Federal Agency: U.S. Department of Housing and Urban Development Federal Financial Assistance Listing: 14.218 Program Name: CDBG Entitlement Grants Cluster Award No. and Year: 2021 B-21-MC-0607 and 2020 B-20-MW-06-0607 Compliance Requirement: Reporting Type of Finding: Material Weakness in Internal Control over Compliance, Instance of Non-compliance Criteria: 2 CFR 200.329(b) requires that reports submitted to the federal awarding agency include all activity of the reporting period, are supported by applicable accounting or performance records, and are fairly presented in accordance with program requirements. For direct recipients of grants or cooperative agreements who make first-tier subawards of $30,000 or more are required to register in the Federal Funding Accountability and Transparency Act (FFATA) Subaward Reporting System (FSRS) and report subaward date through FSRS. The City must report the following items: ? All subaward obligations/modifications that have been reported ? Subaward date ? Subrecipient DUNS number ? Amount of subaward ? Subaward obligation/action date ? Date of report submission ? Subaward number Condition: FFATA reporting was not completed through FSRS. Cause: The City?s internal controls did not ensure the FFATA reporting was completed in accordance with governing requirements. Effect: Information was not reported to the federal awarding agency. Questioned Costs: None reported. Context/Sampling: The entire population of one subrecipient who received in excess of $30,000 was selected for testing. Repeat Finding from Prior Year: No Recommendation: We recommend the City enhance internal controls to ensure FFATA reporting is prepared in accordance with program requirements. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Federal Agency: U.S. Department of Housing and Urban Development Federal Financial Assistance Listing: 14.218 Program Name: CDBG Entitlement Grants Cluster Award No. and Year: 2021 B-21-MC-0607 and 2020 B-20-MW-06-0607 Compliance Requirement: Reporting Type of Finding: Material Weakness in Internal Control over Compliance, Instance of Non-compliance Criteria: 2 CFR 200.329(b) requires that reports submitted to the federal awarding agency include all activity of the reporting period, are supported by applicable accounting or performance records, and are fairly presented in accordance with program requirements. For direct recipients of grants or cooperative agreements who make first-tier subawards of $30,000 or more are required to register in the Federal Funding Accountability and Transparency Act (FFATA) Subaward Reporting System (FSRS) and report subaward date through FSRS. The City must report the following items: ? All subaward obligations/modifications that have been reported ? Subaward date ? Subrecipient DUNS number ? Amount of subaward ? Subaward obligation/action date ? Date of report submission ? Subaward number Condition: FFATA reporting was not completed through FSRS. Cause: The City?s internal controls did not ensure the FFATA reporting was completed in accordance with governing requirements. Effect: Information was not reported to the federal awarding agency. Questioned Costs: None reported. Context/Sampling: The entire population of one subrecipient who received in excess of $30,000 was selected for testing. Repeat Finding from Prior Year: No Recommendation: We recommend the City enhance internal controls to ensure FFATA reporting is prepared in accordance with program requirements. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
FINDING 2022-004 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Number: 84.425 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, Other Matters Condition and Context An effective internal control system was not designed, nor implemented at the School Corporation to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirement. The School Corporation had not designed, nor implemented a system of internal control to ensure that the annual Elementary and Secondary School Emergency Relief (ESSER) annual data reports (Reports) were complete and accurately submitted. The Reports were prepared by one employee without an oversight, or review process in place to detect and correct errors. Additionally, for one of ten key line items tested the School Corporation did not accurately report the information. The Full-time Equivalent (FTE) positions as of March 13, 2020, and September 30, 2020, as required by the ESSER 1, Year 1 annual data report did not agree with the documentation provided. The lack of internal controls was a systemic issue throughout the audit period. The noncompliance was isolated to the ESSER I, Year 1 report. 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 Management had not developed, nor implemented a system of internal control that would have ensured compliance with the grant agreement and the Reporting compliance requirement. Effect The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Reporting compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish internal controls to ensure compliance 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 Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Number: 84.425 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, Other Matters Condition and Context An effective internal control system was not designed, nor implemented at the School Corporation to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirement. The School Corporation had not designed, nor implemented a system of internal control to ensure that the annual Elementary and Secondary School Emergency Relief (ESSER) annual data reports (Reports) were complete and accurately submitted. The Reports were prepared by one employee without an oversight, or review process in place to detect and correct errors. Additionally, for one of ten key line items tested the School Corporation did not accurately report the information. The Full-time Equivalent (FTE) positions as of March 13, 2020, and September 30, 2020, as required by the ESSER 1, Year 1 annual data report did not agree with the documentation provided. The lack of internal controls was a systemic issue throughout the audit period. The noncompliance was isolated to the ESSER I, Year 1 report. 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 Management had not developed, nor implemented a system of internal control that would have ensured compliance with the grant agreement and the Reporting compliance requirement. Effect The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Reporting compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish internal controls to ensure compliance 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 Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Number: 84.425 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, Other Matters Condition and Context An effective internal control system was not designed, nor implemented at the School Corporation to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirement. The School Corporation had not designed, nor implemented a system of internal control to ensure that the annual Elementary and Secondary School Emergency Relief (ESSER) annual data reports (Reports) were complete and accurately submitted. The Reports were prepared by one employee without an oversight, or review process in place to detect and correct errors. Additionally, for one of ten key line items tested the School Corporation did not accurately report the information. The Full-time Equivalent (FTE) positions as of March 13, 2020, and September 30, 2020, as required by the ESSER 1, Year 1 annual data report did not agree with the documentation provided. The lack of internal controls was a systemic issue throughout the audit period. The noncompliance was isolated to the ESSER I, Year 1 report. 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 Management had not developed, nor implemented a system of internal control that would have ensured compliance with the grant agreement and the Reporting compliance requirement. Effect The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Reporting compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish internal controls to ensure compliance 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 Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Number: 84.425 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, Other Matters Condition and Context An effective internal control system was not designed, nor implemented at the School Corporation to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirement. The School Corporation had not designed, nor implemented a system of internal control to ensure that the annual Elementary and Secondary School Emergency Relief (ESSER) annual data reports (Reports) were complete and accurately submitted. The Reports were prepared by one employee without an oversight, or review process in place to detect and correct errors. Additionally, for one of ten key line items tested the School Corporation did not accurately report the information. The Full-time Equivalent (FTE) positions as of March 13, 2020, and September 30, 2020, as required by the ESSER 1, Year 1 annual data report did not agree with the documentation provided. The lack of internal controls was a systemic issue throughout the audit period. The noncompliance was isolated to the ESSER I, Year 1 report. 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 Management had not developed, nor implemented a system of internal control that would have ensured compliance with the grant agreement and the Reporting compliance requirement. Effect The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Reporting compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish internal controls to ensure compliance 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.
