Finding Text
FINDING 2025-010 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): S010A230014, S010A240014 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 by September 30 each year. The School Corporation provided online assessment system security training. The School Corporation electronically captures the completion of the training, which includes the form signoff, in an electronic document. The School Corporation had not established effective internal controls to ensure all applicable personnel received the training prior to September 30. Of the 25 individuals tested, 2 were determined not to have taken the training for the 2024-2025 school year. Another 2 individuals who were employed when the school year started did not take the required training until February 2025, which was after the September 2024 deadline. All 4 instances of noncompliance occurred in the 2024-2025 school year. The lack of internal controls was a systemic issue throughout the audit period, and the noncompliance was limited to the 2024-2025 school year. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: INDIANA STATE BOARD OF ACCOUNTS 35 LAKE RIDGE SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (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). . . ." 20 USC 6311(b)(2)(A) states: "Each State plan shall demonstrate that the State educational agency, in consultation with local educational agencies, has implemented a set of high-quality student academic assessments in mathematics, reading or language arts, and science. The State retains the right to implement such assessments in any other subject chosen by the State." 511 IAC 5-5-5 states in part: ". . . (b) 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. (c) Each individual required to sign the testing integrity agreement under this rule shall sign the form by the date established and included on the testing integrity agreement. . . ." Indiana Assessments Policy Manual states: "Ensure all staff (including, but not limited to, TAs, proctors, principals, teachers in tested as well as non-tested grade levels, front office staff, teacher aides, cafeteria employees, custodians, etc.) complete IDOE's required test security and integrity training by September 30 annually. Locally maintain documentation (attendance sign-in sheets, training agendas, and other training materials) reflecting completion of all required training." Cause The School Corporation did not have effective internal control procedures in place over assessment security training. Effect Not all required employees received the Indiana Testing Security and Integrity training in a timely manner. Noncompliance with the grant agreement and the compliance requirement listed above could result in the repayment of federal funds. Questioned Costs There were no questioned costs identified. Recommendation We recommended that School Corporation's management establish a proper system of internal controls including policies and procedures to ensure that all individuals required to take the assessment system security do so, and in a timely manner. INDIANA STATE BOARD OF ACCOUNTS 36 LAKE RIDGE SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.