Finding Text
FINDING 2023-004
Subject: COVID-19 - Emergency Connectivity Fund Program - Equipment,
Special Tests and Provisions - Restricted Purpose
Federal Agency: Federal Communications Commission
Federal Program: COVID-19 - Emergency Connectivity Fund Program
Assistance Listings Number: 32.009
Federal Award Number and Year (or Other Identifying Number): 50335
Compliance Requirements: Equipment and Real Property Management, Special
Tests and Provisions - Restricted Purpose
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, noncompliance related to asset inventory and per-user limitations of the devices
purchased with Emergency Connectivity Fund (ECF) Program support.
Equipment Management
For each connected device provided to an individual student, the asset inventory must identify:
1. The device or equipment type (i.e., laptop, tablet, mobile hotspot, modem, router);
2. The device or equipment make/model;
3. The device or equipment serial number;
4. The full name of the person to whom the device was provided; and
5. The dates the device was loaned out and returned to the school or the date the school was
notified that the device was missing, lost, or damaged.
The School Corporation maintained a listing of equipment purchased with program funds;
however, there was no documented oversight or review process to ensure the listing was
accurate and complete.
Special Tests and Provisions - Restricted Purpose
To maximize the use of limited funds per-location and per-user limitation will be imposed. As
such, an eligible school will be reimbursed for no more than one connected device per student,
per school.
School Corporation officials stated that the Asset Management system would not have allowed
the same student to register multiple devices; however, there was no documented oversight or
review to ensure that the user limitations in the system were in place during the audit period,
and operating effectively to ensure a student only had one connected device as required by
the grant award.
INDIANA STATE BOARD OF ACCOUNTS
22
LAWRENCEBURG COMMUNITY SCHOOL CORPORATION
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
(Continued)
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 implemented 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.
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.
Views of Responsible Officials
For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.