Finding Text
Finding 2023-001
Information on the federal program:
Subject: Special Education Cluster - Earmarking
Federal Agency: Department of Education
Federal Programs: Special Education Grants to States, Special Education Preschool Grants
Assistance Listings Numbers: 84.027, 84.173
Federal Award Numbers: 20611-054-PN01, 20619-054-PN01, 21611-054-PN01, 21619-054-PN01
Pass-Through Entity: Indiana Department of Education
Compliance Requirement: Matching, Level of Effort, Earmarking
Audit Findings: Significant Deficiency
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 awards 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:…
(g) Be adequately documented...."
511 IAC 7-34-7(b) states:
"The public agency, in providing special education and related services to students in nonpublic schools
must expend at least an amount that is the same proportion of the public agency total subgrant under 20
U.S.C. 1411(f) as the number of nonpublic school students with disabilities, who are enrolled by their
parents in nonpublic schools within its boundaries, is to the total number of students with disabilities of the
same age range."
Condition: The School Corporation did not have internal controls in place to ensure that the Cooperative
complied with the earmarking requirements. The Cooperative did not have adequate procedures in place
to ensure that the required level of expenditures for non-public school students with disabilities was met for
each member school. The Cooperative did not have effective internal controls to ensure non-public school
expenditures were appropriately identified and reported.
Cause: A proper system of internal control 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 control
system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance.
As a result, it could not be determined if each school spent their required earmarking dollars.
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.
Context: The School Corporation is a member of the Wabash Miami Area Programs for Exceptional
Children (Cooperative). During fiscal year 2021-2022 and 2022-2023, the Cooperative operated the special
education programs and spent the federal money on behalf of all its members. As the grant agreements
were between the Indiana Department of Education (IDOE) and each member school, the School
Corporation was responsible for ensuring and providing oversight of the Cooperative. However, there was
inadequate oversight performed by the School Corporation in order to ensure compliance with the Matching,
Level of Effort, Earmarking compliance requirement.
The Non-Public Proportionate Share expenditures for the 20611-054-PN01, 20619-054-PN01, 21611-054-
PN01, and 21619-054-PN01 grant awards could not be verified for the individual member schools. The
non-public school share funds for all member schools were comingled and the aggregate amount of
expenditures was then allocated to the member schools on a percentage basis. These allocations were the
amounts reported to IDOE. As such, we were unable to identify which expenditures were for each school
in order to verify the minimum amount per the grant award was expended and properly reported to IDOE
as required.
The School Corporation’s minimum, nonpublic earmarking requirement for grant awards 20611-054-PN01
and 21611-054-PN01 was $1,643 and $7,941, respectively. The School Corporation did not have any
minimum, nonpublic earmarking requirement for the 20619-054-PN01 and 21619-054-PN01 grant awards.
The lack of internal controls and noncompliance were isolated to the 20611-054-PN01, 20619-054-PN01,
21611-054-PN01, and 21619-054-PN01 grant awards.
Identification as a repeat finding: No.
Recommendation: We recommended that management of the School Corporation establish a proper
system of internal control and develop policies and procedures to ensure non-public proportionate share
funds are appropriately allocated to the member school based on expenses charged directly on behalf of
the member school. Supporting documentation for these expenses should be retained for audit.
Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding
and has prepared a corrective action plan.