FINDING 2022-014 Subject: COVID-19 - Education Stabilization Fund - Cash Management 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): S425D200013, S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Cash Management Audit Findings: Material Weakness, Modified Opinion Condition and Context An effective internal control system was not designed nor implemented at the School Corporation to ensure compliance with the requirements related to the grant agreement and the Cash Management compliance requirement. The School Corporation requested reimbursement based off a calculation with the budgeted line items instead of actual grant expenses. For 19 of 20 reimbursement requests tested, the School Corporation was unable to provide adequate supporting documentation. Due to the lack of supporting documentation, it was not possible to determine if grant payments were reimbursements of expenditures or advance payments. 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: INDIANA STATE BOARD OF ACCOUNTS 54 SCOTT COUNTY SCHOOL DISTRICT 2 SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (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 200.305(b) states in part: "For non-Federal entities other than states, payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means. . . . (3) Reimbursement is the preferred method when the requirements in paragraph (b) cannot be met, when the Federal awarding agency sets a specific condition per ? 200.208, or when the non-Federal entity requests payment by reimbursement. . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in ?? 200.328 and 200.329. . . ." Cause Management had not designed nor implemented a system of internal controls that would have ensured compliance or that supporting documentation would have been maintained and available for audit related to the Cash Management compliance requirement. Effect The failure to retain and provide appropriate supporting documentation prevented the determination of the School Corporation's compliance with the Cash Management compliance requirement. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure that documentation will be maintained and available for audit and comply with the grant agreement and the Cash Management compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-016 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): S425D200013, S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion Condition and Context An effective internal control system was not designed nor implemented at the School Corporation to ensure compliance with the requirements related to the grant agreement and the Reporting compliance requirement. INDIANA STATE BOARD OF ACCOUNTS 57 SCOTT COUNTY SCHOOL DISTRICT 2 SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) The School Corporation filed the four required Elementary and Secondary School Emergency Relief (ESSER) annual data reports. However, none of the reports were supported by the School Corporation's records. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following: . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in ?? 200.328 and 200.329. . . . (3) Records that identify adequately the source and application of funds for federally funded activities. These records must contain information pertaining to Federal awards, authorizations, obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Cause Management had not designed nor implemented a system of internal controls that would have ensured that supporting documentation would have been maintained and available for audit related to the Reporting compliance requirement. INDIANA STATE BOARD OF ACCOUNTS 58 SCOTT COUNTY SCHOOL DISTRICT 2 SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Effect The failure to retain and provide appropriate supporting documentation prevented the determination of the School Corporation's compliance with the Reporting compliance requirement. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure that documentation will be maintained and available for audit and comply with the grant agreement and the Reporting compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-014 Subject: COVID-19 - Education Stabilization Fund - Cash Management 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): S425D200013, S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Cash Management Audit Findings: Material Weakness, Modified Opinion Condition and Context An effective internal control system was not designed nor implemented at the School Corporation to ensure compliance with the requirements related to the grant agreement and the Cash Management compliance requirement. The School Corporation requested reimbursement based off a calculation with the budgeted line items instead of actual grant expenses. For 19 of 20 reimbursement requests tested, the School Corporation was unable to provide adequate supporting documentation. Due to the lack of supporting documentation, it was not possible to determine if grant payments were reimbursements of expenditures or advance payments. 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: INDIANA STATE BOARD OF ACCOUNTS 54 SCOTT COUNTY SCHOOL DISTRICT 2 SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (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 200.305(b) states in part: "For non-Federal entities other than states, payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means. . . . (3) Reimbursement is the preferred method when the requirements in paragraph (b) cannot be met, when the Federal awarding agency sets a specific condition per ? 200.208, or when the non-Federal entity requests payment by reimbursement. . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in ?? 200.328 and 200.329. . . ." Cause Management had not designed nor implemented a system of internal controls that would have ensured compliance or that supporting documentation would have been maintained and available for audit related to the Cash Management compliance requirement. Effect The failure to retain and provide appropriate supporting documentation prevented the determination of the School Corporation's compliance with the Cash Management compliance requirement. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure that documentation will be maintained and available for audit and comply with the grant agreement and the Cash Management compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-016 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): S425D200013, S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion Condition and Context An effective internal control system was not designed nor implemented at the School Corporation to ensure compliance with the requirements related to the grant agreement and the Reporting compliance requirement. INDIANA STATE BOARD OF ACCOUNTS 57 SCOTT COUNTY SCHOOL DISTRICT 2 SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) The School Corporation filed the four required Elementary and Secondary School Emergency Relief (ESSER) annual data reports. However, none of the reports were supported by the School Corporation's records. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following: . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in ?? 200.328 and 200.329. . . . (3) Records that identify adequately the source and application of funds for federally funded activities. These records must contain information pertaining to Federal awards, authorizations, obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Cause Management had not designed nor implemented a system of internal controls that would have ensured that supporting documentation would have been maintained and available for audit related to the Reporting compliance requirement. INDIANA STATE BOARD OF ACCOUNTS 58 SCOTT COUNTY SCHOOL DISTRICT 2 SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Effect The failure to retain and provide appropriate supporting documentation prevented the determination of the School Corporation's compliance with the Reporting compliance requirement. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure that documentation will be maintained and available for audit and comply with the grant agreement and the Reporting compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-014 Subject: COVID-19 - Education Stabilization Fund - Cash Management 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): S425D200013, S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Cash Management Audit Findings: Material Weakness, Modified Opinion Condition and Context An effective internal control system was not designed nor implemented at the School Corporation to ensure compliance with the requirements related to the grant agreement and the Cash Management compliance requirement. The School Corporation requested reimbursement based off a calculation with the budgeted line items instead of actual grant expenses. For 19 of 20 reimbursement requests tested, the School Corporation was unable to provide adequate supporting documentation. Due to the lack of supporting documentation, it was not possible to determine if grant payments were reimbursements of expenditures or advance payments. 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: INDIANA STATE BOARD OF ACCOUNTS 54 SCOTT COUNTY SCHOOL DISTRICT 2 SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (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 200.305(b) states in part: "For non-Federal entities other than states, payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means. . . . (3) Reimbursement is the preferred method when the requirements in paragraph (b) cannot be met, when the Federal awarding agency sets a specific condition per ? 200.208, or when the non-Federal entity requests payment by reimbursement. . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in ?? 200.328 and 200.329. . . ." Cause Management had not designed nor implemented a system of internal controls that would have ensured compliance or that supporting documentation would have been maintained and available for audit related to the Cash Management compliance requirement. Effect The failure to retain and provide appropriate supporting documentation prevented the determination of the School Corporation's compliance with the Cash Management compliance requirement. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure that documentation will be maintained and available for audit and comply with the grant agreement and the Cash Management compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-016 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): S425D200013, S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion Condition and Context An effective internal control system was not designed nor implemented at the School Corporation to ensure compliance with the requirements related to the grant agreement and the Reporting compliance requirement. INDIANA STATE BOARD OF ACCOUNTS 57 SCOTT COUNTY SCHOOL DISTRICT 2 SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) The School Corporation filed the four required Elementary and Secondary School Emergency Relief (ESSER) annual data reports. However, none of the reports were supported by the School Corporation's records. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following: . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in ?? 200.328 and 200.329. . . . (3) Records that identify adequately the source and application of funds for federally funded activities. These records must contain information pertaining to Federal awards, authorizations, obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Cause Management had not designed nor implemented a system of internal controls that would have ensured that supporting documentation would have been maintained and available for audit related to the Reporting compliance requirement. INDIANA STATE BOARD OF ACCOUNTS 58 SCOTT COUNTY SCHOOL DISTRICT 2 SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Effect The failure to retain and provide appropriate supporting documentation prevented the determination of the School Corporation's compliance with the Reporting compliance requirement. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure that documentation will be maintained and available for audit and comply with the grant agreement and the Reporting compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-004 Subject: COVID-19 ? Education Stabilization Fund ? Reporting, Equipment and Real Property Management Federal Agency: Department of Education Federal Program: COVID-19 ? Education Stabilization Fund Assistance Listing Number: 84.425D Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting, Equipment and Real Property Management Audit Finding: Material Weakness Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following: (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in ?? 200.328 Financial reporting . . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Reporting and Equipment and Real Property Management compliance requirements. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with the compliance requirements listed above. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There were no questioned costs identified. Context: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirements. Reporting The School Corporation was required to submit two Annual Data Reports to the Indiana Department of Education (IDOE) to meet federal reporting requirements for ESSER grant awards. The first report was for the period of March 13, 2020 to September 30, 2020 and was due by January 21, 2021. The second report was for the period of October 1, 2020 to June 30, 2021 and was due by May 13, 2022. For both reports that were submitted, there was segregation of duties between the preparation of the report and the review and submission of the report by someone other than the preparer. However, the review was not sufficient to prevent the following error: ? In the second report, the amounts reported as expended did not agree to the underlying expenditure records of the School Corporation for ESSER I and ESSER II awards. Per discussion with the Treasurer, the amount in the report included expenditures through the report due date of May 13, 2022 rather than through the reporting period end date of June 30, 2021. This resulted in an overstatement of expenditures of $83,000 for ESSER I and $184,000 for ESSER II. Equipment and Real Property Management During our testing of equipment and real property management, it was noted that the School Corporation had not conducted a physical inventory during the last two years as required. Identification as a repeat finding: No. Recommendation: Reporting: We recommended someone other than the preparer of the report perform a documented review prior to submission to validate the accuracy and completeness of the data submitted. Equipment and Real Property Management: We recommended that the School Corporation conduct a physical inventory at least once every two years to comply with the federal and state requirements. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
FINDING 2022-004 Subject: COVID-19 ? Education Stabilization Fund ? Reporting, Equipment and Real Property Management Federal Agency: Department of Education Federal Program: COVID-19 ? Education Stabilization Fund Assistance Listing Number: 84.425D Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting, Equipment and Real Property Management Audit Finding: Material Weakness Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following: (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in ?? 200.328 Financial reporting . . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Reporting and Equipment and Real Property Management compliance requirements. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with the compliance requirements listed above. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There were no questioned costs identified. Context: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirements. Reporting The School Corporation was required to submit two Annual Data Reports to the Indiana Department of Education (IDOE) to meet federal reporting requirements for ESSER grant awards. The first report was for the period of March 13, 2020 to September 30, 2020 and was due by January 21, 2021. The second report was for the period of October 1, 2020 to June 30, 2021 and was due by May 13, 2022. For both reports that were submitted, there was segregation of duties between the preparation of the report and the review and submission of the report by someone other than the preparer. However, the review was not sufficient to prevent the following error: ? In the second report, the amounts reported as expended did not agree to the underlying expenditure records of the School Corporation for ESSER I and ESSER II awards. Per discussion with the Treasurer, the amount in the report included expenditures through the report due date of May 13, 2022 rather than through the reporting period end date of June 30, 2021. This resulted in an overstatement of expenditures of $83,000 for ESSER I and $184,000 for ESSER II. Equipment and Real Property Management During our testing of equipment and real property management, it was noted that the School Corporation had not conducted a physical inventory during the last two years as required. Identification as a repeat finding: No. Recommendation: Reporting: We recommended someone other than the preparer of the report perform a documented review prior to submission to validate the accuracy and completeness of the data submitted. Equipment and Real Property Management: We recommended that the School Corporation conduct a physical inventory at least once every two years to comply with the federal and state requirements. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
