Finding Text
FINDING 2024-001
Information on the federal program:
Subject: Child Nutrition Cluster - Internal Controls
Federal Agency: Department of Agriculture
Federal Program: School Breakfast Program, National School Lunch Program
Assistance Listing Number: 10.553, 10.555
Federal Award Numbers and Years (or Other Identifying Numbers): FY 22-23, FY 23-24
Pass-Through Entity: Indiana Department of Education
Compliance Requirement: Eligibility
Audit Finding: Material Weakness
Criteria: 2 CFR section 200.303 states in part:
"The non-Federal entity must:
(a) Establish and maintain effective internal control over Federal award that provides reasonable assurance
that the non-Federal entity is managing the Federal awards 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). . . ."
7 CFR 245.3(c) sates in part:
Each School Food Authority shall serve free and reduced price meals or free milk in the respective programs
to children eligible under its eligibility criteria.
Condition: An effective internal control system was not in place at the School Corporation in order to
ensure compliance with requirements related to the grant agreement and the eligibility compliance
requirement.
Cause: The School Corporation's management had not developed a system of internal controls to ensure
compliance with eligibility requirements.
Effect: The failure to establish an effective internal control system placed the School Corporation at risk of
noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties
within an internal control system could have also allowed noncompliance with the compliance requirements
and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight,
reviews, and approvals over the activities of the programs.
Questioned Costs: There were no questioned costs identified.
Context: During the testing of internal controls over eligibility determinations for free and reduced meals,
we noted there was no formal review control in place. There is no documented, secondary review for the
applications entered in the food service software which determines eligibility. Additionally, there was no
documented review by School Corporation personnel of the Income Eligibility Guidelines used by the food
service software which are updated on annual basis.
Identification as a repeat finding, if applicable: No.
Recommendation: We recommend that the School Corporation's management establish an internal
control process to review the updates to the annual adjustments to the Income Eligibility Guidelines made
to the food service software to determine eligibility to ensure updated guidelines are accurate and complete.
This review should be documented on annual basis to confirm management’s oversight and monitoring of
eligibility determinations.
Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding
and has prepared a corrective action plan.