Finding 1169596 (2024-003)

Material Weakness Repeat Finding
Requirement
E
Questioned Costs
-
Year
2024
Accepted
2026-01-19
Audit: 382583
Organization: Guam Department of Education (GU)

AI Summary

  • Core Issue: GDOE failed to publish required annual notifications for eligibility under the community eligibility provision (CEP) on its website.
  • Impacted Requirements: Compliance with the National School Lunch Act, specifically the requirement to notify local educational agencies (LEAs) by May 1 each year.
  • Recommended Follow-Up: GDOE needs to implement internal controls to ensure timely publication of notifications and proper documentation of CEP approvals.

Finding Text

Finding No.: 2024-003 Federal Agency: U.S. Department of Agriculture AL Program: 10.555 Child Nutrition Cluster Federal Award No.: 7GU300GUB Area: Eligibility Questioned Costs: $0 Criteria: In accordance with the National School Lunch Act, state agencies are required to annually notify local educational agencies (LEAs) of district-wide eligibility for the community eligibility provision (CEP). By May 1 of each year, state agencies must publish lists of eligible and near- eligible LEAs and schools on their state agency websites. Condition: GDOE functions both as State Educational Agency (SEA) and LEA. As a state agency, it is required to fulfil the above criteria. As of December 4, 2025, the annual notification for School Year (SY) 2023-2024 and SY 2024-2025 was not published on GDOE’s website. Specifically, the lists of eligible and near-eligible LEAs and schools was not published on GDOE’s website. Furthermore, documentation of CEP approval was not provided. Cause: GDOE did not enforce controls over compliance with the applicable eligibility requirements relative to annual notifications and publications and retaining documentation of CEP approval. Effect: GDOE is in noncompliance with applicable eligibility requirements. No questioned cost is presented as non-compliance is related to a disclosure requirement and is not specific to a particular cost. Identified as a Repeat Finding: 2023-004 Recommendation: GDOE should establish and implement internal controls over compliance with applicable eligibility requirements. Responsible personnel should prepare and publish required notifications and retain documentation of CEP approval.

Corrective Action Plan

Views of Auditee and Corrective Actions: GDOE agrees with the finding. Plan of action and completion date: The Food and Nutrition Services Management Division (FNSMD) will implement an internal calendar reminder to ensure timely notification to School Districts and the annual upload of district-wide eligibility information for the Community Eligibility Provision (CEP) to the FNSMD and GDOE websites. Additionally, FNSMD will implement an internal process to conduct the Direct Certification Matching activity to determine student eligibility for free school meals (Lunch/Breakfast). This process will include matching student data with lists from the Department of Public Health & Social Services (DPHSS) for SNAP (Food Stamps), TANF, FDPIR, Medicaid, Foster Care, Homelessness, or Migrant status. All Direct Certification Matching activities will be completed by April 1st of each year. Plan to monitor and responsible officials: The FNSMD Administrator, Anthony S. Monforte, and FNSMD Program Coordinator, Franklin J. Cruz, will be responsible for implementation and ongoing execution of corrective actions. Corrective actions will be implemented by March 31, 2026.

Categories

School Nutrition Programs Eligibility

Other Findings in this Audit

  • 1169595 2024-003
    Material Weakness Repeat
  • 1169597 2024-004
    Material Weakness Repeat
  • 1169598 2024-004
    Material Weakness Repeat
  • 1169599 2024-005
    Material Weakness Repeat
  • 1169600 2024-005
    Material Weakness Repeat
  • 1169601 2024-006
    Material Weakness Repeat
  • 1169602 2024-006
    Material Weakness Repeat
  • 1169603 2024-007
    Material Weakness Repeat
  • 1169604 2024-007
    Material Weakness Repeat
  • 1169605 2024-008
    Material Weakness Repeat
  • 1169606 2024-009
    Material Weakness Repeat
  • 1169607 2024-010
    Material Weakness Repeat
  • 1169608 2024-010
    Material Weakness Repeat
  • 1169609 2024-011
    Material Weakness Repeat
  • 1169610 2024-011
    Material Weakness Repeat
  • 1169611 2024-012
    Material Weakness Repeat
  • 1169612 2024-012
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.425 EDUCATION STABILIZATION FUND $105.41M
84.403 CONSOLIDATED GRANT TO THE OUTLYING AREAS $30.00M
84.181 SPECIAL EDUCATION-GRANTS FOR INFANTS AND FAMILIES $1.66M
10.558 CHILD AND ADULT CARE FOOD PROGRAM $648,102
84.027 SPECIAL EDUCATION GRANTS TO STATES $561,018
10.560 STATE ADMINISTRATIVE EXPENSES FOR CHILD NUTRITION $383,408
93.600 HEAD START $356,080
84.424 STUDENT SUPPORT AND ACADEMIC ENRICHMENT PROGRAM $331,968
93.092 AFFORDABLE CARE ACT (ACA) PERSONAL RESPONSIBILITY EDUCATION PROGRAM $232,589
12.U01 ARMY JROTC $220,601
12.U02 AIR FORCE JROTC $190,116
84.371 COMPREHENSIVE LITERACY DEVELOPMENT $173,631
84.372 STATEWIDE LONGITUDINAL DATA SYSTEMS $167,485
84.323 SPECIAL EDUCATION - STATE PERSONNEL DEVELOPMENT $157,292
10.541 CHILD NUTRITION-TECHNOLOGY INNOVATION GRANT $148,409
10.555 NATIONAL SCHOOL LUNCH PROGRAM $125,219
10.579 CHILD NUTRITION DISCRETIONARY GRANTS LIMITED AVAILABILITY $79,076
12.U03 MARINE JROTC $42,462
10.574 TEAM NUTRITION GRANTS $26,237
15.875 ECONOMIC, SOCIAL, AND POLITICAL DEVELOPMENT OF THE TERRITORIES $19,840
10.645 FARM TO SCHOOL STATE FORMULA GRANT $14,242
10.568 EMERGENCY FOOD ASSISTANCE PROGRAM (ADMINISTRATIVE COSTS) $3,986