Finding 950728 (2023-002)

Material Weakness
Requirement
N
Questioned Costs
-
Year
2023
Accepted
2024-03-07

AI Summary

  • Core Issue: The School Corporation failed to properly verify and update eligibility statuses for free and reduced price lunch applications, leading to inaccuracies in the system.
  • Impacted Requirements: Compliance with federal regulations (2 CFR 200.303 and 7 CFR 245.6a) regarding verification procedures and internal controls was not met.
  • Recommended Follow-Up: Implement stronger internal controls and training for staff to ensure accurate verification and timely updates of eligibility statuses.

Finding Text

FINDING 2023-002 Subject: Child Nutrition Cluster - Verification of Free and Reduced Price Lunch Applications Federal Agency: Department of Agriculture Federal Program: National School Lunch Program Assistance Listings Number: 10.555 Federal Award Number and Year (or Other Identifying Number): FY2023 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Verification of Free and Reduced Price Lunch Applications (NSLP) Audit Findings: Material Weakness, Other Matters Condition and Context By November 15 of each school year, the Local Educational Agencies (LEA) must verify the current free and reduced price eligibility of households selected from a sample of applications that it has approved for free and reduced price meals, unless the LEA is otherwise exempt from the verification requirement. The verification sample size is based on the total number of approved applications on file on October 1. If the LEA performs the verification function it must be in accordance with instructions provided by the state agency. The LEA must follow up on children whose eligibility status has changed as the result of verification activities to put them in the correct category. As instructed, LEAs must select a sample of applications to be verified utilizing one of the following methods: a. Standard sample size - The lesser of 3 percent or 3,000 of the approved applications on file as of October 1, selected from error-prone applications. For this purpose, error prone applications are those showing household incomes within $100 monthly or $1,200 annually of the income eligibility guidelines for free and reduced price meals. b. Alternative sample sizes - 1) The lesser of 3 percent or 3,000 applications selected at random from approved applications on file as of October 1 of the school year, or (2) The sum of (a) the lesser of 1 percent of all applications identified as error-prone or 1,000 error-prone applications, and (b) the lesser of 1/2 of 1 percent of, or 500, approved applications in which the household provided, in lieu of income information, a case number showing participation in the SNAP, TANF, or FDPIR. In accordance with the above guidance, the School Corporation selected a sample of verifications based on the alternative sample size. As such, the School Corporation was required to review the lesser of three percent or 3,000 applications selected at random from approved applications on file as of October 1 of the 2022-2023 school year. On October 1, the School Corporation had 178 applications on file and determined that 6 applications were required to be verified; however, the School Corporation chose to verify 14 applications. The Food Service Director was responsible for reviewing the applications selected for verification in fiscal year 2022-2023. A second review was performed by the Assistant Food Service Director as indicated on the Verification Collection Report. Of the 14 applications verified by the School Corporation, a sample of 6 applications were selected for testing. The following errors were noted: (1) For two students, 1 application was to have the eligibility status changed from "Free" to "Paid"; however, this change was not updated and made in the School Corporation's system. (2) For five students, 1 application had the eligibility status of "Reduced" in the School Corporation's system as of July 18, 2022, which agreed to the income verification. However, the eligibility status was changed in the School Corporation's system to "Free" as of August 26, 2022. The lack of internal controls and noncompliance was isolated to 2022-2023. 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 245.6a states in part: ". . . (f) Verification procedures and assistance for households – . . . (7) Eligibility changes. Based on the verification activities, the local educational agency shall make appropriate modifications to the eligibility determinations made initially. The local educational agency must notify the household of any change. Households must be notified of any reduction in benefits in accordance with paragraph (j) of this section. Households with reduced benefits or that are longer eligible for free or reduced price meals must be notified of their right to reapply at any time with documentation of income or participation in one of the eligible programs in paragraph (a)(1) of this section. . . . (j) Adverse action. If verification activities fail to confirm eligibility for free or reduced price benefits or should the household fail to cooperate with verification efforts, the school or local educational agency shall reduce or terminate benefits, as applicable, as follows: Ten days advance notification shall be provided to households that are to receive a reduction or termination of benefits, prior to the actual reduction or termination. The first day of the 10 day advance notice period shall be the day the notice is sent. The notice shall advise the household of: (1) The change; (2) The reasons for the change; (3) Notification of the right to appeal and when the appeal must be filed to ensure continued benefits while awaiting a hearing and decision; (4) Instructions on how to appeal; and (5) The right to reapply at any time during the school year. The reasons for ineligibility shall be properly documented and retained on file at the local educational agency." Cause A proper system of internal controls was not designed by management of the School Corporation. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, verifications for free and reduced price applications were not appropriately changed. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure verifications for free and reduced price applications are appropriately changed. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

