Finding 952499 (2023-002)

Material Weakness
Requirement
B
Questioned Costs
$1
Year
2023
Accepted
2024-03-14

AI Summary

  • Core Issue: The School Corporation failed to maintain necessary documentation for $41,193 in salary expenses related to the 3E Grant, leading to noncompliance with federal cost principles.
  • Impacted Requirements: Lack of internal controls violated 2 CFR 200.303 and 200.403, which mandate effective management and documentation of federal awards.
  • Recommended Follow-Up: Management should implement a robust system of internal controls and develop clear policies and procedures to ensure all costs are properly documented.

Finding Text

FINDING 2023-002 Subject: COVID-19 - Education Stabilization Fund - Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Number: 84.425U Federal Award Number and Year (or Other Identifying Number): S425U210013 Pass-Through Entity: Central Indiana Educational Service Center Compliance Requirement: Allowable Costs/Cost Principles Audit Findings: Material Weakness, Other Matters Condition and Context The School Corporation was the subrecipient of an Explore, Engage, Experience (3E) Grant from the Central Indiana Educational Service Center (CIESC). Per the award letter received from the CIESC, the School Corporation was allocated $200,000 to hire a district coordinator for 3E initiatives. As only one reimbursement covering the period of August 1, 2022 to September 30, 2022, was requested from the CIESC for the 3E grant, all expenditures associated with the grant were selected for testing to verify the expenditures were in conformance with the applicable cost principles. Expenditures totaling $41,193, were for the salary of the grant lead and a secondary salary. No time and effort documentation was maintained to support the salary amounts charged to the program. As a result, these expenditures were determined not to be in conformance with the applicable cost principles and were considered questioned costs. The lack of internal controls and noncompliance were isolated to the 3E Grant expenditures noted above. 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 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 200.430(i) states in part: "Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities . . . (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. . . ." Cause A proper system of internal controls was not designed by management of the School Corporation. 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 implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, costs were not adequately supported by personnel records. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the School Corporation. Questioned Costs Known questioned costs of $41,193 were identified, as detailed in the Condition and Context. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure costs adequately documented. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

Categories

Questioned Costs Allowable Costs / Cost Principles

Other Findings in this Audit

  • 376055 2023-002
    Material Weakness
  • 376056 2023-002
    Material Weakness
  • 376057 2023-002
    Material Weakness
  • 376058 2023-003
    Material Weakness
  • 376059 2023-003
    Material Weakness
  • 376060 2023-003
    Material Weakness
  • 376061 2023-003
    Material Weakness
  • 376062 2023-003
    Material Weakness
  • 376063 2023-004
    Material Weakness
  • 376064 2023-004
    Material Weakness
  • 376065 2023-004
    Material Weakness
  • 376066 2023-004
    Material Weakness
  • 376067 2023-004
    Material Weakness
  • 376068 2023-004
    Material Weakness
  • 952497 2023-002
    Material Weakness
  • 952498 2023-002
    Material Weakness
  • 952500 2023-003
    Material Weakness
  • 952501 2023-003
    Material Weakness
  • 952502 2023-003
    Material Weakness
  • 952503 2023-003
    Material Weakness
  • 952504 2023-003
    Material Weakness
  • 952505 2023-004
    Material Weakness
  • 952506 2023-004
    Material Weakness
  • 952507 2023-004
    Material Weakness
  • 952508 2023-004
    Material Weakness
  • 952509 2023-004
    Material Weakness
  • 952510 2023-004
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
10.555 National School Lunch Program 2022 $1.31M
10.555 National School Lunch Program 2023 $888,320
84.425 Education Stabilization Fund 2022 $660,193
84.027 Special Education_grants to States 2022 $430,242
84.010 Title I Grants to Local Educational Agencies 2022 $253,907
10.553 School Breakfast Program 2022 $181,797
84.010 Title I Grants to Local Educational Agencies 2023 $177,678
10.553 School Breakfast Program 2023 $142,827
84.367 Improving Teacher Quality State Grants 2022 $103,326
84.425 Education Stabilization Fund 2023 $90,276
93.778 Medical Assistance Program 2023 $85,888
84.027 Special Education_grants to States 2023 $75,211
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) 2022 $71,680
93.778 Medical Assistance Program 2022 $36,824
84.173 Special Education_preschool Grants 2023 $33,201
84.367 Improving Teacher Quality State Grants 2023 $27,515
84.424 Student Support and Academic Enrichment Program 2023 $26,585
84.424 Student Support and Academic Enrichment Program 2022 $15,199
84.365 English Language Acquisition State Grants 2022 $5,750
84.365 English Language Acquisition State Grants 2023 $5,220