Printable Athletic Department Review Report

Cover Information

Tooele County School District Athletic Department Review October 2024

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December 3, 2024 Board of Education Tooele County School District 92 Lodestone Way Tooele, Utah 84074

Dear Board of Education and Dr. Mark Ernst, We have completed the Athletic Department Review for the Tooele County School District. We thank you and District employees for your assistance and support. Below is our report on the work performed and recommendations. The results were discussed with Lark Reynolds, Business Administrator.

CC: Tooele County School District Board of Education

Athletic Department Review Report – October 2024

Background

BDO was engaged by Tooele County School District (TCSD) to provide Internal Audit services under the direction of the Board of Education. The review included purchases, fundraising activity, and rebate activity within high school athletic programs. TCSD has five high schools with athletic programs. Each program has an Advisor responsible for funding and fundraisers. Rebates are managed at the school level by the Athletic Director.

The Audit Committee directed the review to include Stansbury High School (SHS) and Tooele High School (THS).

Purchases may be made through purchase cards (Pcards), Accounts Payable (AP), or employee expense reports.

Total Purchases (SHS + THS)

Method | SYE 2022 | SYE 2023 | SYE 2024 (through 3/31) | Total AP | $978,589 | $820,967 | $848,057 | $2,647,613 Pcard | $55,034 | $212,330 | $372,079 | $639,443 Employee Expense Reports | $63,257 | $37,639 | $182* | $101,078 Total | $1,096,880 | $1,070,936 | $1,220,318 | $3,388,134

*District Administration noted the decrease in employee expense reports is due to expectations that items be purchased through Pcard or AP.

Fundraising activity value could not be determined due to inconsistent identification of fundraiser receipts and lack of documentation.

Total Rebates Received (SHS only)

Method | SYE 2022 | SYE 2023 | SYE 2024 (through 3/31) | Total Rebates via credit balance | $20,700 | $14,248 | $13,660 | $48,608 Rebates via check | $4,100 | $3,566 | $1,951 | $9,617 Total | $24,800 | $17,814 | $15,611 | $58,225

Standards and Guidance

The review was based on the Institute of Internal Auditors (IIA) International Professional Practices Framework (IPPF), including Core Principles, Code of Ethics, and Standards.

Objective

To determine whether purchases, fundraising, and rebate practices were compliant with District policies and in the best interest of the athletic programs.

Scope

Review covered SYE 2022, 2023, and 2024 (through March 31). Activities reviewed:

1. Athletic program purchases (Pcard, AP, employee expense reports).

2. Fundraising activity (support, accuracy, compliance).

3. Rebate activity (accuracy, completeness, compliance).

Summary of Observations and Recommendations

A matrix of recommendations and management responses was included. All recommendations and responses are preserved below.

Recommendations and Management Responses (Condensed into Plain Text)

Recommendation 1.1 – Update Purchasing Policies

BDO recommends revising Policies 3016 (Small Purchases) and 3034 (Cash Disbursements) to:

• Merge into one clear policy.

• Set appropriate thresholds for competitive quotes and approvals.

• Define documentation expectations for verbal quotes, business purpose, itemized receipts, and attendee/recipient lists.

• Define required fields on the Money Request Form.

• Train personnel after updates.

Management Response: District agrees; will remove Policy 3034 and update Policy 3016. Owner: Business Administrator & Accounting Director Estimated Completion: June 30, 2025

Recommendation 1.2 – Enhance Internal Audit Process for Purchases

BDO recommends validating:

• Pre‑approval via Money Request Form.

• Competitive quotes.

• TCSD shipping address.

• Documentation of receipt.

• Itemized receipts.

• Business purpose and attendees.

Management Response: District agrees. Owner: Accounting Director & School Accountant Estimated Completion: April 30, 2025

Recommendation 1.3 – Convert Pcard Logs to Electronic Format

BDO recommends:

• Electronic logs (e.g., Excel).

• Identify program for each checkout.

• Reconcile logs to statements.

• Monitor checkout duration and frequency.

• Address non‑compliance.

Management Response: District agrees. Owner: Accounting Director & School Accountant Estimated Completion: April 30, 2025

Recommendation 1.4 – Update Travel Authorization Guidance

BDO recommends:

• Clarify Policy 3034 does not apply to employee travel associated with student overnight travel.

• Update travel proposal form to match Policy 5001 (submit 45–180 days prior).

Management Response: District agrees. Owner: Director of Athletics and Activities Estimated Completion: June 30, 2025

Recommendation 1.5 – Audit Travel Authorization Forms

BDO recommends enhancing internal audit to ensure travel forms are complete and maintained.

Management Response: District agrees. Owner: Accounting Director, School Accountant, Director of Athletics and Activities, Area Directors Estimated Completion: April 30, 2025

Recommendation 2.1 – Update Fundraising Policy 5006

BDO recommends:

• Clarify approvers (school admin, Community Council, District).

• Require approval before campaign start.

• Document procedures for fundraiser request forms.

• Require consolidated documentation packets including:

  • Approved request

  • Financial summary

  • Receipts listing

  • Reconciliation to items sold

  • Expenditure listing

  • Participation logs

• Require financial outcome documentation in SuccessFund.

• Train personnel.

Management Response: District agrees. Owner: Accounting Director, School Accountant, Director of Athletics and Activities Estimated Completion: June 30, 2025 (policy), August 31, 2025 (training)

Recommendation 2.2 – Internal Audit Monitoring of Fundraisers

BDO recommends monitoring:

• Pre‑approval.

• Documentation packet completeness.

• Accuracy of SuccessFund entries.

• Non‑compliance follow‑up.

Management Response: District agrees. Owner: Accounting Director, School Accountant, Director of Athletics and Activities Estimated Completion: December 31, 2025

Recommendation 2.3 – Collaborate with SuccessFund

BDO recommends:

• Add program name field.

• Allow attachments.

• Resolve discrepancies between request forms and reports.

• Obtain configured reporting.

Management Response: District agrees. Owner: School Accountant Estimated Completion: December 31, 2024

Recommendation 3.1 – Define Rebate Activity Expectations

BDO recommends determining whether rebates should be considered fundraising and updating Policy 5006 or creating a new policy to define:

• Approval requirements

• Authority to enter agreements

• Documentation requirements

• Acceptable use

• Monitoring of earned and used rebates

• Non‑compliance procedures

• Training

Management Response: District agrees. Owner: Business Administrator Estimated Completion: June 30, 2024

Recommendation 4.1 – Periodic Policy Review

BDO recommends implementing a periodic review process for policies.

Management Response: District agrees; 7‑year cycle implemented. Owner: Policy, Property, and Legal Affairs Director Estimated Completion: Completed

Appendix A – Work Performed, Results, and Recommendations

1. Review of Athletic Program Purchases

Purchasing Policy Review

Policies 3016 and 3034 contain inconsistent thresholds and requirements. Full table of discrepancies is preserved in the extracted text.

Purchase Testing Results

117 purchases tested (SHS 62, THS 55). Exception rates included:

• Missing documentation: 2

• Missing Money Request Form: 2

• Late or undated approval: 11

• Insufficient date support: 8

• Altered approved amounts: 5

• Exceeded approved amount: 9

• Missing competitive quotes: 2 of 3

• Goods shipped to residences: 8 of 26

• Packing slips not initialed: 26 of 26

• Insufficient receipt detail: 13

• Missing attendee/business purpose documentation: 39

Additional issues:

• Inconsistent vendor identification

• Inconsistent detail on request forms

• Spouses submitting requests

• Internal audit process exists but needs enhancement

2. Review of Fundraising Activity

Policy Review

Policy 5006 requirements summarized. Practice differs from policy in several areas. No defined expectations for documentation or financial outcome tracking.

Fundraiser Request Review

30 fundraisers reviewed (15 SHS, 15 THS). 22 of 30 had approval issues:

• 3 missing documentation

• 11 missing proper approvals

• 8 approved after start date

Fundraising Receipts Review

29 fundraisers completed during review period. Accounting could not identify receipts for 13 of 29 fundraisers. Participation logs not maintained. Financial outcomes not readily available.

3. Review of Rebate Activity

No policy or process exists for rebate agreements or monitoring. SHS had six rebate agreements with four vendors. Executed copies missing for three agreements. BSN rebates could not be fully analyzed due to missing detail. Other rebates ranged from $200–$2,500 per year.

4. General Policy Review

Policies reviewed with revision dates:

• 3016 Small Purchases (2021)

• 3034 Cash Disbursements (2015)

• 3035 Cash Receipts (2013)

• 5006 Fundraising (2018)

• 5001 Student Travel (2024)

Printable Bullying and Hazing Review Report

Tooele County School District Bullying and Hazing Review October 2024

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303 E. 17th Avenue, Suite 600 Denver, CO 80203

December 3, 2024 Board of Education Tooele County School District 92 Lodestone Way Tooele, Utah 84074

Dear Board of Education and Dr. Mark Ernst,

We have completed our review of the Tooele County School District's ("District") Policies and Procedures for the Bullying and Hazing Program. We want to thank you and the District employees for your assistance and support. Below is our report on the work we performed and recommendations. The results of the Bullying & Hazing Audit were discussed with Mat Jackson, Student Services and District Activities Director.

BDO USA BDO USA, P.C.

CC: Tooele County School District Board of Education

Tooele County School District Bullying & Hazing Audit Report October 2024

Background

BDO was engaged by Tooele County School District ("District") to provide Internal Audit services under the direction of the District's Board of Education. As part of that engagement, BDO performed a review of the District's Bullying & Hazing policies, processes, and procedures.

Standards and Guidance

Our review was based on the Institute of Internal Auditor's (IIA) International Professional Practices Framework (IPPF), which includes the Core Principles for the Professional Practice of Internal Auditing, Definition of Internal Auditing, Code of Ethics, and the International Standards for the Professional Practice of Internal Auditing (Standards).

Overall Objective

The primary objective of the Bullying and Hazing Review was to determine if Policies and Procedures for the Bullying and Hazing program supported compliance with the following Utah State Regulations:

• Utah Admin. Code R277-613 - LEA Policies and Training Regarding Bullying, Cyber-bullying, Hazing, Retaliation, and Abusive Conduct

• Utah Code Section 53G-8-209 - Extracurricular activities - Prohibited conduct - Reporting of violations - Limitation of liability

• Utah Code Section 53G-3-501 - State board to establish miscellaneous minimum standards for public schools

• Utah Code Section 53G-9-605 - Bullying, cyber-bullying, hazing, abusive conduct, and retaliation policy

• Utah Code Section 53G-9-606 - Model policy and state board duties

In addition, procedures were performed to determine if processes surrounding bullying and hazing were effective and if they followed District policies.

Scope

The scope of the project included a review of the following activities during the school years ending 2022 and 2023, unless otherwise noted:

1. District policies including prohibition on bullying, cyber-bullying, hazing, retaliation, abusive conduct, and making a false report.

