FINDING 2022-003Subject: Child Nutrition Cluster - ReportingFederal Agency: Department of AgricultureFederal Programs: School Breakfast Program, National School Lunch Program, Summer Food ServiceProgram for Children, COVID-19 - Summer Food Service Program for ChildrenAssistance Listings Numbers: 10.553, 10.555, 10.559Federal Award Numbers and Years (or Other Identifying Numbers): FY 2021, FY 2022Pass-Through Entity: Indiana Department of EducationCompliance Requirement: ReportingAudit Findings: Material Weakness, Other MattersCondition and ContextAn internal control system was designed and implemented, but not effective, at the SchoolCorporation to ensure compliance with requirements related to the grant agreement and the Reportingcompliance requirement.Monthly Sponsor Claims for Reimbursement (Claims) were submitted to the Indiana Departmentof Education based upon meals served for the month. The monthly Claims were prepared by the FoodService Director and reviewed by the Business Manager; however, the internal control was not effective toprevent, or detect and correct, errors. For three of the seven monthly Claims tested, there were differencesbetween the Claims submitted and the School Corporation's summary meal count reports. The threeClaims had less meals served than the School Corporation's summary meal count reports, which resultedin underclaimed meals.The lack of adequate internal controls and noncompliance were systemic issues throughout theaudit period.INDIANA STATE BOARD OF ACCOUNTS19SOUTHWEST DUBOIS COUNTY SCHOOL CORPORATIONSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."7 CFR 210.8(a) states in part:"Internal controls. The school food authority shall establish internal controls which ensure theaccuracy of meal counts prior to the submission of the monthly Claim for Reimbursement. . . .(2) School food authority claims review process. Prior to the submission of a monthlyClaim for Reimbursement, each school food authority shall review the lunch count datafor each school under its jurisdiction to ensure the accuracy of the monthly Claim forReimbursement. . . ."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Reporting compliance requirement.EffectThe failure to establish an effective internal control system enabled material noncompliance to goundetected. Noncompliance with the grant agreement and the Reporting compliance requirement couldresult in the loss of future federal funds to the School Corporation.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish a system of internal controlsto ensure compliance and comply with the Reporting compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-003Subject: Child Nutrition Cluster - ReportingFederal Agency: Department of AgricultureFederal Programs: School Breakfast Program, National School Lunch Program, Summer Food ServiceProgram for Children, COVID-19 - Summer Food Service Program for ChildrenAssistance Listings Numbers: 10.553, 10.555, 10.559Federal Award Numbers and Years (or Other Identifying Numbers): FY 2021, FY 2022Pass-Through Entity: Indiana Department of EducationCompliance Requirement: ReportingAudit Findings: Material Weakness, Other MattersCondition and ContextAn internal control system was designed and implemented, but not effective, at the SchoolCorporation to ensure compliance with requirements related to the grant agreement and the Reportingcompliance requirement.Monthly Sponsor Claims for Reimbursement (Claims) were submitted to the Indiana Departmentof Education based upon meals served for the month. The monthly Claims were prepared by the FoodService Director and reviewed by the Business Manager; however, the internal control was not effective toprevent, or detect and correct, errors. For three of the seven monthly Claims tested, there were differencesbetween the Claims submitted and the School Corporation's summary meal count reports. The threeClaims had less meals served than the School Corporation's summary meal count reports, which resultedin underclaimed meals.The lack of adequate internal controls and noncompliance were systemic issues throughout theaudit period.INDIANA STATE BOARD OF ACCOUNTS19SOUTHWEST DUBOIS COUNTY SCHOOL CORPORATIONSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."7 CFR 210.8(a) states in part:"Internal controls. The school food authority shall establish internal controls which ensure theaccuracy of meal counts prior to the submission of the monthly Claim for Reimbursement. . . .(2) School food authority claims review process. Prior to the submission of a monthlyClaim for Reimbursement, each school food authority shall review the lunch count datafor each school under its jurisdiction to ensure the accuracy of the monthly Claim forReimbursement. . . ."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Reporting compliance requirement.EffectThe failure to establish an effective internal control system enabled material noncompliance to goundetected. Noncompliance with the grant agreement and the Reporting compliance requirement couldresult in the loss of future federal funds to the School Corporation.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish a system of internal controlsto ensure compliance and comply with the Reporting compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-003Subject: Child Nutrition Cluster - ReportingFederal Agency: Department of AgricultureFederal Programs: School Breakfast Program, National School Lunch Program, Summer Food ServiceProgram for Children, COVID-19 - Summer Food Service Program for ChildrenAssistance Listings Numbers: 10.553, 10.555, 10.559Federal Award Numbers and Years (or Other Identifying Numbers): FY 2021, FY 2022Pass-Through Entity: Indiana Department of EducationCompliance Requirement: ReportingAudit Findings: Material Weakness, Other MattersCondition and ContextAn internal control system was designed and implemented, but not effective, at the SchoolCorporation to ensure compliance with requirements related to the grant agreement and the Reportingcompliance requirement.Monthly Sponsor Claims for Reimbursement (Claims) were submitted to the Indiana Departmentof Education based upon meals served for the month. The monthly Claims were prepared by the FoodService Director and reviewed by the Business Manager; however, the internal control was not effective toprevent, or detect and correct, errors. For three of the seven monthly Claims tested, there were differencesbetween the Claims submitted and the School Corporation's summary meal count reports. The threeClaims had less meals served than the School Corporation's summary meal count reports, which resultedin underclaimed meals.The lack of adequate internal controls and noncompliance were systemic issues throughout theaudit period.INDIANA STATE BOARD OF ACCOUNTS19SOUTHWEST DUBOIS COUNTY SCHOOL CORPORATIONSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."7 CFR 210.8(a) states in part:"Internal controls. The school food authority shall establish internal controls which ensure theaccuracy of meal counts prior to the submission of the monthly Claim for Reimbursement. . . .(2) School food authority claims review process. Prior to the submission of a monthlyClaim for Reimbursement, each school food authority shall review the lunch count datafor each school under its jurisdiction to ensure the accuracy of the monthly Claim forReimbursement. . . ."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Reporting compliance requirement.EffectThe failure to establish an effective internal control system enabled material noncompliance to goundetected. Noncompliance with the grant agreement and the Reporting compliance requirement couldresult in the loss of future federal funds to the School Corporation.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish a system of internal controlsto ensure compliance and comply with the Reporting compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-003Subject: Child Nutrition Cluster - ReportingFederal Agency: Department of AgricultureFederal Programs: School Breakfast Program, National School Lunch Program, Summer Food ServiceProgram for Children, COVID-19 - Summer Food Service Program for ChildrenAssistance Listings Numbers: 10.553, 10.555, 10.559Federal Award Numbers and Years (or Other Identifying Numbers): FY 2021, FY 2022Pass-Through Entity: Indiana Department of EducationCompliance Requirement: ReportingAudit Findings: Material Weakness, Other MattersCondition and ContextAn internal control system was designed and implemented, but not effective, at the SchoolCorporation to ensure compliance with requirements related to the grant agreement and the Reportingcompliance requirement.Monthly Sponsor Claims for Reimbursement (Claims) were submitted to the Indiana Departmentof Education based upon meals served for the month. The monthly Claims were prepared by the FoodService Director and reviewed by the Business Manager; however, the internal control was not effective toprevent, or detect and correct, errors. For three of the seven monthly Claims tested, there were differencesbetween the Claims submitted and the School Corporation's summary meal count reports. The threeClaims had less meals served than the School Corporation's summary meal count reports, which resultedin underclaimed meals.The lack of adequate internal controls and noncompliance were systemic issues throughout theaudit period.INDIANA STATE BOARD OF ACCOUNTS19SOUTHWEST DUBOIS COUNTY SCHOOL CORPORATIONSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."7 CFR 210.8(a) states in part:"Internal controls. The school food authority shall establish internal controls which ensure theaccuracy of meal counts prior to the submission of the monthly Claim for Reimbursement. . . .(2) School food authority claims review process. Prior to the submission of a monthlyClaim for Reimbursement, each school food authority shall review the lunch count datafor each school under its jurisdiction to ensure the accuracy of the monthly Claim forReimbursement. . . ."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Reporting compliance requirement.EffectThe failure to establish an effective internal control system enabled material noncompliance to goundetected. Noncompliance with the grant agreement and the Reporting compliance requirement couldresult in the loss of future federal funds to the School Corporation.