Finding 1170363 (2025-003)

Material Weakness Repeat Finding
Requirement
E
Questioned Costs
-
Year
2025
Accepted
2026-01-23
Audit: 383464
Auditor: WADE STABLES PC

AI Summary

  • Core Issue: Two students were incorrectly classified as eligible for free meals when they should have qualified for reduced-price meals due to household income miscalculation.
  • Impacted Requirements: The District failed to accurately assess eligibility based on household income, violating compliance standards under 7 CFR 210.7 and 7 CFR 245.
  • Recommended Follow-Up: Conduct a review of free/reduced applications to ensure correct eligibility determinations and verify that all students are either directly certified or have submitted the necessary income information.

Finding Text

Finding 2025-003 Federal Agency: U.S. Department of Education Passthrough Entity: Missouri Department of Elementary and Secondary Education Assistance Listing Number and Federal Program: Child Nutrition Cluster - 10.553 School Breakfast Program, 10.555 National School Lunch Program, 10.555 COVID-19 Supply Chain Assistance Compliance Requirements: E. Eligibility Criteria: In accordance with 7 CFR 210.7(c)(1)(i) the District is required to correctly determine eligibility for free and reduced price lunches and afterschool snacks based on the requirements under 7 CFR 245. Under 7 CFR 245.6(c)(4), if the student is not automatically eligible under direct certification or another exception, the District must use income information provided by the household of the student to calculate the student's eligibility for free or reduced prices. The District makes applications available to households so that their income can be reported to the District for such purposes. Per 7 CFR 245.6(d), if income information is available to the District from other sources, the District is able to determine that a child whom no application was submitted would meet the eligibility. If no income information is submitted by the student’s family or otherwise available, then the student would be charged full price for meals. Condition: During the course of our audit, we noted that the District had two students in the same household classified as eligible for free meals, however when income for the household was recalculated during testing, the income was above the maximum threshold for free meals. The students should have been eligible for reduced price meals versus free meals. The students were not directly certified for free meals in any other manner. Cause: The household reported an income amount that was being earned by one of the students in the household. The District did not include this income amount in the calculation. After adding the income earned by the student into household income, the calculation reflected total household income in the range that was eligible for reduced price meals. Effect: With improper eligibility status on students for free or reduced meals, the District could over or under report their meal counts by allowing ineligible students to receive reduced or free meals. This could result in the District receiving more in their monthly Claims for Reimbursement than qualified. It could also cause the District to under report their meal counts if eligible students are omitted from the free and reduced meal counts. In addition, the amount charged to students who are classified as full or reduced price may be over or understated if they are classified incorrectly. Questioned Costs: No questioned costs. Perspective Information: This appears to be an isolated event as it was only noted on two students in our sample who were both in the same household. Identification of Repeat Findings: Not a repeat finding. Recommendation: We recommend that the District implement a subsequent review of the free/reduced applications to ensure that each student’s free or reduced meal status is correctly determined. Also, we recommend that the District review the free/reduced list to ensure that all students are either directly certified through another program or that the appropriate income information has been submitted to determine eligibility.

Corrective Action Plan

The District will implement additional internal controls to ensure that all household income is properly included in the eligibility determination process for free and reduced-price meals. The Food Service Director (or authorized designee) will perform a second-level review of all applications prior to final approval, focusing on verification that all sources of income - including income earned by students - are included in the total household calculation. The District will update its internal checklist and train staff responsible for reviewing meal applications to verify that each application is complete, income sources are clearly identified, and supporting documentation (if applicable) has been properly considered. The Food Service Director will conduct a mid-year self-audit of eligibility determinations to confirm accuracy and compliance with 7 CFR 245.6 requirements. The District will maintain documentation of reviews and training to support compliance efforts in furter audits.

Categories

School Nutrition Programs Eligibility

Other Findings in this Audit

  • 1170360 2025-003
    Material Weakness Repeat
  • 1170361 2025-003
    Material Weakness Repeat
  • 1170362 2025-003
    Material Weakness Repeat
  • 1170364 2025-002
    Material Weakness Repeat
  • 1170365 2025-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.027 SPECIAL EDUCATION GRANTS TO STATES $233,073
84.010 TITLE I GRANTS TO LOCAL EDUCATIONAL AGENCIES $179,417
84.367 SUPPORTING EFFECTIVE INSTRUCTION STATE GRANTS (FORMERLY IMPROVING TEACHER QUALITY STATE GRANTS) $47,675
10.555 NATIONAL SCHOOL LUNCH PROGRAM $42,195
10.553 SCHOOL BREAKFAST PROGRAM $40,251
84.424 STUDENT SUPPORT AND ACADEMIC ENRICHMENT PROGRAM $22,744
84.173 SPECIAL EDUCATION PRESCHOOL GRANTS $3,012
84.425 EDUCATION STABILIZATION FUND $321