Finding 963297 (2023-004)

Material Weakness Repeat Finding
Requirement
E
Questioned Costs
-
Year
2023
Accepted
2024-03-28

AI Summary

  • Core Issue: The School Corporation lacks a proper system of internal controls for eligibility determinations in child nutrition programs, leading to a repeat finding of material weakness.
  • Impacted Requirements: Compliance with 2 CFR 200.303 is not met, as there is insufficient oversight and segregation of duties in managing federal awards.
  • Recommended Follow-Up: Management should establish and implement effective internal controls, including clear policies and procedures, to ensure proper reviews and oversight of eligibility determinations.

Finding Text

FINDING 2023-004 Subject: Child Nutrition Cluster - Eligibility Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children Assistance Listings Numbers: 10.553, 10.555, 10.559 Federal Award Number and Year (or Other Identifying Number): FY2022-2023 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Finding: Material Weakness Repeat Finding This is a repeat finding from the prior audit. The prior audit finding number was 2021-004. Condition and Context 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 a child receiving meals that was a direct certified or that submitted an electronic application. Any child enrolled in a participating school who meets the applicable program's definition of "child," may receive meals under the applicable program. In the case of the National School Lunch Program and the School Breakfast Program, children belonging to households meeting nationwide income eligibility requirements may receive meals at no charge or at reduced price. Children who have been determined ineligible for free or reduced-price school meals pay the full price, set by the School Food Authority, for their meals. Children attending SFSP meal service sites receive their meals at no charge. As a general rule, a child's eligibility for free or reduced-price meals under a Child Nutrition Cluster program may be established by the submission of an annual application or statement which furnishes such information as family income and family size. Local educational agencies, institutions, and sponsors then determine eligibility by comparing the data reported by the child's household to published income eligibility guidelines. Additionally, a child may be direct certified. For a direct certification, annual eligibility determinations are based on the child's household receiving benefits under SNAP, FDPIR, the Head Start Program (ALN 93.600), or, under most circumstances, the TANF program (ALN 93.558). A household may furnish documentation of its participation in one of these programs; or the school, institution, or sponsor may obtain the information directly from the State or local agency that administers these programs. Certain foster, runaway, homeless, and migrant children are categorically eligible for free school lunches and breakfasts. Direct certified households do not need to complete an application. The Food Service Director ran the direct certification report weekly and uploaded it to the school lunch point-of-sale system. The Food Service Director verified the information was imported correctly by comparing reports from the point-of-sale system to the upload file. This process continued weekly; however, there was no documentation of the review to ensure the upload had imported correctly and students' status was updated accordingly. In addition, the School Corporation used a food software program to store, manage, and automatically make eligibility determinations dependent upon the information entered into the software by the parents, guardians, or school lunch employees. The School Corporation did not have a proper system of oversight or review to ensure that the federal income guidelines entered into the software program were accurate for fiscal year 2022-2023. The lack of internal controls was isolated to direct certifications and electronic applications during the 2022-2023 school year. 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). . . ." 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. Questioned Costs There were no questioned costs identified. 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. 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 Internal Control / Segregation of Duties Eligibility Matching / Level of Effort / Earmarking Material Weakness

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
  • 963290 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
  • 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