Inaccurate HEERF Reporting DEPARTMENT OF EDUCATION ALN #: 84.425E, 84.425F Federal Award Identification #: P425E204264 and P425F203597 Condition: The University did not accurately report the quarterly information for the institutional expenditures of funds for one quarter. Additionally, the student amounts disbursed on the annual report inaccurately reflected the fiscal year instead of the calendar year. Criteria: 2 CFR 200.329 Questioned Costs: $-0- Context: One quarter?s reporting for the institutional expenditures inaccurately did not report one category of lost revenue that was incurred and was posted late to the University's website. Additionally, the student amounts disbursed on the annual report inaccurately reflected the fiscal year instead of the calendar year. Cause: There was transition in all key personnel during the year. Effect: The information initially reported did not accurately reflect what had occurred at the University. Identification as repeat finding, if applicable: not applicable Recommendation: We recommend the University amend the institution?s quarterly report to include the lost revenue that was claimed. Additionally, we recommend the University amend the 2021 calendar year annual report in the next reporting cycle. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Inaccurate HEERF Reporting DEPARTMENT OF EDUCATION ALN #: 84.425E, 84.425F Federal Award Identification #: P425E204264 and P425F203597 Condition: The University did not accurately report the quarterly information for the institutional expenditures of funds for one quarter. Additionally, the student amounts disbursed on the annual report inaccurately reflected the fiscal year instead of the calendar year. Criteria: 2 CFR 200.329 Questioned Costs: $-0- Context: One quarter?s reporting for the institutional expenditures inaccurately did not report one category of lost revenue that was incurred and was posted late to the University's website. Additionally, the student amounts disbursed on the annual report inaccurately reflected the fiscal year instead of the calendar year. Cause: There was transition in all key personnel during the year. Effect: The information initially reported did not accurately reflect what had occurred at the University. Identification as repeat finding, if applicable: not applicable Recommendation: We recommend the University amend the institution?s quarterly report to include the lost revenue that was claimed. Additionally, we recommend the University amend the 2021 calendar year annual report in the next reporting cycle. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Department of Education COVID-19 Higher Education Emergency Relief Fund (HEERF) ? Assistance Listing #84.425E, #84.425F #2022-003 ? Major Federal Award Finding - Reporting Significant Deficiency in Internal Controls over Compliance Conditions: We noted during testing of two quarterly reports and one annual report required under the HEERF program that the two quarterly reports selected for testing were not filed timely. There were also no review procedures in place surrounding the reporting process to the Department of Education for the HEERF program. The lack of review procedures in place resulted in inaccuracies noted within the annual reporting. Criteria: Federal regulations 2 CFR Section 200.328 - 200.329 provide that required reporting under the federal program must be completed timely and accurately. The quarterly reports for institutional and student aid portion are required to be updated and posted to the website within 10 days of the end of the quarter. Segregation of duties is also a key element of internal controls, including controls over compliance, and involves processes whereby the activities of one employee are reviewed or checked by the activities of another individual, and avoids one employee having the ability to perform a transaction or process from beginning to end. Cause/Context: The University did not meet the reporting deadline requirements set forth by the Department of Education for the HEERF program. Only one individual was involved in the reporting process. There is a higher likelihood of errors going undetected in the absence of monitoring and review. Inaccuracies were noted in the amounts reported in the 2021 calendar annual report for HEERF student disbursements and institutional expenditures. One error out of a sample of forty tested was also noted with the tracking of student responses regarding receipt preferences for HEERF proceeds. Recommendation: Management should review the University?s practices related to reporting under the HEERF program to ensure that reports are submitted timely and that more than one individual is involved in the reporting process. Management should also submit a revision of the HEERF calendar 2021 annual report once the reporting portal is reopened by the Department of Education. Views of Responsible Officials and Planned Corrective Actions: Finding has been reviewed and addressed. See attached Corrective Action Plan.
Department of Education COVID-19 Higher Education Emergency Relief Fund (HEERF) ? Assistance Listing #84.425E, #84.425F #2022-003 ? Major Federal Award Finding - Reporting Significant Deficiency in Internal Controls over Compliance Conditions: We noted during testing of two quarterly reports and one annual report required under the HEERF program that the two quarterly reports selected for testing were not filed timely. There were also no review procedures in place surrounding the reporting process to the Department of Education for the HEERF program. The lack of review procedures in place resulted in inaccuracies noted within the annual reporting. Criteria: Federal regulations 2 CFR Section 200.328 - 200.329 provide that required reporting under the federal program must be completed timely and accurately. The quarterly reports for institutional and student aid portion are required to be updated and posted to the website within 10 days of the end of the quarter. Segregation of duties is also a key element of internal controls, including controls over compliance, and involves processes whereby the activities of one employee are reviewed or checked by the activities of another individual, and avoids one employee having the ability to perform a transaction or process from beginning to end. Cause/Context: The University did not meet the reporting deadline requirements set forth by the Department of Education for the HEERF program. Only one individual was involved in the reporting process. There is a higher likelihood of errors going undetected in the absence of monitoring and review. Inaccuracies were noted in the amounts reported in the 2021 calendar annual report for HEERF student disbursements and institutional expenditures. One error out of a sample of forty tested was also noted with the tracking of student responses regarding receipt preferences for HEERF proceeds. Recommendation: Management should review the University?s practices related to reporting under the HEERF program to ensure that reports are submitted timely and that more than one individual is involved in the reporting process. Management should also submit a revision of the HEERF calendar 2021 annual report once the reporting portal is reopened by the Department of Education. Views of Responsible Officials and Planned Corrective Actions: Finding has been reviewed and addressed. See attached Corrective Action Plan.
Federal Program Information: COVID 19 HEERF Institutional Portion ALN 84.425F Criteria: 2 CFR 200.329 and the terms and conditions of the federal award requires the entity to submit reports quarterly. Condition: The total expenditures on each quarterly report was not correct. Questioned Costs: None Context: The testing of the quarterly reports showed that incorrect amounts were reported for expenditures on each quarterly report. In total the amounts reported for the four quarters was correct for the audit period. Cause/Effect: As part of the College?s normal practices, the College posts a reallocation of certain expenditures. The College did not take this into account when preparing the individual quarterly reports. Repeat Finding from Prior Audit?: Yes, fiscal 2022 had already ended before the College received the prior year audit results. Recommendation: We recommend review of current practices and implement policies establishing monitoring procedures related to quarterly reports. Management Response: The College agrees with the finding and is implementing appropriate procedures.
Higher Education Stabilization Fund (HEERF) Reporting DEPARTMENT OF EDUCATION ALN #: 84.425F and 84.425L Federal Award Identification #: 2021-22 Financial Aid Year Condition: While the University reported the HEERF student emergency grants disbursed each quarter, the HEERF institutional quarterly reporting was not completed and posted to the University?s website. Criteria: 2 CFR 200.329, 86 FR 26213 The University was required to post the Institutional Quarterly Report to their website within 10 days of the end of the quarter in which the funds were spent. Questioned Costs: $0 Context: During the audit, it was noted that the University did not complete the HEERF quarterly reporting requirements and make available on their website as listed in their grant agreements for the institutional and minority serving institution portions of their HEERF funding. Cause: Turnover in staffing. There were multiple rounds of HEERF funding released, each with different requirements, which led to a gap in understanding of the requirements of the HEERF reporting. Effect: The University was not in compliance with the reporting requirements of HEERF. Identification as repeat finding, if applicable: 2021-005 Recommendation: We recommend that the University complete the HEERF quarterly reporting and make this available on their website until they no longer need to based on compliance requirements. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Higher Education Stabilization Fund (HEERF) Reporting DEPARTMENT OF EDUCATION ALN #: 84.425F and 84.425L Federal Award Identification #: 2021-22 Financial Aid Year Condition: While the University reported the HEERF student emergency grants disbursed each quarter, the HEERF institutional quarterly reporting was not completed and posted to the University?s website. Criteria: 2 CFR 200.329, 86 FR 26213 The University was required to post the Institutional Quarterly Report to their website within 10 days of the end of the quarter in which the funds were spent. Questioned Costs: $0 Context: During the audit, it was noted that the University did not complete the HEERF quarterly reporting requirements and make available on their website as listed in their grant agreements for the institutional and minority serving institution portions of their HEERF funding. Cause: Turnover in staffing. There were multiple rounds of HEERF funding released, each with different requirements, which led to a gap in understanding of the requirements of the HEERF reporting. Effect: The University was not in compliance with the reporting requirements of HEERF. Identification as repeat finding, if applicable: 2021-005 Recommendation: We recommend that the University complete the HEERF quarterly reporting and make this available on their website until they no longer need to based on compliance requirements. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Criteria - The ?Reconciliation of Cash on Hand? quarterly reports are to be remitted within the 10th working day following the quarter of when eligible federal expenditures are incurred. Condition - 2 CFR 200.329 The district did not timely report to Pennsylvania Department of Education (PDE) eligible federal expenditures for reimbursement that were incurred during a three-month period throughout the year. Cause/Effect Cause of the Finding ? The district experienced a change of business manager during the school year. During the transition, certain duties of the business office were not completed. Effect of the Finding ? The opportunity cost of managing cashflow of the district due to not receiving reimbursement of federal expenditures in a timely manner. Also, PDE Financial and Account Information (FAI) portal may suspend payment until reporting status is updated. Questioned Costs ? No questioned costs. Recommendations - Report eligible federal expenditure for reimbursement in a timely manner. District?s Response - The district?s administration agrees with this finding. The process of reporting eligible federal expenditures will be modified to ensure requests for reimbursement occur in a timely manner.
Criteria - The ?Reconciliation of Cash on Hand? quarterly reports are to be remitted within the 10th working day following the quarter of when eligible federal expenditures are incurred. Condition - 2 CFR 200.329 The district did not timely report to Pennsylvania Department of Education (PDE) eligible federal expenditures for reimbursement that were incurred during a three-month period throughout the year. Cause/Effect Cause of the Finding ? The district experienced a change of business manager during the school year. During the transition, certain duties of the business office were not completed. Effect of the Finding ? The opportunity cost of managing cashflow of the district due to not receiving reimbursement of federal expenditures in a timely manner. Also, PDE Financial and Account Information (FAI) portal may suspend payment until reporting status is updated. Questioned Costs ? No questioned costs. Recommendations - Report eligible federal expenditure for reimbursement in a timely manner. District?s Response - The district?s administration agrees with this finding. The process of reporting eligible federal expenditures will be modified to ensure requests for reimbursement occur in a timely manner.
