FINDING 2024-003
Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment
Federal Agency: Department of Agriculture
Federal Programs: School Breakfast Program, National School Lunch Program,
Summer Food Service Program for Children
Assistance Listings Numbers: 10.553, 10.555, 10.559
Federal Award Numbers and Years (or Other Identifying Numbers): FY2022-23, FY2023-24
Pass-Through Entity: Indiana Department of Education
Compliance Requirement: Procurement and Suspension and Debarment
Audit Findings: Material Weakness, Other Matters
Condition and Context
An effective internal control system, which would include segregation of duties, was not in place at
the School Corporation in order to ensure compliance with requirements related to the grant agreement
and the following compliance requirement: Procurement and Suspension and Debarment.
INDIANA STATE BOARD OF ACCOUNTS
18
WES-DEL COMMUNITY SCHOOL CORPORATION
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
(Continued)
Suspension and Debarment
The School Corporation did not have effective internal controls in place to ensure contracted
vendors were not suspended or debarred or otherwise excluded from participation in federal
award programs. The School Corporation could not provide evidence the suspension and
debarment status of one vendor was reviewed during the engagement period.
The lack of internal controls and noncompliance were systemic issues throughout the audit period.
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). . . ."
2 CFR 200.318(i) states:
"The non-Federal entity must maintain records sufficient to detail the history of procurement.
These records will include, but are not necessarily limited to, the following: Rationale for the
method of procurement, selection of contract type, contractor selection or rejection, and the
basis for the contract price."
2 CFR 180.300 states:
"When you enter into a covered transaction with another person at the next lower tier, you must
verify that the person with whom you intend to do business is not excluded or disqualified. You
do this by:
(a) Checking the SAM Exclusions; or
(b) Collecting a certification from that person; or
(c) Adding a clause or condition to the covered transaction with that person."
Cause
Management of the School Corporation had not established an effective system of internal controls
that would have ensured reviews of suspension and debarment statuses occurred for vendors. The School
Corporation did not verify whether or not vendors were suspended or debarred prior to entering into an
agreement with that vendor.
INDIANA STATE BOARD OF ACCOUNTS
19
WES-DEL COMMUNITY SCHOOL CORPORATION
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
(Continued)
Effect
The failure to establish an effective internal control system placed the School Corporation in noncompliance
with the grant agreement and the Procurement and Suspension and Debarment compliance
requirement.
Questioned Costs
There were no questioned costs identified.
Recommendation
We recommended the School Corporation should develop policies and procedures to verify the
status of vendors for federal programs and retain documentation of verification of suspension and
debarment reviews performed.
Views of Responsible Officials
For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-003
Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment
Federal Agency: Department of Agriculture
Federal Programs: School Breakfast Program, National School Lunch Program,
Summer Food Service Program for Children
Assistance Listings Numbers: 10.553, 10.555, 10.559
Federal Award Numbers and Years (or Other Identifying Numbers): FY2022-23, FY2023-24
Pass-Through Entity: Indiana Department of Education
Compliance Requirement: Procurement and Suspension and Debarment
Audit Findings: Material Weakness, Other Matters
Condition and Context
An effective internal control system, which would include segregation of duties, was not in place at
the School Corporation in order to ensure compliance with requirements related to the grant agreement
and the following compliance requirement: Procurement and Suspension and Debarment.
INDIANA STATE BOARD OF ACCOUNTS
18
WES-DEL COMMUNITY SCHOOL CORPORATION
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
(Continued)
Suspension and Debarment
The School Corporation did not have effective internal controls in place to ensure contracted
vendors were not suspended or debarred or otherwise excluded from participation in federal
award programs. The School Corporation could not provide evidence the suspension and
debarment status of one vendor was reviewed during the engagement period.
The lack of internal controls and noncompliance were systemic issues throughout the audit period.
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). . . ."
2 CFR 200.318(i) states:
"The non-Federal entity must maintain records sufficient to detail the history of procurement.
These records will include, but are not necessarily limited to, the following: Rationale for the
method of procurement, selection of contract type, contractor selection or rejection, and the
basis for the contract price."
2 CFR 180.300 states:
"When you enter into a covered transaction with another person at the next lower tier, you must
verify that the person with whom you intend to do business is not excluded or disqualified. You
do this by:
(a) Checking the SAM Exclusions; or
(b) Collecting a certification from that person; or
(c) Adding a clause or condition to the covered transaction with that person."
Cause
Management of the School Corporation had not established an effective system of internal controls
that would have ensured reviews of suspension and debarment statuses occurred for vendors. The School
Corporation did not verify whether or not vendors were suspended or debarred prior to entering into an
agreement with that vendor.
