FA 2023-001 Strengthen Controls over Special Reporting
Compliance Requirement: Reporting
Internal Control Impact: Significant Deficiency
Compliance Impact: Nonmaterial Noncompliance
Federal Awarding Agency: U.S. Department of Agriculture
Pass-Through Entity: Georgia Department of Education
AL Numbers and Titles: 10.553 – School Breakfast Program
10.555 – National School Lunch Program
Federal Award Number: 235GA324N1199 (Year: 2023) 225GA324N1099 (Year: 2023)
Questioned Costs: None Identified
Repeat of Prior Year Finding: FA 2022-001
Description:
The policies and procedures of the School District were insufficient to provide adequate internal controls over the monthly Claims for Reimbursement process.
Background:
The Child Nutrition Cluster (CNC) is comprised of various programs that are intended to assist states in administering and overseeing food service program operators that provide healthful, nutritious meals to eligible children in public and non-profit private schools, residential child care institutions, and summer programs. This Cluster of programs also fosters healthy eating habits in children by providing fresh fruits and fresh vegetables to children attending elementary and secondary schools and encourages the domestic consumption of nutritious agricultural commodities.
CNC funding is granted to the Georgia Department of Education (GaDOE) by the U.S. Department of
Agriculture. GaDOE is responsible for distributing funds to local educational agencies (LEAs) based
upon each School District’s monthly Form DE0106 Claim Data report submissions. These DE0106
reports are to be supported by the corresponding Form DE0112 Daily Record of Number of Breakfasts Served and Form DE0118 Daily Record of Number of Lunches Served, which are prepared by the School District from their School Food Service meal sales system.
Criteria:
As a recipient of federal awards, the School District is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 – Internal Controls.
Provisions included in Title 7 CFR Section 210.7(c) require that the School District "base Claims for Reimbursement on lunch counts, taken daily at the point of service, which correctly identify the number of free, reduced price and paid lunches served to eligible children" and "correctly record, consolidate and report those lunch and supplement counts on the Claim for Reimbursement."
In addition, provisions included in Title 7 CFR Section 220.11(d) state that the School District "shall establish internal controls which ensure the accuracy of breakfast counts prior to the submission of the monthly Claim for Reimbursement.”
Condition:
A sample of four months during the standard school year in which a DE-0112, DE-0118, DE-0106 and DE-0107 should have been filed was randomly selected for testing using a non-statistical sampling approach. Additionally, the Form DE0106 reports for the months of July 2022 and June 2023 were selected for testing. These reports were reviewed to determine if appropriate internal controls were implemented and applicable reporting compliance requirements were met. The following deficiencies were noted:
• No Form DE0112 or DE0118 reports were prepared during the period under review.
• Daily meal count sheets maintained by the schools did not reflect evidence of review and approval by lunchroom managers in eight instances, including four breakfast and four lunch counts.
Cause:
In discussing these deficiencies with management, the School District believed completion of DE0112 and DE0018 was not a requirement due to the election of Seamless Summer Option. As a result, the School District did not follow its policies and procedures that govern the reporting process for federal programs.
Effect:
The School District is not in compliance with the Uniform Guidance and GaDOE guidance. Failure to submit accurate monthly Claims for Reimbursement to GaDOE can result in the School District obtaining less federal funding than they are eligible to receive. This deficiency may expose the School District to unnecessary financial strains and shortages within the CNC fund.
Recommendation:
The School District should evaluate their internal control processes regarding the preparation of the Form DE0112 or DE0118 reports and develop or modify procedures to ensure Claims for Reimbursement are based on final and accurate meals counts. The School District should become more familiar with the Federal regulations related to the CNC programs in order to develop or modify internal control procedures that will ensure accurate reporting of meals served. Furthermore, management should develop and implement a monitoring process to ensure that controls are functioning properly.
Views of Responsible Officials:
We concur with this finding.
