Finding 967132 (2023-009)

Material Weakness
Requirement
G
Questioned Costs
-
Year
2023
Accepted
2024-03-31
Audit: 301362
Organization: Wabash City Schools (IN)

AI Summary

  • Core Issue: The School Corporation failed to provide adequate oversight of the Cooperative's special education programs, leading to noncompliance with federal earmarking requirements.
  • Impacted Requirements: The lack of internal controls resulted in an inability to verify proper expenditures for nonpublic school students, violating compliance standards under 2 CFR 200.303 and 511 IAC 7-34-7(b).
  • Recommended Follow-Up: Establish a robust internal control system and develop clear policies and procedures to ensure proper allocation and documentation of Non-Public Proportionate Share funds.

Finding Text

FINDING 2023-009 Subject: Special Education Cluster (IDEA) - Earmarking 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): 20611-054-PN01, 21611-054-PN01, 21619-054-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking Audit Findings: Material Weakness, Modified Opinion INDIANA STATE BOARD OF ACCOUNTS 32 WABASH CITY SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Condition and Context The School Corporation is a member of the Wabash Miami Area Programs for Exceptional Children (Cooperative). During fiscal years 2021-2022 and 2022-2023, 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 corporation, 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 Matching, Level of Effort, Earmarking compliance requirement. The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the earmarking requirements. The Cooperative did not have adequate procedures in place to ensure that the required level of expenditures for nonpublic school students with disabilities was met for each member school corporation. The Cooperative did not have effective internal controls to ensure nonpublic school expenditures were appropriately identified and reported. The Non-Public Proportionate Share expenditures for the 20611-054-PN01, 21611-054-PN01, and 21619-054-PN01 grant awards could not be verified for the individual member school coporations. The nonpublic school share funds for all member schools were comingled and the aggregate amount of expenditures was then allocated to the member school corporations on a percentage basis. These allocations were the amounts reported to the IDOE. As such, we were unable to identify which expenditures were for each school in order to verify the minimum amount per the grant award was expended and properly reported to the IDOE as required. The lack of internal controls and noncompliance were isolated to the 20611-054-PN01, 21611-054-PN01, and 21619-054-PN01 grant awards. 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. . . ." INDIANA STATE BOARD OF ACCOUNTS 33 WABASH CITY SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 511 IAC 7-34-7(b) states: "The public agency, in providing special education and related services to students in nonpublic schools must expend at least an amount that is the same proportion of the public agency total subgrant under 20 U.S.C. 1411(f) as the number of nonpublic school students with disabilities, who are enrolled by their parents in nonpublic schools within its boundaries, is to the total number of students with disabilities of the same age range." 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 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, it could not be determined if each school spent their required earmarking dollars. 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 Non-Public Proportionate Share funds are appropriately allocated to the member school based on expenses charged directly on behalf of the member school corporations. Supporting documentation for these expenses should be retained for audit. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

