Finding 964218 (2023-001)

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

AI Summary

  • Core Issue: The School Corporation lacks an effective system of internal controls, leading to repeated noncompliance in eligibility determinations and vendor checks.
  • Impacted Requirements: Compliance with eligibility, procurement, and verification processes under federal programs is not being met, violating 2 CFR 200.303.
  • Recommended Follow-Up: Management should establish a robust internal control system with clear policies and procedures to ensure proper oversight and segregation of duties.

Finding Text

FINDING 2023-001 Subject: Child Nutrition Cluster - Eligibility, Procurement and Suspension and Debarment, Special Tests and Provisions - Verification of Free and Reduced Price Applications (NSLP) Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children, Special Milk Program for Children Assistance Listings Numbers: 10.553, 10.555, 10.559, 10.556 Federal Award Numbers and Years (or Other Identifying Numbers): 2021-22, 2022-23 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Eligibility, Procurement and Suspension and Debarment, Special Tests and Provisions - Verification of Free and Reduced Price Applications (NSLP) Audit Finding: Material Weakness Repeat Finding This is a repeat of Finding 2021-001 from the prior audit report regarding Procurement and Suspension and Debarment. Condition and Context The School Corporation had not properly designed or implemented a system of internal controls that would likely be effective in preventing, or detecting and correcting, noncompliance. Eligibility 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 eligibility determination of a child receiving meals. The Food Service Director reviewed and issued the initial eligibility determination without a system of oversight or review to ensure the eligibility determination was correct. Suspension and Debarment 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 vendor's suspension and debarment status. The Food Service Director verified applicable vendors were not suspended or debarred from participation in federal programs prior to entering into a covered transaction without a system of oversight or review to ensure compliance prior to payment. INDIANA STATE BOARD OF ACCOUNTS 16 SEYMOUR COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Special Tests and Provisions - Verification of Free and Reduced Price Applications (NSLP) 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 verification of free and reduced price applications. There were no established internal controls in place to ensure that applications selected for verification were in compliance with requirements related to the program. The lack of internal controls was a systemic issue 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). . . ." Cause A proper system of internal controls was not designed 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. 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 Procurement, Suspension & Debarment Internal Control / Segregation of Duties Special Tests & Provisions

Other Findings in this Audit

  • 387770 2023-001
    Material Weakness Repeat
  • 387771 2023-001
    Material Weakness Repeat
  • 387772 2023-001
    Material Weakness Repeat
  • 387773 2023-001
    Material Weakness Repeat
  • 387774 2023-001
    Material Weakness Repeat
  • 387775 2023-001
    Material Weakness Repeat
  • 387776 2023-001
    Material Weakness Repeat
  • 387777 2023-001
    Material Weakness Repeat
  • 387778 2023-002
    Material Weakness
  • 387779 2023-002
    Material Weakness
  • 387780 2023-002
    Material Weakness
  • 387781 2023-002
    Material Weakness
  • 387782 2023-002
    Material Weakness
  • 387783 2023-002
    Material Weakness
  • 964212 2023-001
    Material Weakness Repeat
  • 964213 2023-001
    Material Weakness Repeat
  • 964214 2023-001
    Material Weakness Repeat
  • 964215 2023-001
    Material Weakness Repeat
  • 964216 2023-001
    Material Weakness Repeat
  • 964217 2023-001
    Material Weakness Repeat
  • 964219 2023-001
    Material Weakness Repeat
  • 964220 2023-002
    Material Weakness
  • 964221 2023-002
    Material Weakness
  • 964222 2023-002
    Material Weakness
  • 964223 2023-002
    Material Weakness
  • 964224 2023-002
    Material Weakness
  • 964225 2023-002
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
10.555 National School Lunch Program 2023 $3.07M
10.555 National School Lunch Program 2022 $2.95M
84.425 Education Stabilization Fund 2023 $1.06M
84.010 Title I Grants to Local Educational Agencies 2022 $811,398
84.010 Title I Grants to Local Educational Agencies 2023 $674,665
10.553 School Breakfast Program 2023 $574,155
10.553 School Breakfast Program 2022 $532,736
84.425 Education Stabilization Fund 2022 $524,486
16.710 Public Safety Partnership and Community Policing Grants 2023 $349,463
84.367 Improving Teacher Quality State Grants 2022 $244,259
10.559 Summer Food Service Program for Children 2022 $230,761
84.027 Special Education_grants to States 2023 $202,667
84.365 English Language Acquisition State Grants 2023 $189,474
84.365 English Language Acquisition State Grants 2022 $156,139
84.367 Improving Teacher Quality State Grants 2023 $145,752
84.424 Student Support and Academic Enrichment Program 2022 $97,962
10.559 Summer Food Service Program for Children 2023 $59,357
84.424 Student Support and Academic Enrichment Program 2023 $45,011
84.027 Special Education_grants to States 2022 $23,419
84.173 Special Education_preschool Grants 2023 $3,460
10.649 Pandemic Ebt Administrative Costs 2023 $3,135
10.649 Pandemic Ebt Administrative Costs 2022 $3,063
10.556 Special Milk Program for Children 2023 $1,275
84.173 Special Education_preschool Grants 2022 $1,134
10.556 Special Milk Program for Children 2022 $651