2024-002 Inaccurate Filing of Federal Financial Reports Federal Department: Department of Justice, Office on Violence Against Women Assistance Listing #: 16.526 Compliance and Internal Controls Significant Deficiency Category of Finding – Reporting Criteria – § 200.302 Financial management of Uniform Guidance requires that Esperanza develop and maintain a financial management system to ensure accurate, current, and complete disclosure of the financial results of each Federal award as required by the grant agreements. Esperanza's grants require quarterly FFR (financial) reports be submitted. Condition – The September 30, 2023 and December 31, 2023 FFR reports for Award # 2016-TA-AX-K040 reported inaccurate federal expenditures. Total federal expenditures reported were $783,183 and $809,897 for periods ended September 30, 2023 and December 31, 2023, whereas actual expenditures in the financial management system for the periods ended were $756,435 and $760,887, respectively. Cause – The organization went through turnover of key staff during the fiscal year. In addition, review of the financial reports were performed subsequent to the submission. Effect – Inaccurate financial reporting may result in Esperanza’s status to be delinquent and not be able to draw down funds on the award or future awards from the awarding agency. Recommendation – We recommend that management implement a structured and two-step review process where a knowledgeable and experienced individual other than the preparer reviews the report prior to submission. Management’s Response and Corrective Action – Esperanza has assigned the contract accountant to be responsible for preparing these reports and implemented review processes to ensure these reports are accurate. Responsible party for corrective action – Vivian Huelgo, President and CEO Repeat finding – No
2024-002 Inaccurate Filing of Federal Financial Reports Federal Department: Department of Justice, Office on Violence Against Women Assistance Listing #: 16.526 Compliance and Internal Controls Significant Deficiency Category of Finding – Reporting Criteria – § 200.302 Financial management of Uniform Guidance requires that Esperanza develop and maintain a financial management system to ensure accurate, current, and complete disclosure of the financial results of each Federal award as required by the grant agreements. Esperanza's grants require quarterly FFR (financial) reports be submitted. Condition – The September 30, 2023 and December 31, 2023 FFR reports for Award # 2016-TA-AX-K040 reported inaccurate federal expenditures. Total federal expenditures reported were $783,183 and $809,897 for periods ended September 30, 2023 and December 31, 2023, whereas actual expenditures in the financial management system for the periods ended were $756,435 and $760,887, respectively. Cause – The organization went through turnover of key staff during the fiscal year. In addition, review of the financial reports were performed subsequent to the submission. Effect – Inaccurate financial reporting may result in Esperanza’s status to be delinquent and not be able to draw down funds on the award or future awards from the awarding agency. Recommendation – We recommend that management implement a structured and two-step review process where a knowledgeable and experienced individual other than the preparer reviews the report prior to submission. Management’s Response and Corrective Action – Esperanza has assigned the contract accountant to be responsible for preparing these reports and implemented review processes to ensure these reports are accurate. Responsible party for corrective action – Vivian Huelgo, President and CEO Repeat finding – No
2024-002 Inaccurate Filing of Federal Financial Reports Federal Department: Department of Justice, Office on Violence Against Women Assistance Listing #: 16.526 Compliance and Internal Controls Significant Deficiency Category of Finding – Reporting Criteria – § 200.302 Financial management of Uniform Guidance requires that Esperanza develop and maintain a financial management system to ensure accurate, current, and complete disclosure of the financial results of each Federal award as required by the grant agreements. Esperanza's grants require quarterly FFR (financial) reports be submitted. Condition – The September 30, 2023 and December 31, 2023 FFR reports for Award # 2016-TA-AX-K040 reported inaccurate federal expenditures. Total federal expenditures reported were $783,183 and $809,897 for periods ended September 30, 2023 and December 31, 2023, whereas actual expenditures in the financial management system for the periods ended were $756,435 and $760,887, respectively. Cause – The organization went through turnover of key staff during the fiscal year. In addition, review of the financial reports were performed subsequent to the submission. Effect – Inaccurate financial reporting may result in Esperanza’s status to be delinquent and not be able to draw down funds on the award or future awards from the awarding agency. Recommendation – We recommend that management implement a structured and two-step review process where a knowledgeable and experienced individual other than the preparer reviews the report prior to submission. Management’s Response and Corrective Action – Esperanza has assigned the contract accountant to be responsible for preparing these reports and implemented review processes to ensure these reports are accurate. Responsible party for corrective action – Vivian Huelgo, President and CEO Repeat finding – No
2024-002 Inaccurate Filing of Federal Financial Reports Federal Department: Department of Justice, Office on Violence Against Women Assistance Listing #: 16.526 Compliance and Internal Controls Significant Deficiency Category of Finding – Reporting Criteria – § 200.302 Financial management of Uniform Guidance requires that Esperanza develop and maintain a financial management system to ensure accurate, current, and complete disclosure of the financial results of each Federal award as required by the grant agreements. Esperanza's grants require quarterly FFR (financial) reports be submitted. Condition – The September 30, 2023 and December 31, 2023 FFR reports for Award # 2016-TA-AX-K040 reported inaccurate federal expenditures. Total federal expenditures reported were $783,183 and $809,897 for periods ended September 30, 2023 and December 31, 2023, whereas actual expenditures in the financial management system for the periods ended were $756,435 and $760,887, respectively. Cause – The organization went through turnover of key staff during the fiscal year. In addition, review of the financial reports were performed subsequent to the submission. Effect – Inaccurate financial reporting may result in Esperanza’s status to be delinquent and not be able to draw down funds on the award or future awards from the awarding agency. Recommendation – We recommend that management implement a structured and two-step review process where a knowledgeable and experienced individual other than the preparer reviews the report prior to submission. Management’s Response and Corrective Action – Esperanza has assigned the contract accountant to be responsible for preparing these reports and implemented review processes to ensure these reports are accurate. Responsible party for corrective action – Vivian Huelgo, President and CEO Repeat finding – No
2024-002 Inaccurate Filing of Federal Financial Reports Federal Department: Department of Justice, Office on Violence Against Women Assistance Listing #: 16.526 Compliance and Internal Controls Significant Deficiency Category of Finding – Reporting Criteria – § 200.302 Financial management of Uniform Guidance requires that Esperanza develop and maintain a financial management system to ensure accurate, current, and complete disclosure of the financial results of each Federal award as required by the grant agreements. Esperanza's grants require quarterly FFR (financial) reports be submitted. Condition – The September 30, 2023 and December 31, 2023 FFR reports for Award # 2016-TA-AX-K040 reported inaccurate federal expenditures. Total federal expenditures reported were $783,183 and $809,897 for periods ended September 30, 2023 and December 31, 2023, whereas actual expenditures in the financial management system for the periods ended were $756,435 and $760,887, respectively. Cause – The organization went through turnover of key staff during the fiscal year. In addition, review of the financial reports were performed subsequent to the submission. Effect – Inaccurate financial reporting may result in Esperanza’s status to be delinquent and not be able to draw down funds on the award or future awards from the awarding agency. Recommendation – We recommend that management implement a structured and two-step review process where a knowledgeable and experienced individual other than the preparer reviews the report prior to submission. Management’s Response and Corrective Action – Esperanza has assigned the contract accountant to be responsible for preparing these reports and implemented review processes to ensure these reports are accurate. Responsible party for corrective action – Vivian Huelgo, President and CEO Repeat finding – No
2024-002 Inaccurate Filing of Federal Financial Reports Federal Department: Department of Justice, Office on Violence Against Women Assistance Listing #: 16.526 Compliance and Internal Controls Significant Deficiency Category of Finding – Reporting Criteria – § 200.302 Financial management of Uniform Guidance requires that Esperanza develop and maintain a financial management system to ensure accurate, current, and complete disclosure of the financial results of each Federal award as required by the grant agreements. Esperanza's grants require quarterly FFR (financial) reports be submitted. Condition – The September 30, 2023 and December 31, 2023 FFR reports for Award # 2016-TA-AX-K040 reported inaccurate federal expenditures. Total federal expenditures reported were $783,183 and $809,897 for periods ended September 30, 2023 and December 31, 2023, whereas actual expenditures in the financial management system for the periods ended were $756,435 and $760,887, respectively. Cause – The organization went through turnover of key staff during the fiscal year. In addition, review of the financial reports were performed subsequent to the submission. Effect – Inaccurate financial reporting may result in Esperanza’s status to be delinquent and not be able to draw down funds on the award or future awards from the awarding agency. Recommendation – We recommend that management implement a structured and two-step review process where a knowledgeable and experienced individual other than the preparer reviews the report prior to submission. Management’s Response and Corrective Action – Esperanza has assigned the contract accountant to be responsible for preparing these reports and implemented review processes to ensure these reports are accurate. Responsible party for corrective action – Vivian Huelgo, President and CEO Repeat finding – No
