Finding 961948 (2023-004)

Material Weakness
Requirement
AB
Questioned Costs
-
Year
2023
Accepted
2024-03-27

AI Summary

  • Core Issue: The School Corporation failed to provide adequate oversight of the Clark County Joint Services Program, leading to noncompliance with federal requirements regarding allowable costs and activities.
  • Impacted Requirements: Internal controls over payroll and vendor disbursements were ineffective, resulting in missing documentation and potential misuse of federal funds.
  • Recommended Follow-Up: Implement stronger internal controls and regular audits to ensure compliance with federal guidelines and proper documentation for all expenditures.

Finding Text

FINDING 2023-004 Subject: Special Education Cluster (IDEA) - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 19611-158-PN01, 19619-158-PN01, 20611-158-PN01, 20619-158-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Findings: Material Weakness, Other Matters Condition and Context The School Corporation was a member of the Clark County Joint Services Program (Cooperative). During fiscal year 2021-2022, the Cooperative operated the special education programs and spent the federal money on behalf of all its member school corporations. As the grant agreements were between the Indiana Department of Education (IDOE) and each member school corporation, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. However, there was inadequate oversight performed by the School Corporation to ensure compliance with the Activities Allowed or Unallowed and the Allowable Costs/Cost Principles compliance requirements. The Cooperative did not have internal controls in place over payroll transactions to ensure expenditures were allowed and in conformance with the cost principles. The Treasurer reviewed a report which showed the total amount paid from each fund and account; however, a detailed payroll report was not reviewed which would have identified the employee being paid from the grant fund. For vendor disbursements, although the Deputy Treasurer matched the invoice to the purchase order and provided it to the Corporation Treasurer for review and signature of the Accounts Payable Voucher (claim) prior to payment, the internal control was not effective and did not detect or allow correction of errors. In the initial sample of 6 vendor disbursements, one claim was unable to be provided. As the error was isolated to vendor disbursements, the sample of vendor disbursements only was increased by 31. Within the new sample of 31 vendor disbursements, an additional claim was unable to be provided. As both vendor disbursements with missing documentation were travel expense reimbursements made to the same employee, the ledger was reviewed for additional travel disbursements to that individual. None were identified; thus, no further testing was determined to be necessary. INDIANA STATE BOARD OF ACCOUNTS 20 SILVER CREEK SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) The lack of internal controls over payroll disbursements was isolated to 2021-2022. The ineffective internal controls and noncompliance over vendor disbursements were isolated to the two travel claims 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 200.334 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 300.202(a) states: "General. Amounts provided to the LEA under Part B of the Act - (1) Must be expended in accordance with the applicable provisions of this part; (2) Must be used only to pay the excess costs of providing special education and related services to children with disabilities, consistent with paragraph (b) of this section; and (3) Must be used to supplement State, local, and other Federal funds and not to supplant those funds." 34 CFR 300.208 states: "(a) Uses. Notwithstanding §§ 300.202, 300.203(b), and 300.162(b), funds provided to an LEA under Part B of the Act may be used for the following activities: (1) Services and aids that also benefit nondisabled children. For the costs of special education and related services, and supplementary aids and services, provided in a regular class or other education-related setting to a child with a disability in accordance with the IEP of the child, even if one or more nondisabled children benefit from these services. (2) Early intervening services. To develop and implement coordinated, early intervening educational services in accordance with § 300.226. INDIANA STATE BOARD OF ACCOUNTS 21 SILVER CREEK SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (3) High cost special education and related services. To establish and implement cost or risk sharing funds, consortia, or cooperatives for the LEA itself, or for LEAs working in a consortium of which the LEA is a part, to pay for high cost special education and related services. (b) Administrative case management. An LEA may use funds received under Part B of the Act to purchase appropriate technology for recordkeeping, data collection, and related case management activities of teachers and related services personnel providing services described in the IEP of children with disabilities, that is needed for the implementation of those case management activities." 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: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items . . . (g) Be adequately documented. . . ." 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, appropriate documentation for two travel claims was not retained. 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 There were no questioned costs identified. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure that documentation will be maintained and made available for audit. INDIANA STATE BOARD OF ACCOUNTS 22 SILVER CREEK SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

Categories

Allowable Costs / Cost Principles Subrecipient Monitoring

Other Findings in this Audit

  • 385501 2023-002
    Material Weakness
  • 385502 2023-002
    Material Weakness
  • 385503 2023-003
    Material Weakness
  • 385504 2023-003
    Material Weakness
  • 385505 2023-004
    Material Weakness
  • 385506 2023-004
    Material Weakness
  • 385507 2023-005
    Material Weakness
  • 385508 2023-005
    Material Weakness
  • 385509 2023-006
    Material Weakness
  • 385510 2023-006
    Material Weakness
  • 385511 2023-007
    Material Weakness
  • 385512 2023-007
    Material Weakness
  • 385513 2023-008
    Material Weakness
  • 385514 2023-008
    Material Weakness
  • 385515 2023-008
    Material Weakness
  • 385516 2023-008
    Material Weakness
  • 385517 2023-009
    Material Weakness
  • 385518 2023-009
    Material Weakness
  • 385519 2023-010
    Material Weakness
  • 385520 2023-010
    Material Weakness
  • 961943 2023-002
    Material Weakness
  • 961944 2023-002
    Material Weakness
  • 961945 2023-003
    Material Weakness
  • 961946 2023-003
    Material Weakness
  • 961947 2023-004
    Material Weakness
  • 961949 2023-005
    Material Weakness
  • 961950 2023-005
    Material Weakness
  • 961951 2023-006
    Material Weakness
  • 961952 2023-006
    Material Weakness
  • 961953 2023-007
    Material Weakness
  • 961954 2023-007
    Material Weakness
  • 961955 2023-008
    Material Weakness
  • 961956 2023-008
    Material Weakness
  • 961957 2023-008
    Material Weakness
  • 961958 2023-008
    Material Weakness
  • 961959 2023-009
    Material Weakness
  • 961960 2023-009
    Material Weakness
  • 961961 2023-010
    Material Weakness
  • 961962 2023-010
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
10.555 National School Lunch Program 2022 $1.32M
10.555 National School Lunch Program 2023 $1.05M
84.425 Education Stabilization Fund 2023 $752,597
84.027 Special Education_grants to States 2023 $597,487
84.027 Special Education_grants to States 2022 $594,491
84.010 Title I Grants to Local Educational Agencies 2023 $353,035
84.010 Title I Grants to Local Educational Agencies 2022 $258,864
84.425 Education Stabilization Fund 2022 $202,495
10.553 School Breakfast Program 2022 $195,834
10.553 School Breakfast Program 2023 $171,476
84.367 Improving Teacher Quality State Grants 2023 $100,714
84.367 Improving Teacher Quality State Grants 2022 $77,868
84.365 English Language Acquisition State Grants 2023 $54,077
93.778 Medical Assistance Program 2022 $30,290
84.173 Special Education_preschool Grants 2023 $21,401
93.778 Medical Assistance Program 2023 $21,301
84.173 Special Education_preschool Grants 2022 $19,498
84.424 Student Support and Academic Enrichment Program 2023 $16,201
84.424 Student Support and Academic Enrichment Program 2022 $13,104
10.649 Pandemic Ebt Administrative Costs 2023 $628
10.649 Pandemic Ebt Administrative Costs 2022 $614