Federal program: Child Nutrition Cluster (CFDA 10.553, 10.555) Criteria: Per Title 2, Subtitle A, Chapter II, Subpart D, Section 202.303 (a), a non-Federal entity must "establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)." Condition: A material weakness in controls over compliance was identified for controls over compliance requirement E from the 2022 Office of Management and Budget (OMB) Compliance Supplement. Controls over eligibility determinations were found not to be implemented. Cause: Oversights by administrative staff, which may have been due to a lack of familiarity with the eligibility determination software and processes utilized by the District. Effect or potential effect: A lack of effective internal controls over compliance for eligibility determinations could cause ineligible children to receive the subsidy Questioned costs: No known or estimated questioned costs identified. Context: Out of a population of 242 eligibility determinations subjected to sampling, 25 samples were selected. Of the 25 eligibility determinations selected, none showed evidence of review. Recommendation: The District should develop and implement policies and procedures to ensure that all eligibility determinations are reviewed in a timely manner and documented appropriately. Views of responsible officials: The District understands and concurs with this finding.
Federal Program: Child Nutrition Cluster (CFDA 10.553, 10.555) Criteria: Per Title 2, Subtitle A, Chapter II, Subpart D, Section 202.303 (a), a non-Federal entity must "establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)." Condition: A material weakness in controls over compliance was identified for controls over compliance requirement I(b) from the 2022 Office of Management and Budget (OMB) Compliance Supplement. Controls over suspension and debarment determinations were found not to be implemented. Cause: Oversights by administrative staff, which may have been due to a lack of familiarity with the process of checking suspensions and debarments utilized by the District. Effect or potential effect: A lack of effective internal controls over compliance for suspension and debarment determinations could cause ineligible vendors to receive payments from federal funds. Questioned costs: No known or estimated questioned costs identified. Context: Out of a population of 14 vendors paid using Child Nutrition Cluster funds subjected to sampling, 4 samples were selected. Of the 4 vendors selected, none had evidence that the suspension and debarment determinations were reviewed. Recommendation: The District should develop and implement policies and procedures to ensure that all suspension and debarment determinations are reviewed in a timely manner and documented appropriately. Views of responsible officials: The District understands and concurs with this finding.
Federal program: Child Nutrition Cluster (CFDA 10.553, 10.555) Criteria: Per Title 2, Subtitle A, Chapter II, Subpart D, Section 202.303 (a), a non-Federal entity must "establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)." Condition: A material weakness in controls over compliance was identified for controls over compliance requirement L from the 2022 Office of Management and Budget (OMB) Compliance Supplement. Controls over reporting were found not to be implemented. Cause: Oversights by administrative staff, which may have been due to a lack of familiarity with the process of compiling and submitting reports, as well as difficulties adjusting to process changes related to the pandemic and its effects on the District. Effect or potential effect: A lack of effective internal controls over compliance for reporting could cause incorrect meal numbers to be reported, leading to the district receiving a higher or lower reimbursement than they should have received. Questioned costs: No known or estimated questioned costs identified. Context: Out of a population of 12 monthly reimbursement reports filed for the year ended June 30, 2022, 4 samples were selected. Of the 4 monthly reimbursement reports, none had evidence of review. Recommendation: The District should develop and implement policies and procedures to ensure that all monthly reimbursement reports are reviewed in a timely manner and documented appropriately. Views of responsible officials: The District understands and concurs with this finding
Federal program: Child Nutrition Cluster (CFDA 10.553, 10.555) Criteria: Per Title 2, Subtitle A, Chapter II, Subpart D, Section 202.303 (a), a non-Federal entity must "establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)." Condition: A material weakness in controls over compliance was identified for controls over compliance requirement N.1 from the 2022 Office of Management and Budget (OMB) Compliance Supplement. Controls over eligibility verification were found not to be implemented. Cause: Oversights by administrative staff, which may have been due to a lack of familiarity with the eligibility verification software and processes utilized by the District. Effect or potential effect: A lack of effective internal controls over compliance for eligibility verification could cause ineligible children to receive the subsidy. Questioned costs: No known or estimated questioned costs identified. Context: The 1 eligibility verification performed by the District had no evidence of review. Recommendation: The District should develop and implement policies and procedures to ensure that all eligibility verifications are reviewed in a timely manner and documented appropriately. Views of responsible officials: The District understands and concurs with this finding.
Federal program: Child Nutrition Cluster (CFDA 10.553, 10.555) Criteria: Per Title 2, Subtitle A, Chapter II, Subpart D, Section 202.318 (a), a non-Federal entity must "have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in ?? 200.317 through 200.327.? Condition: An instance of noncompliance was identified over compliance requirement I(a) from the 2022 Office of Management and Budget (OMB) Compliance Supplement. The District does not have a documented procurement policy. Cause: Oversights by administrative staff, which may have been due to a lack of familiarity with procurement policies and the requirements of receiving and administering federal funding. Effect or potential effect: A lack of a documented procurement policy for purchases using federal funds could cause a contract or purchase to be made in an improper manner. Questioned costs: No known or estimated questioned costs identified. Context: There were 245 nonpayroll expenditures, totaling $205,924.67, that were made by the District without a documented procurement policy. Recommendation: The District should develop and implement a formal procurement policy consistent with Federal, State, and local laws and regulations. Views of responsible officials: The District understands and concurs with this finding.
Federal program: Child Nutrition Cluster (CFDA 10.553, 10.555) Criteria: Per Title 7, Subtitle B, Chapter II, Subpart A, Section 210.8 (a).5, a school food authority must "maintain on file, each month's Claim for Reimbursement and all data used in the claims review process, by school. Records shall be retained as specified in ? 210.23(c) of this part." Condition: An instance of noncompliance was identified over compliance requirement L from the 2022 Office of Management and Budget (OMB) Compliance Supplement. Recordkeeping of the daily supporting documentation for the monthly claims was found to not be in compliance with federal requirements. Cause: Oversights by administrative staff, which may have been due to a lack of familiarity with the process of compiling and submitting reports, as well as difficulties adjusting to process changes related to the pandemic and its effects on the District. Effect or potential effect: A lack of proper recordkeeping over the number of meals reported for the Child Nutrition Cluster could cause incorrect meal numbers to be reported, causing an over or under claim on reimbursement. Questioned costs: No known or estimated questioned costs identified. Context: Out of a population of 12 monthly reimbursement reports filed for the year ended June 30, 2022, 4 samples were selected. Of the 4 monthly reimbursement reports, all were supported by daily consolidation sheets, but those sheets did not have the original tally sheets available as support. Recommendation: The District should develop and implement policies and procedures to ensure that all original daily meal counts and tallies used to support reimbursement reports are maintained for the appropriate amount of time. Views of responsible officials: The District understands and concurs with this finding.