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish a system of internal controlsto ensure compliance and comply with the Reporting compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-003Subject: Child Nutrition Cluster - ReportingFederal Agency: Department of AgricultureFederal Programs: School Breakfast Program, National School Lunch Program, Summer Food ServiceProgram for Children, COVID-19 - Summer Food Service Program for ChildrenAssistance Listings Numbers: 10.553, 10.555, 10.559Federal Award Numbers and Years (or Other Identifying Numbers): FY 2021, FY 2022Pass-Through Entity: Indiana Department of EducationCompliance Requirement: ReportingAudit Findings: Material Weakness, Other MattersCondition and ContextAn internal control system was designed and implemented, but not effective, at the SchoolCorporation to ensure compliance with requirements related to the grant agreement and the Reportingcompliance requirement.Monthly Sponsor Claims for Reimbursement (Claims) were submitted to the Indiana Departmentof Education based upon meals served for the month. The monthly Claims were prepared by the FoodService Director and reviewed by the Business Manager; however, the internal control was not effective toprevent, or detect and correct, errors. For three of the seven monthly Claims tested, there were differencesbetween the Claims submitted and the School Corporation's summary meal count reports. The threeClaims had less meals served than the School Corporation's summary meal count reports, which resultedin underclaimed meals.The lack of adequate internal controls and noncompliance were systemic issues throughout theaudit period.INDIANA STATE BOARD OF ACCOUNTS19SOUTHWEST DUBOIS COUNTY SCHOOL CORPORATIONSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."7 CFR 210.8(a) states in part:"Internal controls. The school food authority shall establish internal controls which ensure theaccuracy of meal counts prior to the submission of the monthly Claim for Reimbursement. . . .(2) School food authority claims review process. Prior to the submission of a monthlyClaim for Reimbursement, each school food authority shall review the lunch count datafor each school under its jurisdiction to ensure the accuracy of the monthly Claim forReimbursement. . . ."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Reporting compliance requirement.EffectThe failure to establish an effective internal control system enabled material noncompliance to goundetected. Noncompliance with the grant agreement and the Reporting compliance requirement couldresult in the loss of future federal funds to the School Corporation.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish a system of internal controlsto ensure compliance and comply with the Reporting compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-003Subject: Child Nutrition Cluster - ReportingFederal Agency: Department of AgricultureFederal Programs: School Breakfast Program, National School Lunch Program, Summer Food ServiceProgram for Children, COVID-19 - Summer Food Service Program for ChildrenAssistance Listings Numbers: 10.553, 10.555, 10.559Federal Award Numbers and Years (or Other Identifying Numbers): FY 2021, FY 2022Pass-Through Entity: Indiana Department of EducationCompliance Requirement: ReportingAudit Findings: Material Weakness, Other MattersCondition and ContextAn internal control system was designed and implemented, but not effective, at the SchoolCorporation to ensure compliance with requirements related to the grant agreement and the Reportingcompliance requirement.Monthly Sponsor Claims for Reimbursement (Claims) were submitted to the Indiana Departmentof Education based upon meals served for the month. The monthly Claims were prepared by the FoodService Director and reviewed by the Business Manager; however, the internal control was not effective toprevent, or detect and correct, errors. For three of the seven monthly Claims tested, there were differencesbetween the Claims submitted and the School Corporation's summary meal count reports. The threeClaims had less meals served than the School Corporation's summary meal count reports, which resultedin underclaimed meals.The lack of adequate internal controls and noncompliance were systemic issues throughout theaudit period.INDIANA STATE BOARD OF ACCOUNTS19SOUTHWEST DUBOIS COUNTY SCHOOL CORPORATIONSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."7 CFR 210.8(a) states in part:"Internal controls. The school food authority shall establish internal controls which ensure theaccuracy of meal counts prior to the submission of the monthly Claim for Reimbursement. . . .(2) School food authority claims review process. Prior to the submission of a monthlyClaim for Reimbursement, each school food authority shall review the lunch count datafor each school under its jurisdiction to ensure the accuracy of the monthly Claim forReimbursement. . . ."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Reporting compliance requirement.EffectThe failure to establish an effective internal control system enabled material noncompliance to goundetected. Noncompliance with the grant agreement and the Reporting compliance requirement couldresult in the loss of future federal funds to the School Corporation.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish a system of internal controlsto ensure compliance and comply with the Reporting compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-003Subject: Child Nutrition Cluster - ReportingFederal Agency: Department of AgricultureFederal Programs: School Breakfast Program, National School Lunch Program, Summer Food ServiceProgram for Children, COVID-19 - Summer Food Service Program for ChildrenAssistance Listings Numbers: 10.553, 10.555, 10.559Federal Award Numbers and Years (or Other Identifying Numbers): FY 2021, FY 2022Pass-Through Entity: Indiana Department of EducationCompliance Requirement: ReportingAudit Findings: Material Weakness, Other MattersCondition and ContextAn internal control system was designed and implemented, but not effective, at the SchoolCorporation to ensure compliance with requirements related to the grant agreement and the Reportingcompliance requirement.Monthly Sponsor Claims for Reimbursement (Claims) were submitted to the Indiana Departmentof Education based upon meals served for the month. The monthly Claims were prepared by the FoodService Director and reviewed by the Business Manager; however, the internal control was not effective toprevent, or detect and correct, errors. For three of the seven monthly Claims tested, there were differencesbetween the Claims submitted and the School Corporation's summary meal count reports. The threeClaims had less meals served than the School Corporation's summary meal count reports, which resultedin underclaimed meals.The lack of adequate internal controls and noncompliance were systemic issues throughout theaudit period.INDIANA STATE BOARD OF ACCOUNTS19SOUTHWEST DUBOIS COUNTY SCHOOL CORPORATIONSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."7 CFR 210.8(a) states in part:"Internal controls. The school food authority shall establish internal controls which ensure theaccuracy of meal counts prior to the submission of the monthly Claim for Reimbursement. . . .(2) School food authority claims review process. Prior to the submission of a monthlyClaim for Reimbursement, each school food authority shall review the lunch count datafor each school under its jurisdiction to ensure the accuracy of the monthly Claim forReimbursement. . . ."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Reporting compliance requirement.EffectThe failure to establish an effective internal control system enabled material noncompliance to goundetected. Noncompliance with the grant agreement and the Reporting compliance requirement couldresult in the loss of future federal funds to the School Corporation.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish a system of internal controlsto ensure compliance and comply with the Reporting compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-004Subject: Special Education Cluster (IDEA) - EarmarkingFederal Agency: Department of EducationFederal Program: Special Education Grants to StatesAssistance Listings Number: 84.027Federal Award Number and Year (or Other Identifying Number): 21611-009-PN01Pass-Through Entity: Indiana Department of EducationCompliance Requirement: Matching, Level of Effort, EarmarkingAudit Findings: Material Weakness, Modified OpinionCondition and ContextThe School Corporation is a member of the Exceptional Children's Co-op (Cooperative). Duringfiscal year 2021-2022, the Cooperative operated the special education programs and spent the federalmoney on behalf of all its member schools. As the grant agreements were between the Indiana Departmentof Education (IDOE) and each member school, the School Corporation was responsible for ensuring andproviding oversight of the Cooperative. There was inadequate oversight performed by the SchoolCorporation in order to ensure compliance with the Matching, Level of Effort, Earmarking compliancerequirement.The School Corporation did not have internal controls in place to ensure that the Cooperativecomplied with the earmarking requirements. The Cooperative did not have adequate procedures in placeto ensure that the required level of expenditures for non-public school students with disabilities was met foreach member school. The Cooperative did not have effective internal controls to ensure non-public schoolexpenditures were appropriately identified and reported.The Non-Public Proportionate Share expenditures for the 21611-009-PN01 grant award could notbe verified for the individual member schools. Total grant expenditures were posted as expended. Thenon-public proportionate share expenditures were determined by applying a percentage to the non-publicschool budgeted expenditures. These were the amounts reported to the IDOE. As such, we were unableto identify if the minimum amount per the grant award was expended and properly reported to the IDOE asrequired.The lack of internal controls and noncompliance was isolated to the 21611-009-PN01 grant award.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."INDIANA STATE BOARD OF ACCOUNTS21SOUTHWEST DUBOIS COUNTY SCHOOL CORPORATIONSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)2 CFR 200.403 states in part:"Except where otherwise authorized by statute, costs must meet the following general criteriain order to be allowable under Federal awards: . . .