Carroll Consolidated School Corporation

EIN: 356006836

UEI: T61DJU7DKPG5

Data as of August 19, 2026

3
Audit Years
8
Total Findings
1
Repeat Findings

FY 2022-06-30

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on March 27, 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 27, 2023, which was (1058 days ago).

What is a management decision? →
2022-002
Cost Allowability
REPEATMATERIAL WEAKNESS
Condition

FINDING 2022-002 Information on the federal program: Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Allowable Costs/Cost Principles Audit Finding: Material Weakness Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 7 CFR 210.21(f)(1) states in part: ". . . (ii)(A) The contractor must separately identify for each cost submitted for payment to the school food authority the amount of that cost that is allowable (can be paid from the nonprofit school food service account) and the amount that is unallowable (cannot be paid from the nonprofit school food service account); or (B) The contractor must exclude all unallowable costs from its billing documents and certify that only allowable costs are submitted for payment and records have been established that maintain the visibility of unallowable costs, including directly associated costs in a manner suitable for contract cost determination and verification; (iii) The contractor's determination of its allowable costs must be made in compliance with the applicable Departmental and Program regulations and Office of Management and Budget cost circulars; . . . (vi) The contractor must maintain documentation of costs and discounts, rebates and other applicable credits, and must furnish such documentation upon request to the school food authority, the State agency, or the Department." Condition: 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 requirements. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with the compliance requirements listed above. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. A lack of proper internal controls could have allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There were no questioned costs identified. Context: During testing of 12 vendor disbursements for allowable costs/cost principles, we noted there was one month where there was no documented review by the School Corporation?s Business Manager of expenditures paid to the Food Service Management company by the School Corporation?s Business Manager. The only review was performed by the Food Services Director, who is a Food Service Management company employee. We tested six other monthly submissions of Food Service Management company disbursements and noted they were all appropriately reviewed by the School Corporation with supporting documentation attached. Identification as a repeat finding, if applicable: Yes. Previously identified as finding 2020-002 in the 2020 audit report. Recommendation: We recommend that the School Corporation establish a review control to ensure that costs charged by the food service management company relate to food services and are allowable under the federal compliance requirements. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.

Corrective Action Plan

FINDING 2022-002 Information on the federal program: Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Allowable Costs/Cost Principles Audit Finding: Material Weakness Condition: 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 requirements. Context: During testing of 12 vendor disbursements for allowable costs/cost principles, we noted there was one month where there was no documented review by the School Corporation?s Business Manager of expenditures paid to the Food Service Management Company by the School Corporation?s Business Manager. The only review was performed by the Food Services Director, who is a Food Service Management company employee. We tested six other monthly submissions of Food Service Management company disbursements and noted they were all appropriately reviewed by the School Corporation with supporting documentation attached. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The missing signature appears to be an uncommon oversight within our current system of internal controls. The Superintendent and FSMC Food Service Director will make it a point to review signature pages for both signatures at each monthly financial review. Responsible Party and Timeline for Completion: Superintendent and FSMC Food Service Director discussed this finding on 3/15/2023 and will put corrective action in place immediately.

Prior Finding References

2020-002

About Allowable Costs / Cost Principles →
2022-003
Procurement & Suspension/Debarment
MATERIAL WEAKNESS
Condition

FINDING 2022-003 Information on the federal program: Subject: Child Nutrition Cluster ? Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Material Weakness 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 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." Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the Child Nutrition Program and Procurement and Suspension and Debarment compliance requirements for purchases made outside of the purchasing cooperative. Cause: The School Corporation's management had not developed a system of internal controls that would have ensured compliance with the Procurement and Suspension and Debarment compliance requirement for purchases made outside of the purchasing cooperative. Effect: The failure to establish internal controls could have enabled noncompliance to go undetected. If the vendor that was used outside of the purchasing cooperative would have been suspended or debarred, the failure to comply with the grant agreement and the compliance requirement could have resulted in the loss of federal funds to the School Corporation. Questioned Costs: There were no questioned costs identified. Context: During the audit period, the School Corporation had purchases between $10,000 and $150,000 from four vendors which fall under the small purchase method for federal and state procurement regulations and were charged to Fund 0800 ? School Lunch Fund. For one vendor selected for testing, documentation was not presented to verify the School Corporation had performed checks to assure the vendor was not suspended or debarred prior to entering into the transaction in order to satisfy the suspended and debarment requirements. Identification as a repeat finding, if applicable: No Recommendation: We recommended that the School Corporation's management establish and implement control procedures to ensure compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. This should include ensuring suspension and debarment checks are performed and documented prior to entering into the transaction. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.

