EIN: 351067971
UEI: WM3MHB3GMDT5
Data as of August 22, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 23, 2026. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by September 23, 2026 (31 days from today).
What is a management decision? →An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the Special Education Cluster program and Activities Allowed or Unallowed and Allowable Costs compliance requirements. Cause: Management was not aware that non-public school officials have no authority to obligate or receive federal funds and that School Corporation must maintain control of all Special Education funds, property, equipment and supplies; therefore, reimbursements were made to a non-public school for proportionate share expenditures. Effect: The payment of proportionate share expenditures to a non-public school resulted in the potential misuse of funds that were meant to pay the excess costs of providing special education to students. The unallowable nature of these expenditures may also result in the School Corporation not meeting their requirements related to Non-Public Proportionate Share for the respective grants. Questioned Costs: There were questioned costs identified in the amount of $3,399. Context: During fiscal year 2023-2024, the School Corporation was a member as well as the fiscal agent of Cooperative School Services (Cooperative). The Cooperative operated the special education programs and spent the federal money on behalf of its member schools. As the grant agreement was between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. For costs related to non-public schools, the practice of the Cooperative was to separate out the required amount for each member school from the Cooperative budget, and the member schools would work with the non-public schools to determine how to spend their proportionate share amount. Each member school would then request reimbursement from the Cooperative for non-public school expenditures incurred. This allowed both the Cooperative and member schools to maintain control of all Special Education funds, property, equipment and supplies. In the initial sample of 25 expenditures, there was no noncompliance identified. However, while performing a review of transactions for the Period of Performance compliance requirement, it was noted that non-public schools received direct reimbursements from the Cooperative for their proportionate share expenditures. A total of 13 expenditures were made from Special Education funds to non-public schools on behalf of the member schools during the audit period. Of the 13 expenditures, 3, totaling $3,399, were made on behalf of the School Corporation to a non-public school. In addition, one of the expenditures was used to reimburse the non-public school for the purchase of gift cards and certificates, totaling $670, which was not for the benefit of non-public students. The lack of controls and noncompliance was an isolated to the 22611-047-PN01 grant award. This issue was isolated to fiscal year 2024. Identification as a repeat finding, if applicable: No Recommendation: We recommended that the School Corporation's management establish a system of internal controls to ensure that no direct reimbursements are made to the non-public schools and to ensure compliance with the grant agreement and the Activities Allowed or Unallowed and the Allowable Costs/Cost Principles compliance requirements. Views of Responsible Officials and Planned Corrective Actions: Management has agreed with the finding and prepared a corrective action plan.
Show full finding ▾Hide full finding ▴Information on the federal program: 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 Listing Numbers: 84.027 Federal Award Numbers and Years (or Other Identifying Numbers): 22611-047-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Finding: Material Weakness 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 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). . . ." 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: 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. (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." 34 CFR 300.800 states: "The Secretary provides grants under section 619 of the Act to assist States to provide special education and related services in accordance with Part B of the Act – (a) To children with disabilities aged three through five years; and (b) At a State's discretion, to two-year-old children with disabilities who will turn three during the school year." 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. . . ." 511 IAC 7-34-9 states in part: “(a) The public agency must hold title to and exercise continuing administrative control of all: (1) property; (2) equipment; and (3) supplies; the public agency acquires with Part B funds for the benefit of nonpublic school students with disabilities. (b) The public agency may place equipment and supplies in a nonpublic school for the period of time needed to provide special education and related services. The public agency must ensure that the equipment and supplies: (1) are used only for the provision of special education and related services; and (2) can be removed from the nonpublic school without remodeling the nonpublic school facility.” Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the Special Education Cluster program and Activities Allowed or Unallowed and Allowable Costs compliance requirements. Cause: Management was not aware that non-public school officials have no authority to obligate or receive federal funds and that School Corporation must maintain control of all Special Education funds, property, equipment and supplies; therefore, reimbursements were made to a non-public school for proportionate share expenditures. Effect: The payment of proportionate share expenditures to a non-public school resulted in the potential misuse of funds that were meant to pay the excess costs of providing special education to students. The unallowable nature of these expenditures may also result in the School Corporation not meeting their requirements related to Non-Public Proportionate Share for the respective grants. Questioned Costs: There were questioned costs identified in the amount of $3,399. Context: During fiscal year 2023-2024, the School Corporation was a member as well as the fiscal agent of Cooperative School Services (Cooperative). The Cooperative operated the special education programs and spent the federal money on behalf of its member schools. As the grant agreement was between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. For costs related to non-public schools, the practice of the Cooperative was to separate out the required amount for each member school from the Cooperative budget, and the member schools would work with the non-public schools to determine how to spend their proportionate share amount. Each member school would then request reimbursement from the Cooperative for non-public school expenditures incurred. This allowed both the Cooperative and member schools to maintain control of all Special Education funds, property, equipment and supplies. In the initial sample of 25 expenditures, there was no noncompliance identified. However, while performing a review of transactions for the Period of Performance compliance requirement, it was noted that non-public schools received direct reimbursements from the Cooperative for their proportionate share expenditures. A total of 13 expenditures were made from Special Education funds to non-public schools on behalf of the member schools during the audit period. Of the 13 expenditures, 3, totaling $3,399, were made on behalf of the School Corporation to a non-public school. In addition, one of the expenditures was used to reimburse the non-public school for the purchase of gift cards and certificates, totaling $670, which was not for the benefit of non-public students. The lack of controls and noncompliance was an isolated to the 22611-047-PN01 grant award. This issue was isolated to fiscal year 2024. Identification as a repeat finding, if applicable: No Recommendation: We recommended that the School Corporation's management establish a system of internal controls to ensure that no direct reimbursements are made to the non-public schools and to ensure compliance with the grant agreement and the Activities Allowed or Unallowed and the Allowable Costs/Cost Principles compliance requirements. Views of Responsible Officials and Planned Corrective Actions: Management has agreed with the finding and prepared a corrective action plan.
Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. Corrective Action Plan – Audit Finding (FY 2023–2024) • Revision of Written Procedures o The Rensselaer Central, in coordination with Cooperative School Services, will revise and implement written procedures governing the administration of proportionate share funds for non-public schools to ensure compliance with federal grant requirements. (see IDEA Procurement Plan Earmarking for Non Pub CEIS Funds hyperlinked above) • Strengthening Internal Controls o Additional internal controls will be implemented requiring review and approval by the Director of Special Education, Bookkeeper, and Rensselaer Central Treasurer prior to any reimbursement related to non-public school expenditures funded through the Special Education grant. • Reimbursement Process Changes o Non-public schools will no longer receive reimbursements directly from Cooperative School Services. Cooperative School Services will receive approval and verification from the Non-Public School LEA. o All reimbursement requests must include detailed documentation demonstrating that the expenditure directly benefits eligible non-public school students receiving special education services. • Allowable Cost Verification o Rensselaer Central and Cooperative School Services will implement a verification process to ensure all expenditures comply with federal allowable cost requirements and that funds are used solely for the benefit of eligible non-public school students. • Staff Training o Rensselaer Central and Cooperative School Services personnel responsible for federal grant oversight will receive training on federal grant compliance requirements, including allowable and unallowable expenditures (e.g., gift cards and similar incentives). • Monitoring and Oversight o Rensselaer Central will conduct periodic monitoring of expenditures made on its behalf by Cooperative School Services and maintain documentation demonstrating compliance with oversight responsibilities. • Implementation Timeline o These corrective actions and revised procedures have already been implemented and will apply to all future federal Special Education grant expenditures. • Ongoing Compliance Monitoring o Rensselaer Central and Cooperative School Services will conduct annual reviews of federal grant expenditures and internal controls to ensure continued compliance with IDOE and federal grant requirements. Responsible Party and Timeline for Completion: Corrective action plan has been implemented as this finding impacted fiscal year 2024 but did not recur in fiscal year 2025. The Director of Special Education, Cooperative School Services Bookkeeper, and Rensselaer Central Treasurer will oversee the corrective action plan to monitor the eligibility requirements on an ongoing basis.
