Corrective Action Plans

Program: AL 20.509 – Formula Grants for Rural Areas – Allowability & Subrecipient Monitoring Corrective Action Plan: NDOT recently updated the Invoicing Reimbursement Acceptable Documentation Requirement Guidelines. These guidelines offer comprehensive instruction, best practices, and a clearer definition of allowable expenses for subrecipients. The updated guide was distributed to subrecipients in February 2024. Over the next six months, NDOT plans to conduct additional training sessions through opportunities such as the monthly Transit Manager meetings, on-site visits, or webinars with subrecipients. The objective is to ensure a thorough understanding of required documentation and the identification of eligible federal reimbursement expenses. To assist with transit subrecipient monitoring, NDOT management has designated an internal auditor within the Transit Section. The auditor’s focus will be assessing reimbursement documentation, reviewing time studies, evaluating cost allocation plans, developing risk assessment, and helping to intensify monitoring efforts over all subrecipients. NDOT is also in the process of improving and updating the invoice review process to provide consistency for reviewing and approving invoices to enhance accuracy within the Transit Section. Additionally, NDOT has established a dedicated unit “Financial Oversight” within the Transit Section solely focusing on Subrecipient reimbursements. The four staff members in this unit will report directly to Financial Aid Administrator III, this oversight will enhance the quality checks and consistency among subrecipient reimbursements. The Financial Oversight unit will continue to evaluate and refine the operations to ensure federal regulation and required documentation is in place prior to any subrecipient reimbursement. Contact: Jodi Gibson Anticipated Completion Date: On-going

FINDING 2023-003 Information on the federal program: Subject: Child Nutrition Cluster - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children, Fresh Fruit and Vegetable Program Assistance Listings Numbers: 10.553, 10.555, 10.559, 10.582 Federal Award Number and Year (or Other Identifying Numbers): FY2021-2022, FY2022-2023 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Adrian Wilkerson, Chief Financial Officer Contact Phone Number and Email Address: (219) 838-1819 awilkerson@lakeridgeschools.net Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Activities Allowed or Unallowed and the Allowable Costs/Cost Principles. Context: The School Corporation had not designed or implemented a system of internal control to ensure that program costs incurred by the Food Service Management Company were supported by proper documentation and were allowable. The School Corporation entered into a cost reimbursement contract with a food service management company (FSMC). The FSMC incurred costs and invoiced the School Corporation for reimbursement of the costs. Due to the lack of effective internal controls, the following errors were noted: In a test of 44 items, 22 items (50%) totaling $6,641 did not have proper documentation to support that the expenses were allowable and for the benefit of food service. Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: In addition to the monthly review of the FSMC invoice and budget, the Chief Financial Officer will review and approve the supporting documentation (invoices, payroll records) provided by the FSMC to ensure that expenses are allowable and for the benefit of food service. Anticipated Completion Date: Immediate