USBE emphasizes internal controls and allowable costs to prevent losses and findings

Corey Erickson, a presenter on the USBE special education fiscal monitoring team, told charter business managers that monitors prioritize understanding internal control systems over simply reviewing paperwork.

Erickson said federal rules and USBE administrative rules require LEAs receiving federal awards to establish and maintain effective internal controls that provide reasonable assurance funds are used appropriately. He described the internal‑control framework as cutting across functions and reporting groups and said monitors concentrate on whether written policies align with day‑to‑day practices.

On allowable costs, Erickson explained that IDEA funds must be incremental — providing the ‘‘excess cost’’ of special education services in addition to state and local spending rather than supplanting it — and that costs should align to students’ IEPs when applicable. He stressed expenditures must be necessary, reasonable, documented, and occur within the grant period.

Erickson gave practical examples of internal controls that reduce risk, such as p‑card authorization thresholds, multi‑level approvals, segregation of duties and clearer procurement procedures. He said auditors and external reviews often identify weaknesses that stronger controls would have prevented.

“We say what we do and do what we say,” Erickson said, urging LEAs to ensure their procedures match their written policies and to use the USBE rules manual and available training resources to strengthen controls.

Erickson concluded by noting monitors will sample general ledger purchases and seek evidence that internal controls support accurate, allowable, and properly allocated charges.