Finding 1100806 (2024-002)

FINDING 2024-002 Subject: Special Education Cluster (IDEA) - Internal Controls Federal Agency: Department of Education Federal Programs: Special Education Grants to States, COVID-19 - Special Education Grants to States Assistance Listings Number: 84.027 Federal Award Numbers and Years (or Other Identifying Numbers): 22611-048-PN01, 23611-048-PN01, 24611-048-PN01, 22611-048-ARP Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking Audit Finding: Material Weakness Condition and Context An effective internal control system, which would include segregation of duties, was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the following compliance requirement: INDIANA STATE BOARD OF ACCOUNTS 16 JAC-CEN-DEL COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Level of Effort - Maintenance of Effort The Indiana Department of Education calculates the Level of Effort - Maintenance of Effort based on expenditure information submitted on the Form 9 for that fiscal year. The School Corporation Treasurer was responsible for the preparation and submission of the Form 9. There were no documented internal controls in place, such as an oversight, review, or approval process, to ensure expenditures were correctly reported. The lack of internal controls 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). . . ." Cause A proper system of internal controls was not designed by management of the School Corporation. The individual responsible for review of the Form 9 information signed a cover sheet, but did not receive adequate supporting documentation to ensure expenditures were correctly reported. Effect Without the proper implementation of an effectively designed system of internal controls, expenditure information used by the Indiana Department of Education to review compliance with the Level of Effort - Maintenance of Effort requirement, could be inaccurate. 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 School Corporation's management establish a system of internal controls, including segregation of duties, related to the grant agreement and compliance requirement listed above. INDIANA STATE BOARD OF ACCOUNTS 17 JAC-CEN-DEL COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.