FINDING 2022-004 Subject: Title I Grants to Local Educational Agencies - Reporting Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listings Number: 84.010 Federal Award Numbers and Years (or Other Identifying Numbers): S010A190014 FY2021; S010A200014 FY2021 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters Condition and Context Form 9 Data The State uses the Form 9 data for their required submission of the average state per pupil expenditure data which is submitted to the National Center for Education Statistics. INDIANA STATE BOARD OF ACCOUNTS 26 SOUTH BEND COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) The Form 9 reports are comprised of the School Corporation's transactions recorded during the audit period. Payroll reports, which included summary level payroll data, were provided to a knowledgeable employee for review; however, the reports did not include sufficient detail to effectively review and verify the proper employees were paid from the correct fund, account, and object codes. Reimbursement Requests Requests for reimbursement are utilized by the School Corporation to request reimbursement for allowable expenses paid from Title I funds. Requests for reimbursement should be based on and supported by transactions recorded in the Title I funds of the School Corporation. Summary level reports were run from the School Corporation's financial system by the Director of Federal Grants for the period in which reimbursement was requested. The reports were then attached to the reimbursement request. The Title I Director then approved the reimbursement request prior to submission. Of the three reimbursement requests selected for testing, two could not be verified to the summary level detail attached to the reimbursement request nor to a detailed list of transactions. As the amount requested for reimbursement could not be traced to detailed records nor reports which accumulated or summarized the data, the accuracy and completeness of the reimbursement requests could not be verified. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 27 INDIANA STATE BOARD OF ACCOUNTS SOUTH BEND COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following: . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . . (3) Records that identify adequately the source and application of funds for federally funded activities. These records must contain information pertaining to Federal awards, authorizations, obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." 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, the amounts requested for reimbursement could not be reconciled to the School Corporation's underlying accounting records. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal 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 detailed supporting documentation is used and retained when reviewing Form 9 data and for all requests for reimbursements submitted on behalf of the Title I program funds. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-007 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Number: 84.425D Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion Condition and Context The School Corporation had not properly 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 required 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. The School Corporation submitted three reports during the audit period; however, a single employee prepared and submitted the reports without a review or oversight process in place to prevent or detect and correct errors. Additionally, two of the three reports tested, ESSER I Year 2 and ESSER II Year 1, were not supported by the School Corporation's records. The financial information provided was based on estimates and actual expenditures, and did not agree with the data submitted in the reports, nor to the School Corporation's records; therefore, the reports were determined to be inaccurate and incomplete. The key line item "Overall Expenditures" was tested on both reports. The ESSER I Year 2 report overall expenditures key line item was determined to be understated by $140,160. The ESSER II Year 1 overall expenditures key line item was determined to be overstated by $2,745,818. The lack of internal controls and noncompliance were systemic issues throughout the audit period. 33 INDIANA STATE BOARD OF ACCOUNTS SOUTH BEND COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following. . . ." (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. (3) Records that identify adequately the source and application of funds for federallyfunded activities. These records must contain information pertaining to Federal awards, authorizations, financial obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. . . ." 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. INDIANA STATE BOARD OF ACCOUNTS 34 SOUTH BEND COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, the amounts requested for reimbursement could not be reconciled to the School Corporation's underlying accounting records. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal 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 supporting documentation is used and retained for all required reports submitted on behalf of the Education Stabilization Fund program funds. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-007 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Number: 84.425D Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion Condition and Context The School Corporation had not properly 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 required 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. The School Corporation submitted three reports during the audit period; however, a single employee prepared and submitted the reports without a review or oversight process in place to prevent or detect and correct errors. Additionally, two of the three reports tested, ESSER I Year 2 and ESSER II Year 1, were not supported by the School Corporation's records. The financial information provided was based on estimates and actual expenditures, and did not agree with the data submitted in the reports, nor to the School Corporation's records; therefore, the reports were determined to be inaccurate and incomplete. The key line item "Overall Expenditures" was tested on both reports. The ESSER I Year 2 report overall expenditures key line item was determined to be understated by $140,160. The ESSER II Year 1 overall expenditures key line item was determined to be overstated by $2,745,818. The lack of internal controls and noncompliance were systemic issues throughout the audit period. 33 INDIANA STATE BOARD OF ACCOUNTS SOUTH BEND COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following. . . ." (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. (3) Records that identify adequately the source and application of funds for federallyfunded activities. These records must contain information pertaining to Federal awards, authorizations, financial obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. . . ." 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. INDIANA STATE BOARD OF ACCOUNTS 34 SOUTH BEND COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, the amounts requested for reimbursement could not be reconciled to the School Corporation's underlying accounting records. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal 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 supporting documentation is used and retained for all required reports submitted on behalf of the Education Stabilization Fund program funds. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
US Department of Education Education Stabilization Fund Program Name: Higher Education Emergency Relief Fund (HEERF), Student Aid Portion Assistance Listing #: 84.425E Finding: 2022 – 002 Reporting Condition: The College posted the required quarterly reports to their website more than 10 days after quarter-end. Q3 2021, $0 in emergency financial aid grants awarded; posted 34 days after quarter-end Q4 2021, $0 in emergency financial aid grants awarded; posted 11 days after quarter-end Q1 2022, $0 in emergency financial aid grants awarded; posted 11 days after quarter-end Cause: Personnel less familiar with federal reporting compliance requirements reviewed and completed Higher Education Emergency Relief Fund’s website posting requirements. Effect: Zero change reports were posted to the College’s website after the allowable 10 days after quarter-end. Criteria: Under the May 13, 2021 Notice of Public Posting Requirement of Grant Information for Higher Education Emergency Relief Fund (HEERF) Grantees by the Education Department of the Office of Postsecondary Education in the US Department of Education, institutions receiving HEERF funds must promptly and timely post specific information on the institution’s primary website. This information must appear in a format and location that is easily accessible to the public. It must be updated no later than 10 days after the end of each calendar quarter. The Department is exercising this reporting authority under 2 CFR 200.328 and 2 CFR 200.329. Recommendation: The College should implement reporting procedures specific to each federal award and based on those awards specific reporting compliance requirements. Views of responsible personnel and planned corrective actions: The College agrees with this finding. The College will review existing reporting procedures and ensure appropriate adjustments are made for each federal award based on those awards’ specific reporting compliance requirements. Please refer to corrective action plan on page 13.
FINDING 2022-003 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Number: 84.425D Federal Award Numbers and Years (or Other Identifying Numbers): S425D200-013, S425D210-013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion Condition and Context The School Corporation had not properly 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 required 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. The annual data reports were compiled, prepared, and submitted by three different staff members; however, this process did not allow for the prevention, or detection and correction, of errors. During the audit period, the School Corporation completed and submitted three reports. For two of the three reports tested, ESSER I, Year 2 and ESSER II, Year 1, the reports were not supported by the School Corporation's records. The financial information provided did not agree to the data submitted in the reports; therefore, we could not determine the accuracy or completeness of the 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). . . ." INDIANA STATE BOARD OF ACCOUNTS 26 METROPOLITAN SCHOOL DISTRICT OF LAWRENCE TOWNSHIP SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following: . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." 2 CFR 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 34 CFR 76.731 states: "A State and a subgrantee shall keep records to show its compliance with program requirements." Cause A proper system of internal controls 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, the amounts reported to the IDOE in the annual data reports could not be reconciled to the School Corporation's underlying accounting records. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal 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 supporting documentation is used and retained for all required reports submitted on behalf of the COVID-19 - Education Stabilization Fund program funds. INDIANA STATE BOARD OF ACCOUNTS 27 METROPOLITAN SCHOOL DISTRICT OF LAWRENCE TOWNSHIP SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-003 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Number: 84.425D Federal Award Numbers and Years (or Other Identifying Numbers): S425D200-013, S425D210-013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion Condition and Context The School Corporation had not properly 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 required 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. The annual data reports were compiled, prepared, and submitted by three different staff members; however, this process did not allow for the prevention, or detection and correction, of errors. During the audit period, the School Corporation completed and submitted three reports. For two of the three reports tested, ESSER I, Year 2 and ESSER II, Year 1, the reports were not supported by the School Corporation's records. The financial information provided did not agree to the data submitted in the reports; therefore, we could not determine the accuracy or completeness of the 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). . . ." INDIANA STATE BOARD OF ACCOUNTS 26 METROPOLITAN SCHOOL DISTRICT OF LAWRENCE TOWNSHIP SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following: . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." 2 CFR 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 34 CFR 76.731 states: "A State and a subgrantee shall keep records to show its compliance with program requirements." Cause A proper system of internal controls 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, the amounts reported to the IDOE in the annual data reports could not be reconciled to the School Corporation's underlying accounting records. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal 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 supporting documentation is used and retained for all required reports submitted on behalf of the COVID-19 - Education Stabilization Fund program funds. INDIANA STATE BOARD OF ACCOUNTS 27 METROPOLITAN SCHOOL DISTRICT OF LAWRENCE TOWNSHIP SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-003 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Number: 84.425D Federal Award Numbers and Years (or Other Identifying Numbers): S425D200-013, S425D210-013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion Condition and Context The School Corporation had not properly 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 required 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. The annual data reports were compiled, prepared, and submitted by three different staff members; however, this process did not allow for the prevention, or detection and correction, of errors. During the audit period, the School Corporation completed and submitted three reports. For two of the three reports tested, ESSER I, Year 2 and ESSER II, Year 1, the reports were not supported by the School Corporation's records. The financial information provided did not agree to the data submitted in the reports; therefore, we could not determine the accuracy or completeness of the 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). . . ." INDIANA STATE BOARD OF ACCOUNTS 26 METROPOLITAN SCHOOL DISTRICT OF LAWRENCE TOWNSHIP SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following: . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." 2 CFR 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 34 CFR 76.731 states: "A State and a subgrantee shall keep records to show its compliance with program requirements." Cause A proper system of internal controls 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, the amounts reported to the IDOE in the annual data reports could not be reconciled to the School Corporation's underlying accounting records. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal 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 supporting documentation is used and retained for all required reports submitted on behalf of the COVID-19 - Education Stabilization Fund program funds. INDIANA STATE BOARD OF ACCOUNTS 27 METROPOLITAN SCHOOL DISTRICT OF LAWRENCE TOWNSHIP SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 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 Number: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion Condition and Context The School Corporation had not properly 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 required 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 and 200.329. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Cause A proper system of internal controls was not designed by management of the School Corporation. 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, 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 timely and accurately. 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 Number: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion Condition and Context The School Corporation had not properly 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 required 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 and 200.329. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Cause A proper system of internal controls was not designed by management of the School Corporation. 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, 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 timely and accurately. 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 Number: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion Condition and Context The School Corporation had not properly 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 required 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 and 200.329. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Cause A proper system of internal controls was not designed by management of the School Corporation. 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, 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 timely and accurately. 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 Number: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion Condition and Context The School Corporation had not properly 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 required 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 and 200.329. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Cause A proper system of internal controls was not designed by management of the School Corporation. 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, 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 timely and accurately. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Finding Number 2022-008 Prior Year Finding Number N/A Compliance Requirement: Allowable Costs/Costs Principles Program: U.S. Department of Education Title I Grants to Local Educational Agencies ALN #: 84.010 Award #: Various Award Period: Various COVID-19 – Governor’s Emergency Education Relief (GEER) ALN #: 84.425C Award #: Various Award Period: Various COVID-19 – Elementary and Secondary School Emergency Relief (ESSR) Fund ALN #: 84.425D Award #: Various Award Period: Various COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSR) ALN #: 84.425U Award #: 211941 Award Period: 03/24/2021 – 09/30/2023 COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief – Homeless Children and Youth ALN #: 84.425W Award #: Various Award Period: Various Criteria – In accordance with §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following: 1. Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received. 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 §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance. 3. Records that identify adequately the source and application of funds for federally funded activities. 4. Effective control over, and accountability for, all funds, property, and other assets. The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Further, CFR Section 200.510 (b) requires 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 2 CFR section 200.502, Basis for determining Federal awards expended. Condition – The amounts recorded in the Schedule of Expenditures of Federal Awards (SEFA) agree to the total amount recorded in the general ledger. The summary level payroll transactions recorded in the general ledger could not be reconciled to the transaction level detail provided from the payroll system. When comparing the two populations, we identified the following differences: • ALN 84.425 - For ALN 84.425 sub-program D, we noted a variance of $1,828,609. Total payroll expenditures per the payroll system details amounted to $18,437,724 whereas payroll expenditures per SEFA amounted to $16,609,116. In addition to the above, for ALN 84.425 sub-program U, we noted a variance of $301,432. Total payroll expenditures per the payroll system details amounted to $3,607,738 whereas payroll expenditures per the SEFA amounted to $3,909,170. • ALN 84.010 - We noted a variance of $752,503. Total payroll expenditures per the payroll system details amounted to $40,549,584 whereas payroll expenditures per the SEFA amounted to $39,797,081. Questioned Costs – Not Determinable. Context – This is a condition identified per review of the School System’s population completeness over the compliance requirements for each program. The prevalence of these findings is detailed in the condition section above. Effect – The SEFA may not be completely and accurately stated. In addition, the lack of established internal controls policies and procedures to ensure the SEFA is completely and accurately stated can lead to noncompliance with federal statutes, regulations, and provisions of grant agreements. Cause – The School System did not adhere to their internal policies and procedures to ensure the accuracy of the SEFA. Recommendation – We recommend that the School System develop policies and procedures and enhance their existing reconciliation process to ensure the completeness and accuracy of the SEFA, and that amounts reported on the SEFA are supported by transaction level detail. Views of Responsible Officials – The School System does not concur with the auditor’s findings and recommendations. The total expenditures for all federal programs recorded in the Schedule of Expenditures for Federal Awards are accurately presented and tie to the general ledger. The payroll sub-ledger is corrected before posting to the general ledger every two weeks. The resulting differences are most often immaterial but can be traced to corrections made by the Accounting Office after payroll is reviewed by the grants Restricted Funds Supervisor to ensure payroll is not posted to expired grants. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report. BDO Response – We have reviewed management’s response and our finding remains as indicated, since we could not validate the details of the differences.
