Audit 335870

Federal Agency: U.S. Department of Agriculture Passthrough Entity: Missouri Department of Elementary and Secondary Education Assistance Listing Number and Federal Program: Child Nutrition Cluster – 10.553 School Breakfast Program, 10.555 National School Lunch Program, 10.559 Summer Food Service Program for Children. Compliance Requirement: L. Reporting Criteria: Per 7 CFR 210.8(a) and 7 CFR 220.11(c), the District is required to have proper internal controls over the reporting of monthly meal counts to ensure that information submitted for free and reduced meals is accurate and complete. The monthly meal counts are reported to DESE for reimbursement based on the number of free and reduced meals served during the month. The amount of reimbursement will depend on the number of each type of meal and whether it was for breakfast or lunch. In accordance with 7 CFR 210.7(c)(1)(i), the District is required to correctly determine eligibility for free and reduced price lunches and afterschool snacks based on the requirements under 7 CFR 245. Under 7 CFR 245.6(c)(4), if the student is not automatically eligible under direct certification or another exception, the District must use income information provided by the household of the student to calculate the student's eligibility for free or reduced prices. The District makes applications available to households so that their income can be reported to the District for such purposes. The District then calculates the income on the applications and references the Income Eligibility Guidelines for the school year to determine if households are eligible or ineligible for free or reduced meals. Condition: During our testing, we noted a lack of oversight regarding the monthly Claims for Reimbursement. There was no review noted before they were submitted to DESE nor was there a subsequent review performed after submission. It was noted that the Claims for Reimbursements for February and April were not completed correctly. The Lunch and Breakfast meal counts were switched on both monthly claims. We also noted that the applications for free and reduced lunch were not being reviewed by the Food Service Director for accuracy. We noted one application during testing that had illegible numbers and, therefore, the total income was not clear. The household was determined to be free by the District but there was no clarification to confirm the illegible numbers were correct as assumed. Per discussion with the Food Service Director, they agreed that the income number could have been improperly calculated and that the household could have been incorrectly determined as eligible for free meals. Cause: Control procedures were not in place to ensure that monthly Claims for Reimbursements and Free and Reduced applications were accurately entered/calculated before being submitted. Effect: Without timely review of reports before submission, requested grant revenue can be understated or overstated when based on erroneous submitted grant reports, In addition, other grant noncompliance can be overlooked. This could result in missed funding, excess funding, or other adverse conditions with the grantors. Questioned Costs: No questioned costs noted. Perspective Information: This appears to be a systemic issue as two out of the four months tested contained errors where the Lunch and Breakfast meal counts were switched on the Claims for Reimbursement form. Identification of Repeat Findings: Not a repeat finding. Recommendation: We recommend that the District develop written procedures that require a monthly review by another party for Claims for Reimbursement for the food service programs. This should be done prior to submitting the reimbursement claim to DESE. The review should be done to ensure that all information has been entered, is accurate, and is classified in the appropriate line to ensure reimbursements are for the correct amounts. In addition, we recommend that the District develop written procedures that require Free and Reduced Applications, including the calculations of income, be reviewed before being entered into the District’s tracking program. The review should be done to ensure that calculations of household income and determination of eligibility are correct when referenced to the Income Eligibility Guide.

Federal Agency: U.S. Department of Agriculture Passthrough Entity: Missouri Department of Elementary and Secondary Education Assistance Listing Number and Federal Program: Child Nutrition Cluster – 10.553 School Breakfast Program, 10.555 National School Lunch Program, 10.559 Summer Food Service Program for Children. Compliance Requirement: L. Reporting Criteria: Per 7 CFR 210.8(a) and 7 CFR 220.11(c), the District is required to have proper internal controls over the reporting of monthly meal counts to ensure that information submitted for free and reduced meals is accurate and complete. The monthly meal counts are reported to DESE for reimbursement based on the number of free and reduced meals served during the month. The amount of reimbursement will depend on the number of each type of meal and whether it was for breakfast or lunch. In accordance with 7 CFR 210.7(c)(1)(i), the District is required to correctly determine eligibility for free and reduced price lunches and afterschool snacks based on the requirements under 7 CFR 245. Under 7 CFR 245.6(c)(4), if the student is not automatically eligible under direct certification or another exception, the District must use income information provided by the household of the student to calculate the student's eligibility for free or reduced prices. The District makes applications available to households so that their income can be reported to the District for such purposes. The District then calculates the income on the applications and references the Income Eligibility Guidelines for the school year to determine if households are eligible or ineligible for free or reduced meals. Condition: During our testing, we noted a lack of oversight regarding the monthly Claims for Reimbursement. There was no review noted before they were submitted to DESE nor was there a subsequent review performed after submission. It was noted that the Claims for Reimbursements for February and April were not completed correctly. The Lunch and Breakfast meal counts were switched on both monthly claims. We also noted that the applications for free and reduced lunch were not being reviewed