Federal program: Child Nutrition Cluster (CFDA 10.553, 10.555) Criteria: Per Title 2, Subtitle A, Chapter II, Subpart D, Section 202.303 (a), a non-Federal entity must "establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)." Condition: A material weakness in controls over compliance was identified for controls over compliance requirement E from the 2022 Office of Management and Budget (OMB) Compliance Supplement. Controls over eligibility determinations were found not to be implemented. Cause: Oversights by administrative staff, which may have been due to a lack of familiarity with the eligibility determination software and processes utilized by the District. Effect or potential effect: A lack of effective internal controls over compliance for eligibility determinations could cause ineligible children to receive the subsidy Questioned costs: No known or estimated questioned costs identified. Context: Out of a population of 242 eligibility determinations subjected to sampling, 25 samples were selected. Of the 25 eligibility determinations selected, none showed evidence of review. Recommendation: The District should develop and implement policies and procedures to ensure that all eligibility determinations are reviewed in a timely manner and documented appropriately. Views of responsible officials: The District understands and concurs with this finding.
Federal Program: Child Nutrition Cluster (CFDA 10.553, 10.555) Criteria: Per Title 2, Subtitle A, Chapter II, Subpart D, Section 202.303 (a), a non-Federal entity must "establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)." Condition: A material weakness in controls over compliance was identified for controls over compliance requirement I(b) from the 2022 Office of Management and Budget (OMB) Compliance Supplement. Controls over suspension and debarment determinations were found not to be implemented. Cause: Oversights by administrative staff, which may have been due to a lack of familiarity with the process of checking suspensions and debarments utilized by the District. Effect or potential effect: A lack of effective internal controls over compliance for suspension and debarment determinations could cause ineligible vendors to receive payments from federal funds. Questioned costs: No known or estimated questioned costs identified. Context: Out of a population of 14 vendors paid using Child Nutrition Cluster funds subjected to sampling, 4 samples were selected. Of the 4 vendors selected, none had evidence that the suspension and debarment determinations were reviewed. Recommendation: The District should develop and implement policies and procedures to ensure that all suspension and debarment determinations are reviewed in a timely manner and documented appropriately. Views of responsible officials: The District understands and concurs with this finding.
Federal program: Child Nutrition Cluster (CFDA 10.553, 10.555) Criteria: Per Title 2, Subtitle A, Chapter II, Subpart D, Section 202.303 (a), a non-Federal entity must "establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)." Condition: A material weakness in controls over compliance was identified for controls over compliance requirement L from the 2022 Office of Management and Budget (OMB) Compliance Supplement. Controls over reporting were found not to be implemented. Cause: Oversights by administrative staff, which may have been due to a lack of familiarity with the process of compiling and submitting reports, as well as difficulties adjusting to process changes related to the pandemic and its effects on the District. Effect or potential effect: A lack of effective internal controls over compliance for reporting could cause incorrect meal numbers to be reported, leading to the district receiving a higher or lower reimbursement than they should have received. Questioned costs: No known or estimated questioned costs identified. Context: Out of a population of 12 monthly reimbursement reports filed for the year ended June 30, 2022, 4 samples were selected. Of the 4 monthly reimbursement reports, none had evidence of review. Recommendation: The District should develop and implement policies and procedures to ensure that all monthly reimbursement reports are reviewed in a timely manner and documented appropriately. Views of responsible officials: The District understands and concurs with this finding
Federal program: Child Nutrition Cluster (CFDA 10.553, 10.555) Criteria: Per Title 2, Subtitle A, Chapter II, Subpart D, Section 202.303 (a), a non-Federal entity must "establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)." Condition: A material weakness in controls over compliance was identified for controls over compliance requirement N.1 from the 2022 Office of Management and Budget (OMB) Compliance Supplement. Controls over eligibility verification were found not to be implemented. Cause: Oversights by administrative staff, which may have been due to a lack of familiarity with the eligibility verification software and processes utilized by the District. Effect or potential effect: A lack of effective internal controls over compliance for eligibility verification could cause ineligible children to receive the subsidy. Questioned costs: No known or estimated questioned costs identified. Context: The 1 eligibility verification performed by the District had no evidence of review. Recommendation: The District should develop and implement policies and procedures to ensure that all eligibility verifications are reviewed in a timely manner and documented appropriately. Views of responsible officials: The District understands and concurs with this finding.
Federal program: Child Nutrition Cluster (CFDA 10.553, 10.555) Criteria: Per Title 2, Subtitle A, Chapter II, Subpart D, Section 202.318 (a), a non-Federal entity must "have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in ?? 200.317 through 200.327.? Condition: An instance of noncompliance was identified over compliance requirement I(a) from the 2022 Office of Management and Budget (OMB) Compliance Supplement. The District does not have a documented procurement policy. Cause: Oversights by administrative staff, which may have been due to a lack of familiarity with procurement policies and the requirements of receiving and administering federal funding. Effect or potential effect: A lack of a documented procurement policy for purchases using federal funds could cause a contract or purchase to be made in an improper manner. Questioned costs: No known or estimated questioned costs identified. Context: There were 245 nonpayroll expenditures, totaling $205,924.67, that were made by the District without a documented procurement policy. Recommendation: The District should develop and implement a formal procurement policy consistent with Federal, State, and local laws and regulations. Views of responsible officials: The District understands and concurs with this finding.
Federal program: Child Nutrition Cluster (CFDA 10.553, 10.555) Criteria: Per Title 7, Subtitle B, Chapter II, Subpart A, Section 210.8 (a).5, a school food authority must "maintain on file, each month's Claim for Reimbursement and all data used in the claims review process, by school. Records shall be retained as specified in ? 210.23(c) of this part." Condition: An instance of noncompliance was identified over compliance requirement L from the 2022 Office of Management and Budget (OMB) Compliance Supplement. Recordkeeping of the daily supporting documentation for the monthly claims was found to not be in compliance with federal requirements. Cause: Oversights by administrative staff, which may have been due to a lack of familiarity with the process of compiling and submitting reports, as well as difficulties adjusting to process changes related to the pandemic and its effects on the District. Effect or potential effect: A lack of proper recordkeeping over the number of meals reported for the Child Nutrition Cluster could cause incorrect meal numbers to be reported, causing an over or under claim on reimbursement. Questioned costs: No known or estimated questioned costs identified. Context: Out of a population of 12 monthly reimbursement reports filed for the year ended June 30, 2022, 4 samples were selected. Of the 4 monthly reimbursement reports, all were supported by daily consolidation sheets, but those sheets did not have the original tally sheets available as support. Recommendation: The District should develop and implement policies and procedures to ensure that all original daily meal counts and tallies used to support reimbursement reports are maintained for the appropriate amount of time. Views of responsible officials: The District understands and concurs with this finding.