Criteria - The ?Reconciliation of Cash on Hand? quarterly reports are to be remitted within the 10th working day following the quarter of when eligible federal expenditures are incurred. Condition - 2 CFR 200.329 The district did not timely report to Pennsylvania Department of Education (PDE) eligible federal expenditures for reimbursement that were incurred during a three-month period throughout the year. Cause/Effect Cause of the Finding ? The district experienced a change of business manager during the school year. During the transition, certain duties of the business office were not completed. Effect of the Finding ? The opportunity cost of managing cashflow of the district due to not receiving reimbursement of federal expenditures in a timely manner. Also, PDE Financial and Account Information (FAI) portal may suspend payment until reporting status is updated. Questioned Costs ? No questioned costs. Recommendations - Report eligible federal expenditure for reimbursement in a timely manner. District?s Response - The district?s administration agrees with this finding. The process of reporting eligible federal expenditures will be modified to ensure requests for reimbursement occur in a timely manner.
Criteria - The ?Reconciliation of Cash on Hand? quarterly reports are to be remitted within the 10th working day following the quarter of when eligible federal expenditures are incurred. Condition - 2 CFR 200.329 The district did not timely report to Pennsylvania Department of Education (PDE) eligible federal expenditures for reimbursement that were incurred during a three-month period throughout the year. Cause/Effect Cause of the Finding ? The district experienced a change of business manager during the school year. During the transition, certain duties of the business office were not completed. Effect of the Finding ? The opportunity cost of managing cashflow of the district due to not receiving reimbursement of federal expenditures in a timely manner. Also, PDE Financial and Account Information (FAI) portal may suspend payment until reporting status is updated. Questioned Costs ? No questioned costs. Recommendations - Report eligible federal expenditure for reimbursement in a timely manner. District?s Response - The district?s administration agrees with this finding. The process of reporting eligible federal expenditures will be modified to ensure requests for reimbursement occur in a timely manner.
Criteria - The ?Reconciliation of Cash on Hand? quarterly reports are to be remitted within the 10th working day following the quarter of when eligible federal expenditures are incurred. Condition - 2 CFR 200.329 The district did not timely report to Pennsylvania Department of Education (PDE) eligible federal expenditures for reimbursement that were incurred during a three-month period throughout the year. Cause/Effect Cause of the Finding ? The district experienced a change of business manager during the school year. During the transition, certain duties of the business office were not completed. Effect of the Finding ? The opportunity cost of managing cashflow of the district due to not receiving reimbursement of federal expenditures in a timely manner. Also, PDE Financial and Account Information (FAI) portal may suspend payment until reporting status is updated. Questioned Costs ? No questioned costs. Recommendations - Report eligible federal expenditure for reimbursement in a timely manner. District?s Response - The district?s administration agrees with this finding. The process of reporting eligible federal expenditures will be modified to ensure requests for reimbursement occur in a timely manner.
Criteria - The ?Reconciliation of Cash on Hand? quarterly reports are to be remitted within the 10th working day following the quarter of when eligible federal expenditures are incurred. Condition - 2 CFR 200.329 The district did not timely report to Pennsylvania Department of Education (PDE) eligible federal expenditures for reimbursement that were incurred during a three-month period throughout the year. Cause/Effect Cause of the Finding ? The district experienced a change of business manager during the school year. During the transition, certain duties of the business office were not completed. Effect of the Finding ? The opportunity cost of managing cashflow of the district due to not receiving reimbursement of federal expenditures in a timely manner. Also, PDE Financial and Account Information (FAI) portal may suspend payment until reporting status is updated. Questioned Costs ? No questioned costs. Recommendations - Report eligible federal expenditure for reimbursement in a timely manner. District?s Response - The district?s administration agrees with this finding. The process of reporting eligible federal expenditures will be modified to ensure requests for reimbursement occur in a timely manner.
FINDING 2022-006 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 Number and Year (or Other Identifying Number): S425D200013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters INDIANA STATE BOARD OF ACCOUNTS 26 METROPOLITAN SCHOOL DISTRICT OF WARREN COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Condition and Context An effective internal control system was not designed nor implemented at the School Corporation to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirement. The School Corporation had not designed nor implemented a system of internal controls to ensure that the annual Elementary and Secondary School Emergency Relief (ESSER) annual data reports (Reports) were complete and accurately submitted. The Reports were prepared by one employee without an oversight or review process in place to prevent, or detect and correct, errors. Additionally, for two of ten key line items tested, the School Corporation could not provide supporting documentation. The lack of supporting documentation for the full-time equivalent (FTE) key line item on the ESSER I, Year 1 annual data report prevented the determination of the accuracy of the line items. The lack of internal controls was a systemic issue throughout the audit period. The noncompliance was isolated to the ESSER I, Year 1 report. 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. . . . (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. . . ." INDIANA STATE BOARD OF ACCOUNTS 27 METROPOLITAN SCHOOL DISTRICT OF WARREN COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 2 CFR 200.333 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 76.722 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 developed nor implemented a system of internal controls that would have ensured compliance with the grant agreement and Reporting compliance requirement. Effect The failure to establish an effective internal control system enabled noncompliance to go undetected. Noncompliance with the grant agreement and the Reporting compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish internal controls to ensure compliance and comply with the grant agreement and 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 2022-006 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 Number and Year (or Other Identifying Number): S425D200013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters INDIANA STATE BOARD OF ACCOUNTS 26 METROPOLITAN SCHOOL DISTRICT OF WARREN COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Condition and Context An effective internal control system was not designed nor implemented at the School Corporation to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirement. The School Corporation had not designed nor implemented a system of internal controls to ensure that the annual Elementary and Secondary School Emergency Relief (ESSER) annual data reports (Reports) were complete and accurately submitted. The Reports were prepared by one employee without an oversight or review process in place to prevent, or detect and correct, errors. Additionally, for two of ten key line items tested, the School Corporation could not provide supporting documentation. The lack of supporting documentation for the full-time equivalent (FTE) key line item on the ESSER I, Year 1 annual data report prevented the determination of the accuracy of the line items. The lack of internal controls was a systemic issue throughout the audit period. The noncompliance was isolated to the ESSER I, Year 1 report. 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. . . . (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. . . ." INDIANA STATE BOARD OF ACCOUNTS 27 METROPOLITAN SCHOOL DISTRICT OF WARREN COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 2 CFR 200.333 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 76.722 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 developed nor implemented a system of internal controls that would have ensured compliance with the grant agreement and Reporting compliance requirement. Effect The failure to establish an effective internal control system enabled noncompliance to go undetected. Noncompliance with the grant agreement and the Reporting compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish internal controls to ensure compliance and comply with the grant agreement and 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.
Criteria There are three components to reporting for HEERF: 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. The CARES Act 18004(e) and the CRRSAA 314(e) require an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. While ARP does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, ED exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Annual Reporting (all HEERF Grantees) ED required an annual report from HEERF grantees in April 2022 that included reporting uses of HEERF I CARES Act funds, HEERF II CRRSAA funds, and HEERF III ARP funds for the 2021 calendar year. Quarterly Public Reporting for (a)(1) Institutional Portion, (a)(2), and (a)(3) Funds The CARES, CRRSAA, and ARP institutional quarterly portion reporting requirements involve publicly posting completed forms on the institution?s website. The forms must be conspicuously posted on the institution?s primary website on the same page the reports of the IHE?s activities as to the emergency financial aid grants to students (Student Aid Portion) are posted. IHEs must post this quarterly report form no later than 10 days after the end of each calendar quarter. Quarterly Public Reporting for (a)(1) Student Aid Portion ED requires institutions that received Student Aid Portion awards under CARES Act, CRRSAA and ARP to publicly post certain information on their website. Under the requirements to post student aid public reporting for CRRSAA and ARP, there is a requirement to include certain information on their website. Institutions must publicly post their report as soon as possible, but no later than 30 days after the publication of the notice or 30 days after the date ED first obligated funds under HEERF I, II, or III to the institution for Emergency Financial Aid Grants to Students, whichever comes later. The report must be updated not later than 10 days after the end of each calendar quarter. Further, in accordance with 2 CFR 200.303(a), non-federal entities must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition During our testwork over institutional reporting, it was noted that for one of two quarterly required instances of reporting selected for testing was submitted untimely. This quarterly update was provided 23 days after the date it was required to be updated. Additionally, the required reporting included the University?s final disbursements was not appropriately marked as the final report. Additionally, internal controls were not effective as evidence of review of the reporting prior to posting on the University?s website was not retained by management. As such we could not see evidence the management review control was operating effectively. Cause The University?s HEERF reporting process did not include a requirement to maintain the review documentation and did not operate at a level of precision sufficient to ensure timely and accurate reporting. Effect If appropriate controls are not designed and operating effectively over the HEERF reporting process, HEERF expenditures reported on the University?s website and to U.S. Department of Education may be incomplete, inaccurate, or not posted within the timeframe required resulting in non-compliance. Questioned Costs None noted. Recommendation We recommend that the University implement a implement a requirement to maintain the review documentation and incorporate a detailed review of the various fields of the form to ensure accuracy as well as to ensure the HEERF reporting is completed timely.
