EIN: 351079238
UEI: V725RTH4VVG6
Audited by: Indiana State Board of Accounts
Oversight agency: 84 [Department of Education]
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Data as of September 2, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on February 26, 2025. 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 August 26, 2025 (375 days ago).
What is a management decision? →FINDING 2024-001 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Number: 84.425 Federal Award Numbers and Years (or Other Identifying Numbers): S424U200013, S425D200013, S425U210013, S425W210015 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2022-003. Condition and Context An effective internal control system was not designed, nor implemented, at the School Corporation to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirement. The School Corporation had not designed, nor implemented, a system of internal controls to ensure the annual Elementary and Secondary School Emergency Relief (ESSER) annual Data Collection reports (Reports) were complete and accurately submitted. The School Corporation Reports were reviewed by the Assistant Deputy Treasurer and submitted by the Chief Financial Officer; however, there was no documentation provided to verify that the oversight or review process to prevent, or detect and correct, errors was performed during 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). . . ." Cause There was no documentation that a system of internal controls had been designed and implemented by management of the School Corporation to ensure compliance with the federal award and the Reporting compliance requirement. INDIANA STATE BOARD OF ACCOUNTS 16 FRANKLIN COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Effect Without an effective system of internal controls noncompliance with the federal award and the Reporting compliance requirement could have occurred. Users of the Report rely upon its accuracy to make appropriate decisions. Noncompliance with the conditions of the federal award could result in the loss of federal funding 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 related to the federal award and the Reporting compliance requirement which includes documentation of the operation of the internal controls. 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 2024-001 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Number: 84.425 Federal Award Numbers and Years (or Other Identifying Numbers): S424U200013, S425D200013, S425U210013, S425W210015 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2022-003. Condition and Context An effective internal control system was not designed, nor implemented, at the School Corporation to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirement. The School Corporation had not designed, nor implemented, a system of internal controls to ensure the annual Elementary and Secondary School Emergency Relief (ESSER) annual Data Collection reports (Reports) were complete and accurately submitted. The School Corporation Reports were reviewed by the Assistant Deputy Treasurer and submitted by the Chief Financial Officer; however, there was no documentation provided to verify that the oversight or review process to prevent, or detect and correct, errors was performed during 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). . . ." Cause There was no documentation that a system of internal controls had been designed and implemented by management of the School Corporation to ensure compliance with the federal award and the Reporting compliance requirement. INDIANA STATE BOARD OF ACCOUNTS 16 FRANKLIN COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Effect Without an effective system of internal controls noncompliance with the federal award and the Reporting compliance requirement could have occurred. Users of the Report rely upon its accuracy to make appropriate decisions. Noncompliance with the conditions of the federal award could result in the loss of federal funding 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 related to the federal award and the Reporting compliance requirement which includes documentation of the operation of the internal controls. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-001 Finding Subject: COVID-19 - Education Stabilization Fund - Reporting Summary of Finding: The School Corporation had not designed, nor implemented a system of internal controls, to ensure the annual Elementary and Secondary School Emergency Relief (ESSER) annual Data Collection reports (Reports) were complete and accurately submitted. The School Corporation Reports were reviewed by the Assistant Deputy Treasurer and submitted by the Chief Financial Officer; however, there was no documentation provided to verify that the oversight or review process to prevent, or detect and correct, errors were performed during the audit period. The State Board of Accounts recommends that the School Corporation’s management establish a system of internal controls related to the federal award and the Reporting compliance requirement which includes documentation of the operation of the controls. Contact Person Responsible for Corrective Action: Camilla Hoffman, Assistant Deputy Treasurer Contact Phone Number and Email Address: hoffmanca@franklinschools.org, 317-346-8748 Views of Responsible Officials: We concur with the finding, but we would like to emphasize that the review had been implemented. It just was not documented by the reviewer. Description of Corrective Action Plan: The Assistant Deputy Treasurer will begin documenting her review of the required ESSER reporting via email, so that this review can be verified by auditors or other inquirers. Anticipated Completion Date: This corrective action will be added to the district’s procedures immediately, but ESSER reporting is not anticipated until later in the Spring 2025.
2022-003
FINDING 2024-002 Subject: COVID-19 - Education Stabilization Fund - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Number: 84.425 Federal Award Number and Year (or Other Identifying Number): S424U200013 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Finding: Significant Deficiency Condition and Context An effective internal control system was not designed at the School Corporation to ensure compliance with requirements related to the grant agreement and the Activities Allowed or Unallowed and Allowable Costs/Cost Principles compliance requirements. The School Corporation had designed a system of internal controls to ensure payroll expenditures charged to the grant fund were allowable. However, 2 of the 44 expenditures tested did not have documentation that the internal control had been applied and operated effectively. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: INDIANA STATE BOARD OF ACCOUNTS 17 FRANKLIN COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (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). . . ." Cause An effective system of internal controls had not been designed by management of the School Corporation to ensure compliance with the federal award and the Activities Allowed or Unallowed and Allowable Costs/Cost Principles compliance requirements. An internal control had been designed but was not applied consistently to all payroll transactions. Effect Without an effective system of internal controls, noncompliance with the federal award and the Activities Allowed or Unallowed and Allowable Costs/Cost Principles compliance requirements could have occurred. Noncompliance with the conditions of the federal award could result in the loss of federal funding 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 related to the federal award and the Activities Allowed or Unallowed and Allowable Costs/Cost Principles compliance requirements and apply the controls consistently to all transactions. 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 2024-002 Subject: COVID-19 - Education Stabilization Fund - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Number: 84.425 Federal Award Number and Year (or Other Identifying Number): S424U200013 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Finding: Significant Deficiency Condition and Context An effective internal control system was not designed at the School Corporation to ensure compliance with requirements related to the grant agreement and the Activities Allowed or Unallowed and Allowable Costs/Cost Principles compliance requirements. The School Corporation had designed a system of internal controls to ensure payroll expenditures charged to the grant fund were allowable. However, 2 of the 44 expenditures tested did not have documentation that the internal control had been applied and operated effectively. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: INDIANA STATE BOARD OF ACCOUNTS 17 FRANKLIN COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (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). . . ." Cause An effective system of internal controls had not been designed by management of the School Corporation to ensure compliance with the federal award and the Activities Allowed or Unallowed and Allowable Costs/Cost Principles compliance requirements. An internal control had been designed but was not applied consistently to all payroll transactions. Effect Without an effective system of internal controls, noncompliance with the federal award and the Activities Allowed or Unallowed and Allowable Costs/Cost Principles compliance requirements could have occurred. Noncompliance with the conditions of the federal award could result in the loss of federal funding 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 related to the federal award and the Activities Allowed or Unallowed and Allowable Costs/Cost Principles compliance requirements and apply the controls consistently to all transactions. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-002 Finding Subject: COVID-19 - Education Stabilization Fund – Activities Allowed or Unallowed; Allowable Costs/Cost Principles Summary of Finding: An effective internal control system was not designed at the School Corporation to ensure compliance with requirements related to the grant agreement and the Activities Allowed or Unallowed and Allowable Costs/Cost Principles compliance requirements. The School Corporation had designed a system of internal controls to ensure payroll expenditures charged to the grant fund were allowable. However, 2 of the 44 expenditures tested did not show have documentation that the control had been applied and operated effectively. The State Board of Accounts recommends that the School Corporation’s management establish a system of internal controls related to the federal award and the Activities Allowed or Unallowed and Allowable Costs/Cost Principles compliance requirements and apply the controls consistently to all transactions. Contact Person Responsible for Corrective Action: Kerri Powers-Hoffman, Payroll Specialist Contact Phone Number and Email Address: hoffmank@franklinschools.org, 317-346-8738 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Payroll Specialist will ensure the files posted to the shared drive for the monthly board meetings contain all payroll claims necessary for approval each month. The Payroll Specialist also will review the prior months file to ensure no payroll claims were skipped, which is what resulted in this finding. Anticipated Completion Date: This corrective action has already been implemented.
