Finding 943193 (2022-002)

Material Weakness
Requirement
EG
Questioned Costs
-
Year
2022
Accepted
2024-02-09

AI Summary

  • Core Issue: The School Corporation lacks a proper system of internal controls, leading to a material weakness in compliance with Title I grant requirements.
  • Impacted Requirements: Key compliance areas affected include Eligibility, Level of Effort, and Earmarking, which require effective monitoring and documentation.
  • Recommended Follow-Up: Management should design and implement a robust internal control system with clear policies and procedures to ensure proper segregation of duties and oversight.

Finding Text

FINDING 2022-002 Subject: Title I Grants to Local Educational Agencies - Internal Controls 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 FY2021, S010A200014 FY2021 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Eligibility; Matching, Level of Effort, Earmarking Audit Finding: Material Weakness Condition and Context The School Corporation had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting, material noncompliance related to the grant agreement and the Eligibility and Matching, Level of Effort, Earmarking compliance requirements. Eligibility Data from the School Corporation's student software system is uploaded to the Indiana Department of Education's (IDOE) Data Exchange System. Enrollment and poverty information for the School Corporation is then abstracted by the IDOE from the Data Exchange System. The School Corporation's Research and Evaluation team compared the lunch status eligibility used to determine student poverty in the student software system to the information in Data Exchange System at regular intervals. However, this process was not documented and, therefore, could not be verified. INDIANA STATE BOARD OF ACCOUNTS 22 Level of Effort Form 9 data is submitted to the IDOE semi-annually. The data reported includes the School Corporation's expenditures recorded during that period. The IDOE calculates Maintenance of Effort based on the expenditure information submitted on the Form 9 for that fiscal year. To verify amounts used by the IDOE in their computation were derived from the books and records of the School Corporation, costs were reviewed to ensure they are recorded properly as to account and object code and reported correctly on the Form 9. SOUTH BEND COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) For payroll amounts, summary level payroll reports were provided to a knowledgeable employee for review; however, the reports lacked sufficient detail to effectively review and verify the proper employees were paid from the correct fund, account, and object codes. Earmarking A portion of the School Corporation's Title I allocation is required to be set aside for parental involvement and homeless reservation. The required amount to be set aside is indicated in the Title I grant application. The School Corporation is responsible for monitoring each required set aside throughout the life of the grant to ensure the obligation is met. Monitoring of each set aside was completed on the reimbursement requests; however, reimbursement requests, although reviewed by a knowledgeable employee, were supported by summary level payroll data. The summary level payroll did not provide sufficient detail to effectively review and verify the proper employees were paid from or should have been paid from earmarked Title I funds. The lack of internal controls was a systemic issue 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). . . ." Cause A proper system of internal controls was not designed by management of the School Corporation, which would include segregation of key functions. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper design or implementation of the components of a system of internal controls, including policies and procedures that provide segregation of duties and additional oversight as needed, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. Questioned Costs There were no questioned costs identified. INDIANA STATE BOARD OF ACCOUNTS 23 SOUTH BEND COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Recommendation We recommended that management of the School Corporation design and implement a proper system of internal controls, including policies and procedures that would provide segregation of duties to ensure appropriate reviews, approvals, and oversight are taking place.

Categories

Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties Subrecipient Monitoring

Other Findings in this Audit

  • 366751 2022-002
    Material Weakness
  • 366752 2022-003
    Material Weakness
  • 366753 2022-004
    Material Weakness
  • 366754 2022-005
    Material Weakness
  • 366755 2022-006
    Material Weakness
  • 366756 2022-007
    Material Weakness
  • 366757 2022-006
    Material Weakness
  • 366758 2022-007
    Material Weakness
  • 943194 2022-003
    Material Weakness
  • 943195 2022-004
    Material Weakness
  • 943196 2022-005
    Material Weakness
  • 943197 2022-006
    Material Weakness
  • 943198 2022-007
    Material Weakness
  • 943199 2022-006
    Material Weakness
  • 943200 2022-007
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
84.374 Teacher Incentive Fund $6.11M
84.010 Title I Grants to Local Educational Agencies $4.13M
10.559 Summer Food Service Program for Children $2.27M
10.553 School Breakfast Program $2.00M
84.027 Special Education_grants to States $1.50M
84.336 Teacher Quality Partnership Grants $1.26M
84.011 Migrant Education_state Grant Program $1.14M
84.184 Safe and Drug-Free Schools and Communities_national Programs $712,692
93.778 Medical Assistance Program $543,084
84.367 Improving Teacher Quality State Grants $466,510
84.425 Education Stabilization Fund $404,291
84.334 Gaining Early Awareness and Readiness for Undergraduate Programs $397,667
84.048 Career and Technical Education -- Basic Grants to States $336,025
84.424 Student Support and Academic Enrichment Program $316,382
10.555 National School Lunch Program $294,289
84.002 Adult Education - Basic Grants to States $247,225
84.173 Special Education_preschool Grants $205,310
10.582 Fresh Fruit and Vegetable Program $166,413
84.365 English Language Acquisition State Grants $124,736
84.377 School Improvement Grants $107,067
16.839 Stop School Violence $67,553
84.215 Fund for the Improvement of Education $45,750
21.019 Coronavirus Relief Fund $22,380
10.558 Child and Adult Care Food Program $6,253
10.649 Pandemic Ebt Administrative Costs $5,814
93.575 Child Care and Development Block Grant $1,252