Finding 529489 (2024-004)

Material Weakness
Requirement
AB
Questioned Costs
$1
Year
2024
Accepted
2025-03-24

AI Summary

  • Core Issue: The School Corporation lacks effective internal controls over federal awards, leading to noncompliance with federal regulations.
  • Impacted Requirements: Failure to establish a formal risk assessment process and inadequate documentation for claims resulted in questioned costs totaling $1,013.
  • Recommended Follow-Up: Implement a comprehensive risk assessment policy, conduct regular monitoring of internal controls, and ensure all claims are supported by proper documentation.

Finding Text

FINDING 2024-004 Subject: Child Nutrition Cluster - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Special Milk Program for Children Assistance Listings Numbers: 10.553, 10.555, 10.556 Federal Award Numbers and Years (or Other Identifying Numbers): FY2023, FY2024 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Activities Allowed and Unallowed, Allowable Costs/Cost Principles Audit Findings: Material Weakness, Other Matters Condition and Context Internal control is generally defined as a process affected by an entity's oversight body, management, and other personnel that provides reasonable assurance that the objectives of an entity will be achieved. With respect to federal awards, nonfederal entities, such as the School Corporation, are required to establish and maintain internal controls over federal awards that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and terms and conditions of the federal awards. INDIANA STATE BOARD OF ACCOUNTS 22 CANNELTON CITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Internal control is not one event or circumstance, but a dynamic and iterative process. The internal control process is based on fundamental principles that operate as a whole but are best understood when analyzed individually. The fundamental principles are related to five components of internal control which are as follows: Control Environment, Risk Assessment, Control Activities, Information and Communication, and Monitoring. If a component is not effective, or the components are not operating together in an integrated manner, then an internal control system cannot be effective. Deficiencies as noted below were identified in the risk assessment, monitoring, and control activities components. Risk Assessment The School Corporation has not established a formal risk assessment process. There is no documented risk assessment policy, nor is there evidence of periodic risk identification, analysis, or evaluation. Monitoring The School Corporation did not conduct ongoing or periodic reviews to ensure that internal controls were operating as intended and to identify areas for improvement. Furthermore, the School Corporation did not have a process to follow up on corrective actions written as a response to audit findings. Control Activities A sample of 60 claims was selected for testing. Of the 60 claims selected for testing, 43 claims were vendor claims and 17 were payroll claims. Issues were identified with 5 of the vendor claims as noted below:  Three claims, totaling $700, were paid based solely upon summary statements from the vendor. The School Corporation was unable to provide additional documentation, such as invoices, to detail what items or services had been purchased. Without adequate supporting documentation, we could not determine if the expenses incurred were for activities and costs allowable per the grant.  Two claims, totaling $313, were paid with no supporting documentation. The School Corporation was unable to provide additional documentation, such as invoices, to detail what items or services had been purchased. Without adequate supporting documentation, we could not determine if the expenses incurred were for activities and costs allowable per the grant. The total amount, $1,013, paid without adequate supporting documentation was considered questioned costs. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: INDIANA STATE BOARD OF ACCOUNTS 23 CANNELTON CITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (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). . . ." 2 CFR 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. . . . (g) Be adequately documented. . . ." 7 CFR 210.14(a) states in part: ". . . Revenues received by the nonprofit school food service are to be used only for the operation or improvement of such food service, except that, such revenues shall not be used to purchase land or buildings, unless otherwise approved by FNS, or to construct buildings. . . ." 7 CFR 220.7(e)(1)(ii) states in part: ". . . use all revenues received by such food service only for the operation or improvement of that food service . . ." Cause Management of the School Corporation had not taken steps to design and implement policies and procedures to assess risks facing the School Corporation or to establish and operate monitoring activities that monitor the internal control system. Additionally, the School Corporation did not follow proper recordkeeping procedures. The Treasurer paid claims from federal program funds with no support or based on summary statements. INDIANA STATE BOARD OF ACCOUNTS 24 CANNELTON CITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Effect As a result of the five components of internal control not being adequately designed and implemented, the internal control system cannot be effective. Thus, general risks or specific risks from fraud and significant changes could negatively impact the School Corporation, identified internal control deficiencies could continue, and unidentified flaws within the internal control system could exist. Additionally, we could not determine if federal program funds were used to pay only for the operation or improvement of the food service. Furthermore, the lack of detailed documentation was not in compliance with the cost principles. Continued payment with no support or only summary statements could lead to payments for unallowable activities and additional questioned costs. Questioned Costs Questioned costs in the amount of $1,013 were identified as noted in the Condition and Context. Recommendation We recommended that the School Corporation's management establish a proper system of internal controls, which would include policies and procedures related to risk assessment and monitoring. Additionally, we recommended that the School Corporation's management establish a proper system of internal controls to ensure expenditures made from federal awards have appropriate supporting documentation to ensure expenditures are allowable per the terms and conditions of the federal award and adhere to the cost principles. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

Categories

Questioned Costs Allowable Costs / Cost Principles Subrecipient Monitoring School Nutrition Programs Internal Control / Segregation of Duties

