Finding Text
2022-005 Authorization of Children?s Service Plans Information of the Federal Programs Department of Education AL #84.181 - Special Education - Grants for Infants and Families ? Major Program Passed through State of Maine Department of Education July 1, 2021 - June 30, 2022 Department of Education Special Education Cluster (IDEA) AL #84.027 - Special Education ? Grants to States ? Major Program AL #84.173 - Special Education - Preschool Grants ? Major Program Passed through State of Maine Department of Education July 1, 2021 - June 30, 2022 Repeat Audit Finding: Audit Finding #2021-004 Significant Deficiency Criteria All service plans should be authorized by a designated individual with the appropriate experience or certification and accordingly be documented within the child?s file. This authorization represents approval for the specific services indicated in the child?s plan. The plan is considered authorized when the designated individual electronically locks the plan within CINC. Condition The internal controls over compliance for allowable activities and allowable costs are substantially the same for AL #84.027, #84.173 and AL #84.181. In response to prior year findings, CDS developed a corrective action plan which addressed the importance of documenting the authorization of children?s service plans by working to establish an acceptable time frame protocol for the time between the date a plan is written and the date the plan is locked. The acceptable time frame was also to be monitored at both the Regional Site level by the respective Regional Site program managers and the State level by the quality assurance director. While it was noted that monitoring aspects were implemented at the State and Regional Site level, several instances were still noted in which a plan was unlocked or not locked within the acceptable timeframe. Additionally, it was noted that there were several instances of plans locked by unauthorized individuals. Cause Inconsistent controls and lack of available qualified staff to properly monitor all plans resulted in unlocked plans and unauthorized individuals locking plans, some of which were created at inception and others whereby modifications were made to the plan requiring the file to be re-approved (locked). Effect A critical internal control procedure over financial reporting and compliance is having an appropriate individual with the proper knowledge, experience, and authority to commit funds on behalf of CDS. When the authorization is not documented, there is no assurance that the child?s plans have been reviewed for allowable activities and allowable costs in accordance with CDS policies and the Maine Department of Education Regulations, Chapter 101, Maine Unified Special Education Regulation Birth to Age Twenty. The result is that CDS is at risk for potential noncompliance or misstatement of the financial statements. Context The situations noted in the audit did not result in reportable questioned costs; however, exceptions were still noted in the controls that were tested. The results of the various tests performed throughout the audit yielded an exception rate of 13% based on our sample size. The sample was not intended to be, and was not, a statistically valid sample. Recommendation We recommend that CDS clearly communicate the acceptable time frame policy between the date a plan is written and the date the plan is locked. Furthermore, although program managers at the Regional Site levels are reviewing the unfinalized plan report from CINC on a regular basis, at the State level, we recommend that the quality assurance director continue to perform inspection of the unfinalized plan report from CINC on a regular basis to review the status of all unlocked plans beyond the established time and contact the Regional Sites as needed. In addition, we recommend that it is clearly communicated that individuals must possess the appropriate qualifications to lock plans and that user access rights for locking plans be restricted to only those with the proper qualifications. Alternatively, if management determines that locking children?s plans may no longer be the most effective and efficient means of documenting approval, we recommend that another approach be determined and implemented. If so, we recommend that management consult with the database provider to consider feasibility of other options, such as implementing a field for electronic signature of the authorized individual, or auto-flow updates for plans pending approval. Grantee Response Management agrees with the finding. See the Organization?s corrective action plan for an update on how management plans to address the internal control weaknesses noted in this finding. CDS will continue monitoring the effectiveness of the corrective action plan to ensure the risks associated with financial reporting and noncompliance are mitigated.