Criteria or Specific Requirement: In accordance with the grant agreements and applicable federal record retention standards (2 CFR 200.334), recipients of federal funds must maintain all records pertinent to the grant—including required progress and financial reports—for a minimum of three years from the date of submission of the final expenditure report. Condition and Context: Solvista Health did not retain certain key documents required to be retained under federal regulation and specific grant agreements. Specifically, Solvista Health was unable to provide quarterly reports, expenditure reimbursement packets submitted to the grantors, project expenditure reports, or other grant-related records necessary to demonstrate compliance with federal reporting and record retention standards under the federal programs. Questioned Costs: N/A Cause: Solvista Health did not implement adequate internal controls to ensure that submitted reports and expenditure reimbursement packets were archived and retained in accordance with grant and federal requirements. Effect: The absence of these records could impede the ability to verify proper grant administration and verify submitted expenditures were allowable costs incurred in accordance with the federal award agreement, which could impact future funding eligibility. It also represents a potential noncompliance with federal grant requirements. Identification as a Repeat Finding: Not a repeat finding. Recommendation: Solvista Health should strengthen its document retention policies and processes and implement internal controls to ensure that all required grant reports are consistently reviewed, approved, submitted, retained and retrievable for the required retention period.
Criteria or Specific Requirement: In accordance with the grant agreements and applicable federal record retention standards (2 CFR 200.334), recipients of federal funds must maintain all records pertinent to the grant—including required progress and financial reports—for a minimum of three years from the date of submission of the final expenditure report. Condition and Context: Solvista Health did not retain certain key documents required to be retained under federal regulation and specific grant agreements. Specifically, Solvista Health was unable to provide quarterly reports, expenditure reimbursement packets submitted to the grantors, project expenditure reports, or other grant-related records necessary to demonstrate compliance with federal reporting and record retention standards under the federal programs. Questioned Costs: N/A Cause: Solvista Health did not implement adequate internal controls to ensure that submitted reports and expenditure reimbursement packets were archived and retained in accordance with grant and federal requirements. Effect: The absence of these records could impede the ability to verify proper grant administration and verify submitted expenditures were allowable costs incurred in accordance with the federal award agreement, which could impact future funding eligibility. It also represents a potential noncompliance with federal grant requirements. Identification as a Repeat Finding: Not a repeat finding. Recommendation: Solvista Health should strengthen its document retention policies and processes and implement internal controls to ensure that all required grant reports are consistently reviewed, approved, submitted, retained and retrievable for the required retention period.
Block Grants for Prevention and Treatment of Substance Abuse ALN No. 93.959 U.S. Department of Health and Human Services Opioid STR ALN No. 93.788 U.S. Department of Health and Human Services Criteria or Specific Requirement – Activities Allowed and Unallowed and Cost Principles – 2 CFR Part 200, Subpart E, and Period of Performance – 2 CFR sections 200.308, 200.309, and 200.403(h) Condition – A sample of 80 expenditures were selected from each of the following populations: • ALN No. 93.959 – 1,152 items totaling $1,077,416 • ALN No. 93.788 – 1,222 items totaling $2,537,080 The samples were not, and are not intended to be, statistically valid. Of the 80 expenditures tested from each grant program, the following were determined to lack appropriate supporting documentation to support being charged to grant program: • ALN No. 93.959 - 41 items totaling $25,810, including projected errors over the total population totaling $191,145 • ALN No. 93.788 - 10 items totaling $72,347, including projected errors over the total population totaling $207,012 The Organization did not have adequate supporting documentation demonstrating actual time and effort reporting and lacked evidence of supporting invoices. Cause – The Organization charged budgeted percentages to the grant programs without a system in place to monitor and track that actual time and effort was consistent with budgeted percentages. In addition, the Organization charged expenditures to the grant programs without evidence of supporting invoices. Effect or potential effect – Costs charged to the grant programs could have varied from actual time and effort. In addition, costs charged to the grant could not be supported by actual invoices. Questioned costs – • ALN No. 93.959 - $25,810 • ALN No. 93.788 - $72,347 Context – The Organization did not have a reasonable methodology of allocating costs to these grant programs and did not maintain proper supporting invoices. Identification as a repeat finding, if applicable – Repeat finding (see 2023-003) Recommendation – Management should implement policies and procedures that strengthen internal control over compliance in relation to activities allowed and cost principles. The policy and procedure should be designed to ensure that a reasonable allocation methodology is implemented and followed or that time and effort is certified by the employee on a regular basis. In addition, management should implement a document retention policy consistent with 2 CFR 200.334.
Block Grants for Prevention and Treatment of Substance Abuse ALN No. 93.959 U.S. Department of Health and Human Services Opioid STR ALN No. 93.788 U.S. Department of Health and Human Services Criteria or Specific Requirement – Activities Allowed and Unallowed and Cost Principles – 2 CFR Part 200, Subpart E, and Period of Performance – 2 CFR sections 200.308, 200.309, and 200.403(h) Condition – A sample of 80 expenditures were selected from each of the following populations: • ALN No. 93.959 – 1,152 items totaling $1,077,416 • ALN No. 93.788 – 1,222 items totaling $2,537,080 The samples were not, and are not intended to be, statistically valid. Of the 80 expenditures tested from each grant program, the following were determined to lack appropriate supporting documentation to support being charged to grant program: • ALN No. 93.959 - 41 items totaling $25,810, including projected errors over the total population totaling $191,145 • ALN No. 93.788 - 10 items totaling $72,347, including projected errors over the total population totaling $207,012 The Organization did not have adequate supporting documentation demonstrating actual time and effort reporting and lacked evidence of supporting invoices. Cause – The Organization charged budgeted percentages to the grant programs without a system in place to monitor and track that actual time and effort was consistent with budgeted percentages. In addition, the Organization charged expenditures to the grant programs without evidence of supporting invoices. Effect or potential effect – Costs charged to the grant programs could have varied from actual time and effort. In addition, costs charged to the grant could not be supported by actual invoices. Questioned costs – • ALN No. 93.959 - $25,810 • ALN No. 93.788 - $72,347 Context – The Organization did not have a reasonable methodology of allocating costs to these grant programs and did not maintain proper supporting invoices. Identification as a repeat finding, if applicable – Repeat finding (see 2023-003) Recommendation – Management should implement policies and procedures that strengthen internal control over compliance in relation to activities allowed and cost principles. The policy and procedure should be designed to ensure that a reasonable allocation methodology is implemented and followed or that time and effort is certified by the employee on a regular basis. In addition, management should implement a document retention policy consistent with 2 CFR 200.334.
U.S. Department of Health and Human Services Program Name: Maternal and Child Health Services Block Grant Federal Assistance Listing Number: 93.994 Significant Deficiency, Nonmaterial Noncompliance - Reporting Finding 2024-006 Criteria or Specific Requirement: Per Section 200.303 of the Uniform Grant Guidance, 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. Per 2 CFR 200.334 the recipient must retain all Federal award records for three years from the date of submission of their final financial report. Condition: During the audit we tested 13 reports and noted the following: a) There were four (4) instances out of 13 reports tested where the submitted reports were unable to be provided, including the date of submission for the reports. b) There were 10 instances out of 13 reports tested where the County was unable to provide evidence the report was reviewed prior to submission. Questioned Costs: None. Effect: By not having the required documentation and underlying support, the County is not able to demonstrate compliance with the applicable requirements. Cause: The County did not have a formal policy to ensure documentation was retained to evidence review and submission of all reports. Recommendation: The County should consider creating a formalized policy to require all submitted reports and underlying data are retained in accordance with the Uniform Grant Guidance requirements. Views of Responsible Officials: Management agrees with the finding and is implementing procedures to correct this which is further discussed in the Corrective Action Plan. Corrective Action Plan: See Corrective Action Plan prepared by the County.
Federal Agency: U.S. Department of Education Federal Program Name: Elementary and Secondary School Relief Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Identification Number and Year: S425D210044 Federal Award Date 1/6/2021, S425U210044 Federal Award Date 12/6/2021 and 3/13/2020 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Number(s): 2022-714508-DPI-ESSERFII-163, 2022-714508-DPI-ESSERFIII-165, 2024-714508-DPI-LETRS-165 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Material Weakness in Internal Control over Compliance and Other Matter Criteria or Specific Requirement: 2 CFR 200.334 states that "The recipient and subrecipient must retain all Federal award records for three years from the date of submission of their final financial report. For awards that are renewed quarterly or annually, the recipient and subrecipient must retain records for three years from the date of submission of their quarterly or annual financial report, respectively. Records to be retained include but are not limited to, financial records, supporting documentation, and statistical records." Segregation of duties is an internal control intended to prevent or decrease the occurrence of errors or intentional fraud. Segregation of duties ensures that no single employee has control over all phases of a transaction. Condition: The District is required to file an annual report for ESSER. The supporting documentation used to enter the data into the reporting portal was not maintained and there was no review of the data entered into the form by someone other than the preparer. Accordingly, this does not allow for a proper segregation of duties for internal control purposes. Questioned Costs: None. Context: While performing audit procedures, it was noted that there was no review of the report completed by the finance director by someone else. The supporting documents used to complete the report was not retained by the District. Cause: The lack of segregation of duties is due to the limited number of employees and the size of the District’s operations. Effect: Errors or intentional fraud could occur and not be detected timely by other employees in the normal course of their responsibilities as a result of the lack of segregation of duties. Repeat Finding: No. Recommendation: We recommend the District review its grant reporting processes and implement internal controls to help ensure that there is adequate segregation of duties in regards to grant reporting including special reports and that all supporting documentation is maintained with the filed copy of the report. Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Elementary and Secondary School Relief Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Identification Number and Year: S425D210044 Federal Award Date 1/6/2021, S425U210044 Federal Award Date 12/6/2021 and 3/13/2020 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Number(s): 2022-714508-DPI-ESSERFII-163, 2022-714508-DPI-ESSERFIII-165, 2024-714508-DPI-LETRS-165 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Material Weakness in Internal Control over Compliance and Other Matter Criteria or Specific Requirement: 2 CFR 200.334 states that "The recipient and subrecipient must retain all Federal award records for three years from the date of submission of their final financial report. For awards that are renewed quarterly or annually, the recipient and subrecipient must retain records for three years from the date of submission of their quarterly or annual financial report, respectively. Records to be retained include but are not limited to, financial records, supporting documentation, and statistical records." Segregation of duties is an internal control intended to prevent or decrease the occurrence of errors or intentional fraud. Segregation of duties ensures that no single employee has control over all phases of a transaction. Condition: The District is required to file an annual report for ESSER. The supporting documentation used to enter the data into the reporting portal was not maintained and there was no review of the data entered into the form by someone other than the preparer. Accordingly, this does not allow for a proper segregation of duties for internal control purposes. Questioned Costs: None. Context: While performing audit procedures, it was noted that there was no review of the report completed by the finance director by someone else. The supporting documents used to complete the report was not retained by the District. Cause: The lack of segregation of duties is due to the limited number of employees and the size of the District’s operations. Effect: Errors or intentional fraud could occur and not be detected timely by other employees in the normal course of their responsibilities as a result of the lack of segregation of duties. Repeat Finding: No. Recommendation: We recommend the District review its grant reporting processes and implement internal controls to help ensure that there is adequate segregation of duties in regards to grant reporting including special reports and that all supporting documentation is maintained with the filed copy of the report. Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Elementary and Secondary School Relief Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Identification Number and Year: S425D210044 Federal Award Date 1/6/2021, S425U210044 Federal Award Date 12/6/2021 and 3/13/2020 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Number(s): 2022-714508-DPI-ESSERFII-163, 2022-714508-DPI-ESSERFIII-165, 2024-714508-DPI-LETRS-165 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Material Weakness in Internal Control over Compliance and Other Matter Criteria or Specific Requirement: 2 CFR 200.334 states that "The recipient and subrecipient must retain all Federal award records for three years from the date of submission of their final financial report. For awards that are renewed quarterly or annually, the recipient and subrecipient must retain records for three years from the date of submission of their quarterly or annual financial report, respectively. Records to be retained include but are not limited to, financial records, supporting documentation, and statistical records." Segregation of duties is an internal control intended to prevent or decrease the occurrence of errors or intentional fraud. Segregation of duties ensures that no single employee has control over all phases of a transaction. Condition: The District is required to file an annual report for ESSER. The supporting documentation used to enter the data into the reporting portal was not maintained and there was no review of the data entered into the form by someone other than the preparer. Accordingly, this does not allow for a proper segregation of duties for internal control purposes. Questioned Costs: None. Context: While performing audit procedures, it was noted that there was no review of the report completed by the finance director by someone else. The supporting documents used to complete the report was not retained by the District. Cause: The lack of segregation of duties is due to the limited number of employees and the size of the District’s operations. Effect: Errors or intentional fraud could occur and not be detected timely by other employees in the normal course of their responsibilities as a result of the lack of segregation of duties. Repeat Finding: No. Recommendation: We recommend the District review its grant reporting processes and implement internal controls to help ensure that there is adequate segregation of duties in regards to grant reporting including special reports and that all supporting documentation is maintained with the filed copy of the report. Views of Responsible Officials: There is no disagreement with the audit finding.