Other Findings in this Audit

  • 529482 2024-003
    Material Weakness
  • 529483 2024-003
    Material Weakness
  • 529484 2024-003
    Material Weakness
  • 529485 2024-003
    Material Weakness
  • 529486 2024-003
    Material Weakness
  • 529487 2024-004
    Material Weakness
  • 529488 2024-004
    Material Weakness
  • 529490 2024-004
    Material Weakness
  • 529491 2024-004
    Material Weakness
  • 529492 2024-005
    Material Weakness
  • 529493 2024-005
    Material Weakness
  • 529494 2024-005
    Material Weakness
  • 529495 2024-005
    Material Weakness
  • 529496 2024-005
    Material Weakness
  • 529497 2024-006
    Material Weakness
  • 529498 2024-006
    Material Weakness
  • 529499 2024-006
    Material Weakness
  • 529500 2024-006
    Material Weakness
  • 529501 2024-006
    Material Weakness
  • 529502 2024-006
    Material Weakness
  • 529503 2024-006
    Material Weakness
  • 529504 2024-007
    Material Weakness
  • 529505 2024-007
    Material Weakness
  • 529506 2024-007
    Material Weakness
  • 529507 2024-007
    Material Weakness
  • 529508 2024-008
    Material Weakness Repeat
  • 529509 2024-008
    Material Weakness Repeat
  • 529510 2024-008
    Material Weakness Repeat
  • 529511 2024-008
    Material Weakness Repeat
  • 529512 2024-008
    Material Weakness Repeat
  • 529513 2024-008
    Material Weakness Repeat
  • 529514 2024-008
    Material Weakness Repeat
  • 529515 2024-009
    Material Weakness Repeat
  • 529516 2024-009
    Material Weakness Repeat
  • 1105924 2024-003
    Material Weakness
  • 1105925 2024-003
    Material Weakness
  • 1105926 2024-003
    Material Weakness
  • 1105927 2024-003
    Material Weakness
  • 1105928 2024-003
    Material Weakness
  • 1105929 2024-004
    Material Weakness
  • 1105930 2024-004
    Material Weakness
  • 1105931 2024-004
    Material Weakness
  • 1105932 2024-004
    Material Weakness
  • 1105933 2024-004
    Material Weakness
  • 1105934 2024-005
    Material Weakness
  • 1105935 2024-005
    Material Weakness
  • 1105936 2024-005
    Material Weakness
  • 1105937 2024-005
    Material Weakness
  • 1105938 2024-005
    Material Weakness
  • 1105939 2024-006
    Material Weakness
  • 1105940 2024-006
    Material Weakness
  • 1105941 2024-006
    Material Weakness
  • 1105942 2024-006
    Material Weakness
  • 1105943 2024-006
    Material Weakness
  • 1105944 2024-006
    Material Weakness
  • 1105945 2024-006
    Material Weakness
  • 1105946 2024-007
    Material Weakness
  • 1105947 2024-007
    Material Weakness
  • 1105948 2024-007
    Material Weakness
  • 1105949 2024-007
    Material Weakness
  • 1105950 2024-008
    Material Weakness Repeat
  • 1105951 2024-008
    Material Weakness Repeat
  • 1105952 2024-008
    Material Weakness Repeat
  • 1105953 2024-008
    Material Weakness Repeat
  • 1105954 2024-008
    Material Weakness Repeat
  • 1105955 2024-008
    Material Weakness Repeat
  • 1105956 2024-008
    Material Weakness Repeat
  • 1105957 2024-009
    Material Weakness Repeat
  • 1105958 2024-009
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.425 Education Stabilization Fund 2023 $306,447
84.010 Title I Grants to Local Educational Agencies 2024 $158,170
84.010 Title I Grants to Local Educational Agencies 2023 $142,251
10.555 National School Lunch Program 2023 $133,028
10.555 National School Lunch Program 2024 $117,724
84.425 Education Stabilization Fund 2024 $106,046
84.424 Student Support and Academic Enrichment Program 2024 $58,811
10.553 School Breakfast Program 2024 $48,082
10.553 School Breakfast Program 2023 $47,913
10.579 Child Nutrition Discretionary Grants Limited Availability 2023 $24,809
84.367 Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) 2024 $17,589
84.367 Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) 2023 $15,546
84.424 Student Support and Academic Enrichment Program 2023 $10,254
10.556 Special Milk Program for Children 2024 $9,842
84.027 Special Education Grants to States 2023 $9,174
84.196 Education for Homeless Children and Youth 2023 $9,000
84.358 Rural Education 2024 $7,514
84.358 Rural Education 2023 $6,514
84.027 Special Education Grants to States 2024 $1,722
10.557 Wic Special Supplemental Nutrition Program for Women, Infants, and Children 2024 $1,681
84.173 Special Education Preschool Grants 2023 $930
10.649 Pandemic Ebt Administrative Costs 2023 $628
84.173 Special Education Preschool Grants 2024 $103