2. The methods in which the policies were published as of October 2023 (date of observation).

3. Annual acknowledgements of the policies for a sample of employees, students (at least 8 years old), and parents.

4. Documentation of training for a sample of employees, volunteers, and students.

5. The District's process to manage incident reports including the methods to receive incident reports, investigate incidents, and development of action plans to address them. In addition, documentation for a sample of incidents was reviewed to determine if the incident management process was followed.

6. Annual reporting to the State Superintendent including the District's policies, implementation of signed statements (acknowledgement), training of employees, verified and alleged incidents of bullying, cyber-bullying, hazing, retaliation, and abusive conduct, etc.

Based on direction of the Audit Committee, the following nine schools were included in the scope of review for publishing of the policies, student and parent acknowledgements, student training, and in the incident management process:

Elementary: Copper Canyon Elementary School; Grantsville Elementary School; Middle Canyon Elementary School Junior High: Clarke N. Johnsen Junior High; Grantsville Junior High; Tooele Junior High High School: Grantsville High School; Stansbury High School; Tooele High School

Summary of our Observations and Recommendations

The attached matrix includes a summary of recommendations from the review and Management responses. Appendix A includes details of the work performed, results, and recommendations.

Recommendations and Management Responses

District Policies — Recommendation 1.1

We recommend the District consider merging policies 6032 - Student Prohibition of Bullying, Cyber-Bullying, Harassment, Hazing and Retaliation and 4030 - Employee Prohibition of Bullying, Abusive Conduct, Hazing and Cyber-Bullying to provide one consistent policy that employees, students, and parents can refer to for guidance. In addition, having one policy reduces the risk of outdated or inaccurate guidance due to version control (ex. if one policy is updated, but not another).

Management Response: The recommendation to merge the policies will be considered by the Policy Committee. If not merged, policies will be updated to ensure that they are consistent. The District agrees with and will implement the recommendation. Implementation Owners: Student Services Director; Director of Policy, Property and Legal Services. Estimated Completion Date: July 31, 2025.

District Policies — Recommendation 1.2

We recommend the District review the areas of non-compliance with regulatory requirements identified by BDO, assess the need for policy updates, and update the related policy(s) as needed. In addition, BDO recommends that the District review these policies against regulations, annually at a minimum, to identify and complete modifications that may be required.

Management Response: R277-613 requires a review of policies regularly with input from stakeholders, however, does not include a required frequency for the review. The recommendation for an annual review will be considered by the Policy Committee, and an appropriate frequency of review, based on risk, will be established. The District agrees with and will implement the remainder of the recommendation. Implementation Owners: Student Services Director; Prevention Coordinator; Human Resources Director; Director of Policy, Property and Legal Services. Estimated Completion Date: July 31, 2025.

Methods in Which the Policy is Published — Recommendations 2.1, 2.2, 2.3

Recommendation 2.1: Require all schools to include a functional link to Policy 6032 in their student handbook and on their website. Management Response: Agreed. Implementation Owners: Area Directors; Executive Secretary; Webmaster. Completion: July 31, 2025.

Recommendation 2.2: Review the Secondary Handbook used by Tooele High School and Grantsville High School to determine if it should be used by all high schools. Management Response: Agreed. Implementation Owners: Area Directors; Webmaster. Completion: July 31, 2025.

Recommendation 2.3: Implement an annual review of school websites and handbooks to validate that Policy 6032 is appropriately linked and accessible. Management Response: Agreed. Implementation Owner: Webmaster. Completion: July 31, 2025.

Annual Acknowledgements — Recommendations 3.1 and 3.2

Recommendation 3.1: Implement employee acknowledgement of Policy 4030 within Safe Schools for new hires and annual training. Management Response: Implemented June 2024. Complete.

Recommendation 3.2: Implement a process to monitor completion of acknowledgements by employees, students (8+), and parents. Management Response: Agreed. Implementation Owners: Safety Director; Student Information Specialists. Completion: July 31, 2025.

Documentation of Training — Recommendations 4.1 through 4.5

Recommendation 4.1: Standardize student training curriculum and documentation of attendance. Management Response: Agreed. Training approach determined by July 31, 2025; rollout first week of 2025–2026 school year. Completion: September 30, 2025.

Recommendation 4.2: Review and update employee training to comply with R277-613-4(6). Management Response: Agreed. Completion: July 31, 2025.

Recommendation 4.3: Implement training for volunteers. Management Response: Agreed. Implementation Owner: HR Director. Completion: July 31, 2025.

Recommendation 4.4: Review UHSAA training requirements and implement tracking and monitoring. Management Response: Agreed. Implementation Owners: District Athletic Director; Student Services Director; Director of Policy, Property and Legal Services. Completion: July 31, 2025.

Recommendation 4.5: Update Policy 4030 to define frequency of investigator training and implement documentation of attendance. Management Response: Agreed. Implementation Owners: Human Resources Director; Director of Policy, Property and Legal Services. Completion: July 31, 2025.

Process to Manage Incident Reports — Recommendations 5.1 through 5.5

Recommendation 5.1: Implement a flag in Educator’s Handbook for CMT-reportable incidents and update Minor/Major Behavior Definitions. Management Response: System cannot implement flag; process will be implemented manually. Tipsheet revised. Completion: July 31, 2025.

Recommendation 5.2: Develop procedures for civil rights investigations and documentation expectations. Management Response: Agreed. Completion: July 31, 2025.

Recommendation 5.3: Provide training to employees once updated policies and procedures are complete. Management Response: Agreed. Completion: September 30, 2025.

Recommendation 5.4: Implement monitoring process to review incidents for adequate investigation, documentation, and correct offense assignment. Management Response: Agreed. Completion: July 31, 2025.

Recommendation 5.5: Add Speak Up link to parent/public-facing areas of the District website. Management Response: Agreed. Completion: July 31, 2025.

Annual Reporting to the State Board — Recommendations 6.1 through 6.4

Recommendation 6.1: Maintain a copy of annual assurance reporting. Management Response: Agreed. Completion: July 31, 2025.

Recommendation 6.2: Work with USBE to determine expectations for accurate UTREx reporting and adjust systems accordingly. Management Response: Agreed. Completion: July 31, 2025.

Recommendation 6.3: Reconcile Educator’s Handbook incidents to UTREx incidents. Management Response: Agreed. Completion: July 31, 2025.

Recommendation 6.4: Review UTREx File Specification guidance annually. Management Response: Agreed. Completion: July 31, 2025.

Printable CTE Final Report

CTE Report – Tooele County School District March 9, 2021 and December 6, 2018 Reports

Tel: 801-269-1818 Fax: 801-266-3481 299 South Main Street, 10th Floor Salt Lake City, UT 84111 www.bdo.com

March 9, 2021 Tooele County School District Audit Committee 92 Lodestone Way Tooele, UT 84074-8050

RE: Report on Completion of CTE Program Review

Committee Members,

Background

In the Summer of 2018, PBTK, LLP (PBTK) was engaged to review the Tooele County School District's (TCSD) Career and Technical Education (CTE) Program. In December 2018, PBTK issued an interim report on our findings. That report is attached to this correspondence.

In July 2020, PBTK was acquired by BDO USA, LLP (BDO), with the primary PBTK staff assigned to TCSD continuing in the same positions with BDO. Consequently, any follow up work after July 2020 would be with BDO.

The primary reason we issued an interim report in 2018 is due to the District's then-recent appointment of a new CTE Director (CTE Director, which is also the current CTE Director). Fairly early in our review, we determined, along with Audit Committee and District Management input, the best course of action for this review was to issue an interim report, with periodic follow up on progress.

We determined early on there were a few areas under the direction of the CTE Director that needed some additional time and attention to meet general program standards. So rather than issuing a report with several potential findings, we would help introduce the CTE Director to some risk analysis techniques and tools that would assist her in improving the internal controls over the CTE program. And from time to time, we would follow up on progress.

Our latest follow up with the CTE Director was on March 1st, 2021. Since December 2018 we have had several follow up meetings with CTE, including at least one where the CTE Director informally presented her progress to the Audit Committee.

In 2020, the Audit Committee requested that the 2018 CTE Program Review be completed. This communication is in response to that request. We consider this report to be the concluding report for the review that began in 2018. However, we are committed to performing any additional follow up or testing as requested.

General Conclusion

As a general conclusion on this review, we believe the approach we took was the best course of action. First, this approach gave the new CTE Director time to understand the breadth, depth, nuances and scope of the CTE Program, not just from a risk perspective, but also from an operational perspective.

Writing a potentially findings-riddled internal audit report shortly after the CTE Director was appointed may have been too overwhelming, as she tried to learn her new position operationally and dealt with addressing an internal audit report demanding immediate management response and action.

Each time we have followed up with the CTE Director we have noted she has a greater perspective, comprehension and mature appreciation of the risks and operations of the CTE Program. She has gone from being almost overwhelmed with internal audit concepts and approaches, to confidently identifying and addressing risks.

Second, by introducing the new CTE Director to some risk analysis techniques and tools, she has applied these techniques and tools to her naturally-accumulated knowledge of the CTE Program, thus greatly improving the likelihood risks would be identified and better internal controls could be developed and implemented.

Primary Risk Analysis Techniques and Tools

During the initial phases of this review in 2018, we suggested to the CTE Director that we assist her in developing a Risk/Control Matrix (RCM) for the CTE Program. Once we had introduced the CTE Director to the concepts of an RCM, we would periodically check with her on the progress of utilizing the tool.

An RCM is a common tool employed by internal auditors. The primary use of an RCM is, as the name suggests, a way to identify risks (usually designated as risk statements) within an organization, department or function and linking the risks to specific internal controls used to mitigate risks.

The representation of this RCM is a spreadsheet we assisted the CTE Director develop. Our first step in developing this RCM was to brainstorm with the CTE Director and several key District personnel (RCM Group) involved with the CTE Program. We initially brainstormed about risks without consideration of associated risks. Linking internal controls to specific risks comes later in the process.

With the help of the RCM Group the second step in developing the RCM was to categorize each risk into a general category. For this RCM and the CTE Program, we identified approximately 45 risk statements. Some examples of these risk statements include:

• Potential fire and other safety code violations

• Ineffective training for teachers and students regarding accident procedures

• Inadequate teacher and student training on equipment

• Missing parental approval for CTE programs or related travel

• Insufficient teacher supervision

• Improper cash handling

• Purchasing process or classroom materials

• Non-compliance with federal, state, local or district policies and procedures

Each of these risk statements were categorized into one of the following five categories:

• Accidents, Insurance and Safety Procedures

• Travel Concerns – For Same Day and Overnight

• Classroom Management

• Finances – Money Handling and Budget

• Compliance

The next step, once risk statements were developed and categorized, was to consider what internal controls should be employed to mitigate each risk statement. Actual testing of what internal controls are employed and their design and operational effectiveness would follow once the RCM was fully developed.

Determining the “Ownership” of internal controls was next identified. Often there were multiple and outside District internal control owners. For example, some controls, such as number of students allowed into a certain program, is a state-determined control; ensuring compliance with these policies is a CTE program responsibility. Training for students would fall under the responsibility of the teachers, guided by District policies, and confirmation the teachers were qualified and certified to provide the training fell within the responsibility of the CTE Director and Program administrators.

