Finding 963290 (2023-003)

Material Weakness Repeat Finding
Requirement
ABN
Questioned Costs
$1
Year
2023
Accepted
2024-03-28

AI Summary

  • Core Issue: The School Corporation lacks effective internal controls over payroll and food service revenues, leading to noncompliance and questioned costs.
  • Impacted Requirements: Violations of federal regulations regarding allowable costs and the operation of non-profit school food services.
  • Recommended Follow-Up: Implement a robust system of internal controls, including segregation of duties, to ensure compliance and accurate financial reporting.

Finding Text

FINDING 2023-003 Subject: Child Nutrition Cluster - Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Special Tests and Provisions - Non-Profit School Food Service Accounts 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 Assistance Listings Numbers: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY2021-2022, FY2022-2023 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Special Tests and Provisions - Non-Profit School Food Service Accounts Audit Findings: Material Weakness, Modified Opinion Repeat Finding This is a repeat finding from the prior audit report for the Allowable Costs/Cost Principles. The prior audit finding number was 2021-003. Condition and Context Food Service - Expenditures The School Corporation had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance related to the payroll and payroll benefit costs charged to the grant. The School Corporation's process was to charge food service payroll and related benefits to a Foodservice Payroll fund, and then transfer funds from the Foodservice (School Lunch) fund to reimburse the Foodservice Payroll fund the following month. The amounts transferred from the School Lunch fund to the Foodservice Payroll fund did not always agree to the actual payroll paid. Six of the eleven transfers made during the audit period did not agree to actual payroll paid. This resulted in $144,679, in excess of actual payroll paid, being transferred from the School Lunch fund to the Foodservice Payroll fund. The transfers that were not properly supported were considered questioned costs. Food Service - Revenues The School Corporation had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance related to food service revenues being accounted for in the School Food Account. A School Food Authority (SFA) is required to account for all revenues and expenditures of its non-profit school food service in accordance with state and federal requirements. A SFA must operate its food services on a non-profit basis; all revenue generated by the school food service must be used to operate and improve its food services. The School Corporation's process was to receipt the School Lunch reimbursement received into a Federal Reimbursement fund and then transfer that reimbursement to the School Lunch fund the following month. One individual receipted the monthly reimbursement into the School Lunch fund, there was no documentation that an oversight or review process had been established to ensure the receipt was posted accurately. The April 2022 reimbursement of $158,679 was receipted into the Food Service Federal Reimbursement fund on July 7, 2022. The reimbursement had not been transferred to the School Lunch fund, which is the designated school food service fund, as of June 30, 2023. 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 220.7(e) states in part: ". . . the School Food Authority shall, with respect to participating schools under its jurisdiction: . . . (1) (i) Maintain a nonprofit school food service; (ii) . . . use all revenues received by such food service only for the operation or improvement of that food service . . ." 7 CFR 210.14(a) states in part: "(a) 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. . . ." 7 CFR 220.2 states in part: ". . . Nonprofit school food service account means the restricted account in which all of the revenue from all food service operations conducted by the school food authority principally for the benefit of school children is retained and used only for the operation or improvement of the nonprofit school food service. . . ." 7 CFR 210.2 states in part: ". . . Nonprofit school food service account means the restricted account in which all of the revenue from all food service operations conducted by the sponsor principally for the benefit of children is retained and used only for the operation or improvement of the nonprofit food service. This account shall include, as appropriate, non-Federal funds used to support paid lunches as provided in § 210.14(e), and proceeds from non-program foods . . ." 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. . . ." 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 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, unsupported costs were transferred out of the Foodservice fund and reimbursements were not timely receipted into the fund. 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 $144,679 were identified as explained in the Condition and Context. Recommendation We recommended that management of the School Corporation design and implement a proper system of internal controls, including policies and procedures that would provide segregation of duties to ensure appropriate reviews, approvals, and oversight are taking place to ensure costs transferred out are adequately documented and that reimbursements are timely receipted. 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

