Finding 371369 (2023-004)

Material Weakness
Requirement
G
Questioned Costs
-
Year
2023
Accepted
2024-03-01

AI Summary

  • Core Issue: The School Corporation failed to earmark the required 20% of ESSER III funds for addressing learning loss, only spending 9% of the mandated amount.
  • Impacted Requirements: Noncompliance with federal regulations regarding earmarking and internal controls, risking future federal funding.
  • Recommended Follow-Up: Establish a robust internal control system and develop clear policies and procedures to ensure compliance with earmarking requirements.

Finding Text

FINDING 2023-004 Subject: COVID-19 - Education Stabilization Fund - Earmarking Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Number: 84.425U Federal Award Number and Year (or Other Identifying Number): S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking Audit Findings: Material Weakness, Modified Opinion INDIANA STATE BOARD OF ACCOUNTS 22 CULVER COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Condition and Context Local educational agencies that receive funds under the American Rescue Plan - Elementary and Secondary School Emergency Relief Fund (ESSER III) are to reserve not less than 20 percent of the funds to address learning loss through the implementation of evidence-based interventions, such as summer learning or summer enrichment, extended day, comprehensive afterschool programs, or extended school year programs, and ensure that such interventions respond to students' academic, social, and emotional needs and address the disproportionate impact of the coronavirus on the student subgroups. This requirement was set out in the enabling legislation for the funds and further implemented in the Education Stabilization Relief Fund Application III, which the School Corporation was required to complete for its award. As the School Corporation fully expended its ESSER III award during the audit period, earmarking was tested. The School Corporation, per its application, was required to set aside a total of $329,358 of ESSER III grant funds to be used to provide additional opportunities to students including summer school, career coach, and a social emotional academic learning liaison. Of the grant proceeds received by the School Corporation, a total of $27,840 was expended towards the established set aside. Therefore, only 9 percent of the required 20 percent minimum earmarking requirement was spent. The remaining set aside amount, $301,518, that was requested for reimbursement, was spent on activities that were not a part of the earmarking requirement. The lack of internal controls and noncompliance was isolated to the ESSER III grant noted above. 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 200.208(b) states in part: "The Federal awarding agency or pass-through entity may adjust specific Federal award conditions as needed. . . ." Section 2001(e)(1) of the ARP Act states in part: "A local educational agency that receives funds under this section— (1) shall reserve not less than 20 percent of such funds to address learning loss through the implementation of evidence-based interventions, such as summer learning or summer enrichment, extended day, comprehensive afterschool programs, or extended school year programs, and ensure that such interventions respond to students' academic, social, and emotional needs and address the disproportionate impact of the coronavirus on the student subgroups . . ." INDIANA STATE BOARD OF ACCOUNTS 23 CULVER COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Cause A proper system of internal controls was not designed by management of the School Corporation. 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 statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. 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, the required set-aside was not spent by the School Corporation. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure required earmarking requirements are met. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

Categories

Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 371355 2023-002
    Material Weakness
  • 371356 2023-002
    Material Weakness
  • 371357 2023-002
    Material Weakness
  • 371358 2023-002
    Material Weakness
  • 371359 2023-002
    Material Weakness
  • 371360 2023-002
    Material Weakness
  • 371361 2023-002
    Material Weakness
  • 371362 2023-003
    Material Weakness
  • 371363 2023-003
    Material Weakness
  • 371364 2023-003
    Material Weakness
  • 371365 2023-003
    Material Weakness
  • 371366 2023-003
    Material Weakness
  • 371367 2023-004
    Material Weakness
  • 371368 2023-004
    Material Weakness
  • 371370 2023-005
    Material Weakness
  • 371371 2023-005
    Material Weakness
  • 371372 2023-005
    Material Weakness
  • 371373 2023-006
    Material Weakness Repeat
  • 371374 2023-006
    Material Weakness Repeat
  • 371375 2023-006
    Material Weakness Repeat
  • 371376 2023-006
    Material Weakness Repeat
  • 371377 2023-006
    Material Weakness Repeat
  • 371378 2023-006
    Material Weakness Repeat
  • 371379 2023-007
    Material Weakness
  • 371380 2023-007
    Material Weakness
  • 371381 2023-007
    Material Weakness
  • 947797 2023-002
    Material Weakness
  • 947798 2023-002
    Material Weakness
  • 947799 2023-002
    Material Weakness
  • 947800 2023-002
    Material Weakness
  • 947801 2023-002
    Material Weakness
  • 947802 2023-002
    Material Weakness
  • 947803 2023-002
    Material Weakness
  • 947804 2023-003
    Material Weakness
  • 947805 2023-003
    Material Weakness
  • 947806 2023-003
    Material Weakness
  • 947807 2023-003
    Material Weakness
  • 947808 2023-003
    Material Weakness
  • 947809 2023-004
    Material Weakness
  • 947810 2023-004
    Material Weakness
  • 947811 2023-004
    Material Weakness
  • 947812 2023-005
    Material Weakness
  • 947813 2023-005
    Material Weakness
  • 947814 2023-005
    Material Weakness
  • 947815 2023-006
    Material Weakness Repeat
  • 947816 2023-006
    Material Weakness Repeat
  • 947817 2023-006
    Material Weakness Repeat
  • 947818 2023-006
    Material Weakness Repeat
  • 947819 2023-006
    Material Weakness Repeat
  • 947820 2023-006
    Material Weakness Repeat
  • 947821 2023-007
    Material Weakness
  • 947822 2023-007
    Material Weakness
  • 947823 2023-007
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
84.425 Education Stabilization Fund Fy2023 $1.25M
10.555 National School Lunch Program Fy2023 $439,523
10.555 National School Lunch Program Fy2022 $428,372
84.425 Education Stabilization Fund Fy2022 $325,779
84.010 Title I Grants to Local Educational Agencies Fy2022 $231,897
84.010 Title I Grants to Local Educational Agencies Fy2023 $217,677
10.553 School Breakfast Program Fy2022 $117,131
10.553 School Breakfast Program Fy2023 $89,327
84.027 Special Education_grants to States Fy2022 $71,834
93.778 Medical Assistance Program Fy2023 $64,052
84.367 Improving Teacher Quality State Grants Fy2022 $60,278
10.559 Summer Food Service Program for Children Fy2022 $51,397
84.367 Improving Teacher Quality State Grants Fy2023 $39,006
93.778 Medical Assistance Program Fy2022 $33,924
10.579 Child Nutrition Discretionary Grants Limited Availability Fy2022 $30,000
84.424 Student Support and Academic Enrichment Program Fy2022 $23,567
10.582 Fresh Fruit and Vegetable Program Fy2023 $18,892
10.559 Summer Food Service Program for Children Fy2023 $14,786
84.027 Special Education_grants to States Fy2023 $9,646
10.649 Pandemic Ebt Administrative Costs Fy2023 $628
10.649 Pandemic Ebt Administrative Costs Fy2022 $614