Finding 607143 (2022-003)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2022
Accepted
2023-03-29
Audit: 26815
Auditor: Crowe LLP

AI Summary

  • Core Issue: The School Corporation lacks an effective internal control system for managing federal awards, leading to noncompliance with procurement requirements.
  • Impacted Requirements: Compliance with 2 CFR sections 200.303, 200.318, and 200.320 regarding procurement processes and record-keeping.
  • Recommended Follow-Up: Management should implement necessary controls to ensure compliance with grant agreements and procurement methods, as outlined in their corrective action plan.

Finding Text

FINDING 2022-003 Information on the federal program: Subject: Child Nutrition Cluster - Procurement Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553 and 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY2021, FY2022 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Material Weakness Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards 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 200.318 states: "(i) The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price." 2 CFR 200.320 states: "(b) Procurement by small purchase procedures. Small purchase procedures are those relatively simple and informal procurement methods for securing services, supplies, or other property that do not cost more than the Simplified Acquisition Threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources. Condition: 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 requirements. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with the compliance requirements listed above. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There were no questioned costs identified. Context: For the audit period, there were four vendors that fell within the small purchases procurement threshold. Small purchases are those vendors that the School Corporation has purchased between $10,000 - $150,000 of products and goods. During the testing of Procurement and Suspension and Debarment, we noted one instance in a sample of one, where the School Corporation did not obtain three price or rate quotations from other vendors or document the basis for purchasing form the vendor that was utilized. The School Corporation compared the prices from the selected vendor to one vendor from their purchasing cooperative but did not obtain any additional quotes to meet the three-quote requirement for the small purchases procurement threshold. The lack of controls and noncompliance occurred throughout the audit period. Identification as a repeat finding, if applicable: Yes. Was identified as finding 2020-001 in the prior audit. Recommendation: We recommended that the School Corporation's management establish controls related to the grant agreement and the small purchase procurement method of the Procurement and Suspension and Debarment compliance requirement. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.

Categories

Procurement, Suspension & Debarment School Nutrition Programs

Other Findings in this Audit

  • 30701 2022-003
    Material Weakness Repeat
  • 30702 2022-003
    Material Weakness Repeat
  • 30703 2022-003
    Material Weakness Repeat
  • 30704 2022-002
    Material Weakness
  • 30705 2022-002
    Material Weakness
  • 30706 2022-002
    Material Weakness
  • 30707 2022-002
    Material Weakness
  • 30708 2022-002
    Material Weakness
  • 607144 2022-003
    Material Weakness Repeat
  • 607145 2022-003
    Material Weakness Repeat
  • 607146 2022-002
    Material Weakness
  • 607147 2022-002
    Material Weakness
  • 607148 2022-002
    Material Weakness
  • 607149 2022-002
    Material Weakness
  • 607150 2022-002
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
10.553 School Breakfast Program $244,728
84.010 Title I Grants to Local Educational Agencies $204,743
10.555 National School Lunch Program $167,267
84.425 Covid-19 - Education Stabilization Fund $103,183
93.778 Medical Assistance Program $64,699
84.173 Special Education_preschool Grants $28,372
84.367 Supporting Effective Instruction State Grants $27,103
84.424 Student Support and Academic Enrichment Program $21,665
84.027 Special Education_grants to States $107