Audit 312279

FINDING 2022-003Subject: Child Nutrition Cluster - Allowable Costs/Cost PrinciplesFederal Agency: Department of AgricultureFederal Programs: School Breakfast Program, COVID-19 - School Breakfast Program, NationalSchool Lunch Program, COVID-19 - National School Lunch ProgramAssistance Listings Numbers: 10.553, 10.555Federal Award Numbers and Years (or Other Identifying Numbers): FY2021, FY2022Pass-Through Entity: Indiana Department of EducationCompliance Requirement: Allowable Costs/Cost PrinciplesAudit Findings: Material Weakness, Other MattersCondition and ContextAn effective internal control system was not in place at the School Corporation to ensure compliancewith requirements related to the grant agreement and the Allowable Costs/Cost Principles compliancerequirement.The School Corporation had not developed nor implemented internal controls over transactionspaid from the Child Nutrition Cluster funds to ensure that the payment was an allowable cost for the benefitof the food service program.Additionally, the School Corporation paid food service employees that worked more than 5.25 hoursa day on a biweekly basis with payments that continued into the summer. In order to do this, an employee'spay was annualized based on the expected number of days worked and then divided by 26. Each employeewas required to complete a timesheet every two weeks, which was approved by their supervisor, to supportthe time worked during the school year. Four of the fourteen paychecks selected for testing had errors.Two of the paychecks did not have the required timesheets, and two of the paychecks did not havetimesheets that reflected time worked to adequately support the amount paid to the employee.The lack of internal controls was a systemic issue for all disbursements throughout the audit period.The noncompliance was isolated to payroll disbursements for the school year ended June 30, 2021.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.403 states in part:"Except where otherwise authorized by statute, costs must meet the following general criteriain order to be allowable under Federal awards:(a) Be necessary and reasonable for the performance of the Federal award and be allocablethereto under these principles.(b) Conform to any limitations or exclusions set forth in these principles or in the Federalaward as to types or amount of cost items. . . .(g) Be adequately documented. . . ."2 CFR 200.430(i) states in part:"Standards for Documentation of Personnel Expenses(1) Charges to Federal awards for salaries and wages must be based on records thataccurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonableassurance that the charges are accurate, allowable, and properly allocated;(ii) Be incorporated into the official records of the non-Federal entity;(iii) Reasonably reflect the total activity for which the employee is compensated bythe non-Federal entity, not exceeding 100% of compensated activities . . .(vii) Support the distribution of the employee's salary or wages among specificactivities or cost objectives if the employee works on more than one Federal award; aFederal award and non-Federal award; an indirect cost activity and a direct costactivity; two or more indirect activities which are allocated using different allocationbases; or an unallowable activity and a direct or indirect cost activity. . . ."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Allowable Costs/Cost Principles compliance requirement.EffectThe failure to establish an effective internal control system enabled material noncompliance to goundetected. Noncompliance with the grant agreement and the Allowable Costs/Cost Principles compliancerequirement could result in the loss of future federal funds to the School Corporation.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish internal controls to ensurecompliance and comply with the grant agreement and the Allowable Costs/Cost Principles compliancerequirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2022-004Subject: Child Nutrition Cluster - Activities Allowed or Unallowed, Reporting, SpecialTests and Provisions - Non-Profit School Food Service AccountsFederal Agency: Department of AgricultureFederal Programs: School Breakfast Program, COVID-19 - School Breakfast Program, NationalSchool Lunch Program, COVID-19 - National School Lunch ProgramAssistance Listings Numbers: 10.553, 10.555Federal Award Numbers and Years (or Other Identifying Numbers): FY2021, FY2022Pass-Through Entity: Indiana Department of EducationCompliance Requirements: Activities Allowed or Unallowed, Reporting, Special Tests andProvisions - Non-Profit School Food Service AccountsAudit Finding: Material WeaknessCondition and ContextAn effective internal control system was not designed nor implemented at the School Corporationto ensure compliance with requirements related to the grant agreement and the Activities Allowed orUnallowed, the Reporting, and the Special Tests and Provisions - Non-Profit School Food Service Accountscompliance requirements.Activities Allowed or UnallowedThe School Corporation had not designed nor implemented a system of internal control overSchool Lunch fund disbursements to ensure all activities were for the benefit of the ChildNutrition Cluster. One employee was responsible for processing disbursements without anoversight or review process in place to prevent, or detect and correct, errors.ReportingThe School Corporation had not designed nor implemented a system of internal control toensure that reimbursement requests were accurately submitted. The reimbursement requestswere prepared by one employee based on meals served without an oversight or review processin place to prevent, or detect and correct, errors.Special Tests and Provisions - Non-Profit School Food Service AccountsThe School Corporation had not designed nor implemented a system of internal controls toensure all revenue generated by the school food service was used to operate and improve itsfood service. One employee was responsible for the receipting and disbursing of School Lunchfunds 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.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."CauseManagement had not developed nor implemented a system of internal controls that would haveensured compliance with the grant agreement and the Activities Allowed or Unallowed, the Reporting, andthe Special Tests and Provisions - Non-Profit School Food Service Accounts compliance requirements.EffectThe failure to establish an effective internal control system could have enabled material noncomplianceto go undetected.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish internal controls to ensurecompliance with the grant agreement and the Activities Allowed or Unallowed, the Reporting, and theSpecial Tests and Provisions - Non-Profit School Food Service Accounts compliance requirements.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2022-003Subject: Child Nutrition Cluster - Allowable Costs/Cost PrinciplesFederal Agency: Department of AgricultureFederal Programs: School Breakfast Program, COVID-19 - School Breakfast Program, NationalSchool Lunch Program, COVID-19 - National School Lunch ProgramAssistance Listings Numbers: 10.553, 10.555Federal Award Numbers and Years (or Other Identifying Numbers): FY2021, FY2022Pass-Through Entity: Indiana Department of EducationCompliance Requirement: Allowable Costs/Cost PrinciplesAudit Findings: Material Weakness, Other MattersCondition and ContextAn effective internal control system was not in place at the School Corporation to ensure compliancewith requirements related to the grant agreement and the Allowable Costs/Cost Principles compliancerequirement.The School Corporation had not developed nor implemented internal controls over transactionspaid from the Child Nutrition Cluster funds to ensure that the payment was an allowable cost for the benefitof the food service program.Additionally, the School Corporation paid food service employees that worked more than 5.25 hoursa day on a biweekly basis with payments that continued into the summer. In order to do this, an employee'spay was annualized based on the expected number of days worked and then divided by 26. Each employeewas required to complete a timesheet every two weeks, which was approved by their supervisor, to supportthe time worked during the school year. Four of the fourteen paychecks selected for testing had errors.Two of the paychecks did not have the required timesheets, and two of the paychecks did not havetimesheets that reflected time worked to adequately support the amount paid to the employee.The lack of internal controls was a systemic issue for all disbursements throughout the audit period.The noncompliance was isolated to payroll disbursements for the school year ended June 30, 2021.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.403 states in part:"Except where otherwise authorized by statute, costs must meet the following general criteriain order to be allowable under Federal awards:(a) Be necessary and reasonable for the performance of the Federal award and be allocablethereto under these principles.(b) Conform to any limitations or exclusions set forth in these principles or in the Federalaward as to types or amount of cost items. . . .(g) Be adequately documented. . . ."2 CFR 200.430(i) states in part:"Standards for Documentation of Personnel Expenses(1) Charges to Federal awards for salaries and wages must be based on records thataccurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonableassurance that the charges are accurate, allowable, and properly allocated;(ii) Be incorporated into the official records of the non-Federal entity;(iii) Reasonably reflect the total activity for which the employee is compensated bythe non-Federal entity, not exceeding 100% of compensated activities . . .(vii) Support the distribution of the employee's salary or wages among specificactivities or cost objectives if the employee works on more than one Federal award; aFederal award and non-Federal award; an indirect cost activity and a direct costactivity; two or more indirect activities which are allocated using different allocationbases; or an unallowable activity and a direct or indirect cost activity. . . ."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Allowable Costs/Cost Principles compliance requirement.EffectThe failure to establish an effective internal control system enabled material noncompliance to goundetected. Noncompliance with the grant agreement and the Allowable Costs/Cost Principles compliancerequirement could result in the loss of future federal funds to the School Corporation.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish internal controls to ensurecompliance and comply with the grant agreement and the Allowable Costs/Cost Principles compliancerequirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2022-004Subject: Child Nutrition Cluster - Activities Allowed or Unallowed, Reporting, SpecialTests and Provisions - Non-Profit School Food Service AccountsFederal Agency: Department of AgricultureFederal Programs: School Breakfast Program, COVID-19 - School Breakfast Program, NationalSchool Lunch Program, COVID-19 - National School Lunch ProgramAssistance Listings Numbers: 10.553, 10.555Federal Award Numbers and Years (or Other Identifying Numbers): FY2021, FY2022Pass-Through Entity: Indiana Department of EducationCompliance Requirements: Activities Allowed or Unallowed, Reporting, Special Tests andProvisions - Non-Profit School Food Service AccountsAudit Finding: Material WeaknessCondition and ContextAn effective internal control system was not designed nor implemented at the School Corporationto ensure compliance with requirements related to the grant agreement and the Activities Allowed orUnallowed, the Reporting, and the Special Tests and Provisions - Non-Profit School Food Service Accountscompliance requirements.Activities Allowed or UnallowedThe School Corporation had not designed nor implemented a system of internal control overSchool Lunch fund disbursements to ensure all activities were for the benefit of the ChildNutrition Cluster. One employee was responsible for processing disbursements without anoversight or review process in place to prevent, or detect and correct, errors.ReportingThe School Corporation had not designed nor implemented a system of internal control toensure that reimbursement requests were accurately submitted. The reimbursement requestswere prepared by one employee based on meals served without an oversight or review processin place to prevent, or detect and correct, errors.Special Tests and Provisions - Non-Profit School Food Service AccountsThe School Corporation had not designed nor implemented a system of internal controls toensure all revenue generated by the school food service was used to operate and improve itsfood service. One employee was responsible for the receipting and disbursing of School Lunchfunds 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.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."CauseManagement had not developed nor implemented a system of internal controls that would haveensured compliance with the grant agreement and the Activities Allowed or Unallowed, the Reporting, andthe Special Tests and Provisions - Non-Profit School Food Service Accounts compliance requirements.EffectThe failure to establish an effective internal control system could have enabled material noncomplianceto go undetected.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish internal controls to ensurecompliance with the grant agreement and the Activities Allowed or Unallowed, the Reporting, and theSpecial Tests and Provisions - Non-Profit School Food Service Accounts compliance requirements.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2022-003Subject: Child Nutrition Cluster - Allowable Costs/Cost PrinciplesFederal Agency: Department of AgricultureFederal Programs: School Breakfast Program, COVID-19 - School Breakfast Program, NationalSchool Lunch Program, COVID-19 - National School Lunch ProgramAssistance Listings Numbers: 10.553, 10.555Federal Award Numbers and Years (or Other Identifying Numbers): FY2021, FY2022Pass-Through Entity: Indiana Department of EducationCompliance Requirement: Allowable Costs/Cost PrinciplesAudit Findings: Material Weakness, Other MattersCondition and ContextAn effective internal control system was not in place at the School Corporation to ensure compliancewith requirements related to the grant agreement and the Allowable Costs/Cost Principles compliancerequirement.The School Corporation had not developed nor implemented internal controls over transactionspaid from the Child Nutrition Cluster funds to ensure that the payment was an allowable cost for the benefitof the food service program.Additionally, the School Corporation paid food service employees that worked more than 5.25 hoursa day on a biweekly basis with payments that continued into the summer. In order to do this, an employee'spay was annualized based on the expected number of days worked and then divided by 26. Each employeewas required to complete a timesheet every two weeks, which was approved by their supervisor, to supportthe time worked during the school year. Four of the fourteen paychecks selected for testing had errors.Two of the paychecks did not have the required timesheets, and two of the paychecks did not havetimesheets that reflected time worked to adequately support the amount paid to the employee.The lack of internal controls was a systemic issue for all disbursements throughout the audit period.The noncompliance was isolated to payroll disbursements for the school year ended June 30, 2021.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.403 states in part:"Except where otherwise authorized by statute, costs must meet the following general criteriain order to be allowable under Federal awards:(a) Be necessary and reasonable for the performance of the Federal award and be allocablethereto under these principles.(b) Conform to any limitations or exclusions set forth in these principles or in the Federalaward as to types or amount of cost items. . . .(g) Be adequately documented. . . ."2 CFR 200.430(i) states in part:"Standards for Documentation of Personnel Expenses(1) Charges to Federal awards for salaries and wages must be based on records thataccurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonableassurance that the charges are accurate, allowable, and properly allocated;(ii) Be incorporated into the official records of the non-Federal entity;(iii) Reasonably reflect the total activity for which the employee is compensated bythe non-Federal entity, not exceeding 100% of compensated activities . . .(vii) Support the distribution of the employee's salary or wages among specificactivities or cost objectives if the employee works on more than one Federal award; aFederal award and non-Federal award; an indirect cost activity and a direct costactivity; two or more indirect activities which are allocated using different allocationbases; or an unallowable activity and a direct or indirect cost activity. . . ."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Allowable Costs/Cost Principles compliance requirement.EffectThe failure to establish an effective internal control system enabled material noncompliance to goundetected. Noncompliance with the grant agreement and the Allowable Costs/Cost Principles compliancerequirement could result in the loss of future federal funds to the School Corporation.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish internal controls to ensurecompliance and comply with the grant agreement and the Allowable Costs/Cost Principles compliancerequirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2022-004Subject: Child Nutrition Cluster - Activities Allowed or Unallowed, Reporting, SpecialTests and Provisions - Non-Profit School Food Service AccountsFederal Agency: Department of AgricultureFederal Programs: School Breakfast Program, COVID-19 - School Breakfast Program, NationalSchool Lunch Program, COVID-19 - National School Lunch ProgramAssistance Listings Numbers: 10.553, 10.555Federal Award Numbers and Years (or Other Identifying Numbers): FY2021, FY2022Pass-Through Entity: Indiana Department of EducationCompliance Requirements: Activities Allowed or Unallowed, Reporting, Special Tests andProvisions - Non-Profit School Food Service AccountsAudit Finding: Material WeaknessCondition and ContextAn effective internal control system was not designed nor implemented at the School Corporationto ensure compliance with requirements related to the grant agreement and the Activities Allowed orUnallowed, the Reporting, and the Special Tests and Provisions - Non-Profit School Food Service Accountscompliance requirements.Activities Allowed or UnallowedThe School Corporation had not designed nor implemented a system of internal control overSchool Lunch fund disbursements to ensure all activities were for the benefit of the ChildNutrition Cluster. One employee was responsible for processing disbursements without anoversight or review process in place to prevent, or detect and correct, errors.ReportingThe School Corporation had not designed nor implemented a system of internal control toensure that reimbursement requests were accurately submitted. The reimbursement requestswere prepared by one employee based on meals served without an oversight or review processin place to prevent, or detect and correct, errors.Special Tests and Provisions - Non-Profit School Food Service AccountsThe School Corporation had not designed nor implemented a system of internal controls toensure all revenue generated by the school food service was used to operate and improve itsfood service. One employee was responsible for the receipting and disbursing of School Lunchfunds 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.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."CauseManagement had not developed nor implemented a system of internal controls that would haveensured compliance with the grant agreement and the Activities Allowed or Unallowed, the Reporting, andthe Special Tests and Provisions - Non-Profit School Food Service Accounts compliance requirements.EffectThe failure to establish an effective internal control system could have enabled material noncomplianceto go undetected.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish internal controls to ensurecompliance with the grant agreement and the Activities Allowed or Unallowed, the Reporting, and theSpecial Tests and Provisions - Non-Profit School Food Service Accounts compliance requirements.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2022-003Subject: Child Nutrition Cluster - Allowable Costs/Cost PrinciplesFederal Agency: Department of AgricultureFederal Programs: School Breakfast Program, COVID-19 - School Breakfast Program, NationalSchool Lunch Program, COVID-19 - National School Lunch ProgramAssistance Listings Numbers: 10.553, 10.555Federal Award Numbers and Years (or Other Identifying Numbers): FY2021, FY2022Pass-Through Entity: Indiana Department of EducationCompliance Requirement: Allowable Costs/Cost PrinciplesAudit Findings: Material Weakness, Other MattersCondition and ContextAn effective internal control system was not in place at the School Corporation to ensure compliancewith requirements related to the grant agreement and the Allowable Costs/Cost Principles compliancerequirement.The School Corporation had not developed nor implemented internal controls over transactionspaid from the Child Nutrition Cluster funds to ensure that the payment was an allowable cost for the benefitof the food service program.Additionally, the School Corporation paid food service employees that worked more than 5.25 hoursa day on a biweekly basis with payments that continued into the summer. In order to do this, an employee'spay was annualized based on the expected number of days worked and then divided by 26. Each employeewas required to complete a timesheet every two weeks, which was approved by their supervisor, to supportthe time worked during the school year. Four of the fourteen paychecks selected for testing had errors.Two of the paychecks did not have the required timesheets, and two of the paychecks did not havetimesheets that reflected time worked to adequately support the amount paid to the employee.The lack of internal controls was a systemic issue for all disbursements throughout the audit period.The noncompliance was isolated to payroll disbursements for the school year ended June 30, 2021.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.403 states in part:"Except where otherwise authorized by statute, costs must meet the following general criteriain order to be allowable under Federal awards:(a) Be necessary and reasonable for the performance of the Federal award and be allocablethereto under these principles.(b) Conform to any limitations or exclusions set forth in these principles or in the Federalaward as to types or amount of cost items. . . .(g) Be adequately documented. . . ."2 CFR 200.430(i) states in part:"Standards for Documentation of Personnel Expenses(1) Charges to Federal awards for salaries and wages must be based on records thataccurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonableassurance that the charges are accurate, allowable, and properly allocated;(ii) Be incorporated into the official records of the non-Federal entity;(iii) Reasonably reflect the total activity for which the employee is compensated bythe non-Federal entity, not exceeding 100% of compensated activities . . .(vii) Support the distribution of the employee's salary or wages among specificactivities or cost objectives if the employee works on more than one Federal award; aFederal award and non-Federal award; an indirect cost activity and a direct costactivity; two or more indirect activities which are allocated using different allocationbases; or an unallowable activity and a direct or indirect cost activity. . . ."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Allowable Costs/Cost Principles compliance requirement.EffectThe failure to establish an effective internal control system enabled material noncompliance to goundetected. Noncompliance with the grant agreement and the Allowable Costs/Cost Principles compliancerequirement could result in the loss of future federal funds to the School Corporation.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish internal controls to ensurecompliance and comply with the grant agreement and the Allowable Costs/Cost Principles compliancerequirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2022-004Subject: Child Nutrition Cluster - Activities Allowed or Unallowed, Reporting, SpecialTests and Provisions - Non-Profit School Food Service AccountsFederal Agency: Department of AgricultureFederal Programs: School Breakfast Program, COVID-19 - School Breakfast Program, NationalSchool Lunch Program, COVID-19 - National School Lunch ProgramAssistance Listings Numbers: 10.553, 10.555Federal Award Numbers and Years (or Other Identifying Numbers): FY2021, FY2022Pass-Through Entity: Indiana Department of EducationCompliance Requirements: Activities Allowed or Unallowed, Reporting, Special Tests andProvisions - Non-Profit School Food Service AccountsAudit Finding: Material WeaknessCondition and ContextAn effective internal control system was not designed nor implemented at the School Corporationto ensure compliance with requirements related to the grant agreement and the Activities Allowed orUnallowed, the Reporting, and the Special Tests and Provisions - Non-Profit School Food Service Accountscompliance requirements.Activities Allowed or UnallowedThe School Corporation had not designed nor implemented a system of internal control overSchool Lunch fund disbursements to ensure all activities were for the benefit of the ChildNutrition Cluster. One employee was responsible for processing disbursements without anoversight or review process in place to prevent, or detect and correct, errors.ReportingThe School Corporation had not designed nor implemented a system of internal control toensure that reimbursement requests were accurately submitted. The reimbursement requestswere prepared by one employee based on meals served without an oversight or review processin place to prevent, or detect and correct, errors.Special Tests and Provisions - Non-Profit School Food Service AccountsThe School Corporation had not designed nor implemented a system of internal controls toensure all revenue generated by the school food service was used to operate and improve itsfood service. One employee was responsible for the receipting and disbursing of School Lunchfunds 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.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."CauseManagement had not developed nor implemented a system of internal controls that would haveensured compliance with the grant agreement and the Activities Allowed or Unallowed, the Reporting, andthe Special Tests and Provisions - Non-Profit School Food Service Accounts compliance requirements.EffectThe failure to establish an effective internal control system could have enabled material noncomplianceto go undetected.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish internal controls to ensurecompliance with the grant agreement and the Activities Allowed or Unallowed, the Reporting, and theSpecial Tests and Provisions - Non-Profit School Food Service Accounts compliance requirements.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2022-003Subject: Child Nutrition Cluster - Allowable Costs/Cost PrinciplesFederal Agency: Department of AgricultureFederal Programs: School Breakfast Program, COVID-19 - School Breakfast Program, NationalSchool Lunch Program, COVID-19 - National School Lunch ProgramAssistance Listings Numbers: 10.553, 10.555Federal Award Numbers and Years (or Other Identifying Numbers): FY2021, FY2022Pass-Through Entity: Indiana Department of EducationCompliance Requirement: Allowable Costs/Cost PrinciplesAudit Findings: Material Weakness, Other MattersCondition and ContextAn effective internal control system was not in place at the School Corporation to ensure compliancewith requirements related to the grant agreement and the Allowable Costs/Cost Principles compliancerequirement.The School Corporation had not developed nor implemented internal controls over transactionspaid from the Child Nutrition Cluster funds to ensure that the payment was an allowable cost for the benefitof the food service program.Additionally, the School Corporation paid food service employees that worked more than 5.25 hoursa day on a biweekly basis with payments that continued into the summer. In order to do this, an employee'spay was annualized based on the expected number of days worked and then divided by 26. Each employeewas required to complete a timesheet every two weeks, which was approved by their supervisor, to supportthe time worked during the school year. Four of the fourteen paychecks selected for testing had errors.Two of the paychecks did not have the required timesheets, and two of the paychecks did not havetimesheets that reflected time worked to adequately support the amount paid to the employee.The lack of internal controls was a systemic issue for all disbursements throughout the audit period.The noncompliance was isolated to payroll disbursements for the school year ended June 30, 2021.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.403 states in part:"Except where otherwise authorized by statute, costs must meet the following general criteriain order to be allowable under Federal awards:(a) Be necessary and reasonable for the performance of the Federal award and be allocablethereto under these principles.(b) Conform to any limitations or exclusions set forth in these principles or in the Federalaward as to types or amount of cost items. . . .(g) Be adequately documented. . . ."2 CFR 200.430(i) states in part:"Standards for Documentation of Personnel Expenses(1) Charges to Federal awards for salaries and wages must be based on records thataccurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonableassurance that the charges are accurate, allowable, and properly allocated;(ii) Be incorporated into the official records of the non-Federal entity;(iii) Reasonably reflect the total activity for which the employee is compensated bythe non-Federal entity, not exceeding 100% of compensated activities . . .(vii) Support the distribution of the employee's salary or wages among specificactivities or cost objectives if the employee works on more than one Federal award; aFederal award and non-Federal award; an indirect cost activity and a direct costactivity; two or more indirect activities which are allocated using different allocationbases; or an unallowable activity and a direct or indirect cost activity. . . ."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Allowable Costs/Cost Principles compliance requirement.EffectThe failure to establish an effective internal control system enabled material noncompliance to goundetected. Noncompliance with the grant agreement and the Allowable Costs/Cost Principles compliancerequirement could result in the loss of future federal funds to the School Corporation.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish internal controls to ensurecompliance and comply with the grant agreement and the Allowable Costs/Cost Principles compliancerequirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2022-004Subject: Child Nutrition Cluster - Activities Allowed or Unallowed, Reporting, SpecialTests and Provisions - Non-Profit School Food Service AccountsFederal Agency: Department of AgricultureFederal Programs: School Breakfast Program, COVID-19 - School Breakfast Program, NationalSchool Lunch Program, COVID-19 - National School Lunch ProgramAssistance Listings Numbers: 10.553, 10.555Federal Award Numbers and Years (or Other Identifying Numbers): FY2021, FY2022Pass-Through Entity: Indiana Department of EducationCompliance Requirements: Activities Allowed or Unallowed, Reporting, Special Tests andProvisions - Non-Profit School Food Service AccountsAudit Finding: Material WeaknessCondition and ContextAn effective internal control system was not designed nor implemented at the School Corporationto ensure compliance with requirements related to the grant agreement and the Activities Allowed orUnallowed, the Reporting, and the Special Tests and Provisions - Non-Profit School Food Service Accountscompliance requirements.Activities Allowed or UnallowedThe School Corporation had not designed nor implemented a system of internal control overSchool Lunch fund disbursements to ensure all activities were for the benefit of the ChildNutrition Cluster. One employee was responsible for processing disbursements without anoversight or review process in place to prevent, or detect and correct, errors.ReportingThe School Corporation had not designed nor implemented a system of internal control toensure that reimbursement requests were accurately submitted. The reimbursement requestswere prepared by one employee based on meals served without an oversight or review processin place to prevent, or detect and correct, errors.Special Tests and Provisions - Non-Profit School Food Service AccountsThe School Corporation had not designed nor implemented a system of internal controls toensure all revenue generated by the school food service was used to operate and improve itsfood service. One employee was responsible for the receipting and disbursing of School Lunchfunds 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.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."CauseManagement had not developed nor implemented a system of internal controls that would haveensured compliance with the grant agreement and the Activities Allowed or Unallowed, the Reporting, andthe Special Tests and Provisions - Non-Profit School Food Service Accounts compliance requirements.EffectThe failure to establish an effective internal control system could have enabled material noncomplianceto go undetected.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish internal controls to ensurecompliance with the grant agreement and the Activities Allowed or Unallowed, the Reporting, and theSpecial Tests and Provisions - Non-Profit School Food Service Accounts compliance requirements.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2022-003Subject: Child Nutrition Cluster - Allowable Costs/Cost PrinciplesFederal Agency: Department of AgricultureFederal Programs: School Breakfast Program, COVID-19 - School Breakfast Program, NationalSchool Lunch Program, COVID-19 - National School Lunch ProgramAssistance Listings Numbers: 10.553, 10.555Federal Award Numbers and Years (or Other Identifying Numbers): FY2021, FY2022Pass-Through Entity: Indiana Department of EducationCompliance Requirement: Allowable Costs/Cost PrinciplesAudit Findings: Material Weakness, Other MattersCondition and ContextAn effective internal control system was not in place at the School Corporation to ensure compliancewith requirements related to the grant agreement and the Allowable Costs/Cost Principles compliancerequirement.The School Corporation had not developed nor implemented internal controls over transactionspaid from the Child Nutrition Cluster funds to ensure that the payment was an allowable cost for the benefitof the food service program.Additionally, the School Corporation paid food service employees that worked more than 5.25 hoursa day on a biweekly basis with payments that continued into the summer. In order to do this, an employee'spay was annualized based on the expected number of days worked and then divided by 26. Each employeewas required to complete a timesheet every two weeks, which was approved by their supervisor, to supportthe time worked during the school year. Four of the fourteen paychecks selected for testing had errors.Two of the paychecks did not have the required timesheets, and two of the paychecks did not havetimesheets that reflected time worked to adequately support the amount paid to the employee.The lack of internal controls was a systemic issue for all disbursements throughout the audit period.The noncompliance was isolated to payroll disbursements for the school year ended June 30, 2021.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.403 states in part:"Except where otherwise authorized by statute, costs must meet the following general criteriain order to be allowable under Federal awards:(a) Be necessary and reasonable for the performance of the Federal award and be allocablethereto under these principles.(b) Conform to any limitations or exclusions set forth in these principles or in the Federalaward as to types or amount of cost items. . . .(g) Be adequately documented. . . ."2 CFR 200.430(i) states in part:"Standards for Documentation of Personnel Expenses(1) Charges to Federal awards for salaries and wages must be based on records thataccurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonableassurance that the charges are accurate, allowable, and properly allocated;(ii) Be incorporated into the official records of the non-Federal entity;(iii) Reasonably reflect the total activity for which the employee is compensated bythe non-Federal entity, not exceeding 100% of compensated activities . . .(vii) Support the distribution of the employee's salary or wages among specificactivities or cost objectives if the employee works on more than one Federal award; aFederal award and non-Federal award; an indirect cost activity and a direct costactivity; two or more indirect activities which are allocated using different allocationbases; or an unallowable activity and a direct or indirect cost activity. . . ."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Allowable Costs/Cost Principles compliance requirement.EffectThe failure to establish an effective internal control system enabled material noncompliance to goundetected. Noncompliance with the grant agreement and the Allowable Costs/Cost Principles compliancerequirement could result in the loss of future federal funds to the School Corporation.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish internal controls to ensurecompliance and comply with the grant agreement and the Allowable Costs/Cost Principles compliancerequirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2022-004Subject: Child Nutrition Cluster - Activities Allowed or Unallowed, Reporting, SpecialTests and Provisions - Non-Profit School Food Service AccountsFederal Agency: Department of AgricultureFederal Programs: School Breakfast Program, COVID-19 - School Breakfast Program, NationalSchool Lunch Program, COVID-19 - National School Lunch ProgramAssistance Listings Numbers: 10.553, 10.555Federal Award Numbers and Years (or Other Identifying Numbers): FY2021, FY2022Pass-Through Entity: Indiana Department of EducationCompliance Requirements: Activities Allowed or Unallowed, Reporting, Special Tests andProvisions - Non-Profit School Food Service AccountsAudit Finding: Material WeaknessCondition and ContextAn effective internal control system was not designed nor implemented at the School Corporationto ensure compliance with requirements related to the grant agreement and the Activities Allowed orUnallowed, the Reporting, and the Special Tests and Provisions - Non-Profit School Food Service Accountscompliance requirements.Activities Allowed or UnallowedThe School Corporation had not designed nor implemented a system of internal control overSchool Lunch fund disbursements to ensure all activities were for the benefit of the ChildNutrition Cluster. One employee was responsible for processing disbursements without anoversight or review process in place to prevent, or detect and correct, errors.ReportingThe School Corporation had not designed nor implemented a system of internal control toensure that reimbursement requests were accurately submitted. The reimbursement requestswere prepared by one employee based on meals served without an oversight or review processin place to prevent, or detect and correct, errors.Special Tests and Provisions - Non-Profit School Food Service AccountsThe School Corporation had not designed nor implemented a system of internal controls toensure all revenue generated by the school food service was used to operate and improve itsfood service. One employee was responsible for the receipting and disbursing of School Lunchfunds 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.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."CauseManagement had not developed nor implemented a system of internal controls that would haveensured compliance with the grant agreement and the Activities Allowed or Unallowed, the Reporting, andthe Special Tests and Provisions - Non-Profit School Food Service Accounts compliance requirements.EffectThe failure to establish an effective internal control system could have enabled material noncomplianceto go undetected.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish internal controls to ensurecompliance with the grant agreement and the Activities Allowed or Unallowed, the Reporting, and theSpecial Tests and Provisions - Non-Profit School Food Service Accounts compliance requirements.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2022-007Subject: COVID-19 - Education Stabilization Fund - ReportingFederal Agency: Department of EducationFederal Program: COVID-19 - Education Stabilization FundAssistance Listings Numbers: 84.425C, 84.425D, 84.425UFederal Award Numbers and Years (or Other Identifying Numbers): S425C200018, S425D200013,S425U210013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: ReportingAudit Finding: Material WeaknessCondition and ContextAn effective internal control system, was not designed nor implemented at the School Corporationto ensure compliance with requirements related to the grant agreement and the Reporting compliancerequirement.The School Corporation had not designed nor implemented a system of internal controls to ensurethat the annual Elementary and Secondary School Emergency Relief (ESSER) and the Governor'sEmergency Education Relief (GEER) annual Data Collection reports (Reports) were complete and accuratelysubmitted. The Reports were prepared by one employee without an oversight or review processin place to prevent, or detect and correct, errors.The lack of internal controls was a systemic issue throughout the audit period.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."CauseManagement had not developed nor implemented an effective internal control system that wouldhave ensured compliance with the grant agreement and the Reporting compliance requirement.EffectThe failure to establish an effective internal control system could have enabled material noncomplianceto go undetected.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish internal controls to ensurecompliance with the grant agreement and the Reporting compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2022-007Subject: COVID-19 - Education Stabilization Fund - ReportingFederal Agency: Department of EducationFederal Program: COVID-19 - Education Stabilization FundAssistance Listings Numbers: 84.425C, 84.425D, 84.425UFederal Award Numbers and Years (or Other Identifying Numbers): S425C200018, S425D200013,S425U210013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: ReportingAudit Finding: Material WeaknessCondition and ContextAn effective internal control system, was not designed nor implemented at the School Corporationto ensure compliance with requirements related to the grant agreement and the Reporting compliancerequirement.The School Corporation had not designed nor implemented a system of internal controls to ensurethat the annual Elementary and Secondary School Emergency Relief (ESSER) and the Governor'sEmergency Education Relief (GEER) annual Data Collection reports (Reports) were complete and accuratelysubmitted. The Reports were prepared by one employee without an oversight or review processin place to prevent, or detect and correct, errors.The lack of internal controls was a systemic issue throughout the audit period.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."CauseManagement had not developed nor implemented an effective internal control system that wouldhave ensured compliance with the grant agreement and the Reporting compliance requirement.EffectThe failure to establish an effective internal control system could have enabled material noncomplianceto go undetected.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish internal controls to ensurecompliance with the grant agreement and the Reporting compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2022-005Subject: COVID-19 - Education Stabilization Fund - Allowable Costs/Cost PrinciplesFederal Agency: Department of EducationFederal Program: COVID-19 - Education Stabilization FundAssistance Listings Numbers: 84.425D, 84.425UFederal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425U210013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: Allowable Costs/Cost PrinciplesAudit Findings: Material Weakness, Modified OpinionCondition and ContextAn effective internal control system was not in place at the School Corporation in order to ensurecompliance with requirements related to the grant agreement and the Allowable Costs/Cost Principlescompliance requirement.The School Corporation did not have adequate internal controls in place to ensure that the reimbursementrequests included salaries for all contracted employees and adequate supporting documentationor personnel activity reports, such as time and effort logs or Semi-Annual Certifications. The SchoolCorporation paid salaries for all contracted employees without adequate supporting documentation orpersonnel activity reports, such as time and effort logs or Semi-Annual Certifications. The total amountpaid to contracted employees was $51,644. This amount was considered questioned costs.The lack of internal controls and noncompliance were systemic issues throughout the audit period.CriteriaCFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.430(i) states in part:"Standards for Documentation of Personnel Expenses(1) Charges to Federal awards for salaries and wages must be based on records thataccurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonableassurance that the charges are accurate, allowable, and properly allocated;(ii) Be incorporated into the official records of the non-Federal entity;(iii) Reasonably reflect the total activity for which the employee is compensated bythe non-Federal entity, not exceeding 100% of compensated activities . . .