Federal program: Child Nutrition Cluster (CFDA 10.553, 10.555) Criteria: Per Title 2, Subtitle A, Chapter II, Subpart D, Section 202.303 (a), a non-Federal entity must "establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)." Condition: A material weakness in controls over compliance was identified for controls over compliance requirement E from the 2022 Office of Management and Budget (OMB) Compliance Supplement. Controls over eligibility determinations were found not to be implemented. Cause: Oversights by administrative staff, which may have been due to a lack of familiarity with the eligibility determination software and processes utilized by the District. Effect or potential effect: A lack of effective internal controls over compliance for eligibility determinations could cause ineligible children to receive the subsidy Questioned costs: No known or estimated questioned costs identified. Context: Out of a population of 242 eligibility determinations subjected to sampling, 25 samples were selected. Of the 25 eligibility determinations selected, none showed evidence of review. Recommendation: The District should develop and implement policies and procedures to ensure that all eligibility determinations are reviewed in a timely manner and documented appropriately. Views of responsible officials: The District understands and concurs with this finding.
Federal Program: Child Nutrition Cluster (CFDA 10.553, 10.555) Criteria: Per Title 2, Subtitle A, Chapter II, Subpart D, Section 202.303 (a), a non-Federal entity must "establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)." Condition: A material weakness in controls over compliance was identified for controls over compliance requirement I(b) from the 2022 Office of Management and Budget (OMB) Compliance Supplement. Controls over suspension and debarment determinations were found not to be implemented. Cause: Oversights by administrative staff, which may have been due to a lack of familiarity with the process of checking suspensions and debarments utilized by the District. Effect or potential effect: A lack of effective internal controls over compliance for suspension and debarment determinations could cause ineligible vendors to receive payments from federal funds. Questioned costs: No known or estimated questioned costs identified. Context: Out of a population of 14 vendors paid using Child Nutrition Cluster funds subjected to sampling, 4 samples were selected. Of the 4 vendors selected, none had evidence that the suspension and debarment determinations were reviewed. Recommendation: The District should develop and implement policies and procedures to ensure that all suspension and debarment determinations are reviewed in a timely manner and documented appropriately. Views of responsible officials: The District understands and concurs with this finding.
Federal program: Child Nutrition Cluster (CFDA 10.553, 10.555) Criteria: Per Title 2, Subtitle A, Chapter II, Subpart D, Section 202.303 (a), a non-Federal entity must "establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)." Condition: A material weakness in controls over compliance was identified for controls over compliance requirement L from the 2022 Office of Management and Budget (OMB) Compliance Supplement. Controls over reporting were found not to be implemented. Cause: Oversights by administrative staff, which may have been due to a lack of familiarity with the process of compiling and submitting reports, as well as difficulties adjusting to process changes related to the pandemic and its effects on the District. Effect or potential effect: A lack of effective internal controls over compliance for reporting could cause incorrect meal numbers to be reported, leading to the district receiving a higher or lower reimbursement than they should have received. Questioned costs: No known or estimated questioned costs identified. Context: Out of a population of 12 monthly reimbursement reports filed for the year ended June 30, 2022, 4 samples were selected. Of the 4 monthly reimbursement reports, none had evidence of review. Recommendation: The District should develop and implement policies and procedures to ensure that all monthly reimbursement reports are reviewed in a timely manner and documented appropriately. Views of responsible officials: The District understands and concurs with this finding
Federal program: Child Nutrition Cluster (CFDA 10.553, 10.555) Criteria: Per Title 2, Subtitle A, Chapter II, Subpart D, Section 202.303 (a), a non-Federal entity must "establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)." Condition: A material weakness in controls over compliance was identified for controls over compliance requirement N.1 from the 2022 Office of Management and Budget (OMB) Compliance Supplement. Controls over eligibility verification were found not to be implemented. Cause: Oversights by administrative staff, which may have been due to a lack of familiarity with the eligibility verification software and processes utilized by the District. Effect or potential effect: A lack of effective internal controls over compliance for eligibility verification could cause ineligible children to receive the subsidy. Questioned costs: No known or estimated questioned costs identified. Context: The 1 eligibility verification performed by the District had no evidence of review. Recommendation: The District should develop and implement policies and procedures to ensure that all eligibility verifications are reviewed in a timely manner and documented appropriately. Views of responsible officials: The District understands and concurs with this finding.
Federal program: Child Nutrition Cluster (CFDA 10.553, 10.555) Criteria: Per Title 2, Subtitle A, Chapter II, Subpart D, Section 202.318 (a), a non-Federal entity must "have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in ?? 200.317 through 200.327.? Condition: An instance of noncompliance was identified over compliance requirement I(a) from the 2022 Office of Management and Budget (OMB) Compliance Supplement. The District does not have a documented procurement policy. Cause: Oversights by administrative staff, which may have been due to a lack of familiarity with procurement policies and the requirements of receiving and administering federal funding. Effect or potential effect: A lack of a documented procurement policy for purchases using federal funds could cause a contract or purchase to be made in an improper manner. Questioned costs: No known or estimated questioned costs identified. Context: There were 245 nonpayroll expenditures, totaling $205,924.67, that were made by the District without a documented procurement policy. Recommendation: The District should develop and implement a formal procurement policy consistent with Federal, State, and local laws and regulations. Views of responsible officials: The District understands and concurs with this finding.
Federal program: Child Nutrition Cluster (CFDA 10.553, 10.555) Criteria: Per Title 7, Subtitle B, Chapter II, Subpart A, Section 210.8 (a).5, a school food authority must "maintain on file, each month's Claim for Reimbursement and all data used in the claims review process, by school. Records shall be retained as specified in ? 210.23(c) of this part." Condition: An instance of noncompliance was identified over compliance requirement L from the 2022 Office of Management and Budget (OMB) Compliance Supplement. Recordkeeping of the daily supporting documentation for the monthly claims was found to not be in compliance with federal requirements. Cause: Oversights by administrative staff, which may have been due to a lack of familiarity with the process of compiling and submitting reports, as well as difficulties adjusting to process changes related to the pandemic and its effects on the District. Effect or potential effect: A lack of proper recordkeeping over the number of meals reported for the Child Nutrition Cluster could cause incorrect meal numbers to be reported, causing an over or under claim on reimbursement. Questioned costs: No known or estimated questioned costs identified. Context: Out of a population of 12 monthly reimbursement reports filed for the year ended June 30, 2022, 4 samples were selected. Of the 4 monthly reimbursement reports, all were supported by daily consolidation sheets, but those sheets did not have the original tally sheets available as support. Recommendation: The District should develop and implement policies and procedures to ensure that all original daily meal counts and tallies used to support reimbursement reports are maintained for the appropriate amount of time. Views of responsible officials: The District understands and concurs with this finding.
