Information on the federal program:
Subject: COVID-19 – Education Stabilization Fund – Reporting
Federal Agency: Department of Education
Federal Program: COVID-19 – Education Stabilization Fund
Assistance Listing Number: 84.425D, 84.425U
Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013, S425U210013
Pass-Through Entity: Indiana Department of Education
Compliance Requirement: Reporting
Audit Finding: Significant Deficiency
Criteria: 2 CFR section 200.303 states in part:
"The non-Federal entity must:
(a) Establish and maintain effective internal control over Federal award that provides reasonable assurance
that the non-Federal entity is managing the Federal awards 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 200.302(b) states in part:
"The financial management system of each non-Federal entity must provide for the following:
(2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in
accordance with the reporting requirements set forth in §§ 200.328 Financial reporting . . . ."
34 CFR 76.722 states:
"A State may require a subgrantee to submit reports in a manner and format that assists the State in
complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the
program."
Condition: An effective internal control system was not in place at the School Corporation in order to
ensure compliance with requirements related to the grant agreement and the Reporting compliance
requirements.
Cause: The School District's management had not developed a system of internal controls to ensure
compliance with the compliance requirements listed above.
Effect: The failure to establish an effective internal control system placed the School Corporation at risk of
noncompliance with the grant agreement and the compliance requirements. Internal controls were not
adequate to detect and prevent errors in annual data submitted to the Indiana Department of Education.
Questioned Costs: There were no questioned costs identified. Context: The School Corporation had not designed nor implemented a system of internal control to ensure
that the annual Elementary and Secondary School Emergency Relief (ESSER) annual Data Collection
reports (Reports) were complete and accurately submitted. The reports were prepared and submitted in
JotForm, the online application used by the Indiana Department of Education to collect information, without
an oversight or secondary review process in place to prevent or detect and correct errors.
During the testing of the annual data reports, variances were noted in the amounts expended reported on
the Year 3 and Year 4 annual data reports for the ESSER I, ESSER II and ESSER III grant awards when
compared to underlying disbursement detail for the grant funds. The amounts reported as expended in the
Year 3 reports, which covers the period of July 1, 2021 through June 30, 2022, were underreported by
$10,152. The amounts reported as expended in the Year 4 report, which covers the period of July 1, 2022
through June 30, 2023, were overreported by $43,050. This resulted in a net overreporting of $32,898.
Annual Data Report Year 3 - Period of 7/1/21 - 6/30/22
As Reported Per Support Over (under)
Reported
ESSER I CARES $ 67,160 $ 64,712 $ (2,448)
ESSER II 416,014 428,614 12,600
ESSER III (ARP) 441,903 441,903 -
Total $ 925,077 $ 935,229 $ (10,152)
Annual Data Report Year 4 - Period of 7/1/22 - 6/30/23
As Reported Per Support Over (under)
Reported
ESSER I CARES $ - $ 2,448 $ 2,448
ESSER II 60,897 200,041 139,144
ESSER III (ARP) 623,874 439,233 (184,641)
Total $ 684,771 $ 641,722 $ 43,049
Additionally, Year 3 full-time equivalent employees were improperly reported at 84 instead of 87.
Additionally, the CrossAct Detail for both Year 3 and Year 4 were not provided.
Identification as a repeat finding, if applicable: No.
Recommendation: We recommend someone other than the preparer of the report perform a documented,
secondary review of the report information prior to submission to validate the accuracy and completeness
of the data submitted.
Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding
and has prepared a corrective action plan.