Finding 380592 (2023-007)

Material Weakness
Requirement
B
Questioned Costs
$1
Year
2023
Accepted
2024-03-15

AI Summary

  • Core Issue: Lack of internal controls over payroll disbursements led to unsubstantiated costs, including $1,094 in questioned costs.
  • Impacted Requirements: Noncompliance with 2 CFR 200.303 and 2 CFR 200.403 regarding effective internal controls and documentation of personnel expenses.
  • Recommended Follow-Up: Management should implement a robust internal control system and develop clear policies and procedures for cost documentation.

Finding Text

FINDING 2023-007 Subject: COVID-19 - Education Stabilization Fund - Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Allowable Costs/Cost Principles Audit Findings: Material Weakness, Other Matters Condition and Context The Elementary and Secondary School Emergency Relief (ESSER) Fund provided funding to states and school districts to combat the effects of the coronavirus, help safely reopen and sustain the safe operation of schools, and to address the impact of the coronavirus pandemic on the nation's students. States were required to subgrant a portion of their ESSER allocation to Local Educational Agencies (LEA). Prior to the LEAs receiving their respective subgrants, the LEAs were required to complete an application for ARP ESSER funding, which was submitted to the Indiana Department of Education, the pass-through entity for approval. The application included a district level budget identifying how the LEA intended to spend program funds. The School Corporation did not have internal controls in place over payroll disbursements charged to the ESSER grant funds. Payroll disbursements were paid without evidence that the detailed report of payroll disbursements was reviewed and approved by another person not involved in the original payroll process. Additionally, a sample of 40 payroll disbursements were selected for testing. For 1 payroll disbursement selected for testing, the employee's timesheet could not be provided. As such, we could not substantiate the amount paid, $1,094, out of the grant funds. This amount was considered questioned costs. The lack of internal controls and noncompliance were systemic issues 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). . . ." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: INDIANA STATE BOARD OF ACCOUNTS 27 MADISON-GRANT UNITED SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. . . . (g) Be adequately documented. . . ." 2 CFR 200.430(i) states in part: "Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities (for IHE, this per the IHE's definition of IBS); . . . (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which allocated using different allocation bases; or an unallowable activity and a direct or indirect costs activity. . . ." 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 statements of what should be done to effect internal control, 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, payroll charges could not be substantiated. Questioned Costs Known questioned costs of $1,094 were identified as noted in the Condition and Context. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure costs are adequately documented. INDIANA STATE BOARD OF ACCOUNTS 28 MADISON-GRANT UNITED SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

