Finding 47481 (2022-010)

Material Weakness
Requirement
AB
Questioned Costs
$1
Year
2022
Accepted
2023-03-30

AI Summary

  • Core Issue: The School Corporation lacks an effective system of internal controls, leading to inadequate documentation for Title I grant transactions.
  • Impacted Requirements: Noncompliance with federal regulations regarding allowable costs and documentation standards, resulting in questioned costs totaling $12,794.
  • Recommended Follow-Up: Implement a robust internal control system to ensure compliance and proper documentation for all grant-related activities.

Finding Text

FINDING 2022-010 Subject: Title I Grants to Local Educational Agencies - Activities Allowed or Unallowed, Allowable Costs/Cost Principles 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, S010A190014SIG Pass-Through Entity: Indiana Department of Education Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Findings: Material Weakness, Modified Opinion Condition and Context The School Corporation had not properly designed or implemented a system of internal controls to ensure that proper documentation was retained for audit. A sample of forty transactions charged to the Title I grants during the audit period was selected for testing. The following errors were noted: 1. The School Corporation was unable to provide supporting documentation for three transactions, totaling $6,272. As such, these transactions were unable to be verified as allowable activities or costs for the Title I program. 2. Seven transactions, totaling $887, were for fringe benefit claims; however, the supporting documentation provided did not include details to identify the employees for which the benefits were paid. As a result, we were unable to determine if the payments were on behalf of allowable staff related to the Title I program. 3. Four transactions selected were for a Title I employee's payroll who did not have an approved hourly rate. The total amount of the four transactions paid to that employee was $4,261. 4. For two transactions tested, the payroll check register reported the employee was paid for more hours than was reported on their approved timecard. The additional amount paid to the employee was $1,374. Due to the number and magnitude of exceptions identified, per auditor judgment, we concluded it would not be appropriate to examine the remaining twenty-four transactions. The errors noted above were considered questioned costs. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal controls 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 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass through entity in the case of a subrecipient. . . ." 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: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items . . . (g) Be adequately documented. . . ." 2 CFR 200.430(i) states in part: "Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities (for IHE, this per the IHE's definition of IBS); . . . (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. . . ." 2 CFR 200.309 states: "A non-Federal entity may charge to the Federal award only allowable costs incurred during the period of performance (except as described in ? 200.461 Publication and printing costs) and any costs incurred before the Federal awarding agency or pass-through entity made the Federal award that were authorized by the Federal awarding agency or pass-through entity." Cause Management had not established an effective system of internal controls that would have ensured compliance, or that supporting documentation would have been maintained and made available for audit, with the grant agreement and the Activities Allowed or Unallowed and the Allowable Costs/Cost Principles compliance requirements. Effect The failure to establish an effective system of internal controls and to retain and provide appropriate supporting documentation prevented the determination of the School Corporation's compliance with the compliance requirements listed above. Questioned Costs Known questioned costs of $12,794 were identified, as detailed in Condition and Context. Recommendation We recommended that the School Corporation's management establish an effective system of internal controls to ensure documentation be maintained and made available for audit related to the grant agreement and the Activities Allowed or Unallowed and the Allowable Costs/Cost Principles 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 2022-010 Contact Person Responsible for Corrective Action: Tricia Malone Hudson, District Curriculum Specialist Contact Phone Number: 812-279-3521 Views of Responsible Official: We concur with the audit finding. Description of Corrective Action Plan: The school district will develop a plan for tracking employee pay and timecard alignment. The district will ensure that these documents are available to auditors. All expenditures will have a cover sheet with identifying information, will be attached to the proper invoice(s), signed by 2 parties, and hard copies will be kept on file for audit purposes in folders attached to each grant. Anticipated Completion Date: North Lawrence Community Schools will implement this procedure by June 2023.

Categories

Questioned Costs 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
  • 47475 2022-008
    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
  • 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