Finding Text
Information on the Federal Program :Federal Agency: United States Department of Education
Program Names: Special Education – Grants for Infants and Families
AL: 84.181
Federal Award Year: 2023
Federal Agency: United States Department of Education
Program Names: Special Education Cluster (IDEA)
AL: 84.027, 84.173
Federal Award Year: 2023
Criteria : All service plans should be authorized by a designated individual with the appropriate experience or certification and accordingly be documented within the child's file. This authorization represents approval for the specific services indicated in the child's plan. The plan is considered authorized when the designated individual electronically locks the plan within CINC. Service plans should be maintained for children enrolled in programs and copies retained in accordance with the State of Maine's document retention policy.
Condition Found : In consideration of prior year findings, CDS developed a prior year corrective action plan which
addressed the importance of documenting the authorization of children's service plans by working to establish an acceptable time frame protocol for the time between the date a plan is written and the date the plan is locked. During our testing in the current year we noted several instances were noted in which a plan was unlocked or not locked within the acceptable timeframe. Additionally, it was noted that there were several instances of plans locked by unauthorized individuals. We noted the service plans were not properly maintained for 14 out of 40 children under the Part B program. We understand the individual plans are transferred to other school districts when children either age out or transfer districts, however copies of documentation is not retained by CDS for
audit purposes.
Context: A nonstatistical sample of 40 children was tested under the Part B program and a nonstatistical sample of 40 children was tested under the Part C program.
Cause and Effect: Inconsistent controls and lack of available authorized staff to properly monitor all plans resulted in
unlocked plans and unauthorized individuals locking plans, some of which were created upon determination of the child's eligibility for services and others whereby modifications were made to the plan requiring the file to be re-approved (locked). A critical internal control procedure over financial reporting and compliance is having an appropriate individual with the proper knowledge, experience, and authority to commit funds on behalf of CDS. When the authorization is not documented, there is no assurance that the child's plans have been reviewed for allowable activities and allowable costs in accordance with CDS policies and the Maine Department of Education Regulations, Chapter 101, Maine Unified Special Education Regulation Birth to Age Twenty. The result is that CDS is at risk for potential noncompliance or misstatement of the financial statements.
Identification of a Repeat Finding, if Applicable
A repeat finding; See finding 2022-002 and 2021-002
Recommendation: We continue to recommend CDS clearly communicate the acceptable time frame policy between
the date a plan is written and the date the plan is locked. Furthermore, although program managers at the Regional Site levels are reviewing the unfinalized plan report from CINC on a regular basis, at the State level, we recommend that the quality assurance director continue to perform inspection of the unfinalized plan report from CINC on a regular basis to review the status of all unlocked plans beyond the established time and contact the Regional Sites as needed. In addition, we recommend that it is clearly communicated that individuals possess the appropriate
qualifications to lock plans and that user access rights for locking plans be restricted to only those with the proper qualifications. Alternatively, if management determines that locking children’s plans may no longer be the most effective and efficient means of documenting approval, we recommend that another approach be determined and implemented. If so, we recommend that management consult with the database provider to consider feasibility of other options, such as implementing a field for electronic signature of the authorized individual, or auto-flow updates for plans pending approval.
We also recommend management create a policy to maintain copies of documentation for students
when they transition to another school district. We understand these documents follow the students
to the new district, however this leaves CDS without proper support to undergo audits and other
program reviews.
Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan.