| HR | Benchmarking | As part of the existing reorganization plan, all positions are being audited for documented qualification and certification verification, and new roles are being reviewed by a hiring manager. This work is ongoing. | |
| I-9 Recordkeeping | The I-9 inventory is approximately 98% complete: all I-9s are filed and organized. The remaining items are records that could not be located and must be redone; the anticipated completion date is August 31, 2026. Access controls for the I-9 storage room were installed in April 2026. | |
| Maintaining Institutional Knowledge | The district underwent a massive layoff during the prior superintendent's tenure; more than 1,000 positions were eliminated. We have aggressively worked to rebuild the internal structure and historical knowledge, including the redevelopment of structures and processes proven effective. | |
| Organizational Charts | A new district-wide organizational chart took effect in June 2026 and is in use across the district. It is maintained by the Office of Human Resources and updated with each reorganization. | |
| Processes, e.g., Data Quality, Employee File Maintenance, I-9 | Standard operating procedures for individual human resources roles are approximately 99% complete. They will be reviewed at least annually and updated whenever a position changes. Work continues on updating processes and procedures to ensure compliance. | |
| State Board of Education Reporting | All outstanding FY2025 reports were submitted to the State Board of Education in April 2026, in compliance with state reporting requirements. The Labor Relations team tracks all reportable actions to ensure the required 30-day reporting timeline is met going forward, as an ongoing process. | |
| Succession Planning | A draft succession planning process has been developed and is being reviewed by a cross-functional leadership team. | |
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| Contracts | Authorization | A draft RACI (Responsible, Accountable, Consulted, Informed) matrix has been developed to document authorization roles across procurement and contracts/legal. This process is outlined in the district's modernization plan. | |
| Monitoring | To ensure more accurate monitoring and accountability of contracts, the district has executed new rules regarding assigned owners of every contract. Further checks and balances have been proposed as part of the modernization plan. | |
| Quality Assurance | The district is developing a centralized review workflow. | |
| Requests for Qualifications | Leadership has reviewed the guidance provided by the auditing firm to develop a consolidated end-to-end professional services contracting procedure that integrates procurement, legal, contract administration, and accounts payable requirements. Furthermore, we agree with the guidance to draft and post an RFP for independent compliance co-sourcing. | |
| Single Source/Sole Source Procurement | The district is in the process of adopting a sole/single source standard operating procedure. As recommended, this will call for all professional services contracts, regardless of source structure, to adhere to procurement requirements: requisition, budget check, purchase order, and vendor registration before services begin. | |
| Vendor Record-Keeping | The district agrees with the audit recommendation to complete a separate audit of all Contract Advantage vendor and contract classifications to correct inaccuracies and implement validation controls at intake to prevent future errors. | |
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| Accounts Payable | Payment Processing | An updated payment processing procedure has been completed and will be part of all standard operating procedures. | |
| Payroll Processing | A standardized Payroll Change Authorization Form has been implemented. The APECS system includes an audit trail, and second-level approval and documented business justification is required before any manual check is issued. | |
| Procuring Equipment | In alignment with Policy #2006, the district has an existing process for all equipment purchases to follow, including requisition, budget verification, purchase order, and vendor registration before services or goods are received. Further, the department is updating warehouse storage guidelines to include physical separation and labeling of federal grant-funded equipment with grant identifiers. As of May 29, 2026, warehouse staff have been trained on grant compliance. | |
| Purchases | Complete supporting documentation (signed invoice, business purpose, approvals) is already required in APECS for all purchase types, such as ACH, warrants, vCards, and check requests, before payment release. | |
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| Internal Controls | Conflicts of Interest & Ethics/Fraud Hotline | The district acknowledges gaps in these processes and is currently reviewing the audit's recommendations to execute accordingly. | |
| Formalized Processes & Procedures | The district has adopted the “Yellow Book” (U.S. GAO Government Auditing Standards). Under these standards, the internal audit charter is approved by the Superintendent and does not require Board approval; the updated charter was finalized and approved by the Superintendent on May 8, 2026. The Internal Audit Department has also finalized and published its own standard operating procedures, aligned to the Yellow Book standards.
