Finding 528161 (2024-003)

Material Weakness
Requirement
E
Questioned Costs
-
Year
2024
Accepted
2025-03-14

AI Summary

  • Core Issue: The School Corporation lacks effective internal controls for determining student eligibility for free or reduced-price meals, leading to incorrect eligibility determinations.
  • Impacted Requirements: Compliance with federal regulations (2 CFR 200.303 and 7 CFR 245.6) regarding eligibility assessment and internal control systems is not being met.
  • Recommended Follow-Up: Implement comprehensive policies and procedures for eligibility verification, including regular reviews of data uploads and calculations to ensure compliance and accuracy.

Finding Text

FINDING 2024-003 Subject: Child Nutrition Cluster - Eligibility 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): SY2022-2023, SY2023-2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Findings: Material Weakness, Modified Opinion Condition and Context The School Corporation had not properly 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 determining the eligibility of a child to receive free or reduced-price meals. A child's eligibility for free or reduced-price meals under a Child Nutrition Cluster program may be established by the submission of an annual application or statement which furnishes such information as family income and family size. Local educational agencies, institutions, and sponsors then determine eligibility by comparing the data reported by the child's household to published income eligibility guidelines. Additionally, a child may be direct certified. For a direct certification, annual eligibility determinations are based on the child's household receiving benefits under the Supplemental Nutrition Assistance Program (SNAP), the Food Distribution Program on the Indian Reservations (FDPIR), the Head Start program (ALN 93.600), or, under most circumstances, the Temporary Assistance for Needy Families (TANF) program (ALN 93.558). A household may furnish documentation of its participation in one of these programs; or the school, institution, or sponsor may obtain the information directly from the state or local agency that administers these programs. Certain foster, runaway, homeless, and migrant children are categorically eligible for free school lunches and breakfasts. Direct certified households do not need to complete an application for free or reduced-price meals. The School Corporation contracted with a Food Service Management Company (FSMC) for the operation of the food service program during the audit period. The FSMC had a dedicated representative who worked exclusively with the School Corporation. The School Corporation did not have policies or procedures in place to ensure compliance with determining the eligibility of students for free and reduce price meals as noted in the following: INDIANA STATE BOARD OF ACCOUNTS 19 METROPOLITAN SCHOOL DISTRICT OF BOONE TOWNSHIP SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Direct Certifications The FSMC representative was responsible for generating and reviewing the direct certification file. The FSMC representative downloaded the direct certification file from the State of Indiana database and uploaded it to the school lunch point-of-sale (POS) system. There was no documentation of review by the School Corporation to ensure the upload had been completed, that the upload had imported correctly, or the students' statuses were updated accordingly. Applications The School Corporation utilized a POS system to determine eligibility of the applications submitted for free and reduced price meals based on income eligibility guidelines. The income eligibility guidelines were input by the FSMC representative and reviewed by a knowledgeable school employee for the year ended June 30, 2024; however, there was no documented review or approval in place to ensure the guidelines were properly entered for the year ended June 30, 2023. Applications were submitted online as part of the annual registration process, and, when fully complete, the determination of eligibility was completed by the POS system based on the inputted income eligibility guidelines. The School Corporation relied solely on the POS system to calculate and determine the eligibility status of student applications. There was no documentation of procedures or review to ensure the software system was accurately calculating and determining the student eligibility status. Of the 30 students receiving free and reduced-price meals that were tested, the following noncompliance was noted:  Two students were receiving free meals but, based on reported income, were determined to be eligible for reduced-priced meals.  Two students were receiving reduced-price meals but, based on reported income, were determined to be eligible for free meals. The lack of internal controls and noncompliance were systemic 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). . . ." INDIANA STATE BOARD OF ACCOUNTS 20 METROPOLITAN SCHOOL DISTRICT OF BOONE TOWNSHIP SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 7 CFR 245.6(c)(4) states: "The local educational agency must use the income information provided by the household on the application to calculate the household's total current income. When a household submits an application containing complete documentation, as defined in § 245.2, and the household's total current income is at or below the eligibility limits specified in the Income Eligibility Guidelines as defined in § 245.2, the children in that household must be approved for free or reduced price benefits, as applicable." Cause The system of internal controls over the monthly direct certification uploads, review of the income eligibility guidelines saved in the POS system, and application records were not properly implemented. The School Corporation relied on the FSMC and the POS to determine eligibility without an oversight process in place. Effect Without the proper implementation of an effectively designed system of internal controls, the School Corporation did not calculate eligibility accurately. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the repayment of federal funds. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation design and implement a proper system of internal controls, including policies and procedures that would ensure student eligibility for free or reduced-price lunches is accurately determined and that all documentation is retained. 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 2024-003 Finding Subject: Child Nutrition Cluster - Eligibility Contact Person Responsible for Corrective Action: Kelsey Rodriguez and Beverly Hindes Contact Phone Number: 574-229-2209 and 219-996-4771 x128 Views of Responsible Officials: We agree with the finding. Description of Corrective Action Plan: The Treasurer will ensure compliance with the Food Service Director (NIESC) Kelsey Rodriguez, with the student determination guidelines to receive free or reduced priced meals. The designee will review and sign off. Additionally, all documentation will be maintained. Anticipated Completion Date: March 31, 2025

