Special Olympics Indiana, Inc.

2024-001: Allowable Costs Federal Agency: U.S. Department of Education Federal Program Name: Special Education – Special Olympics Education Programs Assistance Listing Number: 84.380W Pass-Through Agency: Special Olympics, Inc. Pass-Through Numbers: Y-16-24-800-12, Y-16-24-800-13 Award Period: January 1, 2024 – December 31, 2024 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The Compliance Supplement requires that compensation for personal services be charged to the federal grant based upon approved actual time worked on the program and not based on an allocation or budget (2 CFR 200.430(i)). Condition: While performing audit procedures, it was noted that in one (1) of the eight (8) payroll expenses tested, wages charged to the grant did not match underlying payroll records. Questioned Costs: $101 Context: During the process of obtaining an understanding of internal controls and processing of payroll expenditures, we noted an instance where payroll was not charged to the grants based upon approved actual time spent in the program. Cause: Clerical error in summarizing grant expenditures. Effect: The Organization has not fully followed compliance attributes with the allowable costs principles set forth by the Compliance Supplement related to salary expenditures charged to a program. Personnel need to reinforce policies and control procedures to ensure salaries charged to a grant are appropriately based on actual approved time worked in a program. Repeat Finding: No Recommendation: We recommend that the Organization ensure policies and procedures for reviewing and approving payroll expenditures for grant programs be strengthened to ensure mathematically accuracy. Views of Responsible Officials: There is no disagreement with the audit finding.

Criteria: 2 CFR 200.303 includes requirements related to internal controls for federal award programs, including that the Organization must, among other things, ?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)?. Additionally, Uniform Guidance requires non-Federal entities receiving Federal funds to have certain written policies, procedures, and standards of conduct (policies) in place. Condition and Context: The Organization has been administering the federal award for over a decade and has hired knowledgeable programmatic staff who have created an environment which understands the mission and purpose of the program. These individuals have not adequately documented their policies and procedures to fully establish an appropriate system of internal control over compliance. This includes a lack of required written policies as well as inadequate documentation of routine control functions such as those items noted in 2022-002 below. The lack of written policies includes required policies under Uniform Guidance sections ?200.302 (b)(6), ?200.302 (b)(7), ?200.305 (b), ?200.319 (c)(1), ?200.319 (c)(2) and ?200.320 (d)(3). Cause and Effect: The lack of appropriate controls and documentation to support processes surrounding the use of federal funds may result in undetected or uncorrected misstatements or instances of noncompliance. The lack of adequate documentation resulted in finding 2022-002 below. Additionally, as the policies referenced above are not written, the Organization cannot be in compliance with the requirements. Recommendation: The Organization should consider implementing policies, procedures, and internal controls specific to federal awards. Policies should be implemented for all applicable compliance requirements, ensuring that there is appropriate documentation to support the controls taking place. We recommend the policies noted above be written by the Organization, approved by the Board of Directors, and included in the permanent files of the Organization. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the recommendation and has implemented their corrective actions as of the date the financial statements were available for issuance.

Criteria: 2 CFR 200.318(i) establishes the need to maintain records sufficient to detail the history of procurement. 2 CFR 180.300 establishes the responsibilities of participants entering into covered transactions. Condition and Context: We noted one new procured vendor in the current year, which was selected for testing, totaling $29,205 for printing and copying services. We noted the entity lacked sufficient documentation to support the rationale of the procurement method, selection of contract type, contractor selection or rejection, and basis for the contract price. We also noted suspension and debarments requirements were not given consideration prior to entering into these transactions. However, we noted there were adequate invoices to support the purchases. Known Questioned Costs: $29,205 Cause and Effect: As described in item 2022-001, the Organization has not established formal written policies related to procurement and does not have a system in place to adequately document all compliance decisions made during the administration of the program. As a result, the Organization did not comply with the requirement for proper procurement and suspension and debarment. Recommendation: We recommend the Organization develop a system of internal controls aligned with the applicable compliance requirements to sufficiently document procurements and to ensure suspension and debarment is considered prior to entering into future covered transactions. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the recommendation and has implemented their corrective actions as of the date the financial statements were available for issuance