Tri-Central Community Schools

Information on the federal program: Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY2023, FY2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Finding: Material Weakness Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards 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 245.3(c) sates in part: Each School Food Authority shall serve free and reduced price meals or free milk in the respective programs to children eligible under its eligibility criteria. Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the eligibility compliance requirement. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with eligibility requirements. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There were no questioned costs identified. Context: During sample testing of 60 students for eligibility, we noted 3 instances where there was no documented review by someone other than the individual making the eligibility determination. The lack of review was isolated to paper applications. Identification as a repeat finding, if applicable: No. Recommendation: We recommended that the School Corporation’s management establish a formal documented, review over application data entered into the software to ensure the accuracy and completeness of the information entered into the software which is critical to eligibility determination process. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.

Context: During sample testing of 60 students for eligibility, we noted 3 instances where there was no documented review by someone other than the individual making the eligibility determination. The lack of review was isolated to paper applications. Contact Person Responsible for Corrective Action: Tami Wyant, FSD Contact Phone Number: (765) 963-2560 Ext: 1172 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Prior the start of each school year, the FSD will verify within Skyward Food Service Management System that the eligibility guidelines that have been loaded for use in determining free & reduced lunch status are correct according to the published guidelines. During the eligibility review of applications, the Food Service Director will provide the first review to make her initial determination and the applications will have a second review done by the Asst. Food Service Director, who will put her initials on the paper applications as proof of review. For any online applications that are submitted during the school year the FSD will review online and then push the applications onward within Skyward for final processing since the guidelines have already been verified prior to the start of the school year. The FSD will keep a printed copy of the guidelines loaded in Skyward and the Assistant FSD will verify and initial as a second review and keep on file for audit purposes. Anticipated Completion Date: All paper applications that have been received since the start of the school year, 2024-25, will have a second review done and so noted by the reviewer’s initials. Moving forward, all applications received, whether in paper format or online submission, will have the review done prior to approval. Applications are received throughout the year, so action to remedy this situation will take place immediately for any new applications received.

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