Federal Agency: Various Assistance Listing Number: Multiple Compliance Requirement: Reporting Finding 2024-001: Submission of the Audit Reporting Package and Data Collection Form (Repeat of Finding 2023-001) Criteria: Per 2 CFR §200.510(b), the auditee must prepare a Schedule of Federal Awards (SEFA) for the period covered by the auditee’s financial statements. Per §200.512(a), the SEFA must be submitted to the Federal Audit Clearinghouse (FAC) within the required deadline. Condition: The audit reporting package and data collection form for the year ended September 30, 2024, was not submitted to the FAC within the timeframe as required by the Uniform Guidance. Cause: The delay was due to a lack of capacity in the finance department and not following the year-end closing schedule. Effect: To qualify as a low-risk auditee, 2 CFR section 200.520 requires the audit reporting package and data collection form to be submitted to the FAC by the due date for each of the previous two years. Late filing will result in noncompliance with timely submission of financial information to the grantor agencies. Recommendation: Management should address the lack of capacity in the finance department and monitor the year-end closing schedule for a timely audit reporting package and data collection form to ensure compliance with federal deadlines. Questioned costs: None Responsible Official's Response: We agree with the auditors’ comments, and the following action will be taken to improve the situation. At the beginning of fiscal year 2025 we have added capacity to the finance department by one full-time employee. Semcac has also contracted with an outsourcing accounting firm to enhance and improve our internal controls, processes, and procedures to ensure we both follow our year-end closing schedule and provide a timely audit reporting package.
Federal Agency: Various Assistance Listing Number: Multiple Compliance Requirement: Reporting Finding 2024-001: Submission of the Audit Reporting Package and Data Collection Form (Repeat of Finding 2023-001) Criteria: Per 2 CFR §200.510(b), the auditee must prepare a Schedule of Federal Awards (SEFA) for the period covered by the auditee’s financial statements. Per §200.512(a), the SEFA must be submitted to the Federal Audit Clearinghouse (FAC) within the required deadline. Condition: The audit reporting package and data collection form for the year ended September 30, 2024, was not submitted to the FAC within the timeframe as required by the Uniform Guidance. Cause: The delay was due to a lack of capacity in the finance department and not following the year-end closing schedule. Effect: To qualify as a low-risk auditee, 2 CFR section 200.520 requires the audit reporting package and data collection form to be submitted to the FAC by the due date for each of the previous two years. Late filing will result in noncompliance with timely submission of financial information to the grantor agencies. Recommendation: Management should address the lack of capacity in the finance department and monitor the year-end closing schedule for a timely audit reporting package and data collection form to ensure compliance with federal deadlines. Questioned costs: None Responsible Official's Response: We agree with the auditors’ comments, and the following action will be taken to improve the situation. At the beginning of fiscal year 2025 we have added capacity to the finance department by one full-time employee. Semcac has also contracted with an outsourcing accounting firm to enhance and improve our internal controls, processes, and procedures to ensure we both follow our year-end closing schedule and provide a timely audit reporting package.
Federal Agency: Various Assistance Listing Number: Multiple Compliance Requirement: Reporting Finding 2024-001: Submission of the Audit Reporting Package and Data Collection Form (Repeat of Finding 2023-001) Criteria: Per 2 CFR §200.510(b), the auditee must prepare a Schedule of Federal Awards (SEFA) for the period covered by the auditee’s financial statements. Per §200.512(a), the SEFA must be submitted to the Federal Audit Clearinghouse (FAC) within the required deadline. Condition: The audit reporting package and data collection form for the year ended September 30, 2024, was not submitted to the FAC within the timeframe as required by the Uniform Guidance. Cause: The delay was due to a lack of capacity in the finance department and not following the year-end closing schedule. Effect: To qualify as a low-risk auditee, 2 CFR section 200.520 requires the audit reporting package and data collection form to be submitted to the FAC by the due date for each of the previous two years. Late filing will result in noncompliance with timely submission of financial information to the grantor agencies. Recommendation: Management should address the lack of capacity in the finance department and monitor the year-end closing schedule for a timely audit reporting package and data collection form to ensure compliance with federal deadlines. Questioned costs: None Responsible Official's Response: We agree with the auditors’ comments, and the following action will be taken to improve the situation. At the beginning of fiscal year 2025 we have added capacity to the finance department by one full-time employee. Semcac has also contracted with an outsourcing accounting firm to enhance and improve our internal controls, processes, and procedures to ensure we both follow our year-end closing schedule and provide a timely audit reporting package.
Federal Agency: Various Assistance Listing Number: Multiple Compliance Requirement: Reporting Finding 2024-001: Submission of the Audit Reporting Package and Data Collection Form (Repeat of Finding 2023-001) Criteria: Per 2 CFR §200.510(b), the auditee must prepare a Schedule of Federal Awards (SEFA) for the period covered by the auditee’s financial statements. Per §200.512(a), the SEFA must be submitted to the Federal Audit Clearinghouse (FAC) within the required deadline. Condition: The audit reporting package and data collection form for the year ended September 30, 2024, was not submitted to the FAC within the timeframe as required by the Uniform Guidance. Cause: The delay was due to a lack of capacity in the finance department and not following the year-end closing schedule. Effect: To qualify as a low-risk auditee, 2 CFR section 200.520 requires the audit reporting package and data collection form to be submitted to the FAC by the due date for each of the previous two years. Late filing will result in noncompliance with timely submission of financial information to the grantor agencies. Recommendation: Management should address the lack of capacity in the finance department and monitor the year-end closing schedule for a timely audit reporting package and data collection form to ensure compliance with federal deadlines. Questioned costs: None Responsible Official's Response: We agree with the auditors’ comments, and the following action will be taken to improve the situation. At the beginning of fiscal year 2025 we have added capacity to the finance department by one full-time employee. Semcac has also contracted with an outsourcing accounting firm to enhance and improve our internal controls, processes, and procedures to ensure we both follow our year-end closing schedule and provide a timely audit reporting package.
Federal Agency: Various Assistance Listing Number: Multiple Compliance Requirement: Reporting Finding 2024-001: Submission of the Audit Reporting Package and Data Collection Form (Repeat of Finding 2023-001) Criteria: Per 2 CFR §200.510(b), the auditee must prepare a Schedule of Federal Awards (SEFA) for the period covered by the auditee’s financial statements. Per §200.512(a), the SEFA must be submitted to the Federal Audit Clearinghouse (FAC) within the required deadline. Condition: The audit reporting package and data collection form for the year ended September 30, 2024, was not submitted to the FAC within the timeframe as required by the Uniform Guidance. Cause: The delay was due to a lack of capacity in the finance department and not following the year-end closing schedule. Effect: To qualify as a low-risk auditee, 2 CFR section 200.520 requires the audit reporting package and data collection form to be submitted to the FAC by the due date for each of the previous two years. Late filing will result in noncompliance with timely submission of financial information to the grantor agencies. Recommendation: Management should address the lack of capacity in the finance department and monitor the year-end closing schedule for a timely audit reporting package and data collection form to ensure compliance with federal deadlines. Questioned costs: None Responsible Official's Response: We agree with the auditors’ comments, and the following action will be taken to improve the situation. At the beginning of fiscal year 2025 we have added capacity to the finance department by one full-time employee. Semcac has also contracted with an outsourcing accounting firm to enhance and improve our internal controls, processes, and procedures to ensure we both follow our year-end closing schedule and provide a timely audit reporting package.
Federal Agency: Various Assistance Listing Number: Multiple Compliance Requirement: Reporting Finding 2024-001: Submission of the Audit Reporting Package and Data Collection Form (Repeat of Finding 2023-001) Criteria: Per 2 CFR §200.510(b), the auditee must prepare a Schedule of Federal Awards (SEFA) for the period covered by the auditee’s financial statements. Per §200.512(a), the SEFA must be submitted to the Federal Audit Clearinghouse (FAC) within the required deadline. Condition: The audit reporting package and data collection form for the year ended September 30, 2024, was not submitted to the FAC within the timeframe as required by the Uniform Guidance. Cause: The delay was due to a lack of capacity in the finance department and not following the year-end closing schedule. Effect: To qualify as a low-risk auditee, 2 CFR section 200.520 requires the audit reporting package and data collection form to be submitted to the FAC by the due date for each of the previous two years. Late filing will result in noncompliance with timely submission of financial information to the grantor agencies. Recommendation: Management should address the lack of capacity in the finance department and monitor the year-end closing schedule for a timely audit reporting package and data collection form to ensure compliance with federal deadlines. Questioned costs: None Responsible Official's Response: We agree with the auditors’ comments, and the following action will be taken to improve the situation. At the beginning of fiscal year 2025 we have added capacity to the finance department by one full-time employee. Semcac has also contracted with an outsourcing accounting firm to enhance and improve our internal controls, processes, and procedures to ensure we both follow our year-end closing schedule and provide a timely audit reporting package.
Finding 2024-002: Submission of the Audit Reporting Package and Data Collection Form Federal Agency: Various Assistance Listing Number: Multiple Compliance Requirement: Reporting Criteria: Per 2 CFR § 200.510(b), the auditee must prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements. Per §200.512(a), the SEFA must be submitted to the Federal Audit Clearing House (FAC) within the required deadline. Cause: The delay was due to a lack of capacity in the finance department and not following the year-end closing schedule. Effect: To qualify as a low-risk auditee, 2 CFR section 200.520 requires the audit reporting package and data collection form to be submitted to the FAC by the due date for each of the previous two years. Late filing will result in noncompliance with timely submission of financial information to the grantor agencies. Recommendation: Management should address the lack of capacity in the finance department and monitor the year-end closing schedule for a timely audit reporting package and data collection form to ensure compliance with federal deadlines. Questioned costs: None Responsible Official's Response Management concurs with the finding. The Council recognizes the importance of timely submission of the SEFA and related audit documentation to maintain compliance with federal requirements. To address this issue, the Council has engaged an outside provider to assist with process improvements that will streamline financial reporting and ensure timely preparation and submission of all required audit materials. These enhancements will strengthen internal controls and support continued compliance in future reporting periods.
FINDING 2024-003 Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children Assistance Listings Numbers: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY 2023, FY 2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2022-003. Condition and Context An effective internal control system, which would include segregation of duties, was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Federal regulations allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisition threshold, which is set at $250,000. However, Indiana Code 5-22-8 has a more restrictive threshold of $150,000 or less for when small purchase procedures may be used. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds: micro-purchases, typically for those purchases $10,000 or under, and small purchase procedures for those purchases above the micropurchase threshold but below the simplified acquisition threshold. Nonfederal entities may establish a micro-purchase threshold higher than the federal threshold of $10,000 as established in the FAR in accordance with 2 CFR 200.320(a)(1)(iv) and (v). The School Corporation established a higher micropurchase threshold of $50,000. The School Corporation self-certified due to meeting the classification of a public institution and established a higher threshold consistent with state law (Indiana threshold of micropurchases is $50,000). Micro-purchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. Adequate internal controls were not in place over procurements made under the small purchase threshold for one of the two vendors tested during the audit period. The School Corporation made purchases with a vendor in fiscal year 2022-2023 totaling $97,773 and 2023-2024 totaling $59,070 but did not provide audit evidence that price quotations had been requested. Additionally, the School Corporation was not able to provide evidence that internal controls over suspension and debarment procedures were in place. The lack of internal controls was a systemic issue throughout the audit period. The noncompliance was isolated to procurement requirements. INDIANA STATE BOARD OF ACCOUNTS 18 LIBERTY-PERRY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.318(a) states: "The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non- Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.317 through 200.327." 2 CFR 200.320 states in part: "The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. (a) Informal procurement methods. When the value of the procurement for property or services under a Federal award does not exceed the simplified acquisition threshold (SAT), as defined in § 200.1, or a lower threshold established by a non-Federal entity, formal procurement methods are not required. The non-Federal entity may use informal procurement methods to expedite the completion of its transactions and minimize the associated administrative burden and cost. The informal methods used for procurement of property or services at or below the SAT include: . . . (1) . . . (iv) Non-Federal entity increase to the micro-purchase threshold up to $50,000. Non-Federal entities may establish a threshold higher than the micro-purchase threshold identified in the FAR in accordance with the requirements of this section. The non-Federal entity may self-certify a threshold up to $50,000 on an annual basis and must maintain documentation to be made available to the Federal awarding agency and auditors in accordance with § 200.334. The self-certification must include a justification, clear identification of the threshold, and supporting documentation of any of the following: (A) A qualification as a low-risk auditee, in accordance with the criteria in § 200.520 for the most recent audit; (B) An annual internal institutional risk assessment to identify, mitigate, and manage financial risks; or, INDIANA STATE BOARD OF ACCOUNTS 19 LIBERTY-PERRY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (C) For public institutions, a higher threshold consistent with State law. . . ." 2 CFR 180.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking the SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person." Indiana Code 5-22-8-3 states in part: "(a) This section applies only if the purchasing agent expects the purchase to be: (1) at least fifty thousand dollars ($50,000); and (2) not more than one hundred fifty thousand dollars ($150,000). . . . (d) If the purchasing agent receives a satisfactory quote, the purchasing agent shall award a contract to the lowest responsible and responsive offeror for each line or class of supplies required. . . ." Cause The School Corporation was not able to provide documentation to demonstrate that quotes were obtained for purchases under the small purchase method. The School Corporation was unable to provide documentation to demonstrate it checked SAM.gov to verify the contractor was not suspended or debarred prior to entering into the contract. The School Corporation did not have proper policies and procedures in place due to being unaware of the grant requirements. Effect Without the proper implementation of an effectively designed system of internal controls, the School Corporation cannot ensure the contractors paid with federal funds are eligible to participate in federal programs. Any funds the School Corporation used to pay contractors that have been suspended or debarred would be unallowable, and the funding agency could potentially recover them. The School Corporation cannot ensure that contractors paid under the small purchase method were awarded the best price for their services. This could result in federal funding not providing as many services or projects as possible. Questioned Costs There were no questioned costs identified. INDIANA STATE BOARD OF ACCOUNTS 20 LIBERTY-PERRY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Recommendation We recommended that the School Corporation strengthen its system of internal controls to ensure the proper procurement method is followed and documentation is retained. We recommended the School Corporation document its internal control procedures performed to ensure that all contractors that are paid $25,000 or more, all or in part with federal funds, are not suspended or debarred from participating in federal programs before entering into any contracts. We also recommended strengthening its policies and procedures to ensure appropriate evidence is retained for audit. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-003 Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children Assistance Listings Numbers: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY 2023, FY 2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2022-003. Condition and Context An effective internal control system, which would include segregation of duties, was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Federal regulations allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisition threshold, which is set at $250,000. However, Indiana Code 5-22-8 has a more restrictive threshold of $150,000 or less for when small purchase procedures may be used. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds: micro-purchases, typically for those purchases $10,000 or under, and small purchase procedures for those purchases above the micropurchase threshold but below the simplified acquisition threshold. Nonfederal entities may establish a micro-purchase threshold higher than the federal threshold of $10,000 as established in the FAR in accordance with 2 CFR 200.320(a)(1)(iv) and (v). The School Corporation established a higher micropurchase threshold of $50,000. The School Corporation self-certified due to meeting the classification of a public institution and established a higher threshold consistent with state law (Indiana threshold of micropurchases is $50,000). Micro-purchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. Adequate internal controls were not in place over procurements made under the small purchase threshold for one of the two vendors tested during the audit period. The School Corporation made purchases with a vendor in fiscal year 2022-2023 totaling $97,773 and 2023-2024 totaling $59,070 but did not provide audit evidence that price quotations had been requested. Additionally, the School Corporation was not able to provide evidence that internal controls over suspension and debarment procedures were in place. The lack of internal controls was a systemic issue throughout the audit period. The noncompliance was isolated to procurement requirements. INDIANA STATE BOARD OF ACCOUNTS 18 LIBERTY-PERRY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.318(a) states: "The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non- Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.317 through 200.327." 2 CFR 200.320 states in part: "The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. (a) Informal procurement methods. When the value of the procurement for property or services under a Federal award does not exceed the simplified acquisition threshold (SAT), as defined in § 200.1, or a lower threshold established by a non-Federal entity, formal procurement methods are not required. The non-Federal entity may use informal procurement methods to expedite the completion of its transactions and minimize the associated administrative burden and cost. The informal methods used for procurement of property or services at or below the SAT include: . . . (1) . . . (iv) Non-Federal entity increase to the micro-purchase threshold up to $50,000. Non-Federal entities may establish a threshold higher than the micro-purchase threshold identified in the FAR in accordance with the requirements of this section. The non-Federal entity may self-certify a threshold up to $50,000 on an annual basis and must maintain documentation to be made available to the Federal awarding agency and auditors in accordance with § 200.334. The self-certification must include a justification, clear identification of the threshold, and supporting documentation of any of the following: (A) A qualification as a low-risk auditee, in accordance with the criteria in § 200.520 for the most recent audit; (B) An annual internal institutional risk assessment to identify, mitigate, and manage financial risks; or, INDIANA STATE BOARD OF ACCOUNTS 19 LIBERTY-PERRY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (C) For public institutions, a higher threshold consistent with State law. . . ." 2 CFR 180.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking the SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person." Indiana Code 5-22-8-3 states in part: "(a) This section applies only if the purchasing agent expects the purchase to be: (1) at least fifty thousand dollars ($50,000); and (2) not more than one hundred fifty thousand dollars ($150,000). . . . (d) If the purchasing agent receives a satisfactory quote, the purchasing agent shall award a contract to the lowest responsible and responsive offeror for each line or class of supplies required. . . ." Cause The School Corporation was not able to provide documentation to demonstrate that quotes were obtained for purchases under the small purchase method. The School Corporation was unable to provide documentation to demonstrate it checked SAM.gov to verify the contractor was not suspended or debarred prior to entering into the contract. The School Corporation did not have proper policies and procedures in place due to being unaware of the grant requirements. Effect Without the proper implementation of an effectively designed system of internal controls, the School Corporation cannot ensure the contractors paid with federal funds are eligible to participate in federal programs. Any funds the School Corporation used to pay contractors that have been suspended or debarred would be unallowable, and the funding agency could potentially recover them. The School Corporation cannot ensure that contractors paid under the small purchase method were awarded the best price for their services. This could result in federal funding not providing as many services or projects as possible. Questioned Costs There were no questioned costs identified. INDIANA STATE BOARD OF ACCOUNTS 20 LIBERTY-PERRY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Recommendation We recommended that the School Corporation strengthen its system of internal controls to ensure the proper procurement method is followed and documentation is retained. We recommended the School Corporation document its internal control procedures performed to ensure that all contractors that are paid $25,000 or more, all or in part with federal funds, are not suspended or debarred from participating in federal programs before entering into any contracts. We also recommended strengthening its policies and procedures to ensure appropriate evidence is retained for audit. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-003 Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children Assistance Listings Numbers: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY 2023, FY 2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2022-003. Condition and Context An effective internal control system, which would include segregation of duties, was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Federal regulations allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisition threshold, which is set at $250,000. However, Indiana Code 5-22-8 has a more restrictive threshold of $150,000 or less for when small purchase procedures may be used. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds: micro-purchases, typically for those purchases $10,000 or under, and small purchase procedures for those purchases above the micropurchase threshold but below the simplified acquisition threshold. Nonfederal entities may establish a micro-purchase threshold higher than the federal threshold of $10,000 as established in the FAR in accordance with 2 CFR 200.320(a)(1)(iv) and (v). The School Corporation established a higher micropurchase threshold of $50,000. The School Corporation self-certified due to meeting the classification of a public institution and established a higher threshold consistent with state law (Indiana threshold of micropurchases is $50,000). Micro-purchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. Adequate internal controls were not in place over procurements made under the small purchase threshold for one of the two vendors tested during the audit period. The School Corporation made purchases with a vendor in fiscal year 2022-2023 totaling $97,773 and 2023-2024 totaling $59,070 but did not provide audit evidence that price quotations had been requested. Additionally, the School Corporation was not able to provide evidence that internal controls over suspension and debarment procedures were in place. The lack of internal controls was a systemic issue throughout the audit period. The noncompliance was isolated to procurement requirements. INDIANA STATE BOARD OF ACCOUNTS 18 LIBERTY-PERRY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.318(a) states: "The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non- Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.317 through 200.327." 2 CFR 200.320 states in part: "The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. (a) Informal procurement methods. When the value of the procurement for property or services under a Federal award does not exceed the simplified acquisition threshold (SAT), as defined in § 200.1, or a lower threshold established by a non-Federal entity, formal procurement methods are not required. The non-Federal entity may use informal procurement methods to expedite the completion of its transactions and minimize the associated administrative burden and cost. The informal methods used for procurement of property or services at or below the SAT include: . . . (1) . . . (iv) Non-Federal entity increase to the micro-purchase threshold up to $50,000. Non-Federal entities may establish a threshold higher than the micro-purchase threshold identified in the FAR in accordance with the requirements of this section. The non-Federal entity may self-certify a threshold up to $50,000 on an annual basis and must maintain documentation to be made available to the Federal awarding agency and auditors in accordance with § 200.334. The self-certification must include a justification, clear identification of the threshold, and supporting documentation of any of the following: (A) A qualification as a low-risk auditee, in accordance with the criteria in § 200.520 for the most recent audit; (B) An annual internal institutional risk assessment to identify, mitigate, and manage financial risks; or, INDIANA STATE BOARD OF ACCOUNTS 19 LIBERTY-PERRY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (C) For public institutions, a higher threshold consistent with State law. . . ." 2 CFR 180.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking the SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person." Indiana Code 5-22-8-3 states in part: "(a) This section applies only if the purchasing agent expects the purchase to be: (1) at least fifty thousand dollars ($50,000); and (2) not more than one hundred fifty thousand dollars ($150,000). . . . (d) If the purchasing agent receives a satisfactory quote, the purchasing agent shall award a contract to the lowest responsible and responsive offeror for each line or class of supplies required. . . ." Cause The School Corporation was not able to provide documentation to demonstrate that quotes were obtained for purchases under the small purchase method. The School Corporation was unable to provide documentation to demonstrate it checked SAM.gov to verify the contractor was not suspended or debarred prior to entering into the contract. The School Corporation did not have proper policies and procedures in place due to being unaware of the grant requirements. Effect Without the proper implementation of an effectively designed system of internal controls, the School Corporation cannot ensure the contractors paid with federal funds are eligible to participate in federal programs. Any funds the School Corporation used to pay contractors that have been suspended or debarred would be unallowable, and the funding agency could potentially recover them. The School Corporation cannot ensure that contractors paid under the small purchase method were awarded the best price for their services. This could result in federal funding not providing as many services or projects as possible. Questioned Costs There were no questioned costs identified. INDIANA STATE BOARD OF ACCOUNTS 20 LIBERTY-PERRY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Recommendation We recommended that the School Corporation strengthen its system of internal controls to ensure the proper procurement method is followed and documentation is retained. We recommended the School Corporation document its internal control procedures performed to ensure that all contractors that are paid $25,000 or more, all or in part with federal funds, are not suspended or debarred from participating in federal programs before entering into any contracts. We also recommended strengthening its policies and procedures to ensure appropriate evidence is retained for audit. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-003 Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children Assistance Listings Numbers: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY 2023, FY 2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2022-003. Condition and Context An effective internal control system, which would include segregation of duties, was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Federal regulations allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisition threshold, which is set at $250,000. However, Indiana Code 5-22-8 has a more restrictive threshold of $150,000 or less for when small purchase procedures may be used. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds: micro-purchases, typically for those purchases $10,000 or under, and small purchase procedures for those purchases above the micropurchase threshold but below the simplified acquisition threshold. Nonfederal entities may establish a micro-purchase threshold higher than the federal threshold of $10,000 as established in the FAR in accordance with 2 CFR 200.320(a)(1)(iv) and (v). The School Corporation established a higher micropurchase threshold of $50,000. The School Corporation self-certified due to meeting the classification of a public institution and established a higher threshold consistent with state law (Indiana threshold of micropurchases is $50,000). Micro-purchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. Adequate internal controls were not in place over procurements made under the small purchase threshold for one of the two vendors tested during the audit period. The School Corporation made purchases with a vendor in fiscal year 2022-2023 totaling $97,773 and 2023-2024 totaling $59,070 but did not provide audit evidence that price quotations had been requested. Additionally, the School Corporation was not able to provide evidence that internal controls over suspension and debarment procedures were in place. The lack of internal controls was a systemic issue throughout the audit period. The noncompliance was isolated to procurement requirements. INDIANA STATE BOARD OF ACCOUNTS 18 LIBERTY-PERRY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.318(a) states: "The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non- Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.317 through 200.327." 2 CFR 200.320 states in part: "The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. (a) Informal procurement methods. When the value of the procurement for property or services under a Federal award does not exceed the simplified acquisition threshold (SAT), as defined in § 200.1, or a lower threshold established by a non-Federal entity, formal procurement methods are not required. The non-Federal entity may use informal procurement methods to expedite the completion of its transactions and minimize the associated administrative burden and cost. The informal methods used for procurement of property or services at or below the SAT include: . . . (1) . . . (iv) Non-Federal entity increase to the micro-purchase threshold up to $50,000. Non-Federal entities may establish a threshold higher than the micro-purchase threshold identified in the FAR in accordance with the requirements of this section. The non-Federal entity may self-certify a threshold up to $50,000 on an annual basis and must maintain documentation to be made available to the Federal awarding agency and auditors in accordance with § 200.334. The self-certification must include a justification, clear identification of the threshold, and supporting documentation of any of the following: (A) A qualification as a low-risk auditee, in accordance with the criteria in § 200.520 for the most recent audit; (B) An annual internal institutional risk assessment to identify, mitigate, and manage financial risks; or, INDIANA STATE BOARD OF ACCOUNTS 19 LIBERTY-PERRY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (C) For public institutions, a higher threshold consistent with State law. . . ." 2 CFR 180.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking the SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person." Indiana Code 5-22-8-3 states in part: "(a) This section applies only if the purchasing agent expects the purchase to be: (1) at least fifty thousand dollars ($50,000); and (2) not more than one hundred fifty thousand dollars ($150,000). . . . (d) If the purchasing agent receives a satisfactory quote, the purchasing agent shall award a contract to the lowest responsible and responsive offeror for each line or class of supplies required. . . ." Cause The School Corporation was not able to provide documentation to demonstrate that quotes were obtained for purchases under the small purchase method. The School Corporation was unable to provide documentation to demonstrate it checked SAM.gov to verify the contractor was not suspended or debarred prior to entering into the contract. The School Corporation did not have proper policies and procedures in place due to being unaware of the grant requirements. Effect Without the proper implementation of an effectively designed system of internal controls, the School Corporation cannot ensure the contractors paid with federal funds are eligible to participate in federal programs. Any funds the School Corporation used to pay contractors that have been suspended or debarred would be unallowable, and the funding agency could potentially recover them. The School Corporation cannot ensure that contractors paid under the small purchase method were awarded the best price for their services. This could result in federal funding not providing as many services or projects as possible. Questioned Costs There were no questioned costs identified. INDIANA STATE BOARD OF ACCOUNTS 20 LIBERTY-PERRY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Recommendation We recommended that the School Corporation strengthen its system of internal controls to ensure the proper procurement method is followed and documentation is retained. We recommended the School Corporation document its internal control procedures performed to ensure that all contractors that are paid $25,000 or more, all or in part with federal funds, are not suspended or debarred from participating in federal programs before entering into any contracts. We also recommended strengthening its policies and procedures to ensure appropriate evidence is retained for audit. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-003 Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children Assistance Listings Numbers: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY 2023, FY 2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2022-003. Condition and Context An effective internal control system, which would include segregation of duties, was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Federal regulations allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisition threshold, which is set at $250,000. However, Indiana Code 5-22-8 has a more restrictive threshold of $150,000 or less for when small purchase procedures may be used. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds: micro-purchases, typically for those purchases $10,000 or under, and small purchase procedures for those purchases above the micropurchase threshold but below the simplified acquisition threshold. Nonfederal entities may establish a micro-purchase threshold higher than the federal threshold of $10,000 as established in the FAR in accordance with 2 CFR 200.320(a)(1)(iv) and (v). The School Corporation established a higher micropurchase threshold of $50,000. The School Corporation self-certified due to meeting the classification of a public institution and established a higher threshold consistent with state law (Indiana threshold of micropurchases is $50,000). Micro-purchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. Adequate internal controls were not in place over procurements made under the small purchase threshold for one of the two vendors tested during the audit period. The School Corporation made purchases with a vendor in fiscal year 2022-2023 totaling $97,773 and 2023-2024 totaling $59,070 but did not provide audit evidence that price quotations had been requested. Additionally, the School Corporation was not able to provide evidence that internal controls over suspension and debarment procedures were in place. The lack of internal controls was a systemic issue throughout the audit period. The noncompliance was isolated to procurement requirements. INDIANA STATE BOARD OF ACCOUNTS 18 LIBERTY-PERRY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.318(a) states: "The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non- Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.317 through 200.327." 2 CFR 200.320 states in part: "The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. (a) Informal procurement methods. When the value of the procurement for property or services under a Federal award does not exceed the simplified acquisition threshold (SAT), as defined in § 200.1, or a lower threshold established by a non-Federal entity, formal procurement methods are not required. The non-Federal entity may use informal procurement methods to expedite the completion of its transactions and minimize the associated administrative burden and cost. The informal methods used for procurement of property or services at or below the SAT include: . . . (1) . . . (iv) Non-Federal entity increase to the micro-purchase threshold up to $50,000. Non-Federal entities may establish a threshold higher than the micro-purchase threshold identified in the FAR in accordance with the requirements of this section. The non-Federal entity may self-certify a threshold up to $50,000 on an annual basis and must maintain documentation to be made available to the Federal awarding agency and auditors in accordance with § 200.334. The self-certification must include a justification, clear identification of the threshold, and supporting documentation of any of the following: (A) A qualification as a low-risk auditee, in accordance with the criteria in § 200.520 for the most recent audit; (B) An annual internal institutional risk assessment to identify, mitigate, and manage financial risks; or, INDIANA STATE BOARD OF ACCOUNTS 19 LIBERTY-PERRY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (C) For public institutions, a higher threshold consistent with State law. . . ." 2 CFR 180.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking the SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person." Indiana Code 5-22-8-3 states in part: "(a) This section applies only if the purchasing agent expects the purchase to be: (1) at least fifty thousand dollars ($50,000); and (2) not more than one hundred fifty thousand dollars ($150,000). . . . (d) If the purchasing agent receives a satisfactory quote, the purchasing agent shall award a contract to the lowest responsible and responsive offeror for each line or class of supplies required. . . ." Cause The School Corporation was not able to provide documentation to demonstrate that quotes were obtained for purchases under the small purchase method. The School Corporation was unable to provide documentation to demonstrate it checked SAM.gov to verify the contractor was not suspended or debarred prior to entering into the contract. The School Corporation did not have proper policies and procedures in place due to being unaware of the grant requirements. Effect Without the proper implementation of an effectively designed system of internal controls, the School Corporation cannot ensure the contractors paid with federal funds are eligible to participate in federal programs. Any funds the School Corporation used to pay contractors that have been suspended or debarred would be unallowable, and the funding agency could potentially recover them. The School Corporation cannot ensure that contractors paid under the small purchase method were awarded the best price for their services. This could result in federal funding not providing as many services or projects as possible. Questioned Costs There were no questioned costs identified. INDIANA STATE BOARD OF ACCOUNTS 20 LIBERTY-PERRY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Recommendation We recommended that the School Corporation strengthen its system of internal controls to ensure the proper procurement method is followed and documentation is retained. We recommended the School Corporation document its internal control procedures performed to ensure that all contractors that are paid $25,000 or more, all or in part with federal funds, are not suspended or debarred from participating in federal programs before entering into any contracts. We also recommended strengthening its policies and procedures to ensure appropriate evidence is retained for audit. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-003 Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children Assistance Listings Numbers: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY 2023, FY 2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2022-003. Condition and Context An effective internal control system, which would include segregation of duties, was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Federal regulations allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisition threshold, which is set at $250,000. However, Indiana Code 5-22-8 has a more restrictive threshold of $150,000 or less for when small purchase procedures may be used. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds: micro-purchases, typically for those purchases $10,000 or under, and small purchase procedures for those purchases above the micropurchase threshold but below the simplified acquisition threshold. Nonfederal entities may establish a micro-purchase threshold higher than the federal threshold of $10,000 as established in the FAR in accordance with 2 CFR 200.320(a)(1)(iv) and (v). The School Corporation established a higher micropurchase threshold of $50,000. The School Corporation self-certified due to meeting the classification of a public institution and established a higher threshold consistent with state law (Indiana threshold of micropurchases is $50,000). Micro-purchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. Adequate internal controls were not in place over procurements made under the small purchase threshold for one of the two vendors tested during the audit period. The School Corporation made purchases with a vendor in fiscal year 2022-2023 totaling $97,773 and 2023-2024 totaling $59,070 but did not provide audit evidence that price quotations had been requested. Additionally, the School Corporation was not able to provide evidence that internal controls over suspension and debarment procedures were in place. The lack of internal controls was a systemic issue throughout the audit period. The noncompliance was isolated to procurement requirements. INDIANA STATE BOARD OF ACCOUNTS 18 LIBERTY-PERRY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.318(a) states: "The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non- Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.317 through 200.327." 2 CFR 200.320 states in part: "The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. (a) Informal procurement methods. When the value of the procurement for property or services under a Federal award does not exceed the simplified acquisition threshold (SAT), as defined in § 200.1, or a lower threshold established by a non-Federal entity, formal procurement methods are not required. The non-Federal entity may use informal procurement methods to expedite the completion of its transactions and minimize the associated administrative burden and cost. The informal methods used for procurement of property or services at or below the SAT include: . . . (1) . . . (iv) Non-Federal entity increase to the micro-purchase threshold up to $50,000. Non-Federal entities may establish a threshold higher than the micro-purchase threshold identified in the FAR in accordance with the requirements of this section. The non-Federal entity may self-certify a threshold up to $50,000 on an annual basis and must maintain documentation to be made available to the Federal awarding agency and auditors in accordance with § 200.334. The self-certification must include a justification, clear identification of the threshold, and supporting documentation of any of the following: (A) A qualification as a low-risk auditee, in accordance with the criteria in § 200.520 for the most recent audit; (B) An annual internal institutional risk assessment to identify, mitigate, and manage financial risks; or, INDIANA STATE BOARD OF ACCOUNTS 19 LIBERTY-PERRY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (C) For public institutions, a higher threshold consistent with State law. . . ." 2 CFR 180.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking the SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person." Indiana Code 5-22-8-3 states in part: "(a) This section applies only if the purchasing agent expects the purchase to be: (1) at least fifty thousand dollars ($50,000); and (2) not more than one hundred fifty thousand dollars ($150,000). . . . (d) If the purchasing agent receives a satisfactory quote, the purchasing agent shall award a contract to the lowest responsible and responsive offeror for each line or class of supplies required. . . ." Cause The School Corporation was not able to provide documentation to demonstrate that quotes were obtained for purchases under the small purchase method. The School Corporation was unable to provide documentation to demonstrate it checked SAM.gov to verify the contractor was not suspended or debarred prior to entering into the contract. The School Corporation did not have proper policies and procedures in place due to being unaware of the grant requirements. Effect Without the proper implementation of an effectively designed system of internal controls, the School Corporation cannot ensure the contractors paid with federal funds are eligible to participate in federal programs. Any funds the School Corporation used to pay contractors that have been suspended or debarred would be unallowable, and the funding agency could potentially recover them. The School Corporation cannot ensure that contractors paid under the small purchase method were awarded the best price for their services. This could result in federal funding not providing as many services or projects as possible. Questioned Costs There were no questioned costs identified. INDIANA STATE BOARD OF ACCOUNTS 20 LIBERTY-PERRY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Recommendation We recommended that the School Corporation strengthen its system of internal controls to ensure the proper procurement method is followed and documentation is retained. We recommended the School Corporation document its internal control procedures performed to ensure that all contractors that are paid $25,000 or more, all or in part with federal funds, are not suspended or debarred from participating in federal programs before entering into any contracts. We also recommended strengthening its policies and procedures to ensure appropriate evidence is retained for audit. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Finding 2024 – 002 – Single Audit Data Collection Form Not Filed by Due Date Condition: The data collection form for the Single Audit ended June 30, 2024, was not submitted to the Federal Audit Clearinghouse by March 31, 2025. Cause: The audit report was not issued prior to the March 31, 2025, submission date requirement. Therefore, the data collection form required at audit completion was not filed by this date. Criteria: 2 CFR section 200.512(b) provides for a form, referred to as the data collection form, to be prepared at the completion of each audit and submitted by the auditee to the Federal Audit Clearinghouse the earlier of 30 calendar days after receipt of the auditor’s reports or nine months after the end of the audit period Effect: The Town has not met the reporting requirements related to timely submission of the data collection form required for a Single Audit. Therefore, per 2 CFR section 200.520, the Town will not meet the low-risk auditee criteria for future Single Audits that requires submission of the data collection form and reporting package by the due date for each of the two preceding audit years Recommendation: We recommend the Town to develop specific procedures to ensure that the audit report is received prior to the March 31 reporting deadline. Response: The Town will work with the audit firm to ensure that the audit field work is scheduled with sufficient time to allow the audit report and data collection form to be filed timely in the future.
