South Montgomery Community School Corporation

EIN: 351117221

UEI: R6TFLFJR77T3

Data as of August 24, 2026

South Montgomery Community School Corporation5 audit years17 findings2 repeat
5
Audit Years
17
Total Findings
2
Repeat Findings

FY 2024-06-30

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on March 13, 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 September 13, 2025 (345 days ago).

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2024-002
Reporting
MATERIAL WEAKNESS

FINDING 2024-002 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Number: 84.425D Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, FY23/24 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Condition and Context The School Corporation had not properly designed or implemented a system of internal controls that would likely be effective in preventing, or detecting and correcting, noncompliance. The School Corporation was required to submit annual data reports to the Indiana Department of Education via JotForm, a form/report builder. Data to be submitted included, but was not limited to, current period expenditures, prior period expenditures, and expenditures per activity. All four of the reports submitted by the School Corporation were supported by the School Corporation's records. However, there was no evidence of an internal control such as a review or approval process over the data submitted on JotForm. The lack of internal controls was pervasive in the audit period. INDIANA STATE BOARD OF ACCOUNTS 16 SOUTH MONTGOMERY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 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 of the School Corporation stated that constant turnover in Administration and lack of finance staff left no knowledgeable individual to review the reports. 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, reports for the COVID-19 - Education Stabilization Fund program were prepared, entered, and submitted by one individual with no internal control to prevent or detect errors. 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 that all reports are properly reviewed before submission. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

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FINDING 2024-002 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Number: 84.425D Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, FY23/24 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Condition and Context The School Corporation had not properly designed or implemented a system of internal controls that would likely be effective in preventing, or detecting and correcting, noncompliance. The School Corporation was required to submit annual data reports to the Indiana Department of Education via JotForm, a form/report builder. Data to be submitted included, but was not limited to, current period expenditures, prior period expenditures, and expenditures per activity. All four of the reports submitted by the School Corporation were supported by the School Corporation's records. However, there was no evidence of an internal control such as a review or approval process over the data submitted on JotForm. The lack of internal controls was pervasive in the audit period. INDIANA STATE BOARD OF ACCOUNTS 16 SOUTH MONTGOMERY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 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 of the School Corporation stated that constant turnover in Administration and lack of finance staff left no knowledgeable individual to review the reports. 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, reports for the COVID-19 - Education Stabilization Fund program were prepared, entered, and submitted by one individual with no internal control to prevent or detect errors. 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 that all reports are properly reviewed before submission. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

Corrective Action Plan

FINDING 2024-002 Finding Subject: COVID-19 Education Stabilization Fund - Reporting Contact Person Responsible for Corrective Action: Kristin Charles, CFO and HR Director Contact Phone Number and Email Address: (765) 866-0203 and Kristin.charles@southmont.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: ESSER Yearly Reports to be completed by CFO and printed and will review with the superintendent. Anticipated Completion Date: ESSER III Annual Report due April 2025

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FY 2022-06-30

FAC accepted this audit on March 30, 2023 — management decision was due September 30, 2023.

2022-003
Procurement & Suspension/Debarment

During our testing, we noted Suspension and debarment checks were not performed on the contract sampled. Per the school?s procurement policy, it stated that a certification of suspension and debarment needed to be completed prior to entering into a contract for all contracts over the $25,000 threshold.Questioned costs: NoneContext: Using a statistically valid sample, 1 covered transaction was selected for testing. The Transaction selected did not have a suspension and debarment certification prior to entering in a contract with the vendor.Cause: Improper understanding and implementation of existing policies.Effect: Contracts could be entered into with suspended or debarred vendors leading to noncompliance.Repeat Finding: No.Recommendation: We recommend the South Montgomery Community School Corporation increased training for those individuals involved in procurement and contract approval to ensure suspension and debarment checks are performed prior to awarding contracts.View of Responsible Officials: There is no disagreement with the audit finding.

