FINDING 2024-002
Information on the federal program:
Subject: Child Nutrition Cluster - Internal Controls over Procurement and Suspension and Debarment
Federal Agency: Department of Agriculture
Federal Program: School Breakfast Program, National School Lunch Program,
Supply Chain Assistance Program,...
FINDING 2024-002
Information on the federal program:
Subject: Child Nutrition Cluster - Internal Controls over Procurement and Suspension and Debarment
Federal Agency: Department of Agriculture
Federal Program: School Breakfast Program, National School Lunch Program,
Supply Chain Assistance Program, Summer Food Service Program
Assistance Listing Number: 10.553, 10.555, 10.559
Federal Award Numbers and Years (or Other Identifying Numbers): FY 22-23, FY 23-24
Pass-Through Entity: Indiana Department of Education
Compliance Requirement: Procurement and Suspension and Debarment
Audit Finding: Material Weakness
Condition: An effective internal control system was not in place at the School Corporation to ensure
compliance with requirements related to the Child Nutrition Program and Procurement compliance
requirements.
Context:
Procurement
The School Corporation participates in Unified Purchasing Cooperative of the Ohio River Valley (the
“Cooperative”), which procures vendors for food purchases and other supplies on behalf of its members.
During the audit period, the School Corporation also purchased food and supplies from vendors not
procured by the Cooperative. One vendor with aggregate annual purchases of $38,261 for fiscal year
2024 exceeded the small purchase threshold ($10,000 - $150,000). The School Corporation could not
provide documentation showing the bids received from other vendors that were used to compare pricing.
Suspension and Debarment
For the small purchase vendor noted above that was not procured by the Cooperative and had aggregate
annual disbursements exceeding the federal suspension and debarment threshold of $25,000, the School
Corporation did not provide documentation confirming that the vendor was not suspended or debarred
before disbursing federal funds during fiscal year 2024.
Views of Responsible Official: We concur with the finding.
Description of Corrective Action Plan: Management will implement a procurement checklist that is
reviewed after the purchasing process has been completed to ensure compliance with purchasing
requirements for federal awards. Sam.gov will be checked for each vendor with aggregate purchases
above $25,000.
Responsible Party and Timeline for Completion: Ginny Shannon, FSD and Gretchen Berger, Corp
Treasurer - 6-1-2025