Finding 544731 (2024-005)

Material Weakness
Requirement
AB
Questioned Costs
-
Year
2024
Accepted
2025-03-31

AI Summary

  • Core Issue: The School Corporation lacked an effective internal control system, particularly in segregating duties for payroll and vendor payments related to the COVID-19 Education Stabilization Fund.
  • Impacted Requirements: Noncompliance with 2 CFR 200.303, which mandates effective internal controls to ensure proper management of federal awards.
  • Recommended Follow-Up: Management should implement a robust internal control system with proper segregation of duties to prevent and detect noncompliance with grant agreements.

Finding Text

FINDING 2024-005 Subject: COVID-19 - Education Stabilization Fund - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S425U200013 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Finding: Material Weakness Condition and Context An effective internal control system, which would include segregation of duties, was not in place at the School Corporation in order to ensure payroll and vendor payments paid from the COVID-19 - Education Stabilization Fund was allowable and in conformance with the cost principles. The School Corporation did not implement or maintain supporting documentation of the reviews or approval by a knowledgeable person to ensure allowability and conformance with cost principles for payroll and vendor disbursements from the COVID-19 - Education Stabilization Fund grants. The lack of internal controls was a systematic issue during the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: INDIANA STATE BOARD OF ACCOUNTS 24 LIBERTY-PERRY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (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 A proper system of internal controls was not designed by management of the School Corporation, which would include appropriate segregation of duties. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. The School Corporation has policies to establish internal controls and procedures, but did not establish proper internal controls. Effect The failure to establish an effective internal control system could enable material noncompliance to go undetected. Noncompliance with the grant agreement and the Activities Allowed or Unallowed and the Allowable Costs/Cost Principles compliance requirements could have resulted in the loss of federal funds. Questioned Costs There were no questioned costs identified. 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 compliance requirements listed above. An internal control system, including segregation of duties, should be designed and operate effectively to provide reasonable assurance that material noncompliance with the grant agreement or a compliance requirement of a federal program will be prevented, or detected and corrected, on a timely basis. In order to have an effective internal control system, it is important to have proper segregation of duties. This is accomplished by making sure proper oversight, reviews, and approvals take place and to have a separation of functions over certain activities related to the program. The fundamental premise of segregation of duties is that an individual or small group of individuals should not be in a position to initiate, approve, undertake, and review the same activity. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

Categories

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Material Weakness Subrecipient Monitoring Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 544718 2024-003
    Material Weakness Repeat
  • 544719 2024-003
    Material Weakness Repeat
  • 544720 2024-003
    Material Weakness Repeat
  • 544721 2024-003
    Material Weakness Repeat
  • 544722 2024-003
    Material Weakness Repeat
  • 544723 2024-003
    Material Weakness Repeat
  • 544724 2024-004
    Material Weakness
  • 544725 2024-004
    Material Weakness
  • 544726 2024-004
    Material Weakness
  • 544727 2024-004
    Material Weakness
  • 544728 2024-004
    Material Weakness
  • 544729 2024-004
    Material Weakness
  • 544730 2024-005
    Material Weakness
  • 544732 2024-005
    Material Weakness
  • 544733 2024-006
    Material Weakness
  • 544734 2024-006
    Material Weakness
  • 544735 2024-006
    Material Weakness
  • 544736 2024-007
    Material Weakness
  • 544737 2024-007
    Material Weakness
  • 544738 2024-007
    Material Weakness
  • 1121160 2024-003
    Material Weakness Repeat
  • 1121161 2024-003
    Material Weakness Repeat
  • 1121162 2024-003
    Material Weakness Repeat
  • 1121163 2024-003
    Material Weakness Repeat
  • 1121164 2024-003
    Material Weakness Repeat
  • 1121165 2024-003
    Material Weakness Repeat
  • 1121166 2024-004
    Material Weakness
  • 1121167 2024-004
    Material Weakness
  • 1121168 2024-004
    Material Weakness
  • 1121169 2024-004
    Material Weakness
  • 1121170 2024-004
    Material Weakness
  • 1121171 2024-004
    Material Weakness
  • 1121172 2024-005
    Material Weakness
  • 1121173 2024-005
    Material Weakness
  • 1121174 2024-005
    Material Weakness
  • 1121175 2024-006
    Material Weakness
  • 1121176 2024-006
    Material Weakness
  • 1121177 2024-006
    Material Weakness
  • 1121178 2024-007
    Material Weakness
  • 1121179 2024-007
    Material Weakness
  • 1121180 2024-007
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
84.425 Education Stabilization Fund 2023 $796,579
10.555 National School Lunch Program 2023 $517,059
10.555 National School Lunch Program 2024 $437,219
84.425 Education Stabilization Fund 2024 $367,286
84.027 Special Education Grants to States 2024 $248,683
84.010 Title I Grants to Local Educational Agencies 2023 $158,022
10.553 School Breakfast Program 2023 $108,097
10.553 School Breakfast Program 2024 $96,538
84.010 Title I Grants to Local Educational Agencies 2024 $85,118
84.367 Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) 2024 $53,431
84.367 Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) 2023 $32,840
84.424 Student Support and Academic Enrichment Program 2024 $23,232
84.424 Student Support and Academic Enrichment Program 2023 $21,213
10.559 Summer Food Service Program for Children 2024 $12,590
10.559 Summer Food Service Program for Children 2023 $12,407
84.173 Special Education Preschool Grants 2023 $10,245
84.173 Special Education Preschool Grants 2024 $9,125
84.027 Special Education Grants to States 2023 $8,551
93.354 Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response 2024 $7,888
93.778 Medical Assistance Program 2023 $6,406
93.778 Medical Assistance Program 2024 $4,472
93.354 Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response 2023 $4,035