INDIANA STATE BOARD OF ACCOUNTS
19
WES-DEL COMMUNITY SCHOOL CORPORATION
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
(Continued)
Effect
The failure to establish an effective internal control system placed the School Corporation in noncompliance
with the grant agreement and the Procurement and Suspension and Debarment compliance
requirement.
Questioned Costs
There were no questioned costs identified.
Recommendation
We recommended the School Corporation should develop policies and procedures to verify the
status of vendors for federal programs and retain documentation of verification of suspension and
debarment reviews performed.
Views of Responsible Officials
For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-003
Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment
Federal Agency: Department of Agriculture
Federal Programs: School Breakfast Program, National School Lunch Program,
Summer Food Service Program for Children
Assistance Listings Numbers: 10.553, 10.555, 10.559
Federal Award Numbers and Years (or Other Identifying Numbers): FY2022-23, FY2023-24
Pass-Through Entity: Indiana Department of Education
Compliance Requirement: Procurement and Suspension and Debarment
Audit Findings: Material Weakness, Other Matters
Condition and Context
An effective internal control system, which would include segregation of duties, was not in place at
the School Corporation in order to ensure compliance with requirements related to the grant agreement
and the following compliance requirement: Procurement and Suspension and Debarment.
INDIANA STATE BOARD OF ACCOUNTS
18
WES-DEL COMMUNITY SCHOOL CORPORATION
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
(Continued)
Suspension and Debarment
The School Corporation did not have effective internal controls in place to ensure contracted
vendors were not suspended or debarred or otherwise excluded from participation in federal
award programs. The School Corporation could not provide evidence the suspension and
debarment status of one vendor was reviewed during the engagement period.
The lack of internal controls and noncompliance were systemic issues throughout the audit period.
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). . . ."
2 CFR 200.318(i) states:
"The non-Federal entity must maintain records sufficient to detail the history of procurement.
These records will include, but are not necessarily limited to, the following: Rationale for the
method of procurement, selection of contract type, contractor selection or rejection, and the
basis for the contract price."
2 CFR 180.300 states:
"When you enter into a covered transaction with another person at the next lower tier, you must
verify that the person with whom you intend to do business is not excluded or disqualified. You
do this by:
(a) Checking the SAM Exclusions; or
(b) Collecting a certification from that person; or
(c) Adding a clause or condition to the covered transaction with that person."
Cause
Management of the School Corporation had not established an effective system of internal controls
that would have ensured reviews of suspension and debarment statuses occurred for vendors. The School
Corporation did not verify whether or not vendors were suspended or debarred prior to entering into an
agreement with that vendor.
INDIANA STATE BOARD OF ACCOUNTS
19
WES-DEL COMMUNITY SCHOOL CORPORATION
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
(Continued)
Effect
The failure to establish an effective internal control system placed the School Corporation in noncompliance
with the grant agreement and the Procurement and Suspension and Debarment compliance
requirement.
Questioned Costs
There were no questioned costs identified.
Recommendation
We recommended the School Corporation should develop policies and procedures to verify the
status of vendors for federal programs and retain documentation of verification of suspension and
debarment reviews performed.
Views of Responsible Officials
For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-003
Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment
Federal Agency: Department of Agriculture
Federal Programs: School Breakfast Program, National School Lunch Program,
Summer Food Service Program for Children
Assistance Listings Numbers: 10.553, 10.555, 10.559
Federal Award Numbers and Years (or Other Identifying Numbers): FY2022-23, FY2023-24
Pass-Through Entity: Indiana Department of Education
Compliance Requirement: Procurement and Suspension and Debarment
Audit Findings: Material Weakness, Other Matters
Condition and Context
An effective internal control system, which would include segregation of duties, was not in place at
the School Corporation in order to ensure compliance with requirements related to the grant agreement
and the following compliance requirement: Procurement and Suspension and Debarment.
INDIANA STATE BOARD OF ACCOUNTS
18
WES-DEL COMMUNITY SCHOOL CORPORATION
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
(Continued)
Suspension and Debarment
The School Corporation did not have effective internal controls in place to ensure contracted
vendors were not suspended or debarred or otherwise excluded from participation in federal
award programs. The School Corporation could not provide evidence the suspension and
debarment status of one vendor was reviewed during the engagement period.
The lack of internal controls and noncompliance were systemic issues throughout the audit period.
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). . . ."
2 CFR 200.318(i) states:
"The non-Federal entity must maintain records sufficient to detail the history of procurement.
These records will include, but are not necessarily limited to, the following: Rationale for the
method of procurement, selection of contract type, contractor selection or rejection, and the
basis for the contract price."