(vii) Support the distribution of the employee's salary or wages among specificactivities or cost objectives if the employee works on more than one Federal award; aFederal award and non-Federal award; an indirect cost activity and a direct costactivity; two or more indirect activities which are allocated using different allocationbases; or an unallowable activity and a direct or indirect cost activity. . . ."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Allowable Costs/Cost Principles compliance requirement.EffectThe failure to establish an effective internal control system enabled material noncompliance to goundetected. Noncompliance with the grant agreement and the Allowable Costs/Cost Principles compliancerequirement could have resulted in the loss of federal funds to the School Corporation.Questioned CostsQuestioned costs of $51,644 were identified, as described in the Condition and Context.RecommendationWe recommended that the School Corporation's management establish a system of internal controlsto ensure compliance and comply with the grant agreement and the Allowable Costs/Cost Principlescompliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2022-006Subject: COVID-19 - Education Stabilization Fund - Equipment and Real Property ManagementFederal Agency: Department of EducationFederal Program: COVID-19 - Education Stabilization FundAssistance Listings Number: 84.425DFederal Award Number and Year (or Other Identifying Number): S425D200013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: Equipment and Real Property ManagementAudit Findings: Material Weakness, Modified OpinionCondition and ContextAn effective internal control system was not in place at the School Corporation to ensure compliancewith requirements related to the grant agreement and the Equipment and Real Property Managementcompliance requirement.The School Corporation purchased $72,425 of various equipment with Elementary and SecondarySchool Emergency Relief (ESSER) funds. The equipment was not added to the property record whichwould include a description of the property, a serial number or other identification number, the source offunding for the property (including the federal award identification number (FAIN)), who holds title, theacquisition date, cost of the property, percentage of federal participation in the project costs for the federalaward under which the property was acquired, the location, and the use and condition of the property.Additionally, the School Corporation did not adequately safeguard the equipment purchased and had notcompleted a physical inventory of equipment within the last two years.The lack of internal controls and noncompliance were systemic issues throughout the audit period.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.313(d) states in part:"(1) Property records must be maintained that include a description of the property, a serialnumber or other identification number, the source of funding for the property (includingthe FAIN), who holds title, the acquisition date, and cost of the property, percentage offederal participation in the project costs for the federal award under which the propertywas acquired, the location, use and condition of the property, and any ultimate dispositiondata including the date of disposal and sales price of the property(2) A physical inventory of the property must be taken and the results reconciled with theproperty 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. . . ."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the grant agreement and the Equipment and Real Property compliance requirement.EffectThe failure to establish an effective internal control system enabled material noncompliance to goundetected. Noncompliance with the grant agreement and the Equipment and Real Property Managementcompliance requirement could have resulted in the loss of future federal funds to the School Corporation.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish a system of internal controlsto ensure compliance and comply with the grant agreement and the Equipment and Real PropertyManagement compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2022-007Subject: COVID-19 - Education Stabilization Fund - ReportingFederal Agency: Department of EducationFederal Program: COVID-19 - Education Stabilization FundAssistance Listings Numbers: 84.425C, 84.425D, 84.425UFederal Award Numbers and Years (or Other Identifying Numbers): S425C200018, S425D200013,S425U210013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: ReportingAudit Finding: Material WeaknessCondition and ContextAn effective internal control system, was not designed nor implemented at the School Corporationto ensure compliance with requirements related to the grant agreement and the Reporting compliancerequirement.The School Corporation had not designed nor implemented a system of internal controls to ensurethat the annual Elementary and Secondary School Emergency Relief (ESSER) and the Governor'sEmergency Education Relief (GEER) annual Data Collection reports (Reports) were complete and accuratelysubmitted. The Reports were prepared by one employee without an oversight or review processin place to prevent, or detect and correct, errors.The lack of internal controls was a systemic issue throughout the audit period.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."CauseManagement had not developed nor implemented an effective internal control system that wouldhave ensured compliance with the grant agreement and the Reporting compliance requirement.EffectThe failure to establish an effective internal control system could have enabled material noncomplianceto go undetected.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish internal controls to ensurecompliance with the grant agreement and the Reporting compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2022-005Subject: COVID-19 - Education Stabilization Fund - Allowable Costs/Cost PrinciplesFederal Agency: Department of EducationFederal Program: COVID-19 - Education Stabilization FundAssistance Listings Numbers: 84.425D, 84.425UFederal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425U210013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: Allowable Costs/Cost PrinciplesAudit Findings: Material Weakness, Modified OpinionCondition and ContextAn effective internal control system was not in place at the School Corporation in order to ensurecompliance with requirements related to the grant agreement and the Allowable Costs/Cost Principlescompliance requirement.The School Corporation did not have adequate internal controls in place to ensure that the reimbursementrequests included salaries for all contracted employees and adequate supporting documentationor personnel activity reports, such as time and effort logs or Semi-Annual Certifications. The SchoolCorporation paid salaries for all contracted employees without adequate supporting documentation orpersonnel activity reports, such as time and effort logs or Semi-Annual Certifications. The total amountpaid to contracted employees was $51,644. This amount was considered questioned costs.The lack of internal controls and noncompliance were systemic issues throughout the audit period.CriteriaCFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.430(i) states in part:"Standards for Documentation of Personnel Expenses(1) Charges to Federal awards for salaries and wages must be based on records thataccurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonableassurance that the charges are accurate, allowable, and properly allocated;(ii) Be incorporated into the official records of the non-Federal entity;(iii) Reasonably reflect the total activity for which the employee is compensated bythe non-Federal entity, not exceeding 100% of compensated activities . . .(vii) Support the distribution of the employee's salary or wages among specificactivities or cost objectives if the employee works on more than one Federal award; aFederal award and non-Federal award; an indirect cost activity and a direct costactivity; two or more indirect activities which are allocated using different allocationbases; or an unallowable activity and a direct or indirect cost activity. . . ."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Allowable Costs/Cost Principles compliance requirement.EffectThe failure to establish an effective internal control system enabled material noncompliance to goundetected. Noncompliance with the grant agreement and the Allowable Costs/Cost Principles compliancerequirement could have resulted in the loss of federal funds to the School Corporation.Questioned CostsQuestioned costs of $51,644 were identified, as described in the Condition and Context.RecommendationWe recommended that the School Corporation's management establish a system of internal controlsto ensure compliance and comply with the grant agreement and the Allowable Costs/Cost Principlescompliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2022-005Subject: COVID-19 - Education Stabilization Fund - Allowable Costs/Cost PrinciplesFederal Agency: Department of EducationFederal Program: COVID-19 - Education Stabilization FundAssistance Listings Numbers: 84.425D, 84.425UFederal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425U210013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: Allowable Costs/Cost PrinciplesAudit Findings: Material Weakness, Modified OpinionCondition and ContextAn effective internal control system was not in place at the School Corporation in order to ensurecompliance with requirements related to the grant agreement and the Allowable Costs/Cost Principlescompliance requirement.The School Corporation did not have adequate internal controls in place to ensure that the reimbursementrequests included salaries for all contracted employees and adequate supporting documentationor personnel activity reports, such as time and effort logs or Semi-Annual Certifications. The SchoolCorporation paid salaries for all contracted employees without adequate supporting documentation orpersonnel activity reports, such as time and effort logs or Semi-Annual Certifications. The total amountpaid to contracted employees was $51,644. This amount was considered questioned costs.The lack of internal controls and noncompliance were systemic issues throughout the audit period.CriteriaCFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.430(i) states in part:"Standards for Documentation of Personnel Expenses(1) Charges to Federal awards for salaries and wages must be based on records thataccurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonableassurance that the charges are accurate, allowable, and properly allocated;(ii) Be incorporated into the official records of the non-Federal entity;(iii) Reasonably reflect the total activity for which the employee is compensated bythe non-Federal entity, not exceeding 100% of compensated activities . . .(vii) Support the distribution of the employee's salary or wages among specificactivities or cost objectives if the employee works on more than one Federal award; aFederal award and non-Federal award; an indirect cost activity and a direct costactivity; two or more indirect activities which are allocated using different allocationbases; or an unallowable activity and a direct or indirect cost activity. . . ."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Allowable Costs/Cost Principles compliance requirement.EffectThe failure to establish an effective internal control system enabled material noncompliance to goundetected. Noncompliance with the grant agreement and the Allowable Costs/Cost Principles compliancerequirement could have resulted in the loss of federal funds to the School Corporation.Questioned CostsQuestioned costs of $51,644 were identified, as described in the Condition and Context.RecommendationWe recommended that the School Corporation's management establish a system of internal controlsto ensure compliance and comply with the grant agreement and the Allowable Costs/Cost Principlescompliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2022-007Subject: COVID-19 - Education Stabilization Fund - ReportingFederal Agency: Department of EducationFederal Program: COVID-19 - Education Stabilization FundAssistance Listings Numbers: 84.425C, 84.425D, 84.425UFederal Award Numbers and Years (or Other Identifying Numbers): S425C200018, S425D200013,S425U210013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: ReportingAudit Finding: Material WeaknessCondition and ContextAn effective internal control system, was not designed nor implemented at the School Corporationto ensure compliance with requirements related to the grant agreement and the Reporting compliancerequirement.The School Corporation had not designed nor implemented a system of internal controls to ensurethat the annual Elementary and Secondary School Emergency Relief (ESSER) and the Governor'sEmergency Education Relief (GEER) annual Data Collection reports (Reports) were complete and accuratelysubmitted. The Reports were prepared by one employee without an oversight or review processin place to prevent, or detect and correct, errors.The lack of internal controls was a systemic issue throughout the audit period.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."CauseManagement had not developed nor implemented an effective internal control system that wouldhave ensured compliance with the grant agreement and the Reporting compliance requirement.EffectThe failure to establish an effective internal control system could have enabled material noncomplianceto go undetected.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish internal controls to ensurecompliance with the grant agreement and the Reporting compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2022-007Subject: COVID-19 - Education Stabilization Fund - ReportingFederal Agency: Department of EducationFederal Program: COVID-19 - Education Stabilization FundAssistance Listings Numbers: 84.425C, 84.425D, 84.425UFederal Award Numbers and Years (or Other Identifying Numbers): S425C200018, S425D200013,S425U210013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: ReportingAudit Finding: Material WeaknessCondition and ContextAn effective internal control system, was not designed nor implemented at the School Corporationto ensure compliance with requirements related to the grant agreement and the Reporting compliancerequirement.The School Corporation had not designed nor implemented a system of internal controls to ensurethat the annual Elementary and Secondary School Emergency Relief (ESSER) and the Governor'sEmergency Education Relief (GEER) annual Data Collection reports (Reports) were complete and accuratelysubmitted. The Reports were prepared by one employee without an oversight or review processin place to prevent, or detect and correct, errors.The lack of internal controls was a systemic issue throughout the audit period.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."CauseManagement had not developed nor implemented an effective internal control system that wouldhave ensured compliance with the grant agreement and the Reporting compliance requirement.EffectThe failure to establish an effective internal control system could have enabled material noncomplianceto go undetected.