2024-002 Inaccurate Filing of Federal Financial Reports Federal Department: Department of Justice, Office on Violence Against Women Assistance Listing #: 16.526 Compliance and Internal Controls Significant Deficiency Category of Finding – Reporting Criteria – § 200.302 Financial management of Uniform Guidance requires that Esperanza develop and maintain a financial management system to ensure accurate, current, and complete disclosure of the financial results of each Federal award as required by the grant agreements. Esperanza's grants require quarterly FFR (financial) reports be submitted. Condition – The September 30, 2023 and December 31, 2023 FFR reports for Award # 2016-TA-AX-K040 reported inaccurate federal expenditures. Total federal expenditures reported were $783,183 and $809,897 for periods ended September 30, 2023 and December 31, 2023, whereas actual expenditures in the financial management system for the periods ended were $756,435 and $760,887, respectively. Cause – The organization went through turnover of key staff during the fiscal year. In addition, review of the financial reports were performed subsequent to the submission. Effect – Inaccurate financial reporting may result in Esperanza’s status to be delinquent and not be able to draw down funds on the award or future awards from the awarding agency. Recommendation – We recommend that management implement a structured and two-step review process where a knowledgeable and experienced individual other than the preparer reviews the report prior to submission. Management’s Response and Corrective Action – Esperanza has assigned the contract accountant to be responsible for preparing these reports and implemented review processes to ensure these reports are accurate. Responsible party for corrective action – Vivian Huelgo, President and CEO Repeat finding – No
2024-002 Inaccurate Filing of Federal Financial Reports Federal Department: Department of Justice, Office on Violence Against Women Assistance Listing #: 16.526 Compliance and Internal Controls Significant Deficiency Category of Finding – Reporting Criteria – § 200.302 Financial management of Uniform Guidance requires that Esperanza develop and maintain a financial management system to ensure accurate, current, and complete disclosure of the financial results of each Federal award as required by the grant agreements. Esperanza's grants require quarterly FFR (financial) reports be submitted. Condition – The September 30, 2023 and December 31, 2023 FFR reports for Award # 2016-TA-AX-K040 reported inaccurate federal expenditures. Total federal expenditures reported were $783,183 and $809,897 for periods ended September 30, 2023 and December 31, 2023, whereas actual expenditures in the financial management system for the periods ended were $756,435 and $760,887, respectively. Cause – The organization went through turnover of key staff during the fiscal year. In addition, review of the financial reports were performed subsequent to the submission. Effect – Inaccurate financial reporting may result in Esperanza’s status to be delinquent and not be able to draw down funds on the award or future awards from the awarding agency. Recommendation – We recommend that management implement a structured and two-step review process where a knowledgeable and experienced individual other than the preparer reviews the report prior to submission. Management’s Response and Corrective Action – Esperanza has assigned the contract accountant to be responsible for preparing these reports and implemented review processes to ensure these reports are accurate. Responsible party for corrective action – Vivian Huelgo, President and CEO Repeat finding – No
Information on the federal program: Subject: Education Stabilization Fund (ESSER) – Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards 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 200.302(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 Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 Financial reporting . . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirements. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with the compliance requirements listed above. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There were no questioned costs identified. Context: The School Corporation was required to submit two Annual Data Reports to the Indiana Department of Education (IDOE) during the audit period to meet federal reporting requirements for ESSER grant awards. We noted that the ESSER II amount reported on the Year 3 report ($572,289) did not agree to the underlying expenditure records ($558,956) for the period of July 1, 2021 through June 30, 2022. Additionally, we noted that the ESSER I, ESSER II, and ESSER III amounts reported on the Year 4 report ($105,506, $510,158, and $1,156,254, respectively) did not agree to the underlying expenditure records ($138,662, $316,236, and $1,158,054, respectively) for the period of July 1, 2022 through June 30, 2023. We also noted there was no documented, secondary review of the information in the annual data reports by someone other than the preparer. Identification as a repeat finding: This is a repeat finding from the immediately prior audit. The prior finding number was 2022-008. Recommendation: We recommend someone other than the preparer of the report perform a documented review prior to submission to validate the accuracy and completeness of the data submitted. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Information on the federal program: Subject: Education Stabilization Fund (ESSER) – Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards 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 200.302(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 Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 Financial reporting . . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirements. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with the compliance requirements listed above. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There were no questioned costs identified. Context: The School Corporation was required to submit two Annual Data Reports to the Indiana Department of Education (IDOE) during the audit period to meet federal reporting requirements for ESSER grant awards. We noted that the ESSER II amount reported on the Year 3 report ($572,289) did not agree to the underlying expenditure records ($558,956) for the period of July 1, 2021 through June 30, 2022. Additionally, we noted that the ESSER I, ESSER II, and ESSER III amounts reported on the Year 4 report ($105,506, $510,158, and $1,156,254, respectively) did not agree to the underlying expenditure records ($138,662, $316,236, and $1,158,054, respectively) for the period of July 1, 2022 through June 30, 2023. We also noted there was no documented, secondary review of the information in the annual data reports by someone other than the preparer. Identification as a repeat finding: This is a repeat finding from the immediately prior audit. The prior finding number was 2022-008. Recommendation: We recommend someone other than the preparer of the report perform a documented review prior to submission to validate the accuracy and completeness of the data submitted. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Assistance Listing Number(s): 93.558 Name of Federal Program or Cluster: Temporary Assistance for Needy Families (TANF) Name of Federal Agency: Department of Health and Human Services Name of Pass-through Entity: Boys & Girls Clubs of Fox Valley Award Period: July 1, 2023 through June 30, 2024 Criteria or Specific Requirement: 2 CFR section 200.302(b)(2) requires the financial management system of a non-federal entity to provide for accurate, current, and complete disclosure of the financial results of each federal award or program. Condition: Expenditures in total agree to the underlying accounting records, however, general ledger line items and award budget line items do not reconcile for contracted/consulting services, equipment, building costs, other, and indirect costs. Cause: Reports were reconciled only in total to the general ledger and award budgets do not utilize general ledger accounts when developing. Effect or Potential Effect: Costs may be disallowed if not approved in the budget or over budget without prior approval. Repeat Finding: Repeat of finding 2023-007. Recommendation: Reconciliation of not only the total federal expenditures reported to the general ledger, but by budget line item and general ledger accounts. A review process of the reconciliation should be designed and implemented to ensure that both expenditures in total and by budget line item are reported accurately and are supported by the accounting records. Award budgets should be prepared and approved with the actual costs expected per the general ledger accounts to be incurred. Views of Responsible Officials: Boys and Girls Club of Dane County, Inc. agrees with the finding and is implementing a grant budget process.
Assistance Listing Number(s): 93.558 Name of Federal Program or Cluster: Temporary Assistance for Needy Families (TANF) Name of Federal Agency: Department of Health and Human Services Name of Pass-through Entity: Boys & Girls Clubs of Fox Valley Award Period: July 1, 2023 through June 30, 2024 Criteria or Specific Requirement: 2 CFR section 200.302(b)(2) requires the financial management system of a non-federal entity to provide for accurate, current, and complete disclosure of the financial results of each federal award or program. Condition: Expenditures in total agree to the underlying accounting records, however, general ledger line items and award budget line items do not reconcile for contracted/consulting services, equipment, building costs, other, and indirect costs. Cause: Reports were reconciled only in total to the general ledger and award budgets do not utilize general ledger accounts when developing. Effect or Potential Effect: Costs may be disallowed if not approved in the budget or over budget without prior approval. Repeat Finding: Repeat of finding 2023-007. Recommendation: Reconciliation of not only the total federal expenditures reported to the general ledger, but by budget line item and general ledger accounts. A review process of the reconciliation should be designed and implemented to ensure that both expenditures in total and by budget line item are reported accurately and are supported by the accounting records. Award budgets should be prepared and approved with the actual costs expected per the general ledger accounts to be incurred. Views of Responsible Officials: Boys and Girls Club of Dane County, Inc. agrees with the finding and is implementing a grant budget process.
2024-003 – Reimbursement Requests (Significant Deficiency in Internal Controls over Compliance) Federal Program Information Federal Award Title and ALN: Federal Transit Cluster, 20.507, 20.526 Federal Awarding Agency: Department of Transportation Federal Award ID Number: N/A Federal Award Year: 2024 Federal Award Title and ALN: Airport Improvement Program, 20.106 Federal Awarding Agency: Department of Transportation, Federal Aviation Administration Federal Award ID Number: SAF-SWG-3-35-0037-051-2020, SAF-SWG-3-35-0037-057-2021 Federal Award Year: 2024 Condition: The City submitted reimbursements for grants in an untimely fashion for multiple months at a time in the Federal Transit Cluster and only at year-end in the Airport Improvement Program. Criteria: Per 2 CFR 200.303(a), the non-federal entity must 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). Per Title 2 US Code of Federal Regulations Part 200.302b, the non-federal entity must provide for effective control over, and accountability for, all funds, property, and other assets. The non-federal entity must adequately safeguard all assets and assure that they are used solely for authorized purposes. Cause: The City does not have sufficient controls in place to review and approve requests to submit as needed. Questioned Cost: None. Effect: The City’s financial position and cash balances were adversely affected due to the delay in requesting and receiving reimbursement for funds already disbursed. Significant time passing between disbursement of funds and preparation of reimbursement requests may increase the chance of errors.