Criteria There are three components to reporting for HEERF: 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. The CARES Act 18004(e) and the CRRSAA 314(e) require an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. While ARP does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, ED exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Annual Reporting (all HEERF Grantees) ED required an annual report from HEERF grantees in April 2022 that included reporting uses of HEERF I CARES Act funds, HEERF II CRRSAA funds, and HEERF III ARP funds for the 2021 calendar year. Quarterly Public Reporting for (a)(1) Institutional Portion, (a)(2), and (a)(3) Funds The CARES, CRRSAA, and ARP institutional quarterly portion reporting requirements involve publicly posting completed forms on the institution?s website. The forms must be conspicuously posted on the institution?s primary website on the same page the reports of the IHE?s activities as to the emergency financial aid grants to students (Student Aid Portion) are posted. IHEs must post this quarterly report form no later than 10 days after the end of each calendar quarter. Quarterly Public Reporting for (a)(1) Student Aid Portion ED requires institutions that received Student Aid Portion awards under CARES Act, CRRSAA and ARP to publicly post certain information on their website. Under the requirements to post student aid public reporting for CRRSAA and ARP, there is a requirement to include certain information on their website. Institutions must publicly post their report as soon as possible, but no later than 30 days after the publication of the notice or 30 days after the date ED first obligated funds under HEERF I, II, or III to the institution for Emergency Financial Aid Grants to Students, whichever comes later. The report must be updated not later than 10 days after the end of each calendar quarter. Further, in accordance with 2 CFR 200.303(a), non-federal entities must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition During our testwork over institutional reporting, it was noted that for one of two quarterly required instances of reporting selected for testing was submitted untimely. This quarterly update was provided 23 days after the date it was required to be updated. Additionally, the required reporting included the University?s final disbursements was not appropriately marked as the final report. Additionally, internal controls were not effective as evidence of review of the reporting prior to posting on the University?s website was not retained by management. As such we could not see evidence the management review control was operating effectively. Cause The University?s HEERF reporting process did not include a requirement to maintain the review documentation and did not operate at a level of precision sufficient to ensure timely and accurate reporting. Effect If appropriate controls are not designed and operating effectively over the HEERF reporting process, HEERF expenditures reported on the University?s website and to U.S. Department of Education may be incomplete, inaccurate, or not posted within the timeframe required resulting in non-compliance. Questioned Costs None noted. Recommendation We recommend that the University implement a implement a requirement to maintain the review documentation and incorporate a detailed review of the various fields of the form to ensure accuracy as well as to ensure the HEERF reporting is completed timely.
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: 84.425C Federal Award Number and Year (or Other Identifying Number): S425C200018 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 in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirement. INDIANA STATE BOARD OF ACCOUNTS 19 LAKE STATION COMMUNITY SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) The School Corporation completed three annual Elementary and Secondary School Emergency Relief (ESSER) and two Governor's Emergency Education Relief (GEER) annual Data Collection reports (Reports) during the audit period. Data on one report, the GEER I, Year 1 annual report, did not agree to unit's ledger. The expenditures reported on the GEER I, Year 1 annual report were $202,500; however, the School Corporation had no expenditures from the GEER fund during the year 1 reporting period. The lack of internal controls and noncompliance were isolated to the GEER I, Year 1 annual report. 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 Management had not established a system of internal controls that would have ensured compliance with the grant agreement and the Reporting compliance requirement. Effect The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Reporting compliance requirement could result in the loss of future federal funds to the School Corporation. INDIANA STATE BOARD OF ACCOUNTS 20 LAKE STATION COMMUNITY SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish internal controls to ensure compliance 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.
Criteria: There are three components to reporting for HEERF: 1) public reporting on the (a)(1) Student Aid Portion (Quarterly Student Report); 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Institutional Reports), as applicable; and 3) the annual report (Annual Report). The Coronavirus Aid, Relief, and Economic Security (CARES) Act 18004(e) and the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. While American Rescue Plan (ARP) does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, ED exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Per the Form Instructions included on the ?Quarterly Budget and Expenditure Reporting for HEERF I, II, and III (a)(1) Institutional Portion, (a)(2), and (a)(3), if applicable? form, the completed form must be conspicuously posted on the institution?s primary website no later than 10 days after the end of each calendar quarter. Additionally, the Form Instructions include that reports must be maintained for at least three years after the submission of the final report. Condition: Management did not provide sufficient documentation to support the data included in the Annual Report, Quarterly Institutional Reports and Quarterly Student Reports. In addition, for one quarter, a Quarterly Institutional Report and a Quarterly Student Report was not retained on the University?s website. Context: Management provided documentation to support the information included in the reports; however, in several instances, the information provided either did not agree to the data included in the reports or it was unclear as to how the information supported the reports. In addition, the Quarterly Institutional Report and Quarterly Student Report for the quarter ended September 30, 2021 was prepared and posted on the University?s website; however, the reports were erroneously removed. Cause: Management indicated that due to the urgency in ensuring funds were distributed as quickly as possible, documented policies and procedures over reporting for the program were not developed. Additionally, due to staff turnover, information was not retained in a manner that allowed it to be easily retrieved and compiled in a manner supporting the reports. Effect: The reports that were completed could contain inaccurate or incomplete data. In addition, the University was not compliant with the requirement to maintain the reports on the University?s website. Questioned Costs: None Identification of a repeat finding: This is a repeat finding of 2021-003. Recommendations: As the HEERF Program has ended for the University, we recommend that should similar programs become available in the future, that management develop documented policies and procedures to administer the program and that management maintain documentation to evidence the internal controls. Views of responsible officials: The HPU Office of Sponsored Projects (OSP) and Office of Financial Aid work to follow all federal reporting regulations and guidance mandated for the Federal grant & contract programs. For future programs, the Institutional Research, the Office of Sponsored Projects and the Financial Aid Office will generate the reports and will implement layers of review procedure to ensure that the reports are accurate, complete, submitted timely, and if needed, posted in HPU website. For the Institution portion, the Manager for Grants and Contracts will prepare the grant report and this report will be reviewed by the Assistant VP for OSP. For the student portion the periodic reports will be prepared by the staff of the Office of Financial Aid and will be reviewed by the Director of the Financial Aid office. The Business Office will perform a high-level independent review for completeness and accuracy. Finally, moving forward, all the files and documents that support the grant report will be retained.
Criteria: There are three components to reporting for HEERF: 1) public reporting on the (a)(1) Student Aid Portion (Quarterly Student Report); 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Institutional Reports), as applicable; and 3) the annual report (Annual Report). The Coronavirus Aid, Relief, and Economic Security (CARES) Act 18004(e) and the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. While American Rescue Plan (ARP) does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, ED exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Per the Form Instructions included on the ?Quarterly Budget and Expenditure Reporting for HEERF I, II, and III (a)(1) Institutional Portion, (a)(2), and (a)(3), if applicable? form, the completed form must be conspicuously posted on the institution?s primary website no later than 10 days after the end of each calendar quarter. Additionally, the Form Instructions include that reports must be maintained for at least three years after the submission of the final report. Condition: Management did not provide sufficient documentation to support the data included in the Annual Report, Quarterly Institutional Reports and Quarterly Student Reports. In addition, for one quarter, a Quarterly Institutional Report and a Quarterly Student Report was not retained on the University?s website. Context: Management provided documentation to support the information included in the reports; however, in several instances, the information provided either did not agree to the data included in the reports or it was unclear as to how the information supported the reports. In addition, the Quarterly Institutional Report and Quarterly Student Report for the quarter ended September 30, 2021 was prepared and posted on the University?s website; however, the reports were erroneously removed. Cause: Management indicated that due to the urgency in ensuring funds were distributed as quickly as possible, documented policies and procedures over reporting for the program were not developed. Additionally, due to staff turnover, information was not retained in a manner that allowed it to be easily retrieved and compiled in a manner supporting the reports. Effect: The reports that were completed could contain inaccurate or incomplete data. In addition, the University was not compliant with the requirement to maintain the reports on the University?s website. Questioned Costs: None Identification of a repeat finding: This is a repeat finding of 2021-003. Recommendations: As the HEERF Program has ended for the University, we recommend that should similar programs become available in the future, that management develop documented policies and procedures to administer the program and that management maintain documentation to evidence the internal controls. Views of responsible officials: The HPU Office of Sponsored Projects (OSP) and Office of Financial Aid work to follow all federal reporting regulations and guidance mandated for the Federal grant & contract programs. For future programs, the Institutional Research, the Office of Sponsored Projects and the Financial Aid Office will generate the reports and will implement layers of review procedure to ensure that the reports are accurate, complete, submitted timely, and if needed, posted in HPU website. For the Institution portion, the Manager for Grants and Contracts will prepare the grant report and this report will be reviewed by the Assistant VP for OSP. For the student portion the periodic reports will be prepared by the staff of the Office of Financial Aid and will be reviewed by the Director of the Financial Aid office. The Business Office will perform a high-level independent review for completeness and accuracy. Finally, moving forward, all the files and documents that support the grant report will be retained.
