Finding Text
FINDING 2024-004
Subject: COVID-19 - Education Stabilization Fund - Reporting
Federal Agency: Department of Education
Federal Program: COVID-19 - Education Stabilization Fund
Assistance Listings Numbers: 84.425D, 84.425U
Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S425U210013
Pass-Through Entity: Indiana Department of Education
Compliance Requirement: Reporting
Audit Finding: Material Weakness
Repeat Finding
This is a repeat finding from the immediately prior audit report. The prior audit finding number was
2022-004.
Condition and Context
An effective internal control system was not in place at the School Corporation to ensure compliance
with requirements related to the grant agreement and the Reporting compliance requirement.
The School Corporation had not designed or implemented a system of internal controls to ensure
that the Elementary and Secondary School Emergency Relief (ESSER) annual data reports (Reports) were
complete and accurately submitted. The Reports were prepared by the Director of Business Affairs without
a documented oversight, review, or approval process in place to prevent, or detect and correct, errors.
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
The Jotform system in which ESSER annual reports are submitted to the Indiana Department of
Education (IDOE) does not have a required review built into the IT system. The School Corporation officials
were unaware they should document a review of the annual reports.
Effect
The lack of an effective internal control system could enable noncompliance to occur and remain
undetected. Noncompliance with the grant agreement and the Reporting compliance requirement could
result in inaccurate reporting to the IDOE and the loss of future federal funds to the School Corporation.
Questioned Costs
There were no questioned costs identified.
Recommendation
We recommended that the School Corporation's management establish internal controls to ensure
compliance with the grant agreement and the Reporting compliance requirement. Any and all future
ESSER reports submitted in Jotform should document an oversight, review, or approval process by
someone other than the Director of Business Affairs.
Views of Responsible Officials
For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.