Finding 517153 (2024-001)

Material Weakness
Requirement
E
Questioned Costs
$1
Year
2024
Accepted
2024-12-30
Audit: 335092
Organization: Academie Lafayette (MO)

AI Summary

  • Core Issue: Errors in determining student eligibility for free and reduced meals led to material noncompliance.
  • Impacted Requirements: Lack of internal controls violated the Uniform Guidance, which mandates proper management of federal awards.
  • Recommended Follow-Up: The School should assess current processes, identify risks, and establish stronger internal controls to prevent future errors.

Finding Text

Assistance listing number: 10.553 & 10.555 Program title: Child Nutrition Cluster Agency: U.S. Department of Agriculture Pass-Through entity: Missouri Department of Elementary and Secondary Education Compliance Requirement: Eligibility Type of Finding: Material noncompliance Criteria: The Uniform Guidance (2 CFR section 200.303) requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Condition: There were errors in the determination of eligibility of students to receive free and reduced meals. Cause: During the year, there was no second review of the determination of student eligibility to receive free or reduced priced meals. Effect: Due to the lack of effective internal control, errors were noted causing the school to overclaim eligible meals. Questioned costs: $20,578.74 Recommendation: We recommend the School evaluate the key processes, identify risks in existing in the Child Nutrition Cluster and implement internal controls to respond to the identified risks. Views of responsible officials: The School agrees with the finding and will implement the auditor’s recommendation.

Corrective Action Plan

A. Revise and Strengthen Processes 1. New Software Implementation: o Replace the previous software program with a more reliable system. 2. Process Realignment: o Redefine staff roles to ensure clear responsibilities for eligibility determinations and reviews. B. Establish and Strengthen Internal Controls 1. Eligibility Review: o DeAnn Gould, Federal Programs & Grants Coordinator, and Howard Carpenter, Director of Operations, will oversee eligibility determinations using the updated software and Attachment A for reference. o Conduct a second review of all applications to verify accuracy and compliance with eligibility criteria. 2. Regular Edit Checks: o Implement weekly edit checks in the Point of Service (POS) system to confirm correct benefits distribution. C. Staff Training 1. Regular Food and Nutrition Services (FNS) Training: o Conduct quarterly training sessions on eligibility criteria, compliance requirements, and internal control processes. o Include hands-on training for using the new software and reviewing Attachment A criteria. 2. Compliance Assessments: o Assess staff understanding post-training to identify additional support needs. D. Monitoring and Evaluation 1. Audit Schedule: o Conduct monthly internal audits to evaluate compliance and report findings to leadership. 2. Performance Metrics: o Track error rates in eligibility determinations and aim for a significant reduction by June 30, 2025. E. Addressing Questioned Costs 1. Reconciliation Plan: The Missouri Department of Elementary and Secondary Education (DESE) has informed the School that the questioned costs of $20,578.74 will be withheld from future Food Service payment requests. The School will work with DESE to ensure proper adjustments and compliance with this reconciliation plan. 2. Process Transparency: Documentation of the withholdings and their impact on future payments will be maintained and reviewed to confirm accurate reconciliation of the overclaimed amount.

Categories

Questioned Costs School Nutrition Programs Subrecipient Monitoring Eligibility Internal Control / Segregation of Duties Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 517154 2024-001
    Material Weakness
  • 1093595 2024-001
    Material Weakness
  • 1093596 2024-001
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
84.425 Education Stabilization Fund $320,058
84.027 Special Education Grants to States $274,740
84.010 Title I Grants to Local Educational Agencies $216,191
10.555 National School Lunch Program $184,921
84.282 Charter Schools $138,702
10.553 School Breakfast Program $39,447
84.367 Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) $33,447
84.424 Student Support and Academic Enrichment Program $17,052
84.173 Special Education Preschool Grants $2,700