Audit 317107

2023-001 Improve Controls Over Special Tests and Provisions Related to Verification Federal Agency: U.S. Department of Agriculture Cluster/Program: Child Nutrition Cluster Award Name: National School Lunch Program AL Number(s): 10.553/10.555 Award Year: 2023 Compliance Requirement: Special Tests and Provisions Type of Finding Compliance Internal Control over Compliance - Material Weakness Criteria or Specific Requirement By November 15 of each school year, the local education agency (LEA) must verify the current free and reduced-price eligibility of households selected from a sample of applications that it has approved for free and reduced-price meals, unless the LEA is otherwise exempt from the verification requirement. The verification sample size is based on the total number of approved applications on file on October 1st. Management is also responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis. Condition and Context The Town failed to complete the required verification process for the 2023 school year. Cause A lack of understanding of the verification requirements and insufficient oversight by the program management. Effect or Potential Effect The failure to complete the required verification process could result in ineligible participants receiving benefits, thereby potentially affecting the integrity of the National School Lunch Program and leading to the misuse of federal funds. No questioned costs were reported as it is not quantifiable. Recommendation The Town should establish and enforce policies and procedures to ensure that the annual verification process is completed in accordance with USDA requirements. This should include appropriate training for responsible personnel and regular monitoring to ensure compliance. Views of Responsible Official Management agrees with the finding. Planned Corrective Action Management’s corrective action plan is included at the end of this report after the Schedule of Prior Year Findings.

2023-002 Improve Controls Over Eligibility of Approved Free and Reduced Price Lunch Applications Federal Agency: U.S. Department of Agriculture Cluster/Program: Child Nutrition Cluster Award Name: National School Lunch Program AL Number(s): 10.553/10.555 Award Year: 2023 Compliance Requirement: Eligibility Type of Finding Compliance Internal Control over Compliance – Significant Deficiency Criteria or Specific Requirement To qualify for a free or reduced cost meal under the School Breakfast Program and National School Lunch Program, a student’s family must submit an application to the local Food Service Program. The Food Service Program is responsible for determining if applicants are eligible for participation in the program based on income and family size standards established by the federal government. Criteria or Specific Requirement (Continued) Management is also responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis. Condition and Context Of the forty (40) free and reduced lunch applications tested, there was no documented review by a confirming official for one (1) application. Cause Weaknesses in the design and operation of internal controls. Effect or Potential Effect Due to the weaknesses in internal controls noted above, there is the risk that federal funds could be required to be returned, as a result of incorrect eligibility determinations. No questioned costs were reported as it is not quantifiable. Recommendation Written policies and procedures should be developed to document the eligibility determination process. These internal controls over eligibility determination should be consistently implemented, and periodically monitored for operating effectiveness, requiring a review of all eligibility determinations for accuracy by an individual other than the one that initially approves the application. Views of Responsible Official Management agrees with the finding. Planned Corrective Action Management’s corrective action plan is included at the end of this report after the Schedule of Prior Year Findings.

2023-001 Improve Controls Over Special Tests and Provisions Related to Verification Federal Agency: U.S. Department of Agriculture Cluster/Program: Child Nutrition Cluster Award Name: National School Lunch Program AL Number(s): 10.553/10.555 Award Year: 2023 Compliance Requirement: Special Tests and Provisions Type of Finding Compliance Internal Control over Compliance - Material Weakness Criteria or Specific Requirement By November 15 of each school year, the local education agency (LEA) must verify the current free and reduced-price eligibility of households selected from a sample of applications that it has approved for free and reduced-price meals, unless the LEA is otherwise exempt from the verification requirement. The verification sample size is based on the total number of approved applications on file on October 1st. Management is also responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis. Condition and Context The Town failed to complete the required verification process for the 2023 school year. Cause A lack of understanding of the verification requirements and insufficient oversight by the program management. Effect or Potential Effect The failure to complete the required verification process could result in ineligible participants receiving benefits, thereby potentially affecting the integrity of the National School Lunch Program and leading to the misuse of federal funds. No questioned costs were reported as it is not quantifiable. Recommendation The Town should establish and enforce policies and procedures to ensure that the annual verification process is completed in accordance with USDA requirements. This should include appropriate training for responsible personnel and regular monitoring to ensure compliance. Views of Responsible Official Management agrees with the finding. Planned Corrective Action Management’s corrective action plan is included at the end of this report after the Schedule of Prior Year Findings.

