Finding 958783 (2023-003)

Material Weakness
Requirement
AB
Questioned Costs
$1
Year
2023
Accepted
2024-03-20
Audit: 296034
Organization: Lake Ridge Schools (IN)

AI Summary

  • Core Issue: The School Corporation lacked a proper internal control system to verify that costs incurred by the food service management company were documented and allowable.
  • Impacted Requirements: Compliance with federal regulations regarding allowable costs and documentation, specifically 2 CFR 200.303 and 7 CFR 210.21(f)(1).
  • Recommended Follow-Up: Implement a robust internal control system to ensure all expenses are properly documented and compliant with federal guidelines before payment.

Finding Text

FINDING 2023-003 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, COVID-19 - National School Lunch Program, Summer Food Service Program for Children, Fresh Fruit and Vegetable Program Assistance Listings Numbers: 10.553, 10.555, 10.559, 10.582 Federal Award Numbers and Years (or Other Identifying Numbers): 2021-2022, 2022-2023 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Findings: Material Weakness, Modified Opinion Condition and Context The School Corporation entered into a cost reimbursement contract with a food service management company (FSMC). The FSMC incurred costs on behalf of the School Corporation and invoiced the School Corporation for reimbursement of those costs. INDIANA STATE BOARD OF ACCOUNTS 19 LAKE RIDGE SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) The School Corporation had not designed or implemented a system of internal controls to ensure that program costs incurred by the FSMC were supported by proper documentation and were allowable prior to payment. Due to the lack of internal controls, the following errors were noted: In a test of 44 transactions, 22 transactions (50%) totaling $6,641 did not have proper documentation to support that the expenses were for the benefit of the food service program and in conformance with the cost principles. 1. Of the 5 transactions totaling $764, were for food and supply purchases paid for by the FSMC and then invoiced to the School Corporation for reimbursement. The vendor invoices supporting these purchases could not be provided for audit. 2. Of the 15 transactions totaling $5,532, were for FSMC employee payroll, fringe benefits, stipends, and other miscellaneous expenses. Proper supporting documentation could not be provided for audit for these transactions. 3. Of the 2 transactions, were determined to be unallowable expenses, as noted below: a. An Amazon purchase of $27 was for decorations that were shipped to a home residence. The FSMC stated the decorations were for a ceremony for the opening of the School Corporation's weight room. b. The FSMC purchased Visa gift cards totaling $318 that were gifted to FSMC staff. The items noted above were all 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 INDIANA STATE BOARD OF ACCOUNTS 20 LAKE RIDGE SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (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 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 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 200.445(a) states: "Costs of goods or services for personal use of the non-Federal entity's employees are unallowable regardless of whether the cost is reported as taxable income to the employees." 2 CFR 200.467 states: "Costs of selling and marketing any products or services of the non-Federal entity (unless allowed under § 200.421) are unallowable, except as direct costs, with prior approval by the Federal awarding agency when necessary for the performance of the Federal award." Cause A proper system of internal controls was not implemented by management of the School Corporation, which would include segregation of key functions. 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 design or implementation of the components of a system of internal controls, including policies and procedures that provide segregation of duties and additional oversight as needed, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, required supporting documentation could be provided to verify costs paid to the FSMC were allowable and in conformance with the cost principles. In addition, unallowable costs were paid. INDIANA STATE BOARD OF ACCOUNTS 21 LAKE RIDGE SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Noncompliance with the grant agreement and the compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs Known questioned costs of $6,641 were identified as explained in the Condition and Context. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure all costs are adequately documented and for the benefit of the food service program. 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 Internal Control / Segregation of Duties

