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: The consistency of the process of obtaining and inputting children’s financial information and the
setting of the children’s services into CINC is a significant factor of the internal control structure for
the CDS system to ensure that the appropriate payor is paying for the approved services and the
appropriate service rate for the setting.
Condition Found: In response to the fiscal year 2021 findings, CDS piloted a procedure at one of the regional sites,
using a temporary employee to coordinate the "Authorization to Provide Services and Seek Payment" form and to use this form to verify the accuracy of payor information within children's plans. The goal of this pilot procedure was to increase the accuracy of payor information within CINC, as well as to implement a more consistent procedure for obtaining and updating of "Authorization to Provide Services and Seek Payment" forms. However, the temporary employee left during fiscal year 2022 and the pilot was discontinued. During our current year testing we noted 1 out of 40 students for Part B and 1 out of 40 students for Part C did not have the "Authorization to Provide Services and Seek Payment" forms maintained in their files, however, the child was set up as CINC as either MaineCare or Private Insurance. We further noted CDS did not maintain signed authorizations from parents or guardians granting permission for the students to participate in the evaluation and/or program. We noted these authorizations were not properly maintained for 4 out of 40 students under the Part B program and 13 out of 40 under the Part C program. The prior year finding also noted the setting for the children's services of specially designed instruction (SDI) was treated inconsistently across the Regional Sites. The prior year finding indicated the ratio of children to services providers was inconsistent within CINC and the children's plan. The prior year finding noted two instances of SDI 2:1 services that were listed in CINC as individual for the setting.
Context: In testing the status prior year findings, we noted the related corrective action plan had not yet
been fully implemented.
Questioned Costs: None noted
Cause and Effect: Inconsistent controls and lack of available qualified staff to properly monitor all plans resulted in
unlocked plans and unauthorized individuals locking plans, some of which were created at inception and others whereby modifications were made to the plan requiring the file to be reapproved (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 2022-003 and 2021-003
Recommendation: We recommend communicating a clear policy for when the form should be obtained and
establishing a directive for Regional Site staff when it is not returned at the designated time. We also recommend communicating a clear policy surroudning the importance of obtaining and retaining the proper authorizations from parents and guardians to participate in the evaluation and/or program. Moreover, we recommend an employee at each Regional Site should be designated to run a report to show all plans that are missing the “Authorization to Provide Services and Seek Payment” forms and/or authorization forms to participate in services so that those forms
can be addressed by the appropriate employee. Finally, we recommend that once financial and setting information has been entered into the responsible payor input and child’s plan in CINC, it be reviewed by another designated individual to ensure its accuracy.
Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan.