Finding 384570 (2023-007)

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

AI Summary

  • Core Issue: The School Corporation failed to maintain proper internal controls over Title I eligibility, leading to a material weakness and inability to verify socioeconomic data in grant applications.
  • Impacted Requirements: Compliance with 2 CFR 200.303 and 200.334 regarding internal controls and record retention was not met, risking future federal funding.
  • Recommended Follow-Up: Management should establish a robust internal control system with clear policies and procedures to ensure accurate reporting and compliance.

Finding Text

FINDING 2023-007 Subject: Title I Grants to Local Educational Agencies - Eligibility Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listings Number: 84.010 Federal Award Numbers and Years (or Other Identifying Numbers): S010A200014, S010A210014, S010A220014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Findings: Material Weakness, Modified Opinion Condition and Context Eligibility for Title I is determined on the Eligible School Summary of the Tile I application. Enrollment and Poverty numbers are automatically pulled from the Indiana Department of Education's (IDOE) Official Pupil Enrollment (PE) count for each school into the Eligible School Summary page of the Tile I application. The counts that are pre-populated should be based on the School Corporation's records as of October of the prior fiscal year. During the audit period, the School Corporation submitted two Title I Applications. The School Corporation was required to use the October 2020 Real Time Report data for the 2021-2022 Title I application and the October 2021 Real Time Report data for the 2022-2023 Title I Application submitted to the IDOE. Data to be submitted included student socioeconomic status information. The October 2021 Real Time Report used for the 2022-2023 Title I Application, was not available for review. As such, we were unable to verify the amounts reported in the grant application. Additionally, we were unable to verify if the correct socioeconomic status was properly reported for any of the students. The lack of internal controls and noncompliance were isolated to the October 2021 Real Time Report and 2022-2023 Title I Application. 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 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 34 CFR 200.78(a)(1) states: "After reserving funds, as applicable, under § 200.77, including funds for equitable services for private school students, their teachers, and their families, an LEA must allocate funds under this subpart to school attendance areas and schools, identified as eligible and selected to participate under section 1113(a) or (b) of the ESEA, in rank order on the basis of the total number of public school children from low-income families in each area or school." 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, proper documentation was not maintained to ensure enrollment and poverty statues in the Title I Application were accurate. 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 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 to ensure compliance. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

Categories

Internal Control / Segregation of Duties Subrecipient Monitoring Eligibility Material Weakness Matching / Level of Effort / Earmarking Special Tests & Provisions

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
  • 384561 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
  • 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