountain, GA 30083
678.676.1200 | www.dekalbschoolsga.org
FA 2020-001 Improve Controls over Equipment
Compliance Requirement: Equipment and Real Property Management
Internal Control Impact: Significant Deficiency
Compliance Impact: Nonmaterial Noncompliance
Federal Awarding Agency: U.S. Department of Agriculture
Pass-Through Entity: Georgia Department of Education
CDFA Number and Title: Child Nutrition Cluster (CFDA 10.533 and
10.555)
Federal Award Numbers: 215GA324N1199
Questioned Costs: None Identified
Repeat of Prior Year Finding: FA 2019-001, FA 2018-001, FA 2017-001,
and FA 2016-001
Finding Status: Partially Resolved
Description:
The policies and procedures of the School District were insufficient to provide adequate internal controls over
equipment and real property management as it relates to the Child Nutrition Cluster.
Corrective Action Plan:
A process to fully track School Nutrition equipment will be implemented. To ensure accuracy of the equipment
listings, the School Nutrition Inventory Specialist will conduct regular inspections of all kitchen locations
throughout the fiscal year. In addition to regular inspections, School Nutrition equipment listings will be
distributed to site managers quarterly for their review and certification.
Furthermore, to help ensure the completeness of School Nutrition equipment listings, current internal control
processes will be enhanced with the addition of a year-end equipment reconciliation process whereby current year
additions as identified in accounting records are reconciled to individual school listings.
To ensure more satisfactory compliance with 2 CFR 200.313, equipment tracking forms have been updated to
include explicit consideration of required categories not previously reported such as federal participation in cost,
the source of funding with associated FAIN number, and who holds title. The School District will work to ensure
that the equipment tracking form notes information for all required categories for all items.
Estimated Completion Date: October 2022
Contact Person: Dr. Connie Walker
Telephone: 678-676-1780
Email: connie_r_walker@dekalbschoolsga.org
Robert R. Freeman Administrative Complex
1701 Mountain Industrial Blvd. | Stone Mountain, GA 30083
678.676.1200 | www.dekalbschoolsga.org
Presented to and approved by the DeKalb County Board of Education at the August 8th, 2022 Board Meeting.
Signed By:
Dr. Vasanne S. Tinsley, Interim Superintendent
Mrs. Vickie B. Turner, Board Chair
Mr. Diijon DaCosta, Vice Chair
Mrs. Anna Hill
Mr. Marshall D. Orson
Mrs. Deirdre Pierce
Mrs. Allyson Gevertz
Dr. Joyce Morley
Robert R. Freeman Administrative Complex
1701 Mountain Industrial Blvd. | Stone Mountain, GA 30083
678.676.1200 | www.dekalbschoolsga.org