Finding 1104607 (2024-004)

Material Weakness
Requirement
I
Questioned Costs
-
Year
2024
Accepted
2025-03-14

AI Summary

  • Core Issue: The School Corporation failed to ensure compliance with suspension and debarment requirements for vendors, leading to inadequate oversight of the Cooperative's operations.
  • Impacted Requirements: Noncompliance with 2 CFR 200.303 and 2 CFR 180.300 regarding internal controls and vendor verification for covered transactions.
  • Recommended Follow-Up: Establish a robust system of internal controls and develop policies to verify vendor eligibility before entering into any covered transactions.

Finding Text

FINDING 2024-004 Subject: Special Education Cluster (IDEA) - Suspension and Debarment Federal Agency: Department of Education Federal Program: Special Education Grants to States Assistance Listings Number: 84.027 Federal Award Numbers and Years (or Other Identifying Numbers): 22611-046-PN01, 23611-046-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Other Matters INDIANA STATE BOARD OF ACCOUNTS 21 METROPOLITAN SCHOOL DISTRICT OF BOONE TOWNSHIP SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Condition and Context The School Corporation is a member of the Porter County Education Interlocal (Cooperative). During fiscal year 2022-2023, the Cooperative operated the special education programs and spent the federal money on behalf of all its members. As the grant agreements were between the Indiana Department of Education and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. However, there was inadequate oversight performed by the School Corporation in order to ensure compliance with the Procurement and Suspension and the Debarment compliance requirement. The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the suspension and debarment requirements. The Cooperative did not have effective internal controls to ensure compliance with the suspension and debarment requirements. Prior to entering into covered transactions with grant award funds, entities are required to verify that vendors under covered transactions are not suspended, debarred, or otherwise excluded. "Covered transactions" include, but are not limited to, contracts for goods or services awarded under procurement and nonprocurement transactions (i.e., grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the System for Award Management (SAM) exclusions, collecting a certification from that person, or adding a clause or condition to the covered transaction with that person. Upon inquiry of the Cooperative in order to review procedures in place for verifying that an entity with which it plans to enter into a covered transaction is not suspended, debarred, or otherwise excluded, the Cooperative explained that if the covered transaction had a contract, the contract was verified to make sure the clause for suspension and debarment was included. However, if the covered transaction did not involve a contract, the Cooperative did not have procedures in place to verify the suspension and debarment requirements. A population of five covered transactions for goods or services that equaled or exceeded $25,000 paid from grant award funds during the audit period was identified. Three of the five covered transactions did not have documentation to show that they were verified for the suspension and debarment requirements. The lack of internal controls and noncompliance were 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). . . ." 2 CFR 180.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: INDIANA STATE BOARD OF ACCOUNTS 22 METROPOLITAN SCHOOL DISTRICT OF BOONE TOWNSHIP SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (a) Checking the SAM.gov Exclusions, or (b) Collecting a certification from that person, or (c) Adding a clause or condition to the covered transaction with that person." Cause The Cooperative indicated that if the covered transaction had a contract, the contract was verified to make sure the clause for suspension and debarment was included. However, if the covered transaction did not involve a contract, the Cooperative did not have procedures in place to verify the suspension and debarment requirements. 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, vendors to whom payments equal to or in excess of $25,000 were not verified to be suspended, debarred, or otherwise excluded. 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 management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure vendors are not suspended, debarred, or otherwise excluded prior to entering into any covered transactions. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 528157 2024-002
    Material Weakness Repeat
  • 528158 2024-002
    Material Weakness Repeat
  • 528159 2024-002
    Material Weakness Repeat
  • 528160 2024-002
    Material Weakness Repeat
  • 528161 2024-003
    Material Weakness
  • 528162 2024-003
    Material Weakness
  • 528163 2024-003
    Material Weakness
  • 528164 2024-003
    Material Weakness
  • 528165 2024-004
    Material Weakness
  • 528166 2024-004
    Material Weakness
  • 528167 2024-005
    Material Weakness
  • 528168 2024-005
    Material Weakness
  • 528169 2024-005
    Material Weakness
  • 528170 2024-005
    Material Weakness
  • 1104599 2024-002
    Material Weakness Repeat
  • 1104600 2024-002
    Material Weakness Repeat
  • 1104601 2024-002
    Material Weakness Repeat
  • 1104602 2024-002
    Material Weakness Repeat
  • 1104603 2024-003
    Material Weakness
  • 1104604 2024-003
    Material Weakness
  • 1104605 2024-003
    Material Weakness
  • 1104606 2024-003
    Material Weakness
  • 1104608 2024-004
    Material Weakness
  • 1104609 2024-005
    Material Weakness
  • 1104610 2024-005
    Material Weakness
  • 1104611 2024-005
    Material Weakness
  • 1104612 2024-005
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
10.555 National School Lunch Program 2023 $467,433
10.555 National School Lunch Program 2024 $356,373
84.425 Education Stabilization Fund 2023 $298,551
84.425 Education Stabilization Fund 2024 $222,468
84.010 Title I Grants to Local Educational Agencies 2023 $106,369
84.010 Title I Grants to Local Educational Agencies 2024 $85,163
10.553 School Breakfast Program 2023 $60,276
10.553 School Breakfast Program 2024 $52,315
84.027 Special Education Grants to States 2024 $49,116
84.367 Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) 2023 $31,027
10.579 Child Nutrition Discretionary Grants Limited Availability 2024 $30,000
84.367 Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) 2024 $19,208
93.778 Medical Assistance Program 2024 $18,539
84.424 Student Support and Academic Enrichment Program 2023 $14,896
84.424 Student Support and Academic Enrichment Program 2024 $9,805
84.173 Special Education Preschool Grants 2023 $7,393
84.027 Special Education Grants to States 2023 $7,010
84.173 Special Education Preschool Grants 2024 $4,182
93.778 Medical Assistance Program 2023 $1,898