Corrective Action Plan

FINDING 2022-003 Information on the federal program: Subject: Child Nutrition Cluster ? Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Material Weakness Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the Child Nutrition Program and Procurement and Suspension and Debarment compliance requirements for purchases made outside of the purchasing cooperative. Context: During the audit period, the School Corporation had purchases between $10,000 and $150,000 from four vendors which fall under the small purchase method for federal and state procurement regulations and were charged to Fund 0800 ? School Lunch Fund. For one vendor selected for testing, documentation was not presented to verify the School Corporation had performed checks to assure the vendor was not suspended or debarred prior to entering into the transaction in order to satisfy the suspended and debarment requirements. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Moving forward, the SAMS website will be utilized to confirm that purchases from vendors that are between the $10,000 and $150,000 threshold are not suspended or debarred prior to entering into transactions. Responsible Party and Timeline for Completion: The Superintendent or Superintendent?s designee will be the responsible party. This correction will be put into effect 3/15/2023.

About Procurement and Suspension and Debarment →
2022-004
Reporting
MATERIAL WEAKNESS
Condition

FINDING 2022-004 Information on the federal program: Subject: Child Nutrition Cluster ? Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the reporting compliance requirement. Cause: The School Corporation's management had not developed a system of internal controls to ensure accurate information was presented in order to be in compliance with the reporting requirements. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. A lack of effective reviews could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by the review process not ensuring there was accurate reporting of the activities of the programs. Questioned Costs: There were $356 of known questioned costs identified. Context: We noted that for two claims in a sample of four, there was no formal evidence of the sponsor claim reimbursement summary being reviewed by someone independent of who prepared the sponsor claim reimbursement summary prior to submission. We noted that for one claim in a sample of four, the meal counts were over/under claimed for the month. We noted that in October 2020 the School Corporation had overclaimed lunches by 175 meals and underclaimed breakfast by 156 meals. Identification as a repeat finding, if applicable: No. Recommendation: We recommend that the School Corporation establish a review control to verify the sponsor claim reimbursement summaries are correct and agree to the underlying detail. This review should be performed by someone other than the individual submitting the claims and we recommend this review be formally documented. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.

Corrective Action Plan

FINDING 2022-004 Information on the federal program: Subject: Child Nutrition Cluster ? Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the reporting compliance requirement. Context: We noted that for two claims in a sample of four, there was no formal evidence of the sponsor claim reimbursement summary being reviewed by someone independent of who prepared the sponsor claim reimbursement summary prior to submission. We noted that for one claim in a sample of four, the meal counts were over/under claimed for the month. We noted that in October 2020 the School Corporation had overclaimed lunches by 175 meals and underclaimed breakfast by 156 meals. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Superintendent is now utilizing the personalized login on CNP Web to review claims before final submission. The superintendent will also email approval of claims to the FSMC Food Service Director upon submission and approval by the superintendent on CNP Web. Responsible Party and Timeline for Completion: The Superintendent and FSMC Food Service Director will be the responsible parties and the corrective action will take place immediately (3/15/2023).