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish internal controls to ensurecompliance with the grant agreement and the Reporting compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2022-003Subject: Child Nutrition Cluster - Allowable Costs/Cost PrinciplesFederal Agency: Department of AgricultureFederal Programs: School Breakfast Program, COVID-19 - School Breakfast Program, NationalSchool Lunch Program, COVID-19 - National School Lunch ProgramAssistance Listings Numbers: 10.553, 10.555Federal Award Numbers and Years (or Other Identifying Numbers): FY2021, FY2022Pass-Through Entity: Indiana Department of EducationCompliance Requirement: Allowable Costs/Cost PrinciplesAudit Findings: Material Weakness, Other MattersCondition and ContextAn effective internal control system was not in place at the School Corporation to ensure compliancewith requirements related to the grant agreement and the Allowable Costs/Cost Principles compliancerequirement.The School Corporation had not developed nor implemented internal controls over transactionspaid from the Child Nutrition Cluster funds to ensure that the payment was an allowable cost for the benefitof the food service program.Additionally, the School Corporation paid food service employees that worked more than 5.25 hoursa day on a biweekly basis with payments that continued into the summer. In order to do this, an employee'spay was annualized based on the expected number of days worked and then divided by 26. Each employeewas required to complete a timesheet every two weeks, which was approved by their supervisor, to supportthe time worked during the school year. Four of the fourteen paychecks selected for testing had errors.Two of the paychecks did not have the required timesheets, and two of the paychecks did not havetimesheets that reflected time worked to adequately support the amount paid to the employee.The lack of internal controls was a systemic issue for all disbursements throughout the audit period.The noncompliance was isolated to payroll disbursements for the school year ended June 30, 2021.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.403 states in part:"Except where otherwise authorized by statute, costs must meet the following general criteriain order to be allowable under Federal awards:(a) Be necessary and reasonable for the performance of the Federal award and be allocablethereto under these principles.(b) Conform to any limitations or exclusions set forth in these principles or in the Federalaward as to types or amount of cost items. . . .(g) Be adequately documented. . . ."2 CFR 200.430(i) states in part:"Standards for Documentation of Personnel Expenses(1) Charges to Federal awards for salaries and wages must be based on records thataccurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonableassurance that the charges are accurate, allowable, and properly allocated;(ii) Be incorporated into the official records of the non-Federal entity;(iii) Reasonably reflect the total activity for which the employee is compensated bythe non-Federal entity, not exceeding 100% of compensated activities . . .(vii) Support the distribution of the employee's salary or wages among specificactivities or cost objectives if the employee works on more than one Federal award; aFederal award and non-Federal award; an indirect cost activity and a direct costactivity; two or more indirect activities which are allocated using different allocationbases; or an unallowable activity and a direct or indirect cost activity. . . ."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Allowable Costs/Cost Principles compliance requirement.EffectThe failure to establish an effective internal control system enabled material noncompliance to goundetected. Noncompliance with the grant agreement and the Allowable Costs/Cost Principles compliancerequirement could result in the loss of future federal funds to the School Corporation.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish internal controls to ensurecompliance and comply with the grant agreement and the Allowable Costs/Cost Principles compliancerequirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2022-004Subject: Child Nutrition Cluster - Activities Allowed or Unallowed, Reporting, SpecialTests and Provisions - Non-Profit School Food Service AccountsFederal Agency: Department of AgricultureFederal Programs: School Breakfast Program, COVID-19 - School Breakfast Program, NationalSchool Lunch Program, COVID-19 - National School Lunch ProgramAssistance Listings Numbers: 10.553, 10.555Federal Award Numbers and Years (or Other Identifying Numbers): FY2021, FY2022Pass-Through Entity: Indiana Department of EducationCompliance Requirements: Activities Allowed or Unallowed, Reporting, Special Tests andProvisions - Non-Profit School Food Service AccountsAudit Finding: Material WeaknessCondition and ContextAn effective internal control system was not designed nor implemented at the School Corporationto ensure compliance with requirements related to the grant agreement and the Activities Allowed orUnallowed, the Reporting, and the Special Tests and Provisions - Non-Profit School Food Service Accountscompliance requirements.Activities Allowed or UnallowedThe School Corporation had not designed nor implemented a system of internal control overSchool Lunch fund disbursements to ensure all activities were for the benefit of the ChildNutrition Cluster. One employee was responsible for processing disbursements without anoversight or review process in place to prevent, or detect and correct, errors.ReportingThe School Corporation had not designed nor implemented a system of internal control toensure that reimbursement requests were accurately submitted. The reimbursement requestswere prepared by one employee based on meals served without an oversight or review processin place to prevent, or detect and correct, errors.Special Tests and Provisions - Non-Profit School Food Service AccountsThe School Corporation had not designed nor implemented a system of internal controls toensure all revenue generated by the school food service was used to operate and improve itsfood service. One employee was responsible for the receipting and disbursing of School Lunchfunds 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.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."CauseManagement had not developed nor implemented a system of internal controls that would haveensured compliance with the grant agreement and the Activities Allowed or Unallowed, the Reporting, andthe Special Tests and Provisions - Non-Profit School Food Service Accounts compliance requirements.EffectThe failure to establish an effective internal control system could have enabled material noncomplianceto go undetected.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish internal controls to ensurecompliance with the grant agreement and the Activities Allowed or Unallowed, the Reporting, and theSpecial Tests and Provisions - Non-Profit School Food Service Accounts compliance requirements.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2022-003Subject: Child Nutrition Cluster - Allowable Costs/Cost PrinciplesFederal Agency: Department of AgricultureFederal Programs: School Breakfast Program, COVID-19 - School Breakfast Program, NationalSchool Lunch Program, COVID-19 - National School Lunch ProgramAssistance Listings Numbers: 10.553, 10.555Federal Award Numbers and Years (or Other Identifying Numbers): FY2021, FY2022Pass-Through Entity: Indiana Department of EducationCompliance Requirement: Allowable Costs/Cost PrinciplesAudit Findings: Material Weakness, Other MattersCondition and ContextAn effective internal control system was not in place at the School Corporation to ensure compliancewith requirements related to the grant agreement and the Allowable Costs/Cost Principles compliancerequirement.The School Corporation had not developed nor implemented internal controls over transactionspaid from the Child Nutrition Cluster funds to ensure that the payment was an allowable cost for the benefitof the food service program.Additionally, the School Corporation paid food service employees that worked more than 5.25 hoursa day on a biweekly basis with payments that continued into the summer. In order to do this, an employee'spay was annualized based on the expected number of days worked and then divided by 26. Each employeewas required to complete a timesheet every two weeks, which was approved by their supervisor, to supportthe time worked during the school year. Four of the fourteen paychecks selected for testing had errors.Two of the paychecks did not have the required timesheets, and two of the paychecks did not havetimesheets that reflected time worked to adequately support the amount paid to the employee.The lack of internal controls was a systemic issue for all disbursements throughout the audit period.The noncompliance was isolated to payroll disbursements for the school year ended June 30, 2021.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.403 states in part:"Except where otherwise authorized by statute, costs must meet the following general criteriain order to be allowable under Federal awards:(a) Be necessary and reasonable for the performance of the Federal award and be allocablethereto under these principles.(b) Conform to any limitations or exclusions set forth in these principles or in the Federalaward as to types or amount of cost items. . . .(g) Be adequately documented. . . ."2 CFR 200.430(i) states in part:"Standards for Documentation of Personnel Expenses(1) Charges to Federal awards for salaries and wages must be based on records thataccurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonableassurance that the charges are accurate, allowable, and properly allocated;(ii) Be incorporated into the official records of the non-Federal entity;(iii) Reasonably reflect the total activity for which the employee is compensated bythe non-Federal entity, not exceeding 100% of compensated activities . . .(vii) Support the distribution of the employee's salary or wages among specificactivities or cost objectives if the employee works on more than one Federal award; aFederal award and non-Federal award; an indirect cost activity and a direct costactivity; two or more indirect activities which are allocated using different allocationbases; or an unallowable activity and a direct or indirect cost activity. . . ."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Allowable Costs/Cost Principles compliance requirement.EffectThe failure to establish an effective internal control system enabled material noncompliance to goundetected. Noncompliance with the grant agreement and the Allowable Costs/Cost Principles compliancerequirement could result in the loss of future federal funds to the School Corporation.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish internal controls to ensurecompliance and comply with the grant agreement and the Allowable Costs/Cost Principles compliancerequirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2022-004Subject: Child Nutrition Cluster - Activities Allowed or Unallowed, Reporting, SpecialTests and Provisions - Non-Profit School Food Service AccountsFederal Agency: Department of AgricultureFederal Programs: School Breakfast Program, COVID-19 - School Breakfast Program, NationalSchool Lunch Program, COVID-19 - National School Lunch ProgramAssistance Listings Numbers: 10.553, 10.555Federal Award Numbers and Years (or Other Identifying Numbers): FY2021, FY2022Pass-Through Entity: Indiana Department of EducationCompliance Requirements: Activities Allowed or Unallowed, Reporting, Special Tests andProvisions - Non-Profit School Food Service AccountsAudit Finding: Material WeaknessCondition and ContextAn effective internal control system was not designed nor implemented at the School Corporationto ensure compliance with requirements related to the grant agreement and the Activities Allowed orUnallowed, the Reporting, and the Special Tests and Provisions - Non-Profit School Food Service Accountscompliance requirements.Activities Allowed or UnallowedThe School Corporation had not designed nor implemented a system of internal control overSchool Lunch fund disbursements to ensure all activities were for the benefit of the ChildNutrition Cluster. One employee was responsible for processing disbursements without anoversight or review process in place to prevent, or detect and correct, errors.ReportingThe School Corporation had not designed nor implemented a system of internal control toensure that reimbursement requests were accurately submitted. The reimbursement requestswere prepared by one employee based on meals served without an oversight or review processin place to prevent, or detect and correct, errors.Special Tests and Provisions - Non-Profit School Food Service AccountsThe School Corporation had not designed nor implemented a system of internal controls toensure all revenue generated by the school food service was used to operate and improve itsfood service. One employee was responsible for the receipting and disbursing of School Lunchfunds 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.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."CauseManagement had not developed nor implemented a system of internal controls that would haveensured compliance with the grant agreement and the Activities Allowed or Unallowed, the Reporting, andthe Special Tests and Provisions - Non-Profit School Food Service Accounts compliance requirements.EffectThe failure to establish an effective internal control system could have enabled material noncomplianceto go undetected.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish internal controls to ensurecompliance with the grant agreement and the Activities Allowed or Unallowed, the Reporting, and theSpecial Tests and Provisions - Non-Profit School Food Service Accounts compliance requirements.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2022-003Subject: Child Nutrition Cluster - Allowable Costs/Cost PrinciplesFederal Agency: Department of AgricultureFederal Programs: School Breakfast Program, COVID-19 - School Breakfast Program, NationalSchool Lunch Program, COVID-19 - National School Lunch ProgramAssistance Listings Numbers: 10.553, 10.555Federal Award Numbers and Years (or Other Identifying Numbers): FY2021, FY2022Pass-Through Entity: Indiana Department of EducationCompliance Requirement: Allowable Costs/Cost PrinciplesAudit Findings: Material Weakness, Other MattersCondition and ContextAn effective internal control system was not in place at the School Corporation to ensure compliancewith requirements related to the grant agreement and the Allowable Costs/Cost Principles compliancerequirement.The School Corporation had not developed nor implemented internal controls over transactionspaid from the Child Nutrition Cluster funds to ensure that the payment was an allowable cost for the benefitof the food service program.Additionally, the School Corporation paid food service employees that worked more than 5.25 hoursa day on a biweekly basis with payments that continued into the summer. In order to do this, an employee'spay was annualized based on the expected number of days worked and then divided by 26. Each employeewas required to complete a timesheet every two weeks, which was approved by their supervisor, to supportthe time worked during the school year. Four of the fourteen paychecks selected for testing had errors.Two of the paychecks did not have the required timesheets, and two of the paychecks did not havetimesheets that reflected time worked to adequately support the amount paid to the employee.The lack of internal controls was a systemic issue for all disbursements throughout the audit period.The noncompliance was isolated to payroll disbursements for the school year ended June 30, 2021.