2024-003 – Reimbursement Requests (Significant Deficiency in Internal Controls over Compliance) Federal Program Information Federal Award Title and ALN: Federal Transit Cluster, 20.507, 20.526 Federal Awarding Agency: Department of Transportation Federal Award ID Number: N/A Federal Award Year: 2024 Federal Award Title and ALN: Airport Improvement Program, 20.106 Federal Awarding Agency: Department of Transportation, Federal Aviation Administration Federal Award ID Number: SAF-SWG-3-35-0037-051-2020, SAF-SWG-3-35-0037-057-2021 Federal Award Year: 2024 Condition: The City submitted reimbursements for grants in an untimely fashion for multiple months at a time in the Federal Transit Cluster and only at year-end in the Airport Improvement Program. Criteria: Per 2 CFR 200.303(a), the non-federal entity must 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). Per Title 2 US Code of Federal Regulations Part 200.302b, the non-federal entity must provide for effective control over, and accountability for, all funds, property, and other assets. The non-federal entity must adequately safeguard all assets and assure that they are used solely for authorized purposes. Cause: The City does not have sufficient controls in place to review and approve requests to submit as needed. Questioned Cost: None. Effect: The City’s financial position and cash balances were adversely affected due to the delay in requesting and receiving reimbursement for funds already disbursed. Significant time passing between disbursement of funds and preparation of reimbursement requests may increase the chance of errors.
2024-003 – Reimbursement Requests (Significant Deficiency in Internal Controls over Compliance) Federal Program Information Federal Award Title and ALN: Federal Transit Cluster, 20.507, 20.526 Federal Awarding Agency: Department of Transportation Federal Award ID Number: N/A Federal Award Year: 2024 Federal Award Title and ALN: Airport Improvement Program, 20.106 Federal Awarding Agency: Department of Transportation, Federal Aviation Administration Federal Award ID Number: SAF-SWG-3-35-0037-051-2020, SAF-SWG-3-35-0037-057-2021 Federal Award Year: 2024 Condition: The City submitted reimbursements for grants in an untimely fashion for multiple months at a time in the Federal Transit Cluster and only at year-end in the Airport Improvement Program. Criteria: Per 2 CFR 200.303(a), the non-federal entity must 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). Per Title 2 US Code of Federal Regulations Part 200.302b, the non-federal entity must provide for effective control over, and accountability for, all funds, property, and other assets. The non-federal entity must adequately safeguard all assets and assure that they are used solely for authorized purposes. Cause: The City does not have sufficient controls in place to review and approve requests to submit as needed. Questioned Cost: None. Effect: The City’s financial position and cash balances were adversely affected due to the delay in requesting and receiving reimbursement for funds already disbursed. Significant time passing between disbursement of funds and preparation of reimbursement requests may increase the chance of errors.
2024-003 – Reimbursement Requests (Significant Deficiency in Internal Controls over Compliance) Federal Program Information Federal Award Title and ALN: Federal Transit Cluster, 20.507, 20.526 Federal Awarding Agency: Department of Transportation Federal Award ID Number: N/A Federal Award Year: 2024 Federal Award Title and ALN: Airport Improvement Program, 20.106 Federal Awarding Agency: Department of Transportation, Federal Aviation Administration Federal Award ID Number: SAF-SWG-3-35-0037-051-2020, SAF-SWG-3-35-0037-057-2021 Federal Award Year: 2024 Condition: The City submitted reimbursements for grants in an untimely fashion for multiple months at a time in the Federal Transit Cluster and only at year-end in the Airport Improvement Program. Criteria: Per 2 CFR 200.303(a), the non-federal entity must 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). Per Title 2 US Code of Federal Regulations Part 200.302b, the non-federal entity must provide for effective control over, and accountability for, all funds, property, and other assets. The non-federal entity must adequately safeguard all assets and assure that they are used solely for authorized purposes. Cause: The City does not have sufficient controls in place to review and approve requests to submit as needed. Questioned Cost: None. Effect: The City’s financial position and cash balances were adversely affected due to the delay in requesting and receiving reimbursement for funds already disbursed. Significant time passing between disbursement of funds and preparation of reimbursement requests may increase the chance of errors.
2024-003 – Reimbursement Requests (Significant Deficiency in Internal Controls over Compliance) Federal Program Information Federal Award Title and ALN: Federal Transit Cluster, 20.507, 20.526 Federal Awarding Agency: Department of Transportation Federal Award ID Number: N/A Federal Award Year: 2024 Federal Award Title and ALN: Airport Improvement Program, 20.106 Federal Awarding Agency: Department of Transportation, Federal Aviation Administration Federal Award ID Number: SAF-SWG-3-35-0037-051-2020, SAF-SWG-3-35-0037-057-2021 Federal Award Year: 2024 Condition: The City submitted reimbursements for grants in an untimely fashion for multiple months at a time in the Federal Transit Cluster and only at year-end in the Airport Improvement Program. Criteria: Per 2 CFR 200.303(a), the non-federal entity must 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). Per Title 2 US Code of Federal Regulations Part 200.302b, the non-federal entity must provide for effective control over, and accountability for, all funds, property, and other assets. The non-federal entity must adequately safeguard all assets and assure that they are used solely for authorized purposes. Cause: The City does not have sufficient controls in place to review and approve requests to submit as needed. Questioned Cost: None. Effect: The City’s financial position and cash balances were adversely affected due to the delay in requesting and receiving reimbursement for funds already disbursed. Significant time passing between disbursement of funds and preparation of reimbursement requests may increase the chance of errors.
#2024-001 – Significant Deficiency – Allowable Costs and Cost Principles HOME Funds ALN 14.239 Criteria The Office of Management and Budget issuance of the Code of Federal Regulations (CFR) specifically states uniform administrative requirements, cost principles, and audit requirements for federal awards. CFR 200.302(b)(3) states, “The recipient’s financial management system must maintain records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.” Condition During the course of the audit, we noted there was no source documentation for seven expenses tested. Cause The Organization has made a reasonable effort to design proper controls, but has faced challenges in implementing them effectively, primarily with credit card charges and an increase in construction projects. Effect The potential effects of not having supporting documentation on file could include over or undercharging expenses to the federal grants. Questioned Costs $355.59 Perspective Information The finding noted related to seven (7) transactions examined when testing a sample of forty (40) non-payroll cash disbursements. The transactions are all credit card charges that the Organization did not maintain adequate documentation for. Recommendation We recommend having supporting documentation on file for all expenses charged to the Federal grants that shows approval of the expense from an appropriate member of management. View of Responsible Official Please see corresponding Corrective Action Plan.