FAC accepted this audit on March 8, 2023 — management decision was due September 8, 2023.
FINDING 2022-001 Subject: COVID-19 - Education Stabilization Fund - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Number: 84.425U Federal Award Number and Year (or Other Identifying Number): S425U200013 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Findings: Material Weakness, Modified Opinion Condition and Context The School Corporation was a participating member in the Central Nine Career Center (Center). As a member, the School Corporation was responsible for providing financial contributions to support the Center's operations. In 2019, the Center's Executive Director commissioned a facilities study for purposes of addressing the increase in enrollment at the Center. Based on the results of the study, the Center's Governing Board approved an expansion project in May of 2021, with the construction costs to be split between the member schools based upon each member school's student enrollment at the Center. As a result of that calculation, the School Corporation's contribution to the Center for the construction costs was $472,963. The School Corporation elected to use the American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSER) funds awarded under the COVID-19 - Education Stabilization Fund to pay this obligation to the Center in December 2021. Although the School Corporation incurred the financial obligation within the grant's period of performance, the origins of the project predated the COVID-19 pandemic. The project's stated purpose did not provide any evidence that it was to prevent, prepare for, or respond to COVID-19. Additionally, the payment was made without proper supporting documentation. The claim for payment was prepared based upon an invoice submitted to the School Corporation from the Center that listed the amount due on a single line item without a breakdown or itemized detail to support the expense from the federal award. We consider the total payment of $472,963 to be questioned costs. The lack of internal controls and noncompliance was isolated to this single payment. 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). . . ." American Rescue Plan Act section 2001(e) states in part: "Uses of Funds. - A local education agency that receives funds under this section - . . . (2) shall use the remaining funds for any of the following: . . . (E) Coordination of preparedness and response efforts of local education agencies with State, local, Tribal, and territorial public health departments, and other relevant agencies, to improve coordinated responses among such entities to prevent, prepare for, and respond to coronavirus. . . . (G) Developing and implementing procedures and systems to improve the preparedness and response efforts of local educational agencies. . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following . . . (3) Records that identify adequately the source and application of funds for federallyfunded activities. These records must contain information pertaining to Federal awards, authorizations, financial obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. . . ." 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. . . . (g) be adequately documented. . . ." Cause The system of internal controls over the review of federal award expenditures developed by management of the School Corporation was not properly implemented, nor was it operating effectively to ensure expenditures were in compliance with the terms and conditions of the federal award, as well as the Activities Allowed or Unallowed and the Allowable Costs/Cost Principles compliance requirements. Effect Without a proper system of internal controls in place that operated effectively, material noncompliance remained undetected. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funds to the School Corporation. Questioned Costs Questioned costs in the amount of $472,963, were identified as noted in the Condition and Context. Recommendation We recommended that the School Corporation's management establish a proper system of internal controls to ensure expenditures made from federal awards are in compliance with the terms and conditions of the federal award, as well as the Activities Allowed or Unallowed and the Allowable Costs/Cost Principles compliance requirements. 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 2022-001 Subject: COVID-19 - Education Stabilization Fund - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Number: 84.425U Federal Award Number and Year (or Other Identifying Number): S425U200013 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Findings: Material Weakness, Modified Opinion Condition and Context The School Corporation was a participating member in the Central Nine Career Center (Center). As a member, the School Corporation was responsible for providing financial contributions to support the Center's operations. In 2019, the Center's Executive Director commissioned a facilities study for purposes of addressing the increase in enrollment at the Center. Based on the results of the study, the Center's Governing Board approved an expansion project in May of 2021, with the construction costs to be split between the member schools based upon each member school's student enrollment at the Center. As a result of that calculation, the School Corporation's contribution to the Center for the construction costs was $472,963. The School Corporation elected to use the American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSER) funds awarded under the COVID-19 - Education Stabilization Fund to pay this obligation to the Center in December 2021. Although the School Corporation incurred the financial obligation within the grant's period of performance, the origins of the project predated the COVID-19 pandemic. The project's stated purpose did not provide any evidence that it was to prevent, prepare for, or respond to COVID-19. Additionally, the payment was made without proper supporting documentation. The claim for payment was prepared based upon an invoice submitted to the School Corporation from the Center that listed the amount due on a single line item without a breakdown or itemized detail to support the expense from the federal award. We consider the total payment of $472,963 to be questioned costs. The lack of internal controls and noncompliance was isolated to this single payment. 