FINDING 2024-001 DOCUMENT RETENTION SIGNIFICANT DEFICIENCY Federal Program: Child Nutrition Cluster Assistance Listing Number: 10.553 & 10.555 Criteria Per 7 CFR 200.334, “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.” Condition Two claims for meal reimbursement were selected for testing. The School was unable to provide records of meals served. The School qualified for the Community Eligibility Provision program and all students receive free meals. Meals claimed were below the maximum that could have been claimed had all students obtained school meals each day of the periods under review. No determination of questioned costs could be made. Cause The School did not maintain documentation for each individual claim. Effect Reconciliation of meals served data to individual claims was not possible. Recommendation We recommend the School develop internal controls requiring the maintenance of documentation of meals served for the individual claims submitted for the program. Views of Responsible Officials The School’s Corrective Action Plan is included on page 25.
FINDING 2024-001 DOCUMENT RETENTION SIGNIFICANT DEFICIENCY Federal Program: Child Nutrition Cluster Assistance Listing Number: 10.553 & 10.555 Criteria Per 7 CFR 200.334, “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.” Condition Two claims for meal reimbursement were selected for testing. The School was unable to provide records of meals served. The School qualified for the Community Eligibility Provision program and all students receive free meals. Meals claimed were below the maximum that could have been claimed had all students obtained school meals each day of the periods under review. No determination of questioned costs could be made. Cause The School did not maintain documentation for each individual claim. Effect Reconciliation of meals served data to individual claims was not possible. Recommendation We recommend the School develop internal controls requiring the maintenance of documentation of meals served for the individual claims submitted for the program. Views of Responsible Officials The School’s Corrective Action Plan is included on page 25.
FINDING 2024-003 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Number: 84.425U Federal Award Number and Year (or Other Identifying Number): S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2022-002. Condition and Context An effective internal control system was not designed or implemented at the School Corporation to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirement. The School Corporation had not designed, nor implemented, a system of internal controls to ensure that the annual Elementary and Secondary School Emergency Relief (ESSER) Data Collection reports (Reports) were complete and accurately submitted. The Reports were prepared by one employee without a documented oversight, review, or approval process in place to prevent, or detect and correct, errors. Due to the lack of effective internal controls, two of the five Reports submitted during the audit period were not supported by the School Corporation's records. The following errors were noted: For the ESSER III, Year 2 report, which covered the period July 1, 2021 to June 30, 2022, total expenses reported were understated by $369,741. For the ESSER III, Year 3 report, which covered the period July 1, 2022 to June 30, 2023, total expenses reported for Property - Mandatory Subgrant Funds - Exclusive of Learning Loss Set-Aside were understated by $519,504. Total expenses reported for Supplies - Mandatory Subgrant Funds - Learning Loss Set-Aside were overstated by $11,260. The lack of internal controls was a systemic issue throughout the audit period. Noncompliance was isolated to the ESSER III, Year 2 and Year 3 reports. INDIANA STATE BOARD OF ACCOUNTS 18 JAC-CEN-DEL COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Cause A proper system of internal controls was not designed by management of the School Corporation. Due to turnover in the position responsible for review, reports were not reviewed to detect errors prior to submission. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, the ESSER III, Year 2 and Year 3 reports were not supported by the School Corporation's records. INDIANA STATE BOARD OF ACCOUNTS 19 JAC-CEN-DEL COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Questioned Costs There were no questioned costs identified. Recommendation We recommended that the management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure that all reports are supported by the School Corporation's records. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-003 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Number: 84.425U Federal Award Number and Year (or Other Identifying Number): S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2022-002. Condition and Context An effective internal control system was not designed or implemented at the School Corporation to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirement. The School Corporation had not designed, nor implemented, a system of internal controls to ensure that the annual Elementary and Secondary School Emergency Relief (ESSER) Data Collection reports (Reports) were complete and accurately submitted. The Reports were prepared by one employee without a documented oversight, review, or approval process in place to prevent, or detect and correct, errors. Due to the lack of effective internal controls, two of the five Reports submitted during the audit period were not supported by the School Corporation's records. The following errors were noted: For the ESSER III, Year 2 report, which covered the period July 1, 2021 to June 30, 2022, total expenses reported were understated by $369,741. For the ESSER III, Year 3 report, which covered the period July 1, 2022 to June 30, 2023, total expenses reported for Property - Mandatory Subgrant Funds - Exclusive of Learning Loss Set-Aside were understated by $519,504. Total expenses reported for Supplies - Mandatory Subgrant Funds - Learning Loss Set-Aside were overstated by $11,260. The lack of internal controls was a systemic issue throughout the audit period. Noncompliance was isolated to the ESSER III, Year 2 and Year 3 reports. INDIANA STATE BOARD OF ACCOUNTS 18 JAC-CEN-DEL COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Cause A proper system of internal controls was not designed by management of the School Corporation. Due to turnover in the position responsible for review, reports were not reviewed to detect errors prior to submission. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, the ESSER III, Year 2 and Year 3 reports were not supported by the School Corporation's records. INDIANA STATE BOARD OF ACCOUNTS 19 JAC-CEN-DEL COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Questioned Costs There were no questioned costs identified. Recommendation We recommended that the management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure that all reports are supported by the School Corporation's records. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-005 Subject: Title I Grants to Local Educational Agencies - Eligibility 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): S010A210014, S010A220014, S010A230014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Findings: Material Weakness, Modified Opinion Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2022-003. INDIANA STATE BOARD OF ACCOUNTS 23 MADISON CONSOLIDATED SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Condition and Context Eligibility for Title I is determined on the Eligible School Summary of the Tile I application. Enrollment and Poverty numbers are automatically pulled from the Indiana Department of Education's (IDOE) Official Pupil Enrollment (PE) count for each school into the Eligible School Summary page of the Tile I application. These counts that are prepopulated should be based on the School Corporation's records as of October of the prior fiscal year. One person compiled and uploaded enrollment data, including poverty status for Real Time (RT) reports, to the IDOE without a documented oversight or review process to ensure that the information was accurate and retained for audit. In addition, there was no review by the School Corporation of the enrollment and poverty counts that were prepopulated into the School Corporation's Title I grant application. The IDOE used the October 1 RT reports for fiscal years 2021-2022 and 2022-2023, as provided by the School Corporation, to determine Eligibility for the 2022-2023 and 2023-2024 grant programs, respectively. The October 1 RT report could not be presented for audit for 2021-2022, which would have been used to pull in enrollment and poverty information for the 2022-2023 grant. As such, we were unable to verify the amounts reported in the grant application. Additionally, the Indiana State Board of Accounts was unable to verify if the correct socioeconomic status was properly reported for any of the students. Enrollment and poverty numbers for any nonpublic schools are manually entered into the application by the School Corporation. The School Corporation had not established an effective process to review the listing of students from the nonpublic schools for enrollment and poverty counts to be entered into the Title I application and to retain this information for audit. We were unable to determine if the enrolled student count and their poverty status in the application was accurate. The lack of internal controls and lack of information submitted for audit was a systemic issue throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for the Federal awards that are renewed quarterly or annual, from the date of submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." INDIANA STATE BOARD OF ACCOUNTS 24 MADISON CONSOLIDATED SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Cause A proper system of internal controls was not designed by management of the School Corporation, which would include segregation of key functions, to ensure all records pertinent to the federal award were retained for audit. After a change in software providers, information from the previous provider could not be obtained for audit. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, RT reports and nonpublic school enrollment documentation were not maintained for audit, and, as such, the Indiana State Board of Accounts could not determine if the School Corporation complied with the Eligibility compliance requirement. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure RT reports, and nonpublic school enrollment documentation are maintained for audit. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-005 Subject: Title I Grants to Local Educational Agencies - Eligibility 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): S010A210014, S010A220014, S010A230014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Findings: Material Weakness, Modified Opinion Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2022-003. INDIANA STATE BOARD OF ACCOUNTS 23 MADISON CONSOLIDATED SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Condition and Context Eligibility for Title I is determined on the Eligible School Summary of the Tile I application. Enrollment and Poverty numbers are automatically pulled from the Indiana Department of Education's (IDOE) Official Pupil Enrollment (PE) count for each school into the Eligible School Summary page of the Tile I application. These counts that are prepopulated should be based on the School Corporation's records as of October of the prior fiscal year. One person compiled and uploaded enrollment data, including poverty status for Real Time (RT) reports, to the IDOE without a documented oversight or review process to ensure that the information was accurate and retained for audit. In addition, there was no review by the School Corporation of the enrollment and poverty counts that were prepopulated into the School Corporation's Title I grant application. The IDOE used the October 1 RT reports for fiscal years 2021-2022 and 2022-2023, as provided by the School Corporation, to determine Eligibility for the 2022-2023 and 2023-2024 grant programs, respectively. The October 1 RT report could not be presented for audit for 2021-2022, which would have been used to pull in enrollment and poverty information for the 2022-2023 grant. As such, we were unable to verify the amounts reported in the grant application. Additionally, the Indiana State Board of Accounts was unable to verify if the correct socioeconomic status was properly reported for any of the students. Enrollment and poverty numbers for any nonpublic schools are manually entered into the application by the School Corporation. The School Corporation had not established an effective process to review the listing of students from the nonpublic schools for enrollment and poverty counts to be entered into the Title I application and to retain this information for audit. We were unable to determine if the enrolled student count and their poverty status in the application was accurate. The lack of internal controls and lack of information submitted for audit was a systemic issue throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for the Federal awards that are renewed quarterly or annual, from the date of submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." INDIANA STATE BOARD OF ACCOUNTS 24 MADISON CONSOLIDATED SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Cause A proper system of internal controls was not designed by management of the School Corporation, which would include segregation of key functions, to ensure all records pertinent to the federal award were retained for audit. After a change in software providers, information from the previous provider could not be obtained for audit. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, RT reports and nonpublic school enrollment documentation were not maintained for audit, and, as such, the Indiana State Board of Accounts could not determine if the School Corporation complied with the Eligibility compliance requirement. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure RT reports, and nonpublic school enrollment documentation are maintained for audit. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Information on the federal program: Subject: Title I Grants to Local Educational Agencies – Special Tests and Provisions – Annual Report Card, High School Graduation Rate Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listing Number: 84.010A Federal Award Numbers: S010A210014, S010A220014, S010A230014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions – Annual Report Card, High School Graduation Rate 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 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)...." 20 USC 7801(23)(B) states: "To remove a student from a cohort, a school or local educational agency shall require documentation, or obtain information from the State educational agency, to confirm that the student has transferred out, emigrated to another country, or transferred to a prison or juvenile facility, or deceased." 2 CFR 200.333 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient..." 2 CFR 200.334 (Revised Uniform Guidance) 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. . 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 Special Tests and Provisions - Annual Report Card, High School Graduation Rate compliance requirement. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Cause: Management had not developed nor implemented a system of internal control that would have ensured compliance with the grant agreement and the Special Tests and Provisions compliance requirement. Effect: The failure to establish an effective internal control system could enable noncompliance to go undetected. Noncompliance with the grant agreement and the Special Tests and Provisions – Annual Report Card, High School Graduation Rate compliance requirement could result in 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 Special Tests and Provisions - Annual Report Card, High School Graduation Rate compliance requirement. There was no formal documented review of mobility reports in Skyward during our audit period. Identification as a repeat finding: This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2022-003. Recommendation: We recommended that the School Corporation's management establish an effective system of internal control to ensure compliance and comply with the grant agreement and the Special Tests and Provisions - Annual Report Card, High School Graduation Rate compliance requirement. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Information on the federal program: Subject: Title I Grants to Local Educational Agencies – Special Tests and Provisions – Annual Report Card, High School Graduation Rate Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listing Number: 84.010A Federal Award Numbers: S010A210014, S010A220014, S010A230014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions – Annual Report Card, High School Graduation Rate 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 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)...." 20 USC 7801(23)(B) states: "To remove a student from a cohort, a school or local educational agency shall require documentation, or obtain information from the State educational agency, to confirm that the student has transferred out, emigrated to another country, or transferred to a prison or juvenile facility, or deceased." 2 CFR 200.333 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient..." 2 CFR 200.334 (Revised Uniform Guidance) 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. . 