Finding 566933 (2024-002)

Condition: During our testing of monthly reimbursement claims, we identified multiple instances where the number of meals claimed for reimbursement exceeded the number documented on daily meal count sheets maintained by site supervisors or participant rosters. These differences indicate that the claims submitted were not fully supported by the required underlying documentation. Criteria: Title 7 CFR §225.9(d)(5) requires that sponsors certify claims for reimbursement are accurate and supported by available records. Claims that are not substantiated by meal count records do not meet this regulatory requirement. Cause: The control process designed to reconcile daily meal count sheets to the monthly internal summaries prior to claim submission was not operating effectively. Although management performs a second review within 60 days of month-end, initial claims were submitted based on unreconciled summaries due to timing pressures. Effect: Claims for reimbursement were submitted that included meal counts not supported by source documentation. This resulted in noncompliance with the Activities Allowed or Unallowed compliance requirement. Known and likely questioned costs related to these discrepancies were below the Uniform Guidance reporting threshold of $25,000. Context: A sample of 60 daily meal count entries was tested. Of those, 20 (33%) reflected discrepancies between the reported meals on the monthly reimbursement claim and the documented meals served per the corresponding daily meal count sheet. Recommendation: We recommend management strengthen and adhere to internal control procedures that ensure all reimbursement claims are fully reconciled to original daily meal count documentation prior to submission. Where timing constraints necessitate early filing, controls should ensure that amendments are consistently and promptly submitted within the allowable revision window. Management’s Response: See accompanying management’s corrective action plan.