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). . . ." American Rescue Plan Act section 2001(e) states in part: "Uses of Funds. - A local education agency that receives funds under this section - . . . (2) shall use the remaining funds for any of the following: . . . (E) Coordination of preparedness and response efforts of local education agencies with State, local, Tribal, and territorial public health departments, and other relevant agencies, to improve coordinated responses among such entities to prevent, prepare for, and respond to coronavirus. . . . (G) Developing and implementing procedures and systems to improve the preparedness and response efforts of local educational agencies. . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following . . . (3) Records that identify adequately the source and application of funds for federallyfunded activities. These records must contain information pertaining to Federal awards, authorizations, financial obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. . . ." 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. . . . (g) be adequately documented. . . ." Cause The system of internal controls over the review of federal award expenditures developed by management of the School Corporation was not properly implemented, nor was it operating effectively to ensure expenditures were in compliance with the terms and conditions of the federal award, as well as the Activities Allowed or Unallowed and the Allowable Costs/Cost Principles compliance requirements. Effect Without a proper system of internal controls in place that operated effectively, material noncompliance remained undetected. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funds to the School Corporation. Questioned Costs Questioned costs in the amount of $472,963, were identified as noted in the Condition and Context. Recommendation We recommended that the School Corporation's management establish a proper system of internal controls to ensure expenditures made from federal awards are in compliance with the terms and conditions of the federal award, as well as the Activities Allowed or Unallowed and the Allowable Costs/Cost Principles compliance requirements. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Contact Person Responsible for Corrective Action: Tina Gross Contact Phone Number: 317-945-4327 Views of Responsible Official: We concur with this finding, but would like to offer the following explanation: When ESSER funds first become available, there were no guidelines or restrictions that were made available. Instead, the districts were assigned swift deadlines in getting their spending plans submitted. The advice was, if you can link the request to COVID, and IDOE approves the request, then ESSER funds can be used. Months later, in an attempt to tighten things up, the school districts were presented with guidelines. This took place after all of the planning had already been done for all three grants and costs had already been incurred. The renovation cost in question was included in our spending plan submitted to IDOE through the Title Application Center. The following narrative was also submitted with the budget to IDOE as follows: ?We are also requesting $472,962.87 for a renovation project at our local Career Center, Central Nine in Greenwood. Franklin High School is one of eight sending schools for this career center. These renovations will add necessary classroom and lab space for the Diesel, Welding, and Dental programs. The renovations also include meeting space and restrooms. The total cost of Franklin Community Schools? portion of the project is estimated at $652,400, however, we are only requesting a portion of that in ESSER III funds and will cover the difference using district funds? IDOE approved the budget submitted, including this specific transaction. There was no reason for the district to think that this was an unallowable transaction. Description of Corrective Action Plan: The district is willing to transfer this expense to rainy day or operating funds if necessary. Anticipated Completion Date: 2-22-23
FINDING 2022-002 Subject: COVID-19 - Education Stabilization Fund - Special Tests and Provisions - Wage Rate Requirements Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013, S425U200013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Wage Rate Requirements Audit Findings: Material Weakness, Other Matters Condition and Context An effective internal control system was not designed, nor implemented, at the School Corporation to ensure compliance with requirements related to the grant agreement and the Special Tests and Provisions - Wage Rate Requirements compliance requirement. Construction contracts in excess of $2,000 financed by federal assistance funds must pay wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) to their laborers and mechanics. Nonfederal entities are to include in their construction contracts subject to the Wage Rate Requirements a provision that the contractor or subcontractor comply with these requirements and the DOL regulations. This would include a requirement to submit a copy of the payroll and statement of compliance to the entity for each week in which contract work was performed. The School Corporation did not have adequate policies or procedures to ensure that contractors were paid prevailing wage rates for contracts in excess of $2,000 that were paid from federal grant funds. Two contracts during the audit period were subject to wage rate requirements. While the contracts for each contained the required prevailing wage rate clause, the School Corporation did not receive the certified payrolls from either contractor. The lack of internal controls and noncompliance were systemic issues 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). . . ." 