Finding 1114529 (2024-001)

Significant Deficiency
Requirement
E
Questioned Costs
-
Year
2024
Accepted
2025-03-27

AI Summary

  • Core Issue: The School Corporation lacks an effective internal control system to ensure compliance with eligibility requirements for federal nutrition programs.
  • Impacted Requirements: Noncompliance with 2 CFR 200.303 and 7 CFR 245.3(c) regarding proper documentation and review of free and reduced-price lunch eligibility.
  • Recommended Follow-Up: Management should implement a robust internal control system to monitor eligibility compliance and ensure accurate funding and meal pricing.

Finding Text

FINDING 2024-001 Subject: Child Nutrition Cluster - Eligibility Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program Assistance Listings Numbers: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY 2022-2023, FY 2023-2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Finding: Significant Deficiency INDIANA STATE BOARD OF ACCOUNTS 13 SPENCER-OWEN COMMUNITY SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Condition and Context 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. The Deputy Treasurer selected a random sample of students with a free or reduced-price lunch status and verified that their benefit was calculated correctly. This review happens annually in October or November. This internal control would not find issues with Direct Certification or applications completed for students after the annual review date. In an Indiana Department of Education Administrative review of the School Corporation during the audit period, four Direct Certification students were found to have been inappropriately issued reduced benefits as opposed to free benefits. Further, there was no documented review of the free or reduced-price lunch parameters in the School Corporation's nutrition management software, Titan. 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). . . ." 7 CFR 245.3(c) states 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. . . ." Cause The School Corporation was not aware of the requirement to document its review of parameters involving free or reduced-price lunch meals. The School Corporation's current internal control in place did not account for students who may enter into the School Corporation after the October or November count and random selection by the Deputy Treasurer. These errors associated with social economic status could cause incorrect funding and meal prices charged. Thus, 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 by the School Corporation caused 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. Incorrect funding will be given if the social economic status is not verified by the School Corporation. INDIANA STATE BOARD OF ACCOUNTS 14 SPENCER-OWEN COMMUNITY SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls related to the grant agreement and eligibility compliance requirements. 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 Internal Control / Segregation of Duties Eligibility Significant Deficiency Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 538084 2024-001
    Significant Deficiency
  • 538085 2024-001
    Significant Deficiency
  • 538086 2024-001
    Significant Deficiency
  • 538087 2024-001
    Significant Deficiency
  • 1114526 2024-001
    Significant Deficiency
  • 1114527 2024-001
    Significant Deficiency
  • 1114528 2024-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.425 Education Stabilization Fund 2024 $1.25M
10.555 National School Lunch Program 2023 $961,433
10.555 National School Lunch Program 2024 $870,955
84.010 Title I Grants to Local Educational Agencies 2023 $635,284
84.425 Education Stabilization Fund 2023 $545,207
84.010 Title I Grants to Local Educational Agencies 2024 $391,172
10.553 School Breakfast Program 2023 $322,228
10.553 School Breakfast Program 2024 $260,781
93.778 Medical Assistance Program 2024 $194,008
93.778 Medical Assistance Program 2023 $185,729
84.367 Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) 2023 $114,735
84.367 Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) 2024 $79,826
84.027 Special Education Grants to States 2023 $38,111
84.424 Student Support and Academic Enrichment Program 2023 $32,577
84.027 Special Education Grants to States 2024 $20,811
84.424 Student Support and Academic Enrichment Program 2024 $16,946
84.196 Education for Homeless Children and Youth 2023 $9,431
84.173 Special Education Preschool Grants 2024 $6,927
84.173 Special Education Preschool Grants 2023 $1,650