Finding Text
Finding Number: 2022-001 Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Numbers: 10.553/10.555/10.559 Pass-Through Agency: Indiana Department of Education Pass-Through Numbers: SY 2020-21, SY 2021-2022 Award Period: July 1, 2020 to June 30, 2022 Compliance Requirement: Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Control ? Per 2 CFR section 200.303(a), a non-federal entity must: 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 comply with the 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/Context: When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. For 2 out of 4 samples, the School Corporation did not maintain documentation supporting when it had checked the entities? suspension and debarment status. Furthermore, we could not independently verify the entities? suspension and debarment status. Questioned Costs: None noted. Cause: The School Corporation did not retain documentation showing the date it performed the suspension/debarment check. Effect: Failure to adhere to suspension and debarment requirements may result in the School Corporation entering into a contract or purchase with a vendor that is suspended or debarred and not authorized to provide goods and services to the program. Recommendation: We recommend that the School Corporation enhance its procedures and internal controls to ensure that it retains documentation of procurement suspension/debarment status verifications for its vendors and that this documentation is available for audit purposes. Views of responsible officials: Management agrees with the finding.