by the Food Service Director for accuracy. We noted one application during testing that had illegible numbers and, therefore, the total income was not clear. The household was determined to be free by the District but there was no clarification to confirm the illegible numbers were correct as assumed. Per discussion with the Food Service Director, they agreed that the income number could have been improperly calculated and that the household could have been incorrectly determined as eligible for free meals. Cause: Control procedures were not in place to ensure that monthly Claims for Reimbursements and Free and Reduced applications were accurately entered/calculated before being submitted. Effect: Without timely review of reports before submission, requested grant revenue can be understated or overstated when based on erroneous submitted grant reports, In addition, other grant noncompliance can be overlooked. This could result in missed funding, excess funding, or other adverse conditions with the grantors. Questioned Costs: No questioned costs noted. Perspective Information: This appears to be a systemic issue as two out of the four months tested contained errors where the Lunch and Breakfast meal counts were switched on the Claims for Reimbursement form. Identification of Repeat Findings: Not a repeat finding. Recommendation: We recommend that the District develop written procedures that require a monthly review by another party for Claims for Reimbursement for the food service programs. This should be done prior to submitting the reimbursement claim to DESE. The review should be done to ensure that all information has been entered, is accurate, and is classified in the appropriate line to ensure reimbursements are for the correct amounts. In addition, we recommend that the District develop written procedures that require Free and Reduced Applications, including the calculations of income, be reviewed before being entered into the District’s tracking program. The review should be done to ensure that calculations of household income and determination of eligibility are correct when referenced to the Income Eligibility Guide.

Federal Agency: U.S. Department of Agriculture Passthrough Entity: Missouri Department of Elementary and Secondary Education Assistance Listing Number and Federal Program: Child Nutrition Cluster – 10.553 School Breakfast Program, 10.555 National School Lunch Program, 10.559 Summer Food Service Program for Children. Compliance Requirement: L. Reporting Criteria: Per 7 CFR 210.8(a) and 7 CFR 220.11(c), the District is required to have proper internal controls over the reporting of monthly meal counts to ensure that information submitted for free and reduced meals is accurate and complete. The monthly meal counts are reported to DESE for reimbursement based on the number of free and reduced meals served during the month. The amount of reimbursement will depend on the number of each type of meal and whether it was for breakfast or lunch. In accordance with 7 CFR 210.7(c)(1)(i), the District is required to correctly determine eligibility for free and reduced price lunches and afterschool snacks based on the requirements under 7 CFR 245. Under 7 CFR 245.6(c)(4), if the student is not automatically eligible under direct certification or another exception, the District must use income information provided by the household of the student to calculate the student's eligibility for free or reduced prices. The District makes applications available to households so that their income can be reported to the District for such purposes. The District then calculates the income on the applications and references the Income Eligibility Guidelines for the school year to determine if households are eligible or ineligible for free or reduced meals. Condition: During our testing, we noted a lack of oversight regarding the monthly Claims for Reimbursement. There was no review noted before they were submitted to DESE nor was there a subsequent review performed after submission. It was noted that the Claims for Reimbursements for February and April were not completed correctly. The Lunch and Breakfast meal counts were switched on both monthly claims. We also noted that the applications for free and reduced lunch were not being reviewed by the Food Service Director for accuracy. We noted one application during testing that had illegible numbers and, therefore, the total income was not clear. The household was determined to be free by the District but there was no clarification to confirm the illegible numbers were correct as assumed. Per discussion with the Food Service Director, they agreed that the income number could have been improperly calculated and that the household could have been incorrectly determined as eligible for free meals. Cause: Control procedures were not in place to ensure that monthly Claims for Reimbursements and Free and Reduced applications were accurately entered/calculated before being submitted. Effect: Without timely review of reports before submission, requested grant revenue can be understated or overstated when based on erroneous submitted grant reports, In addition, other grant noncompliance can be overlooked. This could result in missed funding, excess funding, or other adverse conditions with the grantors. Questioned Costs: No questioned costs noted. Perspective Information: This appears to be a systemic issue as two out of the four months tested contained errors where the Lunch and Breakfast meal counts were switched on the Claims for Reimbursement form. Identification of Repeat Findings: Not a repeat finding. Recommendation: We recommend that the District develop written procedures that require a monthly review by another party for Claims for Reimbursement for the food service programs. This should be done prior to submitting the reimbursement claim to DESE. The review should be done to ensure that all information has been entered, is accurate, and is classified in the appropriate line to ensure reimbursements are for the correct amounts. In addition, we recommend that the District develop written procedures that require Free and Reduced Applications, including the calculations of income, be reviewed before being entered into the District’s tracking program. The review should be done to ensure that calculations of household income and determination of eligibility are correct when referenced to the Income Eligibility Guide.

