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.
Finding 2022-005 Information on the federal program: Subject: Child Nutrition Cluster - Reporting Federal Agency: Department of Agriculture Federal Programs: National School Lunch Program Assistance Listing Number: 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY 20-21, FY 21-22 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Reporting Audit Findings: Material Weakness Criteria: 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)...." 2 CFR 200.302(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." 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 Child Nutrition Cluster - Reporting compliance requirements. Section III ? Federal Award Findings and Questioned Costs (Continued) FINDING 2021-005 (Continued) 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 internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the Reporting compliance requirement. Questioned Costs: There were no questioned costs identified. Context: There was no documented control in place over the preparation/submission of monthly CNC reimbursement claims. The Food Service Director prepares the monthly reimbursement claims, however, there was no documentation that the reimbursement claims had been reviewed anyone other than the preparer. This was a systemic issue through the audit period. Identification as a repeat finding: No. Recommendation: We recommended that the School Corporation's management establish a documented system of internal control for review and approval related to the grant?s reporting compliance requirements Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Finding 2022-005 Information on the federal program: Subject: Child Nutrition Cluster - Reporting Federal Agency: Department of Agriculture Federal Programs: National School Lunch Program Assistance Listing Number: 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY 20-21, FY 21-22 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Reporting Audit Findings: Material Weakness Criteria: 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)...." 2 CFR 200.302(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." 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 Child Nutrition Cluster - Reporting compliance requirements. Section III ? Federal Award Findings and Questioned Costs (Continued) FINDING 2021-005 (Continued) 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 internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the Reporting compliance requirement. Questioned Costs: There were no questioned costs identified. Context: There was no documented control in place over the preparation/submission of monthly CNC reimbursement claims. The Food Service Director prepares the monthly reimbursement claims, however, there was no documentation that the reimbursement claims had been reviewed anyone other than the preparer. This was a systemic issue through the audit period. Identification as a repeat finding: No. Recommendation: We recommended that the School Corporation's management establish a documented system of internal control for review and approval related to the grant?s reporting compliance requirements Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
2022-001 Untimely and Inaccurate Reporting - Significant Deficiency Department of Education ALN #: 84.425E and 84.425F Criteria: Per 2 CFR section 200.328 and 2 CFR section 200.329, the College must accurately complete quarterly reports and post the completed forms to a publicly accessible location on the College?s website within 10 days of a quarter end. Condition: The College did not accurately complete and/or post three of the four quarterly reports to a publicly accessible location on the College?s website for the period July 1, 2021 through June 30, 2022. Cause: Turnover in the Vice President of Finance position responsible for report preparation combined with inadequate controls in place to review the quarterly reports for accuracy prior to posting to the College?s website. Questioned Costs: N/A Effect: The College was not in compliance with reporting requirements applicable to the HEERF program. Recommendation: Management should revise the quarterly reports, as applicable, noting the changes and post the revised reports to the College?s website. Management should submit copies of the revised report to HEERF reporting through the Department of Education. Management Response: Management agrees with this finding. Refer to the accompanying corrective action plan for additional information.
2022-001 Untimely and Inaccurate Reporting - Significant Deficiency Department of Education ALN #: 84.425E and 84.425F Criteria: Per 2 CFR section 200.328 and 2 CFR section 200.329, the College must accurately complete quarterly reports and post the completed forms to a publicly accessible location on the College?s website within 10 days of a quarter end. Condition: The College did not accurately complete and/or post three of the four quarterly reports to a publicly accessible location on the College?s website for the period July 1, 2021 through June 30, 2022. Cause: Turnover in the Vice President of Finance position responsible for report preparation combined with inadequate controls in place to review the quarterly reports for accuracy prior to posting to the College?s website. Questioned Costs: N/A Effect: The College was not in compliance with reporting requirements applicable to the HEERF program. Recommendation: Management should revise the quarterly reports, as applicable, noting the changes and post the revised reports to the College?s website. Management should submit copies of the revised report to HEERF reporting through the Department of Education. Management Response: Management agrees with this finding. Refer to the accompanying corrective action plan for additional information.
2022-001 Report Submission Delay Program: 93.778 Medicaid Cluster ? Medical Assistance Program, Pass-Through Awards #560005 and #559861 Criteria: In accordance with 2 CFR 200.329, non-Federal entities must submit performance reports at the interval required by the Federal awarding agency or pass-through entity no later than the specified due date. If a justified request is submitted by a non-Federal entity, the Federal agency may extend the due date for any performance report. Condition: During our audit, we identified two quarterly status reports that were submitted to the Contracting Officer?s Representative (COR) after the stated due date. Cause: During the reporting period, two Program Directors stepped down and their positions were temporarily filled by other Program Directors, causing delays in submission due to those individuals overseeing multiple programs with varying reporting requirements. Also, in one instance, UPAC was provided an updated report submission template one day prior to the stated due date and was not able to compile the necessary information into the new template by the stated due date. Effect: Reports were not submitted to the COR in a timely manner and requests for extension of the due date were not made. Questioned Costs: None noted. Context: In both instances, the reports were due to the COR within 20 days of the reporting period end and were submitted one day after the stated due date. Repeat Finding: No. Recommendation: When timely submission may not be possible, UPAC should request an extension from the COR by providing a notice of the delay and rationale for the late report, and, if approved, submit the report by the extended deadline. When extensions are not granted, UPAC should submit reports by the initial stated due date. Views of Responsible Officials: Management agrees with the finding and a response is included in the corrective action plan.
Criteria or Specific Requirement: The Code of Federal Regulations, 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. There are three components to reporting for Higher Education Emergency Relief Funds (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) 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 ARP does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, the Department of Education exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Specific to the quarterly reports, institutions are required to post two separate reports (institutional and student) for each quarter, including the quarterly reports from previous quarters. Quarterly reports should appear on the institution?s website as separate documents by quarter and should not be cumulative. Condition: The University is not in compliance with Student Aid quarterly reporting requirements for HEERF. Questioned Costs: None Context: We tested two of the four required Student Aid Quarterly Reports. While management was able to provide ?look back? reports for our testing, and we concluded the reports tested were completed accurately and timely, we noted that the Student Aid Quarterly Reports were not being maintained on the University?s website as required. We did note that the Institutional Quarterly Reports were being maintained on the Institution?s website as required. Cause: The University was not aware that the Student Aid Quarterly Reports were required to be maintained on the University?s website. Effect: The University was not in compliance with requirement to maintain Student Aid Quarterly Reports on the University?s website. Repeat Finding: No Recommendation: We recommend that the University post and maintain the Student Aid Quarterly reports on the University?s website, as required. In addition, in order to prevent similar instances in the future, we recommend the University ensure interpretation of guidance is accurate through the use of trainings, consultations, and direct correspondence with the regulatory agency, when necessary, to ensure full understanding of reporting requirements. View of Responsible Official: The University agrees with the finding.
