Finding 537990 (2024-005)

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

AI Summary

  • Core Issue: The School Corporation failed to properly obligate federal funds within the required 27-month period, leading to potential reimbursement issues.
  • Impacted Requirements: Non-compliance with 2 CFR 200.303 and 2 CFR 200.403(h) regarding the Period of Performance for federal awards.
  • Recommended Follow-Up: Implement a robust system of internal controls to ensure all costs are obligated by the September 30 deadline and comply with grant agreements.

Finding Text

FINDING 2024-005 Subject: Special Education Cluster (IDEA) - Period of Performance 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, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 22611-047-PN01, 22611-047-ARP, 22619-047-PN01, 22619-047-ARP Pass-Through Entity: Indiana Department of Education Compliance Requirement: Period of Performance Audit Findings: Material Weakness, Other Matters Condition and Context During the audit period, the School Corporation was a member of the Cooperative School Services (Cooperative). The Cooperative operated the special education programs and spent the federal money on behalf of its member schools. As the grant agreement was between the Indiana Department of Education and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. For Special Education Cluster awards, funds must be obligated during the 27 months, extending from July 1 of the fiscal year for which the funds were appropriated through September 30 of the second following fiscal year. When testing transactions which occurred in the liquidation period for the 22611-047-PN01, 22611-047-ARP, 22619-047-PN01, and 22619-047-ARP grant awards, two exceptions were identified in the initial sample of five transactions. When expanding the sample, a third exception was noted, and it was concluded that it would not be appropriate to examine the remaining 14 transactions. For the above listed awards, costs must be obligated by September 30, 2023. For the three identified exceptions, an initial purchase order was made in September, but the ultimate transaction was paid to a separate vendor than the original purchase order, and this obligation was incurred in November 2023. 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 22 NORTH NEWTON SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 2 CFR 200.403(h) states: "Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to § 200.308(e)(3)." 34 CFR 76.707 states in part: ". . . If the obligation is for- . . . (d) Performance of work other than personal services. . . . The obligation is made- On the date on which the State or subgrantee makes a binding written commitment to acquire the property. . . ." 2 CFR 200.1 states in part: ". . . Period of Performance means the total estimated time interval between the start of an initial Federal award and the planned end date . . ." 36 CFR 76.709(a) states: "If a State or a subgrantee does not obligate all of its grant or subgrant funds by the end of the fiscal year for which Congress appropriated the funds, it may obligate the remaining funds during a carryover period of one additional fiscal year." Cause Management had established an initial obligation date that occurred in September of the second fiscal year but modified the final vendor for payment. The new obligation occurred after the period in which the School Corporation was allowed to incur the expense. Effect If funds are not obligated by the end of the specified date, the grantor agency is not obligated to reimburse the School Corporation for costs incurred. This may indicate that the funding that was reimbursed, which incurred outside of the period of performance, will need to be repaid to the grantor agency, and the School Corporation will then need to support the costs with nonfederal funding. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure that no costs are incurred after the September 30 deadline and to ensure compliance with the grant agreement and the Period of Performance compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

Categories

Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties Procurement, Suspension & Debarment Subrecipient Monitoring Material Weakness Period of Performance

Other Findings in this Audit

  • 537978 2024-003
    Material Weakness
  • 537979 2024-003
    Material Weakness
  • 537980 2024-003
    Material Weakness
  • 537981 2024-003
    Material Weakness
  • 537982 2024-004
    Material Weakness
  • 537983 2024-004
    Material Weakness
  • 537984 2024-004
    Material Weakness
  • 537985 2024-004
    Material Weakness
  • 537986 2024-004
    Material Weakness
  • 537987 2024-005
    Material Weakness
  • 537988 2024-005
    Material Weakness
  • 537989 2024-005
    Material Weakness
  • 537991 2024-005
    Material Weakness
  • 537992 2024-005
    Material Weakness
  • 537993 2024-005
    Material Weakness
  • 537994 2024-005
    Material Weakness
  • 1114420 2024-003
    Material Weakness
  • 1114421 2024-003
    Material Weakness
  • 1114422 2024-003
    Material Weakness
  • 1114423 2024-003
    Material Weakness
  • 1114424 2024-004
    Material Weakness
  • 1114425 2024-004
    Material Weakness
  • 1114426 2024-004
    Material Weakness
  • 1114427 2024-004
    Material Weakness
  • 1114428 2024-004
    Material Weakness
  • 1114429 2024-005
    Material Weakness
  • 1114430 2024-005
    Material Weakness
  • 1114431 2024-005
    Material Weakness
  • 1114432 2024-005
    Material Weakness
  • 1114433 2024-005
    Material Weakness
  • 1114434 2024-005
    Material Weakness
  • 1114435 2024-005
    Material Weakness
  • 1114436 2024-005
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
10.555 National School Lunch Program 2023 $471,962
10.555 National School Lunch Program 2024 $372,116
84.425 Education Stabilization Fund 2024 $227,933
84.425 Education Stabilization Fund 2023 $212,814
84.010 Title I Grants to Local Educational Agencies 2023 $153,958
10.553 School Breakfast Program 2023 $101,352
10.553 School Breakfast Program 2024 $69,509
93.778 Medical Assistance Program 2024 $45,194
84.027 Special Education Grants to States 2023 $39,490
84.010 Title I Grants to Local Educational Agencies 2024 $36,887
84.367 Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) 2023 $32,051
93.778 Medical Assistance Program 2023 $19,055
84.027 Special Education Grants to States 2024 $18,699
84.424 Student Support and Academic Enrichment Program 2023 $9,679
84.424 Student Support and Academic Enrichment Program 2024 $7,840
10.559 Summer Food Service Program for Children 2024 $1,784
84.173 Special Education Preschool Grants 2024 $1,292
10.649 Pandemic Ebt Administrative Costs 2023 $628
84.173 Special Education Preschool Grants 2023 $45