Finding Number 2022-008 Prior Year Finding Number N/A Compliance Requirement: Allowable Costs/Costs Principles Program: U.S. Department of Education Title I Grants to Local Educational Agencies ALN #: 84.010 Award #: Various Award Period: Various COVID-19 – Governor’s Emergency Education Relief (GEER) ALN #: 84.425C Award #: Various Award Period: Various COVID-19 – Elementary and Secondary School Emergency Relief (ESSR) Fund ALN #: 84.425D Award #: Various Award Period: Various COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSR) ALN #: 84.425U Award #: 211941 Award Period: 03/24/2021 – 09/30/2023 COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief – Homeless Children and Youth ALN #: 84.425W Award #: Various Award Period: Various Criteria – In accordance with §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following: 1. Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received. 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 §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance. 3. Records that identify adequately the source and application of funds for federally funded activities. 4. Effective control over, and accountability for, all funds, property, and other assets. The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Further, CFR Section 200.510 (b) requires 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 2 CFR section 200.502, Basis for determining Federal awards expended. Condition – The amounts recorded in the Schedule of Expenditures of Federal Awards (SEFA) agree to the total amount recorded in the general ledger. The summary level payroll transactions recorded in the general ledger could not be reconciled to the transaction level detail provided from the payroll system. When comparing the two populations, we identified the following differences: • ALN 84.425 - For ALN 84.425 sub-program D, we noted a variance of $1,828,609. Total payroll expenditures per the payroll system details amounted to $18,437,724 whereas payroll expenditures per SEFA amounted to $16,609,116. In addition to the above, for ALN 84.425 sub-program U, we noted a variance of $301,432. Total payroll expenditures per the payroll system details amounted to $3,607,738 whereas payroll expenditures per the SEFA amounted to $3,909,170. • ALN 84.010 - We noted a variance of $752,503. Total payroll expenditures per the payroll system details amounted to $40,549,584 whereas payroll expenditures per the SEFA amounted to $39,797,081. Questioned Costs – Not Determinable. Context – This is a condition identified per review of the School System’s population completeness over the compliance requirements for each program. The prevalence of these findings is detailed in the condition section above. Effect – The SEFA may not be completely and accurately stated. In addition, the lack of established internal controls policies and procedures to ensure the SEFA is completely and accurately stated can lead to noncompliance with federal statutes, regulations, and provisions of grant agreements. Cause – The School System did not adhere to their internal policies and procedures to ensure the accuracy of the SEFA. Recommendation – We recommend that the School System develop policies and procedures and enhance their existing reconciliation process to ensure the completeness and accuracy of the SEFA, and that amounts reported on the SEFA are supported by transaction level detail. Views of Responsible Officials – The School System does not concur with the auditor’s findings and recommendations. The total expenditures for all federal programs recorded in the Schedule of Expenditures for Federal Awards are accurately presented and tie to the general ledger. The payroll sub-ledger is corrected before posting to the general ledger every two weeks. The resulting differences are most often immaterial but can be traced to corrections made by the Accounting Office after payroll is reviewed by the grants Restricted Funds Supervisor to ensure payroll is not posted to expired grants. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report. BDO Response – We have reviewed management’s response and our finding remains as indicated, since we could not validate the details of the differences.
Finding Number 2022-008 Prior Year Finding Number N/A Compliance Requirement: Allowable Costs/Costs Principles Program: U.S. Department of Education Title I Grants to Local Educational Agencies ALN #: 84.010 Award #: Various Award Period: Various COVID-19 – Governor’s Emergency Education Relief (GEER) ALN #: 84.425C Award #: Various Award Period: Various COVID-19 – Elementary and Secondary School Emergency Relief (ESSR) Fund ALN #: 84.425D Award #: Various Award Period: Various COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSR) ALN #: 84.425U Award #: 211941 Award Period: 03/24/2021 – 09/30/2023 COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief – Homeless Children and Youth ALN #: 84.425W Award #: Various Award Period: Various Criteria – In accordance with §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following: 1. Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received. 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 §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance. 3. Records that identify adequately the source and application of funds for federally funded activities. 4. Effective control over, and accountability for, all funds, property, and other assets. The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Further, CFR Section 200.510 (b) requires 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 2 CFR section 200.502, Basis for determining Federal awards expended. Condition – The amounts recorded in the Schedule of Expenditures of Federal Awards (SEFA) agree to the total amount recorded in the general ledger. The summary level payroll transactions recorded in the general ledger could not be reconciled to the transaction level detail provided from the payroll system. When comparing the two populations, we identified the following differences: • ALN 84.425 - For ALN 84.425 sub-program D, we noted a variance of $1,828,609. Total payroll expenditures per the payroll system details amounted to $18,437,724 whereas payroll expenditures per SEFA amounted to $16,609,116. In addition to the above, for ALN 84.425 sub-program U, we noted a variance of $301,432. Total payroll expenditures per the payroll system details amounted to $3,607,738 whereas payroll expenditures per the SEFA amounted to $3,909,170. • ALN 84.010 - We noted a variance of $752,503. Total payroll expenditures per the payroll system details amounted to $40,549,584 whereas payroll expenditures per the SEFA amounted to $39,797,081. Questioned Costs – Not Determinable. Context – This is a condition identified per review of the School System’s population completeness over the compliance requirements for each program. The prevalence of these findings is detailed in the condition section above. Effect – The SEFA may not be completely and accurately stated. In addition, the lack of established internal controls policies and procedures to ensure the SEFA is completely and accurately stated can lead to noncompliance with federal statutes, regulations, and provisions of grant agreements. Cause – The School System did not adhere to their internal policies and procedures to ensure the accuracy of the SEFA. Recommendation – We recommend that the School System develop policies and procedures and enhance their existing reconciliation process to ensure the completeness and accuracy of the SEFA, and that amounts reported on the SEFA are supported by transaction level detail. Views of Responsible Officials – The School System does not concur with the auditor’s findings and recommendations. The total expenditures for all federal programs recorded in the Schedule of Expenditures for Federal Awards are accurately presented and tie to the general ledger. The payroll sub-ledger is corrected before posting to the general ledger every two weeks. The resulting differences are most often immaterial but can be traced to corrections made by the Accounting Office after payroll is reviewed by the grants Restricted Funds Supervisor to ensure payroll is not posted to expired grants. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report. BDO Response – We have reviewed management’s response and our finding remains as indicated, since we could not validate the details of the differences.
Finding Number 2022-008 Prior Year Finding Number N/A Compliance Requirement: Allowable Costs/Costs Principles Program: U.S. Department of Education Title I Grants to Local Educational Agencies ALN #: 84.010 Award #: Various Award Period: Various COVID-19 – Governor’s Emergency Education Relief (GEER) ALN #: 84.425C Award #: Various Award Period: Various COVID-19 – Elementary and Secondary School Emergency Relief (ESSR) Fund ALN #: 84.425D Award #: Various Award Period: Various COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSR) ALN #: 84.425U Award #: 211941 Award Period: 03/24/2021 – 09/30/2023 COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief – Homeless Children and Youth ALN #: 84.425W Award #: Various Award Period: Various Criteria – In accordance with §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following: 1. Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received. 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 §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance. 3. Records that identify adequately the source and application of funds for federally funded activities. 4. Effective control over, and accountability for, all funds, property, and other assets. The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Further, CFR Section 200.510 (b) requires 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 2 CFR section 200.502, Basis for determining Federal awards expended. Condition – The amounts recorded in the Schedule of Expenditures of Federal Awards (SEFA) agree to the total amount recorded in the general ledger. The summary level payroll transactions recorded in the general ledger could not be reconciled to the transaction level detail provided from the payroll system. When comparing the two populations, we identified the following differences: • ALN 84.425 - For ALN 84.425 sub-program D, we noted a variance of $1,828,609. Total payroll expenditures per the payroll system details amounted to $18,437,724 whereas payroll expenditures per SEFA amounted to $16,609,116. In addition to the above, for ALN 84.425 sub-program U, we noted a variance of $301,432. Total payroll expenditures per the payroll system details amounted to $3,607,738 whereas payroll expenditures per the SEFA amounted to $3,909,170. • ALN 84.010 - We noted a variance of $752,503. Total payroll expenditures per the payroll system details amounted to $40,549,584 whereas payroll expenditures per the SEFA amounted to $39,797,081. Questioned Costs – Not Determinable. Context – This is a condition identified per review of the School System’s population completeness over the compliance requirements for each program. The prevalence of these findings is detailed in the condition section above. Effect – The SEFA may not be completely and accurately stated. In addition, the lack of established internal controls policies and procedures to ensure the SEFA is completely and accurately stated can lead to noncompliance with federal statutes, regulations, and provisions of grant agreements. Cause – The School System did not adhere to their internal policies and procedures to ensure the accuracy of the SEFA. Recommendation – We recommend that the School System develop policies and procedures and enhance their existing reconciliation process to ensure the completeness and accuracy of the SEFA, and that amounts reported on the SEFA are supported by transaction level detail. Views of Responsible Officials – The School System does not concur with the auditor’s findings and recommendations. The total expenditures for all federal programs recorded in the Schedule of Expenditures for Federal Awards are accurately presented and tie to the general ledger. The payroll sub-ledger is corrected before posting to the general ledger every two weeks. The resulting differences are most often immaterial but can be traced to corrections made by the Accounting Office after payroll is reviewed by the grants Restricted Funds Supervisor to ensure payroll is not posted to expired grants. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report. BDO Response – We have reviewed management’s response and our finding remains as indicated, since we could not validate the details of the differences.
Finding Number 2022-008 Prior Year Finding Number N/A Compliance Requirement: Allowable Costs/Costs Principles Program: U.S. Department of Education Title I Grants to Local Educational Agencies ALN #: 84.010 Award #: Various Award Period: Various COVID-19 – Governor’s Emergency Education Relief (GEER) ALN #: 84.425C Award #: Various Award Period: Various COVID-19 – Elementary and Secondary School Emergency Relief (ESSR) Fund ALN #: 84.425D Award #: Various Award Period: Various COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSR) ALN #: 84.425U Award #: 211941 Award Period: 03/24/2021 – 09/30/2023 COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief – Homeless Children and Youth ALN #: 84.425W Award #: Various Award Period: Various Criteria – In accordance with §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following: 1. Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received. 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 §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance. 3. Records that identify adequately the source and application of funds for federally funded activities. 4. Effective control over, and accountability for, all funds, property, and other assets. The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Further, CFR Section 200.510 (b) requires 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 2 CFR section 200.502, Basis for determining Federal awards expended. Condition – The amounts recorded in the Schedule of Expenditures of Federal Awards (SEFA) agree to the total amount recorded in the general ledger. The summary level payroll transactions recorded in the general ledger could not be reconciled to the transaction level detail provided from the payroll system. When comparing the two populations, we identified the following differences: • ALN 84.425 - For ALN 84.425 sub-program D, we noted a variance of $1,828,609. Total payroll expenditures per the payroll system details amounted to $18,437,724 whereas payroll expenditures per SEFA amounted to $16,609,116. In addition to the above, for ALN 84.425 sub-program U, we noted a variance of $301,432. Total payroll expenditures per the payroll system details amounted to $3,607,738 whereas payroll expenditures per the SEFA amounted to $3,909,170. • ALN 84.010 - We noted a variance of $752,503. Total payroll expenditures per the payroll system details amounted to $40,549,584 whereas payroll expenditures per the SEFA amounted to $39,797,081. Questioned Costs – Not Determinable. Context – This is a condition identified per review of the School System’s population completeness over the compliance requirements for each program. The prevalence of these findings is detailed in the condition section above. Effect – The SEFA may not be completely and accurately stated. In addition, the lack of established internal controls policies and procedures to ensure the SEFA is completely and accurately stated can lead to noncompliance with federal statutes, regulations, and provisions of grant agreements. Cause – The School System did not adhere to their internal policies and procedures to ensure the accuracy of the SEFA. Recommendation – We recommend that the School System develop policies and procedures and enhance their existing reconciliation process to ensure the completeness and accuracy of the SEFA, and that amounts reported on the SEFA are supported by transaction level detail. Views of Responsible Officials – The School System does not concur with the auditor’s findings and recommendations. The total expenditures for all federal programs recorded in the Schedule of Expenditures for Federal Awards are accurately presented and tie to the general ledger. The payroll sub-ledger is corrected before posting to the general ledger every two weeks. The resulting differences are most often immaterial but can be traced to corrections made by the Accounting Office after payroll is reviewed by the grants Restricted Funds Supervisor to ensure payroll is not posted to expired grants. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report. BDO Response – We have reviewed management’s response and our finding remains as indicated, since we could not validate the details of the differences.
