Finding 1104790 (2024-005)

Material Weakness
Requirement
H
Questioned Costs
-
Year
2024
Accepted
2025-03-17
Audit: 346388
Organization: Union School Corporation (IN)
Auditor: Crowe LLP

AI Summary

  • Core Issue: The School Corporation lacks effective internal controls to ensure compliance with the period of performance requirements for the Special Education Cluster funding.
  • Impacted Requirements: Compliance with 2 CFR sections 200.303 and 200.309 regarding internal controls and allowable costs during the performance period.
  • Recommended Follow-Up: Implement procedures to ensure invoices are paid before the liquidation date to avoid compliance risks.

Finding Text

Information on the federal program: Subject: Special Education Cluster – Internal Controls Federal Agency: Department of Education Federal Program: Special Education Cluster Assistance Listing Number: 84.027X Federal Award Numbers and Years (or Other Identifying Numbers): 22611-122-ARP Pass-Through Entity: Indiana Department of Education Compliance Requirement: Period of Performance Audit Finding: Material Weakness Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards 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 200.309 states: "A non-Federal entity may charge to the Federal award only allowable costs incurred during the period of performance (except as described in § 200.461 Publication and printing costs) and any costs incurred before the Federal awarding agency or pass-through entity made the Federal award that were authorized by the Federal awarding agency or pass-through entity. Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the period of performance compliance requirement. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with the period of performance requirement. The School Corporation did not have a design control in place to ensure that service provider invoices were paid before the required liquidation date. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. Questioned Costs: There were no questioned costs identified. Context: The School Corporation pays one hundred percent of its Special Education Cluster funding to one service provider. From review of the expense population, we noted 2 payments to the service provider where the service provider was not paid until after liquidation date of December 29, 2023. The School Corporation did not pay the service provider until April 30, 2024 for $258,488 for the services provided. Identification as a repeat finding: No. Recommendation: We recommend the School Corporation implement procedures to ensure the invoices are paid before the required liquidation date. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.

Categories

Subrecipient Monitoring Allowable Costs / Cost Principles Material Weakness Period of Performance Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Other Findings in this Audit

  • 528342 2024-003
    Material Weakness Repeat
  • 528343 2024-004
    Significant Deficiency Repeat
  • 528344 2024-004
    Significant Deficiency Repeat
  • 528345 2024-004
    Significant Deficiency Repeat
  • 528346 2024-004
    Significant Deficiency Repeat
  • 528347 2024-004
    Significant Deficiency Repeat
  • 528348 2024-005
    Material Weakness
  • 528349 2024-006
    Material Weakness
  • 528350 2024-007
    Material Weakness
  • 528351 2024-007
    Material Weakness
  • 528352 2024-008
    Material Weakness
  • 528353 2024-009
    Material Weakness
  • 1104784 2024-003
    Material Weakness Repeat
  • 1104785 2024-004
    Significant Deficiency Repeat
  • 1104786 2024-004
    Significant Deficiency Repeat
  • 1104787 2024-004
    Significant Deficiency Repeat
  • 1104788 2024-004
    Significant Deficiency Repeat
  • 1104789 2024-004
    Significant Deficiency Repeat
  • 1104791 2024-006
    Material Weakness
  • 1104792 2024-007
    Material Weakness
  • 1104793 2024-007
    Material Weakness
  • 1104794 2024-008
    Material Weakness
  • 1104795 2024-009
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
93.778 Medical Assistance Program $453,616
84.027 Special Education Grants to States $258,488
84.010 Title I Grants to Local Educational Agencies $98,551
84.425 Education Stabilization Fund $70,746
10.553 School Breakfast Program $46,012
84.367 Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) $33,146
10.555 National School Lunch Program $24,011
84.173 Special Education Preschool Grants $22,694
84.424 Student Support and Academic Enrichment Program $20,000
10.649 Pandemic Ebt Administrative Costs $3,135