An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the Special Education Cluster program and Period of Performance compliance requirements. Cause: Management had established an initial obligation date that occurred in September of the second fiscal year but modified the final vendor for payment. The new obligation occurred after the period in which the School Corporation was allowed to incur the expense. Effect: If funds are not obligated by the end of the specified date, the grantor agency is not obligated to reimburse the School Corporation for costs incurred. This may indicate that the funding reimbursed that was incurred outside of the period of performance will need to be repaid to the grantor agency, and the School Corporation will then need to support the costs with non-federal funding. Questioned Costs: There were no questioned costs identified. Context: During fiscal year 2023-24, the School Corporation was a member as well as the fiscal agent of Cooperative School Services (Cooperative). The Cooperative operated the special education programs and spent the federal money on behalf of its member schools. As the grant agreement was between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. For Special Education Cluster awards, funds must be obligated during the 27 months, extending from July 1 of the fiscal year for which the funds were appropriated through September 30 of the second following fiscal year. When testing transactions occurred in the liquidation period for the 22611-047-PN01, 22611-047-ARP, 22619-047-PN01 and 22619-047-ARP grant awards, two exceptions were identified in the initial sample of five transactions. When expanding the sample, a third exception was noted, and it was concluded that it would not be appropriate to examine the remaining 14 transactions. For the above listed awards, costs must be obligated by September 30, 2023. For the three identified exceptions, an initial purchase order was made in September, but the ultimate transaction was paid to a separate vendor than the original purchase order, and this obligation was incurred in November 2023. This issue was isolated to fiscal year 2024. Identification as a repeat finding, if applicable: No Recommendation: We recommended that the School Corporation's management establish a system of internal controls to ensure that no costs are incurred after the September 30 deadline and to ensure compliance with the grant agreement and the Period of Performance compliance requirement. Views of Responsible Officials and Planned Corrective Actions: Management has agreed with the finding and prepared a corrective action plan.
Show full finding ▾Hide full finding ▴Information on the federal program: Subject: Special Education Cluster (IDEA) – Period of Performance Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Numbers: 84.027, 84.027X, 84.173, 84.173X Federal Award Numbers and Years (or Other Identifying Numbers): 22611-047-PN01, 22611-047-ARP, 22619-047-PN01, 22619-047-ARP Pass-Through Entity: Indiana Department of Education Compliance Requirement: Period of Performance Audit Finding: Material Weakness 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 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 200.309 states: “A non-Federal entity may charge to the Federal award only allowable costs incurred during the period of performance (except as described in §200.461 Publication and printing costs) and any costs incurred before the Federal awarding agency or pass-through entity made the Federal award that were authorized by the Federal awarding agency or pass-through entity.” 34 CFR 76.707 states in part: “….If the obligation is for – a) Acquisition of real or personal property…. The obligation is made – On the date on which the State or subgrantee makes a binding written commitment to acquire the property.” Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the Special Education Cluster program and Period of Performance compliance requirements. Cause: Management had established an initial obligation date that occurred in September of the second fiscal year but modified the final vendor for payment. The new obligation occurred after the period in which the School Corporation was allowed to incur the expense. Effect: If funds are not obligated by the end of the specified date, the grantor agency is not obligated to reimburse the School Corporation for costs incurred. This may indicate that the funding reimbursed that was incurred outside of the period of performance will need to be repaid to the grantor agency, and the School Corporation will then need to support the costs with non-federal funding. Questioned Costs: There were no questioned costs identified. Context: During fiscal year 2023-24, the School Corporation was a member as well as the fiscal agent of Cooperative School Services (Cooperative). The Cooperative operated the special education programs and spent the federal money on behalf of its member schools. As the grant agreement was between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. For Special Education Cluster awards, funds must be obligated during the 27 months, extending from July 1 of the fiscal year for which the funds were appropriated through September 30 of the second following fiscal year. When testing transactions occurred in the liquidation period for the 22611-047-PN01, 22611-047-ARP, 22619-047-PN01 and 22619-047-ARP grant awards, two exceptions were identified in the initial sample of five transactions. When expanding the sample, a third exception was noted, and it was concluded that it would not be appropriate to examine the remaining 14 transactions. For the above listed awards, costs must be obligated by September 30, 2023. For the three identified exceptions, an initial purchase order was made in September, but the ultimate transaction was paid to a separate vendor than the original purchase order, and this obligation was incurred in November 2023. This issue was isolated to fiscal year 2024. Identification as a repeat finding, if applicable: No Recommendation: We recommended that the School Corporation's management establish a system of internal controls to ensure that no costs are incurred after the September 30 deadline and to ensure compliance with the grant agreement and the Period of Performance compliance requirement. Views of Responsible Officials and Planned Corrective Actions: Management has agreed with the finding and prepared a corrective action plan.
Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. Corrective Action Plan – Period of Performance Finding (FY 2024) • Improved Internal Controls o Rensselaer Central and Cooperative School Services will implement additional review procedures to ensure all federal grant obligations occur within the allowable grant period and that vendor payments align with the original approved purchase orders. • Verification of Obligation Dates o Fiscal staff will verify that purchase orders, vendor invoices, and final payments reflect an obligatory date that occurs prior to the applicable grant deadline. • Staff Training o Rensselaer Central and Cooperative School Services Fiscal personnel involved in grant management will receive training on federal grant period of performance requirements and proper documentation of obligations. • Monitoring Procedures o Rensselaer Central and Cooperative School Services will conduct periodic reviews of federal grant expenditures to ensure ongoing compliance with grant timelines. • Statement of Isolated Occurrence o Rensselaer Central and Cooperative School Services reviewed the circumstances surrounding this finding and determined that the issue was isolated to fiscal year 2024. Responsible Party and Timeline for Completion: Corrective action plan has been implemented as this finding impacted fiscal year 2024 but did not recur in fiscal year 2025. The Director of Special Education, Cooperative School Services Bookkeeper, and Rensselaer Central Treasurer will oversee the corrective action plan to monitor the eligibility requirements on an ongoing basis.
An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the earmarking portion of the Matching, Level of Effort, Earmarking compliance requirement. Cause: The School Corporation participates in a Special Education Cooperative that manages and operates the special education program and oversees the majority of the federal compliance requirements. The School Corporation's management had not developed a system of internal controls that would have ensured compliance with the grant agreement and the Matching, Level of Effort, Earmarking compliance requirement. Effect: The failure to establish an effective internal control system placed the School Corporation in noncompliance with the grant agreement and the Matching, Level of Effort, Earmarking compliance requirement. Noncompliance with the grant agreement or the compliance requirement could have resulted in the loss of federal funds to the School Corporation. Questioned Costs: $27,967 Context: The School Corporation did not meet the earmarking requirements for the grants, which concluded during the audit period. Both the Special Education Grants to States and Special Education Preschool Grants required a proportionate share of their funding to be spent on non-public school students with disabilities. The 22611-047-PN01, 22611-047-ARP, and 23611-047-PN01 grant awards were fully expended during the audit period with minimum Non-Public Proportionate Share earmarking requirements of $20,890, $4,238, and $17,240, respectively. There were not sufficient non-public school expenditures incurred to meet the non-public proportionate share requirement for any of the four grants. The non-public school expenditures fell short of the minimum requirement by $12,644, $1,648 and $13,675 respectively. Identification as a repeat finding: Yes, Finding 2023-003. Recommendation: We recommended that the School Corporation's management establish internal controls to monitor earmarking requirements periodically to ensure compliance with the earmarking compliance requirements by the end of the grant period. This includes meeting with the Cooperative periodically to monitor and track progress towards meeting the earmarking requirements. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Show full finding ▾Hide full finding ▴Information on the federal program: Subject: Special Education Cluster (IDEA) –Earmarking Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Numbers: 84.027, 84.027A, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 22611-047-PN01, 22611-047-ARP, 23611-047-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, and Earmarking Audit Finding: Material Weakness, Other Matters 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 200.207(a) states in part: "The Federal awarding agency or pass-through entity may impose additional specific award conditions as needed . . ." 511 IAC 7-34-7(b) states: "The public agency, in providing special education and related services to students in nonpublic schools and facilities, 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 or facilities within its boundaries, is to the total number of students with disabilities of the same age range." Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the earmarking portion of the Matching, Level of Effort, Earmarking compliance requirement. Cause: The School Corporation participates in a Special Education Cooperative that manages and operates the special education program and oversees the majority of the federal compliance requirements. The School Corporation's management had not developed a system of internal controls that would have ensured compliance with the grant agreement and the Matching, Level of Effort, Earmarking compliance requirement. Effect: The failure to establish an effective internal control system placed the School Corporation in noncompliance with the grant agreement and the Matching, Level of Effort, Earmarking compliance requirement. Noncompliance with the grant agreement or the compliance requirement could have resulted in the loss of federal funds to the School Corporation. Questioned Costs: $27,967 Context: The School Corporation did not meet the earmarking requirements for the grants, which concluded during the audit period. Both the Special Education Grants to States and Special Education Preschool Grants required a proportionate share of their funding to be spent on non-public school students with disabilities. The 22611-047-PN01, 22611-047-ARP, and 23611-047-PN01 grant awards were fully expended during the audit period with minimum Non-Public Proportionate Share earmarking requirements of $20,890, $4,238, and $17,240, respectively. There were not sufficient non-public school expenditures incurred to meet the non-public proportionate share requirement for any of the four grants. The non-public school expenditures fell short of the minimum requirement by $12,644, $1,648 and $13,675 respectively. Identification as a repeat finding: Yes, Finding 2023-003. Recommendation: We recommended that the School Corporation's management establish internal controls to monitor earmarking requirements periodically to ensure compliance with the earmarking compliance requirements by the end of the grant period. This includes meeting with the Cooperative periodically to monitor and track progress towards meeting the earmarking requirements. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Views of Responsible Offocials and Corrective Action Plan: Management agrees with the finding. Corrective Action Plan – Non-Public Proportionate Share Finding (FY 2024) • Revised Procedures o Internal procedures will be updated to plan, track, and ensure non-public proportionate share expenditures meet minimum requirements before grant funds are fully expended. • Monitoring and Verification o Fiscal staff will monitor non-public expenditures throughout the grant period and verify documentation demonstrates direct benefit to eligible non-public students. • Staff Training o Staff and Cooperative personnel will receive training on non-public proportionate share requirements and allowable expenditures. • Future Compliance Measures o Strategies will be implemented to prevent shortfalls in future grant periods, including early adjustments to spending plans to ensure full compliance. Responsible Party and Timeline for Completion: Corrective action plan has been implemented as this finding impacted fiscal year 2024 but did not recur in fiscal year 2025. The Director of Special Education, Cooperative School Services Bookkeeper, and Rensselaer Central Treasurer will oversee the corrective action plan to monitor the eligibility requirements on an ongoing basis.
