Finding 384428 (2023-008)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2023
Accepted
2024-03-26
Audit: 297571
Organization: Rush County Schools (IN)

AI Summary

  • Core Issue: The School Corporation failed to implement effective internal controls for verifying free and reduced price applications, leading to incorrect eligibility determinations.
  • Impacted Requirements: Noncompliance with federal verification procedures as outlined in 2 CFR 200.303 and 7 CFR 245.6a, risking future federal funding.
  • Recommended Follow-Up: Management should establish a robust internal control system, including segregation of duties and proper oversight, to ensure compliance and accuracy in application verifications.

Finding Text

FINDING 2023-008 Subject: Child Nutrition Cluster - Special Tests and Provisions - Verification of Free and Reduced Price Applications (NSLP) Federal Agency: Department of Agriculture Federal Program: National School Lunch Program Assistance Listings Number: 10.555 Federal Award Number and Year (or Other Identifying Number): FY23 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Verification of Free and Reduced Price Applications (NSLP) Audit Findings: Material Weakness, Other Matters Repeat Finding This is a repeat finding from the prior audit report. The prior audit finding number was 2021-003. Condition and Context By November 15 of each school year, the local educational agencies (LEA) must verify the current free and reduced price eligibility of households selected from a sample of applications that it has approved for free and reduced price meals, unless the LEA is otherwise exempt from the verification requirement. The verification sample size is based on the total number of approved applications on file on October 1. As instructed, the LEAs must select a sample of applications to be verified utilizing one of the following methods: a. Standard sample size - The lesser of three percent or 3,000 of the approved applications on file as of October 1, selected from error-prone applications. For this purpose, error prone applications are those showing household incomes within $100 monthly or $1,200 annually of the income eligibility guidelines for free and reduced price meals. INDIANA STATE BOARD OF ACCOUNTS 27 RUSH COUNTY SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) b. Alternative sample sizes - 1) The lesser of 3 percent or 3,000 applications selected at random from approved applications on file as of October 1 of the school year, or (2) The sum of (a) the lesser of 1 percent of all applications identified as error-prone or 1,000 error-prone applications, and (b) the lesser of 1/2 of 1 percent of, or 500, approved applications in which the household provided, in lieu of income information, a case number showing participation in the SNAP, TANF, or FDPIR. In accordance with the above guidance, the School Corporation selected a sample of verifications based on the alternative sample size. As such, the School Corporation was required to review the lesser of 3 percent or 3,000 applications selected at random from approved applications on file as of October 1 of the 2022-2023 school year. On October 1, the School Corporation had 180 applications on file and determined that 6 applications were required to be verified. Although one employee was responsible for performing the required verification of the 6 free and reduced-price applications and another employee reviewed the applications, the internal control was not effective and did not prevent, or detect and correct, errors. There was no documentation of an oversight, review, or approval process to ensure that the verifications were properly performed. All 6 of the required verifications were selected for testing. There were 2 of the 6 verified applications that were calculated incorrectly resulting in improper eligibility status changes. The lack of effective internal controls and noncompliance were isolated to 2022-2023. 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 245.6a states in part: ". . . (f) Verification procedures and assistance for households . . . (7) Eligibility changes. Based on the verification activities, the local educational agency shall make appropriate modifications to the eligibility determinations made initially. The local educational agency must notify the household of any change. Households must be notified of any reduction in benefits in accordance with paragraph (j) of this section. Households with reduced benefits or that are longer eligible for free or reduced price meals must be notified of their right to reapply at any time with documentation of income or participation in one of the eligible programs in paragraph (a)(1) of this section. . . ." INDIANA STATE BOARD OF ACCOUNTS 28 RUSH COUNTY SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 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 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, verifications for free and reduced price applications were not appropriately changed. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure verifications for free and reduced price applications are appropriately changed. 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 2023-008 Finding Subject: Child Nutrition Cluster - Special Tests and Provisions - Verification of Free and Reduced Price Applications INDIANA STATE BOARD OF ACCOUNTS 48 Summary of Finding: One employee was responsible for performing the required verification of the free and reduced price applications. While the verification was reviewed by a second person, that control was not effective. All six of the required verified applications in the fiscal year 2022-23 were tested. Two of the six verified applications were calculated incorrectly resulting in improper eligibility status changes. Contact Person Responsible for Corrective Action: Nancy Schroeder Contact Phone Number and Email Address: 765-932-3901 schroedern@rushville.k12.in.us Views of Responsible Officials: We concur with the finding. Explanation and Reasons for Disagreement: N/A Description of Corrective Action Plan: The middle school cafeteria secretary, Connie Amos, will contact parents regarding verification of their free/reduced lunch application. This information will then be reviewed by the Food Service Director, Nancy Schroeder, to determine the information is accurate. Parents are always notified on any changes to the lunch status. Anticipated Completion Date: April 2024

