Finding 47475 (2022-008)

Material Weakness
Requirement
G
Questioned Costs
-
Year
2022
Accepted
2023-03-30

AI Summary

  • Core Issue: The School Corporation failed to provide adequate oversight of the Cooperative, leading to noncompliance with federal earmarking requirements for special education funding.
  • Impacted Requirements: Compliance with Matching, Level of Effort, and Earmarking requirements under federal regulations was not met, resulting in a material weakness.
  • Recommended Follow-Up: Management should implement effective internal controls and ensure proper documentation of federal expenditures to comply with grant agreements.

Finding Text

FINDING 2022-008 Subject: Special Education Cluster (IDEA) - Earmarking Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.173 Federal Award Numbers and Years: 19611-047-PN01, 19619-047-PN01, 20611-045-PN01, 20619-045-PN01 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 was a member of the Orange-Lawrence-Jackson-Martin-Greene Joint Services Cooperative (Cooperative). During fiscal year 2020-2021, the Cooperative operated as the special education programs and spent the federal money on behalf of all its member schools. As the grant agreements were between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. However, there was inadequate oversight performed by the School Corporation to ensure compliance with the Matching, Level of Effort, Earmarking compliance requirement. The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the earmarking requirements. The Cooperative did not have adequate procedures in place to ensure that the required level of expenditures for nonpublic school students with disabilities was met for each member school. The Cooperative did not have effective internal controls to ensure non-public school expenditures were appropriately identified and reported. The Non-Public Proportionate Share expenditures for the 19611-047-PN01, 19619-047-PN01, 20611-045-PN01, and 20619-045-PN01 grant awards could not be verified for the individual member schools. Proportionate Share Monitoring Reports and other supporting documentation for amounts reported to the IDOE for earmarking were not retained for audit. As such, we were unable to identify the minimum amount per the grant awards was expended and properly reported to the IDOE as required. The lack of internal controls and noncompliance was isolated to the 19611-047-PN01, 19619-047-PN01, 20611-045-PN01, and 20619-045-PN01 grant awards. 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 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: . . . (g) Be adequately document. . . ." 2 CFR 200.208(b) states in part: "The Federal awarding agency or pass-through entity may adjust specific Federal award conditions as needed . . ." 511 IAC 7-34-7(b) states: "The public agency, in providing special education and related services to students in nonpublic schools must expend at least an amount that is the same proportion of the public agency total subgrant under 20 U.S.C. 1411(f) as the number of the nonpublic school students with disabilities, who are enrolled by their parents in nonpublic schools within its boundaries, is to the total number of students with disabilities of the same age range." Cause Management had not developed an effective system of internal controls that would have ensured compliance with the grant agreements and the earmarking requirements of the Matching, Level of Effort, Earmarking compliance requirement. Effect The failure to establish an effective internal control system, as well as adequately document costs of federal awards, prevented the determination of the School Corporation's compliance with the earmarking requirements of the Matching, Level of Effort, Earmarking compliance requirement. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish an effective system of internal controls, as well as appropriately document and identify federal award expenditures to ensure compliance with the Matching, Level of Effort, Earmarking compliance requirement. 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 2022-008 Contact Person Responsible for Corrective Action: Melissa Hinds, Director of Special Education Contact Phone Number: 812-279-3521 Views of Responsible Official: We concur with the audit finding. Description of Corrective Action Plan: A print out of the current expenses and balances will be reviewed by the Special Education Director and District?s Treasurer before the cash request is emailed to the state to ensure there is proper compliance with grant agreement and the matching, level of effort, earmarking and reporting compliance Anticipated Completion Date: February 2023

Categories

Matching / Level of Effort / Earmarking Subrecipient Monitoring Allowable Costs / Cost Principles

Other Findings in this Audit

  • 47451 2022-003
    Material Weakness
  • 47452 2022-004
    Material Weakness
  • 47453 2022-005
    Material Weakness
  • 47454 2022-003
    Material Weakness
  • 47455 2022-004
    Material Weakness
  • 47456 2022-005
    Material Weakness
  • 47457 2022-003
    Material Weakness
  • 47458 2022-004
    Material Weakness
  • 47459 2022-005
    Material Weakness
  • 47460 2022-003
    Material Weakness
  • 47461 2022-004
    Material Weakness
  • 47462 2022-005
    Material Weakness
  • 47463 2022-003
    Material Weakness
  • 47464 2022-004
    Material Weakness
  • 47465 2022-005
    Material Weakness
  • 47466 2022-003
    Material Weakness
  • 47467 2022-004
    Material Weakness
  • 47468 2022-005
    Material Weakness
  • 47469 2022-003
    Material Weakness
  • 47470 2022-004
    Material Weakness
  • 47471 2022-005
    Material Weakness
  • 47472 2022-003
    Material Weakness
  • 47473 2022-004
    Material Weakness
  • 47474 2022-005
    Material Weakness
  • 47476 2022-006
    Material Weakness
  • 47477 2022-007
    Material Weakness
  • 47478 2022-008
    Material Weakness
  • 47479 2022-006
    Material Weakness
  • 47480 2022-007
    Material Weakness
  • 47481 2022-010
    Material Weakness
  • 47482 2022-011
    Material Weakness
  • 47483 2022-012
    Material Weakness
  • 47484 2022-013
    Material Weakness
  • 47485 2022-014
    Material Weakness
  • 47486 2022-015
    Material Weakness
  • 47487 2022-010
    Material Weakness
  • 47488 2022-011
    Material Weakness
  • 47489 2022-012
    Material Weakness
  • 47490 2022-013
    Material Weakness
  • 47491 2022-014
    Material Weakness
  • 47492 2022-015
    Material Weakness
  • 47493 2022-018
    Material Weakness
  • 47494 2022-018
    Material Weakness
  • 47495 2022-017
    Material Weakness
  • 47496 2022-018
    Material Weakness
  • 47497 2022-016
    Material Weakness
  • 47498 2022-017
    Material Weakness
  • 47499 2022-018
    Material Weakness
  • 47500 2022-009
    Material Weakness
  • 47501 2022-009
    Material Weakness
  • 623893 2022-003
    Material Weakness
  • 623894 2022-004
    Material Weakness
  • 623895 2022-005
    Material Weakness
  • 623896 2022-003
    Material Weakness
  • 623897 2022-004
    Material Weakness
  • 623898 2022-005
    Material Weakness
  • 623899 2022-003
    Material Weakness
  • 623900 2022-004
    Material Weakness
  • 623901 2022-005
    Material Weakness
  • 623902 2022-003
    Material Weakness
  • 623903 2022-004
    Material Weakness
  • 623904 2022-005
    Material Weakness
  • 623905 2022-003
    Material Weakness
  • 623906 2022-004
    Material Weakness
  • 623907 2022-005
    Material Weakness
  • 623908 2022-003
    Material Weakness
  • 623909 2022-004
    Material Weakness
  • 623910 2022-005
    Material Weakness
  • 623911 2022-003
    Material Weakness
  • 623912 2022-004
    Material Weakness
  • 623913 2022-005
    Material Weakness
  • 623914 2022-003
    Material Weakness
  • 623915 2022-004
    Material Weakness
  • 623916 2022-005
    Material Weakness
  • 623917 2022-008
    Material Weakness
  • 623918 2022-006
    Material Weakness
  • 623919 2022-007
    Material Weakness
  • 623920 2022-008
    Material Weakness
  • 623921 2022-006
    Material Weakness
  • 623922 2022-007
    Material Weakness
  • 623923 2022-010
    Material Weakness
  • 623924 2022-011
    Material Weakness
  • 623925 2022-012
    Material Weakness
  • 623926 2022-013
    Material Weakness
  • 623927 2022-014
    Material Weakness
  • 623928 2022-015
    Material Weakness
  • 623929 2022-010
    Material Weakness
  • 623930 2022-011
    Material Weakness
  • 623931 2022-012
    Material Weakness
  • 623932 2022-013
    Material Weakness
  • 623933 2022-014
    Material Weakness
  • 623934 2022-015
    Material Weakness
  • 623935 2022-018
    Material Weakness
  • 623936 2022-018
    Material Weakness
  • 623937 2022-017
    Material Weakness
  • 623938 2022-018
    Material Weakness
  • 623939 2022-016
    Material Weakness
  • 623940 2022-017
    Material Weakness
  • 623941 2022-018
    Material Weakness
  • 623942 2022-009
    Material Weakness
  • 623943 2022-009
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
10.555 National School Lunch Program 22 $1.84M
84.425 Education Stabilization Fund 22 $1.32M
84.027 Special Education_grants to States 22 $975,069
84.425 Education Stabilization Fund 21 $862,480
84.010 Title I Grants to Local Educational Agencies 22 $756,412
84.010 Title I Grants to Local Educational Agencies 21 $756,017
84.027 Special Education_grants to States 21 $625,125
10.553 School Breakfast Program 22 $366,043
84.048 Career and Technical Education -- Basic Grants to States 22 $223,010
84.367 Improving Teacher Quality State Grants 21 $182,695
84.048 Career and Technical Education -- Basic Grants to States 21 $178,359
84.367 Improving Teacher Quality State Grants 22 $173,731
84.424 Student Support and Academic Enrichment Program 21 $136,860
10.555 National School Lunch Program 21 $123,737
93.778 Medical Assistance Program 22 $69,074
93.778 Medical Assistance Program 21 $64,916
10.559 Summer Food Service Program for Children 21 $54,204
84.173 Special Education_preschool Grants 22 $42,315
10.559 Summer Food Service Program for Children 22 $36,540
84.173 Special Education_preschool Grants 21 $35,644
10.553 School Breakfast Program 21 $31,026
84.424 Student Support and Academic Enrichment Program 22 $16,715
10.649 Pandemic Ebt Administrative Costs 22 $3,063