2023-003
FAC accepted this audit on March 20, 2024 — management decision was due September 20, 2024.
An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the program grant agreements and the compliance requirements related to suspension and debarment. Cause: The School Corporation’s management had not developed a system of internal controls that would have ensured compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the program grant agreements and applicable Procurement and Suspension and Debarment compliance requirements. Questioned Costs: There were no questioned costs identified. Context: The School Corporation is a member of the Cooperative School Services (Cooperative) and serves as the fiscal agent for the Cooperative. The Cooperative operated the special education programs on behalf of the School Corporation and managed the special education grant funds. As the grant agreement was between the Indiana Department of Education and the School Corporation, the School Corporation was responsible for compliance with the grant agreement and the Suspension and Debarment compliance requirements. During fiscal year 2022, The School Corporation did not have adequate internal controls in place to ensure the Cooperative complied with the suspension and debarment requirements. The Special Education Director obtained suspension and debarment certifications for contracted vendors over $25,000 without an oversight or review process. The lack of controls over suspension and debarment requirements was isolated to fiscal year 2022. Identification as a repeat finding: Yes. Finding 2021-002. Recommendation: We recommended that the School Corporation's management establish a system of controls, including segregation of duties, to ensure compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement including documenting steps taken to verify the vendor selected is not suspended or debarred. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Show full finding ▾Hide full finding ▴Finding 2023-002 Information on the federal program: Subject: Special Education Cluster – Suspension and Debarment Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 20611-047-PN01, 21611-047-PN01, 22611-047-PN01, 20619-047-PN01, 21619-047-PN01, 22619-047-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Material Weakness 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 200.303 states: “When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) C hecking SAM Exclusions; or (b) C ollecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person.” Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the program grant agreements and the compliance requirements related to suspension and debarment. Cause: The School Corporation’s management had not developed a system of internal controls that would have ensured compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the program grant agreements and applicable Procurement and Suspension and Debarment compliance requirements. Questioned Costs: There were no questioned costs identified. Context: The School Corporation is a member of the Cooperative School Services (Cooperative) and serves as the fiscal agent for the Cooperative. The Cooperative operated the special education programs on behalf of the School Corporation and managed the special education grant funds. As the grant agreement was between the Indiana Department of Education and the School Corporation, the School Corporation was responsible for compliance with the grant agreement and the Suspension and Debarment compliance requirements. During fiscal year 2022, The School Corporation did not have adequate internal controls in place to ensure the Cooperative complied with the suspension and debarment requirements. The Special Education Director obtained suspension and debarment certifications for contracted vendors over $25,000 without an oversight or review process. The lack of controls over suspension and debarment requirements was isolated to fiscal year 2022. Identification as a repeat finding: Yes. Finding 2021-002. Recommendation: We recommended that the School Corporation's management establish a system of controls, including segregation of duties, to ensure compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement including documenting steps taken to verify the vendor selected is not suspended or debarred. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Finding 2023-002 Information on the federal program: Subject: Special Education Cluster – Suspension and Debarment Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 20611-047-PN01, 21611-047-PN01, 22611-047-PN01, 20619-047-PN01, 21619-047-PN01, 22619-047-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Material Weakness Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the program grant agreements and the compliance requirements related to suspension and debarment. Context: The School Corporation is a member of the Cooperative School Services (Cooperative) and serves as the fiscal agent for the Cooperative. The Cooperative operated the special education programs on behalf of the School Corporation and managed the special education grant funds. As the grant agreement was between the Indiana Department of Education and the School Corporation, the School Corporation was responsible for compliance with the grant agreement and the Suspension and Debarment compliance requirements. During fiscal year 2022, The School Corporation did not have adequate internal controls in place to ensure the Cooperative complied with the suspension and debarment requirements. The Special Education Director obtained suspension and debarment certifications for contracted vendors over $25,000 without an oversight or review process. The lack of controls over suspension and debarment requirements was isolated to fiscal year 2022. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. Two Cooperative School Service employees will check and initial the procurement and Suspension and Debarments documentation. Management of the School Corporation will request supporting documentation from Cooperative School Services to validate procurement and suspension and debarment procedure where performed to satisfy federal regulations. Responsible Party and Timeline for Completion: The corrective action plan has been put into place by both parties. Sarah Claton, Director of Cooperative Schools Services and the Treasurer, Dawn Claussen, will oversee the corrective action plan.
2021-002
An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the earmarking portion of the Matching, Level of Effort, Earmarking compliance requirement. Cause: The School Corporation participates in a Special Education Cooperative that manages and operates the special education program and oversees the majority of the federal compliance requirements. The School Corporation's management had not developed a system of internal controls that would have ensured compliance with the grant agreement and the Matching, Level of Effort, Earmarking compliance requirement. Effect: The failure to establish an effective internal control system placed the School Corporation in noncompliance with the grant agreement and the Matching, Level of Effort, Earmarking compliance requirement. Noncompliance with the grant agreement or the compliance requirement could have resulted in the loss of federal funds to the School Corporation. Questioned Costs: There were no questioned costs identified. Context: The School Corporation did not meet the earmarking requirements for the grants, which concluded during the audit period. Both the Special Education Grants to States and Special Education Preschool Grants required a proportionate share of their funding to be spent on non-public school students with disabilities. The 20611-047-PN01, 20619-047-PN01, 21611-047-PN01, 21619-047-PN01 grant awards were fully expended during the audit period with minimum Non-Public Proportionate Share earmarking requirements of $19,551, $2,421, $26,253, and $1,959, respectively. There was no supporting documentation provided to support any non-public school expenditures were incurred towards the meeting the non-public proportionate share requirement. Identification as a repeat finding: Yes, Finding 2021-003. Recommendation: We recommended that the School Corporation's management establish internal controls to monitor earmarking requirements periodically to ensure compliance with the earmarking compliance requirements by the end of the grant period. This includes meeting with the Cooperative periodically to monitor and track progress towards meeting the earmarking requirements. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Show full finding ▾Hide full finding ▴Finding 2023-003 Information on the federal program: Subject: Special Education Cluster (IDEA) –Earmarking Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 20611-047-PN01, 21611-047-PN01, 20619-047-PN01, 21619-047-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, and Earmarking Audit Finding: Material Weakness, Other Matters 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 200.207(a) states in part: "The Federal awarding agency or pass-through entity may impose additional specific award conditions as needed . . ." 511 IAC 7-34-7(b) states: "The public agency, in providing special education and related services to students in nonpublic schools and facilities, 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 or facilities within its boundaries, is to the total number of students with disabilities of the same age range." Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the earmarking portion of the Matching, Level of Effort, Earmarking compliance requirement. Cause: The School Corporation participates in a Special Education Cooperative that manages and operates the special education program and oversees the majority of the federal compliance requirements. The School Corporation's management had not developed a system of internal controls that would have ensured compliance with the grant agreement and the Matching, Level of Effort, Earmarking compliance requirement. Effect: The failure to establish an effective internal control system placed the School Corporation in noncompliance with the grant agreement and the Matching, Level of Effort, Earmarking compliance requirement. Noncompliance with the grant agreement or the compliance requirement could have resulted in the loss of federal funds to the School Corporation. Questioned Costs: There were no questioned costs identified. Context: The School Corporation did not meet the earmarking requirements for the grants, which concluded during the audit period. Both the Special Education Grants to States and Special Education Preschool Grants required a proportionate share of their funding to be spent on non-public school students with disabilities. The 20611-047-PN01, 20619-047-PN01, 21611-047-PN01, 21619-047-PN01 grant awards were fully expended during the audit period with minimum Non-Public Proportionate Share earmarking requirements of $19,551, $2,421, $26,253, and $1,959, respectively. There was no supporting documentation provided to support any non-public school expenditures were incurred towards the meeting the non-public proportionate share requirement. Identification as a repeat finding: Yes, Finding 2021-003. Recommendation: We recommended that the School Corporation's management establish internal controls to monitor earmarking requirements periodically to ensure compliance with the earmarking compliance requirements by the end of the grant period. This includes meeting with the Cooperative periodically to monitor and track progress towards meeting the earmarking requirements. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Finding 2023-003 Information on the federal program: Subject: Special Education Cluster (IDEA) –Earmarking Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 20611-047-PN01, 21611-047-PN01, 20619-047-PN01, 21619-047-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, and Earmarking Audit Finding: Material Weakness, Other Matters Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the earmarking portion of the Matching, Level of Effort, Earmarking compliance requirement. Context: The School Corporation did not meet the earmarking requirements for the grants, which concluded during the audit period. Both the Special Education Grants to States and Special Education Preschool Grants required a proportionate share of their funding to be spent on non-public school students with disabilities. The 20611-047-PN01, 20619-047-PN01, 21611-047-PN01, 21619-047-PN01 grant awards were fully expended during the audit period with minimum Non-Public Proportionate Share earmarking requirements of $19,551, $2,421, $26,253, and $1,959, respectively. There was no supporting documentation provided to support any non-public school expenditures were incurred towards the meeting the non-public proportionate share requirement. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. The Cooperative Schools Service has developed a written procedure of documenting expenditures related to the proportionated share earmarking requirement and validate the earmarking requirement to met at the end of the grant’s period of performance or once fully expended. Responsible Party and Timeline for Completion: The correction action plan has been put into place for the 2023-24 school year. Treasurer, Dawn Claussen and Director of Cooperative School Services, Sarah Claton, will oversee the corrective action plan.
