Finding 384572 (2023-008)

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

AI Summary

  • Core Issue: The School Corporation failed to monitor required set-asides for homeless students and lacked oversight for vendor expenditures, leading to systemic noncompliance.
  • Impacted Requirements: Noncompliance with federal regulations regarding matching funds, level of effort, and earmarking under Title I grants.
  • Recommended Follow-Up: Implement a robust internal control system with clear policies and procedures to ensure proper oversight and compliance with federal requirements.

Finding Text

FINDING 2023-008 Subject: Title I Grants to Local Educational Agencies - Matching, Level of Effort, Earmarking 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: Matching, Level of Effort, Earmarking Audit Findings: Material Weakness, Other Matters Condition and Context Earmarking A portion of the School Corporation's Title I allocation was required to be set aside for homeless reservation. The required amount to be set aside was indicated in the Title I grant application. The School Corporation is responsible for monitoring each required set aside throughout the life of the grant to ensure the obligation is met. There was no oversight or review process in place to ensure monitoring of each required set aside. The School Corporation did not provide documentation to show that the obligation was met, or not met, to service all the homeless students in the School Corporation and did not transfer the unused funds to the next grant award. Level of Effort - Individual Transactions (Vendor) The Form 9 (financial) data was submitted by the School Corporation to the Indiana Department of Education (IDOE) semi-annually. The data reported included the School Corporation's expenditures recorded during that period. The IDOE calculated Maintenance of Effort based on the expenditure information submitted on the Form 9 for that fiscal year. To verify amounts used by the IDOE in their computation were derived from the books and records of the School Corporation, costs were reviewed to ensure they were recorded properly as to account and object code and reported correctly on the Form 9. The School Corporation did not have an oversight process in place to ensure that expenditures for vendor were posted to the correct fund, account, and object codes. 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). . . ." 20 USC 6313I(3)(A) states: "A local educational agency shall reserve such funds as are necessary under this part, determined in accordance with subparagraphs (B) and (C), to provide services comparable to those provided to children in schools funded under this part to serve— (i) homeless children and youths, including providing educationally related support services to children in shelters and other locations where children may live; (ii) children in local institutions for neglected children; and (iii) if appropriate, children in local institutions for delinquent children, and neglected or delinquent children in community day programs." Cause A proper system of internal controls, which would include segregation of key functions, 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 the obligation to service homeless students was met or unmet. 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

Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties Subrecipient Monitoring

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
  • 384570 2023-007
    Material Weakness
  • 384571 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