EIN: 351074060
UEI: GA47Z2RJ7XF7
Audited by: CROWE LLP
Oversight agency: 10 [Department of Agriculture]
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Data as of September 7, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on January 21, 2025. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by July 21, 2025 (414 days ago).
What is a management decision? →FAC accepted this audit on March 28, 2023 — management decision was due September 28, 2023.
FAC accepted this audit on July 13, 2021 — management decision was due January 13, 2022.
FINDING 2020-001Subject: Child Nutrition Cluster - Allowable Costs/Cost Principles, Program IncomeFederal Agency: Department of AgricultureFederal Programs: School Breakfast Program, COVID-19 - School Breakfast Program, National SchoolLunch Program, COVID-19 - National School Lunch Program, Special Milk Programfor Children, COVID-19 - Special Milk Program for ChildrenCFDA Numbers: 10.553, 10.555, 10.556Federal Award Numbers and Years (or Other Identifying Numbers): FY2019, FY2020Pass-Through Entity: Indiana Department of EducationCompliance Requirements: Allowable Costs/Cost Principles, Program IncomeAudit Findings: Material Weakness, Other MattersCondition and ContextAn effective internal control system was not in place at the School Corporation to ensure compliancewith requirements related to the grant agreement and the Allowable Costs/Cost Principles andProgram Income compliance requirements.One employee of the School Corporation, paid from the School Lunch fund, did not have adequatesupporting documentation for the time spent on grant activities. The amount charged to the grant,$16,094.60, is considered a questioned cost.The lack of internal controls and noncompliance were systemic issues throughout the audit period.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.403 states in part:"Except where otherwise authorized by statute, costs must meet the following general criteriain order to be allowable under Federal awards:(a) Be necessary and reasonable for the performance of the Federal award and be allocablethereto under these principles.(b) Conform to any limitations or exclusions set forth in these principles or in the Federalaward as to types or amount of cost items. . . .(g) Be adequately documented. . . ."2 CFR 200.430(i) states in part:"Standards for Documentation of Personnel Expenses (1) Charges to Federal awards forsalaries and wages must be based on records that accurately reflect the work performed.These records must:(i) Be supported by a system of internal control which provides reasonable assurancethat the charges are accurate, allowable, and properly allocated;(ii) Be incorporated into the official records of the non-Federal entity;(iii) Reasonably reflect the total activity for which the employee is compensated by thenon-Federal entity, not exceeding 100% of compensated activities (for IHE, this per theIHE's definition of IBS); . . .(vii) Support the distribution of the employee's salary or wages among specific activitiesor cost objectives if the employee works on more than one Federal award; a Federal awardand non-Federal award; an indirect cost activity and a direct cost activity; two or moreindirect activities which are allocated using different allocation bases; or an unallowableactivity and a direct or indirect cost activity. . . ."2 CFR 200.307(e)(2) states in part: "Addition. With prior approval of the Federal awarding agency. . . program income may be added to the Federal award by the Federal agency and the non-Federal entity.The program income must be used for the purposes and under the conditions of the Federal award."CauseManagement had not established a system of internal controls that would have ensured compliancewith the grant agreement and the Allowable Costs/Cost Principles and Program Income compliance requirements.EffectThe failure to maintain and provide adequate supporting documentation prevented the SchoolCorporation's compliance with the Allowable Costs/Cost Principles and Program Income compliancerequirements.Questioned CostsKnown questioned costs in the amount of $16,094.60 were identified, as detailed in the Conditionand Context.RecommendationWe recommended that the School Corporation's management establish a system of internal controlsand maintain adequate supporting documentation to ensure compliance with the grant agreement andthe Allowable Costs/Cost Principles and Program Income compliance requirements.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Show full finding ▾Hide full finding ▴FINDING 2020-001Subject: Child Nutrition Cluster - Allowable Costs/Cost Principles, Program IncomeFederal Agency: Department of AgricultureFederal Programs: School Breakfast Program, COVID-19 - School Breakfast Program, National SchoolLunch Program, COVID-19 - National School Lunch Program, Special Milk Programfor Children, COVID-19 - Special Milk Program for ChildrenCFDA Numbers: 10.553, 10.555, 10.556Federal Award Numbers and Years (or Other Identifying Numbers): FY2019, FY2020Pass-Through Entity: Indiana Department of EducationCompliance Requirements: Allowable Costs/Cost Principles, Program IncomeAudit Findings: Material Weakness, Other MattersCondition and ContextAn effective internal control system was not in place at the School Corporation to ensure compliancewith requirements related to the grant agreement and the Allowable Costs/Cost Principles andProgram Income compliance requirements.One employee of the School Corporation, paid from the School Lunch fund, did not have adequatesupporting documentation for the time spent on grant activities. The amount charged to the grant,$16,094.60, is considered a questioned cost.The lack of internal controls and noncompliance were systemic issues throughout the audit period.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.403 states in part:"Except where otherwise authorized by statute, costs must meet the following general criteriain order to be allowable under Federal awards:(a) Be necessary and reasonable for the performance of the Federal award and be allocablethereto under these principles.