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FINDING 2025-005 Subject: COVID-19 - Education Stabilization Fund - Earmarking 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): S425D210013, S425U200013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking Audit Findings: Material Weakness, Modified Opinion INDIANA STATE BOARD OF ACCOUNTS 21 CLOVERDALE COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Condition and Context An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Earmarking compliance requirement. Local Education Agencies must set aside at least 20 percent of ESSER III (ARP) funding for evidence-based activities to address learning loss. According to guidance from the Indiana Department of Education, summer programming, afterschool, and extended school day are examples, but they are not the only allowable activities to address learning loss and accelerate learning. Additionally, allowable activities that are deemed necessary to carry out the activities to address learning loss, such as transportation or staffing, may also be budged as an activity to address learning loss. Although the School Corporation budgeted 20 percent of its program expenditures for learning loss activities in its grant application, it did not differentiate, code, or track learning loss expenditures separately from non-learning loss activity expenditures. As a result, we could not identify whether 20 percent of the $1,703,452 total ESSER III allocation received by the School Corporation was used for learning loss activities. The School Corporation was unable to provide a complete, detailed list of its learning loss expenditures to demonstrate compliance with the Earmarking requirement. The lack of internal controls and noncompliance were systemic issues both during the audit period and since the beginning of the grant award. 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). . . ." Section 2001(e)(1) of the ARP Act states in part: "A local educational agency that receives funds under this section - (1) shall reserve not less than 20 percent of such funds to address learning loss through the implementation of evidence-based interventions, such as summer learning or summer enrichment, extended day, comprehensive afterschool programs, or extended school year programs, and ensure that such interventions respond to students' academic, social, and emotional needs and address the disproportionate impact of the coronavirus on the student subgroups . . ." Cause The School Corporation officials were unaware that they should track or code learning loss expenditures separately throughout the grant's period of performance. INDIANA STATE BOARD OF ACCOUNTS 22 CLOVERDALE COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Effect Because the School Corporation could not identify which expenditures were considered learning loss, we were unable to obtain sufficient appropriate audit evidence on which to base our opinion on the School Corporation's compliance with the earmarking requirement. 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 the School Corporation's management strengthen its system of internal controls to ensure Earmarking requirements including learning loss set-asides are monitored and identified for audit purposes. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.