Audit 47540

FY End
2022-06-30
Total Expended
$1.03M
Findings
24
Programs
19
Year: 2022 Accepted: 2022-11-06

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
52398 2022-003 Material Weakness - I
52399 2022-004 Material Weakness - N
52400 2022-003 Material Weakness - I
52401 2022-004 Material Weakness - N
52402 2022-003 Material Weakness - I
52403 2022-004 Material Weakness - N
52404 2022-003 Material Weakness - I
52405 2022-004 Material Weakness - N
52406 2022-003 Material Weakness - I
52407 2022-004 Material Weakness - N
52408 2022-003 Material Weakness - I
52409 2022-004 Material Weakness - N
628840 2022-003 Material Weakness - I
628841 2022-004 Material Weakness - N
628842 2022-003 Material Weakness - I
628843 2022-004 Material Weakness - N
628844 2022-003 Material Weakness - I
628845 2022-004 Material Weakness - N
628846 2022-003 Material Weakness - I
628847 2022-004 Material Weakness - N
628848 2022-003 Material Weakness - I
628849 2022-004 Material Weakness - N
628850 2022-003 Material Weakness - I
628851 2022-004 Material Weakness - N

Contacts

Name Title Type
NWKWGSKY1FB9 Angela Simmons-Kenser Auditee
3097858054 Mia Frommelt Auditor
No contacts on file

Notes to SEFA

Accounting Policies: Note 1. Basis of PresentationThe accompanying schedule of expenditures of federal awards (the schedule) includes the federal grantactivity of Fulton County Community Unit School District No. 3 under programs of the federal governmentfor the year ended June 30, 2022. The information in this schedule is presented in accordance with therequirements 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 schedulepresents only a selected portion of the operations of Fulton County Community Unit School District No. 3,it is not intended to and does not present the financial position, changes in net position or cash flows ofFulton County Community Unit School District No. 3.Note 2. Summary of Significant Accounting PoliciesExpenditures reported on the schedule are reported on the cash basis of accounting which is a basis ofaccounting other than accounting principles generally accepted in the United States of America.Accordingly, revenue is recognized and recorded in the account when cash is received. In the samemanner, expenditures are recognized and recorded upon the disbursement of cash. The cash basis ofaccounting does not give effect to accounts receivable, accounts payable and accrued items. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate.

Finding Details

Finding: The District does not have a process to ensure compliance with suspension and debarment rules for vendors within the federal program. Criteria: The April 2022 Office of Management and Budget Compliance Supplement states the following for Compliance Requirements-Suspension and Debarment: ?Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220?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 or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov/HOME, (2) collecting a certification from the entity or, (3) adding a clause or condition to the covered transaction with that entity.? The Illinois State Board of Education states the following under General Procurement-All Programs, Contract Certification Forms: ?The following certification forms must be included with all solicitations, contracts, and/or renewal agreements as described below. The forms must be signed by each bidder/contractor as indicated.? The forms include the Certification Regarding Debarment, Suspension, Ineligibility, and Voluntary Exclusion - Lower Tier Covered Transactions (85-34) Condition: The District participates in a purchasing cooperative for the program. The cooperative issues a request for proposal each April to select the prime vendor for the next school year. The request for proposal does not require the vendors responding to the request to provide a certificate of suspension and debarment. The cooperative does not maintain documentation for a vendor search within the SAM database as an alternative test. Cause: The District has outsourced the prime vendor procurement function to the cooperative and does not monitor the cooperative?s compliance with suspension and debarment rules as established by the Illinois State Board of Education and the Office of Management and Budget.Effect: The District does not have adequate documentation to ensure compliance with federal requirements regarding suspension and debarment. The District could enter into a transaction with a suspended or debarred party. Questioned Costs: $0 Context: The District expended approximately $52,000 with the prime vendor for fiscal year 2022. Total program non-payroll expenditures were $64,000. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend the District require the cooperative to request certification regarding suspension and debarment with each request for proposal issued. We recommend the District require the certification to be provided to them and maintained by the prime vendor and any vendor the District incurs $25,000 or more in a federal program. Response and Corrective Action Plan: The District will require the cooperative to obtain the certification regarding suspension and debarment from vendors as outlined by the Illinois State Board of Education with each request for proposal the cooperative issues. Person Responsible: Jodee Mathis.
Finding: The District does not have a process to ensure compliance with verification of free and reducedprice applications. Criteria: The April 2022 Office of Management and Budget Compliance Supplement states the following for Compliance Requirements-Verification of Free and Reduce- Price Applications: ?By November 15th of each school year, the LEA?must verify the current free and reduced-price eligibility of households selected from a sample of applications that is has approved for free and reduced-price meals.? The Illinois State Board of Education issued the following in September 2021, ?The U.S. Department of Agriculture is requiring all School Nutrition Program sponsors who received and approved Household Eligibility Applications between July 1 and October 1, 2021, to conduct Verification for School Year 2021- 2022?.For Verification, School Food Authorities (SFAs) are required to verify income for a small percentage of households approved for free or reduced-price meals each school year.? Condition: The District selected an application to verify from a pile of all applications. The application selected for verification procedures was not approved for free or reduced-price meals and was the personal application of the employee performing the verification procedures. Error-prone applications were not selected. The population of applications and data submitted to the state of Illinois was from a manual count rather than the point-of-sale system. 76 Fulton County Community Unit School District #3 Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Cause: The District did not use the food service software to randomly generate the list of applications to be verified. The District manually selected an application without consideration to the population or appearance of conflict of interest. Effect: The District did not perform verification procedures on an application that was approved for free or reduced-price meals. Questioned Costs: $0 Context: The District reported twenty-three applications for free or reduced-price meal benefits, two applications as error prone income applications, and one application to be tested on the Verification Summary Report submitted to the state of Illinois. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend the District use the food service point of sale system software to generate reports to complete the Verification Summary Report and to randomly generate the error prone application to be tested through verification procedures. We recommend the District require documentation of supervisory review of all verification reports, procedures, and conclusions. The supervisor should sign the report prior to submission and should sign the conclusion form of each verified application indicating review and approval. Response and Corrective Action Plan: The District will require the food service software to be used for verification data and selection of applications. The District will require documented supervisory approval of verification conclusions and reports submitted to the state of Illinois. Person Responsible: Jodee Mathis
Finding: The District does not have a process to ensure compliance with suspension and debarment rules for vendors within the federal program. Criteria: The April 2022 Office of Management and Budget Compliance Supplement states the following for Compliance Requirements-Suspension and Debarment: ?Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220?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 or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov/HOME, (2) collecting a certification from the entity or, (3) adding a clause or condition to the covered transaction with that entity.? The Illinois State Board of Education states the following under General Procurement-All Programs, Contract Certification Forms: ?The following certification forms must be included with all solicitations, contracts, and/or renewal agreements as described below. The forms must be signed by each bidder/contractor as indicated.? The forms include the Certification Regarding Debarment, Suspension, Ineligibility, and Voluntary Exclusion - Lower Tier Covered Transactions (85-34) Condition: The District participates in a purchasing cooperative for the program. The cooperative issues a request for proposal each April to select the prime vendor for the next school year. The request for proposal does not require the vendors responding to the request to provide a certificate of suspension and debarment. The cooperative does not maintain documentation for a vendor search within the SAM database as an alternative test. Cause: The District has outsourced the prime vendor procurement function to the cooperative and does not monitor the cooperative?s compliance with suspension and debarment rules as established by the Illinois State Board of Education and the Office of Management and Budget.Effect: The District does not have adequate documentation to ensure compliance with federal requirements regarding suspension and debarment. The District could enter into a transaction with a suspended or debarred party. Questioned Costs: $0 Context: The District expended approximately $52,000 with the prime vendor for fiscal year 2022. Total program non-payroll expenditures were $64,000. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend the District require the cooperative to request certification regarding suspension and debarment with each request for proposal issued. We recommend the District require the certification to be provided to them and maintained by the prime vendor and any vendor the District incurs $25,000 or more in a federal program. Response and Corrective Action Plan: The District will require the cooperative to obtain the certification regarding suspension and debarment from vendors as outlined by the Illinois State Board of Education with each request for proposal the cooperative issues. Person Responsible: Jodee Mathis.
Finding: The District does not have a process to ensure compliance with verification of free and reducedprice applications. Criteria: The April 2022 Office of Management and Budget Compliance Supplement states the following for Compliance Requirements-Verification of Free and Reduce- Price Applications: ?By November 15th of each school year, the LEA?must verify the current free and reduced-price eligibility of households selected from a sample of applications that is has approved for free and reduced-price meals.? The Illinois State Board of Education issued the following in September 2021, ?The U.S. Department of Agriculture is requiring all School Nutrition Program sponsors who received and approved Household Eligibility Applications between July 1 and October 1, 2021, to conduct Verification for School Year 2021- 2022?.For Verification, School Food Authorities (SFAs) are required to verify income for a small percentage of households approved for free or reduced-price meals each school year.? Condition: The District selected an application to verify from a pile of all applications. The application selected for verification procedures was not approved for free or reduced-price meals and was the personal application of the employee performing the verification procedures. Error-prone applications were not selected. The population of applications and data submitted to the state of Illinois was from a manual count rather than the point-of-sale system. 76 Fulton County Community Unit School District #3 Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Cause: The District did not use the food service software to randomly generate the list of applications to be verified. The District manually selected an application without consideration to the population or appearance of conflict of interest. Effect: The District did not perform verification procedures on an application that was approved for free or reduced-price meals. Questioned Costs: $0 Context: The District reported twenty-three applications for free or reduced-price meal benefits, two applications as error prone income applications, and one application to be tested on the Verification Summary Report submitted to the state of Illinois. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend the District use the food service point of sale system software to generate reports to complete the Verification Summary Report and to randomly generate the error prone application to be tested through verification procedures. We recommend the District require documentation of supervisory review of all verification reports, procedures, and conclusions. The supervisor should sign the report prior to submission and should sign the conclusion form of each verified application indicating review and approval. Response and Corrective Action Plan: The District will require the food service software to be used for verification data and selection of applications. The District will require documented supervisory approval of verification conclusions and reports submitted to the state of Illinois. Person Responsible: Jodee Mathis
Finding: The District does not have a process to ensure compliance with suspension and debarment rules for vendors within the federal program. Criteria: The April 2022 Office of Management and Budget Compliance Supplement states the following for Compliance Requirements-Suspension and Debarment: ?Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220?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 or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov/HOME, (2) collecting a certification from the entity or, (3) adding a clause or condition to the covered transaction with that entity.? The Illinois State Board of Education states the following under General Procurement-All Programs, Contract Certification Forms: ?The following certification forms must be included with all solicitations, contracts, and/or renewal agreements as described below. The forms must be signed by each bidder/contractor as indicated.? The forms include the Certification Regarding Debarment, Suspension, Ineligibility, and Voluntary Exclusion - Lower Tier Covered Transactions (85-34) Condition: The District participates in a purchasing cooperative for the program. The cooperative issues a request for proposal each April to select the prime vendor for the next school year. The request for proposal does not require the vendors responding to the request to provide a certificate of suspension and debarment. The cooperative does not maintain documentation for a vendor search within the SAM database as an alternative test. Cause: The District has outsourced the prime vendor procurement function to the cooperative and does not monitor the cooperative?s compliance with suspension and debarment rules as established by the Illinois State Board of Education and the Office of Management and Budget.Effect: The District does not have adequate documentation to ensure compliance with federal requirements regarding suspension and debarment. The District could enter into a transaction with a suspended or debarred party. Questioned Costs: $0 Context: The District expended approximately $52,000 with the prime vendor for fiscal year 2022. Total program non-payroll expenditures were $64,000. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend the District require the cooperative to request certification regarding suspension and debarment with each request for proposal issued. We recommend the District require the certification to be provided to them and maintained by the prime vendor and any vendor the District incurs $25,000 or more in a federal program. Response and Corrective Action Plan: The District will require the cooperative to obtain the certification regarding suspension and debarment from vendors as outlined by the Illinois State Board of Education with each request for proposal the cooperative issues. Person Responsible: Jodee Mathis.