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 Special Tests and Provisions - Annual Report Card, High School Graduation Rate compliance requirement. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Cause: Management had not developed nor implemented a system of internal control that would have ensured compliance with the grant agreement and the Special Tests and Provisions compliance requirement. Effect: The failure to establish an effective internal control system could enable noncompliance to go undetected. Noncompliance with the grant agreement and the Special Tests and Provisions – Annual Report Card, High School Graduation Rate compliance requirement could result in 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 Special Tests and Provisions - Annual Report Card, High School Graduation Rate compliance requirement. There was no formal documented review of mobility reports in Skyward during our audit period. Identification as a repeat finding: This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2022-003. Recommendation: We recommended that the School Corporation's management establish an effective system of internal control to ensure compliance and comply with the grant agreement and the Special Tests and Provisions - Annual Report Card, High School Graduation Rate compliance requirement. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Information on the federal program: Subject: Title I Grants to Local Educational Agencies – Special Tests and Provisions – Annual Report Card, High School Graduation Rate Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listing Number: 84.010A Federal Award Numbers: S010A210014, S010A220014, S010A230014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions – Annual Report Card, High School Graduation Rate 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 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)...." 20 USC 7801(23)(B) states: "To remove a student from a cohort, a school or local educational agency shall require documentation, or obtain information from the State educational agency, to confirm that the student has transferred out, emigrated to another country, or transferred to a prison or juvenile facility, or deceased." 2 CFR 200.333 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient..." 2 CFR 200.334 (Revised Uniform Guidance) 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. . 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 Special Tests and Provisions - Annual Report Card, High School Graduation Rate compliance requirement. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Cause: Management had not developed nor implemented a system of internal control that would have ensured compliance with the grant agreement and the Special Tests and Provisions compliance requirement. Effect: The failure to establish an effective internal control system could enable noncompliance to go undetected. Noncompliance with the grant agreement and the Special Tests and Provisions – Annual Report Card, High School Graduation Rate compliance requirement could result in 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 Special Tests and Provisions - Annual Report Card, High School Graduation Rate compliance requirement. There was no formal documented review of mobility reports in Skyward during our audit period. Identification as a repeat finding: This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2022-003. Recommendation: We recommended that the School Corporation's management establish an effective system of internal control to ensure compliance and comply with the grant agreement and the Special Tests and Provisions - Annual Report Card, High School Graduation Rate compliance requirement. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
FINDING 2024-003 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Indiana Department of Education Federal Program: COVID-19 - Education Stablization Fund Assistance Listings Numbers: 84.425C, 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425C200018, S425D200013, S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion Condition and Context The School Corporation was required to submit annual data reports to the Indiana Department of Education (IDOE) via JotForm, a form/report builder. Data to be submitted included, but was not limited to, current period expenditures, prior period expenditures, and expenditures per activity. During the audit period, the School Corporation submitted one ESSER I report, two ESSER II reports, and two ESSER III reports for a total of five reports. The annual data reports were compiled, prepared, and submitted by the Treasurer without an oversight or review process in place to prevent, or detect and correct, errors. In addition, the five annual data reports were not supported by the School Corporation's records. The documentation used to prepare the reports was not retained by the School Corporation and the ledger activity for the time period of each report did not agree to the data submitted. As such, the Indiana State Board of Accounts could not verify the information submitted to the IDOE was accurate or complete. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for the Federal awards that are renewed quarterly or annual, from the date of submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . ." (3) Records that identify adequately the source and application of funds for federally funded activities. These records must contain information pertaining to Federal awards, authorizations, obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." 34 CFR 76.731 states: "A State and a subgrantee shall keep records to show its compliance with program requirements." Cause A proper system of internal controls, which include segregation of key functions, was not established by management of the School Corporation to ensure that reports filed were supported by School Corporation records and had an independent review, for accuracy and completeness, prior to submission. Effect Without a proper system of internal controls in place that operated effectively, the School Corporation submitted reports that were not supported by School Corporation records. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure that documentation utilized in the preparation of the reports is maintained and that there is an independent review of the reports for accuracy and completeness prior to submission. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-003 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Indiana Department of Education Federal Program: COVID-19 - Education Stablization Fund Assistance Listings Numbers: 84.425C, 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425C200018, S425D200013, S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion Condition and Context The School Corporation was required to submit annual data reports to the Indiana Department of Education (IDOE) via JotForm, a form/report builder. Data to be submitted included, but was not limited to, current period expenditures, prior period expenditures, and expenditures per activity. During the audit period, the School Corporation submitted one ESSER I report, two ESSER II reports, and two ESSER III reports for a total of five reports. The annual data reports were compiled, prepared, and submitted by the Treasurer without an oversight or review process in place to prevent, or detect and correct, errors. In addition, the five annual data reports were not supported by the School Corporation's records. The documentation used to prepare the reports was not retained by the School Corporation and the ledger activity for the time period of each report did not agree to the data submitted. As such, the Indiana State Board of Accounts could not verify the information submitted to the IDOE was accurate or complete. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for the Federal awards that are renewed quarterly or annual, from the date of submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . ." (3) Records that identify adequately the source and application of funds for federally funded activities. These records must contain information pertaining to Federal awards, authorizations, obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." 34 CFR 76.731 states: "A State and a subgrantee shall keep records to show its compliance with program requirements." Cause A proper system of internal controls, which include segregation of key functions, was not established by management of the School Corporation to ensure that reports filed were supported by School Corporation records and had an independent review, for accuracy and completeness, prior to submission. Effect Without a proper system of internal controls in place that operated effectively, the School Corporation submitted reports that were not supported by School Corporation records. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure that documentation utilized in the preparation of the reports is maintained and that there is an independent review of the reports for accuracy and completeness prior to submission. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-003 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Indiana Department of Education Federal Program: COVID-19 - Education Stablization Fund Assistance Listings Numbers: 84.425C, 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425C200018, S425D200013, S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion Condition and Context The School Corporation was required to submit annual data reports to the Indiana Department of Education (IDOE) via JotForm, a form/report builder. Data to be submitted included, but was not limited to, current period expenditures, prior period expenditures, and expenditures per activity. During the audit period, the School Corporation submitted one ESSER I report, two ESSER II reports, and two ESSER III reports for a total of five reports. The annual data reports were compiled, prepared, and submitted by the Treasurer without an oversight or review process in place to prevent, or detect and correct, errors. In addition, the five annual data reports were not supported by the School Corporation's records. The documentation used to prepare the reports was not retained by the School Corporation and the ledger activity for the time period of each report did not agree to the data submitted. As such, the Indiana State Board of Accounts could not verify the information submitted to the IDOE was accurate or complete. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for the Federal awards that are renewed quarterly or annual, from the date of submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . ." (3) Records that identify adequately the source and application of funds for federally funded activities. These records must contain information pertaining to Federal awards, authorizations, obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." 34 CFR 76.731 states: "A State and a subgrantee shall keep records to show its compliance with program requirements." Cause A proper system of internal controls, which include segregation of key functions, was not established by management of the School Corporation to ensure that reports filed were supported by School Corporation records and had an independent review, for accuracy and completeness, prior to submission. Effect Without a proper system of internal controls in place that operated effectively, the School Corporation submitted reports that were not supported by School Corporation records. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure that documentation utilized in the preparation of the reports is maintained and that there is an independent review of the reports for accuracy and completeness prior to submission. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-003 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Indiana Department of Education Federal Program: COVID-19 - Education Stablization Fund Assistance Listings Numbers: 84.425C, 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425C200018, S425D200013, S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion Condition and Context The School Corporation was required to submit annual data reports to the Indiana Department of Education (IDOE) via JotForm, a form/report builder. Data to be submitted included, but was not limited to, current period expenditures, prior period expenditures, and expenditures per activity. During the audit period, the School Corporation submitted one ESSER I report, two ESSER II reports, and two ESSER III reports for a total of five reports. The annual data reports were compiled, prepared, and submitted by the Treasurer without an oversight or review process in place to prevent, or detect and correct, errors. In addition, the five annual data reports were not supported by the School Corporation's records. The documentation used to prepare the reports was not retained by the School Corporation and the ledger activity for the time period of each report did not agree to the data submitted. As such, the Indiana State Board of Accounts could not verify the information submitted to the IDOE was accurate or complete. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for the Federal awards that are renewed quarterly or annual, from the date of submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . ." (3) Records that identify adequately the source and application of funds for federally funded activities. These records must contain information pertaining to Federal awards, authorizations, obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." 34 CFR 76.731 states: "A State and a subgrantee shall keep records to show its compliance with program requirements." Cause A proper system of internal controls, which include segregation of key functions, was not established by management of the School Corporation to ensure that reports filed were supported by School Corporation records and had an independent review, for accuracy and completeness, prior to submission. Effect Without a proper system of internal controls in place that operated effectively, the School Corporation submitted reports that were not supported by School Corporation records. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure that documentation utilized in the preparation of the reports is maintained and that there is an independent review of the reports for accuracy and completeness prior to submission. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-003 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Indiana Department of Education Federal Program: COVID-19 - Education Stablization Fund Assistance Listings Numbers: 84.425C, 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425C200018, S425D200013, S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion Condition and Context The School Corporation was required to submit annual data reports to the Indiana Department of Education (IDOE) via JotForm, a form/report builder. Data to be submitted included, but was not limited to, current period expenditures, prior period expenditures, and expenditures per activity. During the audit period, the School Corporation submitted one ESSER I report, two ESSER II reports, and two ESSER III reports for a total of five reports. The annual data reports were compiled, prepared, and submitted by the Treasurer without an oversight or review process in place to prevent, or detect and correct, errors. In addition, the five annual data reports were not supported by the School Corporation's records. The documentation used to prepare the reports was not retained by the School Corporation and the ledger activity for the time period of each report did not agree to the data submitted. As such, the Indiana State Board of Accounts could not verify the information submitted to the IDOE was accurate or complete. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for the Federal awards that are renewed quarterly or annual, from the date of submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . ." (3) Records that identify adequately the source and application of funds for federally funded activities. These records must contain information pertaining to Federal awards, authorizations, obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." 34 CFR 76.731 states: "A State and a subgrantee shall keep records to show its compliance with program requirements." Cause A proper system of internal controls, which include segregation of key functions, was not established by management of the School Corporation to ensure that reports filed were supported by School Corporation records and had an independent review, for accuracy and completeness, prior to submission. Effect Without a proper system of internal controls in place that operated effectively, the School Corporation submitted reports that were not supported by School Corporation records. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure that documentation utilized in the preparation of the reports is maintained and that there is an independent review of the reports for accuracy and completeness prior to submission. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-003 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Indiana Department of Education Federal Program: COVID-19 - Education Stablization Fund Assistance Listings Numbers: 84.425C, 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425C200018, S425D200013, S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion Condition and Context The School Corporation was required to submit annual data reports to the Indiana Department of Education (IDOE) via JotForm, a form/report builder. Data to be submitted included, but was not limited to, current period expenditures, prior period expenditures, and expenditures per activity. During the audit period, the School Corporation submitted one ESSER I report, two ESSER II reports, and two ESSER III reports for a total of five reports. The annual data reports were compiled, prepared, and submitted by the Treasurer without an oversight or review process in place to prevent, or detect and correct, errors. In addition, the five annual data reports were not supported by the School Corporation's records. The documentation used to prepare the reports was not retained by the School Corporation and the ledger activity for the time period of each report did not agree to the data submitted. As such, the Indiana State Board of Accounts could not verify the information submitted to the IDOE was accurate or complete. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for the Federal awards that are renewed quarterly or annual, from the date of submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . ." (3) Records that identify adequately the source and application of funds for federally funded activities. These records must contain information pertaining to Federal awards, authorizations, obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." 34 CFR 76.731 states: "A State and a subgrantee shall keep records to show its compliance with program requirements." Cause A proper system of internal controls, which include segregation of key functions, was not established by management of the School Corporation to ensure that reports filed were supported by School Corporation records and had an independent review, for accuracy and completeness, prior to submission. Effect Without a proper system of internal controls in place that operated effectively, the School Corporation submitted reports that were not supported by School Corporation records. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure that documentation utilized in the preparation of the reports is maintained and that there is an independent review of the reports for accuracy and completeness prior to submission. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-004 Subject: Child Nutrition Cluster - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Special Milk Program for Children Assistance Listings Numbers: 10.553, 10.555, 10.556 Federal Award Numbers and Years (or Other Identifying Numbers): FY2023, FY2024 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Activities Allowed and Unallowed, Allowable Costs/Cost Principles Audit Findings: Material Weakness, Other Matters Condition and Context Internal control is generally defined as a process affected by an entity's oversight body, management, and other personnel that provides reasonable assurance that the objectives of an entity will be achieved. With respect to federal awards, nonfederal entities, such as the School Corporation, are required to establish and maintain internal controls over federal awards that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and terms and conditions of the federal awards. INDIANA STATE BOARD OF ACCOUNTS 22 CANNELTON CITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Internal control is not one event or circumstance, but a dynamic and iterative process. The internal control process is based on fundamental principles that operate as a whole but are best understood when analyzed individually. The fundamental principles are related to five components of internal control which are as follows: Control Environment, Risk Assessment, Control Activities, Information and Communication, and Monitoring. If a component is not effective, or the components are not operating together in an integrated manner, then an internal control system cannot be effective. Deficiencies as noted below were identified in the risk assessment, monitoring, and control activities components. Risk Assessment The School Corporation has not established a formal risk assessment process. There is no documented risk assessment policy, nor is there evidence of periodic risk identification, analysis, or evaluation. Monitoring The School Corporation did not conduct ongoing or periodic reviews to ensure that internal controls were operating as intended and to identify areas for improvement. Furthermore, the School Corporation did not have a process to follow up on corrective actions written as a response to audit findings. Control Activities A sample of 60 claims was selected for testing. Of the 60 claims selected for testing, 43 claims were vendor claims and 17 were payroll claims. Issues were identified with 5 of the vendor claims as noted below: Three claims, totaling $700, were paid based solely upon summary statements from the vendor. The School Corporation was unable to provide additional documentation, such as invoices, to detail what items or services had been purchased. Without adequate supporting documentation, we could not determine if the expenses incurred were for activities and costs allowable per the grant. Two claims, totaling $313, were paid with no supporting documentation. The School Corporation was unable to provide additional documentation, such as invoices, to detail what items or services had been purchased. Without adequate supporting documentation, we could not determine if the expenses incurred were for activities and costs allowable per the grant. The total amount, $1,013, paid without adequate supporting documentation was considered questioned costs. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: INDIANA STATE BOARD OF ACCOUNTS 23 CANNELTON CITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.334 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 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. . . . (g) Be adequately documented. . . ." 7 CFR 210.14(a) states in part: ". . . Revenues received by the nonprofit school food service are to be used only for the operation or improvement of such food service, except that, such revenues shall not be used to purchase land or buildings, unless otherwise approved by FNS, or to construct buildings. . . ." 7 CFR 220.7(e)(1)(ii) states in part: ". . . use all revenues received by such food service only for the operation or improvement of that food service . . ." Cause Management of the School Corporation had not taken steps to design and implement policies and procedures to assess risks facing the School Corporation or to establish and operate monitoring activities that monitor the internal control system. Additionally, the School Corporation did not follow proper recordkeeping procedures. The Treasurer paid claims from federal program funds with no support or based on summary statements. INDIANA STATE BOARD OF ACCOUNTS 24 CANNELTON CITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Effect As a result of the five components of internal control not being adequately designed and implemented, the internal control system cannot be effective. Thus, general risks or specific risks from fraud and significant changes could negatively impact the School Corporation, identified internal control deficiencies could continue, and unidentified flaws within the internal control system could exist. Additionally, we could not determine if federal program funds were used to pay only for the operation or improvement of the food service. Furthermore, the lack of detailed documentation was not in compliance with the cost principles. Continued payment with no support or only summary statements could lead to payments for unallowable activities and additional questioned costs. Questioned Costs Questioned costs in the amount of $1,013 were identified as noted in the Condition and Context. Recommendation We recommended that the School Corporation's management establish a proper system of internal controls, which would include policies and procedures related to risk assessment and monitoring. Additionally, we recommended that the School Corporation's management establish a proper system of internal controls to ensure expenditures made from federal awards have appropriate supporting documentation to ensure expenditures are allowable per the terms and conditions of the federal award and adhere to the cost principles. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-004 Subject: Child Nutrition Cluster - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Special Milk Program for Children Assistance Listings Numbers: 10.553, 10.555, 10.556 Federal Award Numbers and Years (or Other Identifying Numbers): FY2023, FY2024 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Activities Allowed and Unallowed, Allowable Costs/Cost Principles Audit Findings: Material Weakness, Other Matters Condition and Context Internal control is generally defined as a process affected by an entity's oversight body, management, and other personnel that provides reasonable assurance that the objectives of an entity will be achieved. With respect to federal awards, nonfederal entities, such as the School Corporation, are required to establish and maintain internal controls over federal awards that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and terms and conditions of the federal awards. INDIANA STATE BOARD OF ACCOUNTS 22 CANNELTON CITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Internal control is not one event or circumstance, but a dynamic and iterative process. The internal control process is based on fundamental principles that operate as a whole but are best understood when analyzed individually. The fundamental principles are related to five components of internal control which are as follows: Control Environment, Risk Assessment, Control Activities, Information and Communication, and Monitoring. If a component is not effective, or the components are not operating together in an integrated manner, then an internal control system cannot be effective. Deficiencies as noted below were identified in the risk assessment, monitoring, and control activities components. Risk Assessment The School Corporation has not established a formal risk assessment process. There is no documented risk assessment policy, nor is there evidence of periodic risk identification, analysis, or evaluation. Monitoring The School Corporation did not conduct ongoing or periodic reviews to ensure that internal controls were operating as intended and to identify areas for improvement. Furthermore, the School Corporation did not have a process to follow up on corrective actions written as a response to audit findings. Control Activities A sample of 60 claims was selected for testing. Of the 60 claims selected for testing, 43 claims were vendor claims and 17 were payroll claims. Issues were identified with 5 of the vendor claims as noted below: Three claims, totaling $700, were paid based solely upon summary statements from the vendor. The School Corporation was unable to provide additional documentation, such as invoices, to detail what items or services had been purchased. Without adequate supporting documentation, we could not determine if the expenses incurred were for activities and costs allowable per the grant. Two claims, totaling $313, were paid with no supporting documentation. The School Corporation was unable to provide additional documentation, such as invoices, to detail what items or services had been purchased. Without adequate supporting documentation, we could not determine if the expenses incurred were for activities and costs allowable per the grant. The total amount, $1,013, paid without adequate supporting documentation was considered questioned costs. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: INDIANA STATE BOARD OF ACCOUNTS 23 CANNELTON CITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.334 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 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. . . . (g) Be adequately documented. . . ." 7 CFR 210.14(a) states in part: ". . . Revenues received by the nonprofit school food service are to be used only for the operation or improvement of such food service, except that, such revenues shall not be used to purchase land or buildings, unless otherwise approved by FNS, or to construct buildings. . . ." 7 CFR 220.7(e)(1)(ii) states in part: ". . . use all revenues received by such food service only for the operation or improvement of that food service . . ." Cause Management of the School Corporation had not taken steps to design and implement policies and procedures to assess risks facing the School Corporation or to establish and operate monitoring activities that monitor the internal control system. Additionally, the School Corporation did not follow proper recordkeeping procedures. The Treasurer paid claims from federal program funds with no support or based on summary statements. INDIANA STATE BOARD OF ACCOUNTS 24 CANNELTON CITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Effect As a result of the five components of internal control not being adequately designed and implemented, the internal control system cannot be effective. Thus, general risks or specific risks from fraud and significant changes could negatively impact the School Corporation, identified internal control deficiencies could continue, and unidentified flaws within the internal control system could exist. Additionally, we could not determine if federal program funds were used to pay only for the operation or improvement of the food service. Furthermore, the lack of detailed documentation was not in compliance with the cost principles. Continued payment with no support or only summary statements could lead to payments for unallowable activities and additional questioned costs. Questioned Costs Questioned costs in the amount of $1,013 were identified as noted in the Condition and Context. Recommendation We recommended that the School Corporation's management establish a proper system of internal controls, which would include policies and procedures related to risk assessment and monitoring. Additionally, we recommended that the School Corporation's management establish a proper system of internal controls to ensure expenditures made from federal awards have appropriate supporting documentation to ensure expenditures are allowable per the terms and conditions of the federal award and adhere to the cost principles. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-004 Subject: Child Nutrition Cluster - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Special Milk Program for Children Assistance Listings Numbers: 10.553, 10.555, 10.556 Federal Award Numbers and Years (or Other Identifying Numbers): FY2023, FY2024 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Activities Allowed and Unallowed, Allowable Costs/Cost Principles Audit Findings: Material Weakness, Other Matters Condition and Context Internal control is generally defined as a process affected by an entity's oversight body, management, and other personnel that provides reasonable assurance that the objectives of an entity will be achieved. With respect to federal awards, nonfederal entities, such as the School Corporation, are required to establish and maintain internal controls over federal awards that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and terms and conditions of the federal awards. INDIANA STATE BOARD OF ACCOUNTS 22 CANNELTON CITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Internal control is not one event or circumstance, but a dynamic and iterative process. The internal control process is based on fundamental principles that operate as a whole but are best understood when analyzed individually. The fundamental principles are related to five components of internal control which are as follows: Control Environment, Risk Assessment, Control Activities, Information and Communication, and Monitoring. If a component is not effective, or the components are not operating together in an integrated manner, then an internal control system cannot be effective. Deficiencies as noted below were identified in the risk assessment, monitoring, and control activities components. Risk Assessment The School Corporation has not established a formal risk assessment process. There is no documented risk assessment policy, nor is there evidence of periodic risk identification, analysis, or evaluation. Monitoring The School Corporation did not conduct ongoing or periodic reviews to ensure that internal controls were operating as intended and to identify areas for improvement. Furthermore, the School Corporation did not have a process to follow up on corrective actions written as a response to audit findings. Control Activities A sample of 60 claims was selected for testing. Of the 60 claims selected for testing, 43 claims were vendor claims and 17 were payroll claims. Issues were identified with 5 of the vendor claims as noted below: Three claims, totaling $700, were paid based solely upon summary statements from the vendor. The School Corporation was unable to provide additional documentation, such as invoices, to detail what items or services had been purchased. Without adequate supporting documentation, we could not determine if the expenses incurred were for activities and costs allowable per the grant. Two claims, totaling $313, were paid with no supporting documentation. The School Corporation was unable to provide additional documentation, such as invoices, to detail what items or services had been purchased. Without adequate supporting documentation, we could not determine if the expenses incurred were for activities and costs allowable per the grant. The total amount, $1,013, paid without adequate supporting documentation was considered questioned costs. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: INDIANA STATE BOARD OF ACCOUNTS 23 CANNELTON CITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.334 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 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. . . . (g) Be adequately documented. . . ." 