Federal program: Child Nutrition Cluster (CFDA 10.553, 10.555) Criteria: Per Title 2, Subtitle A, Chapter II, Subpart D, Section 202.303 (a), a non-Federal entity must "establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)." Condition: A material weakness in controls over compliance was identified for controls over compliance requirement E from the 2022 Office of Management and Budget (OMB) Compliance Supplement. Controls over eligibility determinations were found not to be implemented. Cause: Oversights by administrative staff, which may have been due to a lack of familiarity with the eligibility determination software and processes utilized by the District. Effect or potential effect: A lack of effective internal controls over compliance for eligibility determinations could cause ineligible children to receive the subsidy Questioned costs: No known or estimated questioned costs identified. Context: Out of a population of 242 eligibility determinations subjected to sampling, 25 samples were selected. Of the 25 eligibility determinations selected, none showed evidence of review. Recommendation: The District should develop and implement policies and procedures to ensure that all eligibility determinations are reviewed in a timely manner and documented appropriately. Views of responsible officials: The District understands and concurs with this finding.
Federal Program: Child Nutrition Cluster (CFDA 10.553, 10.555) Criteria: Per Title 2, Subtitle A, Chapter II, Subpart D, Section 202.303 (a), a non-Federal entity must "establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)." Condition: A material weakness in controls over compliance was identified for controls over compliance requirement I(b) from the 2022 Office of Management and Budget (OMB) Compliance Supplement. Controls over suspension and debarment determinations were found not to be implemented. Cause: Oversights by administrative staff, which may have been due to a lack of familiarity with the process of checking suspensions and debarments utilized by the District. Effect or potential effect: A lack of effective internal controls over compliance for suspension and debarment determinations could cause ineligible vendors to receive payments from federal funds. Questioned costs: No known or estimated questioned costs identified. Context: Out of a population of 14 vendors paid using Child Nutrition Cluster funds subjected to sampling, 4 samples were selected. Of the 4 vendors selected, none had evidence that the suspension and debarment determinations were reviewed. Recommendation: The District should develop and implement policies and procedures to ensure that all suspension and debarment determinations are reviewed in a timely manner and documented appropriately. Views of responsible officials: The District understands and concurs with this finding.
Federal program: Child Nutrition Cluster (CFDA 10.553, 10.555) Criteria: Per Title 2, Subtitle A, Chapter II, Subpart D, Section 202.303 (a), a non-Federal entity must "establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)." Condition: A material weakness in controls over compliance was identified for controls over compliance requirement L from the 2022 Office of Management and Budget (OMB) Compliance Supplement. Controls over reporting were found not to be implemented. Cause: Oversights by administrative staff, which may have been due to a lack of familiarity with the process of compiling and submitting reports, as well as difficulties adjusting to process changes related to the pandemic and its effects on the District. Effect or potential effect: A lack of effective internal controls over compliance for reporting could cause incorrect meal numbers to be reported, leading to the district receiving a higher or lower reimbursement than they should have received. Questioned costs: No known or estimated questioned costs identified. Context: Out of a population of 12 monthly reimbursement reports filed for the year ended June 30, 2022, 4 samples were selected. Of the 4 monthly reimbursement reports, none had evidence of review. Recommendation: The District should develop and implement policies and procedures to ensure that all monthly reimbursement reports are reviewed in a timely manner and documented appropriately. Views of responsible officials: The District understands and concurs with this finding
Federal program: Child Nutrition Cluster (CFDA 10.553, 10.555) Criteria: Per Title 2, Subtitle A, Chapter II, Subpart D, Section 202.303 (a), a non-Federal entity must "establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)." Condition: A material weakness in controls over compliance was identified for controls over compliance requirement N.1 from the 2022 Office of Management and Budget (OMB) Compliance Supplement. Controls over eligibility verification were found not to be implemented. Cause: Oversights by administrative staff, which may have been due to a lack of familiarity with the eligibility verification software and processes utilized by the District. Effect or potential effect: A lack of effective internal controls over compliance for eligibility verification could cause ineligible children to receive the subsidy. Questioned costs: No known or estimated questioned costs identified. Context: The 1 eligibility verification performed by the District had no evidence of review. Recommendation: The District should develop and implement policies and procedures to ensure that all eligibility verifications are reviewed in a timely manner and documented appropriately. Views of responsible officials: The District understands and concurs with this finding.
Federal program: Child Nutrition Cluster (CFDA 10.553, 10.555) Criteria: Per Title 2, Subtitle A, Chapter II, Subpart D, Section 202.318 (a), a non-Federal entity must "have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in ?? 200.317 through 200.327.? Condition: An instance of noncompliance was identified over compliance requirement I(a) from the 2022 Office of Management and Budget (OMB) Compliance Supplement. The District does not have a documented procurement policy. Cause: Oversights by administrative staff, which may have been due to a lack of familiarity with procurement policies and the requirements of receiving and administering federal funding. Effect or potential effect: A lack of a documented procurement policy for purchases using federal funds could cause a contract or purchase to be made in an improper manner. Questioned costs: No known or estimated questioned costs identified. Context: There were 245 nonpayroll expenditures, totaling $205,924.67, that were made by the District without a documented procurement policy. Recommendation: The District should develop and implement a formal procurement policy consistent with Federal, State, and local laws and regulations. Views of responsible officials: The District understands and concurs with this finding.
Federal program: Child Nutrition Cluster (CFDA 10.553, 10.555) Criteria: Per Title 7, Subtitle B, Chapter II, Subpart A, Section 210.8 (a).5, a school food authority must "maintain on file, each month's Claim for Reimbursement and all data used in the claims review process, by school. Records shall be retained as specified in ? 210.23(c) of this part." Condition: An instance of noncompliance was identified over compliance requirement L from the 2022 Office of Management and Budget (OMB) Compliance Supplement. Recordkeeping of the daily supporting documentation for the monthly claims was found to not be in compliance with federal requirements. Cause: Oversights by administrative staff, which may have been due to a lack of familiarity with the process of compiling and submitting reports, as well as difficulties adjusting to process changes related to the pandemic and its effects on the District. Effect or potential effect: A lack of proper recordkeeping over the number of meals reported for the Child Nutrition Cluster could cause incorrect meal numbers to be reported, causing an over or under claim on reimbursement. Questioned costs: No known or estimated questioned costs identified. Context: Out of a population of 12 monthly reimbursement reports filed for the year ended June 30, 2022, 4 samples were selected. Of the 4 monthly reimbursement reports, all were supported by daily consolidation sheets, but those sheets did not have the original tally sheets available as support. Recommendation: The District should develop and implement policies and procedures to ensure that all original daily meal counts and tallies used to support reimbursement reports are maintained for the appropriate amount of time. Views of responsible officials: The District understands and concurs with this finding.