Separately, each department is working with the Project Management team and the Office of the Chief of Staff to enter all SOPs into the system with sufficient detail, including screenshots where applicable, so that a new employee can perform the role upon gaining system access. Visual workflows are being developed to complement the SOPs, and SOPs will be reviewed at least annually as ongoing work. | |
| Internal Audit Manual | The development of an internal audit manual is underway. | |
| Internal Audit Team | The internal audit team has participated in the following trainings since December 2025:
- Virtual Bootcamp, Dec. 8-12, 2025 - Internal Controls Workshop, Feb. 18-19, 2026 - Conducting Performance Audits, March 3-5, 2026 - Yellowbook Training - Audit Interviewing, March 26, 2026
Training continues throughout the year. The district has adopted the U.S. GAO Government Auditing Standards (the “Yellow Book”), which are better suited to a governmental organization than the Institute of Internal Auditors standards. The department is now staffed with six dedicated auditors, including recent hires from the private sector and public accounting. The team began its formal risk assessment and audit-universe definition on June 26, 2026, with leadership interviews underway, and expects to complete its first full audit cycle by the end of August or September 2026. | |
| Policy Management | Staff reviewed each policy to assign ownership to the appropriate senior leader(s). On April 26, 2026, the Board approved a resolution authorizing staff to update the formatting of policy documents — including assigning primary responsibility for each policy to the relevant senior leader, where applicable — without further Board action. Pursuant to that authorization, staff have updated policy ownership information throughout the policy manual.
Approximately 95% of policies have been updated and assigned to the appropriate owner; the remaining policies are in final review and are being uploaded into BoardDocs. | |
| Record Retention | The district will establish a universal retention schedule, e.g., seven years as a default, with department-specific exceptions, centralized at the district level. | |
| School Funds Audit | The district is following the Comptroller’s school audit requirement for Internal School Funds. According to the Internal School Funds Manual issued by the Division of Local Government Audit, Internal Audit (IA) staff may perform audits other than the annual audit. The annual audit is performed by the external CPA firm Watkins Uiberall, which issues the opinion on the district’s financial statements, however Watkins Uibierall relies on the work of the district’s Internal Audit staff for performing the compliance audits relative to internal school funds. Statement on Auditing Standards 128 (SAS 128) allows external auditors to rely on the work of an internal audit function of an organization when the external firm is engaged to perform financial audits. Watkins Uibierall complies with SAS 128 by providing direction to the district’s Internal Audit Department regarding internal school fund audits by reviewing and agreeing to the audit program used to document audit procedures. Additionally, Watkins Uiberall reviews all workpapers related to internal school fund audits to ensure audit quality. | |
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| Funding | Budget Revisions & Transfers | The district currently uses APECS, based on its ability to effectively manage all budget processes. | |
| Federal & State (Charter & Head Start) | The district agrees with the recommendation to develop an updated travel policy, journal entry standards, and standard operating procedures for Title I and ESSER, along with the recommendation to require a grant manager to co-sign on all federally funded documents. Further, MSCS will issue a district-wide directive requiring specific school location codes for all federal grant expenditures. The controller will audit quarterly. Head Start documentation will migrate into the APECS centralized repository within 90 days of receipt, and all charter school disbursements will be redirected through the charter office within 30 days of receipt. | |
| Financial Transactions & Controls | The district is executing the recommendation to centralize journal entry processes to provide the Finance Department read-access to all departmental supporting documentation before approving entries. Further, the district will begin the pre-payment documentation checklist for all transaction types in APECS and initiate ERP assessment to evaluate integration of payroll, inventory, and finance systems. Findings will be presented to the Board. | |
| Board Discretionary Budgets | The district previously drafted a formal Board Member discretionary budget policy covering allowable uses, approval process, and required documentation. This policy was presented and approved by the Board. | |
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| Governance | Policy Management | The district completed its biennial review of all policies (2024–2025 cycle), which the Board formally acknowledged by resolution on March 25, 2025. Historically, revision dates on policies reflected when the policy language was amended rather than when the policy was most recently reviewed. To address this, the Board approved a resolution on April 26, 2026, authorizing staff to update the formatting of all policy documents to include a clearly visible “Last Reviewed” date without further Board action. Those updates have been implemented, and all policies now display the applicable most recent review date.
The April 2026 resolution is available online here
Policies are available for review in BoardDocs at: https://go.boarddocs.com/tn/scsk12/Board.nsf/Public | |
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| IT | Cybersecurity Controls | As technology continues to change rapidly, and security needs expand, we acknowledge gaps in our IT infrastructure and capacity. We reviewed the findings in the audit report and are developing a remediation plan. | |
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| Whitehaven STEM Center | Agreement | The Whitehaven STEM Center is complete and has been handed over to the district; no agreement was required for the completed structure. Going forward, the district’s standard requires an executed MOU governing any donated work, together with a contract between the district and the vendor, before facility-donation work begins. This standard is already in use: an executed MOU is in place for donor facility-improvement work currently underway at another site. | |
| Building Size | The difference in square footage is attributable to increases in the cost of materials and labor between the time the project was initiated and the time of construction. Processes and documentation requirements have been strengthened since the STEM project and are now in effect. | |
| Funding | The building was privately funded and donated: funds flowed through School Seed rather than the district, which received only the completed building. The Board approved any district funds contributed to the project and adopted a resolution accepting the building donation. Scopes of work for IT, security, intercom, and furniture have been finalized, and those items have been ordered or work is underway to complete them. The furniture purchase was approved by the Board in May 2026, and the remaining items are being completed through open district contracts. | |
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