Finding 2023-002 – Inaccurate Property Management Records Federal Agency: U.S. Department of Agriculture (USDA) U.S. Department of Commerce (USDOC) U.S. Department of Defense (USDOD) U.S. Department of Education (USDE) U.S. Department of Energy (USDOE) U.S. Department of Health and Human Services (USDHHS) U.S. Department of Housing and Urban Development (USHUD) U.S. Department of Interior (USDOI) U.S. Department of Justice (USDOJ) U.S. Department of State (USDOS) U.S. Department of Transportation (USDOT) U.S. Director of National Intelligence (USDNI) U.S. Environmental Protection Agency (USEPA) National Aeronautics and Space Administration (NASA) National Endowment for the Humanities (NEH) National Science Foundation (NSF) U.S. Department of Veteran Affairs (USDVA) All Pass-Through Entities Program Name: Research and Development Cluster ALN # and Program Expenditures: Various ($508,850,558) Federal Award Numbers: Various – See schedule of award numbers Federal Award Year: Various – See schedule of award numbers Questioned Costs: None Compliance Requirement: Equipment Type of Finding: Noncompliance and material weakness Condition Found The University did not consistently follow its property management policies and procedures related to maintaining accurate property management records for equipment purchased with federal R&D Cluster program awards. The University conducts research at multiple locations throughout its campus where equipment purchased with federal awards is utilized and maintained. The University identifies all equipment in its property management records with individually assigned asset numbers and each individual asset record includes the specific location of the asset, the federal award general ledger account number which funded the purchase of the asset, and other required information. An asset tag with the assigned asset number is affixed to each asset in accordance with University policy. The University is required to safeguard equipment purchased with federal awards, maintain current property records, and to perform a physical inventory of equipment purchased with federal awards on a biennial basis. During our physical observation of 60 pieces of equipment (with a net book value (NBV) of $224,269) purchased with federal R&D Cluster awards, we noted eight items (with a NBV totaling $0) selected for physical observation were not able to be located for our testing. In response to the exceptions identified in our audit procedures, the University performed a physical inventory of all of its federally funded equipment in January 2024, which identified an additional 1,006 equipment items (with a NBV of $1,726,897) that could not be located, of which 839 were fully depreciated. University management believes these items were disposed of but not appropriately removed from the property records and federal equipment listing. As of June 30, 2023, the University’s federal equipment listing included 6,270 assets (with a NBV of $61,390,724) purchased with R&D Cluster program awards. We also noted the University’s controls for equipment dispositions are not operating at an appropriate level of precision to ensure equipment dispositions are properly authorized and property management records are updated on a timely basis. Criteria According to 2 CFR 200.313(d)(1), property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property, who holds title, the acquisition date, and cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. Per 2 CFR 200.313(d)(3) and (4), a control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of property and adequate maintenance procedures must be developed to keep the property in good condition. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, 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. Effective internal controls should include procedures to ensure that accurate property records are maintained and equipment items are properly tagged. Cause In discussing these conditions with University officials, they stated the decentralized nature of the equipment recordkeeping process can result in delayed reporting of asset disposals. Possible Asserted Effect Failure to maintain accurate property records may prohibit the University from properly safeguarding and maintaining equipment and may result in federal programs not receiving the appropriate share of proceeds from the disposals of equipment purchased with federal funds. Repeat Finding A similar finding was reported in the prior year audit as finding number 2022-002. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Recommendation We recommend the University review its procedures for updating property records to ensure they accurately reflect equipment information. Views of University Officials The University concurs with the finding and has begun to address these concerns. As noted in the finding, the University conducted a full federal equipment inventory in January 2024 and updated property records to ensure accuracy of federally funded equipment.
Finding 2023-002 – Inaccurate Property Management Records Federal Agency: U.S. Department of Agriculture (USDA) U.S. Department of Commerce (USDOC) U.S. Department of Defense (USDOD) U.S. Department of Education (USDE) U.S. Department of Energy (USDOE) U.S. Department of Health and Human Services (USDHHS) U.S. Department of Housing and Urban Development (USHUD) U.S. Department of Interior (USDOI) U.S. Department of Justice (USDOJ) U.S. Department of State (USDOS) U.S. Department of Transportation (USDOT) U.S. Director of National Intelligence (USDNI) U.S. Environmental Protection Agency (USEPA) National Aeronautics and Space Administration (NASA) National Endowment for the Humanities (NEH) National Science Foundation (NSF) U.S. Department of Veteran Affairs (USDVA) All Pass-Through Entities Program Name: Research and Development Cluster ALN # and Program Expenditures: Various ($508,850,558) Federal Award Numbers: Various – See schedule of award numbers Federal Award Year: Various – See schedule of award numbers Questioned Costs: None Compliance Requirement: Equipment Type of Finding: Noncompliance and material weakness Condition Found The University did not consistently follow its property management policies and procedures related to maintaining accurate property management records for equipment purchased with federal R&D Cluster program awards. The University conducts research at multiple locations throughout its campus where equipment purchased with federal awards is utilized and maintained. The University identifies all equipment in its property management records with individually assigned asset numbers and each individual asset record includes the specific location of the asset, the federal award general ledger account number which funded the purchase of the asset, and other required information. An asset tag with the assigned asset number is affixed to each asset in accordance with University policy. The University is required to safeguard equipment purchased with federal awards, maintain current property records, and to perform a physical inventory of equipment purchased with federal awards on a biennial basis. During our physical observation of 60 pieces of equipment (with a net book value (NBV) of $224,269) purchased with federal R&D Cluster awards, we noted eight items (with a NBV totaling $0) selected for physical observation were not able to be located for our testing. In response to the exceptions identified in our audit procedures, the University performed a physical inventory of all of its federally funded equipment in January 2024, which identified an additional 1,006 equipment items (with a NBV of $1,726,897) that could not be located, of which 839 were fully depreciated. University management believes these items were disposed of but not appropriately removed from the property records and federal equipment listing. As of June 30, 2023, the University’s federal equipment listing included 6,270 assets (with a NBV of $61,390,724) purchased with R&D Cluster program awards. We also noted the University’s controls for equipment dispositions are not operating at an appropriate level of precision to ensure equipment dispositions are properly authorized and property management records are updated on a timely basis. Criteria According to 2 CFR 200.313(d)(1), property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property, who holds title, the acquisition date, and cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. Per 2 CFR 200.313(d)(3) and (4), a control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of property and adequate maintenance procedures must be developed to keep the property in good condition. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, 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. Effective internal controls should include procedures to ensure that accurate property records are maintained and equipment items are properly tagged. Cause In discussing these conditions with University officials, they stated the decentralized nature of the equipment recordkeeping process can result in delayed reporting of asset disposals. Possible Asserted Effect Failure to maintain accurate property records may prohibit the University from properly safeguarding and maintaining equipment and may result in federal programs not receiving the appropriate share of proceeds from the disposals of equipment purchased with federal funds. Repeat Finding A similar finding was reported in the prior year audit as finding number 2022-002. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Recommendation We recommend the University review its procedures for updating property records to ensure they accurately reflect equipment information. Views of University Officials The University concurs with the finding and has begun to address these concerns. As noted in the finding, the University conducted a full federal equipment inventory in January 2024 and updated property records to ensure accuracy of federally funded equipment.
Finding 2023-002 – Inaccurate Property Management Records Federal Agency: U.S. Department of Agriculture (USDA) U.S. Department of Commerce (USDOC) U.S. Department of Defense (USDOD) U.S. Department of Education (USDE) U.S. Department of Energy (USDOE) U.S. Department of Health and Human Services (USDHHS) U.S. Department of Housing and Urban Development (USHUD) U.S. Department of Interior (USDOI) U.S. Department of Justice (USDOJ) U.S. Department of State (USDOS) U.S. Department of Transportation (USDOT) U.S. Director of National Intelligence (USDNI) U.S. Environmental Protection Agency (USEPA) National Aeronautics and Space Administration (NASA) National Endowment for the Humanities (NEH) National Science Foundation (NSF) U.S. Department of Veteran Affairs (USDVA) All Pass-Through Entities Program Name: Research and Development Cluster ALN # and Program Expenditures: Various ($508,850,558) Federal Award Numbers: Various – See schedule of award numbers Federal Award Year: Various – See schedule of award numbers Questioned Costs: None Compliance Requirement: Equipment Type of Finding: Noncompliance and material weakness Condition Found The University did not consistently follow its property management policies and procedures related to maintaining accurate property management records for equipment purchased with federal R&D Cluster program awards. The University conducts research at multiple locations throughout its campus where equipment purchased with federal awards is utilized and maintained. The University identifies all equipment in its property management records with individually assigned asset numbers and each individual asset record includes the specific location of the asset, the federal award general ledger account number which funded the purchase of the asset, and other required information. An asset tag with the assigned asset number is affixed to each asset in accordance with University policy. The University is required to safeguard equipment purchased with federal awards, maintain current property records, and to perform a physical inventory of equipment purchased with federal awards on a biennial basis. During our physical observation of 60 pieces of equipment (with a net book value (NBV) of $224,269) purchased with federal R&D Cluster awards, we noted eight items (with a NBV totaling $0) selected for physical observation were not able to be located for our testing. In response to the exceptions identified in our audit procedures, the University performed a physical inventory of all of its federally funded equipment in January 2024, which identified an additional 1,006 equipment items (with a NBV of $1,726,897) that could not be located, of which 839 were fully depreciated. University management believes these items were disposed of but not appropriately removed from the property records and federal equipment listing. As of June 30, 2023, the University’s federal equipment listing included 6,270 assets (with a NBV of $61,390,724) purchased with R&D Cluster program awards. We also noted the University’s controls for equipment dispositions are not operating at an appropriate level of precision to ensure equipment dispositions are properly authorized and property management records are updated on a timely basis. Criteria According to 2 CFR 200.313(d)(1), property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property, who holds title, the acquisition date, and cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. Per 2 CFR 200.313(d)(3) and (4), a control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of property and adequate maintenance procedures must be developed to keep the property in good condition. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, 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. Effective internal controls should include procedures to ensure that accurate property records are maintained and equipment items are properly tagged. Cause In discussing these conditions with University officials, they stated the decentralized nature of the equipment recordkeeping process can result in delayed reporting of asset disposals. Possible Asserted Effect Failure to maintain accurate property records may prohibit the University from properly safeguarding and maintaining equipment and may result in federal programs not receiving the appropriate share of proceeds from the disposals of equipment purchased with federal funds. Repeat Finding A similar finding was reported in the prior year audit as finding number 2022-002. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Recommendation We recommend the University review its procedures for updating property records to ensure they accurately reflect equipment information. Views of University Officials The University concurs with the finding and has begun to address these concerns. As noted in the finding, the University conducted a full federal equipment inventory in January 2024 and updated property records to ensure accuracy of federally funded equipment.
Finding 2023-002 – Inaccurate Property Management Records Federal Agency: U.S. Department of Agriculture (USDA) U.S. Department of Commerce (USDOC) U.S. Department of Defense (USDOD) U.S. Department of Education (USDE) U.S. Department of Energy (USDOE) U.S. Department of Health and Human Services (USDHHS) U.S. Department of Housing and Urban Development (USHUD) U.S. Department of Interior (USDOI) U.S. Department of Justice (USDOJ) U.S. Department of State (USDOS) U.S. Department of Transportation (USDOT) U.S. Director of National Intelligence (USDNI) U.S. Environmental Protection Agency (USEPA) National Aeronautics and Space Administration (NASA) National Endowment for the Humanities (NEH) National Science Foundation (NSF) U.S. Department of Veteran Affairs (USDVA) All Pass-Through Entities Program Name: Research and Development Cluster ALN # and Program Expenditures: Various ($508,850,558) Federal Award Numbers: Various – See schedule of award numbers Federal Award Year: Various – See schedule of award numbers Questioned Costs: None Compliance Requirement: Equipment Type of Finding: Noncompliance and material weakness Condition Found The University did not consistently follow its property management policies and procedures related to maintaining accurate property management records for equipment purchased with federal R&D Cluster program awards. The University conducts research at multiple locations throughout its campus where equipment purchased with federal awards is utilized and maintained. The University identifies all equipment in its property management records with individually assigned asset numbers and each individual asset record includes the specific location of the asset, the federal award general ledger account number which funded the purchase of the asset, and other required information. An asset tag with the assigned asset number is affixed to each asset in accordance with University policy. The University is required to safeguard equipment purchased with federal awards, maintain current property records, and to perform a physical inventory of equipment purchased with federal awards on a biennial basis. During our physical observation of 60 pieces of equipment (with a net book value (NBV) of $224,269) purchased with federal R&D Cluster awards, we noted eight items (with a NBV totaling $0) selected for physical observation were not able to be located for our testing. In response to the exceptions identified in our audit procedures, the University performed a physical inventory of all of its federally funded equipment in January 2024, which identified an additional 1,006 equipment items (with a NBV of $1,726,897) that could not be located, of which 839 were fully depreciated. University management believes these items were disposed of but not appropriately removed from the property records and federal equipment listing. As of June 30, 2023, the University’s federal equipment listing included 6,270 assets (with a NBV of $61,390,724) purchased with R&D Cluster program awards. We also noted the University’s controls for equipment dispositions are not operating at an appropriate level of precision to ensure equipment dispositions are properly authorized and property management records are updated on a timely basis. Criteria According to 2 CFR 200.313(d)(1), property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property, who holds title, the acquisition date, and cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. Per 2 CFR 200.313(d)(3) and (4), a control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of property and adequate maintenance procedures must be developed to keep the property in good condition. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, 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. Effective internal controls should include procedures to ensure that accurate property records are maintained and equipment items are properly tagged. Cause In discussing these conditions with University officials, they stated the decentralized nature of the equipment recordkeeping process can result in delayed reporting of asset disposals. Possible Asserted Effect Failure to maintain accurate property records may prohibit the University from properly safeguarding and maintaining equipment and may result in federal programs not receiving the appropriate share of proceeds from the disposals of equipment purchased with federal funds. Repeat Finding A similar finding was reported in the prior year audit as finding number 2022-002. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Recommendation We recommend the University review its procedures for updating property records to ensure they accurately reflect equipment information. Views of University Officials The University concurs with the finding and has begun to address these concerns. As noted in the finding, the University conducted a full federal equipment inventory in January 2024 and updated property records to ensure accuracy of federally funded equipment.