Finding: The District does not have a process to ensure compliance with verification of free and reducedprice applications. Criteria: The April 2022 Office of Management and Budget Compliance Supplement states the following for Compliance Requirements-Verification of Free and Reduce- Price Applications: ?By November 15th of each school year, the LEA?must verify the current free and reduced-price eligibility of households selected from a sample of applications that is has approved for free and reduced-price meals.? The Illinois State Board of Education issued the following in September 2021, ?The U.S. Department of Agriculture is requiring all School Nutrition Program sponsors who received and approved Household Eligibility Applications between July 1 and October 1, 2021, to conduct Verification for School Year 2021- 2022?.For Verification, School Food Authorities (SFAs) are required to verify income for a small percentage of households approved for free or reduced-price meals each school year.? Condition: The District selected an application to verify from a pile of all applications. The application selected for verification procedures was not approved for free or reduced-price meals and was the personal application of the employee performing the verification procedures. Error-prone applications were not selected. The population of applications and data submitted to the state of Illinois was from a manual count rather than the point-of-sale system. 76 Fulton County Community Unit School District #3 Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Cause: The District did not use the food service software to randomly generate the list of applications to be verified. The District manually selected an application without consideration to the population or appearance of conflict of interest. Effect: The District did not perform verification procedures on an application that was approved for free or reduced-price meals. Questioned Costs: $0 Context: The District reported twenty-three applications for free or reduced-price meal benefits, two applications as error prone income applications, and one application to be tested on the Verification Summary Report submitted to the state of Illinois. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend the District use the food service point of sale system software to generate reports to complete the Verification Summary Report and to randomly generate the error prone application to be tested through verification procedures. We recommend the District require documentation of supervisory review of all verification reports, procedures, and conclusions. The supervisor should sign the report prior to submission and should sign the conclusion form of each verified application indicating review and approval. Response and Corrective Action Plan: The District will require the food service software to be used for verification data and selection of applications. The District will require documented supervisory approval of verification conclusions and reports submitted to the state of Illinois. Person Responsible: Jodee Mathis
Finding: The District does not have a process to ensure compliance with suspension and debarment rules for vendors within the federal program. Criteria: The April 2022 Office of Management and Budget Compliance Supplement states the following for Compliance Requirements-Suspension and Debarment: ?Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220?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 or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov/HOME, (2) collecting a certification from the entity or, (3) adding a clause or condition to the covered transaction with that entity.? The Illinois State Board of Education states the following under General Procurement-All Programs, Contract Certification Forms: ?The following certification forms must be included with all solicitations, contracts, and/or renewal agreements as described below. The forms must be signed by each bidder/contractor as indicated.? The forms include the Certification Regarding Debarment, Suspension, Ineligibility, and Voluntary Exclusion - Lower Tier Covered Transactions (85-34) Condition: The District participates in a purchasing cooperative for the program. The cooperative issues a request for proposal each April to select the prime vendor for the next school year. The request for proposal does not require the vendors responding to the request to provide a certificate of suspension and debarment. The cooperative does not maintain documentation for a vendor search within the SAM database as an alternative test. Cause: The District has outsourced the prime vendor procurement function to the cooperative and does not monitor the cooperative?s compliance with suspension and debarment rules as established by the Illinois State Board of Education and the Office of Management and Budget.Effect: The District does not have adequate documentation to ensure compliance with federal requirements regarding suspension and debarment. The District could enter into a transaction with a suspended or debarred party. Questioned Costs: $0 Context: The District expended approximately $52,000 with the prime vendor for fiscal year 2022. Total program non-payroll expenditures were $64,000. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend the District require the cooperative to request certification regarding suspension and debarment with each request for proposal issued. We recommend the District require the certification to be provided to them and maintained by the prime vendor and any vendor the District incurs $25,000 or more in a federal program. Response and Corrective Action Plan: The District will require the cooperative to obtain the certification regarding suspension and debarment from vendors as outlined by the Illinois State Board of Education with each request for proposal the cooperative issues. Person Responsible: Jodee Mathis.
Finding: The District does not have a process to ensure compliance with verification of free and reducedprice applications. Criteria: The April 2022 Office of Management and Budget Compliance Supplement states the following for Compliance Requirements-Verification of Free and Reduce- Price Applications: ?By November 15th of each school year, the LEA?must verify the current free and reduced-price eligibility of households selected from a sample of applications that is has approved for free and reduced-price meals.? The Illinois State Board of Education issued the following in September 2021, ?The U.S. Department of Agriculture is requiring all School Nutrition Program sponsors who received and approved Household Eligibility Applications between July 1 and October 1, 2021, to conduct Verification for School Year 2021- 2022?.For Verification, School Food Authorities (SFAs) are required to verify income for a small percentage of households approved for free or reduced-price meals each school year.? Condition: The District selected an application to verify from a pile of all applications. The application selected for verification procedures was not approved for free or reduced-price meals and was the personal application of the employee performing the verification procedures. Error-prone applications were not selected. The population of applications and data submitted to the state of Illinois was from a manual count rather than the point-of-sale system. 76 Fulton County Community Unit School District #3 Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Cause: The District did not use the food service software to randomly generate the list of applications to be verified. The District manually selected an application without consideration to the population or appearance of conflict of interest. Effect: The District did not perform verification procedures on an application that was approved for free or reduced-price meals. Questioned Costs: $0 Context: The District reported twenty-three applications for free or reduced-price meal benefits, two applications as error prone income applications, and one application to be tested on the Verification Summary Report submitted to the state of Illinois. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend the District use the food service point of sale system software to generate reports to complete the Verification Summary Report and to randomly generate the error prone application to be tested through verification procedures. We recommend the District require documentation of supervisory review of all verification reports, procedures, and conclusions. The supervisor should sign the report prior to submission and should sign the conclusion form of each verified application indicating review and approval. Response and Corrective Action Plan: The District will require the food service software to be used for verification data and selection of applications. The District will require documented supervisory approval of verification conclusions and reports submitted to the state of Illinois. Person Responsible: Jodee Mathis
Finding: The District does not have a process to ensure compliance with suspension and debarment rules for vendors within the federal program. Criteria: The April 2022 Office of Management and Budget Compliance Supplement states the following for Compliance Requirements-Suspension and Debarment: ?Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220?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 or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov/HOME, (2) collecting a certification from the entity or, (3) adding a clause or condition to the covered transaction with that entity.? The Illinois State Board of Education states the following under General Procurement-All Programs, Contract Certification Forms: ?The following certification forms must be included with all solicitations, contracts, and/or renewal agreements as described below. The forms must be signed by each bidder/contractor as indicated.? The forms include the Certification Regarding Debarment, Suspension, Ineligibility, and Voluntary Exclusion - Lower Tier Covered Transactions (85-34) Condition: The District participates in a purchasing cooperative for the program. The cooperative issues a request for proposal each April to select the prime vendor for the next school year. The request for proposal does not require the vendors responding to the request to provide a certificate of suspension and debarment. The cooperative does not maintain documentation for a vendor search within the SAM database as an alternative test. Cause: The District has outsourced the prime vendor procurement function to the cooperative and does not monitor the cooperative?s compliance with suspension and debarment rules as established by the Illinois State Board of Education and the Office of Management and Budget.Effect: The District does not have adequate documentation to ensure compliance with federal requirements regarding suspension and debarment. The District could enter into a transaction with a suspended or debarred party. Questioned Costs: $0 Context: The District expended approximately $52,000 with the prime vendor for fiscal year 2022. Total program non-payroll expenditures were $64,000. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend the District require the cooperative to request certification regarding suspension and debarment with each request for proposal issued. We recommend the District require the certification to be provided to them and maintained by the prime vendor and any vendor the District incurs $25,000 or more in a federal program. Response and Corrective Action Plan: The District will require the cooperative to obtain the certification regarding suspension and debarment from vendors as outlined by the Illinois State Board of Education with each request for proposal the cooperative issues. Person Responsible: Jodee Mathis.
Finding: The District does not have a process to ensure compliance with verification of free and reducedprice applications. Criteria: The April 2022 Office of Management and Budget Compliance Supplement states the following for Compliance Requirements-Verification of Free and Reduce- Price Applications: ?By November 15th of each school year, the LEA?must verify the current free and reduced-price eligibility of households selected from a sample of applications that is has approved for free and reduced-price meals.? The Illinois State Board of Education issued the following in September 2021, ?The U.S. Department of Agriculture is requiring all School Nutrition Program sponsors who received and approved Household Eligibility Applications between July 1 and October 1, 2021, to conduct Verification for School Year 2021- 2022?.For Verification, School Food Authorities (SFAs) are required to verify income for a small percentage of households approved for free or reduced-price meals each school year.? Condition: The District selected an application to verify from a pile of all applications. The application selected for verification procedures was not approved for free or reduced-price meals and was the personal application of the employee performing the verification procedures. Error-prone applications were not selected. The population of applications and data submitted to the state of Illinois was from a manual count rather than the point-of-sale system. 76 Fulton County Community Unit School District #3 Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Cause: The District did not use the food service software to randomly generate the list of applications to be verified. The District manually selected an application without consideration to the population or appearance of conflict of interest. Effect: The District did not perform verification procedures on an application that was approved for free or reduced-price meals. Questioned Costs: $0 Context: The District reported twenty-three applications for free or reduced-price meal benefits, two applications as error prone income applications, and one application to be tested on the Verification Summary Report submitted to the state of Illinois. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend the District use the food service point of sale system software to generate reports to complete the Verification Summary Report and to randomly generate the error prone application to be tested through verification procedures. We recommend the District require documentation of supervisory review of all verification reports, procedures, and conclusions. The supervisor should sign the report prior to submission and should sign the conclusion form of each verified application indicating review and approval. Response and Corrective Action Plan: The District will require the food service software to be used for verification data and selection of applications. The District will require documented supervisory approval of verification conclusions and reports submitted to the state of Illinois. Person Responsible: Jodee Mathis
Finding: The District does not have a process to ensure compliance with suspension and debarment rules for vendors within the federal program. Criteria: The April 2022 Office of Management and Budget Compliance Supplement states the following for Compliance Requirements-Suspension and Debarment: ?Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220?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 or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov/HOME, (2) collecting a certification from the entity or, (3) adding a clause or condition to the covered transaction with that entity.? The Illinois State Board of Education states the following under General Procurement-All Programs, Contract Certification Forms: ?The following certification forms must be included with all solicitations, contracts, and/or renewal agreements as described below. The forms must be signed by each bidder/contractor as indicated.? The forms include the Certification Regarding Debarment, Suspension, Ineligibility, and Voluntary Exclusion - Lower Tier Covered Transactions (85-34) Condition: The District participates in a purchasing cooperative for the program. The cooperative issues a request for proposal each April to select the prime vendor for the next school year. The request for proposal does not require the vendors responding to the request to provide a certificate of suspension and debarment. The cooperative does not maintain documentation for a vendor search within the SAM database as an alternative test. Cause: The District has outsourced the prime vendor procurement function to the cooperative and does not monitor the cooperative?s compliance with suspension and debarment rules as established by the Illinois State Board of Education and the Office of Management and Budget.Effect: The District does not have adequate documentation to ensure compliance with federal requirements regarding suspension and debarment. The District could enter into a transaction with a suspended or debarred party. Questioned Costs: $0 Context: The District expended approximately $52,000 with the prime vendor for fiscal year 2022. Total program non-payroll expenditures were $64,000. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend the District require the cooperative to request certification regarding suspension and debarment with each request for proposal issued. We recommend the District require the certification to be provided to them and maintained by the prime vendor and any vendor the District incurs $25,000 or more in a federal program. Response and Corrective Action Plan: The District will require the cooperative to obtain the certification regarding suspension and debarment from vendors as outlined by the Illinois State Board of Education with each request for proposal the cooperative issues. Person Responsible: Jodee Mathis.
Finding: The District does not have a process to ensure compliance with verification of free and reducedprice applications. Criteria: The April 2022 Office of Management and Budget Compliance Supplement states the following for Compliance Requirements-Verification of Free and Reduce- Price Applications: ?By November 15th of each school year, the LEA?must verify the current free and reduced-price eligibility of households selected from a sample of applications that is has approved for free and reduced-price meals.? The Illinois State Board of Education issued the following in September 2021, ?The U.S. Department of Agriculture is requiring all School Nutrition Program sponsors who received and approved Household Eligibility Applications between July 1 and October 1, 2021, to conduct Verification for School Year 2021- 2022?.For Verification, School Food Authorities (SFAs) are required to verify income for a small percentage of households approved for free or reduced-price meals each school year.? Condition: The District selected an application to verify from a pile of all applications. The application selected for verification procedures was not approved for free or reduced-price meals and was the personal application of the employee performing the verification procedures. Error-prone applications were not selected. The population of applications and data submitted to the state of Illinois was from a manual count rather than the point-of-sale system. 76 Fulton County Community Unit School District #3 Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Cause: The District did not use the food service software to randomly generate the list of applications to be verified. The District manually selected an application without consideration to the population or appearance of conflict of interest. Effect: The District did not perform verification procedures on an application that was approved for free or reduced-price meals. Questioned Costs: $0 Context: The District reported twenty-three applications for free or reduced-price meal benefits, two applications as error prone income applications, and one application to be tested on the Verification Summary Report submitted to the state of Illinois. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend the District use the food service point of sale system software to generate reports to complete the Verification Summary Report and to randomly generate the error prone application to be tested through verification procedures. We recommend the District require documentation of supervisory review of all verification reports, procedures, and conclusions. The supervisor should sign the report prior to submission and should sign the conclusion form of each verified application indicating review and approval. Response and Corrective Action Plan: The District will require the food service software to be used for verification data and selection of applications. The District will require documented supervisory approval of verification conclusions and reports submitted to the state of Illinois. Person Responsible: Jodee Mathis
Finding: The District does not have a process to ensure compliance with suspension and debarment rules for vendors within the federal program. Criteria: The April 2022 Office of Management and Budget Compliance Supplement states the following for Compliance Requirements-Suspension and Debarment: ?Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220?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 or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov/HOME, (2) collecting a certification from the entity or, (3) adding a clause or condition to the covered transaction with that entity.? The Illinois State Board of Education states the following under General Procurement-All Programs, Contract Certification Forms: ?The following certification forms must be included with all solicitations, contracts, and/or renewal agreements as described below. The forms must be signed by each bidder/contractor as indicated.? The forms include the Certification Regarding Debarment, Suspension, Ineligibility, and Voluntary Exclusion - Lower Tier Covered Transactions (85-34) Condition: The District participates in a purchasing cooperative for the program. The cooperative issues a request for proposal each April to select the prime vendor for the next school year. The request for proposal does not require the vendors responding to the request to provide a certificate of suspension and debarment. The cooperative does not maintain documentation for a vendor search within the SAM database as an alternative test. Cause: The District has outsourced the prime vendor procurement function to the cooperative and does not monitor the cooperative?s compliance with suspension and debarment rules as established by the Illinois State Board of Education and the Office of Management and Budget.Effect: The District does not have adequate documentation to ensure compliance with federal requirements regarding suspension and debarment. The District could enter into a transaction with a suspended or debarred party. Questioned Costs: $0 Context: The District expended approximately $52,000 with the prime vendor for fiscal year 2022. Total program non-payroll expenditures were $64,000. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend the District require the cooperative to request certification regarding suspension and debarment with each request for proposal issued. We recommend the District require the certification to be provided to them and maintained by the prime vendor and any vendor the District incurs $25,000 or more in a federal program. Response and Corrective Action Plan: The District will require the cooperative to obtain the certification regarding suspension and debarment from vendors as outlined by the Illinois State Board of Education with each request for proposal the cooperative issues. Person Responsible: Jodee Mathis.
Finding: The District does not have a process to ensure compliance with verification of free and reducedprice applications. Criteria: The April 2022 Office of Management and Budget Compliance Supplement states the following for Compliance Requirements-Verification of Free and Reduce- Price Applications: ?By November 15th of each school year, the LEA?must verify the current free and reduced-price eligibility of households selected from a sample of applications that is has approved for free and reduced-price meals.? The Illinois State Board of Education issued the following in September 2021, ?The U.S. Department of Agriculture is requiring all School Nutrition Program sponsors who received and approved Household Eligibility Applications between July 1 and October 1, 2021, to conduct Verification for School Year 2021- 2022?.For Verification, School Food Authorities (SFAs) are required to verify income for a small percentage of households approved for free or reduced-price meals each school year.? Condition: The District selected an application to verify from a pile of all applications. The application selected for verification procedures was not approved for free or reduced-price meals and was the personal application of the employee performing the verification procedures. Error-prone applications were not selected. The population of applications and data submitted to the state of Illinois was from a manual count rather than the point-of-sale system. 76 Fulton County Community Unit School District #3 Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Cause: The District did not use the food service software to randomly generate the list of applications to be verified. The District manually selected an application without consideration to the population or appearance of conflict of interest. Effect: The District did not perform verification procedures on an application that was approved for free or reduced-price meals. Questioned Costs: $0 Context: The District reported twenty-three applications for free or reduced-price meal benefits, two applications as error prone income applications, and one application to be tested on the Verification Summary Report submitted to the state of Illinois. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend the District use the food service point of sale system software to generate reports to complete the Verification Summary Report and to randomly generate the error prone application to be tested through verification procedures. We recommend the District require documentation of supervisory review of all verification reports, procedures, and conclusions. The supervisor should sign the report prior to submission and should sign the conclusion form of each verified application indicating review and approval. Response and Corrective Action Plan: The District will require the food service software to be used for verification data and selection of applications. The District will require documented supervisory approval of verification conclusions and reports submitted to the state of Illinois. Person Responsible: Jodee Mathis
Finding: The District does not have a process to ensure compliance with suspension and debarment rules for vendors within the federal program. Criteria: The April 2022 Office of Management and Budget Compliance Supplement states the following for Compliance Requirements-Suspension and Debarment: ?Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220?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 or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov/HOME, (2) collecting a certification from the entity or, (3) adding a clause or condition to the covered transaction with that entity.? The Illinois State Board of Education states the following under General Procurement-All Programs, Contract Certification Forms: ?The following certification forms must be included with all solicitations, contracts, and/or renewal agreements as described below. The forms must be signed by each bidder/contractor as indicated.? The forms include the Certification Regarding Debarment, Suspension, Ineligibility, and Voluntary Exclusion - Lower Tier Covered Transactions (85-34) Condition: The District participates in a purchasing cooperative for the program. The cooperative issues a request for proposal each April to select the prime vendor for the next school year. The request for proposal does not require the vendors responding to the request to provide a certificate of suspension and debarment. The cooperative does not maintain documentation for a vendor search within the SAM database as an alternative test. Cause: The District has outsourced the prime vendor procurement function to the cooperative and does not monitor the cooperative?s compliance with suspension and debarment rules as established by the Illinois State Board of Education and the Office of Management and Budget.Effect: The District does not have adequate documentation to ensure compliance with federal requirements regarding suspension and debarment. The District could enter into a transaction with a suspended or debarred party. Questioned Costs: $0 Context: The District expended approximately $52,000 with the prime vendor for fiscal year 2022. Total program non-payroll expenditures were $64,000. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend the District require the cooperative to request certification regarding suspension and debarment with each request for proposal issued. We recommend the District require the certification to be provided to them and maintained by the prime vendor and any vendor the District incurs $25,000 or more in a federal program. Response and Corrective Action Plan: The District will require the cooperative to obtain the certification regarding suspension and debarment from vendors as outlined by the Illinois State Board of Education with each request for proposal the cooperative issues. Person Responsible: Jodee Mathis.
