Finding 1115235 (2024-002)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2024
Accepted
2025-03-28
Audit: 349508
Organization: South Knox School Corporation (IN)
Auditor: Crowe LLP

AI Summary

  • Core Issue: The School Corporation lacks an effective internal control system for compliance with federal procurement requirements in the Child Nutrition Program.
  • Impacted Requirements: Non-compliance with 2 CFR 200.303, 200.318(a), and 200.320, which mandate proper procurement procedures and internal controls.
  • Recommended Follow-Up: Management should implement a robust internal control system to ensure adherence to procurement policies and maintain necessary documentation for all purchases.

Finding Text

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): FY2023, FY2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement Audit Finding: Material Weakness 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 use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in this part." 2 CFR 200.320 states in part: "The non-Federal Entity must use one of the following methods of procurement. . . . (b) Procurement by small purchase procedures. Small purchase procedures are those relatively simple and informal procurement methods for securing services, supplies, or other property that do not cost more than the Simplified Acquisition Threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources. . . ." Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the Child Nutrition Program and Procurement compliance requirement. Cause: The School Corporation's management had not developed a system of internal controls that would have ensured compliance with the Procurement compliance requirement. 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: The School Corporation utilizes two vendors for the majority of food and supplies purchases for the food service program. One vendor is procured through a purchasing cooperative, Southwest Indiana Co-op, where the School Corporation is a member. The other vendor met the simplified acquisition threshold for fiscal year 2023 and the small purchase threshold for fiscal year 2024. The School Corporation was unable to provide any supporting documentation for the procurement process undertaken as required by the School Corporation’s procurement policy. Management stated the items purchased were chosen based on a comparison of prices with two other vendors, however, management had no documented support for the rationale or process to determine which vendor would be selected for food and supplies purchases. The sample item amount disbursed was $151,511 for food purchases in FY23 and $129,583 for food purchases in FY24. The School Corporation did properly confirm the vendor was not debarred or suspended. Identification as a repeat finding, if applicable: Yes, see Finding 2022-001 in the prior period audit report. Recommendation: We recommended that the School Corporation's management establish a system of internal controls related to ensure that the School Corporation’s procurement policy is adhered to and all documentation is maintained for the procurements performed by the School Corporation. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.

Categories

Procurement, Suspension & Debarment School Nutrition Programs Internal Control / Segregation of Duties

Other Findings in this Audit

  • 538793 2024-002
    Material Weakness Repeat
  • 538794 2024-002
    Material Weakness Repeat
  • 538795 2024-002
    Material Weakness Repeat
  • 538796 2024-003
    Material Weakness
  • 1115236 2024-002
    Material Weakness Repeat
  • 1115237 2024-002
    Material Weakness Repeat
  • 1115238 2024-003
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
84.425 Education Stabilization Fund $653,948
84.010 Title I Grants to Local Educational Agencies $101,748
10.553 School Breakfast Program $98,099
84.027 Special Education Grants to States $76,380
10.555 National School Lunch Program $72,672
93.778 Medical Assistance Program $36,571
21.027 Coronavirus State and Local Fiscal Recovery Funds $24,875
84.367 Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) $23,871
84.424 Student Support and Academic Enrichment Program $10,253
84.173 Special Education Preschool Grants $2,324
10.649 Pandemic Ebt Administrative Costs $628