Finding Text
FINDING 2024-007
Subject: Title I Grants to Local Educational Agencies - Eligibility
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): S010A220014, S010A230014
Pass-Through Entity: Indiana Department of Education
Compliance Requirement: Eligibility
Audit Findings: Material Weakness, Other Matters
Repeat Finding
This is a repeat finding from the immediately prior audit report. The prior audit finding number was
2022-008.
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 Eligibility compliance requirement.
Data from the School Corporation's student software system (Real Time data reports) was
uploaded to the Indiana Department of Education's (IDOE) Data Exchange System. Enrollment information
for the School Corporation was then abstracted by the IDOE from the Data Exchange System and prepopulated
into the Title I application for the School Corporation. The poverty counts in the Title I application
are prepopulated from the Direct Certifications listings by the IDOE. The School Corporation also downloads
the direct certification listings into its student management software to support the poverty counts.
The October 1, 2021 and 2022 Real Time (RT) data reports, which were used to prepopulate the
School Corporation's enrollment numbers for the 2022-2023 and 2023-2024 Title I applications, were tested
for accuracy. Students were selected from the Real Time reports. Their poverty status per the student
management software was verified to the Direct Certifications listing from the state provided by the School
Corporation. Of the 40 students tested for fiscal years 2022-2023 and 2023-2024, the recorded
socioeconomic status of 7 students did not agree to the supporting documentation. The School
Corporation's student software listed the 7 students as free or reduced; however, they were not included in
the Direct Certification listing provided.
The data used for the enrollment and poverty counts was not readily available for audit due to a
turnover in staff. Additional procedures and requests had to be made to obtain the information.
The lack of internal controls and the noncompliance were systemic issues throughout the audit
period.
INDIANA STATE BOARD OF ACCOUNTS
30
GARY COMMUNITY SCHOOL CORPORATION
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
(Continued)
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). . . ."
34 CFR 200.78(a)(1) states:
"After reserving funds, as applicable, under § 200.77, including funds for equitable services for
private school students, their teachers, and their families, an LEA must allocate funds under
this subpart to school attendance areas and schools, identified as eligible and selected to
participate under section 1113(a) or (b) of the ESEA, in rank order on the basis of the total
number of public school children from low-income families in each area or school."
Cause
The School Corporation had not designed or implemented an oversight or review process to ensure
that the enrollment and poverty data prepopulated into the Title I application was accurately reported.
Additionally, due to a turnover in personnel, supporting documentation for the social status of the students
was not readily available.
Effect
Noncompliance with the grant agreement and the compliance requirement could result in the
repayment of federal funds.
Questioned Costs
There were no questioned costs identified.
Recommendation
We recommended that the School Corporation's management establish a system of internal
controls and develop policies and procedures over the Title I application enrollment and poverty information
and that appropriate reviews, approval, and oversight are taking place to ensure compliance. Additionally,
management should develop policies and procedures to ensure that appropriate documentation is retained
to support the accuracy of the enrollment and poverty count information in the application.
Views of Responsible Officials
For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.