FINDING 2024-002
Subject: Title I Grants to Local Educational Agencies - Activities
Allowed or Unallowed, Allowable Costs/Cost Principles
Federal Agency: Department of Education
Federal Program: Title I Grants to Local Educational Agencies
Assistance Listings Number: 84.010
Federal Award Number or Y...
FINDING 2024-002
Subject: Title I Grants to Local Educational Agencies - Activities
Allowed or Unallowed, Allowable Costs/Cost Principles
Federal Agency: Department of Education
Federal Program: Title I Grants to Local Educational Agencies
Assistance Listings Number: 84.010
Federal Award Number or Year (or Other Identifying Number): S010A210014
Pass-Through Entity: Indiana Department of Education
Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles
Audit Findings: Material Weakness, Modified Opinion
Condition and Context
Direct charges to a federal award are to be for allowable activities and allowable costs made in
conformance with the applicable cost principles.
The School Corporation did not have a process or internal controls in place to ensure expenditures
for the 2021 Title I grant award were for allowable activities and costs and in conformance with the cost
principles. The School Corporation was unable to provide supporting documentation for $43,141 worth of
expenditures transferred out of the 2021 grant award fund 4121 from July 1, 2022 to December 1, 2022.
These expenditures were originally expended from the Title I 2021 grant award fund 4121, requested for
reimbursement and then the expenditures were moved to other funds. Because these expenditures were
reappropriated, they were not an allowable activity or cost of the 2021 Title I grant award. In addition, the
School Corporation was unable to provide supporting documentation for $6,646 worth of certified salary
expenditures requested for reimbursement for the same grant award from February 17, 2022 to June 30,
2022. It was determined that this amount was double requested for reimbursement and was not an actual
expenditure. The total amount of $49,787 was considered questioned costs.
Subsequent to the 2021 Title I grant award, the School Corporation established and implemented
a process and internal controls to ensure expenditures for the 2022 and 2023 awards from July 1, 2022
through December 31, 2023, were for allowable activities and costs and in conformance with the cost
principles. The vendor expenditures are initiated by the Title I Director and the Title I Administrative
Assistant. Payroll is reviewed each pay period by the Title I Administrative Assistant. The Business
Manager/Treasurer prepares the reimbursement request using a detailed expenditure report from their
accounting system. The Title I Administrative Assistant verifies the information entered into the reimbursement
request by also comparing it to the detailed expenditure reports. The Title I Administrative Assistant
also reconciles the Title I award to the expenditures.
INDIANA STATE BOARD OF ACCOUNTS
18
METROPOLITAN SCHOOL DISTRICT OF STEUBEN COUNTY
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
(Continued)
If the Title I Administrative Assistant identifies that a correction of errors needs to be made to a Title
I fund, they fill out a Corrections Form. The Title I Director then reviews and signs the form and provides it
to the Business Manager/Treasurer to make the correction in the accounting system prior to completing a
request for reimbursement. After the corrections have been made, the Title I Administrative Assistant
verifies the changes were correctly made. After all corrections are made, the reimbursement request is
approved by the Title I Director and then submitted by the Business Manager/Treasurer.
We tested 25 other non-journal entry expenditures from all three Title I grant awards during the
audit period and did not identify any additional noncompliance with these expenditures.
The lack of internal controls and supporting documentation was isolated to the 2021 Title I grant
award number S010A21001 from February 17, 2022 to December 31, 2022.
Criteria
2 CFR 200.303 states in part:
"The non-Federal entity must:
(a) Establish and maintain effective internal control over the Federal award that provides
reasonable assurance that the non-Federal entity is managing the Federal award in compliance
with Federal statutes, regulations, and the terms and conditions of the Federal
award. These internal controls should be in compliance with guidance in 'Standards for
Internal Control in the Federal Government' issued by the Comptroller General of the
United States or the 'Internal Control Integrated Framework', issued by the Committee of
Sponsoring Organizations of the Treadway Commission (COSO). . . ."
2 CFR 200.403 states in part:
"Except where otherwise authorized by statute, costs must meet the following general criteria
in order to be allowable under Federal awards:
(a) Be necessary and reasonable for the performance of the Federal award and be
allocable thereto under these principles.
(b) Conform to any limitations or exclusions set forth in these principles or in the Federal
award as to types or amount of cost items. . . .
(g) Be adequately documented. . . ."
2 CFR 200.302(b) states in part:
"The recipient's and subrecipient's financial management system must provide for the
following: . . .
(7) Written procedures for determining the allowability of costs in accordance with subpart
E of this part and the terms and conditions of the Federal award."
INDIANA STATE BOARD OF ACCOUNTS
19
METROPOLITAN SCHOOL DISTRICT OF STEUBEN COUNTY
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
(Continued)
2 CFR 200.334 states in part:
"Financial records, supporting documents, statistical records, and all other non-Federal entity
records pertinent to a Federal award must be retained for a period of three years from the date
of submission of the final expenditure report or, for the Federal awards that are renewed
quarterly or annual, from the date of submission of the quarterly or annual financial report,
respectively, as reported to the Federal awarding agency or pass-through entity in the case of
a subrecipient. . . ."
Cause
A proper system of internal controls was not designed by management of the School Corporation.
The School Corporation segregated duties of knowledgeable staff that were involved in the process of
purchasing, entering claim information, processing claim and payroll information, and using reliable
financial data from the accounting system. However, it had not established a process or internal controls
for the 2021 Title I award number S010A21001 to ensure that all accounting corrections were made prior
to processing a request for reimbursement.
Effect
Without the proper implementation of an effectively designed system of internal controls, the School
Corporation could not ensure that only expenditures for allowable activities and costs were made and
requested for reimbursement. Any program funds the School Corporation reallocated to other funds or
double requested for reimbursement would be unallowable, and the awarding agency could potentially
recover them.
Questioned Costs
Questioned costs in the amount of $49,787 were identified as noted in the Condition and Context.
Recommendation
We recommended that Management of the School Corporation establish a proper system of
internal controls and develop written policies and procedures to ensure that expenditures for all Title I grant
awards are for allowable activities and costs in conformance with the cost principles and that support for all
expenditures and journal entries is maintained for the date ranges of costs documented on the requests for
reimbursement.
Views of Responsible Officials
For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.