2023-002 Improve Controls Over Eligibility of Approved Free and Reduced Price Lunch Applications Federal Agency: U.S. Department of Agriculture Cluster/Program: Child Nutrition Cluster Award Name: National School Lunch Program AL Number(s): 10.553/10.555 Award Year: 2023 Compliance Requirement: Eligibility Type of Finding Compliance Internal Control over Compliance – Significant Deficiency Criteria or Specific Requirement To qualify for a free or reduced cost meal under the School Breakfast Program and National School Lunch Program, a student’s family must submit an application to the local Food Service Program. The Food Service Program is responsible for determining if applicants are eligible for participation in the program based on income and family size standards established by the federal government. Criteria or Specific Requirement (Continued) Management is also responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis. Condition and Context Of the forty (40) free and reduced lunch applications tested, there was no documented review by a confirming official for one (1) application. Cause Weaknesses in the design and operation of internal controls. Effect or Potential Effect Due to the weaknesses in internal controls noted above, there is the risk that federal funds could be required to be returned, as a result of incorrect eligibility determinations. No questioned costs were reported as it is not quantifiable. Recommendation Written policies and procedures should be developed to document the eligibility determination process. These internal controls over eligibility determination should be consistently implemented, and periodically monitored for operating effectiveness, requiring a review of all eligibility determinations for accuracy by an individual other than the one that initially approves the application. Views of Responsible Official Management agrees with the finding. Planned Corrective Action Management’s corrective action plan is included at the end of this report after the Schedule of Prior Year Findings.

2023-001 Improve Controls Over Special Tests and Provisions Related to Verification Federal Agency: U.S. Department of Agriculture Cluster/Program: Child Nutrition Cluster Award Name: National School Lunch Program AL Number(s): 10.553/10.555 Award Year: 2023 Compliance Requirement: Special Tests and Provisions Type of Finding Compliance Internal Control over Compliance - Material Weakness Criteria or Specific Requirement By November 15 of each school year, the local education agency (LEA) must verify the current free and reduced-price eligibility of households selected from a sample of applications that it has approved for free and reduced-price meals, unless the LEA is otherwise exempt from the verification requirement. The verification sample size is based on the total number of approved applications on file on October 1st. Management is also responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis. Condition and Context The Town failed to complete the required verification process for the 2023 school year. Cause A lack of understanding of the verification requirements and insufficient oversight by the program management. Effect or Potential Effect The failure to complete the required verification process could result in ineligible participants receiving benefits, thereby potentially affecting the integrity of the National School Lunch Program and leading to the misuse of federal funds. No questioned costs were reported as it is not quantifiable. Recommendation The Town should establish and enforce policies and procedures to ensure that the annual verification process is completed in accordance with USDA requirements. This should include appropriate training for responsible personnel and regular monitoring to ensure compliance. Views of Responsible Official Management agrees with the finding. Planned Corrective Action Management’s corrective action plan is included at the end of this report after the Schedule of Prior Year Findings.

2023-002 Improve Controls Over Eligibility of Approved Free and Reduced Price Lunch Applications Federal Agency: U.S. Department of Agriculture Cluster/Program: Child Nutrition Cluster Award Name: National School Lunch Program AL Number(s): 10.553/10.555 Award Year: 2023 Compliance Requirement: Eligibility Type of Finding Compliance Internal Control over Compliance – Significant Deficiency Criteria or Specific Requirement To qualify for a free or reduced cost meal under the School Breakfast Program and National School Lunch Program, a student’s family must submit an application to the local Food Service Program. The Food Service Program is responsible for determining if applicants are eligible for participation in the program based on income and family size standards established by the federal government. Criteria or Specific Requirement (Continued) Management is also responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis. Condition and Context Of the forty (40) free and reduced lunch applications tested, there was no documented review by a confirming official for one (1) application. Cause Weaknesses in the design and operation of internal controls. Effect or Potential Effect Due to the weaknesses in internal controls noted above, there is the risk that federal funds could be required to be returned, as a result of incorrect eligibility determinations. No questioned costs were reported as it is not quantifiable. Recommendation Written policies and procedures should be developed to document the eligibility determination process. These internal controls over eligibility determination should be consistently implemented, and periodically monitored for operating effectiveness, requiring a review of all eligibility determinations for accuracy by an individual other than the one that initially approves the application. Views of Responsible Official Management agrees with the finding. Planned Corrective Action Management’s corrective action plan is included at the end of this report after the Schedule of Prior Year Findings.

2023-001 Improve Controls Over Special Tests and Provisions Related to Verification Federal Agency: U.S. Department of Agriculture Cluster/Program: Child Nutrition Cluster Award Name: National School Lunch Program AL Number(s): 10.553/10.555 Award Year: 2023 Compliance Requirement: Special Tests and Provisions Type of Finding Compliance Internal Control over Compliance - Material Weakness Criteria or Specific Requirement By November 15 of each school year, the local education agency (LEA) must verify the current free and reduced-price eligibility of households selected from a sample of applications that it has approved for free and reduced-price meals, unless the LEA is otherwise exempt from the verification requirement. The verification sample size is based on the total number of approved applications on file on October 1st. Management is also responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis. Condition and Context The Town failed to complete the required verification process for the 2023 school year. Cause A lack of understanding of the verification requirements and insufficient oversight by the program management. Effect or Potential Effect The failure to complete the required verification process could result in ineligible participants receiving benefits, thereby potentially affecting the integrity of the National School Lunch Program and leading to the misuse of federal funds. No questioned costs were reported as it is not quantifiable. Recommendation The Town should establish and enforce policies and procedures to ensure that the annual verification process is completed in accordance with USDA requirements. This should include appropriate training for responsible personnel and regular monitoring to ensure compliance. Views of Responsible Official Management agrees with the finding. Planned Corrective Action Management’s corrective action plan is included at the end of this report after the Schedule of Prior Year Findings.

2023-002 Improve Controls Over Eligibility of Approved Free and Reduced Price Lunch Applications Federal Agency: U.S. Department of Agriculture Cluster/Program: Child Nutrition Cluster Award Name: National School Lunch Program AL Number(s): 10.553/10.555 Award Year: 2023 Compliance Requirement: Eligibility Type of Finding Compliance Internal Control over Compliance – Significant Deficiency Criteria or Specific Requirement To qualify for a free or reduced cost meal under the School Breakfast Program and National School Lunch Program, a student’s family must submit an application to the local Food Service Program. The Food Service Program is responsible for determining if applicants are eligible for participation in the program based on income and family size standards established by the federal government. Criteria or Specific Requirement (Continued) Management is also responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis. Condition and Context Of the forty (40) free and reduced lunch applications tested, there was no documented review by a confirming official for one (1) application. Cause Weaknesses in the design and operation of internal controls. Effect or Potential Effect Due to the weaknesses in internal controls noted above, there is the risk that federal funds could be required to be returned, as a result of incorrect eligibility determinations. No questioned costs were reported as it is not quantifiable. Recommendation Written policies and procedures should be developed to document the eligibility determination process. These internal controls over eligibility determination should be consistently implemented, and periodically monitored for operating effectiveness, requiring a review of all eligibility determinations for accuracy by an individual other than the one that initially approves the application. Views of Responsible Official Management agrees with the finding. Planned Corrective Action Management’s corrective action plan is included at the end of this report after the Schedule of Prior Year Findings.

