Finding 1180800 (2025-001)

Material Weakness Repeat Finding
Requirement
E
Questioned Costs
-
Year
2025
Accepted
2026-03-18
Audit: 392466
Auditor: CROWE LLP

AI Summary

  • Core Issue: The School Corporation lacks an effective internal control system for managing federal funds, leading to potential noncompliance with eligibility requirements.
  • Impacted Requirements: Compliance with 2 CFR section 200.303, which mandates effective internal controls to ensure adherence to federal statutes and grant agreements.
  • Recommended Follow-Up: Management should implement a robust internal control process to maintain documentation for eligibility determinations and ensure compliance moving forward.

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): FY23-24 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Finding: Material Weakness, Qualified Opinion Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards 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). . . ." Condition: 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. Cause: 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 placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. A lack of documentation to support eligibility determination 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: During the testing of internal controls and compliance over eligibility determinations for free and reduced meals, we selected a sample of 15 applications and 45 direct certifications for testing. For 3 of the 15 applications, the School Corporation was not able to provide any documentation to support the eligibility determination due to turnover in the food service director position. Therefore, we were unable to determine whether the School Corporation complied with the eligibility requirements. The internal control and noncompliance was isolated to fiscal year 2024. Identification as a repeat finding, if applicable: No Recommendation: We recommend that the School Corporation’s management establish an internal control process to maintain all applications and documentation to support eligibility determinations. Views of Responsible Officials and Planned Corrective Actions: Management has agreed with the finding and prepared a corrective action plan.

Corrective Action Plan

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): FY23-24 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Finding: Material Weakness, Qualified Opinion Condition: 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. Context: During the testing of internal controls and compliance over eligibility determinations for free and reduced meals, we selected a sample of 15 applications and 45 direct certifications for testing. For 3 of the 15 applications, the School Corporation was not able to provide any documentation to support the eligibility determination due to turnover in the food service director position. Therefore, we were unable to determine whether the School Corporation complied with the eligibility requirements. The internal control and noncompliance was isolated to fiscal year 2024. Views of Responsible Officials and Corrective Action Plan: School Corporation has implemented procedures to ensure a complete record is maintained for every free and reduced-price meal application and any subsequent eligibility status change. All applications, supporting documentation, and determination records are retained as hard copy files. An electronic Benefit Issuance Document will also be retained during the year and printed as a hard copy record. Any change in eligibility status is documented with the effective date and supporting rationale to provide a clear audit trail. These procedures are now part of the School Corporation’s standard operating practices in school food service to ensure ongoing compliance and continuity moving forward. Responsible Party and Timeline for Completion: Corrective action plan has been implemented as this finding impacted fiscal year 2024 but did not recur in fiscal year 2025. Missy Corns, Food Service Director, and Tracy Albertson, Director of Finance, will oversee the corrective action plan to monitor the eligibility requirements on an ongoing basis.

Categories

School Nutrition Programs Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1180798 2025-001
    Material Weakness Repeat
  • 1180799 2025-001
    Material Weakness Repeat
  • 1180801 2025-002
    Material Weakness Repeat
  • 1180802 2025-002
    Material Weakness Repeat
  • 1180803 2025-002
    Material Weakness Repeat
  • 1180804 2025-003
    Material Weakness Repeat
  • 1180805 2025-003
    Material Weakness Repeat
  • 1180806 2025-003
    Material Weakness Repeat
  • 1180807 2025-003
    Material Weakness Repeat
  • 1180808 2025-004
    Material Weakness Repeat
  • 1180809 2025-004
    Material Weakness Repeat
  • 1180810 2025-004
    Material Weakness Repeat
  • 1180811 2025-004
    Material Weakness Repeat
  • 1180812 2025-005
    Material Weakness Repeat
  • 1180813 2025-005
    Material Weakness Repeat
  • 1180814 2025-005
    Material Weakness Repeat
  • 1180815 2025-005
    Material Weakness Repeat
  • 1180816 2025-005
    Material Weakness Repeat
  • 1180817 2025-005
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.425 EDUCATION STABILIZATION FUND $961,071
84.027 SPECIAL EDUCATION GRANTS TO STATES $306,753
10.553 SCHOOL BREAKFAST PROGRAM $225,283
10.555 NATIONAL SCHOOL LUNCH PROGRAM $177,911
84.010 TITLE I GRANTS TO LOCAL EDUCATIONAL AGENCIES $161,835
93.778 MEDICAL ASSISTANCE PROGRAM $87,678
84.367 SUPPORTING EFFECTIVE INSTRUCTION STATE GRANTS (FORMERLY IMPROVING TEACHER QUALITY STATE GRANTS) $49,178
84.424 STUDENT SUPPORT AND ACADEMIC ENRICHMENT PROGRAM $14,902
84.173 SPECIAL EDUCATION PRESCHOOL GRANTS $13,620