Categories

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

Other Findings in this Audit

  • 384412 2023-003
    Material Weakness Repeat
  • 384413 2023-003
    Material Weakness Repeat
  • 384414 2023-004
    Material Weakness Repeat
  • 384415 2023-004
    Material Weakness Repeat
  • 384416 2023-005
    Material Weakness
  • 384417 2023-005
    Material Weakness
  • 384418 2023-005
    Material Weakness
  • 384419 2023-006
    Material Weakness
  • 384420 2023-006
    Material Weakness
  • 384421 2023-007
    Material Weakness Repeat
  • 384422 2023-007
    Material Weakness Repeat
  • 384423 2023-007
    Material Weakness Repeat
  • 384424 2023-007
    Material Weakness Repeat
  • 384425 2023-007
    Material Weakness Repeat
  • 384426 2023-007
    Material Weakness Repeat
  • 384427 2023-007
    Material Weakness Repeat
  • 384429 2023-009
    Material Weakness Repeat
  • 384430 2023-009
    Material Weakness Repeat
  • 960854 2023-003
    Material Weakness Repeat
  • 960855 2023-003
    Material Weakness Repeat
  • 960856 2023-004
    Material Weakness Repeat
  • 960857 2023-004
    Material Weakness Repeat
  • 960858 2023-005
    Material Weakness
  • 960859 2023-005
    Material Weakness
  • 960860 2023-005
    Material Weakness
  • 960861 2023-006
    Material Weakness
  • 960862 2023-006
    Material Weakness
  • 960863 2023-007
    Material Weakness Repeat
  • 960864 2023-007
    Material Weakness Repeat
  • 960865 2023-007
    Material Weakness Repeat
  • 960866 2023-007
    Material Weakness Repeat
  • 960867 2023-007
    Material Weakness Repeat
  • 960868 2023-007
    Material Weakness Repeat
  • 960869 2023-007
    Material Weakness Repeat
  • 960870 2023-008
    Material Weakness Repeat
  • 960871 2023-009
    Material Weakness Repeat
  • 960872 2023-009
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
10.555 National School Lunch Program 2022 $1.28M
84.027 Special Education_grants to States 2022 $1.22M
84.425 Education Stabilization Fund 2023 $1.20M
10.555 National School Lunch Program 2023 $1.05M
84.010 Title I Grants to Local Educational Agencies 2022 $470,033
84.010 Title I Grants to Local Educational Agencies 2023 $393,650
84.425 Education Stabilization Fund 2022 $321,585
10.553 School Breakfast Program 2022 $274,432
10.553 School Breakfast Program 2023 $248,457
84.367 Improving Teacher Quality State Grants 2022 $145,801
84.027 Special Education_grants to States 2023 $117,465
84.173 Special Education_preschool Grants 2022 $52,756
84.367 Improving Teacher Quality State Grants 2023 $46,523
10.559 Summer Food Service Program for Children 2022 $30,254
84.424 Student Support and Academic Enrichment Program 2022 $18,947
10.559 Summer Food Service Program for Children 2023 $15,289
84.173 Special Education_preschool Grants 2023 $8,833
10.649 Pandemic Ebt Administrative Costs 2023 $3,135
10.649 Pandemic Ebt Administrative Costs 2022 $3,063
10.556 Special Milk Program for Children 2023 $994