EIN: 351097809
UEI: LJKFV4LKDBK3
Data as of August 19, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on February 4, 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 August 4, 2025, which was (381 days ago).
What is a management decision? →FINDING 2024-003 Subject: Child Nutrition Cluster - Allowable Costs/Cost Principles Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program Assistance Listings Numbers: 10.553, 10.555 Federal Award Number and Year (or Other Identifying Number): FY 2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Allowable Costs/Cost Principles Audit Findings: Material Weakness, Modified Opinion Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2022-003. Condition and Context An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Allowable Costs/Cost Principles compliance requirement. During the audit period, there was not an approved salary ordinance for noncertified staff for fiscal year 2023-2024. Of the nine paychecks selected for testing, three did not have hourly rates approved by the governing body. It was further determined that all noncertified staff employees did not have the hourly rates approved by the governing body for 2023-2024. Therefore, we were not able to determine if the amounts paid to these employees were appropriate. The lack of internal controls and noncompliance was limited to payroll disbursements of noncertified employees during 2024. 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). . . ." 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. . . ." 2 CFR 200.430(g)(1) states in part: "Charges to Federal awards for salaries 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 that provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the recipient or subrecipient; (iii) Reasonably reflect the total activity for which the employee is compensated by the recipient or subrecipient, not exceeding 100 percent of compensated activities (for IHEs, this is the IBS); (iv) Encompass federally-assisted and all other activities compensated by the recipient or subrecipient on an integrated basis but may include the use of subsidiary records as defined in the recipient's or subrecipient's written policy; (v) Comply with the established accounting policies and procedures of the recipient or subrecipient (See paragraph (i)(1)(ii) of this section for treatment of incidental work for IHEs.); and . . . (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (meaning, estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient's or subrecipient's written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient's or subrecipient's system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated. (ix) Because practices vary as to the activity constituting a full workload (for example, the Institutional Base Salary (IBS) for IHEs), records may reflect categories of activities expressed as a percentage distribution of total activities. (x) It is recognized that teaching, research, service, and administration are often inextricably intermingled in an academic setting. Therefore, a precise assessment of factors contributing to costs is not required when IHEs record salaries and wages charged to Federal awards . . ." Cause Management had not established an effective system of internal controls that would have ensured compliance with the grant agreement and the Allowable Costs/Cost Principles compliance requirement. Effect The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Allowable Costs/Cost Principles compliance requirement could have resulted in the loss of federal funds to the School Corporation. Questioned Costs The total of known questioned costs was $219,188. Recommendation We recommended that the School Corporation's management establish an effective system of internal controls to ensure compliance and comply with the grant agreement and Allowable Costs/Cost Principles compliance requirement. An internal control system, including segregation of duties, should be designed and operate effectively to provide reasonable assurance that material noncompliance with the grant agreement or a compliance requirement of a federal program will be prevented, or detected and corrected, on a timely basis. In order to have an effective internal control system, it is important to have proper segregation of duties. This is accomplished by making sure proper oversight, reviews, and approvals take place and to have a separation of functions over certain activities related to the program. The fundamental premise of segregation of duties is that an individual or small group of individuals should not be in a position to initiate, approve, undertake, and review the same activity. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-003 Finding Subject: Child Nutrition Cluster (School Lunch) – Allowable Cost Summary of Finding: The payroll for non-certified employees for the 2023-2024 school year has not been approved by the board, leading to a lack of verification for salaries paid from fund 800. As a result, any payroll for non-certified employees paid after August 1, 2023 from fund 800 cannot be verified. Contact Person Responsible for Corrective Action: Robin Popejoy Contact Phone Number and Email Address: 317.758.4172 – rpopejoy@sheridan.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The salary schedules will be submitted to the board for approval. Anticipated Completion Date: May – August 2025
2022-003