2 CFR 180.300 states:
"When you enter into a covered transaction with another person at the next lower tier, you must
verify that the person with whom you intend to do business is not excluded or disqualified. You
do this by:
(a) Checking the SAM Exclusions; or
(b) Collecting a certification from that person; or
(c) Adding a clause or condition to the covered transaction with that person."
Cause
Management of the School Corporation had not established an effective system of internal controls
that would have ensured reviews of suspension and debarment statuses occurred for vendors. The School
Corporation did not verify whether or not vendors were suspended or debarred prior to entering into an
agreement with that vendor.
INDIANA STATE BOARD OF ACCOUNTS
19
WES-DEL COMMUNITY SCHOOL CORPORATION
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
(Continued)
Effect
The failure to establish an effective internal control system placed the School Corporation in noncompliance
with the grant agreement and the Procurement and Suspension and Debarment compliance
requirement.
Questioned Costs
There were no questioned costs identified.
Recommendation
We recommended the School Corporation should develop policies and procedures to verify the
status of vendors for federal programs and retain documentation of verification of suspension and
debarment reviews performed.
Views of Responsible Officials
For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-003
Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment
Federal Agency: Department of Agriculture
Federal Programs: School Breakfast Program, National School Lunch Program,
Summer Food Service Program for Children
Assistance Listings Numbers: 10.553, 10.555, 10.559
Federal Award Numbers and Years (or Other Identifying Numbers): FY2022-23, FY2023-24
Pass-Through Entity: Indiana Department of Education
Compliance Requirement: Procurement and Suspension and Debarment
Audit Findings: Material Weakness, Other Matters
Condition and Context
An effective internal control system, which would include segregation of duties, was not in place at
the School Corporation in order to ensure compliance with requirements related to the grant agreement
and the following compliance requirement: Procurement and Suspension and Debarment.
INDIANA STATE BOARD OF ACCOUNTS
18
WES-DEL COMMUNITY SCHOOL CORPORATION
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
(Continued)
Suspension and Debarment
The School Corporation did not have effective internal controls in place to ensure contracted
vendors were not suspended or debarred or otherwise excluded from participation in federal
award programs. The School Corporation could not provide evidence the suspension and
debarment status of one vendor was reviewed during the engagement period.
The lack of internal controls and noncompliance were systemic issues throughout the audit period.
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). . . ."
2 CFR 200.318(i) states:
"The non-Federal entity must maintain records sufficient to detail the history of procurement.
These records will include, but are not necessarily limited to, the following: Rationale for the
method of procurement, selection of contract type, contractor selection or rejection, and the
basis for the contract price."
2 CFR 180.300 states:
"When you enter into a covered transaction with another person at the next lower tier, you must
verify that the person with whom you intend to do business is not excluded or disqualified. You
do this by:
(a) Checking the SAM Exclusions; or
(b) Collecting a certification from that person; or
(c) Adding a clause or condition to the covered transaction with that person."
Cause
Management of the School Corporation had not established an effective system of internal controls
that would have ensured reviews of suspension and debarment statuses occurred for vendors. The School
Corporation did not verify whether or not vendors were suspended or debarred prior to entering into an
agreement with that vendor.
INDIANA STATE BOARD OF ACCOUNTS
19
WES-DEL COMMUNITY SCHOOL CORPORATION
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
(Continued)
Effect
The failure to establish an effective internal control system placed the School Corporation in noncompliance
with the grant agreement and the Procurement and Suspension and Debarment compliance
requirement.
Questioned Costs
There were no questioned costs identified.
Recommendation
We recommended the School Corporation should develop policies and procedures to verify the
status of vendors for federal programs and retain documentation of verification of suspension and
debarment reviews performed.
Views of Responsible Officials
For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-004
Subject: Title I Grants to Local Educational Agencies - Special
Tests and Provisions - Assessment System Security
Federal Agency: Department of Education
Federal Program: Title I Grants to Local Educational Agencies
Assistance Listings Number: 84.010
Federal Award Numbers and Years (or Other Identifying Numbers): S010A210014, S010A220014,
S010A230014
Pass-Through Entity: Indiana Department of Education
Compliance Requirement: Special Tests and Provisions - Assessment System Security
Audit Findings: Material Weakness, Other Matters
Condition and Context
An effective internal control system, which would include segregation of duties, was not in place at
the School Corporation in order to ensure compliance with requirements related to the grant agreement
and the following compliance requirement: Special Tests and Provisions - Assessment System Security.