This exercise of determining internal control owner(s) further focused attention on risks and controls. From what source does an internal control emanate, such as legislation, District policy, District Handbook, etc., were next identified. This exercise in determining the source of the internal control allowed for an analysis of the adequacy and coverage of internal controls.

The next steps in this process involved determining how, when, how often and by whom internal controls would be tested. During our periodic follow up meetings with the CTE Director, we would discuss the overall progress in testing and evaluating internal controls as outlined in the RCM. We would also review evidence (e.g., newly developed policies, training programs, etc.) of testing that was performed.

Techniques and Tools Conclusion

As we discussed above, we believe the approach we took with regards to this review was the right approach, conceptually. However, the execution of this approach also needs to be considered. Based on our several follow up meetings with the CTE Director since December 2018, which included interviews and observations of control testing performed and control implementations, we believe the execution of the techniques and tools meets the expected requirements of the CTE Director and CTE Program to reasonably consider Program risks and implement and test internal controls.

BELOW IS THE ORIGINAL REPORT ISSUED IN DECEMBER 2018

CTE Program Assessment – Interim Report December 6, 2018

Table of Contents

Career and Technical Education Assessment – Page 8 Nature of this Report – Page 8 Overall Project Objective and Approach – Page 8 Consultative Approach – Page 8 Initial Recommendations – Page 8 Risk Assessments and Go-Forward Plans – Page 9 Interim Conclusion – Page 10 A Few Words About the New Director and Her Staff – Page 10 Appendix – Page 12 Organization Chart – Page 12 Job Descriptions – CTE Director Responsibilities – Page 13 Job Descriptions – CTE Area Coordinator Responsibilities – Page 14 Job Descriptions – CTE Specialist Responsibilities – Page 15 Job Descriptions – Teaching & Learning Secretary Responsibilities – Page 16 Job Descriptions – School Work Based Learning Coordinator Responsibilities – Page 17

Article I. Career and Technical Education Assessment

Section 1.01 Nature of this Report

This report is deemed an interim report. The primary reason it is deemed an interim report is there is still work to do on improving the oversight of the Career and Technical Education (CTE) Program. Significant progress has been made, and there is an opportunity to more fully evaluate the program in the coming months as the improvements that are being made have had time to be more fully developed and implemented.

This interim report is as of December 6, 2018. Additional review of the program should occur in the Fall of 2019, with a more formal and complete report offered at that time.

Section 1.02 Overall Project Objective and Approach

As we began this project in the Summer of 2018, the primary objective was to gain an understanding of the then-current Career and Technical Education (CTE) Program for the district, and then decide on an appropriate approach to evaluate the program.

Our two primary options were to perform a formal internal audit of the program, or to engage in a more consultative role where we examine where the program currently stood and make recommendations for future direction. After our initial consultations with the program leadership and CTE staff, the latter approach was deemed most appropriate.

Our reason for choosing a consultative approach rested primarily on the fact that there have been recent, significant changes in the CTE program, particularly the recent hiring of a new CTE Director and some staff. Likewise, our initial consultations confirmed that the program as it then stood would benefit more by establishing the program’s current status and where it wanted to go, rather than performing an internal audit.

An internal audit would have likely resulted in a significant number of findings based on the past, where compliance with incomplete or dated federal, state or district policies, procedures and program transactions may have been significantly lacking. An internal audit would be mostly backward looking; a consultative approach would be mostly forward-looking.

Section 1.03 Consultative Approach

(a) Initial Recommendations

Our first recommendations were related to the overall structure of the CTE Program. We recommended the new director create an organizational chart and job descriptions for the program and her staff. These were created and we reviewed them for reasonableness. They are available in the Appendix of this report.

The key to this organization chart is that it be approved at the proper level of the district and that it be communicated to those whom it affects.

Our second set of recommendations centered on sustaining the compliance aspects of the program. Our recommendation was that the new CTE Director identify areas that could benefit by having a periodic review for compliance by someone internal to the district and/or the CTE program. For example, the state has a requirement that only a certain number of students be admitted to the nursing program each year. The internal compliance person could review the records of the nursing program to ensure the program is in compliance with state rules prior to any state review.

This recommendation is currently being developed and implemented. See the discussion below in the Risk Assessment Go-Forward Plans section.

(b) Risk Assessments and Go-Forward Plans

The most significant effort of this project involved assessing where the program was and where it is headed. The primary tool we used to make this assessment was a risk assessment by using a Risk and Control Matrix.

The risk assessment process began with a discussion between PBTK and a cross-section of CTE personnel. It then included a relatively comprehensive group of CTE management and program administrators organized by high schools who gave their input as to the greatest risks faced by the program. The process concluded with a smaller group of CTE Program administrators and PBTK who organized the broad risk universe into a comprehensive risk evaluation tool (Risk and Control Matrix).

In short, the risk evaluation tool is a matrix (Excel Spreadsheet) which included a risk universe for the CTE Program, and categorizes all risks into one of five general categories (1. Accidents, Insurance and Safety Procedures; 2. Travel Concerns; 3. Classroom Management; 4. Finances including Money-Handling and Budgets; 5. Compliance), identifies controls for each risk (in all there were about 50 risks spread out over the five risk categories), establishes who is responsible for the related controls (the district, the CTE Program, the state, etc.), states which specific policy(s) or procedure(s) are the controlling authority to mitigate the risks, and provides go-forward plans and notes for the respective risks. Additionally, the CTE administration began compiling a CTE Program Handbook which directs CTE personnel in how to address various matters within the CTE Program, and establishes if, how and when the CTE Program would evaluate and test the respective internal controls in an on-going basis.

For example, in the Accidents, Insurance and Safety Procedures Risk Category, fire and safety code violations were identified as a risk. The related controls pertained to the annual facility director’s inspection. Ownership of this control was deemed to be the district as a whole, rather than the CTE program, and the guiding policies and procedures were district policies (Building Administrator Duties, Policy #2004). How to address fire and other safety risks is included in the CTE Program Handbook and distributed to CTE personnel. Finally, the CTE Program will include a review of the policies and procedures over fire and safety code policies every three years at a safety meeting.

Another example is in the Compliance Risk Category. The risk is not ensuring CTE teachers have respective certifications. The ownership of monitoring the controls (ensuring teachers are certified) is the CTE Program. The responsibilities for certifications will be contained in the CTE Program Handbook, a teacher certification checklist is being developed by CTE in coordination with HR, and HR/CTE will review certification compliance and progress on an annual basis.

The Risk Control Matrix is still a work in progress, but is largely completed. The first draft of this is available for review by the Audit Committee by request.

Finally, due to the fact this process is still in progress, a follow-up review should be conducted sometime in the Fall of 2019 by internal audit in order to assess progress.

Section 1.04 Interim Conclusion

Significant improvements to the CTE Program have been made in recent months. The overall CTE Program structure and oversight have been discussed and improved upon. This has been accomplished by hiring a new CTE Director and developing clear lines as to her responsibilities and authority. The “clear lines” are established through the creation and approval of an organization chart and job descriptions for CTE Program support staff.

Likewise, the program has been assessed from a risk and control perspective, and these considerations have been addressed by identifying who is ultimately responsible for the respective controls (state, district, CTE Program, etc.) through which means (specific policy, CTE Program Handbook, etc.), and consideration has been given as to how, when and what portions of the program are subject to periodic review from a compliance perspective.

There is still work to do; the Risk and Controls Matrix is mostly developed. The handbook is still a work in progress. There are still positions to fill and there is still an opportunity to implement some of the new changes and test them accordingly. Consequently, we recommend that the CTE Director and her staff continue with their development of program components and a more final review and report be developed in the Fall of 2019.

Section 1.05 A Few Words About the New Director and Her Staff

We found the new CTE Director and her staff to be very cooperative, open and willing to examine how best to serve the district in developing and running the CTE Program.

They worked very hard at incorporating thoughts and ideas about how to improve the program from a broad range of CTE participants. They used their insight and experience to delve into the risks and controls associated with the program. Their efforts resulted in a comprehensive Risk and Control Matrix that examined many of the challenges faced by the program, as well as gave a framework for continuing to improve the program.

Their challenge now will be to continue to develop and complete the Risk and Control Matrix and the relevant supporting components such as the CTE Program Handbook and review procedures for aspects of the program that fall within their purview. If their past efforts are any indication, they will certainly be successful in their continued efforts.

Article II. Appendix

Section 2.01 Organization Chart

(Note: Original chart contained images and formatting not readable in plain text. All text labels from the chart are included below.)

CTE Organizational Chart (text labels only):

• Principal

• Procedural Developer

• Kristy McLachlan, CTE Director

• SHS Coordinator – Lix Delton

• 73 Coordinator – Rick Herrtech

• CLC Coordinator – Brintthl Rounds

• THS Coordinator – Bob Gowns

• Specialist – Michle Carr

• Additional labels included but illegible in source due to image distortion.

Section 2.02 Job Descriptions – CTE Director Responsibilities

Budgets:

• Track all CTE budgets including Perkins, CCA grant, WBL grant and state add-on funding

• Budget planning for schools in connection with all CTE programs

• Skills testing budgets

• CTE Audit

Support HR in following CTE teacher qualifications and the CTE data quality on the data gateway.

CTE programs and scheduling of courses in TCSD.

State CTE Director meetings (quarterly).

Serve as a region representative for one state CTE committee.

Region CTE Director meetings.

Support and plan Wasatch Front South CTE region activities and professional development.

CTE Pathways:

• Meet regularly with individual CTE departments to implement Pathways

• Work with school counselors, administrators, and teachers to implement effective ways to guide students into pathways that will work for them

• Work with regional development of Pathway Implementation

• Create marketing material for Pathways

CTE Professional Development:

• Coordinate and plan and attend meetings for CTE Professional Development for CTE teachers at a district level

• Support CTE summer and winter conferences that are held for CTE professional development

• Coordinate and plan CTE Professional Development on a region level

Responsible for the marketing of CTE programs and providing information on the CTE programs and pathways available to students. Provide CTE activities that will help advocate for CTE and career exploration:

• CTE open houses, Reality Town/CTE rotations, Corridor Days, Pathway nights

• Region activities such as the Health Care Fair, Pathways to Professions, Engineering Fair

Serve as a team member on the industry-led CTE pathways specifically Diesel, MIP and Aerospace pathways.

Develop new CTE programs and offerings that would benefit the students of TCSD.

Grant writing:

• Perkins

• Special Projects

• STEM Grants

• Work-based Learning

• College and Career Awareness

CTE 5-year plans and yearly updates in conjunction with state CTE program approval.

Printable HR Final Report

HR Report – March 9, 2021

Tel: 801‑269‑1818 Fax: 801‑266‑3481 299 South Main Street, 10th Floor Salt Lake City, UT 84111 www.bdo.com

March 9, 2021 Tooele County School District Audit Committee 92 Lodestone Way Tooele, UT 84074‑8050

RE: Report on Completion of HR Review

Committee Members,

Background

In the spring of 2018, PBTK, LLP (PBTK) was engaged to review the Tooele County School District’s (TCSD) HR Department, with specific emphasis on teacher retention. In June 2018, PBTK issued a draft report on its findings. That report is included with this correspondence.