FINDING 2024-004 Subject: Child Nutrition Cluster - Suspension and Debarment Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program Assistance Listings Numbers: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY 2023, FY 2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Other Matters Condition and Context Prior to entering into subawards and covered transactions with federal award funds, recipients are required to verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded. "Covered transactions" include, but are not limited to, contracts for goods and services awarded under a nonprocurement transaction (i.e., grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the SAM exclusions, collecting a certification from that person, or adding a clause or condition to the covered transaction with that person. Upon inquiry of the School Corporation, it was determined that the School Corporation ensures all service contracts include a provision regarding suspension and debarment. The contracts are reviewed and signed by a knowledgeable member of the School Corporation. Two vendors with covered transactions for goods or services that equaled or exceeded $25,000 paid from Child Nutrition Cluster funds during the audit period were identified at the School Corporation level and tested. For one of the two vendors, the School Corporation did not verify that the contract included the provision regarding suspension and debarment or otherwise verify the vendor's suspension and debarment status prior to payment. The lack of effective 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 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). . . ." 2 CFR 180.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person." 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 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, vendors to whom payments equal to or in excess of $25,000 were not verified to be not suspended, debarred, or otherwise excluded. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure contractors and subrecipients, as appropriate, are not suspended, debarred, or otherwise excluded prior to entering into any contracts or subawards. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-004 Finding Subject: Child Nutrition Cluster (School Lunch) – Suspension and Debarment Summary of Finding: One of the vendors tested did not have documentation showing that the school corporation had verified they were not suspended or debarred before entering into a covered transaction. Contact Person Responsible for Corrective Action: Robin Popejoy Contact Phone Number and Email Address: 317.758.4172 – rpopejoy@sheridan.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Café Direction will check SAM.gov to ensure the vendor is not suspended or debarred before proceeding with any transactions. Anticipated Completion Date: January 2025
FINDING 2024-005 Subject: Child Nutrition Cluster - Eligibility Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program Assistance Listings Numbers: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY 2023, FY 2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Finding: Material Weakness Condition and Context Any child enrolled in a participating school, who meets the applicable program's definition of "child," may receive meals under applicable programs. A child belonging to households meeting nationwide income eligibility requirements may receive meals at no charge or at a reduced price. Children that have been determined ineligible for free or reduced-price meals pay the full price for their meals. A child's eligibility for free and reduced-priced meals under a Child Nutrition Cluster program may be established by the submission of an annual application or statement which furnished such information as family income and family size. The School Corporation determines eligibility by comparing the data reported by the child's household to published income eligibility guidelines. Annual eligibility determinations may also be based on the child's household receiving benefits under SNAP, FDPIR, the Head Start Program, or, under most circumstances, the TANF program. A household may furnish documentation of its participation in one of those programs, or the School Corporation may obtain the information directly from the State or local agency that administers those 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. One employee uploaded the Direct Certification reports from the state into the software system without a documented oversight or review process in place to ensure direct certified students were properly processed. The lack of internal controls was isolated to the direct certified households. 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, which would include segregation of key functions, was not implemented by management of the School Corporation. 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.
FINDING 2024-005 Finding Subject: Child Nutrition Cluster (School Lunch) – Eligibility Summary of Finding: Café Director uploaded the Direct Certification reports from the state into the software system without following a documented oversight or review process to ensure that direct certified students were accurately processed. This highlights a lack of documented controls for directly certified students. Contact Person Responsible for Corrective Action: Robin Popejoy Contact Phone Number and Email Address: 317.758.4172 – rpopejoy@sheridan.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Data Department will collaborate with the Café Department to input and ensure the accuracy of the information. Anticipated Completion Date: Already started in August of 2024.
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 8, 2023. 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 September 8, 2023, which was (1077 days ago).
