FAC Explorer

Finding 1238876 (2025-010)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-09-30
Audit: 413792
Organization: South Bend Community School Corporation (IN)
Auditor: INDIANA STATE BOARD OF ACCOUNTS

AI Summary

  • Core Issue: The School Corporation failed to ensure that all required staff completed assessment security training and signed the integrity agreement, leading to a significant deficiency in internal controls.
  • Impacted Requirements: Compliance with 2 CFR 200.303 and Indiana state regulations mandating effective internal controls and training documentation for individuals handling secure test materials.
  • Recommended Follow-Up: Implement a verification process to ensure timely completion of training and signing of documentation by all required employees.

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): S010A210014, S010A220014, S010A230014, S010A240014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Assessment System Security Audit Findings: Significant Deficiency, 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 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. Everyone required to sign the testing integrity agreement shall sign the form by an established date. INDIANA STATE BOARD OF ACCOUNTS 41 SOUTH BEND COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Of the 25 individuals tested, the School Corporation could not provide evidence that 1 employee in the 2023-2024 school year and 2 employees in the 2024-2025 school year had completed the required assessment security training or had signed the assessment security agreement. The lack of internal controls was a systemic issue 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 Federals 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 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 A proper system of internal controls was not designed by management of the School Corporation to ensure required school employees took the training. 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, certifications were not properly completed or maintained to ensure employees attended the assessment system training or signed the assessment security agreement. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation implement a verification process to ensure all employees who are required to participate in the training complete the training and sign the required training documentation, either digitally or on physical forms, in a timely manner. INDIANA STATE BOARD OF ACCOUNTS 42 SOUTH BEND COMMUNITY SCHOOL CORPORATION 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.

Corrective Action Plan

FINDING 2025-010 Finding Subject: Title I Grants to Local Educational Agencies - Special Tests and Provisions – Assessment System Security Contact Person Responsible for Corrective Action: Jenna Harrington, Ahnaf Tahmid & Marlaina Johns Contact Phone Number and Email Address: 574-393-6000, jharrington@sbcsc.k12.in.us , atahmid@sbcsc.k12.in.us, mjohns2@sbcsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Established a comprehensive testing security and operations plan featuring: • Role-specific scenario-based training for Coordinators, Proctors, and IT. • Mandatory signed non-disclosure agreements (NDAs) due annually by September 30th. • Retention of sign-in sheets, training slides, and make-up accountability quizzes. • Clear escalation protocols for reporting testing irregularities. Anticipated Completion Date: May 31, 2027