Criteria: There are three components to reporting for HEERF: 1) public reporting on the (a)(1) Student Aid Portion (Quarterly Student Report); 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Institutional Reports), as applicable; and 3) the annual report (Annual Report). The Coronavirus Aid, Relief, and Economic Security (CARES) Act 18004(e) and the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. While American Rescue Plan (ARP) does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, ED exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Per the Form Instructions included on the ?Quarterly Budget and Expenditure Reporting for HEERF I, II, and III (a)(1) Institutional Portion, (a)(2), and (a)(3), if applicable? form, the completed form must be conspicuously posted on the institution?s primary website no later than 10 days after the end of each calendar quarter. Additionally, the Form Instructions include that reports must be maintained for at least three years after the submission of the final report. Condition: Management did not provide sufficient documentation to support the data included in the Annual Report, Quarterly Institutional Reports and Quarterly Student Reports. In addition, for one quarter, a Quarterly Institutional Report and a Quarterly Student Report was not retained on the University?s website. Context: Management provided documentation to support the information included in the reports; however, in several instances, the information provided either did not agree to the data included in the reports or it was unclear as to how the information supported the reports. In addition, the Quarterly Institutional Report and Quarterly Student Report for the quarter ended September 30, 2021 was prepared and posted on the University?s website; however, the reports were erroneously removed. Cause: Management indicated that due to the urgency in ensuring funds were distributed as quickly as possible, documented policies and procedures over reporting for the program were not developed. Additionally, due to staff turnover, information was not retained in a manner that allowed it to be easily retrieved and compiled in a manner supporting the reports. Effect: The reports that were completed could contain inaccurate or incomplete data. In addition, the University was not compliant with the requirement to maintain the reports on the University?s website. Questioned Costs: None Identification of a repeat finding: This is a repeat finding of 2021-003. Recommendations: As the HEERF Program has ended for the University, we recommend that should similar programs become available in the future, that management develop documented policies and procedures to administer the program and that management maintain documentation to evidence the internal controls. Views of responsible officials: The HPU Office of Sponsored Projects (OSP) and Office of Financial Aid work to follow all federal reporting regulations and guidance mandated for the Federal grant & contract programs. For future programs, the Institutional Research, the Office of Sponsored Projects and the Financial Aid Office will generate the reports and will implement layers of review procedure to ensure that the reports are accurate, complete, submitted timely, and if needed, posted in HPU website. For the Institution portion, the Manager for Grants and Contracts will prepare the grant report and this report will be reviewed by the Assistant VP for OSP. For the student portion the periodic reports will be prepared by the staff of the Office of Financial Aid and will be reviewed by the Director of the Financial Aid office. The Business Office will perform a high-level independent review for completeness and accuracy. Finally, moving forward, all the files and documents that support the grant report will be retained.
FINDING 2022-006 Subject: Child Nutrition Cluster - Reporting Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children, COVID-19 - Summer Food Service Program for Children Assistance Listings Numbers: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY 2020-2021, FY 2021-2022 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters Condition and Context An effective system of internal controls was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirement. Monthly Sponsor Claims for Reimbursement (Claims) were submitted to the Indiana Department of Education (IDOE) based upon meals served for the month. All four Claims tested had differences between the Claims submitted and the School Corporation's summary meal count reports. Meal counts did not match the ledgers provided by the Food Management Service Company (FMSC) nor the internally generated reports of the School Corporation. 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 CENTRAL NOBLE COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 2 CFR 200.302(b) (Uniform Guidance) 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 ?? 200.327 Financial reporting and 200.328 Monitoring and reporting program performance. . . ." 2 CFR 200.302(b) (Revised Uniform Guidance) 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 developed a system of internal controls that would have ensured compliance with the grant agreement and the Reporting compliance requirement. Effect The failure to establish an effective system of internal controls enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Reporting compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure compliance and comply with 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 2022-006 Subject: Child Nutrition Cluster - Reporting Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children, COVID-19 - Summer Food Service Program for Children Assistance Listings Numbers: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY 2020-2021, FY 2021-2022 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters Condition and Context An effective system of internal controls was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirement. Monthly Sponsor Claims for Reimbursement (Claims) were submitted to the Indiana Department of Education (IDOE) based upon meals served for the month. All four Claims tested had differences between the Claims submitted and the School Corporation's summary meal count reports. Meal counts did not match the ledgers provided by the Food Management Service Company (FMSC) nor the internally generated reports of the School Corporation. 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 CENTRAL NOBLE COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 2 CFR 200.302(b) (Uniform Guidance) 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 ?? 200.327 Financial reporting and 200.328 Monitoring and reporting program performance. . . ." 2 CFR 200.302(b) (Revised Uniform Guidance) 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 developed a system of internal controls that would have ensured compliance with the grant agreement and the Reporting compliance requirement. Effect The failure to establish an effective system of internal controls enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Reporting compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure compliance and comply with 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 2022-006 Subject: Child Nutrition Cluster - Reporting Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children, COVID-19 - Summer Food Service Program for Children Assistance Listings Numbers: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY 2020-2021, FY 2021-2022 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters Condition and Context An effective system of internal controls was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirement. Monthly Sponsor Claims for Reimbursement (Claims) were submitted to the Indiana Department of Education (IDOE) based upon meals served for the month. All four Claims tested had differences between the Claims submitted and the School Corporation's summary meal count reports. Meal counts did not match the ledgers provided by the Food Management Service Company (FMSC) nor the internally generated reports of the School Corporation. 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 CENTRAL NOBLE COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 2 CFR 200.302(b) (Uniform Guidance) 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 ?? 200.327 Financial reporting and 200.328 Monitoring and reporting program performance. . . ." 2 CFR 200.302(b) (Revised Uniform Guidance) 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 developed a system of internal controls that would have ensured compliance with the grant agreement and the Reporting compliance requirement. Effect The failure to establish an effective system of internal controls enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Reporting compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure compliance and comply with 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 2022-006 Subject: Child Nutrition Cluster - Reporting Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children, COVID-19 - Summer Food Service Program for Children Assistance Listings Numbers: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY 2020-2021, FY 2021-2022 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters Condition and Context An effective system of internal controls was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirement. Monthly Sponsor Claims for Reimbursement (Claims) were submitted to the Indiana Department of Education (IDOE) based upon meals served for the month. All four Claims tested had differences between the Claims submitted and the School Corporation's summary meal count reports. Meal counts did not match the ledgers provided by the Food Management Service Company (FMSC) nor the internally generated reports of the School Corporation. 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 CENTRAL NOBLE COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 2 CFR 200.302(b) (Uniform Guidance) 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 ?? 200.327 Financial reporting and 200.328 Monitoring and reporting program performance. . . ." 2 CFR 200.302(b) (Revised Uniform Guidance) 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 developed a system of internal controls that would have ensured compliance with the grant agreement and the Reporting compliance requirement. Effect The failure to establish an effective system of internal controls enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Reporting compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure compliance and comply with 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 2022-006 Subject: Child Nutrition Cluster - Reporting Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children, COVID-19 - Summer Food Service Program for Children Assistance Listings Numbers: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY 2020-2021, FY 2021-2022 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters Condition and Context An effective system of internal controls was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirement. Monthly Sponsor Claims for Reimbursement (Claims) were submitted to the Indiana Department of Education (IDOE) based upon meals served for the month. All four Claims tested had differences between the Claims submitted and the School Corporation's summary meal count reports. Meal counts did not match the ledgers provided by the Food Management Service Company (FMSC) nor the internally generated reports of the School Corporation. 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 CENTRAL NOBLE COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 2 CFR 200.302(b) (Uniform Guidance) 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 ?? 200.327 Financial reporting and 200.328 Monitoring and reporting program performance. . . ." 2 CFR 200.302(b) (Revised Uniform Guidance) 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 developed a system of internal controls that would have ensured compliance with the grant agreement and the Reporting compliance requirement. Effect The failure to establish an effective system of internal controls enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Reporting compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure compliance and comply with 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 2022-006 Subject: Child Nutrition Cluster - Reporting Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children, COVID-19 - Summer Food Service Program for Children Assistance Listings Numbers: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY 2020-2021, FY 2021-2022 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters Condition and Context An effective system of internal controls was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirement. Monthly Sponsor Claims for Reimbursement (Claims) were submitted to the Indiana Department of Education (IDOE) based upon meals served for the month. All four Claims tested had differences between the Claims submitted and the School Corporation's summary meal count reports. Meal counts did not match the ledgers provided by the Food Management Service Company (FMSC) nor the internally generated reports of the School Corporation. 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 CENTRAL NOBLE COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 2 CFR 200.302(b) (Uniform Guidance) 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 ?? 200.327 Financial reporting and 200.328 Monitoring and reporting program performance. . . ." 2 CFR 200.302(b) (Revised Uniform Guidance) 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 developed a system of internal controls that would have ensured compliance with the grant agreement and the Reporting compliance requirement. Effect The failure to establish an effective system of internal controls enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Reporting compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure compliance and comply with 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 2022-005 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 Number and Year (or Other Identifying Number): S010A200014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters Condition and Context An effective internal control system was not designed, or implemented at the School Corporation to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirement. Total expenditures reported on the 2020-2021 Final Expenditure Report (Report) were not supported by the School Corporation's ledgers. Total expenditures on the Report were $578,452 whereas expenditures per the ledgers were $677,514. 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 21 CONCORD COMMUNITY SCHOOLS 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 Management had not developed a system of internal controls that would have ensured compliance with the Reporting compliance requirement. Effect The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Reporting compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure compliance 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.