2022-004 Department of Health and Human Services FFLA #93.087, 90CU0095, 9/30/2018 ? 9/29/2023 Enhance Safety of Children Affected by Substance Abuse Reporting Significant Deficiency in Internal Control over Compliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. 2 CFR 200.328 and 2 CFR 200.329 require the auditee to collect financial information and monitor its activities under federal awards to assure compliance with applicable federal requirements and performance expectations are being achieved and report these items in accordance with the program requirements. Condition: Through testing of one programmatic report, we noted amounts reported did not agree to supporting documentation. Programmatic information included within the report were included in the wrong category for services provided to adults and children and amounts were included in two categories for services in which no adults or children were provided services. Cause: The preparer of the report improperly inputted the case sizes within the incorrect column within the report and entered incorrect information in two instances. Effect: The report included programmatic information in the wrong categories for services provided and services not provided to adults and children. Questioned Costs: None reported. Context: Included under the award letter of the federal program, one combined quarterly federal cash transaction report was reviewed in the Center?s fiscal year. In addition, one semi-annual federal financial report and one semi-annual programmatic report was reviewed in the Center?s fiscal year. There was a total of 5 reports filed. Repeat Finding from Prior Year: Yes, prior year finding 2021-004 Recommendation: We recommend management review the procedures and control processes surrounding preparation and review of reports to ensure reports are completed based upon supporting documentation. View of Responsible Officials: Management is in agreement.
2022-006 Department of Health and Human Services FFLA #93.829, H79SM083331-02, 5/1/2021 ? 12/31/2022 Section 223 Demonstration Programs to Improve Community Mental Health Services Reporting Significant Deficiency in Internal Control over Compliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. 2 CFR 200.328 and 2 CFR 200.329 require the auditee to collect financial information and monitor its activities under federal awards to assure compliance with applicable federal requirements and performance expectations are being achieved and report these items in accordance with the program requirements. Condition: Through testing of one programmatic report, we noted the number of adults and children served during the reporting period included six individuals twice. Cause: As a result of a software change during the grant year, management combined the listing of adults and children served from two electronic health record systems and did not identify these six individuals were duplicates in the listings. Effect: The programmatic report included a total of six adults and children serviced during the reporting period twice. Questioned Costs: None reported. Context: Included under the award letter of the federal program, one annual federal financial report and one annual programmatic progress report was reviewed in the Center?s fiscal year. There was a total of 5 reports filed. Repeat Finding from Prior Year: Yes, prior year finding 2021-006 Recommendation: We recommend management review the procedures and control processes surrounding preparation and review of reports to ensure reports are completed based upon supporting documentation. View of Responsible Officials: Management is in agreement.
2022?020 REPORTING Federal Program Information: Federal Agency and Program Name Assistance Listing # U.S. Department of Education Rehabilitation Services?Vocational Rehabilitation Grants to State 84.126 Grant Award H126A200095, H126A210095, H126A220095Criteria: 2 CFR 200.303 requires that a 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 and the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 2 CFR 200.302(b)(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. If a Federal awarding agency requires reporting on an accrual basis from a recipient that maintains its records on other than an accrual basis, the recipient must not be required to establish an accrual accounting system. This recipient may develop accrual data for its reports on the basis of an analysis of the documentation on hand. Similarly, a pass-through entity must not require a subrecipient to establish an accrual accounting system and must allow the subrecipient to develop accrual data for its reports on the basis of an analysis of the documentation on hand.? Condition: The West Virginia Division of Rehabilitation Services (WVDRS) is responsible for preparing the Rehabilitation Services Administration (RSA-17), Federal Financial Report, quarterly. The RSA-17 is used to track the status of financial data tied to a particular Federal Grant Award. The RSA-17 report should be complete, accurate, and prepared in accordance with the required accounting basis. There was an error in reporting where certain amounts reported did not agree to the underlying data used to prepare the reports. The Director?s review was not precise enough to detect the error. Questioned Costs: N/A Context: Total federal expenditures for the Vocational Rehabilitation Grant were $31,508,101 for the year ended June 30, 2022. Cause: WVDRS has policies and procedures in place to review the RSA-17 prior to submission; however, the review was not precise enough to identify the errors. Effect: Incorrect data could be reported to the RSA. Recommendation: We recommend that WVDRS enforce the existing policies and procedures surrounding the review and approval of the RSA-17 report prior to submission. Views of Responsible Officials: Management acknowledges the finding. See corrective action plan.
Finding Number: 2022-002 Program: COVID-19 Higher Education Emergency Relief Fund (HEERF) Federal Agency Name: U.S. Department of Education Federal Award Year: July 1, 2021 ? June 30, 2022 Federal Assistance Listing Number: 84.425F 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 apart from the first report, which was due October 30, 2020, and the report covering the first quarter of 2021, which was due by July 10, 2021. 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 the year ended June 30, 2022, although all required reporting was found to be accurate and provided on a timely basis, in compliance with the reporting requirements, the College had not implemented a control that specifically addresses the accuracy and timeliness of the required reporting under HEERF. Cause The College?s HEERF reporting process did not include a control designed to monitor the timeliness and accuracy of the required reporting. Although identified as a finding in the prior year, the timing of the identification of this issue did not allow for the management of the College to implement a control that was responsive to the finding. Effect If appropriate controls are not designed and operating effectively over the HEERF reporting process, HEERF expenditures reported on the College?s website and to ED may be incomplete, inaccurate, or not posted within the timeframe required. Questioned Costs None noted. Prior Year Finding Yes ? 2021-001 Recommendation We recommend that the College implement a more thorough and detailed process and related internal controls to ensure timely and accurate reporting required under its Federal programs. Management?s Views Subsequent to June 30, 2022, management has reviewed its reporting requirements under its Federal programs and implemented controls to ensure accuracy and timeliness of required reporting. These include reconciliation of reporting to the College?s accounting records and a review of requirements to ensure timeliness. Anticipated Completion Date Completed ? October 31, 2022 Responsible Persons Gillian King, Chief of Staff
Federal Agency: U.S. Department of the Treasury Federal Financial Assistance Listing: 21.027 Program Name: COVID-19: Coronavirus State and Local Fiscal Recovery Funds Compliance Requirement: Reporting Type of Finding: Significant Deficiency 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. The City of Rancho Mirage (the City) must submit an annual Project and Expenditure Report that contains costs incurred during the covered period. Critical information includes: ? Obligations and Expenditures o Current period obligation o Cumulative obligation o Current period expenditure o Cumulative expenditure ? Subawards ? Detailed information on any loans issued; contracts and grants awarded; transfers made to other government entities; and direct payments made by the recipient that are greater than $50,000. For amounts less than $50,000, the recipient must report in the aggregate for these same categories of loans issued; contracts and grants awarded; transfers made to other government entities and direct payments made by the recipient. Condition: Expenditure information was reported inaccurately. Cause: The City?s control did not ensure the annual Project and Expenditure Report was prepared in accordance with governing requirements. Effect: Inaccurate information was reported to the federal awarding agency. Questioned Costs: None reported. Context/Sampling: The entire population of one annual Project and Expenditure Report submitted during the year was selected for testing. Repeat Finding from Prior Year: No Recommendation: We recommend the City enhance internal controls to ensure Project and Expenditure Reports are 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 Number or Year (or Other Identifying Number): S425D200013 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. The School Corporation had not designed, or implemented a system of internal control to ensure that the annual Elementary and Secondary School Emergency Relief (ESSER) annual data 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 us from verifying 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 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 or 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 Number or Year (or Other Identifying Number): S425D200013 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. The School Corporation had not designed, or implemented a system of internal control to ensure that the annual Elementary and Secondary School Emergency Relief (ESSER) annual data 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 us from verifying 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 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 or 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 2022-014 Subject: Title I Grants to Local Educational Agencies ? Reporting Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listings Number: 84.010 Federal Award Numbers and Years (or Other Identifying Numbers): S010A190014, S010A200014, S010A190014SIG Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters Condition and Context The system of internal controls over the applicable reports as established by the School Corporation was not properly implemented, nor was it operating effectively to ensure that sufficient audit evidence was maintained to support the requests for reimbursement, as well as the Final Expenditure Reports as submitted by the School. The fiscal years 2020-2021 and 2021-2022 Final Expenditure Reports and three reimbursement requests were selected for testing. The School was unable to provide for audit, documentation to support the underlying data accumulated and summarized in each of the Final Expenditure Reports, or for the three reimbursement requests. The reported data could not be traced to records that accumulate or summarize the data; therefore, the accuracy and completeness of the reports could not be verified. The Title I Director approved the requests for reimbursement and the Final Expenditure Reports prior to submission; however, this review was not effective. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following: . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in ?? 200.328 and 200.329. . . . (3) Records that identify adequately the source and application of funds for federally funded activities. These records must contain information pertaining to Federal awards, authorizations, obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Cause Management had not established an effective system of internal controls that would have ensured compliance, or that supporting documentation would have been maintained and made available for audit, related to the Reporting compliance requirement. Effect The failure to establish an effective system of internal controls and to retain and provide appropriate supporting documentation prevented the determination of the School Corporation's compliance with compliance requirements listed above. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish an effective system of internal controls to ensure documentation be maintained and made available for audit related to the grant agreement and the Reporting compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-014 Subject: Title I Grants to Local Educational Agencies ? Reporting Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listings Number: 84.010 Federal Award Numbers and Years (or Other Identifying Numbers): S010A190014, S010A200014, S010A190014SIG Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters Condition and Context The system of internal controls over the applicable reports as established by the School Corporation was not properly implemented, nor was it operating effectively to ensure that sufficient audit evidence was maintained to support the requests for reimbursement, as well as the Final Expenditure Reports as submitted by the School. The fiscal years 2020-2021 and 2021-2022 Final Expenditure Reports and three reimbursement requests were selected for testing. The School was unable to provide for audit, documentation to support the underlying data accumulated and summarized in each of the Final Expenditure Reports, or for the three reimbursement requests. The reported data could not be traced to records that accumulate or summarize the data; therefore, the accuracy and completeness of the reports could not be verified. The Title I Director approved the requests for reimbursement and the Final Expenditure Reports prior to submission; however, this review was not effective. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following: . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in ?? 200.328 and 200.329. . . . (3) Records that identify adequately the source and application of funds for federally funded activities. These records must contain information pertaining to Federal awards, authorizations, obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Cause Management had not established an effective system of internal controls that would have ensured compliance, or that supporting documentation would have been maintained and made available for audit, related to the Reporting compliance requirement. Effect The failure to establish an effective system of internal controls and to retain and provide appropriate supporting documentation prevented the determination of the School Corporation's compliance with compliance requirements listed above. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish an effective system of internal controls to ensure documentation be maintained and made available for audit related to 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 2022-017 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Number: 84.425D Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters Condition and Context The School Corporation had not designed nor implemented a system of internal controls to ensure that the four Elementary and Secondary School Emergency Relief (ESSER) annual data reports required to be filed during the audit period were complete and accurate prior to submission. Each of the reports was prepared by one employee without an oversight or review process in place to prevent, or detect and correct, errors. Furthermore, 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 The Full-Time Employee (FTE) Positions as of March 13, 2020, and FTE Positions as of September 30, 2020, were not able to be verified to the School's records. ESSER I, Year 2 Report The Key Line Item, Meeting Students' Academic, Social, Emotional, and Other Needs (Excluding Mental Health Supports) - Personnel Services - Salary was overstated by $950. An additional Key Line Item, Operational Continuity and Other Allowed Uses - purchased professional services was understated by $138,739. ESSER II, Year 1 Report The Key Line Item, Meeting Students' Academic, Social, Emotional, and Other Needs (Excluding Mental Health Supports) - Purchased Professional and Technical Services was understated by $111,290. An additional Key Line Item, Meeting Students' Academic, Social, Emotional, and Other Needs (Excluding Mental Health Supports) - Supplies was understated by $6,500. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following: . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in ?? 200.328 and 200.329. . . . (3) Records that identify adequately the source and application of funds for federally-funded activities. These records must contain information pertaining to Federal awards, authorizations, financial obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Cause Management had not designed nor 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 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 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 2022-017 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Number: 84.425D Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters Condition and Context The School Corporation had not designed nor implemented a system of internal controls to ensure that the four Elementary and Secondary School Emergency Relief (ESSER) annual data reports required to be filed during the audit period were complete and accurate prior to submission. Each of the reports was prepared by one employee without an oversight or review process in place to prevent, or detect and correct, errors. Furthermore, 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 The Full-Time Employee (FTE) Positions as of March 13, 2020, and FTE Positions as of September 30, 2020, were not able to be verified to the School's records. ESSER I, Year 2 Report The Key Line Item, Meeting Students' Academic, Social, Emotional, and Other Needs (Excluding Mental Health Supports) - Personnel Services - Salary was overstated by $950. An additional Key Line Item, Operational Continuity and Other Allowed Uses - purchased professional services was understated by $138,739. ESSER II, Year 1 Report The Key Line Item, Meeting Students' Academic, Social, Emotional, and Other Needs (Excluding Mental Health Supports) - Purchased Professional and Technical Services was understated by $111,290. An additional Key Line Item, Meeting Students' Academic, Social, Emotional, and Other Needs (Excluding Mental Health Supports) - Supplies was understated by $6,500. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following: . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in ?? 200.328 and 200.329. . . . (3) Records that identify adequately the source and application of funds for federally-funded activities. These records must contain information pertaining to Federal awards, authorizations, financial obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Cause Management had not designed nor 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 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 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 Program Affected: 84.425E, 84.425F Finding Type: Significant deficiency on compliance and control Criteria: The HEERF I, II, and III funding came with various requirements instituted by the CARES Act, CRRSAA, and ARP and then further defined by the US Department of Education (ED). The ED exercised its reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329 to define three reporting requirements for the HEERF program funds, which include 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. These reporting requirements stipulate specific guidelines regarding when, how, and what information is to be publicly posted on the University?s website. Condition: Per review of the University's quarterly public reporting for the Student Aid Portion, we noted one instance where the amounts and information reported did not adhere to the program requirements. Issues noted included amounts not properly separated between student and institutional fund portions and incorrect amounts and information posted for one period. Cause: Reporting requirements posted by the Department of Education for HEERF program funds have continuously changed with the intent to be made clearer with each subsequent revision. However, it is difficult to draw conclusions on some of the reporting guidance. There were not adequate controls nor review processes in place to monitor the reporting requirements issued by the DoE to ensure quarterly reports for the Student Aid Portion were posted accurately. Effect: The effect or possible effect is that the University may be determined ineligible to receive future HEERF program funding. Additionally, the public does not have accurate information regarding how HEERF program funds were expended by the University from the student aid portion. Questioned Costs: None Recommendation: Controls should be established to allow for a second detailed review of all reporting of HEERF program funds by an official extensively familiar with the reporting requirements published by the DoE and other regulators. Auditee?s Response: The reports will be monitored more closely going forward. See attached corrective action plan. Repeat Finding: Yes, 2021-002
FINDING 2022-003 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Number: 84.425D Federal Award Number or 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 18 FAIRFIELD COMMUNITY SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 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. Two of four annual data reports due and submitted during the audit period contained errors. The Elementary and Secondary School Emergency Relief (ESSER) I, Year 1 annual data report overstated total expenditures by $72,046. The ESSER I, Year 2 annual data report overstated total expenditures by $2,303. 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 Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following: . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in ?? 200.328 and 200.329. . . . (3) Records that identify adequately the source and application of funds for federally funded activities. These records must contain information pertaining to Federal awards, authorizations, obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." INDIANA STATE BOARD OF ACCOUNTS 19 FAIRFIELD COMMUNITY SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Cause Management had not established a system of internal controls that would have ensured compliance with the Reporting compliance requirement. The ESSER1, Year 1 report included expenditures past the reporting period. 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.