FA 2023-001 Strengthen Controls over Special Reporting
Compliance Requirement: Reporting
Internal Control Impact: Significant Deficiency
Compliance Impact: Nonmaterial Noncompliance
Federal Awarding Agency: U.S. Department of Agriculture
Pass-Through Entity: Georgia Department of Education
AL Numbers and Titles: 10.553 – School Breakfast Program
10.555 – National School Lunch Program
Federal Award Number: 235GA324N1199 (Year: 2023) 225GA324N1099 (Year: 2023)
Questioned Costs: None Identified
Repeat of Prior Year Finding: FA 2022-001
Description:
The policies and procedures of the School District were insufficient to provide adequate internal controls over the monthly Claims for Reimbursement process.
Background:
The Child Nutrition Cluster (CNC) is comprised of various programs that are intended to assist states in administering and overseeing food service program operators that provide healthful, nutritious meals to eligible children in public and non-profit private schools, residential child care institutions, and summer programs. This Cluster of programs also fosters healthy eating habits in children by providing fresh fruits and fresh vegetables to children attending elementary and secondary schools and encourages the domestic consumption of nutritious agricultural commodities.
CNC funding is granted to the Georgia Department of Education (GaDOE) by the U.S. Department of
Agriculture. GaDOE is responsible for distributing funds to local educational agencies (LEAs) based
upon each School District’s monthly Form DE0106 Claim Data report submissions. These DE0106
reports are to be supported by the corresponding Form DE0112 Daily Record of Number of Breakfasts Served and Form DE0118 Daily Record of Number of Lunches Served, which are prepared by the School District from their School Food Service meal sales system.
Criteria:
As a recipient of federal awards, the School District is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 – Internal Controls.
Provisions included in Title 7 CFR Section 210.7(c) require that the School District "base Claims for Reimbursement on lunch counts, taken daily at the point of service, which correctly identify the number of free, reduced price and paid lunches served to eligible children" and "correctly record, consolidate and report those lunch and supplement counts on the Claim for Reimbursement."
In addition, provisions included in Title 7 CFR Section 220.11(d) state that the School District "shall establish internal controls which ensure the accuracy of breakfast counts prior to the submission of the monthly Claim for Reimbursement.”
Condition:
A sample of four months during the standard school year in which a DE-0112, DE-0118, DE-0106 and DE-0107 should have been filed was randomly selected for testing using a non-statistical sampling approach. Additionally, the Form DE0106 reports for the months of July 2022 and June 2023 were selected for testing. These reports were reviewed to determine if appropriate internal controls were implemented and applicable reporting compliance requirements were met. The following deficiencies were noted:
• No Form DE0112 or DE0118 reports were prepared during the period under review.
• Daily meal count sheets maintained by the schools did not reflect evidence of review and approval by lunchroom managers in eight instances, including four breakfast and four lunch counts.
Cause:
In discussing these deficiencies with management, the School District believed completion of DE0112 and DE0018 was not a requirement due to the election of Seamless Summer Option. As a result, the School District did not follow its policies and procedures that govern the reporting process for federal programs.
Effect:
The School District is not in compliance with the Uniform Guidance and GaDOE guidance. Failure to submit accurate monthly Claims for Reimbursement to GaDOE can result in the School District obtaining less federal funding than they are eligible to receive. This deficiency may expose the School District to unnecessary financial strains and shortages within the CNC fund.
Recommendation:
The School District should evaluate their internal control processes regarding the preparation of the Form DE0112 or DE0118 reports and develop or modify procedures to ensure Claims for Reimbursement are based on final and accurate meals counts. The School District should become more familiar with the Federal regulations related to the CNC programs in order to develop or modify internal control procedures that will ensure accurate reporting of meals served. Furthermore, management should develop and implement a monitoring process to ensure that controls are functioning properly.
Views of Responsible Officials:
We concur with this finding.
FA 2023-002 Improve Controls over Suspension and Debarment
Compliance Requirement: Procurement and Suspension and Debarment
Internal Control Impact: Significant Deficiency
Compliance Impact: Nonmaterial Noncompliance
Federal Awarding Agency: U.S. Department of Agriculture
Pass-Through Entity: Georgia Department of Education
AL Numbers and Titles: 10.553 – School Breakfast Program
10.555 – National School Lunch Program
Federal Award Number: 235GA324N1199 (Year: 2023) 225GA324N1099 (Year: 2023) Questioned Costs: None Identified
Repeat of Prior Year Finding: FA 2022-002
Description:
A review of expenditures charged to the Child Nutrition Cluster revealed that the School District’s
internal control procedures were not operating appropriately to ensure that the School District’s
suspension and debarment procedures were followed.
Background:
The Child Nutrition Cluster (CNC) is comprised of various programs that are intended to assist states in
administering and overseeing food service program operators that provide healthful, nutritious meals
to eligible children in public and non-profit private schools, residential childcare institutions, and
summer programs. This Cluster of programs also fosters healthy eating habits in children by providing
fresh fruits and fresh vegetables to children attending elementary and secondary schools and
encourages the domestic consumption of nutritious agricultural commodities.
CNC funding was granted to the Georgia Department of Education (GaDOE) by the U.S. Department of
Agriculture. GaDOE is responsible for distributing funds to local educational agencies (LEAs) and
overseeing the various CNC programs. CNC funds totaling $3,009,134.80 were expended and reported
on the Monroe County Board of Education’s Schedule of Expenditures of Federal Awards (SEFA) for
fiscal year 2023.
Criteria:
As a recipient of federal awards, the School District is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 – Internal Controls.
Additionally, Title 2 CFR Section 180.300 states in part that the non-Federal entity must “verify that the entity with whom you intend to do business is not excluded or disqualified. You can do this by: (a) Checking System for Awards Management (SAM) exclusions; or (b) Collecting a certification from the entity; or (c) Adding a clause or condition to the covered transaction with the entity.”
Condition:
A sample of 60 covered transactions was randomly selected for testing using a non-statistical sampling approach. These expenditures were reviewed to determine if appropriate internal controls were implemented and suspension and debarment compliance requirements were met. The following exception was noted:
• For five expenditures, documentation could not be provided to support the entity’s verification that the vendor was not suspended or debarred or otherwise excluded from participating in the transaction.
Cause:
The School District did not follow its policies and procedures that govern the suspension and debarment process for federal programs.
Effect:
The School District is not in compliance with the Uniform Guidance and Georgia Department of Education guidance. Failure to appropriately implement procedures to address suspension and debarment compliance requirements exposes the School District to unnecessary risk of error and misuse of federal funds and could result in the expenditure of federal funds with unqualified vendors. In addition, this deficiency could lead to the return of grant funds associated with unallowable expenditures.
Recommendation:
The School District should evaluate and improve internal control procedures to ensure that vendors are not suspended, debarred or otherwise excluded prior to entering into covered transactions and required suspension and debarment documentation is properly retained. In addition, management should develop a monitoring process to ensure that these procedures are operating appropriately.
Views of Responsible Officials:
We concur with this finding.
FA 2023-002 Improve Controls over Suspension and Debarment
Compliance Requirement: Procurement and Suspension and Debarment
Internal Control Impact: Significant Deficiency
Compliance Impact: Nonmaterial Noncompliance
Federal Awarding Agency: U.S. Department of Agriculture
Pass-Through Entity: Georgia Department of Education
AL Numbers and Titles: 10.553 – School Breakfast Program
10.555 – National School Lunch Program
Federal Award Number: 235GA324N1199 (Year: 2023) 225GA324N1099 (Year: 2023) Questioned Costs: None Identified
Repeat of Prior Year Finding: FA 2022-002
Description:
A review of expenditures charged to the Child Nutrition Cluster revealed that the School District’s
internal control procedures were not operating appropriately to ensure that the School District’s
suspension and debarment procedures were followed.
Background:
The Child Nutrition Cluster (CNC) is comprised of various programs that are intended to assist states in
administering and overseeing food service program operators that provide healthful, nutritious meals
to eligible children in public and non-profit private schools, residential childcare institutions, and
summer programs. This Cluster of programs also fosters healthy eating habits in children by providing
fresh fruits and fresh vegetables to children attending elementary and secondary schools and
encourages the domestic consumption of nutritious agricultural commodities.