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.403 states in part:"Except where otherwise authorized by statute, costs must meet the following general criteriain order to be allowable under Federal awards:(a) Be necessary and reasonable for the performance of the Federal award and be allocablethereto under these principles.(b) Conform to any limitations or exclusions set forth in these principles or in the Federalaward as to types or amount of cost items. . . .(g) Be adequately documented. . . ."2 CFR 200.430(i) states in part:"Standards for Documentation of Personnel Expenses(1) Charges to Federal awards for salaries and wages must be based on records thataccurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonableassurance that the charges are accurate, allowable, and properly allocated;(ii) Be incorporated into the official records of the non-Federal entity;(iii) Reasonably reflect the total activity for which the employee is compensated bythe non-Federal entity, not exceeding 100% of compensated activities . . .(vii) Support the distribution of the employee's salary or wages among specificactivities or cost objectives if the employee works on more than one Federal award; aFederal award and non-Federal award; an indirect cost activity and a direct costactivity; two or more indirect activities which are allocated using different allocationbases; or an unallowable activity and a direct or indirect cost activity. . . ."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Allowable Costs/Cost Principles compliance requirement.EffectThe failure to establish an effective internal control system enabled material noncompliance to goundetected. Noncompliance with the grant agreement and the Allowable Costs/Cost Principles compliancerequirement could result in the loss of future federal funds to the School Corporation.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish internal controls to ensurecompliance and comply with the grant agreement and the Allowable Costs/Cost Principles compliancerequirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2022-004Subject: Child Nutrition Cluster - Activities Allowed or Unallowed, Reporting, SpecialTests and Provisions - Non-Profit School Food Service AccountsFederal Agency: Department of AgricultureFederal Programs: School Breakfast Program, COVID-19 - School Breakfast Program, NationalSchool Lunch Program, COVID-19 - National School Lunch ProgramAssistance Listings Numbers: 10.553, 10.555Federal Award Numbers and Years (or Other Identifying Numbers): FY2021, FY2022Pass-Through Entity: Indiana Department of EducationCompliance Requirements: Activities Allowed or Unallowed, Reporting, Special Tests andProvisions - Non-Profit School Food Service AccountsAudit Finding: Material WeaknessCondition and ContextAn effective internal control system was not designed nor implemented at the School Corporationto ensure compliance with requirements related to the grant agreement and the Activities Allowed orUnallowed, the Reporting, and the Special Tests and Provisions - Non-Profit School Food Service Accountscompliance requirements.Activities Allowed or UnallowedThe School Corporation had not designed nor implemented a system of internal control overSchool Lunch fund disbursements to ensure all activities were for the benefit of the ChildNutrition Cluster. One employee was responsible for processing disbursements without anoversight or review process in place to prevent, or detect and correct, errors.ReportingThe School Corporation had not designed nor implemented a system of internal control toensure that reimbursement requests were accurately submitted. The reimbursement requestswere prepared by one employee based on meals served without an oversight or review processin place to prevent, or detect and correct, errors.Special Tests and Provisions - Non-Profit School Food Service AccountsThe School Corporation had not designed nor implemented a system of internal controls toensure all revenue generated by the school food service was used to operate and improve itsfood service. One employee was responsible for the receipting and disbursing of School Lunchfunds 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.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."CauseManagement had not developed nor implemented a system of internal controls that would haveensured compliance with the grant agreement and the Activities Allowed or Unallowed, the Reporting, andthe Special Tests and Provisions - Non-Profit School Food Service Accounts compliance requirements.EffectThe failure to establish an effective internal control system could have enabled material noncomplianceto go undetected.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish internal controls to ensurecompliance with the grant agreement and the Activities Allowed or Unallowed, the Reporting, and theSpecial Tests and Provisions - Non-Profit School Food Service Accounts compliance requirements.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2022-003Subject: Child Nutrition Cluster - Allowable Costs/Cost PrinciplesFederal Agency: Department of AgricultureFederal Programs: School Breakfast Program, COVID-19 - School Breakfast Program, NationalSchool Lunch Program, COVID-19 - National School Lunch ProgramAssistance Listings Numbers: 10.553, 10.555Federal Award Numbers and Years (or Other Identifying Numbers): FY2021, FY2022Pass-Through Entity: Indiana Department of EducationCompliance Requirement: Allowable Costs/Cost PrinciplesAudit Findings: Material Weakness, Other MattersCondition and ContextAn effective internal control system was not in place at the School Corporation to ensure compliancewith requirements related to the grant agreement and the Allowable Costs/Cost Principles compliancerequirement.The School Corporation had not developed nor implemented internal controls over transactionspaid from the Child Nutrition Cluster funds to ensure that the payment was an allowable cost for the benefitof the food service program.Additionally, the School Corporation paid food service employees that worked more than 5.25 hoursa day on a biweekly basis with payments that continued into the summer. In order to do this, an employee'spay was annualized based on the expected number of days worked and then divided by 26. Each employeewas required to complete a timesheet every two weeks, which was approved by their supervisor, to supportthe time worked during the school year. Four of the fourteen paychecks selected for testing had errors.Two of the paychecks did not have the required timesheets, and two of the paychecks did not havetimesheets that reflected time worked to adequately support the amount paid to the employee.The lack of internal controls was a systemic issue for all disbursements throughout the audit period.The noncompliance was isolated to payroll disbursements for the school year ended June 30, 2021.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.403 states in part:"Except where otherwise authorized by statute, costs must meet the following general criteriain order to be allowable under Federal awards:(a) Be necessary and reasonable for the performance of the Federal award and be allocablethereto under these principles.(b) Conform to any limitations or exclusions set forth in these principles or in the Federalaward as to types or amount of cost items. . . .(g) Be adequately documented. . . ."2 CFR 200.430(i) states in part:"Standards for Documentation of Personnel Expenses(1) Charges to Federal awards for salaries and wages must be based on records thataccurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonableassurance that the charges are accurate, allowable, and properly allocated;(ii) Be incorporated into the official records of the non-Federal entity;(iii) Reasonably reflect the total activity for which the employee is compensated bythe non-Federal entity, not exceeding 100% of compensated activities . . .(vii) Support the distribution of the employee's salary or wages among specificactivities or cost objectives if the employee works on more than one Federal award; aFederal award and non-Federal award; an indirect cost activity and a direct costactivity; two or more indirect activities which are allocated using different allocationbases; or an unallowable activity and a direct or indirect cost activity. . . ."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Allowable Costs/Cost Principles compliance requirement.EffectThe failure to establish an effective internal control system enabled material noncompliance to goundetected. Noncompliance with the grant agreement and the Allowable Costs/Cost Principles compliancerequirement could result in the loss of future federal funds to the School Corporation.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish internal controls to ensurecompliance and comply with the grant agreement and the Allowable Costs/Cost Principles compliancerequirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2022-004Subject: Child Nutrition Cluster - Activities Allowed or Unallowed, Reporting, SpecialTests and Provisions - Non-Profit School Food Service AccountsFederal Agency: Department of AgricultureFederal Programs: School Breakfast Program, COVID-19 - School Breakfast Program, NationalSchool Lunch Program, COVID-19 - National School Lunch ProgramAssistance Listings Numbers: 10.553, 10.555Federal Award Numbers and Years (or Other Identifying Numbers): FY2021, FY2022Pass-Through Entity: Indiana Department of EducationCompliance Requirements: Activities Allowed or Unallowed, Reporting, Special Tests andProvisions - Non-Profit School Food Service AccountsAudit Finding: Material WeaknessCondition and ContextAn effective internal control system was not designed nor implemented at the School Corporationto ensure compliance with requirements related to the grant agreement and the Activities Allowed orUnallowed, the Reporting, and the Special Tests and Provisions - Non-Profit School Food Service Accountscompliance requirements.Activities Allowed or UnallowedThe School Corporation had not designed nor implemented a system of internal control overSchool Lunch fund disbursements to ensure all activities were for the benefit of the ChildNutrition Cluster. One employee was responsible for processing disbursements without anoversight or review process in place to prevent, or detect and correct, errors.ReportingThe School Corporation had not designed nor implemented a system of internal control toensure that reimbursement requests were accurately submitted. The reimbursement requestswere prepared by one employee based on meals served without an oversight or review processin place to prevent, or detect and correct, errors.Special Tests and Provisions - Non-Profit School Food Service AccountsThe School Corporation had not designed nor implemented a system of internal controls toensure all revenue generated by the school food service was used to operate and improve itsfood service. One employee was responsible for the receipting and disbursing of School Lunchfunds 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.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."CauseManagement had not developed nor implemented a system of internal controls that would haveensured compliance with the grant agreement and the Activities Allowed or Unallowed, the Reporting, andthe Special Tests and Provisions - Non-Profit School Food Service Accounts compliance requirements.EffectThe failure to establish an effective internal control system could have enabled material noncomplianceto go undetected.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish internal controls to ensurecompliance with the grant agreement and the Activities Allowed or Unallowed, the Reporting, and theSpecial Tests and Provisions - Non-Profit School Food Service Accounts compliance requirements.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2022-003Subject: Child Nutrition Cluster - Allowable Costs/Cost PrinciplesFederal Agency: Department of AgricultureFederal Programs: School Breakfast Program, COVID-19 - School Breakfast Program, NationalSchool Lunch Program, COVID-19 - National School Lunch ProgramAssistance Listings Numbers: 10.553, 10.555Federal Award Numbers and Years (or Other Identifying Numbers): FY2021, FY2022Pass-Through Entity: Indiana Department of EducationCompliance Requirement: Allowable Costs/Cost PrinciplesAudit Findings: Material Weakness, Other MattersCondition and ContextAn effective internal control system was not in place at the School Corporation to ensure compliancewith requirements related to the grant agreement and the Allowable Costs/Cost Principles compliancerequirement.The School Corporation had not developed nor implemented internal controls over transactionspaid from the Child Nutrition Cluster funds to ensure that the payment was an allowable cost for the benefitof the food service program.Additionally, the School Corporation paid food service employees that worked more than 5.25 hoursa day on a biweekly basis with payments that continued into the summer. In order to do this, an employee'spay was annualized based on the expected number of days worked and then divided by 26. Each employeewas required to complete a timesheet every two weeks, which was approved by their supervisor, to supportthe time worked during the school year. Four of the fourteen paychecks selected for testing had errors.Two of the paychecks did not have the required timesheets, and two of the paychecks did not havetimesheets that reflected time worked to adequately support the amount paid to the employee.The lack of internal controls was a systemic issue for all disbursements throughout the audit period.The noncompliance was isolated to payroll disbursements for the school year ended June 30, 2021.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.403 states in part:"Except where otherwise authorized by statute, costs must meet the following general criteriain order to be allowable under Federal awards:(a) Be necessary and reasonable for the performance of the Federal award and be allocablethereto under these principles.(b) Conform to any limitations or exclusions set forth in these principles or in the Federalaward as to types or amount of cost items. . . .(g) Be adequately documented. . . ."2 CFR 200.430(i) states in part:"Standards for Documentation of Personnel Expenses(1) Charges to Federal awards for salaries and wages must be based on records thataccurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonableassurance that the charges are accurate, allowable, and properly allocated;(ii) Be incorporated into the official records of the non-Federal entity;(iii) Reasonably reflect the total activity for which the employee is compensated bythe non-Federal entity, not exceeding 100% of compensated activities . . .(vii) Support the distribution of the employee's salary or wages among specificactivities or cost objectives if the employee works on more than one Federal award; aFederal award and non-Federal award; an indirect cost activity and a direct costactivity; two or more indirect activities which are allocated using different allocationbases; or an unallowable activity and a direct or indirect cost activity. . . ."