Finding 2024 – 002 – Single Audit Data Collection Form Not Filed by Due Date Condition: The data collection form for the Single Audit ended June 30, 2024, was not submitted to the Federal Audit Clearinghouse by March 31, 2025. Cause: The audit report was not issued prior to the March 31, 2025, submission date requirement. Therefore, the data collection form required at audit completion was not filed by this date. Criteria: 2 CFR section 200.512(b) provides for a form, referred to as the data collection form, to be prepared at the completion of each audit and submitted by the auditee to the Federal Audit Clearinghouse the earlier of 30 calendar days after receipt of the auditor’s reports or nine months after the end of the audit period Effect: The Town has not met the reporting requirements related to timely submission of the data collection form required for a Single Audit. Therefore, per 2 CFR section 200.520, the Town will not meet the low-risk auditee criteria for future Single Audits that requires submission of the data collection form and reporting package by the due date for each of the two preceding audit years Recommendation: We recommend the Town to develop specific procedures to ensure that the audit report is received prior to the March 31 reporting deadline. Response: The Town will work with the audit firm to ensure that the audit field work is scheduled with sufficient time to allow the audit report and data collection form to be filed timely in the future.
Finding 2024 – 002 – Single Audit Data Collection Form Not Filed by Due Date Condition: The data collection form for the Single Audit ended June 30, 2024, was not submitted to the Federal Audit Clearinghouse by March 31, 2025. Cause: The audit report was not issued prior to the March 31, 2025, submission date requirement. Therefore, the data collection form required at audit completion was not filed by this date. Criteria: 2 CFR section 200.512(b) provides for a form, referred to as the data collection form, to be prepared at the completion of each audit and submitted by the auditee to the Federal Audit Clearinghouse the earlier of 30 calendar days after receipt of the auditor’s reports or nine months after the end of the audit period Effect: The Town has not met the reporting requirements related to timely submission of the data collection form required for a Single Audit. Therefore, per 2 CFR section 200.520, the Town will not meet the low-risk auditee criteria for future Single Audits that requires submission of the data collection form and reporting package by the due date for each of the two preceding audit years Recommendation: We recommend the Town to develop specific procedures to ensure that the audit report is received prior to the March 31 reporting deadline. Response: The Town will work with the audit firm to ensure that the audit field work is scheduled with sufficient time to allow the audit report and data collection form to be filed timely in the future.
Finding 2024 – 002 – Single Audit Data Collection Form Not Filed by Due Date Condition: The data collection form for the Single Audit ended June 30, 2024, was not submitted to the Federal Audit Clearinghouse by March 31, 2025. Cause: The audit report was not issued prior to the March 31, 2025, submission date requirement. Therefore, the data collection form required at audit completion was not filed by this date. Criteria: 2 CFR section 200.512(b) provides for a form, referred to as the data collection form, to be prepared at the completion of each audit and submitted by the auditee to the Federal Audit Clearinghouse the earlier of 30 calendar days after receipt of the auditor’s reports or nine months after the end of the audit period Effect: The Town has not met the reporting requirements related to timely submission of the data collection form required for a Single Audit. Therefore, per 2 CFR section 200.520, the Town will not meet the low-risk auditee criteria for future Single Audits that requires submission of the data collection form and reporting package by the due date for each of the two preceding audit years Recommendation: We recommend the Town to develop specific procedures to ensure that the audit report is received prior to the March 31 reporting deadline. Response: The Town will work with the audit firm to ensure that the audit field work is scheduled with sufficient time to allow the audit report and data collection form to be filed timely in the future.
Finding 2024 – 002 – Single Audit Data Collection Form Not Filed by Due Date Condition: The data collection form for the Single Audit ended June 30, 2024, was not submitted to the Federal Audit Clearinghouse by March 31, 2025. Cause: The audit report was not issued prior to the March 31, 2025, submission date requirement. Therefore, the data collection form required at audit completion was not filed by this date. Criteria: 2 CFR section 200.512(b) provides for a form, referred to as the data collection form, to be prepared at the completion of each audit and submitted by the auditee to the Federal Audit Clearinghouse the earlier of 30 calendar days after receipt of the auditor’s reports or nine months after the end of the audit period Effect: The Town has not met the reporting requirements related to timely submission of the data collection form required for a Single Audit. Therefore, per 2 CFR section 200.520, the Town will not meet the low-risk auditee criteria for future Single Audits that requires submission of the data collection form and reporting package by the due date for each of the two preceding audit years Recommendation: We recommend the Town to develop specific procedures to ensure that the audit report is received prior to the March 31 reporting deadline. Response: The Town will work with the audit firm to ensure that the audit field work is scheduled with sufficient time to allow the audit report and data collection form to be filed timely in the future.
FINDING 2024-003 Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children Assistance Listings Numbers: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY 2023, FY 2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2022-003. Condition and Context An effective internal control system, which would include segregation of duties, was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Federal regulations allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisition threshold, which is set at $250,000. However, Indiana Code 5-22-8 has a more restrictive threshold of $150,000 or less for when small purchase procedures may be used. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds: micro-purchases, typically for those purchases $10,000 or under, and small purchase procedures for those purchases above the micropurchase threshold but below the simplified acquisition threshold. Nonfederal entities may establish a micro-purchase threshold higher than the federal threshold of $10,000 as established in the FAR in accordance with 2 CFR 200.320(a)(1)(iv) and (v). The School Corporation established a higher micropurchase threshold of $50,000. The School Corporation self-certified due to meeting the classification of a public institution and established a higher threshold consistent with state law (Indiana threshold of micropurchases is $50,000). Micro-purchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. Adequate internal controls were not in place over procurements made under the small purchase threshold for one of the two vendors tested during the audit period. The School Corporation made purchases with a vendor in fiscal year 2022-2023 totaling $97,773 and 2023-2024 totaling $59,070 but did not provide audit evidence that price quotations had been requested. Additionally, the School Corporation was not able to provide evidence that internal controls over suspension and debarment procedures were in place. The lack of internal controls was a systemic issue throughout the audit period. The noncompliance was isolated to procurement requirements. INDIANA STATE BOARD OF ACCOUNTS 18 LIBERTY-PERRY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.318(a) states: "The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non- Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.317 through 200.327." 2 CFR 200.320 states in part: "The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. (a) Informal procurement methods. When the value of the procurement for property or services under a Federal award does not exceed the simplified acquisition threshold (SAT), as defined in § 200.1, or a lower threshold established by a non-Federal entity, formal procurement methods are not required. The non-Federal entity may use informal procurement methods to expedite the completion of its transactions and minimize the associated administrative burden and cost. The informal methods used for procurement of property or services at or below the SAT include: . . . (1) . . . (iv) Non-Federal entity increase to the micro-purchase threshold up to $50,000. Non-Federal entities may establish a threshold higher than the micro-purchase threshold identified in the FAR in accordance with the requirements of this section. The non-Federal entity may self-certify a threshold up to $50,000 on an annual basis and must maintain documentation to be made available to the Federal awarding agency and auditors in accordance with § 200.334. The self-certification must include a justification, clear identification of the threshold, and supporting documentation of any of the following: (A) A qualification as a low-risk auditee, in accordance with the criteria in § 200.520 for the most recent audit; (B) An annual internal institutional risk assessment to identify, mitigate, and manage financial risks; or, INDIANA STATE BOARD OF ACCOUNTS 19 LIBERTY-PERRY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (C) For public institutions, a higher threshold consistent with State law. . . ." 2 CFR 180.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking the SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person." Indiana Code 5-22-8-3 states in part: "(a) This section applies only if the purchasing agent expects the purchase to be: (1) at least fifty thousand dollars ($50,000); and (2) not more than one hundred fifty thousand dollars ($150,000). . . . (d) If the purchasing agent receives a satisfactory quote, the purchasing agent shall award a contract to the lowest responsible and responsive offeror for each line or class of supplies required. . . ." Cause The School Corporation was not able to provide documentation to demonstrate that quotes were obtained for purchases under the small purchase method. The School Corporation was unable to provide documentation to demonstrate it checked SAM.gov to verify the contractor was not suspended or debarred prior to entering into the contract. The School Corporation did not have proper policies and procedures in place due to being unaware of the grant requirements. Effect Without the proper implementation of an effectively designed system of internal controls, the School Corporation cannot ensure the contractors paid with federal funds are eligible to participate in federal programs. Any funds the School Corporation used to pay contractors that have been suspended or debarred would be unallowable, and the funding agency could potentially recover them. The School Corporation cannot ensure that contractors paid under the small purchase method were awarded the best price for their services. This could result in federal funding not providing as many services or projects as possible. Questioned Costs There were no questioned costs identified. INDIANA STATE BOARD OF ACCOUNTS 20 LIBERTY-PERRY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Recommendation We recommended that the School Corporation strengthen its system of internal controls to ensure the proper procurement method is followed and documentation is retained. We recommended the School Corporation document its internal control procedures performed to ensure that all contractors that are paid $25,000 or more, all or in part with federal funds, are not suspended or debarred from participating in federal programs before entering into any contracts. We also recommended strengthening its policies and procedures to ensure appropriate evidence is retained for audit. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-003 Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children Assistance Listings Numbers: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY 2023, FY 2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2022-003. Condition and Context An effective internal control system, which would include segregation of duties, was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Federal regulations allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisition threshold, which is set at $250,000. However, Indiana Code 5-22-8 has a more restrictive threshold of $150,000 or less for when small purchase procedures may be used. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds: micro-purchases, typically for those purchases $10,000 or under, and small purchase procedures for those purchases above the micropurchase threshold but below the simplified acquisition threshold. Nonfederal entities may establish a micro-purchase threshold higher than the federal threshold of $10,000 as established in the FAR in accordance with 2 CFR 200.320(a)(1)(iv) and (v). The School Corporation established a higher micropurchase threshold of $50,000. The School Corporation self-certified due to meeting the classification of a public institution and established a higher threshold consistent with state law (Indiana threshold of micropurchases is $50,000). Micro-purchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. Adequate internal controls were not in place over procurements made under the small purchase threshold for one of the two vendors tested during the audit period. The School Corporation made purchases with a vendor in fiscal year 2022-2023 totaling $97,773 and 2023-2024 totaling $59,070 but did not provide audit evidence that price quotations had been requested. Additionally, the School Corporation was not able to provide evidence that internal controls over suspension and debarment procedures were in place. The lack of internal controls was a systemic issue throughout the audit period. The noncompliance was isolated to procurement requirements. INDIANA STATE BOARD OF ACCOUNTS 18 LIBERTY-PERRY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.318(a) states: "The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non- Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.317 through 200.327." 2 CFR 200.320 states in part: "The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. (a) Informal procurement methods. When the value of the procurement for property or services under a Federal award does not exceed the simplified acquisition threshold (SAT), as defined in § 200.1, or a lower threshold established by a non-Federal entity, formal procurement methods are not required. The non-Federal entity may use informal procurement methods to expedite the completion of its transactions and minimize the associated administrative burden and cost. The informal methods used for procurement of property or services at or below the SAT include: . . . (1) . . . (iv) Non-Federal entity increase to the micro-purchase threshold up to $50,000. Non-Federal entities may establish a threshold higher than the micro-purchase threshold identified in the FAR in accordance with the requirements of this section. The non-Federal entity may self-certify a threshold up to $50,000 on an annual basis and must maintain documentation to be made available to the Federal awarding agency and auditors in accordance with § 200.334. The self-certification must include a justification, clear identification of the threshold, and supporting documentation of any of the following: (A) A qualification as a low-risk auditee, in accordance with the criteria in § 200.520 for the most recent audit; (B) An annual internal institutional risk assessment to identify, mitigate, and manage financial risks; or, INDIANA STATE BOARD OF ACCOUNTS 19 LIBERTY-PERRY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (C) For public institutions, a higher threshold consistent with State law. . . ." 2 CFR 180.