Finding 2023-002 – Inaccurate Property Management Records Federal Agency: U.S. Department of Agriculture (USDA) U.S. Department of Commerce (USDOC) U.S. Department of Defense (USDOD) U.S. Department of Education (USDE) U.S. Department of Energy (USDOE) U.S. Department of Health and Human Services (USDHHS) U.S. Department of Housing and Urban Development (USHUD) U.S. Department of Interior (USDOI) U.S. Department of Justice (USDOJ) U.S. Department of State (USDOS) U.S. Department of Transportation (USDOT) U.S. Director of National Intelligence (USDNI) U.S. Environmental Protection Agency (USEPA) National Aeronautics and Space Administration (NASA) National Endowment for the Humanities (NEH) National Science Foundation (NSF) U.S. Department of Veteran Affairs (USDVA) All Pass-Through Entities Program Name: Research and Development Cluster ALN # and Program Expenditures: Various ($508,850,558) Federal Award Numbers: Various – See schedule of award numbers Federal Award Year: Various – See schedule of award numbers Questioned Costs: None Compliance Requirement: Equipment Type of Finding: Noncompliance and material weakness Condition Found The University did not consistently follow its property management policies and procedures related to maintaining accurate property management records for equipment purchased with federal R&D Cluster program awards. The University conducts research at multiple locations throughout its campus where equipment purchased with federal awards is utilized and maintained. The University identifies all equipment in its property management records with individually assigned asset numbers and each individual asset record includes the specific location of the asset, the federal award general ledger account number which funded the purchase of the asset, and other required information. An asset tag with the assigned asset number is affixed to each asset in accordance with University policy. The University is required to safeguard equipment purchased with federal awards, maintain current property records, and to perform a physical inventory of equipment purchased with federal awards on a biennial basis. During our physical observation of 60 pieces of equipment (with a net book value (NBV) of $224,269) purchased with federal R&D Cluster awards, we noted eight items (with a NBV totaling $0) selected for physical observation were not able to be located for our testing. In response to the exceptions identified in our audit procedures, the University performed a physical inventory of all of its federally funded equipment in January 2024, which identified an additional 1,006 equipment items (with a NBV of $1,726,897) that could not be located, of which 839 were fully depreciated. University management believes these items were disposed of but not appropriately removed from the property records and federal equipment listing. As of June 30, 2023, the University’s federal equipment listing included 6,270 assets (with a NBV of $61,390,724) purchased with R&D Cluster program awards. We also noted the University’s controls for equipment dispositions are not operating at an appropriate level of precision to ensure equipment dispositions are properly authorized and property management records are updated on a timely basis. Criteria According to 2 CFR 200.313(d)(1), property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property, who holds title, the acquisition date, and cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. Per 2 CFR 200.313(d)(3) and (4), a control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of property and adequate maintenance procedures must be developed to keep the property in good condition. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, 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. Effective internal controls should include procedures to ensure that accurate property records are maintained and equipment items are properly tagged. Cause In discussing these conditions with University officials, they stated the decentralized nature of the equipment recordkeeping process can result in delayed reporting of asset disposals. Possible Asserted Effect Failure to maintain accurate property records may prohibit the University from properly safeguarding and maintaining equipment and may result in federal programs not receiving the appropriate share of proceeds from the disposals of equipment purchased with federal funds. Repeat Finding A similar finding was reported in the prior year audit as finding number 2022-002. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Recommendation We recommend the University review its procedures for updating property records to ensure they accurately reflect equipment information. Views of University Officials The University concurs with the finding and has begun to address these concerns. As noted in the finding, the University conducted a full federal equipment inventory in January 2024 and updated property records to ensure accuracy of federally funded equipment.
Finding 2023-002 – Inaccurate Property Management Records Federal Agency: U.S. Department of Agriculture (USDA) U.S. Department of Commerce (USDOC) U.S. Department of Defense (USDOD) U.S. Department of Education (USDE) U.S. Department of Energy (USDOE) U.S. Department of Health and Human Services (USDHHS) U.S. Department of Housing and Urban Development (USHUD) U.S. Department of Interior (USDOI) U.S. Department of Justice (USDOJ) U.S. Department of State (USDOS) U.S. Department of Transportation (USDOT) U.S. Director of National Intelligence (USDNI) U.S. Environmental Protection Agency (USEPA) National Aeronautics and Space Administration (NASA) National Endowment for the Humanities (NEH) National Science Foundation (NSF) U.S. Department of Veteran Affairs (USDVA) All Pass-Through Entities Program Name: Research and Development Cluster ALN # and Program Expenditures: Various ($508,850,558) Federal Award Numbers: Various – See schedule of award numbers Federal Award Year: Various – See schedule of award numbers Questioned Costs: None Compliance Requirement: Equipment Type of Finding: Noncompliance and material weakness Condition Found The University did not consistently follow its property management policies and procedures related to maintaining accurate property management records for equipment purchased with federal R&D Cluster program awards. The University conducts research at multiple locations throughout its campus where equipment purchased with federal awards is utilized and maintained. The University identifies all equipment in its property management records with individually assigned asset numbers and each individual asset record includes the specific location of the asset, the federal award general ledger account number which funded the purchase of the asset, and other required information. An asset tag with the assigned asset number is affixed to each asset in accordance with University policy. The University is required to safeguard equipment purchased with federal awards, maintain current property records, and to perform a physical inventory of equipment purchased with federal awards on a biennial basis. During our physical observation of 60 pieces of equipment (with a net book value (NBV) of $224,269) purchased with federal R&D Cluster awards, we noted eight items (with a NBV totaling $0) selected for physical observation were not able to be located for our testing. In response to the exceptions identified in our audit procedures, the University performed a physical inventory of all of its federally funded equipment in January 2024, which identified an additional 1,006 equipment items (with a NBV of $1,726,897) that could not be located, of which 839 were fully depreciated. University management believes these items were disposed of but not appropriately removed from the property records and federal equipment listing. As of June 30, 2023, the University’s federal equipment listing included 6,270 assets (with a NBV of $61,390,724) purchased with R&D Cluster program awards. We also noted the University’s controls for equipment dispositions are not operating at an appropriate level of precision to ensure equipment dispositions are properly authorized and property management records are updated on a timely basis. Criteria According to 2 CFR 200.313(d)(1), property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property, who holds title, the acquisition date, and cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. Per 2 CFR 200.313(d)(3) and (4), a control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of property and adequate maintenance procedures must be developed to keep the property in good condition. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, 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. Effective internal controls should include procedures to ensure that accurate property records are maintained and equipment items are properly tagged. Cause In discussing these conditions with University officials, they stated the decentralized nature of the equipment recordkeeping process can result in delayed reporting of asset disposals. Possible Asserted Effect Failure to maintain accurate property records may prohibit the University from properly safeguarding and maintaining equipment and may result in federal programs not receiving the appropriate share of proceeds from the disposals of equipment purchased with federal funds. Repeat Finding A similar finding was reported in the prior year audit as finding number 2022-002. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Recommendation We recommend the University review its procedures for updating property records to ensure they accurately reflect equipment information. Views of University Officials The University concurs with the finding and has begun to address these concerns. As noted in the finding, the University conducted a full federal equipment inventory in January 2024 and updated property records to ensure accuracy of federally funded equipment.
Finding 2023-002 – Inaccurate Property Management Records Federal Agency: U.S. Department of Agriculture (USDA) U.S. Department of Commerce (USDOC) U.S. Department of Defense (USDOD) U.S. Department of Education (USDE) U.S. Department of Energy (USDOE) U.S. Department of Health and Human Services (USDHHS) U.S. Department of Housing and Urban Development (USHUD) U.S. Department of Interior (USDOI) U.S. Department of Justice (USDOJ) U.S. Department of State (USDOS) U.S. Department of Transportation (USDOT) U.S. Director of National Intelligence (USDNI) U.S. Environmental Protection Agency (USEPA) National Aeronautics and Space Administration (NASA) National Endowment for the Humanities (NEH) National Science Foundation (NSF) U.S. Department of Veteran Affairs (USDVA) All Pass-Through Entities Program Name: Research and Development Cluster ALN # and Program Expenditures: Various ($508,850,558) Federal Award Numbers: Various – See schedule of award numbers Federal Award Year: Various – See schedule of award numbers Questioned Costs: None Compliance Requirement: Equipment Type of Finding: Noncompliance and material weakness Condition Found The University did not consistently follow its property management policies and procedures related to maintaining accurate property management records for equipment purchased with federal R&D Cluster program awards. The University conducts research at multiple locations throughout its campus where equipment purchased with federal awards is utilized and maintained. The University identifies all equipment in its property management records with individually assigned asset numbers and each individual asset record includes the specific location of the asset, the federal award general ledger account number which funded the purchase of the asset, and other required information. An asset tag with the assigned asset number is affixed to each asset in accordance with University policy. The University is required to safeguard equipment purchased with federal awards, maintain current property records, and to perform a physical inventory of equipment purchased with federal awards on a biennial basis. During our physical observation of 60 pieces of equipment (with a net book value (NBV) of $224,269) purchased with federal R&D Cluster awards, we noted eight items (with a NBV totaling $0) selected for physical observation were not able to be located for our testing. In response to the exceptions identified in our audit procedures, the University performed a physical inventory of all of its federally funded equipment in January 2024, which identified an additional 1,006 equipment items (with a NBV of $1,726,897) that could not be located, of which 839 were fully depreciated. University management believes these items were disposed of but not appropriately removed from the property records and federal equipment listing. As of June 30, 2023, the University’s federal equipment listing included 6,270 assets (with a NBV of $61,390,724) purchased with R&D Cluster program awards. We also noted the University’s controls for equipment dispositions are not operating at an appropriate level of precision to ensure equipment dispositions are properly authorized and property management records are updated on a timely basis. Criteria According to 2 CFR 200.313(d)(1), property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property, who holds title, the acquisition date, and cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. Per 2 CFR 200.313(d)(3) and (4), a control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of property and adequate maintenance procedures must be developed to keep the property in good condition. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, 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. Effective internal controls should include procedures to ensure that accurate property records are maintained and equipment items are properly tagged. Cause In discussing these conditions with University officials, they stated the decentralized nature of the equipment recordkeeping process can result in delayed reporting of asset disposals. Possible Asserted Effect Failure to maintain accurate property records may prohibit the University from properly safeguarding and maintaining equipment and may result in federal programs not receiving the appropriate share of proceeds from the disposals of equipment purchased with federal funds. Repeat Finding A similar finding was reported in the prior year audit as finding number 2022-002. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Recommendation We recommend the University review its procedures for updating property records to ensure they accurately reflect equipment information. Views of University Officials The University concurs with the finding and has begun to address these concerns. As noted in the finding, the University conducted a full federal equipment inventory in January 2024 and updated property records to ensure accuracy of federally funded equipment.
Finding 2023-004 – Untimely and Inaccurate Reporting of Pell and FDL Data Federal Agency: U.S. Department of Education (USDE) Program Name: Student Financial Assistance Cluster CFDA # and Program Expenditures: 84.268 ($91,771,529); 84.063 ($5,969,524) Federal Award Numbers: P268K231389; P063Q221389; P063P221389; P063Q201389 Federal Award Year: July 1, 2022 to June 30, 2023 Questioned Costs: None Compliance Requirement: Reporting Type of Finding: Noncompliance and material weakness Condition Found The University did not accurately report Federal Direct Loan (FDL) program data to the Common Origination and Disbursement (COD) system within required timeframes. During our testing of 36 students under the FDL program totaling $409,645, we noted the following: - The academic start date reported to COD for FDL disbursements (totaling $162,518) to 10 students was not accurate. Specifically, the date reported was 144 days earlier than the actual academic start date. Upon further review by the University, an additional 1,919 disbursements totaling $23,202,079 were reported with the incorrect academic start date. The University disbursed Pell grants and FDL loans to 3,459 students during the year ended June 30, 2023. - A FDL disbursement sampled (totaling $16,602) for one student was not reported to the COD within 15 days as required. The delay in reporting the FDL disbursement was 16 days. Upon further review by the University, an additional 77 disbursements (totaling $905,149) to 38 students were reported to the COD ranging from 2 to 114 days late. The University disbursed 14,066 Pell grants and FDL loans to 3,459 students subject to COD reporting during the year ended June 30, 2023. Further, we noted the University did not have adequate review or monitoring controls in place to ensure that Pell and FDL disbursement data was accurately reported to the COD within required timeframes. Criteria According to Federal Register Vol. 85 No. 135, Institutions must report student disbursement data, including the academic start date of the term, within 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. Additionally, according to the Student Financial Assistance (SFA) Handbook GEN-13-13, institutions must accurately report academic start dates for all types of FDL disbursements to the COD system. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award is compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include maintaining adequate controls to ensure Pell and FDL data is accurately and timely reported to the COD. Cause In discussing these conditions with University officials, they stated a system issue and training issue contributed to the finding. Possible Asserted Effect Failure to report Pell and FDL data to the COD accurately and within required timeframes results in noncompliance with program requirements and inhibits the ability of the USDE to monitor Pell and FDL program requirements impacted by this data. Repeat Finding A similar finding was not reported in prior years. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Recommendation We recommend the University review its internal control procedures and implement additional management review procedures to ensure data is accurately reported to the COD within required timeframes. Views of University Officials The University concurs with the findings and have begun work on the unmitigated issues.
Finding 2023-003 – Failure to Notify Recipients of Federal Direct Loan Disbursement Federal Agency: U.S. Department of Education (USDE) Program Name: Student Financial Assistance Cluster (SFA) CFDA # and Program Expenditures: 84.268 ($91,771,529) Federal Award Numbers: P268K231389 Federal Award Year: July 1, 2022 to June 30, 2023 Questioned Costs: None Compliance Requirement: Disbursements to or on Behalf of Students Type of Finding: Noncompliance and material weakness Condition Found The University did not notify parents or students of the anticipated date and amount of certain Federal Direct Loan (FDL) disbursements under the SFA program. During our testing of 36 student disbursements under the Federal Direct Loan (FDL) program totaling $409,645, we noted the University did not notify one student (with a loan disbursement of $6,864) of the anticipated date and amount of the disbursement of loan proceeds. Upon further review by the University, an additional 312 students who received disbursements of loan proceeds (totaling $3,706,642) on the same date as the exception discussed in the previous sentence were not notified of the anticipated date and amount of the disbursement of the loan proceeds within required timeframes. The University noted notifications for disbursements for the Booth School of Business were not sent for loans disbursed on September 16, 2022 due to a system error. The University disbursed 10,732 FDL loans (totaling $91,798,461) to 2,408 students during the year ended June 30, 2023. Further, we noted management review controls implemented by the University were not designed at a level of precision to ensure the University sent required FDL notifications to students within required timeframes. Criteria According to 34 CFR 668.165(a)(2), if an institution credits a student ledger account with Direct Loan, Federal Perkins Loan or TEACH Grant program funds, the institution must notify the parent or student of the anticipated date and amount of disbursement. According to 34 CFR 668.165(a)(3) an institution must make this this notification to the student or parent no earlier than 30 days before, and no later than 30 days after, crediting the student’s account at the institution with Direct Loan or TEACH Grants. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, 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. Effective internal controls should include procedures to ensure that required notifications are prepared and sent to students (or parents) within required timeframes. Cause In discussing these conditions with University officials, they stated a system issue failed to send the communications on September 16, 2022. Possible Asserted Effect Failure to notify a parent or student of the anticipated date and amount of disbursement results in noncompliance with FDL program requirements. Repeat Finding A similar finding was not reported in prior years. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Recommendation We recommend the University review its system internal control to ensure notifications of disbursements are made as required by FDL program regulations. Views of University Officials The University concurs with the findings and have begun work on the unmitigated issues.