2021-003
An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Special Tests and Provisions – Wage Rate Requirements compliance requirements. The School Corporation did not include Davis Bacon wage rate requirements in its contract with vendor which includes labor. The School Corporation did not obtain the weekly payroll reports certifications from a construction company and its subcontractors for a building project. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with the compliance requirements listed above. ngs and Questioned Costs (Continued) Finding 2023-004 (Continued) Effect: The failure to design and implement an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Special Tests and Provisions – Wage Rate Requirements 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 did not have an internal control designed to collect the weekly payroll reports certifications from a construction company and its subcontractors, as applicable, for building projects which included HVAC upgrades and replacements. Therefore, no review was performed by management to ensure that pay rates complied with the federal wage rate requirements. The vendor contract did not include a Davis-Bacon clause prescribing federal wage rate requirements required for construction contracts with labor installation costs. As of June 30, 2023, $566,328 was disbursed related to this capital project and charged to the ESSER III grant award (84.425U). The construction payments represented approximately 27.2% of the Education Stabilization Fund expenditures for the audit period. Identification as a repeat finding: No. Recommendation: We recommend the School Corporation include Davis-Bacon wage requirements in construction contracts which are federally funded and implement a formal process to ensure the required weekly payroll report certifications are collected and reviewed by management to ensure compliance with the federal wage rate requirements. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Show full finding ▾Hide full finding ▴Finding 2023-004 Information on the federal program: Subject: Education Stabilization Fund – Special Tests and Provisions - Wage Rate Requirements Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Number: 84.425U Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Wage Rate Requirements Audit Findings: Material Weakness, Qualified Opinion Criteria: 2 CFR section 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). . . ." 29 CFR 5.5 states in part: a.The Agency head shall cause or require the contracting officer to insert in full in any contract in excess of $2,000 which is entered into for the actual construction, alteration and/or repair, including painting and decorating, of a public building or public work, or building or work financed in whole or in part from Federal funds or in accordance with guarantees of a Federal agency or financed from funds obtained by pledge of any contract of a Federal agency to make a loan, grant or annual contribution (except where a different meaning is expressly indicated), and which is subject to the labor standards provisions of any of the acts listed in §5.1, the following clauses… (1) Minimum wages. (i) All laborers and mechanics employed or working upon the site of the work (or under the United States Housing Act of 1937 or under the Housing Act of 1949 in the construction or development of the project), will be paid unconditionally and not less often than once a week, and without subsequent deduction or rebate on any account (except such payroll deductions as are permitted by regulations issued by the Secretary of Labor under the Copeland Act (29 CFR part 3)), the full amount of wages and bona fide fringe benefits (or cash equivalents thereof) due at time of payment computed at rates not less than those contained in the wage determination of the Secretary of Labor which is attached hereto and made a part hereof, regardless of any contractual relationship which may be alleged to exist between the contractor and such laborers and mechanics… (3)(ii)(A) The contractor shall submit weekly for each week in which any contract work is performed a copy of all payrolls to the (write in name of appropriate federal agency) if the agency is a party to the contract, but if the agency is not such a party, the contractor will submit the payrolls to the applicant, sponsor, or owner, as the case may be, for transmission to the (write in name of agency). 2 CFR 200 Appendix II states in part: In addition to other provisions required by the Federal agency or non-Federal entity; all contracts made by the non-Federal entity under the Federal award must contain provisions covering the following, as applicable. . . . (D) Davis-Bacon Act, as amended (40 U.S.C. 3141-3148). When required by Federal program legislation, all prime construction contracts in excess of $2,000 awarded by non-Federal entities must include a provision for compliance with the Davis-Bacon Act (40 U.S.C. 3141-3144, and 3146-3148) as supplemented by Department of Labor regulations (29 CFR Part 5, “Labor Standards Provisions Applicable to Contracts Covering Federally Financed and Assisted Construction”). In accordance with the statute, contractors must be required to pay wages to laborers and mechanics at a rate not less than the prevailing wages specified in a wage determination made by the Secretary of Labor. In addition, contractors must be required to pay wages not less than once a week.. . .” Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Special Tests and Provisions – Wage Rate Requirements compliance requirements. The School Corporation did not include Davis Bacon wage rate requirements in its contract with vendor which includes labor. The School Corporation did not obtain the weekly payroll reports certifications from a construction company and its subcontractors for a building project. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with the compliance requirements listed above. ngs and Questioned Costs (Continued) Finding 2023-004 (Continued) Effect: The failure to design and implement an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Special Tests and Provisions – Wage Rate Requirements 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 did not have an internal control designed to collect the weekly payroll reports certifications from a construction company and its subcontractors, as applicable, for building projects which included HVAC upgrades and replacements. Therefore, no review was performed by management to ensure that pay rates complied with the federal wage rate requirements. The vendor contract did not include a Davis-Bacon clause prescribing federal wage rate requirements required for construction contracts with labor installation costs. As of June 30, 2023, $566,328 was disbursed related to this capital project and charged to the ESSER III grant award (84.425U). The construction payments represented approximately 27.2% of the Education Stabilization Fund expenditures for the audit period. Identification as a repeat finding: No. Recommendation: We recommend the School Corporation include Davis-Bacon wage requirements in construction contracts which are federally funded and implement a formal process to ensure the required weekly payroll report certifications are collected and reviewed by management to ensure compliance with the federal wage rate requirements. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Finding 2023-004 Information on the federal program: Subject: Education Stabilization Fund – Special Tests and Provisions - Wage Rate Requirements Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Number: 84.425U Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Wage Rate Requirements Audit Findings: Material Weakness, Qualified Opinion Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Special Tests and Provisions – Wage Rate Requirements compliance requirements. The School Corporation did not include Davis Bacon wage rate requirements in its contract with vendor which includes labor. The School Corporation did not obtain the weekly payroll reports certifications from a construction company and its subcontractors for a building project. Context: The School Corporation did not have an internal control designed to collect the weekly payroll reports certifications from a construction company and its subcontractors, as applicable, for building projects which included HVAC upgrades and replacements. Therefore, no review was performed by management to ensure that pay rates complied with the federal wage rate requirements. The vendor contract did not include a Davis-Bacon clause prescribing federal wage rate requirements required for construction contracts with labor installation costs. As of June 30, 2023, $566,328 was disbursed related to this capital project and charged to the ESSER III grant award (84.425U). The construction payments represented approximately 27.2% of the Education Stabilization Fund expenditures for the audit period. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. For any contracts related to projects with a cost of greater than $2,000 for the construction, alternation, or repair of public buildings or public works and which are federally funded, management will include a Davis Bacon wage rate requirement clause in the contract or request the vendor to sign a certificate or contract amendment affirming the contractor will comply with federal wage requirements. Management will designate a project manager to oversee the federally funded project and ensure the collection of the required weekly payroll wage report and document their review verifying prevailing wages are being paid to contractors. Responsible Party and Timeline for Completion: The Treasurer, Dawn Claussen, will oversee the corrective action plan which will be implemented by June 30, 2024.