Categories

School Nutrition Programs Internal Control / Segregation of Duties Eligibility Material Weakness Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 528157 2024-002
    Material Weakness Repeat
  • 528158 2024-002
    Material Weakness Repeat
  • 528159 2024-002
    Material Weakness Repeat
  • 528160 2024-002
    Material Weakness Repeat
  • 528162 2024-003
    Material Weakness
  • 528163 2024-003
    Material Weakness
  • 528164 2024-003
    Material Weakness
  • 528165 2024-004
    Material Weakness
  • 528166 2024-004
    Material Weakness
  • 528167 2024-005
    Material Weakness
  • 528168 2024-005
    Material Weakness
  • 528169 2024-005
    Material Weakness
  • 528170 2024-005
    Material Weakness
  • 1104599 2024-002
    Material Weakness Repeat
  • 1104600 2024-002
    Material Weakness Repeat
  • 1104601 2024-002
    Material Weakness Repeat
  • 1104602 2024-002
    Material Weakness Repeat
  • 1104603 2024-003
    Material Weakness
  • 1104604 2024-003
    Material Weakness
  • 1104605 2024-003
    Material Weakness
  • 1104606 2024-003
    Material Weakness
  • 1104607 2024-004
    Material Weakness
  • 1104608 2024-004
    Material Weakness
  • 1104609 2024-005
    Material Weakness
  • 1104610 2024-005
    Material Weakness
  • 1104611 2024-005
    Material Weakness
  • 1104612 2024-005
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
10.555 National School Lunch Program 2023 $467,433
10.555 National School Lunch Program 2024 $356,373
84.425 Education Stabilization Fund 2023 $298,551
84.425 Education Stabilization Fund 2024 $222,468
84.010 Title I Grants to Local Educational Agencies 2023 $106,369
84.010 Title I Grants to Local Educational Agencies 2024 $85,163
10.553 School Breakfast Program 2023 $60,276
10.553 School Breakfast Program 2024 $52,315
84.027 Special Education Grants to States 2024 $49,116
84.367 Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) 2023 $31,027
10.579 Child Nutrition Discretionary Grants Limited Availability 2024 $30,000
84.367 Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) 2024 $19,208
93.778 Medical Assistance Program 2024 $18,539
84.424 Student Support and Academic Enrichment Program 2023 $14,896
84.424 Student Support and Academic Enrichment Program 2024 $9,805
84.173 Special Education Preschool Grants 2023 $7,393
84.027 Special Education Grants to States 2023 $7,010
84.173 Special Education Preschool Grants 2024 $4,182
93.778 Medical Assistance Program 2023 $1,898