The state educational agencies (SEA), in consultation with the local educational agencies (LEA),
are required to establish and maintain an assessment security system that is valid, reliable, and consistent
with relevant professional and technical standards. Within their assessment system, the SEAs must have
policies and procedures to maintain test security measures and ensure that the LEAs implement those
policies and procedures. As such, the Indiana Department of Education created and published the Indiana
Assessments Policy Manual.
As a part of the assessment security, any individual who administers, handles, or has access to
secure test materials at the school or school corporation shall complete assessment training and sign a
testing security and integrity statement that remains on file in the appropriate building-level office each year.
Everyone who is required to sign the testing integrity agreement shall sign the form by an established date.
INDIANA STATE BOARD OF ACCOUNTS
20
WES-DEL COMMUNITY SCHOOL CORPORATION
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
(Continued)
The School Corporation had a process to provide assessment system security training and to
ensure each employee that attended training signed the agreement indicating training was received.
However, documentation was not retained for audit that would provide evidence that training occurred
during fiscal year 2022-2023. Documentation was provided for audit for 2023-2024.
The lack of internal controls and noncompliance were isolated to 2022-2023.
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). . . ."
511 IAC 5-5-5(b) states: "Any individual who administers, handles, or has access to secure test
materials at the school or school corporation shall complete assessment training and sign a testing security
and integrity agreement to remain on file in the appropriate building-level office each year."
Cause
Management of the School Corporation had not established an effective system of internal controls
that would have ensured required staff received training on the Assessment System Security and evidence
of the trainings were retained for audit. Management did not retain documentation for the audit that would
have provided evidence that it had properly held training for staff on the Assessment System Security.
Effect
The failure to establish an effective internal control system placed the School Corporation in noncompliance
with the grant agreement and the Special Tests and Provisions - Assessment System Security
compliance requirement.
Questioned Costs
There were no questioned costs identified.
Recommendation
We recommended that the School should develop policies and procedures to provide training to
required personnel and to retain documentation of training provided for the Assessment System Security.
Views of Responsible Officials
For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-004
Subject: Title I Grants to Local Educational Agencies - Special
Tests and Provisions - Assessment System Security
Federal Agency: Department of Education
Federal Program: Title I Grants to Local Educational Agencies
Assistance Listings Number: 84.010
Federal Award Numbers and Years (or Other Identifying Numbers): S010A210014, S010A220014,
S010A230014
Pass-Through Entity: Indiana Department of Education
Compliance Requirement: Special Tests and Provisions - Assessment System Security
Audit Findings: Material Weakness, Other Matters
Condition and Context
An effective internal control system, which would include segregation of duties, was not in place at
the School Corporation in order to ensure compliance with requirements related to the grant agreement
and the following compliance requirement: Special Tests and Provisions - Assessment System Security.
The state educational agencies (SEA), in consultation with the local educational agencies (LEA),
are required to establish and maintain an assessment security system that is valid, reliable, and consistent
with relevant professional and technical standards. Within their assessment system, the SEAs must have
policies and procedures to maintain test security measures and ensure that the LEAs implement those
policies and procedures. As such, the Indiana Department of Education created and published the Indiana
Assessments Policy Manual.
As a part of the assessment security, any individual who administers, handles, or has access to
secure test materials at the school or school corporation shall complete assessment training and sign a
testing security and integrity statement that remains on file in the appropriate building-level office each year.
Everyone who is required to sign the testing integrity agreement shall sign the form by an established date.
INDIANA STATE BOARD OF ACCOUNTS
20
WES-DEL COMMUNITY SCHOOL CORPORATION
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
(Continued)
The School Corporation had a process to provide assessment system security training and to
ensure each employee that attended training signed the agreement indicating training was received.
However, documentation was not retained for audit that would provide evidence that training occurred
during fiscal year 2022-2023. Documentation was provided for audit for 2023-2024.
The lack of internal controls and noncompliance were isolated to 2022-2023.
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). . . ."
511 IAC 5-5-5(b) states: "Any individual who administers, handles, or has access to secure test
materials at the school or school corporation shall complete assessment training and sign a testing security
and integrity agreement to remain on file in the appropriate building-level office each year."
Cause
Management of the School Corporation had not established an effective system of internal controls
that would have ensured required staff received training on the Assessment System Security and evidence
of the trainings were retained for audit. Management did not retain documentation for the audit that would
have provided evidence that it had properly held training for staff on the Assessment System Security.
Effect
The failure to establish an effective internal control system placed the School Corporation in noncompliance
with the grant agreement and the Special Tests and Provisions - Assessment System Security
compliance requirement.
Questioned Costs
There were no questioned costs identified.
Recommendation
We recommended that the School should develop policies and procedures to provide training to
required personnel and to retain documentation of training provided for the Assessment System Security.
