Finding 635065 (2022-003)

Material Weakness
Requirement
I
Questioned Costs
-
Year
2022
Accepted
2023-03-22

AI Summary

  • Core Issue: The School Corporation lacked adequate oversight and internal controls regarding compliance with federal procurement and suspension/debarment requirements for special education funding.
  • Impacted Requirements: Noncompliance with 2 CFR 200.303 and 2 CFR 180.300, which mandate effective internal controls and verification of vendor eligibility for federal awards.
  • Recommended Follow-Up: Management should implement a robust system of internal controls to ensure compliance with procurement and suspension/debarment requirements moving forward.

Finding Text

FINDING 2022-003 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): 19611-021-PN01, 20611-021-PN01, 20619-021-PN01, 21611-021-PN01, 21619-021-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Other Matters INDIANA STATE BOARD OF ACCOUNTS 19 TIPPECANOE SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Condition and Context The School Corporation is a member of the Greater Lafayette Area Special Services Cooperative (Cooperative). During fiscal year 2020-2021, the Cooperative operated the special education programs and spent the federal money on behalf of all its members. As the grant agreements were between the Indiana Department of Education and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. However, there was inadequate oversight performed by the School Corporation in order to ensure compliance with the Procurement and Suspension and Debarment compliance requirement. The Cooperative was a planning district whose purpose was to provide free appropriate public education to students identified as disabled in accordance with state statute who were legal residents and/or have been accepted through means of open enrollment, or other legal means of transfer to the participating member school corporations in Tippecanoe County. The School Corporation did not have internal controls in place to ensure compliance with the suspension and debarment requirement. The Cooperative did not have adequate internal controls in place to ensure all applicable vendors were not suspended or debarred. Therefore, vendors with contracts over $25,000 were not verified to ensure they were not excluded or disqualified from participation in federal awards programs. The lack of effective internal controls and noncompliance were systemic issues isolated to the 2020-2021 fiscal year. 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 180.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person." INDIANA STATE BOARD OF ACCOUNTS 20 TIPPECANOE SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Cause The School Corporation's management had not developed a system of internal controls that would have ensured compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Effect The failure to establish an effective system of internal controls enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement could have resulted in the loss of 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 system of internal controls to ensure compliance and comply with 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.

Categories

Procurement, Suspension & Debarment Internal Control / Segregation of Duties

Other Findings in this Audit

  • 58618 2022-002
    Material Weakness
  • 58619 2022-003
    Material Weakness
  • 58620 2022-004
    Material Weakness
  • 58621 2022-004
    Material Weakness
  • 58622 2022-002
    Material Weakness
  • 58623 2022-003
    Material Weakness
  • 58624 2022-004
    Material Weakness
  • 635060 2022-002
    Material Weakness
  • 635061 2022-003
    Material Weakness
  • 635062 2022-004
    Material Weakness
  • 635063 2022-004
    Material Weakness
  • 635064 2022-002
    Material Weakness
  • 635066 2022-004
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
10.555 National School Lunch Program Fy 22 $6.85M
84.027 Special Education_grants to States Fy 21 $2.78M
84.027 Special Education_grants to States Fy 22 $2.66M
84.425 Education Stabilization Fund Fy 21 $2.46M
84.010 Title I Grants to Local Educational Agencies Fy 21 $1.52M
10.553 School Breakfast Program Fy 22 $1.48M
84.010 Title I Grants to Local Educational Agencies Fy 22 $1.35M
10.559 Summer Food Service Program for Children Fy 22 $733,428
84.425 Education Stabilization Fund Fy 22 $678,071
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) Fy 22 $524,869
10.555 National School Lunch Program Fy 21 $448,257
84.048 Career and Technical Education -- Basic Grants to States Fy 21 $426,984
84.367 Improving Teacher Quality State Grants Fy 22 $397,491
84.048 Career and Technical Education -- Basic Grants to States Fy 22 $337,918
84.367 Improving Teacher Quality State Grants Fy 21 $199,542
84.424 Student Support and Academic Enrichment Program Fy 21 $118,066
10.559 Summer Food Service Program for Children Fy 21 $113,749
84.173 Special Education_preschool Grants Fy 22 $110,581
84.365 English Language Acquisition State Grants Fy 21 $92,323
84.173 Special Education_preschool Grants Fy 21 $90,006
10.553 School Breakfast Program Fy 21 $72,556
84.365 English Language Acquisition State Grants Fy 22 $72,514
32.009 Emergency Connectivity Fund Program Fy 22 $35,200
84.424 Student Support and Academic Enrichment Program Fy 22 $10,565
10.649 Pandemic Ebt Administrative Costs Fy 22 $3,063