Finding 2023-001
Information on the federal program:
Subject: Special Education Cluster - Earmarking
Federal Agency: Department of Education
Federal Programs: Special Education Grants to States, Special Education Preschool Grants
Assistance Listings Numbers: 84.027, 84.173
Federal Award Numbers: 206...
Finding 2023-001
Information on the federal program:
Subject: Special Education Cluster - Earmarking
Federal Agency: Department of Education
Federal Programs: Special Education Grants to States, Special Education Preschool Grants
Assistance Listings Numbers: 84.027, 84.173
Federal Award Numbers: 20611-054-PN01, 20619-054-PN01, 21611-054-PN01, 21619-054-PN01
Pass-Through Entity: Indiana Department of Education
Compliance Requirement: Matching, Level of Effort, Earmarking
Audit Findings: Significant Deficiency
Condition: The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the
earmarking requirements. The Cooperative did not have adequate procedures in place to ensure that the required level of
expenditures for non-public school students with disabilities was met for each member school. The Cooperative did not
have effective internal controls to ensure non-public school expenditures were appropriately identified and reported.
Context: The School Corporation is a member of the Wabash Miami Area Programs for Exceptional Children (Cooperative).
During fiscal year 2021-2022 and 2022-2023, the Cooperative operated the special education programs and spent the
federal money on behalf of all its members. As the grant agreements were between the Indiana Department of Education
(IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the
Cooperative. However, there was inadequate oversight performed by the School Corporation in order to ensure compliance
with the Matching, Level of Effort, Earmarking compliance requirement.
The Non-Public Proportionate Share expenditures for the 20611-054-PN01, 20619-054-PN01, 21611-054-PN01, and
21619-054-PN01 grant awards could not be verified for the individual member schools. The non-public school share funds
for all member schools were comingled and the aggregate amount of expenditures was then allocated to the member
schools on a percentage basis. These allocations were the amounts reported to IDOE. As such, we were unable to identify
which expenditures were for each school in order to verify the minimum amount per the grant award was expended and
properly reported to IDOE as required.
The School Corporation’s minimum, nonpublic earmarking requirement for grant awards 20611-054-PN01 and 21611-054-
PN01 was $1,643 and $7,941, respectively. The School Corporation did not have any minimum, nonpublic earmarking
requirement for the 20619-054-PN01 and 21619-054-PN01 grant awards.
The lack of internal controls and noncompliance were isolated to the 20611-054-PN01, 20619-054-PN01, 21611-054-PN01,
and 21619-054-PN01 grant awards.
Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding.
1. Meet with LEA Superintendent, Director of Special Education, and Office Manager on January 16th, 2024 at 2:00
pm to review current procedure and brainstorm ideas.
2. Meet with IDOE Finance Specialist for clarification.
Responsible Party and Timeline for Completion: Ann Higgins, WMAP Special Education Director, will oversee the
corrective action plan and timeline for completion. The anticipated completion date is March 1, 2024.