Finding: The District does not have a process to ensure compliance with verification of free and reducedprice applications. Criteria: The April 2022 Office of Management and Budget Compliance Supplement states the following for Compliance Requirements-Verification of Free and Reduce- Price Applications: ?By November 15th of each school year, the LEA?must verify the current free and reduced-price eligibility of households selected from a sample of applications that is has approved for free and reduced-price meals.? The Illinois State Board of Education issued the following in September 2021, ?The U.S. Department of Agriculture is requiring all School Nutrition Program sponsors who received and approved Household Eligibility Applications between July 1 and October 1, 2021, to conduct Verification for School Year 2021- 2022?.For Verification, School Food Authorities (SFAs) are required to verify income for a small percentage of households approved for free or reduced-price meals each school year.? Condition: The District selected an application to verify from a pile of all applications. The application selected for verification procedures was not approved for free or reduced-price meals and was the personal application of the employee performing the verification procedures. Error-prone applications were not selected. The population of applications and data submitted to the state of Illinois was from a manual count rather than the point-of-sale system. 76 Fulton County Community Unit School District #3 Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Cause: The District did not use the food service software to randomly generate the list of applications to be verified. The District manually selected an application without consideration to the population or appearance of conflict of interest. Effect: The District did not perform verification procedures on an application that was approved for free or reduced-price meals. Questioned Costs: $0 Context: The District reported twenty-three applications for free or reduced-price meal benefits, two applications as error prone income applications, and one application to be tested on the Verification Summary Report submitted to the state of Illinois. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend the District use the food service point of sale system software to generate reports to complete the Verification Summary Report and to randomly generate the error prone application to be tested through verification procedures. We recommend the District require documentation of supervisory review of all verification reports, procedures, and conclusions. The supervisor should sign the report prior to submission and should sign the conclusion form of each verified application indicating review and approval. Response and Corrective Action Plan: The District will require the food service software to be used for verification data and selection of applications. The District will require documented supervisory approval of verification conclusions and reports submitted to the state of Illinois. Person Responsible: Jodee Mathis
Finding: The District does not have a process to ensure compliance with suspension and debarment rules for vendors within the federal program. Criteria: The April 2022 Office of Management and Budget Compliance Supplement states the following for Compliance Requirements-Suspension and Debarment: ?Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220?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 or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov/HOME, (2) collecting a certification from the entity or, (3) adding a clause or condition to the covered transaction with that entity.? The Illinois State Board of Education states the following under General Procurement-All Programs, Contract Certification Forms: ?The following certification forms must be included with all solicitations, contracts, and/or renewal agreements as described below. The forms must be signed by each bidder/contractor as indicated.? The forms include the Certification Regarding Debarment, Suspension, Ineligibility, and Voluntary Exclusion - Lower Tier Covered Transactions (85-34) Condition: The District participates in a purchasing cooperative for the program. The cooperative issues a request for proposal each April to select the prime vendor for the next school year. The request for proposal does not require the vendors responding to the request to provide a certificate of suspension and debarment. The cooperative does not maintain documentation for a vendor search within the SAM database as an alternative test. Cause: The District has outsourced the prime vendor procurement function to the cooperative and does not monitor the cooperative?s compliance with suspension and debarment rules as established by the Illinois State Board of Education and the Office of Management and Budget.Effect: The District does not have adequate documentation to ensure compliance with federal requirements regarding suspension and debarment. The District could enter into a transaction with a suspended or debarred party. Questioned Costs: $0 Context: The District expended approximately $52,000 with the prime vendor for fiscal year 2022. Total program non-payroll expenditures were $64,000. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend the District require the cooperative to request certification regarding suspension and debarment with each request for proposal issued. We recommend the District require the certification to be provided to them and maintained by the prime vendor and any vendor the District incurs $25,000 or more in a federal program. Response and Corrective Action Plan: The District will require the cooperative to obtain the certification regarding suspension and debarment from vendors as outlined by the Illinois State Board of Education with each request for proposal the cooperative issues. Person Responsible: Jodee Mathis.
