Finding 496628 (2023-004)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2023
Accepted
2024-09-12
Audit: 319431
Organization: City of Boston (MA)
Auditor: Kpmg LLP

AI Summary

  • Core Issue: There are significant deficiencies in internal controls over school food accounts, specifically regarding the accuracy and completeness of Cash Receipt Forms.
  • Impacted Requirements: Compliance with federal regulations (7 CFR and 2 CFR) that mandate effective internal controls and accurate financial reporting for school food services.
  • Recommended Follow-Up: Enhance policies for Cash Receipt Forms and establish backup procedures to ensure accuracy and completeness in the absence of key personnel.

Finding Text

Finding number: 2023 004 Federal agency: U.S. Department of Agriculture Pass through agency: Commonwealth Department of Elementary and Second Education Program: Child Nutrition Cluster – National School Lunch Program Child Nutrition Cluster – Fresh Fruits and Vegetables ALN #: 10.555, 10.582 Award number: Various Award year: Various Finding: Internal Control over School Food Accounts Prior Year Finding: No Type of Finding: Significant Deficiency Criteria 7 CFR 210.14(a), 210.14(c), 210.19(a)(2), 215.7(d), 220.2 and 220.7(e)(1)(i) indicate that a School Food Authority (SFA) is required to account for all revenues and expenditures of its nonprofit school food service in accordance with State and Federal requirements. A SFA must operate its food services on a non profit basis; all revenue generated by the school food service must be used to operate and improve its food services. Additionally, 2 CFR 200.303 indicates that non Federal entities receiving Federal awards 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. Condition During our testing of school food accounts, it was disclosed that the recording of food service federal reimbursement payments is reviewed and approved by the City of Boston Public Schools Food and Nutrition Services (FNS) Director of Finance. This monthly Cash Receipt Form is prepared and sent from the FNS Director of Finance to the City of Boston Treasury Department (Treasury) outlining the grant’s upcoming wire funds from their monthly claims submission request. However, during our testing of a sample size of three months, we noted the September 2022 cash receipt form was not submitted to Treasury for both the National School Lunch program and Fresh Fruits and Vegetables program. Additionally, we noted a variance of $8,676 between the March 2023 Cash Receipt Form, and the reimbursement request and revenue received for the Fresh Fruits and Vegetable program. Cause This appears to be due to insufficient policies and procedures to ensure the Cash Receipt Form is complete and accurate. Additionally, the policies lack an alternative control in cases where key management is unable to perform the control. Effect The FNS does not have effective internal controls over the SFA. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: None Recommendation We recommend that the FNS enhance its policies to ensure completeness and accuracy of the Cash Receipt Forms and include alternative procedures should the control operator be unavailable. View of Responsible Officials from the Auditee FNS would note that the cash receipt form is not the only control to ensure that school nutrition program revenues are correctly deposited in the school nutrition program account. The FNS Director of Finance also reviews the revenue deposited into the account on at least a monthly basis, compares this with a printed copy of the expected reimbursement amount that was submitted to DESE, writes and initials a confirmation of the deposit amount on the printed reimbursement report, and maintains this paperwork in a file. In the event of a discrepancy between the expected and received amounts, the FNS Director of Finance contacts DESE and/or the city treasury as needed to reconcile. So if a cash receipt form is not submitted or contains an error, any missing or incorrect deposits would be discovered and corrected. However, to reduce the possibility of errors or delays in depositing the funds, the FNS Director of Finance will ensure that the FNS Financial Analyst is able to complete the cash receipt form as a backup when necessary.

Categories

School Nutrition Programs Cash Management Significant Deficiency Internal Control / Segregation of Duties