Finding 2023-004 – Untimely and Inaccurate Reporting of Pell and FDL Data Federal Agency: U.S. Department of Education (USDE) Program Name: Student Financial Assistance Cluster CFDA # and Program Expenditures: 84.268 ($91,771,529); 84.063 ($5,969,524) Federal Award Numbers: P268K231389; P063Q221389; P063P221389; P063Q201389 Federal Award Year: July 1, 2022 to June 30, 2023 Questioned Costs: None Compliance Requirement: Reporting Type of Finding: Noncompliance and material weakness Condition Found The University did not accurately report Federal Direct Loan (FDL) program data to the Common Origination and Disbursement (COD) system within required timeframes. During our testing of 36 students under the FDL program totaling $409,645, we noted the following: - The academic start date reported to COD for FDL disbursements (totaling $162,518) to 10 students was not accurate. Specifically, the date reported was 144 days earlier than the actual academic start date. Upon further review by the University, an additional 1,919 disbursements totaling $23,202,079 were reported with the incorrect academic start date. The University disbursed Pell grants and FDL loans to 3,459 students during the year ended June 30, 2023. - A FDL disbursement sampled (totaling $16,602) for one student was not reported to the COD within 15 days as required. The delay in reporting the FDL disbursement was 16 days. Upon further review by the University, an additional 77 disbursements (totaling $905,149) to 38 students were reported to the COD ranging from 2 to 114 days late. The University disbursed 14,066 Pell grants and FDL loans to 3,459 students subject to COD reporting during the year ended June 30, 2023. Further, we noted the University did not have adequate review or monitoring controls in place to ensure that Pell and FDL disbursement data was accurately reported to the COD within required timeframes. Criteria According to Federal Register Vol. 85 No. 135, Institutions must report student disbursement data, including the academic start date of the term, within 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. Additionally, according to the Student Financial Assistance (SFA) Handbook GEN-13-13, institutions must accurately report academic start dates for all types of FDL disbursements to the COD system. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award is compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include maintaining adequate controls to ensure Pell and FDL data is accurately and timely reported to the COD. Cause In discussing these conditions with University officials, they stated a system issue and training issue contributed to the finding. Possible Asserted Effect Failure to report Pell and FDL data to the COD accurately and within required timeframes results in noncompliance with program requirements and inhibits the ability of the USDE to monitor Pell and FDL program requirements impacted by this data. Repeat Finding A similar finding was not reported in prior years. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Recommendation We recommend the University review its internal control procedures and implement additional management review procedures to ensure data is accurately reported to the COD within required timeframes. Views of University Officials The University concurs with the findings and have begun work on the unmitigated issues.
Finding 2023-005 – Inaccurate Reporting of Higher Education Emergency Relief Fund (HEERF) Quarterly Data Federal Agency: U.S. Department of Education (USDE) Program Name: Higher Education Emergency Relief Fund CFDA # and Program Expenditures: 84.425 ($1,816,217) Federal Award Numbers: P425E204996; P425E204996 – 20B; P425F204056; P425F204056 – 20B Federal Award Year: July 1, 2022 to June 30, 2023 Questioned Costs: None Compliance Requirement: Reporting Type of Finding: Material Weakness and Noncompliance Condition Found The University did not report HEERF expenditure data in the appropriate period to the United States Department of Education (USDE) through the HEERF Quarterly Report. During our testing of two HEERF Quarterly Reports, we noted the University did not appropriately report the institutional expenditures for the period ending September 30, 2022. Specifically, we noted that the following differences: See the Schedule of Findings and Questioned Costs for chart/table. Upon further review, we noted these errors related to expenditures incurred in a prior quarter and that the report from the quarter to which the expenditures pertained should have been revised. The University corrected the impacted reports after these errors were identified by our audit procedures. Additionally, we noted the University did not have adequate review or monitoring controls in place to ensure that the quarterly expenditure data was accurately reported within the appropriate quarterly report. Criteria According to the Office of Management and Budget (OMB) Control Number 1840-0849, Institutions must report quarterly HEERF budget and expenditure data to the USDE. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award is compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include maintaining adequate controls to ensure HEERF data is accurately reported to the USDE. Cause In discussing these conditions with University officials, they stated the preparer and reviewer of the HEERF Quarterly Report did not understand the requirements for reporting corrections in the quarterly report in which the expenditures occurred. Possible Asserted Effect Failure to report accurate HEERF data results in noncompliance with program requirements and inhibits the ability of the USDE to monitor HEERF expenditures. Repeat Finding A similar finding was not reported in prior years. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Recommendation We recommend the University review its internal control procedures and implement additional management review procedures to ensure data is accurately reported to the USDE in the appropriate quarterly report. Views of University Officials The University concurs with the finding.
Finding 2023-005 – Inaccurate Reporting of Higher Education Emergency Relief Fund (HEERF) Quarterly Data Federal Agency: U.S. Department of Education (USDE) Program Name: Higher Education Emergency Relief Fund CFDA # and Program Expenditures: 84.425 ($1,816,217) Federal Award Numbers: P425E204996; P425E204996 – 20B; P425F204056; P425F204056 – 20B Federal Award Year: July 1, 2022 to June 30, 2023 Questioned Costs: None Compliance Requirement: Reporting Type of Finding: Material Weakness and Noncompliance Condition Found The University did not report HEERF expenditure data in the appropriate period to the United States Department of Education (USDE) through the HEERF Quarterly Report. During our testing of two HEERF Quarterly Reports, we noted the University did not appropriately report the institutional expenditures for the period ending September 30, 2022. Specifically, we noted that the following differences: See the Schedule of Findings and Questioned Costs for chart/table. Upon further review, we noted these errors related to expenditures incurred in a prior quarter and that the report from the quarter to which the expenditures pertained should have been revised. The University corrected the impacted reports after these errors were identified by our audit procedures. Additionally, we noted the University did not have adequate review or monitoring controls in place to ensure that the quarterly expenditure data was accurately reported within the appropriate quarterly report. Criteria According to the Office of Management and Budget (OMB) Control Number 1840-0849, Institutions must report quarterly HEERF budget and expenditure data to the USDE. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award is compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include maintaining adequate controls to ensure HEERF data is accurately reported to the USDE. Cause In discussing these conditions with University officials, they stated the preparer and reviewer of the HEERF Quarterly Report did not understand the requirements for reporting corrections in the quarterly report in which the expenditures occurred. Possible Asserted Effect Failure to report accurate HEERF data results in noncompliance with program requirements and inhibits the ability of the USDE to monitor HEERF expenditures. Repeat Finding A similar finding was not reported in prior years. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Recommendation We recommend the University review its internal control procedures and implement additional management review procedures to ensure data is accurately reported to the USDE in the appropriate quarterly report. Views of University Officials The University concurs with the finding.
FINDING 2023-003 Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children, Fresh Fruit and Vegetable Program Assistance Listings Numbers: 10.553, 10.555, 10.559, 10.582 Federal Award Numbers and Years (or Other Identifying Numbers): FY 21-22, FY 22-23 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Eligibility, Procurement and Suspension and Debarment Audit Finding: Material Weakness Repeat Finding This is a repeat finding from the prior audit regarding Internal Controls over Procurement and Suspension and Debarment. The prior audit finding number was 2021-005. Condition and Context The School Corporation had not properly designed or implemented an effective system of internal controls, which would include segregation of duties, that would likely be effective in preventing, or detecting and correcting, material noncompliance. Eligibility Any child enrolled in a participating school or summer camp, who meets the applicable program's definition of "child," may receive meals under applicable programs. A child belonging to households meeting nationwide income eligibility requirements may receive meals at no charge or at a reduced price. Children that have been determined ineligible for free or reduced-price meals pay the full price for their meals. A child's eligibility for free and reducedpriced meals under a Child Nutrition Cluster program may be established by the submission of an annual application or statement which furnished such information as family income and family size. The School Corporation determines eligibility by comparing the data reported by the child's household to published income eligibility guidelines. Annual eligibility determinations may also be based on the child's household receiving benefits under SNAP, FDPIR, the Head Start Program, or, under most circumstances, the TANF program. A household may furnish documentation if its participation in one of those programs, or the School Corporation may obtain the information directly from the State or local agency that administers those programs. Certain foster, runaway, homeless, and migrant children are categorically eligible for free school lunches and breakfasts. Direct certified households do not need to complete an application. The School Corporation utilized a software vendor to determine eligibility based on free and reduced applications submitted online by parents. The income guidelines were updated in the software by one employee without an oversight or review process in place to ensure accuracy. Additionally, one employee uploaded the Direct Certification reports from the state into the software system without a documented oversight or review process in place to ensure directly certified students were properly processed. Suspension and Debarment Prior to entering into subawards and covered transactions with federal award funds, recipients are required to verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded. "Covered transactions" include, but are not limited to, contracts for goods and services awarded under a nonprocurement transaction (i.e., grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the SAMs exclusions, collecting a certification from that vendor, or adding a clause or condition to the covered transaction with that vendor. The School Food Service Department and Business office worked together to ensure vendors were properly procured; however, this process did not include ensuring vendors with whom it plans to enter into a covered transaction with are not suspended, debarred, or otherwise excluded from participation in federal programs. While the Food Service Department did obtain a signed certification, there was no oversight or review process in place to ensure vendors were not suspended, debarred, or otherwise excluded from participation in federal programs prior to entering into covered transactions. The lack of internal controls over eligibility was isolated to the 2022-2023 school year. The lack of internal controls over suspension and debarment was systemic 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). . . ." Cause A proper system of internal controls was not designed by management of the School Corporation, which would include segregation of key functions. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper design or implementation of the components of a system of internal controls, including policies and procedures that provide segregation of duties and additional oversight as needed, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation design and implement a proper system of internal controls, including policies and procedures that would provide segregation of duties to ensure appropriate reviews, approvals, and oversight are taking place. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-003 Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children, Fresh Fruit and Vegetable Program Assistance Listings Numbers: 10.553, 10.555, 10.559, 10.582 Federal Award Numbers and Years (or Other Identifying Numbers): FY 21-22, FY 22-23 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Eligibility, Procurement and Suspension and Debarment Audit Finding: Material Weakness Repeat Finding This is a repeat finding from the prior audit regarding Internal Controls over Procurement and Suspension and Debarment. The prior audit finding number was 2021-005. Condition and Context The School Corporation had not properly designed or implemented an effective system of internal controls, which would include segregation of duties, that would likely be effective in preventing, or detecting and correcting, material noncompliance. Eligibility Any child enrolled in a participating school or summer camp, who meets the applicable program's definition of "child," may receive meals under applicable programs. A child belonging to households meeting nationwide income eligibility requirements may receive meals at no charge or at a reduced price. Children that have been determined ineligible for free or reduced-price meals pay the full price for their meals. A child's eligibility for free and reducedpriced meals under a Child Nutrition Cluster program may be established by the submission of an annual application or statement which furnished such information as family income and family size. The School Corporation determines eligibility by comparing the data reported by the child's household to published income eligibility guidelines. Annual eligibility determinations may also be based on the child's household receiving benefits under SNAP, FDPIR, the Head Start Program, or, under most circumstances, the TANF program. A household may furnish documentation if its participation in one of those programs, or the School Corporation may obtain the information directly from the State or local agency that administers those programs. Certain foster, runaway, homeless, and migrant children are categorically eligible for free school lunches and breakfasts. Direct certified households do not need to complete an application. The School Corporation utilized a software vendor to determine eligibility based on free and reduced applications submitted online by parents. The income guidelines were updated in the software by one employee without an oversight or review process in place to ensure accuracy. Additionally, one employee uploaded the Direct Certification reports from the state into the software system without a documented oversight or review process in place to ensure directly certified students were properly processed. Suspension and Debarment Prior to entering into subawards and covered transactions with federal award funds, recipients are required to verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded. "Covered transactions" include, but are not limited to, contracts for goods and services awarded under a nonprocurement transaction (i.e., grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the SAMs exclusions, collecting a certification from that vendor, or adding a clause or condition to the covered transaction with that vendor. The School Food Service Department and Business office worked together to ensure vendors were properly procured; however, this process did not include ensuring vendors with whom it plans to enter into a covered transaction with are not suspended, debarred, or otherwise excluded from participation in federal programs. While the Food Service Department did obtain a signed certification, there was no oversight or review process in place to ensure vendors were not suspended, debarred, or otherwise excluded from participation in federal programs prior to entering into covered transactions. The lack of internal controls over eligibility was isolated to the 2022-2023 school year. The lack of internal controls over suspension and debarment was systemic 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). . . ." Cause A proper system of internal controls was not designed by management of the School Corporation, which would include segregation of key functions. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper design or implementation of the components of a system of internal controls, including policies and procedures that provide segregation of duties and additional oversight as needed, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation design and implement a proper system of internal controls, including policies and procedures that would provide segregation of duties to ensure appropriate reviews, approvals, and oversight are taking place. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-003 Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children, Fresh Fruit and Vegetable Program Assistance Listings Numbers: 10.553, 10.555, 10.559, 10.582 Federal Award Numbers and Years (or Other Identifying Numbers): FY 21-22, FY 22-23 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Eligibility, Procurement and Suspension and Debarment Audit Finding: Material Weakness Repeat Finding This is a repeat finding from the prior audit regarding Internal Controls over Procurement and Suspension and Debarment. The prior audit finding number was 2021-005. Condition and Context The School Corporation had not properly designed or implemented an effective system of internal controls, which would include segregation of duties, that would likely be effective in preventing, or detecting and correcting, material noncompliance. Eligibility Any child enrolled in a participating school or summer camp, who meets the applicable program's definition of "child," may receive meals under applicable programs. A child belonging to households meeting nationwide income eligibility requirements may receive meals at no charge or at a reduced price. Children that have been determined ineligible for free or reduced-price meals pay the full price for their meals. A child's eligibility for free and reducedpriced meals under a Child Nutrition Cluster program may be established by the submission of an annual application or statement which furnished such information as family income and family size. The School Corporation determines eligibility by comparing the data reported by the child's household to published income eligibility guidelines. Annual eligibility determinations may also be based on the child's household receiving benefits under SNAP, FDPIR, the Head Start Program, or, under most circumstances, the TANF program. A household may furnish documentation if its participation in one of those programs, or the School Corporation may obtain the information directly from the State or local agency that administers those programs. Certain foster, runaway, homeless, and migrant children are categorically eligible for free school lunches and breakfasts. Direct certified households do not need to complete an application. The School Corporation utilized a software vendor to determine eligibility based on free and reduced applications submitted online by parents. The income guidelines were updated in the software by one employee without an oversight or review process in place to ensure accuracy. Additionally, one employee uploaded the Direct Certification reports from the state into the software system without a documented oversight or review process in place to ensure directly certified students were properly processed. Suspension and Debarment Prior to entering into subawards and covered transactions with federal award funds, recipients are required to verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded. "Covered transactions" include, but are not limited to, contracts for goods and services awarded under a nonprocurement transaction (i.e., grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the SAMs exclusions, collecting a certification from that vendor, or adding a clause or condition to the covered transaction with that vendor. The School Food Service Department and Business office worked together to ensure vendors were properly procured; however, this process did not include ensuring vendors with whom it plans to enter into a covered transaction with are not suspended, debarred, or otherwise excluded from participation in federal programs. While the Food Service Department did obtain a signed certification, there was no oversight or review process in place to ensure vendors were not suspended, debarred, or otherwise excluded from participation in federal programs prior to entering into covered transactions. The lack of internal controls over eligibility was isolated to the 2022-2023 school year. The lack of internal controls over suspension and debarment was systemic 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). . . ." Cause A proper system of internal controls was not designed by management of the School Corporation, which would include segregation of key functions. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper design or implementation of the components of a system of internal controls, including policies and procedures that provide segregation of duties and additional oversight as needed, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation design and implement a proper system of internal controls, including policies and procedures that would provide segregation of duties to ensure appropriate reviews, approvals, and oversight are taking place. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-003 Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children, Fresh Fruit and Vegetable Program Assistance Listings Numbers: 10.553, 10.555, 10.559, 10.582 Federal Award Numbers and Years (or Other Identifying Numbers): FY 21-22, FY 22-23 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Eligibility, Procurement and Suspension and Debarment Audit Finding: Material Weakness Repeat Finding This is a repeat finding from the prior audit regarding Internal Controls over Procurement and Suspension and Debarment. The prior audit finding number was 2021-005. Condition and Context The School Corporation had not properly designed or implemented an effective system of internal controls, which would include segregation of duties, that would likely be effective in preventing, or detecting and correcting, material noncompliance. Eligibility Any child enrolled in a participating school or summer camp, who meets the applicable program's definition of "child," may receive meals under applicable programs. A child belonging to households meeting nationwide income eligibility requirements may receive meals at no charge or at a reduced price. Children that have been determined ineligible for free or reduced-price meals pay the full price for their meals. A child's eligibility for free and reducedpriced meals under a Child Nutrition Cluster program may be established by the submission of an annual application or statement which furnished such information as family income and family size. The School Corporation determines eligibility by comparing the data reported by the child's household to published income eligibility guidelines. Annual eligibility determinations may also be based on the child's household receiving benefits under SNAP, FDPIR, the Head Start Program, or, under most circumstances, the TANF program. A household may furnish documentation if its participation in one of those programs, or the School Corporation may obtain the information directly from the State or local agency that administers those programs. Certain foster, runaway, homeless, and migrant children are categorically eligible for free school lunches and breakfasts. Direct certified households do not need to complete an application. The School Corporation utilized a software vendor to determine eligibility based on free and reduced applications submitted online by parents. The income guidelines were updated in the software by one employee without an oversight or review process in place to ensure accuracy. Additionally, one employee uploaded the Direct Certification reports from the state into the software system without a documented oversight or review process in place to ensure directly certified students were properly processed. Suspension and Debarment Prior to entering into subawards and covered transactions with federal award funds, recipients are required to verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded. "Covered transactions" include, but are not limited to, contracts for goods and services awarded under a nonprocurement transaction (i.e., grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the SAMs exclusions, collecting a certification from that vendor, or adding a clause or condition to the covered transaction with that vendor. The School Food Service Department and Business office worked together to ensure vendors were properly procured; however, this process did not include ensuring vendors with whom it plans to enter into a covered transaction with are not suspended, debarred, or otherwise excluded from participation in federal programs. While the Food Service Department did obtain a signed certification, there was no oversight or review process in place to ensure vendors were not suspended, debarred, or otherwise excluded from participation in federal programs prior to entering into covered transactions. The lack of internal controls over eligibility was isolated to the 2022-2023 school year. The lack of internal controls over suspension and debarment was systemic 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). . . ." Cause A proper system of internal controls was not designed by management of the School Corporation, which would include segregation of key functions. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper design or implementation of the components of a system of internal controls, including policies and procedures that provide segregation of duties and additional oversight as needed, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation design and implement a proper system of internal controls, including policies and procedures that would provide segregation of duties to ensure appropriate reviews, approvals, and oversight are taking place. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-003 Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children, Fresh Fruit and Vegetable Program Assistance Listings Numbers: 10.553, 10.555, 10.559, 10.582 Federal Award Numbers and Years (or Other Identifying Numbers): FY 21-22, FY 22-23 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Eligibility, Procurement and Suspension and Debarment Audit Finding: Material Weakness Repeat Finding This is a repeat finding from the prior audit regarding Internal Controls over Procurement and Suspension and Debarment. The prior audit finding number was 2021-005. Condition and Context The School Corporation had not properly designed or implemented an effective system of internal controls, which would include segregation of duties, that would likely be effective in preventing, or detecting and correcting, material noncompliance. Eligibility Any child enrolled in a participating school or summer camp, who meets the applicable program's definition of "child," may receive meals under applicable programs. A child belonging to households meeting nationwide income eligibility requirements may receive meals at no charge or at a reduced price. Children that have been determined ineligible for free or reduced-price meals pay the full price for their meals. A child's eligibility for free and reducedpriced meals under a Child Nutrition Cluster program may be established by the submission of an annual application or statement which furnished such information as family income and family size. The School Corporation determines eligibility by comparing the data reported by the child's household to published income eligibility guidelines. Annual eligibility determinations may also be based on the child's household receiving benefits under SNAP, FDPIR, the Head Start Program, or, under most circumstances, the TANF program. A household may furnish documentation if its participation in one of those programs, or the School Corporation may obtain the information directly from the State or local agency that administers those programs. Certain foster, runaway, homeless, and migrant children are categorically eligible for free school lunches and breakfasts. Direct certified households do not need to complete an application. The School Corporation utilized a software vendor to determine eligibility based on free and reduced applications submitted online by parents. The income guidelines were updated in the software by one employee without an oversight or review process in place to ensure accuracy. Additionally, one employee uploaded the Direct Certification reports from the state into the software system without a documented oversight or review process in place to ensure directly certified students were properly processed. Suspension and Debarment Prior to entering into subawards and covered transactions with federal award funds, recipients are required to verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded. "Covered transactions" include, but are not limited to, contracts for goods and services awarded under a nonprocurement transaction (i.e., grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the SAMs exclusions, collecting a certification from that vendor, or adding a clause or condition to the covered transaction with that vendor. The School Food Service Department and Business office worked together to ensure vendors were properly procured; however, this process did not include ensuring vendors with whom it plans to enter into a covered transaction with are not suspended, debarred, or otherwise excluded from participation in federal programs. While the Food Service Department did obtain a signed certification, there was no oversight or review process in place to ensure vendors were not suspended, debarred, or otherwise excluded from participation in federal programs prior to entering into covered transactions. The lack of internal controls over eligibility was isolated to the 2022-2023 school year. The lack of internal controls over suspension and debarment was systemic 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). . . ." Cause A proper system of internal controls was not designed by management of the School Corporation, which would include segregation of key functions. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper design or implementation of the components of a system of internal controls, including policies and procedures that provide segregation of duties and additional oversight as needed, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation design and implement a proper system of internal controls, including policies and procedures that would provide segregation of duties to ensure appropriate reviews, approvals, and oversight are taking place. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-003 Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children, Fresh Fruit and Vegetable Program Assistance Listings Numbers: 10.553, 10.555, 10.559, 10.582 Federal Award Numbers and Years (or Other Identifying Numbers): FY 21-22, FY 22-23 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Eligibility, Procurement and Suspension and Debarment Audit Finding: Material Weakness Repeat Finding This is a repeat finding from the prior audit regarding Internal Controls over Procurement and Suspension and Debarment. The prior audit finding number was 2021-005. Condition and Context The School Corporation had not properly designed or implemented an effective system of internal controls, which would include segregation of duties, that would likely be effective in preventing, or detecting and correcting, material noncompliance. Eligibility Any child enrolled in a participating school or summer camp, who meets the applicable program's definition of "child," may receive meals under applicable programs. A child belonging to households meeting nationwide income eligibility requirements may receive meals at no charge or at a reduced price. Children that have been determined ineligible for free or reduced-price meals pay the full price for their meals. A child's eligibility for free and reducedpriced meals under a Child Nutrition Cluster program may be established by the submission of an annual application or statement which furnished such information as family income and family size. The School Corporation determines eligibility by comparing the data reported by the child's household to published income eligibility guidelines. Annual eligibility determinations may also be based on the child's household receiving benefits under SNAP, FDPIR, the Head Start Program, or, under most circumstances, the TANF program. A household may furnish documentation if its participation in one of those programs, or the School Corporation may obtain the information directly from the State or local agency that administers those programs. Certain foster, runaway, homeless, and migrant children are categorically eligible for free school lunches and breakfasts. Direct certified households do not need to complete an application. The School Corporation utilized a software vendor to determine eligibility based on free and reduced applications submitted online by parents. The income guidelines were updated in the software by one employee without an oversight or review process in place to ensure accuracy. Additionally, one employee uploaded the Direct Certification reports from the state into the software system without a documented oversight or review process in place to ensure directly certified students were properly processed. Suspension and Debarment Prior to entering into subawards and covered transactions with federal award funds, recipients are required to verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded. "Covered transactions" include, but are not limited to, contracts for goods and services awarded under a nonprocurement transaction (i.e., grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the SAMs exclusions, collecting a certification from that vendor, or adding a clause or condition to the covered transaction with that vendor. The School Food Service Department and Business office worked together to ensure vendors were properly procured; however, this process did not include ensuring vendors with whom it plans to enter into a covered transaction with are not suspended, debarred, or otherwise excluded from participation in federal programs. While the Food Service Department did obtain a signed certification, there was no oversight or review process in place to ensure vendors were not suspended, debarred, or otherwise excluded from participation in federal programs prior to entering into covered transactions. The lack of internal controls over eligibility was isolated to the 2022-2023 school year. The lack of internal controls over suspension and debarment was systemic 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). . . ." Cause A proper system of internal controls was not designed by management of the School Corporation, which would include segregation of key functions. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper design or implementation of the components of a system of internal controls, including policies and procedures that provide segregation of duties and additional oversight as needed, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation design and implement a proper system of internal controls, including policies and procedures that would provide segregation of duties to ensure appropriate reviews, approvals, and oversight are taking place. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-003 Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children, Fresh Fruit and Vegetable Program Assistance Listings Numbers: 10.553, 10.555, 10.559, 10.582 Federal Award Numbers and Years (or Other Identifying Numbers): FY 21-22, FY 22-23 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Eligibility, Procurement and Suspension and Debarment Audit Finding: Material Weakness Repeat Finding This is a repeat finding from the prior audit regarding Internal Controls over Procurement and Suspension and Debarment. The prior audit finding number was 2021-005. Condition and Context The School Corporation had not properly designed or implemented an effective system of internal controls, which would include segregation of duties, that would likely be effective in preventing, or detecting and correcting, material noncompliance. Eligibility Any child enrolled in a participating school or summer camp, who meets the applicable program's definition of "child," may receive meals under applicable programs. A child belonging to households meeting nationwide income eligibility requirements may receive meals at no charge or at a reduced price. Children that have been determined ineligible for free or reduced-price meals pay the full price for their meals. A child's eligibility for free and reducedpriced meals under a Child Nutrition Cluster program may be established by the submission of an annual application or statement which furnished such information as family income and family size. The School Corporation determines eligibility by comparing the data reported by the child's household to published income eligibility guidelines. Annual eligibility determinations may also be based on the child's household receiving benefits under SNAP, FDPIR, the Head Start Program, or, under most circumstances, the TANF program. A household may furnish documentation if its participation in one of those programs, or the School Corporation may obtain the information directly from the State or local agency that administers those programs. Certain foster, runaway, homeless, and migrant children are categorically eligible for free school lunches and breakfasts. Direct certified households do not need to complete an application. The School Corporation utilized a software vendor to determine eligibility based on free and reduced applications submitted online by parents. The income guidelines were updated in the software by one employee without an oversight or review process in place to ensure accuracy. Additionally, one employee uploaded the Direct Certification reports from the state into the software system without a documented oversight or review process in place to ensure directly certified students were properly processed. Suspension and Debarment Prior to entering into subawards and covered transactions with federal award funds, recipients are required to verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded. "Covered transactions" include, but are not limited to, contracts for goods and services awarded under a nonprocurement transaction (i.e., grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the SAMs exclusions, collecting a certification from that vendor, or adding a clause or condition to the covered transaction with that vendor. The School Food Service Department and Business office worked together to ensure vendors were properly procured; however, this process did not include ensuring vendors with whom it plans to enter into a covered transaction with are not suspended, debarred, or otherwise excluded from participation in federal programs. While the Food Service Department did obtain a signed certification, there was no oversight or review process in place to ensure vendors were not suspended, debarred, or otherwise excluded from participation in federal programs prior to entering into covered transactions. The lack of internal controls over eligibility was isolated to the 2022-2023 school year. The lack of internal controls over suspension and debarment was systemic 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). . . ." Cause A proper system of internal controls was not designed by management of the School Corporation, which would include segregation of key functions. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper design or implementation of the components of a system of internal controls, including policies and procedures that provide segregation of duties and additional oversight as needed, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation design and implement a proper system of internal controls, including policies and procedures that would provide segregation of duties to ensure appropriate reviews, approvals, and oversight are taking place. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-004 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S425D200013, S425U200013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion Condition and Context The School Corporation had not designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance. The School Corporation was to submit an annual data report 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 was required to submit two ESSER I reports, two ESSER II reports, and two ESSER III reports, for a total of six reports. However, the School Corporation failed to submit all six required reports. 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 200.302(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." Cause A proper system of internal controls was not designed by management of the School Corporation. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. 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, all Annual Data Reports were not submitted to the IDOE. 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 funding 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 reports are submitted. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-004 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S425D200013, S425U200013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion Condition and Context The School Corporation had not designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance. The School Corporation was to submit an annual data report 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 was required to submit two ESSER I reports, two ESSER II reports, and two ESSER III reports, for a total of six reports. However, the School Corporation failed to submit all six required reports. 