Finding 1137076 (2023-005)

Material Weakness Repeat Finding
Requirement
E
Questioned Costs
-
Year
2023
Accepted
2025-05-19

AI Summary

  • Core Issue: The School Corporation lacks effective internal controls for determining eligibility for free or reduced-price meals, leading to repeated compliance failures.
  • Impacted Requirements: Noncompliance with 2 CFR 200.303 and 7 CFR 245.6 regarding eligibility determination processes and internal controls.
  • Recommended Follow-Up: Implement stronger internal controls and ensure proper review of eligibility determinations to prevent future issues.

Finding Text

FINDING 2023-005 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): FY2022, FY2023 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Findings: Material Weakness, Other Matters Repeat Finding This is a repeat finding from the prior audit report. The prior audit finding number was 2021-002. 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. INDIANA STATE BOARD OF ACCOUNTS 21 SHENANDOAH SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 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. The School Corporation's process for determining student eligibility was that the Assistant Food Service Director make the initial eligibility determination and the Food Service Director review the determination made. Per the School Corporation, all free or reduced priced applications received were subject to this process. A sample of 40 free or reduced priced applications were selected for testing to determine if the identified internal control was in place and operating. Of the 40 free and reduced priced applications selected for testing, 12 did not have the identified internal control in place. For these 12 applications, the Assistant Food Service Director made the initial eligibility determination, but there was no evidence that the Food Service Director reviewed the determination. In addition, a sample of 40 free or reduced priced applications 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 free and reduced priced applications selected for testing, 3 were determined to have the incorrect eligibility status in the system software when compared to supporting documentation. 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 SHENANDOAH SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 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. (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. . . . INDIANA STATE BOARD OF ACCOUNTS 23 SHENANDOAH SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (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 A proper system of internal controls was not designed by management of the School Corporation. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. 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 was incorrectly 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

  • 560623 2023-003
    Material Weakness
  • 560624 2023-003
    Material Weakness
  • 560625 2023-003
    Material Weakness
  • 560626 2023-003
    Material Weakness
  • 560627 2023-003
    Material Weakness
  • 560628 2023-004
    Material Weakness
  • 560629 2023-004
    Material Weakness
  • 560630 2023-004
    Material Weakness
  • 560631 2023-004
    Material Weakness
  • 560632 2023-004
    Material Weakness
  • 560633 2023-005
    Material Weakness Repeat
  • 560634 2023-005
    Material Weakness Repeat
  • 560635 2023-006
    Material Weakness
  • 560636 2023-006
    Material Weakness
  • 560637 2023-006
    Material Weakness
  • 560638 2023-006
    Material Weakness
  • 560639 2023-006
    Material Weakness
  • 560640 2023-007
    Material Weakness
  • 560641 2023-007
    Material Weakness
  • 560642 2023-007
    Material Weakness
  • 560643 2023-007
    Material Weakness
  • 560644 2023-007
    Material Weakness
  • 560645 2023-008
    Material Weakness
  • 560646 2023-009
    Material Weakness
  • 560647 2023-009
    Material Weakness
  • 560648 2023-009
    Material Weakness
  • 560649 2023-009
    Material Weakness
  • 560650 2023-009
    Material Weakness
  • 560651 2023-010
    Material Weakness
  • 560652 2023-010
    Material Weakness
  • 560653 2023-010
    Material Weakness
  • 560654 2023-010
    Material Weakness
  • 560655 2023-011
    Material Weakness
  • 560656 2023-011
    Material Weakness
  • 560657 2023-011
    Material Weakness
  • 560658 2023-011
    Material Weakness
  • 1137065 2023-003
    Material Weakness
  • 1137066 2023-003
    Material Weakness
  • 1137067 2023-003
    Material Weakness
  • 1137068 2023-003
    Material Weakness
  • 1137069 2023-003
    Material Weakness
  • 1137070 2023-004
    Material Weakness
  • 1137071 2023-004
    Material Weakness
  • 1137072 2023-004
    Material Weakness
  • 1137073 2023-004
    Material Weakness
  • 1137074 2023-004
    Material Weakness
  • 1137075 2023-005
    Material Weakness Repeat
  • 1137077 2023-006
    Material Weakness
  • 1137078 2023-006
    Material Weakness
  • 1137079 2023-006
    Material Weakness
  • 1137080 2023-006
    Material Weakness
  • 1137081 2023-006
    Material Weakness
  • 1137082 2023-007
    Material Weakness
  • 1137083 2023-007
    Material Weakness
  • 1137084 2023-007
    Material Weakness
  • 1137085 2023-007
    Material Weakness
  • 1137086 2023-007
    Material Weakness
  • 1137087 2023-008
    Material Weakness
  • 1137088 2023-009
    Material Weakness
  • 1137089 2023-009
    Material Weakness
  • 1137090 2023-009
    Material Weakness
  • 1137091 2023-009
    Material Weakness
  • 1137092 2023-009
    Material Weakness
  • 1137093 2023-010
    Material Weakness
  • 1137094 2023-010
    Material Weakness
  • 1137095 2023-010
    Material Weakness
  • 1137096 2023-010
    Material Weakness
  • 1137097 2023-011
    Material Weakness
  • 1137098 2023-011
    Material Weakness
  • 1137099 2023-011
    Material Weakness
  • 1137100 2023-011
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
10.555 National School Lunch Program 2022 $635,492
10.555 National School Lunch Program 2023 $588,240
84.425 Education Stabilization Fund 2023 $505,770
84.425 Education Stabilization Fund 2022 $399,665
84.010 Title I Grants to Local Educational Agencies 2022 $194,077
84.010 Title I Grants to Local Educational Agencies 2023 $160,964
10.553 School Breakfast Program 2023 $100,944
10.553 School Breakfast Program 2022 $94,867
84.367 Improving Teacher Quality State Grants 2022 $47,504
84.367 Improving Teacher Quality State Grants 2023 $36,434
84.027 Special Education_grants to States 2023 $32,184
84.027 Special Education_grants to States 2022 $26,617
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) 2022 $24,157
10.559 Summer Food Service Program for Children 2022 $20,984
84.424 Student Support and Academic Enrichment Program 2022 $13,175
84.424 Student Support and Academic Enrichment Program 2023 $11,075
84.173 Special Education_preschool Grants 2022 $4,843
10.649 Pandemic Ebt Administrative Costs 2023 $628
10.649 Pandemic Ebt Administrative Costs 2022 $614
84.173 Special Education_preschool Grants 2023 $422