1. Ryan Preston W. Tyler Michael, CPA Schools.Townships@sboa.in.gov

2.  Clearing Account Number 8400  Trust Account  Subsidiary Ledger  Reconciled Monthly  Board Policy

3.  Example ◦ Student Pays $50 ◦ Charges meals ($2) for 10 days ◦ Pursuant to your policy, you will transfer $20 (weekly/monthly, etc.) from 8400 to 800 ◦ Student balance = $30

4.  Example (Continued) Subsidiary Ledger W. Tyler Michael$21.00 Ryan Preston($7.50) Paul Joyce$50.00 Sheri M. Shipp$12.50 Stephanie Jacobs($.50) Shannon Roberts$.50 Total$76.00

5.  Example (Continued) ◦ Students Michael, Joyce, Shipp & Roberts all request their money back ◦ 8400 fund now has a negative balance ($8.00).  School Corporation General fund is required to make up that balance.

6.  Annual Financial Report (AFR)  For Child Nutrition Cluster ◦ Receipts & Disbursements = reimbursement requests ◦ Add Commodities (Federal Noncash Assistance)

7.  ECA Manual [http://in.gov/sboa/4449.htm] ◦ Chapter 3 School Lunch Program  [http://in.gov/sboa/files/sec2010_003.pdf]  “All cash register systems must be equipped with identification keys to indicate (1) paid student meals, (2) reduced price student meals, (3) free student meals, (4) adult meals, (5) a la carte sales and other additional categories the school corporation may wish to identify that may be required by the accounting system.”

14.  Tips for the situation in which they accept deposits into a student’s account via a third party website. ◦ IC 36-1-8-11 allows school to pass along any fee to the student/parent that the third party charges. ◦ Should ensure that third party can provide reports/documentation that will tie daily collections to school receipts and to bank deposits.

15.  The nutrition section of the IDOE website provides templates for a letter/instructions that can be sent to households to assist them in completing a Free/Reduced Lunch Application. It also has samples of letters to notify parents if the application has been approved or denied. www.doe.in.gov/nutrition/snp-free-and- reduced-price-forms

16.  Amended IC 20-26-4-5: Effective January 1, 2016 ◦ Commencing July 1 of each year, it added a requirement for “any individual whose official duties include receiving, processing, depositing, disbursing, or otherwise having access to funds that belong to a school corporation” to have an official bond. ◦ Allows for a blanket bond to cover multiple “individuals” if it is endorsed to cover the “faithful performance of all employees” and it includes sufficient aggregate coverage for all “individuals” listed on the bond. ◦ For audit purposes, SBOA will not take exception to “individuals” that have access to less than $100 per event not being covered by a bond. ◦ Fiscal officer of the School Corporation will be required to submit a copy all the bonds via the Gateway Annual Financial Report in the future.

17.  IC 5-11-1-27(j): ◦ Requires the school to immediately report “all erroneous or irregular material variances, losses, shortages, or thefts” to the SBOA. ◦ School Board has been given the ability to establish a policy that defines a threshold for an item to be considered “material”. If they don’t adopt a policy the threshold will be zero.  IC 5-11-1-27(l): ◦ Requires any school official that has actual knowledge or a reasonable cause to believe that there has been a misappropriation of school funds or school assets to make written notice to the SBOA and the local prosecutor.

18.  If the school lunch transactions are kept in the School Corporation records, then they would be required to meet guidelines of IC 5-13-6-1(c) that states in part: “all local officers… who collect public funds of their respective political subdivisions, shall deposit funds not later than the business day following the receipt of funds…”  If the school lunch transactions are kept in the Extra- Curricular Account records, then they would be required to meet guidelines of IC 20-41-1-9(a) that states in part: “The treasurer shall deposit all receipts in one (1) bank account. The receipts shall be deposited without unreasonable delay.”

19.  Insufficient internal controls for reporting  Insufficient internal controls for eligibility determinations ◦ Procedures had not been established to detect errors or misstatements in meeting reporting and eligibility determination requirements. ◦ Main problem was that mitigating controls were not established to compensate for a lack of segregation of duties.  Cash management noncompliance ◦ During the audit period cash balances were routinely in excess of grant agreement requirements  7 CFR section 210.14(a) says that the child nutrition program should be a nonprofit service.  7 CFR section 210.14(b) says that cash balances should not be excess of 3 months average expenditures. Exceptions may be approved by the State agency.

20.  Requirements start for grants that were received by the state after December 26, 2014.  The new requirements for compensation and documentation can be found in 2015’s 2 CFR 200.430.  The specific requirements for documenting personnel expenses can be found in subsection (i). “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.”  Says, “…charges for the salaries and wages of nonexempt employees, in addition to the supporting documentation described in this section, must also be supported by records indicating the total number of hours worked each day.”

21.  References:  CFR 2015; Title 2; Subtitle A; Chapter II; Part 200; Sec. 200.430 - http://www.gpo.gov/fdsys/pkg/CFR-2015- title2-vol1/pdf/CFR-2015-title2-vol1-part200.pdf  IDOE presentation on learning connection – School Finance Community; Files and Bookmarks; Uniform Grant Guidance (its on pg. 2); IDOE LEA EDGAR.pdf; starts on slide 81.  FAQ for new Uniform Compliance Guidelines on USDOE website (compensation questions are E-7 through E-10) - http://www2.ed.gov/policy/fund/guid/uniform- guidance

22. Schools.Township@sboa.in.gov