Finding 560654 (2023-010)

Material Weakness
Requirement
B
Questioned Costs
-
Year
2023
Accepted
2025-05-19

AI Summary

  • Core Issue: The School Corporation lacked effective internal controls, leading to improper documentation of expenses for the COVID-19 Education Stabilization Fund.
  • Impacted Requirements: Noncompliance with federal cost principles, specifically regarding documentation and approval of expenditures.
  • Recommended Follow-Up: Management should implement a robust internal control system and develop clear policies and procedures for documenting costs.

Finding Text

FINDING 2023-010 Subject: COVID-19 - Education Stabilization Fund - 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, S425U210013 Pass-Through Entity: Department of Education Compliance Requirement: Allowable Costs/Cost Principles Audit Findings: Material Weakness, Other Matters Condition and Context The Elementary and Secondary School Emergency Relief (ESSER) Fund provided funding to states and school districts to help safely reopen and sustain the safe operation of schools and to address the impact of the coronavirus pandemic on the nation's students. States were required to subgrant a portion of their ESSER allocations to Local Educational Agencies (LEA). Prior to the LEAs receiving their respective subgrants, the LEAs were required to complete an application for the ESSER funding, which was submitted to the Indiana Department of Education (IDOE), the pass-through entity for approval. The application included a district level budget identifying how the LEA intended to spend program funds. A sample of 25 claims charged to the ESSER grant program for which reimbursement was received during the audit period was selected for testing to verify that the expenditures were in conformance with the applicable cost principles. Of the 25 claims tested, the following errors were noted: INDIANA STATE BOARD OF ACCOUNTS 32 SHENANDOAH SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued)  Two claims, totaling $983, were for payments to a teacher for part-time tutoring. However, there was not a School Board approved contract or Salary Ordinance that showed the approval of this position or the rate to be paid.  Two claims, totaling $318,922, were for payments for playground equipment; however, the related contract supporting the purchase was not provided. The lack of effective internal controls and noncompliance were systemic issues 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). . . ." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. . . . (g) Be adequately documented. . . ." 2 CFR 200.430(i) states in part: "Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non- Federal entity, not exceeding 100% of compensated activities (for IHE, this per the IHE's definition of IBS); . . . INDIANA STATE BOARD OF ACCOUNTS 33 SHENANDOAH SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. . . ." Cause A proper system of internal controls was not designed by the School Corporation's management. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. 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 a result, expenses were paid without adequate supporting documentation. Noncompliance with the grant agreement and the compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a proper system of internal controls and develop policies and procedures to ensure costs are adequately documented. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

Categories

Allowable Costs / Cost Principles

Other Findings in this Audit

  • 560623 2023-003
    Material Weakness
  • 560624 2023-003
    Material Weakness
  • 560625 2023-003
    Material Weakness
  • 560626 2023-003
    Material Weakness
  • 560627 2023-003
    Material Weakness
  • 560628 2023-004
    Material Weakness
  • 560629 2023-004
    Material Weakness
  • 560630 2023-004
    Material Weakness
  • 560631 2023-004
    Material Weakness
  • 560632 2023-004
    Material Weakness
  • 560633 2023-005
    Material Weakness Repeat
  • 560634 2023-005
    Material Weakness Repeat
  • 560635 2023-006
    Material Weakness
  • 560636 2023-006
    Material Weakness
  • 560637 2023-006
    Material Weakness
  • 560638 2023-006
    Material Weakness
  • 560639 2023-006
    Material Weakness
  • 560640 2023-007
    Material Weakness
  • 560641 2023-007
    Material Weakness
  • 560642 2023-007
    Material Weakness
  • 560643 2023-007
    Material Weakness
  • 560644 2023-007
    Material Weakness
  • 560645 2023-008
    Material Weakness
  • 560646 2023-009
    Material Weakness
  • 560647 2023-009
    Material Weakness
  • 560648 2023-009
    Material Weakness
  • 560649 2023-009
    Material Weakness
  • 560650 2023-009
    Material Weakness
  • 560651 2023-010
    Material Weakness
  • 560652 2023-010
    Material Weakness
  • 560653 2023-010
    Material Weakness
  • 560655 2023-011
    Material Weakness
  • 560656 2023-011
    Material Weakness
  • 560657 2023-011
    Material Weakness
  • 560658 2023-011
    Material Weakness
  • 1137065 2023-003
    Material Weakness
  • 1137066 2023-003
    Material Weakness
  • 1137067 2023-003
    Material Weakness
  • 1137068 2023-003
    Material Weakness
  • 1137069 2023-003
    Material Weakness
  • 1137070 2023-004
    Material Weakness
  • 1137071 2023-004
    Material Weakness
  • 1137072 2023-004
    Material Weakness
  • 1137073 2023-004
    Material Weakness
  • 1137074 2023-004
    Material Weakness
  • 1137075 2023-005
    Material Weakness Repeat
  • 1137076 2023-005
    Material Weakness Repeat
  • 1137077 2023-006
    Material Weakness
  • 1137078 2023-006
    Material Weakness
  • 1137079 2023-006
    Material Weakness
  • 1137080 2023-006
    Material Weakness
  • 1137081 2023-006
    Material Weakness
  • 1137082 2023-007
    Material Weakness
  • 1137083 2023-007
    Material Weakness
  • 1137084 2023-007
    Material Weakness
  • 1137085 2023-007
    Material Weakness
  • 1137086 2023-007
    Material Weakness
  • 1137087 2023-008
    Material Weakness
  • 1137088 2023-009
    Material Weakness
  • 1137089 2023-009
    Material Weakness
  • 1137090 2023-009
    Material Weakness
  • 1137091 2023-009
    Material Weakness
  • 1137092 2023-009
    Material Weakness
  • 1137093 2023-010
    Material Weakness
  • 1137094 2023-010
    Material Weakness
  • 1137095 2023-010
    Material Weakness
  • 1137096 2023-010
    Material Weakness
  • 1137097 2023-011
    Material Weakness
  • 1137098 2023-011
    Material Weakness
  • 1137099 2023-011
    Material Weakness
  • 1137100 2023-011
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
10.555 National School Lunch Program 2022 $635,492
10.555 National School Lunch Program 2023 $588,240
84.425 Education Stabilization Fund 2023 $505,770
84.425 Education Stabilization Fund 2022 $399,665
84.010 Title I Grants to Local Educational Agencies 2022 $194,077
84.010 Title I Grants to Local Educational Agencies 2023 $160,964
10.553 School Breakfast Program 2023 $100,944
10.553 School Breakfast Program 2022 $94,867
84.367 Improving Teacher Quality State Grants 2022 $47,504
84.367 Improving Teacher Quality State Grants 2023 $36,434
84.027 Special Education_grants to States 2023 $32,184
84.027 Special Education_grants to States 2022 $26,617
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) 2022 $24,157
10.559 Summer Food Service Program for Children 2022 $20,984
84.424 Student Support and Academic Enrichment Program 2022 $13,175
84.424 Student Support and Academic Enrichment Program 2023 $11,075
84.173 Special Education_preschool Grants 2022 $4,843
10.649 Pandemic Ebt Administrative Costs 2023 $628
10.649 Pandemic Ebt Administrative Costs 2022 $614
84.173 Special Education_preschool Grants 2023 $422