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2022 ? 003 ? Special Education Cluster ? Suspension and DebarmentFederal Agency: U.S. Department of EducationFederal Program Title: Special Education Cluster (IDEA)Assistance Listing Number: 84.027/84.173Federal Award Identification Number and Year: FY 21 and FY 22Pass-Through Entity: Indiana Department of EducationPass-Through Entity Number: 19611-76-PN01Award Period: July 1, 2020 through June 30, 2022Type of Finding:? Significant Deficiency in Internal Control over Compliance.Criteria: ?2 CFR 200.303 states in part:"The non-Federal entity must: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 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."Condition: During our testing, we noted Suspension and debarment checks were not performed on the contract sampled. Per the school?s procurement policy, it stated that a certification of suspension and debarment needed to be completed prior to entering into a contract for all contracts over the $25,000 threshold.Questioned costs: NoneContext: Using a statistically valid sample, 1 covered transaction was selected for testing. The Transaction selected did not have a suspension and debarment certification prior to entering in a contract with the vendor.Cause: Improper understanding and implementation of existing policies.Effect: Contracts could be entered into with suspended or debarred vendors leading to noncompliance.Repeat Finding: No.Recommendation: We recommend the South Montgomery Community School Corporation increased training for those individuals involved in procurement and contract approval to ensure suspension and debarment checks are performed prior to awarding contracts.View of Responsible Officials: There is no disagreement with the audit finding.

Corrective Action Plan

FINDING 2022-003Contact Person Responsible for Corrective Action: Kristin CharlesContact Phone Number: 765-866-0203Views of the Responsible Official: The School Corporation is in agreement with the Finding.Description of Corrective Action Plan: We have added for the upcoming contract with West Central Special Education Co-Op that they are responsible to report to us if they are under or could be under the threat of any suspension and debarment issues. We will also add this language into any other contract if we are ever in the position to use Federal Grant Funds.Anticipated Completion Date: 4/1/2023

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2022-004
Activities Allowed or Unallowed / Cost Allowability
MATERIAL WEAKNESSQUESTIONED COSTS

During our testing we that an effective internal control system was not in place to ensure compliance with requirements related to allowable costs. Additionally, time and effort procedures were not in place during the audit period.Questioned costs: Known - $80,310.67, Likely - $330,748.52. Known and questioned costs exceed program materiality.Context: In a statistically valid sample, 40 of 40 selections did not have adequate time and effort documentation along with proper timesheets, resulting in questioned costs.Cause: Per discussion with business manager and per testing performed, CLA noted the school did not have time and effort implemented, as they believe they were not required to.Effect: Activities or costs could be charged to a federal grant which do not meet the allowability standards, leading to noncompliance.Repeat Finding: No.Recommendation: We recommend the management ensure controls are consistently in place. Training over the organization's controls may be beneficial.View of Responsible Officials: There is no disagreement with the audit finding.

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2022 ? 004 ? Special Education Cluster (IDEA) Activities Allowed or Unallowed & Allowable Costs/Cost PrinciplesFederal Agency: U.S. Department of EducationFederal Program Title: Special Education Cluster (IDEA)Assistance Listing Number: 84.027/84.173Federal Award Identification Number and Year: FY 21 and FY 22Pass-Through Entity: Indiana Department of EducationPass-Through Entity Number: 19611-76-PN01Award Period: July 1, 2020 through June 30, 2022Type of Finding:? Material Weakness in Internal Control over Compliance, Material Noncompliance (Modified Opinion)Criteria: Per 2 CFR 200.430, 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 which provides reasonable assurance 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 by the non-Federal entity,(iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity's written policy;(v)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). . . ."(vi) Comply with the established accounting policies and practices of the non-Federal entity (See paragraph (h)(1)(ii) above 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 which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.Condition: During our testing we that an effective internal control system was not in place to ensure compliance with requirements related to allowable costs. Additionally, time and effort procedures were not in place during the audit period.Questioned costs: Known - $80,310.67, Likely - $330,748.52. Known and questioned costs exceed program materiality.Context: In a statistically valid sample, 40 of 40 selections did not have adequate time and effort documentation along with proper timesheets, resulting in questioned costs.Cause: Per discussion with business manager and per testing performed, CLA noted the school did not have time and effort implemented, as they believe they were not required to.Effect: Activities or costs could be charged to a federal grant which do not meet the allowability standards, leading to noncompliance.Repeat Finding: No.Recommendation: We recommend the management ensure controls are consistently in place. Training over the organization's controls may be beneficial.View of Responsible Officials: There is no disagreement with the audit finding.