(g) Be adequately documented. . . ."2 CFR 200.208(b) states in part: "The Federal awarding agency or pass-through entity may adjustspecific Federal award conditions as needed . . ."511 IAC 7-34-7(b) states:"The public agency, in providing special education and related services to students in nonpublicschools must expend at least an amount that is the same proportion of the public agency totalsubgrant under 20 U.S.C. 1411(f) as the number of nonpublic school students with disabilities,who are enrolled by their parents in nonpublic schools within its boundaries, is to the totalnumber of students with disabilities of the same age range."CauseThe School Corporation's management had not developed an effective system of internal controlsthat would have ensured compliance with the grant agreements and the earmarking requirements of theMatching, Level of Effort, Earmarking compliance requirement.EffectThe failure to establish an effective internal control system, as well as adequately document costsof federal awards, prevented the determination of the School Corporation's compliance with the earmarkingrequirements of the Matching, Level of Effort, Earmarking compliance requirement.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish an effective system ofinternal controls, as well as appropriately document and identify federal award expenditures to ensure compliancewith the Matching, Level of Effort, Earmarking compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-004Subject: Special Education Cluster (IDEA) - EarmarkingFederal Agency: Department of EducationFederal Program: Special Education Grants to StatesAssistance Listings Number: 84.027Federal Award Number and Year (or Other Identifying Number): 21611-009-PN01Pass-Through Entity: Indiana Department of EducationCompliance Requirement: Matching, Level of Effort, EarmarkingAudit Findings: Material Weakness, Modified OpinionCondition and ContextThe School Corporation is a member of the Exceptional Children's Co-op (Cooperative). Duringfiscal year 2021-2022, the Cooperative operated the special education programs and spent the federalmoney on behalf of all its member schools. As the grant agreements were between the Indiana Departmentof Education (IDOE) and each member school, the School Corporation was responsible for ensuring andproviding oversight of the Cooperative. There was inadequate oversight performed by the SchoolCorporation in order to ensure compliance with the Matching, Level of Effort, Earmarking compliancerequirement.The School Corporation did not have internal controls in place to ensure that the Cooperativecomplied with the earmarking requirements. The Cooperative did not have adequate procedures in placeto ensure that the required level of expenditures for non-public school students with disabilities was met foreach member school. The Cooperative did not have effective internal controls to ensure non-public schoolexpenditures were appropriately identified and reported.The Non-Public Proportionate Share expenditures for the 21611-009-PN01 grant award could notbe verified for the individual member schools. Total grant expenditures were posted as expended. Thenon-public proportionate share expenditures were determined by applying a percentage to the non-publicschool budgeted expenditures. These were the amounts reported to the IDOE. As such, we were unableto identify if the minimum amount per the grant award was expended and properly reported to the IDOE asrequired.The lack of internal controls and noncompliance was isolated to the 21611-009-PN01 grant award.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."INDIANA STATE BOARD OF ACCOUNTS21SOUTHWEST DUBOIS COUNTY SCHOOL CORPORATIONSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)2 CFR 200.403 states in part:"Except where otherwise authorized by statute, costs must meet the following general criteriain order to be allowable under Federal awards: . . .(g) Be adequately documented. . . ."2 CFR 200.208(b) states in part: "The Federal awarding agency or pass-through entity may adjustspecific Federal award conditions as needed . . ."511 IAC 7-34-7(b) states:"The public agency, in providing special education and related services to students in nonpublicschools must expend at least an amount that is the same proportion of the public agency totalsubgrant under 20 U.S.C. 1411(f) as the number of nonpublic school students with disabilities,who are enrolled by their parents in nonpublic schools within its boundaries, is to the totalnumber of students with disabilities of the same age range."CauseThe School Corporation's management had not developed an effective system of internal controlsthat would have ensured compliance with the grant agreements and the earmarking requirements of theMatching, Level of Effort, Earmarking compliance requirement.EffectThe failure to establish an effective internal control system, as well as adequately document costsof federal awards, prevented the determination of the School Corporation's compliance with the earmarkingrequirements of the Matching, Level of Effort, Earmarking compliance requirement.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish an effective system ofinternal controls, as well as appropriately document and identify federal award expenditures to ensure compliancewith the Matching, Level of Effort, Earmarking compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-001Subject: COVID-19 - Education Stabilization Fund - Allowable Costs/Cost PrinciplesFederal Agency: Department of EducationFederal Program: COVID-19 - Education Stabilization FundAssistance Listings Number: 84.425DFederal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: Allowable Costs/Cost PrinciplesAudit Findings: Significant Deficiency, Other MattersCondition and ContextAn effective internal control system was not in place at the School Corporation to ensure compliancewith requirements related to the grant agreement and the Allowable Costs/Cost Principles compliancerequirement.Charges to Federal awards for salaries and wages must be based on records that accurately reflectthe work performed. One employee was paid from ESSER I and ESSER II grant awards and also fromother funding sources. Adequate time records were not maintained for the employee to determine if theproper amount was charged to the federal award. The total amount charged to the federal award of $28,599was considered a questioned cost.The lack of internal controls and noncompliance were systemic issues throughout the audit period.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.430(i) states in part:"Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salariesand wages must be based on records that accurately reflect the work performed. Theserecords must:(i) Be supported by a system of internal control which provides reasonable assurance thatthe charges are accurate, allowable, and properly allocated;(ii) Be incorporated into the official records of the non-Federal entity;INDIANA STATE BOARD OF ACCOUNTS16SOUTHWEST DUBOIS COUNTY SCHOOL CORPORATIONSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)(iii) Reasonably reflect the total activity for which the employee is compensated by thenon-Federal entity, not exceeding 100% of compensated activities (for IHE, this perthe IHE's definition of IBS); . . .(vii) Support the distribution of the employee's salary or wages among specific activitiesor cost objectives if the employee works on more than one Federal award; a Federalaward and non-Federal award; an indirect cost activity and a direct cost activity; twoor more indirect activities which allocated using different allocation bases; or anunallowable activity and a direct or indirect costs activity. . . ."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Allowable Costs/Cost Principles compliance requirement.EffectThe failure to establish an effective internal control system enabled noncompliance to go undetected.Noncompliance with the grant agreement and the Allowable Costs/Cost Principles compliancerequirement could result in the loss of future federal funds to the School Corporation.Questioned CostsQuestioned costs of $28,599 were identified as detailed in the Condition and Context.RecommendationWe recommended that the School Corporation's management establish internal controls to ensurecompliance and comply with the grant agreement and the Allowable Costs/Cost Principles compliancerequirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-001Subject: COVID-19 - Education Stabilization Fund - Allowable Costs/Cost PrinciplesFederal Agency: Department of EducationFederal Program: COVID-19 - Education Stabilization FundAssistance Listings Number: 84.425DFederal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: Allowable Costs/Cost PrinciplesAudit Findings: Significant Deficiency, Other MattersCondition and ContextAn effective internal control system was not in place at the School Corporation to ensure compliancewith requirements related to the grant agreement and the Allowable Costs/Cost Principles compliancerequirement.Charges to Federal awards for salaries and wages must be based on records that accurately reflectthe work performed. One employee was paid from ESSER I and ESSER II grant awards and also fromother funding sources. Adequate time records were not maintained for the employee to determine if theproper amount was charged to the federal award. The total amount charged to the federal award of $28,599was considered a questioned cost.The lack of internal controls and noncompliance were systemic issues throughout the audit period.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.430(i) states in part:"Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salariesand wages must be based on records that accurately reflect the work performed. Theserecords must:(i) Be supported by a system of internal control which provides reasonable assurance thatthe charges are accurate, allowable, and properly allocated;(ii) Be incorporated into the official records of the non-Federal entity;INDIANA STATE BOARD OF ACCOUNTS16SOUTHWEST DUBOIS COUNTY SCHOOL CORPORATIONSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)(iii) Reasonably reflect the total activity for which the employee is compensated by thenon-Federal entity, not exceeding 100% of compensated activities (for IHE, this perthe IHE's definition of IBS); . . .