Views of Responsible Officials
For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-003
Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment
Federal Agency: Department of Agriculture
Federal Programs: School Breakfast Program, National School Lunch Program,
Summer Food Service Program for Children
Assistance Listings Numbers: 10.553, 10.555, 10.559
Federal Award Numbers and Years (or Other Identifying Numbers): FY2022-23, FY2023-24
Pass-Through Entity: Indiana Department of Education
Compliance Requirement: Procurement and Suspension and Debarment
Audit Findings: Material Weakness, Other Matters
Condition and Context
An effective internal control system, which would include segregation of duties, was not in place at
the School Corporation in order to ensure compliance with requirements related to the grant agreement
and the following compliance requirement: Procurement and Suspension and Debarment.
INDIANA STATE BOARD OF ACCOUNTS
18
WES-DEL COMMUNITY SCHOOL CORPORATION
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
(Continued)
Suspension and Debarment
The School Corporation did not have effective internal controls in place to ensure contracted
vendors were not suspended or debarred or otherwise excluded from participation in federal
award programs. The School Corporation could not provide evidence the suspension and
debarment status of one vendor was reviewed during the engagement period.
The lack of internal controls and noncompliance were systemic issues throughout the audit period.
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). . . ."
2 CFR 200.318(i) states:
"The non-Federal entity must maintain records sufficient to detail the history of procurement.
These records will include, but are not necessarily limited to, the following: Rationale for the
method of procurement, selection of contract type, contractor selection or rejection, and the
basis for the contract price."
2 CFR 180.300 states:
"When you enter into a covered transaction with another person at the next lower tier, you must
verify that the person with whom you intend to do business is not excluded or disqualified. You
do this by:
(a) Checking the SAM Exclusions; or
(b) Collecting a certification from that person; or
(c) Adding a clause or condition to the covered transaction with that person."
Cause
Management of the School Corporation had not established an effective system of internal controls
that would have ensured reviews of suspension and debarment statuses occurred for vendors. The School
Corporation did not verify whether or not vendors were suspended or debarred prior to entering into an
agreement with that vendor.
INDIANA STATE BOARD OF ACCOUNTS
19
WES-DEL COMMUNITY SCHOOL CORPORATION
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
(Continued)
Effect
The failure to establish an effective internal control system placed the School Corporation in noncompliance
with the grant agreement and the Procurement and Suspension and Debarment compliance
requirement.
Questioned Costs
There were no questioned costs identified.
Recommendation
We recommended the School Corporation should develop policies and procedures to verify the
status of vendors for federal programs and retain documentation of verification of suspension and
debarment reviews performed.
Views of Responsible Officials
For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-003
Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment
Federal Agency: Department of Agriculture
Federal Programs: School Breakfast Program, National School Lunch Program,
Summer Food Service Program for Children
Assistance Listings Numbers: 10.553, 10.555, 10.559
Federal Award Numbers and Years (or Other Identifying Numbers): FY2022-23, FY2023-24
Pass-Through Entity: Indiana Department of Education
Compliance Requirement: Procurement and Suspension and Debarment
Audit Findings: Material Weakness, Other Matters
Condition and Context
An effective internal control system, which would include segregation of duties, was not in place at
the School Corporation in order to ensure compliance with requirements related to the grant agreement
and the following compliance requirement: Procurement and Suspension and Debarment.
INDIANA STATE BOARD OF ACCOUNTS
18
WES-DEL COMMUNITY SCHOOL CORPORATION
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
(Continued)
Suspension and Debarment
The School Corporation did not have effective internal controls in place to ensure contracted
vendors were not suspended or debarred or otherwise excluded from participation in federal
award programs. The School Corporation could not provide evidence the suspension and
debarment status of one vendor was reviewed during the engagement period.
The lack of internal controls and noncompliance were systemic issues throughout the audit period.
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). . . ."
2 CFR 200.318(i) states:
"The non-Federal entity must maintain records sufficient to detail the history of procurement.
These records will include, but are not necessarily limited to, the following: Rationale for the
method of procurement, selection of contract type, contractor selection or rejection, and the
basis for the contract price."
2 CFR 180.300 states:
"When you enter into a covered transaction with another person at the next lower tier, you must
verify that the person with whom you intend to do business is not excluded or disqualified. You
do this by:
(a) Checking the SAM Exclusions; or
(b) Collecting a certification from that person; or
(c) Adding a clause or condition to the covered transaction with that person."
Cause
Management of the School Corporation had not established an effective system of internal controls
that would have ensured reviews of suspension and debarment statuses occurred for vendors. The School
Corporation did not verify whether or not vendors were suspended or debarred prior to entering into an
agreement with that vendor.
