Finding 525795 (2024-003)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2024
Accepted
2025-03-06

AI Summary

  • Core Issue: The School Corporation lacks effective internal controls for procurement and verifying contractor suspension and debarment, leading to a material weakness.
  • Impacted Requirements: Compliance with federal procurement regulations and suspension/debarment verification for contracts over $25,000 is not being met.
  • Recommended Follow-Up: Strengthen internal controls to ensure adequate price quotations for small purchases and verify suspension/debarment status for all relevant contractors.

Finding Text

FINDING 2024-003 Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program Assistance Listings Numbers: 10.553, 10.555 Federal Award Number and Year (or Other Identifying Number): FY 2023-2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Material Weakness Repeat Finding This is a repeat finding pertaining to internal controls from the immediately prior audit report. The prior audit finding number was 2022-006. Condition and Context An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Procurement Federal regulations allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisition threshold, which is customarily set at $250,000. However, Indiana Code 5-22-8 has a more restrictive threshold of $150,000 or less for when small purchase procedures may be used. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds. Micro-purchases, typically for those purchases $10,000 or under, and small purchase procedures for those purchases above the micro-purchase threshold, but below the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. The School Corporation did not have effective internal controls in place to ensure that an adequate number of price or rate quotations were obtained for all small purchases. Suspension and Debarment Prior to entering into subawards and covered transactions with the Child Nutrition Cluster (CNC) award funds, recipients are required to verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded. "Covered transactions" include, but are not limited to, contracts for goods and services awarded under a nonprocurement transaction (i.e., grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the Excluded Parties List System (EPLS), collecting a certification from that person, or adding a clause or condition to the covered transactions with that person. The School Corporation did not have effective internal controls in place to ensure that the verification was completed for all contractors prior to entering into covered transactions. The lack of internal controls was isolated to fiscal year 2023-2024. INDIANA STATE BOARD OF ACCOUNTS 20 MADISON CONSOLIDATED SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 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 Management had not established a system of internal controls to ensure documentation was obtained and retained to demonstrate they had properly procured all small purchases. Management had not established a system of internal controls to ensure that the School Corporation's procedures for verifying a contractor's suspension and debarment status was followed for all contractors. Effect Without the proper design or implementation of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. This could result in the School Corporation overpaying for goods or services or paying a contractor who has been suspended or debarred, which would be unallowable. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation strengthen its system of internal controls to ensure that an adequate number of price or rate quotations are obtained for all small purchases and that suspension and debarment is verified for all covered transactions of $25,000 or more. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 525794 2024-003
    Material Weakness Repeat
  • 525796 2024-004
    Material Weakness
  • 525797 2024-004
    Material Weakness
  • 525798 2024-005
    Material Weakness Repeat
  • 525799 2024-005
    Material Weakness Repeat
  • 525800 2024-006
    Significant Deficiency
  • 525801 2024-006
    Significant Deficiency
  • 525802 2024-006
    Significant Deficiency
  • 525803 2024-006
    Significant Deficiency
  • 525804 2024-006
    Significant Deficiency
  • 1102236 2024-003
    Material Weakness Repeat
  • 1102237 2024-003
    Material Weakness Repeat
  • 1102238 2024-004
    Material Weakness
  • 1102239 2024-004
    Material Weakness
  • 1102240 2024-005
    Material Weakness Repeat
  • 1102241 2024-005
    Material Weakness Repeat
  • 1102242 2024-006
    Significant Deficiency
  • 1102243 2024-006
    Significant Deficiency
  • 1102244 2024-006
    Significant Deficiency
  • 1102245 2024-006
    Significant Deficiency
  • 1102246 2024-006
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
10.555 National School Lunch Program 2023 $1.24M
10.555 National School Lunch Program 2024 $1.02M
84.010 Title I Grants to Local Educational Agencies 2024 $907,107
84.027 Special Education Grants to States 2023 $820,554
84.010 Title I Grants to Local Educational Agencies 2023 $637,283
10.553 School Breakfast Program 2023 $295,282
10.553 School Breakfast Program 2024 $248,290
84.027 Special Education Grants to States 2024 $184,724
84.425 Education Stabilization Fund 2023 $155,669
84.367 Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) 2024 $138,853
84.041 Impact Aid 2024 $91,722
84.424 Student Support and Academic Enrichment Program 2024 $83,521
84.041 Impact Aid 2023 $76,543
84.367 Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) 2023 $69,623
84.424 Student Support and Academic Enrichment Program 2023 $43,785
84.048 Career and Technical Education -- Basic Grants to States 2023 $42,969
84.048 Career and Technical Education -- Basic Grants to States 2024 $40,688
84.358 Rural Education 2023 $32,745
93.778 Medical Assistance Program 2024 $31,911
93.778 Medical Assistance Program 2023 $29,990
84.196 Education for Homeless Children and Youth 2023 $27,095
84.358 Rural Education 2024 $18,755
84.173 Special Education Preschool Grants 2024 $13,789
84.425 Education Stabilization Fund 2024 $11,182
84.196 Education for Homeless Children and Youth 2024 $10,309
10.649 Pandemic Ebt Administrative Costs 2023 $3,135