FINDING 2022-003 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Number: 84.425D Federal Award Number or 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 18 FAIRFIELD COMMUNITY SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 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. Two of four annual data reports due and submitted during the audit period contained errors. The Elementary and Secondary School Emergency Relief (ESSER) I, Year 1 annual data report overstated total expenditures by $72,046. The ESSER I, Year 2 annual data report overstated total expenditures by $2,303. 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 Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following: . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in ?? 200.328 and 200.329. . . . (3) Records that identify adequately the source and application of funds for federally funded activities. These records must contain information pertaining to Federal awards, authorizations, obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." INDIANA STATE BOARD OF ACCOUNTS 19 FAIRFIELD COMMUNITY SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Cause Management had not established a system of internal controls that would have ensured compliance with the Reporting compliance requirement. The ESSER1, Year 1 report included expenditures past the reporting period. 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.
FINDING 2022-003 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Number: 84.425D Federal Award Number or 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 18 FAIRFIELD COMMUNITY SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 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. Two of four annual data reports due and submitted during the audit period contained errors. The Elementary and Secondary School Emergency Relief (ESSER) I, Year 1 annual data report overstated total expenditures by $72,046. The ESSER I, Year 2 annual data report overstated total expenditures by $2,303. 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 Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following: . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in ?? 200.328 and 200.329. . . . (3) Records that identify adequately the source and application of funds for federally funded activities. These records must contain information pertaining to Federal awards, authorizations, obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." INDIANA STATE BOARD OF ACCOUNTS 19 FAIRFIELD COMMUNITY SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Cause Management had not established a system of internal controls that would have ensured compliance with the Reporting compliance requirement. The ESSER1, Year 1 report included expenditures past the reporting period. 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.
Federal Agency: U.S. Department of the Treasury Federal Financial Assistance Listing: 21.027 Program Name: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Compliance Requirement: Reporting Type of Finding: Significant Deficiency, Instance of Noncompliance Criteria: Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. This includes internal controls over maintaining records of the preparer and approver of required reports. 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. The City of Paramount (the City) must submit an Interim Report and quarterly Project and Expenditure Reports that contain costs incurred during the covered period. Critical information pertaining to both the Interim Report and the Project and Expenditure Reports includes: ? Obligations and Expenditures o Current period obligation o Cumulative obligation o Current period expenditure o Cumulative expenditure Critical information pertaining to the Project and Expenditure Reports specifically includes: ? Subawards ? Detailed information on any loans issued; contracts and grants awarded; transfers made to other government entities; and direct payments made by the recipient that are greater than $50,000. For amounts less than $50,000, the recipient must report in the aggregate for these same categories of loans issued; contracts and grants awarded; transfers made to other government entities and direct payments made by the recipient. Additionally, per the Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) Compliance and Reporting Guidance, all recipients are required to submit Project and Expenditure Reports on a timely basis as summarized in the quarterly report timelines table of the guidance. Condition: We identified 4 instances in which the City did not retain evidence to document the individual approving the City?s required performance reports. Current obligations were reported inaccurately for the Quarter 1 and 2 Project and Expenditure Reports. Additionally, expenditure information was reported inaccurately for the Quarter 2 Project and Expenditure Report and the report was submitted past the required deadline. Further, $48,834 for the purchase of energy efficient lighting upgrades to City Hall were reported incorrectly under ?Public Health - Negative Economic Impact? instead of ?Revenue Replacement?. Cause: The City?s procedures did not include documentation to evidence the individual that approved the reports. The City?s procedures did not ensure the Quarter 2 Project and Expenditure Report was prepared in accordance with program requirements and on a timely basis. Effect: The City did not comply with the requirements of 2 CFR 200.303 and inaccurate information was reported to the federal awarding agency. Questioned Costs: None reported. Context/Sampling: The entire population of one Interim Report and three quarterly Project and Expenditure Reports submitted during the year were selected for testing. Repeat Finding from Prior Year: No. Recommendation: We recommend the City enhance internal controls to ensure Interim and Project and Expenditure Reports are prepared in accordance with program requirements. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
FINDING 2022-008 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Numbers: 84.425C, 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425C200018, S425D200013, S425U210013, S425D210013 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 in place 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) and the Governor's Emergency Education Relief (GEER) 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, two of eight key line items examined were not able to be traced to the School Corporation's records. The School Corporation was unable to provide supporting documentation for Full Time Equivalent (FTE) figures that matched what was reported to the Indiana Department of Education. Variances ranged from 5.7 to 55.27. The lack of internal controls was systemic throughout the audit period. Noncompliance was isolated to ESSER I and GEER I, year 1 annual reports. 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." 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 2022-008 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Numbers: 84.425C, 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425C200018, S425D200013, S425U210013, S425D210013 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 in place 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) and the Governor's Emergency Education Relief (GEER) 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, two of eight key line items examined were not able to be traced to the School Corporation's records. The School Corporation was unable to provide supporting documentation for Full Time Equivalent (FTE) figures that matched what was reported to the Indiana Department of Education. Variances ranged from 5.7 to 55.27. The lack of internal controls was systemic throughout the audit period. Noncompliance was isolated to ESSER I and GEER I, year 1 annual reports. 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." 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 2022-008 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Numbers: 84.425C, 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425C200018, S425D200013, S425U210013, S425D210013 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 in place 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) and the Governor's Emergency Education Relief (GEER) 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, two of eight key line items examined were not able to be traced to the School Corporation's records. The School Corporation was unable to provide supporting documentation for Full Time Equivalent (FTE) figures that matched what was reported to the Indiana Department of Education. Variances ranged from 5.7 to 55.27. The lack of internal controls was systemic throughout the audit period. Noncompliance was isolated to ESSER I and GEER I, year 1 annual reports. 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." 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 2022-008 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Numbers: 84.425C, 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425C200018, S425D200013, S425U210013, S425D210013 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 in place 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) and the Governor's Emergency Education Relief (GEER) 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, two of eight key line items examined were not able to be traced to the School Corporation's records. The School Corporation was unable to provide supporting documentation for Full Time Equivalent (FTE) figures that matched what was reported to the Indiana Department of Education. Variances ranged from 5.7 to 55.27. The lack of internal controls was systemic throughout the audit period. Noncompliance was isolated to ESSER I and GEER I, year 1 annual reports. 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." 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 2022-008 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Numbers: 84.425C, 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425C200018, S425D200013, S425U210013, S425D210013 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 in place 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) and the Governor's Emergency Education Relief (GEER) 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, two of eight key line items examined were not able to be traced to the School Corporation's records. The School Corporation was unable to provide supporting documentation for Full Time Equivalent (FTE) figures that matched what was reported to the Indiana Department of Education. Variances ranged from 5.7 to 55.27. The lack of internal controls was systemic throughout the audit period. Noncompliance was isolated to ESSER I and GEER I, year 1 annual reports. 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." 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.