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) Payrolls and basic records. . . . (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). The payrolls submitted shall set out accurately and completely all of the information required to be maintained under 29 CFR 5.5(a)(3)(i), except that full social security numbers and home addresses shall not be included on weekly transmittals. . . ." Cause A system of internal controls had not been developed nor implemented by management of the School Corporation to ensure compliance with the federal award and the Special Tests and Provisions - Wage Rate Requirements compliance requirement. Effect Without a proper system of internal controls in place that operated effectively, material noncompliance remained undetected. Noncompliance with the provisions of Federal statutes, regulations, the terms and conditions of the federal award, 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. Recommendation We recommended that the School Corporation's management establish a proper system of internal controls to ensure compliance and comply with the terms and conditions of the federal award as well as the Special Tests and Provisions - Wage Rate Requirements 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 2022-002 Subject: COVID-19 - Education Stabilization Fund - Special Tests and Provisions - Wage Rate Requirements Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013, S425U200013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Wage Rate Requirements Audit Findings: Material Weakness, Other Matters Condition and Context An effective internal control system was not designed, nor implemented, at the School Corporation to ensure compliance with requirements related to the grant agreement and the Special Tests and Provisions - Wage Rate Requirements compliance requirement. Construction contracts in excess of $2,000 financed by federal assistance funds must pay wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) to their laborers and mechanics. Nonfederal entities are to include in their construction contracts subject to the Wage Rate Requirements a provision that the contractor or subcontractor comply with these requirements and the DOL regulations. This would include a requirement to submit a copy of the payroll and statement of compliance to the entity for each week in which contract work was performed. The School Corporation did not have adequate policies or procedures to ensure that contractors were paid prevailing wage rates for contracts in excess of $2,000 that were paid from federal grant funds. Two contracts during the audit period were subject to wage rate requirements. While the contracts for each contained the required prevailing wage rate clause, the School Corporation did not receive the certified payrolls from either contractor. The lack of internal controls and noncompliance were systemic issues 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). . . ." 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) Payrolls and basic records. . . . (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). The payrolls submitted shall set out accurately and completely all of the information required to be maintained under 29 CFR 5.5(a)(3)(i), except that full social security numbers and home addresses shall not be included on weekly transmittals. . . ." Cause A system of internal controls had not been developed nor implemented by management of the School Corporation to ensure compliance with the federal award and the Special Tests and Provisions - Wage Rate Requirements compliance requirement. Effect Without a proper system of internal controls in place that operated effectively, material noncompliance remained undetected. Noncompliance with the provisions of Federal statutes, regulations, the terms and conditions of the federal award, 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. Recommendation We recommended that the School Corporation's management establish a proper system of internal controls to ensure compliance and comply with the terms and conditions of the federal award as well as the Special Tests and Provisions - Wage Rate Requirements 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 2022-002 (Auditor Assigned Reference Number) Contact Person Responsible for Corrective Action: Tina Gross Contact Phone Number: 317-945-4327 Views of Responsible Official: We concur with this finding. Description of Corrective Action Plan: In previous years, we have relied on our architects, who have designed and managed our construction and renovation projects, to ensure all federal requirements had been met. It was assumed that if the architect presented a pay application from the contractor, that the architect confirmed the work had been done and that the Davis-Bacon Act requirements had been met. It should be noted that the district was able to present supporting documents that showed the wages were in compliance with the Davis-Bacon Act, as a result of the auditor?s inquiry. Although we suspect the review had been done, it was not properly documented for the district to be able to present evidence of a review to the auditors. For future federally funded projects, the Chief Financial Officer (CFO) will require that any payroll documents associated with that pay application be submitted as supporting documentation. The CFO will confirm compliance with the Davis-Bacon Act by comparing the payroll records to the wage rates required for the project. Once compliance has been confirmed, the CFO will submit the paperwork required for the board to approve the payment earned by the contractor. Anticipated Completion Date: 2-22-23