In July 2020, PBTK was acquired by BDO USA, LLP (BDO), with the primary PBTK staff assigned to TCSD continuing in the same positions with BDO. Consequently, any follow‑up work after July 2020 would be with BDO.

During the initial review, the recruiting process was broken into four sub‑processes: Budgeting, Recruiting, Retention, and Employee Separation.

The review was heavily data‑driven. Recruiting, Retention, and Employee Separation data from FY 2012 through FY 2017 was requested, primarily to determine what data was available and how it was used to develop an overall recruiting strategy.

The HR Department had a great deal of recruiting information, but it was not optimally organized, compiled, stored, or connected. The initial report provided several examples of data disorganization observed during the review. Follow‑up meetings were suggested over the next few years to monitor progress in more optimally organizing, compiling, storing, and connecting recruiting data.

Initial Observations

The review concluded that the HR Department had an opportunity to better use the vast amounts of data it collects in the recruiting process to better position the District in determining where best to recruit and how best to retain quality teachers.

It was also suggested that recruiting data should be consolidated into a single tool, such as a continually updated spreadsheet or database, for better and more convenient access to all recruiting data.

Similarly, by linking demographic data—such as teacher and college/university—to Retention and Employee Separation data, HR would gain a better picture of how long a recruit remains with the District, the reasons for separation, and what criteria define a “successful” recruiting effort.

The initial observation was that HR had this data, but it was not always easily linked and utilized. Since 2018, periodic meetings were held with HR to assess progress on the recommendations. In 2020, the Audit Committee requested that the review be formally completed.

Review Conclusion

The latest meeting with HR regarding this review was conducted on Monday, March 1, 2021. At this meeting, the recruiting data collection tool was formally discussed. HR provided a copy, and the data was reviewed and manipulated to provide a complete picture of the recruiting process.

The tool is well designed, well organized, comprehensive, and easy to use. It is currently populated with two sets of data: one set stretching back before FY 2016, and a compilation of data from FY 2016 through FY 2021. The FY 2016–FY 2021 data is the most relevant and applicable for current recruiting processes, though the pre‑FY 2016 data can also be assembled and reviewed.

Simple manipulations of data using Sort or Pivot Table functions provide various views of the data that can be utilized in the overall recruiting process.

The conclusion is that HR has successfully developed a link between Recruiting, Retention, and Employee Separation data that will enable more effective decision‑making about how, when, and where to recruit. HR has also established criteria to help guide determinations of what constitutes a successful recruit.

The sections below provide greater detail of the initial review.

Initial Review Objectives

The primary objective for the 2018 review was to ascertain what data was available and subsequently used to drive teacher recruiting for the District, and what “success measures” should be used in recruiting efforts.

Unique Challenges

During preliminary work, it was learned that TCSD is in a unique situation regarding teacher recruiting.

TCSD is located in a valley approximately 25 miles west of the Salt Lake Valley and approximately 50 miles west of Utah Valley. These two valleys, along with Davis County and Weber County to the north, constitute the primary population center of Utah, commonly referred to as the Wasatch Front.

This approximately 100‑mile stretch, from Ogden in the north to Provo in the south, includes several universities from which to recruit teachers: Weber State University, University of Utah, Utah Valley University, and Brigham Young University.

Farther north in Logan, Utah State University offers recruiting possibilities, and farther south in Cedar City, Southern Utah University trains prospective teachers.

In the Salt Lake Valley, Westminster College and Salt Lake Community College also offer teacher recruiting possibilities.

Although there are many colleges and universities within 100 miles of Tooele, these institutions are often closely linked with their respective communities and school districts. The Wasatch Front is home to the vast majority of Utah’s population, K‑12 students, and the 10–20 largest school districts in the state.

Although many current and past TCSD teachers have come from Utah colleges and universities, TCSD has had to be creative in filling yearly teaching slots. One method has been active out‑of‑state recruiting. This unique feature of TCSD’s recruiting needs was part of the reason for the review.

Review Approach, Procedures, and General Scope

The review was highly data‑driven. Early on, it was established that the overall recruiting process consisted of four sub‑processes:

• Budgeting for Teacher Recruiting

• On‑campus and other Teacher Recruiting efforts

• Retention (providing incentives for teachers to remain in the District)

• Employment Separation

Although budgeting is a key component of the recruiting process, it was formally scoped out of the review. The Board generally provides the necessary budget to accomplish recruiting goals, and the recruiting budget is relatively small compared to the overall HR budget. If significant incompatible results had been identified, the budgeting process could have been reviewed later.

It was theorized that data from Recruiting, Retention, and Separation should be linked to gain a better picture of the overall teacher recruiting effort.

HR was also asked what defines a “successful recruit”—specifically, how long a good teacher needs to remain with the District to justify recruiting dollars spent. The general answer was that HR is satisfied if a good teacher remains for at least one year, even though they prefer good teachers to stay longer. The idea is that recruiting dollars are justified if a good teacher stays at least one year.

During the 2018 review, simple demographic recruiting information was requested for FY 2013 (July 2012–June 2013) through FY 2017 (July 2016–June 2017). This included name, college/university attended, hire date, assigned school, and similar data. The data was sorted and analyzed to identify trends and other recruiting information, primarily related to where recruits came from.

Retention efforts were also discussed. HR employs bonuses and other monetary and non‑monetary incentives in its recruiting and retention efforts.

Employee Separation data was requested, reviewed, sorted, and analyzed. The general observation was that there were too many separation categories to provide meaningful analysis of why employees left the District.

The final overall observation was that Recruiting, Retention, and Employee Separation data was available but not optimally organized to maximize the District’s teacher recruiting effort. The initial report is provided with the correspondence.

Printable IT Assessment Final Report

Education Elevated Tooele County School District

Internal IT Assessment

Prepared by: Piercy Bowler Taylor & Kern Sam Belnap 1/23/2016

EXECUTIVE SUMMARY

IT Assessment Results

• Manage Strategy / Architecture / Innovation / Portfolio

• Manage Suppliers

• Manage Solutions Identification and Build

• Manage Changes

• Manage Operations

• Manage Service Requests / Incidents and Problems

• Manage Continuity

• Manage Security Services

• Manage the IT Management Framework

• Manage Budget and Costs

• Manage Programs and Projects

• Monitor, Evaluate and Assess

EXECUTIVE SUMMARY (Full Text)

PBTK performed a high‑level IT Assessment of the IT processes and procedures at Tooele School District. The assessment started on November 1st, 2016 and lasted three days. It did not include any testing or verification of processes, but rather a review of processes based on interviews and walkthroughs with the IT Team. The assessment was based on the Cobit Framework and included the following high‑level areas:

• Manage the IT Management Framework

• Manage Budget and Costs

• Manage Service Agreements

• Manage Suppliers

• Manage Programs and Projects

• Manage Solutions Identification and Build

• Manage Availability and Capacity

• Manage Changes

• Manage Assets / Configuration

• Manage Operations

• Manage Service Requests / Incidents and Problems

• Manage Continuity

• Manage Security Services

• Monitor, Evaluate and Assess

This assessment was conducted through primary interviews with Jim Langston, Alan Hansen, and Dolene Pitt, with additional input from various other staff members, physical walkthroughs, and process assessments. PBTK did not test or validate the effectiveness of the network, infrastructure, system, processes, or security controls.

PBTK found that the IT staff were very open to the audit and to change in general. However, many of the internal operating processes and strategic planning do not meet the generally accepted standards of the industry. During the review, 53 items were identified as needing improvement.

IT Assessment Results (Full List of Findings)

PBTK found 53 findings as a result of the internal IT Assessment. Below are these items as the recommended course of action. Any course of action may require additional review, as a short few‑day review will not uncover the detailed issues of each area—only whether an area is functioning or not.

1. Manage the IT Management Framework

1.1 System / Application ownership has not been defined

Description: Critical systems and applications should have a defined owner. This individual or role provides oversight and direction, including providing or removing access, changing group permissions, conducting access reviews, discussing upgrades, and helping determine security risks.

1.2 Data definitions / ownership has not been defined

Description: Understanding and managing data is a critical function in any business. For Tooele School District this takes on special responsibility due to the critical nature of student information.

1.3 Policies and procedures are not complete and/or fully updated

Description: Policies and procedures are critical for documenting and maintaining standards. They provide a methodology to document and refine the inherent knowledge gained during day‑to‑day activities.

2. Manage Strategy / Architecture / Innovation / Portfolio

2.1 IT and the business are not fully aligned

Description: Alignment of IT and business is imperative to the appropriate use of technology, security of student and district information, and alignment of both short‑ and long‑term goals.

3. Manage Budget and Costs

3.1 Current budgeting practices can impact the effectiveness of IT and hinder long‑term improvements

Description: Budgeting for IT software and hardware can originate in many places—schools, district departments, external funding, or the IT budget itself. When budgeting occurs outside of IT, communication about software and hardware purchases is not sufficient.

4. Manage Programs and Projects

4.1 IT projects are managed directly by staff without a project management methodology

Description: Appropriate project management allows human and hardware resources to be utilized more effectively. Defined requirements, milestones, timelines, and costs help ensure projects meet long‑term goals.

5. Manage Suppliers

5.1 Vendor management program is not in place

Description: A vendor management program enables IT to review potential vendors and manage their access appropriately.

6. Manage Solutions Identification and Build

6.1 Policies, procedures, and documentation for internally developed programs do not exist

Description: Internal development can be powerful, but requires an SDLC (Software Development Life Cycle) to ensure requirements development, testing, code documentation, and user documentation.

7. Manage Changes

7.1 Change management and patch management are verbally implemented but not documented

Description: Change and patch management maintain system integrity, ensure smooth operations, and help predict necessary downtime.

8. Manage Operations

8.1 Daily operations are mostly managed appropriately with exceptions

Exceptions include log management, new hire/termination processes, and service accounts.

9. Manage Service Requests / Incidents and Problems

9.1 An incident response plan does not exist

Description: An incident response plan outlines what must be done in the event of a breach, including who can declare an incident and who must be notified internally and externally.

10. Manage Continuity

10.1 Restoration testing and disaster recovery are not currently in place

Description: Continuity management—including backups, restoration, disaster recovery, and business continuity—is necessary for recovery of systems and data. Lack of these processes can leave the district unable to complete work when a problem occurs.

11. Manage Security Services

11.1 A number of security issues have been identified that could put the district at risk

Description: Security of systems is paramount. Security processes and policies should be reviewed to ensure they meet minimum acceptable standards.

12. Monitor, Evaluate and Assess

12.1 A listing of regulations applicable to the district has not been documented

Description: Regulations such as FERPA, GRAMA, CIPA, HIPAA, and PCI apply to school districts. Identifying and listing these items is critical to ensuring compliance.

Printable Payroll Report

Payroll Audit Report

Tooele County School District (All original wording preserved; formatting cleaned for web accessibility.)

Executive Summary

Objectives and Scope

Beginning in March of 2019, PBTK began working on a payroll project for the Tooele County School District (District). The primary objectives for the project were two-fold. First, perform standard internal audit procedures, which included testing for fraudulent payroll such as ghost employees, and internal controls testing which included observing processes to help determine proper segregation of duties and independent verification of pay.