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Allowable Costs/Cost Principles compliance requirement.EffectThe failure to establish an effective internal control system enabled material noncompliance to goundetected. Noncompliance with the grant agreement and the Allowable Costs/Cost Principles compliancerequirement could result in the loss of future federal funds to the School Corporation.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish internal controls to ensurecompliance and comply with the grant agreement and the Allowable Costs/Cost Principles compliancerequirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2022-004Subject: Child Nutrition Cluster - Activities Allowed or Unallowed, Reporting, SpecialTests and Provisions - Non-Profit School Food Service AccountsFederal Agency: Department of AgricultureFederal Programs: School Breakfast Program, COVID-19 - School Breakfast Program, NationalSchool Lunch Program, COVID-19 - National School Lunch ProgramAssistance Listings Numbers: 10.553, 10.555Federal Award Numbers and Years (or Other Identifying Numbers): FY2021, FY2022Pass-Through Entity: Indiana Department of EducationCompliance Requirements: Activities Allowed or Unallowed, Reporting, Special Tests andProvisions - Non-Profit School Food Service AccountsAudit Finding: Material WeaknessCondition and ContextAn effective internal control system was not designed nor implemented at the School Corporationto ensure compliance with requirements related to the grant agreement and the Activities Allowed orUnallowed, the Reporting, and the Special Tests and Provisions - Non-Profit School Food Service Accountscompliance requirements.Activities Allowed or UnallowedThe School Corporation had not designed nor implemented a system of internal control overSchool Lunch fund disbursements to ensure all activities were for the benefit of the ChildNutrition Cluster. One employee was responsible for processing disbursements without anoversight or review process in place to prevent, or detect and correct, errors.ReportingThe School Corporation had not designed nor implemented a system of internal control toensure that reimbursement requests were accurately submitted. The reimbursement requestswere prepared by one employee based on meals served without an oversight or review processin place to prevent, or detect and correct, errors.Special Tests and Provisions - Non-Profit School Food Service AccountsThe School Corporation had not designed nor implemented a system of internal controls toensure all revenue generated by the school food service was used to operate and improve itsfood service. One employee was responsible for the receipting and disbursing of School Lunchfunds 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.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."CauseManagement had not developed nor implemented a system of internal controls that would haveensured compliance with the grant agreement and the Activities Allowed or Unallowed, the Reporting, andthe Special Tests and Provisions - Non-Profit School Food Service Accounts compliance requirements.EffectThe failure to establish an effective internal control system could have enabled material noncomplianceto go undetected.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish internal controls to ensurecompliance with the grant agreement and the Activities Allowed or Unallowed, the Reporting, and theSpecial Tests and Provisions - Non-Profit School Food Service Accounts compliance requirements.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2022-003Subject: Child Nutrition Cluster - Allowable Costs/Cost PrinciplesFederal Agency: Department of AgricultureFederal Programs: School Breakfast Program, COVID-19 - School Breakfast Program, NationalSchool Lunch Program, COVID-19 - National School Lunch ProgramAssistance Listings Numbers: 10.553, 10.555Federal Award Numbers and Years (or Other Identifying Numbers): FY2021, FY2022Pass-Through Entity: Indiana Department of EducationCompliance Requirement: Allowable Costs/Cost PrinciplesAudit Findings: Material Weakness, Other MattersCondition and ContextAn effective internal control system was not in place at the School Corporation to ensure compliancewith requirements related to the grant agreement and the Allowable Costs/Cost Principles compliancerequirement.The School Corporation had not developed nor implemented internal controls over transactionspaid from the Child Nutrition Cluster funds to ensure that the payment was an allowable cost for the benefitof the food service program.Additionally, the School Corporation paid food service employees that worked more than 5.25 hoursa day on a biweekly basis with payments that continued into the summer. In order to do this, an employee'spay was annualized based on the expected number of days worked and then divided by 26. Each employeewas required to complete a timesheet every two weeks, which was approved by their supervisor, to supportthe time worked during the school year. Four of the fourteen paychecks selected for testing had errors.Two of the paychecks did not have the required timesheets, and two of the paychecks did not havetimesheets that reflected time worked to adequately support the amount paid to the employee.The lack of internal controls was a systemic issue for all disbursements throughout the audit period.The noncompliance was isolated to payroll disbursements for the school year ended June 30, 2021.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.403 states in part:"Except where otherwise authorized by statute, costs must meet the following general criteriain order to be allowable under Federal awards:(a) Be necessary and reasonable for the performance of the Federal award and be allocablethereto under these principles.(b) Conform to any limitations or exclusions set forth in these principles or in the Federalaward as to types or amount of cost items. . . .(g) Be adequately documented. . . ."2 CFR 200.430(i) states in part:"Standards for Documentation of Personnel Expenses(1) Charges to Federal awards for salaries and wages must be based on records thataccurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonableassurance that the charges are accurate, allowable, and properly allocated;(ii) Be incorporated into the official records of the non-Federal entity;(iii) Reasonably reflect the total activity for which the employee is compensated bythe non-Federal entity, not exceeding 100% of compensated activities . . .(vii) Support the distribution of the employee's salary or wages among specificactivities or cost objectives if the employee works on more than one Federal award; aFederal award and non-Federal award; an indirect cost activity and a direct costactivity; two or more indirect activities which are allocated using different allocationbases; or an unallowable activity and a direct or indirect cost activity. . . ."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Allowable Costs/Cost Principles compliance requirement.EffectThe failure to establish an effective internal control system enabled material noncompliance to goundetected. Noncompliance with the grant agreement and the Allowable Costs/Cost Principles compliancerequirement could result in the loss of future federal funds to the School Corporation.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish internal controls to ensurecompliance and comply with the grant agreement and the Allowable Costs/Cost Principles compliancerequirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2022-004Subject: Child Nutrition Cluster - Activities Allowed or Unallowed, Reporting, SpecialTests and Provisions - Non-Profit School Food Service AccountsFederal Agency: Department of AgricultureFederal Programs: School Breakfast Program, COVID-19 - School Breakfast Program, NationalSchool Lunch Program, COVID-19 - National School Lunch ProgramAssistance Listings Numbers: 10.553, 10.555Federal Award Numbers and Years (or Other Identifying Numbers): FY2021, FY2022Pass-Through Entity: Indiana Department of EducationCompliance Requirements: Activities Allowed or Unallowed, Reporting, Special Tests andProvisions - Non-Profit School Food Service AccountsAudit Finding: Material WeaknessCondition and ContextAn effective internal control system was not designed nor implemented at the School Corporationto ensure compliance with requirements related to the grant agreement and the Activities Allowed orUnallowed, the Reporting, and the Special Tests and Provisions - Non-Profit School Food Service Accountscompliance requirements.Activities Allowed or UnallowedThe School Corporation had not designed nor implemented a system of internal control overSchool Lunch fund disbursements to ensure all activities were for the benefit of the ChildNutrition Cluster. One employee was responsible for processing disbursements without anoversight or review process in place to prevent, or detect and correct, errors.ReportingThe School Corporation had not designed nor implemented a system of internal control toensure that reimbursement requests were accurately submitted. The reimbursement requestswere prepared by one employee based on meals served without an oversight or review processin place to prevent, or detect and correct, errors.Special Tests and Provisions - Non-Profit School Food Service AccountsThe School Corporation had not designed nor implemented a system of internal controls toensure all revenue generated by the school food service was used to operate and improve itsfood service. One employee was responsible for the receipting and disbursing of School Lunchfunds 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.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."CauseManagement had not developed nor implemented a system of internal controls that would haveensured compliance with the grant agreement and the Activities Allowed or Unallowed, the Reporting, andthe Special Tests and Provisions - Non-Profit School Food Service Accounts compliance requirements.EffectThe failure to establish an effective internal control system could have enabled material noncomplianceto go undetected.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish internal controls to ensurecompliance with the grant agreement and the Activities Allowed or Unallowed, the Reporting, and theSpecial Tests and Provisions - Non-Profit School Food Service Accounts compliance requirements.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2022-007Subject: COVID-19 - Education Stabilization Fund - ReportingFederal Agency: Department of EducationFederal Program: COVID-19 - Education Stabilization FundAssistance Listings Numbers: 84.425C, 84.425D, 84.425UFederal Award Numbers and Years (or Other Identifying Numbers): S425C200018, S425D200013,S425U210013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: ReportingAudit Finding: Material WeaknessCondition and ContextAn effective internal control system, was not designed nor implemented at the School Corporationto ensure compliance with requirements related to the grant agreement and the Reporting compliancerequirement.The School Corporation had not designed nor implemented a system of internal controls to ensurethat the annual Elementary and Secondary School Emergency Relief (ESSER) and the Governor'sEmergency Education Relief (GEER) annual Data Collection reports (Reports) were complete and accuratelysubmitted. The Reports were prepared by one employee without an oversight or review processin place to prevent, or detect and correct, errors.The lack of internal controls was a systemic issue throughout the audit period.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."CauseManagement had not developed nor implemented an effective internal control system that wouldhave ensured compliance with the grant agreement and the Reporting compliance requirement.EffectThe failure to establish an effective internal control system could have enabled material noncomplianceto go undetected.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish internal controls to ensurecompliance with the grant agreement and the Reporting compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2022-007Subject: COVID-19 - Education Stabilization Fund - ReportingFederal Agency: Department of EducationFederal Program: COVID-19 - Education Stabilization FundAssistance Listings Numbers: 84.425C, 84.425D, 84.425UFederal Award Numbers and Years (or Other Identifying Numbers): S425C200018, S425D200013,S425U210013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: ReportingAudit Finding: Material WeaknessCondition and ContextAn effective internal control system, was not designed nor implemented at the School Corporationto ensure compliance with requirements related to the grant agreement and the Reporting compliancerequirement.The School Corporation had not designed nor implemented a system of internal controls to ensurethat the annual Elementary and Secondary School Emergency Relief (ESSER) and the Governor'sEmergency Education Relief (GEER) annual Data Collection reports (Reports) were complete and accuratelysubmitted. The Reports were prepared by one employee without an oversight or review processin place to prevent, or detect and correct, errors.The lack of internal controls was a systemic issue throughout the audit period.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."CauseManagement had not developed nor implemented an effective internal control system that wouldhave ensured compliance with the grant agreement and the Reporting compliance requirement.EffectThe failure to establish an effective internal control system could have enabled material noncomplianceto go undetected.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish internal controls to ensurecompliance with the grant agreement and the Reporting compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2022-005Subject: COVID-19 - Education Stabilization Fund - Allowable Costs/Cost PrinciplesFederal Agency: Department of EducationFederal Program: COVID-19 - Education Stabilization FundAssistance Listings Numbers: 84.425D, 84.425UFederal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425U210013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: Allowable Costs/Cost PrinciplesAudit Findings: Material Weakness, Modified OpinionCondition and ContextAn effective internal control system was not in place at the School Corporation in order to ensurecompliance with requirements related to the grant agreement and the Allowable Costs/Cost Principlescompliance requirement.The School Corporation did not have adequate internal controls in place to ensure that the reimbursementrequests included salaries for all contracted employees and adequate supporting documentationor personnel activity reports, such as time and effort logs or Semi-Annual Certifications. The SchoolCorporation paid salaries for all contracted employees without adequate supporting documentation orpersonnel activity reports, such as time and effort logs or Semi-Annual Certifications. The total amountpaid to contracted employees was $51,644. This amount was considered questioned costs.The lack of internal controls and noncompliance were systemic issues throughout the audit period.CriteriaCFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.430(i) states in part:"Standards for Documentation of Personnel Expenses(1) Charges to Federal awards for salaries and wages must be based on records thataccurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonableassurance that the charges are accurate, allowable, and properly allocated;(ii) Be incorporated into the official records of the non-Federal entity;(iii) Reasonably reflect the total activity for which the employee is compensated bythe non-Federal entity, not exceeding 100% of compensated activities . . .