Finding 1190846 (2025-101)

2025-101 Material Weakness in Internal Control Over Compliance: Reporting Federal program: Federal Agency: Pass-through Entity Questioned Costs: Child Nutrition Cluster: FAL 10.553 School Breakfast Program FAL 10.555 National School Lunch Program U.S. Department of Agriculture Arizona Department of Education N/A Criteria: USDA 7 CFR 210.8(a) of the Uniform Guidance states: "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." Condition: Out of 3 months of meal service records tested to verify the accuracy of the Claim for reimbursement, one months' internal monthly meal count did not agree with the total reported on the monthly claim submitted to the Arizona Department of Education. The variance was 4 meals served. Cause: There was a manual calculation error during the monthly consolidation process. The School relied on a single individual to manually aggregate monthly meal counts, and the lack of a standardized reconciliation worksheet or automated validation tool allowed the clerical oversight to remain undetected. Effect: The School submitted an inaccurate Claim for Reimbursement, resulting in a noncompliance with USDA 7 CFR 210.8 reporting requirements. Recommendation: To help ensure that monthly meal counts are mathematically accurate, management should implement a formal reconciliation process where a designated official—other than the individual who prepared the report—performs a cross-check of the Monthly Claim for Reimbursement against the Daily Meal Count Tally Sheets.