Finding Text
FINDING 2024-002
Information on the federal program:
Subject: COVID-19 – Education Stabilization Fund – Reporting
Federal Agency: Department of Education
Federal Program: COVID-19 – Education Stabilization Fund
Assistance Listing Number: 84.425D, 84.425U
Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425U210013
Pass-Through Entity: Indiana Department of Education
Compliance Requirement: Reporting
Audit Finding: Significant Deficiency
Criteria: 2 CFR section 200.303 states in part:
"The non-Federal entity must:
(a) Establish and maintain effective internal control over Federal award that provides reasonable assurance
that the non-Federal entity is managing the Federal awards in compliance with Federal statutes,
regulations, and the terms and conditions of the Federal award. These internal controls should be in
compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the
Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the
Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ."
2 CFR 200.302(b) states in part:
"The financial management system of each non-Federal entity must provide for the following:
(2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in
accordance with the reporting requirements set forth in §§ 200.328 Financial reporting . . . ."
34 CFR 76.722 states:
"A State may require a subgrantee to submit reports in a manner and format that assists the State in
complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the
program."
Condition: An effective internal control system was not in place at the School Corporation in order to
ensure compliance with requirements related to the grant agreement and the Reporting compliance
requirements.
Cause: The School District's management had not developed a system of internal controls to ensure
compliance with the compliance requirements listed above.
Effect: The failure to establish an effective internal control system placed the School Corporation at risk of
noncompliance with the grant agreement and the compliance requirements. Internal controls were not
adequate to detect and prevent errors in annual data submitted to the Indiana Department of Education.
Questioned Costs: There were no questioned costs identified. FINDING 2024-002 (Continued)
Context: The School Corporation had not designed nor implemented a system of internal control to ensure
that the annual Elementary and Secondary School Emergency Relief (ESSER) annual Data Collection
reports (Reports) were complete and accurately submitted. The reports were prepared and submitted in
JotForm, the online application used by the Indiana Department of Education to collect information, without
an oversight or secondary review process in place to prevent or detect and correct errors.
During the testing of the annual data reports, variances were noted in the amounts expended reported on
the Year 3 and Year 4 annual data reports for the ESSER II and ESSER III grant awards when compared
to underlying disbursement detail for the grant funds. The amounts reported as expended in the Year 3
reports, which covers the period of July 1, 2021 through June 30, 2022, included amounts not expended
until the following fiscal year. The amounts reported as expended in the Year 4 report, which covers the
period of July 1, 2022 through June 30, 2023, for ESSER III totaled $745,052 compared to underlying
disbursement detail of $648,383 for the same period.
Identification as a repeat finding, if applicable: No.
Recommendation: We recommend someone other than the preparer of the report perform a documented,
secondary review of the report information prior to submission to validate the accuracy and completeness
of the data submitted.
Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding
and has prepared a corrective action plan.