Categories

Matching / Level of Effort / Earmarking Allowable Costs / Cost Principles

Other Findings in this Audit

  • 390664 2023-003
    Material Weakness
  • 390665 2023-003
    Material Weakness
  • 390666 2023-003
    Material Weakness
  • 390667 2023-003
    Material Weakness
  • 390668 2023-003
    Material Weakness
  • 390669 2023-003
    Material Weakness
  • 390670 2023-004
    Material Weakness
  • 390671 2023-004
    Material Weakness
  • 390672 2023-004
    Material Weakness
  • 390673 2023-004
    Material Weakness
  • 390674 2023-004
    Material Weakness
  • 390675 2023-004
    Material Weakness
  • 390676 2023-005
    Material Weakness
  • 390677 2023-005
    Material Weakness
  • 390678 2023-005
    Material Weakness
  • 390679 2023-005
    Material Weakness
  • 390680 2023-005
    Material Weakness
  • 390681 2023-005
    Material Weakness
  • 390682 2023-006
    Material Weakness
  • 390683 2023-006
    Material Weakness
  • 390684 2023-006
    Material Weakness
  • 390685 2023-006
    Material Weakness
  • 390686 2023-007
    Material Weakness
  • 390687 2023-007
    Material Weakness
  • 390688 2023-008
    Material Weakness
  • 390689 2023-008
    Material Weakness
  • 390690 2023-009
    Material Weakness
  • 390691 2023-009
    Material Weakness
  • 390692 2023-009
    Material Weakness
  • 390693 2023-010
    Material Weakness
  • 390694 2023-010
    Material Weakness
  • 390695 2023-010
    Material Weakness
  • 390696 2023-010
    Material Weakness
  • 390697 2023-010
    Material Weakness
  • 967106 2023-003
    Material Weakness
  • 967107 2023-003
    Material Weakness
  • 967108 2023-003
    Material Weakness
  • 967109 2023-003
    Material Weakness
  • 967110 2023-003
    Material Weakness
  • 967111 2023-003
    Material Weakness
  • 967112 2023-004
    Material Weakness
  • 967113 2023-004
    Material Weakness
  • 967114 2023-004
    Material Weakness
  • 967115 2023-004
    Material Weakness
  • 967116 2023-004
    Material Weakness
  • 967117 2023-004
    Material Weakness
  • 967118 2023-005
    Material Weakness
  • 967119 2023-005
    Material Weakness
  • 967120 2023-005
    Material Weakness
  • 967121 2023-005
    Material Weakness
  • 967122 2023-005
    Material Weakness
  • 967123 2023-005
    Material Weakness
  • 967124 2023-006
    Material Weakness
  • 967125 2023-006
    Material Weakness
  • 967126 2023-006
    Material Weakness
  • 967127 2023-006
    Material Weakness
  • 967128 2023-007
    Material Weakness
  • 967129 2023-007
    Material Weakness
  • 967130 2023-008
    Material Weakness
  • 967131 2023-008
    Material Weakness
  • 967133 2023-009
    Material Weakness
  • 967134 2023-009
    Material Weakness
  • 967135 2023-010
    Material Weakness
  • 967136 2023-010
    Material Weakness
  • 967137 2023-010
    Material Weakness
  • 967138 2023-010
    Material Weakness
  • 967139 2023-010
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
10.555 National School Lunch Program 2023 $905,037
10.555 National School Lunch Program 2022 $848,384
84.425 Education Stabilization Fund 2022 $421,047
84.010 Title I Grants to Local Educational Agencies 2022 $338,198
10.553 School Breakfast Program 2022 $270,213
84.425 Education Stabilization Fund 2023 $243,051
84.010 Title I Grants to Local Educational Agencies 2023 $242,951
10.553 School Breakfast Program 2023 $229,205
93.575 Child Care and Development Block Grant 2023 $185,995
93.575 Child Care and Development Block Grant 2022 $114,697
10.559 Summer Food Service Program for Children 2022 $94,721
84.027 Special Education_grants to States 2023 $90,788
93.778 Medical Assistance Program 2023 $66,197
84.367 Improving Teacher Quality State Grants 2022 $57,032
84.411 Investing in Innovation (i3) Fund 2023 $55,714
93.778 Medical Assistance Program 2022 $51,680
84.358 Rural Education 2023 $44,742
84.411 Investing in Innovation (i3) Fund 2022 $40,612
84.424 Student Support and Academic Enrichment Program 2022 $32,095
84.367 Improving Teacher Quality State Grants 2023 $30,747
84.173 Special Education_preschool Grants 2022 $22,907
10.559 Summer Food Service Program for Children 2023 $21,773
84.424 Student Support and Academic Enrichment Program 2023 $20,706
84.358 Rural Education 2022 $16,647
84.173 Special Education_preschool Grants 2023 $6,222
84.027 Special Education_grants to States 2022 $1,674