CNC funding was granted to the Georgia Department of Education (GaDOE) by the U.S. Department of
Agriculture. GaDOE is responsible for distributing funds to local educational agencies (LEAs) and
overseeing the various CNC programs. CNC funds totaling $3,009,134.80 were expended and reported
on the Monroe County Board of Education’s Schedule of Expenditures of Federal Awards (SEFA) for
fiscal year 2023.
Criteria:
As a recipient of federal awards, the School District is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 – Internal Controls.
Additionally, Title 2 CFR Section 180.300 states in part that the non-Federal entity must “verify that the entity with whom you intend to do business is not excluded or disqualified. You can do this by: (a) Checking System for Awards Management (SAM) exclusions; or (b) Collecting a certification from the entity; or (c) Adding a clause or condition to the covered transaction with the entity.”
Condition:
A sample of 60 covered transactions was randomly selected for testing using a non-statistical sampling approach. These expenditures were reviewed to determine if appropriate internal controls were implemented and suspension and debarment compliance requirements were met. The following exception was noted:
• For five expenditures, documentation could not be provided to support the entity’s verification that the vendor was not suspended or debarred or otherwise excluded from participating in the transaction.
Cause:
The School District did not follow its policies and procedures that govern the suspension and debarment process for federal programs.
Effect:
The School District is not in compliance with the Uniform Guidance and Georgia Department of Education guidance. Failure to appropriately implement procedures to address suspension and debarment compliance requirements exposes the School District to unnecessary risk of error and misuse of federal funds and could result in the expenditure of federal funds with unqualified vendors. In addition, this deficiency could lead to the return of grant funds associated with unallowable expenditures.
Recommendation:
The School District should evaluate and improve internal control procedures to ensure that vendors are not suspended, debarred or otherwise excluded prior to entering into covered transactions and required suspension and debarment documentation is properly retained. In addition, management should develop a monitoring process to ensure that these procedures are operating appropriately.
Views of Responsible Officials:
We concur with this finding.
FA 2023-001 Strengthen Controls over Special Reporting
Compliance Requirement: Reporting
Internal Control Impact: Significant Deficiency
Compliance Impact: Nonmaterial Noncompliance
Federal Awarding Agency: U.S. Department of Agriculture
Pass-Through Entity: Georgia Department of Education
AL Numbers and Titles: 10.553 – School Breakfast Program
10.555 – National School Lunch Program
Federal Award Number: 235GA324N1199 (Year: 2023) 225GA324N1099 (Year: 2023)
Questioned Costs: None Identified
Repeat of Prior Year Finding: FA 2022-001
Description:
The policies and procedures of the School District were insufficient to provide adequate internal controls over the monthly Claims for Reimbursement process.
Background:
The Child Nutrition Cluster (CNC) is comprised of various programs that are intended to assist states in administering and overseeing food service program operators that provide healthful, nutritious meals to eligible children in public and non-profit private schools, residential child care institutions, and summer programs. This Cluster of programs also fosters healthy eating habits in children by providing fresh fruits and fresh vegetables to children attending elementary and secondary schools and encourages the domestic consumption of nutritious agricultural commodities.
CNC funding is granted to the Georgia Department of Education (GaDOE) by the U.S. Department of
Agriculture. GaDOE is responsible for distributing funds to local educational agencies (LEAs) based
upon each School District’s monthly Form DE0106 Claim Data report submissions. These DE0106
reports are to be supported by the corresponding Form DE0112 Daily Record of Number of Breakfasts Served and Form DE0118 Daily Record of Number of Lunches Served, which are prepared by the School District from their School Food Service meal sales system.
Criteria:
As a recipient of federal awards, the School District is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 – Internal Controls.
Provisions included in Title 7 CFR Section 210.7(c) require that the School District "base Claims for Reimbursement on lunch counts, taken daily at the point of service, which correctly identify the number of free, reduced price and paid lunches served to eligible children" and "correctly record, consolidate and report those lunch and supplement counts on the Claim for Reimbursement."
