Finding Text
2022-004 Impact Aid Application Controls (Repeated 2023-004)
CFDA Title: Impact Aid
CFDA Number: 84.041
Federal Award Number:
Federal Agency: Department of Education
Pass-through Entity:
Condition:
The District does not have an internal control system in place to ensure that supporting documentation is maintained to support the Impact Aid Applications for the elementary and high school. This is a repeat finding from the prior year audit.
Criteria:
1. 2 CFR section 200.303 requires that the District establish and maintain an effective internal control system over the federal award to provide reasonable assurance that the District is managing the federal awards in compliance with federal statutes, regulations and the terms and conditions of the federal award.
2. Application for Impact Aid - Section 7003 (OMB No. 1810-0687) - Each year an LEA must submit this application, which provides the following information: counts of federally connected children in various categories, membership and average daily attendance data, and information on expenditures for children with disabilities. This form is in the Impact Aid Grant System, which does not have a public link, therefore school districts will need to provide a copy to the auditor.
Context:
We requested the supporting documentation to test the compliance of reported students counts on the elementary and high school impact aid applications, but the District had a difficult time providing the supporting application and trust land documentation to support the application. The verification of the trust land students from the Tribe had to be provided again from the trip to support spreadsheets of the students and their addresses.
Effect:
The District risk of noncompliance with federal programs increases if documentation is not maintained to support those compliance requirements.
Cause:
The District did not establish and maintain an adequate internal control system ensure that supporting documentation is maintained to support the membership counts of the children who live on Indian lands.
Recommendation:
We recommend that the District review its internal control systems over its Impact Aid application, and ensure that the document management systems are adequate to ensure appropriate filing of supporting documentation to the applications are maintained so that information can be found in future years.