Finding 529506 (2024-007)

Material Weakness
Requirement
B
Questioned Costs
$1
Year
2024
Accepted
2025-03-24

AI Summary

  • Core Issue: The School Corporation lacks effective internal controls over federal awards, leading to questioned costs totaling $175,481 for non-allowable expenses.
  • Impacted Requirements: Noncompliance with 2 CFR 200.303 and related federal guidelines on allowable costs and internal control systems.
  • Recommended Follow-Up: Establish a formal risk assessment process and implement ongoing monitoring to ensure compliance with federal regulations and improve internal controls.

Finding Text

FINDING 2024-007 Subject: COVID-19 - Education Stabilization Fund - Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Allowable Costs/Cost Principles Audit Findings: Material Weakness, Modified Opinion Condition and Context Internal control is generally defined as a process affected by an entity's oversight body, management, and other personnel that provides reasonable assurance that the objectives of an entity will be achieved. With respect to federal awards, nonfederal entities, such as the School Corporation, are required to establish and maintain internal control over federal awards that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and terms and conditions of the federal awards. INDIANA STATE BOARD OF ACCOUNTS 30 CANNELTON CITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Internal control is not one event or circumstance, but a dynamic and iterative process. The internal control process is based on fundamental principles that operate as a whole but are best understood when analyzed individually. The fundamental principles are related to five components of internal control which are as follows: Control Environment, Risk Assessment, Control Activities, Information and Communication, and Monitoring. If a component is not effective, or the components are not operating together in an integrated manner, then an internal control system cannot be effective. Deficiencies as noted below were identified in the risk assessment, monitoring, and control activities components. Risk Assessment The School Corporation has not established a formal risk assessment process. There is no documented risk assessment policy, nor is there evidence of periodic risk identification, analysis, or evaluation. Monitoring The School Corporation did not conduct ongoing or periodic reviews to ensure that internal controls were operating as intended and to identify areas for improvement. Furthermore, the School Corporation did not have a process to follow up on corrective actions written as a response to audit findings. Control Activities The School Corporation was a participating member in The Exceptional Children's Cooperative (Cooperative) which provided special education services to students on behalf of the School Corporation. The School Corporation utilized $15,672 in program funds to pay for a portion of the School Corporation's required obligations to the Cooperative. This arrangement existed prior to the pandemic, and none of the obligations were related to responding to the pandemic. Additionally, the School Corporation used $12,000 in program funds to pay a retainer fee for information technology services on a contract that existed prior to the COVID-19 pandemic. The School Corporation also used $147,809 in program funds to pay the salary and benefits of a certified staff member who was employed prior to the pandemic and whose job duties were not related to responding to the pandemic. We consider the total of these payments, $175,481, to be 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 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). . . ." INDIANA STATE BOARD OF ACCOUNTS 31 CANNELTON CITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) American Rescue Plan Act section 2001(e) states in part: "Uses of Funds. - A local education agency that receives funds under this section - . . . (2) shall use the remaining funds for any of the following: . . . (E) Coordination of preparedness and response efforts of local education agencies with State, local, Tribal, and territorial public health departments, and other relevant agencies, to improve coordinated responses among such entities to prevent, prepare for, and respond to coronavirus. . . . (G) Developing and implementing procedures and systems to improve the preparedness and response efforts of local educational agencies. . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following . . . (3) Records that identify adequately the source and application of funds for federally funded activities. These records must contain information pertaining to Federal awards, authorizations, financial obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. . . ." 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. . . . (g) be adequately documented. . . ." Cause Management of the School Corporation had not taken steps to design and implement policies and procedures to assess risks facing the School Corporation or to establish and operate monitoring activities that monitor the internal control system. Additionally, the School Corporation's management had not developed a system of internal controls to ensure that expenditures paid from COVID-19 - Education Stabilization Funds were for costs allowed by the grant terms and conditions and in compliance with the allowable cost principles. Effect As a result of the five components of internal control not being adequately designed and implemented, the internal control system cannot be effective. Thus, general risks or specific risks from fraud and significant changes could negatively impact the School Corporation, identified internal control deficiencies could continue, and unidentified flaws within the internal control system could exist. Without a proper system of internal controls in place that operated effectively, material noncompliance that resulted in questioned costs remained undetected. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funds to the School Corporation. INDIANA STATE BOARD OF ACCOUNTS 32 CANNELTON CITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Questioned Costs Questioned costs in the amount of $175,481 were identified as noted in the Condition and Context. Recommendation We recommended that the School Corporation's management establish a proper system of internal controls, which would include policies and procedures related to risk assessment and monitoring. Additionally, we recommended that the School Corporation's management establish a proper system of internal controls to ensure expenditures made from federal awards are for cost allowed per the terms and conditions of the federal award and in compliance with the allowable cost principles. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