2023-001 Improve Controls Over Special Tests and Provisions Related to Verification Federal Agency: U.S. Department of Agriculture Cluster/Program: Child Nutrition Cluster Award Name: National School Lunch Program AL Number(s): 10.553/10.555 Award Year: 2023 Compliance Requirement: Special Tests and Provisions Type of Finding Compliance Internal Control over Compliance - Material Weakness Criteria or Specific Requirement By November 15 of each school year, the local education agency (LEA) must verify the current free and reduced-price eligibility of households selected from a sample of applications that it has approved for free and reduced-price meals, unless the LEA is otherwise exempt from the verification requirement. The verification sample size is based on the total number of approved applications on file on October 1st. Management is also responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis. Condition and Context The Town failed to complete the required verification process for the 2023 school year. Cause A lack of understanding of the verification requirements and insufficient oversight by the program management. Effect or Potential Effect The failure to complete the required verification process could result in ineligible participants receiving benefits, thereby potentially affecting the integrity of the National School Lunch Program and leading to the misuse of federal funds. No questioned costs were reported as it is not quantifiable. Recommendation The Town should establish and enforce policies and procedures to ensure that the annual verification process is completed in accordance with USDA requirements. This should include appropriate training for responsible personnel and regular monitoring to ensure compliance. Views of Responsible Official Management agrees with the finding. Planned Corrective Action Management’s corrective action plan is included at the end of this report after the Schedule of Prior Year Findings.

2023-002 Improve Controls Over Eligibility of Approved Free and Reduced Price Lunch Applications Federal Agency: U.S. Department of Agriculture Cluster/Program: Child Nutrition Cluster Award Name: National School Lunch Program AL Number(s): 10.553/10.555 Award Year: 2023 Compliance Requirement: Eligibility Type of Finding Compliance Internal Control over Compliance – Significant Deficiency Criteria or Specific Requirement To qualify for a free or reduced cost meal under the School Breakfast Program and National School Lunch Program, a student’s family must submit an application to the local Food Service Program. The Food Service Program is responsible for determining if applicants are eligible for participation in the program based on income and family size standards established by the federal government. Criteria or Specific Requirement (Continued) Management is also responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis. Condition and Context Of the forty (40) free and reduced lunch applications tested, there was no documented review by a confirming official for one (1) application. Cause Weaknesses in the design and operation of internal controls. Effect or Potential Effect Due to the weaknesses in internal controls noted above, there is the risk that federal funds could be required to be returned, as a result of incorrect eligibility determinations. No questioned costs were reported as it is not quantifiable. Recommendation Written policies and procedures should be developed to document the eligibility determination process. These internal controls over eligibility determination should be consistently implemented, and periodically monitored for operating effectiveness, requiring a review of all eligibility determinations for accuracy by an individual other than the one that initially approves the application. Views of Responsible Official Management agrees with the finding. Planned Corrective Action Management’s corrective action plan is included at the end of this report after the Schedule of Prior Year Findings.

2023-001 Improve Controls Over Special Tests and Provisions Related to Verification Federal Agency: U.S. Department of Agriculture Cluster/Program: Child Nutrition Cluster Award Name: National School Lunch Program AL Number(s): 10.553/10.555 Award Year: 2023 Compliance Requirement: Special Tests and Provisions Type of Finding Compliance Internal Control over Compliance - Material Weakness Criteria or Specific Requirement By November 15 of each school year, the local education agency (LEA) must verify the current free and reduced-price eligibility of households selected from a sample of applications that it has approved for free and reduced-price meals, unless the LEA is otherwise exempt from the verification requirement. The verification sample size is based on the total number of approved applications on file on October 1st. Management is also responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis. Condition and Context The Town failed to complete the required verification process for the 2023 school year. Cause A lack of understanding of the verification requirements and insufficient oversight by the program management. Effect or Potential Effect The failure to complete the required verification process could result in ineligible participants receiving benefits, thereby potentially affecting the integrity of the National School Lunch Program and leading to the misuse of federal funds. No questioned costs were reported as it is not quantifiable. Recommendation The Town should establish and enforce policies and procedures to ensure that the annual verification process is completed in accordance with USDA requirements. This should include appropriate training for responsible personnel and regular monitoring to ensure compliance. Views of Responsible Official Management agrees with the finding. Planned Corrective Action Management’s corrective action plan is included at the end of this report after the Schedule of Prior Year Findings.

