Finding 2023–001: Reporting – Recordkeeping
Federal Department: U.S. Department of Agriculture
Federal Award Identification Numbers and Year: 23N1199 and 2023
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 shall allow no site to operate until personnel have attended at least one of these training sessions. Each site shall have present at each meal service at least one person who has received this training. (2) Sponsors shall visit each of their sites at least once during the first week of operation under the Program and shall promptly take such actions as are necessary to correct any deficiencies. (3) Sponsors shall review food service operations at each site at least once during the first four weeks of Program operations, and thereafter shall maintain a reasonable level of site monitoring. Sponsors shall complete a monitoring form developed by the State agency during the conduct of these
reviews.
The United States Department of Agriculture, Food and Nutrition Service, The Summer Food Service Program (SFSP), 2016 Administration Guide, Chapter 7, Staff Duties and Training, 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. Therefore, meals must be counted at the actual point of service (i.e., meals are counted 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, Chapter 10, Recordkeeping, states sponsors must be able to document that they have met their monitoring requirements. Monitors must submit a report for pre-operational site visits, site visits during the first week of program operations, and site visits throughout the summer.
Chicago Park District’s (the District) Summer Food Program 2018 Monitor’s Orientation Handbook requires monitors checking site operations to make sure that the site maintains adequate records and that the program is operating in accordance with the requirement. 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 detail, the District application, field trip data, authorized signature form, 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, 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 non-Federal entity must: (a) 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 be in compliance 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). (b) Comply with Federal statutes, regulations, and the terms and conditions of the Federal
awards. (c) Evaluate and monitor the non-Federal entity's compliance with statutes, regulations and the terms and conditions of Federal awards.
Condition
During the current audit period, the District did not adequately document its compliance with the special tests and provisions 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 Summer Food Service Program was administered across 193 sites on a daily basis during the summer months. Specifically, in 2023, 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 are 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 operated under the program during 2023 was 195 sites), we noted the following:
For four sites (16%), the monitoring site review form was not properly completed. The form was either missing the monitor departure time or monitor departed early (five minutes after the start of the approved mealtime).
For two sites (8%), we were unable to properly identify who signed the site visit or the monitoring site review forms because of illegible signatures, without some assistance from the District’s personnel.
For the 25 sites sampled, we tested a total of 10 days (July 17 through July 21 and through July 24 through July 28) from a population of 29 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 two (2) sites (8%), the delivery receipt form either was missing the signature or was not signed.
Five sites (20%) over-claimed the number of meals served by $737. Three of these sites over-claimed 23 lunches and nine snacks served as part of its monthly claim reimbursement. For the remaining two sites, we noted the District was reimbursed for a total of 165 lunches instead of 165 snacks as reported per the daily meal count forms, which represented $615 of the total amount over-claimed. These amounts did not agree with the number of meals reported on the daily meal count forms.
Two sites (8%) under-claimed the number of meals served by $119. The site under-claimed 21 lunches and 15 snacks served as part of its monthly claim reimbursement. These amounts did not agree with the number of meals reported on the daily meal count forms.
For two sites (8%), we were unable to properly identify who signed the delivery ticket and/or daily meal count forms due to illegible signature, without some assistance from the District’s personnel.
In addition, per our discussions with program personnel, we noted the District’s current practice is to follow ISBE’s regulations regarding site visits and reviews by completing the first week visit and reasonable monitoring as defined by completing at least two monitoring site reviews form during the program’s operation. However, we noted that the current policy manual does not include this practice nor define instances whereby more than two reviews would be completed.
Identification of Repeated Findings
Repeated (Prior Finding No. 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.