Finding Text
FINDING 2022-005 Subject: Title I Grants to Local Educational Agencies - Eligibility 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): S010A190014, S010A200014, S010A210014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Findings: Material Weakness, Other Matters Condition and Context An effective internal control system was not designed, nor implemented at the School Corporation to ensure compliance with requirements related to the grant agreement and the Eligibility compliance requirement. School Corporations with participating non-public school children were required to enter the total enrollment and poverty count children into the Title I application. This is to ensure the proper count of nonpublic students are reported to the Indiana Department of Education in order for participating non-public students to receive Title I services. The School Corporation had used the correct non-public school data when completing both Title I applications during the audit period. However, the total enrollment and poverty students at the non-public schools were incorrect for both years. The lack of 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). . . ." 34 CFR 200.64(a)(3)(i) states: "To obtain a count of private school children from low-income families who reside in participating public school attendance areas, the LEA may ? (A) Use the same poverty data the LEA uses to count public school children; (B) (1) Use comparable poverty data from a survey of families of private school students that, to the extent possible, protects the families' identity; and INDIANA STATE BOARD OF ACCOUNTS 25 BEECH GROVE CITY SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (2) Extrapolate data from the survey based on a representative sample if complete actual data are unavailable; (C) Use comparable poverty data from a different source, such as scholarship applications; (D) Apply the low-income percentage of each participating public school attendance area to the number of private school children who reside in that school attendance area; or (E) Use an equated measure of low income correlated with the measure of low income used to count public school children." Cause Management had not developed or implemented a system of internal control that would have ensured compliance with the grant agreement and the Eligibility compliance requirement. Effect The failure to establish an effective internal control system enabled noncompliance to go undetected. Noncompliance with the grant agreement and the Eligibility compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs No questioned costs were identified. Recommendation We recommended that the School Corporation's management establish a system of internal control to ensure compliance and comply with the grant agreement and the Eligibility compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.