FINDING 2024-003 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Number: 84.425U Federal Award Number and Year (or Other Identifying Number): S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2022-002. Condition and Context An effective internal control system was not designed or implemented at the School Corporation to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirement. The School Corporation had not designed, nor implemented, a system of internal controls to ensure that the annual Elementary and Secondary School Emergency Relief (ESSER) Data Collection reports (Reports) were complete and accurately submitted. The Reports were prepared by one employee without a documented oversight, review, or approval process in place to prevent, or detect and correct, errors. Due to the lack of effective internal controls, two of the five Reports submitted during the audit period were not supported by the School Corporation's records. The following errors were noted: For the ESSER III, Year 2 report, which covered the period July 1, 2021 to June 30, 2022, total expenses reported were understated by $369,741. For the ESSER III, Year 3 report, which covered the period July 1, 2022 to June 30, 2023, total expenses reported for Property - Mandatory Subgrant Funds - Exclusive of Learning Loss Set-Aside were understated by $519,504. Total expenses reported for Supplies - Mandatory Subgrant Funds - Learning Loss Set-Aside were overstated by $11,260. The lack of internal controls was a systemic issue throughout the audit period. Noncompliance was isolated to the ESSER III, Year 2 and Year 3 reports. INDIANA STATE BOARD OF ACCOUNTS 18 JAC-CEN-DEL COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 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 200.334 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 Federal awards that are renewed quarterly or 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 of a 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 Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Cause A proper system of internal controls was not designed by management of the School Corporation. Due to turnover in the position responsible for review, reports were not reviewed to detect errors prior to submission. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, the ESSER III, Year 2 and Year 3 reports were not supported by the School Corporation's records. INDIANA STATE BOARD OF ACCOUNTS 19 JAC-CEN-DEL COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Questioned Costs There were no questioned costs identified. Recommendation We recommended that the management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure that all reports are supported by the School Corporation's records. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-003 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Number: 84.425U Federal Award Number and Year (or Other Identifying Number): S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2022-002. Condition and Context An effective internal control system was not designed or implemented at the School Corporation to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirement. The School Corporation had not designed, nor implemented, a system of internal controls to ensure that the annual Elementary and Secondary School Emergency Relief (ESSER) Data Collection reports (Reports) were complete and accurately submitted. The Reports were prepared by one employee without a documented oversight, review, or approval process in place to prevent, or detect and correct, errors. Due to the lack of effective internal controls, two of the five Reports submitted during the audit period were not supported by the School Corporation's records. The following errors were noted: For the ESSER III, Year 2 report, which covered the period July 1, 2021 to June 30, 2022, total expenses reported were understated by $369,741. For the ESSER III, Year 3 report, which covered the period July 1, 2022 to June 30, 2023, total expenses reported for Property - Mandatory Subgrant Funds - Exclusive of Learning Loss Set-Aside were understated by $519,504. Total expenses reported for Supplies - Mandatory Subgrant Funds - Learning Loss Set-Aside were overstated by $11,260. The lack of internal controls was a systemic issue throughout the audit period. Noncompliance was isolated to the ESSER III, Year 2 and Year 3 reports. INDIANA STATE BOARD OF ACCOUNTS 18 JAC-CEN-DEL COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 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 200.334 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 Federal awards that are renewed quarterly or 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 of a 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 Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Cause A proper system of internal controls was not designed by management of the School Corporation. Due to turnover in the position responsible for review, reports were not reviewed to detect errors prior to submission. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, the ESSER III, Year 2 and Year 3 reports were not supported by the School Corporation's records. INDIANA STATE BOARD OF ACCOUNTS 19 JAC-CEN-DEL COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Questioned Costs There were no questioned costs identified. Recommendation We recommended that the management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure that all reports are supported by the School Corporation's records. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Financial Management System- (Material Weakness) Criteria: According to 2 CFR 200.302, the financial management system of each non-Federal entity must provide records that identify adequately the source and application of funds for federally-funded activities. These records must contain information pertaining to Federal awards, authorizations, financial obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. Condition: Statement of financial position transactions were not allocated properly to programs/properties funded with federal funds. Cause: Due to a human error of individuals who were handling the accounting entries, some of transactions were not accurately allocated to the correct programs/properties. Effect: Improper allocation of transactions among various programs/properties could lead to comingling of funds from different projects. This could result in unallowable cost or in allowable cost charged simultaneously to two different programs/properties. Questioned Cost: None noted Recommendation: Establish an internal control procedures in place that provide for separate accountability for projects by allocating transactions properly and producing accurate financial reports for each federally funded programs/properties. Management's Views and Corrective Action Plan : Management's response is included in "Management's View and Corrective Action Plan" at the end of this report after the schedule of findings and questioned cost
Financial Management System- (Material Weakness) Criteria: According to 2 CFR 200.302, the financial management system of each non-Federal entity must provide records that identify adequately the source and application of funds for federally-funded activities. These records must contain information pertaining to Federal awards, authorizations, financial obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. Condition: Statement of financial position transactions were not allocated properly to programs/properties funded with federal funds. Cause: Due to a human error of individuals who were handling the accounting entries, some of transactions were not accurately allocated to the correct programs/properties. Effect: Improper allocation of transactions among various programs/properties could lead to comingling of funds from different projects. This could result in unallowable cost or in allowable cost charged simultaneously to two different programs/properties. Questioned Cost: None noted Recommendation: Establish an internal control procedures in place that provide for separate accountability for projects by allocating transactions properly and producing accurate financial reports for each federally funded programs/properties. Management's Views and Corrective Action Plan : Management's response is included in "Management's View and Corrective Action Plan" at the end of this report after the schedule of findings and questioned cost
FINDING 2024-003 Cash Management – Drawdowns from Incorrect Contract FINDING TYPE Material Weakness in Internal Control over Compliance AGENCY U.S. Department of Health and Human Services ALN 93.224 / 93.527 Health Center Cluster CRITERIA In accordance with 2 CFR 200.302 (b)(3), entities receiving federal funds are responsible for maintaining records that adequately identify the source and application of funds for federallyfunded activities. CONDITION AND CONTEXT During the year ended June 30, 2024, $542,511 of funds related to contract H80CS00718 were incorrectly drawn from contract 21C8ECS44608C6. The error was only noted after the balance in contract 21C8ECS44608C6 was prematurely exhausted by the incorrect drawdowns. Upon noting the error, management informed the federal government of the error and submitted a request to correct the contract balances on June 11, 2024. CAUSE The staff tasked with initiating the draw-downs for this program entered the incorrect contract number into a funding request and the error was then subsequently repeated. EFFECT OR POTENTIAL EFFECT The organization may initiate drawdown requests that are not in compliance with the cash management requirements of the Uniform Guidance. REPEAT FINDING No. RECOMMENDATION We recommend that the organization implement a periodic reconciliation between its internal accounting records and the federal government’s data of each contract’s remaining available balance. VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTION See attached corrective action plan. Questioned Costs None.
FINDING 2024-003 Cash Management – Drawdowns from Incorrect Contract FINDING TYPE Material Weakness in Internal Control over Compliance AGENCY U.S. Department of Health and Human Services ALN 93.224 / 93.527 Health Center Cluster CRITERIA In accordance with 2 CFR 200.302 (b)(3), entities receiving federal funds are responsible for maintaining records that adequately identify the source and application of funds for federallyfunded activities. CONDITION AND CONTEXT During the year ended June 30, 2024, $542,511 of funds related to contract H80CS00718 were incorrectly drawn from contract 21C8ECS44608C6. The error was only noted after the balance in contract 21C8ECS44608C6 was prematurely exhausted by the incorrect drawdowns. Upon noting the error, management informed the federal government of the error and submitted a request to correct the contract balances on June 11, 2024. CAUSE The staff tasked with initiating the draw-downs for this program entered the incorrect contract number into a funding request and the error was then subsequently repeated. EFFECT OR POTENTIAL EFFECT The organization may initiate drawdown requests that are not in compliance with the cash management requirements of the Uniform Guidance. REPEAT FINDING No. RECOMMENDATION We recommend that the organization implement a periodic reconciliation between its internal accounting records and the federal government’s data of each contract’s remaining available balance. VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTION See attached corrective action plan. Questioned Costs None.
FINDING 2024-003 Cash Management – Drawdowns from Incorrect Contract FINDING TYPE Material Weakness in Internal Control over Compliance AGENCY U.S. Department of Health and Human Services ALN 93.224 / 93.527 Health Center Cluster CRITERIA In accordance with 2 CFR 200.302 (b)(3), entities receiving federal funds are responsible for maintaining records that adequately identify the source and application of funds for federallyfunded activities. CONDITION AND CONTEXT During the year ended June 30, 2024, $542,511 of funds related to contract H80CS00718 were incorrectly drawn from contract 21C8ECS44608C6. The error was only noted after the balance in contract 21C8ECS44608C6 was prematurely exhausted by the incorrect drawdowns. Upon noting the error, management informed the federal government of the error and submitted a request to correct the contract balances on June 11, 2024. CAUSE The staff tasked with initiating the draw-downs for this program entered the incorrect contract number into a funding request and the error was then subsequently repeated. EFFECT OR POTENTIAL EFFECT The organization may initiate drawdown requests that are not in compliance with the cash management requirements of the Uniform Guidance. REPEAT FINDING No. RECOMMENDATION We recommend that the organization implement a periodic reconciliation between its internal accounting records and the federal government’s data of each contract’s remaining available balance. VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTION See attached corrective action plan. Questioned Costs None.
FINDING 2024-003 Cash Management – Drawdowns from Incorrect Contract FINDING TYPE Material Weakness in Internal Control over Compliance AGENCY U.S. Department of Health and Human Services ALN 93.224 / 93.527 Health Center Cluster CRITERIA In accordance with 2 CFR 200.302 (b)(3), entities receiving federal funds are responsible for maintaining records that adequately identify the source and application of funds for federallyfunded activities. CONDITION AND CONTEXT During the year ended June 30, 2024, $542,511 of funds related to contract H80CS00718 were incorrectly drawn from contract 21C8ECS44608C6. The error was only noted after the balance in contract 21C8ECS44608C6 was prematurely exhausted by the incorrect drawdowns. Upon noting the error, management informed the federal government of the error and submitted a request to correct the contract balances on June 11, 2024. CAUSE The staff tasked with initiating the draw-downs for this program entered the incorrect contract number into a funding request and the error was then subsequently repeated. EFFECT OR POTENTIAL EFFECT The organization may initiate drawdown requests that are not in compliance with the cash management requirements of the Uniform Guidance. REPEAT FINDING No. RECOMMENDATION We recommend that the organization implement a periodic reconciliation between its internal accounting records and the federal government’s data of each contract’s remaining available balance. VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTION See attached corrective action plan. Questioned Costs None.
