Finding 1115170 (2024-002)

Material Weakness
Requirement
G
Questioned Costs
-
Year
2024
Accepted
2025-03-28

AI Summary

  • Core Issue: The School Corporation lacks internal controls to ensure compliance with earmarking requirements for special education funding, leading to potential noncompliance.
  • Impacted Requirements: Key compliance areas include matching, level of effort, and earmarking as outlined in federal regulations.
  • Recommended Follow-Up: Establish a robust system of internal controls, develop clear policies for fund allocation, and ensure that all calculations are documented and reviewed by another individual.

Finding Text

FINDING 2024-002 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, COVID-19 - Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): H027X210084, H173X210104, H173A210104, H027A220084, H027A230084 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking Audit Findings: Material Weakness, Other Matters INDIANA STATE BOARD OF ACCOUNTS 17 ANDERSON COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Condition and Context The School Corporation did not have internal controls in place to ensure that the School Corporation complied with the earmarking requirements. The School Corporation did not have adequate procedures in place to ensure that the required level of expenditures for nonpublic school students with disabilities was met and to ensure nonpublic school expenditures were appropriately identified and reported. The Special Education Director allocated a portion of the salaries of the teachers that provided services to nonpublic schools and requested reimbursement based on this calculation. There was no documentation of how the calculation was performed or that a review of that calculation by another individual occurred. 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." Cause The Special Education Director is responsible for reporting and tracking funds spent related to the required proportionate share amounts for each grant. The Special Education Director had a procedure in place to request nonpublic school expenditures related to each grant; however, the procedure was not properly documented to allow examiners to verify amounts reimbursed. Examiners were also not able to confirm a secondary review was in place over this procedure, other than the preparation and review by the Special Education Director. INDIANA STATE BOARD OF ACCOUNTS 18 ANDERSON COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 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 such, the earmarking requirements could not be verified as having been met. 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 nonpublic proportionate share funds are appropriately allocated to the member school based on expenses charged directly on behalf of the member school and that the calculated expenditures are reviewed by another individual. Supporting documentation for these expenses should be retained for audit. 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

  • 538720 2024-001
    Significant Deficiency
  • 538721 2024-001
    Significant Deficiency
  • 538722 2024-002
    Material Weakness
  • 538723 2024-002
    Material Weakness
  • 538724 2024-002
    Material Weakness
  • 538725 2024-002
    Material Weakness
  • 538726 2024-002
    Material Weakness
  • 538727 2024-002
    Material Weakness
  • 538728 2024-002
    Material Weakness
  • 538729 2024-002
    Material Weakness
  • 538730 2024-003
    Material Weakness
  • 538731 2024-003
    Material Weakness
  • 538732 2024-003
    Material Weakness
  • 538733 2024-003
    Material Weakness
  • 538734 2024-003
    Material Weakness
  • 538735 2024-003
    Material Weakness
  • 538736 2024-003
    Material Weakness
  • 538737 2024-003
    Material Weakness
  • 1115162 2024-001
    Significant Deficiency
  • 1115163 2024-001
    Significant Deficiency
  • 1115164 2024-002
    Material Weakness
  • 1115165 2024-002
    Material Weakness
  • 1115166 2024-002
    Material Weakness
  • 1115167 2024-002
    Material Weakness
  • 1115168 2024-002
    Material Weakness
  • 1115169 2024-002
    Material Weakness
  • 1115171 2024-002
    Material Weakness
  • 1115172 2024-003
    Material Weakness
  • 1115173 2024-003
    Material Weakness
  • 1115174 2024-003
    Material Weakness
  • 1115175 2024-003
    Material Weakness
  • 1115176 2024-003
    Material Weakness
  • 1115177 2024-003
    Material Weakness
  • 1115178 2024-003
    Material Weakness
  • 1115179 2024-003
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
84.425 Education Stabilization Fund $11.21M
10.555 National School Lunch Program $3.34M
84.010 Title I Grants to Local Educational Agencies $2.84M
10.553 School Breakfast Program $982,477
84.287 Twenty-First Century Community Learning Centers $598,254
84.367 Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) $444,265
84.048 Career and Technical Education -- Basic Grants to States $234,130
93.778 Medical Assistance Program $231,318
84.027 Special Education Grants to States $155,539
10.559 Summer Food Service Program for Children $88,056
84.424 Student Support and Academic Enrichment Program $66,101
84.196 Education for Homeless Children and Youth $65,054
84.365 English Language Acquisition State Grants $64,613
84.173 Special Education Preschool Grants $5,438