Finding 528346 (2024-004)

Significant Deficiency Repeat Finding
Requirement
C
Questioned Costs
-
Year
2024
Accepted
2025-03-17
Audit: 346388
Organization: Union School Corporation (IN)
Auditor: Crowe LLP

AI Summary

  • Core Issue: The School Corporation lacks effective internal controls for managing cash related to the Special Education Cluster, leading to significant delays in paying service providers.
  • Impacted Requirements: Compliance with 2 CFR section 200.303 and cash management requirements, which mandate timely payment of service provider invoices before reimbursement requests.
  • Recommended Follow-Up: Implement procedures to ensure invoices are paid prior to submitting draw requests to the Indiana Department of Education, addressing this repeat finding.

Finding Text

Information on the federal program: Subject: Special Education Cluster – Internal Controls Federal Agency: Department of Education Federal Program: Special Education Cluster Assistance Listing Number: 84.027, 84.027X, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 22611-122-PN01, 23611-122-PN01, 24611-122-PN01, 22611-122-ARP, 22619-122-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Cash Management 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). . . ." For grants and cooperative agreements to non-federal entities that are paid on a reimbursement basis, supporting documentation shows that the costs for which reimbursement was requested were paid prior to the date of the reimbursement request. Pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized as required by the applicable cash management requirements in the federal award to the recipient (2 CFR section 200.305(b)(1)). 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 Cash Management compliance requirements. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with cash management for reimbursement grants. The School Corporation did not have a design control in place to ensure that service provider invoices were paid prior to the submitting reimbursements to the Indiana Department of Education (IDOE). 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. Questioned Costs: There were no questioned costs identified. Context: The School Corporation pays one hundred percent of its Special Education Cluster funding to one service provider, which totaled $3,782,381 for the audit period. For all invoices during the audit period, the School Corporation submitted and received reimbursement from the IDOE prior to paying the service provider, and then the School Corporation remitted payment to the service provider. There was significant delay in the time between the School Corporation was reimbursed by IDOE and when the School Corporation paid the service provider. The delay in payment was in the range of 2 – 4 months for the payments made during the audit period. Identification as a repeat finding: This is a repeat finding from the immediately prior audit. The prior finding number was 2022-003. Recommendation: We recommend the School Corporation implement procedures to ensure the invoices are paid before submitting draw requests and receiving funds from IDOE. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.

Categories

Cash Management Subrecipient Monitoring

Other Findings in this Audit

  • 528342 2024-003
    Material Weakness Repeat
  • 528343 2024-004
    Significant Deficiency Repeat
  • 528344 2024-004
    Significant Deficiency Repeat
  • 528345 2024-004
    Significant Deficiency Repeat
  • 528347 2024-004
    Significant Deficiency Repeat
  • 528348 2024-005
    Material Weakness
  • 528349 2024-006
    Material Weakness
  • 528350 2024-007
    Material Weakness
  • 528351 2024-007
    Material Weakness
  • 528352 2024-008
    Material Weakness
  • 528353 2024-009
    Material Weakness
  • 1104784 2024-003
    Material Weakness Repeat
  • 1104785 2024-004
    Significant Deficiency Repeat
  • 1104786 2024-004
    Significant Deficiency Repeat
  • 1104787 2024-004
    Significant Deficiency Repeat
  • 1104788 2024-004
    Significant Deficiency Repeat
  • 1104789 2024-004
    Significant Deficiency Repeat
  • 1104790 2024-005
    Material Weakness
  • 1104791 2024-006
    Material Weakness
  • 1104792 2024-007
    Material Weakness
  • 1104793 2024-007
    Material Weakness
  • 1104794 2024-008
    Material Weakness
  • 1104795 2024-009
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
93.778 Medical Assistance Program $453,616
84.027 Special Education Grants to States $258,488
84.010 Title I Grants to Local Educational Agencies $98,551
84.425 Education Stabilization Fund $70,746
10.553 School Breakfast Program $46,012
84.367 Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) $33,146
10.555 National School Lunch Program $24,011
84.173 Special Education Preschool Grants $22,694
84.424 Student Support and Academic Enrichment Program $20,000
10.649 Pandemic Ebt Administrative Costs $3,135