Finding 523214 (2024-001)

2024-001. Internal Control Over Compliance United States Department of Agriculture, Passed-through New York State Department of Education: Child Nutrition Cluster School Breakfast Program ALN: 10.553 National School Lunch Program ALN: 10.555 Criteria: 2 CFR §200.303 of the Uniform Guidance issued by the U.S. Office of Management and Budget requires non-Federal entities receiving Federal awards to establish and maintain internal control over the Federal awards 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. Federal awards recipients must maintain written documentation of internal control policies and procedures, such as procurement policies that adhere to state and local law, as well as Federal regulations and statutes; procedures for documenting how costs are to be allocated to Federal awards, documenting actual time and effort for payroll costs charged to Federal awards; cash management procedures to minimize the time elapsed between the receipts and disbursements of Federal funds; and, how to safeguard personally identifiable information. Condition: The District did not update its existing procurement policy to conform to the Uniform Guidance requirements. Cause: Due to turnover in a key business office position, the District was unable to complete a review of its procurement policy. Effect: Having insufficient or non-compliant written policies and procedures could weaken the internal controls over management of Federal awards, potentially increasing the risk of noncompliance with Federal statutes and regulations. Questioned Costs: None reported. Context: The District’s new business official was in the process of drafting an updated purchasing guidelines document, and is responsible for reviewing existing District policies and written procedures and recommending revisions and updates to the Superintendent and Board of Education. This review process and adoption of a policy was not completed until May 2024. Identification of a Repeat Finding: This is not a repeat finding. Recommendation: The District must review its existing written policies and procedures and update them as needed in order to comply with requirements of Uniform Guidance. Views of Responsible Officials of Auditee: The District is aware of this finding and has updated its policy and related procedures in order to comply with the requirements of Uniform Guidance. The Board of Education adopted the updated policy in May 2024.