Rochester Prep Charter Schools

AL 84.425D – American Rescue Plan – Elementary and Secondary School Emergency Relief, Award Number 5891 Criteria: Requirements per part 4 section 20.001 of the Uniform Guidance state that all laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL). Condition: Management had not established an adequate system of internal control over compliance with the Special Tests and Provisions related to Wage Rate Requirements under the Elementary and Secondary School Emergency Relief Fund. Cause: Management did not have adequate internal controls in place to identify and comply with Wage Rate Requirements established under part 4 section 84.425 of the Uniform Guidance. Effect or Potential Effect: Without appropriate internal controls over compliance, non-compliance could occur which the entity may not identify. Laborers and mechanics employed by contractors and subcontractors may not have been paid in accordance with local prevailing wage rates. We were not able to determine if the entity was in compliance with this compliance requirement as appropriate documentation was not requested from the applicable contractor. Questioned Costs: N/A Repeat Finding?: No Recommendation: Management should implement internal controls over Wage Rate Requirements to ensure compliance with applicable Federal statutes, regulations, and terms and conditions of the awards received. Responsible Official’s Response: In this particular finding, the decision was made to undertake a project using organizational reserves. Subsequent to the project taking place additional review indicated it would qualify as permissible under the American Rescue Plan and Federal Funding could potentially cover the project costs. The contract for the work, however, was not further reviewed at the time. After subsequent review, it appears that the contract may not meet the standards for Federal Funding, Management, therefore, has removed the Federal funding revenue from it’s financial statements and has not requested funding for this project under the American Rescue Plan. As a regular course of business, the organization does require any contracts subject to Federal funding requirements meet Federal Funding requirements, including those requirements associated with prevailing wages. Going forward, a comprehensive contract review will be performed for any project retroactively deemed a potentially permissible use of Federal funds Auditor’s Evaluation of the Responsible Official’s Response: Management’s response is appropriate to address the finding. If properly implemented, management’s response would include procedures to prevent reoccurrence in the future.

Responsible Official’s Response: In this particular finding, the decision was made to undertake a project using organizational reserves. Subsequent to the project taking place additional review indicated it would qualify as permissible under the American Rescue Plan and Federal Funding could potentially cover the project costs. The contract for the work, however, was not further reviewed at the time. After subsequent review, it appears that the contract may not meet the standards for Federal Funding, Management, therefore, has removed the Federal funding revenue from it’s financial statements and has not requested funding for this project under the American Rescue Plan. As a regular course of business, the organization does require any contracts subject to Federal funding requirements meet Federal Funding requirements, including those requirements associated with prevailing wages. Going forward, a comprehensive contract review will be performed for any project retroactively deemed a potentially permissible use of Federal funds

Criteria: In accordance with 7 CFR 210.8, the Charter School is required to establish internal controls which ensures the accuracy of meal counts prior to the submission of the monthly reimbursement claims. Condition and Context: Internal controls over compliance are not designed and implemented in a manner which ensures accurate reporting of meals served. The months of November 2021 and February 2022 were selected for testing the underlying support for meals served compared to the meals submitted for reimbursement. In both of these months there were discrepancies in the various categories, Breakfast, Lunch and Snack, compared to what the Charter School submitted for reimbursement. The error rates approached five percent for some of these categories. Further, for the months of November 2021 and February 2022 the Charter School submitted for reimbursement less meals than their records supported, the net difference was less than $6,000. Cause: Due to turnover in the Charter School?s operational staffing, the procedures became decentralized leading to errors in the accumulation phase of the count records. Effect or Potential Effect: Errors were made in claiming process and went undetected by the Charter School. Recommendation: The Charter School needs to examine their current processes and make the necessary adjustments to become in compliance with 7 CFR 210.8. They should also ensure that this supporting documentation is maintained for a period of three years following the final submission for reimbursement for each fiscal year as required by 7 CFR 210.23(c). Properly designed and implemented procedures will ensure that the Charter School remains in compliance with program requirements and is appropriately reimbursed.

Responsible Official?s Response: Rochester Prep is implementing procedures to ensure accurate and timely submission of federal nutrition claims. Specifically: To ensure claims for reimbursement are accurately consolidated, the Charter School will evaluate their point of service accountability system and implement appropriate changes. The Charter School will also conduct edit checks to ensure accountability. Effective July 20, 2022, the school implemented a Meal Counting and Claiming Implementation Plan with the purpose of submitting accurate meal claims to the state and federal child nutrition programs. This implementation plan seeks to eliminate discrepancies between meal counting at the homeroom level, reporting at the school level, and claiming at the state and federal levels.

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