FAC Explorer

Finding 1115504 (2024-004)

Significant Deficiency
Requirement
A
Questioned Costs
-
Year
2024
Accepted
2025-03-28
Audit: 349776
Organization: City of Boston (MA)
Auditor: Kpmg LLP

AI Summary

  • Core Issue: There are significant deficiencies in internal controls over meal count accuracy for the Child and Adult Care Food Program, leading to incomplete and inaccurate reimbursement claims.
  • Impacted Requirements: Compliance with federal regulations on allowable operating costs and effective internal controls as outlined in 7 CFR 226.11(c) and 2 CFR 200.303.
  • Recommended Follow-Up: Enhance review procedures for meal counts and ensure proper documentation is maintained to support reimbursement claims, as well as hold staff accountable for compliance.

Finding Text

Finding number: 2024-004 Federal agency: U.S. Department of Agriculture Pass-through agency: Commonwealth Department of Elementary and Second Education Program: Child and Adult Care Food Program ALN #: 10.558 Award number: 13-035-CF-815 Award year: July 1, 2023 to June 30, 2024 Finding: Internal Control over Allowability Prior Year Finding: No Type of Finding: Significant Deficiency Criteria Reimbursement for Operating Costs of Child and Adult Care Centers CACFP centers and sponsors of centers shall be reimbursed solely according to the meals-times-rates formula outlined in II, “Program Procedures.” Costs claimed by the institution as operating costs must be related to preparing and serving meals to children and/or adults under the CACFP (7 CFR 226.11(c) and definition of “operating costs” in 7 CFR 226.2). Additionally, 2 CFR 200.303 indicates that non-Federal entities receiving Federal awards must 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. Condition During our testing over the allowability of meals reimbursed, we noted that edit checks were performed and documented monthly at the school site level confirming meal count reports. However, out of a sample of 12 monthly Field Coordinator reviews across 72 school sites, there were 3 reviews where the City was unable to provide evidence that the Field Coordinator’s review and approval took place. Cause Field Coordinator edit checks were not precise enough to detect meal count differences for those sites which use a hardcopy tally sheet to count meals priors to entering into the POS system. Additionally, the City was unable to provide documentation showing that the Field Coordinator's review and approval took place in cases. This appears to be due to an insufficient process for documenting and retaining evidence of the Field Coordinator's monthly review. Effect Meal count reports utilized for the monthly claims for reimbursement are not complete and accuracy, nor do they have complete and accurate underlying records to substantiate the meals requested for reimbursement. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs None Recommendation We recommend that FNS enhance their policies and procedures to include a more thorough review and approval of meal counts at the school level to ensure allowability as well as completeness and accuracy of the meal counts submitted for reimbursement. Additionally, we recommend FNS re-enforce their policy to ensure underlying records are maintained in accordance with program requirements. View of Responsible Officials from the Auditee FNS agrees with the importance of accurate meal counting and claiming. We have implemented a new standard operating procedure for after-school supper meals served under CACFP that includes more thorough review of meal counts and related documentation prior to submission of the claim, monthly documentation of the edit check review by Field Coordinators using a Google Form, and procedures for holding program and site-based staff accountable for correctly documenting meal counts and submitting paperwork in a timely manner.

Categories

Cash Management Significant Deficiency Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Other Findings in this Audit