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 200.302(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." Cause A proper system of internal controls was not designed by management of the School Corporation. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. 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, all Annual Data Reports were not submitted to the IDOE. 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 funding 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 reports are submitted. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-004 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S425D200013, S425U200013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion Condition and Context The School Corporation had not designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance. The School Corporation was to submit an annual data report 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 was required to submit two ESSER I reports, two ESSER II reports, and two ESSER III reports, for a total of six reports. However, the School Corporation failed to submit all six required reports. 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 200.302(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." Cause A proper system of internal controls was not designed by management of the School Corporation. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. 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, all Annual Data Reports were not submitted to the IDOE. 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 funding 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 reports are submitted. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-004 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S425D200013, S425U200013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion Condition and Context The School Corporation had not designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance. The School Corporation was to submit an annual data report 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 was required to submit two ESSER I reports, two ESSER II reports, and two ESSER III reports, for a total of six reports. However, the School Corporation failed to submit all six required reports. 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 200.302(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." Cause A proper system of internal controls was not designed by management of the School Corporation. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. 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, all Annual Data Reports were not submitted to the IDOE. 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 funding 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 reports are submitted. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-004 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S425D200013, S425U200013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion Condition and Context The School Corporation had not designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance. The School Corporation was to submit an annual data report 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 was required to submit two ESSER I reports, two ESSER II reports, and two ESSER III reports, for a total of six reports. However, the School Corporation failed to submit all six required reports. 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 200.302(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." Cause A proper system of internal controls was not designed by management of the School Corporation. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. 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, all Annual Data Reports were not submitted to the IDOE. 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 funding 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 reports are submitted. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-004 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S425D200013, S425U200013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion Condition and Context The School Corporation had not designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance. The School Corporation was to submit an annual data report 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 was required to submit two ESSER I reports, two ESSER II reports, and two ESSER III reports, for a total of six reports. However, the School Corporation failed to submit all six required reports. 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 200.302(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." Cause A proper system of internal controls was not designed by management of the School Corporation. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. 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, all Annual Data Reports were not submitted to the IDOE. 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 funding 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 reports are submitted. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Finding 2023-002 Information on the federal program: Subject: Special Education Cluster – Suspension and Debarment Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 20611-047-PN01, 21611-047-PN01, 22611-047-PN01, 20619-047-PN01, 21619-047-PN01, 22619-047-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Material Weakness Criteria: 2 CFR 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 200.303 states: “When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) C hecking SAM Exclusions; or (b) C ollecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person.” Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the program grant agreements and the compliance requirements related to suspension and debarment. Cause: The School Corporation’s management had not developed a system of internal controls that would have ensured compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the program grant agreements and applicable Procurement and Suspension and Debarment compliance requirements. Questioned Costs: There were no questioned costs identified. Context: The School Corporation is a member of the Cooperative School Services (Cooperative) and serves as the fiscal agent for the Cooperative. The Cooperative operated the special education programs on behalf of the School Corporation and managed the special education grant funds. As the grant agreement was between the Indiana Department of Education and the School Corporation, the School Corporation was responsible for compliance with the grant agreement and the Suspension and Debarment compliance requirements. During fiscal year 2022, The School Corporation did not have adequate internal controls in place to ensure the Cooperative complied with the suspension and debarment requirements. The Special Education Director obtained suspension and debarment certifications for contracted vendors over $25,000 without an oversight or review process. The lack of controls over suspension and debarment requirements was isolated to fiscal year 2022. Identification as a repeat finding: Yes. Finding 2021-002. Recommendation: We recommended that the School Corporation's management establish a system of controls, including segregation of duties, to ensure compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement including documenting steps taken to verify the vendor selected is not suspended or debarred. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Finding 2023-002 Information on the federal program: Subject: Special Education Cluster – Suspension and Debarment Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 20611-047-PN01, 21611-047-PN01, 22611-047-PN01, 20619-047-PN01, 21619-047-PN01, 22619-047-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Material Weakness Criteria: 2 CFR 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 200.303 states: “When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) C hecking SAM Exclusions; or (b) C ollecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person.” Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the program grant agreements and the compliance requirements related to suspension and debarment. Cause: The School Corporation’s management had not developed a system of internal controls that would have ensured compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the program grant agreements and applicable Procurement and Suspension and Debarment compliance requirements. Questioned Costs: There were no questioned costs identified. Context: The School Corporation is a member of the Cooperative School Services (Cooperative) and serves as the fiscal agent for the Cooperative. The Cooperative operated the special education programs on behalf of the School Corporation and managed the special education grant funds. As the grant agreement was between the Indiana Department of Education and the School Corporation, the School Corporation was responsible for compliance with the grant agreement and the Suspension and Debarment compliance requirements. During fiscal year 2022, The School Corporation did not have adequate internal controls in place to ensure the Cooperative complied with the suspension and debarment requirements. The Special Education Director obtained suspension and debarment certifications for contracted vendors over $25,000 without an oversight or review process. The lack of controls over suspension and debarment requirements was isolated to fiscal year 2022. Identification as a repeat finding: Yes. Finding 2021-002. Recommendation: We recommended that the School Corporation's management establish a system of controls, including segregation of duties, to ensure compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement including documenting steps taken to verify the vendor selected is not suspended or debarred. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Finding 2023-002 Information on the federal program: Subject: Special Education Cluster – Suspension and Debarment Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 20611-047-PN01, 21611-047-PN01, 22611-047-PN01, 20619-047-PN01, 21619-047-PN01, 22619-047-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Material Weakness Criteria: 2 CFR 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 200.303 states: “When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) C hecking SAM Exclusions; or (b) C ollecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person.” Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the program grant agreements and the compliance requirements related to suspension and debarment. Cause: The School Corporation’s management had not developed a system of internal controls that would have ensured compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the program grant agreements and applicable Procurement and Suspension and Debarment compliance requirements. Questioned Costs: There were no questioned costs identified. Context: The School Corporation is a member of the Cooperative School Services (Cooperative) and serves as the fiscal agent for the Cooperative. The Cooperative operated the special education programs on behalf of the School Corporation and managed the special education grant funds. As the grant agreement was between the Indiana Department of Education and the School Corporation, the School Corporation was responsible for compliance with the grant agreement and the Suspension and Debarment compliance requirements. During fiscal year 2022, The School Corporation did not have adequate internal controls in place to ensure the Cooperative complied with the suspension and debarment requirements. The Special Education Director obtained suspension and debarment certifications for contracted vendors over $25,000 without an oversight or review process. The lack of controls over suspension and debarment requirements was isolated to fiscal year 2022. Identification as a repeat finding: Yes. Finding 2021-002. Recommendation: We recommended that the School Corporation's management establish a system of controls, including segregation of duties, to ensure compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement including documenting steps taken to verify the vendor selected is not suspended or debarred. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Finding 2023-002 Information on the federal program: Subject: Special Education Cluster – Suspension and Debarment Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 20611-047-PN01, 21611-047-PN01, 22611-047-PN01, 20619-047-PN01, 21619-047-PN01, 22619-047-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Material Weakness Criteria: 2 CFR 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 200.303 states: “When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) C hecking SAM Exclusions; or (b) C ollecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person.” Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the program grant agreements and the compliance requirements related to suspension and debarment. Cause: The School Corporation’s management had not developed a system of internal controls that would have ensured compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the program grant agreements and applicable Procurement and Suspension and Debarment compliance requirements. Questioned Costs: There were no questioned costs identified. Context: The School Corporation is a member of the Cooperative School Services (Cooperative) and serves as the fiscal agent for the Cooperative. The Cooperative operated the special education programs on behalf of the School Corporation and managed the special education grant funds. As the grant agreement was between the Indiana Department of Education and the School Corporation, the School Corporation was responsible for compliance with the grant agreement and the Suspension and Debarment compliance requirements. During fiscal year 2022, The School Corporation did not have adequate internal controls in place to ensure the Cooperative complied with the suspension and debarment requirements. The Special Education Director obtained suspension and debarment certifications for contracted vendors over $25,000 without an oversight or review process. The lack of controls over suspension and debarment requirements was isolated to fiscal year 2022. Identification as a repeat finding: Yes. Finding 2021-002. Recommendation: We recommended that the School Corporation's management establish a system of controls, including segregation of duties, to ensure compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement including documenting steps taken to verify the vendor selected is not suspended or debarred. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Finding 2023-002 Information on the federal program: Subject: Special Education Cluster – Suspension and Debarment Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 20611-047-PN01, 21611-047-PN01, 22611-047-PN01, 20619-047-PN01, 21619-047-PN01, 22619-047-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Material Weakness Criteria: 2 CFR 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 200.303 states: “When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) C hecking SAM Exclusions; or (b) C ollecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person.” Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the program grant agreements and the compliance requirements related to suspension and debarment. Cause: The School Corporation’s management had not developed a system of internal controls that would have ensured compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the program grant agreements and applicable Procurement and Suspension and Debarment compliance requirements. Questioned Costs: There were no questioned costs identified. Context: The School Corporation is a member of the Cooperative School Services (Cooperative) and serves as the fiscal agent for the Cooperative. The Cooperative operated the special education programs on behalf of the School Corporation and managed the special education grant funds. As the grant agreement was between the Indiana Department of Education and the School Corporation, the School Corporation was responsible for compliance with the grant agreement and the Suspension and Debarment compliance requirements. During fiscal year 2022, The School Corporation did not have adequate internal controls in place to ensure the Cooperative complied with the suspension and debarment requirements. The Special Education Director obtained suspension and debarment certifications for contracted vendors over $25,000 without an oversight or review process. The lack of controls over suspension and debarment requirements was isolated to fiscal year 2022. Identification as a repeat finding: Yes. Finding 2021-002. Recommendation: We recommended that the School Corporation's management establish a system of controls, including segregation of duties, to ensure compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement including documenting steps taken to verify the vendor selected is not suspended or debarred. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Finding 2023-002 Information on the federal program: Subject: Special Education Cluster – Suspension and Debarment Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 20611-047-PN01, 21611-047-PN01, 22611-047-PN01, 20619-047-PN01, 21619-047-PN01, 22619-047-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Material Weakness Criteria: 2 CFR 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 200.303 states: “When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) C hecking SAM Exclusions; or (b) C ollecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person.” Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the program grant agreements and the compliance requirements related to suspension and debarment. Cause: The School Corporation’s management had not developed a system of internal controls that would have ensured compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the program grant agreements and applicable Procurement and Suspension and Debarment compliance requirements. Questioned Costs: There were no questioned costs identified. Context: The School Corporation is a member of the Cooperative School Services (Cooperative) and serves as the fiscal agent for the Cooperative. The Cooperative operated the special education programs on behalf of the School Corporation and managed the special education grant funds. As the grant agreement was between the Indiana Department of Education and the School Corporation, the School Corporation was responsible for compliance with the grant agreement and the Suspension and Debarment compliance requirements. During fiscal year 2022, The School Corporation did not have adequate internal controls in place to ensure the Cooperative complied with the suspension and debarment requirements. The Special Education Director obtained suspension and debarment certifications for contracted vendors over $25,000 without an oversight or review process. The lack of controls over suspension and debarment requirements was isolated to fiscal year 2022. Identification as a repeat finding: Yes. Finding 2021-002. Recommendation: We recommended that the School Corporation's management establish a system of controls, including segregation of duties, to ensure compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement including documenting steps taken to verify the vendor selected is not suspended or debarred. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Finding 2023-003 Information on the federal program: Subject: Special Education Cluster (IDEA) –Earmarking Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 20611-047-PN01, 21611-047-PN01, 20619-047-PN01, 21619-047-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, and Earmarking Audit Finding: Material Weakness, Other Matters Criteria: 2 CFR 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 200.207(a) states in part: "The Federal awarding agency or pass-through entity may impose additional specific award conditions as needed . . ." 511 IAC 7-34-7(b) states: "The public agency, in providing special education and related services to students in nonpublic schools and facilities, must expend at least an amount that is the same proportion of the public agency total subgrant under 20 U.S.C. 1411(f) as the number of nonpublic school students with disabilities, who are enrolled by their parents in nonpublic schools or facilities within its boundaries, is to the total number of students with disabilities of the same age range." 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 earmarking portion of the Matching, Level of Effort, Earmarking compliance requirement. Cause: The School Corporation participates in a Special Education Cooperative that manages and operates the special education program and oversees the majority of the federal compliance requirements. The School Corporation's management had not developed a system of internal controls that would have ensured compliance with the grant agreement and the Matching, Level of Effort, Earmarking compliance requirement. Effect: The failure to establish an effective internal control system placed the School Corporation in noncompliance with the grant agreement and the Matching, Level of Effort, Earmarking compliance requirement. Noncompliance with the grant agreement or the compliance requirement could have resulted in the loss of federal funds to the School Corporation. Questioned Costs: There were no questioned costs identified. Context: The School Corporation did not meet the earmarking requirements for the grants, which concluded during the audit period. Both the Special Education Grants to States and Special Education Preschool Grants required a proportionate share of their funding to be spent on non-public school students with disabilities. The 20611-047-PN01, 20619-047-PN01, 21611-047-PN01, 21619-047-PN01 grant awards were fully expended during the audit period with minimum Non-Public Proportionate Share earmarking requirements of $19,551, $2,421, $26,253, and $1,959, respectively. There was no supporting documentation provided to support any non-public school expenditures were incurred towards the meeting the non-public proportionate share requirement. Identification as a repeat finding: Yes, Finding 2021-003. Recommendation: We recommended that the School Corporation's management establish internal controls to monitor earmarking requirements periodically to ensure compliance with the earmarking compliance requirements by the end of the grant period. This includes meeting with the Cooperative periodically to monitor and track progress towards meeting the earmarking requirements. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Finding 2023-003 Information on the federal program: Subject: Special Education Cluster (IDEA) –Earmarking Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 20611-047-PN01, 21611-047-PN01, 20619-047-PN01, 21619-047-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, and Earmarking Audit Finding: Material Weakness, Other Matters Criteria: 2 CFR 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 200.207(a) states in part: "The Federal awarding agency or pass-through entity may impose additional specific award conditions as needed . . ." 511 IAC 7-34-7(b) states: "The public agency, in providing special education and related services to students in nonpublic schools and facilities, must expend at least an amount that is the same proportion of the public agency total subgrant under 20 U.S.C. 1411(f) as the number of nonpublic school students with disabilities, who are enrolled by their parents in nonpublic schools or facilities within its boundaries, is to the total number of students with disabilities of the same age range." 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 earmarking portion of the Matching, Level of Effort, Earmarking compliance requirement. Cause: The School Corporation participates in a Special Education Cooperative that manages and operates the special education program and oversees the majority of the federal compliance requirements. The School Corporation's management had not developed a system of internal controls that would have ensured compliance with the grant agreement and the Matching, Level of Effort, Earmarking compliance requirement. Effect: The failure to establish an effective internal control system placed the School Corporation in noncompliance with the grant agreement and the Matching, Level of Effort, Earmarking compliance requirement. Noncompliance with the grant agreement or the compliance requirement could have resulted in the loss of federal funds to the School Corporation. Questioned Costs: There were no questioned costs identified. Context: The School Corporation did not meet the earmarking requirements for the grants, which concluded during the audit period. Both the Special Education Grants to States and Special Education Preschool Grants required a proportionate share of their funding to be spent on non-public school students with disabilities. The 20611-047-PN01, 20619-047-PN01, 21611-047-PN01, 21619-047-PN01 grant awards were fully expended during the audit period with minimum Non-Public Proportionate Share earmarking requirements of $19,551, $2,421, $26,253, and $1,959, respectively. There was no supporting documentation provided to support any non-public school expenditures were incurred towards the meeting the non-public proportionate share requirement. Identification as a repeat finding: Yes, Finding 2021-003. Recommendation: We recommended that the School Corporation's management establish internal controls to monitor earmarking requirements periodically to ensure compliance with the earmarking compliance requirements by the end of the grant period. This includes meeting with the Cooperative periodically to monitor and track progress towards meeting the earmarking requirements. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Finding 2023-003 Information on the federal program: Subject: Special Education Cluster (IDEA) –Earmarking Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 20611-047-PN01, 21611-047-PN01, 20619-047-PN01, 21619-047-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, and Earmarking Audit Finding: Material Weakness, Other Matters Criteria: 2 CFR 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 200.207(a) states in part: "The Federal awarding agency or pass-through entity may impose additional specific award conditions as needed . . ." 511 IAC 7-34-7(b) states: "The public agency, in providing special education and related services to students in nonpublic schools and facilities, must expend at least an amount that is the same proportion of the public agency total subgrant under 20 U.S.C. 1411(f) as the number of nonpublic school students with disabilities, who are enrolled by their parents in nonpublic schools or facilities within its boundaries, is to the total number of students with disabilities of the same age range." 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 earmarking portion of the Matching, Level of Effort, Earmarking compliance requirement. Cause: The School Corporation participates in a Special Education Cooperative that manages and operates the special education program and oversees the majority of the federal compliance requirements. The School Corporation's management had not developed a system of internal controls that would have ensured compliance with the grant agreement and the Matching, Level of Effort, Earmarking compliance requirement. Effect: The failure to establish an effective internal control system placed the School Corporation in noncompliance with the grant agreement and the Matching, Level of Effort, Earmarking compliance requirement. Noncompliance with the grant agreement or the compliance requirement could have resulted in the loss of federal funds to the School Corporation. Questioned Costs: There were no questioned costs identified. Context: The School Corporation did not meet the earmarking requirements for the grants, which concluded during the audit period. Both the Special Education Grants to States and Special Education Preschool Grants required a proportionate share of their funding to be spent on non-public school students with disabilities. The 20611-047-PN01, 20619-047-PN01, 21611-047-PN01, 21619-047-PN01 grant awards were fully expended during the audit period with minimum Non-Public Proportionate Share earmarking requirements of $19,551, $2,421, $26,253, and $1,959, respectively. There was no supporting documentation provided to support any non-public school expenditures were incurred towards the meeting the non-public proportionate share requirement. Identification as a repeat finding: Yes, Finding 2021-003. Recommendation: We recommended that the School Corporation's management establish internal controls to monitor earmarking requirements periodically to ensure compliance with the earmarking compliance requirements by the end of the grant period. This includes meeting with the Cooperative periodically to monitor and track progress towards meeting the earmarking requirements. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Finding 2023-003 Information on the federal program: Subject: Special Education Cluster (IDEA) –Earmarking Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 20611-047-PN01, 21611-047-PN01, 20619-047-PN01, 21619-047-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, and Earmarking Audit Finding: Material Weakness, Other Matters Criteria: 2 CFR 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 200.207(a) states in part: "The Federal awarding agency or pass-through entity may impose additional specific award conditions as needed . . ." 511 IAC 7-34-7(b) states: "The public agency, in providing special education and related services to students in nonpublic schools and facilities, must expend at least an amount that is the same proportion of the public agency total subgrant under 20 U.S.C. 1411(f) as the number of nonpublic school students with disabilities, who are enrolled by their parents in nonpublic schools or facilities within its boundaries, is to the total number of students with disabilities of the same age range." 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 earmarking portion of the Matching, Level of Effort, Earmarking compliance requirement. Cause: The School Corporation participates in a Special Education Cooperative that manages and operates the special education program and oversees the majority of the federal compliance requirements. The School Corporation's management had not developed a system of internal controls that would have ensured compliance with the grant agreement and the Matching, Level of Effort, Earmarking compliance requirement. Effect: The failure to establish an effective internal control system placed the School Corporation in noncompliance with the grant agreement and the Matching, Level of Effort, Earmarking compliance requirement. Noncompliance with the grant agreement or the compliance requirement could have resulted in the loss of federal funds to the School Corporation. Questioned Costs: There were no questioned costs identified. Context: The School Corporation did not meet the earmarking requirements for the grants, which concluded during the audit period. Both the Special Education Grants to States and Special Education Preschool Grants required a proportionate share of their funding to be spent on non-public school students with disabilities. The 20611-047-PN01, 20619-047-PN01, 21611-047-PN01, 21619-047-PN01 grant awards were fully expended during the audit period with minimum Non-Public Proportionate Share earmarking requirements of $19,551, $2,421, $26,253, and $1,959, respectively. There was no supporting documentation provided to support any non-public school expenditures were incurred towards the meeting the non-public proportionate share requirement. Identification as a repeat finding: Yes, Finding 2021-003. Recommendation: We recommended that the School Corporation's management establish internal controls to monitor earmarking requirements periodically to ensure compliance with the earmarking compliance requirements by the end of the grant period. This includes meeting with the Cooperative periodically to monitor and track progress towards meeting the earmarking requirements. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Finding 2023-004 Information on the federal program: Subject: Education Stabilization Fund – Special Tests and Provisions - Wage Rate Requirements Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Number: 84.425U Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Wage Rate Requirements Audit Findings: Material Weakness, Qualified Opinion 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). . . ." 29 CFR 5.5 states in part: a.The Agency head shall cause or require the contracting officer to insert in full in any contract in excess of $2,000 which is entered into for the actual construction, alteration and/or repair, including painting and decorating, of a public building or public work, or building or work financed in whole or in part from Federal funds or in accordance with guarantees of a Federal agency or financed from funds obtained by pledge of any contract of a Federal agency to make a loan, grant or annual contribution (except where a different meaning is expressly indicated), and which is subject to the labor standards provisions of any of the acts listed in §5.1, the following clauses… (1) Minimum wages. (i) All laborers and mechanics employed or working upon the site of the work (or under the United States Housing Act of 1937 or under the Housing Act of 1949 in the construction or development of the project), will be paid unconditionally and not less often than once a week, and without subsequent deduction or rebate on any account (except such payroll deductions as are permitted by regulations issued by the Secretary of Labor under the Copeland Act (29 CFR part 3)), the full amount of wages and bona fide fringe benefits (or cash equivalents thereof) due at time of payment computed at rates not less than those contained in the wage determination of the Secretary of Labor which is attached hereto and made a part hereof, regardless of any contractual relationship which may be alleged to exist between the contractor and such laborers and mechanics… (3)(ii)(A) The contractor shall submit weekly for each week in which any contract work is performed a copy of all payrolls to the (write in name of appropriate federal agency) if the agency is a party to the contract, but if the agency is not such a party, the contractor will submit the payrolls to the applicant, sponsor, or owner, as the case may be, for transmission to the (write in name of agency). 2 CFR 200 Appendix II states in part: In addition to other provisions required by the Federal agency or non-Federal entity; all contracts made by the non-Federal entity under the Federal award must contain provisions covering the following, as applicable. . . . (D) Davis-Bacon Act, as amended (40 U.S.C. 3141-3148). When required by Federal program legislation, all prime construction contracts in excess of $2,000 awarded by non-Federal entities must include a provision for compliance with the Davis-Bacon Act (40 U.S.C. 3141-3144, and 3146-3148) as supplemented by Department of Labor regulations (29 CFR Part 5, “Labor Standards Provisions Applicable to Contracts Covering Federally Financed and Assisted Construction”). In accordance with the statute, contractors must be required to pay wages to laborers and mechanics at a rate not less than the prevailing wages specified in a wage determination made by the Secretary of Labor. In addition, contractors must be required to pay wages not less than once a week.. . .” 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 Special Tests and Provisions – Wage Rate Requirements compliance requirements. The School Corporation did not include Davis Bacon wage rate requirements in its contract with vendor which includes labor. The School Corporation did not obtain the weekly payroll reports certifications from a construction company and its subcontractors for a building project. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with the compliance requirements listed above. ngs and Questioned Costs (Continued) Finding 2023-004 (Continued) Effect: The failure to design and implement an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Special Tests and Provisions – Wage Rate Requirements compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs: There were no questioned costs identified. Context: The School Corporation did not have an internal control designed to collect the weekly payroll reports certifications from a construction company and its subcontractors, as applicable, for building projects which included HVAC upgrades and replacements. Therefore, no review was performed by management to ensure that pay rates complied with the federal wage rate requirements. The vendor contract did not include a Davis-Bacon clause prescribing federal wage rate requirements required for construction contracts with labor installation costs. As of June 30, 2023, $566,328 was disbursed related to this capital project and charged to the ESSER III grant award (84.425U). The construction payments represented approximately 27.2% of the Education Stabilization Fund expenditures for the audit period. Identification as a repeat finding: No. Recommendation: We recommend the School Corporation include Davis-Bacon wage requirements in construction contracts which are federally funded and implement a formal process to ensure the required weekly payroll report certifications are collected and reviewed by management to ensure compliance with the federal wage rate requirements. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Department of Education 2023-002 Pass through Kentucky Department of Education; COVID-19 Education Stabliziation Fund - Assistance Listing No. 84.425; Grant period - Year ended June 30, 2023 Criteria and Condition: 2 CFR 200.303 requires the non-federal entity to establish and maintain effective internal controls over compliane with Federal statues, regulations, and the terms and conditions of the Federal award including proper tracking of grant expenditures or compliance. Cause: Wages paid from the Education Stabilization Fund were paid at rates different than the rates approved for the year Effect: Disbursements could be made using COVID-19 Stabilization Funds that are not in compliance with grant requirements Questioned Costs: No questioned costs were incurred form this finding Context: A sample of 40 payroll checks, from a population of 1,579 payroll checks, was selected for audit procedures. Of the 40 payroll checks tested, we noted one check was paid at a rate different than the rate approved for the year. Recommendation: Controls should be monitored to ensure that payroll is paid at approved rates
Information of the federal program: Federal Grantor: United States Department of Housing and Urban Development Assistance Listing No.: 14.241, Housing Opportunities for Persons with AIDS Ascension Ministry Market: Illinois Pass-Through Grantor: AIDS Foundation of Chicago Federal Grantor: United States Department of Justice Assistance Listing No.: 16.560, National Institute of Justice Research, Evaluation, and Development Project Grants Ascension Ministry Market: Texas Federal Grantor: United States Department of Justice Assistance Listing No.: 16.710, Public Safety Partnership and Community Policing Grants Ascension Ministry Market: Illinois Pass-Through Grantor: The Village of Arlington Heights Police Department Federal Grantor: United States Department of the Treasury Assistance Listing No.: 21.027, COVID-19 Coronavirus State and Local Fiscal Recovery Funds Ascension Ministry Market: Maryland Pass-Through Grantor: Mayor and City Council of Baltimore, through MONSE Federal Grantor: United States Department of Health and Human Services Assistance Listing No.: 93.650, Accountable Health Communities Ascension Ministry Market: Illinois Federal Grantor: United States Department of Health and Human Services Assistance Listing No.: 93.958, Block Grants for Community Mental Health Services Ascension Ministry Market: Illinois Pass-Through Grantor: The State of Illinois Department of Human Services Federal Grantor: United States Department of Homeland Security Assistance Listing No.: 97.036, Disaster Grants – Public Assistance (Presidentially Declared Disasters) Ascension Ministry Market: Florida Pass-Through Grantor: Florida Division of Emergency ManagementFederal Grantor: United States Department of Homeland Security Assistance Listing No.: 97.039, Hazard Mitigation Grant Ascension Ministry Market: Florida Pass-Through Grantor: Florida Division of Emergency Management Criteria or specific requirement (including statutory, regulatory, or other citation): Section 200.303 of the Uniform Guidance states the following regarding internal control: “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).” The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.” Condition: A grant with expenditures of $55,702 under Assistance Listing No. 14.241 was not included on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management; the final Schedule was corrected. (Alexian Brothers-Bonaventure House, Illinois) A grant with expenditures of $204,574 under Assistance Listing No. 16.560 was not included on the preliminary Schedule provided by management; the final Schedule was corrected. (Ascension Seton, Texas) Expenditures in the amount of $89,084 under Assistance Listing No. 16.710 were improperly classified as Assistance Listing No. 93.958; the final Schedule was corrected. (Presence Behavioral Health, Illinois) A grant with expenditures of $230,108 under Assistance Listing No. 21.027 was included on the preliminary Schedule and was subsequently excluded when it was identified as a beneficiary award and not a subrecipient award; the final Schedule was corrected (Ascension Via Christi Hospitals Wichita, Inc., Kansas). A grant with expenditures of $164,195 under Assistance Listing No. 21.027 was not included on the preliminary Schedule provided by management; the final Schedule was corrected. (St. Agnes Healthcare, Inc., Maryland) Expenditures under Assistance Listing No. 93.650 were reported twice on the preliminary Schedule, resulting in overstatement of $314,551; the final Schedule was corrected. (Alexian Brothers Hospital Network, Illinois) A grant with expenditures of $232,713 under Assistance Listing No. 97.039 was misclassified as Assistance Listing No. 97.036; the final Schedule was corrected. (St. Vincent’s Health System, Florida) Cause: Ascension’s (the System) internal controls in place over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards. Effect or Potential Effect: Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes. Questioned costs: None. Context:The table below shows the preliminary and adjusted assistance listing on the Schedule. See table/chart in the finding. Identification as a repeat finding, if applicable: The finding is not a repeat finding from the prior year. Recommendation: Management should implement more robust internal controls to ensure the assistance listing numbers are appropriately listed on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule. Views of responsible officials: The System will enhance grant management award processes by revising its onboarding procedures and add additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the SEFA reporting totals to facilitate accurate reporting. Award amounts were changed on the SEFA reporting schedules after management’s review was executed. Management will implement preventive controls to lock down market SEFA templates after management final review.
