Ravena-Coeymans-Selkirk Central School DistrictLocal Government

Child Nutrition Cluster - Eligibility Information on Federal Program: U.S Department of Agriculture, passed through the New York State Education Department, Child Nutrition Cluster, CFDA No. 10.553 and 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))). Statement of Condition: During our testing we noted one application for free or reduced meals that was calculated incorrectly. The District determined the household was ineligible to receive reduced price meals, however, based on the income eligibility guidelines, the household was eligible for reduced price meals. Statement of Cause: The District used the incorrect eligibility guidelines in determining eligibility for the household. Statement of Effect: The District did not provide reduced priced meals to the eligible household. Questioned Costs: None. Perspective Information: One out of one-hundred seven applications tested was incorrectly denied. All applications for free and reduced priced meals, other than those directly certified, were tested. 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 the Responsible Officials and Planned Corrective Actions:

IDEA Cluster - Procurement Information on Federal Program: Special Education Cluster ? Grants to States, CFDA No. 84.027 and 84.173 Criteria: CFR Section 200.318 stipulates that a non-Federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in Part 200 Subpart D. Additionally, 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. Condition: During our discussions with management and testing of the major program, we noted that the District?s procurement policy is not in compliance with the Uniform Guidance. Additionally, the District is not verifying the eligibility of vendors to participate in Federal assistance programs. Questioned Cost: None. Context: As part of testing of compliance over procurement, the District?s purchasing policy was reviewed and selection of vendors charged to the major program was selected for testing of compliance.Cause: The District did not review compliance requirements related to procurement outlined in 2 CFR Section 200.318 and Section 200.213. Effect: The District is not in compliance with 2 CFR Section 200.318 and 2 CFR Section 200.213. The District?s purchasing policy does not contain the required elements. 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 or the District could be overpaying for goods and services. Perspective Information: Of the District?s vendors charged to the program, 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 Sections 200.318 and 200.213 and update the District?s procurement policy 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. Views of the Responsible Officials and Planned Corrective Actions: The District is currently working on updating the current Procurement Policies. Simultaneously the District is working on a purchasing procedure document to share with everyone that plays a role in the procurement process. Solid guidelines around purchasing will ensure the Districts compliance with all regulatory requirements.

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