Gallatin County CUSD #7Local Government

Criteria: Per 7 CFR Section 210.21(d), "All food solicitations should include terms that require contractors to respond with prices and award contracts to responsive bidders and offerors to supply domestic foods and food products that comply with Buy American." Condition: The District does not include the Buy American provision in their food solicitations. Questioned Costs: None. Context: Total expenditures for the Child Nutrition Cluster were $481,203 for the year ended June 30, 2025. Effect: The District is not in compliance with 7 CFR Section 210.21(d). Cause: The District was not aware this language was required in their solicitations. Recommendation: We recommend that all food solicitations include the proper language to ensure that food products comply with the Buy American provision. Management's Response: We will ensure this language is included in all food solicitations going forward.

Criteria: For good internal controls, expenditures should be authorized. Documentation of supervisory approval should also be retained for all expenditures. Condition: According to the District, the Superintendent reviews all expenditures and supporting documentation before payment is authorized. However, there is no documentation of this review. Questioned Costs: None. Context: Total expenditures of the program were $794,301 for the year ended June 30, 2022. Effect: Increases the risk that inappropriate expenditures could be applied to the grant program resulting in overcharging the grant for costs incurred. Our test was a statistical sample of 12 expenditures and 10 did not have documentation of supervisory approval. Cause: The prior auditor did not require or make the District aware that the school Superintendent was to approve all invoices before payment. Recommendation: We recommend the District provide proper documentation of the Superintendent's approval for payment of invoices. Management's Response: The Superintendent will begin noting her approval with her initial on all invoices.

Criteria: For employees whose time is coded to multiple cost centers, time and effort documentation is essential to support the amount of time charged to each program. That documentation should be approved by the employee's supervisor. Condition: We found that time sheets supporting the amount of time charged to the grant program contained no evidence of supervisory approval. Questioned Costs: None. Context: Total salaries of the program were $408,694 for the year ended June 30, 2022. The portion of these salaries paid to employees working for multiple cost centers is not known. Effect: Increases the risk that inappropriate time charges could be applied to the grant program resulting in overcharging the grant for costs incurred. Our test was a statistical sample of 40 expenditures and 9 did not have supervisory approval. Cause: Hourly employee timesheets are not reviewed and approved by a supervisor. Recommendation: We recommend the District provide proper documentation of a supervisor's approval on the timesheet for payment of hourly employees. Management's Response: The Superintendent and Supervisors will begin reviewing the timesheets and note their approval on them for each pay period.

Criteria: Per Title 2 CFR 200.512(d), the data collection form must be submitted within the earlier of 30 calendar days after receipt of the auditors' report, or nine months after the end of the audit period. Condition: The data collection form for the audit of the year ended June 30, 2021 was due March 31, 2022, but was not submitted until June 17, 2022, or 78 days late. Questioned Costs: None. Context: The data collection form submission must include an attachment of the annual audit report of an independent auditor. As of April 2022, the auditor had not completed the audit in accordance with his agreement with the District. The District fired the auditor and hired a new firm to complete the audit, but the deadline had already passed. Effect: The submission of the prior year audit and data collection form was not done before the deadline. Cause: The data collection form could not be submitted without the audited financial statements. The firm hired to perform the audit failed to do so. They were fired in April 2022, after the submission deadline. The new firm completed the audit and the data collection form was filed on June 17, 2022. Recommendation: We recommend that all required filings be submitted timely according tot he Single Audit Act of 1984 and Title 2, U.S. Code of Federal Regulations guidelines. Management's Response: A new firm has been engaged to perform the District's audits. This will allow filings to be made before the deadlines.

2021-006 Federal Program Name and Year: Child Nutrition Cluster - 2021. CFDA No.: 10.553, 10.555 and 10.559. Passed Through: Illinois State Board of Education. Federal Agency: U.S. Department of Agriculture. Criteria: According to 2 CFR Section 180.300, when a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity is not suspended, debarred or otherwise excluded. Condition: The District had transactions in excess of $25,000 with one vendor that they did not check for suspension and debarment or have a signed certification. Questioned Costs: None. Context: Total payments to the vendor were $229,763 as of June 30, 2021. Effect: The District was at risk of making material payments to vendors who are not allowed to do business with the federal government. There was no noncompliance, but there was no internal control in place to prevent noncompliance. Cause: The District was not aware of this requirement. Recommendation: We recommend the District check the Excluded Parties List System or collect certifications from the entity for any vendor that the District expects to pay more than $25,000 for the year. Management's Response: We were not aware of this requirement, but we will ensure that will comply going forward.