7 CFR 210.14(a) states in part: ". . . Revenues received by the nonprofit school food service are to be used only for the operation or improvement of such food service, except that, such revenues shall not be used to purchase land or buildings, unless otherwise approved by FNS, or to construct buildings. . . ." 7 CFR 220.7(e)(1)(ii) states in part: ". . . use all revenues received by such food service only for the operation or improvement of that food service . . ." Cause Management of the School Corporation had not taken steps to design and implement policies and procedures to assess risks facing the School Corporation or to establish and operate monitoring activities that monitor the internal control system. Additionally, the School Corporation did not follow proper recordkeeping procedures. The Treasurer paid claims from federal program funds with no support or based on summary statements. INDIANA STATE BOARD OF ACCOUNTS 24 CANNELTON CITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Effect As a result of the five components of internal control not being adequately designed and implemented, the internal control system cannot be effective. Thus, general risks or specific risks from fraud and significant changes could negatively impact the School Corporation, identified internal control deficiencies could continue, and unidentified flaws within the internal control system could exist. Additionally, we could not determine if federal program funds were used to pay only for the operation or improvement of the food service. Furthermore, the lack of detailed documentation was not in compliance with the cost principles. Continued payment with no support or only summary statements could lead to payments for unallowable activities and additional questioned costs. Questioned Costs Questioned costs in the amount of $1,013 were identified as noted in the Condition and Context. Recommendation We recommended that the School Corporation's management establish a proper system of internal controls, which would include policies and procedures related to risk assessment and monitoring. Additionally, we recommended that the School Corporation's management establish a proper system of internal controls to ensure expenditures made from federal awards have appropriate supporting documentation to ensure expenditures are allowable per the terms and conditions of the federal award and adhere to the cost principles. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-004 Subject: Child Nutrition Cluster - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Special Milk Program for Children Assistance Listings Numbers: 10.553, 10.555, 10.556 Federal Award Numbers and Years (or Other Identifying Numbers): FY2023, FY2024 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Activities Allowed and Unallowed, Allowable Costs/Cost Principles Audit Findings: Material Weakness, Other Matters Condition and Context Internal control is generally defined as a process affected by an entity's oversight body, management, and other personnel that provides reasonable assurance that the objectives of an entity will be achieved. With respect to federal awards, nonfederal entities, such as the School Corporation, are required to establish and maintain internal controls over federal awards that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and terms and conditions of the federal awards. INDIANA STATE BOARD OF ACCOUNTS 22 CANNELTON CITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Internal control is not one event or circumstance, but a dynamic and iterative process. The internal control process is based on fundamental principles that operate as a whole but are best understood when analyzed individually. The fundamental principles are related to five components of internal control which are as follows: Control Environment, Risk Assessment, Control Activities, Information and Communication, and Monitoring. If a component is not effective, or the components are not operating together in an integrated manner, then an internal control system cannot be effective. Deficiencies as noted below were identified in the risk assessment, monitoring, and control activities components. Risk Assessment The School Corporation has not established a formal risk assessment process. There is no documented risk assessment policy, nor is there evidence of periodic risk identification, analysis, or evaluation. Monitoring The School Corporation did not conduct ongoing or periodic reviews to ensure that internal controls were operating as intended and to identify areas for improvement. Furthermore, the School Corporation did not have a process to follow up on corrective actions written as a response to audit findings. Control Activities A sample of 60 claims was selected for testing. Of the 60 claims selected for testing, 43 claims were vendor claims and 17 were payroll claims. Issues were identified with 5 of the vendor claims as noted below: Three claims, totaling $700, were paid based solely upon summary statements from the vendor. The School Corporation was unable to provide additional documentation, such as invoices, to detail what items or services had been purchased. Without adequate supporting documentation, we could not determine if the expenses incurred were for activities and costs allowable per the grant. Two claims, totaling $313, were paid with no supporting documentation. The School Corporation was unable to provide additional documentation, such as invoices, to detail what items or services had been purchased. Without adequate supporting documentation, we could not determine if the expenses incurred were for activities and costs allowable per the grant. The total amount, $1,013, paid without adequate supporting documentation was considered questioned costs. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: INDIANA STATE BOARD OF ACCOUNTS 23 CANNELTON CITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.334 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 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. . . . (g) Be adequately documented. . . ." 7 CFR 210.14(a) states in part: ". . . Revenues received by the nonprofit school food service are to be used only for the operation or improvement of such food service, except that, such revenues shall not be used to purchase land or buildings, unless otherwise approved by FNS, or to construct buildings. . . ." 7 CFR 220.7(e)(1)(ii) states in part: ". . . use all revenues received by such food service only for the operation or improvement of that food service . . ." Cause Management of the School Corporation had not taken steps to design and implement policies and procedures to assess risks facing the School Corporation or to establish and operate monitoring activities that monitor the internal control system. Additionally, the School Corporation did not follow proper recordkeeping procedures. The Treasurer paid claims from federal program funds with no support or based on summary statements. INDIANA STATE BOARD OF ACCOUNTS 24 CANNELTON CITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Effect As a result of the five components of internal control not being adequately designed and implemented, the internal control system cannot be effective. Thus, general risks or specific risks from fraud and significant changes could negatively impact the School Corporation, identified internal control deficiencies could continue, and unidentified flaws within the internal control system could exist. Additionally, we could not determine if federal program funds were used to pay only for the operation or improvement of the food service. Furthermore, the lack of detailed documentation was not in compliance with the cost principles. Continued payment with no support or only summary statements could lead to payments for unallowable activities and additional questioned costs. Questioned Costs Questioned costs in the amount of $1,013 were identified as noted in the Condition and Context. Recommendation We recommended that the School Corporation's management establish a proper system of internal controls, which would include policies and procedures related to risk assessment and monitoring. Additionally, we recommended that the School Corporation's management establish a proper system of internal controls to ensure expenditures made from federal awards have appropriate supporting documentation to ensure expenditures are allowable per the terms and conditions of the federal award and adhere to the cost principles. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-004 Subject: Child Nutrition Cluster - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Special Milk Program for Children Assistance Listings Numbers: 10.553, 10.555, 10.556 Federal Award Numbers and Years (or Other Identifying Numbers): FY2023, FY2024 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Activities Allowed and Unallowed, Allowable Costs/Cost Principles Audit Findings: Material Weakness, Other Matters Condition and Context Internal control is generally defined as a process affected by an entity's oversight body, management, and other personnel that provides reasonable assurance that the objectives of an entity will be achieved. With respect to federal awards, nonfederal entities, such as the School Corporation, are required to establish and maintain internal controls over federal awards that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and terms and conditions of the federal awards. INDIANA STATE BOARD OF ACCOUNTS 22 CANNELTON CITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Internal control is not one event or circumstance, but a dynamic and iterative process. The internal control process is based on fundamental principles that operate as a whole but are best understood when analyzed individually. The fundamental principles are related to five components of internal control which are as follows: Control Environment, Risk Assessment, Control Activities, Information and Communication, and Monitoring. If a component is not effective, or the components are not operating together in an integrated manner, then an internal control system cannot be effective. Deficiencies as noted below were identified in the risk assessment, monitoring, and control activities components. Risk Assessment The School Corporation has not established a formal risk assessment process. There is no documented risk assessment policy, nor is there evidence of periodic risk identification, analysis, or evaluation. Monitoring The School Corporation did not conduct ongoing or periodic reviews to ensure that internal controls were operating as intended and to identify areas for improvement. Furthermore, the School Corporation did not have a process to follow up on corrective actions written as a response to audit findings. Control Activities A sample of 60 claims was selected for testing. Of the 60 claims selected for testing, 43 claims were vendor claims and 17 were payroll claims. Issues were identified with 5 of the vendor claims as noted below: Three claims, totaling $700, were paid based solely upon summary statements from the vendor. The School Corporation was unable to provide additional documentation, such as invoices, to detail what items or services had been purchased. Without adequate supporting documentation, we could not determine if the expenses incurred were for activities and costs allowable per the grant. Two claims, totaling $313, were paid with no supporting documentation. The School Corporation was unable to provide additional documentation, such as invoices, to detail what items or services had been purchased. Without adequate supporting documentation, we could not determine if the expenses incurred were for activities and costs allowable per the grant. The total amount, $1,013, paid without adequate supporting documentation was considered questioned costs. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: INDIANA STATE BOARD OF ACCOUNTS 23 CANNELTON CITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.334 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 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. . . . (g) Be adequately documented. . . ." 7 CFR 210.14(a) states in part: ". . . Revenues received by the nonprofit school food service are to be used only for the operation or improvement of such food service, except that, such revenues shall not be used to purchase land or buildings, unless otherwise approved by FNS, or to construct buildings. . . ." 7 CFR 220.7(e)(1)(ii) states in part: ". . . use all revenues received by such food service only for the operation or improvement of that food service . . ." Cause Management of the School Corporation had not taken steps to design and implement policies and procedures to assess risks facing the School Corporation or to establish and operate monitoring activities that monitor the internal control system. Additionally, the School Corporation did not follow proper recordkeeping procedures. The Treasurer paid claims from federal program funds with no support or based on summary statements. INDIANA STATE BOARD OF ACCOUNTS 24 CANNELTON CITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Effect As a result of the five components of internal control not being adequately designed and implemented, the internal control system cannot be effective. Thus, general risks or specific risks from fraud and significant changes could negatively impact the School Corporation, identified internal control deficiencies could continue, and unidentified flaws within the internal control system could exist. Additionally, we could not determine if federal program funds were used to pay only for the operation or improvement of the food service. Furthermore, the lack of detailed documentation was not in compliance with the cost principles. Continued payment with no support or only summary statements could lead to payments for unallowable activities and additional questioned costs. Questioned Costs Questioned costs in the amount of $1,013 were identified as noted in the Condition and Context. Recommendation We recommended that the School Corporation's management establish a proper system of internal controls, which would include policies and procedures related to risk assessment and monitoring. Additionally, we recommended that the School Corporation's management establish a proper system of internal controls to ensure expenditures made from federal awards have appropriate supporting documentation to ensure expenditures are allowable per the terms and conditions of the federal award and adhere to the cost principles. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Significant Deficiency Other Noncompliance Program: Assistance Listing: 10.553/10.555 – Child Nutrition Cluster Assistance Listing 84.010A - Title I Grants To Local Educational Agencies Assistance Listing: 84.027/84.027X/84.173/84.173X – Special Education Cluster (IDEA) Assistance Listing: 84.425D – Elementary and Secondary School Emergency Relief Fund (ESSER II) Assistance Listing: 84.425U – Elementary and Secondary School Emergency Relief Fund (ARP ESSER) Repeat Finding: Yes Criteria: 2 CFR 200.303 requires that a non-federal entity must establish and maintain effective internal control over a federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and the terms and conditions of the federal award. 2 CFR 200.334 requires subrecipients to retain all Federal award records for three years from the date of submission of their final financial report. For awards that are renewed quarterly or annually, the recipient and subrecipient must retain records for three years from the date of submission of their quarterly or annual financial report, respectively. Records to be retained include but are not limited to financial records, supporting documentation, and statistical records. Federal agencies or pass-through entities may not impose any other record retention requirements except records must be retained until all litigation, claims, or audit findings involving the records have been resolved and final action taken if any litigation, claim, or audit is started before the expiration of the three-year period. Condition: As part of our statistically valid random sample of sixty non-payroll disbursements from the District’s grant expenditures from major programs, we observed the following instances where information required to ensure that these expenditures fulfilled requirements of 2 CFR Part 200 as follows was not obtained by the District or was otherwise unavailable for our examination: Sixteen instances where there was no documentation to determine the District obtained the required information to ensure that the vendor was not suspended or debarred. One instance where there was no invoice or credit memo to support the transaction. Numerous instances where an invoice was not included in the paid invoice. These invoices were made available to us for our examination on our fourth request Context/ Perspective: This finding is based on our statistically valid random sample of sixty non-payroll cash disbursements charged to major programs of the District. Effect: Failure to follow the federal and state requirements could affect future eligibility for federal award programs or could result in a loss or misappropriation of public assets. Questioned Costs: None Recommendation: We recommend that the District implement additional internal controls as necessary to ensure that proper records are maintained to adequately document its expenditures charged to federal grant programs. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.