In addition, provisions included in Title 7 CFR Section 220.11(d) state that the School District "shall establish internal controls which ensure the accuracy of breakfast counts prior to the submission of the monthly Claim for Reimbursement.”
Condition:
A sample of four months during the standard school year in which a DE-0112, DE-0118, DE-0106 and DE-0107 should have been filed was randomly selected for testing using a non-statistical sampling approach. Additionally, the Form DE0106 reports for the months of July 2022 and June 2023 were selected for testing. These reports were reviewed to determine if appropriate internal controls were implemented and applicable reporting compliance requirements were met. The following deficiencies were noted:
• No Form DE0112 or DE0118 reports were prepared during the period under review.
• Daily meal count sheets maintained by the schools did not reflect evidence of review and approval by lunchroom managers in eight instances, including four breakfast and four lunch counts.
Cause:
In discussing these deficiencies with management, the School District believed completion of DE0112 and DE0018 was not a requirement due to the election of Seamless Summer Option. As a result, the School District did not follow its policies and procedures that govern the reporting process for federal programs.
Effect:
The School District is not in compliance with the Uniform Guidance and GaDOE guidance. Failure to submit accurate monthly Claims for Reimbursement to GaDOE can result in the School District obtaining less federal funding than they are eligible to receive. This deficiency may expose the School District to unnecessary financial strains and shortages within the CNC fund.
Recommendation:
The School District should evaluate their internal control processes regarding the preparation of the Form DE0112 or DE0118 reports and develop or modify procedures to ensure Claims for Reimbursement are based on final and accurate meals counts. The School District should become more familiar with the Federal regulations related to the CNC programs in order to develop or modify internal control procedures that will ensure accurate reporting of meals served. Furthermore, management should develop and implement a monitoring process to ensure that controls are functioning properly.
Views of Responsible Officials:
We concur with this finding.
FA 2023-001 Strengthen Controls over Special Reporting
Compliance Requirement: Reporting
Internal Control Impact: Significant Deficiency
Compliance Impact: Nonmaterial Noncompliance
Federal Awarding Agency: U.S. Department of Agriculture
Pass-Through Entity: Georgia Department of Education
AL Numbers and Titles: 10.553 – School Breakfast Program
10.555 – National School Lunch Program
Federal Award Number: 235GA324N1199 (Year: 2023) 225GA324N1099 (Year: 2023)
Questioned Costs: None Identified
Repeat of Prior Year Finding: FA 2022-001
Description:
The policies and procedures of the School District were insufficient to provide adequate internal controls over the monthly Claims for Reimbursement process.
Background:
The Child Nutrition Cluster (CNC) is comprised of various programs that are intended to assist states in administering and overseeing food service program operators that provide healthful, nutritious meals to eligible children in public and non-profit private schools, residential child care institutions, and summer programs. This Cluster of programs also fosters healthy eating habits in children by providing fresh fruits and fresh vegetables to children attending elementary and secondary schools and encourages the domestic consumption of nutritious agricultural commodities.
CNC funding is granted to the Georgia Department of Education (GaDOE) by the U.S. Department of
Agriculture. GaDOE is responsible for distributing funds to local educational agencies (LEAs) based
upon each School District’s monthly Form DE0106 Claim Data report submissions. These DE0106
reports are to be supported by the corresponding Form DE0112 Daily Record of Number of Breakfasts Served and Form DE0118 Daily Record of Number of Lunches Served, which are prepared by the School District from their School Food Service meal sales system.
Criteria:
As a recipient of federal awards, the School District is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 – Internal Controls.
Provisions included in Title 7 CFR Section 210.7(c) require that the School District "base Claims for Reimbursement on lunch counts, taken daily at the point of service, which correctly identify the number of free, reduced price and paid lunches served to eligible children" and "correctly record, consolidate and report those lunch and supplement counts on the Claim for Reimbursement."
In addition, provisions included in Title 7 CFR Section 220.11(d) state that the School District "shall establish internal controls which ensure the accuracy of breakfast counts prior to the submission of the monthly Claim for Reimbursement.”