What is a management decision? →FINDING 2022-003Subject: Child Nutrition Cluster - Allowable Costs/Cost PrinciplesFederal Agency: Department of AgricultureFederal Programs: School Breakfast Program, COVID-19 - School Breakfast Program, NationalSchool Lunch Program, COVID-19 - National School Lunch ProgramAssistance Listings Numbers: 10.553, 10.555Federal Award Numbers and Years (or Other Identifying Numbers): FY2021, FY2022Pass-Through Entity: Indiana Department of EducationCompliance Requirement: Allowable Costs/Cost PrinciplesAudit 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 compliancerequirement.The School Corporation had not developed nor implemented internal controls over transactionspaid from the Child Nutrition Cluster funds to ensure that the payment was an allowable cost for the benefitof the food service program.Additionally, the School Corporation paid food service employees that worked more than 5.25 hoursa day on a biweekly basis with payments that continued into the summer. In order to do this, an employee'spay was annualized based on the expected number of days worked and then divided by 26. Each employeewas required to complete a timesheet every two weeks, which was approved by their supervisor, to supportthe time worked during the school year. Four of the fourteen paychecks selected for testing had errors.Two of the paychecks did not have the required timesheets, and two of the paychecks did not havetimesheets that reflected time worked to adequately support the amount paid to the employee.The lack of internal controls was a systemic issue for all disbursements throughout the audit period.The noncompliance was isolated to payroll disbursements for the school year ended June 30, 2021.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 for salaries and wages must be based on records thataccurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonableassurance that 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 bythe non-Federal entity, not exceeding 100% of compensated activities . . .(vii) Support the distribution of the employee's salary or wages among specificactivities or cost objectives if the employee works on more than one Federal award; aFederal award and non-Federal award; an indirect cost activity and a direct costactivity; two or more indirect activities which are allocated using different allocationbases; or an unallowable activity and a direct or indirect cost activity. . . ."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Allowable Costs/Cost Principles compliance requirement.EffectThe failure to establish an effective internal control system enabled material noncompliance to goundetected. Noncompliance with the grant agreement and the Allowable Costs/Cost Principles compliancerequirement could result in the loss of future federal funds to the School Corporation.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish internal controls to ensurecompliance and comply with the grant agreement and the Allowable Costs/Cost Principles compliancerequirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-003Contact Person Responsible for Corrective Action: Kim DeVaney/Robin PopejoyContact Phone Number: 317.758.4172Views of Responsible Official: We concur with the finding.Description of Corrective Action Plan: Those procedures and errors were discussed and adjustments have beenmade. To prevent errors the Payroll Specialist will make sure the employee timesheets that was signed off by the Directormatches with the hours they were approved to work when hired.Anticipated Completion Date: February 2023
FINDING 2022-004Subject: Child Nutrition Cluster - Activities Allowed or Unallowed, Reporting, SpecialTests and Provisions - Non-Profit School Food Service AccountsFederal Agency: Department of AgricultureFederal Programs: School Breakfast Program, COVID-19 - School Breakfast Program, NationalSchool Lunch Program, COVID-19 - National School Lunch ProgramAssistance Listings Numbers: 10.553, 10.555Federal Award Numbers and Years (or Other Identifying Numbers): FY2021, FY2022Pass-Through Entity: Indiana Department of EducationCompliance Requirements: Activities Allowed or Unallowed, Reporting, Special Tests andProvisions - Non-Profit School Food Service AccountsAudit Finding: Material WeaknessCondition and ContextAn effective internal control system was not designed nor implemented at the School Corporationto ensure compliance with requirements related to the grant agreement and the Activities Allowed orUnallowed, the Reporting, and the Special Tests and Provisions - Non-Profit School Food Service Accountscompliance requirements.Activities Allowed or UnallowedThe School Corporation had not designed nor implemented a system of internal control overSchool Lunch fund disbursements to ensure all activities were for the benefit of the ChildNutrition Cluster. One employee was responsible for processing disbursements without anoversight or review process in place to prevent, or detect and correct, errors.ReportingThe School Corporation had not designed nor implemented a system of internal control toensure that reimbursement requests were accurately submitted. The reimbursement requestswere prepared by one employee based on meals served without an oversight or review processin place to prevent, or detect and correct, errors.Special Tests and Provisions - Non-Profit School Food Service AccountsThe School Corporation had not designed nor implemented a system of internal controls toensure all revenue generated by the school food service was used to operate and improve itsfood service. One employee was responsible for the receipting and disbursing of School Lunchfunds without an oversight or review process in place to prevent or detect and correct errors.