Finding Text
Federal Program Affected
Federal Agency: U.S. Department of Agriculture
Pass-Through Entity: California Department of Education (CDE)
Program Name: Child Nutrition Cluster
Assistance Listing Number: 10.553, 10.555
Compliance Requirement: L (Reporting)
Criteria or Specific Requirements
Per Title 7, U.S. Code of Federal Regulations, Subtitle B, Chapter II, Subchapter A, Parts 210.8
and 220.11, School Food Authorities (SFA) must establish internal controls which ensure the
accuracy of meal counts prior to the submission of the monthly Claim for Reimbursement. Prior
to submission of a monthly Claim for Reimbursement, each school food authority shall review
the breakfast and lunch count data for each school under its jurisdiction to ensure the accuracy
of the monthly Claim for Reimbursement. The objective of this review is to ensure that monthly
claims include only the number of free, reduced price and paid breakfasts and lunches served on
any day of operation to children currently eligible for such meals. SFA staff shall maintain on file
each month's Claim for Reimbursement and all data used in the claims review process, by
school.
The above-noted CFR section also states that the SFA shall compare each school's daily counts of
meals served against the product of the number of children in that school currently eligible for
free, reduced price and paid lunches, respectively, times an attendance factor.
Condition
The District did not have sufficient controls in place to ensure that monthly Claims for
Reimbursement accurately reflected the numbers of meals served. We noted discrepancies
between the daily meal counts and the monthly Claims for Reimbursement. It is not clear what
records were used to file the monthly Claims for Reimbursement, as the system reports
provided to the auditor for the months of August 2022, October 2022, and January 2023 did not
agree to the meal counts reported on the Claims for Reimbursement. For the three months
noted, the District overclaimed 151 meals, which is approximately $7,141 of excess
reimbursement.
Questioned Costs
There were no questioned costs associated with the identified condition.
Context
The condition was identified through inquiry with District personnel and through review of
available supporting documentation for the monthly Claims for Reimbursement. A nonstatistical
sample of 4 months out of 12 months were selected for reporting testing.
Effect
The District has not complied with the requirements identified in Title 7, U.S. Code of Federal
Regulations, Subtitle B, Chapter II, Subchapter A, Parts 210.8 and 220.11.
Cause
The condition identified appears to have materialized due to the District’s lack of established
procedures to ensure compliance with the requirements under Title 7, U.S. Code of Federal
Regulations, Subtitle B, Chapter II, Subchapter A, Parts 210.8 and 220.11.
Repeat Finding
Yes, see prior year finding 2022-007.
Recommendation
The District should review the requirements stated in Title 7, U.S. Code of Federal Regulations,
Subtitle B, Chapter II, Subchapter A, Parts 210.8 and 220.11 and implement procedures to
address the control deficiencies currently identified. The District should retain all supporting
documentation used to complete the monthly Claims for Reimbursements and ensure the
number of meals reported on the Claims for Reimbursements agree to the supporting system
reports.