Finding 1121166 (2024-004)

Material Weakness
Requirement
E
Questioned Costs
-
Year
2024
Accepted
2025-03-31

AI Summary

  • Core Issue: The School Corporation lacks effective internal controls for determining eligibility for free or reduced-price meals, leading to potential noncompliance.
  • Impacted Requirements: Compliance with federal regulations regarding eligibility determinations under the Child Nutrition Cluster programs.
  • Recommended Follow-Up: Implement robust internal controls and documentation processes to ensure accurate eligibility determinations and compliance with federal guidelines.

Finding Text

FINDING 2024-004 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 2023, FY 2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Findings: Material Weakness, Other Matters Condition and Context The School Corporation had not established effective internal controls that would likely be effective in preventing, or detecting and correcting, noncompliance related to the eligibility determination of a child receiving meals. Any child enrolled in a participating school or summer camp, or attending a Summer Food Service Program (SFSP) meal service site, who meets the applicable program's definition of "child," may receive meals under the applicable program. In the case of the National School Lunch Program and School Breakfast Program, children belonging to households meeting nationwide income eligibility requirements may receive meals at no charge or at reduced-price. Children who have been determined ineligible for free or reduced-price school meals pay the full price, set by the School Food Authority, for their meals. Children attending SFSP meal service sites receive their meals at no charge. As a general rule, a child's eligibility for free or reduced-price meals under a Child Nutrition Cluster program may be established by the submission of an annual application or statement which furnishes such information as family income and family size. Local educational agencies, institutions, and sponsors then determine eligibility by comparing the data reported by the child's household to published income eligibility guidelines. Additionally, a child may be Direct Certified. For a Direct Certification, annual eligibility determinations are based on the child's household receiving benefits under SNAP, FDPIR, the Head Start Program (ALN 93.600), or, under most circumstances, the TANF program (ALN 93.558). A household may furnish documentation of its participation in one of these programs, or the school, institution, or sponsor may obtain the information directly from the state or local agency that administers these programs. Certain foster, runaway, homeless, and migrant children are categorically eligible for free school lunches and breakfasts. Direct Certified households do not need to complete an application. INDIANA STATE BOARD OF ACCOUNTS 21 LIBERTY-PERRY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) The School Corporation's process for determining student eligibility based on income was that the Food Service Director made the initial eligibility determination and the High School Treasurer reviewed the determination made. Per the School Corporation, 10 percent of free or reduced-priced applications received were subject to this process. However, the School Corporation did not provide a list of student applications which had been reviewed during the audit period. Therefore, it could not be determined whether the internal control over free and reduced-price applications was in place. The Food Service Director directly imports the initial list of directly-certified students into the school lunch software at the beginning of each school year. Students who are determined to be directly-certified after the initial import are manually entered into the school lunch software by the Food Service Director. There was no documented review or other internal control in place to ensure students who were directlycertified were entered into the system correctly. A sample of 40 students receiving free or reduced-priced meals that were selected for testing to determine whether required eligibility determinations were made, participants were determined to be eligible, and that only eligible individuals participated in the program. Of the 40 students receiving free or reduced-priced meals that were selected for testing, supporting documentation was not provided for 1 student selected for testing. Therefore, it could not be determined that the correct eligibility status was made in the system software for this student. 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). . . ." 7 CFR 245.6 states in part: ". . . (b) Direct certification. In lieu of requiring a household to complete the free and reduced price meal or free milk application, as specified in paragraph (a) of this section, the local educational agency must certify children as eligible for free meals or free milk in accordance with paragraph (b)(1)(i) of this section or may certify children as eligible for free meals or free milk in accordance with paragraph (b)(2) of this section. If a household also submits an application for directly certified children, the direct certification eligibility determination will take precedence. . . . (5) Direct certification documentation. (i) The required documentation for direct certification is provided in paragraph (2) of the definition of Documentation in § 245.2. INDIANA STATE BOARD OF ACCOUNTS 22 LIBERTY-PERRY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (ii) (A) Beginning in School Year 2012-2013, direct certification with SNAP shall be conducted using a data matching technique only. Letters to households for direct certification may be used only as an additional means to notify households of children's eligibility based on receipt of SNAP benefits. The last period that letters to households may be used as the primary method for direct certification is School Year 2011-2012. While such notices cannot be the primary method used by a state to document receipt of SNAP, the local educational agency shall accept such a letter if presented by a household. (B) Letters or other documents may be used as the primary method for direct certification to document receipt of FDPIR or TANF benefits. (iii) Individual notices from officials of eligible programs for a Foster child, a Homeless child, a Migrant child, a Runaway child, or a Head Start child, as defined in § 245.2, may continue to be used. These notices are provided to school officials who must certify these children as eligible for free meals or free milk, as applicable, without further application, upon receipt of such notice. (c) Determination of eligibility . . . (2) Use of prior year's eligibility status. Prior to the processing of applications or the completion of direct certification procedures for the current school year, children from households with approved applications or documentation of direct certification on file from the preceding year, shall be offered reimbursable free and reduced price meals or free milk, as appropriate. The local educational agency must extend eligibility to newly enrolled children when other children in their household (as defined in § 245.2) were approved for benefits the previous year. However, applications and documentation of direct certification from the preceding year shall be used only to determine eligibility for the first 30 operating days following the first operating day at the beginning of the school year, or until a new eligibility determination is made in the current school year, whichever comes first. At the State agency's discretion, students who, in the preceding school year, attended a school operating a special assistance certification and reimbursement alternative (as permitted in § 245.9)) may be offered free reimbursable meals for up to 30 operating days or until a new eligibility determination is made in the current school year, whichever comes first. . . . (4) Calculating income. The local educational agency must use the income information provided by the household on the application to calculate the household's total current income. When a household submits an application containing complete documentation, as defined in § 245.2, and the household's total current income is at or below the eligibility limits specified in the Income Eligibility Guidelines as defined in § 245.2, the children in that household must be approved for free or reduced price benefits, as applicable. . . ." Cause The School Corporation was unable to provide documentation of student eligibility as noted in the Condition and Context and did not have internal controls over Direct Certification. The School Corporation did not have policies and procedures in place to properly maintain supporting documentation or establish internal controls over Direct Certification. INDIANA STATE BOARD OF ACCOUNTS 23 LIBERTY-PERRY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, a student's eligibility for free or reduced-price meals could not be determined. Noncompliance with the grant agreement and the compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended the School Corporation's management establish a proper system of internal controls and develop policies and procedures to ensure only eligible students receive benefits. 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 Cash Management Matching / Level of Effort / Earmarking Material Weakness