An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Equipment and Real Property Management Requirements compliance requirements. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with the compliance requirements listed above. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There were no questioned costs identified. Context: During the testing of equipment acquisitions, it was noted the School Corporation is maintaining and updating property records, however, had not performed a physical inventory of capital assets during the period under audit. Identification as a repeat finding: No. Recommendation: We recommended that the School Corporation's management perform a physical inventory of capital assets at least once every two years to comply with federal and state regulations and document the inventory process as evidence the physical inventory was performed. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Show full finding ▾Hide full finding ▴Finding 2023-005 Information on the federal program: Subject: Education Stabilization Fund – Equipment and Real Property Management Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Number: 84.425C, 84.425D, 84.425U Pass-Through Entity: Indiana Department of Education Compliance Requirement: Equipment and Real Property Management Audit Findings: Material Weakness Criteria: 2 CFR 200.313(d) states in part: "Management requirements. Procedures for managing equipment (including replacement equipment), whether acquired in whole or in part under a Federal award, until disposition takes place will, as a minimum, meet the following requirements: (1) Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the FAIN), who holds title, the acquisition date, and cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. (2) A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years. (3) A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated. (4) Adequate maintenance procedures must be developed to keep the property in good condition. . . ." Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Equipment and Real Property Management Requirements compliance requirements. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with the compliance requirements listed above. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There were no questioned costs identified. Context: During the testing of equipment acquisitions, it was noted the School Corporation is maintaining and updating property records, however, had not performed a physical inventory of capital assets during the period under audit. Identification as a repeat finding: No. Recommendation: We recommended that the School Corporation's management perform a physical inventory of capital assets at least once every two years to comply with federal and state regulations and document the inventory process as evidence the physical inventory was performed. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Finding 2023-005 Information on the federal program: Subject: Education Stabilization Fund – Equipment and Real Property Management Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Number: 84.425C, 84.425D, 84.425U Pass-Through Entity: Indiana Department of Education Compliance Requirement: Equipment and Real Property Management Audit Findings: Material Weakness Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Equipment and Real Property Management Requirements compliance requirements. Context: During the testing of equipment acquisitions, it was noted the School Corporation is maintaining and updating property records, however, had not performed a physical inventory of capital assets during the period under audit. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. The Rensselaer Central Schools Corporation will hire a firm to perform a physical inventory. Responsible Party and Timeline for Completion: The Treasurer, Dawn Claussen, will oversee the correction plan which will be implemented by June 30, 2024
FAC accepted this audit on March 8, 2023 — management decision was due September 8, 2023.
An effective internal control system was not in place at the School Corporation to ensurecompliance with requirements related to the grant agreement and the compliance requirements related toEligibility.Cause: The School Corporation's management had not developed a system of internal controls that wouldhave ensured compliance with the grant agreement and the eligibility requirements.Effect: The failure to establish an effective internal control system could enable material noncompliance togo undetected. Noncompliance with the grant agreement and the eligibility requirements could haveresulted in the loss of federal funds to the School Corporation.Questioned Costs: There were no questioned costs identifiedContext:Activities Allowed or UnallowedDuring the testing of payroll disbursements changed to Fund 0800, we noted for 9 disbursements out of 40disbursements selected for testing, that the hourly rate paid to the employee was not supported by anapproved pay rate form or other document to verify the approval of the pay rate used. The hours workedwas supported by approved timecards and pay period distribution reports were also approved to supportamounts charged to Fund 0800 for the period.There were no exceptions noted during testing of vendor disbursements charged to Fund 0800.EligibilityThe School Corporation determines eligibility for free or reduced lunch based on nationwide incomeeligibility guidelines on an annual basis. During the compliance testing of eligibility requirements, we notedone instance in a sample of 40 students receiving free or reduced meal benefits, that the benefitdetermination was incorrectly entered into the system. In this one instance, the student had been directlycertified and therefore eligible for free meals, however, was entered into the system as reduced.The lack of internal controls was isolated to fiscal year 2020. No eligibility determinations were made forfiscal year 2021 as the School Corporation accepted federal waivers to provide free meals to all studentsas a result of the COVID-19 pandemic.Identification as a repeat finding: No.Recommendation: We recommended that the School Corporation?s management review internal controlssurrounding eligibility determinations and ensure data is accurately entered into the software which isutilized to make eligibility determinations.We also recommend management implement a pay rate change form for hourly employees whichdocuments approved pay rates upon employment for each individual and any subsequent changes madeto pay rates.Views of Responsible Officials and Planned Corrective Actions: Management agrees with the findingand has prepared a corrective action plan.
Show full finding ▾Hide full finding ▴FINDING 2021-001Information on the federal program:Subject: Child Nutrition Cluster ? Internal ControlsFederal Agency: Department of AgricultureFederal Program: School Breakfast Program, National School Lunch Program, Summer Food ServiceProgramAssistance Listing Numbers: 10.553, 10.555, 10.559Pass-Through Entity: Indiana Department of EducationCompliance Requirement: Eligibility, Activities Allowed or Unallowed/Allowable Cost-Cost PrinciplesAudit Findings: Significant DeficiencyCriteria: 2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over Federal award that provides reasonableassurance that the non-Federal entity is managing the Federal awards in compliance with Federalstatutes, regulations, and the terms and conditions of the Federal award. These internal controlsshould be in compliance with guidance in 'Standards for Internal Control in the FederalGovernment' issued by the Comptroller General of the United States or the 'Internal ControlIntegrated Framework', issued by the Committee of Sponsoring Organizations of the TreadwayCommission (COSO)...."Condition: An effective internal control system was not in place at the School Corporation to ensurecompliance with requirements related to the grant agreement and the compliance requirements related toEligibility.Cause: The School Corporation's management had not developed a system of internal controls that wouldhave ensured compliance with the grant agreement and the eligibility requirements.Effect: The failure to establish an effective internal control system could enable material noncompliance togo undetected. Noncompliance with the grant agreement and the eligibility requirements could haveresulted in the loss of federal funds to the School Corporation.Questioned Costs: There were no questioned costs identifiedContext:Activities Allowed or UnallowedDuring the testing of payroll disbursements changed to Fund 0800, we noted for 9 disbursements out of 40disbursements selected for testing, that the hourly rate paid to the employee was not supported by anapproved pay rate form or other document to verify the approval of the pay rate used. The hours workedwas supported by approved timecards and pay period distribution reports were also approved to supportamounts charged to Fund 0800 for the period.There were no exceptions noted during testing of vendor disbursements charged to Fund 0800.EligibilityThe School Corporation determines eligibility for free or reduced lunch based on nationwide incomeeligibility guidelines on an annual basis. During the compliance testing of eligibility requirements, we notedone instance in a sample of 40 students receiving free or reduced meal benefits, that the benefitdetermination was incorrectly entered into the system. In this one instance, the student had been directlycertified and therefore eligible for free meals, however, was entered into the system as reduced.The lack of internal controls was isolated to fiscal year 2020. No eligibility determinations were made forfiscal year 2021 as the School Corporation accepted federal waivers to provide free meals to all studentsas a result of the COVID-19 pandemic.Identification as a repeat finding: No.Recommendation: We recommended that the School Corporation?s management review internal controlssurrounding eligibility determinations and ensure data is accurately entered into the software which isutilized to make eligibility determinations.We also recommend management implement a pay rate change form for hourly employees whichdocuments approved pay rates upon employment for each individual and any subsequent changes madeto pay rates.Views of Responsible Officials and Planned Corrective Actions: Management agrees with the findingand has prepared a corrective action plan.