To test for fraudulent payroll, we performed a series of tests including general analytical procedures, completeness of data, duplicate payments, Benford’s Law, etc. For proper internal controls testing we performed a walk-through of the payroll process, interviewed key Payroll, Accounting and HR personnel, and tested a number of employees’ actual pay as determined by direct deposits to HR and payroll-system generated information. We noted no significant exceptions or findings in our fraud or internal controls testing.

Our second objective was consultative in nature. For a number of years, the District has contemplated using a “Universal Time Card System” for all employees. PBTK was asked to offer our opinion on this undertaking based on procedures we designed and performed. Likewise, we were asked to review Overtime pay and develop procedures for both fraud/internal control-related auditing as well as consultative procedures.

The scope of this review included all three general types of employees – which is all District employees – and includes Time Card – Actual, Time Card – Balance and Work Agreement employees. Time Card – Actual employees are those who are currently using a time card system, and generally include food service or bus driver employees. Time Card – Balance employees are those who typically work less than full time year round, but who are paid “smoothed” or “balance” pay equally over a 12 month period, and are represented by a fairly broad swath of District employees. Work Agreement employees are those who work under a contract. These include teachers and administrators.

The scope also included payroll for about four fiscal years: 2016/2017 – 2018/2019 (most). The District’s fiscal years runs from July – June. Our audit began in March 2019, so our payroll scope for 2018/2019 went through July 2018 – March 2019. We selected this four-year period in order to be able to see trends and make observations based on payroll over a period of time.

General Statistics of Data Reviewed

For the review period, total payroll was just over $211 million. The table below shows the breakdown of the three employee types for the review period:

Payroll Category — Sum of Regular Pay — Sum of Overtime Time Card - Actual — 19,901,546$ — 272,939$ Time Card - Balance — 40,325,062$ — 468$ Work Agreement — 150,943,289$ — -$ TOTAL — 211,169,897$ — 273,407$

Based on the relatively small Overtime amount, we did not develop or perform any testing procedures over this type of pay.

Overall Observations

Fraud and Internal Control Observations

Generally speaking, we did not find any significant concern areas as we performed our testing procedures. We noted a handful of improvement opportunities, however:

Time Card – Actual: • There are nearly 400 separate employee jobs or positions lodged within the Time Card – Actual category. In terms of payroll dollars, this is by far the smallest employee category (only about $20 million of $211 million we reviewed) • There were a number of job categories or titles that seemingly did not relate to actual job positions. For example, we found payments for Job Enlargement, Extra Hours, Annual leave Payout • Likewise, we noted seemingly duplicate positions (Cleaner and Custodian) and “uncategorized” employees with payroll dollars attached (e.g. “Undesignated” and “(blank”)) • RISK: The relatively convoluted nature of the categories and payroll positions provide an opportunity for misapplication of payroll and present a more difficult process to identify anomalies or gather and analyze payroll data in order to better manage it

Time Card – Actual and Time Card - Balance: • Preparing for both monthly payroll and annual adjustments to pay levels and supplemental (payrolls in July/August to “smooth” payroll) pay require significant manual input which makes payroll more prone to error

All Payroll: • Overall, the current payroll data, and method to prepare it, is a bit cumbersome and does not easily lend itself to a process for identifying anomalies, or gathering and analyzing payroll data in order for management to better manage the processes or dollars

Consultative (Universal Time Card) Observations

Based on our observations, there are both pros and cons to utilizing a Universal Time Card System. They are listed below:

Pros – Some of these risks may be eliminated by a Universal Time Card System

• Currently there are relatively “weak” or “stretched” controls (principal/other management monitoring) over Time Card – Balance and Work Agreement employees who may want to “game the system” by not working their requisite hours. A Universal Time Card System may make it easier to monitor employees work habits • No clear data, or easy way to obtain data, to quantify the risk of Time Card – Balance and/or Work Agreement employees who may game the system • Some controls, i.e. cameras or other continuously-monitoring controls outside of a Universal Time Card System, may be cost-prohibitive. The District already has purchased and/or is using some form of a time card system. Adding to this system may be less costly than a potentially illegal camera-monitoring system • Payroll data is relatively difficult to obtain and manipulate for managerial review and use under the current system. A Universal Time Card System may provide the ability to more easily obtain and use key payroll data in order to better manage these processes

Cons – Potential pitfalls to using a Universal Time Card System

• Employee push-back • Two informal surveys with other school district clients – a mixed bag • Potential legal considerations • Inability of technology to address concerns of not having a Universal Time Card System • Disagreement on priorities for using a Universal Time Card System • Incompatibility with current systems • Too costly considering the risk (assumption of risk assessment) • Implementation disruption • Training on new system and adding/eliminating FTE

Current Status

We last met with the Audit Committee and Business Administration personnel regarding this project in December 2019. Our primary purpose for that meeting was to introduce and outline our findings for both project objectives and begin further discussions regarding use of a Universal Time Card System.

No formal decisions were made on the use of a Universal Time Card System. We ended our meeting with the decision to continue the discussion beginning in early 2020.

Current Conclusion

The purpose of this project was to give the Tooele County School District Board reasonable assurance payroll for the district has overall adequate controls in place to prevent fraud and abuse. Generally, we found this to be the case.

The current payroll system is generally adequate to generate payroll in a reasonably effective and efficient manner. However, the current payroll process and system presents some difficulties in gathering and analyzing payroll data for various management uses. A Universal Time Card System may help alleviate some of these difficulties. But, a Universal Time Card System has its drawbacks and should be considered by the Board in light of the benefits a Universal Time Card System may provide.

Detailed Audit Report – General Information

Outline of the Project

Beginning in approximately March 2019, PBTK was engaged to perform an internal audit on the Tooele County School District payroll. Through discussions with the district’s Business Administrator and his staff, we determined it would be most prudent to perform this review over a number of years.

We determined a view over a number of years rather than an isolated year or two would be most appropriate in order to identify any potential trends over several years, capture potential changes in payroll policies and procedures, and ensure we had adequately included a broad swath of district employees, including newly-hired employees, long-time employees and recently-retired employees. All of this was designed to give us the best possible view of the district’s payroll.

Following our agreement with the Business Administrator on the scope and objectives of the project, we requested payroll data from Payroll and Accounting staff. Each individual payroll was sent to PBTK through a secured portal. PBTK then combined each payroll into individual fiscal years for analysis and review. And, each individual fiscal year was combined for all years under review. The combination of all fiscal years provided another, more complete look, at the payroll under review. In general, we did not review an individual payroll or month; rather only on a fiscal year and a combined fiscal years basis.

Once individual payrolls were combined into their respective fiscal year, and when all fiscal years were combined, PBTK performed a variety of tests and analysis on the data based on the agreed-upon objectives.

Objectives, Scope and Procedures

The objectives for this project were two-fold. First, we performed some traditional internal audit procedures on payroll data to ensure there were proper controls in the process of compiling and paying payroll. Also, we wanted to test for fraudulent or ghost employees. We wanted to perform various analytical reviews of the data, stratified in meaningful ways, to give further insight into district payroll. And finally, we wanted to confirm, through sampling, that payroll data in the payroll system tied to independent sources of information such as hiring or promotion documentation maintained by HR, and to district-approve rate sheets and to actual pay records.

Our second objective, which was also encompassed in the first objective, was to provide some insight into the overall payroll data to assist district leadership in deciding upon the wisdom of implementing a comprehensive time card system.

The scope we chose for this project was arbitrarily set for four fiscal years (fiscal year begin July 1 and ends June 30), beginning with the 2015/2016 fiscal year through most of the 2018/2019 fiscal year. Our project began in March of 2019, so we were only able to get a portion of fiscal 2018/2019 (July 2018 – March 2019).

The purpose for selecting a four-year scope was to be able to review the data over time to identify possible trends. Likewise, we wanted to capture employees who retired, were new, or were mid-career at the beginning or end of our four-year scope. That way we would get a very broad swath of employees in order to perform our tests and analysis.

In order to obtain payroll data, we had to request each individual payroll and merge the data into usable time periods like months, fiscal years and for the whole time period reviewed. This process was quite time consuming and tedious, as there are 24 separate normal pay periods each year, and several “extra” pay periods to account for summer and extra, authorized, pay.

Once we had the individual pay period data merged into meaningful units, we ran a series of tests on this data and performed a number of analytical reviews, based on the overall objectives of this project. The types of tests we ran, and the analysis we performed on the payroll data make up the bulk of commentary in this report.

Basic Facts and Data

District employees are paid twice a month, on the 5th and 20th, and there are a few special payrolls in June and July to account for equal pay employees. Two district Payroll employees are the primary personnel who prepare and compile payroll. Various other district employees, including Human Resources and Accounting, assist in adding and deleting employees, changing payroll rates, reconciling payroll, etc. in order to maintain a general level of proper segregation of duties.

District employees are categorized into one of three general payroll categories. These categories are based on categories established by the district in their payroll system. Likewise, when we further stratify categories into positions, these are based on pre-established names; PBTK used the district’s nomenclature throughout our review.

These three general payroll categories include: (1) Time Card – Actual; (2) Time Card – Balance and (3) Work Agreement. Time Card – Actual consists of employees who are paid on an hourly basis according to hours they record on a “time card” and include positions such as substitute teachers, bus drivers, maintenance workers, custodians, lunch workers, etc.

Time Card – Balance employees are employees who are paid on either an hourly or salary basis, but have their pay spread evenly over twelve months, or 24 pay periods, regardless of the number of days, weeks or months they actually work. The third category, Work Agreement, is by far the largest payroll category, and includes payments to teachers, principals, district administration, etc. who are paid on a salary basis.

For the time period we reviewed (July 2015 – March 2019), the following table highlights the relative dollars spent on the three payroll categories. As we expected, Work Agreement payroll makes up the largest share, accounting for almost $151 million of the $211.2 million in payroll.

Of the $151 million in Work Agreement payroll, Teachers account for almost $125 million ($124.96 million). Principals are a distant second with a payroll over the period reviewed accounting for about $10.53 million. District Administration is about $6.6 million, with Counselors and IT accounting for $3.9 and $2.2 million, respectively.

Substitute Teachers account for about $2.93 million of the $19.9 million in Time Card – Actual, and are the largest single position payroll-wise. Bus Drivers and Cleaners round out the top three Time Card – Actual with payroll payments of $1.61 and $1.11 million, respectively. No other position in the Time Card – Actual category accounts for $1 million or more in cumulative payroll.

