EIN: 351113190
UEI: N6T1XASKX7T5
Data as of August 22, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 30, 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 30, 2023 (1057 days ago).
What is a management decision? →To support cash management procedures, the financial specialist reviews monthly meal counts prior to submission to the pass through entity, as evidenced by the financial specialist's signature on the meal counts forms. In our sample test, 2 of the 8 selections tested, or 25%, lacked the financial specialist's signature documenting that this control was in place and operating effectively. Questioned costs: None. Context: 2 of 8 monthly claims tested did not contain management review sign-offs of the meal counts.2022 ? 002 ? Child Nutrition Cluster Cash Management (Continued) Cause: Procedures to perform and document management reviews of meal counts were not adhered to. Effect: Risk of noncompliance. Repeat Finding: Yes. Recommendation: We recommend the Bartholomew Consolidated School Corp adhere to internal control procedures over the review of meal counts. View of Responsible Officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴2022 ? 002 ? Child Nutrition Cluster Cash Management Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Numbers: 10.553/10.555/10.559 Federal Award Identification Number and Year: FY 21 and FY 22 Pass-Through Agency: Indiana Department of Education Pass-Through Number: 2020-21 and 2021-22 Award Period: July 1, 2020 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: Per the OMB Compliance Supplement, to obtain cash and donated food assistance, a local program operator must submit monthly claims for reimbursement to its administering agency. Condition: To support cash management procedures, the financial specialist reviews monthly meal counts prior to submission to the pass through entity, as evidenced by the financial specialist's signature on the meal counts forms. In our sample test, 2 of the 8 selections tested, or 25%, lacked the financial specialist's signature documenting that this control was in place and operating effectively. Questioned costs: None. Context: 2 of 8 monthly claims tested did not contain management review sign-offs of the meal counts.2022 ? 002 ? Child Nutrition Cluster Cash Management (Continued) Cause: Procedures to perform and document management reviews of meal counts were not adhered to. Effect: Risk of noncompliance. Repeat Finding: Yes. Recommendation: We recommend the Bartholomew Consolidated School Corp adhere to internal control procedures over the review of meal counts. View of Responsible Officials: There is no disagreement with the audit finding.
2022-002 Child Nutrition Cluster ? Assistance Listing No. 10.553/10.555/10.559Recommendation: Adhere to internal control procedures over the review of meal counts. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: Summer Feeding Program Claims will be reviewed and verified before entry with same form and procedure that is currently used for National School Lunch Program claims. Name(s) of the contact person(s) responsible for corrective action: Nancy Millspaugh Planned completion date for corrective action plan: June 30, 2023.
2020-002
All deficiencies related to micro purchase selections. Micro purchases should be reviewed by the accounts payable supervisor, as evidenced by initials, prior to payment of invoice. The deficient selections lacked initials indicating review had occurred. Questioned costs: None. Context: 2 of 13 procurement transactions tested lacked support to document that the control structure was in place and operating effectively. Cause: Procedures to perform and document management reviews of invoices for micro-purchases were not adhered to. Effect: Risk of noncompliance.2022 ? 003 ? Child Nutrition Cluster Procurement (Continued) Repeat Finding: Yes. Recommendation: We recommend the Bartholomew Consolidated School Corp adhere to internal control procedures over the review of invoices for micro-purchases. View of Responsible Officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴2022 ? 003 ? Child Nutrition Cluster Procurement Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Numbers: 10.553/10.555/10.559 Federal Award Identification Number and Year: FY 21 and FY 22 Pass-Through Agency: Indiana Department of Education Pass-Through Number: 2020-21 and 2021-22 Award Period: July 1, 2020 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: 2 CFR 200.303 states that non-federal entities must establish and maintain effective internal control over the Federal award. Condition: All deficiencies related to micro purchase selections. Micro purchases should be reviewed by the accounts payable supervisor, as evidenced by initials, prior to payment of invoice. The deficient selections lacked initials indicating review had occurred. Questioned costs: None. Context: 2 of 13 procurement transactions tested lacked support to document that the control structure was in place and operating effectively. Cause: Procedures to perform and document management reviews of invoices for micro-purchases were not adhered to. Effect: Risk of noncompliance.2022 ? 003 ? Child Nutrition Cluster Procurement (Continued) Repeat Finding: Yes. Recommendation: We recommend the Bartholomew Consolidated School Corp adhere to internal control procedures over the review of invoices for micro-purchases. View of Responsible Officials: There is no disagreement with the audit finding.
