Finding 610677 (2022-003)

Material Weakness
Requirement
ABN
Questioned Costs
$1
Year
2022
Accepted
2023-03-08

AI Summary

  • Core Issue: The School Corporation lacked effective internal controls, leading to a material weakness in compliance with federal grant requirements.
  • Impacted Requirements: Noncompliance with 2 CFR 200.303 and 2 CFR 200.452 regarding allowable costs and internal controls for federal awards.
  • Recommended Follow-Up: Implement stronger internal controls and ensure prior written approval for any future fund transfers related to capital expenditures.

Finding Text

FINDING 2022-003 Subject: Child Nutrition Cluster - Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Special Tests and Provisions - School Food Accounts 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, 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): FY 20-21, FY 21-22 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Special Tests and Provisions - School Food Accounts Audit Findings: Material Weakness, Modified Opinion 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 Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Special Tests and Provisions - School Food Accounts compliance requirements. During the audit period, the School Corporation made one transfer from the Foodservice fund (School Lunch fund). The transfer was related to a completed remodeling project on the cafeteria and kitchen at the middle school. Expenses for the remodeling project were initially paid from Fund 160 (Operating). However, on April 30, 2022, the School Corporation made a transfer in the amount of $300,000 from Fund 800 (School Lunch) to Fund 160 to cover a portion of the remodeling project expenses. Based on inquiry of the School Corporation, the original intent was for the project to paid jointly from the School Lunch fund and the Operating fund, with the School Lunch fund covering only equipment related expenditures. Documentation could not be provided to support this understanding, nor to show permission from the grantor agency, as required, to pay for a remodeling project from School Lunch funds. While price quotes for the equipment were provided, no additional supporting documentation, including invoices, of the expenditures paid could be provided. The above noted transfer was considered a questioned cost. The lack of internal controls and noncompliance were isolated to the transfer of funds described above. 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 20 BEECH GROVE CITY SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 2 CFR 200.452 states: "Costs incurred for utilities, insurance, security, necessary maintenance, janitorial services, repair, or upkeep of buildings and equipment (including Federal property unless otherwise provided for) which neither add to the permanent value of the property nor appreciably prolong its intended life, but keep it in an efficient operating condition, are allowable. Costs incurred for improvements which add to the permanent value of the buildings and equipment or appreciably prolong their intended life must be treated as capital expenditures (see ? 200.439). These costs are only allowable to the extent not paid through rental or other agreements." 2 CFR 200.407 states in part: "Under any given Federal award, the reasonableness and allocability of certain items of costs may be difficult to determine. In order to avoid subsequent disallowance or dispute based on unreasonableness or non-allocability, the non-Federal entity may seek the prior written approval of the cognizant agency for indirect costs or the Federal awarding agency in advance of the incurrence of special or unusual costs. Prior written approval should include the timeframe or scope of the agreement. The absence of prior written approval on any element of cost will not, in itself, affect the reasonableness or allocability of that element, unless prior approval is specifically required for allowability as described under certain circumstances in the following sections of this part: . . . (l) ? 200.439 Equipment and other capital expenditures; . . ." 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. Expenditures of nonprofit school food service revenues shall be in accordance with the financial management system established by the State agency under ? 210.19(a) of this part. . . ." The USDA Food and Nutrition Service Guidance for State Agencies & School Food Authorities, page 16, states in part: ". . . Renovating a School Kitchen 2 CFR 200.452 (see below), Maintenance and repair costs, identifies costs of normal repairs and alterations as allowable so long as they: (1) keep property in an efficient operating condition; (2) do not add to the permanent value of the property or appreciably prolong its intended life; and (3) are not otherwise included in rental or other agreements. Based on these principles, FNS has allowed limited renovations within the inside perimeter of a kitchen/cafeteria space with the required prior State agency approval (2 CFR 200.407 or FNS approval (7 CFR 210.14(a)) . . ." Cause Management had not developed a system of internal control that would have ensured compliance with the grant agreement and the Activities Allowed or Unallowed, the Allowable Costs/Cost Principles, and the Special Tests and Provisions - School Food Accounts compliance requirements. INDIANA STATE BOARD OF ACCOUNTS 21 BEECH GROVE CITY SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Effect The failure to establish an effective internal control system enabled noncompliance to go undetected. Noncompliance with the grant agreement and the Activities Allowed or Unallowed, the Allowable Costs/Cost Principles, and the Special Tests and Provisions - School Food Accounts compliance requirements could result in the loss of future federal funds to the School Corporation. Questioned Costs Questioned costs were identified in the amount of $300,000 as described in the Condition and Context. Recommendation We recommended that the School Corporation's management establish a system of internal control to ensure compliance and comply with the grant agreement and the Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Special Tests and Provisions - School Food Accounts 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 School Nutrition Programs Allowable Costs / Cost Principles Procurement, Suspension & Debarment Special Tests & Provisions