Corrective Action Plan

FINDING 2022-004Contact Person Responsible for Corrective Action: Kristin CharlesContact Phone Number: 765-866-0203Views of the Responsible Official: The School Corporation is in agreement with the Finding.Description of Corrective Action Plan: This should not be an issue moving forward as now write our grant to be used for our Co-Op Bill and do not pay salaries directly. In the future if we plan to pay with Federal Funding, we will require time and effort logs.Anticipated Completion Date: 4/1/2023

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles →
2022-005
Procurement & Suspension/Debarment

During our testing, we noted Suspension and debarment checks were not performed on the contract sampled. Per the school?s procurement policy, it stated that a certification of suspension and debarment needed to be completed prior to entering into a contract for all contracts over the $25,000 threshold.Questioned costs: NoneContext: Using a statistically valid sample, 1 covered transaction was selected for testing. The Transaction selected did not have a suspension and debarment certification prior to entering in a contract with the vendor.Cause: Improper understanding and implementation of existing policies.Effect: Contracts could be entered into with suspended or debarred vendors leading to noncompliance.Repeat Finding: No.Recommendation: We recommend the South Montgomery Community School Corporation increased training for those individuals involved in procurement and contract approval to ensure suspension and debarment checks are performed prior to awarding contracts.View of Responsible Officials: There is no disagreement with the audit finding.

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2022 ? 005 ? Child Nutrition Cluster ? Suspension and DebarmentFederal Agency: U.S. Department of EducationFederal Program Title: Child Nutrition ClusterAssistance Listing Number: 10.553/10.555Federal Award Identification Number and Year: FY 21 and FY 22Pass-Through Entity: Indiana Department of EducationPass-Through Entity Number: FY 2021 and FY 2022Award Period: July 1, 2020 through June 30, 2022Type of Finding:? Significant Deficiency in Internal Control over ComplianceCriteria: ?Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. (2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209-6).?Condition: During our testing, we noted Suspension and debarment checks were not performed on the contract sampled. Per the school?s procurement policy, it stated that a certification of suspension and debarment needed to be completed prior to entering into a contract for all contracts over the $25,000 threshold.Questioned costs: NoneContext: Using a statistically valid sample, 1 covered transaction was selected for testing. The Transaction selected did not have a suspension and debarment certification prior to entering in a contract with the vendor.Cause: Improper understanding and implementation of existing policies.Effect: Contracts could be entered into with suspended or debarred vendors leading to noncompliance.Repeat Finding: No.Recommendation: We recommend the South Montgomery Community School Corporation increased training for those individuals involved in procurement and contract approval to ensure suspension and debarment checks are performed prior to awarding contracts.View of Responsible Officials: There is no disagreement with the audit finding.

Corrective Action Plan

FINDING 2022-005Contact Person Responsible for Corrective Action: Kristin CharlesContact Phone Number: 765-866-0203Views of the Responsible Official: The School Corporation is in agreement with the Finding.Description of Corrective Action Plan: We will provide additional training to our Food Service team about the processes with suspension and debarment. We had assumed we had done enough due diligence since we passed our IDOE Child Nutrition audit; on the same token that audit may not have encompassed the sample that was randomly selected by CLA. We will also add suspension and debarment language into any other contract we anyone that we enter where there is a chance that Federal Dollars could be used for the purchase.Anticipated Completion Date: ASAP

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2022-006
Special Tests & Provisions

During our testing, we noted Transfers to and from the holding account to the school lunch program were not approved by the business manager and board of school trustees. 4 out of 4 transfer samples that were selected did not have proper approval.Questioned costs: None.Context: Using a statistically valid sample, 4 of 4 selections did not have proper approval from the business manager and board of school trustees.Cause: Improper understanding and implementation of existing policies.Effect: Costs could be charged to a federal grant which do not meet the allowability standards, leading to noncompliance.Repeat Finding: No.Recommendation: We recommend the South Montgomery Community School Corporation ensures controls are consistently in place. Training over the organization's controls may be beneficial.View of Responsible Officials: There is no disagreement with the audit finding.