Criteria or specific requirement: Compliance ? The Code of Federal Regulations, 2 CFR section 200.328-200.329 requires that institutions publicly post 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 no later than 10 days after the end of each calendar quarter (September 30, and December 31, March 31, June 30). Internal Control ? Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should 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). Condition: The College did not complete the initial quarterly reporting for the HEERF II (CRRSAA) and HEERF III (ARP) grant. Context: This condition occurred for 4 out of 5 quarterly student reports selected for testing. Cause: Management of the College was unaware of the reporting requirement. Effect: The required information related to the Student Aid Portion of the HEERF funds was not made available to parties of interest in a timely fashion. Repeat Finding: Yes, prior year finding 2021-001 Questioned costs: None noted as the reporting requirement does not affect the allowability of costs and/or activities. Recommendation: Corrective action was taken as of April 20, 2022.
Assistance Listing Number, Federal Agency, and Program Name - U.S. Department of Education, COVID 19 Education Stabilization Fund Higher Education Emergency Relief Fund ALN 84.425E, 84.425F Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - The Coronavirus Aid, Relief, and Economic Securities (CARES) Act Section 18004(e) and the Coronavirus Response and Relief Supplemental Appropriations Act, 2021 Section 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. For ARP, the Department of Education exercises reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Condition - The University did not file accurate and timely reports throughout the fiscal year. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context There were five errors identified that contributed to this finding. 1. The September 30, 2021 quarterly institutional report was not filed timely. 2. The expenses reported on the September 30, 2021 quarterly institutional report were previously reported on the June 30, 2021 quarterly institutional report. 3. The March 31, 2022 student website report did not include specific language regarding eligible students and the reported student count was incorrect. 4. The 2021 annual report included the incorrect number of part time graduate students who received an award which also impacted the total number of students reported. 5. The earmarking requirements were met; however, there were no expenses allocated to these categories on the annual report. Cause and Effect - The University did not have a control in place to ensure reports were accurate and completed timely, which resulted in various errors and reports not being filed timely. Recommendation - The University should implement controls to ensure reports are accurate and completed timely. Views of Responsible Officials and Planned Corrective Actions - 1. The 9/30/21 HEERF institutional report was posted on the University?s website 10 days late. This was due to the staff member responsible going out on medical leave and miscommunication within the area on required filings. There were no additional quarterly reports to be filed so no further controls were put in place for this reporting. The annual report was filed timely. 2. The 9/30/21 institutional report has been removed from the University website as it indicated a duplicate expense that was reported on the 6/30/21 quarterly report. The 06/30/21 report has been marked as the final institutional report. 3. The Student Financial Aid (SFA) office agrees that the March 31, 2022, student website report did not include language regarding eligible students, and the reported student count was incorrect. SFA will amend the March 31, 2022, quarterly student report to reflect the correct number, add language regarding eligible students, and send the correction to the appointed HEERF email address by June 1, 2023. The Associate Director of Compliance and Training will perform a secondary review of any future reports to ensure the completeness and accuracy of the information. 4. The Student Financial Aid (SFA) office agrees that the 2021 annual report included the incorrect number of part-time graduate students who received an award, impacting the total number of students reported. The error was due to incorrectly inputting the information from the supporting data onto the annual report. SFA will amend the 2021 annual report by correcting the number of part-time graduate students by March 24, 2023. The Associate Director of Compliance and Training will perform a secondary review of the data on the annual report and compare it with the supporting documentation. 5. As indicated in the report, the University did comply with earmarking requirements. However, the categories used to report the expenditures on the 12/31/21 annual report were not the specific earmarked categories. The 12/31/21 annual report filed through the Department of Education website has just recently been made active again and the University will make necessary category reporting corrections. As the 12/31/21 annual report was the final report for institutional expenses no additional actions are required.
Assistance Listing Number, Federal Agency, and Program Name - U.S. Department of Education, COVID 19 Education Stabilization Fund Higher Education Emergency Relief Fund ALN 84.425E, 84.425F Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - The Coronavirus Aid, Relief, and Economic Securities (CARES) Act Section 18004(e) and the Coronavirus Response and Relief Supplemental Appropriations Act, 2021 Section 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. For ARP, the Department of Education exercises reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Condition - The University did not file accurate and timely reports throughout the fiscal year. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context There were five errors identified that contributed to this finding. 1. The September 30, 2021 quarterly institutional report was not filed timely. 2. The expenses reported on the September 30, 2021 quarterly institutional report were previously reported on the June 30, 2021 quarterly institutional report. 3. The March 31, 2022 student website report did not include specific language regarding eligible students and the reported student count was incorrect. 4. The 2021 annual report included the incorrect number of part time graduate students who received an award which also impacted the total number of students reported. 5. The earmarking requirements were met; however, there were no expenses allocated to these categories on the annual report. Cause and Effect - The University did not have a control in place to ensure reports were accurate and completed timely, which resulted in various errors and reports not being filed timely. Recommendation - The University should implement controls to ensure reports are accurate and completed timely. Views of Responsible Officials and Planned Corrective Actions - 1. The 9/30/21 HEERF institutional report was posted on the University?s website 10 days late. This was due to the staff member responsible going out on medical leave and miscommunication within the area on required filings. There were no additional quarterly reports to be filed so no further controls were put in place for this reporting. The annual report was filed timely. 2. The 9/30/21 institutional report has been removed from the University website as it indicated a duplicate expense that was reported on the 6/30/21 quarterly report. The 06/30/21 report has been marked as the final institutional report. 3. The Student Financial Aid (SFA) office agrees that the March 31, 2022, student website report did not include language regarding eligible students, and the reported student count was incorrect. SFA will amend the March 31, 2022, quarterly student report to reflect the correct number, add language regarding eligible students, and send the correction to the appointed HEERF email address by June 1, 2023. The Associate Director of Compliance and Training will perform a secondary review of any future reports to ensure the completeness and accuracy of the information. 4. The Student Financial Aid (SFA) office agrees that the 2021 annual report included the incorrect number of part-time graduate students who received an award, impacting the total number of students reported. The error was due to incorrectly inputting the information from the supporting data onto the annual report. SFA will amend the 2021 annual report by correcting the number of part-time graduate students by March 24, 2023. The Associate Director of Compliance and Training will perform a secondary review of the data on the annual report and compare it with the supporting documentation. 5. As indicated in the report, the University did comply with earmarking requirements. However, the categories used to report the expenditures on the 12/31/21 annual report were not the specific earmarked categories. The 12/31/21 annual report filed through the Department of Education website has just recently been made active again and the University will make necessary category reporting corrections. As the 12/31/21 annual report was the final report for institutional expenses no additional actions are required.