Categories

Special Tests & Provisions Subrecipient Monitoring Significant Deficiency Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1238847 2025-003
    Material Weakness Repeat
  • 1238848 2025-003
    Material Weakness Repeat
  • 1238849 2025-003
    Material Weakness Repeat
  • 1238850 2025-003
    Material Weakness Repeat
  • 1238851 2025-003
    Material Weakness Repeat
  • 1238852 2025-003
    Material Weakness Repeat
  • 1238853 2025-003
    Material Weakness Repeat
  • 1238854 2025-004
    Material Weakness Repeat
  • 1238855 2025-004
    Material Weakness Repeat
  • 1238856 2025-004
    Material Weakness Repeat
  • 1238857 2025-004
    Material Weakness Repeat
  • 1238858 2025-004
    Material Weakness Repeat
  • 1238859 2025-004
    Material Weakness Repeat
  • 1238860 2025-004
    Material Weakness Repeat
  • 1238861 2025-005
    Material Weakness Repeat
  • 1238862 2025-005
    Material Weakness Repeat
  • 1238863 2025-005
    Material Weakness Repeat
  • 1238864 2025-005
    Material Weakness Repeat
  • 1238865 2025-005
    Material Weakness Repeat
  • 1238866 2025-005
    Material Weakness Repeat
  • 1238867 2025-006
    Material Weakness Repeat
  • 1238868 2025-006
    Material Weakness Repeat
  • 1238869 2025-007
    Material Weakness Repeat
  • 1238870 2025-007
    Material Weakness Repeat
  • 1238871 2025-008
    Material Weakness Repeat
  • 1238872 2025-008
    Material Weakness Repeat
  • 1238873 2025-009
    Material Weakness Repeat
  • 1238874 2025-009
    Material Weakness Repeat
  • 1238875 2025-010
    Material Weakness Repeat
  • 1238877 2025-011
    Material Weakness Repeat
  • 1238878 2025-011
    Material Weakness Repeat
  • 1238879 2025-012
    Material Weakness Repeat
  • 1238880 2025-012
    Material Weakness Repeat
  • 1238881 2025-013
    Material Weakness Repeat
  • 1238882 2025-013
    Material Weakness Repeat
  • 1238883 2025-014
    Material Weakness Repeat
  • 1238884 2025-014
    Material Weakness Repeat
  • 1238885 2025-015
    Material Weakness Repeat
  • 1238886 2025-015
    Material Weakness Repeat
  • 1238887 2025-016
    Material Weakness Repeat
  • 1238888 2025-016
    Material Weakness Repeat
  • 1238889 2025-017
    Material Weakness Repeat
  • 1238890 2025-017
    Material Weakness Repeat
  • 1238891 2025-018
    Material Weakness Repeat
  • 1238892 2025-018
    Material Weakness Repeat
  • 1238893 2025-019
    Material Weakness Repeat
  • 1238894 2025-019
    Material Weakness Repeat
  • 1238895 2025-019
    Material Weakness Repeat
  • 1238896 2025-019
    Material Weakness Repeat
  • 1238897 2025-019
    Material Weakness Repeat
  • 1238898 2025-019
    Material Weakness Repeat
  • 1238899 2025-019
    Material Weakness Repeat
  • 1238900 2025-019
    Material Weakness Repeat
  • 1238901 2025-020
    Material Weakness Repeat
  • 1238902 2025-020
    Material Weakness Repeat
  • 1238903 2025-020
    Material Weakness Repeat
  • 1238904 2025-020
    Material Weakness Repeat
  • 1238905 2025-020
    Material Weakness Repeat
  • 1238906 2025-020
    Material Weakness Repeat
  • 1238907 2025-020
    Material Weakness Repeat
  • 1238908 2025-020
    Material Weakness Repeat
  • 1238909 2025-021
    Material Weakness Repeat
  • 1238910 2025-021
    Material Weakness Repeat
  • 1238911 2025-021
    Material Weakness Repeat
  • 1238912 2025-021
    Material Weakness Repeat
  • 1238913 2025-021
    Material Weakness Repeat
  • 1238914 2025-022
    Material Weakness Repeat
  • 1238915 2025-022
    Material Weakness Repeat
  • 1238916 2025-022
    Material Weakness Repeat
  • 1238917 2025-023
    Material Weakness Repeat
  • 1238918 2025-023
