Finding Text
7 CFR § 210.8(a) 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." 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 switched from a point-of-sale system that generates a CN-6 Report (Breakfast) and CN-7 Report (Lunch), which is used to compile the monthly reimbursement request submitted to DEW, in August and September. After learning they were 100% Nutrition Cluster eligible, they transition to a faculty operated “clicker count” system, in which a faculty member would observe students going through the cafeteria line and push a button of a clicker counter each time a student left the line with a meal. Clicker counts were then entered into a report and submitted to Food Services Department for entry into a master count. 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. Due to insufficient controls over CN-6 and CN-7 reporting related to breakfast and lunch meal counts, all four (100%) CN reports tested were inaccurate. This led to inaccuracies in meal counts reported in the CRRS system, as shown below: See Actual Finding for Table