Condition:
A sample of four months during the standard school year in which a DE-0112, DE-0118, DE-0106 and DE-0107 should have been filed was randomly selected for testing using a non-statistical sampling approach. Additionally, the Form DE0106 reports for the months of July 2022 and June 2023 were selected for testing. These reports were reviewed to determine if appropriate internal controls were implemented and applicable reporting compliance requirements were met. The following deficiencies were noted:
• No Form DE0112 or DE0118 reports were prepared during the period under review.
• Daily meal count sheets maintained by the schools did not reflect evidence of review and approval by lunchroom managers in eight instances, including four breakfast and four lunch counts.
Cause:
In discussing these deficiencies with management, the School District believed completion of DE0112 and DE0018 was not a requirement due to the election of Seamless Summer Option. As a result, the School District did not follow its policies and procedures that govern the reporting process for federal programs.
Effect:
The School District is not in compliance with the Uniform Guidance and GaDOE guidance. Failure to submit accurate monthly Claims for Reimbursement to GaDOE can result in the School District obtaining less federal funding than they are eligible to receive. This deficiency may expose the School District to unnecessary financial strains and shortages within the CNC fund.
Recommendation:
The School District should evaluate their internal control processes regarding the preparation of the Form DE0112 or DE0118 reports and develop or modify procedures to ensure Claims for Reimbursement are based on final and accurate meals counts. The School District should become more familiar with the Federal regulations related to the CNC programs in order to develop or modify internal control procedures that will ensure accurate reporting of meals served. Furthermore, management should develop and implement a monitoring process to ensure that controls are functioning properly.
Views of Responsible Officials:
We concur with this finding.
FA 2023-002 Improve Controls over Suspension and Debarment
Compliance Requirement: Procurement and Suspension and Debarment
Internal Control Impact: Significant Deficiency
Compliance Impact: Nonmaterial Noncompliance
Federal Awarding Agency: U.S. Department of Agriculture
Pass-Through Entity: Georgia Department of Education
AL Numbers and Titles: 10.553 – School Breakfast Program
10.555 – National School Lunch Program
Federal Award Number: 235GA324N1199 (Year: 2023) 225GA324N1099 (Year: 2023) Questioned Costs: None Identified
Repeat of Prior Year Finding: FA 2022-002
Description:
A review of expenditures charged to the Child Nutrition Cluster revealed that the School District’s
internal control procedures were not operating appropriately to ensure that the School District’s
suspension and debarment procedures were followed.
Background:
The Child Nutrition Cluster (CNC) is comprised of various programs that are intended to assist states in
administering and overseeing food service program operators that provide healthful, nutritious meals
to eligible children in public and non-profit private schools, residential childcare institutions, and
summer programs. This Cluster of programs also fosters healthy eating habits in children by providing
fresh fruits and fresh vegetables to children attending elementary and secondary schools and
encourages the domestic consumption of nutritious agricultural commodities.
CNC funding was granted to the Georgia Department of Education (GaDOE) by the U.S. Department of
Agriculture. GaDOE is responsible for distributing funds to local educational agencies (LEAs) and
overseeing the various CNC programs. CNC funds totaling $3,009,134.80 were expended and reported
on the Monroe County Board of Education’s Schedule of Expenditures of Federal Awards (SEFA) for
fiscal year 2023.
Criteria:
As a recipient of federal awards, the School District is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 – Internal Controls.
Additionally, Title 2 CFR Section 180.300 states in part that the non-Federal entity must “verify that the entity with whom you intend to do business is not excluded or disqualified. You can do this by: (a) Checking System for Awards Management (SAM) exclusions; or (b) Collecting a certification from the entity; or (c) Adding a clause or condition to the covered transaction with the entity.”
Condition:
A sample of 60 covered transactions was randomly selected for testing using a non-statistical sampling approach. These expenditures were reviewed to determine if appropriate internal controls were implemented and suspension and debarment compliance requirements were met. The following exception was noted:
• For five expenditures, documentation could not be provided to support the entity’s verification that the vendor was not suspended or debarred or otherwise excluded from participating in the transaction.