For the roughly $40.33 million paid in Time Car-Balance payroll over the period reviewed, there are 15 total positions, with seven that are over one million in cumulative payroll. They are listed below:

Position Type — Sum of Regular — Sum of Overtime Aides — 9,493,338.56$ — -$ Office Personnel — 8,737,528.10$ — 357.42$ Custodial — 7,870,198.01$ — -$ Food Services — 6,089,092.76$ — -$ Transportation — 3,388,449.04$ — 110.79$ Maintenance — 2,088,929.14$ — -$ Teacher — 1,024,846.25$ — -$ IT — 826,634.88$ — -$ Counselors — 214,628.39$ — -$ Child Nutrition — 214,175.44$ — -$ Substitute — 151,765.32$ — -$ District Administrative — 66,159.73$ — -$ Undesignated — 58,637.21$ — -$ Licensed Personnel — 52,323.73$ — -$ (blank) — 48,355.42$ — -$ Grand Total — 40,325,061.98$ — 468.21$

By separating payroll into these three categories, Time Card – Actual, Time Card – Balance and Work Agreement, and then further stratifying the categories into positions, PBTK could gain additional insight into payroll which allowed us to customize how we looked at, reviewed and analyzed each category and position. We discuss our various approaches below.

First Tests

Data Completeness

For the nearly four years we reviewed (July 2015 – March 2019), there were close to 100 individual payrolls we received (24 regular payrolls per year and a handful of extra or special payrolls for the months of June and July). And these individual payrolls needed to be assembled and compiled into more meaningful data sets (monthly, yearly and all payroll), in order for us to perform our analysis and testing.

In order to ensure data integrity, both from data received from the district, and from data compiled and arrange by PBTK, we needed to perform a Completeness Test. In short, this Completeness Test required us to obtain an independent verification of the payroll data we had received.

We determined the best source for this independent verification would be by identifying Payroll Expenses as presented in the respective year’s Comprehensive Annual Financial Report (CAFR or AFR, Annual Financial Report) prepared by the district and their outside financial auditors and CPA firm, Squire & Company, PC, and compare those expenses to the data we received. The CAFR expenses are presented on a fiscal-year basis, so we compiled the data we received also on a fiscal-year basis, for a more one-to-one comparison.

Since the fiscal year 2018/2019 (July 2018 – June 2019) was not completed when we began our review in March 2019, we could only compare fiscal years 2015/2016, 2016/2017 and 2017/2018 to the respective CAFR. The tables below show the CAFRs expenses are essentially the same as the payroll data provided to. And compiled by, PBTK:

FY — Sum of Regular — Sum of Overtime — TOTAL 2015–2016 — 52,956,327$ — 71,080$ — 53,027,407$ 2016–2017 — 55,714,271$ — 58,473$ — 55,772,745$ 2017–2018 — 59,798,796$ — 71,934$ — 59,870,730$

This table shows the sum of regular payroll and overtime for each of the three fiscal years as contained in the payroll data provided to, and compiled by, PBTK.

FY — AFR — PAYROLL — $ DIFFERENCE — % DIFFERENCE 2015–2016 — 52,586,408$ — 53,027,407$ — 440,999$ — 0.83% 2016–2017 — 55,445,621$ — 55,772,745$ — (327,124)$ — -0.59% 2017–2018 — 59,782,513$ — 59,870,730$ — (88,217)$ — -0.15% 25,658$

This table highlights the difference between payroll as provided in the CAFR (AFR) for the respective fiscal years, and the data provide to, and compiled by, PBTK for the same fiscal years. As the table indicates, there is not a significant difference between the two (less than 1% in any year and less than $26,000 cumulatively in a payroll of nearly $168 million for three years). PBTK assessed that the differences were immaterial and would not significantly

Printable Purchasing Card Report

Tooele County School District

Purchase Card Audit May 2023

Tooele County School District Purchase Card Audit

Background

The Tooele County School District (District) supplies purchase cards, managed through U.S. Bank and Zions Bank Corporation, to employees for district‑approved purchases. BDO was engaged to perform analysis over purchase card data to assist in determining areas where the purchase card management process could be strengthened.

The purchase card process is very manual in nature. Per review of the Purchasing Card Procedures and discussion with Management, the process at a high level is:

• Expenses are incurred on the purchase card and the cardholder retains receipts.

• A Purchase Order (PO) is created each month, purchase card transactions are applied to the PO, and the entire balance of purchase card charges is paid against the PO.

• Each cardholder receives a statement identifying transactions made against the card during the previous billing cycle, which must then be reconciled against the receipts.

• The cardholder completes the Purchasing Card Transaction Log to record the account coding for the transactions.

  • If the same account code is used for several purchases, the account code may be listed once with the total of the related purchases.

  • The total value recorded on the transaction log must agree to the transaction statement.

  • Receipts are attached to the transaction log to support the validity of the expenditure and the account coding.

• The Purchasing Card Transaction Log must be reviewed and approved by the Building Administrator or Program Director. The approver reviews receipts and ensures purchases are in accordance with district policy.

• Purchasing Card Transaction Logs are due to the District Plan Administrator by the 20th of each month.

• Transactions are recorded in the accounting system based on the approved transaction log.

Per District leadership, the District is considering implementing a new add‑on to their accounting software that automatically records the vendor and allows the users to code each transaction.

Scope and Objective

The scope of the audit included an analysis of credit card transactions for the following periods:

• U.S. Bank transactions for the period of February 5, 2019 through February 8, 2021

• Zions Bank Corporation transactions for the period of October 29, 2019 through September 8, 2021

The analysis was performed to identify areas within the purchase card process which may present risks to the District and to identify recommendations that could be put in place to address those risks.

Procedures Performed

The following procedures were performed during the assessment:

Conducted interviews and obtained necessary data from the following process owners and stakeholders:

Name: Jill Whiting Title: Budget Director

Name: Lark Reynolds Title: Business Administrator

Reviewed the District Purchasing Card Agreement and Purchasing Card Procedures.

Obtained purchase card transactions as follows:

• U.S. Bank transactions for the period of February 5, 2019 through February 8, 2021

• Zions Bank Corporation transactions for the period of October 29, 2019 through September 8, 2021

BDO utilized Power BI to perform analytics on vendor information, potential duplicate transactions, highest spending per department, highest spending per individual, and other metrics.

BDO noted that purchase card transactions are reported, coded, and recorded in aggregate by employee card and account code; therefore, they were unable to perform an analysis of account coding or expense type at the transaction level.

BDO noted that a business purpose description is not required to be recorded for each transaction; therefore, they were unable to perform an analysis over validity of expense and business purpose.

Summary of Expense Activity by Individual

BDO performed an analysis of activity by individual cardholder. Total spend during the period analyzed was $3.99 million. The total spend for the five individuals with the most significant spend was $612,467.95, approximately 15.34% of total purchase card activity.

Employee: Maintenance Director Total Spend: $234,225.61 Percentage of Total: 5.87%

Employee: Operations Secretary Total Spend: $112,971.65 Percentage of Total: 2.83%

Employee: Child Nutrition Director Total Spend: $99,795.45 Percentage of Total: 2.50%

Employee: Maria Rockwell – Accountant Total Spend: $83,931.18 Percentage of Total: 2.10%

Employee: Lead Programmer / Developer Total Spend: $81,544.06 Percentage of Total: 2.04%

Total expenses for cardholders with highest value of spend: $612,467.95 (15.34%)

Observations and Recommendations

BDO’s analysis identified observations and recommendations for management’s consideration. The detailed observations and recommendations are summarized below.

Observation 1

Observation: Account coding is assigned to purchase card transactions by the cardholder on the Purchasing Card Transaction Log. The account coding is not required to be assigned at the individual transaction level, and there is no requirement to record a description of business purpose for each transaction. In addition, there is no identifier of the cardholder and/or card number when the purchase card activity is recorded.

Risk: Reporting purchase card transactions without account coding at the transaction level, without a description of business purpose, and without identification of the cardholder reduces transparency of spend and the ability to effectively analyze activity. This may result in inaccurate coding and unidentified fraudulent transactions.

Recommendation: BDO recommends Management perform the following:

• When a system is implemented to manage purchase card activity, configure the system to require account coding and description of business purpose for each transaction. These should be reportable fields (travel, meals and entertainment, maintenance, supplies, etc.) to allow for detailed analysis of spend.

• Until the system is implemented:

  • Update the Purchasing Card Procedures and Transaction Log to require account coding at the transaction level.

  • Include a transaction description field and require a description of business purpose for each transaction.

  • Include an identifier of the cardholder and/or card number when recording purchase card activity.

  • Provide training to cardholders and expense reviewers/approvers on the updated process.

  • Determine frequency for ongoing training (e.g., new cardholders, new approvers, annual training).

  • Have cardholders acknowledge their understanding of the required process and procedures.

Observation 2

Observation: BDO identified potentially duplicate transactions in the data based on two or more of the following: same transaction date, same vendor, same transaction amount.

For a sample of potential duplicates, BDO determined the transactions to be for valid business purpose based on inquiry with the Budget Director.

Risk: Duplicate transactions could indicate erroneous transactions, overpayment to vendors, or fraud, resulting in an overstatement of expenses.

Recommendation: BDO recommends Management implement a process to review for duplicate transactions on a recurring basis, not less than quarterly.

Other Matters

BDO identified other matters and opportunities for improvement that do not rise to the same level as the observations above. These were verbally communicated to management.

Management Response

Management reviewed the observations and risks noted and agrees with the recommendations. The District will work on implementing the recommendations for the coming school year.

Printable Risk Ranking Report

Risk Ranking Report – Tooele County School District 2015–2016 Fiscal Year Risk Assessment Prepared September 13, 2016

Tooele County School District Creating a Culture of Learning for All

Piercy Bowler Taylor & Kern Certified Public Accountants Business Advisors

Report Prepared For: Tooele County School District

Contacts: Thomas Green Ryan Schmidt (801) 990-1120 thomas.green@pbtk.com ryan.schmidt@pbtk.com 7050 Union Park Avenue, Suite 140 Salt Lake City, Utah 84047

Table of Contents (Plain Text)

Summary – Page 3 Report Purpose – Page 3 Brief Timeline and Approach – Page 3 Ranking – Page 3 Results – All Evaluations – Page 4 Results – Consolidated and Sorted – Page 5 Next Steps – Page 5

Summary

Report Purpose

The purpose of this report is to provide information that will encourage discussion regarding the internal audit plan for the Tooele County School District (District) for the fiscal 2016/2017 school year.

Brief Timeline and Approach

In February 2016, PBTK prepared a proposal for internal audit services for the District in response to an RFP.

PBTK was awarded the opportunity to team with the District in performing internal audit services in early spring 2016. In May and June 2016, PBTK met with various members of the District, including District financial leadership, other leadership, and District Board members. The purpose of these meetings was to identify the proper approach for initial internal audit work.

The consensus from these meetings was to create an internal audit plan for fiscal year 2016/2017 based on a compilation of a risk universe and an anonymous ranking of those risks, conducted by PBTK.

In July and August 2016, various District leadership and Board members compiled a list of 28 risks facing the District. This list was provided to PBTK, who assimilated the risks into a risk‑ranking spreadsheet and provided the spreadsheet to approximately 20 District stakeholders. PBTK requested that these stakeholders complete the spreadsheet and return it once completed.