INDIANA STATE BOARD OF ACCOUNTS
19
WES-DEL COMMUNITY SCHOOL CORPORATION
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
(Continued)
Effect
The failure to establish an effective internal control system placed the School Corporation in noncompliance
with the grant agreement and the Procurement and Suspension and Debarment compliance
requirement.
Questioned Costs
There were no questioned costs identified.
Recommendation
We recommended the School Corporation should develop policies and procedures to verify the
status of vendors for federal programs and retain documentation of verification of suspension and
debarment reviews performed.
Views of Responsible Officials
For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-003
Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment
Federal Agency: Department of Agriculture
Federal Programs: School Breakfast Program, National School Lunch Program,
Summer Food Service Program for Children
Assistance Listings Numbers: 10.553, 10.555, 10.559
Federal Award Numbers and Years (or Other Identifying Numbers): FY2022-23, FY2023-24
Pass-Through Entity: Indiana Department of Education
Compliance Requirement: Procurement and Suspension and Debarment
Audit Findings: Material Weakness, Other Matters
Condition and Context
An effective internal control system, which would include segregation of duties, was not in place at
the School Corporation in order to ensure compliance with requirements related to the grant agreement
and the following compliance requirement: Procurement and Suspension and Debarment.
INDIANA STATE BOARD OF ACCOUNTS
18
WES-DEL COMMUNITY SCHOOL CORPORATION
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
(Continued)
Suspension and Debarment
The School Corporation did not have effective internal controls in place to ensure contracted
vendors were not suspended or debarred or otherwise excluded from participation in federal
award programs. The School Corporation could not provide evidence the suspension and
debarment status of one vendor was reviewed during the engagement period.
The lack of internal controls and noncompliance were systemic issues throughout the audit period.
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). . . ."
2 CFR 200.318(i) states:
"The non-Federal entity must maintain records sufficient to detail the history of procurement.
These records will include, but are not necessarily limited to, the following: Rationale for the
method of procurement, selection of contract type, contractor selection or rejection, and the
basis for the contract price."
2 CFR 180.300 states:
"When you enter into a covered transaction with another person at the next lower tier, you must
verify that the person with whom you intend to do business is not excluded or disqualified. You
do this by:
(a) Checking the SAM Exclusions; or
(b) Collecting a certification from that person; or
(c) Adding a clause or condition to the covered transaction with that person."
Cause
Management of the School Corporation had not established an effective system of internal controls
that would have ensured reviews of suspension and debarment statuses occurred for vendors. The School
Corporation did not verify whether or not vendors were suspended or debarred prior to entering into an
agreement with that vendor.
INDIANA STATE BOARD OF ACCOUNTS
19
WES-DEL COMMUNITY SCHOOL CORPORATION
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
(Continued)
Effect
The failure to establish an effective internal control system placed the School Corporation in noncompliance
with the grant agreement and the Procurement and Suspension and Debarment compliance
requirement.
Questioned Costs
There were no questioned costs identified.
Recommendation
We recommended the School Corporation should develop policies and procedures to verify the
status of vendors for federal programs and retain documentation of verification of suspension and
debarment reviews performed.
Views of Responsible Officials
For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-003
Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment
Federal Agency: Department of Agriculture
Federal Programs: School Breakfast Program, National School Lunch Program,
Summer Food Service Program for Children
Assistance Listings Numbers: 10.553, 10.555, 10.559
Federal Award Numbers and Years (or Other Identifying Numbers): FY2022-23, FY2023-24
Pass-Through Entity: Indiana Department of Education
Compliance Requirement: Procurement and Suspension and Debarment
Audit Findings: Material Weakness, Other Matters
Condition and Context
An effective internal control system, which would include segregation of duties, was not in place at
the School Corporation in order to ensure compliance with requirements related to the grant agreement
and the following compliance requirement: Procurement and Suspension and Debarment.
INDIANA STATE BOARD OF ACCOUNTS
18
WES-DEL COMMUNITY SCHOOL CORPORATION
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
(Continued)
Suspension and Debarment
The School Corporation did not have effective internal controls in place to ensure contracted
vendors were not suspended or debarred or otherwise excluded from participation in federal
award programs. The School Corporation could not provide evidence the suspension and
debarment status of one vendor was reviewed during the engagement period.
The lack of internal controls and noncompliance were systemic issues throughout the audit period.
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). . . ."
2 CFR 200.318(i) states:
"The non-Federal entity must maintain records sufficient to detail the history of procurement.
These records will include, but are not necessarily limited to, the following: Rationale for the
method of procurement, selection of contract type, contractor selection or rejection, and the
basis for the contract price."
