Audit 349113

FY End
2024-06-30
Total Expended
$8.60M
Findings
8
Programs
19
Organization: Spencer-Owen Community Schools (IN)
Year: 2024 Accepted: 2025-03-27

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
538084 2024-001 Significant Deficiency - E
538085 2024-001 Significant Deficiency - E
538086 2024-001 Significant Deficiency - E
538087 2024-001 Significant Deficiency - E
1114526 2024-001 Significant Deficiency - E
1114527 2024-001 Significant Deficiency - E
1114528 2024-001 Significant Deficiency - E
1114529 2024-001 Significant Deficiency - E

Contacts

Name Title Type
MFJKQTDLLM37 Annette Brown Auditee
8128292233 Beth Kelley, Cpa, Cfe Auditor
No contacts on file

Notes to SEFA

Title: Note 3. Forest Hills Special Education Cooperative Accounting Policies: Note 1. Summary of Significant Accounting Policies A. Basis of Presentation The accompanying Schedule of Expenditures of Federal Awards (SEFA) includes the federal award activity of the School Corporation under programs of the federal government for the years ended June 30, 2023 and 2024. The information in the SEFA is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Because the SEFA presents only a select portion of the operations of the School Corporation, it is not intended to and does not present the financial position of the School Corporation. The Uniform Guidance requires an annual audit of nonfederal entities expending a total amount of federal awards equal to or in excess of $750,000 in any fiscal year unless by constitution or statute a less frequent audit is required. In accordance with Indiana Code (IC 5-11-1-25), audits of school corporations shall be conducted biennially. Such audits shall include both years within the biennial period. B. Other Significant Accounting Policies Expenditures reported on the SEFA are reported on the cash basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. When federal grants are received on a reimbursement basis, the federal awards are considered expended when the reimbursement is received. Negative amounts shown on the SEFA represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. De Minimis Rate Used: N Rate Explanation: Note 2. Indirect Cost Rate The School Corporation has elected not to use the 10 percent de minimis indirect cost rate allowed under the Uniform Guidance. The School Corporation was a member of the Forest Hills Special Education Cooperative (Cooperative). As a result, some of the activity for the Special Education Cluster (IDEA) that is presented on the SEFA is not presented as receipts and disbursements in the financial statement for the School Corporation. This activity is presented in the financial statement of the Cooperative's fiscal agent. The Cooperative dissolved as of June 30, 2023.

