Finding 46870 (2022-003)

Significant Deficiency Repeat Finding
Requirement
N
Questioned Costs
$1
Year
2022
Accepted
2022-12-19

AI Summary

  • Core Issue: Meal counts for the Child Nutrition Cluster and Child and Adult Care Food Program were inaccurately recorded, leading to discrepancies in claims.
  • Impacted Requirements: Compliance with federal regulations (7 CFR 225.15 and 226.10) requires accurate record-keeping for meal claims to avoid reimbursement denials.
  • Recommended Follow-Up: Strengthen controls over the meal claim process to ensure accurate counting and documentation of meals.

Finding Text

Program Identification Finding Reference Number: F-2022-003 Federal Program Title, Awarding Agency, Pass-Through Entity, Assistance Listing Number, and Award Number: Child Nutrition Cluster, U.S. Department of Agriculture, Passed through the California Department of Education, AL Nos. 10.553, 10.555, and 10.559, PCA Nos. 13523, 13524, 13525, 13526, 15637, 13004, and 13006. (Significant Deficiency) Child and Adult Care Food Program, U.S. Department of Agriculture, Passed through the California Department of Education, AL No. 10.558, PCA Nos. 13529, 13534, and 15577. (Significant Deficiency) Compliance Requirement: Special Tests and Provisions State Audit Guide Finding Code: 30000 and 50000 Criteria Per 7 CFR 225.15 (c)(1), ?Sponsors shall maintain accurate records justifying all meals claimed and documenting that all program funds were spent only on allowable Child Nutrition Program costs. Failure to maintain such records may be grounds for denial of reimbursement for meals served and/or administrative costs claimed during the period covered by the records in question. The sponsor's records shall be available at all times for inspection and audit by representatives of the Secretary, the Comptroller General of the United States, and the State agency for a period of three years following the date of submission of the final claim for reimbursement for the fiscal year.? Per 7 CFR 226.10 (c), ?Claims for Reimbursement shall report information in accordance with the financial management system established by the State agency, and in sufficient detail to justify the reimbursement claimed? In submitting a Claim for Reimbursement, each institution shall certify that the claim is correct and that records are available to support that claim.? Condition Child Nutrition Cluster (CNC) (AL Nos. 10.553, 10.555, and 10.559) During the procedures performed over meals claimed under the Child Nutrition Cluster programs during the fiscal year 2022, we noted that the monthly meal counts recorded in the District?s Cafeteria Management System (CMS) were not fully supported by underlying documentation (e.g., meal count sheets). We sampled 20 out of 711 schools in August 2021, 20 out of 697 schools in November 2021, and 20 out of 696 schools in February 2022. We then validated that the meal counts recorded in the CMS for Breakfast and Lunch were supported by either meal count sheets used at the school sites or by the point-of-sale (POS) system data. Based on our procedures, we noted the following: 1. Of the 20 schools sampled in August 2021, we noted variances in four (4) schools between the CMS count and the meal count sheets for Breakfast. Breakfast meal counts were under-claimed by 46, based on a total sample of 23,497 meals tested, from a total reported population of 1,961,194 meals. 2. Of the 20 schools sampled in November 2021, we noted variances in four (4) schools between the CMS count and the meal count sheets for Breakfast. Breakfast counts were over/(under) claimed by 29 and (1), respectively, based on a total sample of 25,432 meals tested, from a total reported population of 2,508,853 meals. 3. Of the 20 schools sampled in February 2022, we noted variances in four (4) schools between the CMS count and the meal count sheets for Breakfast. Breakfast counts were over/(under) claimed by 9 and (44), respectively, based on a total sample of 19,882 meals tested from a total reported population of 2,575,622 meals. Child And Adult Care Food Program (CACFP) (AL No. 10.558) During the procedures performed over meals claimed under the Child and Adult Care Food Program during the fiscal year 2022, we noted that the monthly meal counts recorded in the District?s Cafeteria Management System (CMS) were not fully supported by underlying documentation (e.g., meal count sheet). We sampled 8 out of 680 schools in September 2021, 9 out of 680 schools in November 2021, and 8 out of 684 schools in February 2022. We then validated that the meal counts recorded in the CMS for Snack and Supper were supported by either meal count sheets used at the school sites or by POS system data. Based on our procedures, we noted the following: 1. Of the 8 schools sampled in September 2021, we noted a variance in one (1) school between the CMS count and the meal count sheets for Supper. Supper meal counts were under-claimed by 10, based on a sample of 12,269 meals tested, from a total reported population of 4,513,335 meals. 