Other Findings in this Audit

  • 34228 2022-003
    Material Weakness
  • 34229 2022-003
    Material Weakness
  • 34230 2022-003
    Material Weakness
  • 34231 2022-003
    Material Weakness
  • 34232 2022-003
    Material Weakness
  • 34233 2022-003
    Material Weakness
  • 34234 2022-003
    Material Weakness
  • 34235 2022-003
    Material Weakness
  • 34236 2022-004
    Material Weakness Repeat
  • 34237 2022-005
    Material Weakness
  • 34238 2022-004
    Material Weakness Repeat
  • 34239 2022-005
    Material Weakness
  • 34240 2022-006
    Material Weakness
  • 34241 2022-007
    Material Weakness
  • 34242 2022-008
    Material Weakness
  • 34243 2022-006
    Material Weakness
  • 34244 2022-007
    Material Weakness
  • 34245 2022-008
    Material Weakness
  • 34246 2022-006
    Material Weakness
  • 34247 2022-007
    Material Weakness
  • 34248 2022-008
    Material Weakness
  • 34249 2022-007
    Material Weakness
  • 34250 2022-008
    Material Weakness
  • 610670 2022-003
    Material Weakness
  • 610671 2022-003
    Material Weakness
  • 610672 2022-003
    Material Weakness
  • 610673 2022-003
    Material Weakness
  • 610674 2022-003
    Material Weakness
  • 610675 2022-003
    Material Weakness
  • 610676 2022-003
    Material Weakness
  • 610678 2022-004
    Material Weakness Repeat
  • 610679 2022-005
    Material Weakness
  • 610680 2022-004
    Material Weakness Repeat
  • 610681 2022-005
    Material Weakness
  • 610682 2022-006
    Material Weakness
  • 610683 2022-007
    Material Weakness
  • 610684 2022-008
    Material Weakness
  • 610685 2022-006
    Material Weakness
  • 610686 2022-007
    Material Weakness
  • 610687 2022-008
    Material Weakness
  • 610688 2022-006
    Material Weakness
  • 610689 2022-007
    Material Weakness
  • 610690 2022-008
    Material Weakness
  • 610691 2022-007
    Material Weakness
  • 610692 2022-008
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
84.425 Education Stabilization Fund Fy 22 $2.72M
10.555 National School Lunch Program Fy 22 $1.85M
84.010 Title I Grants to Local Educational Agencies Fy 21 $728,135
84.010 Title I Grants to Local Educational Agencies Fy 22 $626,486
84.027 Special Education_grants to States Fy 21 $520,011
84.425 Education Stabilization Fund Fy 21 $333,300
10.559 Summer Food Service Program for Children Fy 21 $236,104
10.558 Child and Adult Care Food Program Fy 21 $188,954
84.374 Teacher Incentive Fund Fy 22 $144,211
93.778 Medical Assistance Program Fy 21 $142,935
84.367 Improving Teacher Quality State Grants Fy 22 $138,587
84.367 Improving Teacher Quality State Grants Fy 21 $130,729
84.424 Student Support and Academic Enrichment Program Fy 21 $118,828
93.778 Medical Assistance Program Fy 22 $116,533
10.558 Child and Adult Care Food Program Fy 22 $108,047
84.424 Student Support and Academic Enrichment Program Fy 22 $88,933
10.559 Summer Food Service Program for Children Fy 22 $42,218
10.555 National School Lunch Program Fy 21 $40,861
84.365 English Language Acquisition State Grants Fy 21 $32,039
10.553 School Breakfast Program Fy 21 $19,201
10.553 School Breakfast Program Fy 22 $19,006
84.173 Special Education_preschool Grantsb Fy 22 $18,430
84.365 English Language Acquisition State Grants Fy 22 $13,244
93.575 Child Care and Development Block Grant Fy 22 $3,846
10.649 Pandemic Ebt Administrative Costs Fy 22 $3,063
84.027 Special Education_grants to States Fy 22 $2,557
84.173 Special Education_preschool Grants Fy 21 $1,430