1. Gene Fornecker, Brian Kahl, and Derek Sliter

2. Agenda  Audit Manual & Website  Community Service Fund ◦ Wisconsin Statute Changes ◦ Updated Audit Program  Common School Fund ◦ Updated Audit Program  Membership Audits  National Forest Income  Cooperative Programs  Fund 21  Desk Review and Site Visits  Auditor Questions  Food Service  Special Education  LUNCH  EE Revenue Limit  WUFAR updates  Student Fees  Due Dates  Retiree Benefits  Reporting Findings

3. School Financial Services Homepage at http://sfs.dpi.wi.gov/

9.  Chapter 1 Introduction  Chapter 2 Financial Statement Audit  Chapter 3 Single Audit Requirements  Chapter 4 Special Education  Chapter 5 Pupil Activity Funds Audit  Chapter 6 Membership  Chapter 7 Integration (Chapter 220) Audits  Chapter 8 General Statutory Reference  Chapter 9 Sample Reports and Disclosures

11.  Minimum Standards for Audit and School District Audit Contract Minimum Standards for Audit and School District Audit Contract ◦ The auditor’s examination must be made in accordance with the following:  The standard for financial audits contained in the Government Auditing Standards, 2011 Revision issued by the Comptroller General of the United States (GAO Standards). ◦ DPI may accept a modified opinion in limited circumstances and typically only on the entity-wide statements.

13.  State Program Identification State Program Identification ◦ The Department of Public Instruction has not excluded any of its programs from the single audit. ◦ Using non-fiscal criteria DPI has identified two State financial assistance programs that are designated “Major” State programs. These State programs must be tested every year.  State Program Name Program Number General Aids 255.2XX Special Education 255.101

16.  Reporting State Findings – State Single Audit Guidelines ◦ Auditors should use the following guidance in determining which findings are to be included in the audit report:  Noncompliance that has a potential for adversely affecting the quality of instruction and support for students being served by the program should always be reported. Examples of this type of noncompliance include  services provided by unlicensed staff  failure to perform background checks for contracted providers  incomplete or out-dated individualized education plans  Noncompliance that affects program integrity should always be reported.  Examples of such noncompliance include services provided to ineligible individuals and services that are not allowed by the conditions set forth in the contract.

17.  Reporting State Findings – State Single Audit Guidelines (Continued) ◦ Auditors should use the following guidance in determining which findings are to be included in the audit report:  Noncompliance that results in likely total questioned costs exceeding $1,000 should always be reported.  Fraud should always be reported.  A pattern of noncompliance that indicates a weakness in the agency’s internal controls over compliance should always be reported.

20.  Wisconsin Statute 120.13 (19) ◦ C OMMUNITY PROGRAMS AND SERVICES. Establish and maintain community education, training, recreational, cultural or athletic programs and services, outside the regular curricular and extracurricular programs for pupils, under such terms and conditions as the school board prescribes ◦ The school board may establish and collect fees to cover all or part of the costs of such programs and services ◦ The school board may not expend moneys on ineligible costs as defined by the department by rule

21.  2013 ACT 306 ◦ The bill decreases a school district’s revenue limit by the amount of its ineligible expenditures for community programs and services ◦ This act first applies to the calculation of a school district’s revenue limit for the 2015-16 school year ◦ The department must define ineligible costs related to community programs and services

22.  Wisconsin Administrative Code - PI 80.01 Purpose.  (1) Under s. 120.13 (19), Stats., the school board of a common or union high school district, a unified school district, or a 1st class city school district may establish and maintain community education, training, recreational, cultural or athletic programs and services, outside of its regular curricular and extracurricular programs for pupils.  (2) The purpose of this chapter is to define which costs are ineligible under s. 120.13 (19), Stats.

23.  PI 80.02 Ineligible costs.  A school board may not expend moneys on ineligible costs for community programs and services. The following are ineligible costs: ◦ (1) Costs for any program or service that is limited to only school district pupils. ◦ (2) Costs for any program or service whose schedule presents a significant barrier for age-appropriate school district residents to participate in the program or service. ◦ (3) Costs that are not the actual, additional cost to operate community programs and services under s. 120.13 (19), Stats. ◦ (4) Costs that would be incurred by the school district if the community programs and services were not provided by the school district.

