EIN: 356006868
UEI: YCUMA5JMRK66
Audit also covers EIN: 356004915 · unlinked EINs have no separate FAC filing
Audited by: Crowe LLP
Oversight agency: 84 [Department of Education]
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Data as of September 2, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 21, 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 21, 2025 (347 days ago).
What is a management decision? →An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the eligibility compliance requirement. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with eligibility requirements. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There were no questioned costs identified. Context: During testing over controls for eligibility, for 16 of the 60 applications selected, we noted there was no formal evidence that the applications had been reviewed and further, the application did not specify if the student was eligible for free or reduced lunch. We also noted for 2 of the 60 selections, management was unable to provide support for the student that was selected. Identification as a repeat finding, if applicable: No. Recommendation: We recommended that the School Corporation's management establish a system of internal controls related to the grant agreement and eligibility compliance requirements. We recommend the School Corporation’s management ensure all documentation to support the applicant is maintained in a secure location. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Show full finding ▾Hide full finding ▴Information on the federal program: Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY2023, FY2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Finding: Material Weakness Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the eligibility compliance requirement. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with eligibility requirements. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There were no questioned costs identified. Context: During testing over controls for eligibility, for 16 of the 60 applications selected, we noted there was no formal evidence that the applications had been reviewed and further, the application did not specify if the student was eligible for free or reduced lunch. We also noted for 2 of the 60 selections, management was unable to provide support for the student that was selected. Identification as a repeat finding, if applicable: No. Recommendation: We recommended that the School Corporation's management establish a system of internal controls related to the grant agreement and eligibility compliance requirements. We recommend the School Corporation’s management ensure all documentation to support the applicant is maintained in a secure location. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY2023, FY2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Finding: Material Weakness Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the eligibility compliance requirement. Context: During testing over controls for eligibility, for 16 of the 60 applications selected, we noted there was no formal evidence that the applications had been reviewed and further, the application did not specify if the student was eligible for free or reduced lunch. We also noted for 2 of the 60 selections, management was unable to provide support for the student that was selected. Corrective Action Plan: The Food Services Director and the Treasurer will both sign off on the applications once they have completed their review to determine if the application was accurately denied or approved for free or reduced meals. The completed and reviewed applications will be maintained in a safe and secure location, so they are easily accessible in an instance where they would need to be referenced. Person responsible for implementation and projected implementation date: The Food Services Director and the Corporation Treasurer will implement the corrective action plan starting with applications received for the 2025-2026 school year.
FAC accepted this audit on March 29, 2023 — management decision was due September 29, 2023.
An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirements. 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 segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There were no questioned costs identified. Context: For the audit period, there were two vendors that fell within the small purchases procurement threshold. Small purchases are those vendors that the School Corporation has purchased between $10,000 - $150,000 of products and goods. During the testing of Procurement and Suspension and Debarment, we noted one instance in a sample of one, where the School Corporation did not obtain price or rate quotations from other vendors or document the basis for purchasing from the vendor that was utilized. The amount disbursed to the vendor in fiscal year 2021 and 2022 was $32,638 and $39,945, respectively. In fiscal year 2022, the School Corporation stated they had obtained two quotes, but was not able to provide documentation supporting two quotes were obtained. The School Corporation was not able to provide verification that the vendor was not suspended or debarred. The lack of controls and noncompliance occurred throughout the audit period. Identification as a repeat finding, if applicable: No. Recommendation: We recommended that the School Corporation's management establish controls related to the grant agreement and the small purchase procurement method of the Procurement and Suspension and Debarment compliance requirement. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Show full finding ▾Hide full finding ▴FINDING 2022-002 Information on the federal program: Subject: Special Education Cluster - Procurement Federal Agency: Department of Education Federal Program: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Number: 84.027 and 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 20611-068-PN01, 21611-068-PN01, 20619-068-PN01, 21619-068-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Material Weakness, Noncompliance, Qualified Opinion 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). . . ." 