Audit 383464

Finding 2025-003 Federal Agency: U.S. Department of Education 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, 10.555 COVID-19 Supply Chain Assistance Compliance Requirements: E. Eligibility Criteria: 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. Per 7 CFR 245.6(d), if income information is available to the District from other sources, the District is able to determine that a child whom no application was submitted would meet the eligibility. If no income information is submitted by the student’s family or otherwise available, then the student would be charged full price for meals. Condition: During the course of our audit, we noted that the District had two students in the same household classified as eligible for free meals, however when income for the household was recalculated during testing, the income was above the maximum threshold for free meals. The students should have been eligible for reduced price meals versus free meals. The students were not directly certified for free meals in any other manner. Cause: The household reported an income amount that was being earned by one of the students in the household. The District did not include this income amount in the calculation. After adding the income earned by the student into household income, the calculation reflected total household income in the range that was eligible for reduced price meals. Effect: With improper eligibility status on students for free or reduced meals, the District could over or under report their meal counts by allowing ineligible students to receive reduced or free meals. This could result in the District receiving more in their monthly Claims for Reimbursement than qualified. It could also cause the District to under report their meal counts if eligible students are omitted from the free and reduced meal counts. In addition, the amount charged to students who are classified as full or reduced price may be over or understated if they are classified incorrectly. Questioned Costs: No questioned costs. Perspective Information: This appears to be an isolated event as it was only noted on two students in our sample who were both in the same household. Identification of Repeat Findings: Not a repeat finding. Recommendation: We recommend that the District implement a subsequent review of the free/reduced applications to ensure that each student’s free or reduced meal status is correctly determined. Also, we recommend that the District review the free/reduced list to ensure that all students are either directly certified through another program or that the appropriate income information has been submitted to determine eligibility.

Finding 2025-002 Federal Agency: U.S. Department of Education Passthrough Entity: Missouri Department of Elementary and Secondary Education Assistance Listing Number and Federal Program: 84.027 Special Education Grants to States 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 completed after each semi-annual period by the Special Education program director. These certifications show that the teachers’ time was spent under the Special Education program, and their salaries and benefits are allowable for the Special Education program. Condition: During the course of our audit, we reviewed semi-annual certifications for all teachers whose salaries and/or employee benefits are allocated to the Special Education program, as required. These certifications are used to verify that employees spent all or a portion of their time working on these programs. Per requirements, these certifications should be completed for all teachers whose salaries and/or employee benefits are allocated to the Special Education program. During our testing, we noted that one of the teachers selected for testing was not included on the semi-annual certifications. Cause: There is a lack of oversight in this area. The program director should ensure that applicable teachers have semi-annual certifications completed for their time spent on the Special Education program during each semi-annual period. Also, a second party should be reviewing the signed certifications to ensure the 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 Special Education program, the program director needs to certify that all teachers whose salaries and/or benefits that are going to be applied to the program are spending all or a portion of their time on that program. Without this certification, it is not clear that the amounts reported as Special Education expenditures are indeed eligible expenditures. Questioned Costs: No questioned costs noted. Perspective Information: This appears to be an isolated problem as further review of the semi-annual certifications show that all other teachers whose salaries and/or employee benefits applied to the Special Education program had semi-annual certifications for their time spent on the program. Identification of Repeat Findings: Not a repeat finding. Recommendation: We recommend that the District implement stronger oversight in this area by assigning a review of the certifications after they are completed. Once the certifications are signed by the program director, they should be forwarded to a second party for their review and signature. This review should occur to ensure each Special Education teacher has a semi-annual certification completed for their time spent on the program. Review of the certifications should also have due dates of twice per year to ensure they are done timely and are not overlooked.