Federal Agency: U.S. Department of Agriculture Passthrough Entity: Missouri Department of Elementary and Secondary Education Assistance Listing Number and Federal Program: Child Nutrition Cluster – 10.553 School Breakfast Program, 10.555 National School Lunch Program, 10.559 Summer Food Service Program for Children. Compliance Requirement: L. Reporting Criteria: Per 7 CFR 210.8(a) and 7 CFR 220.11(c), the District is required to have proper internal controls over the reporting of monthly meal counts to ensure that information submitted for free and reduced meals is accurate and complete. The monthly meal counts are reported to DESE for reimbursement based on the number of free and reduced meals served during the month. The amount of reimbursement will depend on the number of each type of meal and whether it was for breakfast or lunch. In accordance with 7 CFR 210.7(c)(1)(i), the District is required to correctly determine eligibility for free and reduced price lunches and afterschool snacks based on the requirements under 7 CFR 245. Under 7 CFR 245.6(c)(4), if the student is not automatically eligible under direct certification or another exception, the District must use income information provided by the household of the student to calculate the student's eligibility for free or reduced prices. The District makes applications available to households so that their income can be reported to the District for such purposes. The District then calculates the income on the applications and references the Income Eligibility Guidelines for the school year to determine if households are eligible or ineligible for free or reduced meals. Condition: During our testing, we noted a lack of oversight regarding the monthly Claims for Reimbursement. There was no review noted before they were submitted to DESE nor was there a subsequent review performed after submission. It was noted that the Claims for Reimbursements for February and April were not completed correctly. The Lunch and Breakfast meal counts were switched on both monthly claims. We also noted that the applications for free and reduced lunch were not being reviewed by the Food Service Director for accuracy. We noted one application during testing that had illegible numbers and, therefore, the total income was not clear. The household was determined to be free by the District but there was no clarification to confirm the illegible numbers were correct as assumed. Per discussion with the Food Service Director, they agreed that the income number could have been improperly calculated and that the household could have been incorrectly determined as eligible for free meals. Cause: Control procedures were not in place to ensure that monthly Claims for Reimbursements and Free and Reduced applications were accurately entered/calculated before being submitted. Effect: Without timely review of reports before submission, requested grant revenue can be understated or overstated when based on erroneous submitted grant reports, In addition, other grant noncompliance can be overlooked. This could result in missed funding, excess funding, or other adverse conditions with the grantors. Questioned Costs: No questioned costs noted. Perspective Information: This appears to be a systemic issue as two out of the four months tested contained errors where the Lunch and Breakfast meal counts were switched on the Claims for Reimbursement form. Identification of Repeat Findings: Not a repeat finding. Recommendation: We recommend that the District develop written procedures that require a monthly review by another party for Claims for Reimbursement for the food service programs. This should be done prior to submitting the reimbursement claim to DESE. The review should be done to ensure that all information has been entered, is accurate, and is classified in the appropriate line to ensure reimbursements are for the correct amounts. In addition, we recommend that the District develop written procedures that require Free and Reduced Applications, including the calculations of income, be reviewed before being entered into the District’s tracking program. The review should be done to ensure that calculations of household income and determination of eligibility are correct when referenced to the Income Eligibility Guide.

