Finding Text
FINDING 2024-003
Subject: Title I Grants to Local Educational Agencies - Special Tests
and Provisions - Assessment System Security
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): 22611-001-P01, 23611-001-P01,
24611-001-P01
Pass-Through Entity: Indiana Department of Education
Compliance Requirement: Special Tests and Provisions - Assessment System Security
Audit Findings: Material Weakness, Other Matters
Condition and Context
State Educational Agencies (SEA), in consultation with Local Educational Agencies (LEA), are
required to establish and maintain an assessment security system that is valid, reliable, and consistent with
relevant professional and technical standards. Within their assessment system, SEAs must have policies
and procedures to maintain test security measures and ensure that LEAs implement those policies and
procedures. As such, the Indiana Department of Education created and published the Indiana
Assessments Policy Manual.
As a part of the assessment security, any individual who administers, handles, or has access to
secure test materials at the school or School Corporation, shall complete assessment training and sign a
testing security and integrity statement that remains on file in the appropriate building-level office each year.
Each individual required to sign the testing integrity agreement, shall sign the form by an established date.
Due to the lack of Internal controls over supporting documentation, 32 of the 40 employees selected
for testing did not have the testing security and integrity statement retained for audit purposes.
The lack of internal controls and noncompliance were systemic issues 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). . . ."
511 IAC 5-5-5(b) states: "Any individual who administers, handles, or has access to secure test
materials at the school or school corporation shall complete assessment training and sign a testing security
and integrity agreement to remain on file in the appropriate building-level office each year."
INDIANA STATE BOARD OF ACCOUNTS 21
WHITKO COMMUNITY SCHOOL CORPORATION
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
(Continued)
Cause
A proper system of internal controls was not designed by management of the School Corporation,
which would include segregation of key functions. Upon inquiry of the School Corporation, it was
determined that an employee who is no longer employed by the School Corporation was responsible for
storing the Indiana Testing Security and Integrity Agreements. The School Corporation was unable to
locate the prior employee's files. The School Corporation was able to obtain the Agreements for one
building for both years and one building for the second year of the audit period.
Effect
Without the proper design or implementation of the components of a system of internal controls,
including policies and procedures that provide segregation of duties and additional oversight as needed,
the internal control system cannot be capable of effectively preventing, or detecting and correcting, material
noncompliance. Someone administrating testing, that has not signed the security and integrity agreement,
could possibly not follow security properly and the testing integrity could be compromised.
Noncompliance with the grant agreement and the compliance requirement 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 that all required employees complete
assessment security training and sign the appropriate forms and retain those forms for audit.
Views of Responsible Officials
For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.