Finding Text
1. Site Claim Reporting
Finding Number: 2023-002
Assistance Listing Number and Title: AL # 10.555/10.553 Child Nutrition Cluster
Federal Award Identification Number / Year: 2023
Federal Agency: U.S. Department of Agriculture
Compliance Requirement: Reporting
Pass-Through Entity: Ohio Department of Education and Workforce
Repeat Finding from Prior Audit? No
Noncompliance and Material Weakness
2 CFR § 400.1 gives regulatory effect to the Department of Agriculture for 2 CFR §200.302(b)(3) which provides that the financial management system of each non-Federal entity must provide for records that identify adequately the source and application of funds for federally- funded activities. These records must contain information pertaining to federal awards, authorizations, obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation.
2 CFR § 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
7 CFR §§ 210.7(c), 210.8(c), and 225.9(d)) provide that at a minimum, a claim must include the number of reimbursable meals/milk served by category and type during the period (generally a month) covered by the claim. All meals claimed for reimbursement must (a) be of types authorized by the school food authority’s, institution’s, or sponsor’s administering agency; (b) be served to eligible children; and (c) be supported by accurate meal counts and records indicating the number of meals served by category and type.
20% percent of the site claim form submissions during fiscal year 2023 did not agree to underlying supporting documentation. These inaccurate submissions resulted in an under-reimbursement of $6,047. The School District contacted the Ohio Department of Education and Workforce in April 2024 and were granted a One-Time-Exception for the one month's underreporting of $6,275. These errors occurred due to a weakness in internal controls, which failed to ensure site claim forms for reimbursable meals served at each building and submitted by the Center to the Ohio Department of Education were entered correctly.
The School District should implement policies and procedures to help ensure that monthly site claim forms are reviewed and submitted to reflect actual counts for reimbursable meals served. Further, measures should be taken to ensure staff completing the site claim forms are adequately trained.