24.  Crossing guards are provided by our school district at our elementary school and at a very busy intersection of a state highway. There are no parochial/private schools in our community.  DPI Response: The primary benefit of this expense is the safety and welfare of the students attending your school and based on this description this would be deemed an “ineligible” cost in Fund 80. It is the district’s duty to document that others benefit for this service beyond those driving the vehicles through that location while the service is provided.

25.  A portion of an administrator’s salary and benefit costs are paid through Fund 80 as we do not have a Community Education Director position and this individual is assigned this duty.  DPI Response: This would be an “ineligible” cost based on the information provided. To retain this arrangement the district will need to define this individual’s employment based on the concept that this employee has been assigned two separate positions that combined grant full time employment as defined by the Board approved job description. Thus, if Fund 80 was no longer operating this individual would no longer have full-time employment.

26.  C HILD CARE PROGRAMS. ◦ 120.13(14)(a) Establish and provide or contract for the provision of child care programs for children. The school board may receive federal or state funds for this purpose. The school board may charge a fee for all or part of the cost of the service for participation in a child care program established under this subsection. Costs associated with a child care program under this subsection may not be included in shared costs under s. 121.07 (6). 120.13(14)(a)121.07 (6)

27.  Community Service Fund Information ◦ http://sfs.dpi.wi.gov/sfs_comm_serv_fund_info http://sfs.dpi.wi.gov/sfs_comm_serv_fund_info  Includes PI 80 ◦ http://sfs.dpi.wi.gov/sfs_comm_serv http://sfs.dpi.wi.gov/sfs_comm_serv  Includes a question and answer

28.  Wisconsin Statute 120.14 (1) At the close of each fiscal year, the school board of each school district shall employ a licensed accountant to audit the school district accounts and certify the audit. The audit shall include information concerning the school district's self-insurance plan under s. 120.13 (2) (b), as specified by the commissioner of insurance, and information about expenditures for community programs and services under s. 120.13 (19).120.13 (2) (b)120.13 (19)

29.  New audit program for 2014-15 ◦ Types of Services Allowed and Unallowed  Review the community service rules  Perform an analytical review  Perform an expenditure test  The disbursement selected is eligible to be recorded in Fund 80 per the rules ◦ Reporting Requirements  Report identified expenditures that do not meet the Fund 80 rules or are considered ineligible by the auditor on the PI 1506 AC  The auditor should not report expenditures that have been reclassified prior to filing the 1506 AC

30.  Fund 80 One-time transfer (prior period adjustment)  Steps to complete the transfer: ◦ 1. District will provide the School Financial Services team (SFS) with a written formal request.  The dollar amount to be transferred and the non-levy source (e.g. fees, donations, etc.) of the balance ◦ 2. School Financial Services team will be allowed at least 10 working days to review the formal request starting on the day following receipt of the complete request. ◦ 3. With the formal, documented approval of SFS, the Board of Education will then act on the formal resolution clearly stating the dollar amount to be transferred and the intended use. ◦ 4. This entire process must be complete on or before Friday, July 31, 2015.

32.  Up to 100% of the moneys received in a fiscal year may be used to purchase computers and related software if the computers are housed in the library  Computers and related software would include: ◦ Equipment additions ◦ Equipment replacement ◦ Capital lease principal

33.  The following objects in function 222 000 “Library Media” expenditures qualify as eligible “instructional media” expenditures for Common School Fund Aid: Object Description 431 Audio-Visual Media 432Library Books 433 Newspapers 434 Periodicals 435 Computer Software Programs 438 Microfilm 439Other Media  Examples of eligible and ineligible expenditures can be found at http://schlib.dpi.wi.gov/schlib_csf_purc.http://schlib.dpi.wi.gov/schlib_csf_purc

34.  Payment Information  Can be located at http://sfs.dpi.wi.gov/sfs_comschhttp://sfs.dpi.wi.gov/sfs_comsch  Common School Fund payments are on a per census count basis  Payments are estimated at $29.05 per census student for 2014-15  Payments were made on 4/27/15

38.  Updated audit program for 2014-15 ◦ Types of Services Allowed and Unallowed  Perform an expenditure test  Test both instructional media and computer equipment  The computer equipment expenditure total can be obtained from addendum A82  The disbursement selected is an eligible common school fund expenditure ◦ Eligibility  Obtain the school census report  Review the procedures used to compile the census number reported