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2022 ? 006 ? Child Nutrition Cluster ? Special Tests and ProvisionsFederal Agency: U.S. Department of EducationFederal Program Title: Child Nutrition ClusterAssistance Listing Number: 10.553/10.555Federal Award Identification Number and Year: FY 21 and FY 22Pass-Through Entity: Indiana Department of EducationPass-Through Entity Number: FY 2021 and FY 2022Award Period: July 1, 2020 through June 30, 2022Type of Finding:? Significant Deficiency in Internal Control over ComplianceCriteria: ?An SFA is required to account for all revenues and expenditures of its non-profit school food service in accordance with state and federal requirements. An SFA must operate its food services on a non-profit basis; all revenue generated by the school food service must be used to operate and improve its food services (7 CFR sections 210.14(a), 210.14(c), 210.19(a)(2), 215.7(d)(1), 220.2, and 220.7(e)(1)(i)).?Condition: During our testing, we noted Transfers to and from the holding account to the school lunch program were not approved by the business manager and board of school trustees. 4 out of 4 transfer samples that were selected did not have proper approval.Questioned costs: None.Context: Using a statistically valid sample, 4 of 4 selections did not have proper approval from the business manager and board of school trustees.Cause: Improper understanding and implementation of existing policies.Effect: Costs could be charged to a federal grant which do not meet the allowability standards, leading to noncompliance.Repeat Finding: No.Recommendation: We recommend the South Montgomery Community School Corporation ensures controls are consistently in place. Training over the organization's controls may be beneficial.View of Responsible Officials: There is no disagreement with the audit finding.

Corrective Action Plan

FINDING 2022-006Contact Person Responsible for Corrective Action: Kristin CharlesContact Phone Number: 765-866-0203Views of the Responsible Official: The School Corporation is in agreement with the Finding.Description of Corrective Action Plan: This was the best process at the time. We are now doing negative expenditures to move the funds. The CAP is to contact another Komputrol school and see how they are processing the movement of funds from 8400 which is where the prepaid lunch money is supposed to go and how it is being moved into fund 800. The board has in essence through the superintendent for me to make posting corrections to get the amount into the proper funds. As the CFO/HR as well as the named treasurer, since this is not enough then we will work together to make sure it is clearly stated in resolution that the CFO/HR or named treasurer has the authority to make these moves in the funds.Anticipated Completion Date: ASAP

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FY 2020-06-30

FAC accepted this audit on May 11, 2021 — management decision was due November 11, 2021.

2020-002
Cash Management / Procurement & Suspension/Debarment
MATERIAL WEAKNESS

FINDING 2020-002 Subject: Child Nutrition Cluster - Cash Management and Procurement 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, 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): FY2018/2019, FY2019/2020 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Cash Management, Procurement and Suspension and Debarment Audit Finding: Material Weakness Condition and Context An internal control system was not in place at the School Corporation to ensure compliance with the requirements related to the grant agreement and the Cash Management and the Procurement and Suspension and Debarment compliance requirements. Cash Management There was no internal control in place to ensure that the balance of the School Lunch fund (net cash resources) was compared to the three months average expenditures. Procurement The Food Service Director and Director of Operations discussed the expenditures; however, there was no evidence of an internal control that would have ensured that the food service management company complied with procurement requirements. 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 Cash Management and Procurement and Suspension and Debarment compliance requirements. Effect The failure to establish a system of internal controls placed the School Corporation at risk of noncompliance with the grant agreement and the Cash Management and Procurement and Suspension and Debarment compliance requirements. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls related to the grant agreement and the Cash Management and 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.

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FINDING 2020-002 Subject: Child Nutrition Cluster - Cash Management and Procurement 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, 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): FY2018/2019, FY2019/2020 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Cash Management, Procurement and Suspension and Debarment Audit Finding: Material Weakness Condition and Context An internal control system was not in place at the School Corporation to ensure compliance with the requirements related to the grant agreement and the Cash Management and the Procurement and Suspension and Debarment compliance requirements. Cash Management There was no internal control in place to ensure that the balance of the School Lunch fund (net cash resources) was compared to the three months average expenditures. Procurement The Food Service Director and Director of Operations discussed the expenditures; however, there was no evidence of an internal control that would have ensured that the food service management company complied with procurement requirements. 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 Cash Management and Procurement and Suspension and Debarment compliance requirements. Effect The failure to establish a system of internal controls placed the School Corporation at risk of noncompliance with the grant agreement and the Cash Management and Procurement and Suspension and Debarment compliance requirements. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls related to the grant agreement and the Cash Management and 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.