2 CFR 200.318 states: "(i) The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price." 2 CFR 200.320 states: "(b) Procurement by small purchase procedures. Small purchase procedures are those relatively simple and informal procurement methods for securing services, supplies, or other property that do not cost more than the Simplified Acquisition Threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources. 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 Procurement and Suspension and Debarment 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 segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There were no questioned costs identified. Context: For the audit period, there were two vendors that fell within the small purchases procurement threshold. Small purchases are those vendors that the School Corporation has purchased between $10,000 - $150,000 of products and goods. During the testing of Procurement and Suspension and Debarment, we noted one instance in a sample of one, where the School Corporation did not obtain price or rate quotations from other vendors or document the basis for purchasing from the vendor that was utilized. The amount disbursed to the vendor in fiscal year 2021 and 2022 was $32,638 and $39,945, respectively. In fiscal year 2022, the School Corporation stated they had obtained two quotes, but was not able to provide documentation supporting two quotes were obtained. The School Corporation was not able to provide verification that the vendor was not suspended or debarred. The lack of controls and noncompliance occurred throughout the audit period. Identification as a repeat finding, if applicable: No. Recommendation: We recommended that the School Corporation's management establish controls related to the grant agreement and the small purchase procurement method of the Procurement and Suspension and Debarment compliance requirement. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
FINDING 2022-002 Information on the federal program: Subject: Special Education Cluster - Procurement Federal Agency: Department of Education Federal Program: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Number: 84.027 and 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 20611-068-PN01, 21611-068-PN01, 20619-068-PN01, 21619-068-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Material Weakness, Noncompliance, Qualified Opinion 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 Procurement and Suspension and Debarment compliance requirements. Context: For the audit period, there were two vendors that fell within the small purchases procurement threshold. Small purchases are those vendors that the School Corporation has purchased between $10,000 - $150,000 of products and goods. During the testing of Procurement and Suspension and Debarment, we noted one instance in a sample of one, where the School Corporation did not obtain price or rate quotations from other vendors or document the basis for purchasing from the vendor that was utilized. The amount disbursed to the vendor in fiscal year 2021 and 2022 was $32,638 and $39,945, respectively. In fiscal year 2022, the School Corporation stated they had obtained two quotes, but was not able to provide documentation supporting two quotes were obtained. The School Corporation was not able to provide verification that the vendor was not suspended or debarred. The lack of controls and noncompliance occurred throughout the audit period. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Director of Special Services will conduct the search for individuals to fill the specialized or high-need positions required. If the positions are not filled by employees of Centerville-Abington Community Schools (CACS) then a search for vendors providing the services is conducted. The Director of Special Services will obtain quotes from an adequate number of qualified sources, three if possible. The quotes will be submitted to the Superintendent of CACS for review, sign & dated and returned to the Director. The reviewed quotes will be maintained in each FY grant folder. The Director will also maintain a memo of the procedure for filling the specialized or high-need positions. The memo will also be reviewed by the Superintendent of CACS each year and maintained in each FY grant folder. If a vendor is selected to fill the positions the Director of Special Services will conduct the suspension & debarment search on each vendor contracted. The suspension & debarment search documents will be printed and sent to the Superintendent of CACS for review, sign & dated and returned to the Director. The reviewed suspension & debarment documents will be maintained in each FY grant folder. Copies of all of A District Accredited School Corporation Since 2007 the above described reviewed, signed & dated documents will be filed in each FY grant folder maintained by the Corporation Treasurer of CACS. Responsible Party and Timeline for Completion: The Director of Special Services will conduct the search for qualified individuals or vendors to fill the specialized or high-need positions as soon as the need is identified or as positions become open. If an individual is not hired as an employee of CACS then quotes will be obtained & a vendor will be contracted. If a vendor is contracted the Director of Special Services will conduct the suspension & debarment search within three business days of selecting the vendor. All required documents will be sent to the Superintendent within three business days of receipt of each document. The Superintendent will return reviewed, signed & dated documents to the Director within three business days. Copies will be provided to the Corporation Treasurer at the same time they are sent to the Director. These procedures will be implemented immediately.
