Finding 526660 (2024-006)

Significant Deficiency
Requirement
B
Questioned Costs
$1
Year
2024
Accepted
2025-03-11

AI Summary

  • Core Issue: The District improperly used National School Lunch Program funds to pay an employee not working in the program, resulting in questioned costs of $59,074.56.
  • Impacted Requirements: This violates Federal regulations on allocable costs and internal controls, risking funding and potential reimbursement obligations.
  • Recommended Follow-Up: Ensure all Food Service expenditures are related to the program and implement a two-signature approval process for payroll changes to prevent future errors.

Finding Text

Federal Program Information: Funding Agency: U.S. Department of Agriculture Title: National School Lunch Program FAL Number: 10.555 & 10.553 Passthrough: N/A Award Year: 2024 Criteria: Title 2 Subtitle A Chapter II Part 200 Section 200.405 Allocable Costs (a) Allocable costs in general. A cost is allocable to a Federal award or other cost objective if the cost is assignable to that Federal award or other cost objective in accordance with the relative benefits received. This standard is met if the cost satisfies any of the following criteria: (1) Is incurred specifically for the Federal award; (2) Benefits both the Federal award and other work of the recipient or subrecipient and can be distributed in proportions that may be approximated using reasonable methods; or (3) Is necessary to the overall operation of the recipient or subrecipient and is assignable in part to the Federal award in accordance with these cost principles. (b) Allocation of indirect costs. All activities which benefit from the recipient's or subrecipient's indirect cost, including unallowable activities and donated services by the recipient or subrecipient or third parties, will receive an appropriate allocation of indirect costs. (c) Limitation on charging certain allocable costs to other Federal awards. A cost allocable to a particular Federal award may not be charged to other Federal awards (for example, to overcome fund deficiencies or to avoid restrictions imposed by Federal statutes, regulations, or the terms and conditions of the Federal awards). However, this prohibition would not preclude the recipient or subrecipient from shifting costs that are allowable under two or more Federal awards in accordance with existing Federal statutes, regulations, or the terms and conditions of the Federal awards. (d) Direct cost allocation principles. If a cost benefits two or more projects or activities in proportions that can be determined without undue effort or cost, the cost must be allocated to the projects based on the proportional benefit However, when those proportions cannot be determined because of the interrelationship of the work involved, then, notwithstanding paragraph (c), the costs may be allocated or transferred to benefitted projects on any reasonable documented basis. Where the purchase of equipment or other capital asset is specifically authorized under a Federal award, the costs are assignable to the Federal award regardless of the use that may be made of the equipment or other capital asset involved, when no longer needed for the purpose for which it was originally required. See also §§ 200.310 through 200.316 and 200.439. Condition: During our review of national school lunch payroll, we identified the following issues:  The District used school lunch funds to pay the payroll of an employee who was not working in the program. The employee worked in transportation and accounts payable. Questioned Costs: $59,074.56. This is the amount of school lunch program funds which were paid to the employee. We did not identify any other employees who were not legitimate employees of the school lunch program. Cause: The District did not ensure the funds expended were related to the national school lunch program. Effect: The District is not in compliance with Federal regulations related to internal control procedures and compliance requirements in relation to the grant and could put funding in jeopardy or require the District to reimburse the program. Auditor’s Recommendation: We recommend that all expenditures from the Food Service funds be related to food service. Ensure that only employees in food service are paid out of the national school lunch program funds. Responsible official’s view:  Specific corrective action plan for the finding: This was the result of an error in changing a employee’s position from one department to another. Moving forward, the Human Resources Department will notify Payroll of any changes in position and will require TWO SIGNATURES prior to making any changes in pay coding.  Timeline for completion of corrective action plan: Immediately. This process has already been put in place.  Employee positions(s) responsible for meeting the timeline: Finance Director and Human Resources Director

Corrective Action Plan

Corrective Action Plan 2024-006 – Unallowable Expenditures National School Lunch Program (Significant Deficiency) Federal Program Information: Funding Agency: U.S. Department of Agriculture Title: National School Lunch Program FAL Number: 10.555 & 10.553 Passthrough: N/A Award Year: 2024 Responsible Official’s Plan: Due to the timing of the finding, the District is performing a permanent cash transfer in March to be compliant with the National School Lunch Program. Additionally, the specific corrective action plan provides details for how we have ensured the unallowable expenses for the National School Lunch Program will not occur again. Specific corrective action plan for finding: This was the result of an error in changing an employee's position from one department to another. Moving forward, the Human Resources Department will notify Payroll of any changes in position and will require TWO SIGNATURES prior to making any changes in pay coding. The two signatures are from the Director of Human Resources and the Director of Finance. Timeline for completion of corrective action plan: The permanent cash transfer process has begun and will be completed by March 31, 2025. The form to ensure two signatures are captured prior to making changes in pay coding is already created and being utilized. Employee positions responsible for meeting the timeline: Director of Finance – Cooper Jones Director of Human Resources – Lisa Salazar

Categories

Questioned Costs Allowable Costs / Cost Principles School Nutrition Programs

Other Findings in this Audit

  • 1103102 2024-006
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.041 Impact Aid $898,653
10.553 School Breakfast Program $744,520
84.060 Indian Education Grants to Local Educational Agencies $334,131
84.367 Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) $230,870
84.424 Student Support and Academic Enrichment Program $163,230
10.565 Commodity Supplemental Food Program $161,438
84.010 Title I Grants to Local Educational Agencies $153,000
84.358 Rural Education $92,926
10.555 National School Lunch Program $92,160
10.582 Fresh Fruit and Vegetable Program $74,007
84.048 Career and Technical Education -- Basic Grants to States $53,367
84.365 English Language Acquisition State Grants $36,777
84.173 Special Education Preschool Grants $16,449
84.027 Special Education Grants to States $15,935
84.425 Education Stabilization Fund $15,650