Finding Number 2022-008 Prior Year Finding Number N/A Compliance Requirement: Allowable Costs/Costs Principles Program: U.S. Department of Education Title I Grants to Local Educational Agencies ALN #: 84.010 Award #: Various Award Period: Various COVID-19 – Governor’s Emergency Education Relief (GEER) ALN #: 84.425C Award #: Various Award Period: Various COVID-19 – Elementary and Secondary School Emergency Relief (ESSR) Fund ALN #: 84.425D Award #: Various Award Period: Various COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSR) ALN #: 84.425U Award #: 211941 Award Period: 03/24/2021 – 09/30/2023 COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief – Homeless Children and Youth ALN #: 84.425W Award #: Various Award Period: Various Criteria – In accordance with §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following: 1. Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received. 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 §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance. 3. Records that identify adequately the source and application of funds for federally funded activities. 4. Effective control over, and accountability for, all funds, property, and other assets. The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Further, CFR Section 200.510 (b) requires 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 2 CFR section 200.502, Basis for determining Federal awards expended. Condition – The amounts recorded in the Schedule of Expenditures of Federal Awards (SEFA) agree to the total amount recorded in the general ledger. The summary level payroll transactions recorded in the general ledger could not be reconciled to the transaction level detail provided from the payroll system. When comparing the two populations, we identified the following differences: • ALN 84.425 - For ALN 84.425 sub-program D, we noted a variance of $1,828,609. Total payroll expenditures per the payroll system details amounted to $18,437,724 whereas payroll expenditures per SEFA amounted to $16,609,116. In addition to the above, for ALN 84.425 sub-program U, we noted a variance of $301,432. Total payroll expenditures per the payroll system details amounted to $3,607,738 whereas payroll expenditures per the SEFA amounted to $3,909,170. • ALN 84.010 - We noted a variance of $752,503. Total payroll expenditures per the payroll system details amounted to $40,549,584 whereas payroll expenditures per the SEFA amounted to $39,797,081. Questioned Costs – Not Determinable. Context – This is a condition identified per review of the School System’s population completeness over the compliance requirements for each program. The prevalence of these findings is detailed in the condition section above. Effect – The SEFA may not be completely and accurately stated. In addition, the lack of established internal controls policies and procedures to ensure the SEFA is completely and accurately stated can lead to noncompliance with federal statutes, regulations, and provisions of grant agreements. Cause – The School System did not adhere to their internal policies and procedures to ensure the accuracy of the SEFA. Recommendation – We recommend that the School System develop policies and procedures and enhance their existing reconciliation process to ensure the completeness and accuracy of the SEFA, and that amounts reported on the SEFA are supported by transaction level detail. Views of Responsible Officials – The School System does not concur with the auditor’s findings and recommendations. The total expenditures for all federal programs recorded in the Schedule of Expenditures for Federal Awards are accurately presented and tie to the general ledger. The payroll sub-ledger is corrected before posting to the general ledger every two weeks. The resulting differences are most often immaterial but can be traced to corrections made by the Accounting Office after payroll is reviewed by the grants Restricted Funds Supervisor to ensure payroll is not posted to expired grants. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report. BDO Response – We have reviewed management’s response and our finding remains as indicated, since we could not validate the details of the differences.
Finding Number 2022-008 Prior Year Finding Number N/A Compliance Requirement: Allowable Costs/Costs Principles Program: U.S. Department of Education Title I Grants to Local Educational Agencies ALN #: 84.010 Award #: Various Award Period: Various COVID-19 – Governor’s Emergency Education Relief (GEER) ALN #: 84.425C Award #: Various Award Period: Various COVID-19 – Elementary and Secondary School Emergency Relief (ESSR) Fund ALN #: 84.425D Award #: Various Award Period: Various COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSR) ALN #: 84.425U Award #: 211941 Award Period: 03/24/2021 – 09/30/2023 COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief – Homeless Children and Youth ALN #: 84.425W Award #: Various Award Period: Various Criteria – In accordance with §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following: 1. Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received. 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 §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance. 3. Records that identify adequately the source and application of funds for federally funded activities. 4. Effective control over, and accountability for, all funds, property, and other assets. The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Further, CFR Section 200.510 (b) requires 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 2 CFR section 200.502, Basis for determining Federal awards expended. Condition – The amounts recorded in the Schedule of Expenditures of Federal Awards (SEFA) agree to the total amount recorded in the general ledger. The summary level payroll transactions recorded in the general ledger could not be reconciled to the transaction level detail provided from the payroll system. When comparing the two populations, we identified the following differences: • ALN 84.425 - For ALN 84.425 sub-program D, we noted a variance of $1,828,609. Total payroll expenditures per the payroll system details amounted to $18,437,724 whereas payroll expenditures per SEFA amounted to $16,609,116. In addition to the above, for ALN 84.425 sub-program U, we noted a variance of $301,432. Total payroll expenditures per the payroll system details amounted to $3,607,738 whereas payroll expenditures per the SEFA amounted to $3,909,170. • ALN 84.010 - We noted a variance of $752,503. Total payroll expenditures per the payroll system details amounted to $40,549,584 whereas payroll expenditures per the SEFA amounted to $39,797,081. Questioned Costs – Not Determinable. Context – This is a condition identified per review of the School System’s population completeness over the compliance requirements for each program. The prevalence of these findings is detailed in the condition section above. Effect – The SEFA may not be completely and accurately stated. In addition, the lack of established internal controls policies and procedures to ensure the SEFA is completely and accurately stated can lead to noncompliance with federal statutes, regulations, and provisions of grant agreements. Cause – The School System did not adhere to their internal policies and procedures to ensure the accuracy of the SEFA. Recommendation – We recommend that the School System develop policies and procedures and enhance their existing reconciliation process to ensure the completeness and accuracy of the SEFA, and that amounts reported on the SEFA are supported by transaction level detail. Views of Responsible Officials – The School System does not concur with the auditor’s findings and recommendations. The total expenditures for all federal programs recorded in the Schedule of Expenditures for Federal Awards are accurately presented and tie to the general ledger. The payroll sub-ledger is corrected before posting to the general ledger every two weeks. The resulting differences are most often immaterial but can be traced to corrections made by the Accounting Office after payroll is reviewed by the grants Restricted Funds Supervisor to ensure payroll is not posted to expired grants. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report. BDO Response – We have reviewed management’s response and our finding remains as indicated, since we could not validate the details of the differences.
Finding Number 2022-008 Prior Year Finding Number N/A Compliance Requirement: Allowable Costs/Costs Principles Program: U.S. Department of Education Title I Grants to Local Educational Agencies ALN #: 84.010 Award #: Various Award Period: Various COVID-19 – Governor’s Emergency Education Relief (GEER) ALN #: 84.425C Award #: Various Award Period: Various COVID-19 – Elementary and Secondary School Emergency Relief (ESSR) Fund ALN #: 84.425D Award #: Various Award Period: Various COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSR) ALN #: 84.425U Award #: 211941 Award Period: 03/24/2021 – 09/30/2023 COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief – Homeless Children and Youth ALN #: 84.425W Award #: Various Award Period: Various Criteria – In accordance with §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following: 1. Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received. 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 §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance. 3. Records that identify adequately the source and application of funds for federally funded activities. 4. Effective control over, and accountability for, all funds, property, and other assets. The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Further, CFR Section 200.510 (b) requires 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 2 CFR section 200.502, Basis for determining Federal awards expended. Condition – The amounts recorded in the Schedule of Expenditures of Federal Awards (SEFA) agree to the total amount recorded in the general ledger. The summary level payroll transactions recorded in the general ledger could not be reconciled to the transaction level detail provided from the payroll system. When comparing the two populations, we identified the following differences: • ALN 84.425 - For ALN 84.425 sub-program D, we noted a variance of $1,828,609. Total payroll expenditures per the payroll system details amounted to $18,437,724 whereas payroll expenditures per SEFA amounted to $16,609,116. In addition to the above, for ALN 84.425 sub-program U, we noted a variance of $301,432. Total payroll expenditures per the payroll system details amounted to $3,607,738 whereas payroll expenditures per the SEFA amounted to $3,909,170. • ALN 84.010 - We noted a variance of $752,503. Total payroll expenditures per the payroll system details amounted to $40,549,584 whereas payroll expenditures per the SEFA amounted to $39,797,081. Questioned Costs – Not Determinable. Context – This is a condition identified per review of the School System’s population completeness over the compliance requirements for each program. The prevalence of these findings is detailed in the condition section above. Effect – The SEFA may not be completely and accurately stated. In addition, the lack of established internal controls policies and procedures to ensure the SEFA is completely and accurately stated can lead to noncompliance with federal statutes, regulations, and provisions of grant agreements. Cause – The School System did not adhere to their internal policies and procedures to ensure the accuracy of the SEFA. Recommendation – We recommend that the School System develop policies and procedures and enhance their existing reconciliation process to ensure the completeness and accuracy of the SEFA, and that amounts reported on the SEFA are supported by transaction level detail. Views of Responsible Officials – The School System does not concur with the auditor’s findings and recommendations. The total expenditures for all federal programs recorded in the Schedule of Expenditures for Federal Awards are accurately presented and tie to the general ledger. The payroll sub-ledger is corrected before posting to the general ledger every two weeks. The resulting differences are most often immaterial but can be traced to corrections made by the Accounting Office after payroll is reviewed by the grants Restricted Funds Supervisor to ensure payroll is not posted to expired grants. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report. BDO Response – We have reviewed management’s response and our finding remains as indicated, since we could not validate the details of the differences.
Finding Number 2022-008 Prior Year Finding Number N/A Compliance Requirement: Allowable Costs/Costs Principles Program: U.S. Department of Education Title I Grants to Local Educational Agencies ALN #: 84.010 Award #: Various Award Period: Various COVID-19 – Governor’s Emergency Education Relief (GEER) ALN #: 84.425C Award #: Various Award Period: Various COVID-19 – Elementary and Secondary School Emergency Relief (ESSR) Fund ALN #: 84.425D Award #: Various Award Period: Various COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSR) ALN #: 84.425U Award #: 211941 Award Period: 03/24/2021 – 09/30/2023 COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief – Homeless Children and Youth ALN #: 84.425W Award #: Various Award Period: Various Criteria – In accordance with §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following: 1. Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received. 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 §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance. 3. Records that identify adequately the source and application of funds for federally funded activities. 4. Effective control over, and accountability for, all funds, property, and other assets. The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Further, CFR Section 200.510 (b) requires 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 2 CFR section 200.502, Basis for determining Federal awards expended. Condition – The amounts recorded in the Schedule of Expenditures of Federal Awards (SEFA) agree to the total amount recorded in the general ledger. The summary level payroll transactions recorded in the general ledger could not be reconciled to the transaction level detail provided from the payroll system. When comparing the two populations, we identified the following differences: • ALN 84.425 - For ALN 84.425 sub-program D, we noted a variance of $1,828,609. Total payroll expenditures per the payroll system details amounted to $18,437,724 whereas payroll expenditures per SEFA amounted to $16,609,116. In addition to the above, for ALN 84.425 sub-program U, we noted a variance of $301,432. Total payroll expenditures per the payroll system details amounted to $3,607,738 whereas payroll expenditures per the SEFA amounted to $3,909,170. • ALN 84.010 - We noted a variance of $752,503. Total payroll expenditures per the payroll system details amounted to $40,549,584 whereas payroll expenditures per the SEFA amounted to $39,797,081. Questioned Costs – Not Determinable. Context – This is a condition identified per review of the School System’s population completeness over the compliance requirements for each program. The prevalence of these findings is detailed in the condition section above. Effect – The SEFA may not be completely and accurately stated. In addition, the lack of established internal controls policies and procedures to ensure the SEFA is completely and accurately stated can lead to noncompliance with federal statutes, regulations, and provisions of grant agreements. Cause – The School System did not adhere to their internal policies and procedures to ensure the accuracy of the SEFA. Recommendation – We recommend that the School System develop policies and procedures and enhance their existing reconciliation process to ensure the completeness and accuracy of the SEFA, and that amounts reported on the SEFA are supported by transaction level detail. Views of Responsible Officials – The School System does not concur with the auditor’s findings and recommendations. The total expenditures for all federal programs recorded in the Schedule of Expenditures for Federal Awards are accurately presented and tie to the general ledger. The payroll sub-ledger is corrected before posting to the general ledger every two weeks. The resulting differences are most often immaterial but can be traced to corrections made by the Accounting Office after payroll is reviewed by the grants Restricted Funds Supervisor to ensure payroll is not posted to expired grants. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report. BDO Response – We have reviewed management’s response and our finding remains as indicated, since we could not validate the details of the differences.
