Finding 960076 (2023-005)

Material Weakness
Requirement
L
Questioned Costs
-
Year
2023
Accepted
2024-03-22
Audit: 296662
Organization: Southwest School Corporation (IN)
Auditor: Crowe LLP

AI Summary

  • Core Issue: The School Corporation lacked effective internal controls to ensure compliance with federal reporting requirements for the Special Education Cluster.
  • Impacted Requirements: Noncompliance with 2 CFR 200.303 and 200.302(b) led to inaccuracies in reimbursement requests and inadequate documentation.
  • Recommended Follow-Up: Management should implement a robust internal control system and develop clear policies and procedures for accurate reporting and documentation.

Finding Text

FINDING 2023-005 Information on the federal program: Subject: Special Education Cluster (IDEA) - Reporting Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.027X, 84.173, 84.173X Federal Award Numbers and Years (or Other Identifying Numbers): 19611-022-PN01, 20611-022-PN01, 21611-022-PN01, 22611-022-PN01, 22611-022-ARP, 23611-022-PN01, 20619-022-PN01, 21619-022- PN01, 22619-022-PN01, 22611-022-ARP, 23611-022-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Qualified Opinion FINDING 2023-005 (Continued) Criteria: 2 CFR 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 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following: (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . .” 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." 2 CFR 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 34 CFR 76.731 states: "A State and a subgrantee shall keep records to show its compliance with program requirements." Condition: The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the reporting requirements. The Cooperative had not designed or implemented adequate policies or procedures to determine that requests for reimbursement were submitted accurately and agreed to supporting documentation. There was a documented oversight, review, and approval process in place; however, the Cooperative did not adequately ensure that proper procedures were followed. 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. FINDING 2023-005 (Continued) 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, amounts requested for reimbursement could not be traced to the Cooperative’s ledgers for expenditures. Noncompliance with the grant agreement and the compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs: There were no questioned costs identified. Context: The School Corporation is a member of the Greene-Sullivan Special Education Cooperative (Cooperative). During fiscal year 2021-2022, the Cooperative operated the special education programs and spent the federal money on behalf of all its members.  As the grant agreements were between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. However, there was inadequate oversight performed by the School Corporation in order to ensure compliance with the Reporting compliance requirement. The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the reporting requirements. The Cooperative had not designed or implemented adequate policies or procedures to determine that requests for reimbursement were submitted accurately and agreed to supporting documentation. There was a documented oversight, review, and approval process in place; however, the Cooperative did not adequately ensure that proper procedures were followed. For fiscal year 2022, 51 Reimbursement Reports were tested. 14 Reimbursement Reports could not be traced to unit ledgers for expenditures, and 21 Reports did not have appropriate supporting documentation. For fiscal year 2023, 23 Reimbursement Reports were tested. Three Reimbursements Report did not agree to supporting documentation, and key line items could not be verified. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Identification as a repeat finding: No Recommendation: We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure supporting documentation is used and retained for all reimbursement requests submitted. fficials and Planned Corrective Actions: Management agrees with the finding has prepared a corrective action plan.

Categories

Subrecipient Monitoring Internal Control / Segregation of Duties Matching / Level of Effort / Earmarking Cash Management Material Weakness Reporting

Other Findings in this Audit

  • 383601 2023-002
    Material Weakness
  • 383602 2023-002
    Material Weakness
  • 383603 2023-002
    Material Weakness
  • 383604 2023-002
    Material Weakness
  • 383605 2023-002
    Material Weakness
  • 383606 2023-002
    Material Weakness
  • 383607 2023-002
    Material Weakness
  • 383608 2023-002
    Material Weakness
  • 383609 2023-002
    Material Weakness
  • 383610 2023-002
    Material Weakness
  • 383611 2023-002
    Material Weakness
  • 383612 2023-003
    Significant Deficiency
  • 383613 2023-003
    Significant Deficiency
  • 383614 2023-003
    Significant Deficiency
  • 383615 2023-003
    Significant Deficiency
  • 383616 2023-004
    Material Weakness
  • 383617 2023-004
    Material Weakness
  • 383618 2023-004
    Material Weakness
  • 383619 2023-004
    Material Weakness
  • 383620 2023-004
    Material Weakness
  • 383621 2023-004
    Material Weakness
  • 383622 2023-004
    Material Weakness
  • 383623 2023-004
    Material Weakness
  • 383624 2023-004
    Material Weakness
  • 383625 2023-004
    Material Weakness
  • 383626 2023-004
    Material Weakness
  • 383627 2023-005
    Material Weakness
  • 383628 2023-005
    Material Weakness
  • 383629 2023-005
    Material Weakness
  • 383630 2023-005
    Material Weakness
  • 383631 2023-005
    Material Weakness
  • 383632 2023-005
    Material Weakness
  • 383633 2023-005
    Material Weakness
  • 383634 2023-005
    Material Weakness
  • 383635 2023-005
    Material Weakness
  • 383636 2023-005
    Material Weakness
  • 383637 2023-005
    Material Weakness
  • 383638 2023-006
    Material Weakness
  • 960043 2023-002
    Material Weakness
  • 960044 2023-002
    Material Weakness
  • 960045 2023-002
    Material Weakness
  • 960046 2023-002
    Material Weakness
  • 960047 2023-002
    Material Weakness
  • 960048 2023-002
    Material Weakness
  • 960049 2023-002
    Material Weakness
  • 960050 2023-002
    Material Weakness
  • 960051 2023-002
    Material Weakness
  • 960052 2023-002
    Material Weakness
  • 960053 2023-002
    Material Weakness
  • 960054 2023-003
    Significant Deficiency
  • 960055 2023-003
    Significant Deficiency
  • 960056 2023-003
    Significant Deficiency
  • 960057 2023-003
    Significant Deficiency
  • 960058 2023-004
    Material Weakness
  • 960059 2023-004
    Material Weakness
  • 960060 2023-004
    Material Weakness
  • 960061 2023-004
    Material Weakness
  • 960062 2023-004
    Material Weakness
  • 960063 2023-004
    Material Weakness
  • 960064 2023-004
    Material Weakness
  • 960065 2023-004
    Material Weakness
  • 960066 2023-004
    Material Weakness
  • 960067 2023-004
    Material Weakness
  • 960068 2023-004
    Material Weakness
  • 960069 2023-005
    Material Weakness
  • 960070 2023-005
    Material Weakness
  • 960071 2023-005
    Material Weakness
  • 960072 2023-005
    Material Weakness
  • 960073 2023-005
    Material Weakness
  • 960074 2023-005
    Material Weakness
  • 960075 2023-005
    Material Weakness
  • 960077 2023-005
    Material Weakness
  • 960078 2023-005
    Material Weakness
  • 960079 2023-005
    Material Weakness
  • 960080 2023-006
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
84.425 Covid-19 - Education Stabilization Fund $1.40M
10.553 School Breakfast Program $561,369
84.027 Special Education_grants to States $283,763
84.010 Title I Grants to Local Educational Agencies $245,898
10.555 National School Lunch Program $152,768
84.027 Covid-19 - Special Education_grants to States $74,887
93.778 Medical Assistance Program $63,594
84.424 Student Support and Academic Enrichment Program $20,815
84.173 Special Education_preschool Grants $13,485
84.173 Covid-19 - Special Education_preschool Grants $2,704
10.649 Pandemic Ebt Administrative Costs $1,242
84.367 Improving Teacher Quality State Grants $723