  • 539061 2024-003
    Significant Deficiency Repeat
  • 539062 2024-004
    Significant Deficiency
  • 539063 2024-005
    Significant Deficiency
  • 539064 2024-006
    Significant Deficiency Repeat
  • 539065 2024-007
    Significant Deficiency Repeat
  • 539066 2024-008
    Significant Deficiency Repeat
  • 539067 2024-009
    Significant Deficiency Repeat
  • 539068 2024-009
    Significant Deficiency Repeat
  • 539069 2024-009
    Significant Deficiency Repeat
  • 539070 2024-010
    Significant Deficiency Repeat
  • 539071 2024-010
    Significant Deficiency Repeat
  • 539072 2024-011
    Material Weakness
  • 539073 2024-012
    Significant Deficiency Repeat
  • 1115503 2024-003
    Significant Deficiency Repeat
  • 1115505 2024-005
    Significant Deficiency
  • 1115506 2024-006
    Significant Deficiency Repeat
  • 1115507 2024-007
    Significant Deficiency Repeat
  • 1115508 2024-008
    Significant Deficiency Repeat
  • 1115509 2024-009
    Significant Deficiency Repeat
  • 1115510 2024-009
    Significant Deficiency Repeat
  • 1115511 2024-009
    Significant Deficiency Repeat
  • 1115512 2024-010
    Significant Deficiency Repeat
  • 1115513 2024-010
    Significant Deficiency Repeat
  • 1115514 2024-011
    Material Weakness
  • 1115515 2024-012
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
84.425 Education Stabilization Fund $203.78M
84.010 Title I Grants to Local Educational Agencies $58.87M
14.267 Continuum of Care Program $40.38M
10.555 National School Lunch Program $30.91M
84.027 Special Education Grants to States $17.94M
97.067 Homeland Security Grant Program $13.81M
97.083 Staffing for Adequate Fire and Emergency Response (safer) $9.97M
14.239 Home Investment Partnerships Program $5.87M
21.023 Emergency Rental Assistance Program $4.73M
84.173 Special Education Preschool Grants $3.24M
84.424 Student Support and Academic Enrichment Program $3.12M
84.367 Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) $3.00M
14.231 Emergency Solutions Grant Program $2.77M
84.048 Career and Technical Education -- Basic Grants to States $2.24M
84.365 English Language Acquisition State Grants $1.94M
10.558 Child and Adult Care Food Program $1.93M
93.045 Special Programs for the Aging, Title Iii, Part C, Nutrition Services $1.89M
66.443 Reducing Lead in Drinking Water (sdwa 1459b) $1.48M
97.106 Securing the Cities Program $1.28M
14.905 Lead Hazard Reduction Demonstration Grant Program $1.11M
10.582 Fresh Fruit and Vegetable Program $1.09M
14.248 Community Development Block Grants Section 108 Loan Guarantees $919,562
10.559 Summer Food Service Program for Children $883,164
20.500 Federal Transit Capital Investment Grants $815,500
16.833 National Sexual Assault Kit Initiative $777,046
84.287 Twenty-First Century Community Learning Centers $748,658
93.044 Special Programs for the Aging, Title Iii, Part B, Grants for Supportive Services and Senior Centers $737,136
84.184 School Safely National Activities $731,838
97.111 Regional Catastrophic Preparedness Grant Program (rcpgp) $711,470
93.493 Congressional Directives $680,072
93.053 Nutrition Services Incentive Program $593,356
97.024 Emergency Food and Shelter National Board Program $556,657
93.079 Cooperative Agreements to Promote Adolescent Health Through School-Based Hiv/std Prevention and School-Based Surveillance $526,196
20.616 National Priority Safety Programs $496,691
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $425,792
93.043 Special Programs for the Aging, Title Iii, Part D, Disease Prevention and Health Promotion Services $402,254
93.052 National Family Caregiver Support, Title Iii, Part E $398,440
97.044 Assistance to Firefighters Grant $393,945
21.027 Coronavirus State and Local Fiscal Recovery Funds $353,549
94.016 Americorps Seniors Senior Companion Program (scp) 94.016 $329,650
16.738 Edward Byrne Memorial Justice Assistance Grant Program $302,301
20.219 Recreational Trails Program $300,000
97.047 Bric: Building Resilient Infrastructure and Communities $294,366
84.002 Adult Education - Basic Grants to States $276,923
16.741 Dna Backlog Reduction Program $254,896
84.336 Teacher Quality Partnership Grants $222,942
16.015 Missing Alzheimer's Disease Patient Assistance Program $142,079
94.002 Americorps Seniors Retired and Senior Volunteer Program (rsvp) 94.002 $134,183
10.935 Urban Agriculture and Innovative Production $132,138
93.566 Refugee and Entrant Assistance State/replacement Designee Administered Programs $131,056
14.401 Fair Housing Assistance Program $119,749
84.196 Education for Homeless Children and Youth $106,059
16.588 Violence Against Women Formula Grants $104,318
14.241 Housing Opportunities for Persons with Aids $99,539
45.301 Museums for America $93,526
97.042 Emergency Management Performance Grants $91,427
32.001 Communications Information and Assistance and Investigation of Complaints $77,625
16.745 Criminal and Juvenile Justice and Mental Health Collaboration Program $73,828
16.838 Comprehensive Opioid, Stimulant, and Other Substances Use Program $68,165
10.331 Gus Schumacher Nutrition Incentive Program $65,759
14.889 Choice Neighborhoods Implementation Grants $59,681
10.579 Child Nutrition Discretionary Grants Limited Availability $59,354
97.056 Port Security Grant Program $42,469
10.575 Farm to School Grant Program $37,410
93.042 Special Programs for the Aging, Title Vii, Chapter 2, Long Term Care Ombudsman Services for Older Individuals $35,915
14.246 Community Development Block Grants/brownfields Economic Development Initiative $28,049
16.742 Paul Coverdell Forensic Sciences Improvement Grant Program $27,991
66.818 Brownfields Multipurpose, Assessment, Revolving Loan Fund, and Cleanup Cooperative Agreements $25,980
15.904 Historic Preservation Fund Grants-in-Aid $11,270
16.710 Public Safety Partnership and Community Policing Grants $10,945
16.820 Postconviction Testing of Dna Evidence $9,290
14.218 Community Development Block Grants/entitlement Grants $2,146
14.261 National Homeless Data Analysis Project (nhdap) $1,750
10.727 Inflation Reduction Act Urban & Community Forestry Program $1,232
17.259 Wioa Youth Activities $1,145
11.307 Economic Adjustment Assistance $949
17.285 Registered Apprenticeship $582
17.258 Wioa Adult Program $214
21.009 Volunteer Income Tax Assistance (vita) Matching Grant Program $182
17.289 Community Project Funding/congressionally Directed Spending $107
17.278 Wioa Dislocated Worker Formula Grants $101
17.207 Employment Service/wagner-Peyser Funded Activities $67