Finding 610189 (2022-002)

Material Weakness
Requirement
B
Questioned Costs
-
Year
2022
Accepted
2023-03-07
Audit: 29668
Organization: Clay Community Schools (IN)

AI Summary

  • Core Issue: The School Corporation lacked an effective internal control system, leading to noncompliance with grant requirements for allowable costs.
  • Impacted Requirements: Compliance with 2 CFR 200.303 and 2 CFR 200.403 regarding internal controls and documentation for federal awards.
  • Recommended Follow-Up: Management should implement a robust internal control system to ensure compliance with grant agreements and cost principles.

Finding Text

FINDING 2022-002 Subject: Child Nutrition Cluster - Allowable Costs/Cost Principles 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 Numbers and Years (or Other Identifying Numbers): 2020-2021, 2021-2022 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Allowable Costs/Cost Principles 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 Allowable Costs/Cost Principles compliance requirement. A total of forty food service program disbursements were selected for testing. Fourteen disbursements across four contracted vendors had items purchased that were not charged in accordance with contracted prices. An additional thirteen disbursements, from a single vendor, did not have supporting documentation to determine if the amount charged per the invoices agreed to the initial bid pricing documentation. 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). . . ." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, cost 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. (c) Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-Federal entity. . . . (g) Be adequately documented. . . ." Cause Management had not developed an effective system of internal control that would have ensured compliance with the grant agreement and the Allowable Costs/Cost Principles compliance requirement. Effect The failure to establish an effective internal control system enabled noncompliance to go undetected. Noncompliance with the grant agreement and the 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 an effective system of internal control to ensure compliance and comply with the grant agreement and the Allowable Costs/Cost Principles 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

Allowable Costs / Cost Principles School Nutrition Programs Procurement, Suspension & Debarment

Other Findings in this Audit

  • 33743 2022-002
    Material Weakness
  • 33744 2022-003
    Material Weakness Repeat
  • 33745 2022-002
    Material Weakness
  • 33746 2022-003
    Material Weakness Repeat
  • 33747 2022-002
    Material Weakness
  • 33748 2022-003
    Material Weakness Repeat
  • 33749 2022-002
    Material Weakness
  • 33750 2022-003
    Material Weakness Repeat
  • 33751 2022-002
    Material Weakness
  • 33752 2022-003
    Material Weakness Repeat
  • 33753 2022-002
    Material Weakness
  • 33754 2022-003
    Material Weakness Repeat
  • 33755 2022-005
    Material Weakness
  • 33756 2022-006
    Material Weakness
  • 33757 2022-005
    Material Weakness
  • 33758 2022-006
    Material Weakness
  • 33759 2022-004
    Material Weakness
  • 33760 2022-004
    Material Weakness
  • 33761 2022-004
    Material Weakness
  • 33762 2022-004
    Material Weakness
  • 610185 2022-002
    Material Weakness
  • 610186 2022-003
    Material Weakness Repeat
  • 610187 2022-002
    Material Weakness
  • 610188 2022-003
    Material Weakness Repeat
  • 610190 2022-003
    Material Weakness Repeat
  • 610191 2022-002
    Material Weakness
  • 610192 2022-003
    Material Weakness Repeat
  • 610193 2022-002
    Material Weakness
  • 610194 2022-003
    Material Weakness Repeat
  • 610195 2022-002
    Material Weakness
  • 610196 2022-003
    Material Weakness Repeat
  • 610197 2022-005
    Material Weakness
  • 610198 2022-006
    Material Weakness
  • 610199 2022-005
    Material Weakness
  • 610200 2022-006
    Material Weakness
  • 610201 2022-004
    Material Weakness
  • 610202 2022-004
    Material Weakness
  • 610203 2022-004
    Material Weakness
  • 610204 2022-004
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
10.555 National School Lunch Program 22 $2.21M
84.425 Education Stabilization Fund 22 $1.58M
84.027 Special Education_grants to States 22 $1.15M
84.027 Special Education_grants to States 21 $1.04M
84.010 Title I Grants to Local Educational Agencies 22 $986,073
84.010 Title I Grants to Local Educational Agencies 21 $720,589
84.425 Education Stabilization Fund 21 $643,282
10.553 School Breakfast Program 22 $639,324
10.555 National School Lunch Program 21 $166,704
84.367 Improving Teacher Quality State Grants 22 $163,058
84.367 Improving Teacher Quality State Grants 21 $67,195
10.553 School Breakfast Program 21 $65,630
84.002 Adult Education - Basic Grants to States 21 $64,205
84.002 Adult Education - Basic Grants to States 22 $59,273
84.424 Student Support and Academic Enrichment Program 22 $55,292
84.424 Student Support and Academic Enrichment Program 21 $50,703
84.173 Special Education_preschool Grants 21 $41,011
84.173 Special Education_preschool Grants 22 $34,737
84.048 Career and Technical Education -- Basic Grants to States 21 $27,459
84.048 Career and Technical Education -- Basic Grants to States 22 $21,633
21.019 Coronavirus Relief Fund 21 $2,006
96.001 Social Security_disability Insurance 22 $546
96.001 Social Security_disability Insurance 21 $154