FINDING 2021-001Information on the federal program:Subject: Child Nutrition Cluster - Internal ControlsFederal Agency: Department of Agricultureupenn en enFederal Program: School Breakfast Program, National School Lunch Program, Summer Food ServiceProgramAssistance Listing Numbers: 10.553, 10.555, 10.559Pass-Through Entity: Indiana Department of EducationCompliance Requirement: Eligibility, Activities Allowed or Unallowed/Allowable Cost-Cost PrinciplesAudit Findings: Significant DeficiencyCondition: An ?effective internal control system.was not in place at the School Corporation to ensurecompliance with requirements related to the grant agreement and the compliance requirements related toEligibility.Context:Activities Allowed or UnallowedDuring the testing of payroll disbursements changed to Fund 0800, we noted for 9 disbursements out of 40disbursements selected for testing, that the hourly rate paid to the employee was not supported by anapproved pay rate form or other document to verify the approval of the pay rate used. The hours workedwas ?supported by? approved timecards and pay period dfstributfon? reports were afso a?pproved to supportamounts charged to Fund 0800 for the period.There were no exceptions noted during testing of vendor disbursements charged to Fund 0800.EligibilityThe School Corporation determines eligibility for free or reduced lunch based on nationwide incomeeligibility guidelines on an annual basis. During the compliance testing of eligibility requirements, we notedone instance in a sample of 40 students receiving free or reduced meal benefits, that the benefitdetermination was incorrectly entered into the system. In this one instance, the student had been directlycertified and therefore eligible for free meals, however, was entered into the system as reduced.The lack of internal controls was isolated to fiscal year 2020. No eligibility determinations were made forfiscal year 2021 as the School Corporation accepted federal waivers to provide free meals to all studentsas a result of the COVID-19 pandemic.Views of Responsible Officials and Planned Corrective Actions: Management agrees with the findingA Salary Schedule increase range will be approved by the Board of School Trustees. The Food ServiceD_ireqtor and Payroll clerk will enter the proper hourly rate per food service employee.Responsible party and- timeline for completion: The corrective action plan will be put in place by June30, 2023. The individuals overseeing the corrective action plan are the following:Lori Zeider - Food Service DirectorDawn Claussen - Treasurer, Rensselaer Central Schools Corp
An effective internal control system was not in place at the School Corporation in order toensure compliance with requirements related to the grant agreements and the following compliancerequirements: Procurement and Suspension and Debarment.Cause: The School Corporation?s management had not developed a system of internal controls that wouldhave ensured compliance with the grant agreement and the Procurement and Suspension and Debarmentcompliance requirement.Effect: The failure to establish an effective internal control system enabled material noncompliance to goundetected. Noncompliance with the grant agreement and the Procurement and Suspension andDebarment requirement could have resulted in the loss of federal funds to the School Corporation.Questioned Costs: There were no questioned costs identified.Context: The School Corporation is a member of the Cooperative School Services (Cooperative). TheCooperative operated the special education programs on behalf of the School Corporation and managedthe special education grant funds. As the grant agreement was between the Indiana Department ofEducation and the School Corporation, the School Corporation was responsible for compliance with thegrant agreement and the Procurement and Suspension and Debarment compliance requirement.Procurement ? Simplified AcquisitionThe School Corporation did not have adequate internal controls in place to ensure the Cooperativecomplied with the procurement requirements for simplified acquisitions. The Cooperative did not haveadequate procedures in place to ensure procurements for simplified acquisitions were properly advertisedand bids accepted. There were two vendors who met the Simplified Acquisition threshold during the auditperiod; neither were properly procured.Suspension and DebarmentThe School Corporation did not have adequate internal controls in place to ensure the Cooperativecomplied with the Suspension and Debarment requirements. During school year 2020, the Cooperative didnot have adequate procedures in place to ensure that applicable vendors who received federal funds werenot suspended or debarred from participation in federal awards programs. There were three contractedvendors during the audit period; the unit did not perform procedures to ensure the vendors were notexcluded or disqualified.During the 2021 school year, The School Corporation did not have adequate internal controls in place toensure the Cooperative complied with the suspension and debarment requirements. The SpecialEducation Director obtained suspension and debarment certifications for contracted vendors over $25,000without an oversight or review process.The lack of controls and noncompliance related to procurement were isolated to school year 2020. The lackof controls related to suspension and debarment were systemic throughout the audit period; however, thenoncompliance was isolated to school year 2020.Identification as a repeat finding: No.Recommendation: We recommended that the School Corporation's management establish controls toensure compliance with the grant agreement and the Procurement and Suspension and Debarmentcompliance requirement.Views of Responsible Officials and Planned Corrective Actions: Management agrees with the findingand has prepared a corrective action plan.
Show full finding ▾Hide full finding ▴FINDING 2021-002Information on the federal program:Subject: Special Education Cluster ? Procurement and Suspension and DebarmentFederal Agency: Department of EducationFederal Programs: Special Education Grants to States, Special Education Preschool GrantsAssistance Listing Numbers: 84.027, 84.173Federal Award Numbers and Years (or Other Identifying Numbers): 19611-049-PN01, 20611-047-PN01,19619-49-PN01, 20619-047-PN01, 21611-047-PN01Pass-Through Entity: Indiana Department of EducationCompliance Requirement: Procurement and Suspension and DebarmentAudit Finding: Material Weakness, Qualified OpinionCriteria: 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 assurancethat 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 incompliance with guidance in 'Standards for Internal Control in the Federal Government' issued by theComptroller General of the United States or the 'Internal Control Integrated Framework', issued by theCommittee of Sponsoring Organizations of the Treadway Commission (COSO)...."2 CFR 200.303 states:?When you enter into a covered transaction with another person at the next lower tier, you must verify thatthe person with whom you intend to do business is not excluded or disqualified.You do this by:(a) Checking SAM Exclusions; or(b) Collecting a certification from that person; or(c) Adding a clause or condition to the covered transaction with that person.?2 CFR 200.320 states in part:"The non-Federal Entity must use one of the following methods of procurement??(c) Procurement by sealed bids (formal advertising). Bids are publicly solicited, and a firm fixed pricecontract (lump sum or unit price) is awarded to the responsible bidder whose bid, conforming with all thematerial terms and conditions of the invitation for bids, is the lowest in price. The sealed bid method is thepreferred method for procuring construction, if the conditions in paragraph (c)(1) of this section apply. . . ."Condition: An effective internal control system was not in place at the School Corporation in order toensure compliance with requirements related to the grant agreements and the following compliancerequirements: Procurement and Suspension and Debarment.Cause: The School Corporation?s management had not developed a system of internal controls that wouldhave ensured compliance with the grant agreement and the Procurement and Suspension and Debarmentcompliance requirement.Effect: The failure to establish an effective internal control system enabled material noncompliance to goundetected. Noncompliance with the grant agreement and the Procurement and Suspension andDebarment requirement could have resulted in the loss of federal funds to the School Corporation.Questioned Costs: There were no questioned costs identified.Context: The School Corporation is a member of the Cooperative School Services (Cooperative). TheCooperative operated the special education programs on behalf of the School Corporation and managedthe special education grant funds. As the grant agreement was between the Indiana Department ofEducation and the School Corporation, the School Corporation was responsible for compliance with thegrant agreement and the Procurement and Suspension and Debarment compliance requirement.Procurement ? Simplified AcquisitionThe School Corporation did not have adequate internal controls in place to ensure the Cooperativecomplied with the procurement requirements for simplified acquisitions. The Cooperative did not haveadequate procedures in place to ensure procurements for simplified acquisitions were properly advertisedand bids accepted. There were two vendors who met the Simplified Acquisition threshold during the auditperiod; neither were properly procured.Suspension and DebarmentThe School Corporation did not have adequate internal controls in place to ensure the Cooperativecomplied with the Suspension and Debarment requirements. During school year 2020, the Cooperative didnot have adequate procedures in place to ensure that applicable vendors who received federal funds werenot suspended or debarred from participation in federal awards programs. There were three contractedvendors during the audit period; the unit did not perform procedures to ensure the vendors were notexcluded or disqualified.During the 2021 school year, The School Corporation did not have adequate internal controls in place toensure the Cooperative complied with the suspension and debarment requirements. The SpecialEducation Director obtained suspension and debarment certifications for contracted vendors over $25,000without an oversight or review process.The lack of controls and noncompliance related to procurement were isolated to school year 2020. The lackof controls related to suspension and debarment were systemic throughout the audit period; however, thenoncompliance was isolated to school year 2020.Identification as a repeat finding: No.Recommendation: We recommended that the School Corporation's management establish controls toensure compliance with the grant agreement and the Procurement and Suspension and Debarmentcompliance requirement.Views of Responsible Officials and Planned Corrective Actions: Management agrees with the findingand has prepared a corrective action plan.