Cause:
The School District did not follow its policies and procedures that govern the suspension and debarment process for federal programs.
Effect:
The School District is not in compliance with the Uniform Guidance and Georgia Department of Education guidance. Failure to appropriately implement procedures to address suspension and debarment compliance requirements exposes the School District to unnecessary risk of error and misuse of federal funds and could result in the expenditure of federal funds with unqualified vendors. In addition, this deficiency could lead to the return of grant funds associated with unallowable expenditures.
Recommendation:
The School District should evaluate and improve internal control procedures to ensure that vendors are not suspended, debarred or otherwise excluded prior to entering into covered transactions and required suspension and debarment documentation is properly retained. In addition, management should develop a monitoring process to ensure that these procedures are operating appropriately.
Views of Responsible Officials:
We concur with this finding.
FA 2023-002 Improve Controls over Suspension and Debarment
Compliance Requirement: Procurement and Suspension and Debarment
Internal Control Impact: Significant Deficiency
Compliance Impact: Nonmaterial Noncompliance
Federal Awarding Agency: U.S. Department of Agriculture
Pass-Through Entity: Georgia Department of Education
AL Numbers and Titles: 10.553 – School Breakfast Program
10.555 – National School Lunch Program
Federal Award Number: 235GA324N1199 (Year: 2023) 225GA324N1099 (Year: 2023) Questioned Costs: None Identified
Repeat of Prior Year Finding: FA 2022-002
Description:
A review of expenditures charged to the Child Nutrition Cluster revealed that the School District’s
internal control procedures were not operating appropriately to ensure that the School District’s
suspension and debarment procedures were followed.
Background:
The Child Nutrition Cluster (CNC) is comprised of various programs that are intended to assist states in
administering and overseeing food service program operators that provide healthful, nutritious meals
to eligible children in public and non-profit private schools, residential childcare institutions, and
summer programs. This Cluster of programs also fosters healthy eating habits in children by providing
fresh fruits and fresh vegetables to children attending elementary and secondary schools and
encourages the domestic consumption of nutritious agricultural commodities.
CNC funding was granted to the Georgia Department of Education (GaDOE) by the U.S. Department of
Agriculture. GaDOE is responsible for distributing funds to local educational agencies (LEAs) and
overseeing the various CNC programs. CNC funds totaling $3,009,134.80 were expended and reported
on the Monroe County Board of Education’s Schedule of Expenditures of Federal Awards (SEFA) for
fiscal year 2023.
Criteria:
As a recipient of federal awards, the School District is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 – Internal Controls.
Additionally, Title 2 CFR Section 180.300 states in part that the non-Federal entity must “verify that the entity with whom you intend to do business is not excluded or disqualified. You can do this by: (a) Checking System for Awards Management (SAM) exclusions; or (b) Collecting a certification from the entity; or (c) Adding a clause or condition to the covered transaction with the entity.”
Condition:
A sample of 60 covered transactions was randomly selected for testing using a non-statistical sampling approach. These expenditures were reviewed to determine if appropriate internal controls were implemented and suspension and debarment compliance requirements were met. The following exception was noted:
• For five expenditures, documentation could not be provided to support the entity’s verification that the vendor was not suspended or debarred or otherwise excluded from participating in the transaction.
Cause:
The School District did not follow its policies and procedures that govern the suspension and debarment process for federal programs.
Effect:
The School District is not in compliance with the Uniform Guidance and Georgia Department of Education guidance. Failure to appropriately implement procedures to address suspension and debarment compliance requirements exposes the School District to unnecessary risk of error and misuse of federal funds and could result in the expenditure of federal funds with unqualified vendors. In addition, this deficiency could lead to the return of grant funds associated with unallowable expenditures.
Recommendation:
The School District should evaluate and improve internal control procedures to ensure that vendors are not suspended, debarred or otherwise excluded prior to entering into covered transactions and required suspension and debarment documentation is properly retained. In addition, management should develop a monitoring process to ensure that these procedures are operating appropriately.
Views of Responsible Officials:
We concur with this finding.