Higher Education Stabilization Fund (HEERF) Reporting DEPARTMENT OF EDUCATION ALN #: 84.425F and 84.425L Federal Award Identification #: P425F204061 and P425L200175 Condition: While the College posted the HEERF institutional quarterly reports to the College?s website, the reports were not accurate. Criteria: 2 CFR 200.329, 86 FR 26213 Questioned Costs: $0 Context: During the audit, it was noted that quarterly reporting did not agree to the College records for the institutional funds expended nor was the minority serving institution fund expenditures reported. 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 College was not in compliance with the reporting requirements of HEERF. Identification as repeat finding, if applicable: Not applicable Recommendation: As the College expended all HEERF funding as of June 30, 2022, we recommend that the College post corrected quarterly reports to their website. 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 #: P425F204061 and P425L200175 Condition: While the College posted the HEERF institutional quarterly reports to the College?s website, the reports were not accurate. Criteria: 2 CFR 200.329, 86 FR 26213 Questioned Costs: $0 Context: During the audit, it was noted that quarterly reporting did not agree to the College records for the institutional funds expended nor was the minority serving institution fund expenditures reported. 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 College was not in compliance with the reporting requirements of HEERF. Identification as repeat finding, if applicable: Not applicable Recommendation: As the College expended all HEERF funding as of June 30, 2022, we recommend that the College post corrected quarterly reports to their website. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2022-001: Significant Deficiency in Reporting Federal Program - COVID-19 ? Education Stabilization Fund Federal Agency - U.S. Department of Education Pass-Through Entity - Not Applicable AL Number - 84.425 Federal Award Identification Numbers - P425E205608, P425F205088 and P425N200710 Federal Award Year - June 30, 2022 Repeat of Prior Year Finding 2021-001 Criteria: Section 18004(e) of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), and Section 314(e) of the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) requires institutions receiving funds under the respective sections, to submit a report to the Secretary describing the use of funds distributed from the Higher Education Emergency Relief Funds (HEERF). While the American Rescue Plan Act (ARP) does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, the Department of Education exercises this reporting authority under 2 CFR Section 200.328 and 2 CFR section 200.329. Condition: The School was unable to verify that the quarterly public reports for both the student aid portions and institutional portions were properly reviewed and approved by an appropriate independent person and posted to the School?s website, or updated, on a timely basis. Questioned Costs: Not applicable. Context: Not applicable. Cause: The School did not retain verifiable evidence to support adherence to report review and approval requirements or reporting deadlines in accordance with HEERF requirements. Effect: The School did not provide the public with timely, accurate data related to student aid and institutional expenditures. Recommendation: The School should assign an individual to monitor reporting requirements of HEERF awards to ensure the School is in compliance. Management's Response: Management agrees with the finding and will implement enhanced procedures to comply with the requirement of Section 18004(e) of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), Section 314(e) of the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) and 2 CFR sections 200.328 and 200.329.
Finding 2022-001: Significant Deficiency in Reporting Federal Program - COVID-19 ? Education Stabilization Fund Federal Agency - U.S. Department of Education Pass-Through Entity - Not Applicable AL Number - 84.425 Federal Award Identification Numbers - P425E205608, P425F205088 and P425N200710 Federal Award Year - June 30, 2022 Repeat of Prior Year Finding 2021-001 Criteria: Section 18004(e) of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), and Section 314(e) of the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) requires institutions receiving funds under the respective sections, to submit a report to the Secretary describing the use of funds distributed from the Higher Education Emergency Relief Funds (HEERF). While the American Rescue Plan Act (ARP) does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, the Department of Education exercises this reporting authority under 2 CFR Section 200.328 and 2 CFR section 200.329. Condition: The School was unable to verify that the quarterly public reports for both the student aid portions and institutional portions were properly reviewed and approved by an appropriate independent person and posted to the School?s website, or updated, on a timely basis. Questioned Costs: Not applicable. Context: Not applicable. Cause: The School did not retain verifiable evidence to support adherence to report review and approval requirements or reporting deadlines in accordance with HEERF requirements. Effect: The School did not provide the public with timely, accurate data related to student aid and institutional expenditures. Recommendation: The School should assign an individual to monitor reporting requirements of HEERF awards to ensure the School is in compliance. Management's Response: Management agrees with the finding and will implement enhanced procedures to comply with the requirement of Section 18004(e) of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), Section 314(e) of the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) and 2 CFR sections 200.328 and 200.329.
Finding 2022-001: Significant Deficiency in Reporting Federal Program - COVID-19 ? Education Stabilization Fund Federal Agency - U.S. Department of Education Pass-Through Entity - Not Applicable AL Number - 84.425 Federal Award Identification Numbers - P425E205608, P425F205088 and P425N200710 Federal Award Year - June 30, 2022 Repeat of Prior Year Finding 2021-001 Criteria: Section 18004(e) of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), and Section 314(e) of the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) requires institutions receiving funds under the respective sections, to submit a report to the Secretary describing the use of funds distributed from the Higher Education Emergency Relief Funds (HEERF). While the American Rescue Plan Act (ARP) does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, the Department of Education exercises this reporting authority under 2 CFR Section 200.328 and 2 CFR section 200.329. Condition: The School was unable to verify that the quarterly public reports for both the student aid portions and institutional portions were properly reviewed and approved by an appropriate independent person and posted to the School?s website, or updated, on a timely basis. Questioned Costs: Not applicable. Context: Not applicable. Cause: The School did not retain verifiable evidence to support adherence to report review and approval requirements or reporting deadlines in accordance with HEERF requirements. Effect: The School did not provide the public with timely, accurate data related to student aid and institutional expenditures. Recommendation: The School should assign an individual to monitor reporting requirements of HEERF awards to ensure the School is in compliance. Management's Response: Management agrees with the finding and will implement enhanced procedures to comply with the requirement of Section 18004(e) of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), Section 314(e) of the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) and 2 CFR sections 200.328 and 200.329.
2022-002 Accurate Quarterly Reporting Federal Agency: U.S. Department of Education 84.425F HEERF ? Institutional Portion Criteria ? Per Federal Regulation 2 CFR Section 200.329(b), the Department of Education must require a recipient to provide financial data and accomplishments. The Department of Education required quarterly reports to be prepared by all recipients of HEERF funds, outlining the student funds used and the institutional funds used. Condition ? During review of the quarterly reports for HEERF, and reviewing against expenses, it was noted that the College was not submitting the reports with the expenses they intended to charge to HEERF in the quarter the expense was incurred. Questioned Costs ? N/A. Effect ? The quarterly reports submitted do not accurately reflect the use of the HEERF funding. Perspective Information ? There was no strong guidance for the College on reporting requirements for this grant. The College was under the impression that they should report the expenses they chose to apply to the grant in the quarter they chose to charge the grant rather than the quarter the expense was incurred. Cause ? Due to the lack of guidance, the College was incorrectly reporting the expenses in the quarter in which they applied the expense against the grant, rather than the quarter in which the grant expense was incurred. Recommendation ? We recommend that the College amend their prior quarterly reports and repost, which they are in the process of doing.
