Finding 386867 (2023-008)

Material Weakness
Requirement
G
Questioned Costs
-
Year
2023
Accepted
2024-03-28

AI Summary

  • Core Issue: The School Corporation lacks a proper system of internal controls, leading to noncompliance with Title I grant requirements.
  • Impacted Requirements: Key areas affected include earmarking for parental involvement and homeless services, expenditure reporting accuracy, and fund allocation methodology.
  • Recommended Follow-Up: Establish and document a robust internal control system, including segregation of duties and oversight processes, to ensure compliance with federal regulations.

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) S010A190014, S010A200014, S010A210014, S010A220014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking 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. Earmarking A portion of the School Corporation's Title I allocation was required to be set aside for parental involvement and 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 and Payroll) 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 its computation were derived from the 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 payroll and vendor were posted to the correct fund, account, and object codes. Level of Effort - Maintenance of Effort The financial information submitted by the School Corporation to the IDOE through the Form 9 report, was used by the IDOE to calculate the School Corporation's Level of Effort - Maintenance of Effort. There was an oversight or review process at the School Corporation level over vendor and payroll expenditures; however, the oversight and review process was not documented to ensure the data used to complete the Form 9 was reported accurately in the correct fund, account, and object code. Level of Effort - Supplementing Not Supplanting The School Corporation may use Title I funds only to supplement the funds that would, in the absence of the Title I funds, be made available from state and local sources for the education of students participating in a Title I program. To demonstrate compliance, the School Corporation must demonstrate that it has a methodology (through written procedures) and followed the methodology to allocate state and local funds to each Title I school. They also must ensure that the Title I school received all the state and local funds it would otherwise receive if it were not receiving Title I funds. The School Corporation did not provide written procedures for the methodology used for the FY 2021 and FY 2022 Title I applications. The School Corporation had not developed written procedures for methodology; therefore, we were not able to determine how the School Corporation allocated funding per each school. The lack of internal controls and noncompliance were systemic 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 6313(c)(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." 20 USC 6691 states: "Funds made available under this subchapter shall be used to supplement, and not supplant, non-Federal funds that would otherwise be used for activities authorized under this subchapter." Cause A proper system of internal controls was not designed by management of the School Corporation which would include segregation of key functions. 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. In addition, a written methodology of the allocation of state and local funds to each Title I school was not provided. Noncompliance with the grant agreement and the compliance requirement could result in the loss of future federal funds 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.

Corrective Action Plan

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 Listing Number: 84.010 Federal Award Numbers and Years (or Other Identifying Numbers): S010A190014, S010A200014, S010A210014, S010A220014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking Summary of Finding: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Terri Chance Contact Phone Number and Email Address: 219-924-4250 tchance@griffith.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Griffith Public Schools will be developing, implementing, and documenting, a system of internal controls, including policies and procedures that provide segregation of duties to ensure appropriate reviews, approvals and oversight are taking place. Anticipated Completion Date: June 30, 2025

Categories

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

Other Findings in this Audit

  • 386846 2023-003
    Material Weakness Repeat
  • 386847 2023-003
    Material Weakness Repeat
  • 386848 2023-003
    Material Weakness Repeat
  • 386849 2023-003
    Material Weakness Repeat
  • 386850 2023-003
    Material Weakness Repeat
  • 386851 2023-003
    Material Weakness Repeat
  • 386852 2023-003
    Material Weakness Repeat
  • 386853 2023-004
    Material Weakness Repeat
  • 386854 2023-004
    Material Weakness Repeat
  • 386855 2023-004
    Material Weakness Repeat
  • 386856 2023-005
    Material Weakness Repeat
  • 386857 2023-005
    Material Weakness Repeat
  • 386858 2023-005
    Material Weakness Repeat
  • 386859 2023-005
    Material Weakness Repeat
  • 386860 2023-005
    Material Weakness Repeat
  • 386861 2023-005
    Material Weakness Repeat
  • 386862 2023-005
    Material Weakness Repeat
  • 386863 2023-006
    Material Weakness
  • 386864 2023-006
    Material Weakness
  • 386865 2023-007
    Material Weakness
  • 386866 2023-007
    Material Weakness
  • 386868 2023-008
    Material Weakness
  • 386869 2023-009
    Material Weakness
  • 386870 2023-009
    Material Weakness
  • 386871 2023-009
    Material Weakness
  • 386872 2023-010
    Material Weakness
  • 386873 2023-010
    Material Weakness
  • 963288 2023-003
    Material Weakness Repeat
  • 963289 2023-003
    Material Weakness Repeat
  • 963290 2023-003
    Material Weakness Repeat
  • 963291 2023-003
    Material Weakness Repeat
  • 963292 2023-003
    Material Weakness Repeat
  • 963293 2023-003
    Material Weakness Repeat
  • 963294 2023-003
    Material Weakness Repeat
  • 963295 2023-004
    Material Weakness Repeat
  • 963296 2023-004
    Material Weakness Repeat
  • 963297 2023-004
    Material Weakness Repeat
  • 963298 2023-005
    Material Weakness Repeat
  • 963299 2023-005
    Material Weakness Repeat
  • 963300 2023-005
    Material Weakness Repeat
  • 963301 2023-005
    Material Weakness Repeat
  • 963302 2023-005
    Material Weakness Repeat
  • 963303 2023-005
    Material Weakness Repeat
  • 963304 2023-005
    Material Weakness Repeat
  • 963305 2023-006
    Material Weakness
  • 963306 2023-006
    Material Weakness
  • 963307 2023-007
    Material Weakness
  • 963308 2023-007
    Material Weakness
  • 963309 2023-008
    Material Weakness
  • 963310 2023-008
    Material Weakness
  • 963311 2023-009
    Material Weakness
  • 963312 2023-009
    Material Weakness
  • 963313 2023-009
    Material Weakness
  • 963314 2023-010
    Material Weakness
  • 963315 2023-010
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
84.425 Education Stabilization Fund 2023 $1.41M
10.555 National School Lunch Program 2023 $1.06M
84.010 Title I Grants to Local Educational Agencies 2023 $615,259
84.027 Special Education_grants to States 2022 $526,339
10.559 Summer Food Service Program for Children 2022 $446,118
84.010 Title I Grants to Local Educational Agencies 2022 $294,989
10.553 School Breakfast Program 2023 $187,522
10.553 School Breakfast Program 2022 $164,094
84.425 Education Stabilization Fund 2022 $150,429
93.778 Medical Assistance Program 2023 $83,079
84.367 Improving Teacher Quality State Grants 2023 $80,515
10.555 National School Lunch Program 2022 $65,379
93.778 Medical Assistance Program 2022 $43,079
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) 2023 $40,426
10.559 Summer Food Service Program for Children 2023 $40,338
84.424 Student Support and Academic Enrichment Program 2023 $22,199
10.649 Pandemic Ebt Administrative Costs 2022 $3,063
10.649 Pandemic Ebt Administrative Costs 2023 $628