About Reporting →
2022-005
Cash Management
MATERIAL WEAKNESS
Condition

FINDING 2022-005 Information on the federal program: Subject: COVID-19 ? Education Stabilization Fund ? Cash Management, Other Matters Federal Agency: Department of Education Federal Program: Elementary and Secondary School Emergency Relief (ESSER II) Fund Assistance Listing Number: 84.425D Pass-Through Entity: Indiana Department of Education Compliance Requirement: Cash Management Audit Finding: Material Weakness, Noncompliance, Other Matters Criteria: 2 CFR section 200.303 states in part: ?The non-Federal entity must: ? Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in `Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the `Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)?.? Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the cash management compliance requirements for the COVID-19 ? Education Stabilization Fund. Cause: The School Corporation?s management had not developed a system of internal controls to ensure compliance with the compliance requirements listed above. Effect: The failure to establish an effective internal control system enabled noncompliance with the grant agreement and the compliance requirements. A lack of an internal control system allowed noncompliance with the compliance requirements and could 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 no questioned costs identified. Context: During our audit procedures, we noted that in fiscal year 2021, the School Corporation had drawn down $108,445 more in ESSER II funds than what they had expended. The School Corporation received $297,500 of ESSER II funds during fiscal year 2021, but had only disbursed $189,055. The School Corporation spent $107,361 of the remaining funds during fiscal year 2022 and had an ending balance of $1,084 as of June 30, 2022. The ESSER II grant is a cost reimbursement grant and therefore, the School Corporation should not have drawn down these funds prior to the expenses being incurred. Identification as a repeat finding, if applicable: No. Recommendation: We recommend that the School Corporation establish an internal control that would ensure funds from cost reimbursement grants are not requested prior to the expenses being incurred. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.

Corrective Action Plan

FINDING 2022-005 Information on the federal program: Subject: COVID-19 ? Education Stabilization Fund ? Cash Management, Other Matters Federal Agency: Department of Education Federal Program: Elementary and Secondary School Emergency Relief (ESSER II) Fund Assistance Listing Number: 84.425D Pass-Through Entity: Indiana Department of Education Compliance Requirement: Cash Management Audit Finding: Material Weakness, Noncompliance, Other Matters Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the cash management compliance requirements for the COVID-19 ? Education Stabilization Fund. Context: During our audit procedures, we noted that in fiscal year 2021, the School Corporation had drawn down $108,445 more in ESSER II funds than what they had expended. The School Corporation received $297,500 of ESSER II funds during fiscal year 2021, but had only disbursed $189,055. The School Corporation spent $107,361 of the remaining funds during fiscal year 2022 and had an ending balance of $1,084 as of June 30, 2022. The ESSER II grant is a cost reimbursement grant and therefore, the School Corporation should not have drawn down these funds prior to the expenses being incurred. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Superintendent and/or the Superintendent?s designees will not request funds from reimbursable grants before expenditures have been made by the corporation. Responsible Party and Timeline for Completion: The responsible parties are the Superintendent and/or the Superintendent?s designees. The corrective action will take place immediately (3/15/2023).

About Cash Management →

FY 2020-06-30

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on April 21, 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 October 21, 2021, which was (1764 days ago).

What is a management decision? →
2020-002
Cost Allowability / Program Income / Special Tests & Provisions
MATERIAL WEAKNESSQUESTIONED COSTS
Condition

