Finding Text
2022-001 ? Lack of Verification of Free and Reduced Price Applications (NSLP) and Lack of Adequate Internal Controls over Verification of Free and Reduced Price Applications (NSLP) Criteria: The 7 CFR section 245.6a ? Verification Requirements requires that by November 15th of each school year, the local educational agency (LEA) must verify current free and reduced price eligibility of participating households. This is accomplished by selecting a sample of applications that are approved for free and reduced price meals. The sample size is based on the total number of approved applications on file as of October 1st. The 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain effective internal controls that provide reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be compliant with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Parnassus Preparatory School did not select a sample of applications approved for free and reduced price meals as of October 1st, 2021 to verify eligibility for the program. The School did not have internal controls in place to ensure the verification process was performed by November 15th, 2021. Cause: In prior years, the School had controls in place for a member of the administrative team to perform an annual verification of free and reduced price eligibility by November 15th of each year. Based on inquiries with School management, this control was not in place during fiscal year 2022 due to staff turnover. Effect: By not performing the annual verification of free and reduced price applications and not having proper internal controls to ensure the annual verification process was performed, there is a risk that households may be approved for free and reduced price meals without meeting the proper eligibility requirements. Questioned Costs: None. Repeat Finding of Immediate Prior Year: No. Recommendation: We recommend that controls be implemented to ensure an annual verification of free and reduced price applications is completed by November 15th, even in the circumstances of staff turnover.