An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirements. 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 segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There were no questioned costs identified. Context: For the audit period, there were four vendors that fell within the small purchases procurement threshold. Small purchases are those vendors that the School Corporation has purchased between $10,000 - $150,000 of products and goods. During the testing of Procurement and Suspension and Debarment, we noted one instance in a sample of one, where the School Corporation did not obtain three price or rate quotations from other vendors or document the basis for purchasing form the vendor that was utilized. The School Corporation compared the prices from the selected vendor to one vendor from their purchasing cooperative but did not obtain any additional quotes to meet the three-quote requirement for the small purchases procurement threshold. The lack of controls and noncompliance occurred throughout the audit period. Identification as a repeat finding, if applicable: Yes. Was identified as finding 2020-001 in the prior audit. Recommendation: We recommended that the School Corporation's management establish controls related to the grant agreement and the small purchase procurement method of the Procurement and Suspension and Debarment compliance requirement. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Show full finding ▾Hide full finding ▴FINDING 2022-003 Information on the federal program: Subject: Child Nutrition Cluster - Procurement Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553 and 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY2021, FY2022 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment 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). . . ." 2 CFR 200.318 states: "(i) The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price." 2 CFR 200.320 states: "(b) Procurement by small purchase procedures. Small purchase procedures are those relatively simple and informal procurement methods for securing services, supplies, or other property that do not cost more than the Simplified Acquisition Threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources. 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 Procurement and Suspension and Debarment 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 segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There were no questioned costs identified. Context: For the audit period, there were four vendors that fell within the small purchases procurement threshold. Small purchases are those vendors that the School Corporation has purchased between $10,000 - $150,000 of products and goods. During the testing of Procurement and Suspension and Debarment, we noted one instance in a sample of one, where the School Corporation did not obtain three price or rate quotations from other vendors or document the basis for purchasing form the vendor that was utilized. The School Corporation compared the prices from the selected vendor to one vendor from their purchasing cooperative but did not obtain any additional quotes to meet the three-quote requirement for the small purchases procurement threshold. The lack of controls and noncompliance occurred throughout the audit period. Identification as a repeat finding, if applicable: Yes. Was identified as finding 2020-001 in the prior audit. Recommendation: We recommended that the School Corporation's management establish controls related to the grant agreement and the small purchase procurement method of the Procurement and Suspension and Debarment compliance requirement. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Information on the federal program: Subject: Child Nutrition Cluster - Procurement Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553 and 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY2021, FY2022 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 grant agreement and the Procurement and Suspension and Debarment compliance requirements. Context: For the audit period, there were four vendors that fell within the small purchases procurement threshold. Small purchases are those vendors that the School Corporation has purchased between $10,000 - $150,000 of products and goods. During the testing of Procurement and Suspension and Debarment, we noted one instance in a sample of one, where the School Corporation did not obtain three price or rate quotations from other vendors or document the basis for purchasing form the vendor that was utilized. The School Corporation compared the prices from the selected vendor to one vendor from their purchasing cooperative but did not obtain any additional quotes to meet the three-quote requirement for the small purchases procurement threshold. The lack of controls and noncompliance occurred throughout the audit period. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Food Service Director (FSD) will obtain a minimum of three price or rate quotes for each vendor with expected purchases of $10,000 to $150,000 each school year. Those quotes may be from vendors within and/or outside of the purchasing cooperative. Those quotes will be sent to the Assistant Superintendent who will then present those quotes with a recommendation to the School Board at a meeting open to the public. The School Board will award the appropriate vendor with the purchase of goods for the school year. The discussion, vote and award will be noted in the minutes of the school board meeting. The Assistant Superintendent will notify the FSD of the school board?s decision via email with signed & dated quotes attached. The FSD will maintain copies of all quotes including the quotes that were not accepted in each school year folder. The FSD will send suspension & debarment documents to the Assistant Superintendent for review, signature and date within three business days of selection of the vendor. The Assistant Superintendent will return the suspension & debarment documents to the FSD within three business days of receipt of the documents. The FSD will maintain all reviewed, signed & dated documents in each school year folder. Responsible Party and Timeline for Completion: The corrective action plan will take effect immediately. All tasks will be completed before each new school year begins. The FSD is responsible to obtain three rate or price quotes. The FSD will conduct the suspension & debarment search. The FSD is responsible A District Accredited School Corporation Since 2007 to maintain the files for each school year. The FSD will send all required information to the Assistant Superintendent. The Assistant Superintendent will present and make recommendations to the School Board. The Assistant Superintendent will notify the FSD of the School Board?s decision. SUMMARY
2020-001
FAC accepted this audit on June 24, 2021 — management decision was due December 24, 2021.
