Finding 1114664 (2024-003)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2024
Accepted
2025-03-27

AI Summary

  • Core Issue: The School Corporation lacks effective internal controls to ensure compliance with federal procurement and suspension/debarment requirements.
  • Impacted Requirements: Noncompliance with 2 CFR 200.303 and 2 CFR 180.300, leading to a repeat finding from the previous audit.
  • Recommended Follow-Up: Management should implement a robust internal control system and develop policies to verify vendor eligibility before transactions.

Finding Text

FINDING 2024-003 Subject: Child Nutrition Cluster - 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): FY22/23, FY23/24 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 2022-001. 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 the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Suspension and Debarment The School Corporation did not follow procedures to ensure that applicable vendors who received federal funds were not suspended or debarred from participation in federal awards programs. For three of five vendors tested with covered transactions that exceeded $25,000, the School Corporation did not perform procedures to ensure compliance with requirements regarding verification that the vendor was not suspended or debarred from participation in federal programs. The lack of internal controls and noncompliance were systemic issues 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). . . ." INDIANA STATE BOARD OF ACCOUNTS 22 EAST NOBLE SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 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.gov Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person." Cause A proper system of internal controls was not designed by management of the School Corporation. Although the School Corporation was aware of the Procurement and Suspension and Debarment compliance requirement, management did verify the suspension or debarment status for certain vendors during the audit period. Effect Without the proper implementation of an effectively designed system of internal controls, the School Corporation cannot ensure that the vendors paid with federal funds were eligible to participate in federal programs. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure vendors are not suspended, debarred, or otherwise excluded prior to entering into any covered transactions. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

Categories

Procurement, Suspension & Debarment School Nutrition Programs

Other Findings in this Audit

  • 538219 2024-003
    Material Weakness Repeat
  • 538220 2024-003
    Material Weakness Repeat
  • 538221 2024-003
    Material Weakness Repeat
  • 538222 2024-003
    Material Weakness Repeat
  • 538223 2024-003
    Material Weakness Repeat
  • 538224 2024-003
    Material Weakness Repeat
  • 538225 2024-004
    Material Weakness
  • 538226 2024-004
    Material Weakness
  • 538227 2024-004
    Material Weakness
  • 538228 2024-004
    Material Weakness
  • 538229 2024-004
    Material Weakness
  • 538230 2024-004
    Material Weakness
  • 538231 2024-005
    Material Weakness
  • 538232 2024-005
    Material Weakness
  • 538233 2024-005
    Material Weakness
  • 538234 2024-005
    Material Weakness
  • 538235 2024-005
    Material Weakness
  • 538236 2024-005
    Material Weakness
  • 538237 2024-005
    Material Weakness
  • 538238 2024-005
    Material Weakness
  • 538239 2024-005
    Material Weakness
  • 538240 2024-006
    Material Weakness
  • 538241 2024-006
    Material Weakness
  • 538242 2024-006
    Material Weakness
  • 538243 2024-006
    Material Weakness
  • 538244 2024-006
    Material Weakness
  • 538245 2024-006
    Material Weakness
  • 538246 2024-006
    Material Weakness
  • 538247 2024-006
    Material Weakness
  • 538248 2024-006
    Material Weakness
  • 538249 2024-007
    Material Weakness
  • 538250 2024-007
    Material Weakness
  • 538251 2024-007
    Material Weakness
  • 538252 2024-007
    Material Weakness
  • 538253 2024-008
    Material Weakness
  • 538254 2024-008
    Material Weakness
  • 1114661 2024-003
    Material Weakness Repeat
  • 1114662 2024-003
    Material Weakness Repeat
  • 1114663 2024-003
    Material Weakness Repeat
  • 1114665 2024-003
    Material Weakness Repeat
  • 1114666 2024-003
    Material Weakness Repeat
  • 1114667 2024-004
    Material Weakness
  • 1114668 2024-004
    Material Weakness
  • 1114669 2024-004
    Material Weakness
  • 1114670 2024-004
    Material Weakness
  • 1114671 2024-004
    Material Weakness
  • 1114672 2024-004
    Material Weakness
  • 1114673 2024-005
    Material Weakness
  • 1114674 2024-005
    Material Weakness
  • 1114675 2024-005
    Material Weakness
  • 1114676 2024-005
    Material Weakness
  • 1114677 2024-005
    Material Weakness
  • 1114678 2024-005
    Material Weakness
  • 1114679 2024-005
    Material Weakness
  • 1114680 2024-005
    Material Weakness
  • 1114681 2024-005
    Material Weakness
  • 1114682 2024-006
    Material Weakness
  • 1114683 2024-006
    Material Weakness
  • 1114684 2024-006
    Material Weakness
  • 1114685 2024-006
    Material Weakness
  • 1114686 2024-006
    Material Weakness
  • 1114687 2024-006
    Material Weakness
  • 1114688 2024-006
    Material Weakness
  • 1114689 2024-006
    Material Weakness
  • 1114690 2024-006
    Material Weakness
  • 1114691 2024-007
    Material Weakness
  • 1114692 2024-007
    Material Weakness
  • 1114693 2024-007
    Material Weakness
  • 1114694 2024-007
    Material Weakness
  • 1114695 2024-008
    Material Weakness
  • 1114696 2024-008
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
10.555 National School Lunch Program $1.45M
84.010 Title I Grants to Local Educational Agencies $582,891
10.553 School Breakfast Program $243,182
84.367 Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) $146,864
10.559 Summer Food Service Program for Children $121,788
84.027 Special Education Grants to States $84,344
93.778 Medical Assistance Program $26,583
84.365 English Language Acquisition State Grants $26,025
84.424 Student Support and Academic Enrichment Program $23,859
84.173 Special Education Preschool Grants $4,998
84.425 Education Stabilization Fund $3,180
10.649 Pandemic Ebt Administrative Costs $3,135