West Deptford Township Board of Education

Finding No. 2023-002 Information on the Federal Program U.S. Department of Agriculture – Child Nutrition Cluster (Federal Award Year 7/1/22 to 6/30/23): School Breakfast Program (Assistance Listing Number 10.553) (FAIN – 231NJ304N1199) National School Lunch Program (Assistance Listing Number 10.555) (FAIN – 231NJ304N1199) National School Lunch Program - Food Distribution Program (Assistance Listing Number 10.555) (FAIN – 231NJ304N1199) National School Lunch Program - Supply Chain Assistance Funding (Assistance Listing Number 10.555) (FAIN – 221NJ344N8903) Criteria or Specific Requirement CFR Section 210.14 Resource Management (b) Net cash resources. The school food authority shall limit its net cash resources to an amount that does not exceed 3 months average expenditures for its nonprofit school food service or such other amount may be approved by the State agency in accordance with CFR Section 210.19(a). Condition The School District’s Food Service Fund Net Cash Resources exceeded its three months average expenditures by $696,886.34. Questioned Costs None. Context While performing the calculation to determine if the Food Service program is running at a nonprofit status, it was determined that the net cash resources totaled $1,095,097.70 at June 30, 2023 which exceeded the three months average expenditures of $398,211.36 calculated using the sample Net Cash Resources Schedule in the format provided by the U.S.D.A. Effect or Potential Effect The School District is not in compliance with CFR section 210.14 and requirements as prescribed the Office of School Finance, Department of Education, State of New Jersey Audit Program. Cause The School District did not monitor the finances of its Food Service Fund to ensure its Net Cash Resources at the end of the fiscal year did not exceed the Fund’s three months average expenditures. Identification as a Repeat Finding The condition existed in the immediately preceding fiscal year – see Finding No. 2022-001. Recommendation The School District monitor the finances of its Food Service Fund and create a plan to reduce the net cash resources below its three month average expenditures. View of Responsible Officials and Planned Corrective Action The responsible officials agree with the finding and will address the matter as part of their corrective action plan.

Method of Implementation - The Food Service Director shall maintain a listing of necessary food service operational enhancements and capital expenditures. By April of each year, the Food Service Director will review cash and expenditures for prior months. If cash is expected to accumulate in excess of 3 months average expenditures, the Food Service Director will begin to purchase items for the Food Service operation contained on the list referenced above. A plan is in place for expending the funds but it is in the review process. The SBA has also began budgeting percentages of different salaries in the cafeteria budget (custodial, accountant, etc). Person Responsible for Implementation - Food Service Director & School Business Administrator. Implementation Date - 6/30/2024

2022-001

Finding No. 2023-004 Information on the Federal Program U.S. Department of Agriculture – Child Nutrition Cluster (Federal Award Year 7/1/22 to 6/30/23): School Breakfast Program (Assistance Listing Number 10.553) (FAIN – 231NJ304N1199) National School Lunch Program (Assistance Listing Number 10.555) (FAIN – 231NJ304N1199) National School Lunch Program - Food Distribution Program (Assistance Listing Number 10.555) (FAIN – 231NJ304N1199) National School Lunch Program - Supply Chain Assistance Funding (Assistance Listing Number 10.555) (FAIN – 221NJ344N8903) Criteria or Specific Requirement For School Breakfast Program and National School Lunch Program, children belonging to households meeting nationwide income eligibility requirements may receive meals at no charge or at reduced price. Children who have been determined ineligible for free or reduced price school meals pay the full price for their meals. A child’s eligibility for free or reduced price meals may be established by the submission of an annual application or statement which furnishes such information as family income and family size. Annual eligibility determinations may also be based on the child’s household receiving benefits under other federal assistance programs, this process is referred to as Direct Certification. Condition Several students reported as “low income” and receiving free or reduced price meals lacked appropriate qualifying documentation (Free and Reduced Lunch Application or Direct Certification). Questioned Costs None. Context The procedures over Child Nutrition Cluster Eligibility were performed in conjunction with the Application for State School Aid. The population of resident low income students includes 600 free students and 127 reduced students; our sample for the low income test included 189 free students and 46 reduced students. During the test of low income, we noted the following: (a) 16 free students did not have valid lunch applications or direct certification to support their eligibility determination; (b) Based on income reported on the lunch applications, 4 free students should have been categorized as reduced; and 2 free students and 2 reduced students should have been categorized as paid. The sample was not statistically valid. Effect or Potential Effect The School District receives cash assistance by claiming meals served to eligible children for reimbursement. The School District may have received reimbursement for meals served to ineligible children. Cause The School District did not have procedures in place to ensure eligibility determination is always supported by qualifying documentation. Identification as a Repeat Finding Not applicable. Recommendation The School District develop and implement procedures to ensure all eligibility determinations are supported by qualifying documentation (Free and Reduced Lunch Application or Direct Certification). View of Responsible Officials and Planned Corrective Action The responsible officials agree with the finding and will address the matter as part of their corrective action plan.