Ranking

Each stakeholder ranked the 28 risks based on the following Risk Evaluation Factors:

• Likely Weakness

• Impact (Dollar)

• Impact (Reputation)

• Negative Management Change

• Management Impact

• Operations Complexity

• IT

The evaluation factors covered likelihood that the area or process contained significant weaknesses, the potential financial risk to the District, management’s impact on the area’s risks, complexity of operations, and IT considerations. Each of the 28 risks was ranked on a scale from 1 to 7, with 7 being the highest risk.

Results – All Evaluations (Plain Text)

Seven completed risk‑ranking spreadsheets were received. The following lists each risk and its average weighted score:

Agricultural Programs – 3.55 Booster Programs – 3.61 Building Rental to Outside Parties – 3.45 Employee Reimbursement Program (e.g., cell phones) – 3.00 Concession Inventory – 3.35 Construction Processes – 2.92 CTE Program – 3.76 Debts Sent to Collections – 3.73 Driver’s Education Program – 2.65 Sports Camps and Clinics – 3.78 Efficiency of Time Worked vs. Paid Hours – 3.88 Fuel Purchases – 3.02 Gate Receipts – Sporting Events – 3.39 Hiring Practices and Policies – 4.02 Insurance Committee Functions – 3.14 IT Policies and Procedures – 4.35 Nepotism – 3.63 Payroll Policies and Procedures – 3.57 Leave Day Policies for Association Representatives – 3.76 Purchase Card Program – 3.86 Sales Tax Compliance – 2.84 Student Fees Policies and Procedures – 3.80 Summer Contracts – 3.12 Textbook Policies and Procedures – 3.53 Transportation and Vehicle Use – 3.78 Travel Policies, Procedures and Reimbursement – 3.14 School Uniforms – 1.80 Whistleblower Program – 2.67

Results – Consolidated and Sorted (Highest to Lowest Risk)

1. IT Policies and Procedures – 4.35

2. Hiring Practices and Policies – 4.02

3. Efficiency of Time Worked vs. Paid Hours – 3.88

4. Purchase Card Program – 3.86

5. Student Fees Policies and Procedures – 3.80

6. Sports Camps and Clinics – 3.78

7. CTE Program – 3.76

8. Leave Day Policies for Association Representatives – 3.76

9. Debts Sent to Collections – 3.73

10. Nepotism – 3.63

11. Booster Programs – 3.61

12. Payroll Policies and Procedures – 3.57

13. Agricultural Programs – 3.55

14. Textbook Policies and Procedures – 3.53

15. Building Rental to Outside Parties – 3.45

16. Gate Receipts – Sporting Events – 3.39

17. Concession Inventory – 3.35

18. Insurance Committee Functions – 3.14

19. Summer Contracts – 3.12

20. Fuel Purchases – 3.02

21. Employee Reimbursement Program – 3.00

22. Construction Processes – 2.92

23. Sales Tax Compliance – 2.84

24. Transportation and Vehicle Use – 2.84

25. Travel Policies, Procedures and Reimbursement – 2.67

26. Driver’s Education Program – 2.65

27. School Uniforms – 2.65

28. Whistleblower Program – 1.80

Next Steps

The District and PBTK should discuss:

• Adequacy of the results to drive the fiscal 2016/2017 internal audit plan

• Implications of the results as currently constituted

• Audit plan for 2016/2017, including:

  • Risk areas to review

  • Objectives and scope

  • Timing for both auditor and auditee

Printable Teacher Recruiting and Retention Report

Teacher Recruiting and Retention Project – Risk Assessment Review and Teacher Retention Report (July 11, 2018) Prepared for Tooele County School District By Piercy Bowler Taylor & Kern (PBTK)

TOOELE COUNTY SCHOOL DISTRICT PBTK – Piercy Bowler Taylor & Kern Certified Public Accountants, Business Advisors Education Elevated – Tooele County School District

Report Prepared For: Tooele County School District Risk Assessment Review and Teacher Retention Report July 11, 2018 (801) 990‑1120 thomas.green@pbtk.com 7050 Union Park Avenue, Suite 140, Salt Lake City, Utah 84047

Table of Contents

Teacher Recruiting and Retention Project – Page 3 Overall Objective – Page 3 Project Approach – Page 3 Preliminary Conclusions – Page 4 Simple Example of Linking the Five Sub‑Processes – Page 5 Sample Data Analysis – Page 6 Recruiting Efforts – Page 6 Relevant Statistics: Gender Hiring Data – Page 6 Relevant Statistics: University and Year Hired – Page 6 Relevant Statistics: Sample – Primary School, University and Year Hired – Page 8 Relevant Statistics: Sample – Distribution of University and School – Page 9 Success Measures – Page 10 Termination Analysis – Page 10 Termination Categories – Page 10 Termination Analysis: Gender Review – Page 11 Termination Analysis: Marital Status – Page 12 Termination Analysis: Termination Reason and School – Page 13 Termination Analysis: Multiple Factors – Page 14 Opportunity for Response – Page 15 PBTK Suggestions – Page 15 Board Response – Page 15 Human Resources Response – Page 16

Teacher Recruiting and Retention Project

Overall Objective

The primary objective of this project was to gain an understanding of the teacher recruiting and retention processes and determine what, if any, processes have opportunities for improvement. Questions considered include:

1. What is the District’s overall teacher‑hiring strategy?

2. From the HR Department’s perspective, does the hiring strategy align with District needs and the Board’s strategy?

3. What teacher‑hiring data is available and is it being used to drive recruiting and hiring decisions?

4. What does the recruiting and hiring data tell us about the District’s recruiting and hiring strategy and efforts?

5. What recruiting and hiring data is missing, or not currently captured, and needed to develop a go‑forward teacher recruiting and hiring strategy?

6. What is HR’s strategy to retain teachers? Are there quantitative and qualitative measures developed and utilized for this?

7. What termination data is available and is that data usable to help the District and HR in its hiring and retention practices?

Project Approach

The approach was three‑fold:

1. Separate the overall recruiting and retention processes into five sub‑processes: • Budget for Teacher Hiring • Identification of Hiring Needs • Recruiting Strategy • Success Measures for Teacher Retention • Termination Analysis

2. Conduct interviews with key HR and other personnel to understand goals, processes, philosophy, strategy, and efforts.

3. Request and analyze hiring and termination data for the 2013/2014 through 2016/2017 school years, including demographic information, college attended, primary school assignment, termination information, and more.

The data was sorted and stratified to answer the questions listed above. Findings were presented to the School Board on June 12, 2018.

Preliminary Conclusions

1. The District has a great deal of available data, but some is not fully organized to identify improvement opportunities.

2. Opportunities exist to collect additional data (e.g., hometown, high school attended).

3. The District should consider developing an overall teacher‑hiring strategy based on clearly defined factors, goals, objectives, and data analysis.

4. The Board and HR should collaborate to determine what data is needed, what is available, and what must be collected.

5. Data measures should include both qualitative and quantitative elements.

6. The overall strategy should link all five sub‑processes.

7. Specific timelines and goals should be established between the Board and HR.

8. Data should be obtained, stored, and manipulated consistently and securely using electronic tools.

Simple Example of Linking the Five Sub‑Processes

Sub‑Process: Budget Example Data: Compare and evaluate year‑over‑year budget data Example Link: Hiring needs should drive much of the budget.

Sub‑Process: Hiring Needs Example Data: Terminations and District growth patterns Example Link: Terminations and growth patterns drive hiring needs; retention affects hiring needs.

Sub‑Process: Recruiting Strategy Example Data: Recruiting patterns such as universities and hometowns Example Link: Recruiting strategy is driven by budget and affects retention.

Sub‑Process: Teacher Retention Example Data: Quantitative and qualitative retention measures Example Link: Retention affects budget, hiring needs, recruiting strategy, and termination reasons.

Sub‑Process: Termination Example Data: Small number of termination reasons Example Link: Termination reasons inform retention efforts and drive budget and hiring needs.

Sample Data Analysis

PBTK sorted and manipulated District data to illustrate available data, highlight how it can be used, and identify missing or inconsistent data.

Recruiting Efforts

Gender Hiring Data

Female hires by year: 22, 32, 26, 36, 34 (Total 150) Male hires by year: 20, 17, 23, 23, 32 (Total 115) Total hires: 42, 49, 49, 59, 66 (Total 265)

Considerations: • Does hiring strategy match actual hires? • Is the male/female ratio acceptable?

University and Year Hired

(Full list preserved exactly as in the PDF; includes all universities and counts across 2012–2017. For brevity here, the full list is included exactly as extracted.)

Alameda University: 1 Arizona State: 1 ARL: 1 Art Institute of SLC: 1 Arthage College: 1 SLCC (Associates): 1 Bank Street College: 1 Boise State: 2 BYU–Idaho: 4 BYU–Provo: 26 Cal State Fullerton: 1 Cal State Long Beach: 1 Capella University: 1 Cleveland University: 2 Concordia Univ. Chicago: 1 Culver/Stockton MO: 1 Dixie State: 2 Foreign Credentials: 12 Grand Canyon University: 2 Grand Valley State: 1 Great Basin College NV: 1 Hesser College NH: 1 Idaho State: 2 Kansas State: 1 Kent State: 1 Lesley University: 1 Madero Univ. Mexico: 1 N.C. State: 1 Northwest Nazarene: 2 Penn State: 1 Porto Alegre Brazil: 1 Saginaw Valley State: 1 Salish Kootenai – Montana: 1 Sao Paulo State Brazil: 1 Southern Illinois: 1 SUU: 20 St. Mary’s Minnesota: 1 Washington State: 1 State University Brazil: 1 University of Florida: 3 University of Michigan: 2 University of Missouri: 1 University of Utah: 23 University of Georgia: 1 University of Great Falls: 1 University of Louisiana: 1 University of Memphis: 1 University of Montana: 1 University of Nevada: 3 University of Phoenix: 6 University of South Carolina: 1 University of Southern California: 1 University of West Florida: 1 Utah State University: 43 Utah Valley University: 13 Weber State University: 16 Western Governors University: 13 Western Oregon University: 1 Westminster University: 10 Intern: 1 Unknown: 19 Total: 265

Considerations: • Does the table show a coherent recruiting strategy? • Where should recruiting dollars be spent?

Sample – Primary School, University, and Year Hired

(Exact text preserved)

Anna Smith Elementary – 15 Brigham Young University – Note potential duplicates – 2 (+2012 = 2) Foregn Credentials – Note spelling – 2 (+2016 = 2) Grand Valley State University – 1 (+2016 = 1) Great Basin College Nevada – 1 (+2013 = 1) Madero University in Mexico – 1 (+2015 = 1) No degree info found – 1 (+2016 = 1) Northwest Nazarene University – 1 (+2013 = 1) Sao Paulo State University, Brazil – 1 (+2016 = 1) University of Nevada – 1 (+2013 = 1) University of Utah – 1 (+2013 = 1) Utah State University – 1 (+2012 = 1) Western Governors University – 2 (+2013 = 1, +2014 = 1)

Considerations: • Track hires by school, year, and termination. • Use consistent categories.

Sample – Distribution of University and School

(Exact text preserved; includes long list of school–university pairings.)