Federal program: Child Nutrition Cluster (CFDA 10.553, 10.555) Criteria: Per Title 2, Subtitle A, Chapter II, Subpart D, Section 202.303 (a), a non-Federal entity must "establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)." Condition: A material weakness in controls over compliance was identified for controls over compliance requirement E from the 2022 Office of Management and Budget (OMB) Compliance Supplement. Controls over eligibility determinations were found not to be implemented. Cause: Oversights by administrative staff, which may have been due to a lack of familiarity with the eligibility determination software and processes utilized by the District. Effect or potential effect: A lack of effective internal controls over compliance for eligibility determinations could cause ineligible children to receive the subsidy Questioned costs: No known or estimated questioned costs identified. Context: Out of a population of 242 eligibility determinations subjected to sampling, 25 samples were selected. Of the 25 eligibility determinations selected, none showed evidence of review. Recommendation: The District should develop and implement policies and procedures to ensure that all eligibility determinations are reviewed in a timely manner and documented appropriately. Views of responsible officials: The District understands and concurs with this finding.
Federal Program: Child Nutrition Cluster (CFDA 10.553, 10.555) Criteria: Per Title 2, Subtitle A, Chapter II, Subpart D, Section 202.303 (a), a non-Federal entity must "establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)." Condition: A material weakness in controls over compliance was identified for controls over compliance requirement I(b) from the 2022 Office of Management and Budget (OMB) Compliance Supplement. Controls over suspension and debarment determinations were found not to be implemented. Cause: Oversights by administrative staff, which may have been due to a lack of familiarity with the process of checking suspensions and debarments utilized by the District. Effect or potential effect: A lack of effective internal controls over compliance for suspension and debarment determinations could cause ineligible vendors to receive payments from federal funds. Questioned costs: No known or estimated questioned costs identified. Context: Out of a population of 14 vendors paid using Child Nutrition Cluster funds subjected to sampling, 4 samples were selected. Of the 4 vendors selected, none had evidence that the suspension and debarment determinations were reviewed. Recommendation: The District should develop and implement policies and procedures to ensure that all suspension and debarment determinations are reviewed in a timely manner and documented appropriately. Views of responsible officials: The District understands and concurs with this finding.
Federal program: Child Nutrition Cluster (CFDA 10.553, 10.555) Criteria: Per Title 2, Subtitle A, Chapter II, Subpart D, Section 202.303 (a), a non-Federal entity must "establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)." Condition: A material weakness in controls over compliance was identified for controls over compliance requirement L from the 2022 Office of Management and Budget (OMB) Compliance Supplement. Controls over reporting were found not to be implemented. Cause: Oversights by administrative staff, which may have been due to a lack of familiarity with the process of compiling and submitting reports, as well as difficulties adjusting to process changes related to the pandemic and its effects on the District. Effect or potential effect: A lack of effective internal controls over compliance for reporting could cause incorrect meal numbers to be reported, leading to the district receiving a higher or lower reimbursement than they should have received. Questioned costs: No known or estimated questioned costs identified. Context: Out of a population of 12 monthly reimbursement reports filed for the year ended June 30, 2022, 4 samples were selected. Of the 4 monthly reimbursement reports, none had evidence of review. Recommendation: The District should develop and implement policies and procedures to ensure that all monthly reimbursement reports are reviewed in a timely manner and documented appropriately. Views of responsible officials: The District understands and concurs with this finding
Federal program: Child Nutrition Cluster (CFDA 10.553, 10.555) Criteria: Per Title 2, Subtitle A, Chapter II, Subpart D, Section 202.303 (a), a non-Federal entity must "establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)." Condition: A material weakness in controls over compliance was identified for controls over compliance requirement N.1 from the 2022 Office of Management and Budget (OMB) Compliance Supplement. Controls over eligibility verification were found not to be implemented. Cause: Oversights by administrative staff, which may have been due to a lack of familiarity with the eligibility verification software and processes utilized by the District. Effect or potential effect: A lack of effective internal controls over compliance for eligibility verification could cause ineligible children to receive the subsidy. Questioned costs: No known or estimated questioned costs identified. Context: The 1 eligibility verification performed by the District had no evidence of review. Recommendation: The District should develop and implement policies and procedures to ensure that all eligibility verifications are reviewed in a timely manner and documented appropriately. Views of responsible officials: The District understands and concurs with this finding.
Federal program: Child Nutrition Cluster (CFDA 10.553, 10.555) Criteria: Per Title 2, Subtitle A, Chapter II, Subpart D, Section 202.318 (a), a non-Federal entity must "have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in ?? 200.317 through 200.327.? Condition: An instance of noncompliance was identified over compliance requirement I(a) from the 2022 Office of Management and Budget (OMB) Compliance Supplement. The District does not have a documented procurement policy. Cause: Oversights by administrative staff, which may have been due to a lack of familiarity with procurement policies and the requirements of receiving and administering federal funding. Effect or potential effect: A lack of a documented procurement policy for purchases using federal funds could cause a contract or purchase to be made in an improper manner. Questioned costs: No known or estimated questioned costs identified. Context: There were 245 nonpayroll expenditures, totaling $205,924.67, that were made by the District without a documented procurement policy. Recommendation: The District should develop and implement a formal procurement policy consistent with Federal, State, and local laws and regulations. Views of responsible officials: The District understands and concurs with this finding.
Federal program: Child Nutrition Cluster (CFDA 10.553, 10.555) Criteria: Per Title 7, Subtitle B, Chapter II, Subpart A, Section 210.8 (a).5, a school food authority must "maintain on file, each month's Claim for Reimbursement and all data used in the claims review process, by school. Records shall be retained as specified in ? 210.23(c) of this part." Condition: An instance of noncompliance was identified over compliance requirement L from the 2022 Office of Management and Budget (OMB) Compliance Supplement. Recordkeeping of the daily supporting documentation for the monthly claims was found to not be in compliance with federal requirements. Cause: Oversights by administrative staff, which may have been due to a lack of familiarity with the process of compiling and submitting reports, as well as difficulties adjusting to process changes related to the pandemic and its effects on the District. Effect or potential effect: A lack of proper recordkeeping over the number of meals reported for the Child Nutrition Cluster could cause incorrect meal numbers to be reported, causing an over or under claim on reimbursement. Questioned costs: No known or estimated questioned costs identified. Context: Out of a population of 12 monthly reimbursement reports filed for the year ended June 30, 2022, 4 samples were selected. Of the 4 monthly reimbursement reports, all were supported by daily consolidation sheets, but those sheets did not have the original tally sheets available as support. Recommendation: The District should develop and implement policies and procedures to ensure that all original daily meal counts and tallies used to support reimbursement reports are maintained for the appropriate amount of time. Views of responsible officials: The District understands and concurs with this finding.
