Finding Text
FINDING 2023-002
Subject: Emergency Connectivity Fund Program - Activities Allowed or Unallowed,
Allowable Costs/Cost Principles, Period of Performance
Federal Agency: Federal Communications Commission
Federal Program: Emergency Connectivity Fund Program
Assistance Listings Number: 32.009
Federal Award Number and Year (or Other Identifying Number): ECF 222119178
Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/
Cost Principles, Period of Performance
Audit Finding: Material Weakness
Condition and Context
The School Corporation had not properly designed or implemented a system of internal controls,
which would include appropriate segregation of duties that would likely be effective in preventing, or
detecting and correcting, noncompliance related to Emergency Connectivity Fund (ECF) Program expenditures.
Allowable ECF Program expenditures were devices or services used primarily for off-campus educational
purposes by students or school staff with otherwise unmet need. Approved eligible equipment and
services requested during the first two application filing windows were to be received or delivered between
July 1, 2021 and June 30, 2023.
The School Corporation completed two reimbursement requests and submitted them online;
however, there was no evidence of an oversight or review process to ensure that the expenses included
on the reimbursement requests were for allowable devices, adequately supported with invoices, and
received within the applicable time window.
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
A proper system of internal controls was not designed by management of the School Corporation,
which would include segregation of key functions. Embedded within a properly designed and implemented
internal control system should be internal controls consisting of policies and procedures. Policies reflect
the School Corporation's management of what should be done to effect internal controls, and procedures
should consist of actions that would implement these policies.
INDIANA STATE BOARD OF ACCOUNTS
19
METROPOLITAN SCHOOL DISTRICT OF DECATUR TOWNSHIP
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
(Continued)
Effect
Without the proper design or implementation of the components of a system of internal controls,
including policies and procedures that provide segregation of duties and additional oversight as needed,
the internal control system cannot be capable of effectively preventing, or detecting and correcting, material
noncompliance.
Questioned Costs
There were no questioned costs identified.
Recommendation
We recommended that management of the School Corporation design and implement a proper
system of internal controls, including policies and procedures that would provide segregation of duties to
ensure appropriate reviews, approvals, and oversight are taking place.
Views of Responsible Officials
For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.