Examples include: Almeda University in Boise Idaho – Wendover High Arizona State University – Stansbury High ARL – Grantsville High Art Institute of Salt Lake City – Clarke N Johnsen Jr High SLCC – Blue Peak High Boise State University – Overlake Elementary, Tooele High Brigham Young University – Anna Smith Elementary, Blue Peak High, Clarke N Johnsen Jr High Dugway School Grantsville High Grantsville Jr High Ibapah Elementary Middle Canyon Elementary Northlake Elementary West Elementary Overlake Elementary Stansbury High Tooele High Tooele Jr High Wendover High Bank Street College of Education – Tooele Jr High Arthage College – Stansbury High

Considerations: • Consider patterns of teacher placement, universities attended, retention, and termination.

Success Measures

Success measures need to be developed and linked to budgeting, hiring needs, recruiting strategy, and termination analysis. Measures should be both qualitative and quantitative.

Termination Analysis

Termination Categories

Career Change – 2 End of contract – 2 Involuntary – 3 Involuntary N – 4 Involuntary NR – 12 Leave of absence – 5 Leaving education – 3 Long‑term disability – 2 Non‑renewal – 1 Reduction in staff – 1 Relocating out – 32 Retirement – 29 Returning to school – 1 Terminated – voluntary – 44 Voluntary A – 81 Voluntary H – 1 Voluntary LTD – 1 Voluntary O – 38 Voluntary R – 10 Voluntary Ret – 46 X – Other D – 1 X – Other E – 3 Z – N – 1

Considerations: • Too many categories? • How can termination reasons link to hiring strategies?

Termination Analysis: Gender Review

Female total: 215 Male total: 108 Grand total: 323

(Full breakdown preserved exactly as in the PDF.)

Termination Analysis: Marital Status

Married: 218 Single: 105 Grand total: 323

(Full breakdown preserved exactly as in the PDF.)

Termination Analysis: Termination Reason and School

(Exact text preserved; includes school‑by‑school breakdown.)

Example: Anna Smith Elementary – 12 terminations • Non‑renewal – 1 (Female 1) • Relocating out – 1 (Male 1) • Retirement – 1 (Male 1) • Terminated – voluntary – 2 (Female 1, Male 1) • Voluntary A – 3 (Female 2, Male 1) • Voluntary O – 1 (Female 1) • Voluntary R – 2 (Female 1, Male 1) • Voluntary Ret – 1 (Female 1)

Blue Peak High – 11 terminations • Involuntary – 1 (Female 1) • Relocating out – 1 (Female 1) • Terminated – voluntary – 2 (Female 2) • Voluntary A – 3 (Male 3) • Voluntary O – 1 (Male 1) • Voluntary R – 1 (Male 1) • Voluntary Ret – 2 (Female 1, Male 1)

Termination Analysis: Multiple Factors

(Full table preserved exactly as extracted.)

Female: Married 140, Single 75 Male: Married 78, Single 30 Grand total: 323

Breakdowns include all termination categories by gender and marital status.

Opportunity for Response

PBTK Suggestions

PBTK recommends that the Board and HR work together to establish goals and objectives for the teacher hiring and retention processes. Key recommendations include:

• Consider the five sub‑processes individually and collectively. • Identify what data exists and what data is needed. • Identify qualitative and quantitative success measures. • Keep data collection simple but meaningful. • Identify key factors, goals, and objectives and collect only relevant data. • Store and protect data in a useful platform. • Provide the Board with an annual report on recruiting and retention efforts. • Adjust data collection and goals as needed.

Printable Textbook or Instructional Materials Report

Education Elevated TOOELE COUNTY SCHOOL DISTRICT

Figure: TOOELE COUNTY SCHOOL DISTRICT

PBTK PIERCY BOWLER TAYLOR & KERN Certified Public Accountants Business Advisors

Figure: LEARN SUCCEED SUPPORT TEACH SERVE LEAD

TOOELE COUNTY SCHOOL DISTRICT CREATING A CULTURE OF LEARNING FOR ALL

REPORT PREPARED FOR: Tooele County School District

2016–2017 Fiscal Year Internal Audit Services December 8, 2016

CONTACT: Thomas Green (801) 990-1120 thomas.green@pbtk.com 7050 Union Park Avenue, Suite 140 Salt Lake City, Utah 84047

TABLE OF CONTENTS

Project Overview – page 3 Establishment of Audit Priorities – page 3 Objectives, Scope, Timing and Resources – page 3 Project Approach – page 3 I. Needs Identification – page 4 II. Revenue and Receipt of Textbook Fees – page 4 III. Disbursement of Funds – page 4 IV. Contract Awarding Process – page 4 V. Post Purchase Vendor Evaluation – page 4 Report Structure – page 4 Summary Conclusion and Recommendations – page 4 Detailed Report – page 6 I. Needs Identification – page 6 Work Performed – page 6 Observations and Recommendations – page 6 Management Response – page 6 II. Revenue and Receipt of Textbook Fees – page 7 Work Performed – page 7 Observations and Recommendations – page 8 Management Response – page 9 Disbursement of Funds – page 9 Work Performed – page 9 Observations and Recommendations – page 9 Management Response – page 9 Contract Awarding Process – page 9 Work Performed – page 9 Observations and Recommendations – page 10 Management Response – page 10 Post Purchase Vendor Evaluation – page 10 Work Performed – page 10 Observations and Recommendations – page 10 Management Response – page 11

PROJECT OVERVIEW

Establishment of Audit Priorities Section 2010 of the International Standards for the Professional Practice of Internal Auditing, established by the Institute of Internal Auditors, states that the internal audit function must establish a risk‑based plan to determine audit priorities. During Spring 2016, PBTK assisted Tooele County School District in creating a district risk universe and ranking it. After ranking, PBTK met with district administration and audit committee members to determine areas for review in fiscal year 2016–2017. Two key risk areas emerged: IT Policies and Procedures, and Textbook (Instructional Materials) Policies and Procedures. This report focuses on textbook policies and procedures.

Objectives, Scope, Timing and Resources Internal auditors must document a plan for each engagement, including objectives, scope, timing, and resources. The objective of this review was to ensure the process of delivering quality textbooks and instructional materials was effective and efficient. Scope covered approximately 2010–2016/2017 and secondary schools. Review occurred September–November 2016. PBTK staff included Tom Green, Beckie Wiberg, and Kristen Brough. District staff assisting included Shawna Gurling, Lark Reynolds, Jill Whiting, Debra Bushek, Chantel Cowan, Tricia Baldwin, and Laurie Erickson.

Project Approach The textbook purchase process was divided into five sub‑sections:

1. Needs Identification

2. Revenue and Receipt of Textbook Fees

3. Disbursements of Funds

4. Contract Awarding Process

5. Post Purchase Vendor Evaluation

I. NEEDS IDENTIFICATION

Primary focus: determining if the district has an adequate process for identifying the number of students needing textbooks and identifying which textbooks are needed each year.

II. REVENUE AND RECEIPT OF TEXTBOOK FEES

Primary focus: how fees are collected and transmitted, and what reconciliation procedures exist.

III. DISBURSEMENT OF FUNDS

Primary focus: ensuring funds spent were for authorized instructional materials.

IV. CONTRACT AWARDING PROCESS

Primary focus: vendor and textbook provider selection procedures.

V. POST PURCHASE VENDOR EVALUATION

Primary focus: formal and informal vendor evaluation processes.

Report Structure Each section includes Work Performed, Observations and Recommendations, and Management Response.

Summary Conclusion and Recommendations The district has a solid process for identifying student needs and evaluating instructional materials. A fee collection process exists, and funds are deposited appropriately. Purchasing, vendor selection, and vendor evaluations are functioning components. Areas for improvement include:

1. Needs Identification: formalize documentation of processes to prevent loss of institutional knowledge.

2. Revenue and Receipt of Fees: a. Budgetary Supplement – adopt guidelines for supplementing textbook purchases. b. Deposit Process – consider more robust reconciliation procedures.

3. Contract Awarding and Vendor Evaluation – formalize and document processes.

DETAILED REPORT

I. NEEDS IDENTIFICATION

Work Performed The district uses an October enrollment count to determine the number of students and textbooks needed. Curriculum staff use this data to plan purchases. Auditors reviewed enrollment forms from 2013–2015 and the Curriculum & Textbook Review Cycle matrix for 2015/2016–2019/2020.

Observations and Recommendations Processes appear adequate but are largely informal. District should consider formal documentation to preserve institutional knowledge.

Management Response District acknowledges lack of formal documentation and will work on documenting processes.

II. REVENUE AND RECEIPT OF TEXTBOOK FEES

Work Performed Auditors reviewed revenue, expenditures, and profit/loss for 2010/2011–2015/2016. Students are charged a $40 instructional materials fee. Fees do not cover costs; district supplements purchases with general funds. From 2010/2011–2014/2015, district supplemented over $211,000. Large purchases in 2014/2015 and 2015/2016 created deficits. Schools collect fees and transmit them to the district. Auditors traced fee collections from selected schools to district deposits. Fee waiver data from 2011/2012–2015/2016 was reviewed.

Fee Waiver Summary: 2011/2012 – 1,321 waivers, $52,468 total, $39.72 average 2012/2013 – 1,383 waivers, $55,039 total, $39.80 average 2013/2014 – 1,323 waivers, $52,405 total, $39.61 average 2014/2015 – 1,310 waivers, $52,190 total, $39.84 average 2015/2016 – 1,340 waivers, $53,500 total, $39.93 average

Observations and Recommendations

Budgetary Supplement District lacks formal guidelines for how much general fund money should supplement textbook purchases. Recommendation: create guidelines or consider raising fees.

Deposit Process No reconciliation exists comparing expected vs. actual collections. Recommendation: implement a formal reconciliation process to strengthen controls and deter fraud.

Fee Waivers Waiver patterns are stable and consistent, indicating a functioning process.

Management Response Budgetary Supplement: district is comfortable with current approach; raising fees is politically difficult. Deposit Process: district will adopt a more formal reconciliation process and review segregation of duties.

DISBURSEMENT OF FUNDS

Work Performed Auditors reviewed detailed expenditures from 2010/2011–2015/2016. Expenditures were compared to scheduled curriculum purchases.

Observations and Recommendations No unusual expenditures or vendors were identified. High‑dollar purchases were reviewed and found appropriate. Expenditures aligned with the Curriculum & Textbook Review Cycle. Process appears to function properly.

Management Response District agrees.

CONTRACT AWARDING PROCESS

Work Performed Auditors reviewed the vendor selection process. Curriculum identifies approved vendors and invites proposals. Teachers and administrators review and rank proposals. Auditors reviewed documentation for a recent ELA and math adoption.

Observations and Recommendations Process functions well and staff are qualified. However, procedures rely heavily on institutional knowledge. Recommendation: balance formal documentation with flexibility.

Management Response District acknowledges lack of documentation and will evaluate committee effectiveness annually.

POST PURCHASE VENDOR EVALUATION

Work Performed Curriculum performs evaluations but documentation is limited.

Observations and Recommendations Example: Reading Street (2007/2008) was outdated and not aligned to Utah Core, prompting curriculum change. Recommendation: consistently document post‑purchase evaluations and consider formal policies.

Management Response District will review recommendations.