Finding Text
FINDING 2024-003
Subject: COVID-19 - Emergency Connectivity Fund Program - Special
Tests and Provisions - Restricted Purpose
Federal Agency: Federal Communications Commission
Federal Program: COVID-19 - Emergency Connectivity Fund Program
Assistance Listings Number: 32.009
Federal Award Number and Year (or Other Identifying Number): FY23
Compliance Requirement: Special Tests and Provisions - Restricted Purpose
Audit Finding: Material Weakness
Condition and Context
The School Corporation had not properly designed or implemented a system of internal controls,
which would include appropriate segregation of duties, that would likely be effective in preventing, or
detecting and correcting, noncompliance related to asset inventory and per-user limitations of the devices
purchased with Emergency Connectivity Fund (ECF) Program support.
The School Corporation maintained an asset inventory for the purchased equipment; however, the
data was input into the asset listing, from the equipment invoice by the Information Technology department
without a documented review or oversight process to prevent, or detect and correct, errors. In addition,
there was not a documented review or oversight process to ensure each student only received one device.
The lack of internal controls was systemic throughout the audit period.
INDIANA STATE BOARD OF ACCOUNTS
22
HUNTINGTON COUNTY COMMUNITY SCHOOL CORPORATION
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
(Continued)
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). . . ."
Cause
A proper system of internal controls was not designed by management of the School Corporation
to ensure that students only received one device. Evidence of another individual reviewing the student
inventory listing was not provided, so there was nothing to show there was an internal control over this
compliance requirement.
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. 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 the School Corporation's management establish a system of internal
controls related to the grant agreement and the Special Tests and Provisions - Restricted Purpose
compliance requirement.
Views of Responsible Officials
For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.