Finding Text
50000 – Eligibility
Federal Agency: U.S. Department of Agriculture
Pass-Through Entity: California Department of Education (CDE)
Program Name: Child Nutrition Cluster
Assistance Listing Number: 10.553, 10.555
Compliance Requirement: E (Eligibility)
Type of Finding: Material Weakness, Material Noncompliance
Criteria or Specific Requirements
Per Title 7, U.S. Code of Federal Regulations, Subtitle B, Chapter II, Subchapter A, Part 245.6(c) (4) states that the local educational agency must use the income information provided by the household on the application to calculate the household's total current income. When a household submits an application containing complete documentation, as defined in § 245.2, and the household's total current income is at or below the eligibility limits specified in the Income Eligibility Guidelines as defined in § 245.2, the children in that household must be approved for free or reduced price benefits, as applicable.
Per Title 7, U.S. Code of Federal Regulations, Subtitle B, Chapter II, Subchapter A, Part 245.6(e) states that the local educational agency must maintain documentation substantiating eligibility determinations on file for 3 years after the date of the fiscal year to which they pertain, except that if audit findings have not been resolved, the documentation must be maintained as long as required for resolution of the issues raised by the audit.
Condition
The District did not have sufficient controls in place to ensure that students were accurately included as eligible to receive free or reduced-price meals. There was no evidence that meal applications had been reviewed by the Director of Nutrition Services. Of 40 students selected for testing, six had been determined to be eligible for reduced-price meals while the audit determined that they were eligible for free meals. No application could be located for one student.
Cause
The condition identified appears to have materialized due to the District’s lack of established internal control procedures to ensure compliance with the requirements under Title 7, U.S. Code of Federal Regulations, Subtitle B, Chapter II, Subchapter A, Part 245.6 (c) and Part 245.6 (e).
Effect
The District has not complied with the requirements identified in Title 7, U.S. Code of Federal Regulations, Subtitle B, Chapter II, Subchapter A, Part 245.6 (c) and Part 245.6 (e).
Questioned Costs
There were no questioned costs associated with the identified condition.
Context/Sampling
The condition was identified through inquiry with District personnel and through review of available supporting documentation for the student eligibility for free or reduced-price meals. A nonstatistical sample of 40 out of 847 students were selected for eligibility testing.
Repeat Finding
No.
Recommendation
The District should review the requirements stated in Title 7, U.S. Code of Federal Regulations, Subtitle B, Chapter II, Subchapter A, Part 245.6 (c) and Part 245.6 (e) and implement procedures to address the control deficiencies currently identified. The District should retain all supporting documentation used to complete the eligibility determination for a minimum of three years as required by the Code.