Finding Details

FINDING 2024-001 Subject: Child Nutrition Cluster - Eligibility Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program Assistance Listings Numbers: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY 2022-2023, FY 2023-2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Finding: Significant Deficiency INDIANA STATE BOARD OF ACCOUNTS 13 SPENCER-OWEN COMMUNITY SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Condition and Context An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Eligibility compliance requirement. The Deputy Treasurer selected a random sample of students with a free or reduced-price lunch status and verified that their benefit was calculated correctly. This review happens annually in October or November. This internal control would not find issues with Direct Certification or applications completed for students after the annual review date. In an Indiana Department of Education Administrative review of the School Corporation during the audit period, four Direct Certification students were found to have been inappropriately issued reduced benefits as opposed to free benefits. Further, there was no documented review of the free or reduced-price lunch parameters in the School Corporation's nutrition management software, Titan. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 7 CFR 245.3(c) states in part: "Each School Food Authority shall serve free and reduced price meals or free milk in the respective programs to children eligible under its eligibility criteria. . . ." Cause The School Corporation was not aware of the requirement to document its review of parameters involving free or reduced-price lunch meals. The School Corporation's current internal control in place did not account for students who may enter into the School Corporation after the October or November count and random selection by the Deputy Treasurer. These errors associated with social economic status could cause incorrect funding and meal prices charged. Thus, the School Corporation's management had not developed a system of internal controls to ensure compliance with eligibility requirements. Effect The failure to establish an effective internal control system by the School Corporation caused noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Incorrect funding will be given if the social economic status is not verified by the School Corporation. INDIANA STATE BOARD OF ACCOUNTS 14 SPENCER-OWEN COMMUNITY SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls related to the grant agreement and eligibility compliance requirements. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-001 Subject: Child Nutrition Cluster - Eligibility Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program Assistance Listings Numbers: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY 2022-2023, FY 2023-2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Finding: Significant Deficiency INDIANA STATE BOARD OF ACCOUNTS 13 SPENCER-OWEN COMMUNITY SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Condition and Context An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Eligibility compliance requirement. The Deputy Treasurer selected a random sample of students with a free or reduced-price lunch status and verified that their benefit was calculated correctly. This review happens annually in October or November. This internal control would not find issues with Direct Certification or applications completed for students after the annual review date. In an Indiana Department of Education Administrative review of the School Corporation during the audit period, four Direct Certification students were found to have been inappropriately issued reduced benefits as opposed to free benefits. Further, there was no documented review of the free or reduced-price lunch parameters in the School Corporation's nutrition management software, Titan. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 7 CFR 245.3(c) states in part: "Each School Food Authority shall serve free and reduced price meals or free milk in the respective programs to children eligible under its eligibility criteria. . . ." Cause The School Corporation was not aware of the requirement to document its review of parameters involving free or reduced-price lunch meals. The School Corporation's current internal control in place did not account for students who may enter into the School Corporation after the October or November count and random selection by the Deputy Treasurer. These errors associated with social economic status could cause incorrect funding and meal prices charged. Thus, the School Corporation's management had not developed a system of internal controls to ensure compliance with eligibility requirements. Effect The failure to establish an effective internal control system by the School Corporation caused noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Incorrect funding will be given if the social economic status is not verified by the School Corporation. INDIANA STATE BOARD OF ACCOUNTS 14 SPENCER-OWEN COMMUNITY SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls related to the grant agreement and eligibility compliance requirements. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-001 Subject: Child Nutrition Cluster - Eligibility Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program Assistance Listings Numbers: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY 2022-2023, FY 2023-2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Finding: Significant Deficiency INDIANA STATE BOARD OF ACCOUNTS 13 SPENCER-OWEN COMMUNITY SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Condition and Context An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Eligibility compliance requirement. The Deputy Treasurer selected a random sample of students with a free or reduced-price lunch status and verified that their benefit was calculated correctly. This review happens annually in October or November. This internal control would not find issues with Direct Certification or applications completed for students after the annual review date. In an Indiana Department of Education Administrative review of the School Corporation during the audit period, four Direct Certification students were found to have been inappropriately issued reduced benefits as opposed to free benefits. Further, there was no documented review of the free or reduced-price lunch parameters in the School Corporation's nutrition management software, Titan. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 7 CFR 245.3(c) states in part: "Each School Food Authority shall serve free and reduced price meals or free milk in the respective programs to children eligible under its eligibility criteria. . . ." Cause The School Corporation was not aware of the requirement to document its review of parameters involving free or reduced-price lunch meals. The School Corporation's current internal control in place did not account for students who may enter into the School Corporation after the October or November count and random selection by the Deputy Treasurer. These errors associated with social economic status could cause incorrect funding and meal prices charged. Thus, the School Corporation's management had not developed a system of internal controls to ensure compliance with eligibility requirements. Effect The failure to establish an effective internal control system by the School Corporation caused noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Incorrect funding will be given if the social economic status is not verified by the School Corporation. INDIANA STATE BOARD OF ACCOUNTS 14 SPENCER-OWEN COMMUNITY SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls related to the grant agreement and eligibility compliance requirements. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-001 Subject: Child Nutrition Cluster - Eligibility Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program Assistance Listings Numbers: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY 2022-2023, FY 2023-2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Finding: Significant Deficiency INDIANA STATE BOARD OF ACCOUNTS 13 SPENCER-OWEN COMMUNITY SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Condition and Context An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Eligibility compliance requirement. The Deputy Treasurer selected a random sample of students with a free or reduced-price lunch status and verified that their benefit was calculated correctly. This review happens annually in October or November. This internal control would not find issues with Direct Certification or applications completed for students after the annual review date. In an Indiana Department of Education Administrative review of the School Corporation during the audit period, four Direct Certification students were found to have been inappropriately issued reduced benefits as opposed to free benefits. Further, there was no documented review of the free or reduced-price lunch parameters in the School Corporation's nutrition management software, Titan. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 7 CFR 245.3(c) states in part: "Each School Food Authority shall serve free and reduced price meals or free milk in the respective programs to children eligible under its eligibility criteria. . . ." Cause The School Corporation was not aware of the requirement to document its review of parameters involving free or reduced-price lunch meals. The School Corporation's current internal control in place did not account for students who may enter into the School Corporation after the October or November count and random selection by the Deputy Treasurer. These errors associated with social economic status could cause incorrect funding and meal prices charged. Thus, the School Corporation's management had not developed a system of internal controls to ensure compliance with eligibility requirements. Effect The failure to establish an effective internal control system by the School Corporation caused noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Incorrect funding will be given if the social economic status is not verified by the School Corporation. INDIANA STATE BOARD OF ACCOUNTS 14 SPENCER-OWEN COMMUNITY SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls related to the grant agreement and eligibility compliance requirements. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-001 Subject: Child Nutrition Cluster - Eligibility Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program Assistance Listings Numbers: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY 2022-2023, FY 2023-2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Finding: Significant Deficiency INDIANA STATE BOARD OF ACCOUNTS 13 SPENCER-OWEN COMMUNITY SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Condition and Context An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Eligibility compliance requirement. The Deputy Treasurer selected a random sample of students with a free or reduced-price lunch status and verified that their benefit was calculated correctly. This review happens annually in October or November. This internal control would not find issues with Direct Certification or applications completed for students after the annual review date. In an Indiana Department of Education Administrative review of the School Corporation during the audit period, four Direct Certification students were found to have been inappropriately issued reduced benefits as opposed to free benefits. Further, there was no documented review of the free or reduced-price lunch parameters in the School Corporation's nutrition management software, Titan. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 7 CFR 245.3(c) states in part: "Each School Food Authority shall serve free and reduced price meals or free milk in the respective programs to children eligible under its eligibility criteria. . . ." Cause The School Corporation was not aware of the requirement to document its review of parameters involving free or reduced-price lunch meals. The School Corporation's current internal control in place did not account for students who may enter into the School Corporation after the October or November count and random selection by the Deputy Treasurer. These errors associated with social economic status could cause incorrect funding and meal prices charged. Thus, the School Corporation's management had not developed a system of internal controls to ensure compliance with eligibility requirements. Effect The failure to establish an effective internal control system by the School Corporation caused noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Incorrect funding will be given if the social economic status is not verified by the School Corporation. INDIANA STATE BOARD OF ACCOUNTS 14 SPENCER-OWEN COMMUNITY SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls related to the grant agreement and eligibility compliance requirements. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-001 Subject: Child Nutrition Cluster - Eligibility Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program Assistance Listings Numbers: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY 2022-2023, FY 2023-2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Finding: Significant Deficiency INDIANA STATE BOARD OF ACCOUNTS 13 SPENCER-OWEN COMMUNITY SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Condition and Context An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Eligibility compliance requirement. The Deputy Treasurer selected a random sample of students with a free or reduced-price lunch status and verified that their benefit was calculated correctly. This review happens annually in October or November. This internal control would not find issues with Direct Certification or applications completed for students after the annual review date. In an Indiana Department of Education Administrative review of the School Corporation during the audit period, four Direct Certification students were found to have been inappropriately issued reduced benefits as opposed to free benefits. Further, there was no documented review of the free or reduced-price lunch parameters in the School Corporation's nutrition management software, Titan. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 7 CFR 245.3(c) states in part: "Each School Food Authority shall serve free and reduced price meals or free milk in the respective programs to children eligible under its eligibility criteria. . . ." Cause The School Corporation was not aware of the requirement to document its review of parameters involving free or reduced-price lunch meals. The School Corporation's current internal control in place did not account for students who may enter into the School Corporation after the October or November count and random selection by the Deputy Treasurer. These errors associated with social economic status could cause incorrect funding and meal prices charged. Thus, the School Corporation's management had not developed a system of internal controls to ensure compliance with eligibility requirements. Effect The failure to establish an effective internal control system by the School Corporation caused noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Incorrect funding will be given if the social economic status is not verified by the School Corporation. INDIANA STATE BOARD OF ACCOUNTS 14 SPENCER-OWEN COMMUNITY SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls related to the grant agreement and eligibility compliance requirements. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-001 Subject: Child Nutrition Cluster - Eligibility Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program Assistance Listings Numbers: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY 2022-2023, FY 2023-2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Finding: Significant Deficiency INDIANA STATE BOARD OF ACCOUNTS 13 SPENCER-OWEN COMMUNITY SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Condition and Context An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Eligibility compliance requirement. The Deputy Treasurer selected a random sample of students with a free or reduced-price lunch status and verified that their benefit was calculated correctly. This review happens annually in October or November. This internal control would not find issues with Direct Certification or applications completed for students after the annual review date. In an Indiana Department of Education Administrative review of the School Corporation during the audit period, four Direct Certification students were found to have been inappropriately issued reduced benefits as opposed to free benefits. Further, there was no documented review of the free or reduced-price lunch parameters in the School Corporation's nutrition management software, Titan. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 7 CFR 245.3(c) states in part: "Each School Food Authority shall serve free and reduced price meals or free milk in the respective programs to children eligible under its eligibility criteria. . . ." Cause The School Corporation was not aware of the requirement to document its review of parameters involving free or reduced-price lunch meals. The School Corporation's current internal control in place did not account for students who may enter into the School Corporation after the October or November count and random selection by the Deputy Treasurer. These errors associated with social economic status could cause incorrect funding and meal prices charged. Thus, the School Corporation's management had not developed a system of internal controls to ensure compliance with eligibility requirements. Effect The failure to establish an effective internal control system by the School Corporation caused noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Incorrect funding will be given if the social economic status is not verified by the School Corporation. INDIANA STATE BOARD OF ACCOUNTS 14 SPENCER-OWEN COMMUNITY SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls related to the grant agreement and eligibility compliance requirements. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-001 Subject: Child Nutrition Cluster - Eligibility Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program Assistance Listings Numbers: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY 2022-2023, FY 2023-2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Finding: Significant Deficiency INDIANA STATE BOARD OF ACCOUNTS 13 SPENCER-OWEN COMMUNITY SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Condition and Context An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Eligibility compliance requirement. The Deputy Treasurer selected a random sample of students with a free or reduced-price lunch status and verified that their benefit was calculated correctly. This review happens annually in October or November. This internal control would not find issues with Direct Certification or applications completed for students after the annual review date. In an Indiana Department of Education Administrative review of the School Corporation during the audit period, four Direct Certification students were found to have been inappropriately issued reduced benefits as opposed to free benefits. Further, there was no documented review of the free or reduced-price lunch parameters in the School Corporation's nutrition management software, Titan. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 7 CFR 245.3(c) states in part: "Each School Food Authority shall serve free and reduced price meals or free milk in the respective programs to children eligible under its eligibility criteria. . . ." Cause The School Corporation was not aware of the requirement to document its review of parameters involving free or reduced-price lunch meals. The School Corporation's current internal control in place did not account for students who may enter into the School Corporation after the October or November count and random selection by the Deputy Treasurer. These errors associated with social economic status could cause incorrect funding and meal prices charged. Thus, the School Corporation's management had not developed a system of internal controls to ensure compliance with eligibility requirements. Effect The failure to establish an effective internal control system by the School Corporation caused noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Incorrect funding will be given if the social economic status is not verified by the School Corporation. INDIANA STATE BOARD OF ACCOUNTS 14 SPENCER-OWEN COMMUNITY SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls related to the grant agreement and eligibility compliance requirements. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.