2 CFR 180.300 states:
"When you enter into a covered transaction with another person at the next lower tier, you must
verify that the person with whom you intend to do business is not excluded or disqualified. You
do this by:
(a) Checking the SAM Exclusions; or
(b) Collecting a certification from that person; or
(c) Adding a clause or condition to the covered transaction with that person."
Cause
Management of the School Corporation had not established an effective system of internal controls
that would have ensured reviews of suspension and debarment statuses occurred for vendors. The School
Corporation did not verify whether or not vendors were suspended or debarred prior to entering into an
agreement with that vendor.
INDIANA STATE BOARD OF ACCOUNTS
19
WES-DEL COMMUNITY SCHOOL CORPORATION
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
(Continued)
Effect
The failure to establish an effective internal control system placed the School Corporation in noncompliance
with the grant agreement and the Procurement and Suspension and Debarment compliance
requirement.
Questioned Costs
There were no questioned costs identified.
Recommendation
We recommended the School Corporation should develop policies and procedures to verify the
status of vendors for federal programs and retain documentation of verification of suspension and
debarment reviews performed.
Views of Responsible Officials
For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-003
Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment
Federal Agency: Department of Agriculture
Federal Programs: School Breakfast Program, National School Lunch Program,
Summer Food Service Program for Children
Assistance Listings Numbers: 10.553, 10.555, 10.559
Federal Award Numbers and Years (or Other Identifying Numbers): FY2022-23, FY2023-24
Pass-Through Entity: Indiana Department of Education
Compliance Requirement: Procurement and Suspension and Debarment
Audit Findings: Material Weakness, Other Matters
Condition and Context
An effective internal control system, which would include segregation of duties, was not in place at
the School Corporation in order to ensure compliance with requirements related to the grant agreement
and the following compliance requirement: Procurement and Suspension and Debarment.
INDIANA STATE BOARD OF ACCOUNTS
18
WES-DEL COMMUNITY SCHOOL CORPORATION
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
(Continued)
Suspension and Debarment
The School Corporation did not have effective internal controls in place to ensure contracted
vendors were not suspended or debarred or otherwise excluded from participation in federal
award programs. The School Corporation could not provide evidence the suspension and
debarment status of one vendor was reviewed during the engagement period.
The lack of internal controls and noncompliance were systemic issues throughout the audit period.
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). . . ."
2 CFR 200.318(i) states:
"The non-Federal entity must maintain records sufficient to detail the history of procurement.
These records will include, but are not necessarily limited to, the following: Rationale for the
method of procurement, selection of contract type, contractor selection or rejection, and the
basis for the contract price."
2 CFR 180.300 states:
"When you enter into a covered transaction with another person at the next lower tier, you must
verify that the person with whom you intend to do business is not excluded or disqualified. You
do this by:
(a) Checking the SAM Exclusions; or
(b) Collecting a certification from that person; or
(c) Adding a clause or condition to the covered transaction with that person."
Cause
Management of the School Corporation had not established an effective system of internal controls
that would have ensured reviews of suspension and debarment statuses occurred for vendors. The School
Corporation did not verify whether or not vendors were suspended or debarred prior to entering into an
agreement with that vendor.
INDIANA STATE BOARD OF ACCOUNTS
19
WES-DEL COMMUNITY SCHOOL CORPORATION
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
(Continued)
Effect
The failure to establish an effective internal control system placed the School Corporation in noncompliance
with the grant agreement and the Procurement and Suspension and Debarment compliance
requirement.
Questioned Costs
There were no questioned costs identified.
Recommendation
We recommended the School Corporation should develop policies and procedures to verify the
status of vendors for federal programs and retain documentation of verification of suspension and
debarment reviews performed.
Views of Responsible Officials
For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-004
Subject: Title I Grants to Local Educational Agencies - Special
Tests and Provisions - Assessment System Security
Federal Agency: Department of Education
Federal Program: Title I Grants to Local Educational Agencies
Assistance Listings Number: 84.010
Federal Award Numbers and Years (or Other Identifying Numbers): S010A210014, S010A220014,
S010A230014
Pass-Through Entity: Indiana Department of Education
Compliance Requirement: Special Tests and Provisions - Assessment System Security
Audit Findings: Material Weakness, Other Matters
Condition and Context
An effective internal control system, which would include segregation of duties, was not in place at
the School Corporation in order to ensure compliance with requirements related to the grant agreement
and the following compliance requirement: Special Tests and Provisions - Assessment System Security.
