FAC Explorer

Finding 539061 (2024-003)

Significant Deficiency Repeat Finding
Requirement
Activities Allowed/Unallowed
Questioned Costs
$1
Year
2024
Accepted
2025-03-28
Audit: 349776
Organization: City of Boston (MA)
Auditor: Kpmg LLP

AI Summary

  • Core Issue: Inaccurate meal count reports and insufficient recordkeeping led to noncompliance with reimbursement claims for the National School Lunch Program.
  • Impacted Requirements: Failure to maintain accurate records and perform thorough reviews violates federal regulations on meal reimbursement and record retention.
  • Recommended Follow-Up: Enhance policies for meal count reviews and ensure compliance with recordkeeping requirements; implement electronic tracking to reduce errors.

Finding Text

Finding number: 2024-003 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 ALN #: 10.555 Award number: 13-035 Award year: July 1, 2023 to June 30, 2024 Finding: Internal Control and Compliance over Allowability and Reporting Prior Year Finding: Yes; 2023-003 Type of Finding: Significant Deficiency and Noncompliance Criteria Allowability: Reimbursement for meals served is not based on costs; it is determined solely by applying the applicable meals times rates formula. Financial Reporting: a. Claims for Reimbursement SFAs and sponsors must submit monthly claims for reimbursement for meals and snacks served to eligible students within 60 days following the last day of the month covered by the claim (7 CFR sections 210.8, 220.11, 215.10, and 225.15(c). The state agency has an additional 30 days to submit a consolidated report to FNS (7 CFR 210.5(d), 220.13(b)(2), 215.11(c)(2), and 225.8). b. Recordkeeping Each month’s claim for reimbursement and all data used in the claims review process must be maintained on file. Accurate records must be maintained justifying all meals claimed and documenting that all Program funds were spent only on allowable Child Nutrition Program costs. Failure to maintain such records may be grounds for denial of reimbursement for meals served and/or administrative costs claimed during the period covered by the records in question. Records are required to be retained for a period of three years after submission of the final Claim for Reimbursement for the fiscal year. Or, if audit findings have not been resolved, the records must be retained beyond the three-year period aslong as required for the resolution of the issues raised by the audit. School food authorities are required to make the information available to the Department and the state agency upon request. 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 completeness and accuracy testing of the City of Boston Public Schools Food and Nutrition Services (FNS) monthly claims for reimbursement and recordkeeping, which included the allowability of meals reimbursed, we noted that edit checks were performed and documented monthly at the school site level confirming meal count reports. However, out of a sample of 60 days across 12 schools, there were 14 days across 7 schools that did not agree to the underlying manual tally sheets. Additionally, out of a sample of 12 monthly Field Coordinator reviews across 72 school sites, there were 3 reviews where the City was unable to provide evidence that the Field Coordinator’s review and approval took place. Cause This appears to be due to insufficient policies and procedures surrounding the claims for reimbursement and recordkeeping. Effect Meal count reports utilized for the monthly claims for reimbursement are not complete and accuracy, nor do they have complete and accurate underlying records to substantiate the meals requested for reimbursement. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs $108 Recommendation We recommend that FNS enhance their policies and procedures to include a more thorough review and approval of meal counts at the school level to ensure allowability as well as completeness and accuracy of the meal counts submitted for reimbursement. Additionally, we recommend FNS re-enforce their policy to ensure underlying records are maintained in accordance with program requirements. View of Responsible Officials from the Auditee FNS agrees with the importance of accurate meal counting and claiming. Because most errors result from arithmetic or data entry mistakes when cafeteria staff record meals served on paper tally sheets and laterenter totals into the computer, we now require that all meals served in the cafeterias be recorded electronically in the POS system at the point of service. We are also exploring ways to use the electronic POS system to record meals that are served in classrooms. The monthly review of school edit check reports by the field coordinators is also now documented using a Google Form that each coordinator is required to complete each month for review by the financial analyst prior to submission of the claim. We will emphasize the importance of proper meal counting and retention of documents during training for cashiers and cafeteria managers.

Corrective Action Plan

Boston Public Schools Food and Nutrition Services has begun implementing advanced policies including additional segregation of duties and additional documentation to ensure that all deposits made have clear and accurate cash receipt forms. Anticipated Completion Date: June 30, 2025 Responsible Contact Person: Colin Musto, Assistant City Auditor, Grants Monitoring Unit colin.musto@boston.gov

Categories

Questioned Costs School Nutrition Programs Cash Management Reporting Significant Deficiency Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Other Findings in this Audit