Federal Agency: U.S. Department of Agriculture Passthrough Entity: Missouri Department of Elementary and Secondary Education Assistance Listing Number and Federal Program: Child Nutrition Cluster – 10.553 School Breakfast Program, 10.555 National School Lunch Program, 10.559 Summer Food Service Program for Children. Compliance Requirement: L. Reporting Criteria: Per 7 CFR 210.8(a) and 7 CFR 220.11(c), the District is required to have proper internal controls over the reporting of monthly meal counts to ensure that information submitted for free and reduced meals is accurate and complete. The monthly meal counts are reported to DESE for reimbursement based on the number of free and reduced meals served during the month. The amount of reimbursement will depend on the number of each type of meal and whether it was for breakfast or lunch. In accordance with 7 CFR 210.7(c)(1)(i), the District is required to correctly determine eligibility for free and reduced price lunches and afterschool snacks based on the requirements under 7 CFR 245. Under 7 CFR 245.6(c)(4), if the student is not automatically eligible under direct certification or another exception, the District must use income information provided by the household of the student to calculate the student's eligibility for free or reduced prices. The District makes applications available to households so that their income can be reported to the District for such purposes. The District then calculates the income on the applications and references the Income Eligibility Guidelines for the school year to determine if households are eligible or ineligible for free or reduced meals. Condition: During our testing, we noted a lack of oversight regarding the monthly Claims for Reimbursement. There was no review noted before they were submitted to DESE nor was there a subsequent review performed after submission. It was noted that the Claims for Reimbursements for February and April were not completed correctly. The Lunch and Breakfast meal counts were switched on both monthly claims. We also noted that the applications for free and reduced lunch were not being reviewed by the Food Service Director for accuracy. We noted one application during testing that had illegible numbers and, therefore, the total income was not clear. The household was determined to be free by the District but there was no clarification to confirm the illegible numbers were correct as assumed. Per discussion with the Food Service Director, they agreed that the income number could have been improperly calculated and that the household could have been incorrectly determined as eligible for free meals. Cause: Control procedures were not in place to ensure that monthly Claims for Reimbursements and Free and Reduced applications were accurately entered/calculated before being submitted. Effect: Without timely review of reports before submission, requested grant revenue can be understated or overstated when based on erroneous submitted grant reports, In addition, other grant noncompliance can be overlooked. This could result in missed funding, excess funding, or other adverse conditions with the grantors. Questioned Costs: No questioned costs noted. Perspective Information: This appears to be a systemic issue as two out of the four months tested contained errors where the Lunch and Breakfast meal counts were switched on the Claims for Reimbursement form. Identification of Repeat Findings: Not a repeat finding. Recommendation: We recommend that the District develop written procedures that require a monthly review by another party for Claims for Reimbursement for the food service programs. This should be done prior to submitting the reimbursement claim to DESE. The review should be done to ensure that all information has been entered, is accurate, and is classified in the appropriate line to ensure reimbursements are for the correct amounts. In addition, we recommend that the District develop written procedures that require Free and Reduced Applications, including the calculations of income, be reviewed before being entered into the District’s tracking program. The review should be done to ensure that calculations of household income and determination of eligibility are correct when referenced to the Income Eligibility Guide.

Findings and Questioned Costs – Major Federal Award Programs Audit Federal Agency: U.S. Department of Education Passthrough Entity: Missouri Department of Elementary and Secondary Education Assistance Listing Number and Federal Program: 84.010 Title I Grants to Local Educational Agencies Compliance Requirement: B. Allowable Costs Criteria: Per 2 CFR 200.430(g)(1)(i), the District is required to have records that are supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated. The District uses semi-annual certifications to determine if the salaries and/or employee benefits of its employees are allowable for the grant. These certifications are to be signed after each semi-annual period by the teacher and the Title I program director. These certifications show that the teachers’ time was spent under the Title I program, and their salaries and benefits are allowable for the Title I program. Condition: During the course of our audit, we reviewed semi-annual certifications for all Title I teachers, as required. These certifications are used to verify that the employee spent one hundred percent of their time working in the Title I program. Per requirements, these certifications should be signed at the end of the applicable period as that is when the actual time spent in the program is known. However, during our review, we noted that all the certifications were signed at the beginning of the applicable semi-annual period. Cause: There is a lack of oversight in this area. Supervisors should ensure the teachers complete the semi-annual certifications in a timely manner after the end of each semi-annual period. Also, program directors should be reviewing the signed certifications to ensure all program requirements are followed to avoid any noncompliance issues and consequences. Effect: Semi-annual certifications are listed under the Allowable Costs/Cost Principles compliance requirement. In order to apply expenditures to the Title I Program, the employees need to certify that they are spending all of their time on that program. Without this certification, it is not clear that the amounts reported as Title I expenditures are indeed eligible expenditures. Questioned Costs: No questioned costs noted. Perspective Information: This appears to be a systemic problem since all Title I semi-annual certifications for the fiscal year 2024 were reviewed and all certifications were filled out at the beginning of each semi-annual period instead of subsequent to the period. Identification of Repeat Findings: Not a repeat finding. Recommendation: We recommend that the District employ stronger oversight in this area by assigning a review to the Title Program Director or equivalent. Once the certifications are signed by a supervisor, they should be forwarded to this point person for their review and signature. The certifications should be reviewed to ensure each Title teacher is completing a semi-annual certification and that it is being signed by the supervisor. These certifications should also have a due date twice a year to ensure they are done timely and are not overlooked. These should be added to the review checklist already used for Title I reporting. Views of Responsible Officials: The District will set up automated reminders through the internal tracking system with specific deadlines to ensure that all certifications are completed and signed no later than 30 business days after the end of the applicable periods. Regular checks will be conducted by the Title 1 Coordinator to verify that all certifications are completed and signed within the required timeframes. All relevant staff members will undergo training on the new procedures, and will be assigned roles and responsibilities for monitoring and submitting the certifications. See Corrective Action Plan.