(b) Conform to any limitations or exclusions set forth in these principles or in the Federalaward as to types or amount of cost items. . . .(g) Be adequately documented. . . ."2 CFR 200.430(i) states in part:"Standards for Documentation of Personnel Expenses (1) Charges to Federal awards forsalaries and wages must be based on records that accurately reflect the work performed.These records must:(i) Be supported by a system of internal control which provides reasonable assurancethat the charges are accurate, allowable, and properly allocated;(ii) Be incorporated into the official records of the non-Federal entity;(iii) Reasonably reflect the total activity for which the employee is compensated by thenon-Federal entity, not exceeding 100% of compensated activities (for IHE, this per theIHE's definition of IBS); . . .(vii) Support the distribution of the employee's salary or wages among specific activitiesor cost objectives if the employee works on more than one Federal award; a Federal awardand non-Federal award; an indirect cost activity and a direct cost activity; two or moreindirect activities which are allocated using different allocation bases; or an unallowableactivity and a direct or indirect cost activity. . . ."2 CFR 200.307(e)(2) states in part: "Addition. With prior approval of the Federal awarding agency. . . program income may be added to the Federal award by the Federal agency and the non-Federal entity.The program income must be used for the purposes and under the conditions of the Federal award."CauseManagement had not established a system of internal controls that would have ensured compliancewith the grant agreement and the Allowable Costs/Cost Principles and Program Income compliance requirements.EffectThe failure to maintain and provide adequate supporting documentation prevented the SchoolCorporation's compliance with the Allowable Costs/Cost Principles and Program Income compliancerequirements.Questioned CostsKnown questioned costs in the amount of $16,094.60 were identified, as detailed in the Conditionand Context.RecommendationWe recommended that the School Corporation's management establish a system of internal controlsand maintain adequate supporting documentation to ensure compliance with the grant agreement andthe Allowable Costs/Cost Principles and Program Income compliance requirements.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
CORRECTIVE ACTION PLANFINDING 2020-001 (Auditor Assigned Reference Number)Contact Person Responsible for Corrective Action: Sheila GlassContact Phone Number: 317-544-6041Views of Responsible Official: We concur with the finding. We self-identified thequestioned cost in 2021 and have decided to pay the lone employee through fundsother than the School Lunch fund as of May 2021.Description of Corrective Action Plan:Beginning in May 2021, ACSC recognized the need to complete Time and Effort logsfor one employee being paid $16,090.60 from the School Lunch grant. Although theemployee plans weekly with the Director of Food Services, and therefore is eligible tobe paid from the fund, ACSC has decided not to use the fund for a portion of theemployee?s salary.Anticipated Completion Date:This finding will be corrected June 2021.Michael D. Sullivan, Ed.DAssistant SuperintendentAvon Community School Corporation
FINDING 2020-002Subject: Child Nutrition Cluster - Eligibility, Suspension and Debarment, Program IncomeFederal Agency: Department of AgricultureFederal Programs: School Breakfast Program, COVID-19 - School Breakfast Program, National SchoolLunch Program, COVID-19 - National School Lunch Program, Special Milk Programfor Children, COVID-19 - Special Milk Program for ChildrenCFDA Numbers: 10.553, 10.555, 10.556Federal Award Numbers and Years (or Other Identifying Numbers): FY2019, FY2020Pass-Through Entity: Indiana Department of EducationCompliance Requirements: Eligibility, Procurement and Suspension and Debarment, Program IncomeAudit Finding: Material WeaknessCondition and ContextAn effective internal control system was not in place at the School Corporation to ensure compliancewith requirements related to the grant agreement and the Eligibility, Procurement and Suspensionand Debarment, and Program Income compliance requirements.EligibilityThe School Corporation used a food service software, which automatically made eligibilitydeterminations dependent upon the information entered in the software by the students' parentsor guardians. However, the School Corporation did not have a proper system of oversightor review to ensure that the federal income guidelines entered into the software were accurate.Additionally, the direct certification reports were uploaded into the food service software withouta proper system of oversight or review to ensure that all students on the direct certificationreports were entered accurately in the system.Suspension and DebarmentOne employee verified that vendors were not suspended or debarred from participation in federalprograms without a proper system of oversight or review.Program IncomeThe School Corporation had not designed or implemented adequate policies and proceduresto ensure that program income was assessed properly. Food prices for each school year wereentered into the student lunch system without a proper system of oversight or review.The lack of internal controls was a systemic issue throughout the audit period.