Finding 1106021 (2024-002)

Material Weakness
Requirement
E
Questioned Costs
-
Year
2024
Accepted
2025-03-24

AI Summary

  • Core Issue: The School Corporation lacks effective internal controls for verifying eligibility of students receiving free/reduced meal benefits through Direct Certification.
  • Impacted Requirements: Non-compliance with 2 CFR 200.303 regarding internal control systems for managing federal awards.
  • Recommended Follow-Up: Management should implement a review process by someone other than the Assistant Food Service Director to ensure accuracy in eligibility determinations.

Finding Text

FINDING 2024-002 Subject: Child Nutrition Cluster - Eligibility 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 23, FY 24 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Finding: Material Weakness Condition and Context An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Eligibility compliance requirement. The Indiana Department of Education defines "Direct Certification" (DC) as follows: "(DC) is a method to automatically qualify students for free or reduced meals using data from Family and Social Services Administration (SNAP, TANF, and Medicaid) and Department of Child Services (Foster) and matching that with the Local Educational Agency's reported enrollment. Direct Certified households do not need to complete a meal application and will not be included in the verification process because their eligibility has already been verified." Internal controls had not been properly designed and implemented over students receiving free/reduced price meal benefits via DC. The Assistant Food Service Director generated the DC reports on the School Nutrition Program Indiana web portal and entered resulting eligibility determinations into the point-of-sale system (Harmony) without a documented oversight, review or approval in process in place to ensure their accuracy. The lack of internal controls over the DCs was a systemic issue throughout the audit period. 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). . . ." Cause School Corporation officials were unaware they should document a review of the DC process by someone other than the Assistant Food Service Director. Effect The lack of an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the Eligibility compliance requirement. Verifying the accuracy of students directly certified for benefits in the point-of-sale system will ensure that ineligible students do not receive free or reduced-price meals. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management strengthen its system of internal controls to ensure that directly certified students eligible for meal benefits are verified for accuracy in Harmony by someone other than the Assistant Food Service Director. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

Categories

School Nutrition Programs Eligibility Matching / Level of Effort / Earmarking Material Weakness Internal Control / Segregation of Duties

Other Findings in this Audit

  • 529571 2024-002
    Material Weakness
  • 529572 2024-003
    Material Weakness Repeat
  • 529573 2024-002
    Material Weakness
  • 529574 2024-003
    Material Weakness Repeat
  • 529575 2024-002
    Material Weakness
  • 529576 2024-003
    Material Weakness Repeat
  • 529577 2024-002
    Material Weakness
  • 529578 2024-003
    Material Weakness Repeat
  • 529579 2024-002
    Material Weakness
  • 529580 2024-003
    Material Weakness Repeat
  • 529581 2024-002
    Material Weakness
  • 529582 2024-003
    Material Weakness Repeat
  • 1106013 2024-002
    Material Weakness
  • 1106014 2024-003
    Material Weakness Repeat
  • 1106015 2024-002
    Material Weakness
  • 1106016 2024-003
    Material Weakness Repeat
  • 1106017 2024-002
    Material Weakness
  • 1106018 2024-003
    Material Weakness Repeat
  • 1106019 2024-002
    Material Weakness
  • 1106020 2024-003
    Material Weakness Repeat
  • 1106022 2024-003
    Material Weakness Repeat
  • 1106023 2024-002
    Material Weakness
  • 1106024 2024-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
10.555 National School Lunch Program 2023 $633,763
10.555 National School Lunch Program 2024 $513,584
84.425 Education Stabilization Fund 2023 $416,492
84.010 Title I Grants to Local Educational Agencies 2023 $180,339
84.425 Education Stabilization Fund 2024 $167,603
10.553 School Breakfast Program 2023 $161,524
84.010 Title I Grants to Local Educational Agencies 2024 $151,292
10.553 School Breakfast Program 2024 $138,705
84.002 Adult Education - Basic Grants to States 2024 $74,991
84.027 Special Education Grants to States 2023 $56,964
84.252 Urban Community Service 2024 $50,022
93.778 Medical Assistance Program 2024 $42,624
93.778 Medical Assistance Program 2023 $38,580
10.559 Summer Food Service Program for Children 2024 $36,559
84.002 Adult Education - Basic Grants to States 2023 $32,838
10.559 Summer Food Service Program for Children 2023 $32,023
84.367 Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) 2023 $31,062
84.367 Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) 2024 $22,738
84.424 Student Support and Academic Enrichment Program 2024 $21,643
84.424 Student Support and Academic Enrichment Program 2023 $17,989
84.027 Special Education Grants to States 2024 $14,313
84.173 Special Education Preschool Grants 2024 $12,118
84.252 Urban Community Service 2023 $8,821
84.173 Special Education Preschool Grants 2023 $5,321