FINDING 2024-003 Cash Management – Drawdowns from Incorrect Contract FINDING TYPE Material Weakness in Internal Control over Compliance AGENCY U.S. Department of Health and Human Services ALN 93.224 / 93.527 Health Center Cluster CRITERIA In accordance with 2 CFR 200.302 (b)(3), entities receiving federal funds are responsible for maintaining records that adequately identify the source and application of funds for federallyfunded activities. CONDITION AND CONTEXT During the year ended June 30, 2024, $542,511 of funds related to contract H80CS00718 were incorrectly drawn from contract 21C8ECS44608C6. The error was only noted after the balance in contract 21C8ECS44608C6 was prematurely exhausted by the incorrect drawdowns. Upon noting the error, management informed the federal government of the error and submitted a request to correct the contract balances on June 11, 2024. CAUSE The staff tasked with initiating the draw-downs for this program entered the incorrect contract number into a funding request and the error was then subsequently repeated. EFFECT OR POTENTIAL EFFECT The organization may initiate drawdown requests that are not in compliance with the cash management requirements of the Uniform Guidance. REPEAT FINDING No. RECOMMENDATION We recommend that the organization implement a periodic reconciliation between its internal accounting records and the federal government’s data of each contract’s remaining available balance. VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTION See attached corrective action plan. Questioned Costs None.
FINDING 2024-003 Cash Management – Drawdowns from Incorrect Contract FINDING TYPE Material Weakness in Internal Control over Compliance AGENCY U.S. Department of Health and Human Services ALN 93.224 / 93.527 Health Center Cluster CRITERIA In accordance with 2 CFR 200.302 (b)(3), entities receiving federal funds are responsible for maintaining records that adequately identify the source and application of funds for federallyfunded activities. CONDITION AND CONTEXT During the year ended June 30, 2024, $542,511 of funds related to contract H80CS00718 were incorrectly drawn from contract 21C8ECS44608C6. The error was only noted after the balance in contract 21C8ECS44608C6 was prematurely exhausted by the incorrect drawdowns. Upon noting the error, management informed the federal government of the error and submitted a request to correct the contract balances on June 11, 2024. CAUSE The staff tasked with initiating the draw-downs for this program entered the incorrect contract number into a funding request and the error was then subsequently repeated. EFFECT OR POTENTIAL EFFECT The organization may initiate drawdown requests that are not in compliance with the cash management requirements of the Uniform Guidance. REPEAT FINDING No. RECOMMENDATION We recommend that the organization implement a periodic reconciliation between its internal accounting records and the federal government’s data of each contract’s remaining available balance. VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTION See attached corrective action plan. Questioned Costs None.
FINDING 2024-003 Cash Management – Drawdowns from Incorrect Contract FINDING TYPE Material Weakness in Internal Control over Compliance AGENCY U.S. Department of Health and Human Services ALN 93.224 / 93.527 Health Center Cluster CRITERIA In accordance with 2 CFR 200.302 (b)(3), entities receiving federal funds are responsible for maintaining records that adequately identify the source and application of funds for federallyfunded activities. CONDITION AND CONTEXT During the year ended June 30, 2024, $542,511 of funds related to contract H80CS00718 were incorrectly drawn from contract 21C8ECS44608C6. The error was only noted after the balance in contract 21C8ECS44608C6 was prematurely exhausted by the incorrect drawdowns. Upon noting the error, management informed the federal government of the error and submitted a request to correct the contract balances on June 11, 2024. CAUSE The staff tasked with initiating the draw-downs for this program entered the incorrect contract number into a funding request and the error was then subsequently repeated. EFFECT OR POTENTIAL EFFECT The organization may initiate drawdown requests that are not in compliance with the cash management requirements of the Uniform Guidance. REPEAT FINDING No. RECOMMENDATION We recommend that the organization implement a periodic reconciliation between its internal accounting records and the federal government’s data of each contract’s remaining available balance. VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTION See attached corrective action plan. Questioned Costs None.
FINDING 2024-004 Special Tests and Provisions – Application of Sliding Fees FINDING TYPE Significant Deficiency in Internal Control over Compliance AGENCY U.S. Department of Health and Human Services ALN 93.224 / 93.527 Health Center Cluster CRITERIA In accordance with 42 USC 254b(k)(3)(E), (F), and (G); 42 CFR sections 51c.303(e), (f), and (g); and 42 CFR sections 56.303(e), (f), and (g) 2 CFR 200.302 (b)(3), health centers must prepare and apply a sliding fee discount schedule (SFDS) so that amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient’s ability to pay. CONDITION AND CONTEXT During the year ended June 30, 2024, out of a sample of 40 transactions, we noted 12 instances where the sliding fee discount was either incorrectly calculated or not applied. In addition, we noted 4 items for which documentation supporting the fee was not available. The known error in the sample was $725 and the projected total error was $4,169. CAUSE Given the volume of patients served by the health center program, there were instances where the staff made errors in the application of the SFDS. EFFECT OR POTENTIAL EFFECT The organization was not consistently in compliance with the SFDS requirements of the health center program. REPEAT FINDING No. RECOMMENDATION We recommend that the organization implement a review of its SFDS protocols and adjust processes and retrain staff to ensure consistent application of the SFDS. VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTION See attached corrective action plan. Questioned Costs None.
FINDING 2024-004 Special Tests and Provisions – Application of Sliding Fees FINDING TYPE Significant Deficiency in Internal Control over Compliance AGENCY U.S. Department of Health and Human Services ALN 93.224 / 93.527 Health Center Cluster CRITERIA In accordance with 42 USC 254b(k)(3)(E), (F), and (G); 42 CFR sections 51c.303(e), (f), and (g); and 42 CFR sections 56.303(e), (f), and (g) 2 CFR 200.302 (b)(3), health centers must prepare and apply a sliding fee discount schedule (SFDS) so that amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient’s ability to pay. CONDITION AND CONTEXT During the year ended June 30, 2024, out of a sample of 40 transactions, we noted 12 instances where the sliding fee discount was either incorrectly calculated or not applied. In addition, we noted 4 items for which documentation supporting the fee was not available. The known error in the sample was $725 and the projected total error was $4,169. CAUSE Given the volume of patients served by the health center program, there were instances where the staff made errors in the application of the SFDS. EFFECT OR POTENTIAL EFFECT The organization was not consistently in compliance with the SFDS requirements of the health center program. REPEAT FINDING No. RECOMMENDATION We recommend that the organization implement a review of its SFDS protocols and adjust processes and retrain staff to ensure consistent application of the SFDS. VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTION See attached corrective action plan. Questioned Costs None.
FINDING 2024-004 Special Tests and Provisions – Application of Sliding Fees FINDING TYPE Significant Deficiency in Internal Control over Compliance AGENCY U.S. Department of Health and Human Services ALN 93.224 / 93.527 Health Center Cluster CRITERIA In accordance with 42 USC 254b(k)(3)(E), (F), and (G); 42 CFR sections 51c.303(e), (f), and (g); and 42 CFR sections 56.303(e), (f), and (g) 2 CFR 200.302 (b)(3), health centers must prepare and apply a sliding fee discount schedule (SFDS) so that amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient’s ability to pay. CONDITION AND CONTEXT During the year ended June 30, 2024, out of a sample of 40 transactions, we noted 12 instances where the sliding fee discount was either incorrectly calculated or not applied. In addition, we noted 4 items for which documentation supporting the fee was not available. The known error in the sample was $725 and the projected total error was $4,169. CAUSE Given the volume of patients served by the health center program, there were instances where the staff made errors in the application of the SFDS. EFFECT OR POTENTIAL EFFECT The organization was not consistently in compliance with the SFDS requirements of the health center program. REPEAT FINDING No. RECOMMENDATION We recommend that the organization implement a review of its SFDS protocols and adjust processes and retrain staff to ensure consistent application of the SFDS. VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTION See attached corrective action plan. Questioned Costs None.
FINDING 2024-004 Special Tests and Provisions – Application of Sliding Fees FINDING TYPE Significant Deficiency in Internal Control over Compliance AGENCY U.S. Department of Health and Human Services ALN 93.224 / 93.527 Health Center Cluster CRITERIA In accordance with 42 USC 254b(k)(3)(E), (F), and (G); 42 CFR sections 51c.303(e), (f), and (g); and 42 CFR sections 56.303(e), (f), and (g) 2 CFR 200.302 (b)(3), health centers must prepare and apply a sliding fee discount schedule (SFDS) so that amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient’s ability to pay. CONDITION AND CONTEXT During the year ended June 30, 2024, out of a sample of 40 transactions, we noted 12 instances where the sliding fee discount was either incorrectly calculated or not applied. In addition, we noted 4 items for which documentation supporting the fee was not available. The known error in the sample was $725 and the projected total error was $4,169. CAUSE Given the volume of patients served by the health center program, there were instances where the staff made errors in the application of the SFDS. EFFECT OR POTENTIAL EFFECT The organization was not consistently in compliance with the SFDS requirements of the health center program. REPEAT FINDING No. RECOMMENDATION We recommend that the organization implement a review of its SFDS protocols and adjust processes and retrain staff to ensure consistent application of the SFDS. VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTION See attached corrective action plan. Questioned Costs None.
