Finding 609405 (2022-003)

Material Weakness
Requirement
I
Questioned Costs
-
Year
2022
Accepted
2023-03-27

AI Summary

  • Core Issue: The School Corporation lacked effective internal controls for procurement, leading to noncompliance with federal requirements for purchases over $10,000.
  • Impacted Requirements: Noncompliance with 2 CFR 200.303, 200.318, and 200.320 regarding procurement procedures and internal controls.
  • Recommended Follow-Up: Management should implement a robust internal control system to ensure compliance with grant agreements and procurement regulations.

Finding Text

FINDING 2022-003 Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, COVID-19 - School Breakfast Program, National School Lunch Program, COVID-19 - National School Lunch Program Assistance Listings Numbers: 10.553, 10.555 Federal Award Number and Year (or Other Identifying Number): FY 2020-21 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Other Matters Condition and Context 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 requirement. One of two small purchases tested did not comply. The School Corporation did not obtain price or rate quotes for purchases of milk exceeding $10,000 from an adequate number of sources, which fell under the small purchase procedures. The lack of internal controls and noncompliance was isolated to milk procurements made during fiscal year 2020-2021. 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 18 FRANKLIN COUNTY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 2 CFR 200.318 states in part: "(a) The non-Federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations provided that the procurements conform to applicable Federal law and the standards identified in this part. . . . (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 in part: "The non-Federal entity must use one of the following methods of procurement. . . . (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. . . ." Cause Management had not established a system of internal controls that would have ensured compliance with the Procurement and Suspension and Debarment compliance requirement. Effect The failure to design and implement an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure compliance and comply with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

Categories

Procurement, Suspension & Debarment School Nutrition Programs

Other Findings in this Audit

  • 32962 2022-003
    Material Weakness
  • 32963 2022-003
    Material Weakness
  • 32964 2022-003
    Material Weakness
  • 32965 2022-003
    Material Weakness
  • 32966 2022-002
    Material Weakness
  • 32967 2022-002
    Material Weakness
  • 609404 2022-003
    Material Weakness
  • 609406 2022-003
    Material Weakness
  • 609407 2022-003
    Material Weakness
  • 609408 2022-002
    Material Weakness
  • 609409 2022-002
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
84.027 Special Education_grants to States Fy 21 $725,658
84.027 Special Education_grants to States Fy 22 $601,129
10.553 School Breakfast Program Fy 22 $317,347
84.010 Title I Grants to Local Educational Agencies Fy 21 $290,080
10.555 National School Lunch Program Fy 21 $214,378
84.010 Title I Grants to Local Educational Agencies Fy 22 $188,095
84.425 Education Stabilization Fund Fy 21 $127,688
84.367 Improving Teacher Quality State Grants Fy 21 $62,440
93.778 Medical Assistance Program Fy 21 $51,026
10.555 National School Lunch Program Fy 22 $50,838
84.424 Student Support and Academic Enrichment Program Fy 22 $40,975
93.778 Medical Assistance Program Fy 22 $35,445
84.424 Student Support and Academic Enrichment Program Fy 21 $22,592
10.553 School Breakfast Program Fy 21 $21,954
84.367 Improving Teacher Quality State Grants Fy 22 $21,566
84.425 Education Stabilization Fund Fy 22 $15,322
84.173 Special Education_preschool Grants Fy 21 $11,830
84.173 Special Education_preschool Grants Fy 22 $11,705