Condition: Based on the controls in place as described by staff of the organization, there were multiple instances of invoices and timesheets that did not contain evidence of approvals. Criteria: Monitoring and reporting program performance, as prescribed by 2 CFR section 200.329, requires all requests for reimbursement and reports to be evidenced by formal review and approval processes. Effect: By not having proper review and approvals in place, inaccurate information could have been submitted to the funding agency. In addition, the funding agency could have rejected reimbursement requests and found the Organization to be out of compliance. Cause: There is inconsistent documentation of approvals on invoices and timesheets. In addition, there is no formalized procedure in place on reviewing and submitting the required reports to the funding agency. Questioned Costs: No known questioned costs were identified during the course of the audit. Recommendation: We recommend the Organization further develop their policies and procedures related to federal awards to ensure compliance with the grant contracts and ensure there is proper review and documented approval.
FINDING 2022-002 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, Other Matters Condition and Context An effective internal controls system was not designed, nor implemented at the School Corporation to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirement. The School Corporation had not designed, nor implemented a system of internal control to ensure that the annual Elementary and Secondary School Emergency Relief (ESSER) annual Data Collection reports (Reports) were complete and accurately submitted. The Reports were prepared by one employee without an oversight or review process in place to prevent, or detect and correct, errors. Additionally, for one of seven key line items tested the School Corporation could not provide supporting documentation. The lack of supporting documentation for the full time equivalent(FTE) key line item on the ESSER I, Year 1, annual report prevented the determination of the accuracy of the line item. The lack of internal controls was a systemic issue throughout the audit period. The noncompliance was isolated to the ESSER 1, Year 1 report. 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 Management had not developed or implemented a system of internal controls that would have ensured compliance with the grant agreement and the Reporting compliance requirement. Effect The failure to establish an effective internal controls system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and Reporting compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish internal controls to ensure compliance 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 2022-002 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, Other Matters Condition and Context An effective internal controls system was not designed, nor implemented at the School Corporation to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirement. The School Corporation had not designed, nor implemented a system of internal control to ensure that the annual Elementary and Secondary School Emergency Relief (ESSER) annual Data Collection reports (Reports) were complete and accurately submitted. The Reports were prepared by one employee without an oversight or review process in place to prevent, or detect and correct, errors. Additionally, for one of seven key line items tested the School Corporation could not provide supporting documentation. The lack of supporting documentation for the full time equivalent(FTE) key line item on the ESSER I, Year 1, annual report prevented the determination of the accuracy of the line item. The lack of internal controls was a systemic issue throughout the audit period. The noncompliance was isolated to the ESSER 1, Year 1 report. 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 Management had not developed or implemented a system of internal controls that would have ensured compliance with the grant agreement and the Reporting compliance requirement. Effect The failure to establish an effective internal controls system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and Reporting compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish internal controls to ensure compliance 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 2022-002 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, Other Matters Condition and Context An effective internal controls system was not designed, nor implemented at the School Corporation to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirement. The School Corporation had not designed, nor implemented a system of internal control to ensure that the annual Elementary and Secondary School Emergency Relief (ESSER) annual Data Collection reports (Reports) were complete and accurately submitted. The Reports were prepared by one employee without an oversight or review process in place to prevent, or detect and correct, errors. Additionally, for one of seven key line items tested the School Corporation could not provide supporting documentation. The lack of supporting documentation for the full time equivalent(FTE) key line item on the ESSER I, Year 1, annual report prevented the determination of the accuracy of the line item. The lack of internal controls was a systemic issue throughout the audit period. The noncompliance was isolated to the ESSER 1, Year 1 report. 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 Management had not developed or implemented a system of internal controls that would have ensured compliance with the grant agreement and the Reporting compliance requirement. Effect The failure to establish an effective internal controls system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and Reporting compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish internal controls to ensure compliance 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.
Criteria: There are three components to reporting for HEERF: 1) public reporting on the (a)(1) Student Aid Portion (Quarterly Student Report); 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Institutional Reports), as applicable; and 3) the annual report (Annual Report). The Coronavirus Aid, Relief, and Economic Security (CARES) Act 18004(e) and the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. While American Rescue Plan (ARP) does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, ED exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Per the Form Instructions included on the ?Quarterly Budget and Expenditure Reporting for HEERF I, II, and III (a)(1) Institutional Portion, (a)(2), and (a)(3), if applicable? form, the completed form must be conspicuously posted on the institution?s primary website no later than 10 days after the end of each calendar quarter. Additionally, the Form Instructions include that reports must be maintained for at least three years after the submission of the final report. Condition: Management did not provide sufficient documentation to support the data included in the Annual Report, Quarterly Institutional Reports and Quarterly Student Reports. In addition, for one quarter, a Quarterly Institutional Report and a Quarterly Student Report was not retained on the University?s website. Context: Management provided documentation to support the information included in the reports; however, in several instances, the information provided either did not agree to the data included in the reports or it was unclear as to how the information supported the reports. In addition, the Quarterly Institutional Report and Quarterly Student Report for the quarter ended September 30, 2021 was prepared and posted on the University?s website; however, the reports were erroneously removed. Cause: Management indicated that due to the urgency in ensuring funds were distributed as quickly as possible, documented policies and procedures over reporting for the program were not developed. Additionally, due to staff turnover, information was not retained in a manner that allowed it to be easily retrieved and compiled in a manner supporting the reports. Effect: The reports that were completed could contain inaccurate or incomplete data. In addition, the University was not compliant with the requirement to maintain the reports on the University?s website. Questioned Costs: None Identification of a repeat finding: This is a repeat finding of 2021-003. Recommendations: As the HEERF Program has ended for the University, we recommend that should similar programs become available in the future, that management develop documented policies and procedures to administer the program and that management maintain documentation to evidence the internal controls. Views of responsible officials: The HPU Office of Sponsored Projects (OSP) and Office of Financial Aid work to follow all federal reporting regulations and guidance mandated for the Federal grant & contract programs. For future programs, the Institutional Research, the Office of Sponsored Projects and the Financial Aid Office will generate the reports and will implement layers of review procedure to ensure that the reports are accurate, complete, submitted timely, and if needed, posted in HPU website. For the Institution portion, the Manager for Grants and Contracts will prepare the grant report and this report will be reviewed by the Assistant VP for OSP. For the student portion the periodic reports will be prepared by the staff of the Office of Financial Aid and will be reviewed by the Director of the Financial Aid office. The Business Office will perform a high-level independent review for completeness and accuracy. Finally, moving forward, all the files and documents that support the grant report will be retained.
