Finding Text
FINDING 2023-001
Information on the federal program:
Subject: Special Education Cluster (IDEA) – Suspension and Debarment
Federal Agency: Department of Education
Federal Program: Special Education Grants to States, Special Education Preschool Grants
Assistance Listing Numbers: 84.027, 84.027X, 84.173, 84.173X
Federal Award Numbers and Years (Or Other Identifying Number): 21611-095-PN01, 22611-095-PN01,
22611-095-ARP, 23611-095-PN01, 22619-095-PN01, 23619-095-PN01, 22619-095-ARP
Pass-Through Entity: Indiana Department of Education
Compliance Requirement: Procurement and Suspension and Debarment
Audit Finding: Material Weakness
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). . . ."
2 CFR 180.300 states:
"When you enter into a covered transaction with another person at the next lower tier, you must verify that
the person with whom you intend to do business is not excluded or disqualified.
You do this by:
(a) Checking the SAM Exclusions; or
(b) Collecting a certification from that person; or
(c) Adding a clause or condition to the covered transaction with that person."
Condition: An effective internal control system was not in place at the School Corporation to ensure
compliance with requirements related to the grant agreements and Procurement and Suspension and
Debarment compliance requirements.
Cause: The School Corporation's management had not developed a system of internal controls that would
have ensured compliance with the Procurement and Suspension and Debarment compliance requirement.
Effect: The failure to establish internal controls enabled noncompliance to go undetected. The failure to
comply with the grant agreement and the compliance requirement could have resulted in the loss of federal
funds to the School Corporation.
Questioned Costs: There were no questioned costs identified.
Context: During the audit period, the School Corporation had purchases over $25,000 from one vendor
charged to the Special Education Cluster grants which requires suspension and debarment procedures.
For the vendor selected for testing, there was no evidence provided to verify that the vendor was checked
for suspension and debarment prior to entering into the transaction. The total amount disbursed to the
vendor during the audit period was $113,921.
Identification as a repeat finding, if applicable: No.
Recommendation: We recommended that the School Corporation's management establish and implement
control procedures to ensure compliance with the grant agreement and the Procurement and Suspension
and Debarment compliance requirement. This should include verifying suspension and debarment status,
obtaining a certification from the vendor, or adding a clause or condition to the contract with the vendor
prior to entering into the transaction.
Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding
and has prepared a corrective action plan.