2. Of the 8 schools sampled in February 2022, we noted variances in four (4) schools between the CMS count and the meal count sheets for both Snack and Supper. Snack counts were over-claimed by 20, based on a total sample of 4,609 meals tested from a total reported population of 1,183,533 meals. Supper counts were over/(under) claimed by 27 and (21), respectively, based on a total sample of 14,854 meals tested from a total reported population of 3,686,216 meals. Our samples were statistically valid samples. Cause and Effect The condition appears to be caused by human error while manually counting the paper meal count sheets. Inaccurate claims of meal counts could lead to questioned costs. Questioned Costs Federal regulation 2 CFR 200.516 (a)(3) requires the auditor to report questioned costs when likely questioned costs exceed $25,000. Child Nutrition Cluster (CNC) (AL Nos. 10.553, 10.555, and 10.559) Overclaimed - $95; Underclaimed ? $(230) Child And Adult Care Food Program (CACFP) (AL No. 10.558) Overclaimed - $126; Underclaimed ? $(122) The following are the total over/(under) claimed per meal type and per program: "See schedule of Findings and Questioned Costs for chart/table" Repeat Finding This finding is a repeat finding as indicated in the Status of Prior Audit Finding as finding number F-2021-007. Recommendation We recommend that the District continue to strengthen its controls over the meal claim process to ensure that meals are accurately counted, inputted into CMS and claimed for reimbursement. Views of Responsible Officials, Planned Corrective Actions, and Contact Information For the 2021-22 school year, the Food Services Division used federal waivers to support students and families by providing meals under multiple programs. Starting August 2021, COVID concerns resulted in the district discontinuing breakfast in the classroom. USDA waivers permitted the distribution of breakfast and supper meals to students as they left campus for consumption at home. As the school year progressed, the after-school supper program was reinstated for a small group of students at some schools, and this group of students was given a breakfast to take home. Additionally, we distributed weekend meals comprising of supper and snacks. Lastly, the district requested Food Services to serve a morning snack (at the District?s expense) for hungry students. The snacks were tracked manually for reimbursement from ESSER funds by the district. Each meal service required a different form to count meals and multiple sheets for the same meal period depending on how the meal bags were distributed (exit gate vs. classroom). The managers had many forms that had to be put together and summed up to come up with the reimbursable counts. Manually compiling and uploading the information is the reason for the variances. Each time there was a change in the operation, the Food Service team had to create a new training module for the change in operation, which created additional forms leading to the errors seen in the audit review. We want to state respectfully that our error rate for meal counts was 0.4% which, given the multiple food distribution channels to support students, is understandable. To address the audit findings, Food Services will review and modify our procedures and be stringent in monitoring our existing systems and procedures: 1. Food Services Division will add steps to our current meal claiming procedures to ensure accuracy of claims. a. Food Service Manager will utilize the Meal Count Consolidation Form for meal periods that have more than one meal count sheet. b. Food Service Manager will input meal counts into CMS based on information from the Consolidation Form. c. Food Service Manager will run a weekly Meal Counts Report generated from CMS. d. Food Service Manager will compare daily meal count documents to the five-day Meal Count Report for accuracy. e. Area Food Services Supervisors (AFSS) will randomly check meal counts entered in CMS and compare them with the numbers entered in daily meal count sheets. Each school will have a random review every 2-3 months, and where errors are found there will be additional follow up. 2. Food Services will follow the review steps as indicated in Corrective Action Response #1 and confirm the claim for accuracy prior to submission to CNIPS. a. Food Services Central Office Staff will provide a daily meal count report to all Supervisors for review to identify any inputting errors. b. Food Service Managers will review and adjust meal counts prior to the CNIPS claim submission, based on AFSS feedback. The target date for the implementation of the above corrective action plan is by the end of February 2023. Name: Manish Singh Title: Director, Food Services Division Telephone: (213) 241-2993

Categories

Questioned Costs Subrecipient Monitoring Special Tests & Provisions Matching / Level of Effort / Earmarking Cash Management School Nutrition Programs Significant Deficiency