2023-002 Improve Controls Over Eligibility of Approved Free and Reduced Price Lunch Applications Federal Agency: U.S. Department of Agriculture Cluster/Program: Child Nutrition Cluster Award Name: National School Lunch Program AL Number(s): 10.553/10.555 Award Year: 2023 Compliance Requirement: Eligibility Type of Finding Compliance Internal Control over Compliance – Significant Deficiency Criteria or Specific Requirement To qualify for a free or reduced cost meal under the School Breakfast Program and National School Lunch Program, a student’s family must submit an application to the local Food Service Program. The Food Service Program is responsible for determining if applicants are eligible for participation in the program based on income and family size standards established by the federal government. Criteria or Specific Requirement (Continued) Management is also responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis. Condition and Context Of the forty (40) free and reduced lunch applications tested, there was no documented review by a confirming official for one (1) application. Cause Weaknesses in the design and operation of internal controls. Effect or Potential Effect Due to the weaknesses in internal controls noted above, there is the risk that federal funds could be required to be returned, as a result of incorrect eligibility determinations. No questioned costs were reported as it is not quantifiable. Recommendation Written policies and procedures should be developed to document the eligibility determination process. These internal controls over eligibility determination should be consistently implemented, and periodically monitored for operating effectiveness, requiring a review of all eligibility determinations for accuracy by an individual other than the one that initially approves the application. Views of Responsible Official Management agrees with the finding. Planned Corrective Action Management’s corrective action plan is included at the end of this report after the Schedule of Prior Year Findings.

2023-001 Improve Controls Over Special Tests and Provisions Related to Verification Federal Agency: U.S. Department of Agriculture Cluster/Program: Child Nutrition Cluster Award Name: National School Lunch Program AL Number(s): 10.553/10.555 Award Year: 2023 Compliance Requirement: Special Tests and Provisions Type of Finding Compliance Internal Control over Compliance - Material Weakness Criteria or Specific Requirement By November 15 of each school year, the local education agency (LEA) must verify the current free and reduced-price eligibility of households selected from a sample of applications that it has approved for free and reduced-price meals, unless the LEA is otherwise exempt from the verification requirement. The verification sample size is based on the total number of approved applications on file on October 1st. Management is also responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis. Condition and Context The Town failed to complete the required verification process for the 2023 school year. Cause A lack of understanding of the verification requirements and insufficient oversight by the program management. Effect or Potential Effect The failure to complete the required verification process could result in ineligible participants receiving benefits, thereby potentially affecting the integrity of the National School Lunch Program and leading to the misuse of federal funds. No questioned costs were reported as it is not quantifiable. Recommendation The Town should establish and enforce policies and procedures to ensure that the annual verification process is completed in accordance with USDA requirements. This should include appropriate training for responsible personnel and regular monitoring to ensure compliance. Views of Responsible Official Management agrees with the finding. Planned Corrective Action Management’s corrective action plan is included at the end of this report after the Schedule of Prior Year Findings.

