Finding 265131 (2022-004)

Material Weakness Repeat Finding
Requirement
A
Questioned Costs
$1
Year
2022
Accepted
2023-03-30

AI Summary

  • Core Issue: Schools failed to keep accurate records of meals served, leading to discrepancies in reimbursement claims.
  • Impacted Requirements: Recordkeeping standards from the National School Lunch Program were not met, resulting in questioned costs of $105,144 and $334 for two schools.
  • Recommended Follow-Up: Implement electronic tracking, maintain individual count sheets, ensure proper sign-off on records, and organize documentation for compliance with retention requirements.

Finding Text

Child Nutrition Cluster ? School Nutrition Program ? Assistance Listing #10.555 and Summer Food Service Program ? Assistance Listing #10.559 2022-004 ? Material Weakness in Controls over Compliance and Compliance Finding: Activities Allowed or Unallowed This is a repeat of prior year finding 2021-005 Conditions: The Schools failed to maintain full and accurate records of the number of meals served as a basis for the claim for reimbursement. The total monthly counts of meals served that was reported could not be reliably substantiated. The amount of meals submitted for reimbursement were higher than the daily or weekly count sheets maintained. Criteria: Part 4, Recordkeeping Requirements of the Permanent Agreement for the National School Lunch/USDA Foods Distribution Special Milk, Afterschool Snack, and Breakfast Programs stipulates the following: ?The Sponsor must keep full and accurate records of the Breakfast, Lunch, Afterschool Snack and Special Milk Programs to serve as a basis for the claim for reimbursement and for audit and review purposes. The records are to be kept three years after the date of the final claim for reimbursement for the fiscal year to which they pertain or as long as there are unresolved audit findings or investigations related to those records.? ?Meal Service: 1. Daily number of breakfasts, lunches, afterschool snacks, and special milk served to children. 2. Daily number of breakfasts, lunches, afterschool snacks, and special milk served free or at reduced price. 3. Daily number of breakfasts, lunches, afterschool snacks and milk served to adults. 4. Daily amounts of food prepared and served (production records). 5. Daily attendance sheets/rosters for afterschool care programs serving snacks.? Cause: The food program expanded as the eligibility requirements were waived during the COVID-19 pandemic. Prior to the expansion of the program, the Schools electronically tracked meals served to eligible students. During the pandemic, eligibility requirements were waived and the priority was to get food to students quickly. At this time, the Schools converted to paper count sheets at each location distributing food. The procedures for reviewing, accumulating and maintaining the paper count sheets appear to have been ineffective. Context: A sample of ten months of lunches and five months of breakfasts spread over nine sites of food distribution were selected from a population of 145. The number of lunches reported for the ten sampled was 21,524. The number of lunches supported with count sheets was 21,221. The five sampled months of breakfasts reported 3,804 served. These months were supported by count sheets totaling 964. The various sites operate under agreements with the two high schools, West Catholic High School and Catholic Central High School. West Catholic operates six sites in addition to the high school. The sample tested 12 months distributed across these seven sites. West Catholic reported 19,171 meals for these twelve months. The observed count sheets supported 16,305 meals, which is an error rate of 16%. West Catholic High School received reimbursement of $701,916 for the year ended June 30, 2022. Questioned Costs: $105,144 Catholic Central High School operated one site in addition to the high school. The sample tested four months across these two sites. Catholic Central reported 6,488 meals for these four months. The observed count sheets supported 6,481 meals, which is an error rate of >1%. Catholic Central High School received reimbursement of $309,494 for the year ended June 30, 2022. Questioned Costs: $334 Recommendations: We recommend the following processes be implemented: ? When possible, utilize the electronic software in service prior to the pandemic ? Individual count sheets, whether daily or weekly sheets, should be maintained for each area where food is distributed. This could be the cafeteria or classroom. ? Each individual counting the meals served must count the students as the food is distributed, sign and date the count sheet the day the sheet is completed. ? The director of the program should sign the count sheet to document approval and agreement to production reports. ? The count sheets for each location must be organized in a manner sufficient to support the monthly request for reimbursement. This calculation must be maintained for the required time period (three years from the date of the final claim for reimbursement for the fiscal year to which the claim pertains). Views of Responsible Officials and Planned Corrective Actions: We concur with the findings of the auditors. We have developed a plan to address the findings, and are actively working to implement that plan. The corrective action plan is attached to this report.

Corrective Action Plan

2022-004 Material Weakness in Controls over Compliance: Activities Allowed or Unallowed We agree with the recommendations and have made improvements to our procedures. The schools were not prepared for the rapid expansion of the food program, not only at our two high schools, but our partner schools' which requested contracted breakfast/lunch food services for their students as well. This unprecedented growth coupled with supply chain issues from food wholesalers, and shortage of employees in the hiring pool, only exacerbated our issues. The audit sample showed a large error rate for one of the schools. We have gone through the entire year for the school(s) individual count sheets. In the event the Michigan Department of Education determines that the identified discrepancies warrant a repayment we have recorded an allowance in the financial statements for the year ended June 30, 2021. Staff were not properly trained in how to complete the count sheets; however, supervisors did not take the time once they saw there was a problem due to everyone trying to simply get the meals served to the children. In addition, there was a lack of oversight of the Food Service Manager by her direct supervisor. At the time of the 2021 audit, when the issue was brought to our attention, we developed new procedures. School staff performing counts have been trained in how to properly complete the count sheets. The Business Manager now reviews all count sheets and ties counts to the summary report used to submit claims prior to submittal for reimbursement. Given that training and implementation of procedures did not fully occur until January 2022, there are errors in counts prior to implementation of the procedures and repeat findings in fiscal year 2021-22. In addition, with the end of the pandemic, beginning with the 2022-23 school year, the schools were able to resume using electronic software to accurately capture the meal counts.

Categories

Questioned Costs School Nutrition Programs Cash Management Eligibility Material Weakness

Other Findings in this Audit

  • 265132 2022-005
    Significant Deficiency Repeat
  • 265133 2022-006
    Significant Deficiency
  • 265134 2022-007
    Significant Deficiency
  • 265135 2022-004
    Material Weakness Repeat
  • 265136 2022-005
    Significant Deficiency Repeat
  • 265137 2022-006
    Significant Deficiency
  • 265138 2022-007
    Significant Deficiency
  • 841573 2022-004
    Material Weakness Repeat
  • 841574 2022-005
    Significant Deficiency Repeat
  • 841575 2022-006
    Significant Deficiency
  • 841576 2022-007
    Significant Deficiency
  • 841577 2022-004
    Material Weakness Repeat
  • 841578 2022-005
    Significant Deficiency Repeat
  • 841579 2022-006
    Significant Deficiency
  • 841580 2022-007
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
10.555 National School Lunch Program $1.02M
10.559 Summer Food Service Program for Children $60,510
10.558 Child and Adult Care Food Program $34,164
10.649 Pandemic Ebt Administrative Costs $1,228