Finding 385436 (2023-004)

Material Weakness Repeat Finding
Requirement
AB
Questioned Costs
$1
Year
2023
Accepted
2024-03-27

AI Summary

  • Core Issue: There are significant weaknesses in internal controls over allowable costs in the Child Nutrition Cluster, leading to repeated findings of noncompliance.
  • Impacted Requirements: Expenditures must align with federal guidelines for allowable costs, and all claims should undergo proper review and documentation.
  • Recommended Follow-Up: Implement stronger internal controls, including segregation of duties and thorough documentation processes, to ensure compliance and prevent future issues.

Finding Text

FINDING 2023-004 Subject: Child Nutrition Cluster - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program Assistance Listings Numbers: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY 22, FY 23 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Findings: Material Weakness, Other Matters Repeat Finding This is a repeat finding for Allowable Costs/Cost Principles from the prior audit report. The prior audit finding number was 2021-002. Condition and Context Reimbursement for meals served is not based on costs; it is determined solely by applying the applicable meals times rates formula. A School Corporation can use its entire reimbursement payment for any combination of allowable operating and administrative costs. Therefore, expenditures charged to the food service program fund (fund 800) are to be for the benefit of the food service program and in conformance with applicable cost principles. Forty vendor claims were selected for testing to ensure the identified internal control of one employee prepares the claim and a second knowledgeable individual reviews the claim prior to payment was in place and operating effectively. For two of the forty vendor claims tested, one employee prepared and approved the claim without a review or oversight process by a second knowledgeable employee. In addition, one of the two claims was approved without supporting documentation. An additional forty claims were selected to ensure the expenditures were for the benefit of the food service program. For the forty claims tested, the following issues were noted:  Seven claims, as detailed below, were for unallowable activities and unallowable costs.  One claim was for the purchase of gift cards for staff gifts totaling $905. INDIANA STATE BOARD OF ACCOUNTS 25 METROPOLITAN SCHOOL DISTRICT OF SOUTHWEST ALLEN COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued)  Two claims were refunds of prepaid lunch account balances totaling $1,790.  Two claims were reimbursements to an employee for staff breakfasts totaling $110.  One claim was for the purchase of medication totaling $8.  One claim was for the purchase of uniforms totaling $50, which included no supporting documentation for the purchase.  Eight claims included the payment of sales tax totaling $85. Due to the noncompliance identified above, an additional twenty-one claims paid to one employee were judgmentally selected for testing. For the additional twenty-one claims tested, the following errors were noted:  One claim was for the purchase of a back brace shipped to an employee's house totaling $31.  Twelve claims included the payment of sales tax totaling $195. In addition, all refunds not already selected for testing were reviewed. A total of sixty-seven additional refunds of prepaid lunch account balances were identified and determined to be incorrectly made from Fund 800. The total amount of the additional refunds was $6,476. The total amount of unallowed activities and unallowable costs charged to the School Lunch fund was $9,650. This amount was considered questioned costs. The lack of effective internal controls and noncompliance were systemic issues 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). . . ." 7 CFR 220.7(e)(1) states in part: ". . . the School Food Authority shall, with respect to participating schools under its jurisdiction: . . . (ii) . . . use all revenues received by such food service only for the operation or improvement of that food service . . ." INDIANA STATE BOARD OF ACCOUNTS 26 METROPOLITAN SCHOOL DISTRICT OF SOUTHWEST ALLEN COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 7 CFR 210.14(a) states in part: ". . . Revenues received by the nonprofit school food service are to be used only for the operation or improvement of such food service, except that, such revenues shall not be used to purchase land or buildings, unless otherwise approved by FNS, or to construct buildings. . . ." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. . . . (g) Be adequately documented. . . ." 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 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, costs that were not necessary and reasonable for the performance of the federal award were paid for with federal funds. 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 Known questioned costs of $9,650 were identified as detailed in the Condition and Context. Recommendation We recommended the School Corporation's management establish a proper system of internal controls and develop policies and procedures to ensure costs are for the benefit of the food service program and are adequately documented. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

Categories

Questioned Costs Allowable Costs / Cost Principles School Nutrition Programs

Other Findings in this Audit

  • 385430 2023-002
    Material Weakness
  • 385431 2023-002
    Material Weakness
  • 385432 2023-003
    Material Weakness
  • 385433 2023-003
    Material Weakness
  • 385434 2023-004
    Material Weakness Repeat
  • 385435 2023-004
    Material Weakness Repeat
  • 385437 2023-004
    Material Weakness Repeat
  • 385438 2023-005
    Material Weakness
  • 385439 2023-005
    Material Weakness
  • 385440 2023-006
    Material Weakness Repeat
  • 385441 2023-006
    Material Weakness Repeat
  • 385442 2023-006
    Material Weakness Repeat
  • 385443 2023-006
    Material Weakness Repeat
  • 385444 2023-007
    Material Weakness
  • 385445 2023-007
    Material Weakness
  • 385446 2023-007
    Material Weakness
  • 385447 2023-007
    Material Weakness
  • 385448 2023-007
    Material Weakness
  • 961872 2023-002
    Material Weakness
  • 961873 2023-002
    Material Weakness
  • 961874 2023-003
    Material Weakness
  • 961875 2023-003
    Material Weakness
  • 961876 2023-004
    Material Weakness Repeat
  • 961877 2023-004
    Material Weakness Repeat
  • 961878 2023-004
    Material Weakness Repeat
  • 961879 2023-004
    Material Weakness Repeat
  • 961880 2023-005
    Material Weakness
  • 961881 2023-005
    Material Weakness
  • 961882 2023-006
    Material Weakness Repeat
  • 961883 2023-006
    Material Weakness Repeat
  • 961884 2023-006
    Material Weakness Repeat
  • 961885 2023-006
    Material Weakness Repeat
  • 961886 2023-007
    Material Weakness
  • 961887 2023-007
    Material Weakness
  • 961888 2023-007
    Material Weakness
  • 961889 2023-007
    Material Weakness
  • 961890 2023-007
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
10.555 National School Lunch Program 2022 $3.75M
10.555 National School Lunch Program 2023 $2.47M
10.553 School Breakfast Program 2022 $440,921
84.010 Title I Grants to Local Educational Agencies 2022 $277,959
84.027 Special Education_grants to States 2023 $253,867
10.553 School Breakfast Program 2023 $251,219
84.010 Title I Grants to Local Educational Agencies 2023 $152,794
93.778 Medical Assistance Program 2023 $115,781
84.367 Improving Teacher Quality State Grants 2023 $88,593
93.778 Medical Assistance Program 2022 $77,307
84.027 Special Education_grants to States 2022 $68,082
84.424 Student Support and Academic Enrichment Program 2022 $62,535
84.367 Improving Teacher Quality State Grants 2022 $51,574
84.048 Career and Technical Education -- Basic Grants to States 2022 $43,123
84.173 Special Education_preschool Grants 2022 $36,371
84.048 Career and Technical Education -- Basic Grants to States 2023 $36,125
84.425 Education Stabilization Fund 2022 $33,992
84.173 Special Education_preschool Grants 2023 $28,174
84.365 English Language Acquisition State Grants 2022 $10,821
84.365 English Language Acquisition State Grants 2023 $8,992
84.196 Education for Homeless Children and Youth 2022 $5,441
10.649 Pandemic Ebt Administrative Costs 2023 $3,135
10.649 Pandemic Ebt Administrative Costs 2022 $3,063
84.425 Education Stabilization Fund 2023 $1,469
84.424 Student Support and Academic Enrichment Program 2023 $728