Federal program: Child Nutrition Cluster (CFDA 10.553, 10.555) Criteria: Per Title 2, Subtitle A, Chapter II, Subpart D, Section 202.303 (a), a non-Federal entity must "establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)." Condition: A material weakness in controls over compliance was identified for controls over compliance requirement E from the 2022 Office of Management and Budget (OMB) Compliance Supplement. Controls over eligibility determinations were found not to be implemented. Cause: Oversights by administrative staff, which may have been due to a lack of familiarity with the eligibility determination software and processes utilized by the District. Effect or potential effect: A lack of effective internal controls over compliance for eligibility determinations could cause ineligible children to receive the subsidy Questioned costs: No known or estimated questioned costs identified. Context: Out of a population of 242 eligibility determinations subjected to sampling, 25 samples were selected. Of the 25 eligibility determinations selected, none showed evidence of review. Recommendation: The District should develop and implement policies and procedures to ensure that all eligibility determinations are reviewed in a timely manner and documented appropriately. Views of responsible officials: The District understands and concurs with this finding.
Federal Program: Child Nutrition Cluster (CFDA 10.553, 10.555) Criteria: Per Title 2, Subtitle A, Chapter II, Subpart D, Section 202.303 (a), a non-Federal entity must "establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)." Condition: A material weakness in controls over compliance was identified for controls over compliance requirement I(b) from the 2022 Office of Management and Budget (OMB) Compliance Supplement. Controls over suspension and debarment determinations were found not to be implemented. Cause: Oversights by administrative staff, which may have been due to a lack of familiarity with the process of checking suspensions and debarments utilized by the District. Effect or potential effect: A lack of effective internal controls over compliance for suspension and debarment determinations could cause ineligible vendors to receive payments from federal funds. Questioned costs: No known or estimated questioned costs identified. Context: Out of a population of 14 vendors paid using Child Nutrition Cluster funds subjected to sampling, 4 samples were selected. Of the 4 vendors selected, none had evidence that the suspension and debarment determinations were reviewed. Recommendation: The District should develop and implement policies and procedures to ensure that all suspension and debarment determinations are reviewed in a timely manner and documented appropriately. Views of responsible officials: The District understands and concurs with this finding.
Federal program: Child Nutrition Cluster (CFDA 10.553, 10.555) Criteria: Per Title 2, Subtitle A, Chapter II, Subpart D, Section 202.303 (a), a non-Federal entity must "establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)." Condition: A material weakness in controls over compliance was identified for controls over compliance requirement L from the 2022 Office of Management and Budget (OMB) Compliance Supplement. Controls over reporting were found not to be implemented. Cause: Oversights by administrative staff, which may have been due to a lack of familiarity with the process of compiling and submitting reports, as well as difficulties adjusting to process changes related to the pandemic and its effects on the District. Effect or potential effect: A lack of effective internal controls over compliance for reporting could cause incorrect meal numbers to be reported, leading to the district receiving a higher or lower reimbursement than they should have received. Questioned costs: No known or estimated questioned costs identified. Context: Out of a population of 12 monthly reimbursement reports filed for the year ended June 30, 2022, 4 samples were selected. Of the 4 monthly reimbursement reports, none had evidence of review. Recommendation: The District should develop and implement policies and procedures to ensure that all monthly reimbursement reports are reviewed in a timely manner and documented appropriately. Views of responsible officials: The District understands and concurs with this finding
Federal program: Child Nutrition Cluster (CFDA 10.553, 10.555) Criteria: Per Title 2, Subtitle A, Chapter II, Subpart D, Section 202.303 (a), a non-Federal entity must "establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)." Condition: A material weakness in controls over compliance was identified for controls over compliance requirement N.1 from the 2022 Office of Management and Budget (OMB) Compliance Supplement. Controls over eligibility verification were found not to be implemented. Cause: Oversights by administrative staff, which may have been due to a lack of familiarity with the eligibility verification software and processes utilized by the District. Effect or potential effect: A lack of effective internal controls over compliance for eligibility verification could cause ineligible children to receive the subsidy. Questioned costs: No known or estimated questioned costs identified. Context: The 1 eligibility verification performed by the District had no evidence of review. Recommendation: The District should develop and implement policies and procedures to ensure that all eligibility verifications are reviewed in a timely manner and documented appropriately. Views of responsible officials: The District understands and concurs with this finding.
Federal program: Child Nutrition Cluster (CFDA 10.553, 10.555) Criteria: Per Title 2, Subtitle A, Chapter II, Subpart D, Section 202.318 (a), a non-Federal entity must "have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in ?? 200.317 through 200.327.? Condition: An instance of noncompliance was identified over compliance requirement I(a) from the 2022 Office of Management and Budget (OMB) Compliance Supplement. The District does not have a documented procurement policy. Cause: Oversights by administrative staff, which may have been due to a lack of familiarity with procurement policies and the requirements of receiving and administering federal funding. Effect or potential effect: A lack of a documented procurement policy for purchases using federal funds could cause a contract or purchase to be made in an improper manner. Questioned costs: No known or estimated questioned costs identified. Context: There were 245 nonpayroll expenditures, totaling $205,924.67, that were made by the District without a documented procurement policy. Recommendation: The District should develop and implement a formal procurement policy consistent with Federal, State, and local laws and regulations. Views of responsible officials: The District understands and concurs with this finding.
Federal program: Child Nutrition Cluster (CFDA 10.553, 10.555) Criteria: Per Title 7, Subtitle B, Chapter II, Subpart A, Section 210.8 (a).5, a school food authority must "maintain on file, each month's Claim for Reimbursement and all data used in the claims review process, by school. Records shall be retained as specified in ? 210.23(c) of this part." Condition: An instance of noncompliance was identified over compliance requirement L from the 2022 Office of Management and Budget (OMB) Compliance Supplement. Recordkeeping of the daily supporting documentation for the monthly claims was found to not be in compliance with federal requirements. Cause: Oversights by administrative staff, which may have been due to a lack of familiarity with the process of compiling and submitting reports, as well as difficulties adjusting to process changes related to the pandemic and its effects on the District. Effect or potential effect: A lack of proper recordkeeping over the number of meals reported for the Child Nutrition Cluster could cause incorrect meal numbers to be reported, causing an over or under claim on reimbursement. Questioned costs: No known or estimated questioned costs identified. Context: Out of a population of 12 monthly reimbursement reports filed for the year ended June 30, 2022, 4 samples were selected. Of the 4 monthly reimbursement reports, all were supported by daily consolidation sheets, but those sheets did not have the original tally sheets available as support. Recommendation: The District should develop and implement policies and procedures to ensure that all original daily meal counts and tallies used to support reimbursement reports are maintained for the appropriate amount of time. Views of responsible officials: The District understands and concurs with this finding.