Method of Implementation - The School District shall obtain and provide necessary training to personnel regarding A.S.S.A. reporting guidelines and low income eligibility guidelines; the School District shall ensure student lunch statuses are documented appropriately throughout the District's online databases {PowerSchool, PaySchools, IEP Direct, etc.). Responsible for Implementation - Food Service Director, School Accountant & School Business Administrator. Implementation Date - Immediate

Information on the Federal Program U.S. Department of Treasury ? Coronavirus State and Local Fiscal Recovery Fund (SLFRF) (Assistance Listing Number 21.027) (FAIN ? SLFRFDOE1SES) -7/1/21 ? 6/30/22 Passed through N.J. Department of Education as Additional or Compensatory Special Education and Related Services (ACSERS) Criteria or Specific Requirement P.L. 2021, c.109 requires School Districts to offer up to one year of additional or compensatory special education and related services to students with disabilities if a determination is made by the student?s Individualized Education Program (IEP) team that the student requires such services. The N.J. Department of Education (NJDOE) will reimburse School Districts for services provided through the American Rescue Plan State Fiscal Recovery Fund. School Districts submit application in December 2021 estimating the total costs to be incurred in the 2021-2022 school year, and submit a final application before July 2022 with adjustments to the initial costs estimates, as needed. Condition The School District did not make adjustments to initial costs estimates for ACSERS; therefore, the School District was reimbursed more costs than actually incurred by the funding agency. Questioned Costs Known or likely questioned costs are not greater than the reporting threshold. Context The population and sample for ACSERS expenditures include tuition costs, instructional aid costs, and transportation costs for two students who exceeded the age of eligibility in 2021-2022 school year attending an approved private school for students with disabilities. During the test, we noted the following: (1) the School District overclaimed and was over-reimbursed instructional aid costs than incurred for one student; and (2) the School District overclaimed and was over-reimbursed transportation costs than incurred for both students. Effect or Potential Effect Unallowable costs were reported to and reimbursed by the funding agency. Cause Final application did not reflect adjustments to the initial costs estimates. Identification as a Repeat Finding Not applicable. Recommendation The School District develop and implement internal control procedures to ensure only allowable costs are reported to grantor agency when seeking reimbursements. View of Responsible Officials and Planned Corrective Action The responsible officials agree with the finding and will address the matter as part of their corrective action plan.

Finding No. 2022-003 Information on the Federal Program U.S. Department of Treasury ? Coronavirus State and Local Fiscal Recovery Fund (SLFRF) (Assistance Listing Number 21.027) (FAIN ? SLFRFDOE1SES) -7/1/21 ? 6/30/22 Passed through N.J. Department of Education as Additional or Compensatory Special Education and Related Services (ACSERS) Condition - The School District did not make adjustments to the initial cost estimates for ACSERS; therefore, the School District was reimbursed more costs than were actually incurred. Recommendation - The School District develop and implement internal control procedures to ensure only allowable costs are reported to grantor agency when seeking reimbursements. Method of Implementation - The School District shall allow an internal control procedure that completes a verification of a report prior to submission. This will allow a third party verification of the submitted report. Person Responsible - Child Study Team Director / School Business Administrator. Planned Date of Completion - Immediate. See Corrective Action Plan for full chart/table

Finding No. 2021-001 Information on the Federal Program U.S. Department of Agriculture ? Child Nutrition Cluster (Federal Award Year 7/1/20 to 6/30/21): School Breakfast Program (Assistance Listing Number 10.553) (FAIN ? 211NJ304N1099) National School Lunch Program (Assistance Listing Number 10.555) (FAIN ? 211NJ304N1099) National School Lunch Program - Food Distribution Program (Assistance Listing Number 10.555) (FAIN ? 211NJ304N1099) National School Lunch Program ? Emergency Operational Cost Program ? Schools (Assistance Listing Number 10.555) (FAIN ? 202121H170341) Criteria or Specific Requirement CFR Section 210.14 Resource Management (b) Net cash resources. The school food authority shall limit its net cash resources to an amount that does not exceed 3 months average expenditures for its nonprofit school food service or such other amount may be approved by the State agency in accordance with CFR Section 210.19(a). Condition The School District?s Food Service Fund Net Cash Resources exceeded its three months average expenditures by $62,912.89. Questioned Costs None. Context While performing the calculation to determine if the Food Service program is running at a nonprofit status, it was determined that the net cash resources totaled $341,235.25 at June 30, 2021 which exceeded the three months average expenditures of $278,322.36 calculated using the sample Net Cash Resources Schedule in the format provided by the U.S.D.A. Effect or Potential Effect The School District is not in compliance with CFR section 210.14 and requirements as prescribed the Office of School Finance, Department of Education, State of New Jersey Audit Program. Cause The School District did not monitor the finances of its Food Service Fund to ensure its Net Cash Resources at the end of the fiscal year did not exceed the Fund?s three months average expenditures.

The Food Service Director shall maintain a listing of necessary food service operational enhancements and capital expenditures. By April of each year, the Food Service Director will review cash and expenditures for prior months. If cash is expected to accumulate in excess of 3 months average expenditures, the Food Service Director will begin to purchase items for the Food Service operation contained on the list referenced above. Person responsible - Food Service Director. Planned Date of Completion - June 30, 2022