39.  Updated audit program for 2014-15 ◦ Reporting Requirements – Annual Report  Obtain Addendum A82  Trace amounts reported in addendum A82 to the district’s general ledger  Recompute the aid remaining ◦ Reporting Requirements – Census Report  Obtain the district’s signature/certification page and supporting documentation for the school census report  Trace the census number reported to DPI to supporting documentation

41.  161 Membership audits for 2014-15 ◦ 39 districts with summer school findings ◦ 25 districts with findings related to the September to January Reconciliation ◦ 4 districts with a high number of total errors  Districts will be reviewed for possible inclusion in 2015-16

44.  Wisconsin Statute 23.09 (18m) N ATIONAL FOREST INCOME. If the governor designates the department (DNR) under s. 16.54 (2) to distribute moneys received by the state as national forest income under 16 USC 500, the department shall distribute the moneys to school districts that contain national forest lands within their boundaries. The distribution to each school district shall be in proportion to the national forest acreage in each school district.16.54 (2)16 USC 500

45.  CFDA # 10.665 (Schools and Roads – Grants to States)  Compliance Supplement is available  Distributions of National Forest Income by the Wisconsin Department of Natural Resources should be coded to source 780  Contact Kathy Farmer from the DNR at kathy.farmer@wisconsin.gov with questions. kathy.farmer@wisconsin.gov

47.  Fund revenues must equal expenditures.  All expenditures are charged to the Package/Cooperative plan participants.  There can be no fund balance or fund deficit reported in the package/cooperative funds.  Fund 91 is used when CESA is the fiscal agent  Fund 99 is used when a district is the fiscal agent.

48.  The use of the term deferred should be limited to items reported as deferred outflows of resources or deferred inflows of resources.  Therefore, the term deferred revenue should not be used in the presentation of the financial statements.  Unearned Revenue - payments received for future services to be performed or goods to be delivered.

50.  Permanent Fund ◦ Should be used to report resources that are legally restricted to the extent that only earnings and not principal, may be used for purposes that support the district’s programs ◦ Resources should benefit the government ◦ Need to keep the corpus intact

51.  Activity groups where staff decides how to raise funds and how to appropriate them ◦ Examples  Athletic Fundraisers  School Fundraiser (Example – Field Trips)  Band Uniforms  School Musical

53.  OMB Circular A-133 §___.520 requires that the auditor use a risk based approach to determine which programs are major. The auditor is also required to identify which Type A programs are low risk and which Type B programs are high risk. The auditor shall identify Type B programs which are high-risk using professional judgment and the criteria in §___.525.  Comments: The School District A and the School District B were required to have a federal single audit in 2013-14. The audit workpapers reviewed did contain the required Type B risk assessment. However, the risk assessment for these two districts did not include the Title I program. A program below the Type B threshold was tested for School District A instead of the Type B program.

54.  Wisconsin Statute 120.14 requires that the district hire a licensed accountant to audit the school district accounts annually. The audit shall include information about expenditures for community programs and services. The Wisconsin Department of Public Instruction (DPI) has developed an audit program to meet this requirement. The auditor will be required to report ineligible community service expenditures to DPI beginning with the 2014-15 audits.  Comments: The audit program developed by DPI was not used for the three districts reviewed.

55.  Title II, Part A funds are for training, hiring, and retaining skilled educators ◦ Site visits conducted by program staff  Documentation for salaries and fringes claimed  NO FOOD PURCHASES ◦ Program Contact is Abdallah Bendada at Abdallah.Bendada@dpi.wi.gov Abdallah.Bendada@dpi.wi.gov

57.  Why are there late changes to the annual report and the aid certification report? ◦ Annual Report Review  Reclassifications  TIF closeout monies reclassified to source 219  Old outstanding checks reclassified from source 971 to 815900  Open enrollment transactions ◦ Audit Report Review  Fund Balance/Net Position does not equal the other reports filed with DPI ◦ Late Filing of Claims ◦ District Fails MOE

58.  Question ◦ District is allocating HRA medical payments at year- end ◦ The allocation base used is health insurance premiums ◦ Allocating HRA payments provides a more consistent expenditure and district staff do not need to know actual medical expenditures ◦ Can the district continue to allocate the actual HRA medical payments using health insurance premiums as the allocation method?