FINDING 2021-002Information on the federal program:Subject: Special Education Cluster - Procurement and Suspension and DebarmentFederal Agency: Department of EducationFederal Programs: Special Education Grants to States, Special Education Preschool GrantsAssistance Listing Numbers: 84.027, 84.173Federal Award Numbers and Years (or Other Identifying Numbers): 19611-049-PN01, 20611-047-PN01,19619-49-PN01, 20619-047-PN01, 21611-047-PN01Pass-Through Entity: Indiana Department of EducationCompliance Requirement: Procurement and Suspension and DebarmentAudit Finding: Material Weakness, Qualified OpinionCondition: An effective internal control system was not in place at the School Corporation in order toensure compliance with requirements related to the grant agreements and the following compliancerequirements: Procurement and Suspension and Debarment.Context: The School Corporation is a member of the Cooperative School Services (Cooperative). TheCooperative operated the special education programs on behalf of the School Corporation and managedthe special education grant funds. As the grant agreement was between the Indiana Department ofEducation and the School Corporation, the School Corporation was responsible for compliance with thegrant agreement and the Procurement and Suspension and Debarment compliance requirement.Procurement - Simplified AcquisitionThe School Corporation did not have adequate internal controls in place to ensure the Cooperativecomplied with the procurement requirements for simplified acquisitions. The Cooperative did not haveadequate procedures in place to ensure procurements for simplified acquisitions were properly advertisedand bids accepted. There were two vendors who met the Simplified Acquisition threshold during the auditperiod; neither were properly procured.Suspension and DebarmentThe School Corporation did not have adequate internal controls in place to ensure the Cooperativecomplied with the Suspension and Debarment requirements. During school year 2020, the Cooperativedid not have adequate procedures in place to ensure that applicable vendors who received federal fundswere not suspended or debarred from participation in federal awards programs. There were threecontracted vendors during the audit period; the unit did not perform procedures to ensure the vendorswere not excluded or disqualified.During the 2021 school year, The School Corporation did not have adequate internal controls in place toensure the Cooperative complied with the suspension and debarment requirements. The SpecialEducation Director obtained suspension and debarment certifications for contracted vendors over $25,000without an oversight or review process.The lack of controls and noncompliance related to procurement were isolated to school year 2020. The lackof controls related to suspension and debarment were systemic throughout the audit period; however, thenoncompliance was isolated to school year 2020.Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding.Two Cooperative employees will check and initial the Procurement and Suspension and Debarmentsdocumentation. Management of the School Corporation will request supporting documentation fromCooperative to validate procurement and suspension and debarment procedure were performed to satisfyfederal regulations.Responsible party and timeline for completion: The corrective action plan will be put in place by June30, 2023. Patti Kem, Director of Cooperative School Services, will oversee the corrective action plan.
An effective internal control system was not in place at the School Corporation in order toensure compliance with requirements related to the grant agreement and the earmarking portion of theMatching, Level of Effort, Earmarking compliance requirement.Cause: The School Corporation's management had not developed a system of internal controls that wouldhave ensured compliance with the grant agreement and the Matching, Level of Effort, Earmarkingcompliance requirement.Effect: The failure to establish an effective internal control system placed the School Corporation innoncompliance with the grant agreement and the Matching, Level of Effort, Earmarking compliancerequirement. Noncompliance with the grant agreement or the compliance requirement could have resultedin the loss of federal funds to the School Corporation.Questioned Costs: There were no questioned costs identified.Context: The School Corporation did not meet the earmarking requirements for the grants, whichconcluded during the audit period. Both the Special Education Grants to States and Special EducationPreschool Grants required a proportionate share of their funding to be spent on non-public schoolstudents with disabilities. The 19611-049-PN01 and 19619-49-PN01 grant awards were fully expendedduring the audit period with minimum Non-Public Proportionate Share earmarking requirements of$24,266 and $6,121, respectively. Based upon the documentation provided for non-public schoolexpenditures, the School Corporation expended $15,700 of the required $30,367 for fiscal year2019-2020 grant award.Identification as a repeat finding: Yes, see Finding 2019-001.Recommendation: We recommended that the School Corporation's management establish a systemof internal controls to ensure compliance with the Matching, Level of Effort, Earmarkingcompliance requirement.Views of Responsible Officials and Planned Corrective Actions: Management agrees with thefinding and has prepared a corrective action plan.
Show full finding ▾Hide full finding ▴FINDING 2021-003Information on the federal program:Subject: Special Education Cluster (IDEA) ? Matching, Level of Effort, EarmarkingFederal Agency: Department of EducationFederal Programs: Special Education Grants to States, Special Education Preschool GrantsAssistance Listing Numbers: 84.027, 84.173Federal Award Numbers and Years (or Other Identifying Numbers): 19611-049-PN01, 20611-047-PN01,19619-49-PN01, 20619-047-PN01, 21611-047-PN01Pass-Through Entity: Indiana Department of EducationCompliance Requirement: Matching, Level of Effort, EarmarkingAudit Finding: Significant Deficiency, Other MattersCriteria: 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 assurancethat 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 incompliance with guidance in 'Standards for Internal Control in the Federal Government' issued by theComptroller General of the United States or the 'Internal Control Integrated Framework', issued by theCommittee of Sponsoring Organizations of the Treadway Commission (COSO)...."2 CFR 200.207(a) states in part: "The Federal awarding agency or pass-through entity may imposeadditional specific award conditions as needed . . ."511 IAC 7-34-7(b) states:"The public agency, in providing special education and related services to students in nonpublic schoolsand facilities, must expend at least an amount that is the same proportion of the public agency total subgrantunder 20 U.S.C. 1411(f) as the number of nonpublic school students with disabilities, who are enrolled bytheir parents in nonpublic schools or facilities within its boundaries, is to the total number of students withdisabilities of the same age range."Condition: An effective internal control system was not in place at the School Corporation in order toensure compliance with requirements related to the grant agreement and the earmarking portion of theMatching, Level of Effort, Earmarking compliance requirement.Cause: The School Corporation's management had not developed a system of internal controls that wouldhave ensured compliance with the grant agreement and the Matching, Level of Effort, Earmarkingcompliance requirement.Effect: The failure to establish an effective internal control system placed the School Corporation innoncompliance with the grant agreement and the Matching, Level of Effort, Earmarking compliancerequirement. Noncompliance with the grant agreement or the compliance requirement could have resultedin the loss of federal funds to the School Corporation.Questioned Costs: There were no questioned costs identified.Context: The School Corporation did not meet the earmarking requirements for the grants, whichconcluded during the audit period. Both the Special Education Grants to States and Special EducationPreschool Grants required a proportionate share of their funding to be spent on non-public schoolstudents with disabilities. The 19611-049-PN01 and 19619-49-PN01 grant awards were fully expendedduring the audit period with minimum Non-Public Proportionate Share earmarking requirements of$24,266 and $6,121, respectively. Based upon the documentation provided for non-public schoolexpenditures, the School Corporation expended $15,700 of the required $30,367 for fiscal year2019-2020 grant award.Identification as a repeat finding: Yes, see Finding 2019-001.Recommendation: We recommended that the School Corporation's management establish a systemof internal controls to ensure compliance with the Matching, Level of Effort, Earmarkingcompliance requirement.Views of Responsible Officials and Planned Corrective Actions: Management agrees with thefinding and has prepared a corrective action plan.
FINDING 2021-003Information on the federal program:Subject: Special Education Cluster (IDEA) - Matching, Level of Effort, EarmarkingFederal Agency: Department of EducationFederal Programs: Special Education Grants to States, Special Education Preschool GrantsAssistance Listing Numbers: 84.027, 84.173Federal Award Numbers and Years (or Other Identifying Numbers): 19611-049-PN01, 20611-047-PN01,19619-49-PN01, 20619-047-PN01, 21611-047-PN01Pass-Through Entity: Indiana Department of EducationCompliance Requirement: Procurement and Suspension and DebarmentAudit Finding: Significant Deficiency, Other MattersCondition: An effective internal control system was not in place at the School Corporation in order toensure compliance with requirements related to the grant agreement and the earmarking portion of theMatching, Level of Effort, Earmarking compliance requirement.Context: The School Corporation did not meet the earmarking requirements for the grants, whichconcluded during the audit period. Both the Special Education Grants to States and Special EducationPreschool Grants required a proportionate share of their funding to be spent on non-public schoolstudents with disabilities. The 19611-049-PN01 and 19619-49-PN01 grant awards were fully expendedduring the audit period with minimum Non-Public Proportionate Share earmarking requirements of$24,266 and $6,121, respectively. Based upon the documentation provided for non-public schoolexpenditures, the School Corporation expended $15,700 of the required $30,367 for fiscal year 2019-2020 grant award.Views of Responsible Officials and Planned Corrective Actions: Management agrees with the findingThe Cooperative has developed a written procedure for documenting expenditures related to theproportionate share earmarking requirement at the School Corporation level to address this issue goingforward. The School Corporation will maintain the proper documentation to support the Non-PublicProportional Share earmarking requirement and validate the earmarking requirement is met at the end ofthe grant's period of performance or once fully expended.Responsible party and timeline for completion: The corrective action plan will be put in place by June30, 2023. Dawn Claussen, Treasurer, will oversee the corrective action plan.
2019-001
FAC accepted this audit on March 25, 2020 — management decision was due September 25, 2020.