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking the SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person." Indiana Code 5-22-8-3 states in part: "(a) This section applies only if the purchasing agent expects the purchase to be: (1) at least fifty thousand dollars ($50,000); and (2) not more than one hundred fifty thousand dollars ($150,000). . . . (d) If the purchasing agent receives a satisfactory quote, the purchasing agent shall award a contract to the lowest responsible and responsive offeror for each line or class of supplies required. . . ." Cause The School Corporation was not able to provide documentation to demonstrate that quotes were obtained for purchases under the small purchase method. The School Corporation was unable to provide documentation to demonstrate it checked SAM.gov to verify the contractor was not suspended or debarred prior to entering into the contract. The School Corporation did not have proper policies and procedures in place due to being unaware of the grant requirements. Effect Without the proper implementation of an effectively designed system of internal controls, the School Corporation cannot ensure the contractors paid with federal funds are eligible to participate in federal programs. Any funds the School Corporation used to pay contractors that have been suspended or debarred would be unallowable, and the funding agency could potentially recover them. The School Corporation cannot ensure that contractors paid under the small purchase method were awarded the best price for their services. This could result in federal funding not providing as many services or projects as possible. Questioned Costs There were no questioned costs identified. INDIANA STATE BOARD OF ACCOUNTS 20 LIBERTY-PERRY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Recommendation We recommended that the School Corporation strengthen its system of internal controls to ensure the proper procurement method is followed and documentation is retained. We recommended the School Corporation document its internal control procedures performed to ensure that all contractors that are paid $25,000 or more, all or in part with federal funds, are not suspended or debarred from participating in federal programs before entering into any contracts. We also recommended strengthening its policies and procedures to ensure appropriate evidence is retained for audit. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-003 Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children Assistance Listings Numbers: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY 2023, FY 2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2022-003. Condition and Context An effective internal control system, which would include segregation of duties, was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Federal regulations allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisition threshold, which is set at $250,000. However, Indiana Code 5-22-8 has a more restrictive threshold of $150,000 or less for when small purchase procedures may be used. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds: micro-purchases, typically for those purchases $10,000 or under, and small purchase procedures for those purchases above the micropurchase threshold but below the simplified acquisition threshold. Nonfederal entities may establish a micro-purchase threshold higher than the federal threshold of $10,000 as established in the FAR in accordance with 2 CFR 200.320(a)(1)(iv) and (v). The School Corporation established a higher micropurchase threshold of $50,000. The School Corporation self-certified due to meeting the classification of a public institution and established a higher threshold consistent with state law (Indiana threshold of micropurchases is $50,000). Micro-purchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. Adequate internal controls were not in place over procurements made under the small purchase threshold for one of the two vendors tested during the audit period. The School Corporation made purchases with a vendor in fiscal year 2022-2023 totaling $97,773 and 2023-2024 totaling $59,070 but did not provide audit evidence that price quotations had been requested. Additionally, the School Corporation was not able to provide evidence that internal controls over suspension and debarment procedures were in place. The lack of internal controls was a systemic issue throughout the audit period. The noncompliance was isolated to procurement requirements. INDIANA STATE BOARD OF ACCOUNTS 18 LIBERTY-PERRY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.318(a) states: "The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non- Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.317 through 200.327." 2 CFR 200.320 states in part: "The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. (a) Informal procurement methods. When the value of the procurement for property or services under a Federal award does not exceed the simplified acquisition threshold (SAT), as defined in § 200.1, or a lower threshold established by a non-Federal entity, formal procurement methods are not required. The non-Federal entity may use informal procurement methods to expedite the completion of its transactions and minimize the associated administrative burden and cost. The informal methods used for procurement of property or services at or below the SAT include: . . . (1) . . . (iv) Non-Federal entity increase to the micro-purchase threshold up to $50,000. Non-Federal entities may establish a threshold higher than the micro-purchase threshold identified in the FAR in accordance with the requirements of this section. The non-Federal entity may self-certify a threshold up to $50,000 on an annual basis and must maintain documentation to be made available to the Federal awarding agency and auditors in accordance with § 200.334. The self-certification must include a justification, clear identification of the threshold, and supporting documentation of any of the following: (A) A qualification as a low-risk auditee, in accordance with the criteria in § 200.520 for the most recent audit; (B) An annual internal institutional risk assessment to identify, mitigate, and manage financial risks; or, INDIANA STATE BOARD OF ACCOUNTS 19 LIBERTY-PERRY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (C) For public institutions, a higher threshold consistent with State law. . . ." 2 CFR 180.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking the SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person." Indiana Code 5-22-8-3 states in part: "(a) This section applies only if the purchasing agent expects the purchase to be: (1) at least fifty thousand dollars ($50,000); and (2) not more than one hundred fifty thousand dollars ($150,000). . . . (d) If the purchasing agent receives a satisfactory quote, the purchasing agent shall award a contract to the lowest responsible and responsive offeror for each line or class of supplies required. . . ." Cause The School Corporation was not able to provide documentation to demonstrate that quotes were obtained for purchases under the small purchase method. The School Corporation was unable to provide documentation to demonstrate it checked SAM.gov to verify the contractor was not suspended or debarred prior to entering into the contract. The School Corporation did not have proper policies and procedures in place due to being unaware of the grant requirements. Effect Without the proper implementation of an effectively designed system of internal controls, the School Corporation cannot ensure the contractors paid with federal funds are eligible to participate in federal programs. Any funds the School Corporation used to pay contractors that have been suspended or debarred would be unallowable, and the funding agency could potentially recover them. The School Corporation cannot ensure that contractors paid under the small purchase method were awarded the best price for their services. This could result in federal funding not providing as many services or projects as possible. Questioned Costs There were no questioned costs identified. INDIANA STATE BOARD OF ACCOUNTS 20 LIBERTY-PERRY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Recommendation We recommended that the School Corporation strengthen its system of internal controls to ensure the proper procurement method is followed and documentation is retained. We recommended the School Corporation document its internal control procedures performed to ensure that all contractors that are paid $25,000 or more, all or in part with federal funds, are not suspended or debarred from participating in federal programs before entering into any contracts. We also recommended strengthening its policies and procedures to ensure appropriate evidence is retained for audit. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-003 Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children Assistance Listings Numbers: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY 2023, FY 2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2022-003. Condition and Context An effective internal control system, which would include segregation of duties, was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Federal regulations allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisition threshold, which is set at $250,000. However, Indiana Code 5-22-8 has a more restrictive threshold of $150,000 or less for when small purchase procedures may be used. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds: micro-purchases, typically for those purchases $10,000 or under, and small purchase procedures for those purchases above the micropurchase threshold but below the simplified acquisition threshold. Nonfederal entities may establish a micro-purchase threshold higher than the federal threshold of $10,000 as established in the FAR in accordance with 2 CFR 200.320(a)(1)(iv) and (v). The School Corporation established a higher micropurchase threshold of $50,000. The School Corporation self-certified due to meeting the classification of a public institution and established a higher threshold consistent with state law (Indiana threshold of micropurchases is $50,000). Micro-purchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. Adequate internal controls were not in place over procurements made under the small purchase threshold for one of the two vendors tested during the audit period. The School Corporation made purchases with a vendor in fiscal year 2022-2023 totaling $97,773 and 2023-2024 totaling $59,070 but did not provide audit evidence that price quotations had been requested. Additionally, the School Corporation was not able to provide evidence that internal controls over suspension and debarment procedures were in place. The lack of internal controls was a systemic issue throughout the audit period. The noncompliance was isolated to procurement requirements. INDIANA STATE BOARD OF ACCOUNTS 18 LIBERTY-PERRY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.318(a) states: "The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non- Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.317 through 200.327." 2 CFR 200.320 states in part: "The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. (a) Informal procurement methods. When the value of the procurement for property or services under a Federal award does not exceed the simplified acquisition threshold (SAT), as defined in § 200.1, or a lower threshold established by a non-Federal entity, formal procurement methods are not required. The non-Federal entity may use informal procurement methods to expedite the completion of its transactions and minimize the associated administrative burden and cost. The informal methods used for procurement of property or services at or below the SAT include: . . . (1) . . . (iv) Non-Federal entity increase to the micro-purchase threshold up to $50,000. Non-Federal entities may establish a threshold higher than the micro-purchase threshold identified in the FAR in accordance with the requirements of this section. The non-Federal entity may self-certify a threshold up to $50,000 on an annual basis and must maintain documentation to be made available to the Federal awarding agency and auditors in accordance with § 200.334. The self-certification must include a justification, clear identification of the threshold, and supporting documentation of any of the following: (A) A qualification as a low-risk auditee, in accordance with the criteria in § 200.520 for the most recent audit; (B) An annual internal institutional risk assessment to identify, mitigate, and manage financial risks; or, INDIANA STATE BOARD OF ACCOUNTS 19 LIBERTY-PERRY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (C) For public institutions, a higher threshold consistent with State law. . . ." 2 CFR 180.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking the SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person." Indiana Code 5-22-8-3 states in part: "(a) This section applies only if the purchasing agent expects the purchase to be: (1) at least fifty thousand dollars ($50,000); and (2) not more than one hundred fifty thousand dollars ($150,000). . . . (d) If the purchasing agent receives a satisfactory quote, the purchasing agent shall award a contract to the lowest responsible and responsive offeror for each line or class of supplies required. . . ." Cause The School Corporation was not able to provide documentation to demonstrate that quotes were obtained for purchases under the small purchase method. The School Corporation was unable to provide documentation to demonstrate it checked SAM.gov to verify the contractor was not suspended or debarred prior to entering into the contract. The School Corporation did not have proper policies and procedures in place due to being unaware of the grant requirements. Effect Without the proper implementation of an effectively designed system of internal controls, the School Corporation cannot ensure the contractors paid with federal funds are eligible to participate in federal programs. Any funds the School Corporation used to pay contractors that have been suspended or debarred would be unallowable, and the funding agency could potentially recover them. The School Corporation cannot ensure that contractors paid under the small purchase method were awarded the best price for their services. This could result in federal funding not providing as many services or projects as possible. Questioned Costs There were no questioned costs identified. INDIANA STATE BOARD OF ACCOUNTS 20 LIBERTY-PERRY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Recommendation We recommended that the School Corporation strengthen its system of internal controls to ensure the proper procurement method is followed and documentation is retained. We recommended the School Corporation document its internal control procedures performed to ensure that all contractors that are paid $25,000 or more, all or in part with federal funds, are not suspended or debarred from participating in federal programs before entering into any contracts. We also recommended strengthening its policies and procedures to ensure appropriate evidence is retained for audit. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-003 Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children Assistance Listings Numbers: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY 2023, FY 2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2022-003. Condition and Context An effective internal control system, which would include segregation of duties, was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Federal regulations allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisition threshold, which is set at $250,000. However, Indiana Code 5-22-8 has a more restrictive threshold of $150,000 or less for when small purchase procedures may be used. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds: micro-purchases, typically for those purchases $10,000 or under, and small purchase procedures for those purchases above the micropurchase threshold but below the simplified acquisition threshold. Nonfederal entities may establish a micro-purchase threshold higher than the federal threshold of $10,000 as established in the FAR in accordance with 2 CFR 200.320(a)(1)(iv) and (v). The School Corporation established a higher micropurchase threshold of $50,000. The School Corporation self-certified due to meeting the classification of a public institution and established a higher threshold consistent with state law (Indiana threshold of micropurchases is $50,000). Micro-purchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. Adequate internal controls were not in place over procurements made under the small purchase threshold for one of the two vendors tested during the audit period. The School Corporation made purchases with a vendor in fiscal year 2022-2023 totaling $97,773 and 2023-2024 totaling $59,070 but did not provide audit evidence that price quotations had been requested. Additionally, the School Corporation was not able to provide evidence that internal controls over suspension and debarment procedures were in place. The lack of internal controls was a systemic issue throughout the audit period. The noncompliance was isolated to procurement requirements. INDIANA STATE BOARD OF ACCOUNTS 18 LIBERTY-PERRY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.318(a) states: "The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non- Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.317 through 200.327." 