"COVID-19 Higher Education Emergency Relief Fund Program Assistance Lising Number 84.425E COVID-19 Relief Fund for Student Aid U.S. Department of Education Program Year 2021-2022" Criteria or specific requirement ? Quarterly Public Reporting for (a)(1) Student Aid Portion 2 CFR Sections 200.328 and 200.329. Condition ? University did not disclose on their website the estimated total number of students at the institution that are eligible to receive Emergency Financial Aid Grants to Students under the ARP (a)(1) subprogram. Questioned costs ? None Context ? Out of the population of nine special reporting requirements for the fiscal year, a sample of three reports were selected for testing. For the Q2 public reporting for Student Aid Portion, the estimated total number of students at the institution that were eligible to receive Emergency Financial Aid Grants to Students under the ARP (a)(1) subprogram was not publicly posted to the institution's website. This sample was not a statistically valid sample. Effect ? The public was not notified of of the estimated total number of students at the institution that were eligible to receive Emergency Financial Aid Grants to Students under the ARP (a)(1) subprogram in a timely or accurate manner. Cause ? Personnel responsible for reporting overlooked the public posting requirement of grant information for HEERF grantees as noted in 86 FR 26213. Indication as a repeat finding ? N/A Recommendation ? The University should review its procedures for publicly reporting the Student Aid Portion in accordance with 86 FR 26213.
The Lawrence County Fiscal Court Did Not Establish And Maintain Effective Internal Controls Over Compliance With Coronavirus State and Local Fiscal Recovery Fund (SLFRF) Requirements Federal Program: Assistance Listing #: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Award Number and Year: 2022 Name of Federal Agency: U.S. Department of the Treasury Compliance Requirements: Activities Allowed or Unallowed; Allowable Costs/Cost Principles; Reporting Type of Finding: Significant Deficiency Amount of Questioned Costs: $0 COVID Related: Yes The Lawrence County Fiscal Court transferred federal funds from the ARPA fund to the general, jail, road, LGEA, and E-911 funds without first ensuring sufficient supporting documentation of allowable expenditures during the same period as the funds were reported as expended on the Schedule of Expenditures of Federal Awards (SEFA). The county was awarded $2,975,148 in American Rescue Plan Act (ARPA) funds, receiving the first payment of $1,487,618 into the ARPA fund in May 2021, and their second payment of $1,487,530 in June 2022.The fiscal court?s transfers in total from the ARPA fund to each fund are provided below: ? General - $714,640 ? Road - $250,000 ? Jail - $40,000 ? LGEA - $25,000 ? E-911 - $10,000 ? Payroll - $217,739 These transfers from the ARPA fund were considered ?lost revenue? according to their fiscal court meeting minutes. At the time of these transfers, and until auditors inquired about the supporting documentation, the county did not maintain a list of expenditures that reconciled to the transfer total. After this inquiry, the county gathered documentation and provided auditors a reconciliation of expenditures of eligible costs that supported the amount transferred into the general fund. An effective internal control system was not in place in Lawrence County to ensure compliance with requirements related to the administration of ARPA funds and the Allowable Costs/Cost Principles compliance requirements. The lack of internal controls was a systemic issue throughout the period. Failure to establish and maintain effective internal controls over compliance with federal program requirements could subject the county to the risk of reporting ineligible expenditures on the SEFA and using grant funds for unallowable purposes. 2 CFR 200.303 states in part, ?[t]he 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.? 2 CFR ?200.302(b) states, ?[t]he financial management system of each non-Federal entity must provide for the following ?: (2) [a]ccurate, current and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set for in ?200.328 and 200.329.? In addition, 2 CFR ?200.502(a) states, ?[t]he determination of when a Federal award is expended must be based on when the activity related to the Federal award occurs.? Therefore, the county should only include expenditures on the Schedule of Expenditures of Federal Awards (SEFA) for which there is sufficient supporting documentation. We recommend the county establish and maintain internal controls over compliance for all federal program expenditures to ensure accurate use and reporting of federal awards, including maintaining sufficient supporting documentation of expenditures that reconciles to any transfer from a federal program fund into other county funds.
Finding 2022-003 ? Significant Deficiency, Compliance and Control Federal Assistance Listing No. 84.425E U.S. Department Of Education ESF Section 2 ? Higher Education (Higher Education Emergency Relief Fund (HEERF)) - Reporting Criteria: 2 CFR section 200.328 and 2 CFR section 200.329 requires grantees to submit quarterly reports for both student and institutional portions along with an annual report to the Department of Education. Condition: In our nonstatistical testing of 2 quarterly reports and 1 annual report, it was noted that for the one student report selected, the University excluded a subset of non-Title IV eligible students from the estimated total number of students at the institution that are eligible to receive Emergency Financial Aid Grants to Students under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms. Cause: Management based the reporting requirement on the HEERF 1 guidance, which had more stringent eligibility requirements, in reporting the estimated total number of students at the institution that are eligible to receive Emergency Financial Aid Grants to Students under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms. Effect: The estimated total number of students at the institution eligible to receive emergency financial aid grants to students reported was less than the actual by approximately 400 students. Questioned Costs: Not applicable Context: One item on the selected student report was not reported in conformity with the guidance. Identification As A Repeat Finding: Not a repeat finding. Recommendation: We recommend that management develop a system with appropriate controls that allows for implementing the most recent guidance on HEERF reporting. Views Of Responsible Officials/Corrective Action Plan (Unaudited): The Controller and Compliance Officers are working together to correct the previously filed reports to update the estimated total number of students at the institution that are eligible to receive Emergency Financial Aid Grants to Students under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms. Completion Date: April 2023 Contact Person: Tom Corley, Controller and Director of Fiscal Operations and Carrie Stevens, Associate Vice President of Compliance
Finding 2022-003 ? Significant Deficiency, Compliance and Control Federal Assistance Listing No. 84.425E U.S. Department Of Education ESF Section 2 ? Higher Education (Higher Education Emergency Relief Fund (HEERF)) - Reporting Criteria: 2 CFR section 200.328 and 2 CFR section 200.329 requires grantees to submit quarterly reports for both student and institutional portions along with an annual report to the Department of Education. Condition: In our nonstatistical testing of 2 quarterly reports and 1 annual report, it was noted that for the one student report selected, the University excluded a subset of non-Title IV eligible students from the estimated total number of students at the institution that are eligible to receive Emergency Financial Aid Grants to Students under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms. Cause: Management based the reporting requirement on the HEERF 1 guidance, which had more stringent eligibility requirements, in reporting the estimated total number of students at the institution that are eligible to receive Emergency Financial Aid Grants to Students under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms. Effect: The estimated total number of students at the institution eligible to receive emergency financial aid grants to students reported was less than the actual by approximately 400 students. Questioned Costs: Not applicable Context: One item on the selected student report was not reported in conformity with the guidance. Identification As A Repeat Finding: Not a repeat finding. Recommendation: We recommend that management develop a system with appropriate controls that allows for implementing the most recent guidance on HEERF reporting. Views Of Responsible Officials/Corrective Action Plan (Unaudited): The Controller and Compliance Officers are working together to correct the previously filed reports to update the estimated total number of students at the institution that are eligible to receive Emergency Financial Aid Grants to Students under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms. Completion Date: April 2023 Contact Person: Tom Corley, Controller and Director of Fiscal Operations and Carrie Stevens, Associate Vice President of Compliance
Finding 2022-003 ? Significant Deficiency, Compliance and Control Federal Assistance Listing No. 84.425E U.S. Department Of Education ESF Section 2 ? Higher Education (Higher Education Emergency Relief Fund (HEERF)) - Reporting Criteria: 2 CFR section 200.328 and 2 CFR section 200.329 requires grantees to submit quarterly reports for both student and institutional portions along with an annual report to the Department of Education. Condition: In our nonstatistical testing of 2 quarterly reports and 1 annual report, it was noted that for the one student report selected, the University excluded a subset of non-Title IV eligible students from the estimated total number of students at the institution that are eligible to receive Emergency Financial Aid Grants to Students under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms. Cause: Management based the reporting requirement on the HEERF 1 guidance, which had more stringent eligibility requirements, in reporting the estimated total number of students at the institution that are eligible to receive Emergency Financial Aid Grants to Students under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms. Effect: The estimated total number of students at the institution eligible to receive emergency financial aid grants to students reported was less than the actual by approximately 400 students. Questioned Costs: Not applicable Context: One item on the selected student report was not reported in conformity with the guidance. Identification As A Repeat Finding: Not a repeat finding. Recommendation: We recommend that management develop a system with appropriate controls that allows for implementing the most recent guidance on HEERF reporting. Views Of Responsible Officials/Corrective Action Plan (Unaudited): The Controller and Compliance Officers are working together to correct the previously filed reports to update the estimated total number of students at the institution that are eligible to receive Emergency Financial Aid Grants to Students under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms. Completion Date: April 2023 Contact Person: Tom Corley, Controller and Director of Fiscal Operations and Carrie Stevens, Associate Vice President of Compliance