Other Findings in this Audit

  • 46865 2022-003
    Significant Deficiency Repeat
  • 46866 2022-003
    Significant Deficiency Repeat
  • 46867 2022-003
    Significant Deficiency Repeat
  • 46868 2022-003
    Significant Deficiency Repeat
  • 46869 2022-003
    Significant Deficiency Repeat
  • 46871 2022-003
    Significant Deficiency Repeat
  • 46872 2022-003
    Significant Deficiency Repeat
  • 46873 2022-003
    Significant Deficiency Repeat
  • 46874 2022-004
    Significant Deficiency
  • 46875 2022-005
    Material Weakness
  • 46876 2022-005
    Material Weakness
  • 46877 2022-005
    Material Weakness
  • 46878 2022-002
    Material Weakness Repeat
  • 46879 2022-002
    Material Weakness Repeat
  • 46880 2022-002
    Material Weakness Repeat
  • 46881 2022-002
    Material Weakness Repeat
  • 46882 2022-001
    Material Weakness Repeat
  • 46883 2022-001
    Material Weakness Repeat
  • 623307 2022-003
    Significant Deficiency Repeat
  • 623308 2022-003
    Significant Deficiency Repeat
  • 623309 2022-003
    Significant Deficiency Repeat
  • 623310 2022-003
    Significant Deficiency Repeat
  • 623311 2022-003
    Significant Deficiency Repeat
  • 623312 2022-003
    Significant Deficiency Repeat
  • 623313 2022-003
    Significant Deficiency Repeat
  • 623314 2022-003
    Significant Deficiency Repeat
  • 623315 2022-003
    Significant Deficiency Repeat
  • 623316 2022-004
    Significant Deficiency
  • 623317 2022-005
    Material Weakness
  • 623318 2022-005
    Material Weakness
  • 623319 2022-005
    Material Weakness
  • 623320 2022-002
    Material Weakness Repeat
  • 623321 2022-002
    Material Weakness Repeat
  • 623322 2022-002
    Material Weakness Repeat
  • 623323 2022-002
    Material Weakness Repeat
  • 623324 2022-001
    Material Weakness Repeat
  • 623325 2022-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.425 Covid-19 Elementary and Secondary School Emergency Relief (esser Ii) Fund $693.06M
84.425 Covid-19 American Rescue Plan Act (arp Act) Esser III Fund $392.28M
84.010 Every Student Succeeds Act (essa), Title I Part A Basic $331.33M
10.555 Child Nutrition School Programs Lunch $176.59M
10.558 Child Nutrition Child Care Food Program (ccfp) Claims $142.65M
84.027 Special Ed: Idea Basic Local Assistance Entitlement $110.06M
93.323 Covid-19 Epidemiology and Laboratory Capacity for Infectious Diseases (elc), School Based Covid-19 Testing $75.04M
10.553 Child Nutrition School Programs Breakfast $68.41M
84.425 Covid-19 Expanded Learning Opportunities (elo) Esser II Fund State Reserve $54.21M
10.559 Child Nutrition Summer Food Services Program Operations $28.67M
84.424 Essa Title Iv, Part A, Student Support and Academic Enrichment Grant Program $28.22M
84.367 Essa Title Ii, Part A, Supporting Effective Instruction $26.51M
32.009 Emergency Connectivity Fund Program $25.91M
10.555 Donated Food Commodities $24.70M
10.555 Covid-19 Child Nutrition School Nutrition Program (snp) Emergency Operational Costs Reimbursement (ecr) $13.30M
84.027 Special Ed: Individual with Disabilities Education (idea) Local Assistance, Part B, Sec.611 Early Intervening Services $13.17M
10.558 Child Nutrition Child Care Food Program - Cash in Lieu of Commodities $9.73M
84.334 Gaining Early Awareness and Readiness for Undergraduate Programs $9.37M
84.365 Title III English Learner Student $8.95M
84.002 Wioa - Adult Basic Ed/ela $8.66M
84.425 Covid-19 Governor's Emergency Education Relief (geer) Fund: Learning Loss Mitigation $7.11M
10.558 Covid-19 Child Nutrition Child and Adult Care Food Program (cacfp) Ecr $6.87M
84.027 Special Ed: Idea Mental Health Allocation Plan $6.53M
84.010 Essa, Comprehensive Support & Improvement (csi) $6.08M
84.048 Carl D. Perkins - Secondary Program, Sec131 $6.00M
84.173 Idea Preschool Expansion Grant $5.09M
84.002 Wioa - Ad Ed & Fam Lit/el - Civics $4.88M
84.425 Covid-19 Esser Fund California Community Schools Partnership Program $4.59M
84.002 Wioa - Adult Secondary Ed $3.72M
93.575 Covid-19 Child Development: Coronavirus Response and Relief Supplemental Appropriations (crrsa) Act - One Time Stipend $3.54M