2 CFR 200.320 states in part: "The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. (a) Informal procurement methods. When the value of the procurement for property or services under a Federal award does not exceed the simplified acquisition threshold (SAT), as defined in § 200.1, or a lower threshold established by a non-Federal entity, formal procurement methods are not required. The non-Federal entity may use informal procurement methods to expedite the completion of its transactions and minimize the associated administrative burden and cost. The informal methods used for procurement of property or services at or below the SAT include: . . . (1) . . . (iv) Non-Federal entity increase to the micro-purchase threshold up to $50,000. Non-Federal entities may establish a threshold higher than the micro-purchase threshold identified in the FAR in accordance with the requirements of this section. The non-Federal entity may self-certify a threshold up to $50,000 on an annual basis and must maintain documentation to be made available to the Federal awarding agency and auditors in accordance with § 200.334. The self-certification must include a justification, clear identification of the threshold, and supporting documentation of any of the following: (A) A qualification as a low-risk auditee, in accordance with the criteria in § 200.520 for the most recent audit; (B) An annual internal institutional risk assessment to identify, mitigate, and manage financial risks; or, INDIANA STATE BOARD OF ACCOUNTS 19 LIBERTY-PERRY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (C) For public institutions, a higher threshold consistent with State law. . . ." 2 CFR 180.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking the SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person." Indiana Code 5-22-8-3 states in part: "(a) This section applies only if the purchasing agent expects the purchase to be: (1) at least fifty thousand dollars ($50,000); and (2) not more than one hundred fifty thousand dollars ($150,000). . . . (d) If the purchasing agent receives a satisfactory quote, the purchasing agent shall award a contract to the lowest responsible and responsive offeror for each line or class of supplies required. . . ." Cause The School Corporation was not able to provide documentation to demonstrate that quotes were obtained for purchases under the small purchase method. The School Corporation was unable to provide documentation to demonstrate it checked SAM.gov to verify the contractor was not suspended or debarred prior to entering into the contract. The School Corporation did not have proper policies and procedures in place due to being unaware of the grant requirements. Effect Without the proper implementation of an effectively designed system of internal controls, the School Corporation cannot ensure the contractors paid with federal funds are eligible to participate in federal programs. Any funds the School Corporation used to pay contractors that have been suspended or debarred would be unallowable, and the funding agency could potentially recover them. The School Corporation cannot ensure that contractors paid under the small purchase method were awarded the best price for their services. This could result in federal funding not providing as many services or projects as possible. Questioned Costs There were no questioned costs identified. INDIANA STATE BOARD OF ACCOUNTS 20 LIBERTY-PERRY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Recommendation We recommended that the School Corporation strengthen its system of internal controls to ensure the proper procurement method is followed and documentation is retained. We recommended the School Corporation document its internal control procedures performed to ensure that all contractors that are paid $25,000 or more, all or in part with federal funds, are not suspended or debarred from participating in federal programs before entering into any contracts. We also recommended strengthening its policies and procedures to ensure appropriate evidence is retained for audit. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-003 Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children Assistance Listings Numbers: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY 2023, FY 2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2022-003. Condition and Context An effective internal control system, which would include segregation of duties, was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Federal regulations allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisition threshold, which is set at $250,000. However, Indiana Code 5-22-8 has a more restrictive threshold of $150,000 or less for when small purchase procedures may be used. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds: micro-purchases, typically for those purchases $10,000 or under, and small purchase procedures for those purchases above the micropurchase threshold but below the simplified acquisition threshold. Nonfederal entities may establish a micro-purchase threshold higher than the federal threshold of $10,000 as established in the FAR in accordance with 2 CFR 200.320(a)(1)(iv) and (v). The School Corporation established a higher micropurchase threshold of $50,000. The School Corporation self-certified due to meeting the classification of a public institution and established a higher threshold consistent with state law (Indiana threshold of micropurchases is $50,000). Micro-purchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. Adequate internal controls were not in place over procurements made under the small purchase threshold for one of the two vendors tested during the audit period. The School Corporation made purchases with a vendor in fiscal year 2022-2023 totaling $97,773 and 2023-2024 totaling $59,070 but did not provide audit evidence that price quotations had been requested. Additionally, the School Corporation was not able to provide evidence that internal controls over suspension and debarment procedures were in place. The lack of internal controls was a systemic issue throughout the audit period. The noncompliance was isolated to procurement requirements. INDIANA STATE BOARD OF ACCOUNTS 18 LIBERTY-PERRY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.318(a) states: "The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non- Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.317 through 200.327." 2 CFR 200.320 states in part: "The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. (a) Informal procurement methods. When the value of the procurement for property or services under a Federal award does not exceed the simplified acquisition threshold (SAT), as defined in § 200.1, or a lower threshold established by a non-Federal entity, formal procurement methods are not required. The non-Federal entity may use informal procurement methods to expedite the completion of its transactions and minimize the associated administrative burden and cost. The informal methods used for procurement of property or services at or below the SAT include: . . . (1) . . . (iv) Non-Federal entity increase to the micro-purchase threshold up to $50,000. Non-Federal entities may establish a threshold higher than the micro-purchase threshold identified in the FAR in accordance with the requirements of this section. The non-Federal entity may self-certify a threshold up to $50,000 on an annual basis and must maintain documentation to be made available to the Federal awarding agency and auditors in accordance with § 200.334. The self-certification must include a justification, clear identification of the threshold, and supporting documentation of any of the following: (A) A qualification as a low-risk auditee, in accordance with the criteria in § 200.520 for the most recent audit; (B) An annual internal institutional risk assessment to identify, mitigate, and manage financial risks; or, INDIANA STATE BOARD OF ACCOUNTS 19 LIBERTY-PERRY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (C) For public institutions, a higher threshold consistent with State law. . . ." 2 CFR 180.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking the SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person." Indiana Code 5-22-8-3 states in part: "(a) This section applies only if the purchasing agent expects the purchase to be: (1) at least fifty thousand dollars ($50,000); and (2) not more than one hundred fifty thousand dollars ($150,000). . . . (d) If the purchasing agent receives a satisfactory quote, the purchasing agent shall award a contract to the lowest responsible and responsive offeror for each line or class of supplies required. . . ." Cause The School Corporation was not able to provide documentation to demonstrate that quotes were obtained for purchases under the small purchase method. The School Corporation was unable to provide documentation to demonstrate it checked SAM.gov to verify the contractor was not suspended or debarred prior to entering into the contract. The School Corporation did not have proper policies and procedures in place due to being unaware of the grant requirements. Effect Without the proper implementation of an effectively designed system of internal controls, the School Corporation cannot ensure the contractors paid with federal funds are eligible to participate in federal programs. Any funds the School Corporation used to pay contractors that have been suspended or debarred would be unallowable, and the funding agency could potentially recover them. The School Corporation cannot ensure that contractors paid under the small purchase method were awarded the best price for their services. This could result in federal funding not providing as many services or projects as possible. Questioned Costs There were no questioned costs identified. INDIANA STATE BOARD OF ACCOUNTS 20 LIBERTY-PERRY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Recommendation We recommended that the School Corporation strengthen its system of internal controls to ensure the proper procurement method is followed and documentation is retained. We recommended the School Corporation document its internal control procedures performed to ensure that all contractors that are paid $25,000 or more, all or in part with federal funds, are not suspended or debarred from participating in federal programs before entering into any contracts. We also recommended strengthening its policies and procedures to ensure appropriate evidence is retained for audit. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Finding 2024 – 002 – Single Audit Data Collection Form Not Filed by Due Date Condition: The data collection form for the Single Audit ended June 30, 2024, was not submitted to the Federal Audit Clearinghouse by March 31, 2025. Cause: The audit report was not issued prior to the March 31, 2025, submission date requirement. Therefore, the data collection form required at audit completion was not filed by this date. Criteria: 2 CFR section 200.512(b) provides for a form, referred to as the data collection form, to be prepared at the completion of each audit and submitted by the auditee to the Federal Audit Clearinghouse the earlier of 30 calendar days after receipt of the auditor’s reports or nine months after the end of the audit period Effect: The Town has not met the reporting requirements related to timely submission of the data collection form required for a Single Audit. Therefore, per 2 CFR section 200.520, the Town will not meet the low-risk auditee criteria for future Single Audits that requires submission of the data collection form and reporting package by the due date for each of the two preceding audit years Recommendation: We recommend the Town to develop specific procedures to ensure that the audit report is received prior to the March 31 reporting deadline. Response: The Town will work with the audit firm to ensure that the audit field work is scheduled with sufficient time to allow the audit report and data collection form to be filed timely in the future.
Finding 2024 – 002 – Single Audit Data Collection Form Not Filed by Due Date Condition: The data collection form for the Single Audit ended June 30, 2024, was not submitted to the Federal Audit Clearinghouse by March 31, 2025. Cause: The audit report was not issued prior to the March 31, 2025, submission date requirement. Therefore, the data collection form required at audit completion was not filed by this date. Criteria: 2 CFR section 200.512(b) provides for a form, referred to as the data collection form, to be prepared at the completion of each audit and submitted by the auditee to the Federal Audit Clearinghouse the earlier of 30 calendar days after receipt of the auditor’s reports or nine months after the end of the audit period Effect: The Town has not met the reporting requirements related to timely submission of the data collection form required for a Single Audit. Therefore, per 2 CFR section 200.520, the Town will not meet the low-risk auditee criteria for future Single Audits that requires submission of the data collection form and reporting package by the due date for each of the two preceding audit years Recommendation: We recommend the Town to develop specific procedures to ensure that the audit report is received prior to the March 31 reporting deadline. Response: The Town will work with the audit firm to ensure that the audit field work is scheduled with sufficient time to allow the audit report and data collection form to be filed timely in the future.
Finding 2024 – 002 – Single Audit Data Collection Form Not Filed by Due Date Condition: The data collection form for the Single Audit ended June 30, 2024, was not submitted to the Federal Audit Clearinghouse by March 31, 2025. Cause: The audit report was not issued prior to the March 31, 2025, submission date requirement. Therefore, the data collection form required at audit completion was not filed by this date. Criteria: 2 CFR section 200.512(b) provides for a form, referred to as the data collection form, to be prepared at the completion of each audit and submitted by the auditee to the Federal Audit Clearinghouse the earlier of 30 calendar days after receipt of the auditor’s reports or nine months after the end of the audit period Effect: The Town has not met the reporting requirements related to timely submission of the data collection form required for a Single Audit. Therefore, per 2 CFR section 200.520, the Town will not meet the low-risk auditee criteria for future Single Audits that requires submission of the data collection form and reporting package by the due date for each of the two preceding audit years Recommendation: We recommend the Town to develop specific procedures to ensure that the audit report is received prior to the March 31 reporting deadline. Response: The Town will work with the audit firm to ensure that the audit field work is scheduled with sufficient time to allow the audit report and data collection form to be filed timely in the future.
Finding 2024 – 002 – Single Audit Data Collection Form Not Filed by Due Date Condition: The data collection form for the Single Audit ended June 30, 2024, was not submitted to the Federal Audit Clearinghouse by March 31, 2025. Cause: The audit report was not issued prior to the March 31, 2025, submission date requirement. Therefore, the data collection form required at audit completion was not filed by this date. Criteria: 2 CFR section 200.512(b) provides for a form, referred to as the data collection form, to be prepared at the completion of each audit and submitted by the auditee to the Federal Audit Clearinghouse the earlier of 30 calendar days after receipt of the auditor’s reports or nine months after the end of the audit period Effect: The Town has not met the reporting requirements related to timely submission of the data collection form required for a Single Audit. Therefore, per 2 CFR section 200.520, the Town will not meet the low-risk auditee criteria for future Single Audits that requires submission of the data collection form and reporting package by the due date for each of the two preceding audit years Recommendation: We recommend the Town to develop specific procedures to ensure that the audit report is received prior to the March 31 reporting deadline. Response: The Town will work with the audit firm to ensure that the audit field work is scheduled with sufficient time to allow the audit report and data collection form to be filed timely in the future.
Finding 2024 – 002 – Single Audit Data Collection Form Not Filed by Due Date Condition: The data collection form for the Single Audit ended June 30, 2024, was not submitted to the Federal Audit Clearinghouse by March 31, 2025. Cause: The audit report was not issued prior to the March 31, 2025, submission date requirement. Therefore, the data collection form required at audit completion was not filed by this date. Criteria: 2 CFR section 200.512(b) provides for a form, referred to as the data collection form, to be prepared at the completion of each audit and submitted by the auditee to the Federal Audit Clearinghouse the earlier of 30 calendar days after receipt of the auditor’s reports or nine months after the end of the audit period Effect: The Town has not met the reporting requirements related to timely submission of the data collection form required for a Single Audit. Therefore, per 2 CFR section 200.520, the Town will not meet the low-risk auditee criteria for future Single Audits that requires submission of the data collection form and reporting package by the due date for each of the two preceding audit years Recommendation: We recommend the Town to develop specific procedures to ensure that the audit report is received prior to the March 31 reporting deadline. Response: The Town will work with the audit firm to ensure that the audit field work is scheduled with sufficient time to allow the audit report and data collection form to be filed timely in the future.
