Finding Text
FINDING 2024-001
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): S010A210014, S010A220014,
S010A230014
Pass-Through Entity: Indiana Department of Education
Compliance Requirement: Eligibility
Audit Finding: Significant Deficiency
Condition and Context
Eligibility for Title I is determined on the Eligible School Summary of the Title I application.
Enrollment and poverty numbers are automatically pulled from the Indiana Department of Education's
(IDOE) Official Pupil Enrollment (PE) count for each school into the Eligible School Summary page of the
Title I application. The counts that are prepopulated should be based on the School Corporation's records
as of October of the prior fiscal year.
During the audit period, the School Corporation submitted two Title I applications. The School
Corporation was required to use the October 2021 PE report data for the 2022-2023 Title I application and
the October 2022 PE report data for the 2023-2024 Title I application submitted to the IDOE. Data to be
submitted included student socioeconomic status information.
Additionally, the School Corporation receives enrollment and poverty data from nonpublic schools
that receive Title I funding. The School Corporation must manually enter that information into the Title I
application.
During the review, we noted that both the PE report and the enrollment and poverty data was
prepared and reviewed by the Title I Director. No other reviews were performed.
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). . . ."
INDIANA STATE BOARD OF ACCOUNTS 16
ANDERSON COMMUNITY SCHOOL CORPORATION
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
(Continued)
Cause
The Title I Director reviews all the information that is prepopulated by the IDOE in the Title I
application and confirms all nonpublic schools information reported in the application. However, officials
were not aware that a second review should take place prior to submission with procedures performed by
the second reviewer properly documented.
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, proper documentation of a review of the Title I application was not maintained.
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 design and implement a proper
system of internal controls, including policies and procedures that would provide segregation of duties to
ensure appropriate reviews, approvals, and oversight are taking place and the review is documented.
Views of Responsible Officials
For the views of responsible officials, refer to the Corrective Action Plan that is part of the report.