Finding 385518 (2023-009)

Material Weakness
Requirement
C
Questioned Costs
-
Year
2023
Accepted
2024-03-27

AI Summary

  • Core Issue: The School Corporation lacks a proper internal control system, leading to potential noncompliance with cash management requirements.
  • Impacted Requirements: Compliance with 2 CFR 200.303 and 2 CFR 200.305(b) is compromised, risking future federal funding.
  • Recommended Follow-Up: Management should establish effective internal controls, including segregation of duties and proper documentation for reimbursement requests.

Finding Text

FINDING 2023-009 Subject: COVID-19 - Education Stabilization Fund - Cash Management Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Number: 84.425D Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Cash Management Audit Findings: Material Weakness, Modified Opinion Condition and Context The School Corporation had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance related to the Cash Management compliance requirement. INDIANA STATE BOARD OF ACCOUNTS 30 SILVER CREEK SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Reimbursement requests for the program were prepared by one employee and reviewed by another employee; however, no supporting documentation was provided to the reviewer. As documentation did not accompany the reimbursement request, and the reimbursement requests, as noted below, did not agree to the ledger, the reviewer could not have ensured expenses were paid prior to requesting reimbursement. Five reimbursement requests were submitted during the audit period. All five reimbursement requests were selected for testing. Of the five reimbursement requests tested, three were not traceable to the School Corporation's fund ledger. For those three reimbursement requests, the expenditures in the ledger exceeded the amount requested by $67,907, in total. However, as the expenditures could not be determined for each reimbursement requested, it could not be determined if the School Corporation paid for the expense prior to requesting reimbursement. The lack of internal controls and noncompliance were systemic issues throughout the audit period for ESSER I and ESSER II grant funds. 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 200.305(b) states in part: "For non-Federal entities other than states, payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means. . . . (3) Reimbursement is the preferred method when the requirements in paragraph (b) cannot be met, when the Federal awarding agency sets a specific condition per § 200.208, or when the non-Federal entity requests payment by reimbursement. . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . ." INDIANA STATE BOARD OF ACCOUNTS 31 SILVER CREEK SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 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, it could not be determined if all expenditures were paid by the School Corporation prior to requesting reimbursement. 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 prior to filing the reimbursement requests. 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 Cash Management Material Weakness Reporting Subrecipient Monitoring Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 385501 2023-002
    Material Weakness
  • 385502 2023-002
    Material Weakness
  • 385503 2023-003
    Material Weakness
  • 385504 2023-003
    Material Weakness
  • 385505 2023-004
    Material Weakness
  • 385506 2023-004
    Material Weakness
  • 385507 2023-005
    Material Weakness
  • 385508 2023-005
    Material Weakness
  • 385509 2023-006
    Material Weakness
  • 385510 2023-006
    Material Weakness
  • 385511 2023-007
    Material Weakness
  • 385512 2023-007
    Material Weakness
  • 385513 2023-008
    Material Weakness
  • 385514 2023-008
    Material Weakness
  • 385515 2023-008
    Material Weakness
  • 385516 2023-008
    Material Weakness
  • 385517 2023-009
    Material Weakness
  • 385519 2023-010
    Material Weakness
  • 385520 2023-010
    Material Weakness
  • 961943 2023-002
    Material Weakness
  • 961944 2023-002
    Material Weakness
  • 961945 2023-003
    Material Weakness
  • 961946 2023-003
    Material Weakness
  • 961947 2023-004
    Material Weakness
  • 961948 2023-004
    Material Weakness
  • 961949 2023-005
    Material Weakness
  • 961950 2023-005
    Material Weakness
  • 961951 2023-006
    Material Weakness
  • 961952 2023-006
    Material Weakness
  • 961953 2023-007
    Material Weakness
  • 961954 2023-007
    Material Weakness
  • 961955 2023-008
    Material Weakness
  • 961956 2023-008
    Material Weakness
  • 961957 2023-008
    Material Weakness
  • 961958 2023-008
    Material Weakness
  • 961959 2023-009
    Material Weakness
  • 961960 2023-009
    Material Weakness
  • 961961 2023-010
    Material Weakness
  • 961962 2023-010
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
10.555 National School Lunch Program 2022 $1.32M
10.555 National School Lunch Program 2023 $1.05M
84.425 Education Stabilization Fund 2023 $752,597
84.027 Special Education_grants to States 2023 $597,487
84.027 Special Education_grants to States 2022 $594,491
84.010 Title I Grants to Local Educational Agencies 2023 $353,035
84.010 Title I Grants to Local Educational Agencies 2022 $258,864
84.425 Education Stabilization Fund 2022 $202,495
10.553 School Breakfast Program 2022 $195,834
10.553 School Breakfast Program 2023 $171,476
84.367 Improving Teacher Quality State Grants 2023 $100,714
84.367 Improving Teacher Quality State Grants 2022 $77,868
84.365 English Language Acquisition State Grants 2023 $54,077
93.778 Medical Assistance Program 2022 $30,290
84.173 Special Education_preschool Grants 2023 $21,401
93.778 Medical Assistance Program 2023 $21,301
84.173 Special Education_preschool Grants 2022 $19,498
84.424 Student Support and Academic Enrichment Program 2023 $16,201
84.424 Student Support and Academic Enrichment Program 2022 $13,104
10.649 Pandemic Ebt Administrative Costs 2023 $628
10.649 Pandemic Ebt Administrative Costs 2022 $614