Other Findings in this Audit

  • 544718 2024-003
    Material Weakness Repeat
  • 544719 2024-003
    Material Weakness Repeat
  • 544720 2024-003
    Material Weakness Repeat
  • 544721 2024-003
    Material Weakness Repeat
  • 544722 2024-003
    Material Weakness Repeat
  • 544723 2024-003
    Material Weakness Repeat
  • 544724 2024-004
    Material Weakness
  • 544725 2024-004
    Material Weakness
  • 544726 2024-004
    Material Weakness
  • 544727 2024-004
    Material Weakness
  • 544728 2024-004
    Material Weakness
  • 544729 2024-004
    Material Weakness
  • 544730 2024-005
    Material Weakness
  • 544731 2024-005
    Material Weakness
  • 544732 2024-005
    Material Weakness
  • 544733 2024-006
    Material Weakness
  • 544734 2024-006
    Material Weakness
  • 544735 2024-006
    Material Weakness
  • 544736 2024-007
    Material Weakness
  • 544737 2024-007
    Material Weakness
  • 544738 2024-007
    Material Weakness
  • 1121160 2024-003
    Material Weakness Repeat
  • 1121161 2024-003
    Material Weakness Repeat
  • 1121162 2024-003
    Material Weakness Repeat
  • 1121163 2024-003
    Material Weakness Repeat
  • 1121164 2024-003
    Material Weakness Repeat
  • 1121165 2024-003
    Material Weakness Repeat
  • 1121167 2024-004
    Material Weakness
  • 1121168 2024-004
    Material Weakness
  • 1121169 2024-004
    Material Weakness
  • 1121170 2024-004
    Material Weakness
  • 1121171 2024-004
    Material Weakness
  • 1121172 2024-005
    Material Weakness
  • 1121173 2024-005
    Material Weakness
  • 1121174 2024-005
    Material Weakness
  • 1121175 2024-006
    Material Weakness
  • 1121176 2024-006
    Material Weakness
  • 1121177 2024-006
    Material Weakness
  • 1121178 2024-007
    Material Weakness
  • 1121179 2024-007
    Material Weakness
  • 1121180 2024-007
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
84.425 Education Stabilization Fund 2023 $796,579
10.555 National School Lunch Program 2023 $517,059
10.555 National School Lunch Program 2024 $437,219
84.425 Education Stabilization Fund 2024 $367,286
84.027 Special Education Grants to States 2024 $248,683
84.010 Title I Grants to Local Educational Agencies 2023 $158,022
10.553 School Breakfast Program 2023 $108,097
10.553 School Breakfast Program 2024 $96,538
84.010 Title I Grants to Local Educational Agencies 2024 $85,118
84.367 Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) 2024 $53,431
84.367 Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) 2023 $32,840
84.424 Student Support and Academic Enrichment Program 2024 $23,232
84.424 Student Support and Academic Enrichment Program 2023 $21,213
10.559 Summer Food Service Program for Children 2024 $12,590
10.559 Summer Food Service Program for Children 2023 $12,407
84.173 Special Education Preschool Grants 2023 $10,245
84.173 Special Education Preschool Grants 2024 $9,125
84.027 Special Education Grants to States 2023 $8,551
93.354 Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response 2024 $7,888
93.778 Medical Assistance Program 2023 $6,406
93.778 Medical Assistance Program 2024 $4,472
93.354 Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response 2023 $4,035