FINDING 2022-003 Information on the federal program: Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Numbers: 84.425D, 84.425U Federal Award Numbers (or Other Identifying Numbers): S425D200013, S425D210013, S425U200013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion 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 awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)...." 2 CFR 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following: (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in ?? 200.328 and 200.329. . . . (3) Records that identify adequately the source and application of funds for federally funded activities. These records must contain information pertaining to Federal awards, authorizations, obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. . . ." 34 CFR 76.722 states: ?A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program.? Condition: 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. Three of four annual data reports due and submitted during the audit period were materially misstated. ? The Elementary and Secondary School Emergency Relief (ESSER I), Year 2 annual data report understated total expenditures by $145,422. ? The Elementary and Secondary School Emergency Relief (ESSER II), Year 1 annual data report overstated total expenditures by $412,355. ? The American Rescue Plan?Elementary and Secondary School Emergency Relief (ARP ESSER), Year 1 annual data report overstated total expenditures by $550,973. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Cause: Management had not established a system of internal controls that would have ensured compliance with the Reporting compliance requirement. The two overstated reports included expenditures past the reporting period. 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: 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. Identification as a repeat finding, if applicable: No. 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 and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
FINDING 2022-003 Information on the federal program: Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Numbers: 84.425D, 84.425U Federal Award Numbers (or Other Identifying Numbers): S425D200013, S425D210013, S425U200013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion 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 awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)...." 2 CFR 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following: (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in ?? 200.328 and 200.329. . . . (3) Records that identify adequately the source and application of funds for federally funded activities. These records must contain information pertaining to Federal awards, authorizations, obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. . . ." 34 CFR 76.722 states: ?A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program.? Condition: 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. Three of four annual data reports due and submitted during the audit period were materially misstated. ? The Elementary and Secondary School Emergency Relief (ESSER I), Year 2 annual data report understated total expenditures by $145,422. ? The Elementary and Secondary School Emergency Relief (ESSER II), Year 1 annual data report overstated total expenditures by $412,355. ? The American Rescue Plan?Elementary and Secondary School Emergency Relief (ARP ESSER), Year 1 annual data report overstated total expenditures by $550,973. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Cause: Management had not established a system of internal controls that would have ensured compliance with the Reporting compliance requirement. The two overstated reports included expenditures past the reporting period. 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: 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. Identification as a repeat finding, if applicable: No. 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 and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
FINDING 2022-002 Subject: COVID-19 Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013, S425U200013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness 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 awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)...." 2 CFR 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 2 CFR 200.302(b) states in part: ?The financial management system of each non-Federal entity must provide for the following: . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in ?? 200.328 and 200.329. . . . (3) Records that identify adequately the source and application of funds for federally funded activities. These records must contain information pertaining to Federal awards, authorizations, obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Condition: 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. Cause: Management had not established an effective system of internal controls that would have ensured compliance with the grant agreement and the Reporting compliance requirement. Context: Although, the School Treasurer and the Superintendent worked independently to compile the information for the Elementary and Secondary School Emergency Relief (ESSER) annual data reports (Reports) reports and then reviewed each other?s notes and prepared the annual date reports, the control was not effective and did not detect and allow correction of errors prior to submission. Due to the lack of effective internal controls, the Reports contained the following errors: -ESSER I, Annual Year 1 Report The School Corporation did not file this report. According to the detailed disbursements, no ESSER funds were expended for the applicable date range. However, the full-time employee numbers should have been reported. These numbers were 117.5 at 3/13/20 and 113.5 at 9/30/20. - ESSER I, Annual Year 2 Report The School Corporation did not enter the correct amounts for the following categories: - Addressing Physical Health & Safety - Personal Services - Salaries. The appropriated amount of $44,000 was reported instead of the actual disbursement of $36,377. - Meeting Student's Academic, Social, Emotional, and Other Needs - Supplies. The appropriated amount of $73,390 was reported instead of the actual disbursement of $796. - ESSER II, Annual Year 2 Report The School Corporation did not enter the correct amount for the Meeting Student?s Academic, Social, Emotional, and Other Needs ? Supplies category. The appropriated amount of $408,715 was report instead of the actual disbursement of $400,439. The lack of internal controls and noncompliance were systemic issues throughout the audit period. 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. Identification as a repeat finding, if applicable: No 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 and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
FINDING 2022-002 Subject: COVID-19 Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013, S425U200013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness 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 awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)...." 2 CFR 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 2 CFR 200.302(b) states in part: ?The financial management system of each non-Federal entity must provide for the following: . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in ?? 200.328 and 200.329. . . . (3) Records that identify adequately the source and application of funds for federally funded activities. These records must contain information pertaining to Federal awards, authorizations, obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Condition: 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. Cause: Management had not established an effective system of internal controls that would have ensured compliance with the grant agreement and the Reporting compliance requirement. Context: Although, the School Treasurer and the Superintendent worked independently to compile the information for the Elementary and Secondary School Emergency Relief (ESSER) annual data reports (Reports) reports and then reviewed each other?s notes and prepared the annual date reports, the control was not effective and did not detect and allow correction of errors prior to submission. Due to the lack of effective internal controls, the Reports contained the following errors: -ESSER I, Annual Year 1 Report The School Corporation did not file this report. According to the detailed disbursements, no ESSER funds were expended for the applicable date range. However, the full-time employee numbers should have been reported. These numbers were 117.5 at 3/13/20 and 113.5 at 9/30/20. - ESSER I, Annual Year 2 Report The School Corporation did not enter the correct amounts for the following categories: - Addressing Physical Health & Safety - Personal Services - Salaries. The appropriated amount of $44,000 was reported instead of the actual disbursement of $36,377. - Meeting Student's Academic, Social, Emotional, and Other Needs - Supplies. The appropriated amount of $73,390 was reported instead of the actual disbursement of $796. - ESSER II, Annual Year 2 Report The School Corporation did not enter the correct amount for the Meeting Student?s Academic, Social, Emotional, and Other Needs ? Supplies category. The appropriated amount of $408,715 was report instead of the actual disbursement of $400,439. The lack of internal controls and noncompliance were systemic issues throughout the audit period. 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. Identification as a repeat finding, if applicable: No 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 and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
FINDING 2022-002 Subject: COVID-19 Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013, S425U200013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness 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 awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)...." 2 CFR 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 2 CFR 200.302(b) states in part: ?The financial management system of each non-Federal entity must provide for the following: . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in ?? 200.328 and 200.329. . . . (3) Records that identify adequately the source and application of funds for federally funded activities. These records must contain information pertaining to Federal awards, authorizations, obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Condition: 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. Cause: Management had not established an effective system of internal controls that would have ensured compliance with the grant agreement and the Reporting compliance requirement. Context: Although, the School Treasurer and the Superintendent worked independently to compile the information for the Elementary and Secondary School Emergency Relief (ESSER) annual data reports (Reports) reports and then reviewed each other?s notes and prepared the annual date reports, the control was not effective and did not detect and allow correction of errors prior to submission. Due to the lack of effective internal controls, the Reports contained the following errors: -ESSER I, Annual Year 1 Report The School Corporation did not file this report. According to the detailed disbursements, no ESSER funds were expended for the applicable date range. However, the full-time employee numbers should have been reported. These numbers were 117.5 at 3/13/20 and 113.5 at 9/30/20. - ESSER I, Annual Year 2 Report The School Corporation did not enter the correct amounts for the following categories: - Addressing Physical Health & Safety - Personal Services - Salaries. The appropriated amount of $44,000 was reported instead of the actual disbursement of $36,377. - Meeting Student's Academic, Social, Emotional, and Other Needs - Supplies. The appropriated amount of $73,390 was reported instead of the actual disbursement of $796. - ESSER II, Annual Year 2 Report The School Corporation did not enter the correct amount for the Meeting Student?s Academic, Social, Emotional, and Other Needs ? Supplies category. The appropriated amount of $408,715 was report instead of the actual disbursement of $400,439. The lack of internal controls and noncompliance were systemic issues throughout the audit period. 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. Identification as a repeat finding, if applicable: No 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 and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
2022-005 Federal Agency: U.S. Department of Education Pass-through Entity: Oregon Higher Education Coordinating Commission (84.425C) Assistance Listing Numbers: 84.425 Federal Award Number: P425E202575; P425F202249; P425L200619; P425N200061 Pass-through Grant Number: 20-075M Program Name: Education Stabilization Fund Reporting under Higher Education Emergency Relief Funds (HEERF) Significant Deficiency in Internal Control over Compliance 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) 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 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. Condition - During our testing, we noted the following issues over reporting: ? The financial data reported in the some of the quarterly reports posted for the institutional portion were not supported by the underlying trial balance activity. Cause - The College did not have adequate and/or functioning controls in place to ensure the reporting was accurate. Effect - The College is not in compliance with the reporting requirements described in the OMB Compliance Supplement and required by the Department of Education. Questioned Costs ? None reported Context/Sampling ? Two student quarterly reports, three institutional quarterly reports, and the annual report required under HEERF and due within fiscal year 2022 were tested. Repeat Finding ? Yes, prior year finding 2021-005 Recommendation ? The reporting process was greatly improved over the prior year. The College should continue to ensure the process to review, update, and verify reporting under HEERF is done accurately is occurring. View of Responsible Officials - Management agrees with this finding and will implement the recommendations.
