Finding 57924 (2022-002)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2022
Accepted
2023-03-21

AI Summary

  • Core Issue: The School Corporation lacks adequate internal controls to ensure compliance with suspension and debarment requirements for special education grants.
  • Impacted Requirements: Non-compliance with 2 CFR 200.303 regarding effective internal control over federal awards, leading to a repeat finding from the previous audit.
  • Recommended Follow-Up: Management should implement robust internal controls to ensure adherence to grant agreements and compliance requirements.

Finding Text

FINDING 2022-002 Subject: Special Education Cluster (IDEA) - Suspension and Debarment Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 21611-047-PN01, 21619-047-PN01, 22611-047-PN01, 22619-047- PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Material Weakness INDIANA STATE BOARD OF ACCOUNTS 15 KANKAKEE VALLEY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2020-003. Condition and Context The School Corporation is a member of the Cooperative School Services (Cooperative). The Cooperative operated the special education programs on behalf of the School Corporation and managed the Special Education grant funds. As the grant agreement was between the Indiana Department of Education and the School Corporation, the School Corporation was responsible for compliance with the grant agreement and the suspension and debarment requirements of the Procurement and Suspension and Debarment compliance requirement. The School Corporation did not have adequate internal controls in place to ensure the Cooperative complied with the suspension and debarment requirements. The Special Education Director obtained suspension and debarment certifications for contracted vendors over $25,000 without an oversight or review process. 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 Management had not developed a system of internal controls that would have ensured compliance with the grant agreement and the suspension and debarment requirements of the Procurement and Suspension and Debarment compliance requirement. Effect The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the suspension and debarment requirements of the Procurement and Suspension and Debarment compliance requirement. Questioned Costs There were no questioned costs identified. INDIANA STATE BOARD OF ACCOUNTS 16 KANKAKEE VALLEY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Recommendation We recommended that the School Corporation's management establish internal controls to ensure compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. 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 2022-002 Contact Person Responsible for Corrective Action: Chris Richie Contact Phone Number: 219 987 4711 ext.113 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Cooperative School Services will implement the following procedures: o Post open position on IDOE site and other similar job sites that might be appropriate: print and save the posting/advertisement. o Post on Cooperative School Services website. o Advertise the position in a newspaper if it is a shortage area and few responses are anticipated through the posting on IDOE such that it might be a contracted position. Keep a copy of the advertisement. o Send posting to contracting companies/vendors if it is a shortage area and few responses are anticipated through posting on IDOE such that it might be a contracted position. Document contacts with the companies. o Hold interviews with any prospective staff member(s) and review qualifications. o Review the potential contract and salary/hourly rate of potential staff member(s) for non- contract company candidates and contracting company candidates. o If there is only one potential staff member and that person is available through contracting companies, inquire with other companies as to the rate for a comparable individual?s contract with their companies and/or other school districts to see what their rates are for the same position. o Make a determination about the person to hire based upon interviews, references, skills, experience, etc. o If using a contracting company, verify Suspension/Debarment status of the selected company. Have two (2) individuals within the CSS office review and verify the S/D status, then sign off on the S/D form provided through CSS after the vendor has completed the form. o Send letter to Fiscal Agent Superintendent and School Board seeking approval of contract. o Following board approval, sign contract and return to contracting company. o Check for returned contract, signed by representative of the company. o Send copies of fully signed contract to Fiscal Agent School Corporation Treasurer and CSS Bookkeeper. o Provide the CSS board with information regarding the contracting arrangements and the S/D status of the vendor. o Send copies of Susp/Debarment documentation to each corporation Attn: Supt and Treasurer with the spreadsheet of contracting information. Anticipated Completion Date: 3/31/23

Categories

Procurement, Suspension & Debarment Internal Control / Segregation of Duties

Other Findings in this Audit

  • 57925 2022-003
    Material Weakness
  • 60695 2022-002
    Material Weakness Repeat
  • 60696 2022-003
    Material Weakness
  • 60697 2022-003
    Material Weakness
  • 60698 2022-002
    Material Weakness Repeat
  • 60699 2022-003
    Material Weakness
  • 60700 2022-004
    Material Weakness
  • 60701 2022-005
    Material Weakness
  • 60702 2022-006
    Material Weakness
  • 60703 2022-004
    Material Weakness
  • 60704 2022-005
    Material Weakness
  • 60705 2022-006
    Material Weakness
  • 60706 2022-004
    Material Weakness
  • 60707 2022-005
    Material Weakness
  • 60708 2022-006
    Material Weakness
  • 60709 2022-004
    Material Weakness
  • 60710 2022-005
    Material Weakness
  • 60711 2022-006
    Material Weakness
  • 60712 2022-004
    Material Weakness
  • 60713 2022-005
    Material Weakness
  • 60714 2022-006
    Material Weakness
  • 634366 2022-002
    Material Weakness Repeat
  • 634367 2022-003
    Material Weakness
  • 637137 2022-002
    Material Weakness Repeat
  • 637138 2022-003
    Material Weakness
  • 637139 2022-003
    Material Weakness
  • 637140 2022-002
    Material Weakness Repeat
  • 637141 2022-003
    Material Weakness
  • 637142 2022-004
    Material Weakness
  • 637143 2022-005
    Material Weakness
  • 637144 2022-006
    Material Weakness
  • 637145 2022-004
    Material Weakness
  • 637146 2022-005
    Material Weakness
  • 637147 2022-006
    Material Weakness
  • 637148 2022-004
    Material Weakness
  • 637149 2022-005
    Material Weakness
  • 637150 2022-006
    Material Weakness
  • 637151 2022-004
    Material Weakness
  • 637152 2022-005
    Material Weakness
  • 637153 2022-006
    Material Weakness
  • 637154 2022-004
    Material Weakness
  • 637155 2022-005
    Material Weakness
  • 637156 2022-006
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
10.559 Summer Food Service Program for Children Fy 22 $1.93M
10.559 Summer Food Service Program for Children Fy 21 $1.33M
84.027 Special Education_grants to States Fy 22 $808,676
84.027 Special Education_grants to States Fy 21 $802,396
84.425 Education Stabilization Fund Fy 22 $596,813
84.010 Title I Grants to Local Educational Agencies Fy 22 $326,939
84.010 Title I Grants to Local Educational Agencies Fy 21 $299,076
84.425 Education Stabilization Fund Fy 21 $259,794
10.555 National School Lunch Program Fy 21 $238,800
10.555 National School Lunch Program Fy 22 $159,493
84.367 Improving Teacher Quality State Grants Fy 22 $99,604
93.778 Medical Assistance Program Fy 21 $92,257
32.009 Emergency Connectivity Fund Program Fy 22 $80,000
84.367 Improving Teacher Quality State Grants Fy 21 $58,811
84.173 Special Education_preschool Grants Fy 22 $32,760
84.424 Student Support and Academic Enrichment Program Fy 21 $22,794
84.173 Special Education_preschool Grants Fy 21 $21,863
10.553 School Breakfast Program Fy 21 $19,490
84.365 English Language Acquisition State Grants Fy 22 $11,977
84.365 English Language Acquisition State Grants Fy 21 $11,825
84.048 Career and Technical Education -- Basic Grants to States Fy 21 $5,000
10.649 Pandemic Ebt Administrative Costs Fy 22 $3,063
93.778 Medical Assistance Program Fy 22 $-60,725