FINDING 2020-001 Subject: Child Nutrition Cluster - Procurement Federal Agency: Department of Agriculture Federal Programs: 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, Other Matters Condition and Context An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the procurement requirements of the Procurement and Suspension and Debarment compliance requirement. The School Corporation was a member of HPS, LLC (a GPO) which solicited, evaluated, and awarded bids for commodities and cafeteria products on behalf of its members. The Indiana Department of Education considered a GPO as a single source for the goods procured by the members of the Service Center. Therefore, the pricelist provided by this organization for goods and services counted as one of the required number of sources. The School Corporation did not obtain price or rate quotations from additional qualified sources for the purchase of commodities and cafeteria products beyond those provided by the GPO. Therefore, the School Corporation did not obtain price or rate quotations from an adequate number of sources for purchases of goods or services exceeding $10,000 which fell under the small purchase procedures. Additionally, no sealed bids were obtained for purchases of goods or services exceeding the $150,000 simplified acquisition threshold. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.320 states in part: "The non-Federal entity must use one of the following methods of procurement. . . . (b) Procurement by small purchase procedures. Small purchase procedures are those relatively simple and informal procurement methods for securing services, supplies, or other property that do not cost more than the Simplified Acquisition Threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources. (c) Procurement by sealed bids (formal advertising). Bids are publicly solicited and a firm fixed price contract (lump sum or unit price) is awarded to the responsible bidder whose bid, conforming with all the material terms and conditions of the invitation for bids, is the lowest in price. . . ." Cause Management had not developed a system of internal controls that would have ensured compliance with the grant agreement and the procurement requirements. Effect The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the procurement requirements could have resulted in the loss of funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure compliance and comply with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Show full finding ▾Hide full finding ▴FINDING 2020-001 Subject: Child Nutrition Cluster - Procurement Federal Agency: Department of Agriculture Federal Programs: 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, Other Matters Condition and Context An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the procurement requirements of the Procurement and Suspension and Debarment compliance requirement. The School Corporation was a member of HPS, LLC (a GPO) which solicited, evaluated, and awarded bids for commodities and cafeteria products on behalf of its members. The Indiana Department of Education considered a GPO as a single source for the goods procured by the members of the Service Center. Therefore, the pricelist provided by this organization for goods and services counted as one of the required number of sources. The School Corporation did not obtain price or rate quotations from additional qualified sources for the purchase of commodities and cafeteria products beyond those provided by the GPO. Therefore, the School Corporation did not obtain price or rate quotations from an adequate number of sources for purchases of goods or services exceeding $10,000 which fell under the small purchase procedures. Additionally, no sealed bids were obtained for purchases of goods or services exceeding the $150,000 simplified acquisition threshold. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.320 states in part: "The non-Federal entity must use one of the following methods of procurement. . . . (b) Procurement by small purchase procedures. Small purchase procedures are those relatively simple and informal procurement methods for securing services, supplies, or other property that do not cost more than the Simplified Acquisition Threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources. (c) Procurement by sealed bids (formal advertising). Bids are publicly solicited and a firm fixed price contract (lump sum or unit price) is awarded to the responsible bidder whose bid, conforming with all the material terms and conditions of the invitation for bids, is the lowest in price. . . ." Cause Management had not developed a system of internal controls that would have ensured compliance with the grant agreement and the procurement requirements. Effect The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the procurement requirements could have resulted in the loss of funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure compliance and comply with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2020-001 Contact Person Responsible for Corrective Action: Sean Stevenson, Assistant Superintendent & Tyna Stover, Corporation Treasurer Contact Phone Number: 765-855-3475 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Food Service Director will obtain price or rate quotations from additional qualified sources for the purchase of commodities and cafeteria goods & services $10,000 which fall under the small purchase and purchases exceeding the simplified acquisition threshold procedures beyond those product prices & rate quotations provided by HPS LLC. Anticipated Completion Date: This will begin with obtaining prices & rate quotations for the 2021-2022 school year.
FAC accepted this audit on July 14, 2019 — management decision was due January 14, 2020.
GSA_MIGRATION
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GSA_MIGRATION
FAC accepted this audit on November 7, 2018 — management decision was due May 7, 2019.
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