In this edition
March 1, 2022
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Employee Compensation Payment Requirements: Reduce Annual Auditor Findings
Things to Remember When Filling Out SNSP Applications
A Common Mistake: Name Differences
Mark Your Calendars!
Key Documentation for Student Applications
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Employee Compensation Payment Requirements: Reduce Annual Auditor Findings |
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The employee compensation payment requirements are one of the areas tested during the annual fiscal and internal control practices procedures that are required by the Wisconsin Department of Public Instruction (DPI). Compensation agreements need to meet a number of specific requirements to be in compliance. The following is a list of these requirements:
- The agreements must be signed by BOTH a School representative and the employee prior to the first payment date under the contract.
- The agreements must include the compensation amounts.
- The schools must maintain documentation of employees electronically signing the agreements if electronic signatures are used.
To be in compliance, the agreements should also include the date range that the contract covers and they should be dated on the date they are signed.
In addition to these specific requirements, schools are required to provide employees with the dates that payroll will be paid prior to making any payments for the school year. This information can be included in the compensation agreements. Employees are required to be paid at least once every 31 days.
Pay rate changes that occur during the school year create additional documentation requirements. For all pay rate changes, one of the following must be provided to the employees before the change is made.
- Written notification of the change (in paper or electronically).
- A document signed by the employee agreeing to the pay change.
For an ongoing change, the written notification must include the date the change is effective and the increase or decrease for each paycheck including how the amount is calculated.
One-time payments such as bonuses fall into this category as well. If the pay change is a one-time payment, the written notification must include when the amount will be paid and how much the amount will be.
Schools can take an active role in preventing any non-compliance findings:
- Do a regular internal audit of a sample of compensation agreements.
- Review the agreements for the items listed above, and, if any missing components are noted, have them corrected as soon as possible.
- Ensure to have procedures documented for pay rate changes. When there are policies and procedures in place that detail the documentation requirements for bonuses paid, merit increases, etc., staff involved in the payroll process can ensure they are obtaining all of the necessary items.
- Review a sample of employees from payroll registers throughout the year. Total compensation paid for the payroll should be compared to the amount that is detailed in the compensation agreement. If any differences are found, they can be investigated and corrected.
Completing these procedures throughout the school year should help reduce any potential non-compliance findings by the auditors during the fall procedures. For more information, visit www.dpi.wi.gov/parental-education-options/choice-programs or contact your Hawkins Ash CPAs representative.
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Rachel Burrow, CPA | Audit Manager
D 608.793.3114
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Things to Remember When Filling Out SNSP Applications |
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The Special Needs Scholarship Program (SNSP) is a great program that allows a student with a disability, who meets certain eligibility requirements, to receive a state-funded scholarship to attend a participating private school. The application process is a team effort and requires a student’s parent and a school’s SNSP Administrator or Designee to fill out a paper application. If not filled out correctly, this single sheet of paper can determine the eligibility of a student. Here are some of the key requirements of the SNSP application:
- All parts of the paper application or transfer request need to be completed except the race, ethnicity, telephone number, middle initials, and name suffixes.
- There are several areas of the application that require the parent or school to check designated boxes on the application. Ensure that these items are filled out along with the other parts of the application.
- Ensure the parent’s or guardian’s initials are included in the first two boxes under the parent or guardian certification section.
- Every student’s first name, last name, and grade level in the Student Information System (SIS) system must match the application information submitted to DPI and the student’s paper application.
- Make sure that the current resident school district matches the school district verification documentation that is obtained.
- All parts of the application need to be legible.
- Corrections need to be made using the strikethrough method as follows:
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Using a
“strikethrough line” with indelible ink and not with the use of correction fluid, i.e. “white-out.” Any paper applications and transfer requests corrected with “white-out” are ineligible.
- The school administrator or designee must initial all changes made to the paper application or transfer requests and must have written documentation to support the change.
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Parent signature and signature date must be completed before the school sent the IEP/Services plan verification email to the LEA AND before the application was submitted.
- The paper application or transfer request must be signed by an individual who was the SNSP Administrator or an SNSP designee as of the date the application was received.
- After the LEA has provided a copy of a student’s IEP/Services plan the SNSP Administrator or Designee needs to complete the final sections of the application noting final eligibility status, signature of the SNSP Administrator or Designee and date the final eligibility decision was made. At this time it is also important to compare the following items reported on the application to the information obtained from the LEA:
- Name of the LEA that developed the IEP or services plan
- Date of last IEP team or services plan evaluation or reevaluation reported on the application to the information obtained from the LEA.
