Finding 539027 (2024-003)

Material Weakness
Requirement
AB
Questioned Costs
$1
Year
2024
Accepted
2025-03-28
Audit: 349745
Organization: Milan Community Schools (IN)
Auditor: Crowe LLP

AI Summary

  • Core Issue: The School District lacks an effective internal control system for managing the Education Stabilization Fund, risking noncompliance with federal requirements.
  • Impacted Requirements: Compliance with 2 CFR 200.403 and 2 CFR 200.303, which outline necessary cost principles and internal control standards for federal awards.
  • Recommended Follow-Up: The School District should maintain proper documentation for vendor and payroll disbursements, including time-and-effort logs for employees charged to federal grants.

Finding Text

Information on the federal program: Subject: COVID-19 – Education Stabilization Fund – Activities Allowed or Unallowed/Allowable Costs Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425C, 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425C200018, S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Finding: Material Weakness, Other Matters Criteria: 2 CFR 200.403 establishes principles and standards for determining costs for federal awards carried out through grants, cost reimbursement contracts, and other agreements with state and local governments. To be allowable, under federal awards, cost must meet certain criteria: a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. g) Be adequately documented. h) Cost must be incurred during the approved budget period. Additionally, 2 CFR 200.303 indicates that non-Federal Entities receiving Federal awards must 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 terms and conditions of the Federal award. Condition: An effective internal control system was not in place at the School District to ensure compliance with requirements related to the Education Stabilization Fund and Activities Allowed or Unallowed. Cause: The School District's management had not developed a system of internal controls that would have ensured compliance with the Activities Allowed or Unallowed compliance requirement. Effect: The failure to establish an effective internal control system placed the School District at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: $5,651 (Known questioned costs). Context: During the testing of vendor and payroll disbursements charged to Education Stabilization Fund grant awards during the audit period, the following exceptions were noted:  Management was unable to provide an approved accounts payable voucher and supporting invoice for one vendor disbursement in a sample of 12 vendor disbursements.  For one salaried employee selected out of a sample of 40 payroll disbursements, the employee was charged to Education Stabilization Fund grants for 50% of their time worked in a pay period. The School Corporation did not maintain any time-and-effort logs to support the employee’s partial allocation to Education Stabilization Fund grants. Identification as a repeat finding, if applicable: No. Recommendation: We recommended that the School District maintain supporting documentation for vendor and payroll disbursements to support costs charged to the federal grant awards. For payroll disbursements charged to Federal awards, management should maintain time and effort records to support payroll costs allocated to Education Stabilization Grant funds to verify they are allowable and supported by documentation for work performed under the award. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.

Categories

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

Other Findings in this Audit

  • 539019 2024-002
    Material Weakness Repeat
  • 539020 2024-002
    Material Weakness Repeat
  • 539021 2024-002
    Material Weakness Repeat
  • 539022 2024-002
    Material Weakness Repeat
  • 539023 2024-002
    Material Weakness Repeat
  • 539024 2024-003
    Material Weakness
  • 539025 2024-003
    Material Weakness
  • 539026 2024-004
    Material Weakness
  • 539028 2024-004
    Material Weakness
  • 539029 2024-003
    Material Weakness
  • 539030 2024-004
    Material Weakness
  • 539031 2024-003
    Material Weakness
  • 539032 2024-004
    Material Weakness
  • 1115461 2024-002
    Material Weakness Repeat
  • 1115462 2024-002
    Material Weakness Repeat
  • 1115463 2024-002
    Material Weakness Repeat
  • 1115464 2024-002
    Material Weakness Repeat
  • 1115465 2024-002
    Material Weakness Repeat
  • 1115466 2024-003
    Material Weakness
  • 1115467 2024-003
    Material Weakness
  • 1115468 2024-004
    Material Weakness
  • 1115469 2024-003
    Material Weakness
  • 1115470 2024-004
    Material Weakness
  • 1115471 2024-003
    Material Weakness
  • 1115472 2024-004
    Material Weakness
  • 1115473 2024-003
    Material Weakness
  • 1115474 2024-004
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
84.425 Education Stabilization Fund $584,758
10.553 School Breakfast Program $167,047
84.010 Title I Grants to Local Educational Agencies $149,085
93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance $125,000
10.555 National School Lunch Program $111,595
32.009 Emergency Connectivity Fund Program $98,176
10.579 Child Nutrition Discretionary Grants Limited Availability $30,000
84.367 Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) $28,047
84.196 Education for Homeless Children and Youth $24,990
93.778 Medical Assistance Program $17,685
84.027 Special Education Grants to States $10,204
84.424 Student Support and Academic Enrichment Program $10,000
10.559 Summer Food Service Program for Children $5,106
10.649 Pandemic Ebt Administrative Costs $628