FINDING 2022-003 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013,S425D210013, S425U200013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Condition and Context An effective internal control system was not designed, nor implemented at the School Corporation to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirement. The School Corporation had not designed, nor implemented a system of internal controls to ensure that the annual Elementary and Secondary School Emergency Relief (ESSER) and the Governor's Emergency Education Relief (GEER) annual Data Collection reports (Reports) were complete and accurately submitted. The Reports were prepared by one employee without an oversight or review process in place to prevent, or detect and correct, errors. The lack of internal controls was a systemic issue throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Cause A system of internal controls had not been designed nor implemented by management of the School Corporation to ensure compliance with the federal award and the Reporting compliance requirement. Effect The failure to design and implement an effective system of internal could have enabled noncompliance with the federal award and the Reporting compliance requirement. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls related to the federal award and the Reporting 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 2022-003 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013,S425D210013, S425U200013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Condition and Context An effective internal control system was not designed, nor implemented at the School Corporation to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirement. The School Corporation had not designed, nor implemented a system of internal controls to ensure that the annual Elementary and Secondary School Emergency Relief (ESSER) and the Governor's Emergency Education Relief (GEER) annual Data Collection reports (Reports) were complete and accurately submitted. The Reports were prepared by one employee without an oversight or review process in place to prevent, or detect and correct, errors. The lack of internal controls was a systemic issue throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Cause A system of internal controls had not been designed nor implemented by management of the School Corporation to ensure compliance with the federal award and the Reporting compliance requirement. Effect The failure to design and implement an effective system of internal could have enabled noncompliance with the federal award and the Reporting compliance requirement. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls related to the federal award and the Reporting 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 2022-003 (Auditor Assigned Reference Number) Contact Person Responsible for Corrective Action: Tina Gross Contact Phone Number: 317-346-8749 Views of Responsible Official: We concur with this finding. Description of Corrective Action Plan: The district will implement an additional review of reports submitted for federal grants, and document that review of any final submission. Anticipated Completion Date: 2-23-23
FAC accepted this audit on June 16, 2021 — management decision was due December 16, 2021.
FINDING 2020-002 Subject: Special Education Cluster (IDEA) - Procurement 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): 20611-031-PN01, 19611-031-PN01, 18611-031-PN01, 20619-031-PN01, 19619-031-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Other Matters Condition and Context An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the procurement requirements of the Procurement and Suspension and Debarment compliance requirement. The School Corporation was a member of a special education cooperative (Cooperative). The Cooperative operated the special education programs on behalf of the School Corporation and managed the special education grant funds. Because the grant agreements were between the Indiana Department of Education and the School Corporation, the School Corporation is ultimately responsible for compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. The School Corporation did not have adequate procedures in place to ensure that the Cooperative complied with the procurement requirements. The Cooperative did not have adequate procedures in place to ensure that micro purchases were equitably distributed among qualified suppliers or to ensure that price or rate quotations were obtained from an adequate number of qualified sources for small purchases. The School Corporation did not obtain price or rate quotes for purchases of goods or services exceeding the small purchase threshold from an adequate number of sources for 100 percent of the vendors tested. The lack of internal controls and noncompliance were systemic issues 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 200.320 states in part: "The non-Federal Entity must use one of the following methods of procurement. (a) Procurement by micro-purchases. Procurement by micro-purchase is the acquisition of supplies or services, the aggregate dollar amount of which does not exceed the micropurchase threshold (? 