Categories

Questioned Costs Allowable Costs / Cost Principles

Other Findings in this Audit

  • 380557 2023-002
    Material Weakness Repeat
  • 380558 2023-002
    Material Weakness Repeat
  • 380559 2023-002
    Material Weakness Repeat
  • 380560 2023-002
    Material Weakness Repeat
  • 380561 2023-002
    Material Weakness Repeat
  • 380562 2023-002
    Material Weakness Repeat
  • 380563 2023-003
    Material Weakness
  • 380564 2023-003
    Material Weakness
  • 380565 2023-003
    Material Weakness
  • 380566 2023-003
    Material Weakness
  • 380567 2023-003
    Material Weakness
  • 380568 2023-003
    Material Weakness
  • 380569 2023-004
    Material Weakness Repeat
  • 380570 2023-004
    Material Weakness Repeat
  • 380571 2023-004
    Material Weakness Repeat
  • 380572 2023-004
    Material Weakness Repeat
  • 380573 2023-004
    Material Weakness Repeat
  • 380574 2023-004
    Material Weakness Repeat
  • 380575 2023-005
    Material Weakness
  • 380576 2023-005
    Material Weakness
  • 380577 2023-005
    Material Weakness
  • 380578 2023-005
    Material Weakness
  • 380579 2023-005
    Material Weakness
  • 380580 2023-005
    Material Weakness
  • 380581 2023-005
    Material Weakness
  • 380582 2023-006
    Material Weakness
  • 380583 2023-006
    Material Weakness
  • 380584 2023-006
    Material Weakness
  • 380585 2023-006
    Material Weakness
  • 380586 2023-006
    Material Weakness
  • 380587 2023-006
    Material Weakness
  • 380588 2023-006
    Material Weakness
  • 380589 2023-007
    Material Weakness
  • 380590 2023-007
    Material Weakness
  • 380591 2023-007
    Material Weakness
  • 380593 2023-007
    Material Weakness
  • 380594 2023-008
    Material Weakness
  • 380595 2023-008
    Material Weakness
  • 380596 2023-008
    Material Weakness
  • 380597 2023-008
    Material Weakness
  • 380598 2023-008
    Material Weakness
  • 380599 2023-009
    Material Weakness
  • 956999 2023-002
    Material Weakness Repeat
  • 957000 2023-002
    Material Weakness Repeat
  • 957001 2023-002
    Material Weakness Repeat
  • 957002 2023-002
    Material Weakness Repeat
  • 957003 2023-002
    Material Weakness Repeat
  • 957004 2023-002
    Material Weakness Repeat
  • 957005 2023-003
    Material Weakness
  • 957006 2023-003
    Material Weakness
  • 957007 2023-003
    Material Weakness
  • 957008 2023-003
    Material Weakness
  • 957009 2023-003
    Material Weakness
  • 957010 2023-003
    Material Weakness
  • 957011 2023-004
    Material Weakness Repeat
  • 957012 2023-004
    Material Weakness Repeat
  • 957013 2023-004
    Material Weakness Repeat
  • 957014 2023-004
    Material Weakness Repeat
  • 957015 2023-004
    Material Weakness Repeat
  • 957016 2023-004
    Material Weakness Repeat
  • 957017 2023-005
    Material Weakness
  • 957018 2023-005
    Material Weakness
  • 957019 2023-005
    Material Weakness
  • 957020 2023-005
    Material Weakness
  • 957021 2023-005
    Material Weakness
  • 957022 2023-005
    Material Weakness
  • 957023 2023-005
    Material Weakness
  • 957024 2023-006
    Material Weakness
  • 957025 2023-006
    Material Weakness
  • 957026 2023-006
    Material Weakness
  • 957027 2023-006
    Material Weakness
  • 957028 2023-006
    Material Weakness
  • 957029 2023-006
    Material Weakness
  • 957030 2023-006
    Material Weakness
  • 957031 2023-007
    Material Weakness
  • 957032 2023-007
    Material Weakness
  • 957033 2023-007
    Material Weakness
  • 957034 2023-007
    Material Weakness
  • 957035 2023-007
    Material Weakness
  • 957036 2023-008
    Material Weakness
  • 957037 2023-008
    Material Weakness
  • 957038 2023-008
    Material Weakness
  • 957039 2023-008
    Material Weakness
  • 957040 2023-008
    Material Weakness
  • 957041 2023-009
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
10.555 National School Lunch Program 2023 $550,440
10.555 National School Lunch Program 2022 $543,201
84.425 Education Stabilization Fund 2023 $517,866
84.425 Education Stabilization Fund 2022 $417,732
84.010 Title I Grants to Local Educational Agencies 2023 $263,779
84.010 Title I Grants to Local Educational Agencies 2022 $258,963
10.553 School Breakfast Program 2022 $128,915
10.553 School Breakfast Program 2023 $116,149
84.367 Improving Teacher Quality State Grants 2023 $45,784
84.367 Improving Teacher Quality State Grants 2022 $43,904
84.424 Student Support and Academic Enrichment Program 2022 $42,984
84.027 Special Education_grants to States 2023 $30,427
10.559 Summer Food Service Program for Children 2022 $28,442
84.424 Student Support and Academic Enrichment Program 2023 $15,655
84.173 Special Education_preschool Grants 2023 $9,445
10.559 Summer Food Service Program for Children 2023 $2,511
84.027 Special Education_grants to States 2022 $2,190
10.649 Pandemic Ebt Administrative Costs 2023 $628
10.649 Pandemic Ebt Administrative Costs 2022 $614
84.173 Special Education_preschool Grants 2022 $364