Finding 624979 (2022-005)

Material Weakness Repeat Finding
Requirement
G
Questioned Costs
-
Year
2022
Accepted
2023-03-08

AI Summary

  • Core Issue: The School Corporation lacks effective internal controls to ensure compliance with federal grant requirements related to special education funding.
  • Impacted Requirements: Noncompliance with Matching, Level of Effort, and Earmarking requirements, specifically regarding expenditures for non-public students.
  • Recommended Follow-Up: Management should implement internal controls and proper documentation practices to meet grant compliance and expenditure requirements.

Finding Text

FINDING 2022-005 Subject: Special Education Cluster (IDEA) - Earmarking 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): 19611-127-PN01, 20611-127-PN01, 19619-127-PN01, 20619-127-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking Audit Findings: Material Weakness, Modified Opinion Repeat Finding This is a repeat finding from the immediately prior audit. The prior audit finding number was 2020-010. Condition and Context An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Matching, Level of Effort, Earmarking compliance requirement. Proportionate share is an amount of funds that must be expended on special education/related services for parentally-placed private school and homeschooled students. The amount to be spent is automatically calculated within each grant application. The School Corporation had not designed, nor implemented policies and procedures to ensure that the required level of expenditures for non-public students was met for each grant. The School Corporation failed to maintain records of actual time spent providing services to the participating nonpublic schools for Non-Public Proportionate Share expenditures for the 19611-127-PN01, 19619-127-PN01, 20611-127-PN01, and 20619-127-PN01 grant awards. The salaries reported as expended for the nonpublic school expenditures were based on an estimate of time instead of actual time spent. As such, we could not verify that the minimum amount per grant award was expended. The lack of internal controls and noncompliance were isolated to the 19611-127-PN01, 19619-127-PN01, 20611-127-PN01, and 20619-127-PN01 grant awards. 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 awards. 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: . . . (g) Be adequately documented. . . ." 2 CFR 200.208(b) states in part: "The Federal awarding agency or pass-through entity may adjust specific Federal award conditions as needed . . ." 511 IAC 7-34-7(b) states: "The public agency, in providing special education and related services to students in nonpublic schools must expend at least an amount that is the same proportion of the public agency total subgrant under 20 U.S.C. 1411(f) as the number of nonpublic school students with disabilities, who are enrolled by their parents in nonpublic schools within its boundaries, is to the total number of students with disabilities of the same age range." Cause Management had not developed a system of internal control that would have ensured compliance with the grant agreement and the Matching, Level of Effort, Earmarking compliance requirement. Effect The failure to establish an effective internal control system, as well as adequately document costs of federal awards, prevented the determination of the School Corporation's compliance with the earmarking requirements of the Matching, Level of Effort, Earmarking compliance requirement. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish internal controls, as well as appropriately document and identify federal award expenditures, to ensure compliance with the grant agreement and the Matching, Level of Effort, Earmarking compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

Categories

Matching / Level of Effort / Earmarking Allowable Costs / Cost Principles

Other Findings in this Audit

  • 48531 2022-006
    Material Weakness Repeat
  • 48532 2022-006
    Material Weakness Repeat
  • 48533 2022-006
    Material Weakness Repeat
  • 48534 2022-006
    Material Weakness Repeat
  • 48535 2022-006
    Material Weakness Repeat
  • 48536 2022-006
    Material Weakness Repeat
  • 48537 2022-005
    Material Weakness Repeat
  • 48538 2022-005
    Material Weakness Repeat
  • 48539 2022-005
    Material Weakness Repeat
  • 48540 2022-003
    Material Weakness Repeat
  • 48541 2022-004
    Material Weakness Repeat
  • 48542 2022-003
    Material Weakness Repeat
  • 48543 2022-004
    Material Weakness Repeat
  • 48544 2022-008
    Material Weakness
  • 48545 2022-008
    Material Weakness
  • 48546 2022-008
    Material Weakness
  • 48547 2022-007
    Material Weakness
  • 48548 2022-008
    Material Weakness
  • 48549 2022-009
    Material Weakness
  • 48550 2022-008
    Material Weakness
  • 624973 2022-006
    Material Weakness Repeat
  • 624974 2022-006
    Material Weakness Repeat
  • 624975 2022-006
    Material Weakness Repeat
  • 624976 2022-006
    Material Weakness Repeat
  • 624977 2022-006
    Material Weakness Repeat
  • 624978 2022-006
    Material Weakness Repeat
  • 624980 2022-005
    Material Weakness Repeat
  • 624981 2022-005
    Material Weakness Repeat
  • 624982 2022-003
    Material Weakness Repeat
  • 624983 2022-004
    Material Weakness Repeat
  • 624984 2022-003
    Material Weakness Repeat
  • 624985 2022-004
    Material Weakness Repeat
  • 624986 2022-008
    Material Weakness
  • 624987 2022-008
    Material Weakness
  • 624988 2022-008
    Material Weakness
  • 624989 2022-007
    Material Weakness
  • 624990 2022-008
    Material Weakness
  • 624991 2022-009
    Material Weakness
  • 624992 2022-008
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
84.425 Education Stabilization Fund 22 $2.05M
84.027 Special Education_grants to States 22 $1.50M
10.555 National School Lunch Program 22 $1.35M
84.010 Title I Grants to Local Educational Agencies 22 $594,939
84.010 Title I Grants to Local Educational Agencies 21 $490,100
84.027 Special Education_grants to States 21 $404,907
10.553 School Breakfast Program 22 $303,657
84.425 Education Stabilization Fund 21 $296,608
84.367 Improving Teacher Quality State Grants 22 $161,130
10.555 National School Lunch Program 21 $126,907
84.041 Impact Aid 21 $91,304
84.367 Improving Teacher Quality State Grants 21 $78,585
84.424 Student Support and Academic Enrichment Program 22 $73,919
84.041 Impact Aid 22 $66,464
84.048 Career and Technical Education -- Basic Grants to States 22 $63,519
10.553 School Breakfast Program 21 $44,524
84.173 Special Education_preschool Grants 21 $36,962
93.778 Medical Assistance Program 21 $36,397
84.173 Special Education_preschool Grants 22 $36,270
84.424 Student Support and Academic Enrichment Program 21 $23,993
93.778 Medical Assistance Program 22 $22,481
84.358 Rural Education 22 $16,743
84.196 Education for Homeless Children and Youth 22 $4,474
10.649 Pandemic Ebt Administrative Costs 22 $3,063
84.365 English Language Acquisition State Grants 21 $1,598
84.196 Education for Homeless Children and Youth 21 $396