FINDING 2022-009 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425C, 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425C200018, S425D200013, S425U200013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters Condition and Context An effective internal control system was not designed nor implemented at the School Corporation to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirement. The School Corporation completed and submitted four annual Data Collection reports (Reports) for the Elementary and Secondary School Emergency Relief (ESSER) grants and two Reports for the Governors Emergency Education Relief (GEER) grant. The reported data on three of the Reports as noted below could not be traced back to records that accumulate or summarize the data; therefore, the accuracy and completeness of the Reports could not be verified. ESSER I, Year 1 Report and GEER I, Year 1 Report The full-time equivalent (FTE) positions could not be verified. A spreadsheet that showed FTE positions was provided for audit; however, the spreadsheet had more FTE positions then what was reported due to the School Corporations software incorrectly assigning FTE positions to all items paid. ESSER III, Year 1 Report The School Corporation's ledgers indicated expenses totaling $43,084 were spent for salaries and stipends during the reporting period. However, these expenditures were not included in the report. 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. . . . (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." 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 Management had not developed a system of internal controls that would have ensured compliance with the grant agreement and Reporting compliance requirement. Effect The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Reporting compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish effective internal controls to ensure compliance 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 2022-009 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425C, 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425C200018, S425D200013, S425U200013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters Condition and Context An effective internal control system was not designed nor implemented at the School Corporation to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirement. The School Corporation completed and submitted four annual Data Collection reports (Reports) for the Elementary and Secondary School Emergency Relief (ESSER) grants and two Reports for the Governors Emergency Education Relief (GEER) grant. The reported data on three of the Reports as noted below could not be traced back to records that accumulate or summarize the data; therefore, the accuracy and completeness of the Reports could not be verified. ESSER I, Year 1 Report and GEER I, Year 1 Report The full-time equivalent (FTE) positions could not be verified. A spreadsheet that showed FTE positions was provided for audit; however, the spreadsheet had more FTE positions then what was reported due to the School Corporations software incorrectly assigning FTE positions to all items paid. ESSER III, Year 1 Report The School Corporation's ledgers indicated expenses totaling $43,084 were spent for salaries and stipends during the reporting period. However, these expenditures were not included in the report. 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. . . . (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." 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 Management had not developed a system of internal controls that would have ensured compliance with the grant agreement and Reporting compliance requirement. Effect The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Reporting compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish effective internal controls to ensure compliance 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 2022-009 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425C, 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425C200018, S425D200013, S425U200013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters Condition and Context An effective internal control system was not designed nor implemented at the School Corporation to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirement. The School Corporation completed and submitted four annual Data Collection reports (Reports) for the Elementary and Secondary School Emergency Relief (ESSER) grants and two Reports for the Governors Emergency Education Relief (GEER) grant. The reported data on three of the Reports as noted below could not be traced back to records that accumulate or summarize the data; therefore, the accuracy and completeness of the Reports could not be verified. ESSER I, Year 1 Report and GEER I, Year 1 Report The full-time equivalent (FTE) positions could not be verified. A spreadsheet that showed FTE positions was provided for audit; however, the spreadsheet had more FTE positions then what was reported due to the School Corporations software incorrectly assigning FTE positions to all items paid. ESSER III, Year 1 Report The School Corporation's ledgers indicated expenses totaling $43,084 were spent for salaries and stipends during the reporting period. However, these expenditures were not included in the report. 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. . . . (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." 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 Management had not developed a system of internal controls that would have ensured compliance with the grant agreement and Reporting compliance requirement. Effect The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Reporting compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish effective internal controls to ensure compliance 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 2022-009 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425C, 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425C200018, S425D200013, S425U200013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters Condition and Context An effective internal control system was not designed nor implemented at the School Corporation to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirement. The School Corporation completed and submitted four annual Data Collection reports (Reports) for the Elementary and Secondary School Emergency Relief (ESSER) grants and two Reports for the Governors Emergency Education Relief (GEER) grant. The reported data on three of the Reports as noted below could not be traced back to records that accumulate or summarize the data; therefore, the accuracy and completeness of the Reports could not be verified. ESSER I, Year 1 Report and GEER I, Year 1 Report The full-time equivalent (FTE) positions could not be verified. A spreadsheet that showed FTE positions was provided for audit; however, the spreadsheet had more FTE positions then what was reported due to the School Corporations software incorrectly assigning FTE positions to all items paid. ESSER III, Year 1 Report The School Corporation's ledgers indicated expenses totaling $43,084 were spent for salaries and stipends during the reporting period. However, these expenditures were not included in the report. 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. . . . (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." 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 Management had not developed a system of internal controls that would have ensured compliance with the grant agreement and Reporting compliance requirement. Effect The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Reporting compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish effective internal controls to ensure compliance 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 2022-008 Information on the federal program: Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID19 - Education Stabilization Fund Assistance Listings Numbers: 84.425C, 84.425D Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425C200018 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Significant Deficiency 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 reasonableassurance 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 incompliance with guidance in 'Standards for Internal Control in the Federal Government' issued by theComptroller General of the United States or the 'Internal Control Integrated Framework', issued by theCommittee 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 inaccordance with the reporting requirements set forth in ?? 200.328 and 200.329. . . ." Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirement. Cause: Management had not developed an effective system of internal controls that would have ensured compliance with the grant agreement and the Reporting compliance requirement. Effect: The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Reporting compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs: There were no questioned costs identified. Context: The School Corporation did not have an effective system of internal controls to ensure that the annual Elementary and Secondary School Emergency Relief (ESSER) and the Governor?s Emergency Education Relief (GEER) annual Data Collection reports (Reports) were accurately submitted. The School Corporation had six annual data reports due during the audit period. The Full Time Equivalent (FTE) key line item on both the ESSER I, Fiscal Year 2021 and the GEER, Fiscal Year 2021 annual Data Collection reports were not accurately submitted. The lack of internal controls and noncompliance were isolated to the ESSER 1, Fiscal Year 2021 and GEER, Fiscal Year 2021 reports. Identification as a repeat finding, if applicable: No Recommendation: We recommend that the School Corporation's management establish effective internal controls to ensure compliance and comply with the grant agreement and the Reporting compliance requirement. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
FINDING 2022-008 Information on the federal program: Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID19 - Education Stabilization Fund Assistance Listings Numbers: 84.425C, 84.425D Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425C200018 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Significant Deficiency 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 reasonableassurance 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 incompliance with guidance in 'Standards for Internal Control in the Federal Government' issued by theComptroller General of the United States or the 'Internal Control Integrated Framework', issued by theCommittee 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 inaccordance with the reporting requirements set forth in ?? 200.328 and 200.329. . . ." Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirement. Cause: Management had not developed an effective system of internal controls that would have ensured compliance with the grant agreement and the Reporting compliance requirement. Effect: The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Reporting compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs: There were no questioned costs identified. Context: The School Corporation did not have an effective system of internal controls to ensure that the annual Elementary and Secondary School Emergency Relief (ESSER) and the Governor?s Emergency Education Relief (GEER) annual Data Collection reports (Reports) were accurately submitted. The School Corporation had six annual data reports due during the audit period. The Full Time Equivalent (FTE) key line item on both the ESSER I, Fiscal Year 2021 and the GEER, Fiscal Year 2021 annual Data Collection reports were not accurately submitted. The lack of internal controls and noncompliance were isolated to the ESSER 1, Fiscal Year 2021 and GEER, Fiscal Year 2021 reports. Identification as a repeat finding, if applicable: No Recommendation: We recommend that the School Corporation's management establish effective internal controls to ensure compliance and comply with the grant agreement and the Reporting compliance requirement. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.