59.  Answer ◦ DPI Guidance  District payments for actual medical expenditures using HRAs should be coded to Object 249. The employee’s current fund and function would also be used to record these expenditures.  a)-Payment of actual medical expenditures through an HRA.  XXE XXXXXX-249 xxxx  XXB 711000 xxxx

60.  Answer ◦ Omni-Circular  Fringe benefits may be assigned to cost objectives by identifying specific benefits to specific individual employees or by allocating on the basis of entity-wide salaries and wages of employees receiving the benefits. When the allocation method is used, separate allocations must be made to selective groupings of employees, unless the non- Federal entity demonstrates that costs in relationship to salaries and wages do not differ significantly for different groups of employees. ◦ Independent Auditor  Wages and health insurance are not a reasonable allocation basis for HRA medical expenditures

63.  Background  Effective July 1, 2011 School Food Authorities participating in the NSL program must ensure that they provide the same level of support for lunches served to students who are not eligible for free/reduced price lunches as they are for students receiving free lunches  DPI School Nutrition team has a tool on its website to help districts determine correct pricing for its meals

64.  If the calculator shows that the district has its paid lunch price too low they have 2 options: 1.Adjust its meal price, or 2.Provide non-federal funding to cover the difference  Many districts do not want to raise meal prices but previous rules prohibited General Fund transfers to Fund 50.  For 2014-15 fiscal year, districts will be allowed to make transfers to Fund 50 from Fund 10 even if they have a Fund 50 positive fund balance.  The transfer to Fund 50 will become part of the district’s shared cost  The PI 1505 will be modified to allow transfers

66.  DPI licensure is migrating to the new ELO system (Educator Licensing Online)  Due to problems with that system the “No Valid License” information typically provided for auditors will not be available  The SPED audit program has been modified for the June 30, 2015 audit  Most notable change is the addition of minimum sample sizes for testing of payroll costs charged to Fund 27 Project 011…based upon total district enrollment

67. District EnrollmentSample Size 400 Students or less3 (at least 1 instructional and 1 support) 401-800 Students6 (at least 3 instructional and 2 support) 801-1,200 Students9 (at least 5 instructional and 2 support) 1,201-3,000 students12 (at least 7 instructional and 3 support) 3,001 – 10,00018 (at least 10 instructional and 5 support) 10,001 – 30,00024 (at least 13 instructional and 7 support) More than 30,000 student50 (at least 30 instructional and 15 support)

68.  Acceptable Licensure documentation ◦ An original, photocopy or scan of a DPI license certificate ◦ For individuals licensed before 6/30/14, the ELO public Directory Search listing (http://tepdl.dpi.wi.gov/licensing/elo-public- search )http://tepdl.dpi.wi.gov/licensing/elo-public- search ◦ For individuals who have applied for a license after 7/1/14 but haven’t received a license, a copy of the completed application for the appropriate license and proof of payment

69.  If the LEA is unable to provide the appropriate licensure documentation then a Questioned Cost should be identified on the NVL/QC Worksheet and emailed to dpisfsreports@dpi.wi.gov dpisfsreports@dpi.wi.gov

71.  Facility project ◦ Per Wisconsin Statute §121.91(4)(o) school districts may exceed the revenue limit on a non-recurring basis for a project to increase the energy efficiency of a facility. ◦ The project is governed by a performance contract entered into under Wisconsin Statute §66.0133.  Energy Savings Performance Contracting per Wisconsin Statute §66.0133 is broader that the Revenue Limit exemption with regard to nature projects. 71

72.  Districts are encouraged to consider their options, but know the prudent course is to limit projects to facility energy efficiency measures.  Administrative Rule PI 15 is currently being reviewed for revision purposes. 72

73.  Reminders: ◦ Publication and Reporting requirements.  Budget Hearing and DPI ◦ Energy savings must be used to reduce the tax levy. ◦ Always separate BOE motions for each levy by fund to the second digit. Separate Fund 38 & Fund 39.  More information forthcoming: ◦ Reporting and verification of EE savings 73

