Finding Text
Federal Agency: U.S. Department of Agriculture
Federal Program Name: Child and Adult Care Food Program
Assistance Listing Number: 10.558
Pass-Through Agency: Feeding Our Future
Award Period: February 2021 – December 2021
Type of Finding:
• Material Weakness in Internal Control over Compliance
• Material Noncompliance (Adverse Opinion)
Criteria or specific requirement: 2 CFR section 200.303(a) requires that nonfederal entities must establish and maintain effective internal control over the Federal award that provides 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. MDE also issued At-Risk Afterschool Care Centers Guidance for School Year 2021-22 which indicated that CACFP at-risk meals can only be claimed for reimbursement on days when an afterschool program is provided. As an example, the guidance indicated that a 7-day meals bundle would not be an allowable use of the flexibilities if the afterschool care program is only provided for 2 days a week. Additionally, in that same memo, MDE indicated that it was expected that USDA expects that CACFR operators follow the lead of schools to discontinue use of noncongregate meal waivers once it is safe for children to return to school in each community.
Condition: The Organization purchased meals from a vendor that delivered meals to homes of participating children. There was not documentation of delivery of meals, such as delivery logs, schedule of deliveries, etc. to support the number of meals actually delivered, but rather an invoice showing the total meal number. Meals on the provided invoices included seven day meal bundles which were also not allowed under the program guidance as the afterschool programs were not provided all seven days. In addition, the site application submitted by the sponsor organization indicated that meals were served on site, when they were not. Schools resumed in-person learning in September of 2021, but noncongregate meals were provided by the Organization from September-December of 2021 instead of on-site congregate meals.
Questioned costs: Reimbursed meals for 2021 totaled $2,736,462, which did not contain evidence of delivery of meals by the vendor.
Context: Between February-December of 2021, the Organization was reimbursed by its sponsor organization for approximately 574,000 meals, totaling $2,736,462, which consisted of seven day meal bundles delivered by the vendor. There was no supporting documentation related to delivery of meals by the vendor, other than a weekly invoice indicating the number of meals. The contract with the vendor also did not specify delivery arrangements, pricing, or other relevant details. Meal bundles containing seven days of a supper/snack were provided which was also not allowed.
Cause: The Organization’s management indicated it was not told by the sponsor organization to maintain documentation supporting delivery of meals; management also indicated they did not receive guidance from their sponsor on seven day meal bundles not being allowed, or discontinuance of noncongregate meals in the fall of 2021.
Effect: A lack of sufficient documentation exists related to the delivery of meals. Meals and snacks were reimbursed to the Organization from federal funds related to meals and snacks provided on days that were not allowable.
Recommendation: We recommend the Organization attend training, review federal requirements, and fully understand the documentation and meal requirements of the program if they apply for funding with this program again.
Views of responsible officials: This program was initiated during the height of COVID, when guidelines on both state and federal levels were changing rapidly. Management provided auditors with documentation for participation in the meal program. Documentation included participant names that were printed and/or written in cursive as is customary for the served population. The printed names were not considered signatures and rejected by the auditors. Management attended all trainings provided by the sponsor organization and followed all of the program sponsor guidelines. See the Corrective Action Plan for further details.