2023-002 Improve Controls Over Eligibility of Approved Free and Reduced Price Lunch Applications Federal Agency: U.S. Department of Agriculture Cluster/Program: Child Nutrition Cluster Award Name: National School Lunch Program AL Number(s): 10.553/10.555 Award Year: 2023 Compliance Requirement: Eligibility Type of Finding Compliance Internal Control over Compliance – Significant Deficiency Criteria or Specific Requirement To qualify for a free or reduced cost meal under the School Breakfast Program and National School Lunch Program, a student’s family must submit an application to the local Food Service Program. The Food Service Program is responsible for determining if applicants are eligible for participation in the program based on income and family size standards established by the federal government. Criteria or Specific Requirement (Continued) Management is also responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis. Condition and Context Of the forty (40) free and reduced lunch applications tested, there was no documented review by a confirming official for one (1) application. Cause Weaknesses in the design and operation of internal controls. Effect or Potential Effect Due to the weaknesses in internal controls noted above, there is the risk that federal funds could be required to be returned, as a result of incorrect eligibility determinations. No questioned costs were reported as it is not quantifiable. Recommendation Written policies and procedures should be developed to document the eligibility determination process. These internal controls over eligibility determination should be consistently implemented, and periodically monitored for operating effectiveness, requiring a review of all eligibility determinations for accuracy by an individual other than the one that initially approves the application. Views of Responsible Official Management agrees with the finding. Planned Corrective Action Management’s corrective action plan is included at the end of this report after the Schedule of Prior Year Findings.

2023-001 Improve Controls Over Special Tests and Provisions Related to Verification Federal Agency: U.S. Department of Agriculture Cluster/Program: Child Nutrition Cluster Award Name: National School Lunch Program AL Number(s): 10.553/10.555 Award Year: 2023 Compliance Requirement: Special Tests and Provisions Type of Finding Compliance Internal Control over Compliance - Material Weakness Criteria or Specific Requirement By November 15 of each school year, the local education agency (LEA) must verify the current free and reduced-price eligibility of households selected from a sample of applications that it has approved for free and reduced-price meals, unless the LEA is otherwise exempt from the verification requirement. The verification sample size is based on the total number of approved applications on file on October 1st. Management is also responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis. Condition and Context The Town failed to complete the required verification process for the 2023 school year. Cause A lack of understanding of the verification requirements and insufficient oversight by the program management. Effect or Potential Effect The failure to complete the required verification process could result in ineligible participants receiving benefits, thereby potentially affecting the integrity of the National School Lunch Program and leading to the misuse of federal funds. No questioned costs were reported as it is not quantifiable. Recommendation The Town should establish and enforce policies and procedures to ensure that the annual verification process is completed in accordance with USDA requirements. This should include appropriate training for responsible personnel and regular monitoring to ensure compliance. Views of Responsible Official Management agrees with the finding. Planned Corrective Action Management’s corrective action plan is included at the end of this report after the Schedule of Prior Year Findings.

2023-002 Improve Controls Over Eligibility of Approved Free and Reduced Price Lunch Applications Federal Agency: U.S. Department of Agriculture Cluster/Program: Child Nutrition Cluster Award Name: National School Lunch Program AL Number(s): 10.553/10.555 Award Year: 2023 Compliance Requirement: Eligibility Type of Finding Compliance Internal Control over Compliance – Significant Deficiency Criteria or Specific Requirement To qualify for a free or reduced cost meal under the School Breakfast Program and National School Lunch Program, a student’s family must submit an application to the local Food Service Program. The Food Service Program is responsible for determining if applicants are eligible for participation in the program based on income and family size standards established by the federal government. Criteria or Specific Requirement (Continued) Management is also responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis. Condition and Context Of the forty (40) free and reduced lunch applications tested, there was no documented review by a confirming official for one (1) application. Cause Weaknesses in the design and operation of internal controls. Effect or Potential Effect Due to the weaknesses in internal controls noted above, there is the risk that federal funds could be required to be returned, as a result of incorrect eligibility determinations. No questioned costs were reported as it is not quantifiable. Recommendation Written policies and procedures should be developed to document the eligibility determination process. These internal controls over eligibility determination should be consistently implemented, and periodically monitored for operating effectiveness, requiring a review of all eligibility determinations for accuracy by an individual other than the one that initially approves the application. Views of Responsible Official Management agrees with the finding. Planned Corrective Action Management’s corrective action plan is included at the end of this report after the Schedule of Prior Year Findings.