(vii) Support the distribution of the employee's salary or wages among specificactivities or cost objectives if the employee works on more than one Federal award; aFederal award and non-Federal award; an indirect cost activity and a direct costactivity; two or more indirect activities which are allocated using different allocationbases; or an unallowable activity and a direct or indirect cost activity. . . ."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Allowable Costs/Cost Principles compliance requirement.EffectThe failure to establish an effective internal control system enabled material noncompliance to goundetected. Noncompliance with the grant agreement and the Allowable Costs/Cost Principles compliancerequirement could have resulted in the loss of federal funds to the School Corporation.Questioned CostsQuestioned costs of $51,644 were identified, as described in the Condition and Context.RecommendationWe recommended that the School Corporation's management establish a system of internal controlsto ensure compliance and comply with the grant agreement and the Allowable Costs/Cost Principlescompliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2022-006Subject: COVID-19 - Education Stabilization Fund - Equipment and Real Property ManagementFederal Agency: Department of EducationFederal Program: COVID-19 - Education Stabilization FundAssistance Listings Number: 84.425DFederal Award Number and Year (or Other Identifying Number): S425D200013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: Equipment and Real Property ManagementAudit Findings: Material Weakness, Modified OpinionCondition and ContextAn effective internal control system was not in place at the School Corporation to ensure compliancewith requirements related to the grant agreement and the Equipment and Real Property Managementcompliance requirement.The School Corporation purchased $72,425 of various equipment with Elementary and SecondarySchool Emergency Relief (ESSER) funds. The equipment was not added to the property record whichwould include a description of the property, a serial number or other identification number, the source offunding for the property (including the federal award identification number (FAIN)), who holds title, theacquisition date, cost of the property, percentage of federal participation in the project costs for the federalaward under which the property was acquired, the location, and the use and condition of the property.Additionally, the School Corporation did not adequately safeguard the equipment purchased and had notcompleted a physical inventory of equipment within the last two years.The lack of internal controls and noncompliance were systemic issues throughout the audit period.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.313(d) states in part:"(1) Property records must be maintained that include a description of the property, a serialnumber or other identification number, the source of funding for the property (includingthe FAIN), who holds title, the acquisition date, and cost of the property, percentage offederal participation in the project costs for the federal award under which the propertywas acquired, the location, use and condition of the property, and any ultimate dispositiondata including the date of disposal and sales price of the property(2) A physical inventory of the property must be taken and the results reconciled with theproperty 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. . . ."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the grant agreement and the Equipment and Real Property compliance requirement.EffectThe failure to establish an effective internal control system enabled material noncompliance to goundetected. Noncompliance with the grant agreement and the Equipment and Real Property Managementcompliance requirement could have resulted in the loss of future federal funds to the School Corporation.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish a system of internal controlsto ensure compliance and comply with the grant agreement and the Equipment and Real PropertyManagement compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2022-007Subject: COVID-19 - Education Stabilization Fund - ReportingFederal Agency: Department of EducationFederal Program: COVID-19 - Education Stabilization FundAssistance Listings Numbers: 84.425C, 84.425D, 84.425UFederal Award Numbers and Years (or Other Identifying Numbers): S425C200018, S425D200013,S425U210013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: ReportingAudit Finding: Material WeaknessCondition and ContextAn effective internal control system, was not designed nor implemented at the School Corporationto ensure compliance with requirements related to the grant agreement and the Reporting compliancerequirement.The School Corporation had not designed nor implemented a system of internal controls to ensurethat the annual Elementary and Secondary School Emergency Relief (ESSER) and the Governor'sEmergency Education Relief (GEER) annual Data Collection reports (Reports) were complete and accuratelysubmitted. The Reports were prepared by one employee without an oversight or review processin place to prevent, or detect and correct, errors.The lack of internal controls was a systemic issue throughout the audit period.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."CauseManagement had not developed nor implemented an effective internal control system that wouldhave ensured compliance with the grant agreement and the Reporting compliance requirement.EffectThe failure to establish an effective internal control system could have enabled material noncomplianceto go undetected.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish internal controls to ensurecompliance with the grant agreement and the Reporting compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2022-005Subject: COVID-19 - Education Stabilization Fund - Allowable Costs/Cost PrinciplesFederal Agency: Department of EducationFederal Program: COVID-19 - Education Stabilization FundAssistance Listings Numbers: 84.425D, 84.425UFederal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425U210013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: Allowable Costs/Cost PrinciplesAudit Findings: Material Weakness, Modified OpinionCondition and ContextAn effective internal control system was not in place at the School Corporation in order to ensurecompliance with requirements related to the grant agreement and the Allowable Costs/Cost Principlescompliance requirement.The School Corporation did not have adequate internal controls in place to ensure that the reimbursementrequests included salaries for all contracted employees and adequate supporting documentationor personnel activity reports, such as time and effort logs or Semi-Annual Certifications. The SchoolCorporation paid salaries for all contracted employees without adequate supporting documentation orpersonnel activity reports, such as time and effort logs or Semi-Annual Certifications. The total amountpaid to contracted employees was $51,644. This amount was considered questioned costs.The lack of internal controls and noncompliance were systemic issues throughout the audit period.CriteriaCFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.430(i) states in part:"Standards for Documentation of Personnel Expenses(1) Charges to Federal awards for salaries and wages must be based on records thataccurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonableassurance that the charges are accurate, allowable, and properly allocated;(ii) Be incorporated into the official records of the non-Federal entity;(iii) Reasonably reflect the total activity for which the employee is compensated bythe non-Federal entity, not exceeding 100% of compensated activities . . .(vii) Support the distribution of the employee's salary or wages among specificactivities or cost objectives if the employee works on more than one Federal award; aFederal award and non-Federal award; an indirect cost activity and a direct costactivity; two or more indirect activities which are allocated using different allocationbases; or an unallowable activity and a direct or indirect cost activity. . . ."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Allowable Costs/Cost Principles compliance requirement.EffectThe failure to establish an effective internal control system enabled material noncompliance to goundetected. Noncompliance with the grant agreement and the Allowable Costs/Cost Principles compliancerequirement could have resulted in the loss of federal funds to the School Corporation.Questioned CostsQuestioned costs of $51,644 were identified, as described in the Condition and Context.RecommendationWe recommended that the School Corporation's management establish a system of internal controlsto ensure compliance and comply with the grant agreement and the Allowable Costs/Cost Principlescompliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2022-005Subject: COVID-19 - Education Stabilization Fund - Allowable Costs/Cost PrinciplesFederal Agency: Department of EducationFederal Program: COVID-19 - Education Stabilization FundAssistance Listings Numbers: 84.425D, 84.425UFederal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425U210013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: Allowable Costs/Cost PrinciplesAudit Findings: Material Weakness, Modified OpinionCondition and ContextAn effective internal control system was not in place at the School Corporation in order to ensurecompliance with requirements related to the grant agreement and the Allowable Costs/Cost Principlescompliance requirement.The School Corporation did not have adequate internal controls in place to ensure that the reimbursementrequests included salaries for all contracted employees and adequate supporting documentationor personnel activity reports, such as time and effort logs or Semi-Annual Certifications. The SchoolCorporation paid salaries for all contracted employees without adequate supporting documentation orpersonnel activity reports, such as time and effort logs or Semi-Annual Certifications. The total amountpaid to contracted employees was $51,644. This amount was considered questioned costs.The lack of internal controls and noncompliance were systemic issues throughout the audit period.CriteriaCFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.430(i) states in part:"Standards for Documentation of Personnel Expenses(1) Charges to Federal awards for salaries and wages must be based on records thataccurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonableassurance that the charges are accurate, allowable, and properly allocated;(ii) Be incorporated into the official records of the non-Federal entity;(iii) Reasonably reflect the total activity for which the employee is compensated bythe non-Federal entity, not exceeding 100% of compensated activities . . .(vii) Support the distribution of the employee's salary or wages among specificactivities or cost objectives if the employee works on more than one Federal award; aFederal award and non-Federal award; an indirect cost activity and a direct costactivity; two or more indirect activities which are allocated using different allocationbases; or an unallowable activity and a direct or indirect cost activity. . . ."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Allowable Costs/Cost Principles compliance requirement.EffectThe failure to establish an effective internal control system enabled material noncompliance to goundetected. Noncompliance with the grant agreement and the Allowable Costs/Cost Principles compliancerequirement could have resulted in the loss of federal funds to the School Corporation.Questioned CostsQuestioned costs of $51,644 were identified, as described in the Condition and Context.RecommendationWe recommended that the School Corporation's management establish a system of internal controlsto ensure compliance and comply with the grant agreement and the Allowable Costs/Cost Principlescompliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2022-007Subject: COVID-19 - Education Stabilization Fund - ReportingFederal Agency: Department of EducationFederal Program: COVID-19 - Education Stabilization FundAssistance Listings Numbers: 84.425C, 84.425D, 84.425UFederal Award Numbers and Years (or Other Identifying Numbers): S425C200018, S425D200013,S425U210013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: ReportingAudit Finding: Material WeaknessCondition and ContextAn effective internal control system, was not designed nor implemented at the School Corporationto ensure compliance with requirements related to the grant agreement and the Reporting compliancerequirement.The School Corporation had not designed nor implemented a system of internal controls to ensurethat the annual Elementary and Secondary School Emergency Relief (ESSER) and the Governor'sEmergency Education Relief (GEER) annual Data Collection reports (Reports) were complete and accuratelysubmitted. The Reports were prepared by one employee without an oversight or review processin place to prevent, or detect and correct, errors.The lack of internal controls was a systemic issue throughout the audit period.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."CauseManagement had not developed nor implemented an effective internal control system that wouldhave ensured compliance with the grant agreement and the Reporting compliance requirement.EffectThe failure to establish an effective internal control system could have enabled material noncomplianceto go undetected.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish internal controls to ensurecompliance with the grant agreement and the Reporting compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2022-007Subject: COVID-19 - Education Stabilization Fund - ReportingFederal Agency: Department of EducationFederal Program: COVID-19 - Education Stabilization FundAssistance Listings Numbers: 84.425C, 84.425D, 84.425UFederal Award Numbers and Years (or Other Identifying Numbers): S425C200018, S425D200013,S425U210013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: ReportingAudit Finding: Material WeaknessCondition and ContextAn effective internal control system, was not designed nor implemented at the School Corporationto ensure compliance with requirements related to the grant agreement and the Reporting compliancerequirement.The School Corporation had not designed nor implemented a system of internal controls to ensurethat the annual Elementary and Secondary School Emergency Relief (ESSER) and the Governor'sEmergency Education Relief (GEER) annual Data Collection reports (Reports) were complete and accuratelysubmitted. The Reports were prepared by one employee without an oversight or review processin place to prevent, or detect and correct, errors.The lack of internal controls was a systemic issue throughout the audit period.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."CauseManagement had not developed nor implemented an effective internal control system that wouldhave ensured compliance with the grant agreement and the Reporting compliance requirement.EffectThe failure to establish an effective internal control system could have enabled material noncomplianceto go undetected.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish internal controls to ensurecompliance with the grant agreement and the Reporting compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.