Finding: The District does not have a process to ensure compliance with verification of free and reducedprice applications. Criteria: The April 2022 Office of Management and Budget Compliance Supplement states the following for Compliance Requirements-Verification of Free and Reduce- Price Applications: ?By November 15th of each school year, the LEA?must verify the current free and reduced-price eligibility of households selected from a sample of applications that is has approved for free and reduced-price meals.? The Illinois State Board of Education issued the following in September 2021, ?The U.S. Department of Agriculture is requiring all School Nutrition Program sponsors who received and approved Household Eligibility Applications between July 1 and October 1, 2021, to conduct Verification for School Year 2021- 2022?.For Verification, School Food Authorities (SFAs) are required to verify income for a small percentage of households approved for free or reduced-price meals each school year.? Condition: The District selected an application to verify from a pile of all applications. The application selected for verification procedures was not approved for free or reduced-price meals and was the personal application of the employee performing the verification procedures. Error-prone applications were not selected. The population of applications and data submitted to the state of Illinois was from a manual count rather than the point-of-sale system. 76 Fulton County Community Unit School District #3 Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Cause: The District did not use the food service software to randomly generate the list of applications to be verified. The District manually selected an application without consideration to the population or appearance of conflict of interest. Effect: The District did not perform verification procedures on an application that was approved for free or reduced-price meals. Questioned Costs: $0 Context: The District reported twenty-three applications for free or reduced-price meal benefits, two applications as error prone income applications, and one application to be tested on the Verification Summary Report submitted to the state of Illinois. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend the District use the food service point of sale system software to generate reports to complete the Verification Summary Report and to randomly generate the error prone application to be tested through verification procedures. We recommend the District require documentation of supervisory review of all verification reports, procedures, and conclusions. The supervisor should sign the report prior to submission and should sign the conclusion form of each verified application indicating review and approval. Response and Corrective Action Plan: The District will require the food service software to be used for verification data and selection of applications. The District will require documented supervisory approval of verification conclusions and reports submitted to the state of Illinois. Person Responsible: Jodee Mathis
Finding: The District does not have a process to ensure compliance with suspension and debarment rules for vendors within the federal program. Criteria: The April 2022 Office of Management and Budget Compliance Supplement states the following for Compliance Requirements-Suspension and Debarment: ?Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220?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 or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov/HOME, (2) collecting a certification from the entity or, (3) adding a clause or condition to the covered transaction with that entity.? The Illinois State Board of Education states the following under General Procurement-All Programs, Contract Certification Forms: ?The following certification forms must be included with all solicitations, contracts, and/or renewal agreements as described below. The forms must be signed by each bidder/contractor as indicated.? The forms include the Certification Regarding Debarment, Suspension, Ineligibility, and Voluntary Exclusion - Lower Tier Covered Transactions (85-34) Condition: The District participates in a purchasing cooperative for the program. The cooperative issues a request for proposal each April to select the prime vendor for the next school year. The request for proposal does not require the vendors responding to the request to provide a certificate of suspension and debarment. The cooperative does not maintain documentation for a vendor search within the SAM database as an alternative test. Cause: The District has outsourced the prime vendor procurement function to the cooperative and does not monitor the cooperative?s compliance with suspension and debarment rules as established by the Illinois State Board of Education and the Office of Management and Budget.Effect: The District does not have adequate documentation to ensure compliance with federal requirements regarding suspension and debarment. The District could enter into a transaction with a suspended or debarred party. Questioned Costs: $0 Context: The District expended approximately $52,000 with the prime vendor for fiscal year 2022. Total program non-payroll expenditures were $64,000. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend the District require the cooperative to request certification regarding suspension and debarment with each request for proposal issued. We recommend the District require the certification to be provided to them and maintained by the prime vendor and any vendor the District incurs $25,000 or more in a federal program. Response and Corrective Action Plan: The District will require the cooperative to obtain the certification regarding suspension and debarment from vendors as outlined by the Illinois State Board of Education with each request for proposal the cooperative issues. Person Responsible: Jodee Mathis.
Finding: The District does not have a process to ensure compliance with verification of free and reducedprice applications. Criteria: The April 2022 Office of Management and Budget Compliance Supplement states the following for Compliance Requirements-Verification of Free and Reduce- Price Applications: ?By November 15th of each school year, the LEA?must verify the current free and reduced-price eligibility of households selected from a sample of applications that is has approved for free and reduced-price meals.? The Illinois State Board of Education issued the following in September 2021, ?The U.S. Department of Agriculture is requiring all School Nutrition Program sponsors who received and approved Household Eligibility Applications between July 1 and October 1, 2021, to conduct Verification for School Year 2021- 2022?.For Verification, School Food Authorities (SFAs) are required to verify income for a small percentage of households approved for free or reduced-price meals each school year.? Condition: The District selected an application to verify from a pile of all applications. The application selected for verification procedures was not approved for free or reduced-price meals and was the personal application of the employee performing the verification procedures. Error-prone applications were not selected. The population of applications and data submitted to the state of Illinois was from a manual count rather than the point-of-sale system. 76 Fulton County Community Unit School District #3 Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Cause: The District did not use the food service software to randomly generate the list of applications to be verified. The District manually selected an application without consideration to the population or appearance of conflict of interest. Effect: The District did not perform verification procedures on an application that was approved for free or reduced-price meals. Questioned Costs: $0 Context: The District reported twenty-three applications for free or reduced-price meal benefits, two applications as error prone income applications, and one application to be tested on the Verification Summary Report submitted to the state of Illinois. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend the District use the food service point of sale system software to generate reports to complete the Verification Summary Report and to randomly generate the error prone application to be tested through verification procedures. We recommend the District require documentation of supervisory review of all verification reports, procedures, and conclusions. The supervisor should sign the report prior to submission and should sign the conclusion form of each verified application indicating review and approval. Response and Corrective Action Plan: The District will require the food service software to be used for verification data and selection of applications. The District will require documented supervisory approval of verification conclusions and reports submitted to the state of Illinois. Person Responsible: Jodee Mathis
Finding: The District does not have a process to ensure compliance with suspension and debarment rules for vendors within the federal program. Criteria: The April 2022 Office of Management and Budget Compliance Supplement states the following for Compliance Requirements-Suspension and Debarment: ?Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220?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 or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov/HOME, (2) collecting a certification from the entity or, (3) adding a clause or condition to the covered transaction with that entity.? The Illinois State Board of Education states the following under General Procurement-All Programs, Contract Certification Forms: ?The following certification forms must be included with all solicitations, contracts, and/or renewal agreements as described below. The forms must be signed by each bidder/contractor as indicated.? The forms include the Certification Regarding Debarment, Suspension, Ineligibility, and Voluntary Exclusion - Lower Tier Covered Transactions (85-34) Condition: The District participates in a purchasing cooperative for the program. The cooperative issues a request for proposal each April to select the prime vendor for the next school year. The request for proposal does not require the vendors responding to the request to provide a certificate of suspension and debarment. The cooperative does not maintain documentation for a vendor search within the SAM database as an alternative test. Cause: The District has outsourced the prime vendor procurement function to the cooperative and does not monitor the cooperative?s compliance with suspension and debarment rules as established by the Illinois State Board of Education and the Office of Management and Budget.Effect: The District does not have adequate documentation to ensure compliance with federal requirements regarding suspension and debarment. The District could enter into a transaction with a suspended or debarred party. Questioned Costs: $0 Context: The District expended approximately $52,000 with the prime vendor for fiscal year 2022. Total program non-payroll expenditures were $64,000. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend the District require the cooperative to request certification regarding suspension and debarment with each request for proposal issued. We recommend the District require the certification to be provided to them and maintained by the prime vendor and any vendor the District incurs $25,000 or more in a federal program. Response and Corrective Action Plan: The District will require the cooperative to obtain the certification regarding suspension and debarment from vendors as outlined by the Illinois State Board of Education with each request for proposal the cooperative issues. Person Responsible: Jodee Mathis.
