Finding Text
FINDING 2023-008
Subject: COVID-19 - Education Stabilization Fund - Activities Allowed or Unallowed
Federal Agency: Department of Education
Federal Program: COVID-19 - Education Stabilization Fund
Assistance Listings Numbers: 84.425D, 84.425U
Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013,
S425U210013
Pass-Through Entity: Indiana Department of Education
Compliance Requirement: Activities Allowed or Unallowed
Audit Finding: Material Weakness
Condition and Context
The Elementary and Secondary School Emergency Relief (ESSER) Fund provided funding to
states and school districts to combat the effects of the coronavirus, help safely reopen and sustain the safe
operation of schools, and to address the impact of the coronavirus pandemic on the nation's students.
States were required to subgrant a portion of their ESSER allocation to Local Education Agencies (LEA).
Prior to the LEAs receiving their respective subgrants, the LEAs were required to complete an application
for ARP ESSER funding, which was submitted to the Indiana Department of Education, the pass-through
entity for approval. The application included a district level budget identifying how the LEA intended to
spend program funds.
The School Corporation did not have internal controls in place over payroll disbursements charged
to the ESSER grant funds. Payroll disbursements were paid without evidence that the detailed report of
payroll disbursements was reviewed and approved by another person not involved in the original payroll
process.
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). . . ."
INDIANA STATE BOARD OF ACCOUNTS
29
MADISON-GRANT UNITED SCHOOL CORPORATION
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
(Continued)
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 control, 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.