Finding Text
GENERAL INFORMATION: Grant Title: Child Nutrition Cluster: School Breakfast Program and National School Lunch Program Federal Award Number and Year: 2024 Assistance Listing #: 10.553 and 10.555 Federal Agency: US Department of Agriculture Pass-through Entity number: 88 Pass-through Agency: WV Department of Education CONDITION: The Board did not ensure compliance with the guidelines required for the National School Lunch Program and School Breakfast Program (the Programs) Special Tests and Provisions requirement. CONTEXT: We were unable to confirm that non-program adults are paying for meals prepared for the National School Lunch Program and School Breakfast Program. Outstanding receivables for meals were not being pursued for collection. CRITERIA: Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) Appendix XI Part 4 Section Child Nutrition Cluster Section III. N. 3. states, in part, that: "A [School Food Authority] SFA is required to account for all revenues and expenditures of its non-profit school food service in accordance with State requirements. An SFA must operate its food services on a non-profit basis; all revenue generated by the school food service must be used to operate and improve its food services (7 CFR sections 210.14(a), 210.14(c), 210.19(a)(2), 215.7(d)(1), 220.2, and 220.7(e)(1)(i)." Title 7 U.S. CFR Part 210 National School Lunch Program §210.14(a) states, in part, that: "...School food authorities shall maintain a nonprofit school food service. Revenues received by the nonprofit school food service are to be used only for the operation or improvement of such food service, except that, such revenues shall not be used to purchase land or buildings, unless otherwise approved by FNS, or to construct buildings. Expenditures of nonprofit school food service revenues shall be in accordance with the financial management system established by the State agency under § 210.19(a) of this part." Title 126 - Procedural Rule of the West Virginia Board of Education Series 85 - Policies of Operation Manual Child Nutrition Programs (Policy 4320 §126-85-83) states in part: "83.1. Meals served to teachers, administrators, custodians and other adults, such as school patrons, elderly volunteers and Foster Grandparents Program participants, must be priced so that the adult payments in combination with income from other sources (such as state or local fringe benefits or payroll funds, or funding from voluntary agencies) are sufficient to cover the meal costs. The charge for adult meals is determined by the county board of education and approved by the WVDE in the Agreement between SFA and SA. It is recommended that the charge(s) be established at or near the county per meal costs. Adult meals are not reimbursable nor counted in the commodity allocation entitlement." "83.3. Meals served to adults not directly involved in the child nutrition program such as administrators, teachers, aides, student teachers and other persons working or visiting in the school may not be served free of charge unless the cost of the meal is reimbursed to the program from another funding source. These meals must be reported as non-program adult meals." QUESTIONED COSTS: Unknown CAUSE: The Board does not have a Food Service Collection Policy. Further, the Board is not actively pursuing past due balances for purchases of meals. EFFECT: The Board has potentially used National School Lunch Program funds to subsidize meals for adults who are not eligible to receive free or reduced meals as part of the Program. Furthermore, failure to collect funds on the outstanding receivables inhibits the ability to capitalize such funds for operating and improving its food services. REPEAT FINDING: Yes PRIOR YEAR FINDING NUMBER: 2023-021 RECOMMENDATION: The Upshur County Board of Education should comply with the requirements of the National School Lunch Program as required by the Code of Federal Regulations. In addition, the Board should establish and follow a collection policy and attempt to collect the outstanding balances on the receivables related to the National School Lunch Program.