Finding 496927 (2023-001)

Significant Deficiency
Requirement
E
Questioned Costs
-
Year
2023
Accepted
2024-09-16

AI Summary

  • Core Issue: About 60 students were incorrectly marked as eligible for free meals without proper applications or documentation.
  • Impacted Requirements: Eligibility must be verified through applications or approved documentation, not through administrative overrides.
  • Recommended Follow-up: Ensure only eligible students are classified for free meals based on proper applications, with all decisions documented and reviewed by knowledgeable officials.

Finding Text

2023-001 U.S. Department of Agriculture, for the period July 1, 2022 through June 30, 2023, Assistance Listing #10.553-10.559, Internal Controls over School Nutrition Program (Child Nutrition Cluster) Criteria: To receive free or reduced meals through the School Nutrition Program, students must qualify for such funding either though meeting income guidelines, receiving TANF or SNAP, or by being on the DHS preapproved list. This qualification must be assessed through applications submitted by parents or via other qualifying documentation. Condition: Approximately 60 students were marked as eligible for free meals without substantiating eligibility through the required application process or via alternative documentation. Cause: During fiscal year 2023, there was a very low rate of return for school nutrition applications. As such, management used administrative override to judgmentally determine that approximately 60 additional students were considered free. Controls were ineffective in preventing this administrative override from management. Effect: The District may have erroneously received supplemental School Nutrition Program funding. Recommendation: There are no provisions in the regulations that provide for large scale reclassifications through administrative override. As such, we recommend that only students who are deemed eligible for free or reduced meals through the application process be marked as such. All eligibility determinations should be documented and reviewed by an official with adequate knowledge of the School Nutrition Program eligibility criteria. Questioned Costs: None

Corrective Action Plan

Management’s Response/Corrective Action Plan: We agree with RKO's recommendation that there are no provisions in the regulations that provide for large scale reclassifications through administrative override. There was some confusion on the part of Maine School Administrative District No. 35 when a communication from the State of Maine was received in November of 2022, that the rate of Free and Reduced children identified at Maine School Administrative District No. 35 had dropped dramatically from the prior year (due to the meals being free to all) and that it may negatively impact our subsidy. At that point, Maine School Administrative District No. 35 asked its building administrators to identify needy families based on conversations they had previously had with parents, from speaking with their guidance counselors, from knowledge they had working with outside community agencies (68 Hours of Hunger) to help identify families potentially in need. From there the lists provided by the building administrators were compared with the families who had already submitted applications, and the directly certified students, and any students who were not identified in either of those cohorts were added to the free and reduced list per administrative override. When RKO arrived in May 2023 to perform interim testing, they let us know that this was not appropriate. At that time, we removed those students from the free and reduced list, and adjusted all of our previously submitted claim forms to account for the change. Maine School Administrative District No. 35 is now clear on the rules with regards to the use of administrative override, and will not use it again in the future.

Categories

Eligibility School Nutrition Programs Internal Control / Segregation of Duties Special Tests & Provisions

Other Findings in this Audit

  • 496928 2023-001
    Significant Deficiency
  • 496929 2023-001
    Significant Deficiency
  • 496930 2023-001
    Significant Deficiency
  • 1073369 2023-001
    Significant Deficiency
  • 1073370 2023-001
    Significant Deficiency
  • 1073371 2023-001
    Significant Deficiency
  • 1073372 2023-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.027 Local Entitlement $549,314
84.425 Covid-19 Elementary and Secondary School Emergency Relief III Arp $409,670
10.555 National School Lunch Program $264,686
84.010 Title 1a Disadvantaged $205,008
21.027 Covid-19 State and Local Fiscal Recovery Funds - Extended Learning Opportunities $132,551
84.367 Title Iia - Supporting Effective Instruction $76,995
10.553 National School Lunch Program - Breakfast Program $72,572
10.555 National School Lunch Program - Supply Chain Assistance $61,699
84.425 Covid-19 Governor Emergency Education Relief $61,200
21.027 Covid-19 State and Local Fiscal Recovery Funds - College Coordinator $59,252
10.555 National School Lunch Program - Donated Commodities $45,657
84.027 Covid-19 Local Entitlement Arp $40,298
84.002 Family Literacy $7,549
84.173 Preschool Grants $6,177
84.173 Covid-19 Preschool Grants Arp $4,603
10.649 Covid-19 Pandemic Ebt Administrative Costs: Snap $3,140