Finding 28492 (2022-003)

Material Weakness
Requirement
E
Questioned Costs
-
Year
2022
Accepted
2023-03-30

AI Summary

  • Core Issue: The School Corporation lacked an effective internal control system to ensure compliance with Title I grant eligibility requirements.
  • Impacted Requirements: Compliance with 2 CFR 200.303 regarding internal controls over federal awards was not met, risking noncompliance with grant agreements.
  • Recommended Follow-Up: Management should implement a robust internal control system to monitor and verify eligibility determinations for Title I grants.

Finding Text

FINDING 2022-003 Subject: Title I Grants to Local Educational Agencies - Internal Controls 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): S010A200014, S010A210014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Finding: Material Weakness Condition and Context An effective internal control system was not designed, nor implemented at the School Corporation to ensure compliance with requirements related to the grant agreement and the Eligibility compliance requirement. Eligibility for Title I was determined on the Eligible School Summary of the Title I application. Enrollment and poverty numbers for the public school district were automatically pulled from Indiana Department of Education's (IDOE) Official Pupil Enrollment (PE) count for each school into the Eligible School Summary page of the Title I application. These numbers were used to calculate Percent Poverty, which was then used to rank schools for Title I eligibility. The percent poverty was calculated based on a student's socioeconomic status as determined on their Application for Free and Reduced Lunch. The School Corporation did not have an oversight or review process in place to ensure that the food service software company (Titan) accurately determined free and reduced lunch eligibility for all students that submitted an online application. Titan uploaded the income guidelines for free and reduced lunch for each school into the software; however, an individual at the School Corporation did not review the guidelines for accuracy. 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 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 Management had not designed or implemented a system of internal controls that would have ensured compliance with the grant agreement and the Eligibility compliance requirement. Effect The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the Eligibility compliance requirement. 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 Eligibility compliance requirement. 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 2022-003 Contact Person Responsible for Corrective Action: Kasey Clark Contact Phone Number: 574-772-1604 Views of Responsible Official: We concur with the findings. Description of Corrective Action Plan: The income guidelines will be uploaded into the food service system after printing off the government site and two people will have eyes on them and this has started for 2022/2023. Anticipated Completion Date: March 2023

Categories

Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties Subrecipient Monitoring Eligibility Material Weakness School Nutrition Programs

Other Findings in this Audit

  • 28493 2022-004
    Material Weakness
  • 28494 2022-005
    Material Weakness
  • 28495 2022-006
    Material Weakness
  • 28496 2022-003
    Material Weakness
  • 28497 2022-004
    Material Weakness
  • 28498 2022-005
    Material Weakness
  • 28499 2022-006
    Material Weakness
  • 28500 2022-007
    Material Weakness
  • 28501 2022-008
    Material Weakness
  • 28502 2022-009
    Material Weakness
  • 28503 2022-010
    Material Weakness
  • 28504 2022-007
    Material Weakness
  • 28505 2022-008
    Material Weakness
  • 28506 2022-009
    Material Weakness
  • 28507 2022-010
    Material Weakness
  • 28508 2022-008
    Material Weakness
  • 28509 2022-009
    Material Weakness
  • 28510 2022-010
    Material Weakness
  • 604934 2022-003
    Material Weakness
  • 604935 2022-004
    Material Weakness
  • 604936 2022-005
    Material Weakness
  • 604937 2022-006
    Material Weakness
  • 604938 2022-003
    Material Weakness
  • 604939 2022-004
    Material Weakness
  • 604940 2022-005
    Material Weakness
  • 604941 2022-006
    Material Weakness
  • 604942 2022-007
    Material Weakness
  • 604943 2022-008
    Material Weakness
  • 604944 2022-009
    Material Weakness
  • 604945 2022-010
    Material Weakness
  • 604946 2022-007
    Material Weakness
  • 604947 2022-008
    Material Weakness
  • 604948 2022-009
    Material Weakness
  • 604949 2022-010
    Material Weakness
  • 604950 2022-008
    Material Weakness
  • 604951 2022-009
    Material Weakness
  • 604952 2022-010
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
84.425 Education Stabilization Fund 22 $2.72M
10.555 National School Lunch Program 22 $856,037
84.027 Special Education_grants to States 22 $575,688
84.010 Title I Grants to Local Educational Agencies 21 $534,108
84.010 Title I Grants to Local Educational Agencies 22 $437,588
10.553 School Breakfast Program 22 $253,396
84.027 Special Education_grants to States 21 $204,394
10.559 Summer Food Service Program for Children 21 $148,860
84.425 Education Stabilization Fund 21 $116,185
10.555 National School Lunch Program 21 $101,298
84.367 Improving Teacher Quality State Grants 21 $73,206
84.358 Rural Education 22 $67,261
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) 22 $59,259
10.559 Summer Food Service Program for Children 22 $52,555
93.778 Medical Assistance Program 21 $50,141
84.367 Improving Teacher Quality State Grants 22 $49,417
93.778 Medical Assistance Program 22 $48,994
84.358 Rural Education 21 $47,951
84.424 Student Support and Academic Enrichment Program 21 $38,157
10.553 School Breakfast Program 21 $36,362
84.424 Student Support and Academic Enrichment Program 22 $21,766
84.173 Special Education_preschool Grants 22 $16,499
84.173 Special Education_preschool Grants 21 $16,453
10.558 Child and Adult Care Food Program 22 $7,399
10.558 Child and Adult Care Food Program 21 $5,987
84.334 Gaining Early Awareness and Readiness for Undergraduate Programs 21 $5,000
84.334 Gaining Early Awareness and Readiness for Undergraduate Programs 22 $1,200