(vii) Support the distribution of the employee's salary or wages among specific activitiesor cost objectives if the employee works on more than one Federal award; a Federalaward and non-Federal award; an indirect cost activity and a direct cost activity; twoor more indirect activities which allocated using different allocation bases; or anunallowable activity and a direct or indirect costs activity. . . ."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Allowable Costs/Cost Principles compliance requirement.EffectThe failure to establish an effective internal control system enabled noncompliance to go undetected.Noncompliance with the grant agreement and the Allowable Costs/Cost Principles compliancerequirement could result in the loss of future federal funds to the School Corporation.Questioned CostsQuestioned costs of $28,599 were identified as detailed in the Condition and Context.RecommendationWe recommended that the School Corporation's management establish internal controls to ensurecompliance and comply with the grant agreement and the Allowable Costs/Cost Principles compliancerequirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-001Subject: COVID-19 - Education Stabilization Fund - Allowable Costs/Cost PrinciplesFederal Agency: Department of EducationFederal Program: COVID-19 - Education Stabilization FundAssistance Listings Number: 84.425DFederal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: Allowable Costs/Cost PrinciplesAudit Findings: Significant Deficiency, Other MattersCondition and ContextAn effective internal control system was not in place at the School Corporation to ensure compliancewith requirements related to the grant agreement and the Allowable Costs/Cost Principles compliancerequirement.Charges to Federal awards for salaries and wages must be based on records that accurately reflectthe work performed. One employee was paid from ESSER I and ESSER II grant awards and also fromother funding sources. Adequate time records were not maintained for the employee to determine if theproper amount was charged to the federal award. The total amount charged to the federal award of $28,599was considered a questioned cost.The lack of internal controls and noncompliance were systemic issues throughout the audit period.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.430(i) states in part:"Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salariesand wages must be based on records that accurately reflect the work performed. Theserecords must:(i) Be supported by a system of internal control which provides reasonable assurance thatthe charges are accurate, allowable, and properly allocated;(ii) Be incorporated into the official records of the non-Federal entity;INDIANA STATE BOARD OF ACCOUNTS16SOUTHWEST DUBOIS COUNTY SCHOOL CORPORATIONSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)(iii) Reasonably reflect the total activity for which the employee is compensated by thenon-Federal entity, not exceeding 100% of compensated activities (for IHE, this perthe IHE's definition of IBS); . . .(vii) Support the distribution of the employee's salary or wages among specific activitiesor cost objectives if the employee works on more than one Federal award; a Federalaward and non-Federal award; an indirect cost activity and a direct cost activity; twoor more indirect activities which allocated using different allocation bases; or anunallowable activity and a direct or indirect costs activity. . . ."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Allowable Costs/Cost Principles compliance requirement.EffectThe failure to establish an effective internal control system enabled noncompliance to go undetected.Noncompliance with the grant agreement and the Allowable Costs/Cost Principles compliancerequirement could result in the loss of future federal funds to the School Corporation.Questioned CostsQuestioned costs of $28,599 were identified as detailed in the Condition and Context.RecommendationWe recommended that the School Corporation's management establish internal controls to ensurecompliance and comply with the grant agreement and the Allowable Costs/Cost Principles compliancerequirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-002Subject: COVID-19 - Education Stabilization Fund - ReportingFederal Agency: Department of EducationFederal Program: COVID-19 - Education Stabilization FundAssistance Listings Number: 84.425DFederal Award Number and Year (or Other Identifying Number): S425D200013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: ReportingAudit Findings: Material Weakness, Other MattersCondition and ContextAn effective internal control system was not in place at the School Corporation to ensure compliancewith requirements related to the grant agreement and the Reporting compliance requirement.INDIANA STATE BOARD OF ACCOUNTS17SOUTHWEST DUBOIS COUNTY SCHOOL CORPORATIONSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)One of five annual reports required to be completed during the audit period contained materialerrors. The Elementary and Secondary School Emergency Relief (ESSER I), Year 1 annual data reportoverstated total expenditures made between March 13, 2020, and September, 30, 2020, by $130,918. Inaddition, documentation provided for the number of full-time employee positions did not support theamounts reported.The lack of internal controls and noncompliance were systemic issues throughout the audit period.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.334 states in part:"Financial records, supporting documents, statistical records, and all other non-Federal entityrecords pertinent to a Federal award must be retained for a period of three years from the dateof submission of the final expenditure report or, for Federal awards that are renewed quarterlyor annually, from the date of the submission of the quarterly or annual financial report,respectively, as reported to the Federal awarding agency or pass-through entity in the case ofa subrecipient. . . ."2 CFR 200.302(b) states in part:"The financial management system of each non-Federal entity must provide for the following:. . .(2) Accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with the reporting requirements set forth in ?? 200.328and 200.329. . . .(3) Records that identify adequately the source and application of funds for federallyfunded activities. These records must contain information pertaining to Federalawards, authorizations, obligations, unobligated balances, assets, expenditures,income and interest and be supported by source documentation. . . ."34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and formatthat assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out otherresponsibilities under the program."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Reporting compliance requirement.INDIANA STATE BOARD OF ACCOUNTS18SOUTHWEST DUBOIS COUNTY SCHOOL CORPORATIONSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)EffectThe failure to establish an effective internal control system enabled material noncompliance to goundetected. Noncompliance with the grant agreement and the Reporting compliance requirement couldresult in the loss of future federal funds to the School Corporation.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish internal controls to ensurecompliance and comply with the grant agreement and the Reporting compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-002Subject: COVID-19 - Education Stabilization Fund - ReportingFederal Agency: Department of EducationFederal Program: COVID-19 - Education Stabilization FundAssistance Listings Number: 84.425DFederal Award Number and Year (or Other Identifying Number): S425D200013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: ReportingAudit Findings: Material Weakness, Other MattersCondition and ContextAn effective internal control system was not in place at the School Corporation to ensure compliancewith requirements related to the grant agreement and the Reporting compliance requirement.INDIANA STATE BOARD OF ACCOUNTS17SOUTHWEST DUBOIS COUNTY SCHOOL CORPORATIONSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)One of five annual reports required to be completed during the audit period contained materialerrors. The Elementary and Secondary School Emergency Relief (ESSER I), Year 1 annual data reportoverstated total expenditures made between March 13, 2020, and September, 30, 2020, by $130,918. Inaddition, documentation provided for the number of full-time employee positions did not support theamounts reported.The lack of internal controls and noncompliance were systemic issues throughout the audit period.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.334 states in part:"Financial records, supporting documents, statistical records, and all other non-Federal entityrecords pertinent to a Federal award must be retained for a period of three years from the dateof submission of the final expenditure report or, for Federal awards that are renewed quarterlyor annually, from the date of the submission of the quarterly or annual financial report,respectively, as reported to the Federal awarding agency or pass-through entity in the case ofa subrecipient. . . ."2 CFR 200.302(b) states in part:"The financial management system of each non-Federal entity must provide for the following:. . .(2) Accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with the reporting requirements set forth in ?? 200.328and 200.329. . . .(3) Records that identify adequately the source and application of funds for federallyfunded activities. These records must contain information pertaining to Federalawards, authorizations, obligations, unobligated balances, assets, expenditures,income and interest and be supported by source documentation. . . ."34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and formatthat assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out otherresponsibilities under the program."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Reporting compliance requirement.INDIANA STATE BOARD OF ACCOUNTS18SOUTHWEST DUBOIS COUNTY SCHOOL CORPORATIONSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)EffectThe failure to establish an effective internal control system enabled material noncompliance to goundetected. Noncompliance with the grant agreement and the Reporting compliance requirement couldresult in the loss of future federal funds to the School Corporation.