Bethlehem Central School District

Child Nutrition Cluster - Procurement Information on Federal Program: U.S. Department of Agriculture Child Nutrition Cluster (National School Breakfast Program, School Lunch Program, School Lunch Program Supply Chain- COVID 19 Assistance Listing numbers 10.553 and 10.555) passed through the New York State Education Department. Criteria: 2 CFR Section 200.213 stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal Assistance programs or activities. Statement of Condition: During our discussions with management, we noted that the District is not verifying the eligibility of vendors to participate in Federal assistance programs on an annual basis. Statement of Cause: The District did not review compliance requirements related to procurement outlined in 2 CFR Section 200.213. Statement of Effect: The District is not in compliance with 2 CFR Section 200.213. The District is not performing required procedures, as a result, vendors that are not eligible for participation in Federal assistance programs or activities could be selected. Questioned Costs: None Perspective Information: As a result of inquiry, the District performed a review of the District’s vendors charged to the fund, and none were suspended or debarred from participation in Federal assistance programs or activities. Repeat Finding: No Recommendation: We recommend that the District review the requirements of 2 CFR Section 200.213 and ensure that a review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to disbursing funds to the vendor. This should be verified on an annual basis. Views of the Responsible Officials and Planned Corrective Actions: The Bethlehem Central School District appreciates the requirements of 2 CFR Section 200.213. The District's recent review of vendors indicated that there weren't any instances of ineligibility for participation in Federal assistance programs. To ensure formalized compliance, the District is updating procurement procedures which will highlight that the Purchasing Agent will check the SAMS Debarment and Suspension website on an annual basis. Results from this annual check will be logged and shared with both the Treasurer and Chief Business and Financial Officer and will be available for access by auditors or the public. Ineligible vendors, as noted on the SAMS website, will be removed from the District's financial management system. Implementation Date - Effective immediately.

Emergency Connectivity Fund Program - Procurement, Suspension and Debarment Information on Federal Program: Federal Communications Commission Emergency Connectivity Fund Program Assistance Listing No. 32.009. Criteria: 2 CFR Section 200.213 stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Statement of Condition: During our discussions with management and testing of the major program, we noted that the District is not verifying the eligibility of vendors to participate in this specific Federal assistance programs. Statement of Cause: The District did not review compliance requirements related to procurement outlined in 2 CFR Section 200.213 for this major program.Statement of Effect: The District is not in compliance with 2 CFR Section 200.213. The District is not performing required procedures, as a result, vendors that are not eligible for participation in Federal assistance programs or activities could be selected. Questioned Cost: None. Perspective Information: As part of testing of compliance over procurement, a selection of vendors charged to the major program was selected for testing of compliance. Of the District?s vendors charged to the major program that were selected for testing, none were suspended or debarred from participation in Federal assistance programs or activities. Repeat Finding: No Recommendation: We recommend that the District review the requirements of 2 CFR Section 200.213 and ensure that a review of the eligibility of potential vendors to participate in all Federal assistance programs or activities is performed prior to disbursing federal funds to the vendor. Views of the Responsible Officials and Planned Corrective Actions: Effective immediately, the District is implementing the following: ? The Procurement Specialist in the Technology Department (Maura O?Brien) will check the SAMS Debarment and Suspension website quarterly. ? The data obtained from the quarterly check will be logged into a Google Sheet that is shared with Erin Sheevers, the Chief Technology Officer. ? Any ineligible vendor information will be shared with the Accountant (Steven Terry) in the Business Office. Implementation Date: October 14, 2022.

Special Education Cluster- Procurement, Suspension and Debarment Information on Federal Program: U.S. Department of Education Special Education Cluster ? Grants to States, CFDA No. 84.027 and 84.173 passed through the New York State Education Department. Criteria: 2 CFR Section 200.213 stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Statement of Condition: During our discussions with management and testing of the major program, we noted that the District is not verifying the eligibility of vendors to participate in Federal assistance programs. Statement of Cause: The District did not review compliance requirements related to procurement outlined in 2 CFR Section 200.213. Statement of Effect: The District is not in compliance with 2 CFR Section 200.213. The District is not performing required procedures, as a result, vendors that are not eligible for participation in Federal assistance programs or activities could be selected. Questioned Cost: None. Perspective Information: As part of testing of compliance over procurement, a selection of vendors charged to the major program was selected for testing of compliance. Of the District?s vendors charged to the major program that were selected for testing, none were suspended or debarred from participation in Federal assistance programs or activities. Repeat Finding: No Recommendation: We recommend that the District review the requirements of 2 CFR Section 200.213 and ensure that a review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to disbursing federal funds to the vendor. Views of the Responsible Officials and Planned Corrective Actions: The Special Education and Student Services (SESS)Department has implemented the following procedures: The SESS annual consultant agreement has been revised to include a clause regarding debarment; the SESS office Secretary I will check the SAMS Disbarment and Suspension website quarterly; data from the quarterly check will be logged into a Google Sheet that is shared with the SESS Director and Assistant Director of SESS; any ineligible vendor information will be shared with the Business Office.