Federal Agency: U.S. Department of Agriculture Passthrough Entity: Missouri Department of Elementary and Secondary Education Assistance Listing Number and Federal Program: Child Nutrition Cluster – 10.553 School Breakfast Program, 10.555 National School Lunch Program, 10.559 Summer Food Service Program for Children. Compliance Requirement: L. Reporting Criteria: Per 7 CFR 210.8(a) and 7 CFR 220.11(c), the District is required to have proper internal controls over the reporting of monthly meal counts to ensure that information submitted for free and reduced meals is accurate and complete. The monthly meal counts are reported to DESE for reimbursement based on the number of free and reduced meals served during the month. The amount of reimbursement will depend on the number of each type of meal and whether it was for breakfast or lunch. In accordance with 7 CFR 210.7(c)(1)(i), the District is required to correctly determine eligibility for free and reduced price lunches and afterschool snacks based on the requirements under 7 CFR 245. Under 7 CFR 245.6(c)(4), if the student is not automatically eligible under direct certification or another exception, the District must use income information provided by the household of the student to calculate the student's eligibility for free or reduced prices. The District makes applications available to households so that their income can be reported to the District for such purposes. The District then calculates the income on the applications and references the Income Eligibility Guidelines for the school year to determine if households are eligible or ineligible for free or reduced meals. Condition: During our testing, we noted a lack of oversight regarding the monthly Claims for Reimbursement. There was no review noted before they were submitted to DESE nor was there a subsequent review performed after submission. It was noted that the Claims for Reimbursements for February and April were not completed correctly. The Lunch and Breakfast meal counts were switched on both monthly claims. We also noted that the applications for free and reduced lunch were not being reviewed by the Food Service Director for accuracy. We noted one application during testing that had illegible numbers and, therefore, the total income was not clear. The household was determined to be free by the District but there was no clarification to confirm the illegible numbers were correct as assumed. Per discussion with the Food Service Director, they agreed that the income number could have been improperly calculated and that the household could have been incorrectly determined as eligible for free meals. Cause: Control procedures were not in place to ensure that monthly Claims for Reimbursements and Free and Reduced applications were accurately entered/calculated before being submitted. Effect: Without timely review of reports before submission, requested grant revenue can be understated or overstated when based on erroneous submitted grant reports, In addition, other grant noncompliance can be overlooked. This could result in missed funding, excess funding, or other adverse conditions with the grantors. Questioned Costs: No questioned costs noted. Perspective Information: This appears to be a systemic issue as two out of the four months tested contained errors where the Lunch and Breakfast meal counts were switched on the Claims for Reimbursement form. Identification of Repeat Findings: Not a repeat finding. Recommendation: We recommend that the District develop written procedures that require a monthly review by another party for Claims for Reimbursement for the food service programs. This should be done prior to submitting the reimbursement claim to DESE. The review should be done to ensure that all information has been entered, is accurate, and is classified in the appropriate line to ensure reimbursements are for the correct amounts. In addition, we recommend that the District develop written procedures that require Free and Reduced Applications, including the calculations of income, be reviewed before being entered into the District’s tracking program. The review should be done to ensure that calculations of household income and determination of eligibility are correct when referenced to the Income Eligibility Guide.

Federal Agency: U.S. Department of Agriculture Passthrough Entity: Missouri Department of Elementary and Secondary Education Assistance Listing Number and Federal Program: Child Nutrition Cluster – 10.553 School Breakfast Program, 10.555 National School Lunch Program, 10.559 Summer Food Service Program for Children. Compliance Requirement: L. Reporting Criteria: Per 7 CFR 210.8(a) and 7 CFR 220.11(c), the District is required to have proper internal controls over the reporting of monthly meal counts to ensure that information submitted for free and reduced meals is accurate and complete. The monthly meal counts are reported to DESE for reimbursement based on the number of free and reduced meals served during the month. The amount of reimbursement will depend on the number of each type of meal and whether it was for breakfast or lunch. In accordance with 7 CFR 210.7(c)(1)(i), the District is required to correctly determine eligibility for free and reduced price lunches and afterschool snacks based on the requirements under 7 CFR 245. Under 7 CFR 245.6(c)(4), if the student is not automatically eligible under direct certification or another exception, the District must use income information provided by the household of the student to calculate the student's eligibility for free or reduced prices. The District makes applications available to households so that their income can be reported to the District for such purposes. The District then calculates the income on the applications and references the Income Eligibility Guidelines for the school year to determine if households are eligible or ineligible for free or reduced meals. Condition: During our testing, we noted a lack of oversight regarding the monthly Claims for Reimbursement. There was no review noted before they were submitted to DESE nor was there a subsequent review performed after submission. It was noted that the Claims for Reimbursements for February and April were not completed correctly. The Lunch and Breakfast meal counts were switched on both monthly claims. We also noted that the applications for free and reduced lunch were not being reviewed by the