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.010 TITLE I GRANTS TO LOCAL EDUCATIONAL AGENCIES 2024 $11.75M
10.555 NATIONAL SCHOOL LUNCH PROGRAM 2024 $9.52M
84.010 TITLE I GRANTS TO LOCAL EDUCATIONAL AGENCIES 2025 $8.27M
10.555 NATIONAL SCHOOL LUNCH PROGRAM 2025 $8.02M
84.027 SPECIAL EDUCATION GRANTS TO STATES 2025 $4.53M
84.374 TEACHER AND SCHOOL LEADER INCENTIVE GRANTS (FORMERLY THE TEACHER INCENTIVE FUND) 2024 $3.40M
10.553 SCHOOL BREAKFAST PROGRAM 2024 $3.00M
10.553 SCHOOL BREAKFAST PROGRAM 2025 $2.41M
84.334 GAINING EARLY AWARENESS AND READINESS FOR UNDERGRADUATE PROGRAMS 2024 $1.83M
84.184 SCHOOL SAFELY NATIONAL ACTIVITIES 2024 $1.69M
84.334 GAINING EARLY AWARENESS AND READINESS FOR UNDERGRADUATE PROGRAMS 2025 $1.63M
84.367 SUPPORTING EFFECTIVE INSTRUCTION STATE GRANTS (FORMERLY IMPROVING TEACHER QUALITY STATE GRANTS) 2024 $1.11M
84.336 TEACHER QUALITY PARTNERSHIP GRANTS 2024 $1.05M
84.336 TEACHER QUALITY PARTNERSHIP GRANTS 2025 $1.01M
10.558 CHILD AND ADULT CARE FOOD PROGRAM 2024 $957,987
84.011 MIGRANT EDUCATION STATE GRANT PROGRAM 2024 $929,569
84.215 INNOVATIVE APPROACHES TO LITERACY; PROMISE NEIGHBORHOODS; FULL-SERVICE COMMUNITY SCHOOLS; AND CONGRESSIONALLY DIRECTED SPENDING FOR ELEMENTARY AND SECONDARY EDUCATION COMMUNITY PROJECTS 2024 $910,537
97.036 DISASTER GRANTS - PUBLIC ASSISTANCE (PRESIDENTIALLY DECLARED DISASTERS) 2024 $881,458
84.184 SCHOOL SAFELY NATIONAL ACTIVITIES 2025 $855,321
84.051 CAREER AND TECHNICAL EDUCATION -- NATIONAL PROGRAMS 2025 $839,868
10.558 CHILD AND ADULT CARE FOOD PROGRAM 2025 $707,849
84.424 STUDENT SUPPORT AND ACADEMIC ENRICHMENT PROGRAM 2024 $698,029
32.004 UNIVERSAL SERVICE FUND - SCHOOLS AND LIBRARIES 2024 $689,885
84.011 MIGRANT EDUCATION STATE GRANT PROGRAM 2025 $639,019
84.215 INNOVATIVE APPROACHES TO LITERACY; PROMISE NEIGHBORHOODS; FULL-SERVICE COMMUNITY SCHOOLS; AND CONGRESSIONALLY DIRECTED SPENDING FOR ELEMENTARY AND SECONDARY EDUCATION COMMUNITY PROJECTS 2025 $610,051
93.778 GRANTS TO STATES FOR MEDICAID 2024 $518,707
84.424 STUDENT SUPPORT AND ACADEMIC ENRICHMENT PROGRAM 2025 $456,802
84.367 SUPPORTING EFFECTIVE INSTRUCTION STATE GRANTS (FORMERLY IMPROVING TEACHER QUALITY STATE GRANTS) 2025 $408,733
93.778 GRANTS TO STATES FOR MEDICAID 2025 $402,182
84.048 CAREER AND TECHNICAL EDUCATION -- BASIC GRANTS TO STATES 2024 $346,769
84.027 SPECIAL EDUCATION GRANTS TO STATES 2024 $340,862
84.365 ENGLISH LANGUAGE ACQUISITION STATE GRANTS 2024 $328,319
84.048 CAREER AND TECHNICAL EDUCATION -- BASIC GRANTS TO STATES 2025 $308,148
10.559 SUMMER FOOD SERVICE PROGRAM FOR CHILDREN 2025 $270,301
32.004 UNIVERSAL SERVICE FUND - SCHOOLS AND LIBRARIES 2025 $262,809
10.559 SUMMER FOOD SERVICE PROGRAM FOR CHILDREN 2024 $217,903
84.002 ADULT EDUCATION - BASIC GRANTS TO STATES 2024 $209,421
84.365 ENGLISH LANGUAGE ACQUISITION STATE GRANTS 2025 $206,296
84.002 ADULT EDUCATION - BASIC GRANTS TO STATES 2025 $146,692
84.374 TEACHER AND SCHOOL LEADER INCENTIVE GRANTS (FORMERLY THE TEACHER INCENTIVE FUND) 2025 $131,008
93.566 REFUGEE AND ENTRANT ASSISTANCE STATE/REPLACEMENT DESIGNEE ADMINISTERED PROGRAMS 2024 $120,657
84.173 SPECIAL EDUCATION PRESCHOOL GRANTS 2025 $114,612
84.425 EDUCATION STABILIZATION FUND 2025 $78,748
93.243 SUBSTANCE ABUSE AND MENTAL HEALTH SERVICES PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE 2024 $57,647
84.196 EDUCATION FOR HOMELESS CHILDREN AND YOUTH 2025 $35,554
84.051 CAREER AND TECHNICAL EDUCATION -- NATIONAL PROGRAMS 2024 $29,386
84.425 EDUCATION STABILIZATION FUND 2024 $27,119
93.566 REFUGEE AND ENTRANT ASSISTANCE STATE/REPLACEMENT DESIGNEE ADMINISTERED PROGRAMS 2025 $26,191
10.582 FRESH FRUIT AND VEGETABLE PROGRAM 2024 $13,468
84.173 SPECIAL EDUCATION PRESCHOOL GRANTS 2024 $7,749