Finding Text
FINDING 2024-008
Subject: Title I Grants to Local Educational Agencies - Eligibility
Federal Agency: Department of Education
Federal Program: Title I Grants to Local Educational Agencies
Assistance Listings Number: 84.010
Federal Award Numbers and Years (or Other Identifying Numbers): S010A220014, S010A230014
Pass-Through Entity: Indiana Department of Education
Compliance Requirement: Eligibility
Audit Finding: Material Weakness
Condition and Context
The School Corporation had not designed or implemented an effective internal control system over
the Eligibility compliance requirement.
Eligibility for Title I is determined on the Eligible School Summary of the Title I application. Enrollment
and Poverty numbers are automatically pulled from the Indiana Department of Education's (IDOE)
Official Pupil Enrollment (PE) count for each school into the Eligible School Summary page of the Title I
application. These counts that are prepopulated should be based on the School Corporation's records as
of October of the prior fiscal year. There was no review by the School Corporation of the enrollment and
poverty counts that were prepopulated into the School Corporation's Title I grant application.
The lack of internal controls was a systemic issue 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). . . ."
Cause
Management did not develop a system of internal controls that segregated key functions over
reporting student enrollment and poverty status to the IDOE via the Title I, Part A grant application.
Effect
Without an effective internal control system, including segregation of duties, the School Corporation
is at risk for noncompliance with the grant agreement and the Eligibility compliance requirement.
Questioned Costs
There were no questioned costs identified.
INDIANA STATE BOARD OF ACCOUNTS
33
EAST NOBLE SCHOOL CORPORATION
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
(Continued)
Recommendation
We recommended that the School Corporation's management establish a system of internal
controls, including segregation of duties, related to the grant agreement and the Eligibility compliance
requirement.
Views of Responsible Officials
For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.