Corrective Action Plan

FINDING 2020-002 Contact Person Responsible for Corrective Action: Kristin Charles Contact Phone Number: 765.866.0203 Views of Responsible Official: These things were being discussed, but we did not document appropriately. Description of Corrective Action Plan: We have updated our monthly meeting checklist, and this will be reviewed and documentation of that review monthly. Anticipated Completion Date: Immediately (we are also going to go back and add this checklist to the previously documented monthly meetings)

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2020-003
Program Income
MATERIAL WEAKNESS

FINDING 2020-003 Subject: Child Nutrition Cluster - Program Income 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, 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): FY2018/2019, FY2019/2020 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Program Income 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 the requirements related to the grant agreement and the Program Income compliance requirement. Transfers from the School Lunch Prepaid Accts fund to the School Lunch fund were made monthly; however, the transfers were not based on actual sales to students as shown on the sales activity reports provided by the Food Service Director. Due to the lack of effective internal controls, program income was overreported. The aggregate amount of the misstatement in the months selected for testing was $20,900. This is estimated to be $97,298 when projected to the population. 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 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). . . ." 7 CFR 210.14(c) states: "Financial assurances. The school food authority shall meet the requirements of the State agency for compliance with ? 210.19(a) including any separation of records of nonprofit school food service from records of any other food service which may be operated by the school food authority as provided in paragraph (a) of this section." 7 CFR 210.14(f)(3) states: "All revenue from the sale of nonprogram foods shall accrue to the nonprofit school food service account of a participating school food authority." 7 CFR 220.7(e) states in part: "Each school food authority approved to participate in the program shall enter into a written agreement with the State agency or the Department through the FNSRO, as applicable that may be amended as necessary. . . . Such agreements shall provide that the School Food Authority shall, with respect to participating schools under its jurisdiction: . . . (12) Maintain a financial management system as prescribed by the State agency, or FNSRO where applicable; . . ." Cause Management had not developed an effective system of internal controls that would have ensured compliance with the Program Income compliance requirement. 18 INDIANA STATE BOARD OF ACCOUNTS SOUTH MONTGOMERY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Effect The failure to establish an effective system of internal controls enabled noncompliance to go undetected. Noncompliance with the grant agreement and the Program Income compliance requirement could have resulted in the 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 to ensure compliance and comply with the Program Income compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

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FINDING 2020-003 Subject: Child Nutrition Cluster - Program Income 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, 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): FY2018/2019, FY2019/2020 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Program Income 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 the requirements related to the grant agreement and the Program Income compliance requirement. Transfers from the School Lunch Prepaid Accts fund to the School Lunch fund were made monthly; however, the transfers were not based on actual sales to students as shown on the sales activity reports provided by the Food Service Director. Due to the lack of effective internal controls, program income was overreported. The aggregate amount of the misstatement in the months selected for testing was $20,900. This is estimated to be $97,298 when projected to the population. 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 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). . . ." 7 CFR 210.14(c) states: "Financial assurances. The school food authority shall meet the requirements of the State agency for compliance with ? 210.19(a) including any separation of records of nonprofit school food service from records of any other food service which may be operated by the school food authority as provided in paragraph (a) of this section." 7 CFR 210.14(f)(3) states: "All revenue from the sale of nonprogram foods shall accrue to the nonprofit school food service account of a participating school food authority." 7 CFR 220.7(e) states in part: "Each school food authority approved to participate in the program shall enter into a written agreement with the State agency or the Department through the FNSRO, as applicable that may be amended as necessary. . . . Such agreements shall provide that the School Food Authority shall, with respect to participating schools under its jurisdiction: . . . (12) Maintain a financial management system as prescribed by the State agency, or FNSRO where applicable; . . ." Cause Management had not developed an effective system of internal controls that would have ensured compliance with the Program Income compliance requirement. 18 INDIANA STATE BOARD OF ACCOUNTS SOUTH MONTGOMERY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Effect The failure to establish an effective system of internal controls enabled noncompliance to go undetected. Noncompliance with the grant agreement and the Program Income compliance requirement could have resulted in the 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 to ensure compliance and comply with the Program Income compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

Corrective Action Plan

FINDING 2020-003 Contact Person Responsible for Corrective Action: Kristin Charles Contact Phone Number: 765.866.0203 Views of Responsible Official: We felt through our previous corrective action plan that we had met this requirement. We have setup fund 8400 and maintained the balance in fund 8400 that if every single person with money on prepaid accounts asked for a refund, we would be able to comply while also making sure daily balances were balanced at the building level. Description of Corrective Action Plan: We will work with Chartwells and our POS system to see what reports we can generate to meet this request. Anticipated Completion Date: By June 30th, 2021

