Finding 385502 (2023-002)

Material Weakness
Requirement
EN
Questioned Costs
-
Year
2023
Accepted
2024-03-27

AI Summary

  • Core Issue: The School Corporation lacks a proper system of internal controls, leading to potential noncompliance in eligibility determinations for free and reduced-price meal applications.
  • Impacted Requirements: Compliance with 2 CFR 200.303 regarding effective internal controls over federal awards, specifically for the National School Lunch Program.
  • Recommended Follow-Up: Management should design and implement a robust internal control system, ensuring segregation of duties and appropriate oversight for eligibility reviews and verifications.

Finding Text

FINDING 2023-002 Subject: Child Nutrition Cluster - Eligibility, Special Tests and Provisions - Verification of Free and Reduced Price Applications (NSLP) 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): FY22/23, FY22/23 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Eligibility, Special Tests and Provisions - Verification of Free and Reduced Price Applications (NSLP) 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 with the Eligibility and the Special Tests and Provisions - Verification of Free and the Reduced Price Applications (NSLP) compliance requirements. INDIANA STATE BOARD OF ACCOUNTS 16 SILVER CREEK SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Eligibility 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. The Account Specialist reviewed and issued the initial eligibility determination without a system of oversight or review to ensure the eligibility determination was correct. Special Tests and Provisions - Verification of Free and Reduced Price Applications (NSLP) (Applies to National School Lunch Program only) 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 verification of free and reduced price applications. The Account Specialist performed the verification of free and reduced price applications without a system of oversight or review to ensure the verification was correct. 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: (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 designed 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. INDIANA STATE BOARD OF ACCOUNTS 17 SILVER CREEK SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 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 Material Weakness Matching / Level of Effort / Earmarking Special Tests & Provisions

Other Findings in this Audit

  • 385501 2023-002
    Material Weakness
  • 385503 2023-003
    Material Weakness
  • 385504 2023-003
    Material Weakness
  • 385505 2023-004
    Material Weakness
  • 385506 2023-004
    Material Weakness
  • 385507 2023-005
    Material Weakness
  • 385508 2023-005
    Material Weakness
  • 385509 2023-006
    Material Weakness
  • 385510 2023-006
    Material Weakness
  • 385511 2023-007
    Material Weakness
  • 385512 2023-007
    Material Weakness
  • 385513 2023-008
    Material Weakness
  • 385514 2023-008
    Material Weakness
  • 385515 2023-008
    Material Weakness
  • 385516 2023-008
    Material Weakness
  • 385517 2023-009
    Material Weakness
  • 385518 2023-009
    Material Weakness
  • 385519 2023-010
    Material Weakness
  • 385520 2023-010
    Material Weakness
  • 961943 2023-002
    Material Weakness
  • 961944 2023-002
    Material Weakness
  • 961945 2023-003
    Material Weakness
  • 961946 2023-003
    Material Weakness
  • 961947 2023-004
    Material Weakness
  • 961948 2023-004
    Material Weakness
  • 961949 2023-005
    Material Weakness
  • 961950 2023-005
    Material Weakness
  • 961951 2023-006
    Material Weakness
  • 961952 2023-006
    Material Weakness
  • 961953 2023-007
    Material Weakness
  • 961954 2023-007
    Material Weakness
  • 961955 2023-008
    Material Weakness
  • 961956 2023-008
    Material Weakness
  • 961957 2023-008
    Material Weakness
  • 961958 2023-008
    Material Weakness
  • 961959 2023-009
    Material Weakness
  • 961960 2023-009
    Material Weakness
  • 961961 2023-010
    Material Weakness
  • 961962 2023-010
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
10.555 National School Lunch Program 2022 $1.32M
10.555 National School Lunch Program 2023 $1.05M
84.425 Education Stabilization Fund 2023 $752,597
84.027 Special Education_grants to States 2023 $597,487
84.027 Special Education_grants to States 2022 $594,491
84.010 Title I Grants to Local Educational Agencies 2023 $353,035
84.010 Title I Grants to Local Educational Agencies 2022 $258,864
84.425 Education Stabilization Fund 2022 $202,495
10.553 School Breakfast Program 2022 $195,834
10.553 School Breakfast Program 2023 $171,476
84.367 Improving Teacher Quality State Grants 2023 $100,714
84.367 Improving Teacher Quality State Grants 2022 $77,868
84.365 English Language Acquisition State Grants 2023 $54,077
93.778 Medical Assistance Program 2022 $30,290
84.173 Special Education_preschool Grants 2023 $21,401
93.778 Medical Assistance Program 2023 $21,301
84.173 Special Education_preschool Grants 2022 $19,498
84.424 Student Support and Academic Enrichment Program 2023 $16,201
84.424 Student Support and Academic Enrichment Program 2022 $13,104
10.649 Pandemic Ebt Administrative Costs 2023 $628
10.649 Pandemic Ebt Administrative Costs 2022 $614