2022-003 Child Nutrition Cluster ? Assistance Listing No. 10.553/10.555/10.559 Recommendation: Adhere to internal control procedures over the review of invoices for micro- purchases. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: Cafe managers will initial or sign invoices upon receipt. Food Service Financial Specialist (Andrew Millspaugh) will sign off on invoices once they have been reconciled to the company statements. Food Service Personnel Coordinator (Vicki Fields) will review the invoices before sending to the business office for payment. Food Service Director (Nancy Millspaugh) will approve entries before they are sent to the business office. A form similar to the one being used for bank reconciliation will be used to verify the invoices were reconciled, reviewed and entered with approval. Name(s) of the contact person(s) responsible for corrective action: Nancy Millspaugh Planned completion date for corrective action plan: April 30, 2023
2020-003
The deficient selection was for a vendor that is typically only used for small purchases that do not exceed the suspension and debarment threshold, however during the audit period, the client procured larger-value equipment from this vendor, leading the total purchases to exceed the threshold. Questioned Costs: None. Context: For 1 of 4 vendors tested, documentation of the verification of the suspension/debarment status of the vendor was not provided. Cause: Procedures were not adhered to for the documentation of the verification that all vendors were not suspended or debarred from participation in Federal assistance programs or activities.2022 ? 004 ? Child Nutrition Suspension and Debarment (Continued) Effect: While this did not occur in the instance identified in this finding, lack of verification of vendors? debarment or suspension status could cause federal grant funds to be expended with vendors that are excluded from participation in Federal assistance programs or activities. Repeat Finding: Yes. Recommendation: We recommend procedures be implemented to annually (at a minimum) document the verification that all vendors are not suspended or debarred from participation in Federal assistance programs or activities. Views of Responsible Officials: Management agrees with the finding.
Show full finding ▾Hide full finding ▴2022 ? 004 ? Child Nutrition Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553/10.555/10.559 Federal Award Identification Number and Year: FY 21 and FY 22 Pass-Through Agency: Indiana Department of Education Pass-Through Number: 2020-21 and 2021-22 Award Period: July 1, 2020 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: CFR Title 2 Part 200.214 states that nonfederal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Nonfederal entities must verify that contracts with certain parties are not debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: The deficient selection was for a vendor that is typically only used for small purchases that do not exceed the suspension and debarment threshold, however during the audit period, the client procured larger-value equipment from this vendor, leading the total purchases to exceed the threshold. Questioned Costs: None. Context: For 1 of 4 vendors tested, documentation of the verification of the suspension/debarment status of the vendor was not provided. Cause: Procedures were not adhered to for the documentation of the verification that all vendors were not suspended or debarred from participation in Federal assistance programs or activities.2022 ? 004 ? Child Nutrition Suspension and Debarment (Continued) Effect: While this did not occur in the instance identified in this finding, lack of verification of vendors? debarment or suspension status could cause federal grant funds to be expended with vendors that are excluded from participation in Federal assistance programs or activities. Repeat Finding: Yes. Recommendation: We recommend procedures be implemented to annually (at a minimum) document the verification that all vendors are not suspended or debarred from participation in Federal assistance programs or activities. Views of Responsible Officials: Management agrees with the finding.
2022-004 Child Nutrition Cluster ? Assistance Listing No. 10.553/10.555/10.559 Recommendation: Implement procedures to annually (at a minimum) document the verification that all vendors are not suspended or debarred from participation in Federal assistance programs or activities. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: All vendors that the Food Service Department plans to use for quotes will receive a contract which includes a form to report suspension or debarment from participation in Federal assistance programs or activities. Name(s) of the contact person(s) responsible for corrective action: Nancy MillspaughPlanned completion date for corrective action plan: July 1, 2023 If the U.S. Department of Agriculture has questions regarding this plan, please call Nancy Millspaugh at 812-376-4462
2020-003
FAC accepted this audit on July 22, 2021 — management decision was due January 22, 2022.