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 nor implemented a system of internal controls that would haveensured compliance with the grant agreement and the Activities Allowed or Unallowed, the Reporting, andthe Special Tests and Provisions - Non-Profit School Food Service Accounts compliance requirements.EffectThe failure to establish an effective internal control system could have enabled material noncomplianceto go undetected.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish internal controls to ensurecompliance with the grant agreement and the Activities Allowed or Unallowed, the Reporting, and theSpecial Tests and Provisions - Non-Profit School Food Service Accounts compliance requirements.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-004Contact Person Responsible for Corrective Action: Robin PopejoyContact Phone Number: 317.758.4172Views of Responsible Official: We concur with the finding.Description of Corrective Action Plan: Those procedures and errors were discussed and adjustments have beenmade. To cover oversight of the School Food Service Accounts, at the close of the month the Director of Business willsend Director of Food Service reports to approve all activity of School Food Service Accounts.Anticipated Completion Date: February 2023
FINDING 2022-005Subject: COVID-19 - Education Stabilization Fund - Allowable Costs/Cost PrinciplesFederal Agency: Department of EducationFederal Program: COVID-19 - Education Stabilization FundAssistance Listings Numbers: 84.425D, 84.425UFederal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425U210013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: Allowable Costs/Cost PrinciplesAudit Findings: Material Weakness, Modified OpinionCondition and ContextAn effective internal control system was not in place at the School Corporation in order to ensurecompliance with requirements related to the grant agreement and the Allowable Costs/Cost Principlescompliance requirement.The School Corporation did not have adequate internal controls in place to ensure that the reimbursementrequests included salaries for all contracted employees and adequate supporting documentationor personnel activity reports, such as time and effort logs or Semi-Annual Certifications. The SchoolCorporation paid salaries for all contracted employees without adequate supporting documentation orpersonnel activity reports, such as time and effort logs or Semi-Annual Certifications. The total amountpaid to contracted employees was $51,644. This amount was considered questioned costs.The lack of internal controls and noncompliance were systemic issues throughout the audit period.CriteriaCFR 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 200.430(i) states in part:"Standards for Documentation of Personnel Expenses(1) Charges to Federal awards for salaries and wages must be based on records thataccurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonableassurance that 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 bythe non-Federal entity, not exceeding 100% of compensated activities . . .(vii) Support the distribution of the employee's salary or wages among specificactivities or cost objectives if the employee works on more than one Federal award; aFederal award and non-Federal award; an indirect cost activity and a direct costactivity; two or more indirect activities which are allocated using different allocationbases; or an unallowable activity and a direct or indirect cost activity. . . ."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Allowable Costs/Cost Principles compliance requirement.EffectThe failure to establish an effective internal control system enabled material noncompliance to goundetected. Noncompliance with the grant agreement and the Allowable Costs/Cost Principles compliancerequirement could have resulted in the loss of federal funds to the School Corporation.Questioned CostsQuestioned costs of $51,644 were identified, as described in the Condition and Context.RecommendationWe recommended that the School Corporation's management establish a system of internal controlsto ensure compliance and comply with the grant agreement and the Allowable Costs/Cost Principlescompliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-005Contact Person Responsible for Corrective Action: Robin Popejoy/Kim DeVaneyContact Phone Number: 317.758.4172Views of Responsible Official: We concur with the finding.Description of Corrective Action Plan: Those procedures and errors were discussed and adjustment have been made.As this finding is in review of ESSER funding, it should be noted that most all guidance and direction for these grantscame after they were issued. All financial transactions related to grants will have board oversight and approval.Anticipated Completion Date: February 2023
