Finding 1114397 (2024-005)

Material Weakness
Requirement
G
Questioned Costs
-
Year
2024
Accepted
2025-03-27

AI Summary

  • Core Issue: The School Corporation failed to provide adequate oversight of the Cooperative, leading to noncompliance with federal requirements for special education funding.
  • Impacted Requirements: Key compliance areas affected include Matching, Level of Effort, and Earmarking, resulting in unspent funds totaling $13,595.71.
  • Recommended Follow-Up: Implement stronger internal controls and oversight procedures to ensure compliance with federal regulations and proper expenditure reporting for future grants.

Finding Text

FINDING 2024-005 Subject: Special Education Cluster (IDEA) - Earmarking Federal Agency: Department of Education Federal Programs: Special Education Grants to States, COVID-19 - Special Education Grants to States, Special Education Preschool Grants Assistance Listings Numbers: 84.027A, 84.027X, 84.173A Federal Award Numbers and Years (or Other Identifying Numbers): 21611-026-PN01, 21619-026-PN01, 22611-026-PN01, 22611-026-ARP, 22619-026-PN01, 23619-026-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking Audit Findings: Material Weakness, Modified Opinion Condition and Context The School Corporation is a member of the Harrison County Exceptional Learners Cooperative (Cooperative). During both fiscal years under audit, the Cooperative operated the special education programs and spent federal money on behalf of all its members. As the grant agreements were between the Indiana Department of Education (IDOE) 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 Matching, Level of Effort, Earmarking compliance requirement. The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the earmarking requirements. The Cooperative did not have adequate procedures in place to ensure that the required level of expenditures for nonpublic school students with disabilities was met for each member school. The Cooperative did not have effective internal controls to ensure nonpublic school expenditures were appropriately identified and reported. The Non-Public Proportionate Share expenditures for the 21611-026-PN01, 21619-026-PN01, 22611-026-PN01, 22611-026-ARP, 22619-026-PN01, and 23619-026-PN01 grant awards could not be verified for the individual member schools. Total grant expenditures were posted as expended. The nonpublic proportionate share expenditures were determined by applying a percentage to the nonpublic school budgeted expenditures. These were the amounts reported to the IDOE. As such, the Indiana State Board of Accounts was unable to identify if the minimum amount per the grant award was expended and properly reported to the IDOE as required. The 22611-026-PN01, 22611-026-ARP, 22619-026-PN01, and 23619-026-PN01 grant awards ended during the audit period. The School Corporation did not have internal controls in place to ensure that the Cooperative fully spent the required nonpublic proportionate share amounts by the end of the grant award. The following schedule shows the total nonpublic proportionate share approved by the IDOE for all member corporations for each grant award compared with the total expenditures posted to the ledger for nonpublic proportionate share. The remaining difference of $13,595.71 is nonpublic proportionate share money not spent by the Cooperative on behalf of member schools by the end of the grant award for all awards ending during the audit period. INDIANA STATE BOARD OF ACCOUNTS 25 SOUTH HARRISON COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Grant Award/ IDOE Approved Non- Total Non-Public Proportionate Project No. Public Proportionate Share Share Spent by Cooperative Difference 22611-026-PN01 $ 47,289.04 $ 40,688.11 $ 6,600.93 22611-026-ARP 10,585.73 5,233.83 5,351.90 22619-026-PN01 1,952.05 1,263.05 689.00 23619-026-PN01 3,949.95 2,996.07 953.88 Total $ 63,776.77 $ 50,181.06 $ 13,595.71 The lack of internal controls and noncompliance were isolated to the 21611-026-PN01, 21619-026- PN01, 22611-026-PN01, 22611-026-ARP, 22619-026-PN01, and 23619-026-PN01 grant awards. 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 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (g) Be adequately documented. . . ." 2 CFR 200.208(b) states in part: "The Federal awarding agency or pass-through entity may adjust specific Federal award conditions as needed . . ." 511 IAC 7-34-7(b) states: "The public agency, in providing special education and related services to students in nonpublic schools must expend at least an amount that is the same proportion of the public agency total subgrant under 20 U.S.C. 1411(f) as the number of nonpublic school students with disabilities, who are enrolled by their parents in nonpublic schools within its boundaries, is to the total number of students with disabilities of the same age range." INDIANA STATE BOARD OF ACCOUNTS 26 SOUTH HARRISON COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Cause The School Corporation's Director of Business Operations/Treasurer, who was also the fiscal agent for the Cooperative, stated that the amounts attributed to member corporations for nonpublic proportionate share had been calculated for many years using the methodology noted above. She was unaware that such an allocation was not allowed until the issue was identified for the grants ending in fiscal year 2022-2023 and was not able to correct the issue for the grants ending in 2023-2024. The School Corporation had the option to apply for a waiver to allow the unspent portion of nonpublic proportionate share funds to be used for other grants purposes, but she indicated that the School Corporation was told that it would not matter and that the School Corporation would still have been in noncompliance. Effect Without a proper system of internal controls in place that operated effectively, the School Corporation was unable to ensure that the Cooperative properly tracked nonpublic proportionate share expenditures in a manner that would allow us to verify that the Earmarking requirements of the federal award had been met. Due to the lack of proper oversight from the School Corporation, the Cooperative also did not fully spend the required nonpublic proportionate share amounts on behalf of the School Corporation. 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 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 nonpublic proportionate share funds are properly accounted for by the Cooperative based on expenditures charged directly on behalf of the member school. Supporting documentation for these expenditures should be retained for audit. We also recommend tracking total nonpublic proportionate share by approved grant amounts from the IDOE to ensure proportionate share is being spent by the end of the grant award. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