FINDING 2019-001 Subject: Special Education Cluster (IDEA) - Matching, Level of Effort, Earmarking Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants CFDA Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 14216-150-PN01, 14217-049-PN01, 45717-049-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking Audit Findings: Material Weakness, Other Matters Condition and Context An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the earmarking portion of the Matching, Level of Effort, Earmarking compliance requirement. The School Corporation did not have internal controls in place to ensure that its expenditures inaid of non-public school students with disabilities were at least that of the same amount allocated (the proportionate share) from the grant for these students. The School Corporation did not meet the earmarking requirements for the grants, which concluded during the audit period. Both the Special Education Grants to States and Special Education Preschool Grants required a proportionate share of their funding to be spent on non-public school students with disabilities. Based upon the documentation provided for non-public school expenditures, the School Corporation expended $9,560 of the required $12,774 for fiscal year 2017-2018 and $13,658 of the required $15,695 for 2018-2019, towards the Non-Public Proportionate Share. Grants awarded in 2017-2018 and 2018-2019 had not ended during our audit period; therefore, the earmarking requirements were not tested during this audit. The lack of effective internal controls and noncompliance were systemic issues that occurred 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). . . ." 2 CFR 200.207(a) states in part: "The Federal awarding agency or pass-through entity may impose additional specific award conditions as needed . . ." 511 IAC 7-34-7(b) states: "The public agency, in providing special education and related services to students in nonpublic schools and facilities, 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 or facilities within its boundaries, is to the total number of students with disabilities of the same age range." Cause The School Corporation's management had not developed a system of internal controls that would have ensured compliance with the grant agreement and the Matching, Level of Effort, Earmarking compliance requirement. Effect The failure to establish an effective internal control system placed the School Corporation in noncompliance with the grant agreement and the Matching, Level of Effort, Earmarking compliance requirement. Noncompliance with the grant agreement or the compliance requirement could have resulted in the loss of federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure compliance with the Matching, Level of Effort, Earmarking compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Show full finding ▾Hide full finding ▴FINDING 2019-001 Subject: Special Education Cluster (IDEA) - Matching, Level of Effort, Earmarking Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants CFDA Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 14216-150-PN01, 14217-049-PN01, 45717-049-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking Audit Findings: Material Weakness, Other Matters Condition and Context An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the earmarking portion of the Matching, Level of Effort, Earmarking compliance requirement. The School Corporation did not have internal controls in place to ensure that its expenditures inaid of non-public school students with disabilities were at least that of the same amount allocated (the proportionate share) from the grant for these students. The School Corporation did not meet the earmarking requirements for the grants, which concluded during the audit period. Both the Special Education Grants to States and Special Education Preschool Grants required a proportionate share of their funding to be spent on non-public school students with disabilities. Based upon the documentation provided for non-public school expenditures, the School Corporation expended $9,560 of the required $12,774 for fiscal year 2017-2018 and $13,658 of the required $15,695 for 2018-2019, towards the Non-Public Proportionate Share. Grants awarded in 2017-2018 and 2018-2019 had not ended during our audit period; therefore, the earmarking requirements were not tested during this audit. The lack of effective internal controls and noncompliance were systemic issues that occurred 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). . . ." 2 CFR 200.207(a) states in part: "The Federal awarding agency or pass-through entity may impose additional specific award conditions as needed . . ." 511 IAC 7-34-7(b) states: "The public agency, in providing special education and related services to students in nonpublic schools and facilities, 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 or facilities within its boundaries, is to the total number of students with disabilities of the same age range." Cause The School Corporation's management had not developed a system of internal controls that would have ensured compliance with the grant agreement and the Matching, Level of Effort, Earmarking compliance requirement. Effect The failure to establish an effective internal control system placed the School Corporation in noncompliance with the grant agreement and the Matching, Level of Effort, Earmarking compliance requirement. Noncompliance with the grant agreement or the compliance requirement could have resulted in the loss of federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure compliance with the Matching, Level of Effort, Earmarking compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2019-001 Contact Person Responsible for Corrective Action: Dawn Claussen, Treasurer Contact Phone Number ? 219-866-7822 Views of Responsible Official: We concur with the findings. Description of Corrective Action Plan: We are in the process of developing an internal controls policy with the Special Education Cooperative in order to avoid non-compliance. Anticipated Completion Date: June 1, 2020
FINDING 2019-002 Subject: Special Education Cluster (IDEA) - Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants CFDA Numbers: 84.027, 84.173 Federal Award Numbers and Years or (Other Identifying Numbers): 14216-150-PN01, 14217-049-PN01, 45717-049-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Allowable Costs/Cost Principles Audit Findings: Material Weakness, Other Matters Condition and Context An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Allowable Costs/Cost Principles compliance requirement. The School Corporation did not have internal controls in place to ensure that its expenditures inaid of non-public school students with disabilities were at least that of the same amount allocated (the proportionate share) from the grant for these students. The School Corporation did not meet the earmarking requirements for the grants, which concluded during the audit period. Both the Special Education Grants to States and Special Education Preschool Grants required a proportionate share of their funding to be spent on non-public school students with disabilities. Based upon the documentation provided for non-public school expenditures, the School Corporation expended $9,560 of the required $12,774 for fiscal year 2017-2018 and $13,658 of the required $15,695 for 2018-2019, towards the Non-Public Proportionate Share. Expenditures of $5,250 made for non-public school students were not supported by the accounting records and are considered questioned costs. The lack of effective internal controls and noncompliance were systemic issues that occurred 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). . . ." 2 CFR 200.207(a) states in part: "The Federal awarding agency or pass-through entity may impose additional specific award conditions as needed . . ." 511 IAC 7-34-7(b) states: "The public agency, in providing special education and related services to students in nonpublic schools and facilities, 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 or facilities within its boundaries, is to the total number of students with disabilities of the same age range." Cause The School Corporation's management had not developed a system of internal controls that would have ensured compliance with the grant agreement and the Allowable Costs/Cost Principles compliance requirement. Effect The failure to establish an effective internal control system placed the School Corporation in noncompliance with the grant agreement and the Allowable Costs/Cost Principles compliance requirement. Noncompliance with the grant agreement or the compliance requirement could have resulted in the loss of federal funds to the School Corporation. Questioned Costs Actual questioned costs in the amount of $5,251 were identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure compliance with the Allowable Costs/Cost Principles compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Show full finding ▾Hide full finding ▴FINDING 2019-002 Subject: Special Education Cluster (IDEA) - Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants CFDA Numbers: 84.027, 84.173 Federal Award Numbers and Years or (Other Identifying Numbers): 14216-150-PN01, 14217-049-PN01, 45717-049-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Allowable Costs/Cost Principles Audit Findings: Material Weakness, Other Matters Condition and Context An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Allowable Costs/Cost Principles compliance requirement. The School Corporation did not have internal controls in place to ensure that its expenditures inaid of non-public school students with disabilities were at least that of the same amount allocated (the proportionate share) from the grant for these students. The School Corporation did not meet the earmarking requirements for the grants, which concluded during the audit period. Both the Special Education Grants to States and Special Education Preschool Grants required a proportionate share of their funding to be spent on non-public school students with disabilities. Based upon the documentation provided for non-public school expenditures, the School Corporation expended $9,560 of the required $12,774 for fiscal year 2017-2018 and $13,658 of the required $15,695 for 2018-2019, towards the Non-Public Proportionate Share. Expenditures of $5,250 made for non-public school students were not supported by the accounting records and are considered questioned costs. The lack of effective internal controls and noncompliance were systemic issues that occurred 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). . . ." 2 CFR 200.207(a) states in part: "The Federal awarding agency or pass-through entity may impose additional specific award conditions as needed . . ." 511 IAC 7-34-7(b) states: "The public agency, in providing special education and related services to students in nonpublic schools and facilities, 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 or facilities within its boundaries, is to the total number of students with disabilities of the same age range." Cause The School Corporation's management had not developed a system of internal controls that would have ensured compliance with the grant agreement and the Allowable Costs/Cost Principles compliance requirement. Effect The failure to establish an effective internal control system placed the School Corporation in noncompliance with the grant agreement and the Allowable Costs/Cost Principles compliance requirement. Noncompliance with the grant agreement or the compliance requirement could have resulted in the loss of federal funds to the School Corporation. Questioned Costs Actual questioned costs in the amount of $5,251 were identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure compliance with the Allowable Costs/Cost Principles compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2019-002 Contact Person Responsible for Corrective Action: Dawn Claussen, Treasurer Contact Phone Number ? 219-866-7822 Views of Responsible Official: We concur with the findings. Description of Corrective Action Plan: We are in the process of developing an internal controls policy with the Special Education Cooperative in order to avoid non-compliance. Anticipated Completion Date: June 1, 2020
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