Finding Number 2022-008 Prior Year Finding Number N/A Compliance Requirement: Allowable Costs/Costs Principles Program: U.S. Department of Education Title I Grants to Local Educational Agencies ALN #: 84.010 Award #: Various Award Period: Various COVID-19 – Governor’s Emergency Education Relief (GEER) ALN #: 84.425C Award #: Various Award Period: Various COVID-19 – Elementary and Secondary School Emergency Relief (ESSR) Fund ALN #: 84.425D Award #: Various Award Period: Various COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSR) ALN #: 84.425U Award #: 211941 Award Period: 03/24/2021 – 09/30/2023 COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief – Homeless Children and Youth ALN #: 84.425W Award #: Various Award Period: Various Criteria – In accordance with §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following: 1. Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received. 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 §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance. 3. Records that identify adequately the source and application of funds for federally funded activities. 4. Effective control over, and accountability for, all funds, property, and other assets. The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Further, CFR Section 200.510 (b) requires 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 2 CFR section 200.502, Basis for determining Federal awards expended. Condition – The amounts recorded in the Schedule of Expenditures of Federal Awards (SEFA) agree to the total amount recorded in the general ledger. The summary level payroll transactions recorded in the general ledger could not be reconciled to the transaction level detail provided from the payroll system. When comparing the two populations, we identified the following differences: • ALN 84.425 - For ALN 84.425 sub-program D, we noted a variance of $1,828,609. Total payroll expenditures per the payroll system details amounted to $18,437,724 whereas payroll expenditures per SEFA amounted to $16,609,116. In addition to the above, for ALN 84.425 sub-program U, we noted a variance of $301,432. Total payroll expenditures per the payroll system details amounted to $3,607,738 whereas payroll expenditures per the SEFA amounted to $3,909,170. • ALN 84.010 - We noted a variance of $752,503. Total payroll expenditures per the payroll system details amounted to $40,549,584 whereas payroll expenditures per the SEFA amounted to $39,797,081. Questioned Costs – Not Determinable. Context – This is a condition identified per review of the School System’s population completeness over the compliance requirements for each program. The prevalence of these findings is detailed in the condition section above. Effect – The SEFA may not be completely and accurately stated. In addition, the lack of established internal controls policies and procedures to ensure the SEFA is completely and accurately stated can lead to noncompliance with federal statutes, regulations, and provisions of grant agreements. Cause – The School System did not adhere to their internal policies and procedures to ensure the accuracy of the SEFA. Recommendation – We recommend that the School System develop policies and procedures and enhance their existing reconciliation process to ensure the completeness and accuracy of the SEFA, and that amounts reported on the SEFA are supported by transaction level detail. Views of Responsible Officials – The School System does not concur with the auditor’s findings and recommendations. The total expenditures for all federal programs recorded in the Schedule of Expenditures for Federal Awards are accurately presented and tie to the general ledger. The payroll sub-ledger is corrected before posting to the general ledger every two weeks. The resulting differences are most often immaterial but can be traced to corrections made by the Accounting Office after payroll is reviewed by the grants Restricted Funds Supervisor to ensure payroll is not posted to expired grants. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report. BDO Response – We have reviewed management’s response and our finding remains as indicated, since we could not validate the details of the differences.
Finding Number 2022-008 Prior Year Finding Number N/A Compliance Requirement: Allowable Costs/Costs Principles Program: U.S. Department of Education Title I Grants to Local Educational Agencies ALN #: 84.010 Award #: Various Award Period: Various COVID-19 – Governor’s Emergency Education Relief (GEER) ALN #: 84.425C Award #: Various Award Period: Various COVID-19 – Elementary and Secondary School Emergency Relief (ESSR) Fund ALN #: 84.425D Award #: Various Award Period: Various COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSR) ALN #: 84.425U Award #: 211941 Award Period: 03/24/2021 – 09/30/2023 COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief – Homeless Children and Youth ALN #: 84.425W Award #: Various Award Period: Various Criteria – In accordance with §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following: 1. Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received. 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 §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance. 3. Records that identify adequately the source and application of funds for federally funded activities. 4. Effective control over, and accountability for, all funds, property, and other assets. The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Further, CFR Section 200.510 (b) requires 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 2 CFR section 200.502, Basis for determining Federal awards expended. Condition – The amounts recorded in the Schedule of Expenditures of Federal Awards (SEFA) agree to the total amount recorded in the general ledger. The summary level payroll transactions recorded in the general ledger could not be reconciled to the transaction level detail provided from the payroll system. When comparing the two populations, we identified the following differences: • ALN 84.425 - For ALN 84.425 sub-program D, we noted a variance of $1,828,609. Total payroll expenditures per the payroll system details amounted to $18,437,724 whereas payroll expenditures per SEFA amounted to $16,609,116. In addition to the above, for ALN 84.425 sub-program U, we noted a variance of $301,432. Total payroll expenditures per the payroll system details amounted to $3,607,738 whereas payroll expenditures per the SEFA amounted to $3,909,170. • ALN 84.010 - We noted a variance of $752,503. Total payroll expenditures per the payroll system details amounted to $40,549,584 whereas payroll expenditures per the SEFA amounted to $39,797,081. Questioned Costs – Not Determinable. Context – This is a condition identified per review of the School System’s population completeness over the compliance requirements for each program. The prevalence of these findings is detailed in the condition section above. Effect – The SEFA may not be completely and accurately stated. In addition, the lack of established internal controls policies and procedures to ensure the SEFA is completely and accurately stated can lead to noncompliance with federal statutes, regulations, and provisions of grant agreements. Cause – The School System did not adhere to their internal policies and procedures to ensure the accuracy of the SEFA. Recommendation – We recommend that the School System develop policies and procedures and enhance their existing reconciliation process to ensure the completeness and accuracy of the SEFA, and that amounts reported on the SEFA are supported by transaction level detail. Views of Responsible Officials – The School System does not concur with the auditor’s findings and recommendations. The total expenditures for all federal programs recorded in the Schedule of Expenditures for Federal Awards are accurately presented and tie to the general ledger. The payroll sub-ledger is corrected before posting to the general ledger every two weeks. The resulting differences are most often immaterial but can be traced to corrections made by the Accounting Office after payroll is reviewed by the grants Restricted Funds Supervisor to ensure payroll is not posted to expired grants. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report. BDO Response – We have reviewed management’s response and our finding remains as indicated, since we could not validate the details of the differences.
Finding Number 2022-008 Prior Year Finding Number N/A Compliance Requirement: Allowable Costs/Costs Principles Program: U.S. Department of Education Title I Grants to Local Educational Agencies ALN #: 84.010 Award #: Various Award Period: Various COVID-19 – Governor’s Emergency Education Relief (GEER) ALN #: 84.425C Award #: Various Award Period: Various COVID-19 – Elementary and Secondary School Emergency Relief (ESSR) Fund ALN #: 84.425D Award #: Various Award Period: Various COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSR) ALN #: 84.425U Award #: 211941 Award Period: 03/24/2021 – 09/30/2023 COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief – Homeless Children and Youth ALN #: 84.425W Award #: Various Award Period: Various Criteria – In accordance with §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following: 1. Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received. 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 §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance. 3. Records that identify adequately the source and application of funds for federally funded activities. 4. Effective control over, and accountability for, all funds, property, and other assets. The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Further, CFR Section 200.510 (b) requires 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 2 CFR section 200.502, Basis for determining Federal awards expended. Condition – The amounts recorded in the Schedule of Expenditures of Federal Awards (SEFA) agree to the total amount recorded in the general ledger. The summary level payroll transactions recorded in the general ledger could not be reconciled to the transaction level detail provided from the payroll system. When comparing the two populations, we identified the following differences: • ALN 84.425 - For ALN 84.425 sub-program D, we noted a variance of $1,828,609. Total payroll expenditures per the payroll system details amounted to $18,437,724 whereas payroll expenditures per SEFA amounted to $16,609,116. In addition to the above, for ALN 84.425 sub-program U, we noted a variance of $301,432. Total payroll expenditures per the payroll system details amounted to $3,607,738 whereas payroll expenditures per the SEFA amounted to $3,909,170. • ALN 84.010 - We noted a variance of $752,503. Total payroll expenditures per the payroll system details amounted to $40,549,584 whereas payroll expenditures per the SEFA amounted to $39,797,081. Questioned Costs – Not Determinable. Context – This is a condition identified per review of the School System’s population completeness over the compliance requirements for each program. The prevalence of these findings is detailed in the condition section above. Effect – The SEFA may not be completely and accurately stated. In addition, the lack of established internal controls policies and procedures to ensure the SEFA is completely and accurately stated can lead to noncompliance with federal statutes, regulations, and provisions of grant agreements. Cause – The School System did not adhere to their internal policies and procedures to ensure the accuracy of the SEFA. Recommendation – We recommend that the School System develop policies and procedures and enhance their existing reconciliation process to ensure the completeness and accuracy of the SEFA, and that amounts reported on the SEFA are supported by transaction level detail. Views of Responsible Officials – The School System does not concur with the auditor’s findings and recommendations. The total expenditures for all federal programs recorded in the Schedule of Expenditures for Federal Awards are accurately presented and tie to the general ledger. The payroll sub-ledger is corrected before posting to the general ledger every two weeks. The resulting differences are most often immaterial but can be traced to corrections made by the Accounting Office after payroll is reviewed by the grants Restricted Funds Supervisor to ensure payroll is not posted to expired grants. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report. BDO Response – We have reviewed management’s response and our finding remains as indicated, since we could not validate the details of the differences.
Finding Number 2022-008 Prior Year Finding Number N/A Compliance Requirement: Allowable Costs/Costs Principles Program: U.S. Department of Education Title I Grants to Local Educational Agencies ALN #: 84.010 Award #: Various Award Period: Various COVID-19 – Governor’s Emergency Education Relief (GEER) ALN #: 84.425C Award #: Various Award Period: Various COVID-19 – Elementary and Secondary School Emergency Relief (ESSR) Fund ALN #: 84.425D Award #: Various Award Period: Various COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSR) ALN #: 84.425U Award #: 211941 Award Period: 03/24/2021 – 09/30/2023 COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief – Homeless Children and Youth ALN #: 84.425W Award #: Various Award Period: Various Criteria – In accordance with §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following: 1. Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received. 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 §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance. 3. Records that identify adequately the source and application of funds for federally funded activities. 4. Effective control over, and accountability for, all funds, property, and other assets. The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Further, CFR Section 200.510 (b) requires 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 2 CFR section 200.502, Basis for determining Federal awards expended. Condition – The amounts recorded in the Schedule of Expenditures of Federal Awards (SEFA) agree to the total amount recorded in the general ledger. The summary level payroll transactions recorded in the general ledger could not be reconciled to the transaction level detail provided from the payroll system. When comparing the two populations, we identified the following differences: • ALN 84.425 - For ALN 84.425 sub-program D, we noted a variance of $1,828,609. Total payroll expenditures per the payroll system details amounted to $18,437,724 whereas payroll expenditures per SEFA amounted to $16,609,116. In addition to the above, for ALN 84.425 sub-program U, we noted a variance of $301,432. Total payroll expenditures per the payroll system details amounted to $3,607,738 whereas payroll expenditures per the SEFA amounted to $3,909,170. • ALN 84.010 - We noted a variance of $752,503. Total payroll expenditures per the payroll system details amounted to $40,549,584 whereas payroll expenditures per the SEFA amounted to $39,797,081. Questioned Costs – Not Determinable. Context – This is a condition identified per review of the School System’s population completeness over the compliance requirements for each program. The prevalence of these findings is detailed in the condition section above. Effect – The SEFA may not be completely and accurately stated. In addition, the lack of established internal controls policies and procedures to ensure the SEFA is completely and accurately stated can lead to noncompliance with federal statutes, regulations, and provisions of grant agreements. Cause – The School System did not adhere to their internal policies and procedures to ensure the accuracy of the SEFA. Recommendation – We recommend that the School System develop policies and procedures and enhance their existing reconciliation process to ensure the completeness and accuracy of the SEFA, and that amounts reported on the SEFA are supported by transaction level detail. Views of Responsible Officials – The School System does not concur with the auditor’s findings and recommendations. The total expenditures for all federal programs recorded in the Schedule of Expenditures for Federal Awards are accurately presented and tie to the general ledger. The payroll sub-ledger is corrected before posting to the general ledger every two weeks. The resulting differences are most often immaterial but can be traced to corrections made by the Accounting Office after payroll is reviewed by the grants Restricted Funds Supervisor to ensure payroll is not posted to expired grants. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report. BDO Response – We have reviewed management’s response and our finding remains as indicated, since we could not validate the details of the differences.