Finding Number: 2024-004 Repeat Finding: Similar to prior year finding 2023-005 Program Name/Assistance Listing Title: Indian School Equalization Program, Administrative Cost Grants for Indian Schools, Indian Education Facilities, Operations, and Maintenance, Special Education Cluster, and Education Stabilization Fund - COVID-19 Assistance Listing Number: 15.042, 15.046, 15.047, 84.010, 84.027, and 84.425D Federal Agency: U.S. Department of the Interior, U.S. Department of Treasury, U.S. Department of Education Federal Award Number: A23AV00811, Unknown (21.027) Questioned Costs: None Type of Finding: Noncompliance, Material Weakness Compliance Requirement: Reporting Criteria: 2 CFR § 200.512(a) provides, in part: "The audit must be completed and the data collection form ... must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period." 2 CFR § 200.520 provides, in part: "That to qualify as a low-risk auditee and be eligible for reduced audit coverage the following condition must be met: Single audits were performed on an annual basis in accordance with the provisions of this Subpart, including submitting the data collection form and the reporting package to the FAC within the timeframe specified in § 200.512." Condition: The School did submit their audit for the fiscal year ending June 30, 2024 timely. The audit was submitted August XX, 2025, which was XXX days past the March 31, 2025 deadline. Effect: Not making all audit documentation available in a timely manner resulted in the audit and data collection form submissions to be late and, therefore, not available to the public within the required timeframe. This late submission also excludes the School from qualifying as a low-risk auditee. Cause: Management oversight. Recommendation: The School should implement procedures to ensure that all audit documentation is available for the audit in a timely manner and the audit report is completed and submitted within the appropriate timeframe. Response: The School’s responses are presented in a separate document. Contact person: Dolores Silva, Chief Financial Officer
Finding Number: 2024-004 Repeat Finding: Similar to prior year finding 2023-005 Program Name/Assistance Listing Title: Indian School Equalization Program, Administrative Cost Grants for Indian Schools, Indian Education Facilities, Operations, and Maintenance, Special Education Cluster, and Education Stabilization Fund - COVID-19 Assistance Listing Number: 15.042, 15.046, 15.047, 84.010, 84.027, and 84.425D Federal Agency: U.S. Department of the Interior, U.S. Department of Treasury, U.S. Department of Education Federal Award Number: A23AV00811, Unknown (21.027) Questioned Costs: None Type of Finding: Noncompliance, Material Weakness Compliance Requirement: Reporting Criteria: 2 CFR § 200.512(a) provides, in part: "The audit must be completed and the data collection form ... must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period." 2 CFR § 200.520 provides, in part: "That to qualify as a low-risk auditee and be eligible for reduced audit coverage the following condition must be met: Single audits were performed on an annual basis in accordance with the provisions of this Subpart, including submitting the data collection form and the reporting package to the FAC within the timeframe specified in § 200.512." Condition: The School did submit their audit for the fiscal year ending June 30, 2024 timely. The audit was submitted August XX, 2025, which was XXX days past the March 31, 2025 deadline. Effect: Not making all audit documentation available in a timely manner resulted in the audit and data collection form submissions to be late and, therefore, not available to the public within the required timeframe. This late submission also excludes the School from qualifying as a low-risk auditee. Cause: Management oversight. Recommendation: The School should implement procedures to ensure that all audit documentation is available for the audit in a timely manner and the audit report is completed and submitted within the appropriate timeframe. Response: The School’s responses are presented in a separate document. Contact person: Dolores Silva, Chief Financial Officer
Finding Number: 2024-004 Repeat Finding: Similar to prior year finding 2023-005 Program Name/Assistance Listing Title: Indian School Equalization Program, Administrative Cost Grants for Indian Schools, Indian Education Facilities, Operations, and Maintenance, Special Education Cluster, and Education Stabilization Fund - COVID-19 Assistance Listing Number: 15.042, 15.046, 15.047, 84.010, 84.027, and 84.425D Federal Agency: U.S. Department of the Interior, U.S. Department of Treasury, U.S. Department of Education Federal Award Number: A23AV00811, Unknown (21.027) Questioned Costs: None Type of Finding: Noncompliance, Material Weakness Compliance Requirement: Reporting Criteria: 2 CFR § 200.512(a) provides, in part: "The audit must be completed and the data collection form ... must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period." 2 CFR § 200.520 provides, in part: "That to qualify as a low-risk auditee and be eligible for reduced audit coverage the following condition must be met: Single audits were performed on an annual basis in accordance with the provisions of this Subpart, including submitting the data collection form and the reporting package to the FAC within the timeframe specified in § 200.512." Condition: The School did submit their audit for the fiscal year ending June 30, 2024 timely. The audit was submitted August XX, 2025, which was XXX days past the March 31, 2025 deadline. Effect: Not making all audit documentation available in a timely manner resulted in the audit and data collection form submissions to be late and, therefore, not available to the public within the required timeframe. This late submission also excludes the School from qualifying as a low-risk auditee. Cause: Management oversight. Recommendation: The School should implement procedures to ensure that all audit documentation is available for the audit in a timely manner and the audit report is completed and submitted within the appropriate timeframe. Response: The School’s responses are presented in a separate document. Contact person: Dolores Silva, Chief Financial Officer
Finding Number: 2024-004 Repeat Finding: Similar to prior year finding 2023-005 Program Name/Assistance Listing Title: Indian School Equalization Program, Administrative Cost Grants for Indian Schools, Indian Education Facilities, Operations, and Maintenance, Special Education Cluster, and Education Stabilization Fund - COVID-19 Assistance Listing Number: 15.042, 15.046, 15.047, 84.010, 84.027, and 84.425D Federal Agency: U.S. Department of the Interior, U.S. Department of Treasury, U.S. Department of Education Federal Award Number: A23AV00811, Unknown (21.027) Questioned Costs: None Type of Finding: Noncompliance, Material Weakness Compliance Requirement: Reporting Criteria: 2 CFR § 200.512(a) provides, in part: "The audit must be completed and the data collection form ... must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period." 2 CFR § 200.520 provides, in part: "That to qualify as a low-risk auditee and be eligible for reduced audit coverage the following condition must be met: Single audits were performed on an annual basis in accordance with the provisions of this Subpart, including submitting the data collection form and the reporting package to the FAC within the timeframe specified in § 200.512." Condition: The School did submit their audit for the fiscal year ending June 30, 2024 timely. The audit was submitted August XX, 2025, which was XXX days past the March 31, 2025 deadline. Effect: Not making all audit documentation available in a timely manner resulted in the audit and data collection form submissions to be late and, therefore, not available to the public within the required timeframe. This late submission also excludes the School from qualifying as a low-risk auditee. Cause: Management oversight. Recommendation: The School should implement procedures to ensure that all audit documentation is available for the audit in a timely manner and the audit report is completed and submitted within the appropriate timeframe. Response: The School’s responses are presented in a separate document. Contact person: Dolores Silva, Chief Financial Officer
Finding Number: 2024-004 Repeat Finding: Similar to prior year finding 2023-005 Program Name/Assistance Listing Title: Indian School Equalization Program, Administrative Cost Grants for Indian Schools, Indian Education Facilities, Operations, and Maintenance, Special Education Cluster, and Education Stabilization Fund - COVID-19 Assistance Listing Number: 15.042, 15.046, 15.047, 84.010, 84.027, and 84.425D Federal Agency: U.S. Department of the Interior, U.S. Department of Treasury, U.S. Department of Education Federal Award Number: A23AV00811, Unknown (21.027) Questioned Costs: None Type of Finding: Noncompliance, Material Weakness Compliance Requirement: Reporting Criteria: 2 CFR § 200.512(a) provides, in part: "The audit must be completed and the data collection form ... must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period." 2 CFR § 200.520 provides, in part: "That to qualify as a low-risk auditee and be eligible for reduced audit coverage the following condition must be met: Single audits were performed on an annual basis in accordance with the provisions of this Subpart, including submitting the data collection form and the reporting package to the FAC within the timeframe specified in § 200.512." Condition: The School did submit their audit for the fiscal year ending June 30, 2024 timely. The audit was submitted August XX, 2025, which was XXX days past the March 31, 2025 deadline. Effect: Not making all audit documentation available in a timely manner resulted in the audit and data collection form submissions to be late and, therefore, not available to the public within the required timeframe. This late submission also excludes the School from qualifying as a low-risk auditee. Cause: Management oversight. Recommendation: The School should implement procedures to ensure that all audit documentation is available for the audit in a timely manner and the audit report is completed and submitted within the appropriate timeframe. Response: The School’s responses are presented in a separate document. Contact person: Dolores Silva, Chief Financial Officer
Submission of the Audit Package and Data Collection Form - Federal Agency: Various Assistance Listing Number: Multiple Compliance Requirement: Reporting Criteria: Per 2 CFR §200.510(b), the auditee must prepare a Schedule of Federal Awards (SEFA) for the period covered by the auditee’s financial statements. Per §200.512(a), the SEFA must be submitted to the Federal Audit Clearinghouse (FAC) within the required deadline. Condition: The audit reporting package and data collection form for the year ended June 30, 2024, was not submitted to the FAC within the timeframe as required by the Uniform Guidance. Cause: The delay was due to identified discrepancies and inconsistencies in the initial financial statement reconciliations which the Organization subsequently prepared revised reconciliations, made material adjustments to affected accounts, and issued an updated trial balance. This caused a significant delay in the audit testing and wrap up. Effect: To qualify as a low-risk auditee, 2 CFR section 200.520 requires the audit reporting package and data collection form to be submitted to the FAC by the due date for each of the previous two years. Late filing will result in noncompliance with timely submission of financial information to the grantor agencies. Recommendation: We recommend the Organization strengthen its internal controls over the reconciliation process, including implementing a formal review procedure and ensuring reconciliations are supported by complete and accurate documentation prior to audit fieldwork. Timely and accurate reconciliations are critical to maintaining reliable financial reporting and audit readiness. Questioned costs: None Responsible Official's Response: CMJTS acknowledges the delay and has been making improvements to ensure reconciliations are done timely. Accounting staff have been given additional training on bank reconciliations, and they are now reconciling bank transactions daily. This real time reconciling helps ensure that all transactions are processed accurately. Bank reconciliations are then signed off by Finance Manager and the Board Treasurer monthly. Accounting staff have been given additional training on statement of financial position reconciliations and will be reconciling them monthly. The statement of financial position, with supporting documentation, will then be signed off by the Finance Manager monthly.
Single Audit Data Collection Form Not Filed by Due Date- Condition: The data collection form for the Single Audit ended May 31, 2023 was not submitted to the Federal Clearinghouse by Feburary 28, 2024.Criteria" 2 CRF Section 200.512(b) provides for a form, referred to as the data collection form, to be prepared at the completion of each audit and submitted by the auditee to the Federal Audit Clearinghouse the earlier of 30 calendar days after the receipt of the auditor's report or nine months after the end of the audit period. Cause: THe audit report was not issued prior to February 28, 2024, submission date requirement. Therefore, the data collection form required at audit completion was not filed by this date. Effect: The Organization has not met the reporting requirements related to timely submission of the data collection from required for a Single Audit. Therefore, per 2 CFR section 200.520, the Organization will not meet the low-risk auditee criteria for the next Single Audit the requires sbumission of the data collection form and reporting package. Recommendation: We recommend that the Organization develop specific procedures to ensure that the data collection for is submitted prior to the February 28th reporting deadline. Response: The Organization will work with the audit firm to ensure the data collection form is filed timely.
Single Audit Data Collection Form Not Filed by Due Date- Condition: The data collection form for the Single Audit ended May 31, 2023 was not submitted to the Federal Clearinghouse by Feburary 28, 2024.Criteria" 2 CRF Section 200.512(b) provides for a form, referred to as the data collection form, to be prepared at the completion of each audit and submitted by the auditee to the Federal Audit Clearinghouse the earlier of 30 calendar days after the receipt of the auditor's report or nine months after the end of the audit period. Cause: THe audit report was not issued prior to February 28, 2024, submission date requirement. Therefore, the data collection form required at audit completion was not filed by this date. Effect: The Organization has not met the reporting requirements related to timely submission of the data collection from required for a Single Audit. Therefore, per 2 CFR section 200.520, the Organization will not meet the low-risk auditee criteria for the next Single Audit the requires sbumission of the data collection form and reporting package. Recommendation: We recommend that the Organization develop specific procedures to ensure that the data collection for is submitted prior to the February 28th reporting deadline. Response: The Organization will work with the audit firm to ensure the data collection form is filed timely.
Program: CFDA #93.224 - Consolidated Health Centers, CFDA #93.527 - Grants for New and Expanded Services under the Health Center Program. Condition: For the second consecutive years, BRHC did not comply with the required submission date of the data collection form and reporting package to the Federal Audit Clearinghouse (FAC) for the year ended December 31, 2023. Criteria: The Uniform Guidance in 2 CFR section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the FAC within the earlier of 30 days after receipt of the auditor's report or nine (9) months after year end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Cause: The audit report was not issued prior to the September 30, 2023, submission date requirement. Therefore, the data collection form required at audit completion was not filed by this date. Effect: BRHC has not met the reporting requirements related to timely submission of the data collection form required for a Single Audit. Therefore, per 2 CFR section 200.520, BRHC will not meet the low-risk auditee criteria for future Single Audits that requires submission of the data collection form and reporting package by the due date for each of the two proceeding audit years. Recommendation: We recommend that BRHC develop specific procedures to ensure that the audit report is received prior to the September 30 reporting deadline. View of Responsible Officials and Planned Corrective Action: See Corrective Action Plan.
