CRITERIA Federal regulations (7 CFR 225.15(d)) state (1) each sponsor shall hold Program training sessions for its administrative and site personnel and shall allow no site to operate until personnel have attended at least one of these training sessions. Each site shall have present at each meal service at least one person who has received this training. (2) Sponsors shall visit each of their sites at least once during the first week of operation under the Program and shall promptly take such actions as are necessary to correct any deficiencies. (3) Sponsors shall review food service operations at each site at least once during the first four weeks of Program operations, and thereafter shall maintain a reasonable level of site monitoring. Sponsors shall complete a monitoring form developed by the State agency during the conduct of these reviews. The United States Department of Agriculture, Food and Nutrition Service, The Summer Food Service Program, 2016 Administration Guide, Chapter 7, Staff Duties and Training, states ?It is critical that site personnel and monitors understand the importance of accurate point of service meal counts. Only complete meals served to eligible children can be claimed for reimbursement. Therefore, meals must be counted at the actual point of service, i.e., meals are counted as they are served, to ensure that an accurate count of meals served is obtained and reported. Counting meals at the point of service also allows site personnel to ensure that only complete meals are served.? Also, Chapter 10, Recordkeeping, states sponsors must be able to document that they have met their monitoring requirements. Monitors must submit a report for pre-operational site visits, site visits during the first week of program operations, and site visits throughout the summer. Chicago Park District?s (the District) Summer Food Program 2018 Monitor?s Orientation Handbook (Handbook) requires monitors checking site operations to make sure that the site maintains adequate records and that the program is operating in accordance with the requirement. To comply with this requirement, the District utilizes a monitoring checklist that is attached to each site file. The checklist requires documentation of ISBE approved application, ISBE participation detail, the District application, field trip data, authorized signature form, authorized signature form, training sign-in sheets, certificate of training, park enrollment roster and site responsibilities. Per the District?s Summer Food Program Management manual, the District replaced a series of paper forms with two online forms: Summer Food Weekly Summary and Summer Food Program Daily Timesheets. However, two paper documents will continue to exist, the daily receipts and the state mandated Daily Meal Count Form. 2 CFR Part 200, Subpart D ? Post Federal Awards Requirements, Section 200.303 Internal controls states ?The non-Federal entity must: (a) 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. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (b) Comply with Federal statutes, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity's compliance with statutes, regulations and the terms and conditions of Federal awards. CONDITION During the current audit period, the District was unable to fully implement its corrective action plan, which included maintaining adequate controls over required monitoring and meal count forms to ensure forms were properly completed and approved by authorized personnel. Also, the District did not adequately document its compliance with the special tests and provisions requirements of the Summer Food Service Program for Children (SFSP). QUESTIONED COSTS None. CONTEXT During our testing of monitoring at twenty-five (25) sites (total sites operated under the program during 2022 was 196 sites), we noted the following: ? One (1) site (4%) file was missing the required training certificate or training sign-in sheet of the Camp Director. ? For two (2) sites (8%), the site monitoring review was not conducted within the first four weeks of program operations, as required. ? For five (5) sites (20%), a site visit was not conducted at least once during the first week of operation. Also, for one of these 5 sites, the pre-operational site visit was not conducted. For the twenty-five (25) sites sampled, we tested a total of ten (10) days (7/11, 7/12, 7/13, 7/14, 7/15, 7/18, 7/19, 7/20, 7/21, and 7/22) from a population of 37 days (calculated based on # of days meals were claimed for reimbursements during the program) to verify that the delivery ticket, daily meal count form, and the Summer Food Weekly Summary form were properly completed and reviewed by authorized personnel. We noted the following: ? For seven (7) sites (28%), the delivery receipt form was either not signed or was signed by personnel not included on the authorized signature form and who did not receive training. ? For four (4) sites (16%), the daily meal count form and/or the Summer Food Weekly Summer form was either not signed or was signed by personnel not included on the authorized signature form and who did not receive training ? Eight (8) sites (32%) were missing one or more of the required forms (daily meal count forms and/or delivery tickets). For 6 of 8 sites, the missing daily meal count forms resulted in reimbursement of $8,031. ? One (1) site (4%) over-claimed the number of meals served by $22. The site over-claimed 4 lunches and 4 snacks served as part of its monthly claim reimbursement. These amounts did not agree with the number of meals reported on the daily meal count forms. ? For seven (7) sites (28%), the meals served times as reported on the Summer Food Weekly Summary form were not served within the approved meal times reported on the ISBE application participation detail form. IDENTIFICATION OF REPEATED FINDING Repeated (Prior Finding No. 2021-001, 2020-001, 2019-001, 2018-001, 2017-001, 2016-001, 2015-002, 2014-002, 2013-001, and 2012-1). EFFECT Failure to maintain supporting documentation of the required monitoring and meal count forms and to ensure the forms are properly completed and approved by authorized personnel is a violation of the program?s requirements and impairs the District?s ability to adequately monitor the Federally funded program. This could also result in questioned and disallowed costs which the District may need to reimburse to its grantor agency. CAUSE Per discussions with management, the Summer Food Service Program was administered across 195 sites on a daily basis over the course of the summer months. Specifically, in 2022, the program and the corrective actions planned were interrupted and significantly impacted by the transition to the new Software. RECOMMENDATION We recommend the District continue to implement internal controls to improve compliance with Federal regulations over the SFSP. In addition, we recommend the District ensure adequate staff resources and training are in place to ensure accurate reporting of all meals served, as well as, all required forms are completed and signed by authorized personnel. Specifically, we recommend that the District consider adding another level of review/oversight to the monitoring process, which may include Park Supervisors and/or Area Managers being responsible for the accuracy of the required forms.