Finding Text
FINDING 2024-007
Subject: Title I Grants to Local Educational Agencies - Special
Tests and Provisions - Supplement Not Supplant
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: Special Tests and Provisions - Supplement Not Supplant
Audit Finding: Material Weakness
INDIANA STATE BOARD OF ACCOUNTS
28
HUNTINGTON COUNTY COMMUNITY SCHOOL CORPORATION
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
(Continued)
Condition and Context
An effective internal control system was not in place at the School Corporation to ensure
compliance with requirements related to the grant agreement and the Special Tests and Provisions -
Supplement Not Supplant compliance requirement.
The School Corporation was unable to provide evidence of an internal control being in place to
ensure that all Title I schools received an equitable share of the state and local funds that it would have
received had they not been receiving Title I funds.
The Title I applications included the methodology used to distribute state and local funds to all
schools within the School Corporation and documentation was presented for audit that reflected the actual
calculation.
The lack of internal controls was a systemic issue 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 all Title I schools received an equitable share of the state and local funds that it would have
received had they not been receiving Title I funds.
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 Supplement Not Supplant compliance
requirement.
Questioned Costs
There were no questioned costs identified.
Recommendation
We recommended that the School Corporation's management establish a system of internal
controls related to the grant agreement and the Special Tests and Provisions - Supplement Not Supplant
compliance requirement.
INDIANA STATE BOARD OF ACCOUNTS
29
HUNTINGTON COUNTY COMMUNITY SCHOOL CORPORATION
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
(Continued)
Views of Responsible Officials
For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.