Finding Text
FINDING 2024-004
Subject: Title I Grants to Local Educational Agencies - Special
Tests and Provisions - Assessment System Security
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: Special Tests and Provisions - Assessment System Security
Audit Findings: Material Weakness, Other Matters
Condition and Context
State educational agencies (SEA), in consultation with local educational agencies (LEA), are
required to establish and maintain an assessment security system that is valid, reliable, and consistent with
relevant professional and technical standards. Within their assessment system, SEAs must have policies
and procedures to maintain test security measures and ensure that LEAs implement those policies and
procedures. As such, the Indiana Department of Education created and published the Indiana Assessment
Policy Manual.
As a part of the assessment security, any individual who administers, handles, or has access to
secure test materials at the school or school corporation shall complete assessment training and sign a
testing security and integrity statement that remains on file in the appropriate building-level office each year.
Each individual required to sign the testing integrity agreement shall sign the form by an established date.
The School Corporation had a process to provide assessment system security training and to
ensure each employee that attended training signed the agreement indicating training was received.
However, there was no process in place to ensure that all documentation of school employees being trained
was retained for audit.
Due to the lack of internal controls over maintaining the supporting documentation, some of the
Indiana Testing and Security agreements were not provided for review. A sample of 40 employees was
selected for testing from the School Corporation's roster. Of the 40 employees tested, 8 did not have a
signed agreement on file indicating training was received as required.
The lack of internal controls and noncompliance was isolated to the 2022-2023 school year for 3 of
the buildings.
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). . . ."
INDIANA STATE BOARD OF ACCOUNTS
22
MADISON CONSOLIDATED SCHOOLS
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
(Continued)
511 IAC 5-5-5(b) states: "Any individual who administers, handles, or has access to secure test
materials at the school or school corporation shall complete assessment training and sign a testing security
and integrity agreement to remain on file in the appropriate building-level office each year."
Cause
A proper system of internal controls was not designed by management of the School Corporation
to ensure that all Indiana Testing and Security agreements were on file and could be presented for audit.
Agreements for 8 employees selected for testing could not be located.
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, not all required employees have the required Indiana Testing Security and
Integrity agreement maintained for Assessment System Security.
Noncompliance with the grant agreement and the compliance requirement 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 all required employees complete
assessment security training and that the signed appropriate forms are retained for audit.
Views of Responsible Officials
For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.