Finding Text
7 CFR § 210.8(a) states in part, "The school food authority shall establish internal controls which ensure the accuracy of meal counts prior to the submission of the monthly Claim for Reimbursement. At a minimum, these internal controls shall include: an on-site review of the meal counting and claiming system employed by each school within the jurisdiction of the school food authority; comparisons of daily free, reduced price and paid meal counts against data which will assist in the identification of meal counts in excess of the number of free, reduced price and paid meals served each day to children eligible for such meals; and a system for following up on those meal counts which suggest the likelihood of meal counting problems." 7 CFR § 220.11(b) states in part, “Claims for Reimbursement shall include data in sufficient detail to justify the reimbursement claimed and to enable the State Agency to provide the Reports of School Program Operations required under § 220.13(b)(2).” In Ohio, the Ohio Department of Education and Workforce (DEW) requires school districts to use the Claims Reporting and Reimbursement System (CRRS) to report meal data for reimbursement. The District uses a point-of-sale system that generates a CN-6 Report (Breakfast) and CN-7 Report (Lunch), which is used to manually complete a monthly CN-6 and CN-7 summary worksheet that shows meals served to students each day based on the point-of-sale system data. This worksheet is used to compile the monthly reimbursement request submitted to DEW. Due to insufficient controls over CN-6 and CN-7 reporting related to breakfast and lunch meal counts, two out of three (66%) monthly claims for reimbursement reported inaccuracies in meal counts in the CRRS system. This weakness resulted in a loss of accountability over meal count reporting and could lead to a reduction or forfeiture of future funding for this program. The District should develop control policies and procedures to help ensure the number of meals served and reported to DEW agree to the respective summary meal count forms and the meals served / tabulated on the point-of-sale system CN-6 and CN-7 Reports. The procedures should include an independent review of the meal counts manually entered into the point-of-sale system, based upon the daily meal count forms, and the meal counts manually entered into CRRS, based upon the point-of-sale system CN-6 and CN-7 reports, by an employee not associated with the computer entry. These review procedures should be acknowledged by initials / signatures on the point-of-sale system reports and the CRRS Site Claim Reports. If there are errors or discrepancies between the point-of-sale reports and the amounts reported to DEW, the District should maintain supporting documentation to demonstrate the meals reported to DEW were accurate and complete.