Finding 43497 (2022-011)

Material Weakness Repeat Finding
Requirement
EN
Questioned Costs
-
Year
2022
Accepted
2023-09-24

AI Summary

  • Core Issue: The School Corporation lacks effective internal controls over Title I grant processes, particularly regarding the participation of private school children, leading to a repeat finding.
  • Impacted Requirements: Compliance with eligibility criteria and special provisions for private school participation is not being met, risking noncompliance with federal regulations.
  • Recommended Follow-Up: Management should implement robust internal controls to ensure compliance with grant agreements and eligibility requirements for Title I services.

Finding Text

FINDING 2022-011 Subject: Title I Grants to Local Educational Agencies - Internal Controls 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 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Eligibility, Special Tests and Provisions - Participation of Private School Children Audit Finding: Material Weakness Repeat Finding This is a repeat finding from the immediately prior audit report regarding Special Tests and Provisions - Participation of Private School Children. The prior audit finding number was 2020-018. INDIANA STATE BOARD OF ACCOUNTS 42 GOSHEN COMMUNITY SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Condition and Context Eligibility - Real Time Reports The School Corporation submits the October Real Time report each year to the Indiana Department of Education (IDOE). This data is used to report the School Corporation's enrollment and poverty (socioeconomic) status of the students enrolled in each school. The School Corporation had not properly designed or implemented a system of internal controls over the October Real Time reports. In addition, enrollment and poverty numbers for the nonpublic school were manually entered into the Title I Application by the Title I Director without an oversight or review process to prevent or detect errors. Eligibility - Direct Certifications/Income Applications A list of students that qualified for free and reduced-price meals through direct certification was periodically downloaded from the IDOE website and imported into the school lunch program. However, there were no documented internal controls to ensure the information was uploaded on a timely basis. Additionally, there was no documentation of an oversight or review process over the Direct Certification upload into the Food Service software which was used to determine free and reduced lunch eligibility. Special Tests and Provisions - Participation of Private School Children Nonpublic school students are entitled to receive Title I services if they live in an eligible school attendance area and are failing or at risk of failing based on educational need. Planned services were provided to the nonpublic school students during the audit period; however, there was no internal control system in place to ensure the services were provided. The lack of internal controls was a systemic issue 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). . . ." Cause Management had not developed an effective system of internal controls that would have ensured compliance with the grant agreements and the Eligibility and the Special Tests and Provisions - Participation of Private School Children compliance requirements. Effect The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the Eligibility and the Special Tests and Provisions - Participation of Private School Children compliance requirements. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish internal controls related to the grant agreement and the Eligibility and the Special Tests and Provisions - Participation of Private School Children compliance requirements. 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 2022-011 Contact Person Responsible for Corrective Action: Whitney Dixon, Treasurer, Samantha Todd, Grants Manager, and Christopher Dixon, Director of Nutrition Contact Phone Number: 574-533-8631 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Eligibility ? Real Time Reports During the October Pupil Enrollment process, the student roster will be pulled from Data Exchange (DEX). The student data will be pulled from the food service software. This data will be compared and digitally signed by building principals. Student socioeconomic status will be reviewed and verified by the food service manager or designee. The reviewed and verified PE report will be digitally reviewed and signed by the CFO and Superintendent. Eligibility ? Direct Certifications/Income Applications Monthly the grants manager completes the DC download and imports the data into the school nutrition software. Once completed, the Director of School Nutrition verifies the information and signs the download document that is saved on the districts network. This control was implemented in March 2023. Participation of Private School Children Participation is determined by a process that includes standardized test scores and teacher input to determine what services are required. Test scores are provided at the beginning of the year, middle of the year, and end of the year to monitor and adjust accordingly the services that are required. Assistant Superintendent, Tracey Noe will review and sign the participation list and approve services at the nonpublic schools. This process will be implemented during the 2023-24 grant cycle. Anticipated Completion Date: October 2023, March 2023 and July 2023, respectively.