Finding Number 2022-008 Prior Year Finding Number N/A Compliance Requirement: Allowable Costs/Costs Principles Program: U.S. Department of Education Title I Grants to Local Educational Agencies ALN #: 84.010 Award #: Various Award Period: Various COVID-19 – Governor’s Emergency Education Relief (GEER) ALN #: 84.425C Award #: Various Award Period: Various COVID-19 – Elementary and Secondary School Emergency Relief (ESSR) Fund ALN #: 84.425D Award #: Various Award Period: Various COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSR) ALN #: 84.425U Award #: 211941 Award Period: 03/24/2021 – 09/30/2023 COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief – Homeless Children and Youth ALN #: 84.425W Award #: Various Award Period: Various Criteria – In accordance with §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following: 1. Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received. 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 §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance. 3. Records that identify adequately the source and application of funds for federally funded activities. 4. Effective control over, and accountability for, all funds, property, and other assets. The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Further, CFR Section 200.510 (b) requires 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 2 CFR section 200.502, Basis for determining Federal awards expended. Condition – The amounts recorded in the Schedule of Expenditures of Federal Awards (SEFA) agree to the total amount recorded in the general ledger. The summary level payroll transactions recorded in the general ledger could not be reconciled to the transaction level detail provided from the payroll system. When comparing the two populations, we identified the following differences: • ALN 84.425 - For ALN 84.425 sub-program D, we noted a variance of $1,828,609. Total payroll expenditures per the payroll system details amounted to $18,437,724 whereas payroll expenditures per SEFA amounted to $16,609,116. In addition to the above, for ALN 84.425 sub-program U, we noted a variance of $301,432. Total payroll expenditures per the payroll system details amounted to $3,607,738 whereas payroll expenditures per the SEFA amounted to $3,909,170. • ALN 84.010 - We noted a variance of $752,503. Total payroll expenditures per the payroll system details amounted to $40,549,584 whereas payroll expenditures per the SEFA amounted to $39,797,081. Questioned Costs – Not Determinable. Context – This is a condition identified per review of the School System’s population completeness over the compliance requirements for each program. The prevalence of these findings is detailed in the condition section above. Effect – The SEFA may not be completely and accurately stated. In addition, the lack of established internal controls policies and procedures to ensure the SEFA is completely and accurately stated can lead to noncompliance with federal statutes, regulations, and provisions of grant agreements. Cause – The School System did not adhere to their internal policies and procedures to ensure the accuracy of the SEFA. Recommendation – We recommend that the School System develop policies and procedures and enhance their existing reconciliation process to ensure the completeness and accuracy of the SEFA, and that amounts reported on the SEFA are supported by transaction level detail. Views of Responsible Officials – The School System does not concur with the auditor’s findings and recommendations. The total expenditures for all federal programs recorded in the Schedule of Expenditures for Federal Awards are accurately presented and tie to the general ledger. The payroll sub-ledger is corrected before posting to the general ledger every two weeks. The resulting differences are most often immaterial but can be traced to corrections made by the Accounting Office after payroll is reviewed by the grants Restricted Funds Supervisor to ensure payroll is not posted to expired grants. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report. BDO Response – We have reviewed management’s response and our finding remains as indicated, since we could not validate the details of the differences.
Finding Number 2022-008 Prior Year Finding Number N/A Compliance Requirement: Allowable Costs/Costs Principles Program: U.S. Department of Education Title I Grants to Local Educational Agencies ALN #: 84.010 Award #: Various Award Period: Various COVID-19 – Governor’s Emergency Education Relief (GEER) ALN #: 84.425C Award #: Various Award Period: Various COVID-19 – Elementary and Secondary School Emergency Relief (ESSR) Fund ALN #: 84.425D Award #: Various Award Period: Various COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSR) ALN #: 84.425U Award #: 211941 Award Period: 03/24/2021 – 09/30/2023 COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief – Homeless Children and Youth ALN #: 84.425W Award #: Various Award Period: Various Criteria – In accordance with §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following: 1. Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received. 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 §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance. 3. Records that identify adequately the source and application of funds for federally funded activities. 4. Effective control over, and accountability for, all funds, property, and other assets. The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Further, CFR Section 200.510 (b) requires 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 2 CFR section 200.502, Basis for determining Federal awards expended. Condition – The amounts recorded in the Schedule of Expenditures of Federal Awards (SEFA) agree to the total amount recorded in the general ledger. The summary level payroll transactions recorded in the general ledger could not be reconciled to the transaction level detail provided from the payroll system. When comparing the two populations, we identified the following differences: • ALN 84.425 - For ALN 84.425 sub-program D, we noted a variance of $1,828,609. Total payroll expenditures per the payroll system details amounted to $18,437,724 whereas payroll expenditures per SEFA amounted to $16,609,116. In addition to the above, for ALN 84.425 sub-program U, we noted a variance of $301,432. Total payroll expenditures per the payroll system details amounted to $3,607,738 whereas payroll expenditures per the SEFA amounted to $3,909,170. • ALN 84.010 - We noted a variance of $752,503. Total payroll expenditures per the payroll system details amounted to $40,549,584 whereas payroll expenditures per the SEFA amounted to $39,797,081. Questioned Costs – Not Determinable. Context – This is a condition identified per review of the School System’s population completeness over the compliance requirements for each program. The prevalence of these findings is detailed in the condition section above. Effect – The SEFA may not be completely and accurately stated. In addition, the lack of established internal controls policies and procedures to ensure the SEFA is completely and accurately stated can lead to noncompliance with federal statutes, regulations, and provisions of grant agreements. Cause – The School System did not adhere to their internal policies and procedures to ensure the accuracy of the SEFA. Recommendation – We recommend that the School System develop policies and procedures and enhance their existing reconciliation process to ensure the completeness and accuracy of the SEFA, and that amounts reported on the SEFA are supported by transaction level detail. Views of Responsible Officials – The School System does not concur with the auditor’s findings and recommendations. The total expenditures for all federal programs recorded in the Schedule of Expenditures for Federal Awards are accurately presented and tie to the general ledger. The payroll sub-ledger is corrected before posting to the general ledger every two weeks. The resulting differences are most often immaterial but can be traced to corrections made by the Accounting Office after payroll is reviewed by the grants Restricted Funds Supervisor to ensure payroll is not posted to expired grants. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report. BDO Response – We have reviewed management’s response and our finding remains as indicated, since we could not validate the details of the differences.
Finding Number 2022-008 Prior Year Finding Number N/A Compliance Requirement: Allowable Costs/Costs Principles Program: U.S. Department of Education Title I Grants to Local Educational Agencies ALN #: 84.010 Award #: Various Award Period: Various COVID-19 – Governor’s Emergency Education Relief (GEER) ALN #: 84.425C Award #: Various Award Period: Various COVID-19 – Elementary and Secondary School Emergency Relief (ESSR) Fund ALN #: 84.425D Award #: Various Award Period: Various COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSR) ALN #: 84.425U Award #: 211941 Award Period: 03/24/2021 – 09/30/2023 COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief – Homeless Children and Youth ALN #: 84.425W Award #: Various Award Period: Various Criteria – In accordance with §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following: 1. Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received. 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 §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance. 3. Records that identify adequately the source and application of funds for federally funded activities. 4. Effective control over, and accountability for, all funds, property, and other assets. The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Further, CFR Section 200.510 (b) requires 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 2 CFR section 200.502, Basis for determining Federal awards expended. Condition – The amounts recorded in the Schedule of Expenditures of Federal Awards (SEFA) agree to the total amount recorded in the general ledger. The summary level payroll transactions recorded in the general ledger could not be reconciled to the transaction level detail provided from the payroll system. When comparing the two populations, we identified the following differences: • ALN 84.425 - For ALN 84.425 sub-program D, we noted a variance of $1,828,609. Total payroll expenditures per the payroll system details amounted to $18,437,724 whereas payroll expenditures per SEFA amounted to $16,609,116. In addition to the above, for ALN 84.425 sub-program U, we noted a variance of $301,432. Total payroll expenditures per the payroll system details amounted to $3,607,738 whereas payroll expenditures per the SEFA amounted to $3,909,170. • ALN 84.010 - We noted a variance of $752,503. Total payroll expenditures per the payroll system details amounted to $40,549,584 whereas payroll expenditures per the SEFA amounted to $39,797,081. Questioned Costs – Not Determinable. Context – This is a condition identified per review of the School System’s population completeness over the compliance requirements for each program. The prevalence of these findings is detailed in the condition section above. Effect – The SEFA may not be completely and accurately stated. In addition, the lack of established internal controls policies and procedures to ensure the SEFA is completely and accurately stated can lead to noncompliance with federal statutes, regulations, and provisions of grant agreements. Cause – The School System did not adhere to their internal policies and procedures to ensure the accuracy of the SEFA. Recommendation – We recommend that the School System develop policies and procedures and enhance their existing reconciliation process to ensure the completeness and accuracy of the SEFA, and that amounts reported on the SEFA are supported by transaction level detail. Views of Responsible Officials – The School System does not concur with the auditor’s findings and recommendations. The total expenditures for all federal programs recorded in the Schedule of Expenditures for Federal Awards are accurately presented and tie to the general ledger. The payroll sub-ledger is corrected before posting to the general ledger every two weeks. The resulting differences are most often immaterial but can be traced to corrections made by the Accounting Office after payroll is reviewed by the grants Restricted Funds Supervisor to ensure payroll is not posted to expired grants. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report. BDO Response – We have reviewed management’s response and our finding remains as indicated, since we could not validate the details of the differences.
Finding Number 2022-008 Prior Year Finding Number N/A Compliance Requirement: Allowable Costs/Costs Principles Program: U.S. Department of Education Title I Grants to Local Educational Agencies ALN #: 84.010 Award #: Various Award Period: Various COVID-19 – Governor’s Emergency Education Relief (GEER) ALN #: 84.425C Award #: Various Award Period: Various COVID-19 – Elementary and Secondary School Emergency Relief (ESSR) Fund ALN #: 84.425D Award #: Various Award Period: Various COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSR) ALN #: 84.425U Award #: 211941 Award Period: 03/24/2021 – 09/30/2023 COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief – Homeless Children and Youth ALN #: 84.425W Award #: Various Award Period: Various Criteria – In accordance with §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following: 1. Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received. 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 §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance. 3. Records that identify adequately the source and application of funds for federally funded activities. 4. Effective control over, and accountability for, all funds, property, and other assets. The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Further, CFR Section 200.510 (b) requires 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 2 CFR section 200.502, Basis for determining Federal awards expended. Condition – The amounts recorded in the Schedule of Expenditures of Federal Awards (SEFA) agree to the total amount recorded in the general ledger. The summary level payroll transactions recorded in the general ledger could not be reconciled to the transaction level detail provided from the payroll system. When comparing the two populations, we identified the following differences: • ALN 84.425 - For ALN 84.425 sub-program D, we noted a variance of $1,828,609. Total payroll expenditures per the payroll system details amounted to $18,437,724 whereas payroll expenditures per SEFA amounted to $16,609,116. In addition to the above, for ALN 84.425 sub-program U, we noted a variance of $301,432. Total payroll expenditures per the payroll system details amounted to $3,607,738 whereas payroll expenditures per the SEFA amounted to $3,909,170. • ALN 84.010 - We noted a variance of $752,503. Total payroll expenditures per the payroll system details amounted to $40,549,584 whereas payroll expenditures per the SEFA amounted to $39,797,081. Questioned Costs – Not Determinable. Context – This is a condition identified per review of the School System’s population completeness over the compliance requirements for each program. The prevalence of these findings is detailed in the condition section above. Effect – The SEFA may not be completely and accurately stated. In addition, the lack of established internal controls policies and procedures to ensure the SEFA is completely and accurately stated can lead to noncompliance with federal statutes, regulations, and provisions of grant agreements. Cause – The School System did not adhere to their internal policies and procedures to ensure the accuracy of the SEFA. Recommendation – We recommend that the School System develop policies and procedures and enhance their existing reconciliation process to ensure the completeness and accuracy of the SEFA, and that amounts reported on the SEFA are supported by transaction level detail. Views of Responsible Officials – The School System does not concur with the auditor’s findings and recommendations. The total expenditures for all federal programs recorded in the Schedule of Expenditures for Federal Awards are accurately presented and tie to the general ledger. The payroll sub-ledger is corrected before posting to the general ledger every two weeks. The resulting differences are most often immaterial but can be traced to corrections made by the Accounting Office after payroll is reviewed by the grants Restricted Funds Supervisor to ensure payroll is not posted to expired grants. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report. BDO Response – We have reviewed management’s response and our finding remains as indicated, since we could not validate the details of the differences.
Criteria: Under the Coronavirus Aid, Relief, and Economic Security Act 18004(e) and the Coronavirus Response and Relief Supplemental Appropriations Act 314(e) institutions that received funds underHEERF I and HEERF II are required to submit a report to the secretary on how the school used its HEERF funds. While the American Rescue Plan did not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, the U.S. Department of Education exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329.Condition/context: A sample of 8 special reports from the population of 8 special reports was selected. For each report, the University was unable to provide support for submission or publication dates. In addition, the University could not provide consistent institutional records for the data included in the reports nor could they provide support that the reports were reviewed prior to posting.Our sample was not, and was not intended to be, statistically valid.Questioned costs: None.Cause/Effect: Due to the turnover in the business office, the University was unable to locate support for the submission or publication dates, consistent institutional records for the data included in the reports or documented review of the reports prior to posting. The lack of support for submission or publication dates, data reported and documented review results in a material noncompliance with the reporting compliancerequirement.Repeat finding: YesRecommendation: We recommend the University update previously posted reports to accurately reflect the actual expenditures during the time period covered by the report. We recommend each report beposted to the University?s website on separate documents by quarter and should not be cumulative. We also recommend the University implement a process to ensure the submission dates and publication dates are maintained to ensure compliance with the reporting due dates and that the data submitted in the reports is properly supported by institutional records. Lastly, we recommend each report be properly reviewed by someone other than the preparer and that the review be documented with a signature anddate.Views of responsible officials and planned corrective actions: Heritage University will update the previously posted reports to accurately reflect the actual expenditures during FY20 & FY21 on the University?s website by quarter. Going further it will be the Grant accountant?s practice that the submission dates and publication dates are maintained and documented with reporting due dates. All documents will be reviewed and approved by the VP of Administration/CFO with dated signatures.
