Finding 384561 (2023-005)

Material Weakness
Requirement
BI
Questioned Costs
-
Year
2023
Accepted
2024-03-26

AI Summary

  • Core Issue: The School Corporation lacks effective internal controls over federal awards, leading to non-compliance with cost principles and procurement regulations.
  • Impacted Requirements: Compliance with 2 CFR 200.303 is not met due to insufficient oversight and documentation in the approval process for expenses.
  • Recommended Follow-Up: Management should establish a robust internal control system with clear policies and procedures to ensure proper segregation of duties and oversight.

Finding Text

FINDING 2023-005 Subject: Special Education Cluster (IDEA) - Allowable Costs/Cost Principles, Procurement and Suspension and Debarment Federal Agency: Department of Education Federal Programs: Special Education Grants to States, COVID-19 - Special Education Grants to States, Special Education Preschool Grants, COVID-19 - Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.027X, 84.173, 84.173X Federal Award Numbers and Years (or Other Identifying Numbers): 19611-113-PN01, 20611-113-PN01, 21611-113-PN01, 21619-014-PN01, 22611-113-PN01, 22619-014-PN01, 23611-113-PN01, 23619-014-PN01, 22611-113-ARP, 22619-113-ARP Pass-Through Entity: Indiana Department of Education Compliance Requirements: Allowable Costs/Cost Principles, Procurement and Suspension and Debarment Audit Finding: Material Weakness Condition and Context Direct charges to a federal award are to be for allowable costs and made in conformance with the applicable cost principles. In addition, procurements under federal awards are to be made in compliance with applicable federal regulations and other procurement requirements specific to an award. The School Corporation's process to ensure an expense was for an allowable cost in conformance with the cost principles and procured appropriately was for the Deputy Treasurer or Grant Administrator to prepare an Accounts Payable Voucher (APV), and the Corporation Treasurer to review and approve the APV. To test the internal control for effectiveness, a sample of 40 APVs charged to the grant was selected for testing. For 9 of the 40 APVs tested, there was not a documented review by the Corporation Treasurer. As such, we determined the internal control as designed could not be effective at ensuring an expense was for an allowable cost in conformance with the cost principles and procured appropriately 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, which would include segregation of key functions, was not implemented 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 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.

Categories

Procurement, Suspension & Debarment Internal Control / Segregation of Duties Allowable Costs / Cost Principles

Other Findings in this Audit

  • 384554 2023-004
    Material Weakness Repeat
  • 384555 2023-004
    Material Weakness Repeat
  • 384556 2023-004
    Material Weakness Repeat
  • 384557 2023-004
    Material Weakness Repeat
  • 384558 2023-004
    Material Weakness Repeat
  • 384559 2023-004
    Material Weakness Repeat
  • 384560 2023-005
    Material Weakness
  • 384562 2023-005
    Material Weakness
  • 384563 2023-005
    Material Weakness
  • 384564 2023-005
    Material Weakness
  • 384565 2023-005
    Material Weakness
  • 384566 2023-005
    Material Weakness
  • 384567 2023-006
    Material Weakness Repeat
  • 384568 2023-006
    Material Weakness Repeat
  • 384569 2023-007
    Material Weakness
  • 384570 2023-007
    Material Weakness
  • 384571 2023-008
    Material Weakness
  • 384572 2023-008
    Material Weakness
  • 960996 2023-004
    Material Weakness Repeat
  • 960997 2023-004
    Material Weakness Repeat
  • 960998 2023-004
    Material Weakness Repeat
  • 960999 2023-004
    Material Weakness Repeat
  • 961000 2023-004
    Material Weakness Repeat
  • 961001 2023-004
    Material Weakness Repeat
  • 961002 2023-005
    Material Weakness
  • 961003 2023-005
    Material Weakness
  • 961004 2023-005
    Material Weakness
  • 961005 2023-005
    Material Weakness
  • 961006 2023-005
    Material Weakness
  • 961007 2023-005
    Material Weakness
  • 961008 2023-005
    Material Weakness
  • 961009 2023-006
    Material Weakness Repeat
  • 961010 2023-006
    Material Weakness Repeat
  • 961011 2023-007
    Material Weakness
  • 961012 2023-007
    Material Weakness
  • 961013 2023-008
    Material Weakness
  • 961014 2023-008
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
10.555 National School Lunch Program 2022 $1.36M
10.555 National School Lunch Program 2023 $1.33M
84.425 Education Stabilization Fund 2023 $556,140
84.010 Title I Grants to Local Educational Agencies 2022 $404,526
84.010 Title I Grants to Local Educational Agencies 2023 $404,429
10.553 School Breakfast Program 2022 $253,804
10.553 School Breakfast Program 2023 $234,279
84.367 Improving Teacher Quality State Grants 2022 $138,545
84.048 Career and Technical Education -- Basic Grants to States 2022 $123,553
84.425 Education Stabilization Fund 2022 $111,116
84.367 Improving Teacher Quality State Grants 2023 $106,552
84.048 Career and Technical Education -- Basic Grants to States 2023 $104,705
10.559 Summer Food Service Program for Children 2022 $82,234
84.027 Special Education_grants to States 2023 $76,041
84.424 Student Support and Academic Enrichment Program 2022 $62,216
10.559 Summer Food Service Program for Children 2023 $43,650
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) 2022 $35,814
84.424 Student Support and Academic Enrichment Program 2023 $23,496
93.778 Medical Assistance Program 2022 $22,814
93.778 Medical Assistance Program 2023 $18,506
84.173 Special Education_preschool Grants 2022 $13,891
84.365 English Language Acquisition State Grants 2022 $9,890
84.365 English Language Acquisition State Grants 2023 $7,721
84.027 Special Education_grants to States 2022 $4,226
10.649 Pandemic Ebt Administrative Costs 2023 $3,135
10.649 Pandemic Ebt Administrative Costs 2022 $3,063
84.173 Special Education_preschool Grants 2023 $811