Audit 394138

Criteria: Per 7 CFR Section 210.21(d), "All food solicitations should include terms that require contractors to respond with prices and award contracts to responsive bidders and offerors to supply domestic foods and food products that comply with Buy American." Condition: The District does not include the Buy American provision in their food solicitations. Questioned Costs: None. Context: Total expenditures for the Child Nutrition Cluster were $212,203 for the year ended June 30, 2025. Effect: The District is not in compliance with 7 CFR Section 210.21(d). Cause: The District was not aware this language was required in their solicitations. Recommendation: We recommend that all food solicitation include the proper language to ensure that food products comply with the Buy American provision. Management's Response: We will ensure this language is included in all food solicitations going forward.

Criteria: For internal controls over reporting, the daily meal counts submitted to the Illinois State Board of Education should be reviewed by a responsible official for accuracy prior to submission. Condition: Meal counts are submitted to the Illinois State Board of Education without review for accuracy by a responsible official. As a result we noted snack counts were not correctly reported to the Illinois State Board of Education for the three months tested by the auditor. Questioned Costs: Known Questioned Costs are $849. Projected Questioned Costs are $3,429. Context: Total revenues for the Child Nutrition Cluster were $212,203 for the year ended June 30, 2025. Effect: Increased risk that inaccurate counts could be submitted to the Illinois State Board of Education, leading to inaccurate grant funds received. Cause: The Food Service Director was unaware that a responsible official should be reviewing the meal count reports before submission to ensure accuracy. Recommendation: We recommend the District expand their internal controls to require a responsible official to review the daily meal count reports for accuracy prior to submission of the reports to the Illinois State Board of Education. Management's Response: Daily meal counts will be reviewed by the administration on a monthly basis.

Criteria: Per Title 2 CFR 200.512(d), "the data collection form must be submitted within the earlier of 30 calendar days after receipt of the auditor's report, or nine months after the end of the audit period. Condition: The District did not file their Data Collection form on time. The 2024 Data Collection Form was not filed until July 15, 2025. Questioned Costs: None. Context: The Data Collection Form must be submitted to the Federal Audit Clearinghouse in a timely manner. Effect: The District is not in compliance with the Single Audit Act of 1984 and Title 2 U.S. Code of Federal Regulations (CFR) Part 200. Cause: The District requested assistance from the auditing firm to upload the required form with oversight by the District. The submission was overlooked after the audit was completed. Recommendation: We recommend that all required filings be submitted timely according to the Single Audit Act of 1984 and Title 2 U.S. Code of Federal Regulations guidelines. Management's Response: The auditors discussed the issue with the District. A new checklist will be used with audit completion to ensure timely submission for the 2026 fiscal year.

Criteria: According to 2 CFR Section 180.300, when a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity is not suspended, debarred or otherwise excluded. Condition: The District had transactions in excess of $25,000 with three vendors in which they did not verify that the vendor is not suspended, debarred or otherwise excluded. Questioned Costs: None. Context: Payments to the three vendors totaled $459,201 for the year ended June 30, 2025. Effect: The District was at risk of making material payments to a vendor who is not allowed to do business with the federal government. There was no noncompliance, but there was no internal control in place to prevent noncompliance. Cause: The District was not aware of this requirement. Recommendation: We recommend the District check the Excluded Parties List System or collect certifications from the entity for any vendor in which the District expects to spend more than $25,000 of federal grant funds for the year. Management's Response: We were not aware of this requirement, but we will ensure that we comply going forward.

Criteria: Under 34 CFR 300.203, as a condition of receiving funds uner Part B of the Individual with Disabilities Education Act (IDEA), a local education agency (LEA) must budget, for the education of children with disabilities, at least the same amount from state and local funds as expended in the preceding fiscal year under the Eligibility Standard. Condition: For the fiscal year ended June 30, 2025, the District's budgeted expenditures for the education of children with disabilities from state and local funds were $628,704, which is $189,818 less than the $818,522 spent in the prior fiscal year. The District did not meet any of the allowable exceptions to the Maintenance of Effort requirements as outlined in 34 CFR 300.204 and 300.205. Questioned Costs: None. Context: Total expenditures for the Special Education Cluster were $245,474 for the year ended June 30, 2025. Effect: The District failed to meet the Maintenance of Effort requirement resulting in noncompliance with federal regulations for the Eligibility Standard. Cause: The District was unaware of this compliance requirement. Recommendation: We recommend the District implement procedures to monitor the Maintenance of Effort compliance throughout the year, including during the budgeting process. Management's Response: We are now aware of the compliance requirement and will monitor the Maintenance of Effort compliance under the Eligibility Standard going forward.

Criteria: Uniform Guidance requires policies related to cash management, cost allowability, procurement, and conflict of interest provisions, along with appropriate financial management systems and internal controls over federal awards to safeguard federal funds. Condition: The District did not have written policies and procedures over any of the components of grant administration. Questioned Costs: None. Context: Total federal grants expended during the fiscal year ended June 30, 2025 was $782,363. Effect: There are no written policies in place to prevent the misuse of federal funds. Cause: The District was not aware of this requirement. Recommendation: The District needs to develop written policies and procedures related to cash management, cost allowability, procurement, and conflict of interest provisions for federal funds it receives. Management's Response: We will complete and adopt appropriate policies as soon as possible.