Finding 381056 (2023-003)

Material Weakness
Requirement
E
Questioned Costs
-
Year
2023
Accepted
2024-03-19

AI Summary

  • Core Issue: The School Corporation lacks a proper system of internal controls for determining eligibility for child nutrition programs, leading to a material weakness in compliance.
  • Impacted Requirements: Failure to meet 2 CFR 200.303, which mandates effective internal controls to ensure compliance with federal regulations.
  • Recommended Follow-Up: Management should establish and implement a robust internal control system with clear policies and procedures, ensuring segregation of duties and proper oversight.

Finding Text

FINDING 2023-003 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 Number and Year (or Other Identifying Number): FY 2023 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Finding: Material Weakness Condition and Context The School Corporation had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties, 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 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 the 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 system parameters, including income guidelines, were entered by the software vendor without a documented review or oversight process by the School Corporation to ensure the parameters entered were accurate. If an application is flagged by the system process, a hold is placed on the application and a manual verification is completed. The manual applications were certified without a documented review or oversight process. The lack of internal controls was isolated to fiscal year 2022-2023. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: INDIANA STATE BOARD OF ACCOUNTS 21 GREATER JASPER CONSOLIDATED SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (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). . . ." Cause A proper system of internal controls was not implemented by management of the School Corporation, which would include segregation of key functions. 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 design or implementation of the components of a system of internal controls, including policies and procedures that provide segregation of duties and additional oversight as needed, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation design and implement a proper system of internal controls, including policies and procedures that would provide segregation of duties to ensure appropriate reviews, approvals, and oversight are taking place. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

Corrective Action Plan

Finding 2023-003 Finding Subject: Child Nutrition Cluster-Eligibility Summary of Finding: (suggestion: The School Corporation had not properly designed or implemented internal controls over eligibility.) Contact Person Responsible for Corrective Plan: Dr. Tracy Lorey, Monica Young, April Hopf Contact Phone Number and Email Address 812-482-1801 tlorey@gjcs.k12.in.us myoung@gjcs.k12.in.us ahopf@gjcs.k12.in.us Views of Responsible Officials: We agree with the Finding. Description of Corrective Action Plan: The corporation meets virtually each year with the software vendor to set up all free/reduced lunch applications, federal income guidelines and forms. A certified and signed copy of the income guidelines will be kept on file to show the match between the guidelines and point of sale. The applications that are flagged by the system will be reviewed for approval or denied and a copy will be maintained for The State Board of Accounts for audit. Anticipation Completion Date: February 2024

Categories

School Nutrition Programs Internal Control / Segregation of Duties Eligibility Material Weakness Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 381057 2023-003
    Material Weakness
  • 381058 2023-003
    Material Weakness
  • 381059 2023-004
    Material Weakness
  • 381060 2023-004
    Material Weakness
  • 381061 2023-004
    Material Weakness
  • 381062 2023-004
    Material Weakness
  • 381063 2023-004
    Material Weakness
  • 381064 2023-004
    Material Weakness
  • 381065 2023-005
    Material Weakness
  • 381066 2023-005
    Material Weakness
  • 381067 2023-006
    Material Weakness
  • 381068 2023-006
    Material Weakness
  • 381069 2023-006
    Material Weakness
  • 381070 2023-006
    Material Weakness
  • 381071 2023-006
    Material Weakness
  • 381072 2023-006
    Material Weakness
  • 381073 2023-006
    Material Weakness
  • 957498 2023-003
    Material Weakness
  • 957499 2023-003
    Material Weakness
  • 957500 2023-003
    Material Weakness
  • 957501 2023-004
    Material Weakness
  • 957502 2023-004
    Material Weakness
  • 957503 2023-004
    Material Weakness
  • 957504 2023-004
    Material Weakness
  • 957505 2023-004
    Material Weakness
  • 957506 2023-004
    Material Weakness
  • 957507 2023-005
    Material Weakness
  • 957508 2023-005
    Material Weakness
  • 957509 2023-006
    Material Weakness
  • 957510 2023-006
    Material Weakness
  • 957511 2023-006
    Material Weakness
  • 957512 2023-006
    Material Weakness
  • 957513 2023-006
    Material Weakness
  • 957514 2023-006
    Material Weakness
  • 957515 2023-006
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
10.555 National School Lunch Program 22 $1.76M
10.555 National School Lunch Program 23 $1.33M
84.425 Education Stabilization Fund 22 $1.16M
84.425 Education Stabilization Fund 23 $368,036
93.575 Child Care and Development Block Grant 22 $304,429
84.010 Title I Grants to Local Educational Agencies 22 $280,898
84.010 Title I Grants to Local Educational Agencies 23 $272,128
84.048 Career and Technical Education -- Basic Grants to States 22 $250,480
10.553 School Breakfast Program 22 $231,063
10.553 School Breakfast Program 23 $213,665
84.048 Career and Technical Education -- Basic Grants to States 23 $195,140
84.027 Special Education_grants to States 23 $112,745
84.367 Improving Teacher Quality State Grants 22 $104,608
93.778 Medical Assistance Program 23 $100,331
93.778 Medical Assistance Program 22 $91,060
84.027 Special Education_grants to States 22 $58,309
84.367 Improving Teacher Quality State Grants 23 $57,844
10.559 Summer Food Service Program for Children 22 $50,116
93.575 Child Care and Development Block Grant 23 $45,546
84.424 Student Support and Academic Enrichment Program 23 $32,248
84.365 English Language Acquisition State Grants 23 $29,743
84.365 English Language Acquisition State Grants 22 $28,397
10.559 Summer Food Service Program for Children 23 $20,604
84.424 Student Support and Academic Enrichment Program 22 $11,466
84.173 Special Education_preschool Grants 23 $11,434
10.649 Pandemic Ebt Administrative Costs 23 $3,135
10.649 Pandemic Ebt Administrative Costs 22 $3,063
84.173 Special Education_preschool Grants 22 $1,648