84.425 Covid-19 Elo Grant Geer II $3.18M
93.596 General Child Care Center - Mandatory & Matching Fund $3.06M
84.425 Covid-19 Esser Fund $2.51M
97.039 Hazard Mitigation Grant Program $2.22M
84.126 Rehab- Transition Partnership Program/trans Part - Greater La $2.04M
12.U00 Reserve Officer Training Corps Vitalization Act $1.87M
84.048 Carl D. Perkins - Vocational and Technical Education, Sec 132 $1.74M
84.027 Special Ed: Idea Local Assistance, Private School Isps $1.68M
93.575 General Child Care Center - Block Grant $1.41M
84.377 School Improvement Grants $1.28M
84.173 Special Ed: Idea - Part B, Sec 619; Preschool Grants Early $1.23M
84.010 Essa, Title I Part A. Neglected $1.18M
84.181 Special Education-Grants for Infants and Families: Early Intervention Funds - Part C $1.17M
17.259 Wioa - T-1 Youth Source System $1.07M
93.505 Affordable Care Act (aca) Maternal, Infant, and Early Childhood Home Visiting Program $1.02M
84.011 Title I - Migrant Ed - Regular $874,537
10.559 Child Nutrition Summer Food Services Program Sponsor Administration $756,231
84.173 Special Ed: Idea - Part B, Sec 619; Preschool Grants Early Intervening Services $708,178
84.365 Title III Immigrant Student $507,829
84.425 Covid-19 Twenty-First Century Learning Centers Rate Increase Elementary and Secondary School Emergency Relief (esser Iii) State Reserve After School Programs $492,444
93.079 Cdcp - School Based Hiv/std Prevention $455,922
84.425 Covid-19 Arp Act - Homeless Children and Youth (arp-Hcy) Program $310,076
84.196 Education for Homeless Children & Youth $301,288
84.287 Twenty-First Century Community Learning Centers $299,829
93.600 Early Head Start $289,157
84.305 Air Credit Recovery $209,681
84.011 Title I - Migrant Ed - Summer $208,189
84.425 Covid-19 Coronavirus Aid, Relief, and Economic Security (cares) Act Esser Child Nutrition $207,015
93.994 Child Health Outreach Initiative - Whole Person Care $177,470
84.060 Indian Education $115,847
17.259 Wioa Youth $102,000
93.575 Cctr Programs Administered by California Department of Social Services $99,736
17.258 Workforce Innovation and Opportunity Act (wioa) - Worksource Educational Partnership - Adult $90,279
20.205 Highway Planning and Construction: Active Transportation Program $86,843
84.027 Special Ed: Idea - Supporting Inclusive Practices, Part B - Sec 611 $83,799
17.278 Wioa - Worksource Educational Partnership - Dislocated Workers $71,974
17.245 Employment Development Department Trade Act: Trade Adjustment Assistance (taa) $71,300
84.027 Special Ed: Idea - Alternate Dispute Resolution, Part B - Sec 611 $69,986
84.365 National Professional Development Grant, Project Royal $65,295
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) Tick Fire $49,003
93.566 California Department of Social Services Refugee Program Bureau $47,687
47.076 Usc - Math for America Los Angeles $47,577
10.665 Forest Reserve $42,851
12.900 Startalk: Exploring Arabic Through Technology, Startalk - Lausd $39,063
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) Getty Fire $34,567
84.011 Title I - Migrant Ed - School Readiness $32,656
84.010 Essa, Title I Part D. Delinquent $30,919
84.173 Preschool Expansion - Staff Development $26,402
84.365 Loyola Marymount University (lmu) Purposeful Engagement in Academic Rigor and Language Learning (pearll) Project $26,382
93.558 County Youth Jobs Program - Calworks $13,999
84.411 Wested Federal Investing in Innovation and Improvement Program I3 Grant $13,058
84.173 Special Ed: Idea - Preschool Capacity Building, Part B - Sec 619 2020-21 Embedded Instruction $9,504
10.649 Pandemic Electronic Benefit Transfer (ebt) Administrative Grant $5,814
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $4,527
10.574 Child Nutrition Team Nutrition Grants $3,893
94.014 Youth Service America Corporation $3,601
93.719 Arra - State Grants to Promote Health Information Technology $842
93.079 Youth Risk Behavior Survey Participation $500
16.839 Stop School Violence $421
93.575 Covid-19 Cares Act General Child Care and Development (cctr) $118