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish internal controls to ensurecompliance and comply with the grant agreement and the Reporting compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-003Subject: Child Nutrition Cluster - ReportingFederal Agency: Department of AgricultureFederal Programs: School Breakfast Program, National School Lunch Program, Summer Food ServiceProgram for Children, COVID-19 - Summer Food Service Program for ChildrenAssistance Listings Numbers: 10.553, 10.555, 10.559Federal Award Numbers and Years (or Other Identifying Numbers): FY 2021, FY 2022Pass-Through Entity: Indiana Department of EducationCompliance Requirement: ReportingAudit Findings: Material Weakness, Other MattersCondition and ContextAn internal control system was designed and implemented, but not effective, at the SchoolCorporation to ensure compliance with requirements related to the grant agreement and the Reportingcompliance requirement.Monthly Sponsor Claims for Reimbursement (Claims) were submitted to the Indiana Departmentof Education based upon meals served for the month. The monthly Claims were prepared by the FoodService Director and reviewed by the Business Manager; however, the internal control was not effective toprevent, or detect and correct, errors. For three of the seven monthly Claims tested, there were differencesbetween the Claims submitted and the School Corporation's summary meal count reports. The threeClaims had less meals served than the School Corporation's summary meal count reports, which resultedin underclaimed meals.The lack of adequate internal controls and noncompliance were systemic issues throughout theaudit period.INDIANA STATE BOARD OF ACCOUNTS19SOUTHWEST DUBOIS COUNTY SCHOOL CORPORATIONSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."7 CFR 210.8(a) states in part:"Internal controls. The school food authority shall establish internal controls which ensure theaccuracy of meal counts prior to the submission of the monthly Claim for Reimbursement. . . .(2) School food authority claims review process. Prior to the submission of a monthlyClaim for Reimbursement, each school food authority shall review the lunch count datafor each school under its jurisdiction to ensure the accuracy of the monthly Claim forReimbursement. . . ."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Reporting compliance requirement.EffectThe failure to establish an effective internal control system enabled material noncompliance to goundetected. Noncompliance with the grant agreement and the Reporting compliance requirement couldresult in the loss of future federal funds to the School Corporation.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish a system of internal controlsto ensure compliance and comply with the Reporting compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-003Subject: Child Nutrition Cluster - ReportingFederal Agency: Department of AgricultureFederal Programs: School Breakfast Program, National School Lunch Program, Summer Food ServiceProgram for Children, COVID-19 - Summer Food Service Program for ChildrenAssistance Listings Numbers: 10.553, 10.555, 10.559Federal Award Numbers and Years (or Other Identifying Numbers): FY 2021, FY 2022Pass-Through Entity: Indiana Department of EducationCompliance Requirement: ReportingAudit Findings: Material Weakness, Other MattersCondition and ContextAn internal control system was designed and implemented, but not effective, at the SchoolCorporation to ensure compliance with requirements related to the grant agreement and the Reportingcompliance requirement.Monthly Sponsor Claims for Reimbursement (Claims) were submitted to the Indiana Departmentof Education based upon meals served for the month. The monthly Claims were prepared by the FoodService Director and reviewed by the Business Manager; however, the internal control was not effective toprevent, or detect and correct, errors. For three of the seven monthly Claims tested, there were differencesbetween the Claims submitted and the School Corporation's summary meal count reports. The threeClaims had less meals served than the School Corporation's summary meal count reports, which resultedin underclaimed meals.The lack of adequate internal controls and noncompliance were systemic issues throughout theaudit period.INDIANA STATE BOARD OF ACCOUNTS19SOUTHWEST DUBOIS COUNTY SCHOOL CORPORATIONSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."7 CFR 210.8(a) states in part:"Internal controls. The school food authority shall establish internal controls which ensure theaccuracy of meal counts prior to the submission of the monthly Claim for Reimbursement. . . .(2) School food authority claims review process. Prior to the submission of a monthlyClaim for Reimbursement, each school food authority shall review the lunch count datafor each school under its jurisdiction to ensure the accuracy of the monthly Claim forReimbursement. . . ."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Reporting compliance requirement.EffectThe failure to establish an effective internal control system enabled material noncompliance to goundetected. Noncompliance with the grant agreement and the Reporting compliance requirement couldresult in the loss of future federal funds to the School Corporation.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish a system of internal controlsto ensure compliance and comply with the Reporting compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-003Subject: Child Nutrition Cluster - ReportingFederal Agency: Department of AgricultureFederal Programs: School Breakfast Program, National School Lunch Program, Summer Food ServiceProgram for Children, COVID-19 - Summer Food Service Program for ChildrenAssistance Listings Numbers: 10.553, 10.555, 10.559Federal Award Numbers and Years (or Other Identifying Numbers): FY 2021, FY 2022Pass-Through Entity: Indiana Department of EducationCompliance Requirement: ReportingAudit Findings: Material Weakness, Other MattersCondition and ContextAn internal control system was designed and implemented, but not effective, at the SchoolCorporation to ensure compliance with requirements related to the grant agreement and the Reportingcompliance requirement.Monthly Sponsor Claims for Reimbursement (Claims) were submitted to the Indiana Departmentof Education based upon meals served for the month. The monthly Claims were prepared by the FoodService Director and reviewed by the Business Manager; however, the internal control was not effective toprevent, or detect and correct, errors. For three of the seven monthly Claims tested, there were differencesbetween the Claims submitted and the School Corporation's summary meal count reports. The threeClaims had less meals served than the School Corporation's summary meal count reports, which resultedin underclaimed meals.The lack of adequate internal controls and noncompliance were systemic issues throughout theaudit period.INDIANA STATE BOARD OF ACCOUNTS19SOUTHWEST DUBOIS COUNTY SCHOOL CORPORATIONSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."7 CFR 210.8(a) states in part:"Internal controls. The school food authority shall establish internal controls which ensure theaccuracy of meal counts prior to the submission of the monthly Claim for Reimbursement. . . .(2) School food authority claims review process. Prior to the submission of a monthlyClaim for Reimbursement, each school food authority shall review the lunch count datafor each school under its jurisdiction to ensure the accuracy of the monthly Claim forReimbursement. . . ."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Reporting compliance requirement.EffectThe failure to establish an effective internal control system enabled material noncompliance to goundetected. Noncompliance with the grant agreement and the Reporting compliance requirement couldresult in the loss of future federal funds to the School Corporation.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish a system of internal controlsto ensure compliance and comply with the Reporting compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-003Subject: Child Nutrition Cluster - ReportingFederal Agency: Department of AgricultureFederal Programs: School Breakfast Program, National School Lunch Program, Summer Food ServiceProgram for Children, COVID-19 - Summer Food Service Program for ChildrenAssistance Listings Numbers: 10.553, 10.555, 10.559Federal Award Numbers and Years (or Other Identifying Numbers): FY 2021, FY 2022Pass-Through Entity: Indiana Department of EducationCompliance Requirement: ReportingAudit Findings: Material Weakness, Other MattersCondition and ContextAn internal control system was designed and implemented, but not effective, at the SchoolCorporation to ensure compliance with requirements related to the grant agreement and the Reportingcompliance requirement.Monthly Sponsor Claims for Reimbursement (Claims) were submitted to the Indiana Departmentof Education based upon meals served for the month. The monthly Claims were prepared by the FoodService Director and reviewed by the Business Manager; however, the internal control was not effective toprevent, or detect and correct, errors. For three of the seven monthly Claims tested, there were differencesbetween the Claims submitted and the School Corporation's summary meal count reports. The threeClaims had less meals served than the School Corporation's summary meal count reports, which resultedin underclaimed meals.The lack of adequate internal controls and noncompliance were systemic issues throughout theaudit period.INDIANA STATE BOARD OF ACCOUNTS19SOUTHWEST DUBOIS COUNTY SCHOOL CORPORATIONSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."7 CFR 210.8(a) states in part:"Internal controls. The school food authority shall establish internal controls which ensure theaccuracy of meal counts prior to the submission of the monthly Claim for Reimbursement. . . .(2) School food authority claims review process. Prior to the submission of a monthlyClaim for Reimbursement, each school food authority shall review the lunch count datafor each school under its jurisdiction to ensure the accuracy of the monthly Claim forReimbursement. . . ."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Reporting compliance requirement.EffectThe failure to establish an effective internal control system enabled material noncompliance to goundetected. Noncompliance with the grant agreement and the Reporting compliance requirement couldresult in the loss of future federal funds to the School Corporation.