FINDING 2022-006Subject: COVID-19 - Education Stabilization Fund - Equipment and Real Property ManagementFederal Agency: Department of EducationFederal Program: COVID-19 - Education Stabilization FundAssistance Listings Number: 84.425DFederal Award Number and Year (or Other Identifying Number): S425D200013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: Equipment and Real Property ManagementAudit Findings: Material Weakness, Modified OpinionCondition 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 Equipment and Real Property Managementcompliance requirement.The School Corporation purchased $72,425 of various equipment with Elementary and SecondarySchool Emergency Relief (ESSER) funds. The equipment was not added to the property record whichwould include a description of the property, a serial number or other identification number, the source offunding for the property (including the federal award identification number (FAIN)), who holds title, theacquisition date, cost of the property, percentage of federal participation in the project costs for the federalaward under which the property was acquired, the location, and the use and condition of the property.Additionally, the School Corporation did not adequately safeguard the equipment purchased and had notcompleted a physical inventory of equipment within the last two years.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 200.313(d) states in part:"(1) Property records must be maintained that include a description of the property, a serialnumber or other identification number, the source of funding for the property (includingthe FAIN), who holds title, the acquisition date, and cost of the property, percentage offederal participation in the project costs for the federal award under which the propertywas acquired, the location, use and condition of the property, and any ultimate dispositiondata including the date of disposal and sales price of the property(2) A physical inventory of the property must be taken and the results reconciled with theproperty records at least once every two years.(3) A control system must be developed to ensure adequate safeguards to prevent loss,damage, or theft of the property. Any loss, damage, or theft must be investigated. . . ."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the grant agreement and the Equipment and Real Property compliance requirement.EffectThe failure to establish an effective internal control system enabled material noncompliance to goundetected. Noncompliance with the grant agreement and the Equipment and Real Property Managementcompliance requirement could have resulted in the loss of future federal funds to the School Corporation.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish a system of internal controlsto ensure compliance and comply with the grant agreement and the Equipment and Real PropertyManagement compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-006Contact Person Responsible for Corrective Action: Robin PopejoyContact Phone Number: 317.758.4172Views of Responsible Official: We concur with the finding.Description of Corrective Action Plan: Those procedures and errors were discussed and adjustment will be made. TheDirector of Business will conduct and internal audit of capital assets records. New staff will also be trained on trackingcapital assets transitions and completing the necessary documentation for future capital assets transaction. There is aconstruction project that will result in capital assets being added.Anticipated Completion Date: June 2023
FINDING 2022-007Subject: COVID-19 - Education Stabilization Fund - ReportingFederal Agency: Department of EducationFederal Program: COVID-19 - Education Stabilization FundAssistance Listings Numbers: 84.425C, 84.425D, 84.425UFederal Award Numbers and Years (or Other Identifying Numbers): S425C200018, S425D200013,S425U210013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: ReportingAudit Finding: Material WeaknessCondition and ContextAn effective internal control system, was not designed nor implemented at the School Corporationto ensure compliance with requirements related to the grant agreement and the Reporting compliancerequirement.The School Corporation had not designed nor implemented a system of internal controls to ensurethat the annual Elementary and Secondary School Emergency Relief (ESSER) and the Governor'sEmergency Education Relief (GEER) annual Data Collection reports (Reports) were complete and accuratelysubmitted. The Reports were prepared by one employee without an oversight or review processin place to prevent, or detect and correct, errors.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 nor implemented an effective internal control system that wouldhave ensured compliance with the grant agreement and the Reporting compliance requirement.EffectThe failure to establish an effective internal control system could have enabled material noncomplianceto go undetected.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish internal controls to ensurecompliance with the grant agreement and the Reporting compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-007Contact Person Responsible for Corrective Action: Robin Popejoy/Kim DeVaneyContact Phone Number: 317.758.4172Views of Responsible Official: We concur with the finding.Description of Corrective Action Plan: Those procedures and errors were discussed and adjustment have been made.As this finding is in review of ESSER funding, it should be noted that most all guidance and direction for these grantscame after they were issued. As ESSER reports and reimbursements are completed the supporting documents will bekept with reports. Prior to submission, reports completed and documentation compiled by the Grant Specialist will bereviewed by the Director of Business.Anticipated Completion Date: February 2023INDIANA STATE
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 30, 2021. 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 September 30, 2021, which was (1785 days ago).
