Audit 390321

2025-005 U.S. Department of Agriculture Pass-Through Iowa Department of Education Child Nutrition Cluster Programs: 10.553 School Breakfast Program 10.555 National School Lunch Program 10.555 Commodities- Department of Defense (Noncash) 10.555 Commodities (Noncash) 10.559 Summer Food Service Program for Children 10.582 Fresh Fruit and Vegetable Program Federal Award Year: 2025 Finding: The District does not have a process to properly maintain documentation to support compliance with eligibility requirements within the federal program. Criteria: The 2025 Office of Management and Budget Compliance Supplement states the following for Compliance Requirements-Eligibility – Direct Certification: “Annual eligibility determinations may also be based on the child’s household receiving benefits under the Supplemental Nutrition Assistance Program (SNAP), Food Distribution Program on the Indian Reservations (FDPIR), the Head Start Program, or under most circumstances, the Temporary Assistance for Needy Families (TANF) program. A household may furnish documentation of its participation in one of these programs; or the school… may obtain the information directly from the state or local agency that administers these programs.” The Iowa Department of Education’s Eligibility Manual for School Meals states: “LEAs must keep direct certification documentation on file for a minimum of three years after submission of the final claim for reimbursement for the fiscal year to which the records apply. Documentation must be kept longer if required by an audit. If audit findings have not been resolved, the applications must be retained as long as required for resolution of the issues raised by the audit [7 CFR 245.6(e).” Condition: The District does not have a process to retain monthly data used in determining eligibility for free and reduced priced meals from the State E Look up system for direct certification statuses. The District does not have documentation readily available that was used in determining eligibility for free and reduced priced meals from the State E Look up system for direct certification statuses. Context: The District could not produce documentation of state certification for 3 out of 25 students selected for eligibility testing. They were all subsequently determined to be eligible by utilizing the State E Look up system, however, the District did not retain the original documentation to support eligibility. Cause: The District does not monitor compliance with eligibility recordkeeping rules as established by the Iowa Department of Education and the Office of Management and Budget. Effect: The District does not have adequate documentation to ensure compliance with federal requirements regarding eligibility recordkeeping. The District could incorrectly identify students for free and reduced-price lunches. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend the District implement a process to review and to retain records used in determining eligibility for the required period of time. Response and Corrective Action Plan: The District will implement a process to review and retain records used in determining eligibility as outlined by the Iowa Department of Education and Office of Management and Budget.