Criteria: Under the Coronavirus Aid, Relief, and Economic Security Act 18004(e) and the Coronavirus Response and Relief Supplemental Appropriations Act 314(e) institutions that received funds underHEERF I and HEERF II are required to submit a report to the secretary on how the school used its HEERF funds. While the American Rescue Plan did not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, the U.S. Department of Education exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329.Condition/context: A sample of 8 special reports from the population of 8 special reports was selected. For each report, the University was unable to provide support for submission or publication dates. In addition, the University could not provide consistent institutional records for the data included in the reports nor could they provide support that the reports were reviewed prior to posting.Our sample was not, and was not intended to be, statistically valid.Questioned costs: None.Cause/Effect: Due to the turnover in the business office, the University was unable to locate support for the submission or publication dates, consistent institutional records for the data included in the reports or documented review of the reports prior to posting. The lack of support for submission or publication dates, data reported and documented review results in a material noncompliance with the reporting compliancerequirement.Repeat finding: YesRecommendation: We recommend the University update previously posted reports to accurately reflect the actual expenditures during the time period covered by the report. We recommend each report beposted to the University?s website on separate documents by quarter and should not be cumulative. We also recommend the University implement a process to ensure the submission dates and publication dates are maintained to ensure compliance with the reporting due dates and that the data submitted in the reports is properly supported by institutional records. Lastly, we recommend each report be properly reviewed by someone other than the preparer and that the review be documented with a signature anddate.Views of responsible officials and planned corrective actions: Heritage University will update the previously posted reports to accurately reflect the actual expenditures during FY20 & FY21 on the University?s website by quarter. Going further it will be the Grant accountant?s practice that the submission dates and publication dates are maintained and documented with reporting due dates. All documents will be reviewed and approved by the VP of Administration/CFO with dated signatures.
Reference Number: 2022-003Federal Agency: U.S. Department of EducationFederal Program: Education Stabilization FundAssistance Listing Number: 84.425FAward Number and Period: P425F200021; May 4, 2020 ? June 30, 2023Compliance Requirement: ReportingType of Finding: Significant Deficiency in Internal Controls over Compliance, Other MattersCriteria or specific requirement:2 CFR, Part 200, Section 200.328 requires that unless otherwise approved by OMB, the Federal awarding agency must solicit only the OMB-approved governmentwide data elements for collection of financial information (at time of publication the Federal Financial Report or such future, OMB-approved, governmentwide data elements available from the OMB-designated standards lead. This information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes, and preferably in coordination with performance reporting. The Federal awarding agency must use OMB-approved common information collections, as applicable, when providing financial and performance reporting information.Condition:The College was unable to provide supporting documentation that agreed to the quarterly and annual reports submitted for the grant.Context:As part of the testing of the reporting requirement, CLA identified 2 errors in the quarterly reports out of the 4 tested, and an error in the annual report.Cause:The College did not have appropriate controls to ensure documentation for the quarterly and annual reporting was properly maintained.Effect:The College annual reporting may not be accurate and supported.Repeat Finding: NoQuestioned Costs:NoneRecommendation:We recommend the College review current procedures to ensure documentation is maintained to support the amounts submitted on quarterly and annual reports.Views of Responsible Officials:Management agrees with the finding.
Reference Number: 2022-003Federal Agency: U.S. Department of EducationFederal Program: Education Stabilization FundAssistance Listing Number: 84.425FAward Number and Period: P425F200021; May 4, 2020 ? June 30, 2023Compliance Requirement: ReportingType of Finding: Significant Deficiency in Internal Controls over Compliance, Other MattersCriteria or specific requirement:2 CFR, Part 200, Section 200.328 requires that unless otherwise approved by OMB, the Federal awarding agency must solicit only the OMB-approved governmentwide data elements for collection of financial information (at time of publication the Federal Financial Report or such future, OMB-approved, governmentwide data elements available from the OMB-designated standards lead. This information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes, and preferably in coordination with performance reporting. The Federal awarding agency must use OMB-approved common information collections, as applicable, when providing financial and performance reporting information.Condition:The College was unable to provide supporting documentation that agreed to the quarterly and annual reports submitted for the grant.Context:As part of the testing of the reporting requirement, CLA identified 2 errors in the quarterly reports out of the 4 tested, and an error in the annual report.Cause:The College did not have appropriate controls to ensure documentation for the quarterly and annual reporting was properly maintained.Effect:The College annual reporting may not be accurate and supported.Repeat Finding: NoQuestioned Costs:NoneRecommendation:We recommend the College review current procedures to ensure documentation is maintained to support the amounts submitted on quarterly and annual reports.Views of Responsible Officials:Management agrees with the finding.
Reference Number: 2022-003Federal Agency: U.S. Department of EducationFederal Program: Education Stabilization FundAssistance Listing Number: 84.425FAward Number and Period: P425F200021; May 4, 2020 ? June 30, 2023Compliance Requirement: ReportingType of Finding: Significant Deficiency in Internal Controls over Compliance, Other MattersCriteria or specific requirement:2 CFR, Part 200, Section 200.328 requires that unless otherwise approved by OMB, the Federal awarding agency must solicit only the OMB-approved governmentwide data elements for collection of financial information (at time of publication the Federal Financial Report or such future, OMB-approved, governmentwide data elements available from the OMB-designated standards lead. This information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes, and preferably in coordination with performance reporting. The Federal awarding agency must use OMB-approved common information collections, as applicable, when providing financial and performance reporting information.Condition:The College was unable to provide supporting documentation that agreed to the quarterly and annual reports submitted for the grant.Context:As part of the testing of the reporting requirement, CLA identified 2 errors in the quarterly reports out of the 4 tested, and an error in the annual report.Cause:The College did not have appropriate controls to ensure documentation for the quarterly and annual reporting was properly maintained.Effect:The College annual reporting may not be accurate and supported.Repeat Finding: NoQuestioned Costs:NoneRecommendation:We recommend the College review current procedures to ensure documentation is maintained to support the amounts submitted on quarterly and annual reports.Views of Responsible Officials:Management agrees with the finding.
FINDING 2022-002Subject: COVID-19 - Education Stabilization Fund - ReportingFederal Agency: Department of EducationFederal Program: COVID-19 - Education Stabilization FundAssistance Listings Number: 84.425DFederal Award Number and Year (or Other Identifying Number): S425D200013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: ReportingAudit Findings: Material Weakness, Other MattersCondition and ContextAn effective internal control system was not in place at the School Corporation to ensure compliancewith requirements related to the grant agreement and the Reporting compliance requirement.INDIANA STATE BOARD OF ACCOUNTS17SOUTHWEST DUBOIS COUNTY SCHOOL CORPORATIONSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)One of five annual reports required to be completed during the audit period contained materialerrors. The Elementary and Secondary School Emergency Relief (ESSER I), Year 1 annual data reportoverstated total expenditures made between March 13, 2020, and September, 30, 2020, by $130,918. Inaddition, documentation provided for the number of full-time employee positions did not support theamounts reported.The lack of internal controls and noncompliance were systemic issues throughout the audit period.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.334 states in part:"Financial records, supporting documents, statistical records, and all other non-Federal entityrecords pertinent to a Federal award must be retained for a period of three years from the dateof submission of the final expenditure report or, for Federal awards that are renewed quarterlyor annually, from the date of the submission of the quarterly or annual financial report,respectively, as reported to the Federal awarding agency or pass-through entity in the case ofa subrecipient. . . ."2 CFR 200.302(b) states in part:"The financial management system of each non-Federal entity must provide for the following:. . .(2) Accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with the reporting requirements set forth in ?? 200.328and 200.329. . . .(3) Records that identify adequately the source and application of funds for federallyfunded activities. These records must contain information pertaining to Federalawards, authorizations, obligations, unobligated balances, assets, expenditures,income and interest and be supported by source documentation. . . ."34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and formatthat assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out otherresponsibilities under the program."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Reporting compliance requirement.INDIANA STATE BOARD OF ACCOUNTS18SOUTHWEST DUBOIS COUNTY SCHOOL CORPORATIONSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)EffectThe failure to establish an effective internal control system enabled material noncompliance to goundetected. Noncompliance with the grant agreement and the Reporting compliance requirement couldresult in the loss of future federal funds to the School Corporation.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish internal controls to ensurecompliance and comply with the grant agreement and the Reporting compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-002Subject: COVID-19 - Education Stabilization Fund - ReportingFederal Agency: Department of EducationFederal Program: COVID-19 - Education Stabilization FundAssistance Listings Number: 84.425DFederal Award Number and Year (or Other Identifying Number): S425D200013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: ReportingAudit Findings: Material Weakness, Other MattersCondition and ContextAn effective internal control system was not in place at the School Corporation to ensure compliancewith requirements related to the grant agreement and the Reporting compliance requirement.INDIANA STATE BOARD OF ACCOUNTS17SOUTHWEST DUBOIS COUNTY SCHOOL CORPORATIONSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)One of five annual reports required to be completed during the audit period contained materialerrors. The Elementary and Secondary School Emergency Relief (ESSER I), Year 1 annual data reportoverstated total expenditures made between March 13, 2020, and September, 30, 2020, by $130,918. Inaddition, documentation provided for the number of full-time employee positions did not support theamounts reported.The lack of internal controls and noncompliance were systemic issues throughout the audit period.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.334 states in part:"Financial records, supporting documents, statistical records, and all other non-Federal entityrecords pertinent to a Federal award must be retained for a period of three years from the dateof submission of the final expenditure report or, for Federal awards that are renewed quarterlyor annually, from the date of the submission of the quarterly or annual financial report,respectively, as reported to the Federal awarding agency or pass-through entity in the case ofa subrecipient. . . ."2 CFR 200.302(b) states in part:"The financial management system of each non-Federal entity must provide for the following:. . .(2) Accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with the reporting requirements set forth in ?? 200.328and 200.329. . . .(3) Records that identify adequately the source and application of funds for federallyfunded activities. These records must contain information pertaining to Federalawards, authorizations, obligations, unobligated balances, assets, expenditures,income and interest and be supported by source documentation. . . ."34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and formatthat assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out otherresponsibilities under the program."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Reporting compliance requirement.INDIANA STATE BOARD OF ACCOUNTS18SOUTHWEST DUBOIS COUNTY SCHOOL CORPORATIONSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)EffectThe failure to establish an effective internal control system enabled material noncompliance to goundetected. Noncompliance with the grant agreement and the Reporting compliance requirement couldresult in the loss of future federal funds to the School Corporation.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish internal controls to ensurecompliance and comply with the grant agreement and the Reporting compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-010Subject: COVID-19 - Education Stabilization Fund - ReportingFederal Agency: Department of EducationFederal Program: COVID-19 - Education Stabilization FundAssistance Listings Numbers: 84.425D, 84.425UFederal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013,S425U210013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: ReportingAudit Findings: Material Weakness, Modified OpinionINDIANA STATE BOARD OF ACCOUNTS33BLACKFORD COUNTY SCHOOLSSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)Condition and ContextAn effective internal control system was not designed or implemented at the School Corporation toensure compliance with requirements related to the grant agreement and the Reporting compliancerequirement.The School Corporation completed and submitted four annual Data Collection reports (Reports) forthe Elementary and Secondary School Emergency Relief (ESSER) grants. For three of the four Reportstested, the Reports were not supported by the unit's records. The financial information provided did notagree to the data submitted in the Reports; therefore, we could not determine the accuracy of the Reports.Additionally, seven of seven key line items selected for testing could not be traced to supporting documentation.The lack of internal controls and noncompliance were systemic issues throughout the audit period.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring 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 Federalaward or program in accordance with the reporting requirements set forth in?? 200.328 and 200.329. . . ."34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and formatthat assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out otherresponsibilities under the program."2 CFR 200.334 states in part:"Financial records, supporting documents, statistical records, and all other non-Federal entityrecords pertinent to a Federal award must be retained for a period of three years from the dateof submission of the final expenditure report or, for Federal awards that are renewed quarterlyor annually, from the date of the submission of the quarterly or annual financial report,respectively, as reported to the Federal awarding agency or pass-through entity in the case ofa subrecipient. . . ."INDIANA STATE BOARD OF ACCOUNTS34BLACKFORD COUNTY SCHOOLSSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)34 CFR 76.731 states: "A State and a subgrantee shall keep records to show its compliance withprogram requirements."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Reporting compliance requirement.EffectThe failure to design and implement an effective internal control system enabled noncompliance togo undetected with the Reporting compliance requirement.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish effective internal controlsto ensure compliance and comply with the grant agreement and the Reporting compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.INDIANA STATE BOARD OF ACCOUNTS35