What is a management decision? →FINDING 2020-002 Subject: Child Nutrition Cluster - Procurement Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program CFDA Numbers: 10.553, 10.555 Federal Award Number and Year (or Other Identifying Number): FY 2019 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Other Matters Condition and Context An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the procurement requirements of the Procurement and Suspension and Debarment compliance requirement. The School Corporation had estimated that one vendor who was to provide food products would fall under the Small Purchase Procurement Method. However, a review of disbursements to the vendor indicated that the vendor fell under the Exceeds Simplified Acquisition Procurement Method. As a result, the School Corporation did not follow the proper procedures for the Exceeds Simplified Acquisition Procurement Method and did not obtain the required bids. The lack of effective internal controls and noncompliance was isolated to the vendor mentioned above for fiscal year 2018-2019. The School Corporation joined a purchasing cooperative for 2019-2020 and did not use this vendor. 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). . . ."2 CFR 200.320 states in part: "The non-Federal entity must use one of the following methods of procurement. . . . (c) Procurement by sealed bids (formal advertising). Bids are publicly solicited and a firm fixed price contract (lump sum or unit price) is awarded to the responsible bidder whose bid, conforming with all the material terms and conditions of the invitation for bids, is the lowest in price. The sealed bid method is the preferred method for procuring construction, if the conditions in paragraph (c)(1) of this section apply . . . (2) If sealed bids are used, the following requirements apply: (i) Bids must be solicited from an adequate number of known suppliers, providing them sufficient response time prior to the date set for opening the bids, for local, and tribal governments, the invitation for bids must be publicly advertised; . . ." Cause Management had not developed an effective system of internal controls that would have ensured compliance with the grant agreement and the procurement requirements. Effect The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the procurement requirements could have resulted in the loss of funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure compliance and comply with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2020-002 Report Period: 7/1/2018 ? 6/30/20 Title of Result and Comment: Child Nutrition Cluster - Procurement Contact Person Responsible for Corrective Action: Robin Popejoy Contact Phone Number: 317.758.4172 Contact Email: rpopejoy@sheridan.k12.in.us Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: For the 2018 ? 2019 school year Sheridan Community Schools used a vendor that fell under the Small Purchase Procurement Method. When it was discovered Sheridan Community Schools switched to a Co-op that handles vendor contracts and stays within the parameters required, this started in with the 2019 school year. Anticipated Completion Date: July 1, 2019
FINDING 2020-003 Subject: Special Education Cluster (IDEA) - Procurement Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants CFDA Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 14217-025-PN01, 18611-023-PN01, 19611-023-PN01, 18619-023-PN01, 19619-023-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Other MattersAn effective internal control system was not in place at the School Corporation to ensure compliance with the requirements related to the grant agreement and the procurement requirements of the Procurement and Suspension and Debarment compliance requirement. The School Corporation is a member of the Hamilton-Boone-Madison Special Services Cooperative (Cooperative). The grant agreements for the federal programs were between the Indiana Department of Education (IDOE) and each member school corporation of the Cooperative. Because the grant agreements were between the IDOE and the School Corporation, the School Corporation was ultimately responsible for compliance with the Procurement and Suspension and Debarment compliance requirement. The written procurement policies and procedures of the fiscal agent did not comply with the procurement standards outlined in the criteria below for fiscal year 2018-2019. The written policies did not specify avoiding the acquisition of unnecessary or duplicative items, or that all solicitations should incorporate a description of the technical requirements of the procurement. The fiscal agent also had a policy to use local geographical preferences in the evaluation of bids or proposals. The School Corporation did not establish effective internal controls over purchases that fall within the small purchases requirement, allowing noncompliance to go undetected. Price or rate quotes were not obtained from an adequate number of qualified sources, and full and open competition was not provided. The lack of effective controls and noncompliance were systemic issues for 2018-2019. 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). . . ." 2 CFR 200.318 states in part: "(a) The non-Federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in this part. . . . (d) The non-Federal entity's procedures must avoid acquisition of unnecessary or duplicative items. Consideration should be given to consolidating or breaking out procurements to obtain a more economical purchase. Where appropriate, an analysis will be made of lease versus purchase alternatives, and any other appropriate analysis to determine the most economical approach. . . . (i) The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. . . ."2 CFR 200.319 states in part: ". . . (b) The non-Federal entity must conduct procurements in a manner that prohibits the use of statutorily or administratively imposed state, local, or tribal geographical preferences in the evaluation of bids or proposals, except in those cases where applicable Federal statutes expressly mandate or encourage geographic preference. . . . (c) The non-Federal entity must have written procedures for procurement transactions. These procedures must ensure that all solicitations: (1) Incorporate a clear and accurate description of the technical requirements for the material, product, or service to be procured. . . ." 