Finding 1123475 (2024-004)

Material Weakness
Requirement
B
Questioned Costs
-
Year
2024
Accepted
2025-03-31

AI Summary

  • Core Issue: The School Corporation lacked effective internal controls over payroll, leading to noncompliance with federal requirements for allowable costs.
  • Impacted Requirements: Documentation of time and effort for staff paid from federal funds was inadequate, violating 2 CFR 200.303 and 200.430(i).
  • Recommended Follow-Up: Management should establish a robust internal control system to ensure proper documentation and compliance with allowable costs for federal disbursements.

Finding Text

FINDING 2024-004 Subject: COVID-19 - Education Stabilization Fund - Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Allowable Costs/Cost Principles Audit Findings: Material Weakness, Other Matters Condition and Context An effective internal control system, which would include segregation of duties, was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the following compliance requirement: Allowable Costs/Cost Principles. Federal funds may only be used to pay staff for work that has occurred supporting the objective of the federal program. As such, proper time and effort documentation is to be maintained by the School Corporation. The purpose of time and effort recording is to provide documentation of the time spent working on specific federal programs to ensure charges are accurate for each program. Reimbursements were prepared by one employee and reviewed by another employee prior to submission; however, this internal control was not effective in preventing noncompliance with allowable costs/cost principles. INDIANA STATE BOARD OF ACCOUNTS 22 MT. VERNON COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Out of 14 employees tested, 1 employee was paid 50 percent of their salary from the COVID-19 - Education Stabilization Funds (ESF) grant and 50 percent of their salary from another funding source. The School Corporation was not able to provide documentation that supported the hours paid from the ESF grant. The ineffective internal controls were systemic throughout the audit period. The noncompliance was isolated to payrolls for September and October of 2022. 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 200.430(i) states in part: "Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities . . . (iv) Encompass federally-assisted and all other activities compensated by the recipient or subrecipient on an integrated basis but may include the use of subsidiary records as defined in the recipient's or subrecipient's written policy; . . . (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. . . ." INDIANA STATE BOARD OF ACCOUNTS 23 MT. VERNON COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) While across the board stipends are not permitted, LEAs may pay staff for COVID-related work that has been documented. Most, if not all, staff likely had extra responsibilities as well as time and effort to respond to the pandemic. ESSER funds can be used to pay staff for that work and LEAs are responsible for documenting that this work occurred. (Indiana Department of Education, ESSER III Frequently Asked Questions (FAQs) updated August 16, 2021) Cause A proper system of internal controls over the payroll disbursements for employees who worked with both federal and nonfederal programs was not properly designed or implemented by management. The School Corporation did not maintain a record of the actual time spent working on extra responsibilities for COVID-related work to ensure allowability. 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, the proper allocation could not be determined for reimbursements for one employee's payroll for September and October of 2022. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management design and implement a system of internal controls to ensure that disbursement documentation will be obtained, retained, and made available for audit and that the disbursements comply with the Allowable Costs/Cost Principles compliance requirement.

Categories

Allowable Costs / Cost Principles

Other Findings in this Audit

  • 547022 2024-003
    Material Weakness
  • 547023 2024-003
    Material Weakness
  • 547024 2024-003
    Material Weakness
  • 547025 2024-003
    Material Weakness
  • 547026 2024-003
    Material Weakness
  • 547027 2024-003
    Material Weakness
  • 547028 2024-003
    Material Weakness
  • 547029 2024-004
    Material Weakness
  • 547030 2024-004
    Material Weakness
  • 547031 2024-004
    Material Weakness
  • 547032 2024-004
    Material Weakness
  • 547033 2024-004
    Material Weakness
  • 547034 2024-005
    Material Weakness Repeat
  • 547035 2024-005
    Material Weakness Repeat
  • 547036 2024-005
    Material Weakness Repeat
  • 547037 2024-005
    Material Weakness Repeat
  • 547038 2024-005
    Material Weakness Repeat
  • 1123464 2024-003
    Material Weakness
  • 1123465 2024-003
    Material Weakness
  • 1123466 2024-003
    Material Weakness
  • 1123467 2024-003
    Material Weakness
  • 1123468 2024-003
    Material Weakness
  • 1123469 2024-003
    Material Weakness
  • 1123470 2024-003
    Material Weakness
  • 1123471 2024-004
    Material Weakness
  • 1123472 2024-004
    Material Weakness
  • 1123473 2024-004
    Material Weakness
  • 1123474 2024-004
    Material Weakness
  • 1123476 2024-005
    Material Weakness Repeat
  • 1123477 2024-005
    Material Weakness Repeat
  • 1123478 2024-005
    Material Weakness Repeat
  • 1123479 2024-005
    Material Weakness Repeat
  • 1123480 2024-005
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
10.555 National School Lunch Program 2023 $1.36M
10.555 National School Lunch Program 2024 $1.27M
84.425 Education Stabilization Fund 2023 $851,979
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) 2023 $685,524
84.010 Title I Grants to Local Educational Agencies 2024 $279,032
10.553 School Breakfast Program 2024 $201,588
10.553 School Breakfast Program 2023 $184,549
93.778 Medical Assistance Program 2024 $178,929
84.027 Special Education Grants to States 2023 $128,433
93.778 Medical Assistance Program 2023 $117,045
32.009 Emergency Connectivity Fund Program 2023 $102,398
84.010 Title I Grants to Local Educational Agencies 2023 $98,549
84.367 Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) 2023 $97,659
84.027 Special Education Grants to States 2024 $95,923
84.367 Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) 2024 $52,249
84.425 Education Stabilization Fund 2024 $51,809
84.424 Student Support and Academic Enrichment Program 2024 $25,888
84.365 English Language Acquisition State Grants 2023 $19,756
84.173 Special Education Preschool Grants 2024 $16,743
84.365 English Language Acquisition State Grants 2024 $13,019
84.424 Student Support and Academic Enrichment Program 2023 $3,346
84.173 Special Education Preschool Grants 2023 $1,327