Finding 1229310 (2025-006)

Material Weakness Repeat Finding
Requirement
A
Questioned Costs
-
Year
2025
Accepted
2026-09-10
Audit: 410783
Auditor: LB CARLSON LLP

AI Summary

  • Core Issue: The District lacks adequate internal controls for accurately counting meals in child nutrition programs, leading to potential overclaims for reimbursement.
  • Impacted Requirements: Compliance with 7 CFR § 210.8 is not being met, specifically regarding meal count documentation for federal programs.
  • Recommended Follow-Up: The District should review and enhance its meal counting procedures and maintain proper documentation to ensure future compliance.

Finding Text

SIGNIFICANT DEFICIENCIES IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF AGRICULTURE, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, CHILD NUTRITION CLUSTER – FEDERAL ALN 10.555, 10.559, AND 10.553 (CONTINUED) 2025-006 Internal Control Over Compliance With Allowable Activities Requirements Criteria – 7 CFR § 210.8 requires the District to establish and maintain effective internal control over compliance with requirements applicable to federal program allowable activities, including meal count requirements applicable to child nutrition cluster federal programs. Condition – During our audit, we noted that the District does not have adequate internal controls in place within its child nutrition cluster federal programs to assure that it was properly counting meals (specifically pre-K students at non-public schools and summer meals served at apartment building sites). Questioned Costs – None. Context – Eligible meal counts submitted to the Minnesota Department of Education (MDE) for five months tested, noted the District claimed more eligible meals for reimbursement than documented in its internal meal count records. This was not a statistically valid sample. Repeat Finding – This is a current year finding. Cause – This was an oversight by district personnel. Effect – Inaccurate meal count submissions resulted in the District receiving reimbursement for ineligible meals served. Recommendation – We recommend the District revisit the procedures and processes in place for counting meals for reimbursement, licensure status at non-public sites, and retain documentation for meal counts submitted. View of Responsible Official and Planned Corrective Actions – The District agrees with the finding. The District will review and update its policies and procedures relating to eligible meal tracking and reimbursement submission for its child nutrition cluster federal program to ensure compliance with the Uniform Guidance in the future. The District has separately issued a Corrective Action Plan related to this finding.

Corrective Action Plan

SIGNIFICANT DEFICIENCIES IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF AGRICULTURE, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, CHILD NUTRITION CLUSTER – FEDERAL ALN 10.555, 10.559, AND 10.553 2025-006 Internal Control Over Compliance With Allowable Activities Requirements Finding Summary Criteria – 7 CFR § 210.8 requires the District to establish and maintain effective internal control over compliance with requirements applicable to federal program allowable activities, including meal count requirements applicable to child nutrition cluster federal programs. Condition – The District did not have sufficient controls in place within its child nutrition cluster to assure that it was accurately reporting meals counts for federal reimbursement, specifically pre-K students at non-public schools and summer meals served at apartment building sites. Corrective Action Plan Actions Planned – The District will review its policies and procedures relating to meal counts for its federal programs and will ensure that accurate meal counts are documented and submitted for federal reimbursement. Official Responsible – Brian Schultz, the District’s Finance Director. Planned Completion Date – December 31, 2026. Disagreement With or Explanation of Finding – The District agrees with this finding. Plan to Monitor – Brian Schultz, the District’s Finance Director, will review and update the District’s policies and procedures relating to eligible meal tracking and reimbursement submission for its child nutrition cluster federal program to ensure compliance with the Uniform Guidance in the future.

Categories

Internal Control / Segregation of Duties Cash Management Eligibility School Nutrition Programs

Other Findings in this Audit

  • 1229305 2025-005
    Material Weakness Repeat
  • 1229306 2025-005
    Material Weakness Repeat
  • 1229307 2025-005
    Material Weakness Repeat
  • 1229308 2025-006
    Material Weakness Repeat
  • 1229309 2025-006
    Material Weakness Repeat
  • 1229311 2025-007
    Material Weakness Repeat
  • 1229312 2025-007
    Material Weakness Repeat
  • 1229313 2025-007
    Material Weakness Repeat
  • 1229314 2025-007
    Material Weakness Repeat
  • 1229315 2025-007
    Material Weakness Repeat
  • 1229316 2025-007
    Material Weakness Repeat
  • 1229317 2025-007
    Material Weakness Repeat
  • 1229318 2025-007
    Material Weakness Repeat
  • 1229319 2025-007
    Material Weakness Repeat
  • 1229320 2025-007
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
10.555 NATIONAL SCHOOL LUNCH PROGRAM $1.77M
84.027 SPECIAL EDUCATION GRANTS TO STATES $1.64M
84.010 TITLE I GRANTS TO LOCAL EDUCATIONAL AGENCIES $608,663
10.553 SCHOOL BREAKFAST PROGRAM $563,429
84.367 SUPPORTING EFFECTIVE INSTRUCTION STATE GRANTS (FORMERLY IMPROVING TEACHER QUALITY STATE GRANTS) $248,192
10.559 SUMMER FOOD SERVICE PROGRAM FOR CHILDREN $134,503
84.365 ENGLISH LANGUAGE ACQUISITION STATE GRANTS $119,655
84.181 SPECIAL EDUCATION-GRANTS FOR INFANTS AND FAMILIES $56,272
84.173 SPECIAL EDUCATION PRESCHOOL GRANTS $43,855
84.060 INDIAN EDUCATION GRANTS TO LOCAL EDUCATIONAL AGENCIES $13,516