FINDING 2020-002 Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, COVID-19 - School Breakfast Program, National School Lunch Program, COVID-19 - National School Lunch Program, Summer Food Service Program for Children, COVID-19 - Summer Food Service Program for Children CFDA Numbers: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): 2018-19, 2019-20 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Cash Management, Eligibility, Program Income, Special Tests and Provisions - Paid Lunch Equity Audit Finding: Material Weakness 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 Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Cash Management, Eligibility, Program Income, and Special Tests and Provisions - Paid Lunch Equity compliance requirements. Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Program Income The School Corporation had not established internal controls, which would include segregation of duties, related to payroll. The School Corporation did not have an oversight or review process in place to ensure that the payroll charged to the grant was for the use or benefit of the food service authority or a proper use of program income. Cash Management The School Corporation had not established internal controls, which would include segregation of duties, that would have ensured that the balance in the School Lunch fund, which represented the net cash resources, did not exceed three months average expenditures. Eligibility The School Corporation had not established internal controls, which would include segregation of duties, related to entering student information into the School Corporation's school lunch software. Manual applications prepared by parents were entered into the school lunch software by one employee without an oversight or review process. Also, one employee was solely responsible for uploading the direct certification list into the School Corporation's school lunch software without an oversight or review process in place to ensure that the information in the School Corporation's computer system was correct. Program Income The School Corporation had not established internal controls, which would include segregation of duties, that would have ensured the proper recording of program income. Special Tests and Provisions - Paid Lunch Equity The School Corporation had not established internal controls, which would include segregation of duties, related to the paid lunch equity calculation. One employee was solely responsible for the information entered into the Paid Lunch Equity Calculator without an oversight or review process. 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 Management had not developed a system of internal controls that would have ensured compliance with the grant agreement and the Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Cash Management, Eligibility, Program Income, and Special Tests and Provisions - Paid Lunch Equity compliance requirements. Effect The failure to establish an effective internal control system, which would include segregation of duties, 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 also allow noncompliance with the compliance requirements and allow 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. Recommendation We recommended that the School Corporation's management establish a system of internal controls, including segregation of duties, to ensure compliance with the grant agreement and comply with the Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Cash Management, Eligibility, Program Income, and Special Tests and Provisions - Paid Lunch Equity compliance requirements. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Show full finding ▾Hide full finding ▴FINDING 2020-002 Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, COVID-19 - School Breakfast Program, National School Lunch Program, COVID-19 - National School Lunch Program, Summer Food Service Program for Children, COVID-19 - Summer Food Service Program for Children CFDA Numbers: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): 2018-19, 2019-20 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Cash Management, Eligibility, Program Income, Special Tests and Provisions - Paid Lunch Equity Audit Finding: Material Weakness 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 Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Cash Management, Eligibility, Program Income, and Special Tests and Provisions - Paid Lunch Equity compliance requirements. Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Program Income The School Corporation had not established internal controls, which would include segregation of duties, related to payroll. The School Corporation did not have an oversight or review process in place to ensure that the payroll charged to the grant was for the use or benefit of the food service authority or a proper use of program income. Cash Management The School Corporation had not established internal controls, which would include segregation of duties, that would have ensured that the balance in the School Lunch fund, which represented the net cash resources, did not exceed three months average expenditures. Eligibility The School Corporation had not established internal controls, which would include segregation of duties, related to entering student information into the School Corporation's school lunch software. Manual applications prepared by parents were entered into the school lunch software by one employee without an oversight or review process. Also, one employee was solely responsible for uploading the direct certification list into the School Corporation's school lunch software without an oversight or review process in place to ensure that the information in the School Corporation's computer system was correct. Program Income The School Corporation had not established internal controls, which would include segregation of duties, that would have ensured the proper recording of program income. Special Tests and Provisions - Paid Lunch Equity The School Corporation had not established internal controls, which would include segregation of duties, related to the paid lunch equity calculation. One employee was solely responsible for the information entered into the Paid Lunch Equity Calculator without an oversight or review process. 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 Management had not developed a system of internal controls that would have ensured compliance with the grant agreement and the Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Cash Management, Eligibility, Program Income, and Special Tests and Provisions - Paid Lunch Equity compliance requirements. Effect The failure to establish an effective internal control system, which would include segregation of duties, 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 also allow noncompliance with the compliance requirements and allow 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. Recommendation We recommended that the School Corporation's management establish a system of internal controls, including segregation of duties, to ensure compliance with the grant agreement and comply with the Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Cash Management, Eligibility, Program Income, and Special Tests and Provisions - Paid Lunch Equity compliance requirements. 