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish a system of internal controlsto ensure compliance and comply with the Reporting compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-003Subject: Child Nutrition Cluster - ReportingFederal Agency: Department of AgricultureFederal Programs: School Breakfast Program, National School Lunch Program, Summer Food ServiceProgram for Children, COVID-19 - Summer Food Service Program for ChildrenAssistance Listings Numbers: 10.553, 10.555, 10.559Federal Award Numbers and Years (or Other Identifying Numbers): FY 2021, FY 2022Pass-Through Entity: Indiana Department of EducationCompliance Requirement: ReportingAudit Findings: Material Weakness, Other MattersCondition and ContextAn internal control system was designed and implemented, but not effective, at the SchoolCorporation to ensure compliance with requirements related to the grant agreement and the Reportingcompliance requirement.Monthly Sponsor Claims for Reimbursement (Claims) were submitted to the Indiana Departmentof Education based upon meals served for the month. The monthly Claims were prepared by the FoodService Director and reviewed by the Business Manager; however, the internal control was not effective toprevent, or detect and correct, errors. For three of the seven monthly Claims tested, there were differencesbetween the Claims submitted and the School Corporation's summary meal count reports. The threeClaims had less meals served than the School Corporation's summary meal count reports, which resultedin underclaimed meals.The lack of adequate internal controls and noncompliance were systemic issues throughout theaudit period.INDIANA STATE BOARD OF ACCOUNTS19SOUTHWEST DUBOIS COUNTY SCHOOL CORPORATIONSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."7 CFR 210.8(a) states in part:"Internal controls. The school food authority shall establish internal controls which ensure theaccuracy of meal counts prior to the submission of the monthly Claim for Reimbursement. . . .(2) School food authority claims review process. Prior to the submission of a monthlyClaim for Reimbursement, each school food authority shall review the lunch count datafor each school under its jurisdiction to ensure the accuracy of the monthly Claim forReimbursement. . . ."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Reporting compliance requirement.EffectThe failure to establish an effective internal control system enabled material noncompliance to goundetected. Noncompliance with the grant agreement and the Reporting compliance requirement couldresult in the loss of future federal funds to the School Corporation.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish a system of internal controlsto ensure compliance and comply with the Reporting compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-003Subject: Child Nutrition Cluster - ReportingFederal Agency: Department of AgricultureFederal Programs: School Breakfast Program, National School Lunch Program, Summer Food ServiceProgram for Children, COVID-19 - Summer Food Service Program for ChildrenAssistance Listings Numbers: 10.553, 10.555, 10.559Federal Award Numbers and Years (or Other Identifying Numbers): FY 2021, FY 2022Pass-Through Entity: Indiana Department of EducationCompliance Requirement: ReportingAudit Findings: Material Weakness, Other MattersCondition and ContextAn internal control system was designed and implemented, but not effective, at the SchoolCorporation to ensure compliance with requirements related to the grant agreement and the Reportingcompliance requirement.Monthly Sponsor Claims for Reimbursement (Claims) were submitted to the Indiana Departmentof Education based upon meals served for the month. The monthly Claims were prepared by the FoodService Director and reviewed by the Business Manager; however, the internal control was not effective toprevent, or detect and correct, errors. For three of the seven monthly Claims tested, there were differencesbetween the Claims submitted and the School Corporation's summary meal count reports. The threeClaims had less meals served than the School Corporation's summary meal count reports, which resultedin underclaimed meals.The lack of adequate internal controls and noncompliance were systemic issues throughout theaudit period.INDIANA STATE BOARD OF ACCOUNTS19SOUTHWEST DUBOIS COUNTY SCHOOL CORPORATIONSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."7 CFR 210.8(a) states in part:"Internal controls. The school food authority shall establish internal controls which ensure theaccuracy of meal counts prior to the submission of the monthly Claim for Reimbursement. . . .(2) School food authority claims review process. Prior to the submission of a monthlyClaim for Reimbursement, each school food authority shall review the lunch count datafor each school under its jurisdiction to ensure the accuracy of the monthly Claim forReimbursement. . . ."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Reporting compliance requirement.EffectThe failure to establish an effective internal control system enabled material noncompliance to goundetected. Noncompliance with the grant agreement and the Reporting compliance requirement couldresult in the loss of future federal funds to the School Corporation.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish a system of internal controlsto ensure compliance and comply with the Reporting compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-003Subject: Child Nutrition Cluster - ReportingFederal Agency: Department of AgricultureFederal Programs: School Breakfast Program, National School Lunch Program, Summer Food ServiceProgram for Children, COVID-19 - Summer Food Service Program for ChildrenAssistance Listings Numbers: 10.553, 10.555, 10.559Federal Award Numbers and Years (or Other Identifying Numbers): FY 2021, FY 2022Pass-Through Entity: Indiana Department of EducationCompliance Requirement: ReportingAudit Findings: Material Weakness, Other MattersCondition and ContextAn internal control system was designed and implemented, but not effective, at the SchoolCorporation to ensure compliance with requirements related to the grant agreement and the Reportingcompliance requirement.Monthly Sponsor Claims for Reimbursement (Claims) were submitted to the Indiana Departmentof Education based upon meals served for the month. The monthly Claims were prepared by the FoodService Director and reviewed by the Business Manager; however, the internal control was not effective toprevent, or detect and correct, errors. For three of the seven monthly Claims tested, there were differencesbetween the Claims submitted and the School Corporation's summary meal count reports. The threeClaims had less meals served than the School Corporation's summary meal count reports, which resultedin underclaimed meals.The lack of adequate internal controls and noncompliance were systemic issues throughout theaudit period.INDIANA STATE BOARD OF ACCOUNTS19SOUTHWEST DUBOIS COUNTY SCHOOL CORPORATIONSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."7 CFR 210.8(a) states in part:"Internal controls. The school food authority shall establish internal controls which ensure theaccuracy of meal counts prior to the submission of the monthly Claim for Reimbursement. . . .(2) School food authority claims review process. Prior to the submission of a monthlyClaim for Reimbursement, each school food authority shall review the lunch count datafor each school under its jurisdiction to ensure the accuracy of the monthly Claim forReimbursement. . . ."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Reporting compliance requirement.EffectThe failure to establish an effective internal control system enabled material noncompliance to goundetected. Noncompliance with the grant agreement and the Reporting compliance requirement couldresult in the loss of future federal funds to the School Corporation.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish a system of internal controlsto ensure compliance and comply with the Reporting compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-004Subject: Special Education Cluster (IDEA) - EarmarkingFederal Agency: Department of EducationFederal Program: Special Education Grants to StatesAssistance Listings Number: 84.027Federal Award Number and Year (or Other Identifying Number): 21611-009-PN01Pass-Through Entity: Indiana Department of EducationCompliance Requirement: Matching, Level of Effort, EarmarkingAudit Findings: Material Weakness, Modified OpinionCondition and ContextThe School Corporation is a member of the Exceptional Children's Co-op (Cooperative). Duringfiscal year 2021-2022, the Cooperative operated the special education programs and spent the federalmoney on behalf of all its member schools. As the grant agreements were between the Indiana Departmentof Education (IDOE) and each member school, the School Corporation was responsible for ensuring andproviding oversight of the Cooperative. There was inadequate oversight performed by the SchoolCorporation in order to ensure compliance with the Matching, Level of Effort, Earmarking compliancerequirement.The School Corporation did not have internal controls in place to ensure that the Cooperativecomplied with the earmarking requirements. The Cooperative did not have adequate procedures in placeto ensure that the required level of expenditures for non-public school students with disabilities was met foreach member school. The Cooperative did not have effective internal controls to ensure non-public schoolexpenditures were appropriately identified and reported.The Non-Public Proportionate Share expenditures for the 21611-009-PN01 grant award could notbe verified for the individual member schools. Total grant expenditures were posted as expended. Thenon-public proportionate share expenditures were determined by applying a percentage to the non-publicschool budgeted expenditures. These were the amounts reported to the IDOE. As such, we were unableto identify if the minimum amount per the grant award was expended and properly reported to the IDOE asrequired.The lack of internal controls and noncompliance was isolated to the 21611-009-PN01 grant award.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."INDIANA STATE BOARD OF ACCOUNTS21SOUTHWEST DUBOIS COUNTY SCHOOL CORPORATIONSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)2 CFR 200.403 states in part:"Except where otherwise authorized by statute, costs must meet the following general criteriain order to be allowable under Federal awards: . . .