Categories

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

Other Findings in this Audit

  • 43470 2022-003
    Material Weakness Repeat
  • 43471 2022-004
    Material Weakness Repeat
  • 43472 2022-003
    Material Weakness Repeat
  • 43473 2022-004
    Material Weakness Repeat
  • 43474 2022-003
    Material Weakness Repeat
  • 43475 2022-004
    Material Weakness Repeat
  • 43476 2022-003
    Material Weakness Repeat
  • 43477 2022-004
    Material Weakness Repeat
  • 43478 2022-003
    Material Weakness Repeat
  • 43479 2022-004
    Material Weakness Repeat
  • 43480 2022-003
    Material Weakness Repeat
  • 43481 2022-004
    Material Weakness Repeat
  • 43482 2022-003
    Material Weakness Repeat
  • 43483 2022-004
    Material Weakness Repeat
  • 43484 2022-003
    Material Weakness Repeat
  • 43485 2022-004
    Material Weakness Repeat
  • 43486 2022-003
    Material Weakness Repeat
  • 43487 2022-004
    Material Weakness Repeat
  • 43488 2022-005
    Material Weakness Repeat
  • 43489 2022-006
    Material Weakness Repeat
  • 43490 2022-007
    Material Weakness
  • 43491 2022-005
    Material Weakness Repeat
  • 43492 2022-006
    Material Weakness Repeat
  • 43493 2022-007
    Material Weakness
  • 43494 2022-005
    Material Weakness Repeat
  • 43495 2022-006
    Material Weakness Repeat
  • 43496 2022-007
    Material Weakness
  • 43498 2022-011
    Material Weakness Repeat
  • 43499 2022-009
    Material Weakness
  • 43500 2022-010
    Material Weakness
  • 43501 2022-008
    Material Weakness
  • 43502 2022-009
    Material Weakness
  • 43503 2022-008
    Material Weakness
  • 43504 2022-009
    Material Weakness
  • 43505 2022-008
    Material Weakness
  • 43506 2022-009
    Material Weakness
  • 619912 2022-003
    Material Weakness Repeat
  • 619913 2022-004
    Material Weakness Repeat
  • 619914 2022-003
    Material Weakness Repeat
  • 619915 2022-004
    Material Weakness Repeat
  • 619916 2022-003
    Material Weakness Repeat
  • 619917 2022-004
    Material Weakness Repeat
  • 619918 2022-003
    Material Weakness Repeat
  • 619919 2022-004
    Material Weakness Repeat
  • 619920 2022-003
    Material Weakness Repeat
  • 619921 2022-004
    Material Weakness Repeat
  • 619922 2022-003
    Material Weakness Repeat
  • 619923 2022-004
    Material Weakness Repeat
  • 619924 2022-003
    Material Weakness Repeat
  • 619925 2022-004
    Material Weakness Repeat
  • 619926 2022-003
    Material Weakness Repeat
  • 619927 2022-004
    Material Weakness Repeat
  • 619928 2022-003
    Material Weakness Repeat
  • 619929 2022-004
    Material Weakness Repeat
  • 619930 2022-005
    Material Weakness Repeat
  • 619931 2022-006
    Material Weakness Repeat
  • 619932 2022-007
    Material Weakness
  • 619933 2022-005
    Material Weakness Repeat
  • 619934 2022-006
    Material Weakness Repeat
  • 619935 2022-007
    Material Weakness
  • 619936 2022-005
    Material Weakness Repeat
  • 619937 2022-006
    Material Weakness Repeat
  • 619938 2022-007
    Material Weakness
  • 619939 2022-011
    Material Weakness Repeat
  • 619940 2022-011
    Material Weakness Repeat
  • 619941 2022-009
    Material Weakness
  • 619942 2022-010
    Material Weakness
  • 619943 2022-008
    Material Weakness
  • 619944 2022-009
    Material Weakness
  • 619945 2022-008
    Material Weakness
  • 619946 2022-009
    Material Weakness
  • 619947 2022-008
    Material Weakness
  • 619948 2022-009
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
84.374 Teacher Incentive Fund Fy 2022 $1.90M
84.374 Teacher Incentive Fund Fy 2021 $1.41M
84.425 Education Stabilization Fund Fy 2022 $848,265
84.010 Title I Grants to Local Educational Agencies Fy 2021 $789,944
10.553 School Breakfast Program Fy 2022 $779,613
84.027 Special Education_grants to States Fy 2022 $743,671
10.555 National School Lunch Program Fy 2021 $292,335
84.010 Title I Grants to Local Educational Agencies Fy 2022 $215,048
84.424 Student Support and Academic Enrichment Program Fy 2021 $155,532
84.367 Improving Teacher Quality State Grants Fy 2021 $145,734
10.559 Summer Food Service Program for Children Fy 2022 $139,725
10.559 Summer Food Service Program for Children Fy 2021 $117,188
93.778 Medical Assistance Program Fy 2021 $108,536
10.553 School Breakfast Program Fy 2021 $86,705
10.555 National School Lunch Program Fy 2022 $84,920
84.173 Special Education_preschool Grants Fy 2022 $72,589
84.173 Special Education_preschool Grants Fy 2021 $71,486
93.778 Medical Assistance Program Fy 2022 $67,954
84.367 Improving Teacher Quality State Grants Fy 2022 $67,699
84.425 Education Stabilization Fund Fy 2021 $44,638
84.365 English Language Acquisition State Grants Fy 2021 $25,235
10.649 Pandemic Ebt Administrative Costs Fy 2022 $3,063