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 Contact Person Responsible for Corrective Action: Nancy Millspaugh Contact Phone Number: 812-376-4462 Views of Responsible Official: We concur with the finding Description of Corrective Action Plan: Allowable Costs/Cost Principles The food service personnel coordinator will prepare the food service payroll, payroll specialist will enter payroll. A report will be printed for food service director to review to ensure only allowable payroll was charged to the grant. Program Income Program income is prepared by food service financial specialist and reviewed by food service director monthly. Control is already in place. Food service director will compare payroll report to food service 0800 expenditure report to verify that only allowable payroll was charged to the grant. Cash Management A process is already in place to ensure the net cash resources do not exceed the three-month average of School Lunch fund expenditures. The deputy treasurer prepares the report, the report is compared/reviewed by the food service director and the food service financial specialist. After review and comparison a form will be completed to document review, will be signed by food service director and food service financial specialist and this will be filed with the form for future audit review. Eligibility Manual applications will be pulled in October and February for review for accuracy. Every 50 applications will be pulled for review and a list of these applications will be retained for further audit reviews. Food Service personnel coordinator will review the forms for accuracy as this position is not directly involved in entering applications. Direct Certification will be run in July, October and January by the PC/Integration specialist . A selection of students will be checked for accuracy in the school lunch software system by the food service director. A list of these students will be kept on file for future audit review. Special Tests and Provisions-Paid Lunch Equity Food Service financial specialist will prepare the information to be included in the Paid Lunch Equity Calculator and after review, the food service director will enter the information into the calculator. Documentation will be included to show this was reviewed and kept on file for future audit review. Anticipated completion Date: 8/1/2021
FINDING 2020-003 Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, COVID-19 - School Breakfast Program, National School Lunch Program, COVID-19 - National School Lunch Program, Summer Food Service Program for Children, COVID-19 - Summer Food Service Program for Children CFDA Numbers: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): 2018-19, 2019-20 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 and Suspension and Debarment compliance requirements. Procurement The School Corporation had not established internal controls, which would include segregation of duties, to ensure contracts were awarded for small purchases and purchases that exceed the simplified acquisition threshold. Contracts were not awarded to vendors in which the School Corporation had procurements in excess of $50,000. Suspension and Debarment The School Corporation had not established internal controls, which would include segregation of duties, to ensure that vendors were not suspended or debarred from participation in federal programs. The School Corporation did not verify that vendors were not suspended or debarred from participation in federal programs for two vendors for fiscal year 2018-2019 and one vendor for 2019-2020. The lack of 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 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. . . . (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 200.320 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. (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. . . . (d) Procurement by competitive proposals. The technique of competitive proposals is normally conducted with more than one source submitting an offer, and either a fixed price or cost-reimbursement type contact is awarded. It is generally used when conditions are not appropriate for the use of sealed bids. . . . (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." 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 the 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 Management had not developed a system of internal controls that would have ensured compliance with the grant agreement and the Procurement and Suspension and Debarment 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 Procurement and Suspension and Debarment compliance requirement could have resulted in a loss of federal 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, including segregation of duties, to ensure compliance and comply with the grant agreement and the Procurement and Suspension and Debarment compliance requirements. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Show full finding ▾Hide full finding ▴FINDING 2020-003 Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, COVID-19 - School Breakfast Program, National School Lunch Program, COVID-19 - National School Lunch Program, Summer Food Service Program for Children, COVID-19 - Summer Food Service Program for Children CFDA Numbers: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): 2018-19, 2019-20 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 and Suspension and Debarment compliance requirements. Procurement The School Corporation had not established internal controls, which would include segregation of duties, to ensure contracts were awarded for small purchases and purchases that exceed the simplified acquisition threshold. Contracts were not awarded to vendors in which the School Corporation had procurements in excess of $50,000. Suspension and Debarment The School Corporation had not established internal controls, which would include segregation of duties, to ensure that vendors were not suspended or debarred from participation in federal programs. The School Corporation did not verify that vendors were not suspended or debarred from participation in federal programs for two vendors for fiscal year 2018-2019 and one vendor for 2019-2020. The lack of 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 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. . . . (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 200.320 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. (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. . . . (d) Procurement by competitive proposals. The technique of competitive proposals is normally conducted with more than one source submitting an offer, and either a fixed price or cost-reimbursement type contact is awarded. It is generally used when conditions are not appropriate for the use of sealed bids. . . . (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." 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 the 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 Management had not developed a system of internal controls that would have ensured compliance with the grant agreement and the Procurement and Suspension and Debarment 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 Procurement and Suspension and Debarment compliance requirement could have resulted in a loss of federal 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, including segregation of duties, to ensure compliance and comply with the grant agreement and the Procurement and Suspension and Debarment compliance requirements. 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 Contact Person Responsible for Corrective Action: Nancy Millspaugh Contact Phone Number: 812-376-4462 Views of Responsible Official: We concur with the finding Description of Corrective Action Plan: Procurement For any vendor $50,000+ for food service, the food service director will see that a contract is provided. Suspension and Debarment To verify that vendors are not suspended or debarred from participation in federal programs, the food service director will check the SAM Exclusions or collect a certification from the vendor or add a clause or condition to the covered transaction with the vendor. This process will then be verified by the food service financial specialist and documented for future audit review. Anticipated completion Date: 8/1/2021
FAC accepted this audit on May 8, 2019 — management decision was due November 8, 2019.
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2016-005
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2016-009
FAC accepted this audit on October 22, 2018 — management decision was due April 22, 2019.
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