Finding 571674 (2024-002)

Material Weakness
Requirement
L
Questioned Costs
-
Year
2024
Accepted
2025-07-21
Audit: 362615
Organization: Oro Grande School District (CA)
Auditor: Eide Bailly LLP

AI Summary

  • Core Issue: The District lacks proper controls to ensure that monthly Claims for Reimbursement accurately reflect meal counts, leading to discrepancies and potential revenue overstatements.
  • Impacted Requirements: Compliance with Title 7, Code of Federal Regulations, requiring accurate meal count reviews and timely submission of claims.
  • Recommended Follow-Up: Implement a point-of-sale (POS) system and establish a review process to verify meal counts before claims submission.

Finding Text

Criteria or Specific Requirements: Per Title 7, Code of Federal Regulations, Subtitle B, Chapter II, Subchapter A, Parts 210.8 and 220.11, School Food Authorities (SFA) must establish internal controls which ensure the accuracy of meal counts prior to the submission of the monthly Claim for Reimbursement. Prior to submission of a monthly Claim for Reimbursement, each school food authority shall review the breakfast and lunch count data for each school under its jurisdiction to ensure the accuracy of the monthly Claim for Reimbursement. The objective of this review is to ensure that monthly claims include only the number of free, reduced price and paid breakfasts and lunches served on any day of operation to children currently eligible for such meals. SFA staff shall maintain on file each month’s Claim for Reimbursement and all data used in the claims review process, by school. The above-noted CFR section also states that the SFA shall compare each school’s daily counts of meals serve against the product of the number of children in that school currently eligible for free, reduced price and paid lunches, respectively, times an attendance factor. Per Title 7, Code of Federal Regulations, Subtitle B, Chapter II, Subchapter A, Parts 210.8 and 220.11, SFA 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. Condition The District did not have sufficient controls in place to ensure that monthly Claims for Reimbursement accurately reflected the numbers of meals served. There is no indication that a second person reviews data submissions. We noted discrepancies between the daily meal counts and the monthly Claims for Reimbursement. The system reports provided to the auditor for the 12 months selected for testing did not agree to the meal counts reported on the Claims for Reimbursement. Discrepancies included the misclassification of 1,665 lunch meals served. Misstatement of the number of lunch meals served resulted in overstatement revenue of $7,109. The District did not have sufficient controls in place to ensure that monthly Claims for Reimbursement accurately reflected the numbers of meals served. We noted discrepancies between the daily meal counts and the monthly Claims for Reimbursement. During the audit year, the District did not use a point-of-sale (POS) system to track meals served. There was no analytical review or edit check performed to determine reasonableness of meal counts, such as comparing the number of students enrolled to the number of meals served on a daily basis by site. Such analysis would allow staff to identify possible errors timely and in advance of filing a claim. Although not required, a POS system would automate these analyses, allowing for greater staff efficiencies and accuracy. Cause The condition identified appears to have materialized due to the District’s lack of established procedures to ensure compliance with the requirements under Title 7, Code of Federal Regulations, Subtitle B, Chapter II, Subchapter A, Parts 210.8 and 220.11. Effect The District has not complied with the requirements identified in Title 7, Code of Federal Regulations, Subtitle B, Chapter II, Subchapter A, Parts 210.8 and 220.11. Questioned Costs There were no questioned costs associated with the identified condition. Context/Sampling The condition was identified through inquiry with District personnel and through review of available supporting documentation for the monthly Claims for Reimbursement. A nonstatistical sample of 12 months out of 12 months was selected for reporting testing. Condition The District did not have sufficient controls in place to ensure that monthly Claims for Reimbursement accurately reflected the numbers of meals served. There is no indication that a second person reviews data submissions. We noted discrepancies between the daily meal counts and the monthly Claims for Reimbursement. The system reports provided to the auditor for the 12 months selected for testing did not agree to the meal counts reported on the Claims for Reimbursement. Discrepancies included the misclassification of 1,665 lunch meals served. Misstatement of the number of lunch meals served resulted in overstatement revenue of $7,109. The District did not have sufficient controls in place to ensure that monthly Claims for Reimbursement accurately reflected the numbers of meals served. We noted discrepancies between the daily meal counts and the monthly Claims for Reimbursement. During the audit year, the District did not use a point-of-sale (POS) system to track meals served. There was no analytical review or edit check performed to determine reasonableness of meal counts, such as comparing the number of students enrolled to the number of meals served on a daily basis by site. Such analysis would allow staff to identify possible errors timely and in advance of filing a claim. Although not required, a POS system would automate these analyses, allowing for greater staff efficiencies and accuracy. Cause The condition identified appears to have materialized due to the District’s lack of established procedures to ensure compliance with the requirements under Title 7, Code of Federal Regulations, Subtitle B, Chapter II, Subchapter A, Parts 210.8 and 220.11. Effect The District has not complied with the requirements identified in Title 7, Code of Federal Regulations, Subtitle B, Chapter II, Subchapter A, Parts 210.8 and 220.11. Questioned Costs There were no questioned costs associated with the identified condition. Context/Sampling The condition was identified through inquiry with District personnel and through review of available supporting documentation for the monthly Claims for Reimbursement. A nonstatistical sample of 12 months out of 12 months was selected for reporting testing.

Categories

Cash Management Reporting Internal Control / Segregation of Duties

Other Findings in this Audit

  • 571672 2024-002
    Material Weakness
  • 571673 2024-002
    Material Weakness
  • 571675 2024-002
    Material Weakness
  • 571676 2024-002
    Material Weakness
  • 571677 2024-002
    Material Weakness
  • 1148114 2024-002
    Material Weakness
  • 1148115 2024-002
    Material Weakness
  • 1148116 2024-002
    Material Weakness
  • 1148117 2024-002
    Material Weakness
  • 1148118 2024-002
    Material Weakness
  • 1148119 2024-002
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
10.555 School Lunch - Section 11 $1.69M
84.027 Basic Local Assistance Entitlement, Part B, Sec 611 $1.01M
10.553 School Breakfast Needy $849,245
32.009 Covid-19 Emergency Connectivity Fund $676,184
10.558 Cacfp Claims - Centers and Family Day Care Homes $649,737
10.555 School Lunch - Section 4 $223,968
10.555 Covid-19 Supply Chain Assistance (sca) Funds $206,810
10.555 Commodities $190,072
84.425 Covid-19 Elementary and Secondary School Emergency Relief III (esser Iii) Fund $163,617
84.027 Mental Health Allocation Plan, Part B, Sec 611 $69,429
84.425 Covid-19 Elementary and Secondary School Emergency Relief III (esser Iii) Fund: Learning Loss $67,634
84.010 School Improvement Funding for Leas $67,590
10.555 Local Food for Schools $52,298
84.010 Title I, Part A, Basic Grants Low Income and Neglected $51,361
10.558 Cash in Lieu of Commodities $43,681
84.365 Title Iii, English Learner Student Program $38,459
84.424 Title Iv, Part A, Student Support and Academic Enrichment $10,000
84.367 Title Ii, Part A, Supporting Effective Instruction $4,498