CORRECTIVE ACTION PLAN OF CURRENT AUDIT FINDINGS
June 30, 2023
FINDING 2023-001
Subject: Special Education Cluster (IDEA) – Earmarking
Federal Agency: Department of Education
Federal Program: Special Education Preschool Grants
Assistance Listing Number: 84.173
Federal Award Number: 22619-043-PN01
Co...
CORRECTIVE ACTION PLAN OF CURRENT AUDIT FINDINGS
June 30, 2023
FINDING 2023-001
Subject: Special Education Cluster (IDEA) – Earmarking
Federal Agency: Department of Education
Federal Program: Special Education Preschool Grants
Assistance Listing Number: 84.173
Federal Award Number: 22619-043-PN01
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 Northwest Indiana Special Education Cooperative
(Cooperative). During fiscal year 2022-2023, the Cooperative operated the special education program and spent
the federal money on behalf of all its members. As the grant agreement was 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 22619-043-PN01 grant award could not be verified for
the individual member schools. Total grant expenditures were posted as expended. The non-public proportionate
share expenditures were determined by applying a percentage to the non-public school budgeted expenditures.
As such, we were unable to identify if the minimum amount per the grant award was expended and properly
reported to IDOE as required.
The lack of internal controls was isolated to the 22619-043-PN01 grant award.
Views of Responsible Official: We concur with the finding.
Description of Corrective Action Plan: As a member of the Northwest Indiana Special Education Cooperative
(NISEC), Highland reported their proportionate share based on a percentage of expenditures and had successful
audits in doing so. When Highland was notified that this process was no longer acceptable, we immediately
implemented an internal control process with NISEC which included a detailed reporting of staff work hours for
nonpublic schools related to only our school corporation. The report is then reviewed and signed by the NISEC
staff working for the nonpublic school and their supervisor. The employee detailed time and effort report is then
provided to the NISEC finance department for a second review and signature before being reported to payroll.
NISEC payroll then charges the proportionate share to the IDEA Part B and the Special Education Pre-School
grants in the payroll system bi-weekly based on the time and effort report pertinent to just Highland. The time and
effort reports are then used to submit the reimbursements request to the Department of Education for Highland’s
proportionate share.
Additionally, any IDEA Part B nonpublic material expense is broken out in detail with Highland’s proportionate
share for approval by the NISEC finance office prior to vendor payment and the reimbursement request is
submitted to the Department of Education.
Responsible Party and Timeline for Completion: Federal regulation requires name and title of person
overseeing corrective action plan and anticipated completion date.
Peyton Gilmore, NISEC CFO, indicated that NISEC stopped reporting nonpublic proportionate share expenditures
by percentages as of the 2022/2023 school year. An internal control procedure to report nonpublic proportionate
share expenditures by detailed time and effort work of expenditures was implemented as of September 2022.