There are a few items that DPI deems “uncorrectable” errors on the application which will immediately cause the student to be ineligible for SNSP. It is important that schools lookout for the following:
- The parent/guardian signature does not match the parent/guardian name.
- The paper application or transfer request is completed by a student who was not yet 18 at the time they completed the application or transfer request.
- The date application or transfer request received, parent/guardian signature or parent/guardian date signed was not filled out on the paper application or transfer request.
As is evident, the documentation requirements for SNSP applications can be cumbersome. Our best advice is to use the DPI’s SNSP application checklist and print one-off for each student’s file to use as a guide. The checklist can be found here:
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As always if you have any questions regarding these requirements, please contact your Hawkins Ash CPAs representative. |
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Erica Knerzer, CPA | Senior Audit Manager
D 608.793.3113
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A Common Mistake: Name Differences |
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Schools are required to verify the parent/guardian names on residency and income documentation match with the Online Application System (OAS) as part of the application verification process. When performing enrollment audits, we often find discrepancies where the OAS has the correct legal name of the parent /guardian but the name on the residency/income documents is different. Although these errors are correctable, it can be difficult to get a response from parents before the reporting deadline (December 15th for fall and May 1st for spring) if these types of errors are found during the enrollment audits. Here is a guide to determine if you need to obtain additional documentation:
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For certain cases where minor name differences exist, one way for the school to fix this right away would be to obtain a signed letter or an email from the parent stating the following: |
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“My correct legal name is (name in OAS). The name on my (residency or income) documentation is (name on documentation). My name is incorrectly spelled on the documentation and correct on the Online Parent Application” |
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Some common examples of cases where a letter from the parent would be sufficient:
- Name misspelled (Theresa vs Teresa)
- Name abbreviated (Dan vs Daniel)
- Multiple last names (Maria Gonzalez-Dominquez vs Maria Gonzalez)
A letter would not be sufficient for differences if there are different names. In these situations, new residency documentation will need to be obtained that meets the requirements. Here are some examples:
- Ralph Smith vs Ralph Weber
- Maria Gonzalez vs Maria Dominquez
- Ronald McGregory vs Thomas McGregory
Please note that the above applies only to situations where the OAS has the correct legal name of the parent/guardian. If corrections are needed to the OAS, different steps will need to be taken to address the issue.
At Hawkins Ash CPAs, our auditors are available to our clients throughout the year. To ensure a smooth audit, we prefer that clients contact us as the need arises. Please contact us today.
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Brittany Leonard, CPA | Partner
D 608.793.3123
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Take a look at all the important due dates for WPCP and SNSP for the 2022 calendar year. Print this out to have handy throughout the year. |
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Key Documentation for Student Applications |
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The DPI is very specific about the documents that must be received for student applications and the information in them. Below are points to remember as you review applications this year:
- If a family applied to the program using a Form 1040 (Joint or Indiv), the School must obtain a copy of the Form 1040 and it needs to include the 1st and 2nd page of the Form filed.
- The parents’ first and last names on the proof of residency and income verification documents must match the parents’ names in the Online Application System (OAS) exactly.
- Make sure one of the DPI-allowed documents for proof of residency is obtained. A complete list of acceptable documents can be found on the WI DPI Private School Choice Programs: DPI Bulletins website.
- If a utility or cable bill is used for proof of residency:
- The document should include the service address and the mailing address and they must match.
- Use the last read date or the service date to determine if the document meets the date requirements. The due date is not sufficient.
- Ensure the services include cable and/or landline services. A bill for internet-only services is not permissible.
- The proof of residency document should be the full document and should include the full address – house number, street, city, state, and zip code. Photos of only one part of the documentation or envelopes with the address should not be accepted.
- If it is determined a student moved as of the 3rd Friday in September, the School is required to obtain new residency documentation dated between August 20, 2022 and September 30, 2022.
- Ensure school district verification is obtained in every student’s file and that a method acceptable by DPI was used to verify the school district. A complete list of acceptable methods can be found on the WI DPI Private School Choice Programs: DPI Bulletins website.
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Emily Donohue, CPA | Manager
D 920.337.4542
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