Other Findings in this Audit

  • 382335 2023-003
    Material Weakness
  • 382336 2023-003
    Material Weakness
  • 382337 2023-003
    Material Weakness
  • 382338 2023-003
    Material Weakness
  • 382339 2023-003
    Material Weakness
  • 382340 2023-003
    Material Weakness
  • 382341 2023-003
    Material Weakness
  • 382342 2023-003
    Material Weakness
  • 382343 2023-004
    Material Weakness
  • 382344 2023-004
    Material Weakness
  • 382345 2023-004
    Material Weakness
  • 382346 2023-004
    Material Weakness
  • 382347 2023-004
    Material Weakness
  • 382348 2023-004
    Material Weakness
  • 382349 2023-004
    Material Weakness
  • 382350 2023-004
    Material Weakness
  • 382351 2023-005
    Material Weakness
  • 382352 2023-005
    Material Weakness
  • 382353 2023-006
    Material Weakness Repeat
  • 382354 2023-006
    Material Weakness Repeat
  • 382355 2023-007
    Material Weakness
  • 382356 2023-007
    Material Weakness
  • 382357 2023-008
    Material Weakness
  • 382358 2023-008
    Material Weakness
  • 958777 2023-003
    Material Weakness
  • 958778 2023-003
    Material Weakness
  • 958779 2023-003
    Material Weakness
  • 958780 2023-003
    Material Weakness
  • 958781 2023-003
    Material Weakness
  • 958782 2023-003
    Material Weakness
  • 958784 2023-003
    Material Weakness
  • 958785 2023-004
    Material Weakness
  • 958786 2023-004
    Material Weakness
  • 958787 2023-004
    Material Weakness
  • 958788 2023-004
    Material Weakness
  • 958789 2023-004
    Material Weakness
  • 958790 2023-004
    Material Weakness
  • 958791 2023-004
    Material Weakness
  • 958792 2023-004
    Material Weakness
  • 958793 2023-005
    Material Weakness
  • 958794 2023-005
    Material Weakness
  • 958795 2023-006
    Material Weakness Repeat
  • 958796 2023-006
    Material Weakness Repeat
  • 958797 2023-007
    Material Weakness
  • 958798 2023-007
    Material Weakness
  • 958799 2023-008
    Material Weakness
  • 958800 2023-008
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
84.425 Education Stabilization Fund 2023 $3.99M
84.010 Title I Grants to Local Educational Agencies 2022 $1.24M
84.010 Title I Grants to Local Educational Agencies 2023 $1.13M
10.555 National School Lunch Program 2023 $1.10M
93.600 Head Start 2022 $769,328
93.600 Head Start 2023 $696,692
32.009 Emergency Connectivity Fund Program 2022 $646,000
10.553 School Breakfast Program 2023 $382,625
10.559 Summer Food Service Program for Children 2022 $365,587
10.553 School Breakfast Program 2022 $269,215
84.425 Education Stabilization Fund 2022 $204,600
84.367 Improving Teacher Quality State Grants 2022 $182,775
84.287 Twenty-First Century Community Learning Centers 2023 $175,000
84.367 Improving Teacher Quality State Grants 2023 $137,509
84.424 Student Support and Academic Enrichment Program 2022 $137,103
84.287 Twenty-First Century Community Learning Centers 2022 $81,340
10.558 Child and Adult Care Food Program 2022 $73,832
84.027 Special Education_grants to States 2023 $52,670
32.009 Emergency Connectivity Fund Program 2023 $44,000
84.027 Special Education_grants to States 2022 $39,494
93.778 Medical Assistance Program 2022 $37,522
10.582 Fresh Fruit and Vegetable Program 2023 $21,737
93.778 Medical Assistance Program 2023 $19,177
10.555 National School Lunch Program 2022 $10,254
10.558 Child and Adult Care Food Program 2023 $7,953
84.173 Special Education_preschool Grants 2023 $4,970
10.649 Pandemic Ebt Administrative Costs 2023 $3,135
10.649 Pandemic Ebt Administrative Costs 2022 $3,063
84.173 Special Education_preschool Grants 2022 $2,859
10.559 Summer Food Service Program for Children 2023 $1,770
84.424 Student Support and Academic Enrichment Program 2023 $184