Federal program: Child Nutrition Cluster (CFDA 10.553, 10.555) Criteria: Per Title 2, Subtitle A, Chapter II, Subpart D, Section 202.303 (a), a non-Federal entity must "establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)." Condition: A material weakness in controls over compliance was identified for controls over compliance requirement E from the 2022 Office of Management and Budget (OMB) Compliance Supplement. Controls over eligibility determinations were found not to be implemented. Cause: Oversights by administrative staff, which may have been due to a lack of familiarity with the eligibility determination software and processes utilized by the District. Effect or potential effect: A lack of effective internal controls over compliance for eligibility determinations could cause ineligible children to receive the subsidy Questioned costs: No known or estimated questioned costs identified. Context: Out of a population of 242 eligibility determinations subjected to sampling, 25 samples were selected. Of the 25 eligibility determinations selected, none showed evidence of review. Recommendation: The District should develop and implement policies and procedures to ensure that all eligibility determinations are reviewed in a timely manner and documented appropriately. Views of responsible officials: The District understands and concurs with this finding.
Federal Program: Child Nutrition Cluster (CFDA 10.553, 10.555) Criteria: Per Title 2, Subtitle A, Chapter II, Subpart D, Section 202.303 (a), a non-Federal entity must "establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)." Condition: A material weakness in controls over compliance was identified for controls over compliance requirement I(b) from the 2022 Office of Management and Budget (OMB) Compliance Supplement. Controls over suspension and debarment determinations were found not to be implemented. Cause: Oversights by administrative staff, which may have been due to a lack of familiarity with the process of checking suspensions and debarments utilized by the District. Effect or potential effect: A lack of effective internal controls over compliance for suspension and debarment determinations could cause ineligible vendors to receive payments from federal funds. Questioned costs: No known or estimated questioned costs identified. Context: Out of a population of 14 vendors paid using Child Nutrition Cluster funds subjected to sampling, 4 samples were selected. Of the 4 vendors selected, none had evidence that the suspension and debarment determinations were reviewed. Recommendation: The District should develop and implement policies and procedures to ensure that all suspension and debarment determinations are reviewed in a timely manner and documented appropriately. Views of responsible officials: The District understands and concurs with this finding.
Federal program: Child Nutrition Cluster (CFDA 10.553, 10.555) Criteria: Per Title 2, Subtitle A, Chapter II, Subpart D, Section 202.303 (a), a non-Federal entity must "establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)." Condition: A material weakness in controls over compliance was identified for controls over compliance requirement L from the 2022 Office of Management and Budget (OMB) Compliance Supplement. Controls over reporting were found not to be implemented. Cause: Oversights by administrative staff, which may have been due to a lack of familiarity with the process of compiling and submitting reports, as well as difficulties adjusting to process changes related to the pandemic and its effects on the District. Effect or potential effect: A lack of effective internal controls over compliance for reporting could cause incorrect meal numbers to be reported, leading to the district receiving a higher or lower reimbursement than they should have received. Questioned costs: No known or estimated questioned costs identified. Context: Out of a population of 12 monthly reimbursement reports filed for the year ended June 30, 2022, 4 samples were selected. Of the 4 monthly reimbursement reports, none had evidence of review. Recommendation: The District should develop and implement policies and procedures to ensure that all monthly reimbursement reports are reviewed in a timely manner and documented appropriately. Views of responsible officials: The District understands and concurs with this finding
Federal program: Child Nutrition Cluster (CFDA 10.553, 10.555) Criteria: Per Title 2, Subtitle A, Chapter II, Subpart D, Section 202.303 (a), a non-Federal entity must "establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)." Condition: A material weakness in controls over compliance was identified for controls over compliance requirement N.1 from the 2022 Office of Management and Budget (OMB) Compliance Supplement. Controls over eligibility verification were found not to be implemented. Cause: Oversights by administrative staff, which may have been due to a lack of familiarity with the eligibility verification software and processes utilized by the District. Effect or potential effect: A lack of effective internal controls over compliance for eligibility verification could cause ineligible children to receive the subsidy. Questioned costs: No known or estimated questioned costs identified. Context: The 1 eligibility verification performed by the District had no evidence of review. Recommendation: The District should develop and implement policies and procedures to ensure that all eligibility verifications are reviewed in a timely manner and documented appropriately. Views of responsible officials: The District understands and concurs with this finding.
Federal program: Child Nutrition Cluster (CFDA 10.553, 10.555) Criteria: Per Title 2, Subtitle A, Chapter II, Subpart D, Section 202.318 (a), a non-Federal entity must "have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in ?? 200.317 through 200.327.? Condition: An instance of noncompliance was identified over compliance requirement I(a) from the 2022 Office of Management and Budget (OMB) Compliance Supplement. The District does not have a documented procurement policy. Cause: Oversights by administrative staff, which may have been due to a lack of familiarity with procurement policies and the requirements of receiving and administering federal funding. Effect or potential effect: A lack of a documented procurement policy for purchases using federal funds could cause a contract or purchase to be made in an improper manner. Questioned costs: No known or estimated questioned costs identified. Context: There were 245 nonpayroll expenditures, totaling $205,924.67, that were made by the District without a documented procurement policy. Recommendation: The District should develop and implement a formal procurement policy consistent with Federal, State, and local laws and regulations. Views of responsible officials: The District understands and concurs with this finding.
Federal program: Child Nutrition Cluster (CFDA 10.553, 10.555) Criteria: Per Title 7, Subtitle B, Chapter II, Subpart A, Section 210.8 (a).5, a school food authority must "maintain on file, each month's Claim for Reimbursement and all data used in the claims review process, by school. Records shall be retained as specified in ? 210.23(c) of this part." Condition: An instance of noncompliance was identified over compliance requirement L from the 2022 Office of Management and Budget (OMB) Compliance Supplement. Recordkeeping of the daily supporting documentation for the monthly claims was found to not be in compliance with federal requirements. Cause: Oversights by administrative staff, which may have been due to a lack of familiarity with the process of compiling and submitting reports, as well as difficulties adjusting to process changes related to the pandemic and its effects on the District. Effect or potential effect: A lack of proper recordkeeping over the number of meals reported for the Child Nutrition Cluster could cause incorrect meal numbers to be reported, causing an over or under claim on reimbursement. Questioned costs: No known or estimated questioned costs identified. Context: Out of a population of 12 monthly reimbursement reports filed for the year ended June 30, 2022, 4 samples were selected. Of the 4 monthly reimbursement reports, all were supported by daily consolidation sheets, but those sheets did not have the original tally sheets available as support. Recommendation: The District should develop and implement policies and procedures to ensure that all original daily meal counts and tallies used to support reimbursement reports are maintained for the appropriate amount of time. Views of responsible officials: The District understands and concurs with this finding.