Categories

School Nutrition Programs Eligibility Material Weakness Special Tests & Provisions Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Other Findings in this Audit

  • 374279 2023-004
    -
  • 374280 2023-005
    Material Weakness
  • 374281 2023-003
    Material Weakness
  • 374282 2023-004
    Material Weakness
  • 374283 2023-005
    Material Weakness
  • 374284 2023-004
    Material Weakness
  • 374285 2023-005
    Material Weakness
  • 374286 2023-002
    Material Weakness
  • 374287 2023-003
    Material Weakness
  • 374288 2023-004
    Material Weakness
  • 374289 2023-005
    Material Weakness
  • 374290 2023-004
    Material Weakness
  • 374291 2023-005
    Material Weakness
  • 374292 2023-003
    Material Weakness
  • 374293 2023-004
    Material Weakness
  • 374294 2023-005
    Material Weakness
  • 374295 2023-006
    Material Weakness
  • 374296 2023-006
    Material Weakness
  • 374297 2023-006
    Material Weakness
  • 950721 2023-004
    -
  • 950722 2023-005
    Material Weakness
  • 950723 2023-003
    Material Weakness
  • 950724 2023-004
    Material Weakness
  • 950725 2023-005
    Material Weakness
  • 950726 2023-004
    Material Weakness
  • 950727 2023-005
    Material Weakness
  • 950729 2023-003
    Material Weakness
  • 950730 2023-004
    Material Weakness
  • 950731 2023-005
    Material Weakness
  • 950732 2023-004
    Material Weakness
  • 950733 2023-005
    Material Weakness
  • 950734 2023-003
    Material Weakness
  • 950735 2023-004
    Material Weakness
  • 950736 2023-005
    Material Weakness
  • 950737 2023-006
    Material Weakness
  • 950738 2023-006
    Material Weakness
  • 950739 2023-006
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
10.555 National School Lunch Program Fy2022 $761,674
10.555 National School Lunch Program Fy2023 $665,512
84.425 Education Stabilization Fund Fy2022 $579,379
84.425 Education Stabilization Fund Fy2023 $433,356
84.010 Title I Grants to Local Educational Agencies Fy2023 $281,847
84.027 Special Education_grants to States Fy2022 $250,932
10.553 School Breakfast Program Fy2022 $174,317
10.553 School Breakfast Program Fy2023 $162,806
32.009 Emergency Connectivity Fund Program Fy2022 $154,090
10.559 Summer Food Service Program for Children Fy2022 $143,956
84.027 Special Education_grants to States Fy2023 $127,270
32.009 Emergency Connectivity Fund Program Fy 2023 $111,076
84.367 Improving Teacher Quality State Grants Fy2023 $49,740
93.778 Medical Assistance Program Fy2022 $38,939
93.778 Medical Assistance Program Fy2023 $35,196
84.010 Title I Grants to Local Educational Agencies Fy2022 $33,878
10.579 Child Nutrition Discretionary Grants Limited Availability Fy2022 $30,000
84.424 Student Support and Academic Enrichment Program Fy2023 $13,049
10.559 Summer Food Service Program for Children Fy2023 $11,114
84.173 Special Education_preschool Grants Fy 2022 $5,426
84.367 Improving Teacher Quality State Grants Fy2022 $4,439
84.173 Special Education_preschool Grants Fy2023 $4,055