2022-005 Federal Agency: U.S. Department of Education Pass-through Entity: Oregon Higher Education Coordinating Commission (84.425C) Assistance Listing Numbers: 84.425 Federal Award Number: P425E202575; P425F202249; P425L200619; P425N200061 Pass-through Grant Number: 20-075M Program Name: Education Stabilization Fund Reporting under Higher Education Emergency Relief Funds (HEERF) Significant Deficiency in Internal Control over Compliance 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) 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 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. Condition - During our testing, we noted the following issues over reporting: ? The financial data reported in the some of the quarterly reports posted for the institutional portion were not supported by the underlying trial balance activity. Cause - The College did not have adequate and/or functioning controls in place to ensure the reporting was accurate. Effect - The College is not in compliance with the reporting requirements described in the OMB Compliance Supplement and required by the Department of Education. Questioned Costs ? None reported Context/Sampling ? Two student quarterly reports, three institutional quarterly reports, and the annual report required under HEERF and due within fiscal year 2022 were tested. Repeat Finding ? Yes, prior year finding 2021-005 Recommendation ? The reporting process was greatly improved over the prior year. The College should continue to ensure the process to review, update, and verify reporting under HEERF is done accurately is occurring. View of Responsible Officials - Management agrees with this finding and will implement the recommendations.
2022-005 Federal Agency: U.S. Department of Education Pass-through Entity: Oregon Higher Education Coordinating Commission (84.425C) Assistance Listing Numbers: 84.425 Federal Award Number: P425E202575; P425F202249; P425L200619; P425N200061 Pass-through Grant Number: 20-075M Program Name: Education Stabilization Fund Reporting under Higher Education Emergency Relief Funds (HEERF) Significant Deficiency in Internal Control over Compliance 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) 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 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. Condition - During our testing, we noted the following issues over reporting: ? The financial data reported in the some of the quarterly reports posted for the institutional portion were not supported by the underlying trial balance activity. Cause - The College did not have adequate and/or functioning controls in place to ensure the reporting was accurate. Effect - The College is not in compliance with the reporting requirements described in the OMB Compliance Supplement and required by the Department of Education. Questioned Costs ? None reported Context/Sampling ? Two student quarterly reports, three institutional quarterly reports, and the annual report required under HEERF and due within fiscal year 2022 were tested. Repeat Finding ? Yes, prior year finding 2021-005 Recommendation ? The reporting process was greatly improved over the prior year. The College should continue to ensure the process to review, update, and verify reporting under HEERF is done accurately is occurring. View of Responsible Officials - Management agrees with this finding and will implement the recommendations.
2022-005 Federal Agency: U.S. Department of Education Pass-through Entity: Oregon Higher Education Coordinating Commission (84.425C) Assistance Listing Numbers: 84.425 Federal Award Number: P425E202575; P425F202249; P425L200619; P425N200061 Pass-through Grant Number: 20-075M Program Name: Education Stabilization Fund Reporting under Higher Education Emergency Relief Funds (HEERF) Significant Deficiency in Internal Control over Compliance 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) 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 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. Condition - During our testing, we noted the following issues over reporting: ? The financial data reported in the some of the quarterly reports posted for the institutional portion were not supported by the underlying trial balance activity. Cause - The College did not have adequate and/or functioning controls in place to ensure the reporting was accurate. Effect - The College is not in compliance with the reporting requirements described in the OMB Compliance Supplement and required by the Department of Education. Questioned Costs ? None reported Context/Sampling ? Two student quarterly reports, three institutional quarterly reports, and the annual report required under HEERF and due within fiscal year 2022 were tested. Repeat Finding ? Yes, prior year finding 2021-005 Recommendation ? The reporting process was greatly improved over the prior year. The College should continue to ensure the process to review, update, and verify reporting under HEERF is done accurately is occurring. View of Responsible Officials - Management agrees with this finding and will implement the recommendations.
FINDING 2022-003 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013, 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 in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirement. The School Corporation had four annual data reports due during the audit period. All four reports were submitted as required; however, none of the reports were supported by the School Corporation's records. The Elementary and Secondary School Emergency Relief (ESSER I), the Elementary and Secondary School Emergency Relief (ESSER II), and the American Rescue Plan-Elementary and Secondary School Emergency Relief (ARP ESSER), year 1 annual data reports overstated total expenditures made during the reporting period. The ESSER I, year 2 annual data report understated total expenditures made during the reporting period. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following: . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in ?? 200.328 and 200.329. . . . (3) Records that identify adequately the source and application of funds for federallyfunded activities. These records must contain information pertaining to Federal awards, authorizations, financial obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Cause 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 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 2022-003 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013, 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 in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirement. The School Corporation had four annual data reports due during the audit period. All four reports were submitted as required; however, none of the reports were supported by the School Corporation's records. The Elementary and Secondary School Emergency Relief (ESSER I), the Elementary and Secondary School Emergency Relief (ESSER II), and the American Rescue Plan-Elementary and Secondary School Emergency Relief (ARP ESSER), year 1 annual data reports overstated total expenditures made during the reporting period. The ESSER I, year 2 annual data report understated total expenditures made during the reporting period. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following: . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in ?? 200.328 and 200.329. . . . (3) Records that identify adequately the source and application of funds for federallyfunded activities. These records must contain information pertaining to Federal awards, authorizations, financial obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Cause 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 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 2022-003 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013, 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 in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirement. The School Corporation had four annual data reports due during the audit period. All four reports were submitted as required; however, none of the reports were supported by the School Corporation's records. The Elementary and Secondary School Emergency Relief (ESSER I), the Elementary and Secondary School Emergency Relief (ESSER II), and the American Rescue Plan-Elementary and Secondary School Emergency Relief (ARP ESSER), year 1 annual data reports overstated total expenditures made during the reporting period. The ESSER I, year 2 annual data report understated total expenditures made during the reporting period. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following: . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in ?? 200.328 and 200.329. . . . (3) Records that identify adequately the source and application of funds for federallyfunded activities. These records must contain information pertaining to Federal awards, authorizations, financial obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Cause 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 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.