FINDING 2023-008
Subject: Title I Grants to Local Educational Agencies - Special
Tests and Provisions - Assessment System Security
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: Special Tests and Provisions - Assessment System Security
Audit Findings: Material Weakness, Other Matters
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 Special Tests and Provisions - Assessment System
Security compliance requirement.
The School Corporation had not developed and adopted a written test security policy. Although
training had been provided to staff on an annual basis, the School Corporation had not established a system
of internal controls regarding test security for assessments. In addition, there were no documented internal
controls in place to ensure all individuals that should have received training did receive training.
The lack of internal controls and noncompliance due to not adopting a test security policy were
systemic issues throughout the audit period.
INDIANA STATE BOARD OF ACCOUNTS
27
CROTHERSVILLE COMMUNITY SCHOOLS
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
(Continued)
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 200.207(a) states in part: "The Federal awarding agency or pass-through entity may impose
additional specific award conditions as needed, . . ."
511 IAC 5-5-5(b) states: "Any individual who administers, handles, or has access to secure test
materials at the school or school corporation shall complete assessment training and sign a testing security
and integrity agreement to remain on file in the appropriate building-level office each year."
Indiana Assessment Program Manual, Section 10, Part D states in part:
". . . Locally developed written test security policies must include, but not be limited to, the
following descriptions regarding how the corporation will:
● Ensure that all appropriate staff have knowledge of the Code of Ethical Practices and
Procedures and understand how to secure, administer, and handle the assessments
while in their possession.
● Ensure all appropriate staff receive Test Security and Integrity Training prior to IDOE's
established deadline.
● Ensure all appropriate staff receive test administration training prior to the stare of the
state testing window for each assessment.
● Ensure staff members who will provide students with testing accommodations are
familiar with each student's individual accommodation needs as per the student's IEP,
ILP, Section 504 Plan, CSEP, and/or Service Plan prior to testing.
● Ensure staff members who will provide students with test accommodations receive
focused training on providing such accommodations prior to the start of the state
testing window for each assessment.
● Ensure all appropriate staff receive test security refresher training prior to the start of
the state testing window for each assessment.
● Define and clearly communicate at least once annually for all appropriate staff how
staff implementation of test administration and test security standards and procedures
will be monitored by school administrators.
INDIANA STATE BOARD OF ACCOUNTS
28
CROTHERSVILLE COMMUNITY SCHOOLS
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
(Continued)
● Provide any other information and professional development necessary to ensure that
all appropriate staff have the knowledge and skills necessary to make ethical decisions
related to preparing students for an assessment, administering the assessment, and
interpreting the results from assessment.
● Establish a testing schedule. At a minimum, the schedule should include the assessment
name, testing dates and times, applicable grade levels, content areas, and
testing room locations. Local testing schedules must be developed prior to the start of
the state testing window for each assessment.
● Establish an access policy for assessment materials that allows only appropriate staff
to have access to test administration manuals prior to the administration of the test,
but prohibits the reviewing of any secure test questions before, during, or after the
assessment administration.
● Establish a process that ensures all student assessments are secure when they are
not being administered.
● Annually review school materials and practices related to preparing students for
assessments. The description must include an explanation regarding how the corporation
will ensure test preparation materials used by school staff are appropriate and do
not violate test security protocols.
● Monitor testing to ensure staff are administering assessments with fidelity in terms of
test administration and test security protocols/procedures and that staff are appropriately
providing students with accommodations included in their formal plan.
● Provide channels of communication that allow teachers, administrators, students,
parents/guardians, and other community members to voice their concerns about
testing practices they consider inappropriate (see the Testing Concerns and Security
Violations Report form in Appendix C).
● Establish procedures for investigating any complaint, allegation, or concern about
inappropriate testing practices, and ensuring the protection of both the rights of
individuals and of the integrity of the assessment.
● Investigate any complaint of inappropriate testing practices or testing irregularities
according to the Protocol for Reporting and Investigating Alleged Breaches as established
and published pursuant to 511 IAC 5-5-4 (see Appendix A)."
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 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. As a result, the School Corporation did not have a written test security policy.
INDIANA STATE BOARD OF ACCOUNTS
29
CROTHERSVILLE COMMUNITY SCHOOLS
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
(Continued)
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 establish a proper system of
internal controls and develop policies and procedures to ensure a written test security policy is created and
adopted.
Views of Responsible Officials
For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.