Finding 547034 (2024-005)

Material Weakness Repeat Finding
Requirement
L
Questioned Costs
-
Year
2024
Accepted
2025-03-31

AI Summary

  • Core Issue: The School Corporation failed to report the correct expenditures for ESSER II and ESSER III, continuing a pattern of noncompliance from previous audits.
  • Impacted Requirements: The lack of effective internal controls violated federal reporting standards, specifically under 2 CFR 200.303 and 34 CFR 76.722.
  • Recommended Follow-Up: Management should implement a robust system of internal controls and update policies to ensure accurate reporting of expenditures moving forward.

Finding Text

FINDING 2024-005 Subject: COVID-19 - Education Stabilization Fund - Reporting 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): S425D200013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2022-003. Condition and Context Internal controls were in place over reporting where two individuals were involved in submitting and reviewing the reports prior to submission. However, the internal controls were not effective in order to ensure compliance with requirements related to the grant agreement and the following compliance requirement: Reporting. INDIANA STATE BOARD OF ACCOUNTS 24 MT. VERNON COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) The School Corporation was required to submit an annual data report to the Indiana Department of Education. Data to be submitted includes, but is not limited to, current period expenditure, prior period expenditure, and expenditures per activity. During the audit period, the School Corporation submitted 2021-2022 expenditures for ESSER II - Year 3 and ESSER III - Year 3 instead of reporting 2022-2023 expenditures for ESSER II - Year 3 and ESSER III - Year 3. The lack of effective internal controls was systemic throughout the audit period. The noncompliance was isolated to the ESSER II - Year 3 and ESSER III - Year 3 reporting. 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). . . ." 2 CFR 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for the Federal awards that are renewed quarterly or annual, from the date of submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Cause The School Corporation had policies and procedures in place over proper reporting on its annual data report; however, officials indicated their understanding of the guidance provided as to which year's expenditures were to be reported was different than what was required. INDIANA STATE BOARD OF ACCOUNTS 25 MT. VERNON COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. Expenditures reported on the annual data report for ESSER II and ESSER III year 3 were not accurate. Questioned Costs There were no questioned costs identified. Recommendation We recommended the School Corporation's management establish a proper system of internal controls and develop policies and procedures to ensure expenditures on the annual data reporting for ESSER II and ESSER III are accurate. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

Corrective Action Plan

FINDING 2024-005 Finding Subject:. The School Corporation was required to submit annual data reports to the Indiana Department of Education (IDOE) via JotForm, a form/report builder. Data to be submitted included, but was not limited to, current period expenditures, prior period expenditures, and expenditures per activity. During the audit period, the School Corporation was required to submit five annual data reports as outlined below. Fund Applicable Reporting Period ESSER I July 1, 2021 – June 30, 2022 ESSER II July 1, 2021 – June 30, 2022 ESSER III July 1, 2021 – June 30, 2022 ESSER II July 1, 2022 – June 30, 2023 ESSER III July 1, 2022 – June 30, 2023 All five annual data reports were selected for testing. Two of the five annual data reports did not include the correct expenditure information. Specifically the ESSER II and ESSER III annual data reports with an applicable reporting period of July 1, 2022, to June 30, 2023, did not include expenditure data for this period. Instead, the annual reports incorrectly reported expenditures from the previous period of July 1, 2021 to June 30, 2022. Contact Person Responsible for Corrective Action: Greg Elkins, CFO Contact Phone Number and Email Address: (317) 485-3100, greg.elkins@mvcsc.k12.in.us Views of Responsible Officials: We agree with the finding. Description of Corrective Action Plan: Since the conclusion of the 2020-2022 SBOA audit, the CFO and Corporation Treasurer have archived numerous email threads and other evidence of communication which documents the process for pulling ESSER financial data from the Skyward Finance system and submitting the required reports. This documentation shows the CFO and Treasurer regularly communicating, checking and rechecking the data, and verifying the timely submission of that data. The school received periodic requests from the Indiana Department of Education, Office of Federal Grants asking it to submit financial data for all ESSER funds. Originally, the data requests were submitted through JotForms which do not have the capability of notifying any individuals other than the recipient. The school was required to create its own documents for proof of submission and did so. In subsequent requests, IDOE provided Excel spreadsheets to be completed and returned electronically. Those emails and spreadsheets have been curated by the school. The school has documented unclear instructions provided by IDOE, the pass through agency. The school accepts responsibility to report grant activity for the federally required reporting periods regardless. The school will ask for explicit instructions from IDOE and reconfirm the reporting data required and time period(s) in question. This additional layer of internal controls will be added to the process currently utilized by the CFO and Corporation Treasurer. The school has not expended any dollars from any ESSER fund since 2023. Anticipated Completion Date: TBD based on when the next reporting submission is requested by IDOE (all ESSER grants activities have ceased and the funds have been closed out locally.)