FINDING 2020-002 Subject: Child Nutrition Cluster - Allowable Costs/Cost Principles, Program Income, Special Tests and Provisions - School Food Accounts 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 CFDA Numbers: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY 2019, FY 2020 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Allowable Costs/Cost Principles, Program Income, Special Tests and Provisions - School Food Accounts 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 Allowable Costs/Cost Principles, Program Income, and Special Tests and Provisions - School Food Accounts compliance requirements. The School Corporation had not designed or implemented adequate policies and procedures to ensure that program costs were supported by proper documentation, were allowable, and only for the operation of the food service program. In addition, there were no internal controls to ensure that food service program sales were properly recorded in the School Lunch fund. Allowable Costs/Cost Principles, Program Income, Special Tests and Provisions - School Food Accounts The School Corporation entered into a cost-reimbursement contract, dated November 7, 2018, with a food service management company. Eleven invoices for payment to the food service management company, which totaled $139,802, were selected for testing. Supporting documentation was presented for only $9,554 of the costs invoiced. Due to the lack of documentation, we were unable to determine if the remaining costs paid, $130,248, were allowable expenditures, and therefore, proper uses of program income for the federal programs. The costs that were not properly documented were considered questioned costs. Program Income, Special Tests and Provisions - School Food Accounts The School Corporation had not designed or implemented adequate policies and procedures to ensure that the food service program sales were properly recorded in the School Lunch fund. The federal reimbursement claim for November 2019 was resubmitted to correct the eligibility status of some students after an Indiana Department of Education Administrative Review. The monthly transfer of the amount of consumed meals from the Prepaid Food fund to the School Lunch fund had already been posted based upon the original meal counts and, therefore, was incorrect. No adjustment was made to account for this correction. In addition, adult meal counts for November 2019 and January 2020 were requested, but not provided for audit. The lack of internal controls, noncompliance, and failure to maintain adequate supporting documentation of program costs 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 210.21(f)(1) states in part: ". . . (ii)(A) The contractor must separately identify for each cost submitted for payment to the school food authority the amount of that cost that is allowable (can be paid from the nonprofit school food service account) and the amount that is unallowable (cannot be paid from the nonprofit school food service account); or (B) The contractor must exclude all unallowable costs from its billing documents and certify that only allowable costs are submitted for payment and records have been established that maintain the visibility of unallowable costs, including directly associated costs in a manner suitable for contract cost determination and verification; (iii) The contractor's determination of its allowable costs must be made in compliance with the applicable Departmental and Program regulations and Office of Management and Budget cost circulars; . . . (vi) The contractor must maintain documentation of costs and discounts, rebates and other applicable credits, and must furnish such documentation upon request to the school food authority, the State agency, or the Department." 7 CFR 210.14 states in part: "(a) Nonprofit school food service. School food authorities shall maintain a nonprofit school food service. Revenues received by the nonprofit school food service are to be used only for the operation or improvement of such food service, except that, such revenues shall not be used to purchase land or buildings, unless otherwise approved by FNS, or to construct buildings. Expenditures of nonprofit school food service revenues shall be in accordance with the financial management system established by the State agency under ? 210.19(a) of this part. . . . (c) 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. . . . (f)(3) 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: . . . (1)(ii) In accordance with the financial management system established under ? 220.13(i) of this part, use all revenues received by such food service only for the operation or improvement of that food service . . . (12) Maintain a financial management system as prescribed by the State agency, or FNSRO where applicable; . . ." Cause The School Corporation's management had not developed a system of internal controls that would have ensured compliance or that supporting documentation would have been maintained and made available for audit related to the compliance requirements listed above. Effect The failure to retain and provide appropriate supporting documentation prevented the determination of the School Corporation's compliance with the compliance requirements listed above. Questioned Costs Known questioned costs of $130,248 were identified in the Condition and Context. Recommendation We recommended that the School Corporation's management establish internal controls to ensure that documentation will be maintained and made available for audit related to the grant agreement and the Allowable Costs/Cost Principles, Program Income, and Special Tests and Provisions ? School Food Accounts 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: Lisa Beaver Contact Phone Number: 574-967-4113 ext. 1008 Views of Responsible Official: Treasurer concurs with finding. Description of Corrective Action Plan: FSMC will provide all backup documentation of the Chartwells subsidy invoice to the SFA every month. This will include the following Food Invoices, Labor Sheets, rebates and Other Costs. This will allow the SFA to review and ensure that all cost are allowable to the school food service fund. Regarding Monthly Claims: SFA and Chartwells will continue the same process regarding monthly claims. The SFA will review the claims versus the Point of Sale claim report to ensure that all meals were claimed correctly. If IDOE makes a correction, the SFA and Chartwells will communicate the correction to each other to ensure that all past claims for the month are recorded correctly. Anticipated Completion Date: Will begin fulfilling corrective action plan April 12, 2021

About Allowable Costs / Cost Principles, Program Income, Special Tests and Provisions →
2020-003
Procurement & Suspension/Debarment
MATERIAL WEAKNESS
Condition

FINDING 2020-003 Subject: Child Nutrition Cluster - 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 CFDA Numbers: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY 2019, FY 2020 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment 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 Procurement and Suspension and Debarment compliance requirement. The School Corporation contracted with a food service management company (FSMC) for the operation of the food service program. The School Corporation did not have policies or procedures to ensure compliance with procurement requirements to verify that the invoices submitted to the School Corporation were those actually paid by the FSMC, or to ensure that the FSMC invoices included credits for any discounts, rebates, or other credits. The School Corporation did not request, nor did the FSMC provide, documentation to verify that the invoices received by the School Corporation resulted from and contained the same invoices that were paid by the FSMC. The School Corporation also did not verify the return of discounts, rebates, or credits from the FSMC. The lack of internal controls and noncompliance were systemic issues throughout the FSMC contract period during 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 210.21(f)(1)(vi) states: "The contractor must maintain documentation of costs and discounts, rebates and other applicable credits, and must furnish such documentation upon request to the school food authority, the State agency, or the Department." Cause The School Corporation's 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 material noncompliance to go undetected. Noncompliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement 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 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.

