Finding 638607 (2022-004)

Material Weakness
Requirement
I
Questioned Costs
-
Year
2022
Accepted
2023-03-12
Audit: 58369
Organization: Union School Corporation (IN)
Auditor: Crowe LLP

AI Summary

  • Core Issue: The School Corporation lacked an effective internal control system to ensure compliance with federal procurement and suspension/debarment requirements.
  • Impacted Requirements: Noncompliance with 2 CFR sections 200.303, 200.318(a), 200.320, and 180.300 regarding procurement processes and verification of service provider eligibility.
  • Recommended Follow-Up: Implement procedures to ensure compliance with grant agreement requirements and establish a robust internal control system for procurement and oversight.

Finding Text

Finding 2022-004 Information on the federal program: Subject: Special Education Cluster ? Procurement and Suspension and Debarment Federal Agency: Department of Education Federal Program: Special Education Cluster Assistance Listing Number: 84.027 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Material Weakness, Modified Opinion Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards 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 200.318(a) states: "The non-Federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in this part." 2 CFR 200.320 states in part: "The non-Federal Entity must use one of the following methods of procurement. . . . (b) Formal procurement methods. When the value of the procurement for property or services under a Federal financial assistance award exceeds the SAT, or a lower threshold established by a non-Federal entity, formal procurement methods are required. Formal procurement methods require following documented procedures. Formal procurement methods also require public advertising unless a non-competitive procurement can be used in accordance with ? 200.319 or paragraph (c) of this section. The following formal methods of procurement are used for procurement of property or services above the simplified acquisition threshold or a value below the simplified acquisition threshold the non-Federal entity determines to be appropriate: (1) Sealed bids (2) Proposals Section III ? Federal Award Findings and Questioned Costs (Continued) 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 the SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person." Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirements. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with the compliance requirements listed above. Effect: The failure to establish an effective internal control system enabled noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There were no questioned costs identified. Context: The School Corporation did not perform a formal procurement when the School Corporation signed a contract with the service provider in July 2017. Additionally, the contract was extended in February 2019 through June 30, 2029 without a formal procurement process. The School Corporation did not have procedures in place to ensure the service provider was not debarred or suspended when the original contracts and amendments were signed. Identification as a repeat finding: No. Recommendation: We recommend the School Corporation implement procedures to ensure compliance with the grant agreement requirements and the procurement and suspension and debarment compliance requirement. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.

Categories

Procurement, Suspension & Debarment Internal Control / Segregation of Duties

Other Findings in this Audit

  • 62157 2022-002
    Material Weakness
  • 62158 2022-003
    Material Weakness
  • 62159 2022-004
    Material Weakness
  • 62160 2022-002
    Material Weakness
  • 62161 2022-003
    Material Weakness
  • 62162 2022-004
    Material Weakness
  • 62163 2022-002
    Material Weakness
  • 62164 2022-003
    Material Weakness
  • 62165 2022-004
    Material Weakness
  • 638599 2022-002
    Material Weakness
  • 638600 2022-003
    Material Weakness
  • 638601 2022-004
    Material Weakness
  • 638602 2022-002
    Material Weakness
  • 638603 2022-003
    Material Weakness
  • 638604 2022-004
    Material Weakness
  • 638605 2022-002
    Material Weakness
  • 638606 2022-003
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
84.027 Special Education_grants to States $539,356
84.010 Title I Grants to Local Educational Agencies $501,869
84.367 Supporting Effective Instruction State Grants $52,769
84.425 Covid-19 Education Stabilization Fund $35,026
10.559 Summer Food Service Program for Children $30,663
10.579 Child Nutrition Discretionary Grants Limited Availability $19,672
84.358 Rural Education $13,840
84.424 Student Support and Academic Enrichment Program $10,000