75. Revenue Changes  Allow Source 957, Unrealized Gains On Investments, in Fund 72  Allow Source 964, Insurance Claims and Reimbursements, in Fund 27  Source 263, Vocational Education Projects, was changed to “Educational Program Sales” and includes revenues generated from School ‘Café Sales’  Source 964, Insurance claims and Reimbursements, should include reimbursements received from insurance companies for ‘Clinic Costs’ operated by districts for employees  Source 780, Federal Aid Received through State Agencies other than DPI, includes National Forest Income received from the WI Dept of Natural Resources

76. Expenditure Changes  Allow Object 998, Unrealized Loss on Investments, in Fund 72  Allow Object 940, Dues and Fees, with Function 252000, Fiscal, in Fund 73  Modify description of Function 221300, Instructional Staff Training, to include the incremental cost of providing subs in classrooms while teachers attend training  Object 310, Personal Services, includes non- itemized travel costs (itemized travel costs gets coded using Object 343)

77. Balance Sheet Changes  Allow 815900, Other Deposits Payable, in Funds 38 and 39 to account for good faith deposits received (reversed out when final debt has been issued)

78.  http://sfs.dpi.wi.gov/sfs_wufar http://sfs.dpi.wi.gov/sfs_wufar  Revisions #24 and #25 applicable for the fiscal year ended June 30, 2015

80. If the district claims summer school membership for purposes of State Aid under s.121.14, Wis. Stats: There shall be no cost to the resident student beyond individual use supplies (towels, gym clothes, band instruments, notebooks, pencils), and textbooks or similar items (workbooks). Fees for equipment, admission to a facility or event, transportation, shuttling, and food & lodging for off-campus activities are prohibited if a district claims state aid. Summer school fees may not be used to subsidize other classes or students. 80

81. If the district claims summer school membership for purposes of State Aid under s.121.14, Wis. Stats: Items for which fees are charged must be legally permitted and actually purchased for summer school use. Even if the class is not aided, required, or credited, fees may be charged but must be based upon the actual cost of the class. Therefore …. You must be able to document that expenditures were made to cover the fee charged to each individual student. 81

82. Resources  See DPI's websites regarding fees : Summer Schoolhttp://sfs.dpi.wi.gov/sfs_summ_schhttp://sfs.dpi.wi.gov/sfs_summ_sch School Fees (General)http://sfs.dpi.wi.gov/sfs_feeshttp://sfs.dpi.wi.gov/sfs_fees

86. District reports ◦ PI-1505 AC  Due Friday, August 28  Opens July 13 ◦ PI-1505 and PI-1505 SE – Both the Full and the Special Education Annual Reports  Due Friday, September 18  Opens July 13

87. Auditor reports ◦ Auditor Certification PI-1506 AC  Due Friday, September 11  Opens July 13 ◦ Audited Fund Balance PI-1505 FB  Due Friday, September 11  Opens July 13 ◦ Special Education No Valid License Worksheet  Due Friday, September 18  Send completed xls document to: dpisfsreports@dpi.state.wi.us dpisfsreports@dpi.state.wi.us ◦ Audited Financial Statements  Due December 1, 2015

88. Audit reports for the fiscal year ended June 30, 2015 must be filed to DPI in PDF format by December 1: auditreports@dpi.state.wi.us ◦ Audited financial statements ◦ Management letters, SAS 115 Communications of Internal control matters, and any SAS 114 Communication with Those Charged with Governance ◦ Single Audit reports if issued separately ◦ Data Collection Form (YES! WE WANT IT!)

90.  Shared Costs ◦ Must go to an irrevocable account to be counted as an expenditure  OPEB Trust  HRA account (custodial agreement must be irrevocable)  District CAN’T get money back  Expenditure in following year is reduced if there are forfeitures  NOT REVENUE TO A DISTRICT - No revenue is recorded. Expenditure is less in following year.

91.  HRA, TSA and other employee benefit accounts ◦ If a district is making a contribution into an HRA fund, it must go into an irrevocable account. ◦ May or may not be accounted for in Fund 73 ◦ Guidance for all HRA accounting can be found at: http://sfs.dpi.wi.gov/files/sfs/pdf/HRA_and_HSA.pdf

92.  Cash contribution into the Fund 73 trust must be completed (posted) by July 30 th for it to count in the year ending June 30 th.