Categories

Questioned Costs Allowable Costs / Cost Principles Subrecipient Monitoring Internal Control / Segregation of Duties Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 529482 2024-003
    Material Weakness
  • 529483 2024-003
    Material Weakness
  • 529484 2024-003
    Material Weakness
  • 529485 2024-003
    Material Weakness
  • 529486 2024-003
    Material Weakness
  • 529487 2024-004
    Material Weakness
  • 529488 2024-004
    Material Weakness
  • 529489 2024-004
    Material Weakness
  • 529490 2024-004
    Material Weakness
  • 529491 2024-004
    Material Weakness
  • 529492 2024-005
    Material Weakness
  • 529493 2024-005
    Material Weakness
  • 529494 2024-005
    Material Weakness
  • 529495 2024-005
    Material Weakness
  • 529496 2024-005
    Material Weakness
  • 529497 2024-006
    Material Weakness
  • 529498 2024-006
    Material Weakness
  • 529499 2024-006
    Material Weakness
  • 529500 2024-006
    Material Weakness
  • 529501 2024-006
    Material Weakness
  • 529502 2024-006
    Material Weakness
  • 529503 2024-006
    Material Weakness
  • 529504 2024-007
    Material Weakness
  • 529505 2024-007
    Material Weakness
  • 529507 2024-007
    Material Weakness
  • 529508 2024-008
    Material Weakness Repeat
  • 529509 2024-008
    Material Weakness Repeat
  • 529510 2024-008
    Material Weakness Repeat
  • 529511 2024-008
    Material Weakness Repeat
  • 529512 2024-008
    Material Weakness Repeat
  • 529513 2024-008
    Material Weakness Repeat
  • 529514 2024-008
    Material Weakness Repeat
  • 529515 2024-009
    Material Weakness Repeat
  • 529516 2024-009
    Material Weakness Repeat
  • 1105924 2024-003
    Material Weakness
  • 1105925 2024-003
    Material Weakness
  • 1105926 2024-003
    Material Weakness
  • 1105927 2024-003
    Material Weakness
  • 1105928 2024-003
    Material Weakness
  • 1105929 2024-004
    Material Weakness
  • 1105930 2024-004
    Material Weakness
  • 1105931 2024-004
    Material Weakness
  • 1105932 2024-004
    Material Weakness
  • 1105933 2024-004
    Material Weakness
  • 1105934 2024-005
    Material Weakness
  • 1105935 2024-005
    Material Weakness
  • 1105936 2024-005
    Material Weakness
  • 1105937 2024-005
    Material Weakness
  • 1105938 2024-005
    Material Weakness
  • 1105939 2024-006
    Material Weakness
  • 1105940 2024-006
    Material Weakness
  • 1105941 2024-006
    Material Weakness
  • 1105942 2024-006
    Material Weakness
  • 1105943 2024-006
    Material Weakness
  • 1105944 2024-006
    Material Weakness
  • 1105945 2024-006
    Material Weakness
  • 1105946 2024-007
    Material Weakness
  • 1105947 2024-007
    Material Weakness
  • 1105948 2024-007
    Material Weakness
  • 1105949 2024-007
    Material Weakness
  • 1105950 2024-008
    Material Weakness Repeat
  • 1105951 2024-008
    Material Weakness Repeat
  • 1105952 2024-008
    Material Weakness Repeat
  • 1105953 2024-008
    Material Weakness Repeat
  • 1105954 2024-008
    Material Weakness Repeat
  • 1105955 2024-008
    Material Weakness Repeat
  • 1105956 2024-008
    Material Weakness Repeat
  • 1105957 2024-009
    Material Weakness Repeat
  • 1105958 2024-009
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.425 Education Stabilization Fund 2023 $306,447
84.010 Title I Grants to Local Educational Agencies 2024 $158,170
84.010 Title I Grants to Local Educational Agencies 2023 $142,251
10.555 National School Lunch Program 2023 $133,028
10.555 National School Lunch Program 2024 $117,724
84.425 Education Stabilization Fund 2024 $106,046
84.424 Student Support and Academic Enrichment Program 2024 $58,811
10.553 School Breakfast Program 2024 $48,082
10.553 School Breakfast Program 2023 $47,913
10.579 Child Nutrition Discretionary Grants Limited Availability 2023 $24,809
84.367 Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) 2024 $17,589
84.367 Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) 2023 $15,546
84.424 Student Support and Academic Enrichment Program 2023 $10,254
10.556 Special Milk Program for Children 2024 $9,842
84.027 Special Education Grants to States 2023 $9,174
84.196 Education for Homeless Children and Youth 2023 $9,000
84.358 Rural Education 2024 $7,514
84.358 Rural Education 2023 $6,514
84.027 Special Education Grants to States 2024 $1,722
10.557 Wic Special Supplemental Nutrition Program for Women, Infants, and Children 2024 $1,681
84.173 Special Education Preschool Grants 2023 $930
10.649 Pandemic Ebt Administrative Costs 2023 $628
84.173 Special Education Preschool Grants 2024 $103