Significant Deficiency Other Noncompliance Program: Assistance Listing: 10.553/10.555 – Child Nutrition Cluster Assistance Listing 84.010A - Title I Grants To Local Educational Agencies Assistance Listing: 84.027/84.027X/84.173/84.173X – Special Education Cluster (IDEA) Assistance Listing: 84.425D – Elementary and Secondary School Emergency Relief Fund (ESSER II) Assistance Listing: 84.425U – Elementary and Secondary School Emergency Relief Fund (ARP ESSER) Repeat Finding: Yes Criteria: 2 CFR 200.303 requires that a non-federal entity must establish and maintain effective internal control over a federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and the terms and conditions of the federal award. 2 CFR 200.334 requires subrecipients to retain all Federal award records for three years from the date of submission of their final financial report. For awards that are renewed quarterly or annually, the recipient and subrecipient must retain records for three years from the date of submission of their quarterly or annual financial report, respectively. Records to be retained include but are not limited to financial records, supporting documentation, and statistical records. Federal agencies or pass-through entities may not impose any other record retention requirements except records must be retained until all litigation, claims, or audit findings involving the records have been resolved and final action taken if any litigation, claim, or audit is started before the expiration of the three-year period. Condition: As part of our statistically valid random sample of sixty non-payroll disbursements from the District’s grant expenditures from major programs, we observed the following instances where information required to ensure that these expenditures fulfilled requirements of 2 CFR Part 200 as follows was not obtained by the District or was otherwise unavailable for our examination: Sixteen instances where there was no documentation to determine the District obtained the required information to ensure that the vendor was not suspended or debarred. One instance where there was no invoice or credit memo to support the transaction. Numerous instances where an invoice was not included in the paid invoice. These invoices were made available to us for our examination on our fourth request Context/ Perspective: This finding is based on our statistically valid random sample of sixty non-payroll cash disbursements charged to major programs of the District. Effect: Failure to follow the federal and state requirements could affect future eligibility for federal award programs or could result in a loss or misappropriation of public assets. Questioned Costs: None Recommendation: We recommend that the District implement additional internal controls as necessary to ensure that proper records are maintained to adequately document its expenditures charged to federal grant programs. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.
Significant Deficiency Other Noncompliance Program: Assistance Listing: 10.553/10.555 – Child Nutrition Cluster Assistance Listing 84.010A - Title I Grants To Local Educational Agencies Assistance Listing: 84.027/84.027X/84.173/84.173X – Special Education Cluster (IDEA) Assistance Listing: 84.425D – Elementary and Secondary School Emergency Relief Fund (ESSER II) Assistance Listing: 84.425U – Elementary and Secondary School Emergency Relief Fund (ARP ESSER) Repeat Finding: Yes Criteria: 2 CFR 200.303 requires that a non-federal entity must establish and maintain effective internal control over a federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and the terms and conditions of the federal award. 2 CFR 200.334 requires subrecipients to retain all Federal award records for three years from the date of submission of their final financial report. For awards that are renewed quarterly or annually, the recipient and subrecipient must retain records for three years from the date of submission of their quarterly or annual financial report, respectively. Records to be retained include but are not limited to financial records, supporting documentation, and statistical records. Federal agencies or pass-through entities may not impose any other record retention requirements except records must be retained until all litigation, claims, or audit findings involving the records have been resolved and final action taken if any litigation, claim, or audit is started before the expiration of the three-year period. Condition: As part of our statistically valid random sample of sixty non-payroll disbursements from the District’s grant expenditures from major programs, we observed the following instances where information required to ensure that these expenditures fulfilled requirements of 2 CFR Part 200 as follows was not obtained by the District or was otherwise unavailable for our examination: Sixteen instances where there was no documentation to determine the District obtained the required information to ensure that the vendor was not suspended or debarred. One instance where there was no invoice or credit memo to support the transaction. Numerous instances where an invoice was not included in the paid invoice. These invoices were made available to us for our examination on our fourth request Context/ Perspective: This finding is based on our statistically valid random sample of sixty non-payroll cash disbursements charged to major programs of the District. Effect: Failure to follow the federal and state requirements could affect future eligibility for federal award programs or could result in a loss or misappropriation of public assets. Questioned Costs: None Recommendation: We recommend that the District implement additional internal controls as necessary to ensure that proper records are maintained to adequately document its expenditures charged to federal grant programs. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.
Significant Deficiency Other Noncompliance Program: Assistance Listing: 10.553/10.555 – Child Nutrition Cluster Assistance Listing 84.010A - Title I Grants To Local Educational Agencies Assistance Listing: 84.027/84.027X/84.173/84.173X – Special Education Cluster (IDEA) Assistance Listing: 84.425D – Elementary and Secondary School Emergency Relief Fund (ESSER II) Assistance Listing: 84.425U – Elementary and Secondary School Emergency Relief Fund (ARP ESSER) Repeat Finding: Yes Criteria: 2 CFR 200.303 requires that a non-federal entity must establish and maintain effective internal control over a federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and the terms and conditions of the federal award. 2 CFR 200.334 requires subrecipients to retain all Federal award records for three years from the date of submission of their final financial report. For awards that are renewed quarterly or annually, the recipient and subrecipient must retain records for three years from the date of submission of their quarterly or annual financial report, respectively. Records to be retained include but are not limited to financial records, supporting documentation, and statistical records. Federal agencies or pass-through entities may not impose any other record retention requirements except records must be retained until all litigation, claims, or audit findings involving the records have been resolved and final action taken if any litigation, claim, or audit is started before the expiration of the three-year period. Condition: As part of our statistically valid random sample of sixty non-payroll disbursements from the District’s grant expenditures from major programs, we observed the following instances where information required to ensure that these expenditures fulfilled requirements of 2 CFR Part 200 as follows was not obtained by the District or was otherwise unavailable for our examination: Sixteen instances where there was no documentation to determine the District obtained the required information to ensure that the vendor was not suspended or debarred. One instance where there was no invoice or credit memo to support the transaction. Numerous instances where an invoice was not included in the paid invoice. These invoices were made available to us for our examination on our fourth request Context/ Perspective: This finding is based on our statistically valid random sample of sixty non-payroll cash disbursements charged to major programs of the District. Effect: Failure to follow the federal and state requirements could affect future eligibility for federal award programs or could result in a loss or misappropriation of public assets. Questioned Costs: None Recommendation: We recommend that the District implement additional internal controls as necessary to ensure that proper records are maintained to adequately document its expenditures charged to federal grant programs. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.
Significant Deficiency Other Noncompliance Program: Assistance Listing: 10.553/10.555 – Child Nutrition Cluster Assistance Listing 84.010A - Title I Grants To Local Educational Agencies Assistance Listing: 84.027/84.027X/84.173/84.173X – Special Education Cluster (IDEA) Assistance Listing: 84.425D – Elementary and Secondary School Emergency Relief Fund (ESSER II) Assistance Listing: 84.425U – Elementary and Secondary School Emergency Relief Fund (ARP ESSER) Repeat Finding: Yes Criteria: 2 CFR 200.303 requires that a non-federal entity must establish and maintain effective internal control over a federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and the terms and conditions of the federal award. 2 CFR 200.334 requires subrecipients to retain all Federal award records for three years from the date of submission of their final financial report. For awards that are renewed quarterly or annually, the recipient and subrecipient must retain records for three years from the date of submission of their quarterly or annual financial report, respectively. Records to be retained include but are not limited to financial records, supporting documentation, and statistical records. Federal agencies or pass-through entities may not impose any other record retention requirements except records must be retained until all litigation, claims, or audit findings involving the records have been resolved and final action taken if any litigation, claim, or audit is started before the expiration of the three-year period. Condition: As part of our statistically valid random sample of sixty non-payroll disbursements from the District’s grant expenditures from major programs, we observed the following instances where information required to ensure that these expenditures fulfilled requirements of 2 CFR Part 200 as follows was not obtained by the District or was otherwise unavailable for our examination: Sixteen instances where there was no documentation to determine the District obtained the required information to ensure that the vendor was not suspended or debarred. One instance where there was no invoice or credit memo to support the transaction. Numerous instances where an invoice was not included in the paid invoice. These invoices were made available to us for our examination on our fourth request Context/ Perspective: This finding is based on our statistically valid random sample of sixty non-payroll cash disbursements charged to major programs of the District. Effect: Failure to follow the federal and state requirements could affect future eligibility for federal award programs or could result in a loss or misappropriation of public assets. Questioned Costs: None Recommendation: We recommend that the District implement additional internal controls as necessary to ensure that proper records are maintained to adequately document its expenditures charged to federal grant programs. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.
Significant Deficiency Other Noncompliance Program: Assistance Listing: 10.553/10.555 – Child Nutrition Cluster Assistance Listing 84.010A - Title I Grants To Local Educational Agencies Assistance Listing: 84.027/84.027X/84.173/84.173X – Special Education Cluster (IDEA) Assistance Listing: 84.425D – Elementary and Secondary School Emergency Relief Fund (ESSER II) Assistance Listing: 84.425U – Elementary and Secondary School Emergency Relief Fund (ARP ESSER) Repeat Finding: Yes Criteria: 2 CFR 200.303 requires that a non-federal entity must establish and maintain effective internal control over a federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and the terms and conditions of the federal award. 2 CFR 200.334 requires subrecipients to retain all Federal award records for three years from the date of submission of their final financial report. For awards that are renewed quarterly or annually, the recipient and subrecipient must retain records for three years from the date of submission of their quarterly or annual financial report, respectively. Records to be retained include but are not limited to financial records, supporting documentation, and statistical records. Federal agencies or pass-through entities may not impose any other record retention requirements except records must be retained until all litigation, claims, or audit findings involving the records have been resolved and final action taken if any litigation, claim, or audit is started before the expiration of the three-year period. Condition: As part of our statistically valid random sample of sixty non-payroll disbursements from the District’s grant expenditures from major programs, we observed the following instances where information required to ensure that these expenditures fulfilled requirements of 2 CFR Part 200 as follows was not obtained by the District or was otherwise unavailable for our examination: Sixteen instances where there was no documentation to determine the District obtained the required information to ensure that the vendor was not suspended or debarred. One instance where there was no invoice or credit memo to support the transaction. Numerous instances where an invoice was not included in the paid invoice. These invoices were made available to us for our examination on our fourth request Context/ Perspective: This finding is based on our statistically valid random sample of sixty non-payroll cash disbursements charged to major programs of the District. Effect: Failure to follow the federal and state requirements could affect future eligibility for federal award programs or could result in a loss or misappropriation of public assets. Questioned Costs: None Recommendation: We recommend that the District implement additional internal controls as necessary to ensure that proper records are maintained to adequately document its expenditures charged to federal grant programs. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.