The state educational agencies (SEA), in consultation with the local educational agencies (LEA),
are required to establish and maintain an assessment security system that is valid, reliable, and consistent
with relevant professional and technical standards. Within their assessment system, the SEAs must have
policies and procedures to maintain test security measures and ensure that the LEAs implement those
policies and procedures. As such, the Indiana Department of Education created and published the Indiana
Assessments Policy Manual.
As a part of the assessment security, any individual who administers, handles, or has access to
secure test materials at the school or school corporation shall complete assessment training and sign a
testing security and integrity statement that remains on file in the appropriate building-level office each year.
Everyone who is required to sign the testing integrity agreement shall sign the form by an established date.
INDIANA STATE BOARD OF ACCOUNTS
20
WES-DEL COMMUNITY SCHOOL CORPORATION
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
(Continued)
The School Corporation had a process to provide assessment system security training and to
ensure each employee that attended training signed the agreement indicating training was received.
However, documentation was not retained for audit that would provide evidence that training occurred
during fiscal year 2022-2023. Documentation was provided for audit for 2023-2024.
The lack of internal controls and noncompliance were isolated to 2022-2023.
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). . . ."
511 IAC 5-5-5(b) states: "Any individual who administers, handles, or has access to secure test
materials at the school or school corporation shall complete assessment training and sign a testing security
and integrity agreement to remain on file in the appropriate building-level office each year."
Cause
Management of the School Corporation had not established an effective system of internal controls
that would have ensured required staff received training on the Assessment System Security and evidence
of the trainings were retained for audit. Management did not retain documentation for the audit that would
have provided evidence that it had properly held training for staff on the Assessment System Security.
Effect
The failure to establish an effective internal control system placed the School Corporation in noncompliance
with the grant agreement and the Special Tests and Provisions - Assessment System Security
compliance requirement.
Questioned Costs
There were no questioned costs identified.
Recommendation
We recommended that the School should develop policies and procedures to provide training to
required personnel and to retain documentation of training provided for the Assessment System Security.
Views of Responsible Officials
For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-004
Subject: Title I Grants to Local Educational Agencies - Special
Tests and Provisions - Assessment System Security
Federal Agency: Department of Education
Federal Program: Title I Grants to Local Educational Agencies
Assistance Listings Number: 84.010
Federal Award Numbers and Years (or Other Identifying Numbers): S010A210014, S010A220014,
S010A230014
Pass-Through Entity: Indiana Department of Education
Compliance Requirement: Special Tests and Provisions - Assessment System Security
Audit Findings: Material Weakness, Other Matters
Condition and Context
An effective internal control system, which would include segregation of duties, was not in place at
the School Corporation in order to ensure compliance with requirements related to the grant agreement
and the following compliance requirement: Special Tests and Provisions - Assessment System Security.
The state educational agencies (SEA), in consultation with the local educational agencies (LEA),
are required to establish and maintain an assessment security system that is valid, reliable, and consistent
with relevant professional and technical standards. Within their assessment system, the SEAs must have
policies and procedures to maintain test security measures and ensure that the LEAs implement those
policies and procedures. As such, the Indiana Department of Education created and published the Indiana
Assessments Policy Manual.
As a part of the assessment security, any individual who administers, handles, or has access to
secure test materials at the school or school corporation shall complete assessment training and sign a
testing security and integrity statement that remains on file in the appropriate building-level office each year.
Everyone who is required to sign the testing integrity agreement shall sign the form by an established date.
INDIANA STATE BOARD OF ACCOUNTS
20
WES-DEL COMMUNITY SCHOOL CORPORATION
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
(Continued)
The School Corporation had a process to provide assessment system security training and to
ensure each employee that attended training signed the agreement indicating training was received.
However, documentation was not retained for audit that would provide evidence that training occurred
during fiscal year 2022-2023. Documentation was provided for audit for 2023-2024.
The lack of internal controls and noncompliance were isolated to 2022-2023.
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). . . ."
511 IAC 5-5-5(b) states: "Any individual who administers, handles, or has access to secure test
materials at the school or school corporation shall complete assessment training and sign a testing security
and integrity agreement to remain on file in the appropriate building-level office each year."
Cause
Management of the School Corporation had not established an effective system of internal controls
that would have ensured required staff received training on the Assessment System Security and evidence
of the trainings were retained for audit. Management did not retain documentation for the audit that would
have provided evidence that it had properly held training for staff on the Assessment System Security.
Effect
The failure to establish an effective internal control system placed the School Corporation in noncompliance
with the grant agreement and the Special Tests and Provisions - Assessment System Security
compliance requirement.
Questioned Costs
There were no questioned costs identified.
Recommendation
We recommended that the School should develop policies and procedures to provide training to
required personnel and to retain documentation of training provided for the Assessment System Security.
Views of Responsible Officials
For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.