Food Service Director for accuracy. We noted one application during testing that had illegible numbers and, therefore, the total income was not clear. The household was determined to be free by the District but there was no clarification to confirm the illegible numbers were correct as assumed. Per discussion with the Food Service Director, they agreed that the income number could have been improperly calculated and that the household could have been incorrectly determined as eligible for free meals. Cause: Control procedures were not in place to ensure that monthly Claims for Reimbursements and Free and Reduced applications were accurately entered/calculated before being submitted. Effect: Without timely review of reports before submission, requested grant revenue can be understated or overstated when based on erroneous submitted grant reports, In addition, other grant noncompliance can be overlooked. This could result in missed funding, excess funding, or other adverse conditions with the grantors. Questioned Costs: No questioned costs noted. Perspective Information: This appears to be a systemic issue as two out of the four months tested contained errors where the Lunch and Breakfast meal counts were switched on the Claims for Reimbursement form. Identification of Repeat Findings: Not a repeat finding. Recommendation: We recommend that the District develop written procedures that require a monthly review by another party for Claims for Reimbursement for the food service programs. This should be done prior to submitting the reimbursement claim to DESE. The review should be done to ensure that all information has been entered, is accurate, and is classified in the appropriate line to ensure reimbursements are for the correct amounts. In addition, we recommend that the District develop written procedures that require Free and Reduced Applications, including the calculations of income, be reviewed before being entered into the District’s tracking program. The review should be done to ensure that calculations of household income and determination of eligibility are correct when referenced to the Income Eligibility Guide.

Federal Agency: U.S. Department of Agriculture Passthrough Entity: Missouri Department of Elementary and Secondary Education Assistance Listing Number and Federal Program: Child Nutrition Cluster – 10.553 School Breakfast Program, 10.555 National School Lunch Program, 10.559 Summer Food Service Program for Children. Compliance Requirement: L. Reporting Criteria: Per 7 CFR 210.8(a) and 7 CFR 220.11(c), the District is required to have proper internal controls over the reporting of monthly meal counts to ensure that information submitted for free and reduced meals is accurate and complete. The monthly meal counts are reported to DESE for reimbursement based on the number of free and reduced meals served during the month. The amount of reimbursement will depend on the number of each type of meal and whether it was for breakfast or lunch. In accordance with 7 CFR 210.7(c)(1)(i), the District is required to correctly determine eligibility for free and reduced price lunches and afterschool snacks based on the requirements under 7 CFR 245. Under 7 CFR 245.6(c)(4), if the student is not automatically eligible under direct certification or another exception, the District must use income information provided by the household of the student to calculate the student's eligibility for free or reduced prices. The District makes applications available to households so that their income can be reported to the District for such purposes. The District then calculates the income on the applications and references the Income Eligibility Guidelines for the school year to determine if households are eligible or ineligible for free or reduced meals. Condition: During our testing, we noted a lack of oversight regarding the monthly Claims for Reimbursement. There was no review noted before they were submitted to DESE nor was there a subsequent review performed after submission. It was noted that the Claims for Reimbursements for February and April were not completed correctly. The Lunch and Breakfast meal counts were switched on both monthly claims. We also noted that the applications for free and reduced lunch were not being reviewed by the Food Service Director for accuracy. We noted one application during testing that had illegible numbers and, therefore, the total income was not clear. The household was determined to be free by the District but there was no clarification to confirm the illegible numbers were correct as assumed. Per discussion with the Food Service Director, they agreed that the income number could have been improperly calculated and that the household could have been incorrectly determined as eligible for free meals. Cause: Control procedures were not in place to ensure that monthly Claims for Reimbursements and Free and Reduced applications were accurately entered/calculated before being submitted. Effect: Without timely review of reports before submission, requested grant revenue can be understated or overstated when based on erroneous submitted grant reports, In addition, other grant noncompliance can be overlooked. This could result in missed funding, excess funding, or other adverse conditions with the grantors. Questioned Costs: No questioned costs noted. Perspective Information: This appears to be a systemic issue as two out of the four months tested contained errors where the Lunch and Breakfast meal counts were switched on the Claims for Reimbursement form. Identification of Repeat Findings: Not a repeat finding. Recommendation: We recommend that the District develop written procedures that require a monthly review by another party for Claims for Reimbursement for the food service programs. This should be done prior to submitting the reimbursement claim to DESE. The review should be done to ensure that all information has been entered, is accurate, and is classified in the appropriate line to ensure reimbursements are for the correct amounts. In addition, we recommend that the District develop written procedures that require Free and Reduced Applications, including the calculations of income, be reviewed before being entered into the District’s tracking program. The review should be done to ensure that calculations of household income and determination of eligibility are correct when referenced to the Income Eligibility Guide.

