Finding Text
Finding Number: 2023-003
Prior Year Finding: No
Federal Agency: U.S. Department of Education
Federal Program: Title I, Part A
Assistance Listing: 84.010
Pass-Through Entity: Maryland State Department of Education
Pass-Through Award Number and Period: 201310-01 (7/1/19 – 9/30/21) 231095-01 (7/1/22 – 9/30/24)
211116-01 (7/1/20 – 9/30/22) 211303-01 (7/1/20 – 9/30/22)
221499-01 (7/1/21 – 9/30/23) 221769-01 (7/1/21 – 9/30/22)
Compliance Requirement: Special Test
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or Specific Requirement
Compliance: Per section 1115(c) of the ESEA (20 USC 6315(c)), an LEA, after timely and meaningful consultation with private school officials, must provide equitable services to eligible private school children, their teachers, and their families. Eligible private school children are those who reside in a participating public school attendance area and have educational needs.
Control: Per 2 CFR section 200.303(a), a non-Federal entity must: 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 comply with the 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).
Condition/Context
The Board is required to verify the eligibility of private school children prior to providing equitable services under the grant. Eligible private school children are those who reside in a participating public school attendance area and have educational needs. We noted 1 out of 8 students tested where the student was ineligible to receive services per the limitations noted above.
Questioned Costs
Undeterminable.
Cause
The student participation process does not include matching the student’s address and current grade level to a Title I attendance area for eligibility determination. Effect
Students could be included in the equitable services calculations that should be excluded based on their school attendance zone.
Recommendation
We recommend that the Board revises the Student Participation process to include a step that includes matching the student grade level to the corresponding school type and a step to include a second review of the Title I School eligibility address and school type by a second staff member.
Views of Responsible Officials
Management agrees with the finding.