About Program Income →
2020-004
Period of Performance
MATERIAL WEAKNESSREPEAT

FINDING 2020-004 Subject: Special Education Cluster - Period of Performance 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): 14217-076-PN01, 18611-076-PN01, 45717-076-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Period of Performance 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 2018-007. 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 Period of Performance compliance requirement. Federal funds for the Special Education Cluster (IDEA) were not separated for each grant year. The intermingling of funds did not allow the testing of the Period of Performance compliance requirement. The lack of internal controls was a systemic issue, which occurred throughout the audit period. The lack of supporting documentation prevented the determination of the School Corporation's compliance with the Period of Performance compliance requirement. 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 200.302(b)(3) states: "Records that identify adequately the source and application of funds for federally-funded activities. These records must contain information pertaining to Federal awards, authorizations, obligations, unobligated balances, assets, expenditures, income and interest, and be supported by documentation." 2 CFR 200.333 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." Cause Management had not developed a system of internal controls that would have ensured that supporting documentation related to the Period of Performance compliance requirement was maintained and made available for audit. Effect The failure to establish an internal control system and provide sufficient supporting documentation prevented the determination of the School Corporation's compliance with the grant agreement and the Period of Performance compliance requirement. 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 that documentation related to the grant agreement and the Period of Performance compliance requirement will be maintained and available for audit. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report. 21 INDIANA STATE

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FINDING 2020-004 Subject: Special Education Cluster - Period of Performance 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): 14217-076-PN01, 18611-076-PN01, 45717-076-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Period of Performance 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 2018-007. 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 Period of Performance compliance requirement. Federal funds for the Special Education Cluster (IDEA) were not separated for each grant year. The intermingling of funds did not allow the testing of the Period of Performance compliance requirement. The lack of internal controls was a systemic issue, which occurred throughout the audit period. The lack of supporting documentation prevented the determination of the School Corporation's compliance with the Period of Performance compliance requirement. 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 200.302(b)(3) states: "Records that identify adequately the source and application of funds for federally-funded activities. These records must contain information pertaining to Federal awards, authorizations, obligations, unobligated balances, assets, expenditures, income and interest, and be supported by documentation." 2 CFR 200.333 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." Cause Management had not developed a system of internal controls that would have ensured that supporting documentation related to the Period of Performance compliance requirement was maintained and made available for audit. Effect The failure to establish an internal control system and provide sufficient supporting documentation prevented the determination of the School Corporation's compliance with the grant agreement and the Period of Performance compliance requirement. 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 that documentation related to the grant agreement and the Period of Performance compliance requirement will be maintained and available for audit. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report. 21 INDIANA STATE

Corrective Action Plan

FINDING 2020-004 Contact Person Responsible for Corrective Action: Kristin Charles Contact Phone Number: 765.866.0203 Views of Responsible Official: This was completed, but not for the entire audit period and we understood that this would still be on this audit. Description of Corrective Action Plan: We will continue to maintain the separate funds for each special ed grant to help ensure no comingling of funds/grants. Anticipated Completion Date: Completed

Prior Finding References

2018-007

About Period of Performance →

FY 2018-06-30

FAC accepted this audit on March 31, 2019 — management decision was due October 1, 2019.

2018-003
Program Income
MATERIAL WEAKNESSREPEAT

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2016-003

About Program Income →
2018-004
Reporting
MATERIAL WEAKNESS

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

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2018-005
Reporting
MATERIAL WEAKNESS

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

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2018-006
Cost Allowability
MATERIAL WEAKNESS

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Allowable Costs / Cost Principles →
2018-007
Period of Performance
MATERIAL WEAKNESS

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

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FY 2016-06-30

FAC accepted this audit on July 23, 2018 — management decision was due January 23, 2019.

2016-003
Program Income
MATERIAL WEAKNESS

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Program Income →
2016-004
Reporting
MATERIAL WEAKNESS

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

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2016-005
Cash Management
MATERIAL WEAKNESS

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Cash Management →
2016-006
Period of Performance
MATERIAL WEAKNESS

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Period of Performance →

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