Finding Text
FINDING 2022-009 Subject: Special Education Cluster (IDEA) ? Earmarking Federal Agency: Department of Education Federal Program: Special Education Grants to States Assistance Listing Number: 84.027 Federal Award Numbers and Years (or Other Identifying Numbers): 20611-109-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Earmarking Audit Findings: Material Weakness 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). . . ." 511 IAC 7-34-7(b) states: "The public agency, in providing special education and related services to students in nonpublic schools and facilities, 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 nonpublic school students with disabilities, who are enrolled by their parents in nonpublic schools or facilities within its boundaries, is to the total number of students with disabilities of the same age range." Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the compliance requirements listed above. Cause: The School Corporation had not established an effective system of internal controls that would have ensured compliance with the grant agreement and the compliance requirements listed above. Effect: The School did not comply with the earmarking requirements of the compliance requirements listed above. Noncompliance with the grant agreement and the compliance requirements listed above could have resulted in the loss of funds to the School Corporation. Questioned Costs: There were no questioned costs identified. Context: A proportionate share of special education funds was earmarked to the local private school. The School Corporation could not provide support to substantiate that non-public services were provided. For the special education grant awards that were fully expended during the audit period, the School Corporation did not expend the minimum required amount on services for non-public students with disabilities. Identification as a repeat finding: Yes, see Finding 2020-005 Recommendation: We recommended the School Corporation?s management establish a system of internal controls and maintain adequate supporting documentation to ensure compliance with the grant agreement and the Earmarking compliance requirements. In addition, we recommended the School Corporation improve communication with the local private school to ensure the proportionate share is fully expended, or a waiver with adequate documentation is filed. Views of Responsible Officials: Management agrees with the finding and has prepared a corrective action plan.