200.67 Micro-purchase). To the extent practicable, the non-Federal entity must distribute micro-purchases equitably among qualified suppliers. Micropurchases may be awarded without soliciting competitive quotations if the non-Federal entity considers the price to be reasonable. (b) Procurement by small purchase procedures. Small purchase procedures are those relatively simple and informal procurement methods for securing services, supplies, or other property that do not cost more than the Simplified Acquisition Threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources. . . ." Cause Management had not developed a system of internal controls that would have ensured compliance with the grant agreement and the procurement requirements. Effect The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the procurement requirements of the Procurement and Suspension and Debarment 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 effective internal controls to ensure compliance and comply with the procurement requirements of the Procurement and Suspension and Debarment 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 2020-002 Subject: Special Education Cluster (IDEA) - Procurement 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): 20611-031-PN01, 19611-031-PN01, 18611-031-PN01, 20619-031-PN01, 19619-031-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Other Matters Condition and Context An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the procurement requirements of the Procurement and Suspension and Debarment compliance requirement. The School Corporation was a member of a special education cooperative (Cooperative). The Cooperative operated the special education programs on behalf of the School Corporation and managed the special education grant funds. Because the grant agreements were between the Indiana Department of Education and the School Corporation, the School Corporation is ultimately responsible for compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. The School Corporation did not have adequate procedures in place to ensure that the Cooperative complied with the procurement requirements. The Cooperative did not have adequate procedures in place to ensure that micro purchases were equitably distributed among qualified suppliers or to ensure that price or rate quotations were obtained from an adequate number of qualified sources for small purchases. The School Corporation did not obtain price or rate quotes for purchases of goods or services exceeding the small purchase threshold from an adequate number of sources for 100 percent of the vendors tested. The lack of internal controls and noncompliance were systemic issues 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 200.320 states in part: "The non-Federal Entity must use one of the following methods of procurement. (a) Procurement by micro-purchases. Procurement by micro-purchase is the acquisition of supplies or services, the aggregate dollar amount of which does not exceed the micropurchase threshold (? 200.67 Micro-purchase). To the extent practicable, the non-Federal entity must distribute micro-purchases equitably among qualified suppliers. Micropurchases may be awarded without soliciting competitive quotations if the non-Federal entity considers the price to be reasonable. (b) Procurement by small purchase procedures. Small purchase procedures are those relatively simple and informal procurement methods for securing services, supplies, or other property that do not cost more than the Simplified Acquisition Threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources. . . ." Cause Management had not developed a system of internal controls that would have ensured compliance with the grant agreement and the procurement requirements. Effect The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the procurement requirements of the Procurement and Suspension and Debarment 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 effective internal controls to ensure compliance and comply with the procurement requirements of the Procurement and Suspension and Debarment compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
CORRECTIVE ACTION PLAN FINDING 2020-002 (Auditor Assigned Reference Number) Contact Person Responsible for Corrective Action: Dr. Angela L. Balsley Executive Director abalsley@earlywood.org Contact Phone Number: Ph: 574-933-3705 Views of Responsible Official: We concur with the finding Description of Corrective Action Plan: The Earlywood Governing Board adopted the following policies on May 12th a. 734 Cost Principles- Spending Federal Funds b. 735 Time And Effort Reporting c. 736 Procurement- Federal Grants And Funds Administrative Guideline 736 will be discussed with the Association on June 2, 2021. The guidelines will include internal procedures for documenting relevant purchasing decisions on micro purchases within Skyward, our software used for our business office functions. Additionally, procedures will be included to identify when the accumulation of micro purchases for a particular vendor are approaching the definition of small purchases so that related price quotations may be obtained. Anticipated Completion Date: July 1, 2021
FAC accepted this audit on May 22, 2019 — management decision was due November 22, 2019.
GSA_MIGRATION
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GSA_MIGRATION
FAC accepted this audit on March 21, 2018 — management decision was due September 21, 2018.
GSA_MIGRATION
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