Categories

Subrecipient Monitoring Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties Material Weakness Reporting

Other Findings in this Audit

  • 547022 2024-003
    Material Weakness
  • 547023 2024-003
    Material Weakness
  • 547024 2024-003
    Material Weakness
  • 547025 2024-003
    Material Weakness
  • 547026 2024-003
    Material Weakness
  • 547027 2024-003
    Material Weakness
  • 547028 2024-003
    Material Weakness
  • 547029 2024-004
    Material Weakness
  • 547030 2024-004
    Material Weakness
  • 547031 2024-004
    Material Weakness
  • 547032 2024-004
    Material Weakness
  • 547033 2024-004
    Material Weakness
  • 547035 2024-005
    Material Weakness Repeat
  • 547036 2024-005
    Material Weakness Repeat
  • 547037 2024-005
    Material Weakness Repeat
  • 547038 2024-005
    Material Weakness Repeat
  • 1123464 2024-003
    Material Weakness
  • 1123465 2024-003
    Material Weakness
  • 1123466 2024-003
    Material Weakness
  • 1123467 2024-003
    Material Weakness
  • 1123468 2024-003
    Material Weakness
  • 1123469 2024-003
    Material Weakness
  • 1123470 2024-003
    Material Weakness
  • 1123471 2024-004
    Material Weakness
  • 1123472 2024-004
    Material Weakness
  • 1123473 2024-004
    Material Weakness
  • 1123474 2024-004
    Material Weakness
  • 1123475 2024-004
    Material Weakness
  • 1123476 2024-005
    Material Weakness Repeat
  • 1123477 2024-005
    Material Weakness Repeat
  • 1123478 2024-005
    Material Weakness Repeat
  • 1123479 2024-005
    Material Weakness Repeat
  • 1123480 2024-005
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
10.555 National School Lunch Program 2023 $1.36M
10.555 National School Lunch Program 2024 $1.27M
84.425 Education Stabilization Fund 2023 $851,979
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) 2023 $685,524
84.010 Title I Grants to Local Educational Agencies 2024 $279,032
10.553 School Breakfast Program 2024 $201,588
10.553 School Breakfast Program 2023 $184,549
93.778 Medical Assistance Program 2024 $178,929
84.027 Special Education Grants to States 2023 $128,433
93.778 Medical Assistance Program 2023 $117,045
32.009 Emergency Connectivity Fund Program 2023 $102,398
84.010 Title I Grants to Local Educational Agencies 2023 $98,549
84.367 Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) 2023 $97,659
84.027 Special Education Grants to States 2024 $95,923
84.367 Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) 2024 $52,249
84.425 Education Stabilization Fund 2024 $51,809
84.424 Student Support and Academic Enrichment Program 2024 $25,888
84.365 English Language Acquisition State Grants 2023 $19,756
84.173 Special Education Preschool Grants 2024 $16,743
84.365 English Language Acquisition State Grants 2024 $13,019
84.424 Student Support and Academic Enrichment Program 2023 $3,346
84.173 Special Education Preschool Grants 2023 $1,327