Finding 2025–001: Reporting – Recordkeeping Federal Department: U.S. Department of Agriculture Federal Award Identification Numbers and Year: 25N1199 Pass-through Agency: Illinois State Board of Education (ISBE) Child Nutrition Cluster: Summer Food Service Program for Children (SFSPC), Federal Assistance Listing Number 10.559 Criteria Federal regulations (7 CFR 225.15(d)) state (1) each sponsor shall hold Program training sessions for its administrative and site personnel and must not allow a site to operate until personnel have attended at least one of these training sessions. The State agency may waive these training requirements for operation of the Program during unanticipated school closures. (i) Training of site personnel must, at a minimum, include: the purpose of the Program; site eligibility; recordkeeping; site operations, including both congregate and non-congregate meal services; meal pattern requirements; and the duties of a monitor. (ii) Each sponsor must ensure that its administrative personnel attend State agency training provided to sponsors, and sponsors must provide training throughout the summer to ensure that administrative personnel are thoroughly knowledgeable in all required areas of Program administration and operation and are provided with sufficient information to enable them to carry out their Program responsibilities. (iii) Each site must have present at each meal service at least one person who has received this training. (2) Sponsors must conduct pre-operational visits for new sites, sites that experienced operational problems the previous year, and existing sites that are new to non-congregate meal service, to determine that the sites have the capacity to provide meal service for the anticipated number of children in attendance and the capability to conduct the proposed meal service. (3) Sponsors must visit each of their sites, as specified in paragraphs (d)(3)(i) through (iv) of this section, at least once during the first two weeks of program operations and must promptly take such actions as are necessary to correct any deficiencies. Sponsors must conduct these visits for: (i) All new sites; (ii) All existing sites that are new to providing non-congregate meal service; (iii) All sites that have been determined by the sponsor to need a visit based on criteria established by the State agency pertaining to operational problems noted in the prior year, as set forth in § 225.7(o); and (iv) Any other sites that the State agency has determined need a visit. (4) Sponsors must conduct a full review of food service operations at each site at least once during the first four weeks of Program operations, and thereafter must maintain a reasonable level of site monitoring. Sponsors must complete a monitoring form developed by the State agency during the conduct of these reviews. Sponsors may conduct a full review of food service operations at the same time they are conducting a site visit required under paragraph (d)(3) of this section. The United States Department of Agriculture, Food and Nutrition Service, The Summer Food Service Program (SFSP), 2024 Introduction to the Summer Food Service Program Administration Guide, Unit 4: Operating the Meal Service for the Summer Food Service Program states, “It is critical that site personnel and monitors understand the importance of accurate point of service meal counts. Only complete meals served to eligible children can be claimed for reimbursement. Meal counts are required for each day and each meal service in which meals and snacks are served. Therefore, meals and snacks must be counted at the actual point of service, as they are served, to ensure that an accurate count of meals served is obtained and reported). Counting meals at the point of service also allows site personnel to ensure that only complete meals are served.” Also, Unit 3: Administering Summer Food Service Program states, “sponsors must be able to document that they have complied with monitoring requirements. Monitors must submit the following reports: Pre-operational site visits for new sites, sites that experienced operational problems the previous year, and existing sites that are new to non-congregate meal service; Initial site visits, conducted at least once during the first 2 weeks of Program operations; and Additional site visits conducted throughout the period of Program operation.” Chicago Park District’s (the District) Summer Food Program Monitor Manual requires monitors checking site operations to make sure that the site maintains adequate records and that the program is operating in accordance with the requirements. To comply with this requirement, the District utilizes a monitoring checklist that is attached to each site file. The checklist requires documentation of ISBE-approved application, ISBE participation details, the District application, field trip data, authorized signature form, training sign-in sheets, certificate of training, park enrollment roster, and site responsibilities. Per the District’s Summer Food Program Management Manual, the District replaced a series of paper forms with two online forms: Summer Food Weekly Summary and Summer Food Program Daily Timesheets. However, two paper documents will continue to exist. They are the daily receipts and the state-mandated Daily Meal Count Form. 2 CFR Part 200, Subpart D – Post Federal Awards Requirements, Section 200.303 Internal Controls states, “The recipient and subrecipient must: (a) Establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient and subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the 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). (b) Comply with the U.S. Constitution, Federal statutes, regulations, and the terms and conditions of the Federal award. (c) Evaluate and monitor the recipient’s or subrecipient’s compliance with statutes, regulations, and the terms and conditions of Federal awards. (d) Take prompt action when instances of noncompliance are identified. (e) Take reasonable cybersecurity and other measures to safeguard information including protected personally identifiable information and other types of information. This also includes information the Federal agency or pass-through entity designates as sensitive or other information the recipient or subrecipient considers sensitive and is consistent with applicable Federal, state, local, and tribal laws regarding privacy and responsibility over confidentiality. Condition During the current-year audit period, the District did not adequately document its compliance with the special tests and provision requirements of the SFSPC. This included maintaining adequate controls over required monitoring and meal count forms to ensure forms were properly completed and approved by authorized personnel. Cause Per our discussions with management, the SFSP was administered across 197 sites on a daily basis during the summer months. Specifically, in 2025, the program and the corrective actions planned were interrupted and significantly impacted due to a shortage of staff as positions were not filled successfully. Effect Failure to maintain supporting documentation of the required monitoring and meal count forms and ensure that the forms have been properly completed and approved by authorized personnel is a violation of the program’s requirements and impairs the District’s ability to adequately monitor the federally funded program. This could also result in questioned and disallowed costs, which the District may need to reimburse to its grantor agency. Questioned Costs None. Context During our testing of monitoring at 25 sites (total sites operating under the program during 2025 were 197 sites), we noted the following: For three sites (12%), the site monitoring review was not conducted within the first four weeks of program operations, as required. For one site (4%), lunch was served at 11:30 AM on one day, which was outside the approved meal service window of 12:00 PM to 12:30 PM. For the 25 sites sampled, we tested a total of 10 days (July 7 through July 11 and July 21 through July 25) from a population of 39 days (calculated based on the number of days meals were claimed for reimbursements during the program) to verify that the delivery ticket, daily meal count form, and the Summer Food Weekly Summary form were properly completed and reviewed by authorized personnel. We noted the following: For one site (4%), 85 snacks were incorrectly reported and claimed as lunch, resulting in a total of $350 net over-claimed in meal reimbursements. Identification of Repeated Findings Repeated (Prior Finding Numbers 2024-001, 2023-001, and 2022-001). Recommendation We recommend the District continue to implement internal controls to improve compliance with federal regulations over the SFSP. In addition, we recommend the District ensure adequate staff resources and training are in place to ensure accurate reporting of all meals served, as well as all required forms are properly completed. Also, we suggest the District update its policy manual to define “reasonable monitoring” of the SFSP program, including any deviations from its current practice of completing at least two monitoring site reviews forms. Lastly, we suggest the District update its required forms (daily meal count, site visit/monitoring site review) to have authorized personnel include a printed signature, which will assist in easily identifying and verifying that the person is authorized to sign the form(s). Views of Responsible Officials and Planned Corrective Action The District agrees with the finding and recommendation. The District’s corrective action plan is on page 15.