Federal Agency: U.S. Department of Agriculture Passthrough Entity: Missouri Department of Elementary and Secondary Education Assistance Listing Number and Federal Program: Child Nutrition Cluster – 10.553 School Breakfast Program, 10.555 National School Lunch Program, 10.559 Summer Food Service Program for Children. Compliance Requirement: L. Reporting Criteria: Per 7 CFR 210.8(a) and 7 CFR 220.11(c), the District is required to have proper internal controls over the reporting of monthly meal counts to ensure that information submitted for free and reduced meals is accurate and complete. The monthly meal counts are reported to DESE for reimbursement based on the number of free and reduced meals served during the month. The amount of reimbursement will depend on the number of each type of meal and whether it was for breakfast or lunch. In accordance with 7 CFR 210.7(c)(1)(i), the District is required to correctly determine eligibility for free and reduced price lunches and afterschool snacks based on the requirements under 7 CFR 245. Under 7 CFR 245.6(c)(4), if the student is not automatically eligible under direct certification or another exception, the District must use income information provided by the household of the student to calculate the student's eligibility for free or reduced prices. The District makes applications available to households so that their income can be reported to the District for such purposes. The District then calculates the income on the applications and references the Income Eligibility Guidelines for the school year to determine if households are eligible or ineligible for free or reduced meals. Condition: During our testing, we noted a lack of oversight regarding the monthly Claims for Reimbursement. There was no review noted before they were submitted to DESE nor was there a subsequent review performed after submission. It was noted that the Claims for Reimbursements for February and April were not completed correctly. The Lunch and Breakfast meal counts were switched on both monthly claims. We also noted that the applications for free and reduced lunch were not being reviewed by the Food Service Director for accuracy. We noted one application during testing that had illegible numbers and, therefore, the total income was not clear. The household was determined to be free by the District but there was no clarification to confirm the illegible numbers were correct as assumed. Per discussion with the Food Service Director, they agreed that the income number could have been improperly calculated and that the household could have been incorrectly determined as eligible for free meals. Cause: Control procedures were not in place to ensure that monthly Claims for Reimbursements and Free and Reduced applications were accurately entered/calculated before being submitted. Effect: Without timely review of reports before submission, requested grant revenue can be understated or overstated when based on erroneous submitted grant reports, In addition, other grant noncompliance can be overlooked. This could result in missed funding, excess funding, or other adverse conditions with the grantors. Questioned Costs: No questioned costs noted. Perspective Information: This appears to be a systemic issue as two out of the four months tested contained errors where the Lunch and Breakfast meal counts were switched on the Claims for Reimbursement form. Identification of Repeat Findings: Not a repeat finding. Recommendation: We recommend that the District develop written procedures that require a monthly review by another party for Claims for Reimbursement for the food service programs. This should be done prior to submitting the reimbursement claim to DESE. The review should be done to ensure that all information has been entered, is accurate, and is classified in the appropriate line to ensure reimbursements are for the correct amounts. In addition, we recommend that the District develop written procedures that require Free and Reduced Applications, including the calculations of income, be reviewed before being entered into the District’s tracking program. The review should be done to ensure that calculations of household income and determination of eligibility are correct when referenced to the Income Eligibility Guide.

