Finding Text
FINDING 2024-011
Subject: Special Education Cluster (IDEA) - Level of Effort
Federal Agency: Department of Education
Federal Programs: Special Education Grants to States, COVID-19 - Special Education Grants to States
Assistance Listings Numbers: 84.027, 84.027X
Federal Award Numbers and Years (or Other Identifying Numbers): 21611-027-PN01, 22611-027-PN01,
22611-027-ARP
Pass-Through Entity: Indiana Department of Education
Compliance Requirement: Matching, Level of Effort, Earmarking
Audit Finding: Material Weakness
Condition and Context
Level of Effort - Individual Transactions (Vendor)
The Form 9 (financial) data was submitted by the School Corporation to the Indiana Department
of Education (IDOE) semiannually. The data reported included the School Corporation's
expenditures recorded during that period. The IDOE calculated Maintenance of Effort based
on the expenditure information submitted on the Form 9 for that fiscal year. To verify amounts
used by the IDOE in their computation were derived from the books and records of the School
Corporation, costs were reviewed to ensure they were recorded properly as to account and
object code and reported correctly on the Form 9.
The School Corporation did not have an oversight process in place to ensure that vendor
expenditures were posted to the correct fund, account, and object codes.
The lack of internal controls was a systemic issue throughout the audit period.
INDIANA STATE BOARD OF ACCOUNTS
34
HUNTINGTON COUNTY COMMUNITY SCHOOL CORPORATION
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
(Continued)
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
There was no proper internal control in place to ensure all the nonpublic proportionate share
amounts were being expended properly for Earmarking or reporting of expenditures on the Form 9 for Level
of Effort.
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. As such, potential noncompliance could have occurred with Form 9 reporting.
Questioned Costs
There were no questioned costs identified.
Recommendation
We recommended that management of the School Corporation design and implement a proper
system of internal controls, including policies and procedures that would provide segregation of duties to
ensure appropriate reviews, approvals, and oversight are taking place to ensure compliance.
Views of Responsible Officials
For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.