Information of the federal program: Federal Grantor: United States Department of Housing and Urban Development Assistance Listing No.: 14.241, Housing Opportunities for Persons with AIDS Ascension Ministry Market: Illinois Pass-Through Grantor: AIDS Foundation of Chicago Federal Grantor: United States Department of Justice Assistance Listing No.: 16.560, National Institute of Justice Research, Evaluation, and Development Project Grants Ascension Ministry Market: Texas Federal Grantor: United States Department of Justice Assistance Listing No.: 16.710, Public Safety Partnership and Community Policing Grants Ascension Ministry Market: Illinois Pass-Through Grantor: The Village of Arlington Heights Police Department Federal Grantor: United States Department of the Treasury Assistance Listing No.: 21.027, COVID-19 Coronavirus State and Local Fiscal Recovery Funds Ascension Ministry Market: Maryland Pass-Through Grantor: Mayor and City Council of Baltimore, through MONSE Federal Grantor: United States Department of Health and Human Services Assistance Listing No.: 93.650, Accountable Health Communities Ascension Ministry Market: Illinois Federal Grantor: United States Department of Health and Human Services Assistance Listing No.: 93.958, Block Grants for Community Mental Health Services Ascension Ministry Market: Illinois Pass-Through Grantor: The State of Illinois Department of Human Services Federal Grantor: United States Department of Homeland Security Assistance Listing No.: 97.036, Disaster Grants – Public Assistance (Presidentially Declared Disasters) Ascension Ministry Market: Florida Pass-Through Grantor: Florida Division of Emergency ManagementFederal Grantor: United States Department of Homeland Security Assistance Listing No.: 97.039, Hazard Mitigation Grant Ascension Ministry Market: Florida Pass-Through Grantor: Florida Division of Emergency Management Criteria or specific requirement (including statutory, regulatory, or other citation): Section 200.303 of the Uniform Guidance states the following regarding internal control: “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).” The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.” Condition: A grant with expenditures of $55,702 under Assistance Listing No. 14.241 was not included on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management; the final Schedule was corrected. (Alexian Brothers-Bonaventure House, Illinois) A grant with expenditures of $204,574 under Assistance Listing No. 16.560 was not included on the preliminary Schedule provided by management; the final Schedule was corrected. (Ascension Seton, Texas) Expenditures in the amount of $89,084 under Assistance Listing No. 16.710 were improperly classified as Assistance Listing No. 93.958; the final Schedule was corrected. (Presence Behavioral Health, Illinois) A grant with expenditures of $230,108 under Assistance Listing No. 21.027 was included on the preliminary Schedule and was subsequently excluded when it was identified as a beneficiary award and not a subrecipient award; the final Schedule was corrected (Ascension Via Christi Hospitals Wichita, Inc., Kansas). A grant with expenditures of $164,195 under Assistance Listing No. 21.027 was not included on the preliminary Schedule provided by management; the final Schedule was corrected. (St. Agnes Healthcare, Inc., Maryland) Expenditures under Assistance Listing No. 93.650 were reported twice on the preliminary Schedule, resulting in overstatement of $314,551; the final Schedule was corrected. (Alexian Brothers Hospital Network, Illinois) A grant with expenditures of $232,713 under Assistance Listing No. 97.039 was misclassified as Assistance Listing No. 97.036; the final Schedule was corrected. (St. Vincent’s Health System, Florida) Cause: Ascension’s (the System) internal controls in place over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards. Effect or Potential Effect: Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes. Questioned costs: None. Context:The table below shows the preliminary and adjusted assistance listing on the Schedule. See table/chart in the finding. Identification as a repeat finding, if applicable: The finding is not a repeat finding from the prior year. Recommendation: Management should implement more robust internal controls to ensure the assistance listing numbers are appropriately listed on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule. Views of responsible officials: The System will enhance grant management award processes by revising its onboarding procedures and add additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the SEFA reporting totals to facilitate accurate reporting. Award amounts were changed on the SEFA reporting schedules after management’s review was executed. Management will implement preventive controls to lock down market SEFA templates after management final review.
Information of the federal program: Federal Grantor: United States Department of Housing and Urban Development Assistance Listing No.: 14.241, Housing Opportunities for Persons with AIDS Ascension Ministry Market: Illinois Pass-Through Grantor: AIDS Foundation of Chicago Federal Grantor: United States Department of Justice Assistance Listing No.: 16.560, National Institute of Justice Research, Evaluation, and Development Project Grants Ascension Ministry Market: Texas Federal Grantor: United States Department of Justice Assistance Listing No.: 16.710, Public Safety Partnership and Community Policing Grants Ascension Ministry Market: Illinois Pass-Through Grantor: The Village of Arlington Heights Police Department Federal Grantor: United States Department of the Treasury Assistance Listing No.: 21.027, COVID-19 Coronavirus State and Local Fiscal Recovery Funds Ascension Ministry Market: Maryland Pass-Through Grantor: Mayor and City Council of Baltimore, through MONSE Federal Grantor: United States Department of Health and Human Services Assistance Listing No.: 93.650, Accountable Health Communities Ascension Ministry Market: Illinois Federal Grantor: United States Department of Health and Human Services Assistance Listing No.: 93.958, Block Grants for Community Mental Health Services Ascension Ministry Market: Illinois Pass-Through Grantor: The State of Illinois Department of Human Services Federal Grantor: United States Department of Homeland Security Assistance Listing No.: 97.036, Disaster Grants – Public Assistance (Presidentially Declared Disasters) Ascension Ministry Market: Florida Pass-Through Grantor: Florida Division of Emergency ManagementFederal Grantor: United States Department of Homeland Security Assistance Listing No.: 97.039, Hazard Mitigation Grant Ascension Ministry Market: Florida Pass-Through Grantor: Florida Division of Emergency Management Criteria or specific requirement (including statutory, regulatory, or other citation): Section 200.303 of the Uniform Guidance states the following regarding internal control: “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).” The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.” Condition: A grant with expenditures of $55,702 under Assistance Listing No. 14.241 was not included on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management; the final Schedule was corrected. (Alexian Brothers-Bonaventure House, Illinois) A grant with expenditures of $204,574 under Assistance Listing No. 16.560 was not included on the preliminary Schedule provided by management; the final Schedule was corrected. (Ascension Seton, Texas) Expenditures in the amount of $89,084 under Assistance Listing No. 16.710 were improperly classified as Assistance Listing No. 93.958; the final Schedule was corrected. (Presence Behavioral Health, Illinois) A grant with expenditures of $230,108 under Assistance Listing No. 21.027 was included on the preliminary Schedule and was subsequently excluded when it was identified as a beneficiary award and not a subrecipient award; the final Schedule was corrected (Ascension Via Christi Hospitals Wichita, Inc., Kansas). A grant with expenditures of $164,195 under Assistance Listing No. 21.027 was not included on the preliminary Schedule provided by management; the final Schedule was corrected. (St. Agnes Healthcare, Inc., Maryland) Expenditures under Assistance Listing No. 93.650 were reported twice on the preliminary Schedule, resulting in overstatement of $314,551; the final Schedule was corrected. (Alexian Brothers Hospital Network, Illinois) A grant with expenditures of $232,713 under Assistance Listing No. 97.039 was misclassified as Assistance Listing No. 97.036; the final Schedule was corrected. (St. Vincent’s Health System, Florida) Cause: Ascension’s (the System) internal controls in place over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards. Effect or Potential Effect: Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes. Questioned costs: None. Context:The table below shows the preliminary and adjusted assistance listing on the Schedule. See table/chart in the finding. Identification as a repeat finding, if applicable: The finding is not a repeat finding from the prior year. Recommendation: Management should implement more robust internal controls to ensure the assistance listing numbers are appropriately listed on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule. Views of responsible officials: The System will enhance grant management award processes by revising its onboarding procedures and add additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the SEFA reporting totals to facilitate accurate reporting. Award amounts were changed on the SEFA reporting schedules after management’s review was executed. Management will implement preventive controls to lock down market SEFA templates after management final review.
Information of the federal program: Federal Grantor: United States Department of Housing and Urban Development Assistance Listing No.: 14.241, Housing Opportunities for Persons with AIDS Ascension Ministry Market: Illinois Pass-Through Grantor: AIDS Foundation of Chicago Federal Grantor: United States Department of Justice Assistance Listing No.: 16.560, National Institute of Justice Research, Evaluation, and Development Project Grants Ascension Ministry Market: Texas Federal Grantor: United States Department of Justice Assistance Listing No.: 16.710, Public Safety Partnership and Community Policing Grants Ascension Ministry Market: Illinois Pass-Through Grantor: The Village of Arlington Heights Police Department Federal Grantor: United States Department of the Treasury Assistance Listing No.: 21.027, COVID-19 Coronavirus State and Local Fiscal Recovery Funds Ascension Ministry Market: Maryland Pass-Through Grantor: Mayor and City Council of Baltimore, through MONSE Federal Grantor: United States Department of Health and Human Services Assistance Listing No.: 93.650, Accountable Health Communities Ascension Ministry Market: Illinois Federal Grantor: United States Department of Health and Human Services Assistance Listing No.: 93.958, Block Grants for Community Mental Health Services Ascension Ministry Market: Illinois Pass-Through Grantor: The State of Illinois Department of Human Services Federal Grantor: United States Department of Homeland Security Assistance Listing No.: 97.036, Disaster Grants – Public Assistance (Presidentially Declared Disasters) Ascension Ministry Market: Florida Pass-Through Grantor: Florida Division of Emergency ManagementFederal Grantor: United States Department of Homeland Security Assistance Listing No.: 97.039, Hazard Mitigation Grant Ascension Ministry Market: Florida Pass-Through Grantor: Florida Division of Emergency Management Criteria or specific requirement (including statutory, regulatory, or other citation): Section 200.303 of the Uniform Guidance states the following regarding internal control: “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).” The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.” Condition: A grant with expenditures of $55,702 under Assistance Listing No. 14.241 was not included on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management; the final Schedule was corrected. (Alexian Brothers-Bonaventure House, Illinois) A grant with expenditures of $204,574 under Assistance Listing No. 16.560 was not included on the preliminary Schedule provided by management; the final Schedule was corrected. (Ascension Seton, Texas) Expenditures in the amount of $89,084 under Assistance Listing No. 16.710 were improperly classified as Assistance Listing No. 93.958; the final Schedule was corrected. (Presence Behavioral Health, Illinois) A grant with expenditures of $230,108 under Assistance Listing No. 21.027 was included on the preliminary Schedule and was subsequently excluded when it was identified as a beneficiary award and not a subrecipient award; the final Schedule was corrected (Ascension Via Christi Hospitals Wichita, Inc., Kansas). A grant with expenditures of $164,195 under Assistance Listing No. 21.027 was not included on the preliminary Schedule provided by management; the final Schedule was corrected. (St. Agnes Healthcare, Inc., Maryland) Expenditures under Assistance Listing No. 93.650 were reported twice on the preliminary Schedule, resulting in overstatement of $314,551; the final Schedule was corrected. (Alexian Brothers Hospital Network, Illinois) A grant with expenditures of $232,713 under Assistance Listing No. 97.039 was misclassified as Assistance Listing No. 97.036; the final Schedule was corrected. (St. Vincent’s Health System, Florida) Cause: Ascension’s (the System) internal controls in place over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards. Effect or Potential Effect: Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes. Questioned costs: None. Context:The table below shows the preliminary and adjusted assistance listing on the Schedule. See table/chart in the finding. Identification as a repeat finding, if applicable: The finding is not a repeat finding from the prior year. Recommendation: Management should implement more robust internal controls to ensure the assistance listing numbers are appropriately listed on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule. Views of responsible officials: The System will enhance grant management award processes by revising its onboarding procedures and add additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the SEFA reporting totals to facilitate accurate reporting. Award amounts were changed on the SEFA reporting schedules after management’s review was executed. Management will implement preventive controls to lock down market SEFA templates after management final review.
