Finding 537939 (2024-001)

Material Weakness
Requirement
I
Questioned Costs
-
Year
2024
Accepted
2025-03-27

AI Summary

  • Core Issue: The School Corporation failed to verify that vendors paid over $25,000 with Special Education funds were not suspended or debarred, lacking necessary documentation.
  • Impacted Requirements: Noncompliance with federal regulations (2 CFR 200.303 and 31 CFR 180.300) regarding vendor eligibility checks and internal controls.
  • Recommended Follow-Up: Strengthen internal controls to ensure vendor eligibility checks are performed and documented for all transactions over $25,000 funded by federal programs.

Finding Text

FINDING 2024-001 Subject: Special Education Cluster (IDEA) - Suspension and Debarment Federal Agency: Department of Education Federal Programs: Special Education Grants to States, COVID-19 - Special Education Grants to States, Special Education Preschool Grants, COVID-19 - Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.027X, 84.173, 84.173X Federal Award Numbers and Years (or Other Identifying Numbers): H027A190084, 22611-093-ARP, H173A180104, H173A210104, 22619-093-ARP Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Condition and Context Prior to entering into a covered transaction for goods and services equal to or over $25,000 that were paid with Special Education Cluster funds, recipients are required to verify that such contractors or vendors are not suspended, debarred, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. The verification is to be done by checking SAM Exclusions, collecting a certification from that person, or adding a clause or condition to the covered transaction with that person. Upon inquiry of the School Corporation, the procedures in place over suspension and debarment during the audit period were to verify new vendors, when being entered into the system, were not excluded on SAM.gov. However, the School Corporation did not retain documentation of SAM.gov verifications, nor were checks done each year to verify that applicable vendors were still considered eligible under federal requirements. A population of six covered transactions for goods or services, totaling $569,754, that equaled or exceeded $25,000 paid from Special Education funds during the audit period was identified. No documentation was available to verify that the School Corporation performed the required checks. The lack of effective 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 16 KOKOMO SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 31 CFR 180.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person if allowed by this rule; or (c) Adding a clause or condition to the covered transaction with that person." Cause A proper system of internal controls was not designed by the management of the School Corporation. The School Corporation was unable to provide documentation to demonstrate it checked SAM.gov or received certification from applicable vendors to verify that contractors and vendors were not suspended or debarred. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. No documentation existed to ensure vendors to whom payments equal to or in excess of $25,000 were verified to not be suspended, debarred, or otherwise excluded. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation strengthen its system of internal controls to ensure that all vendors that are paid $25,000 or more, all or in part with federal funds, are not suspended or debarred from participating in federal program before entering into any covered transactions and retain documentation to support the performance of these procedures. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 537933 2024-001
    Material Weakness
  • 537934 2024-001
    Material Weakness
  • 537935 2024-001
    Material Weakness
  • 537936 2024-001
    Material Weakness
  • 537937 2024-001
    Material Weakness
  • 537938 2024-001
    Material Weakness
  • 537940 2024-001
    Material Weakness
  • 537941 2024-002
    Material Weakness Repeat
  • 537942 2024-002
    Material Weakness Repeat
  • 537943 2024-002
    Material Weakness Repeat
  • 537944 2024-002
    Material Weakness Repeat
  • 1114375 2024-001
    Material Weakness
  • 1114376 2024-001
    Material Weakness
  • 1114377 2024-001
    Material Weakness
  • 1114378 2024-001
    Material Weakness
  • 1114379 2024-001
    Material Weakness
  • 1114380 2024-001
    Material Weakness
  • 1114381 2024-001
    Material Weakness
  • 1114382 2024-001
    Material Weakness
  • 1114383 2024-002
    Material Weakness Repeat
  • 1114384 2024-002
    Material Weakness Repeat
  • 1114385 2024-002
    Material Weakness Repeat
  • 1114386 2024-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.010 Title I Grants to Local Educational Agencies 2024 $3.48M
93.600 Head Start 2024 $3.18M
10.555 National School Lunch Program 2024 $3.08M
84.010 Title I Grants to Local Educational Agencies 2023 $2.00M
84.027 Special Education Grants to States 2024 $1.87M
84.027 Special Education Grants to States 2023 $1.53M
10.553 School Breakfast Program 2023 $1.05M
10.553 School Breakfast Program 2024 $1.00M
93.575 Child Care and Development Block Grant 2023 $946,670
84.367 Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) 2024 $405,611
84.425 Education Stabilization Fund 2023 $355,768
84.048 Career and Technical Education -- Basic Grants to States 2024 $300,705
84.367 Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) 2023 $291,460
93.575 Child Care and Development Block Grant 2024 $276,490
84.048 Career and Technical Education -- Basic Grants to States 2023 $229,391
10.555 National School Lunch Program 2023 $221,875
93.600 Head Start 2023 $211,076
84.334 Gaining Early Awareness and Readiness for Undergraduate Programs 2024 $178,875
93.778 Medical Assistance Program 2023 $149,203
32.004 Universal Service Fund - Schools and Libraries 2023 $135,461
93.778 Medical Assistance Program 2024 $123,874
84.424 Student Support and Academic Enrichment Program 2024 $122,097
84.425 Education Stabilization Fund 2024 $109,771
84.173 Special Education Preschool Grants 2024 $104,183
84.173 Special Education Preschool Grants 2023 $98,101
10.558 Child and Adult Care Food Program 2024 $93,728
84.002 Adult Education - Basic Grants to States 2024 $83,519
10.558 Child and Adult Care Food Program 2023 $80,813
84.002 Adult Education - Basic Grants to States 2023 $57,467
84.424 Student Support and Academic Enrichment Program 2023 $42,854
84.196 Education for Homeless Children and Youth 2023 $29,380
10.582 Fresh Fruit and Vegetable Program 2023 $28,244
84.334 Gaining Early Awareness and Readiness for Undergraduate Programs 2023 $27,525
10.559 Summer Food Service Program for Children 2024 $20,311
10.559 Summer Food Service Program for Children 2023 $17,053
84.196 Education for Homeless Children and Youth 2024 $15,620
84.365 English Language Acquisition State Grants 2024 $12,569
84.365 English Language Acquisition State Grants 2023 $11,251
93.566 Refugee and Entrant Assistance State/replacement Designee Administered Programs 2024 $8,565
93.566 Refugee and Entrant Assistance State/replacement Designee Administered Programs 2023 $2,554
32.004 Universal Service Fund - Schools and Libraries 2024 $1,031