Program: CFDA #93.224 - Consolidated Health Centers, CFDA #93.527 - Grants for New and Expanded Services under the Health Center Program. Condition: For the second consecutive years, BRHC did not comply with the required submission date of the data collection form and reporting package to the Federal Audit Clearinghouse (FAC) for the year ended December 31, 2023. Criteria: The Uniform Guidance in 2 CFR section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the FAC within the earlier of 30 days after receipt of the auditor's report or nine (9) months after year end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Cause: The audit report was not issued prior to the September 30, 2023, submission date requirement. Therefore, the data collection form required at audit completion was not filed by this date. Effect: BRHC has not met the reporting requirements related to timely submission of the data collection form required for a Single Audit. Therefore, per 2 CFR section 200.520, BRHC will not meet the low-risk auditee criteria for future Single Audits that requires submission of the data collection form and reporting package by the due date for each of the two proceeding audit years. Recommendation: We recommend that BRHC develop specific procedures to ensure that the audit report is received prior to the September 30 reporting deadline. View of Responsible Officials and Planned Corrective Action: See Corrective Action Plan.
Program: CFDA #93.224 - Consolidated Health Centers, CFDA #93.527 - Grants for New and Expanded Services under the Health Center Program. Condition: For the second consecutive years, BRHC did not comply with the required submission date of the data collection form and reporting package to the Federal Audit Clearinghouse (FAC) for the year ended December 31, 2023. Criteria: The Uniform Guidance in 2 CFR section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the FAC within the earlier of 30 days after receipt of the auditor's report or nine (9) months after year end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Cause: The audit report was not issued prior to the September 30, 2023, submission date requirement. Therefore, the data collection form required at audit completion was not filed by this date. Effect: BRHC has not met the reporting requirements related to timely submission of the data collection form required for a Single Audit. Therefore, per 2 CFR section 200.520, BRHC will not meet the low-risk auditee criteria for future Single Audits that requires submission of the data collection form and reporting package by the due date for each of the two proceeding audit years. Recommendation: We recommend that BRHC develop specific procedures to ensure that the audit report is received prior to the September 30 reporting deadline. View of Responsible Officials and Planned Corrective Action: See Corrective Action Plan.
Program: CFDA #93.224 - Consolidated Health Centers, CFDA #93.527 - Grants for New and Expanded Services under the Health Center Program. Condition: For the second consecutive years, BRHC did not comply with the required submission date of the data collection form and reporting package to the Federal Audit Clearinghouse (FAC) for the year ended December 31, 2023. Criteria: The Uniform Guidance in 2 CFR section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the FAC within the earlier of 30 days after receipt of the auditor's report or nine (9) months after year end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Cause: The audit report was not issued prior to the September 30, 2023, submission date requirement. Therefore, the data collection form required at audit completion was not filed by this date. Effect: BRHC has not met the reporting requirements related to timely submission of the data collection form required for a Single Audit. Therefore, per 2 CFR section 200.520, BRHC will not meet the low-risk auditee criteria for future Single Audits that requires submission of the data collection form and reporting package by the due date for each of the two proceeding audit years. Recommendation: We recommend that BRHC develop specific procedures to ensure that the audit report is received prior to the September 30 reporting deadline. View of Responsible Officials and Planned Corrective Action: See Corrective Action Plan.
Program: CFDA #93.224 - Consolidated Health Centers, CFDA #93.527 - Grants for New and Expanded Services under the Health Center Program. Condition: For the second consecutive years, BRHC did not comply with the required submission date of the data collection form and reporting package to the Federal Audit Clearinghouse (FAC) for the year ended December 31, 2023. Criteria: The Uniform Guidance in 2 CFR section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the FAC within the earlier of 30 days after receipt of the auditor's report or nine (9) months after year end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Cause: The audit report was not issued prior to the September 30, 2023, submission date requirement. Therefore, the data collection form required at audit completion was not filed by this date. Effect: BRHC has not met the reporting requirements related to timely submission of the data collection form required for a Single Audit. Therefore, per 2 CFR section 200.520, BRHC will not meet the low-risk auditee criteria for future Single Audits that requires submission of the data collection form and reporting package by the due date for each of the two proceeding audit years. Recommendation: We recommend that BRHC develop specific procedures to ensure that the audit report is received prior to the September 30 reporting deadline. View of Responsible Officials and Planned Corrective Action: See Corrective Action Plan.
Program: CFDA #93.224 - Consolidated Health Centers, CFDA #93.527 - Grants for New and Expanded Services under the Health Center Program. Condition: For the second consecutive years, BRHC did not comply with the required submission date of the data collection form and reporting package to the Federal Audit Clearinghouse (FAC) for the year ended December 31, 2023. Criteria: The Uniform Guidance in 2 CFR section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the FAC within the earlier of 30 days after receipt of the auditor's report or nine (9) months after year end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Cause: The audit report was not issued prior to the September 30, 2023, submission date requirement. Therefore, the data collection form required at audit completion was not filed by this date. Effect: BRHC has not met the reporting requirements related to timely submission of the data collection form required for a Single Audit. Therefore, per 2 CFR section 200.520, BRHC will not meet the low-risk auditee criteria for future Single Audits that requires submission of the data collection form and reporting package by the due date for each of the two proceeding audit years. Recommendation: We recommend that BRHC develop specific procedures to ensure that the audit report is received prior to the September 30 reporting deadline. View of Responsible Officials and Planned Corrective Action: See Corrective Action Plan.
Program: CFDA #93.224 - Consolidated Health Centers, CFDA #93.527 - Grants for New and Expanded Services under the Health Center Program. Condition: For the second consecutive years, BRHC did not comply with the required submission date of the data collection form and reporting package to the Federal Audit Clearinghouse (FAC) for the year ended December 31, 2023. Criteria: The Uniform Guidance in 2 CFR section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the FAC within the earlier of 30 days after receipt of the auditor's report or nine (9) months after year end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Cause: The audit report was not issued prior to the September 30, 2023, submission date requirement. Therefore, the data collection form required at audit completion was not filed by this date. Effect: BRHC has not met the reporting requirements related to timely submission of the data collection form required for a Single Audit. Therefore, per 2 CFR section 200.520, BRHC will not meet the low-risk auditee criteria for future Single Audits that requires submission of the data collection form and reporting package by the due date for each of the two proceeding audit years. Recommendation: We recommend that BRHC develop specific procedures to ensure that the audit report is received prior to the September 30 reporting deadline. View of Responsible Officials and Planned Corrective Action: See Corrective Action Plan.
Program: CFDA #93.224 - Consolidated Health Centers, CFDA #93.527 - Grants for New and Expanded Services under the Health Center Program. Condition: For the second consecutive years, BRHC did not comply with the required submission date of the data collection form and reporting package to the Federal Audit Clearinghouse (FAC) for the year ended December 31, 2023. Criteria: The Uniform Guidance in 2 CFR section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the FAC within the earlier of 30 days after receipt of the auditor's report or nine (9) months after year end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Cause: The audit report was not issued prior to the September 30, 2023, submission date requirement. Therefore, the data collection form required at audit completion was not filed by this date. Effect: BRHC has not met the reporting requirements related to timely submission of the data collection form required for a Single Audit. Therefore, per 2 CFR section 200.520, BRHC will not meet the low-risk auditee criteria for future Single Audits that requires submission of the data collection form and reporting package by the due date for each of the two proceeding audit years. Recommendation: We recommend that BRHC develop specific procedures to ensure that the audit report is received prior to the September 30 reporting deadline. View of Responsible Officials and Planned Corrective Action: See Corrective Action Plan.
Program: CFDA #93.224 - Consolidated Health Centers, CFDA #93.527 - Grants for New and Expanded Services under the Health Center Program. Condition: For the second consecutive years, BRHC did not comply with the required submission date of the data collection form and reporting package to the Federal Audit Clearinghouse (FAC) for the year ended December 31, 2023. Criteria: The Uniform Guidance in 2 CFR section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the FAC within the earlier of 30 days after receipt of the auditor's report or nine (9) months after year end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Cause: The audit report was not issued prior to the September 30, 2023, submission date requirement. Therefore, the data collection form required at audit completion was not filed by this date. Effect: BRHC has not met the reporting requirements related to timely submission of the data collection form required for a Single Audit. Therefore, per 2 CFR section 200.520, BRHC will not meet the low-risk auditee criteria for future Single Audits that requires submission of the data collection form and reporting package by the due date for each of the two proceeding audit years. Recommendation: We recommend that BRHC develop specific procedures to ensure that the audit report is received prior to the September 30 reporting deadline. View of Responsible Officials and Planned Corrective Action: See Corrective Action Plan.
Program: CFDA #93.224 - Consolidated Health Centers, CFDA #93.527 - Grants for New and Expanded Services under the Health Center Program. Condition: For the second consecutive years, BRHC did not comply with the required submission date of the data collection form and reporting package to the Federal Audit Clearinghouse (FAC) for the year ended December 31, 2023. Criteria: The Uniform Guidance in 2 CFR section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the FAC within the earlier of 30 days after receipt of the auditor's report or nine (9) months after year end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Cause: The audit report was not issued prior to the September 30, 2023, submission date requirement. Therefore, the data collection form required at audit completion was not filed by this date. Effect: BRHC has not met the reporting requirements related to timely submission of the data collection form required for a Single Audit. Therefore, per 2 CFR section 200.520, BRHC will not meet the low-risk auditee criteria for future Single Audits that requires submission of the data collection form and reporting package by the due date for each of the two proceeding audit years. Recommendation: We recommend that BRHC develop specific procedures to ensure that the audit report is received prior to the September 30 reporting deadline. View of Responsible Officials and Planned Corrective Action: See Corrective Action Plan.
Program: CFDA #93.224 - Consolidated Health Centers, CFDA #93.527 - Grants for New and Expanded Services under the Health Center Program. Condition: For the second consecutive years, BRHC did not comply with the required submission date of the data collection form and reporting package to the Federal Audit Clearinghouse (FAC) for the year ended December 31, 2023. Criteria: The Uniform Guidance in 2 CFR section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the FAC within the earlier of 30 days after receipt of the auditor's report or nine (9) months after year end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Cause: The audit report was not issued prior to the September 30, 2023, submission date requirement. Therefore, the data collection form required at audit completion was not filed by this date. Effect: BRHC has not met the reporting requirements related to timely submission of the data collection form required for a Single Audit. Therefore, per 2 CFR section 200.520, BRHC will not meet the low-risk auditee criteria for future Single Audits that requires submission of the data collection form and reporting package by the due date for each of the two proceeding audit years. Recommendation: We recommend that BRHC develop specific procedures to ensure that the audit report is received prior to the September 30 reporting deadline. View of Responsible Officials and Planned Corrective Action: See Corrective Action Plan.
Program: CFDA #93.224 - Consolidated Health Centers, CFDA #93.527 - Grants for New and Expanded Services under the Health Center Program. Condition: For the second consecutive years, BRHC did not comply with the required submission date of the data collection form and reporting package to the Federal Audit Clearinghouse (FAC) for the year ended December 31, 2023. Criteria: The Uniform Guidance in 2 CFR section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the FAC within the earlier of 30 days after receipt of the auditor's report or nine (9) months after year end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Cause: The audit report was not issued prior to the September 30, 2023, submission date requirement. Therefore, the data collection form required at audit completion was not filed by this date. Effect: BRHC has not met the reporting requirements related to timely submission of the data collection form required for a Single Audit. Therefore, per 2 CFR section 200.520, BRHC will not meet the low-risk auditee criteria for future Single Audits that requires submission of the data collection form and reporting package by the due date for each of the two proceeding audit years. Recommendation: We recommend that BRHC develop specific procedures to ensure that the audit report is received prior to the September 30 reporting deadline. View of Responsible Officials and Planned Corrective Action: See Corrective Action Plan.
U.S. Department of Health and Human Services Pass-Through Minnesota Department of Commerce ALN 93.568 Low-Income Home Energy Assistance U.S. Department of Health and Human Services Direct ALN 93.600 Head Start Cluster Finding 2023-001: Submission of the Audit Reporting Package and Data Collection Form (Repeat of Finding 2022-001) Criteria: The auditee is responsible for ensuring the timely submission of the audit reporting package and data collection form to the Federal Audit Clearing Housing (FAC). Condition: The audit reporting package and data collection form for the year ended September 30, 2023, was not submitted to the FAC within the timeframe as required by the Uniform Guidance. Cause: The audit was not completed as of the due date of submission. Effect: To qualify as a low-risk auditee, 2 CFR section 200.520 requires the audit reporting package and data collection form to be submitted to the FAC by the due date for each of the previous two years. Late filing will result in noncompliance with timely submission of financial information to the grantor agencies. Recommendation: We recommend the submission of the audit reporting package and the data collection form as soon as the audit is available Questioned costs: None Responsible Official's Response: We agree with the auditors' comments, and the following action will be taken to improve the situation. Semcac will be increasing capacity within the accounting department, specifically around audit tasks as well as implementing strategies throughout our programs to create efficiencies that will drive timely and accurate submission of financial transactions.