  • 539062 2024-004
    Significant Deficiency
  • 539063 2024-005
    Significant Deficiency
  • 539064 2024-006
    Significant Deficiency Repeat
  • 539065 2024-007
    Significant Deficiency Repeat
  • 539066 2024-008
    Significant Deficiency Repeat
  • 539067 2024-009
    Significant Deficiency Repeat
  • 539068 2024-009
    Significant Deficiency Repeat
  • 539069 2024-009
    Significant Deficiency Repeat
  • 539070 2024-010
    Significant Deficiency Repeat
  • 539071 2024-010
    Significant Deficiency Repeat
  • 539072 2024-011
    Material Weakness
  • 539073 2024-012
    Significant Deficiency Repeat
  • 1115503 2024-003
    Significant Deficiency Repeat
  • 1115504 2024-004
    Significant Deficiency
  • 1115505 2024-005
    Significant Deficiency
  • 1115506 2024-006
    Significant Deficiency Repeat
  • 1115507 2024-007
    Significant Deficiency Repeat
  • 1115508 2024-008
    Significant Deficiency Repeat
  • 1115509 2024-009
    Significant Deficiency Repeat
  • 1115510 2024-009
    Significant Deficiency Repeat
  • 1115511 2024-009
    Significant Deficiency Repeat
  • 1115512 2024-010
    Significant Deficiency Repeat
  • 1115513 2024-010
    Significant Deficiency Repeat
  • 1115514 2024-011
    Material Weakness
  • 1115515 2024-012
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
84.425 Education Stabilization Fund $203.78M
84.010 Title I Grants to Local Educational Agencies $58.87M
14.267 Continuum of Care Program $40.38M
10.555 National School Lunch Program $30.91M
84.027 Special Education Grants to States $17.94M
97.067 Homeland Security Grant Program $13.81M
97.083 Staffing for Adequate Fire and Emergency Response (safer) $9.97M
14.239 Home Investment Partnerships Program $5.87M
21.023 Emergency Rental Assistance Program $4.73M
84.173 Special Education Preschool Grants $3.24M
84.424 Student Support and Academic Enrichment Program $3.12M
84.367 Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) $3.00M
14.231 Emergency Solutions Grant Program $2.77M
84.048 Career and Technical Education -- Basic Grants to States $2.24M
84.365 English Language Acquisition State Grants $1.94M
10.558 Child and Adult Care Food Program $1.93M
93.045 Special Programs for the Aging, Title Iii, Part C, Nutrition Services $1.89M
66.443 Reducing Lead in Drinking Water (sdwa 1459b) $1.48M
97.106 Securing the Cities Program $1.28M
14.905 Lead Hazard Reduction Demonstration Grant Program $1.11M
10.582 Fresh Fruit and Vegetable Program $1.09M
14.248 Community Development Block Grants Section 108 Loan Guarantees $919,562
10.559 Summer Food Service Program for Children $883,164
20.500 Federal Transit Capital Investment Grants $815,500
16.833 National Sexual Assault Kit Initiative $777,046
84.287 Twenty-First Century Community Learning Centers $748,658
93.044 Special Programs for the Aging, Title Iii, Part B, Grants for Supportive Services and Senior Centers $737,136
84.184 School Safely National Activities $731,838
97.111 Regional Catastrophic Preparedness Grant Program (rcpgp) $711,470
93.493 Congressional Directives $680,072
93.053 Nutrition Services Incentive Program $593,356
97.024 Emergency Food and Shelter National Board Program $556,657
93.079 Cooperative Agreements to Promote Adolescent Health Through School-Based Hiv/std Prevention and School-Based Surveillance $526,196
20.616 National Priority Safety Programs $496,691
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $425,792
93.043 Special Programs for the Aging, Title Iii, Part D, Disease Prevention and Health Promotion Services $402,254
93.052 National Family Caregiver Support, Title Iii, Part E $398,440
97.044 Assistance to Firefighters Grant $393,945
21.027 Coronavirus State and Local Fiscal Recovery Funds $353,549
94.016 Americorps Seniors Senior Companion Program (scp) 94.016 $329,650
16.738 Edward Byrne Memorial Justice Assistance Grant Program $302,301
20.219 Recreational Trails Program $300,000
97.047 Bric: Building Resilient Infrastructure and Communities $294,366
84.002 Adult Education - Basic Grants to States $276,923
16.741 Dna Backlog Reduction Program $254,896
84.336 Teacher Quality Partnership Grants $222,942
16.015 Missing Alzheimer's Disease Patient Assistance Program $142,079
94.002 Americorps Seniors Retired and Senior Volunteer Program (rsvp) 94.002 $134,183
10.935 Urban Agriculture and Innovative Production $132,138
93.566 Refugee and Entrant Assistance State/replacement Designee Administered Programs $131,056
14.401 Fair Housing Assistance Program $119,749
84.196 Education for Homeless Children and Youth $106,059
16.588 Violence Against Women Formula Grants $104,318
14.241 Housing Opportunities for Persons with Aids $99,539
45.301 Museums for America $93,526
97.042 Emergency Management Performance Grants $91,427
32.001 Communications Information and Assistance and Investigation of Complaints $77,625
16.745 Criminal and Juvenile Justice and Mental Health Collaboration Program $73,828
16.838 Comprehensive Opioid, Stimulant, and Other Substances Use Program $68,165
10.331 Gus Schumacher Nutrition Incentive Program $65,759
14.889 Choice Neighborhoods Implementation Grants $59,681
10.579 Child Nutrition Discretionary Grants Limited Availability $59,354
97.056 Port Security Grant Program $42,469
10.575 Farm to School Grant Program $37,410
93.042 Special Programs for the Aging, Title Vii, Chapter 2, Long Term Care Ombudsman Services for Older Individuals $35,915
14.246 Community Development Block Grants/brownfields Economic Development Initiative $28,049
16.742 Paul Coverdell Forensic Sciences Improvement Grant Program $27,991
66.818 Brownfields Multipurpose, Assessment, Revolving Loan Fund, and Cleanup Cooperative Agreements $25,980
15.904 Historic Preservation Fund Grants-in-Aid $11,270
16.710 Public Safety Partnership and Community Policing Grants $10,945
16.820 Postconviction Testing of Dna Evidence $9,290
14.218 Community Development Block Grants/entitlement Grants $2,146
14.261 National Homeless Data Analysis Project (nhdap) $1,750
10.727 Inflation Reduction Act Urban & Community Forestry Program $1,232
17.259 Wioa Youth Activities $1,145
11.307 Economic Adjustment Assistance $949
17.285 Registered Apprenticeship $582
17.258 Wioa Adult Program $214
21.009 Volunteer Income Tax Assistance (vita) Matching Grant Program $182
17.289 Community Project Funding/congressionally Directed Spending $107
17.278 Wioa Dislocated Worker Formula Grants $101
17.207 Employment Service/wagner-Peyser Funded Activities $67