Categories

Matching / Level of Effort / Earmarking Allowable Costs / Cost Principles

Other Findings in this Audit

  • 537945 2024-001
    Material Weakness
  • 537946 2024-001
    Material Weakness
  • 537947 2024-002
    Material Weakness
  • 537948 2024-002
    Material Weakness
  • 537949 2024-003
    Material Weakness
  • 537950 2024-003
    Material Weakness
  • 537951 2024-003
    Material Weakness
  • 537952 2024-003
    Material Weakness
  • 537953 2024-003
    Material Weakness
  • 537954 2024-004
    Material Weakness
  • 537955 2024-005
    Material Weakness
  • 537956 2024-005
    Material Weakness
  • 537957 2024-005
    Material Weakness
  • 537958 2024-005
    Material Weakness
  • 537959 2024-005
    Material Weakness
  • 537960 2024-006
    Material Weakness
  • 537961 2024-006
    Material Weakness
  • 537962 2024-006
    Material Weakness
  • 1114387 2024-001
    Material Weakness
  • 1114388 2024-001
    Material Weakness
  • 1114389 2024-002
    Material Weakness
  • 1114390 2024-002
    Material Weakness
  • 1114391 2024-003
    Material Weakness
  • 1114392 2024-003
    Material Weakness
  • 1114393 2024-003
    Material Weakness
  • 1114394 2024-003
    Material Weakness
  • 1114395 2024-003
    Material Weakness
  • 1114396 2024-004
    Material Weakness
  • 1114398 2024-005
    Material Weakness
  • 1114399 2024-005
    Material Weakness
  • 1114400 2024-005
    Material Weakness
  • 1114401 2024-005
    Material Weakness
  • 1114402 2024-006
    Material Weakness
  • 1114403 2024-006
    Material Weakness
  • 1114404 2024-006
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
10.555 National School Lunch Program 2023 $1.35M
10.555 National School Lunch Program 2024 $1.19M
84.027 Special Education Grants to States 2023 $805,609
84.425 Education Stabilization Fund 2023 $765,709
84.010 Title I Grants to Local Educational Agencies 2023 $556,034
32.009 Emergency Connectivity Fund Program 2023 $501,849
10.553 School Breakfast Program 2023 $371,440
10.553 School Breakfast Program 2024 $331,324
93.575 Child Care and Development Block Grant 2023 $255,507
84.010 Title I Grants to Local Educational Agencies 2024 $195,201
84.027 Special Education Grants to States 2024 $144,645
84.424 Student Support and Academic Enrichment Program 2024 $131,316
84.367 Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) 2023 $117,781
93.778 Medical Assistance Program 2023 $112,509
84.367 Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) 2024 $100,467
93.778 Medical Assistance Program 2024 $93,203
93.575 Child Care and Development Block Grant 2024 $79,161
84.424 Student Support and Academic Enrichment Program 2023 $65,598
84.173 Special Education Preschool Grants 2024 $40,088
84.425 Education Stabilization Fund 2024 $11,445
10.649 Pandemic Ebt Administrative Costs 2023 $6,198
84.173 Special Education Preschool Grants 2023 $1,559