2019-002 Administrative Prerogative Information on Federal Program: National School Lunch Programs and School Breakfast Program CFDA No. 10.553 and CFDA No. 10.555. Criteria: According to the 2018-19 NYSED Free and Reduced Price Income Eligibility and Policy Information, in certain circumstances when households fail to apply for free or reduced price meals, the nutritional needs of students who are obviously at an economic disadvantage may be addressed by local officials. Using administrative prerogative, local officials may complete an application for a student known to be eligible if the household had applied. To exercise this option properly, an application must be completed on behalf of the student, based on the best family size and income information available. The source of this information must be noted on the application. Documented prior efforts must be made by the District to obtain a completed application from the parent or guardian. This option must be used judiciously and only after repeated efforts to obtain applications from families have been unsuccessful. Condition: During our testing we noted one application for free meals was completed by the building Principal under administrative prerogative. However, income information, and attempts to obtain income information for the family for which the application was completed was not documented. Therefore, we were unable to determine if the free meals provided were appropriate. Questioned Costs: We were unable to determine an amount based on missing income information on the application. Context: A sample of 41 students receiving free or reduced price meals was selected for testing. Upon further review those 41 students represented the entire population of families receiving free or reduced price meals through submission of applications to the District. Any other students receiving free or reduced price meals were automatically eligible and directly certified through the county. Our sample therefore represented the complete population of applicants. Effect: We are unable to confirm if the determination of free meals was appropriate. Cause: Policies and procedures were not adhered to in regards to documentation of family income as documentation was not maintained to support decision. Perspective Information: Based on testing of the complete population there was only one application completed under administrative prerogative. Repeat Finding: No Recommendation: We recommend that the policies and procedures in place in regards to administrative prerogative be documented and attached to the eligibility application, and include the total household members, income information, manor and attempts made with the family to obtain this information. We recommend that the District put a procedure in place to document and review applications completed under Administrative Prerogative. Views of Responsible Officials and Planned Corrective Actions: The District will document all attempts to communicate with families and to assist them with applying for free or reduced priced meals at schools. If administrative prerogative is to be used, we will, to the best of our ability, determine the household size and income for the student(s) for which we are attempting to utilize administrative prerogative.

2019-003 Eligibility Information on Federal Program: National School Lunch Programs and School Breakfast Program CFDA No. 10.553 and CFDA No. 10.555. Criteria: A child?s eligibility for free or reduced price meals under a Child Nutrition Cluster program may be established by the submission of an annual application or statement which furnishes such information as family income and family size. Local educational agencies (LEAs), institutions, and sponsors determine eligibility by comparing the data reported by the child?s household to published income eligibility guidelines. In addition to publishing income eligibility information in the Federal Register, the Food and Nutrition Service agency of the United State Department of Agriculture (FNS) makes it available on the FNS website at http://www.fns.usda.gov/schoolmeals/income-eligibility-guidelines. Children from households with incomes at or below 130 percent of the Federal poverty level are eligible to receive meals or milk free under the School Nutrition Programs. Children from households with incomes above 130 percent but at or below 185 percent of Federal poverty level are eligible to receive reduced price meals. Persons from households with incomes exceeding 185 percent of the poverty level pay the full price (7 CFR section 245.2, 245.3, and 245.6; section 9(b)(1) of the NSLA (42 USC 1758 (b)(1)); sections 3(a)(6) and 4(e) of the CNA (42 USC 1772 (a)(6) and 1773(e))). Condition: During our testing we noted one application for free meals was calculated incorrectly. The District determined the household was eligible to receive free meals, however, based on the income eligibility guidelines, the household was eligible for reduced price meals. Questioned Costs: The District received an estimated $133 in federal and state revenue that had the household been properly classified as reduced price they would not have been eligible to receive. In addition, the District lost approximately $135 in general sale of meals revenue in the school lunch fund as the students in this household were not charged the reduced price meal fee. This estimate assumed all 3 students received free lunches for all 180 days of the school year. Context: A sample of 41 students receiving free or reduced price meals was selected for testing. Upon further review those 41 students represented the entire population of families receiving free or reduced price meals through submission of applications to the District. Any other students receiving free or reduced price meals were automatically eligible and directly certified through the county. Our sample therefore represented the complete population of applicants. Effect: The District received more in state and federal funding then they were eligible for. Cause: The District?s school lunch software automatically calculates the eligibility of each household based on the data input into the software. The number of household members was incorrectly input into the software causing the incorrect determination of eligibility for that household. While there is a review of the application received, there is no review of the input into the software and the individual who reviews the application is the same individual who inputs the information into the software. Perspective Information: Based on testing of the complete population there was only one application that was incorrectly calculated out of the population. Repeat Finding: No Recommendation: We recommend that the District implement a procedure to compare the free and reduced price applications to the input of the information into the software to ensure they are in agreement. This review should be documented and performed by someone without responsibility for eligibility determination under this program. Views of Responsible Officials and Planned Corrective Actions: The food service director will perform the verification of the data submitted on free and reduced priced program applications.

GSA_MIGRATION

GSA_MIGRATION