Finding Text
FINDING 2024-004
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): S010A210014, S010A220014,
S010A230014
Pass-Through Entity: Indiana Department of Education
Compliance Requirement: Eligibility
Audit Finding: Material Weakness
INDIANA STATE BOARD OF ACCOUNTS
23
HUNTINGTON COUNTY COMMUNITY SCHOOL CORPORATION
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
(Continued)
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. The counts that are prepopulated should be based on the School Corporation's records
as of October of the prior fiscal year.
During the audit period, the School Corporation submitted two Title I Applications. The School
Corporation was required to use the October 2021 Real Time Report data for the 2022-2023 Title I
application and the October 2022 Real Time Report data for the 2023-2024 Title I Application submitted to
the IDOE. Data to be submitted included student socioeconomic status information.
The October 2021 and 2022 reports were available for review and the Title I Director cross checks
the information in the Title I application with the October enrollment and poverty rates at each school from
the Certification Summary reports; however, no other school personnel verifies the Title I numbers on the
application. Additionally, the nonpublic school sends its annual enrollment and poverty counts to the Title
I Director, but the Title I Director does not verify these student numbers are accurate. The Title I Director
does verify the student addresses are within the district, but she does not verify the enrollment and poverty
are correct.
The lack of internal controls was systemic 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
A proper system of internal controls was not designed by management of the School Corporation
to ensure enrollment and poverty rates were properly reported on the Title I 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
24
HUNTINGTON COUNTY COMMUNITY SCHOOL CORPORATION
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
(Continued)
Recommendation
We recommended that management of the School Corporation establish a proper system of
internal controls over Real Time reports.
Views of Responsible Officials
For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.