Other Findings in this Audit

  • 496626 2023-003
    Material Weakness
  • 496627 2023-004
    Significant Deficiency
  • 496629 2023-005
    Material Weakness
  • 496630 2023-006
    Material Weakness Repeat
  • 496631 2023-007
    Material Weakness Repeat
  • 496632 2023-008
    Material Weakness
  • 496633 2023-009
    Material Weakness Repeat
  • 496634 2023-010
    Material Weakness
  • 496635 2023-011
    Material Weakness
  • 496636 2023-012
    Significant Deficiency
  • 496637 2023-011
    Material Weakness
  • 496638 2023-012
    Significant Deficiency
  • 496639 2023-013
    Significant Deficiency
  • 496640 2023-014
    Material Weakness
  • 496641 2023-015
    Material Weakness
  • 496642 2023-016
    Material Weakness
  • 1073068 2023-003
    Material Weakness
  • 1073069 2023-004
    Significant Deficiency
  • 1073070 2023-004
    Significant Deficiency
  • 1073071 2023-005
    Material Weakness
  • 1073072 2023-006
    Material Weakness Repeat
  • 1073073 2023-007
    Material Weakness Repeat
  • 1073074 2023-008
    Material Weakness
  • 1073075 2023-009
    Material Weakness Repeat
  • 1073076 2023-010
    Material Weakness
  • 1073077 2023-011
    Material Weakness
  • 1073078 2023-012
    Significant Deficiency
  • 1073079 2023-011
    Material Weakness
  • 1073080 2023-012
    Significant Deficiency
  • 1073081 2023-013
    Significant Deficiency
  • 1073082 2023-014
    Material Weakness
  • 1073083 2023-015
    Material Weakness
  • 1073084 2023-016
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
14.239 Home Investment Partnerships Program $155.28M
21.027 Coronavirus State and Local Fiscal Recovery Funds $137.12M
84.425 Education Stabilization Fund $95.96M
84.010 Title I Grants to Local Educational Agencies $36.42M
14.267 Continuum of Care Program $33.21M
10.555 National School Lunch Program $30.28M
84.027 Special Education_grants to States $18.48M
97.067 Homeland Security Grant Program $14.25M
21.023 Emergency Rental Assistance Program $13.46M
14.231 Emergency Solutions Grant Program $9.76M
97.083 Staffing for Adequate Fire and Emergency Response (safer) $7.37M
14.218 Community Development Block Grants/entitlement Grants $2.92M
84.367 Improving Teacher Quality State Grants $2.66M
66.443 Reducing Lead in Drinking Water (sdwa 1459b) $2.33M
84.365 English Language Acquisition State Grants $1.97M
84.048 Career and Technical Education -- Basic Grants to States $1.89M
14.248 Community Development Block Grants_section 108 Loan Guarantees $1.81M
10.558 Child and Adult Care Food Program $1.72M
10.582 Fresh Fruit and Vegetable Program $1.42M
84.424 Student Support and Academic Enrichment Program $1.21M
93.045 Special Programs for the Aging_title Iii, Part C_nutrition Services $1.17M
84.173 Special Education_preschool Grants $984,808
84.287 Twenty-First Century Community Learning Centers $975,544
14.905 Lead Hazard Reduction Demonstration Grant Program $932,129
10.559 Summer Food Service Program for Children $847,800
93.053 Nutrition Services Incentive Program $819,095
84.002 Adult Education - Basic Grants to States $637,747
97.106 Securing the Cities Program $633,137
93.079 Cooperative Agreements to Promote Adolescent Health Through School-Based Hiv/std Prevention and School-Based Surveillance $529,609
16.833 National Sexual Assault Kit Initiative $419,758
16.034 Coronavirus Emergency Supplemental Funding Program $361,892
16.741 Dna Backlog Reduction Program $304,935
97.111 Regional Catastrophic Preparedness Grant Program (rcpgp) $296,943
94.016 Senior Companion Program $282,802
97.044 Assistance to Firefighters Grant $275,718
16.738 Edward Byrne Memorial Justice Assistance Grant Program $220,692
93.044 Special Programs for the Aging_title Iii, Part B_grants for Supportive Services and Senior Centers $216,589
14.241 Housing Opportunities for Persons with Aids $146,150
94.002 Retired and Senior Volunteer Program $128,436
97.056 Port Security Grant Program $114,220
10.579 Child Nutrition Discretionary Grants Limited Availability $112,182
16.588 Violence Against Women Formula Grants $106,201
84.196 Education for Homeless Children and Youth $101,856
97.024 Emergency Food and Shelter National Board Program $93,705
45.024 Promotion of the Arts_grants to Organizations and Individuals $75,000
16.820 Postconviction Testing of Dna Evidence to Exonerate the Innocent $70,275
10.935 Urban Agriculture and Innovative Production $68,330
16.751 Edward Byrne Memorial Competitive Grant Program $62,566
93.052 National Family Caregiver Support, Title Iii, Part E $54,824
47.076 Education and Human Resources $48,623
93.043 Special Programs for the Aging_title Iii, Part D_disease Prevention and Health Promotion Services $47,562
14.401 Fair Housing Assistance Program_state and Local $43,110
97.042 Emergency Management Performance Grants $42,546
10.331 Food Insecurity Nutrition Incentive Grants Program $40,575
16.838 Comprehensive Opioid Abuse Site-Based Program $38,947
14.889 Choice Neighborhoods Implementation Grants $38,598
14.261 Homeless Management Information Systems Technical Assistance $38,248
84.305 Education Research, Development and Dissemination $32,566
16.742 Paul Coverdell Forensic Sciences Improvement Grant Program $25,988
93.042 Special Programs for the Aging_title Vii, Chapter 2_long Term Care Ombudsman Services for Older Individuals $19,965
14.246 Community Development Block Grants/brownfields Economic Development Initiative $13,770
16.745 Criminal and Juvenile Justice and Mental Health Collaboration Program $12,444
93.566 Refugee and Entrant Assistance_state Administered Programs $9,500
16.560 National Institute of Justice Research, Evaluation, and Development Project Grants $7,450
66.818 Brownfields Assessment and Cleanup Cooperative Agreements $6,810
20.205 Highway Planning and Construction $6,244
84.411 Investing in Innovation (i3) Fund $1,192
16.710 Public Safety Partnership and Community Policing Grants $1,068
20.600 State and Community Highway Safety $283
16.817 Byrne Criminal Justice Innovation Program $-17
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $-385,211