FINDING 2022-010Subject: COVID-19 - Education Stabilization Fund - ReportingFederal Agency: Department of EducationFederal Program: COVID-19 - Education Stabilization FundAssistance Listings Numbers: 84.425D, 84.425UFederal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013,S425U210013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: ReportingAudit Findings: Material Weakness, Modified OpinionINDIANA STATE BOARD OF ACCOUNTS33BLACKFORD COUNTY SCHOOLSSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)Condition and ContextAn effective internal control system was not designed or implemented at the School Corporation toensure compliance with requirements related to the grant agreement and the Reporting compliancerequirement.The School Corporation completed and submitted four annual Data Collection reports (Reports) forthe Elementary and Secondary School Emergency Relief (ESSER) grants. For three of the four Reportstested, the Reports were not supported by the unit's records. The financial information provided did notagree to the data submitted in the Reports; therefore, we could not determine the accuracy of the Reports.Additionally, seven of seven key line items selected for testing could not be traced to supporting documentation.The lack of internal controls and noncompliance were systemic issues throughout the audit period.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring 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 Federalaward or program in accordance with the reporting requirements set forth in?? 200.328 and 200.329. . . ."34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and formatthat assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out otherresponsibilities under the program."2 CFR 200.334 states in part:"Financial records, supporting documents, statistical records, and all other non-Federal entityrecords pertinent to a Federal award must be retained for a period of three years from the dateof submission of the final expenditure report or, for Federal awards that are renewed quarterlyor annually, from the date of the submission of the quarterly or annual financial report,respectively, as reported to the Federal awarding agency or pass-through entity in the case ofa subrecipient. . . ."INDIANA STATE BOARD OF ACCOUNTS34BLACKFORD COUNTY SCHOOLSSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)34 CFR 76.731 states: "A State and a subgrantee shall keep records to show its compliance withprogram requirements."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Reporting compliance requirement.EffectThe failure to design and implement an effective internal control system enabled noncompliance togo undetected with the Reporting compliance requirement.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish effective internal controlsto ensure compliance and comply with the grant agreement and the Reporting compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.INDIANA STATE BOARD OF ACCOUNTS35
FINDING 2022-010Subject: COVID-19 - Education Stabilization Fund - ReportingFederal Agency: Department of EducationFederal Program: COVID-19 - Education Stabilization FundAssistance Listings Numbers: 84.425D, 84.425UFederal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013,S425U210013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: ReportingAudit Findings: Material Weakness, Modified OpinionINDIANA STATE BOARD OF ACCOUNTS33BLACKFORD COUNTY SCHOOLSSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)Condition and ContextAn effective internal control system was not designed or implemented at the School Corporation toensure compliance with requirements related to the grant agreement and the Reporting compliancerequirement.The School Corporation completed and submitted four annual Data Collection reports (Reports) forthe Elementary and Secondary School Emergency Relief (ESSER) grants. For three of the four Reportstested, the Reports were not supported by the unit's records. The financial information provided did notagree to the data submitted in the Reports; therefore, we could not determine the accuracy of the Reports.Additionally, seven of seven key line items selected for testing could not be traced to supporting documentation.The lack of internal controls and noncompliance were systemic issues throughout the audit period.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring 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 Federalaward or program in accordance with the reporting requirements set forth in?? 200.328 and 200.329. . . ."34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and formatthat assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out otherresponsibilities under the program."2 CFR 200.334 states in part:"Financial records, supporting documents, statistical records, and all other non-Federal entityrecords pertinent to a Federal award must be retained for a period of three years from the dateof submission of the final expenditure report or, for Federal awards that are renewed quarterlyor annually, from the date of the submission of the quarterly or annual financial report,respectively, as reported to the Federal awarding agency or pass-through entity in the case ofa subrecipient. . . ."INDIANA STATE BOARD OF ACCOUNTS34BLACKFORD COUNTY SCHOOLSSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)34 CFR 76.731 states: "A State and a subgrantee shall keep records to show its compliance withprogram requirements."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Reporting compliance requirement.EffectThe failure to design and implement an effective internal control system enabled noncompliance togo undetected with the Reporting compliance requirement.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish effective internal controlsto ensure compliance and comply with the grant agreement and the Reporting compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.INDIANA STATE BOARD OF ACCOUNTS35
FINDING 2022-010Subject: COVID-19 - Education Stabilization Fund - ReportingFederal Agency: Department of EducationFederal Program: COVID-19 - Education Stabilization FundAssistance Listings Numbers: 84.425D, 84.425UFederal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013,S425U210013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: ReportingAudit Findings: Material Weakness, Modified OpinionINDIANA STATE BOARD OF ACCOUNTS33BLACKFORD COUNTY SCHOOLSSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)Condition and ContextAn effective internal control system was not designed or implemented at the School Corporation toensure compliance with requirements related to the grant agreement and the Reporting compliancerequirement.The School Corporation completed and submitted four annual Data Collection reports (Reports) forthe Elementary and Secondary School Emergency Relief (ESSER) grants. For three of the four Reportstested, the Reports were not supported by the unit's records. The financial information provided did notagree to the data submitted in the Reports; therefore, we could not determine the accuracy of the Reports.Additionally, seven of seven key line items selected for testing could not be traced to supporting documentation.The lack of internal controls and noncompliance were systemic issues throughout the audit period.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring 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 Federalaward or program in accordance with the reporting requirements set forth in?? 200.328 and 200.329. . . ."34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and formatthat assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out otherresponsibilities under the program."2 CFR 200.334 states in part:"Financial records, supporting documents, statistical records, and all other non-Federal entityrecords pertinent to a Federal award must be retained for a period of three years from the dateof submission of the final expenditure report or, for Federal awards that are renewed quarterlyor annually, from the date of the submission of the quarterly or annual financial report,respectively, as reported to the Federal awarding agency or pass-through entity in the case ofa subrecipient. . . ."INDIANA STATE BOARD OF ACCOUNTS34BLACKFORD COUNTY SCHOOLSSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)34 CFR 76.731 states: "A State and a subgrantee shall keep records to show its compliance withprogram requirements."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Reporting compliance requirement.EffectThe failure to design and implement an effective internal control system enabled noncompliance togo undetected with the Reporting compliance requirement.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish effective internal controlsto ensure compliance and comply with the grant agreement and the Reporting compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.INDIANA STATE BOARD OF ACCOUNTS35
FINDING 2022-005Subject: COVID-19 - Education Stabilization Fund - ReportingFederal Agency: Department of EducationFederal Program: COVID-19 - Education Stabilization FundAssistance Listings Number: 84.425DFederal Award Number and Year (or Other Identifying Number): S425D200013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: ReportingAudit Findings: Material Weakness, Other MattersINDIANA STATE BOARD OF ACCOUNTS22MONROE COUNTY COMMUNITY SCHOOL CORPORATIONSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)Condition and ContextAn effective internal control system was not designed nor implemented at the School Corporationto ensure compliance with the requirements related to the grant agreement and the Reporting compliancerequirement.The School Corporation filed the four required Elementary and Secondary School EmergencyRelief (ESSER) annual data reports. However, the ESSER I, Year 1 and ESSER I, Year 2 reports werenot supported by the School Corporation's records. For each of the reports, two key line items wereselected for verification, none of the line items tested were supported by the School Corporation's records.For the ESSER I, Year 2 report the data included expenditures for two months beyond the reporting period.The lack of internal controls and noncompliance were applicable to the ESSER I grant during theaudit period.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.334 states in part:"Financial records, supporting documents, statistical records, and all other non-Federal entityrecords pertinent to a Federal award must be retained for a period of three years from the dateof submission of the final expenditure report or, for Federal awards that are renewed quarterlyor annually, from the date of the submission of the quarterly or annual financial report,respectively, as reported to the Federal awarding agency or pass-through entity in the case ofa subrecipient. . . ."2 CFR 200.302(b) states in part:"The financial management system of each non-Federal entity must provide for the following:. . .(2) Accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with the reporting requirements set forth in ?? 200.328and 200.329. . . .(3) Records that identify adequately the source and application of funds for federallyfunded activities. These records must contain information pertaining to Federalawards, authorizations, obligations, unobligated balances, assets, expenditures,income and interest and be supported by source documentation. . . ."INDIANA STATE BOARD OF ACCOUNTS23MONROE COUNTY COMMUNITY SCHOOL CORPORATIONSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and formatthat assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out otherresponsibilities under the program."CauseManagement had not designed, nor implemented a system of internal controls that would haveensured compliance or that supporting documentation would have been maintained and available for auditrelated to the Reporting compliance requirement.EffectThe failure to retain and provide appropriate supporting documentation prevented the determination of the School Corporation's compliance with the Reporting compliance requirement. Noncompliancewith the grant agreement and the Reporting compliance requirement could result in the loss of future federalfunds to the School Corporation.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish a system of internal controls to ensure that documentation will be maintained and available for audit and comply with the grantagreement and the Reporting compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-005Subject: COVID-19 - Education Stabilization Fund - ReportingFederal Agency: Department of EducationFederal Program: COVID-19 - Education Stabilization FundAssistance Listings Number: 84.425DFederal Award Number and Year (or Other Identifying Number): S425D200013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: ReportingAudit Findings: Material Weakness, Other MattersINDIANA STATE BOARD OF ACCOUNTS22MONROE COUNTY COMMUNITY SCHOOL CORPORATIONSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)Condition and ContextAn effective internal control system was not designed nor implemented at the School Corporationto ensure compliance with the requirements related to the grant agreement and the Reporting compliancerequirement.The School Corporation filed the four required Elementary and Secondary School EmergencyRelief (ESSER) annual data reports. However, the ESSER I, Year 1 and ESSER I, Year 2 reports werenot supported by the School Corporation's records. For each of the reports, two key line items wereselected for verification, none of the line items tested were supported by the School Corporation's records.For the ESSER I, Year 2 report the data included expenditures for two months beyond the reporting period.The lack of internal controls and noncompliance were applicable to the ESSER I grant during theaudit period.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.334 states in part:"Financial records, supporting documents, statistical records, and all other non-Federal entityrecords pertinent to a Federal award must be retained for a period of three years from the dateof submission of the final expenditure report or, for Federal awards that are renewed quarterlyor annually, from the date of the submission of the quarterly or annual financial report,respectively, as reported to the Federal awarding agency or pass-through entity in the case ofa subrecipient. . . ."2 CFR 200.302(b) states in part:"The financial management system of each non-Federal entity must provide for the following:. . .(2) Accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with the reporting requirements set forth in ?? 200.328and 200.329. . . .(3) Records that identify adequately the source and application of funds for federallyfunded activities. These records must contain information pertaining to Federalawards, authorizations, obligations, unobligated balances, assets, expenditures,income and interest and be supported by source documentation. . . ."INDIANA STATE BOARD OF ACCOUNTS23MONROE COUNTY COMMUNITY SCHOOL CORPORATIONSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and formatthat assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out otherresponsibilities under the program."CauseManagement had not designed, nor implemented a system of internal controls that would haveensured compliance or that supporting documentation would have been maintained and available for auditrelated to the Reporting compliance requirement.EffectThe failure to retain and provide appropriate supporting documentation prevented the determination of the School Corporation's compliance with the Reporting compliance requirement. Noncompliancewith the grant agreement and the Reporting compliance requirement could result in the loss of future federalfunds to the School Corporation.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish a system of internal controls to ensure that documentation will be maintained and available for audit and comply with the grantagreement and the Reporting compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-005Subject: COVID-19 - Education Stabilization Fund - ReportingFederal Agency: Department of EducationFederal Program: COVID-19 - Education Stabilization FundAssistance Listings Numbers: 84.425D, 84.425UFederal Award Numbers and Years (or Other Identifying Numbers): S425D20013, S425D210013,S425U210013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: ReportingAudit Findings: Material Weakness, Other MattersCondition and ContextAn effective internal control system was not designed, nor implemented, at the School Corporationto ensure compliance with requirements related to the grant agreement and the Reporting compliancerequirement.The School Corporation completed and submitted four annual Data Collection reports (Reports) forthe Elementary and Secondary School Emergency Relief (ESSER) grants. The Reports were prepared byone employee without an oversite or review process in place to prevent, or detect and correct, errors.Additionally, one of the four Reports tested was not supported by the School Corporation's records.The financial information provided did not agree to all the data submitted in the Report; therefore, we couldnot determine the accuracy of the Report. Additionally, two of six key line items selected for testing couldnot be traced to supporting documentation.The lack of internal controls and noncompliance were systemic issues throughout the audit period.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring 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 Federalaward or program in accordance with the reporting requirements set forth in ?? 200.328and 200.329. . . ."34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and formatthat assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out otherresponsibilities under the program."2 CFR 200.334 states in part:"Financial records, supporting documents, statistical records, and all other non-Federal entityrecords pertinent to a Federal award must be retained for a period of three years from the dateof submission of the final expenditure report or, for Federal awards that are renewed quarterlyor annually, from the date of the submission of the quarterly or annual financial report, respectively,as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.. . ."34 CFR 76.731 states: "A State and a subgrantee shall keep records to show its compliance withprogram requirements."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Reporting compliance requirement.EffectThe failure to establish an effective internal control system enabled noncompliance to go undetected.Noncompliance with the grant agreement and the Reporting compliance requirement could resultin the loss of future federal funds to the School Corporation.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish effective internal controlsto ensure compliance and comply with the grant agreement and the Reporting compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.