Finding 1238916 (2025-022)

Material Weakness Repeat Finding
Requirement
L
Questioned Costs
-
Year
2025
Accepted
2026-09-30

AI Summary

  • Core Issue: The School Corporation has repeated issues with inaccurate reimbursement requests for the Education Stabilization Fund, specifically with 7 out of 15 requests being unsupported.
  • Impacted Requirements: Noncompliance with federal regulations regarding internal controls and financial reporting, as outlined in 2 CFR 200.303 and 200.302(b).
  • Recommended Follow-Up: Implement a robust internal control system, improve staff training on federal requirements, and establish standardized documentation policies to ensure accurate financial reporting.

Finding Text

FINDING 2025-022 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Number: 84.425U Federal Award Number (or Other Identifying Number): S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2023-010. Condition and Context During the audit period, the School Corporation received 36 total reimbursements related to the Education Stabilization Fund grant. The School Corporation received 2 ESSER I reimbursements, 8 ESSER II reimbursements, 16 ESSER III reimbursements, and 10 ARP HCY reimbursements. A sample of 15 reimbursements request forms were tested against the School Corporations records for accuracy. Of the 15 reimbursement requests forms tested, 7 totaling $9,583,074 were not supported by the School Corporation's records. The errors detected were isolated to the ESSER III grant. The lack of internal controls and noncompliance were systemic throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: INDIANA STATE BOARD OF ACCOUNTS 68 SOUTH BEND COMMUNITY SCHOOL CORPORATION 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). . . ." 2 CFR 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following. . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Cause The School Corporation did not establish or implement a properly designed internal control system, including appropriate segregation of duties, to ensure the accuracy and reliability of financial data submitted to the Indiana Department of Education. The absence of formal review procedures, oversight mechanisms, and reconciliation processes resulted in the submission of materially misstated reimbursement requests. Contributing factors included inadequate staff training on federal reporting requirements, the lack of documented financial reporting policies, and insufficient allocation of resources to monitor compliance with grant guidelines. Effect As a result, 7 out of 15 reimbursement request forms tested during the audit period were either overstated or understated, reflecting inconsistent and inaccurate financial reporting tied to federal grant activity. These systemic errors represent significant noncompliance and undermine the reliability of reporting used for state and federal oversight. Questioned Costs There were no questioned costs identified. INDIANA STATE BOARD OF ACCOUNTS 69 SOUTH BEND COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Recommendation The School Corporation should strengthen its financial reporting processes related to federal grant activity by implementing a formal internal control system that ensures accuracy, consistency, and proper documentation. This includes reconciling financial records with data submitted through JotForm, establishing review procedures for reimbursement requests, and assigning qualified personnel to verify all reports prior to submission. Staff responsible for grant management and financial reporting should receive necessary support and resources regarding federal documentation standards and reporting requirements. The School Corporation should adopt standardized documentation policies and procedures across all departments to ensure compliance and oversight. 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

CORRECTIVE ACTION PLAN FINDING 2025-022 Finding Subject: Education Stabilization Fund – Reporting Contact Person Responsible for Corrective Action: Darice Austin-Phillips, Ahnaf Tahmid & Marlaina Johns Contact Phone Number and Email Address: 574-393-6000, daustin@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: Internal Control Manual: Released a comprehensive manual covering segregation of duties, purchasing, and grant management. Reimbursement & Reporting Oversight: Added explicit supervisor review signatures to grant packet supporting documents and financial reports prior to final agency submission. Anticipated Completion Date: Grant Ended: December 2025 IC Updates: January 1, 2025

Categories

Internal Control / Segregation of Duties Subrecipient Monitoring

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
  • 1238876 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
  • 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