Finding 26368 (2022-002)

2 CFR ? 400 gives regulatory effect to the Department of Agriculture for 2 CFR ? 200.305(b) which requires that for non-Federal entities other than states, payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means. 2 CFR ? 200.305(b)(3) states reimbursement is the preferred method when the requirements in this paragraph (b) cannot be met, when the Federal awarding agency sets a specific condition per ?200.208, or when the non-Federal entity requests payment by reimbursement or when the non-Federal entity requests payment by reimbursement. 7 CFR ? 210 relates to the implementation of the National School Lunch Program where the Department provides States with general and special cash assistance and donations of foods acquired by the Department to be used to assist schools in serving nutritious lunches to children each school day. 7 CFR ? 210.7(c) states to be entitled to reimbursement under this part, each school food authority shall ensure that Claims for Reimbursement are limited to the number of free, reduced price and paid lunches and meal supplements that are served to children eligible for free, reduced price and paid lunches and meal supplements, respectively, for each day of operation. Claims for reimbursement should be based on lunch counts, taken daily at the point of service, which correctly identify the number of free, reduced price and paid lunches served to eligible children. Each school food authority should correctly record, consolidate, and report those lunch and supplement counts on the Claim for Reimbursement. The District completed the required site claim forms; however, due to lack of controls over review of the forms for accuracy, the January 2022 site claim form was overstated by 15 meals. The site claim form was used for federal reimbursement to the District and thus resulted in more reimbursements ($68) than the District was entitled to based on free, reduced, and paid lunches. Failure to properly report meals for reimbursement can result in loss of revenue, excess reimbursements, and/or federal questioned costs. The District should establish and implement procedures to verify the accuracy of reimbursement site claim forms.