Information of the federal program: Federal Grantor: United States Department of Housing and Urban Development Assistance Listing No.: 14.241, Housing Opportunities for Persons with AIDS Ascension Ministry Market: Illinois Pass-Through Grantor: AIDS Foundation of Chicago Federal Grantor: United States Department of Justice Assistance Listing No.: 16.560, National Institute of Justice Research, Evaluation, and Development Project Grants Ascension Ministry Market: Texas Federal Grantor: United States Department of Justice Assistance Listing No.: 16.710, Public Safety Partnership and Community Policing Grants Ascension Ministry Market: Illinois Pass-Through Grantor: The Village of Arlington Heights Police Department Federal Grantor: United States Department of the Treasury Assistance Listing No.: 21.027, COVID-19 Coronavirus State and Local Fiscal Recovery Funds Ascension Ministry Market: Maryland Pass-Through Grantor: Mayor and City Council of Baltimore, through MONSE Federal Grantor: United States Department of Health and Human Services Assistance Listing No.: 93.650, Accountable Health Communities Ascension Ministry Market: Illinois Federal Grantor: United States Department of Health and Human Services Assistance Listing No.: 93.958, Block Grants for Community Mental Health Services Ascension Ministry Market: Illinois Pass-Through Grantor: The State of Illinois Department of Human Services Federal Grantor: United States Department of Homeland Security Assistance Listing No.: 97.036, Disaster Grants – Public Assistance (Presidentially Declared Disasters) Ascension Ministry Market: Florida Pass-Through Grantor: Florida Division of Emergency ManagementFederal Grantor: United States Department of Homeland Security Assistance Listing No.: 97.039, Hazard Mitigation Grant Ascension Ministry Market: Florida Pass-Through Grantor: Florida Division of Emergency Management Criteria or specific requirement (including statutory, regulatory, or other citation): Section 200.303 of the Uniform Guidance states the following regarding internal control: “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).” The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.” Condition: A grant with expenditures of $55,702 under Assistance Listing No. 14.241 was not included on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management; the final Schedule was corrected. (Alexian Brothers-Bonaventure House, Illinois) A grant with expenditures of $204,574 under Assistance Listing No. 16.560 was not included on the preliminary Schedule provided by management; the final Schedule was corrected. (Ascension Seton, Texas) Expenditures in the amount of $89,084 under Assistance Listing No. 16.710 were improperly classified as Assistance Listing No. 93.958; the final Schedule was corrected. (Presence Behavioral Health, Illinois) A grant with expenditures of $230,108 under Assistance Listing No. 21.027 was included on the preliminary Schedule and was subsequently excluded when it was identified as a beneficiary award and not a subrecipient award; the final Schedule was corrected (Ascension Via Christi Hospitals Wichita, Inc., Kansas). A grant with expenditures of $164,195 under Assistance Listing No. 21.027 was not included on the preliminary Schedule provided by management; the final Schedule was corrected. (St. Agnes Healthcare, Inc., Maryland) Expenditures under Assistance Listing No. 93.650 were reported twice on the preliminary Schedule, resulting in overstatement of $314,551; the final Schedule was corrected. (Alexian Brothers Hospital Network, Illinois) A grant with expenditures of $232,713 under Assistance Listing No. 97.039 was misclassified as Assistance Listing No. 97.036; the final Schedule was corrected. (St. Vincent’s Health System, Florida) Cause: Ascension’s (the System) internal controls in place over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards. Effect or Potential Effect: Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes. Questioned costs: None. Context:The table below shows the preliminary and adjusted assistance listing on the Schedule. See table/chart in the finding. Identification as a repeat finding, if applicable: The finding is not a repeat finding from the prior year. Recommendation: Management should implement more robust internal controls to ensure the assistance listing numbers are appropriately listed on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule. Views of responsible officials: The System will enhance grant management award processes by revising its onboarding procedures and add additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the SEFA reporting totals to facilitate accurate reporting. Award amounts were changed on the SEFA reporting schedules after management’s review was executed. Management will implement preventive controls to lock down market SEFA templates after management final review.
Information of the federal program: Federal Grantor: United States Department of Housing and Urban Development Assistance Listing No.: 14.241, Housing Opportunities for Persons with AIDS Ascension Ministry Market: Illinois Pass-Through Grantor: AIDS Foundation of Chicago Federal Grantor: United States Department of Justice Assistance Listing No.: 16.560, National Institute of Justice Research, Evaluation, and Development Project Grants Ascension Ministry Market: Texas Federal Grantor: United States Department of Justice Assistance Listing No.: 16.710, Public Safety Partnership and Community Policing Grants Ascension Ministry Market: Illinois Pass-Through Grantor: The Village of Arlington Heights Police Department Federal Grantor: United States Department of the Treasury Assistance Listing No.: 21.027, COVID-19 Coronavirus State and Local Fiscal Recovery Funds Ascension Ministry Market: Maryland Pass-Through Grantor: Mayor and City Council of Baltimore, through MONSE Federal Grantor: United States Department of Health and Human Services Assistance Listing No.: 93.650, Accountable Health Communities Ascension Ministry Market: Illinois Federal Grantor: United States Department of Health and Human Services Assistance Listing No.: 93.958, Block Grants for Community Mental Health Services Ascension Ministry Market: Illinois Pass-Through Grantor: The State of Illinois Department of Human Services Federal Grantor: United States Department of Homeland Security Assistance Listing No.: 97.036, Disaster Grants – Public Assistance (Presidentially Declared Disasters) Ascension Ministry Market: Florida Pass-Through Grantor: Florida Division of Emergency ManagementFederal Grantor: United States Department of Homeland Security Assistance Listing No.: 97.039, Hazard Mitigation Grant Ascension Ministry Market: Florida Pass-Through Grantor: Florida Division of Emergency Management Criteria or specific requirement (including statutory, regulatory, or other citation): Section 200.303 of the Uniform Guidance states the following regarding internal control: “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).” The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.” Condition: A grant with expenditures of $55,702 under Assistance Listing No. 14.241 was not included on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management; the final Schedule was corrected. (Alexian Brothers-Bonaventure House, Illinois) A grant with expenditures of $204,574 under Assistance Listing No. 16.560 was not included on the preliminary Schedule provided by management; the final Schedule was corrected. (Ascension Seton, Texas) Expenditures in the amount of $89,084 under Assistance Listing No. 16.710 were improperly classified as Assistance Listing No. 93.958; the final Schedule was corrected. (Presence Behavioral Health, Illinois) A grant with expenditures of $230,108 under Assistance Listing No. 21.027 was included on the preliminary Schedule and was subsequently excluded when it was identified as a beneficiary award and not a subrecipient award; the final Schedule was corrected (Ascension Via Christi Hospitals Wichita, Inc., Kansas). A grant with expenditures of $164,195 under Assistance Listing No. 21.027 was not included on the preliminary Schedule provided by management; the final Schedule was corrected. (St. Agnes Healthcare, Inc., Maryland) Expenditures under Assistance Listing No. 93.650 were reported twice on the preliminary Schedule, resulting in overstatement of $314,551; the final Schedule was corrected. (Alexian Brothers Hospital Network, Illinois) A grant with expenditures of $232,713 under Assistance Listing No. 97.039 was misclassified as Assistance Listing No. 97.036; the final Schedule was corrected. (St. Vincent’s Health System, Florida) Cause: Ascension’s (the System) internal controls in place over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards. Effect or Potential Effect: Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes. Questioned costs: None. Context:The table below shows the preliminary and adjusted assistance listing on the Schedule. See table/chart in the finding. Identification as a repeat finding, if applicable: The finding is not a repeat finding from the prior year. Recommendation: Management should implement more robust internal controls to ensure the assistance listing numbers are appropriately listed on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule. Views of responsible officials: The System will enhance grant management award processes by revising its onboarding procedures and add additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the SEFA reporting totals to facilitate accurate reporting. Award amounts were changed on the SEFA reporting schedules after management’s review was executed. Management will implement preventive controls to lock down market SEFA templates after management final review.
2023-001 Lack of Documentation to Support Distribution of Wages (Significant Deficiency) Federal Agency: Department of Education Pass-through Agency: New Hampshire Department of Education Cluster/Program: Education Stabilization Fund Assistance Listing Number: 84.425U Passed-through Identification: #20220575 Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Type of Finding: Internal Control over Compliance – Significant deficiency Criteria or Specific Requirement: Federal regulations 2 CFR 200.303 states, the District, as a recipient of Federal funds, must establish and maintain effective internal controls 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. In addition, under 2 CFR 200.430, it states that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must (1) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, (2) be incorporated into the official records of the non-Federal entity, (3) reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities, and (4) support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award or a federal award and non-Federal award. Condition: During our review of payroll charged to the grant, we noted one employee who did not have a signed contract or payrate form. Cause: Administrative oversight. Effect: The District did not have adequate documentation to support the distribution of the employee’s wages paid using grant funds. Questioned Costs: $95,699 Repeat Finding: No Recommendation: We recommend that documentation be retained to support the distribution of salaries and wages for all employees paid using grant funds. Views of Responsible Officials: Management’s views and corrective action plan is included at the end of this report.
2023-002 Lack of Documentation to Support Vendor Payment (Significant Deficiency) Federal Agency: Department of Education Pass-through Agency: New Hampshire Department of Education Cluster/Program: Supporting Effective Instruction State Grants Assistance Listing Number: 84.367 Passed-through Identification: #20220933 Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Type of Finding: Internal Control over Compliance – Significant deficiency Criteria or Specific Requirement: Federal regulations 2 CFR 200.303 states, the District, as a recipient of Federal funds, must establish and maintain effective internal controls 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. Condition: During our review of disbursements, no documentation was provided for one sample selected for testing. Cause: Administrative oversight. Effect: The District did not have adequate documentation to support the disbursement. Questioned Costs: $1,487 Repeat Finding: No Recommendation: We recommend that documentation be retained to support the disbursement for all invoices paid using grant funds. Views of Responsible Officials: Management’s views and corrective action plan is included at the end of this report.
Finding Number: 2023-002 Prior Year Finding: No Federal Agency: U.S. Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing: 84.425 C,D,U,W Pass-Through Entity: Maryland State Department of Education Pass-Through Award Number and Period: 201873-01 (3/13/20 – 9/30/22) 221869-01 (6/1/22 – 9/30/24) 201787-01 (3/13/20 – 9/30/22) 211956-01 (3/24/21 – 9/30/23) 202233-01 (3/13/20 – 9/30/22) 221568-01 (7/1/21 – 9/30/22) 221422-01 (7/1/21 – 9/30/23) 221894-01 (7/1/21 – 9/30/23) Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement Control: Per 2 CFR section 200.303(a), a 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 comply with the 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). Condition/Context For 2 out of 60 samples, the Board did not retain documentation supporting proper approval of the costs charged to the grant. Questioned Costs None noted. Cause The Board did not establish and maintain effective internal control over the Federal award in accordance with the COSO framework noted above for 2 out of 60 samples. Effect Failure to perform timely approvals of grant expenditures may result in the Board charging expenditures to the grant that are unallowable. Recommendation We recommend that the Board enhance its procedures and internal controls to ensure that it retains documentation of expenditure approvals and that this documentation is available for audit purposes. Views of Responsible Officials Management agrees with the finding.
Finding Number: 2023-002 Prior Year Finding: No Federal Agency: U.S. Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing: 84.425 C,D,U,W Pass-Through Entity: Maryland State Department of Education Pass-Through Award Number and Period: 201873-01 (3/13/20 – 9/30/22) 221869-01 (6/1/22 – 9/30/24) 201787-01 (3/13/20 – 9/30/22) 211956-01 (3/24/21 – 9/30/23) 202233-01 (3/13/20 – 9/30/22) 221568-01 (7/1/21 – 9/30/22) 221422-01 (7/1/21 – 9/30/23) 221894-01 (7/1/21 – 9/30/23) Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement Control: Per 2 CFR section 200.303(a), a 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 comply with the 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). Condition/Context For 2 out of 60 samples, the Board did not retain documentation supporting proper approval of the costs charged to the grant. Questioned Costs None noted. Cause The Board did not establish and maintain effective internal control over the Federal award in accordance with the COSO framework noted above for 2 out of 60 samples. Effect Failure to perform timely approvals of grant expenditures may result in the Board charging expenditures to the grant that are unallowable. Recommendation We recommend that the Board enhance its procedures and internal controls to ensure that it retains documentation of expenditure approvals and that this documentation is available for audit purposes. Views of Responsible Officials Management agrees with the finding.
Finding Number: 2023-002 Prior Year Finding: No Federal Agency: U.S. Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing: 84.425 C,D,U,W Pass-Through Entity: Maryland State Department of Education Pass-Through Award Number and Period: 201873-01 (3/13/20 – 9/30/22) 221869-01 (6/1/22 – 9/30/24) 201787-01 (3/13/20 – 9/30/22) 211956-01 (3/24/21 – 9/30/23) 202233-01 (3/13/20 – 9/30/22) 221568-01 (7/1/21 – 9/30/22) 221422-01 (7/1/21 – 9/30/23) 221894-01 (7/1/21 – 9/30/23) Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement Control: Per 2 CFR section 200.303(a), a 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 comply with the 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). Condition/Context For 2 out of 60 samples, the Board did not retain documentation supporting proper approval of the costs charged to the grant. Questioned Costs None noted. Cause The Board did not establish and maintain effective internal control over the Federal award in accordance with the COSO framework noted above for 2 out of 60 samples. Effect Failure to perform timely approvals of grant expenditures may result in the Board charging expenditures to the grant that are unallowable. Recommendation We recommend that the Board enhance its procedures and internal controls to ensure that it retains documentation of expenditure approvals and that this documentation is available for audit purposes. Views of Responsible Officials Management agrees with the finding.
Finding Number: 2023-002 Prior Year Finding: No Federal Agency: U.S. Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing: 84.425 C,D,U,W Pass-Through Entity: Maryland State Department of Education Pass-Through Award Number and Period: 201873-01 (3/13/20 – 9/30/22) 221869-01 (6/1/22 – 9/30/24) 201787-01 (3/13/20 – 9/30/22) 211956-01 (3/24/21 – 9/30/23) 202233-01 (3/13/20 – 9/30/22) 221568-01 (7/1/21 – 9/30/22) 221422-01 (7/1/21 – 9/30/23) 221894-01 (7/1/21 – 9/30/23) Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement Control: Per 2 CFR section 200.303(a), a 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 comply with the 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). Condition/Context For 2 out of 60 samples, the Board did not retain documentation supporting proper approval of the costs charged to the grant. Questioned Costs None noted. Cause The Board did not establish and maintain effective internal control over the Federal award in accordance with the COSO framework noted above for 2 out of 60 samples. Effect Failure to perform timely approvals of grant expenditures may result in the Board charging expenditures to the grant that are unallowable. Recommendation We recommend that the Board enhance its procedures and internal controls to ensure that it retains documentation of expenditure approvals and that this documentation is available for audit purposes. Views of Responsible Officials Management agrees with the finding.
Finding Number: 2023-002 Prior Year Finding: No Federal Agency: U.S. Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing: 84.425 C,D,U,W Pass-Through Entity: Maryland State Department of Education Pass-Through Award Number and Period: 201873-01 (3/13/20 – 9/30/22) 221869-01 (6/1/22 – 9/30/24) 201787-01 (3/13/20 – 9/30/22) 211956-01 (3/24/21 – 9/30/23) 202233-01 (3/13/20 – 9/30/22) 221568-01 (7/1/21 – 9/30/22) 221422-01 (7/1/21 – 9/30/23) 221894-01 (7/1/21 – 9/30/23) Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement Control: Per 2 CFR section 200.303(a), a 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 comply with the 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). Condition/Context For 2 out of 60 samples, the Board did not retain documentation supporting proper approval of the costs charged to the grant. Questioned Costs None noted. Cause The Board did not establish and maintain effective internal control over the Federal award in accordance with the COSO framework noted above for 2 out of 60 samples. Effect Failure to perform timely approvals of grant expenditures may result in the Board charging expenditures to the grant that are unallowable. Recommendation We recommend that the Board enhance its procedures and internal controls to ensure that it retains documentation of expenditure approvals and that this documentation is available for audit purposes. Views of Responsible Officials Management agrees with the finding.