Audit 396377

Criteria or specific requirement: Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Schools was unable to provide evidence of timesheet approval for 2 of 40 payroll samples tested. Context: Forty timesheets were selected for testing and the following exceptions were noted: • For 2 of 40 timesheets selected for testing, Schools was unable to provide documentation evidencing the timesheets were properly approved. Questioned costs: Not applicable. Cause: Schools’ procedures and controls were not sufficient to ensure that time and effort reporting was accurately performed and documented, nor that employee time was properly allocated and approved. Effect: There is an increased risk of charging unallowed payroll costs to the program. Recommendation: Schools should reevaluate its current process, implement proper controls, and perform additional training over time and effort reporting. Schools should not seek federal reimbursement unless it can substantiate that the time and effort was dedicated to the federal program. Documentation should be readily available for audit.

Criteria or specific requirement: SFAs and sponsors must submit monthly claims for reimbursement for meals and snacks served to eligible students within 60 days following the last day of the month covered by the claim. Each month's claim for reimbursement and all data used in the claims review process must be maintained on file. Accurate records must be maintained justifying all meals claimed and documenting that all Program funds were spent only on allowable Child Nutrition Program costs. Condition: Schools was unable to provide evidence of review and approval for 3 of 3 reporting samples tested. Context: The schools did not properly review and approve 3 of 3 Meal Reimbursement Reports. Questioned costs: Undetermined. Cause: The schools did not have internal controls established to ensure proper review and approval of the NSLP/FFVP Claim Reimbursement Summary/Meal Reimbursement Summary. Effect: There is a risk that meals were submitted for reimbursement; however, they did not qualify. Recommendation: We recommend that the Schools review their policies and procedures to ensure they include proper review and approval of the Meal Reimbursement Reports. Views of responsible officials: The School agrees with this finding. See separate Corrective Action Plan related to this finding.