Finding 526891 (2024-002)

Material Weakness
Requirement
N
Questioned Costs
-
Year
2024
Accepted
2025-03-13

AI Summary

  • Core Issue: The School Corporation lacks effective internal controls, specifically segregation of duties, for managing federal funds related to the School Breakfast and National School Lunch Programs.
  • Impacted Requirements: Compliance with 2 CFR 200.303 is not met, as there is inadequate documentation and oversight of federal reimbursements in the non-profit school food service accounts.
  • Recommended Follow-Up: Management should redesign internal controls to ensure proper documentation and oversight are established and maintained moving forward.

Finding Text

FINDING 2024-002 Subject: Child Nutrition Cluster- Special Tests and Provisions - Non-Profit School Food Service Accounts 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): SY 2022-2023, SY 2023-2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Non-Profit School Food Service Accounts Audit Finding: Material Weakness Condition and Context An effective internal control system, which would include segregation of duties, was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Special Tests and Provisions - Non-Profit School Food Service Accounts compliance requirement. INDIANA STATE BOARD OF ACCOUNTS 18 SOUTHWESTERN JEFFERSON COUNTY CONSOLIDATED SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) All revenues and expenditures of the nonprofit school food service account are to be accounted for in accordance with state and federal requirements. As such, separate accounting is to be made for the school food service, federal reimbursements are to be correctly credited to the food service account, and transfers out of the school food service account are to be for allowable costs of the school food service. Receipt of the School Corporation's federal reimbursements were posted to the ledger by one individual, the established internal control of having the Treasurer review and sign the receipts to ensure that all reimbursements were properly credited to the food service account was not documented after March 2023. The lack of internal controls was a systemic issue from March of 2023 through the end of 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 After an upgrade to the School Corporation's financial management software, the Treasurer no longer manually signed the receipts to document her review. No alternative documentation of her review, or a compensating internal control was presented for audit. 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 revenues not being correctly credited to the food service account to be used for allowable costs. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation design its system of internal controls to ensure that internal controls are in place and properly documented. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

Corrective Action Plan

FINDING 2024-002 Finding Subject: Child Nutrition Cluster- Special Tests and Provisions-Non-Profit School Food Service Accounts Summary of Finding: Finding 2024-002 indicates a failure to maintain adequate internal control systems with regards to requirements related to the grant agreement and the Special Tests and Provisions-Non-Profit School Food Service Accounts compliance requirement. As a result of these inadequate internal control systems, the corporation did not prevent, detect, and/or correct errors prior to submission. It has been recommended that a system of internal control be implemented which would include multiple individuals with a segregation of duties. This system should include signatures of each person involved along with their role in the internal control system process. Contact Person Responsible for Corrective Action: Katie King, Food Services Director Contact Phone Number and Email Address: 812-866-6254, kking@swjcs.us Views of Responsible Officials: We concur with this audit finding. Description of Corrective Action Plan: Action taken to remedy finding 2024-002 includes, but is not limited to, the following: 􀁸 Beginning immediately, Assistant Treasurer 1 will prepare a DocuSign envelope monthly with the following financial reports to be reviewed: o Appropriation Report o Expenditure Report o Revenue Report o Fund Detail Report o Fund Report 􀁸 The DocuSign Envelope will be routed to the Food Services Director, for the initial review. 􀁸 The Food Service Director will complete his/her review, adding comments and suggestions as needed. An eSignature will confirm that the data appears accurate. 􀁸 The DocuSign Envelope will then be routed to Assistant Treasurer 2 for an additional review. 􀁸 Assistant Treasurer 2 will complete his/her review, adding comments and suggestions as needed. An eSignature will confirm that the data appears accurate. 􀁸 If corrections to the report are required: o The Food Service Director and/or Assistant Treasurer 2 will decline to sign and discuss the changes needed with Assistant Treasurer 1. o Assistant Treasurer 1 will then create a second DocuSign Envelope, with the needed corrections and begin the process again. 􀁸 If no corrections are needed, the Chief Financial Officer, designated as monitor, will confirm that both the Food Service Director and Assistant Treasurer 2 reviews have been completed and indicates as such via eSignatures. 􀁸 After the above steps have been taken, the report will be submitted 􀁸 The Grant Coordinator indicates its completion by eSignature in the appropriate location. INDIANA STATE BOARD OF ACCOUNTS 33 􀀃 􀀃 Anticipated Completion Date: March 1, 2025

Categories

School Nutrition Programs Allowable Costs / Cost Principles Cash Management Material Weakness Internal Control / Segregation of Duties Special Tests & Provisions Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 526892 2024-002
    Material Weakness
  • 526893 2024-002
    Material Weakness
  • 526894 2024-002
    Material Weakness
  • 526895 2024-003
    Material Weakness Repeat
  • 526896 2024-003
    Material Weakness Repeat
  • 526897 2024-003
    Material Weakness Repeat
  • 526898 2024-003
    Material Weakness Repeat
  • 526899 2024-003
    Material Weakness Repeat
  • 1103333 2024-002
    Material Weakness
  • 1103334 2024-002
    Material Weakness
  • 1103335 2024-002
    Material Weakness
  • 1103336 2024-002
    Material Weakness
  • 1103337 2024-003
    Material Weakness Repeat
  • 1103338 2024-003
    Material Weakness Repeat
  • 1103339 2024-003
    Material Weakness Repeat
  • 1103340 2024-003
    Material Weakness Repeat
  • 1103341 2024-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
10.555 National School Lunch Program 2023 $659,387
10.555 National School Lunch Program 2024 $577,014
84.425 Education Stabilization Fund 2024 $572,933
84.425 Education Stabilization Fund 2023 $505,078
84.010 Title I Grants to Local Educational Agencies 2023 $316,020
10.553 School Breakfast Program 2023 $219,496
84.010 Title I Grants to Local Educational Agencies 2024 $211,294
10.553 School Breakfast Program 2024 $207,574
84.027 Special Education Grants to States 2024 $76,589
16.710 Public Safety Partnership and Community Policing Grants 2023 $68,215
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) 2023 $37,561
84.367 Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) 2023 $33,279
84.424 Student Support and Academic Enrichment Program 2023 $31,276
84.027 Special Education Grants to States 2023 $23,328
84.424 Student Support and Academic Enrichment Program 2024 $15,219
84.367 Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) 2024 $13,758
10.579 Child Nutrition Discretionary Grants Limited Availability 2024 $10,407
16.710 Public Safety Partnership and Community Policing Grants 2024 $5,034
84.173 Special Education Preschool Grants 2024 $4,557
10.649 Pandemic Ebt Administrative Costs 2023 $628
84.173 Special Education Preschool Grants 2023 $300