Finding 1084662 (2023-001)

-
Requirement
A
Questioned Costs
$1
Year
2023
Accepted
2024-11-18

AI Summary

  • Core Issue: The District charged unallowable costs of $25,938 to the Supply Chain Assistance award for processed food items, violating federal regulations.
  • Impacted Requirements: Compliance with federal allowable cost requirements for the Child Nutrition Cluster programs, specifically the Supply Chain Assistance award.
  • Recommended Follow-up: The District should enhance staff training on program requirements and implement stronger monitoring to ensure only allowable costs are charged to federal programs.

Finding Text

2023-001 The District charged unallowable costs to the Supply Chain Assistance award of the Child Nutrition Cluster. Assistance Listing Number and Title: 10.553 – School Breakfast Program 10.555 – National School Lunch Program 10.559 – Summer Food Service Program for Children Federal Grantor Name: U.S. Department of Agriculture Federal Award/Contract Number: N/A Pass-through Entity Name: Office of Superintendent of Public Instruction Pass-through Award/Contract Number: N/A Known Questioned Cost Amount: $25,938 Prior Year Audit Finding: N/A Background The District participates in the Child Nutrition Cluster, which includes the School Breakfast Program, National School Lunch Program and Summer Food Service Program for Children. These programs provide free or reduced-price meals to students from families with low incomes. In the 2022–23 school year, the District received $1,571,422 in federal funding, including $287,371 in Supply Chain Assistance awards, to administer these programs. Federal regulations require school districts to comply with allowable uses of the funds. Specifically, for the Supply Chain Assistance awards, district must use funds exclusively to purchase domestic, unprocessed or minimally processed food products for the school meal programs. Description of Condition The District had adequate internal controls for ensuring it materially complied with activities allowed and allowable cost requirements. While the District had a process to track all food items it claimed under the Supply Chain Assistance award, our audit found the District charged unallowable and unsupported food items to the award. Cause of Condition The Supply Chain Assistance award was new for the Child Nutrition Cluster in the 2022–23 school year. The District did not perform sufficient monitoring and relied on one staff member to ensure allowable costs were applied to the program. Staff were unfamiliar with the restrictive requirements for the award and claimed all food-related expenditures as allowable. Effect of Condition and Questioned Costs We determined the District received reimbursement for 17 unallowed food purchases of processed food products totaling $25,938. We are questioning these costs. Federal regulations require the Office of the Washington State Auditor to report known questioned costs that are more than $25,000 for each type of compliance requirement. Failure to comply with federal requirements may jeopardize the District’s eligibility for future federal assistance. Recommendation We recommend the District monitor to ensure staff understand program requirements and only charge allowable costs to federal programs in compliance with federal allowable cost requirements. District’s Response The district concurs with the auditors regarding claiming processed items under the Supply Chain Assistance award. Although the district was aware of the restrictions on this award and sought input from others regarding the allowability of the claimed items, there were several processed food products that slipped into the final claim. The disallowed items cost a total of $25,938. The district had an additional list of fruits and vegetables for 2022-23 totaling $75,059.71 that were not included in the original claim, an amount far exceeding the disallowed total. For 2023-24, the district has made multiple checks for processed vs unprocessed foods claimed in the Supply Chain Assistance award. This includes multiple staff reviewing the claimed items and cross-checking against the 2022-23 claim. All items deemed processed have been removed from the2023-24 claim. Auditor’s Remarks We thank the District for its cooperation throughout the audit and the steps it is taking to address these concerns. We will review the status of the District’s corrective action during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, Subpart E, Cost Principles, establishes requirements for determining allowable costs and supporting costs allocated to federal programs. Office of Superintendent of Public Instruction (OSPI) Bulletin 029-22, Child Nutrition Services, establishes requirements for allowable use of Supply Chain Assistance funds.

Categories

Questioned Costs Allowable Costs / Cost Principles School Nutrition Programs Subrecipient Monitoring

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
84.010 Title I Grants to Local Educational Agencies $394,322
84.027 Covid 19 - Special Education Grants to States $393,231
10.555 National School Lunch Program $179,445
84.027 Special Education Grants to States $148,758
32.009 Covid 19 - Emergency Connectivity Fund Program $130,935
10.553 School Breakfast Program $126,332
12.U01 Usmc Jrotc $94,370
84.367 Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) $85,985
21.027 Covid 19 - Coronavirus State and Local Fiscal Recovery Funds $73,260
84.173 Special Education Preschool Grants $71,741
84.011 Migrant Education State Grant Program $67,438
93.354 Covid 19 - Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response $59,476
97.036 Covid 19 - Disaster Grants - Public Assistance (presidentially Declared Disasters) $57,964
84.424 Student Support and Academic Enrichment Program $41,160
84.173 Covid 19 - Special Education Preschool Grants $33,071
10.559 Summer Food Service Program for Children $25,487
10.665 Schools and Roads - Grants to States $21,905
84.365 English Language Acquisition State Grants $20,000
45.310 Grants to States $5,402
84.048 Career and Technical Education -- Basic Grants to States $2,591
84.425 Covid 19 - Education Stabilization Fund $517