(g) Be adequately documented. . . ."2 CFR 200.208(b) states in part: "The Federal awarding agency or pass-through entity may adjustspecific Federal award conditions as needed . . ."511 IAC 7-34-7(b) states:"The public agency, in providing special education and related services to students in nonpublicschools must expend at least an amount that is the same proportion of the public agency totalsubgrant under 20 U.S.C. 1411(f) as the number of nonpublic school students with disabilities,who are enrolled by their parents in nonpublic schools within its boundaries, is to the totalnumber of students with disabilities of the same age range."CauseThe School Corporation's management had not developed an effective system of internal controlsthat would have ensured compliance with the grant agreements and the earmarking requirements of theMatching, Level of Effort, Earmarking compliance requirement.EffectThe failure to establish an effective internal control system, as well as adequately document costsof federal awards, prevented the determination of the School Corporation's compliance with the earmarkingrequirements of the Matching, Level of Effort, Earmarking compliance requirement.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish an effective system ofinternal controls, as well as appropriately document and identify federal award expenditures to ensure compliancewith the Matching, Level of Effort, Earmarking compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-004Subject: Special Education Cluster (IDEA) - EarmarkingFederal Agency: Department of EducationFederal Program: Special Education Grants to StatesAssistance Listings Number: 84.027Federal Award Number and Year (or Other Identifying Number): 21611-009-PN01Pass-Through Entity: Indiana Department of EducationCompliance Requirement: Matching, Level of Effort, EarmarkingAudit Findings: Material Weakness, Modified OpinionCondition and ContextThe School Corporation is a member of the Exceptional Children's Co-op (Cooperative). Duringfiscal year 2021-2022, the Cooperative operated the special education programs and spent the federalmoney on behalf of all its member schools. As the grant agreements were between the Indiana Departmentof Education (IDOE) and each member school, the School Corporation was responsible for ensuring andproviding oversight of the Cooperative. There was inadequate oversight performed by the SchoolCorporation in order to ensure compliance with the Matching, Level of Effort, Earmarking compliancerequirement.The School Corporation did not have internal controls in place to ensure that the Cooperativecomplied with the earmarking requirements. The Cooperative did not have adequate procedures in placeto ensure that the required level of expenditures for non-public school students with disabilities was met foreach member school. The Cooperative did not have effective internal controls to ensure non-public schoolexpenditures were appropriately identified and reported.The Non-Public Proportionate Share expenditures for the 21611-009-PN01 grant award could notbe verified for the individual member schools. Total grant expenditures were posted as expended. Thenon-public proportionate share expenditures were determined by applying a percentage to the non-publicschool budgeted expenditures. These were the amounts reported to the IDOE. As such, we were unableto identify if the minimum amount per the grant award was expended and properly reported to the IDOE asrequired.The lack of internal controls and noncompliance was isolated to the 21611-009-PN01 grant award.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."INDIANA STATE BOARD OF ACCOUNTS21SOUTHWEST DUBOIS COUNTY SCHOOL CORPORATIONSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)2 CFR 200.403 states in part:"Except where otherwise authorized by statute, costs must meet the following general criteriain order to be allowable under Federal awards: . . .(g) Be adequately documented. . . ."2 CFR 200.208(b) states in part: "The Federal awarding agency or pass-through entity may adjustspecific Federal award conditions as needed . . ."511 IAC 7-34-7(b) states:"The public agency, in providing special education and related services to students in nonpublicschools must expend at least an amount that is the same proportion of the public agency totalsubgrant under 20 U.S.C. 1411(f) as the number of nonpublic school students with disabilities,who are enrolled by their parents in nonpublic schools within its boundaries, is to the totalnumber of students with disabilities of the same age range."CauseThe School Corporation's management had not developed an effective system of internal controlsthat would have ensured compliance with the grant agreements and the earmarking requirements of theMatching, Level of Effort, Earmarking compliance requirement.EffectThe failure to establish an effective internal control system, as well as adequately document costsof federal awards, prevented the determination of the School Corporation's compliance with the earmarkingrequirements of the Matching, Level of Effort, Earmarking compliance requirement.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish an effective system ofinternal controls, as well as appropriately document and identify federal award expenditures to ensure compliancewith the Matching, Level of Effort, Earmarking compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-001Subject: COVID-19 - Education Stabilization Fund - Allowable Costs/Cost PrinciplesFederal Agency: Department of EducationFederal Program: COVID-19 - Education Stabilization FundAssistance Listings Number: 84.425DFederal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: Allowable Costs/Cost PrinciplesAudit Findings: Significant Deficiency, Other MattersCondition and ContextAn effective internal control system was not in place at the School Corporation to ensure compliancewith requirements related to the grant agreement and the Allowable Costs/Cost Principles compliancerequirement.Charges to Federal awards for salaries and wages must be based on records that accurately reflectthe work performed. One employee was paid from ESSER I and ESSER II grant awards and also fromother funding sources. Adequate time records were not maintained for the employee to determine if theproper amount was charged to the federal award. The total amount charged to the federal award of $28,599was considered a questioned cost.The lack of internal controls and noncompliance were systemic issues throughout the audit period.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.430(i) states in part:"Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salariesand wages must be based on records that accurately reflect the work performed. Theserecords must:(i) Be supported by a system of internal control which provides reasonable assurance thatthe charges are accurate, allowable, and properly allocated;(ii) Be incorporated into the official records of the non-Federal entity;INDIANA STATE BOARD OF ACCOUNTS16SOUTHWEST DUBOIS COUNTY SCHOOL CORPORATIONSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)(iii) Reasonably reflect the total activity for which the employee is compensated by thenon-Federal entity, not exceeding 100% of compensated activities (for IHE, this perthe IHE's definition of IBS); . . .(vii) Support the distribution of the employee's salary or wages among specific activitiesor cost objectives if the employee works on more than one Federal award; a Federalaward and non-Federal award; an indirect cost activity and a direct cost activity; twoor more indirect activities which allocated using different allocation bases; or anunallowable activity and a direct or indirect costs activity. . . ."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Allowable Costs/Cost Principles compliance requirement.EffectThe failure to establish an effective internal control system enabled noncompliance to go undetected.Noncompliance with the grant agreement and the Allowable Costs/Cost Principles compliancerequirement could result in the loss of future federal funds to the School Corporation.Questioned CostsQuestioned costs of $28,599 were identified as detailed in the Condition and Context.RecommendationWe recommended that the School Corporation's management establish internal controls to ensurecompliance and comply with the grant agreement and the Allowable Costs/Cost Principles compliancerequirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-001Subject: COVID-19 - Education Stabilization Fund - Allowable Costs/Cost PrinciplesFederal Agency: Department of EducationFederal Program: COVID-19 - Education Stabilization FundAssistance Listings Number: 84.425DFederal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: Allowable Costs/Cost PrinciplesAudit Findings: Significant Deficiency, Other MattersCondition and ContextAn effective internal control system was not in place at the School Corporation to ensure compliancewith requirements related to the grant agreement and the Allowable Costs/Cost Principles compliancerequirement.Charges to Federal awards for salaries and wages must be based on records that accurately reflectthe work performed. One employee was paid from ESSER I and ESSER II grant awards and also fromother funding sources. Adequate time records were not maintained for the employee to determine if theproper amount was charged to the federal award. The total amount charged to the federal award of $28,599was considered a questioned cost.The lack of internal controls and noncompliance were systemic issues throughout the audit period.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.430(i) states in part:"Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salariesand wages must be based on records that accurately reflect the work performed. Theserecords must:(i) Be supported by a system of internal control which provides reasonable assurance thatthe charges are accurate, allowable, and properly allocated;(ii) Be incorporated into the official records of the non-Federal entity;INDIANA STATE BOARD OF ACCOUNTS16SOUTHWEST DUBOIS COUNTY SCHOOL CORPORATIONSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)(iii) Reasonably reflect the total activity for which the employee is compensated by thenon-Federal entity, not exceeding 100% of compensated activities (for IHE, this perthe IHE's definition of IBS); . . .