Finding: The District does not have a process to ensure compliance with verification of free and reducedprice applications. Criteria: The April 2022 Office of Management and Budget Compliance Supplement states the following for Compliance Requirements-Verification of Free and Reduce- Price Applications: ?By November 15th of each school year, the LEA?must verify the current free and reduced-price eligibility of households selected from a sample of applications that is has approved for free and reduced-price meals.? The Illinois State Board of Education issued the following in September 2021, ?The U.S. Department of Agriculture is requiring all School Nutrition Program sponsors who received and approved Household Eligibility Applications between July 1 and October 1, 2021, to conduct Verification for School Year 2021- 2022?.For Verification, School Food Authorities (SFAs) are required to verify income for a small percentage of households approved for free or reduced-price meals each school year.? Condition: The District selected an application to verify from a pile of all applications. The application selected for verification procedures was not approved for free or reduced-price meals and was the personal application of the employee performing the verification procedures. Error-prone applications were not selected. The population of applications and data submitted to the state of Illinois was from a manual count rather than the point-of-sale system. 76 Fulton County Community Unit School District #3 Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Cause: The District did not use the food service software to randomly generate the list of applications to be verified. The District manually selected an application without consideration to the population or appearance of conflict of interest. Effect: The District did not perform verification procedures on an application that was approved for free or reduced-price meals. Questioned Costs: $0 Context: The District reported twenty-three applications for free or reduced-price meal benefits, two applications as error prone income applications, and one application to be tested on the Verification Summary Report submitted to the state of Illinois. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend the District use the food service point of sale system software to generate reports to complete the Verification Summary Report and to randomly generate the error prone application to be tested through verification procedures. We recommend the District require documentation of supervisory review of all verification reports, procedures, and conclusions. The supervisor should sign the report prior to submission and should sign the conclusion form of each verified application indicating review and approval. Response and Corrective Action Plan: The District will require the food service software to be used for verification data and selection of applications. The District will require documented supervisory approval of verification conclusions and reports submitted to the state of Illinois. Person Responsible: Jodee Mathis
Finding: The District does not have a process to ensure compliance with suspension and debarment rules for vendors within the federal program. Criteria: The April 2022 Office of Management and Budget Compliance Supplement states the following for Compliance Requirements-Suspension and Debarment: ?Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220?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 or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov/HOME, (2) collecting a certification from the entity or, (3) adding a clause or condition to the covered transaction with that entity.? The Illinois State Board of Education states the following under General Procurement-All Programs, Contract Certification Forms: ?The following certification forms must be included with all solicitations, contracts, and/or renewal agreements as described below. The forms must be signed by each bidder/contractor as indicated.? The forms include the Certification Regarding Debarment, Suspension, Ineligibility, and Voluntary Exclusion - Lower Tier Covered Transactions (85-34) Condition: The District participates in a purchasing cooperative for the program. The cooperative issues a request for proposal each April to select the prime vendor for the next school year. The request for proposal does not require the vendors responding to the request to provide a certificate of suspension and debarment. The cooperative does not maintain documentation for a vendor search within the SAM database as an alternative test. Cause: The District has outsourced the prime vendor procurement function to the cooperative and does not monitor the cooperative?s compliance with suspension and debarment rules as established by the Illinois State Board of Education and the Office of Management and Budget.Effect: The District does not have adequate documentation to ensure compliance with federal requirements regarding suspension and debarment. The District could enter into a transaction with a suspended or debarred party. Questioned Costs: $0 Context: The District expended approximately $52,000 with the prime vendor for fiscal year 2022. Total program non-payroll expenditures were $64,000. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend the District require the cooperative to request certification regarding suspension and debarment with each request for proposal issued. We recommend the District require the certification to be provided to them and maintained by the prime vendor and any vendor the District incurs $25,000 or more in a federal program. Response and Corrective Action Plan: The District will require the cooperative to obtain the certification regarding suspension and debarment from vendors as outlined by the Illinois State Board of Education with each request for proposal the cooperative issues. Person Responsible: Jodee Mathis.
Finding: The District does not have a process to ensure compliance with verification of free and reducedprice applications. Criteria: The April 2022 Office of Management and Budget Compliance Supplement states the following for Compliance Requirements-Verification of Free and Reduce- Price Applications: ?By November 15th of each school year, the LEA?must verify the current free and reduced-price eligibility of households selected from a sample of applications that is has approved for free and reduced-price meals.? The Illinois State Board of Education issued the following in September 2021, ?The U.S. Department of Agriculture is requiring all School Nutrition Program sponsors who received and approved Household Eligibility Applications between July 1 and October 1, 2021, to conduct Verification for School Year 2021- 2022?.For Verification, School Food Authorities (SFAs) are required to verify income for a small percentage of households approved for free or reduced-price meals each school year.? Condition: The District selected an application to verify from a pile of all applications. The application selected for verification procedures was not approved for free or reduced-price meals and was the personal application of the employee performing the verification procedures. Error-prone applications were not selected. The population of applications and data submitted to the state of Illinois was from a manual count rather than the point-of-sale system. 76 Fulton County Community Unit School District #3 Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Cause: The District did not use the food service software to randomly generate the list of applications to be verified. The District manually selected an application without consideration to the population or appearance of conflict of interest. Effect: The District did not perform verification procedures on an application that was approved for free or reduced-price meals. Questioned Costs: $0 Context: The District reported twenty-three applications for free or reduced-price meal benefits, two applications as error prone income applications, and one application to be tested on the Verification Summary Report submitted to the state of Illinois. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend the District use the food service point of sale system software to generate reports to complete the Verification Summary Report and to randomly generate the error prone application to be tested through verification procedures. We recommend the District require documentation of supervisory review of all verification reports, procedures, and conclusions. The supervisor should sign the report prior to submission and should sign the conclusion form of each verified application indicating review and approval. Response and Corrective Action Plan: The District will require the food service software to be used for verification data and selection of applications. The District will require documented supervisory approval of verification conclusions and reports submitted to the state of Illinois. Person Responsible: Jodee Mathis