FINDING 2024-004 Special Tests and Provisions – Application of Sliding Fees FINDING TYPE Significant Deficiency in Internal Control over Compliance AGENCY U.S. Department of Health and Human Services ALN 93.224 / 93.527 Health Center Cluster CRITERIA In accordance with 42 USC 254b(k)(3)(E), (F), and (G); 42 CFR sections 51c.303(e), (f), and (g); and 42 CFR sections 56.303(e), (f), and (g) 2 CFR 200.302 (b)(3), health centers must prepare and apply a sliding fee discount schedule (SFDS) so that amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient’s ability to pay. CONDITION AND CONTEXT During the year ended June 30, 2024, out of a sample of 40 transactions, we noted 12 instances where the sliding fee discount was either incorrectly calculated or not applied. In addition, we noted 4 items for which documentation supporting the fee was not available. The known error in the sample was $725 and the projected total error was $4,169. CAUSE Given the volume of patients served by the health center program, there were instances where the staff made errors in the application of the SFDS. EFFECT OR POTENTIAL EFFECT The organization was not consistently in compliance with the SFDS requirements of the health center program. REPEAT FINDING No. RECOMMENDATION We recommend that the organization implement a review of its SFDS protocols and adjust processes and retrain staff to ensure consistent application of the SFDS. VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTION See attached corrective action plan. Questioned Costs None.
FINDING 2024-004 Special Tests and Provisions – Application of Sliding Fees FINDING TYPE Significant Deficiency in Internal Control over Compliance AGENCY U.S. Department of Health and Human Services ALN 93.224 / 93.527 Health Center Cluster CRITERIA In accordance with 42 USC 254b(k)(3)(E), (F), and (G); 42 CFR sections 51c.303(e), (f), and (g); and 42 CFR sections 56.303(e), (f), and (g) 2 CFR 200.302 (b)(3), health centers must prepare and apply a sliding fee discount schedule (SFDS) so that amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient’s ability to pay. CONDITION AND CONTEXT During the year ended June 30, 2024, out of a sample of 40 transactions, we noted 12 instances where the sliding fee discount was either incorrectly calculated or not applied. In addition, we noted 4 items for which documentation supporting the fee was not available. The known error in the sample was $725 and the projected total error was $4,169. CAUSE Given the volume of patients served by the health center program, there were instances where the staff made errors in the application of the SFDS. EFFECT OR POTENTIAL EFFECT The organization was not consistently in compliance with the SFDS requirements of the health center program. REPEAT FINDING No. RECOMMENDATION We recommend that the organization implement a review of its SFDS protocols and adjust processes and retrain staff to ensure consistent application of the SFDS. VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTION See attached corrective action plan. Questioned Costs None.
FINDING 2024-004 Special Tests and Provisions – Application of Sliding Fees FINDING TYPE Significant Deficiency in Internal Control over Compliance AGENCY U.S. Department of Health and Human Services ALN 93.224 / 93.527 Health Center Cluster CRITERIA In accordance with 42 USC 254b(k)(3)(E), (F), and (G); 42 CFR sections 51c.303(e), (f), and (g); and 42 CFR sections 56.303(e), (f), and (g) 2 CFR 200.302 (b)(3), health centers must prepare and apply a sliding fee discount schedule (SFDS) so that amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient’s ability to pay. CONDITION AND CONTEXT During the year ended June 30, 2024, out of a sample of 40 transactions, we noted 12 instances where the sliding fee discount was either incorrectly calculated or not applied. In addition, we noted 4 items for which documentation supporting the fee was not available. The known error in the sample was $725 and the projected total error was $4,169. CAUSE Given the volume of patients served by the health center program, there were instances where the staff made errors in the application of the SFDS. EFFECT OR POTENTIAL EFFECT The organization was not consistently in compliance with the SFDS requirements of the health center program. REPEAT FINDING No. RECOMMENDATION We recommend that the organization implement a review of its SFDS protocols and adjust processes and retrain staff to ensure consistent application of the SFDS. VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTION See attached corrective action plan. Questioned Costs None.
Information on the federal program: Subject: Education Stabilization Fund (ESSER) – Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards 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 200.302(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 Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 Financial reporting . . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirements. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with the compliance requirements listed above. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There were no questioned costs identified. Context: The School Corporation was required to submit two Annual Data Reports to the Indiana Department of Education (IDOE) during the audit period to meet federal reporting requirements for ESSER grant awards. We noted that the ESSER I, ESSER II, and ESSER III amounts reported for the reports covering the FY22 time period ($3,000, $0 and $0, respectively) did not agree to the underlying expenditure records ($0, $207,168, and $104,885, respectively, for the period of July 1, 2021 through June 30, 2022). Additionally, we noted that the ESSER I, ESSER II, and ESSER III amounts reported for the reports covering the FY23 time period ($0, $328,359 and $334,119, respectively) did not agree to the underlying expenditure records ($0, $121,193 and $229,234, respectively, for the period of July 1, 2022 through June 30, 2023). Identification as a repeat finding: No. Recommendation: We recommend someone other than the preparer of the report perform a documented review prior to submission to validate the accuracy and completeness of the data submitted. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Information on the federal program: Subject: Education Stabilization Fund (ESSER) – Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards 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 200.302(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 Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 Financial reporting . . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirements. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with the compliance requirements listed above. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There were no questioned costs identified. Context: The School Corporation was required to submit two Annual Data Reports to the Indiana Department of Education (IDOE) during the audit period to meet federal reporting requirements for ESSER grant awards. We noted that the ESSER I, ESSER II, and ESSER III amounts reported for the reports covering the FY22 time period ($3,000, $0 and $0, respectively) did not agree to the underlying expenditure records ($0, $207,168, and $104,885, respectively, for the period of July 1, 2021 through June 30, 2022). Additionally, we noted that the ESSER I, ESSER II, and ESSER III amounts reported for the reports covering the FY23 time period ($0, $328,359 and $334,119, respectively) did not agree to the underlying expenditure records ($0, $121,193 and $229,234, respectively, for the period of July 1, 2022 through June 30, 2023). Identification as a repeat finding: No. Recommendation: We recommend someone other than the preparer of the report perform a documented review prior to submission to validate the accuracy and completeness of the data submitted. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Information on the federal program: Subject: Education Stabilization Fund (ESSER) – Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425D Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards 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 200.302(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 Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 Financial reporting . . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirements. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with the compliance requirements listed above. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There were no questioned costs identified. Context: The School Corporation was required to submit two Annual Data Reports to the Indiana Department of Education (IDOE) during the audit period to meet federal reporting requirements for ESSER grant awards. We noted that the ESSER I and ESSER II amounts reported for the reports covering the FY22 time period ($90,217 and $238,439, respectively) did not agree to the underlying expenditure records ($81,958 and $400,439 respectively, for the period of July 1, 2021 through June 30, 2022). Identification as a repeat finding: This is a repeat finding form the immediately prior audit. The prior finding number was 2022-002. Recommendation: We recommend someone other than the preparer of the report perform a documented review prior to submission to validate the accuracy and completeness of the data submitted. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Information on the federal program: Subject: Education Stabilization Fund (ESSER) – Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425D Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards 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 200.302(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 Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 Financial reporting . . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirements. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with the compliance requirements listed above. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There were no questioned costs identified. Context: The School Corporation was required to submit two Annual Data Reports to the Indiana Department of Education (IDOE) during the audit period to meet federal reporting requirements for ESSER grant awards. We noted that the ESSER I and ESSER II amounts reported for the reports covering the FY22 time period ($90,217 and $238,439, respectively) did not agree to the underlying expenditure records ($81,958 and $400,439 respectively, for the period of July 1, 2021 through June 30, 2022). Identification as a repeat finding: This is a repeat finding form the immediately prior audit. The prior finding number was 2022-002. Recommendation: We recommend someone other than the preparer of the report perform a documented review prior to submission to validate the accuracy and completeness of the data submitted. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Information on the federal program: Subject: COVID-19 – Education Stabilization Fund – Reporting Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards 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 200.302(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 Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 Financial reporting . . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirements. Cause: The School District's management had not developed a system of internal controls to ensure compliance with the compliance requirements listed above. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. Internal controls were not adequate to detect and prevent errors in annual data submitted to the Indiana Department of Education. Questioned Costs: There were no questioned costs identified. Context: The School Corporation had not designed nor implemented a system of internal control to ensure that the annual Elementary and Secondary School Emergency Relief (ESSER) annual Data Collection reports (Reports) were complete and accurately submitted. The reports were prepared and submitted in JotForm, the online application used by the Indiana Department of Education to collect information, without an oversight or secondary review process in place to prevent or detect and correct errors. During the testing of the annual data reports, variances were noted in the amounts expended reported on the Year 4 annual data report for the ESSER I and the Year 3 annual data reports for ESSER II and ESSER III grant awards when compared to underlying disbursement detail for the grant funds covering the period of July 1, 2022 through June 30, 2023. The amounts reported as expended in the annual data reports were underreported by $504,240 compared to underlying funds ledger detail. Identification as a repeat finding, if applicable: No. Recommendation: We recommend someone other than the preparer of the report perform a documented, secondary review of the report information prior to submission to validate the accuracy and completeness of the data submitted. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Information on the federal program: Subject: COVID-19 – Education Stabilization Fund – Reporting Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards 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 200.302(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 Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 Financial reporting . . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirements. Cause: The School District's management had not developed a system of internal controls to ensure compliance with the compliance requirements listed above. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. Internal controls were not adequate to detect and prevent errors in annual data submitted to the Indiana Department of Education. Questioned Costs: There were no questioned costs identified. Context: The School Corporation had not designed nor implemented a system of internal control to ensure that the annual Elementary and Secondary School Emergency Relief (ESSER) annual Data Collection reports (Reports) were complete and accurately submitted. The reports were prepared and submitted in JotForm, the online application used by the Indiana Department of Education to collect information, without an oversight or secondary review process in place to prevent or detect and correct errors. During the testing of the annual data reports, variances were noted in the amounts expended reported on the Year 4 annual data report for the ESSER I and the Year 3 annual data reports for ESSER II and ESSER III grant awards when compared to underlying disbursement detail for the grant funds covering the period of July 1, 2022 through June 30, 2023. The amounts reported as expended in the annual data reports were underreported by $504,240 compared to underlying funds ledger detail. Identification as a repeat finding, if applicable: No. Recommendation: We recommend someone other than the preparer of the report perform a documented, secondary review of the report information prior to submission to validate the accuracy and completeness of the data submitted. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Information on the federal program: Subject: COVID-19 – Education Stabilization Fund – Reporting Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards 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 200.302(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 Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 Financial reporting . . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirements. Cause: The School District's management had not developed a system of internal controls to ensure compliance with the compliance requirements listed above. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. Internal controls were not adequate to detect and prevent errors in annual data submitted to the Indiana Department of Education. Questioned Costs: There were no questioned costs identified. Context: The School Corporation had not designed nor implemented a system of internal control to ensure that the annual Elementary and Secondary School Emergency Relief (ESSER) annual Data Collection reports (Reports) were complete and accurately submitted. The reports were prepared and submitted in JotForm, the online application used by the Indiana Department of Education to collect information, without an oversight or secondary review process in place to prevent or detect and correct errors. During the testing of the annual data reports, variances were noted in the amounts expended reported on the Year 4 annual data report for the ESSER I and the Year 3 annual data reports for ESSER II and ESSER III grant awards when compared to underlying disbursement detail for the grant funds covering the period of July 1, 2022 through June 30, 2023. The amounts reported as expended in the annual data reports were underreported by $504,240 compared to underlying funds ledger detail. Identification as a repeat finding, if applicable: No. Recommendation: We recommend someone other than the preparer of the report perform a documented, secondary review of the report information prior to submission to validate the accuracy and completeness of the data submitted. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Information on the federal program: Subject: COVID-19 – Education Stabilization Fund – Reporting Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards 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 200.302(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 Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 Financial reporting . . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirements. Cause: The School District's management had not developed a system of internal controls to ensure compliance with the compliance requirements listed above. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. Internal controls were not adequate to detect and prevent errors in annual data submitted to the Indiana Department of Education. Questioned Costs: There were no questioned costs identified. Context: The School Corporation had not designed nor implemented a system of internal control to ensure that the annual Elementary and Secondary School Emergency Relief (ESSER) annual Data Collection reports (Reports) were complete and accurately submitted. The reports were prepared and submitted in JotForm, the online application used by the Indiana Department of Education to collect information, without an oversight or secondary review process in place to prevent or detect and correct errors. During the testing of the annual data reports, variances were noted in the amounts expended reported on the Year 4 annual data report for the ESSER I and the Year 3 annual data reports for ESSER II and ESSER III grant awards when compared to underlying disbursement detail for the grant funds covering the period of July 1, 2022 through June 30, 2023. The amounts reported as expended in the annual data reports were underreported by $504,240 compared to underlying funds ledger detail. Identification as a repeat finding, if applicable: No. Recommendation: We recommend someone other than the preparer of the report perform a documented, secondary review of the report information prior to submission to validate the accuracy and completeness of the data submitted. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Information on the federal program: Subject: COVID-19 – Education Stabilization Fund – Reporting Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Significant Deficiency Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards 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 200.302(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 Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 Financial reporting . . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirements. Cause: The School District's management had not developed a system of internal controls to ensure compliance with the compliance requirements listed above. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. Internal controls were not adequate to detect and prevent errors in annual data submitted to the Indiana Department of Education. Questioned Costs: There were no questioned costs identified. Context: The School Corporation had not designed nor implemented a system of internal control to ensure that the annual Elementary and Secondary School Emergency Relief (ESSER) annual Data Collection reports (Reports) were complete and accurately submitted. The reports were prepared and submitted in JotForm, the online application used by the Indiana Department of Education to collect information, without an oversight or secondary review process in place to prevent or detect and correct errors. During the testing of the annual data reports, variances were noted in the amounts expended reported on the Year 3 and Year 4 annual data reports for the ESSER I, ESSER II and ESSER III grant awards when compared to underlying disbursement detail for the grant funds. The amounts reported as expended in the Year 3 reports, which covers the period of July 1, 2021 through June 30, 2022, were underreported by $10,152. The amounts reported as expended in the Year 4 report, which covers the period of July 1, 2022 through June 30, 2023, were overreported by $43,050. This resulted in a net overreporting of $32,898. Annual Data Report Year 3 - Period of 7/1/21 - 6/30/22 As Reported Per Support Over (under) Reported ESSER I CARES $ 67,160 $ 64,712 $ (2,448) ESSER II 416,014 428,614 12,600 ESSER III (ARP) 441,903 441,903 - Total $ 925,077 $ 935,229 $ (10,152) Annual Data Report Year 4 - Period of 7/1/22 - 6/30/23 As Reported Per Support Over (under) Reported ESSER I CARES $ - $ 2,448 $ 2,448 ESSER II 60,897 200,041 139,144 ESSER III (ARP) 623,874 439,233 (184,641) Total $ 684,771 $ 641,722 $ 43,049 Additionally, Year 3 full-time equivalent employees were improperly reported at 84 instead of 87. Additionally, the CrossAct Detail for both Year 3 and Year 4 were not provided. Identification as a repeat finding, if applicable: No. Recommendation: We recommend someone other than the preparer of the report perform a documented, secondary review of the report information prior to submission to validate the accuracy and completeness of the data submitted. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Information on the federal program: Subject: COVID-19 – Education Stabilization Fund – Reporting Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Significant Deficiency Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards 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 200.302(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 Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 Financial reporting . . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirements. Cause: The School District's management had not developed a system of internal controls to ensure compliance with the compliance requirements listed above. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. Internal controls were not adequate to detect and prevent errors in annual data submitted to the Indiana Department of Education. Questioned Costs: There were no questioned costs identified. Context: The School Corporation had not designed nor implemented a system of internal control to ensure that the annual Elementary and Secondary School Emergency Relief (ESSER) annual Data Collection reports (Reports) were complete and accurately submitted. The reports were prepared and submitted in JotForm, the online application used by the Indiana Department of Education to collect information, without an oversight or secondary review process in place to prevent or detect and correct errors. During the testing of the annual data reports, variances were noted in the amounts expended reported on the Year 3 and Year 4 annual data reports for the ESSER I, ESSER II and ESSER III grant awards when compared to underlying disbursement detail for the grant funds. The amounts reported as expended in the Year 3 reports, which covers the period of July 1, 2021 through June 30, 2022, were underreported by $10,152. The amounts reported as expended in the Year 4 report, which covers the period of July 1, 2022 through June 30, 2023, were overreported by $43,050. This resulted in a net overreporting of $32,898. Annual Data Report Year 3 - Period of 7/1/21 - 6/30/22 As Reported Per Support Over (under) Reported ESSER I CARES $ 67,160 $ 64,712 $ (2,448) ESSER II 416,014 428,614 12,600 ESSER III (ARP) 441,903 441,903 - Total $ 925,077 $ 935,229 $ (10,152) Annual Data Report Year 4 - Period of 7/1/22 - 6/30/23 As Reported Per Support Over (under) Reported ESSER I CARES $ - $ 2,448 $ 2,448 ESSER II 60,897 200,041 139,144 ESSER III (ARP) 623,874 439,233 (184,641) Total $ 684,771 $ 641,722 $ 43,049 Additionally, Year 3 full-time equivalent employees were improperly reported at 84 instead of 87. Additionally, the CrossAct Detail for both Year 3 and Year 4 were not provided. Identification as a repeat finding, if applicable: No. Recommendation: We recommend someone other than the preparer of the report perform a documented, secondary review of the report information prior to submission to validate the accuracy and completeness of the data submitted. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Information on the federal program: Subject: COVID-19 – Education Stabilization Fund – Reporting Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Significant Deficiency Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards 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 200.302(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 Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 Financial reporting . . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirements. Cause: The School District's management had not developed a system of internal controls to ensure compliance with the compliance requirements listed above. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. Internal controls were not adequate to detect and prevent errors in annual data submitted to the Indiana Department of Education. Questioned Costs: There were no questioned costs identified. Context: The School Corporation had not designed nor implemented a system of internal control to ensure that the annual Elementary and Secondary School Emergency Relief (ESSER) annual Data Collection reports (Reports) were complete and accurately submitted. The reports were prepared and submitted in JotForm, the online application used by the Indiana Department of Education to collect information, without an oversight or secondary review process in place to prevent or detect and correct errors. During the testing of the annual data reports, variances were noted in the amounts expended reported on the Year 3 and Year 4 annual data reports for the ESSER I, ESSER II and ESSER III grant awards when compared to underlying disbursement detail for the grant funds. The amounts reported as expended in the Year 3 reports, which covers the period of July 1, 2021 through June 30, 2022, were underreported by $10,152. The amounts reported as expended in the Year 4 report, which covers the period of July 1, 2022 through June 30, 2023, were overreported by $43,050. This resulted in a net overreporting of $32,898. Annual Data Report Year 3 - Period of 7/1/21 - 6/30/22 As Reported Per Support Over (under) Reported ESSER I CARES $ 67,160 $ 64,712 $ (2,448) ESSER II 416,014 428,614 12,600 ESSER III (ARP) 441,903 441,903 - Total $ 925,077 $ 935,229 $ (10,152) Annual Data Report Year 4 - Period of 7/1/22 - 6/30/23 As Reported Per Support Over (under) Reported ESSER I CARES $ - $ 2,448 $ 2,448 ESSER II 60,897 200,041 139,144 ESSER III (ARP) 623,874 439,233 (184,641) Total $ 684,771 $ 641,722 $ 43,049 Additionally, Year 3 full-time equivalent employees were improperly reported at 84 instead of 87. Additionally, the CrossAct Detail for both Year 3 and Year 4 were not provided. Identification as a repeat finding, if applicable: No. Recommendation: We recommend someone other than the preparer of the report perform a documented, secondary review of the report information prior to submission to validate the accuracy and completeness of the data submitted. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Information on the federal program: Subject: COVID-19 – Education Stabilization Fund – Reporting Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Significant Deficiency Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards 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 200.302(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 Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 Financial reporting . . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirements. Cause: The School District's management had not developed a system of internal controls to ensure compliance with the compliance requirements listed above. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. Internal controls were not adequate to detect and prevent errors in annual data submitted to the Indiana Department of Education. Questioned Costs: There were no questioned costs identified. Context: The School Corporation had not designed nor implemented a system of internal control to ensure that the annual Elementary and Secondary School Emergency Relief (ESSER) annual Data Collection reports (Reports) were complete and accurately submitted. The reports were prepared and submitted in JotForm, the online application used by the Indiana Department of Education to collect information, without an oversight or secondary review process in place to prevent or detect and correct errors. During the testing of the annual data reports, variances were noted in the amounts expended reported on the Year 3 and Year 4 annual data reports for the ESSER I, ESSER II and ESSER III grant awards when compared to underlying disbursement detail for the grant funds. The amounts reported as expended in the Year 3 reports, which covers the period of July 1, 2021 through June 30, 2022, were underreported by $10,152. The amounts reported as expended in the Year 4 report, which covers the period of July 1, 2022 through June 30, 2023, were overreported by $43,050. This resulted in a net overreporting of $32,898. Annual Data Report Year 3 - Period of 7/1/21 - 6/30/22 As Reported Per Support Over (under) Reported ESSER I CARES $ 67,160 $ 64,712 $ (2,448) ESSER II 416,014 428,614 12,600 ESSER III (ARP) 441,903 441,903 - Total $ 925,077 $ 935,229 $ (10,152) Annual Data Report Year 4 - Period of 7/1/22 - 6/30/23 As Reported Per Support Over (under) Reported ESSER I CARES $ - $ 2,448 $ 2,448 ESSER II 60,897 200,041 139,144 ESSER III (ARP) 623,874 439,233 (184,641) Total $ 684,771 $ 641,722 $ 43,049 Additionally, Year 3 full-time equivalent employees were improperly reported at 84 instead of 87. Additionally, the CrossAct Detail for both Year 3 and Year 4 were not provided. Identification as a repeat finding, if applicable: No. Recommendation: We recommend someone other than the preparer of the report perform a documented, secondary review of the report information prior to submission to validate the accuracy and completeness of the data submitted. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Information on the federal program: Subject: COVID-19 – Education Stabilization Fund – Reporting Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Significant Deficiency Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards 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 200.302(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 Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 Financial reporting . . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirements. Cause: The School District's management had not developed a system of internal controls to ensure compliance with the compliance requirements listed above. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. Internal controls were not adequate to detect and prevent errors in annual data submitted to the Indiana Department of Education. Questioned Costs: There were no questioned costs identified. Context: The School Corporation had not designed nor implemented a system of internal control to ensure that the annual Elementary and Secondary School Emergency Relief (ESSER) annual Data Collection reports (Reports) were complete and accurately submitted. The reports were prepared and submitted in JotForm, the online application used by the Indiana Department of Education to collect information, without an oversight or secondary review process in place to prevent or detect and correct errors. During the testing of the annual data reports, variances were noted in the amounts expended reported on the Year 3 and Year 4 annual data reports for the ESSER I, ESSER II and ESSER III grant awards when compared to underlying disbursement detail for the grant funds. The amounts reported as expended in the Year 3 reports, which covers the period of July 1, 2021 through June 30, 2022, were underreported by $10,152. The amounts reported as expended in the Year 4 report, which covers the period of July 1, 2022 through June 30, 2023, were overreported by $43,050. This resulted in a net overreporting of $32,898. Annual Data Report Year 3 - Period of 7/1/21 - 6/30/22 As Reported Per Support Over (under) Reported ESSER I CARES $ 67,160 $ 64,712 $ (2,448) ESSER II 416,014 428,614 12,600 ESSER III (ARP) 441,903 441,903 - Total $ 925,077 $ 935,229 $ (10,152) Annual Data Report Year 4 - Period of 7/1/22 - 6/30/23 As Reported Per Support Over (under) Reported ESSER I CARES $ - $ 2,448 $ 2,448 ESSER II 60,897 200,041 139,144 ESSER III (ARP) 623,874 439,233 (184,641) Total $ 684,771 $ 641,722 $ 43,049 Additionally, Year 3 full-time equivalent employees were improperly reported at 84 instead of 87. Additionally, the CrossAct Detail for both Year 3 and Year 4 were not provided. Identification as a repeat finding, if applicable: No. Recommendation: We recommend someone other than the preparer of the report perform a documented, secondary review of the report information prior to submission to validate the accuracy and completeness of the data submitted. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
FINDING 2024-003 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Indiana Department of Education Federal Program: COVID-19 - Education Stablization Fund Assistance Listings Numbers: 84.425C, 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425C200018, S425D200013, S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion Condition and Context The School Corporation was required to submit annual data reports to the Indiana Department of Education (IDOE) via JotForm, a form/report builder. Data to be submitted included, but was not limited to, current period expenditures, prior period expenditures, and expenditures per activity. During the audit period, the School Corporation submitted one ESSER I report, two ESSER II reports, and two ESSER III reports for a total of five reports. The annual data reports were compiled, prepared, and submitted by the Treasurer without an oversight or review process in place to prevent, or detect and correct, errors. In addition, the five annual data reports were not supported by the School Corporation's records. The documentation used to prepare the reports was not retained by the School Corporation and the ledger activity for the time period of each report did not agree to the data submitted. As such, the Indiana State Board of Accounts could not verify the information submitted to the IDOE was accurate or complete. The lack of internal controls and noncompliance were systemic issues throughout the audit period. 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 200.334 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. . . ." 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 Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . ." (3) Records that identify adequately the source and application of funds for federally funded activities. These records must contain information pertaining to Federal awards, 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 format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." 34 CFR 76.731 states: "A State and a subgrantee shall keep records to show its compliance with program requirements." Cause A proper system of internal controls, which include segregation of key functions, was not established by management of the School Corporation to ensure that reports filed were supported by School Corporation records and had an independent review, for accuracy and completeness, prior to submission. Effect Without a proper system of internal controls in place that operated effectively, the School Corporation submitted reports that were not supported by School Corporation records. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure that documentation utilized in the preparation of the reports is maintained and that there is an independent review of the reports for accuracy and completeness prior to submission. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.