(vii) Support the distribution of the employee's salary or wages among specific activitiesor cost objectives if the employee works on more than one Federal award; a Federalaward and non-Federal award; an indirect cost activity and a direct cost activity; twoor more indirect activities which allocated using different allocation bases; or anunallowable activity and a direct or indirect costs activity. . . ."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Allowable Costs/Cost Principles compliance requirement.EffectThe failure to establish an effective internal control system enabled noncompliance to go undetected.Noncompliance with the grant agreement and the Allowable Costs/Cost Principles compliancerequirement could result in the loss of future federal funds to the School Corporation.Questioned CostsQuestioned costs of $28,599 were identified as detailed in the Condition and Context.RecommendationWe recommended that the School Corporation's management establish internal controls to ensurecompliance and comply with the grant agreement and the Allowable Costs/Cost Principles compliancerequirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-001Subject: COVID-19 - Education Stabilization Fund - Allowable Costs/Cost PrinciplesFederal Agency: Department of EducationFederal Program: COVID-19 - Education Stabilization FundAssistance Listings Number: 84.425DFederal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: Allowable Costs/Cost PrinciplesAudit Findings: Significant Deficiency, Other MattersCondition and ContextAn effective internal control system was not in place at the School Corporation to ensure compliancewith requirements related to the grant agreement and the Allowable Costs/Cost Principles compliancerequirement.Charges to Federal awards for salaries and wages must be based on records that accurately reflectthe work performed. One employee was paid from ESSER I and ESSER II grant awards and also fromother funding sources. Adequate time records were not maintained for the employee to determine if theproper amount was charged to the federal award. The total amount charged to the federal award of $28,599was considered a questioned cost.The lack of internal controls and noncompliance were systemic issues throughout the audit period.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.430(i) states in part:"Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salariesand wages must be based on records that accurately reflect the work performed. Theserecords must:(i) Be supported by a system of internal control which provides reasonable assurance thatthe charges are accurate, allowable, and properly allocated;(ii) Be incorporated into the official records of the non-Federal entity;INDIANA STATE BOARD OF ACCOUNTS16SOUTHWEST DUBOIS COUNTY SCHOOL CORPORATIONSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)(iii) Reasonably reflect the total activity for which the employee is compensated by thenon-Federal entity, not exceeding 100% of compensated activities (for IHE, this perthe IHE's definition of IBS); . . .(vii) Support the distribution of the employee's salary or wages among specific activitiesor cost objectives if the employee works on more than one Federal award; a Federalaward and non-Federal award; an indirect cost activity and a direct cost activity; twoor more indirect activities which allocated using different allocation bases; or anunallowable activity and a direct or indirect costs activity. . . ."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Allowable Costs/Cost Principles compliance requirement.EffectThe failure to establish an effective internal control system enabled noncompliance to go undetected.Noncompliance with the grant agreement and the Allowable Costs/Cost Principles compliancerequirement could result in the loss of future federal funds to the School Corporation.Questioned CostsQuestioned costs of $28,599 were identified as detailed in the Condition and Context.RecommendationWe recommended that the School Corporation's management establish internal controls to ensurecompliance and comply with the grant agreement and the Allowable Costs/Cost Principles compliancerequirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-002Subject: COVID-19 - Education Stabilization Fund - ReportingFederal Agency: Department of EducationFederal Program: COVID-19 - Education Stabilization FundAssistance Listings Number: 84.425DFederal Award Number and Year (or Other Identifying Number): S425D200013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: ReportingAudit Findings: Material Weakness, Other MattersCondition and ContextAn effective internal control system was not in place at the School Corporation to ensure compliancewith requirements related to the grant agreement and the Reporting compliance requirement.INDIANA STATE BOARD OF ACCOUNTS17SOUTHWEST DUBOIS COUNTY SCHOOL CORPORATIONSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)One of five annual reports required to be completed during the audit period contained materialerrors. The Elementary and Secondary School Emergency Relief (ESSER I), Year 1 annual data reportoverstated total expenditures made between March 13, 2020, and September, 30, 2020, by $130,918. Inaddition, documentation provided for the number of full-time employee positions did not support theamounts reported.The lack of internal controls and noncompliance were systemic issues throughout the audit period.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.334 states in part:"Financial records, supporting documents, statistical records, and all other non-Federal entityrecords pertinent to a Federal award must be retained for a period of three years from the dateof submission of the final expenditure report or, for Federal awards that are renewed quarterlyor annually, from the date of the submission of the quarterly or annual financial report,respectively, as reported to the Federal awarding agency or pass-through entity in the case ofa subrecipient. . . ."2 CFR 200.302(b) states in part:"The financial management system of each non-Federal entity must provide for the following:. . .(2) Accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with the reporting requirements set forth in ?? 200.328and 200.329. . . .(3) Records that identify adequately the source and application of funds for federallyfunded activities. These records must contain information pertaining to Federalawards, authorizations, obligations, unobligated balances, assets, expenditures,income and interest and be supported by source documentation. . . ."34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and formatthat assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out otherresponsibilities under the program."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Reporting compliance requirement.INDIANA STATE BOARD OF ACCOUNTS18SOUTHWEST DUBOIS COUNTY SCHOOL CORPORATIONSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)EffectThe failure to establish an effective internal control system enabled material noncompliance to goundetected. Noncompliance with the grant agreement and the Reporting compliance requirement couldresult in the loss of future federal funds to the School Corporation.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish internal controls to ensurecompliance and comply with the grant agreement and the Reporting compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-002Subject: COVID-19 - Education Stabilization Fund - ReportingFederal Agency: Department of EducationFederal Program: COVID-19 - Education Stabilization FundAssistance Listings Number: 84.425DFederal Award Number and Year (or Other Identifying Number): S425D200013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: ReportingAudit Findings: Material Weakness, Other MattersCondition and ContextAn effective internal control system was not in place at the School Corporation to ensure compliancewith requirements related to the grant agreement and the Reporting compliance requirement.INDIANA STATE BOARD OF ACCOUNTS17SOUTHWEST DUBOIS COUNTY SCHOOL CORPORATIONSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)One of five annual reports required to be completed during the audit period contained materialerrors. The Elementary and Secondary School Emergency Relief (ESSER I), Year 1 annual data reportoverstated total expenditures made between March 13, 2020, and September, 30, 2020, by $130,918. Inaddition, documentation provided for the number of full-time employee positions did not support theamounts reported.The lack of internal controls and noncompliance were systemic issues throughout the audit period.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.334 states in part:"Financial records, supporting documents, statistical records, and all other non-Federal entityrecords pertinent to a Federal award must be retained for a period of three years from the dateof submission of the final expenditure report or, for Federal awards that are renewed quarterlyor annually, from the date of the submission of the quarterly or annual financial report,respectively, as reported to the Federal awarding agency or pass-through entity in the case ofa subrecipient. . . ."2 CFR 200.302(b) states in part:"The financial management system of each non-Federal entity must provide for the following:. . .(2) Accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with the reporting requirements set forth in ?? 200.328and 200.329. . . .(3) Records that identify adequately the source and application of funds for federallyfunded activities. These records must contain information pertaining to Federalawards, authorizations, obligations, unobligated balances, assets, expenditures,income and interest and be supported by source documentation. . . ."34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and formatthat assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out otherresponsibilities under the program."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Reporting compliance requirement.INDIANA STATE BOARD OF ACCOUNTS18SOUTHWEST DUBOIS COUNTY SCHOOL CORPORATIONSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)EffectThe failure to establish an effective internal control system enabled material noncompliance to goundetected. Noncompliance with the grant agreement and the Reporting compliance requirement couldresult in the loss of future federal funds to the School Corporation.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish internal controls to ensurecompliance and comply with the grant agreement and the Reporting compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.