94. Two Main Types of Findings:  Pupil Transportation – Around 50 findings  Special Education – Around 45 findings  Other findings: ◦ Two General Aids Findings ◦ One Common School Fund Finding ◦ One SAGE Finding

95. See the new Reporting Findings section within Chapter 3 of the Audit Manual http://sfs.dpi.wi.gov/sites/default/files/imce/sfs/rep orting%20findings.doc Main point of emphasis:  Looking for more specificity in findings ◦ This helps districts develop an appropriate Corrective Action Plan and it helps us form our Management Decisions ◦ Vague findings lead to vague CAP’s

96. Four Main Types of Findings:  Preparation of Financial Statements – 337 districts  Segregation of Duties – 272 districts  Material Audit Adjustments – 74 districts  Bank Reconciliations – 13 districts

97.  New in the 2013-14 FY and subsequent years ◦ Following up on all Financial Statement Findings without an appropriate Corrective Action Plan ◦ Letters were sent to 85+ districts asking for additional information in regards to their submitted CAP’s

98. Condition: The internal control system does not include a process for preparing the annual audited financial statements and the related disclosures in accordance with U.S. generally accepted accounting principles (GAAP). Examples of Corrective Action Plans:  Board of Directors reviews and approves the financial statements after preparation by the Auditor. ◦ Does it address the condition that exists? If not, does it provide mitigating controls?  District will continue to rely on the auditors. ◦ Does it address the condition that exists? If not, does it provide mitigating controls?

99. Condition: We noted that the District has limited staff which does not allow for the proper segregation of duties.  Is this condition specific enough?  Which financial areas are affected? ◦ If none are listed we assume all areas

100. Examples of Corrective Action Plans:  District plans to hire additional staff to help segregate duties. ◦ Does it address the condition that exists? If not, does it provide mitigating controls?  The finding does not warrant further action. The cost outweighs the benefit. ◦ Does it address the condition that exists? If not, does it provide mitigating controls?

101. Examples of Corrective Action Plans:  The District agrees with the finding and continues to evaluate procedures to minimize its exposure. ◦ Does it address the condition that exists? If not, does it provide mitigating controls?  The Board reviews and approves all expenditures on a monthly basis prior to mailing checks. ◦ Does it address the condition that exists? If not, does it provide mitigating controls?

102. Condition: The audit firm proposed and the District posted to its general ledger accounts journal entries for correcting certain misstatements. Examples of Corrective Action Plans:  District will continue to rely upon the audit firm to propose audit adjustments necessary to adjust accounts in accordance with GAAP. Management will review and approve these entries prior to recording them. ◦ Does it address the condition that exists? If not, does it provide mitigating controls?

103. Examples of Corrective Action Plans:  District will provide more oversight. ◦ Does it address the condition that exists? If not, does it provide mitigating controls?  The District will incorporate financial reporting internal controls to detect significant adjustments, prevent significantly misstated financial statements and increase the accuracy of the interim financial reports used by management. ◦ Does it address the condition that exists? If not, does it provide mitigating controls?

104. Condition: A bank reconciliation was not being performed on a monthly basis. Cash receipts were not recorded timely during the 2013/14 school year. Examples of Corrective Action Plans:  District will provide more oversight. ◦ Does it address the condition that exists? If not, does it provide mitigating controls?

105. Examples of Corrective Action Plans:  District will design procedures to prevent in the future. ◦ Does it address the condition that exists? If not, does it provide mitigating controls?  Bank reconciliations will be prepared timely in the future utilizing the bank reconciliation feature in the general ledger software. ◦ Does it address the condition that exists? If not, does it provide mitigating controls?

106.  The Corrective Action Plan should address the Condition  Try to be specific with the findings, especially in segregation of duties, to help the district formulate their Corrective Action Plan  Bank Reconciliations – Who prepares and reviews?

108.  Gene Fornecker, CPA ◦ 608/267-7882 ◦ eugene.fornecker@dpi.wi.gov eugene.fornecker@dpi.wi.gov  Brian Kahl, CPA ◦ 608/266-3862 ◦ brian.kahl@dpi.wi.gov brian.kahl@dpi.wi.gov  Derek Sliter, CPA ◦ 608/267-9218 ◦ Derek.sliter@dpi.wi.gov Derek.sliter@dpi.wi.gov