Significant Deficiency Other Noncompliance Program: Assistance Listing: 10.553/10.555 – Child Nutrition Cluster Assistance Listing 84.010A - Title I Grants To Local Educational Agencies Assistance Listing: 84.027/84.027X/84.173/84.173X – Special Education Cluster (IDEA) Assistance Listing: 84.425D – Elementary and Secondary School Emergency Relief Fund (ESSER II) Assistance Listing: 84.425U – Elementary and Secondary School Emergency Relief Fund (ARP ESSER) Repeat Finding: Yes Criteria: 2 CFR 200.303 requires that a non-federal entity must establish and maintain effective internal control over a federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and the terms and conditions of the federal award. 2 CFR 200.334 requires subrecipients to retain all Federal award records for three years from the date of submission of their final financial report. For awards that are renewed quarterly or annually, the recipient and subrecipient must retain records for three years from the date of submission of their quarterly or annual financial report, respectively. Records to be retained include but are not limited to financial records, supporting documentation, and statistical records. Federal agencies or pass-through entities may not impose any other record retention requirements except records must be retained until all litigation, claims, or audit findings involving the records have been resolved and final action taken if any litigation, claim, or audit is started before the expiration of the three-year period. Condition: As part of our statistically valid random sample of sixty non-payroll disbursements from the District’s grant expenditures from major programs, we observed the following instances where information required to ensure that these expenditures fulfilled requirements of 2 CFR Part 200 as follows was not obtained by the District or was otherwise unavailable for our examination: Sixteen instances where there was no documentation to determine the District obtained the required information to ensure that the vendor was not suspended or debarred. One instance where there was no invoice or credit memo to support the transaction. Numerous instances where an invoice was not included in the paid invoice. These invoices were made available to us for our examination on our fourth request Context/ Perspective: This finding is based on our statistically valid random sample of sixty non-payroll cash disbursements charged to major programs of the District. Effect: Failure to follow the federal and state requirements could affect future eligibility for federal award programs or could result in a loss or misappropriation of public assets. Questioned Costs: None Recommendation: We recommend that the District implement additional internal controls as necessary to ensure that proper records are maintained to adequately document its expenditures charged to federal grant programs. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.
Significant Deficiency Other Noncompliance Program: Assistance Listing: 10.553/10.555 – Child Nutrition Cluster Assistance Listing 84.010A - Title I Grants To Local Educational Agencies Assistance Listing: 84.027/84.027X/84.173/84.173X – Special Education Cluster (IDEA) Assistance Listing: 84.425D – Elementary and Secondary School Emergency Relief Fund (ESSER II) Assistance Listing: 84.425U – Elementary and Secondary School Emergency Relief Fund (ARP ESSER) Repeat Finding: Yes Criteria: 2 CFR 200.303 requires that a non-federal entity must establish and maintain effective internal control over a federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and the terms and conditions of the federal award. 2 CFR 200.334 requires subrecipients to retain all Federal award records for three years from the date of submission of their final financial report. For awards that are renewed quarterly or annually, the recipient and subrecipient must retain records for three years from the date of submission of their quarterly or annual financial report, respectively. Records to be retained include but are not limited to financial records, supporting documentation, and statistical records. Federal agencies or pass-through entities may not impose any other record retention requirements except records must be retained until all litigation, claims, or audit findings involving the records have been resolved and final action taken if any litigation, claim, or audit is started before the expiration of the three-year period. Condition: As part of our statistically valid random sample of sixty non-payroll disbursements from the District’s grant expenditures from major programs, we observed the following instances where information required to ensure that these expenditures fulfilled requirements of 2 CFR Part 200 as follows was not obtained by the District or was otherwise unavailable for our examination: Sixteen instances where there was no documentation to determine the District obtained the required information to ensure that the vendor was not suspended or debarred. One instance where there was no invoice or credit memo to support the transaction. Numerous instances where an invoice was not included in the paid invoice. These invoices were made available to us for our examination on our fourth request Context/ Perspective: This finding is based on our statistically valid random sample of sixty non-payroll cash disbursements charged to major programs of the District. Effect: Failure to follow the federal and state requirements could affect future eligibility for federal award programs or could result in a loss or misappropriation of public assets. Questioned Costs: None Recommendation: We recommend that the District implement additional internal controls as necessary to ensure that proper records are maintained to adequately document its expenditures charged to federal grant programs. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.
Significant Deficiency Other Noncompliance Program: Assistance Listing: 10.553/10.555 – Child Nutrition Cluster Assistance Listing 84.010A - Title I Grants To Local Educational Agencies Assistance Listing: 84.027/84.027X/84.173/84.173X – Special Education Cluster (IDEA) Assistance Listing: 84.425D – Elementary and Secondary School Emergency Relief Fund (ESSER II) Assistance Listing: 84.425U – Elementary and Secondary School Emergency Relief Fund (ARP ESSER) Repeat Finding: Yes Criteria: 2 CFR 200.303 requires that a non-federal entity must establish and maintain effective internal control over a federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and the terms and conditions of the federal award. 2 CFR 200.334 requires subrecipients to retain all Federal award records for three years from the date of submission of their final financial report. For awards that are renewed quarterly or annually, the recipient and subrecipient must retain records for three years from the date of submission of their quarterly or annual financial report, respectively. Records to be retained include but are not limited to financial records, supporting documentation, and statistical records. Federal agencies or pass-through entities may not impose any other record retention requirements except records must be retained until all litigation, claims, or audit findings involving the records have been resolved and final action taken if any litigation, claim, or audit is started before the expiration of the three-year period. Condition: As part of our statistically valid random sample of sixty non-payroll disbursements from the District’s grant expenditures from major programs, we observed the following instances where information required to ensure that these expenditures fulfilled requirements of 2 CFR Part 200 as follows was not obtained by the District or was otherwise unavailable for our examination: Sixteen instances where there was no documentation to determine the District obtained the required information to ensure that the vendor was not suspended or debarred. One instance where there was no invoice or credit memo to support the transaction. Numerous instances where an invoice was not included in the paid invoice. These invoices were made available to us for our examination on our fourth request Context/ Perspective: This finding is based on our statistically valid random sample of sixty non-payroll cash disbursements charged to major programs of the District. Effect: Failure to follow the federal and state requirements could affect future eligibility for federal award programs or could result in a loss or misappropriation of public assets. Questioned Costs: None Recommendation: We recommend that the District implement additional internal controls as necessary to ensure that proper records are maintained to adequately document its expenditures charged to federal grant programs. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.
FINDING 2024-003 Subject: Title I Grants to Local Educational Agencies - Eligibility 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): S010A200014, S010A220014, S010A230014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Findings: Material Weakness, Other Matters Condition and Context The School Corporation did not have adequate procedures in place to ensure that the socioeconomic status of the students were reported properly in the Title I application. Although the grant application was prepared by the HR Coordinator and reviewed and approved by the Superintendent of Schools and Treasurer, the internal controls were not effective to ensure the students' socioeconomic status was accurately reported. Eligibility for Title I is determined on the Eligible School Summary of the Title I application. Enrollment and Poverty numbers are automatically pulled from the Indiana Department of Education's (IDOE) Official Pupil Enrollment (PE) count for each school into the Eligible School Summary page of the Title I application. The counts that are prepopulated should be based on the School Corporation's records as of October of the prior fiscal year. During the audit period, the School Corporation submitted two Title I applications. The School Corporation was required to use the October 2021 Real Time Report data for the 2022-2023 Title I application and the October 2022 Real Time Report data for the 2023-2024 Title I application submitted to the IDOE. Data to be submitted included student socioeconomic status information. The school lunch software was used to verify the socioeconomic status of students reported in the Title I application. A total of 25 students were selected for testing. The socioeconomic status for 3 of the 9 students tested from the October 2021 Real Time Report data did not agree to data reported in the 2022-2023 Title I application. The lack of internal controls and noncompliance were isolated to the October 2021 Real Time Report and 2022-2023 Title I application. INDIANA STATE BOARD OF ACCOUNTS 18 NORTH GIBSON SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for the Federal awards that are renewed quarterly or annual, from the date of submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 34 CFR 200.78(a)(1) states: "After reserving funds, as applicable, under § 200.77, including funds for equitable services for private school students, their teachers, and their families, an LEA must allocate funds under this subpart to school attendance areas and schools, identified as eligible and selected to participate under section 1113(a) or (b) of the ESEA, in rank order on the basis of the total number of public school children from low-income families in each area or school." Cause Although the School Corporation had properly designed and implemented a system of internal controls, which included appropriate segregation of duties, it was not effective in preventing, or detecting and correcting, noncompliance related to the Eligibility compliance requirement. The underlying information, reviewed and approved by the Superintendent of Schools and Treasurer, was not adequate to determine the socioeconomic status of the students. Effect Without a proper system of internal controls in place that operated effectively, the School Corporation did not maintain accurate supporting documentation to support the data in the Title I application. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. INDIANA STATE BOARD OF ACCOUNTS 19 NORTH GIBSON SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure that adequate documentation is maintained to support the information in the Title I application. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-005 Subject: COVID-19 - Education Stabilization Fund - Allowable Costs/Cost Principles and Activities Allowed or Unallowed Federal Agency: Indiana Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Allowable Costs/Cost Principles, Activities Allowed or Unallowed Audit Findings: Material Weakness, Modified Opinion Condition and Context The COVID-19 - Education Stabilization Fund (ESF), established by the Coronavirus Aid, Relief, and Economic Security (CARES) Act and further funded by the Coronavirus Response and Relief Supplemental Appropriations Act (CRSSA) and the American Rescue Plan (ARP) Act, was for the purpose of preventing, preparing for, or responding to the novel coronavirus. A sample of 40 vendor and payroll disbursements that were charged to the ESF grant for which reimbursement was received during the audit period was selected for testing to verify the expenditures were in conformance with the applicable allowable cost principles. Of the 40 disbursements tested, 4 payroll disbursements for accelerated learning were approved, but the School Corporation could not provide documentation to show where the governing board approved their rate of pay. In addition, there was a transfer from the ESSER II - Cares grant fund to the Education fund for $117,177 to reimburse that fund for expenses on June 20, 2024. The School Corporation was unable to provide documentation for the expenses that were reimbursed to ensure they were for allowable activities and allowable costs. The ineffective internal controls were a systemic issue 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 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. . . . (g) Be adequately documented. . . ." Cause Management had not developed a system of internal controls that would have ensured compliance with the Allowable Costs/Cost Principles and the Activities Allowed or Unallowed compliance requirements. Management was not aware that they should have only been reimbursed for expenditures made out of the ESF funds or should have moved the expenditures and retained proper documentation to support what expenditures tied to what was reimbursed. It was noted that the accelerated learning rate of pay was discussed at a School Board meeting, but the approved wage rates were not documented in the School Board minutes or on any sort of salary schedule approved by the School Board members. Effect The failure to design and implement an effective internal control system enabled noncompliance to go undetected. Noncompliance with the grant agreement and the Allowable Cost/Cost Principles and the Activities Allowed or Unallowed compliance requirements could result in the loss of future federal funds to the School Corporation. Questioned Costs There was a total of $173,841 of questioned costs as referenced under the Condition and Context. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure only allowable activities and allowable costs are charged to grants funds and to ensure grant money is only requested for reimbursement for monies directly related to the grant program. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-006 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Indiana Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2022-010. 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. Even though the reports were reviewed by someone other than the preparer, the School Corporation was not able to provide financial information that was used to determine amounts used in the reports. The School Corporation completed and submitted four annual Data Collection reports (Reports) for the Elementary and Secondary School Emergency Relief (ESSER) grants. For all four of the Reports, the School Corporation was unable to provide financial information to support the amounts in the Reports; therefore, the Indiana State Board of Accounts could not determine the accuracy of the Reports. Additionally, eight of eight key line items selected for testing could not be verified to the financial records. 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." 2 CFR 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for the Federal awards that are renewed quarterly or annual, from the date of submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 34 CFR 76.731 states: "A State and a subgrantee shall keep records to show its compliance with program requirements." Cause According to the School Corporation, these issues were due to the reporting differences of how the annual expenditure report categories are different than the annual Data Collection reports. The School Corporation indicated that it had to go employee by employee to properly place them under the correct category using the reimbursement requests but did not retain that documentation of how it came to the numbers. Effect The failure to design and implement an effective internal control system enabled noncompliance to go undetected with the Reporting compliance requirement. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish effective internal controls to ensure reports submitted are accurate and have supporting documentation. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-005 Subject: COVID-19 - Education Stabilization Fund - Allowable Costs/Cost Principles and Activities Allowed or Unallowed Federal Agency: Indiana Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Allowable Costs/Cost Principles, Activities Allowed or Unallowed Audit Findings: Material Weakness, Modified Opinion Condition and Context The COVID-19 - Education Stabilization Fund (ESF), established by the Coronavirus Aid, Relief, and Economic Security (CARES) Act and further funded by the Coronavirus Response and Relief Supplemental Appropriations Act (CRSSA) and the American Rescue Plan (ARP) Act, was for the purpose of preventing, preparing for, or responding to the novel coronavirus. A sample of 40 vendor and payroll disbursements that were charged to the ESF grant for which reimbursement was received during the audit period was selected for testing to verify the expenditures were in conformance with the applicable allowable cost principles. Of the 40 disbursements tested, 4 payroll disbursements for accelerated learning were approved, but the School Corporation could not provide documentation to show where the governing board approved their rate of pay. In addition, there was a transfer from the ESSER II - Cares grant fund to the Education fund for $117,177 to reimburse that fund for expenses on June 20, 2024. The School Corporation was unable to provide documentation for the expenses that were reimbursed to ensure they were for allowable activities and allowable costs. The ineffective internal controls were a systemic issue 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 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. . . . (g) Be adequately documented. . . ." Cause Management had not developed a system of internal controls that would have ensured compliance with the Allowable Costs/Cost Principles and the Activities Allowed or Unallowed compliance requirements. Management was not aware that they should have only been reimbursed for expenditures made out of the ESF funds or should have moved the expenditures and retained proper documentation to support what expenditures tied to what was reimbursed. It was noted that the accelerated learning rate of pay was discussed at a School Board meeting, but the approved wage rates were not documented in the School Board minutes or on any sort of salary schedule approved by the School Board members. Effect The failure to design and implement an effective internal control system enabled noncompliance to go undetected. Noncompliance with the grant agreement and the Allowable Cost/Cost Principles and the Activities Allowed or Unallowed compliance requirements could result in the loss of future federal funds to the School Corporation. Questioned Costs There was a total of $173,841 of questioned costs as referenced under the Condition and Context. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure only allowable activities and allowable costs are charged to grants funds and to ensure grant money is only requested for reimbursement for monies directly related to the grant program. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-006 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Indiana Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2022-010. 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. Even though the reports were reviewed by someone other than the preparer, the School Corporation was not able to provide financial information that was used to determine amounts used in the reports. The School Corporation completed and submitted four annual Data Collection reports (Reports) for the Elementary and Secondary School Emergency Relief (ESSER) grants. For all four of the Reports, the School Corporation was unable to provide financial information to support the amounts in the Reports; therefore, the Indiana State Board of Accounts could not determine the accuracy of the Reports. Additionally, eight of eight key line items selected for testing could not be verified to the financial records. 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." 2 CFR 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for the Federal awards that are renewed quarterly or annual, from the date of submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 34 CFR 76.731 states: "A State and a subgrantee shall keep records to show its compliance with program requirements." Cause According to the School Corporation, these issues were due to the reporting differences of how the annual expenditure report categories are different than the annual Data Collection reports. The School Corporation indicated that it had to go employee by employee to properly place them under the correct category using the reimbursement requests but did not retain that documentation of how it came to the numbers. Effect The failure to design and implement an effective internal control system enabled noncompliance to go undetected with the Reporting compliance requirement. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish effective internal controls to ensure reports submitted are accurate and have supporting documentation. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-005 Subject: COVID-19 - Education Stabilization Fund - Allowable Costs/Cost Principles and Activities Allowed or Unallowed Federal Agency: Indiana Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Allowable Costs/Cost Principles, Activities Allowed or Unallowed Audit Findings: Material Weakness, Modified Opinion Condition and Context The COVID-19 - Education Stabilization Fund (ESF), established by the Coronavirus Aid, Relief, and Economic Security (CARES) Act and further funded by the Coronavirus Response and Relief Supplemental Appropriations Act (CRSSA) and the American Rescue Plan (ARP) Act, was for the purpose of preventing, preparing for, or responding to the novel coronavirus. A sample of 40 vendor and payroll disbursements that were charged to the ESF grant for which reimbursement was received during the audit period was selected for testing to verify the expenditures were in conformance with the applicable allowable cost principles. Of the 40 disbursements tested, 4 payroll disbursements for accelerated learning were approved, but the School Corporation could not provide documentation to show where the governing board approved their rate of pay. In addition, there was a transfer from the ESSER II - Cares grant fund to the Education fund for $117,177 to reimburse that fund for expenses on June 20, 2024. The School Corporation was unable to provide documentation for the expenses that were reimbursed to ensure they were for allowable activities and allowable costs. The ineffective internal controls were a systemic issue 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 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. . . . (g) Be adequately documented. . . ." Cause Management had not developed a system of internal controls that would have ensured compliance with the Allowable Costs/Cost Principles and the Activities Allowed or Unallowed compliance requirements. Management was not aware that they should have only been reimbursed for expenditures made out of the ESF funds or should have moved the expenditures and retained proper documentation to support what expenditures tied to what was reimbursed. It was noted that the accelerated learning rate of pay was discussed at a School Board meeting, but the approved wage rates were not documented in the School Board minutes or on any sort of salary schedule approved by the School Board members. Effect The failure to design and implement an effective internal control system enabled noncompliance to go undetected. Noncompliance with the grant agreement and the Allowable Cost/Cost Principles and the Activities Allowed or Unallowed compliance requirements could result in the loss of future federal funds to the School Corporation. Questioned Costs There was a total of $173,841 of questioned costs as referenced under the Condition and Context. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure only allowable activities and allowable costs are charged to grants funds and to ensure grant money is only requested for reimbursement for monies directly related to the grant program. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-006 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Indiana Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2022-010. 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. Even though the reports were reviewed by someone other than the preparer, the School Corporation was not able to provide financial information that was used to determine amounts used in the reports. The School Corporation completed and submitted four annual Data Collection reports (Reports) for the Elementary and Secondary School Emergency Relief (ESSER) grants. For all four of the Reports, the School Corporation was unable to provide financial information to support the amounts in the Reports; therefore, the Indiana State Board of Accounts could not determine the accuracy of the Reports. Additionally, eight of eight key line items selected for testing could not be verified to the financial records. 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." 2 CFR 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for the Federal awards that are renewed quarterly or annual, from the date of submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 34 CFR 76.731 states: "A State and a subgrantee shall keep records to show its compliance with program requirements." Cause According to the School Corporation, these issues were due to the reporting differences of how the annual expenditure report categories are different than the annual Data Collection reports. The School Corporation indicated that it had to go employee by employee to properly place them under the correct category using the reimbursement requests but did not retain that documentation of how it came to the numbers. Effect The failure to design and implement an effective internal control system enabled noncompliance to go undetected with the Reporting compliance requirement. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish effective internal controls to ensure reports submitted are accurate and have supporting documentation. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-005 Subject: COVID-19 - Education Stabilization Fund - Allowable Costs/Cost Principles and Activities Allowed or Unallowed Federal Agency: Indiana Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Allowable Costs/Cost Principles, Activities Allowed or Unallowed Audit Findings: Material Weakness, Modified Opinion Condition and Context The COVID-19 - Education Stabilization Fund (ESF), established by the Coronavirus Aid, Relief, and Economic Security (CARES) Act and further funded by the Coronavirus Response and Relief Supplemental Appropriations Act (CRSSA) and the American Rescue Plan (ARP) Act, was for the purpose of preventing, preparing for, or responding to the novel coronavirus. A sample of 40 vendor and payroll disbursements that were charged to the ESF grant for which reimbursement was received during the audit period was selected for testing to verify the expenditures were in conformance with the applicable allowable cost principles. Of the 40 disbursements tested, 4 payroll disbursements for accelerated learning were approved, but the School Corporation could not provide documentation to show where the governing board approved their rate of pay. In addition, there was a transfer from the ESSER II - Cares grant fund to the Education fund for $117,177 to reimburse that fund for expenses on June 20, 2024. The School Corporation was unable to provide documentation for the expenses that were reimbursed to ensure they were for allowable activities and allowable costs. The ineffective internal controls were a systemic issue 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 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. . . . (g) Be adequately documented. . . ." Cause Management had not developed a system of internal controls that would have ensured compliance with the Allowable Costs/Cost Principles and the Activities Allowed or Unallowed compliance requirements. Management was not aware that they should have only been reimbursed for expenditures made out of the ESF funds or should have moved the expenditures and retained proper documentation to support what expenditures tied to what was reimbursed. It was noted that the accelerated learning rate of pay was discussed at a School Board meeting, but the approved wage rates were not documented in the School Board minutes or on any sort of salary schedule approved by the School Board members. Effect The failure to design and implement an effective internal control system enabled noncompliance to go undetected. Noncompliance with the grant agreement and the Allowable Cost/Cost Principles and the Activities Allowed or Unallowed compliance requirements could result in the loss of future federal funds to the School Corporation. Questioned Costs There was a total of $173,841 of questioned costs as referenced under the Condition and Context. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure only allowable activities and allowable costs are charged to grants funds and to ensure grant money is only requested for reimbursement for monies directly related to the grant program. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-006 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Indiana Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2022-010. 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. Even though the reports were reviewed by someone other than the preparer, the School Corporation was not able to provide financial information that was used to determine amounts used in the reports. The School Corporation completed and submitted four annual Data Collection reports (Reports) for the Elementary and Secondary School Emergency Relief (ESSER) grants. For all four of the Reports, the School Corporation was unable to provide financial information to support the amounts in the Reports; therefore, the Indiana State Board of Accounts could not determine the accuracy of the Reports. Additionally, eight of eight key line items selected for testing could not be verified to the financial records. 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." 2 CFR 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for the Federal awards that are renewed quarterly or annual, from the date of submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 34 CFR 76.731 states: "A State and a subgrantee shall keep records to show its compliance with program requirements." Cause According to the School Corporation, these issues were due to the reporting differences of how the annual expenditure report categories are different than the annual Data Collection reports. The School Corporation indicated that it had to go employee by employee to properly place them under the correct category using the reimbursement requests but did not retain that documentation of how it came to the numbers. Effect The failure to design and implement an effective internal control system enabled noncompliance to go undetected with the Reporting compliance requirement. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish effective internal controls to ensure reports submitted are accurate and have supporting documentation. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
2024 – 001 – Allowable costs/cost principles - Cost Transfers Grantor: Department of Health and Human Services, National Institute of Health Cluster: Research and Development Cluster Award Names: Various Award Numbers: Various Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855 Award Year: 2023-2024 Passthrough Entity: Various Criteria: The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report. Condition: Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers: the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days. Cause: For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer. Effect: The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines. Questioned Costs: There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred. Recommendation: We recommend the University review and update its cost transfer policies and procedures to require maintaining a comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines. Management’s Views and Corrective Action Plan: Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers Grantor: Department of Health and Human Services, National Institute of Health Cluster: Research and Development Cluster Award Names: Various Award Numbers: Various Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855 Award Year: 2023-2024 Passthrough Entity: Various Criteria: The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report. Condition: Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers: the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days. Cause: For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer. Effect: The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines. Questioned Costs: There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred. Recommendation: We recommend the University review and update its cost transfer policies and procedures to require maintaining a comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines. Management’s Views and Corrective Action Plan: Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers Grantor: Department of Health and Human Services, National Institute of Health Cluster: Research and Development Cluster Award Names: Various Award Numbers: Various Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855 Award Year: 2023-2024 Passthrough Entity: Various Criteria: The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report. Condition: Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers: the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days. Cause: For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer. Effect: The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines. Questioned Costs: There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred. Recommendation: We recommend the University review and update its cost transfer policies and procedures to require maintaining a comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines. Management’s Views and Corrective Action Plan: Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers Grantor: Department of Health and Human Services, National Institute of Health Cluster: Research and Development Cluster Award Names: Various Award Numbers: Various Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855 Award Year: 2023-2024 Passthrough Entity: Various Criteria: The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report. Condition: Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers: the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days. Cause: For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer. Effect: The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines. Questioned Costs: There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred. Recommendation: We recommend the University review and update its cost transfer policies and procedures to require maintaining a comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines. Management’s Views and Corrective Action Plan: Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for additional details.