Federal program: Child Nutrition Cluster (CFDA 10.553, 10.555) Criteria: Per Title 2, Subtitle A, Chapter II, Subpart D, Section 202.303 (a), a non-Federal entity must "establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)." Condition: A material weakness in controls over compliance was identified for controls over compliance requirement E from the 2022 Office of Management and Budget (OMB) Compliance Supplement. Controls over eligibility determinations were found not to be implemented. Cause: Oversights by administrative staff, which may have been due to a lack of familiarity with the eligibility determination software and processes utilized by the District. Effect or potential effect: A lack of effective internal controls over compliance for eligibility determinations could cause ineligible children to receive the subsidy Questioned costs: No known or estimated questioned costs identified. Context: Out of a population of 242 eligibility determinations subjected to sampling, 25 samples were selected. Of the 25 eligibility determinations selected, none showed evidence of review. Recommendation: The District should develop and implement policies and procedures to ensure that all eligibility determinations are reviewed in a timely manner and documented appropriately. Views of responsible officials: The District understands and concurs with this finding.
Federal Program: Child Nutrition Cluster (CFDA 10.553, 10.555) Criteria: Per Title 2, Subtitle A, Chapter II, Subpart D, Section 202.303 (a), a non-Federal entity must "establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)." Condition: A material weakness in controls over compliance was identified for controls over compliance requirement I(b) from the 2022 Office of Management and Budget (OMB) Compliance Supplement. Controls over suspension and debarment determinations were found not to be implemented. Cause: Oversights by administrative staff, which may have been due to a lack of familiarity with the process of checking suspensions and debarments utilized by the District. Effect or potential effect: A lack of effective internal controls over compliance for suspension and debarment determinations could cause ineligible vendors to receive payments from federal funds. Questioned costs: No known or estimated questioned costs identified. Context: Out of a population of 14 vendors paid using Child Nutrition Cluster funds subjected to sampling, 4 samples were selected. Of the 4 vendors selected, none had evidence that the suspension and debarment determinations were reviewed. Recommendation: The District should develop and implement policies and procedures to ensure that all suspension and debarment determinations are reviewed in a timely manner and documented appropriately. Views of responsible officials: The District understands and concurs with this finding.
Federal program: Child Nutrition Cluster (CFDA 10.553, 10.555) Criteria: Per Title 2, Subtitle A, Chapter II, Subpart D, Section 202.303 (a), a non-Federal entity must "establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)." Condition: A material weakness in controls over compliance was identified for controls over compliance requirement L from the 2022 Office of Management and Budget (OMB) Compliance Supplement. Controls over reporting were found not to be implemented. Cause: Oversights by administrative staff, which may have been due to a lack of familiarity with the process of compiling and submitting reports, as well as difficulties adjusting to process changes related to the pandemic and its effects on the District. Effect or potential effect: A lack of effective internal controls over compliance for reporting could cause incorrect meal numbers to be reported, leading to the district receiving a higher or lower reimbursement than they should have received. Questioned costs: No known or estimated questioned costs identified. Context: Out of a population of 12 monthly reimbursement reports filed for the year ended June 30, 2022, 4 samples were selected. Of the 4 monthly reimbursement reports, none had evidence of review. Recommendation: The District should develop and implement policies and procedures to ensure that all monthly reimbursement reports are reviewed in a timely manner and documented appropriately. Views of responsible officials: The District understands and concurs with this finding
Federal program: Child Nutrition Cluster (CFDA 10.553, 10.555) Criteria: Per Title 2, Subtitle A, Chapter II, Subpart D, Section 202.303 (a), a non-Federal entity must "establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)." Condition: A material weakness in controls over compliance was identified for controls over compliance requirement N.1 from the 2022 Office of Management and Budget (OMB) Compliance Supplement. Controls over eligibility verification were found not to be implemented. Cause: Oversights by administrative staff, which may have been due to a lack of familiarity with the eligibility verification software and processes utilized by the District. Effect or potential effect: A lack of effective internal controls over compliance for eligibility verification could cause ineligible children to receive the subsidy. Questioned costs: No known or estimated questioned costs identified. Context: The 1 eligibility verification performed by the District had no evidence of review. Recommendation: The District should develop and implement policies and procedures to ensure that all eligibility verifications are reviewed in a timely manner and documented appropriately. Views of responsible officials: The District understands and concurs with this finding.
Federal program: Child Nutrition Cluster (CFDA 10.553, 10.555) Criteria: Per Title 2, Subtitle A, Chapter II, Subpart D, Section 202.318 (a), a non-Federal entity must "have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in ?? 200.317 through 200.327.? Condition: An instance of noncompliance was identified over compliance requirement I(a) from the 2022 Office of Management and Budget (OMB) Compliance Supplement. The District does not have a documented procurement policy. Cause: Oversights by administrative staff, which may have been due to a lack of familiarity with procurement policies and the requirements of receiving and administering federal funding. Effect or potential effect: A lack of a documented procurement policy for purchases using federal funds could cause a contract or purchase to be made in an improper manner. Questioned costs: No known or estimated questioned costs identified. Context: There were 245 nonpayroll expenditures, totaling $205,924.67, that were made by the District without a documented procurement policy. Recommendation: The District should develop and implement a formal procurement policy consistent with Federal, State, and local laws and regulations. Views of responsible officials: The District understands and concurs with this finding.
Federal program: Child Nutrition Cluster (CFDA 10.553, 10.555) Criteria: Per Title 7, Subtitle B, Chapter II, Subpart A, Section 210.8 (a).5, a school food authority must "maintain on file, each month's Claim for Reimbursement and all data used in the claims review process, by school. Records shall be retained as specified in ? 210.23(c) of this part." Condition: An instance of noncompliance was identified over compliance requirement L from the 2022 Office of Management and Budget (OMB) Compliance Supplement. Recordkeeping of the daily supporting documentation for the monthly claims was found to not be in compliance with federal requirements. Cause: Oversights by administrative staff, which may have been due to a lack of familiarity with the process of compiling and submitting reports, as well as difficulties adjusting to process changes related to the pandemic and its effects on the District. Effect or potential effect: A lack of proper recordkeeping over the number of meals reported for the Child Nutrition Cluster could cause incorrect meal numbers to be reported, causing an over or under claim on reimbursement. Questioned costs: No known or estimated questioned costs identified. Context: Out of a population of 12 monthly reimbursement reports filed for the year ended June 30, 2022, 4 samples were selected. Of the 4 monthly reimbursement reports, all were supported by daily consolidation sheets, but those sheets did not have the original tally sheets available as support. Recommendation: The District should develop and implement policies and procedures to ensure that all original daily meal counts and tallies used to support reimbursement reports are maintained for the appropriate amount of time. Views of responsible officials: The District understands and concurs with this finding.