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."CauseManagement had not developed or implemented a system of internal controls that would haveensured compliance with the grant agreement and the Eligibility, Procurement and Suspension andDebarment, and Program Income compliance requirements.EffectThe failure to establish an internal control system placed the School Corporation at risk of noncompliancewith the grant agreement and the Eligibility, Procurement and Suspension and Debarment, andProgram Income compliance requirements. A lack of segregation of duties within an internal control systemcould have also allowed noncompliance with the compliance requirements listed above and allowed themisuse and mismanagement of federal funds and assets by not having proper oversight, reviews, andapprovals over the activities of the programs.Questioned CostsThere were no questioned costs identified.RecommendationWe recommend that the School Corporation's management establish a system of internal controlsto ensure compliance with the grant agreement and the Eligibility, Procurement and Suspension andDebarment, and Program Income compliance requirements.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Show full finding ▾Hide full finding ▴FINDING 2020-002Subject: Child Nutrition Cluster - Eligibility, Suspension and Debarment, Program IncomeFederal Agency: Department of AgricultureFederal Programs: School Breakfast Program, COVID-19 - School Breakfast Program, National SchoolLunch Program, COVID-19 - National School Lunch Program, Special Milk Programfor Children, COVID-19 - Special Milk Program for ChildrenCFDA Numbers: 10.553, 10.555, 10.556Federal Award Numbers and Years (or Other Identifying Numbers): FY2019, FY2020Pass-Through Entity: Indiana Department of EducationCompliance Requirements: Eligibility, Procurement and Suspension and Debarment, Program IncomeAudit Finding: Material WeaknessCondition and ContextAn effective internal control system was not in place at the School Corporation to ensure compliancewith requirements related to the grant agreement and the Eligibility, Procurement and Suspensionand Debarment, and Program Income compliance requirements.EligibilityThe School Corporation used a food service software, which automatically made eligibilitydeterminations dependent upon the information entered in the software by the students' parentsor guardians. However, the School Corporation did not have a proper system of oversightor review to ensure that the federal income guidelines entered into the software were accurate.Additionally, the direct certification reports were uploaded into the food service software withouta proper system of oversight or review to ensure that all students on the direct certificationreports were entered accurately in the system.Suspension and DebarmentOne employee verified that vendors were not suspended or debarred from participation in federalprograms without a proper system of oversight or review.Program IncomeThe School Corporation had not designed or implemented adequate policies and proceduresto ensure that program income was assessed properly. Food prices for each school year wereentered into the student lunch system without a proper system of oversight or review.The lack of internal controls was a systemic issue throughout the audit period.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."CauseManagement had not developed or implemented a system of internal controls that would haveensured compliance with the grant agreement and the Eligibility, Procurement and Suspension andDebarment, and Program Income compliance requirements.EffectThe failure to establish an internal control system placed the School Corporation at risk of noncompliancewith the grant agreement and the Eligibility, Procurement and Suspension and Debarment, andProgram Income compliance requirements. A lack of segregation of duties within an internal control systemcould have also allowed noncompliance with the compliance requirements listed above and allowed themisuse and mismanagement of federal funds and assets by not having proper oversight, reviews, andapprovals over the activities of the programs.Questioned CostsThere were no questioned costs identified.RecommendationWe recommend that the School Corporation's management establish a system of internal controlsto ensure compliance with the grant agreement and the Eligibility, Procurement and Suspension andDebarment, and Program Income compliance requirements.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
CORRECTIVE ACTION PLANFINDING 2020-002 (Auditor assigned Reference Number)Contact Person Responsible for Corrective Action: Sheila Glass and Emily CatesContact Phone Number: 317-544-6041Views of Responsible Official: We concur with the finding. We were notified of the issuein May 2021 and will correct it as of June 2021.Description of Corrective Action Plan:1. Eligibility ? Income guidelines were checked and were correct in the Point ofSale lunch system. However, we did not have a paper trail to prove they werechecked. Going forward, we will screen shot the guidelines and print it withtwo signatures. The Direct Certification rosters were downloaded from IDOE,uploaded into lunch system and filed but did not have a secondreview/signature. We have addressed that and will have a second personcheck and sign off.2. Suspension and debarment checks were completed for vendors that wespend $25,000+ with. However, the one that they pulled to check was avendor that was not in the system so we did not have a print out for thatparticular vendor but did have copies for other vendors. (Some vendors donot register with SAM.) Auditor instructed us that best practice going forwardis to print out the no results screen and file that. He also suggested all printouts contain two signatures. We have already implemented this process for20/21 SY.3. Program Income ? Meal prices were entered into lunch system by us andwere correct. However, we also did not have a paper trail for this (same asEligibility). Going forward, we will screen shot meal prices in lunch system andhave two signatures.Anticipated Completion Date:This finding will be corrected as of June 2021Michael D. Sullivan, Ed.DAssistant SuperintendentAvon Community School Corporation
FAC accepted this audit on April 21, 2019 — management decision was due October 21, 2019.
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2016-003
FAC accepted this audit on October 24, 2018 — management decision was due April 24, 2019.
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