Finding 1238715 (2025-001)

Material Weakness Repeat Finding
Requirement
E
Questioned Costs
-
Year
2025
Accepted
2026-09-30

AI Summary

  • Core Issue: There is a material weakness in internal controls over eligibility for the Child and Adult Care Food Program, risking compliance with federal requirements.
  • Impacted Requirements: The organization failed to maintain proper documentation and review processes for determining child eligibility based on household income levels.
  • Recommended Follow-Up: Implement stronger internal controls to ensure all eligibility determinations are documented, reviewed, and retained to prevent future compliance issues.

Finding Text

2025-001 Finding – Federal Award Finding Type: Material Weakness in Internal Control over Compliance – Eligibility Identification of Federal Program: AL Number: 10.558 Child and Adult Care Food Program Criteria / Requirement: The 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. In order to be eligible for free meals under the Child and Adult Care Food Program, the participating child’s household must be at or below 130 percent of the poverty level. In order to be eligible for reduced price meals under the Child and Adult Care Food Program, the participating child’s household must be between 130 percent and 185 percent of the poverty level. Condition / Context: During the audit, 25 children participating in the Child and Adult Care Food Program were tested for eligibility. For one child tested, the supporting documentation for the child’s household income eligibility was unable to be located. However, the Organization was able to retroactively provide documentation that the child was eligible for the program. Additionally, one other child tested had the supporting documentation for eligibility, however there was no documented review of the eligibility file. Cause: The procedures and controls in place were not followed to ensure that eligibility determination was properly reviewed and that eligibility documentation is retained. Effect: The Organization could have provided meals to an ineligible child, resulting in noncompliance with the federal award requirements. Questioned Costs: None Recommendation: We recommend that the Organization implement the necessary internal controls to ensure that each child served under the program has a completed eligibility determination and that the file is appropriately reviewed. Management’s Response: Management concurs with the finding and will implement effective internal controls to ensure that eligibility requirements are met, documented, properly reviewed, and retained.

Corrective Action Plan

OCDC has implemented the following corrective actions: 1. Implement a secondary review control Eligibility determinations will include documented evidence of review, such as reviewer name/initials and date, to demonstrate that eligibility has been verified prior to or as part of the applicable claiming process. 2. Reinforce Staff Training and Procedures Staff responsible for determining, reviewing, or maintaining CACFP eligibility will receive a refresher training on the procedures, documentation requirements, review responsibilities, and record retention expectations. 3. Conduct periodic monitoring Program leadership will periodically review a sample of eligibility files to confirm that required documentation is present, eligibility determinations are supported, and evidence of review is documented. Identified exceptions will be corrected promptly and recurring issues addressed through additional training or process improvements. Name(s) of the contact people responsible for correction action: Melissa Buxton, Chief Financial Officer and CACFP Program Leadership Plan completion date for corrective action plan: Corrective actions began in spring 2026 after OCDC self-identified the weakness. Initial corrective measures have been implemented, with periodic monitoring continuing as an ongoing internal control with training reinforcement completed by October 31, 2026.

Categories

Eligibility Material Weakness Matching / Level of Effort / Earmarking

Programs in Audit

ALN Program Name Expenditures
10.558 CHILD AND ADULT CARE FOOD PROGRAM $2.25M
93.600 HEAD START $478,840
93.870 MATERNAL, INFANT AND EARLY CHILDHOOD HOME VISITING GRANT $132,838
84.011 MIGRANT EDUCATION STATE GRANT PROGRAM $59,057