2 CFR 200.320 states in part: "The non-Federal Entity must use one of the following methods of procurement. . . . (b) Procurement by small purchase procedures. Small purchase procedures are those relatively simple and informal procurement methods for securing services, supplies, or other property that do not cost more than the Simplified Acquisition Threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources. . . . (f) Procurement by noncompetitive proposals. Procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when one or more of the following circumstances apply: (1) The item is available only from a single source; (2) The public exigency or emergency for the requirement will not permit a delay resulting from competitive solicitation; (3) The Federal awarding agency or pass-through entity expressly authorizes noncompetitive proposals in response to a written request from the non-Federal Entity; or (4) After solicitation of a number of sources, competition is determined inadequate." Cause Management had not developed a system of internal controls that would have ensured compliance with the Procurement and Suspension and Debarment compliance requirement. Effect The failure to establish an effective internal control system enabled noncompliance to go undetected. Noncompliance with the grant agreement and the procurement requirements could have resulted in the loss of funds to the School Corporation. Questioned Costs There were no questioned costs identified.Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure compliance and comply with the grant agreement and Procurement and Suspension and Debarment compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2020-003 Report Period: 7/1/2018 ? 6/30/20 Title of Result and Comment: Special Education Cluster (IDEA) - Procurement Contact Person Responsible for Corrective Action: Robin Popejoy Contact Phone Number: 317.758.4172 Contact Email: rpopejoy@sheridan.k12.in.us Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: This was carryover finding 2019-002 of Noblesville Schools and was corrected in the 2018-2019 school year. Anticipated Completion Date: 2018-2019 school year.This was a carry over finding in the last audit and was corrected during the 2017-2018 school year
FINDING 2020-004 Subject: Special Education Cluster (IDEA) - Equipment and Real Property Management Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants CFDA Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 20611-062-PN01, 18611-023-PN01, 19611-023-PN01, 18619-023-PN01, 19619-023-PN01, 20619-023-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Equipment and Real Property Management Audit Findings: Material Weakness, Modified Opinion Condition and Context An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Equipment and Real Property Management compliance requirement. The School Corporation was a member of a special education cooperative (Cooperative). The Cooperative operated the special education programs on behalf of the School Corporation and managed the special education grant funds. Because the grant agreements were between the Indiana Department of Education and the School Corporation, the School Corporation is ultimately responsible for compliance with the grant agreement and the Equipment and Real Property Management compliance requirement. The School Corporation did not have adequate procedures in place to ensure that the Cooperative complied with the Equipment and Real Property Management compliance requirements. The Cooperative did not have adequate procedures in place to ensure that equipment purchased with grant funds were properly recorded and maintained in the unit's equipment records. Equipment that was disposed of during the audit period was removed from the equipment list with no record being kept of method of disposition. The lack of internal controls and proper documentation for the disposition of the equipment was isolated to fiscal year 2019-2020.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). . . ." 2 CFR 200.313 states in part: ". . . (e) Disposition. When original or replacement equipment acquired under a Federal award is no longer needed for the original project or program or for other activities currently or previously supported by a Federal awarding agency, except as otherwise provided in Federal statutes, regulations, or Federal awarding agency disposition instructions, the non-Federal entity must request disposition instructions from the Federal awarding agency if required by the terms and conditions of the Federal award. Disposition of the equipment will be made as follows, in accordance with Federal awarding agency disposition instructions. . . ." Cause Management had not developed a system of internal controls that would have ensured compliance with the grant agreement and the Equipment and Real Property Management compliance requirement. Effect The failure to provide the supporting documentation for the disposition of equipment prevented the determination of the School Corporation's compliance with the Equipment and Real Property Management compliance requirement. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish effective internal controls to ensure compliance and comply with the Equipment and Real Property Management compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2020-004 Report Period: 7/1/2018 ? 6/30/20 Title of Result and Comment: Special Education Cluster ? Equipment and Real Property Management Contact Person Responsible for Corrective Action: Robin Popejoy Contact Phone Number: 317.758.4172 Contact Email: rpopejoy@sheridan.k12.in.us Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Director of the Hamilton-Boone-Madison Special Services Cooperative learned of the requirement to include the disposition date and sale price if sold in the equipment record on January 7, 2021. At that time columns were added to the Cooperative?s equipment record indicating the date of disposition of equipment and the sale price, if any. Going forward from January 8, 2021, HBMCCS tracks the disposition date and sale price of all equipment. Anticipated Completion Date: 1/8/2021 INDIANA STATE
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on April 3, 2019. 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 October 3, 2019, which was (2513 days ago).
What is a management decision? →GSA_MIGRATION
GSA_MIGRATION
2016-003
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on August 1, 2018. 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 February 1, 2019, which was (2757 days ago).
What is a management decision? →GSA_MIGRATION
GSA_MIGRATION
GSA_MIGRATION
GSA_MIGRATION
GSA_MIGRATION
GSA_MIGRATION
GSA_MIGRATION
GSA_MIGRATION
GSA_MIGRATION
GSA_MIGRATION
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