  • 386846 2023-003
    Material Weakness Repeat
  • 386847 2023-003
    Material Weakness Repeat
  • 386848 2023-003
    Material Weakness Repeat
  • 386849 2023-003
    Material Weakness Repeat
  • 386850 2023-003
    Material Weakness Repeat
  • 386851 2023-003
    Material Weakness Repeat
  • 386852 2023-003
    Material Weakness Repeat
  • 386853 2023-004
    Material Weakness Repeat
  • 386854 2023-004
    Material Weakness Repeat
  • 386855 2023-004
    Material Weakness Repeat
  • 386856 2023-005
    Material Weakness Repeat
  • 386857 2023-005
    Material Weakness Repeat
  • 386858 2023-005
    Material Weakness Repeat
  • 386859 2023-005
    Material Weakness Repeat
  • 386860 2023-005
    Material Weakness Repeat
  • 386861 2023-005
    Material Weakness Repeat
  • 386862 2023-005
    Material Weakness Repeat
  • 386863 2023-006
    Material Weakness
  • 386864 2023-006
    Material Weakness
  • 386865 2023-007
    Material Weakness
  • 386866 2023-007
    Material Weakness
  • 386867 2023-008
    Material Weakness
  • 386868 2023-008
    Material Weakness
  • 386869 2023-009
    Material Weakness
  • 386870 2023-009
    Material Weakness
  • 386871 2023-009
    Material Weakness
  • 386872 2023-010
    Material Weakness
  • 386873 2023-010
    Material Weakness
  • 963288 2023-003
    Material Weakness Repeat
  • 963289 2023-003
    Material Weakness Repeat
  • 963291 2023-003
    Material Weakness Repeat
  • 963292 2023-003
    Material Weakness Repeat
  • 963293 2023-003
    Material Weakness Repeat
  • 963294 2023-003
    Material Weakness Repeat
  • 963295 2023-004
    Material Weakness Repeat
  • 963296 2023-004
    Material Weakness Repeat
  • 963297 2023-004
    Material Weakness Repeat
  • 963298 2023-005
    Material Weakness Repeat
  • 963299 2023-005
    Material Weakness Repeat
  • 963300 2023-005
    Material Weakness Repeat
  • 963301 2023-005
    Material Weakness Repeat
  • 963302 2023-005
    Material Weakness Repeat
  • 963303 2023-005
    Material Weakness Repeat
  • 963304 2023-005
    Material Weakness Repeat
  • 963305 2023-006
    Material Weakness
  • 963306 2023-006
    Material Weakness
  • 963307 2023-007
    Material Weakness
  • 963308 2023-007
    Material Weakness
  • 963309 2023-008
    Material Weakness
  • 963310 2023-008
    Material Weakness
  • 963311 2023-009
    Material Weakness
  • 963312 2023-009
    Material Weakness
  • 963313 2023-009
    Material Weakness
  • 963314 2023-010
    Material Weakness
  • 963315 2023-010
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
84.425 Education Stabilization Fund 2023 $1.41M
10.555 National School Lunch Program 2023 $1.06M
84.010 Title I Grants to Local Educational Agencies 2023 $615,259
84.027 Special Education_grants to States 2022 $526,339
10.559 Summer Food Service Program for Children 2022 $446,118
84.010 Title I Grants to Local Educational Agencies 2022 $294,989
10.553 School Breakfast Program 2023 $187,522
10.553 School Breakfast Program 2022 $164,094
84.425 Education Stabilization Fund 2022 $150,429
93.778 Medical Assistance Program 2023 $83,079
84.367 Improving Teacher Quality State Grants 2023 $80,515
10.555 National School Lunch Program 2022 $65,379
93.778 Medical Assistance Program 2022 $43,079
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) 2023 $40,426
10.559 Summer Food Service Program for Children 2023 $40,338
84.424 Student Support and Academic Enrichment Program 2023 $22,199
10.649 Pandemic Ebt Administrative Costs 2022 $3,063
10.649 Pandemic Ebt Administrative Costs 2023 $628