Finding 384555 (2023-004)

Material Weakness Repeat Finding
Requirement
Eligibility
Questioned Costs
-
Year
2023
Accepted
2024-03-26

AI Summary

  • Core Issue: The School Corporation lacks effective internal controls for determining eligibility and processing claims for the Child Nutrition Cluster programs, leading to a material weakness in compliance.
  • Impacted Requirements: Eligibility determinations and claims reporting are not properly reviewed, violating 2 CFR 200.303 regarding internal control standards.
  • Recommended Follow-Up: Management should establish a robust internal control system with clear policies, procedures, and segregation of duties to ensure accurate eligibility assessments and claims processing.

Finding Text

FINDING 2023-004 Subject: Child Nutrition Cluster - Internal Controls 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 Requirements: Eligibility, Reporting Audit Finding: Material Weakness Repeat Finding This is a repeat finding for Eligibility from the prior audit report. The prior audit finding number was 2021-005. Condition and Context Eligibility Any child enrolled in a participating school who meets the applicable program's definition of "child," may receive meals under the applicable programs. A child belonging to households meeting nationwide income eligibility requirements may receive meals at no charge or at a reduced price. Children that have been determined ineligible for free or reduced-price meals pay the full price for their meals. A child's eligibility for free and reduced-priced meals under a Child Nutrition Cluster program may be established by the submission of an annual application or statement which furnished such information as family income and family size. The School Corporation determines eligibility by comparing the data reported by the child's household to published income eligibility guidelines. Annual eligibility determinations may also be based on the child's household receiving benefits under SNAP, FDPIR, the Head Start Program, or, under most circumstances, the TANF program. A household may furnish documentation if its participation in one of those programs, or the School Corporation may obtain the information directly from the State or local agency that administers those 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. Paper applications and online applications are processed in the School Corporation's software system to determine if students are eligible for free or reduced meals. Paper applications are input by the Nutrition Services Director and online applications are directly submitted by parents. The software's determination of eligibility is recalculated by the Nutrition Services Director without an oversight or review process in place to ensure accuracy. Additionally, the Nutrition Services Director downloaded the Direct Certifications file from the CNC Web Portal and uploaded the file into the School Corporation's software on a monthly basis without a documented oversight or review process in place to ensure directly certified students were properly processed. The lack of internal controls was isolated to fiscal year 2022-2023. Reporting The School Corporation must submit monthly sponsor claims for reimbursement (claims) for meals and snacks served to eligible students within 60 days following the last day of the month covered by the claim. Claims were submitted to the Indiana Department of Education (IDOE) as required; however, the claims were prepared by one employee without a review or approval process in place to prevent, or detect and correct, errors. The lack of internal controls was a systemic issue 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). . . ." Cause A proper system of internal controls, which would include segregation of key functions, 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 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.

Categories

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

Other Findings in this Audit

  • 384554 2023-004
    Material Weakness Repeat
  • 384556 2023-004
    Material Weakness Repeat
  • 384557 2023-004
    Material Weakness Repeat
  • 384558 2023-004
    Material Weakness Repeat
  • 384559 2023-004
    Material Weakness Repeat
  • 384560 2023-005
    Material Weakness
  • 384561 2023-005
    Material Weakness
  • 384562 2023-005
    Material Weakness
  • 384563 2023-005
    Material Weakness
  • 384564 2023-005
    Material Weakness
  • 384565 2023-005
    Material Weakness
  • 384566 2023-005
    Material Weakness
  • 384567 2023-006
    Material Weakness Repeat
  • 384568 2023-006
    Material Weakness Repeat
  • 384569 2023-007
    Material Weakness
  • 384570 2023-007
    Material Weakness
  • 384571 2023-008
    Material Weakness
  • 384572 2023-008
    Material Weakness
  • 960996 2023-004
    Material Weakness Repeat
  • 960997 2023-004
    Material Weakness Repeat
  • 960998 2023-004
    Material Weakness Repeat
  • 960999 2023-004
    Material Weakness Repeat
  • 961000 2023-004
    Material Weakness Repeat
  • 961001 2023-004
    Material Weakness Repeat
  • 961002 2023-005
    Material Weakness
  • 961003 2023-005
    Material Weakness
  • 961004 2023-005
    Material Weakness
  • 961005 2023-005
    Material Weakness
  • 961006 2023-005
    Material Weakness
  • 961007 2023-005
    Material Weakness
  • 961008 2023-005
    Material Weakness
  • 961009 2023-006
    Material Weakness Repeat
  • 961010 2023-006
    Material Weakness Repeat
  • 961011 2023-007
    Material Weakness
  • 961012 2023-007
    Material Weakness
  • 961013 2023-008
    Material Weakness
  • 961014 2023-008
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
10.555 National School Lunch Program 2022 $1.36M
10.555 National School Lunch Program 2023 $1.33M
84.425 Education Stabilization Fund 2023 $556,140
84.010 Title I Grants to Local Educational Agencies 2022 $404,526
84.010 Title I Grants to Local Educational Agencies 2023 $404,429
10.553 School Breakfast Program 2022 $253,804
10.553 School Breakfast Program 2023 $234,279
84.367 Improving Teacher Quality State Grants 2022 $138,545
84.048 Career and Technical Education -- Basic Grants to States 2022 $123,553
84.425 Education Stabilization Fund 2022 $111,116
84.367 Improving Teacher Quality State Grants 2023 $106,552
84.048 Career and Technical Education -- Basic Grants to States 2023 $104,705
10.559 Summer Food Service Program for Children 2022 $82,234
84.027 Special Education_grants to States 2023 $76,041
84.424 Student Support and Academic Enrichment Program 2022 $62,216
10.559 Summer Food Service Program for Children 2023 $43,650
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) 2022 $35,814
84.424 Student Support and Academic Enrichment Program 2023 $23,496
93.778 Medical Assistance Program 2022 $22,814
93.778 Medical Assistance Program 2023 $18,506
84.173 Special Education_preschool Grants 2022 $13,891
84.365 English Language Acquisition State Grants 2022 $9,890
84.365 English Language Acquisition State Grants 2023 $7,721
84.027 Special Education_grants to States 2022 $4,226
10.649 Pandemic Ebt Administrative Costs 2023 $3,135
10.649 Pandemic Ebt Administrative Costs 2022 $3,063
84.173 Special Education_preschool Grants 2023 $811