Finding 607525 (2022-002)

Material Weakness Repeat Finding
Requirement
AB
Questioned Costs
$1
Year
2022
Accepted
2023-03-26

AI Summary

  • Core Issue: The School Corporation lacks effective internal controls to ensure compliance with federal grant requirements, leading to unallowable costs and insufficient documentation.
  • Impacted Requirements: Compliance with 2 CFR 200.303 and 7 CFR regulations regarding allowable costs and documentation is not being met, resulting in repeated findings.
  • Recommended Follow-Up: Implement a robust internal control system to track and document all costs accurately, ensuring compliance with federal guidelines to prevent future issues.

Finding Text

FINDING 2022-002 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, Summer Food Service Program for Children, COVID-19 - Summer Food Service Program for Children Assistance Listings Numbers: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): 2020-2021, 2021-2022 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Findings: Material Weakness, Modified Opinion Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2020-003. Condition and Context An effective internal control system was not designed or implemented at the School Corporation to ensure compliance with requirements related to the grant agreement and the Activities Allowed or Unallowed and the Allowable Costs/Cost Principles compliance requirements. Food Service Management Company The School Corporation had not designed nor implemented a system of internal controls to ensure that program costs were supported by proper documentation, were allowable, and only for the operation of the food service program. The School Corporation entered into a cost reimbursement contract, dated July 1, 2020, with a food service management company (FSMC). Two invoices for payment to the FSMC, which totaled $420,481, were selected for testing. Supporting documentation was presented for only $347,867 of the costs invoiced. Due to the lack of supporting documentation, we were unable to determine if the remaining costs paid, $72,614, were allowable expenditures. The costs that were not properly documented were considered questioned costs. INDIANA STATE BOARD OF ACCOUNTS 20 GARY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) In the supporting documentation presented for audit, sales tax was erroneously paid totaling $469. These unallowable costs were considered questioned costs. Payroll In fiscal year 2021-2022, the School Corporation's Inventory Analyst was assigned an additional role, Food Service Manager, which included additional compensation paid out of the Child Nutrition Cluster grant funds. The Food Service Manager did not maintain documentation of time spent on federal program and non-federal program activities. The total paid to the Food Service Manager from the School Lunch fund without proper documentation was $28,269. The costs that were not properly documented were 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: (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). . . ." 7 CFR 210.21(f)(1) states in part: ". . . (ii) (A) The contractor must separately identify for each cost submitted for payment to the school food authority the amount of that cost that is allowable (can be paid from the nonprofit school food service account) and the amount that is unallowable (cannot be paid from the nonprofit school food service account); or (B) The contractor must exclude all unallowable costs from its billing documents and certify that only allowable costs are submitted for payment and records have been established that maintain the visibility of unallowable costs, including directly associated costs in a manner suitable for contract cost determination and verification; (iii) The contractor's determination of its allowable costs must be made in compliance with the applicable Departmental and Program regulations and Office of Management and Budget cost circulars; . . . (vi) The contractor must maintain documentation of costs and discounts, rebates and other applicable credits, and must furnish such documentation upon request to the school food authority, the State agency, or the Department." 7 CFR 220.7(e) states in part: ". . . the School Food Authority shall, with respect to participating schools under its jurisdiction: INDIANA STATE BOARD OF ACCOUNTS 21 GARY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (1) (i) Maintain a nonprofit school food service; (ii) . . . use all revenues received by such food service only for the operation or improvement of that food service . . ." 7 CFR 210.14(a) states in part: "Nonprofit school food service. School food authorities shall maintain a nonprofit school food service. 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 225.15(a)(1) states: "Sponsors shall operate the food service in accordance with: the provisions of this part; any instructions and handbooks issued by FNS under this part; and any instructions and handbooks issued by the State agency which are not inconsistent with the provisions of this part." 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. . . ." 2 CFR 200.430(i) states in part: "Standards for documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities (for IHE, this per the IHE's definition of IBS); . . . (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. . . ." INDIANA STATE BOARD OF ACCOUNTS 22 GARY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Cause Management had not designed or implemented a system of internal controls that would have ensured compliance with the grant agreement and the Activities Allowed or Unallowed and the Allowable Costs/Cost Principles compliance requirements. Effect The failure to establish an effective system of internal controls and retain and provide appropriate supporting documentation prevented the determination of the School Corporation's compliance with the compliance requirements listed above. The failure to design and implement an effective system of internal controls enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Activities Allowed or Unallowed and the Allowable Costs/Cost Principles compliance requirements could result in the loss of future federal funds to the School Corporation. Questioned Costs Known questioned costs of $101,352 were identified as detailed in the Condition and Context. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure that documentation will be maintained and made available for audit and comply with the grant agreement and the Activities Allowed or Unallowed and the Allowable Costs/Cost Principles compliance requirements. 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 School Nutrition Programs