Corrective Action Plan

FINDING 2020-003 Contact Person Responsible for Corrective Action: Lisa Beaver Contact Phone Number: 574-967-4113 ext. 1008 Views of Responsible Official: Treasurer concurs with finding. Description of Corrective Action Plan: All rebates and credits are issued on the monthly Chartwells subsidy invoice to the SFA. The FSMC will provide backup documentation to the SFA regarding the details of these rebates upon request of the SFA. This will be completed by September 30th of each school year. Anticipated Completion Date: Will begin fulfilling corrective action plan April 12, 2021

About Procurement and Suspension and Debarment →
2020-004
Eligibility
MATERIAL WEAKNESS
Condition

FINDING 2020-004 Subject: Child Nutrition Cluster - Eligibility 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 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: Eligibility 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 Eligibility compliance requirement. Parents submitted free and reduced-price meal applications for the food service program, which was the basis for the determination of the students' eligibility status. The School Corporation was unable to provide 55 out of 88 (63 percent) paper and online applications for fiscal year 2018-2019; therefore, we were unable to determine the School Corporation's compliance with the Eligibility compliance requirement. The lack of internal controls and failure to retain supporting documentation was a systemic issue during 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 200.302(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 source 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 The School Corporation's management had not developed a system of internal controls that would have ensured that supporting documentation was maintained and made available for audit related to the Eligibility compliance requirement. Effect The failure to retain and provide appropriate supporting documentation prevented the determination of the School Corporation's compliance with the Eligibility compliance requirement for 2018-2019. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish internal controls to ensure that documentation will be maintained and made available for audit related to the grant agreement and the Eligibility 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 2020-004 Contact Person Responsible for Corrective Action: Lisa Beaver Contact Phone Number: 574-967-4113 ext. 1008 Views of Responsible Official: Treasurer concurs with finding. Description of Corrective Action Plan: This corrective action given to SFA was issued before FSMC was contracted with the SFA. Current process between SFA and FSMC will continue. This process is defined below: ? All Applications will be processed by FSMC Food Service Director- Signed ? All Applications will be reviewed a second time by food unit lead- Initialed ? All Applications will be sent to the SFA for review and initials ? All applications will be placed in a binder marked by school year and stored at SFA administration building Anticipated Completion Date: Will begin fulfilling corrective action plan April 12, 2021

About Eligibility →
2020-005
Special Tests & Provisions
MATERIAL WEAKNESS
Condition

FINDING 2020-005 Subject: Child Nutrition Cluster - Special Tests and Provisions - Paid Lunch Equity Federal Agency: Department of Agriculture Federal Programs: National School Lunch Program, COVID-19 - National School Lunch Program CFDA Number: 10.555 Federal Award Number and Year (or Other Identifying Number): FY 2019 Pass-Through Entity: Indiana Department of Education Compliance Requirement: 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 Special Tests and Provisions - Paid Lunch Equity compliance requirement. The paid lunch equity calculations for fiscal year 2018-2019 were prepared by the Food Service Director without a system of oversight, review, or approval before submission of the calculation to the Indiana Department of Education. The lack of internal controls was isolated to 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). . . ." Cause The School Corporation's management had not developed a system of internal controls to ensure compliance with the Special Tests and Provisions - Paid Lunch Equity compliance requirement. Effect The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the Special Tests and Provisions - Paid Lunch Equity 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 compliance with the grant agreement and the Special Tests and Provisions - Paid Lunch Equity 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 2020-005 Contact Person Responsible for Corrective Action: Lisa Beaver Contact Phone Number: 574-967-4113 ext. 1008 Views of Responsible Official: Treasurer concurs with finding. Description of Corrective Action Plan: This corrective action given to SFA was issued before FSMC was contracted with the SFA. Current process between SFA and FSMC will continue. This process is defined below: ? FSMC Food Service Director will gather PLE info and submit to district manager via email for a second review ? FSMC Food Service Director will send to Superintendent and Business Manager via email for review ? Superintendent will review and submit to DOE via email for final approval ? Superintendent will keep email thread as proof DOE approves ? PLE will be sent to the School Board for final approval Anticipated Completion Date: Will begin fulfilling corrective action plan April 12, 2021

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