Finding 501884 (2023-001)

FA 2023-001 Improve Internal Control Activities Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Eligibility Reporting Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Agriculture Pass-Through Entity: Georgia Department of Education AL Numbers and Titles: 10.553 – School Breakfast Program 10.555 – National School Lunch Program 10.555 – COVID-19-National School Lunch Program Federal Award Numbers: 225GA324N1099 (Year: 2022), 235GA324N1199 (Year: 2023) Questioned Costs: None Identified Description: A review of expenditures, free and reduced meal applications, and reporting requirements related to the Child Nutrition Cluster revealed that the School District’s internal control procedures were not operating appropriately to ensure that appropriate reviews and approvals occurred. Background Information: The Child Nutrition Cluster (CNC) is comprised of various programs that are intended to assist states in administering and overseeing food service program operators that provide healthful, nutritious meals to eligible children in public and non-profit private schools, residential child care institutions, and summer programs. This Cluster of programs also fosters healthy eating habits in children by providing fresh fruits and fresh vegetables to children attending elementary and secondary schools and encourages the domestic consumption of nutritious agricultural commodities. CNC funding was granted to the Georgia Department of Education (GaDOE) by the U.S. Department of Agriculture. GaDOE is responsible for distributing funds to local educational agencies (LEAs) and overseeing the various CNC programs. CNC funds totaling $1,861,046.22 were expended and reported on the City of Jefferson Board of Education’s Schedule of Expenditures of Federal Awards (SEFA) for fiscal year 2023. Criteria: As a recipient of federal awards, the School District is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 – Internal Controls. Condition: Internal controls over various compliance requirements associated with the Child Nutrition Cluster were reviewed by the auditors. The following deficiencies were noted upon performing these tests: • A sample of twenty-eight expenditures was randomly selected for testing using a non-statistical sampling approach. Evidence of review and approval was not reflected for seven expenditures. • A sample of 40 free and reduced meal applications was randomly selected for testing using a non-statistical sampling approach. Twelve applications did not contain evidence of review of the eligibility determination for free and reduced meals. • A sample of three meal count reports was randomly selected for testing using a non-statistical sampling approach. Evidence of review and approval was not reflected for these three reports. Cause: In discussing this deficiency with the School District, they noted these issues were a result of turnover within the Central Office. Effect: The School District is not in compliance with the Uniform Guidance and GaDOE guidance. Failure to review expenditures for allowability, free and reduced meal applications for appropriate eligibility requirements, and meal counts for accurate reporting exposes the School District to unnecessary risk of error and misuse of federal funds. Recommendation: The School District should review current internal control procedures related to the Child Nutrition Cluster. Where vulnerable, the School District should develop and/or modify its policies and procedures to ensure that all expenditures, student free and reduced meal applications, and meal count reports reflect evidence of review for associated compliance requirements. Furthermore, management should develop and implement a monitoring process to ensure that controls are operating appropriately. Views of Responsible Officials: We concur with this finding.