Other Findings in this Audit

  • 31070 2022-002
    Material Weakness Repeat
  • 31071 2022-004
    Material Weakness Repeat
  • 31072 2022-003
    Material Weakness
  • 31073 2022-002
    Material Weakness Repeat
  • 31074 2022-003
    Material Weakness
  • 31075 2022-004
    Material Weakness Repeat
  • 31076 2022-002
    Material Weakness Repeat
  • 31077 2022-003
    Material Weakness
  • 31078 2022-004
    Material Weakness Repeat
  • 31079 2022-002
    Material Weakness Repeat
  • 31080 2022-004
    Material Weakness Repeat
  • 31081 2022-003
    Material Weakness
  • 31082 2022-003
    Material Weakness
  • 31083 2022-002
    Material Weakness Repeat
  • 31084 2022-004
    Material Weakness Repeat
  • 31085 2022-002
    Material Weakness Repeat
  • 31086 2022-003
    Material Weakness
  • 31087 2022-004
    Material Weakness Repeat
  • 31088 2022-005
    Material Weakness Repeat
  • 31089 2022-006
    Material Weakness
  • 31090 2022-007
    Material Weakness Repeat
  • 31091 2022-008
    Material Weakness Repeat
  • 31092 2022-005
    Material Weakness Repeat
  • 31093 2022-006
    Material Weakness
  • 31094 2022-007
    Material Weakness Repeat
  • 31095 2022-008
    Material Weakness Repeat
  • 31096 2022-009
    Material Weakness
  • 31097 2022-010
    Material Weakness
  • 31098 2022-011
    Material Weakness
  • 31099 2022-009
    Material Weakness
  • 31100 2022-011
    Material Weakness
  • 31101 2022-010
    Material Weakness
  • 31102 2022-009
    Material Weakness
  • 31103 2022-010
    Material Weakness
  • 31104 2022-009
    Material Weakness
  • 31105 2022-010
    Material Weakness
  • 31106 2022-010
    Material Weakness
  • 31107 2022-009
    Material Weakness
  • 34688 2022-009
    Material Weakness
  • 34689 2022-010
    Material Weakness
  • 34690 2022-009
    Material Weakness
  • 34691 2022-010
    Material Weakness
  • 607512 2022-002
    Material Weakness Repeat
  • 607513 2022-004
    Material Weakness Repeat
  • 607514 2022-003
    Material Weakness
  • 607515 2022-002
    Material Weakness Repeat
  • 607516 2022-003
    Material Weakness
  • 607517 2022-004
    Material Weakness Repeat
  • 607518 2022-002
    Material Weakness Repeat
  • 607519 2022-003
    Material Weakness
  • 607520 2022-004
    Material Weakness Repeat
  • 607521 2022-002
    Material Weakness Repeat
  • 607522 2022-004
    Material Weakness Repeat
  • 607523 2022-003
    Material Weakness
  • 607524 2022-003
    Material Weakness
  • 607526 2022-004
    Material Weakness Repeat
  • 607527 2022-002
    Material Weakness Repeat
  • 607528 2022-003
    Material Weakness
  • 607529 2022-004
    Material Weakness Repeat
  • 607530 2022-005
    Material Weakness Repeat
  • 607531 2022-006
    Material Weakness
  • 607532 2022-007
    Material Weakness Repeat
  • 607533 2022-008
    Material Weakness Repeat
  • 607534 2022-005
    Material Weakness Repeat
  • 607535 2022-006
    Material Weakness
  • 607536 2022-007
    Material Weakness Repeat
  • 607537 2022-008
    Material Weakness Repeat
  • 607538 2022-009
    Material Weakness
  • 607539 2022-010
    Material Weakness
  • 607540 2022-011
    Material Weakness
  • 607541 2022-009
    Material Weakness
  • 607542 2022-011
    Material Weakness
  • 607543 2022-010
    Material Weakness
  • 607544 2022-009
    Material Weakness
  • 607545 2022-010
    Material Weakness
  • 607546 2022-009
    Material Weakness
  • 607547 2022-010
    Material Weakness
  • 607548 2022-010
    Material Weakness
  • 607549 2022-009
    Material Weakness
  • 611130 2022-009
    Material Weakness
  • 611131 2022-010
    Material Weakness
  • 611132 2022-009
    Material Weakness
  • 611133 2022-010
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
84.010 Title I Grants to Local Educational Agencies Fy22 $10.42M
84.010 Title I Grants to Local Educational Agencies Fy21 $8.24M
10.555 National School Lunch Program Fy22 $2.11M
84.027 Special Education_grants to States Fy21 $1.70M
10.553 School Breakfast Program Fy22 $749,089
10.559 Summer Food Service Program for Children Fy21 $619,578
10.559 Summer Food Service Program for Children Fy22 $588,166
84.425 Education Stabilization Fund Fy22 $356,835
10.555 National School Lunch Program Fy21 $326,086
84.048 Career and Technical Education -- Basic Grants to States Fy22 $261,473
84.048 Career and Technical Education -- Basic Grants to States Fy21 $168,962
84.173 Special Education_preschool Grants Fy21 $117,197
84.027 Special Education_grants to States Fy22 $81,313
93.778 Medical Assistance Program Fy22 $78,444
84.173 Special Education_preschool Grants Fy22 $70,071
12.000 Officer Training Corps (jrotc) Fy22 $58,966
12.000 Officer Training Corps (jrotc) Fy21 $56,951
84.196 Education for Homeless Children and Youth Fy22 $49,310
10.558 Child and Adult Care Food Program Fy 22 $41,677
93.778 Medical Assistance Program Fy21 $38,114
84.196 Education for Homeless Children and Youth Fy21 $17,179
84.425 Education Stabilization Fund Fy21 $9,774
10.649 Pandemic Ebt Administrative Costs Fy22 $5,814
84.426 Randolph-Sheppard Financial Relief and Restoration Payments Fy22 $3,937