Federal Agency: U.S. Department of Agriculture Passthrough Entity: Missouri Department of Elementary and Secondary Education Assistance Listing Number and Federal Program: Child Nutrition Cluster – 10.553 School Breakfast Program, 10.555 National School Lunch Program, 10.559 Summer Food Service Program for Children. Compliance Requirement: L. Reporting Criteria: Per 7 CFR 210.8(a) and 7 CFR 220.11(c), the District is required to have proper internal controls over the reporting of monthly meal counts to ensure that information submitted for free and reduced meals is accurate and complete. The monthly meal counts are reported to DESE for reimbursement based on the number of free and reduced meals served during the month. The amount of reimbursement will depend on the number of each type of meal and whether it was for breakfast or lunch. In accordance with 7 CFR 210.7(c)(1)(i), the District is required to correctly determine eligibility for free and reduced price lunches and afterschool snacks based on the requirements under 7 CFR 245. Under 7 CFR 245.6(c)(4), if the student is not automatically eligible under direct certification or another exception, the District must use income information provided by the household of the student to calculate the student's eligibility for free or reduced prices. The District makes applications available to households so that their income can be reported to the District for such purposes. The District then calculates the income on the applications and references the Income Eligibility Guidelines for the school year to determine if households are eligible or ineligible for free or reduced meals. Condition: During our testing, we noted a lack of oversight regarding the monthly Claims for Reimbursement. There was no review noted before they were submitted to DESE nor was there a subsequent review performed after submission. It was noted that the Claims for Reimbursements for February and April were not completed correctly. The Lunch and Breakfast meal counts were switched on both monthly claims. We also noted that the applications for free and reduced lunch were not being reviewed by the Food Service Director for accuracy. We noted one application during testing that had illegible numbers and, therefore, the total income was not clear. The household was determined to be free by the District but there was no clarification to confirm the illegible numbers were correct as assumed. Per discussion with the Food Service Director, they agreed that the income number could have been improperly calculated and that the household could have been incorrectly determined as eligible for free meals. Cause: Control procedures were not in place to ensure that monthly Claims for Reimbursements and Free and Reduced applications were accurately entered/calculated before being submitted. Effect: Without timely review of reports before submission, requested grant revenue can be understated or overstated when based on erroneous submitted grant reports, In addition, other grant noncompliance can be overlooked. This could result in missed funding, excess funding, or other adverse conditions with the grantors. Questioned Costs: No questioned costs noted. Perspective Information: This appears to be a systemic issue as two out of the four months tested contained errors where the Lunch and Breakfast meal counts were switched on the Claims for Reimbursement form. Identification of Repeat Findings: Not a repeat finding. Recommendation: We recommend that the District develop written procedures that require a monthly review by another party for Claims for Reimbursement for the food service programs. This should be done prior to submitting the reimbursement claim to DESE. The review should be done to ensure that all information has been entered, is accurate, and is classified in the appropriate line to ensure reimbursements are for the correct amounts. In addition, we recommend that the District develop written procedures that require Free and Reduced Applications, including the calculations of income, be reviewed before being entered into the District’s tracking program. The review should be done to ensure that calculations of household income and determination of eligibility are correct when referenced to the Income Eligibility Guide.

Findings and Questioned Costs – Major Federal Award Programs Audit Federal Agency: U.S. Department of Education Passthrough Entity: Missouri Department of Elementary and Secondary Education Assistance Listing Number and Federal Program: 84.010 Title I Grants to Local Educational Agencies Compliance Requirement: B. Allowable Costs Criteria: Per 2 CFR 200.430(g)(1)(i), the District is required to have records that are supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated. The District uses semi-annual certifications to determine if the salaries and/or employee benefits of its employees are allowable for the grant. These certifications are to be signed after each semi-annual period by the teacher and the Title I program director. These certifications show that the teachers’ time was spent under the Title I program, and their salaries and benefits are allowable for the Title I program. Condition: During the course of our audit, we reviewed semi-annual certifications for all Title I teachers, as required. These certifications are used to verify that the employee spent one hundred percent of their time working in the Title I program. Per requirements, these certifications should be signed at the end of the applicable period as that is when the actual time spent in the program is known. However, during our review, we noted that all the certifications were signed at the beginning of the applicable semi-annual period. Cause: There is a lack of oversight in this area. Supervisors should ensure the teachers complete the semi-annual certifications in a timely manner after the end of each semi-annual period. Also, program directors should be reviewing the signed certifications to ensure all program requirements are followed to avoid any noncompliance issues and consequences. Effect: Semi-annual certifications are listed under the Allowable Costs/Cost Principles compliance requirement. In order to apply expenditures to the Title I Program, the employees need to certify that they are spending all of their time on that program. Without this certification, it is not clear that the amounts reported as Title I expenditures are indeed eligible expenditures. Questioned Costs: No questioned costs noted. Perspective Information: This appears to be a systemic problem since all Title I semi-annual certifications for the fiscal year 2024 were reviewed and all certifications were filled out at the beginning of each semi-annual period instead of subsequent to the period. Identification of Repeat Findings: Not a repeat finding. Recommendation: We recommend that the District employ stronger oversight in this area by assigning a review to the Title Program Director or equivalent. Once the certifications are signed by a supervisor, they should be forwarded to this point person for their review and signature. The certifications should be reviewed to ensure each Title teacher is completing a semi-annual certification and that it is being signed by the supervisor. These certifications should also have a due date twice a year to ensure they are done timely and are not overlooked. These should be added to the review checklist already used for Title I reporting. Views of Responsible Officials: The District will set up automated reminders through the internal tracking system with specific deadlines to ensure that all certifications are completed and signed no later than 30 business days after the end of the applicable periods. Regular checks will be conducted by the Title 1 Coordinator to verify that all certifications are completed and signed within the required timeframes. All relevant staff members will undergo training on the new procedures, and will be assigned roles and responsibilities for monitoring and submitting the certifications. See Corrective Action Plan.