Windber Area School DistrictLocal Government

CONDITION: The District failed to complete the verification process in accordance with compliance requirements. While the District reported utilizing the Standard (3% Error Prone) sampling method, the sample verified did not represent error prone applications. Further, the District?s records were not subsequently updated to reflect the changes that resulted from the verification process performed. CRITERIA: In accordance with the Uniform Grant Guidance, United States Department of Agriculture, Child Nutrition Cluster, Part III, Section N., ?Special Tests and Provisions? regarding Verification of Free and Reduced Price Application, the Standard (3% ?error prone?) sampling method defines ?error prone? as an application in which the household income reported is within $100 monthly or $1,200 annually of the income eligibility guidelines for free and reduced price meals. The guidance further requires that timely changes are made to students? eligibility status based on documentation and other information obtained through the verification process. CAUSE: District management does not have a review process in place to ensure accuracy in completion of the verification process, or follow-up procedures to ensure subsequent changes are made to eligibility status based on verification records. EFFECT: The effect of this deficiency was noncompliance with the Child Nutrition Cluster requirements regarding the verification process. Further, the failure to ensure a status change from free to reduced for one of the applications selected resulted in the District undercharging three students for meals, as well as error in subsidy received. QUESTIONED COSTS: None over reportable threshold of $25,000. PROPER PERSPECTIVE (SAMPLING): The District?s verification procedures required selection of 3% of approved applications for verification of household income, which resulted in two applications selected for verification by the District. 100% of these applications were tested for compliance. Although the District failed to select ?error-prone? applications and did not update their records with the results of the verification process, no other applications were available to expand testing. The audit sample was statistically valid. REPEAT FINDING: Yes. RECOMMENDATION: We recommend that management review the results of the verification process each year to ensure accuracy in the process, as well as the resulting eligibility status changes, if any. Additionally, personnel responsible for the verification process should pursue training on proper reporting within the PrimeroEdge system. MANAGEMENT RESPONSE: Management agrees with the recommendations. Management will perform a review of the verification procedures and results, including eligibility status changes, in the future to ensure accuracy. Further, essential personnel will obtain training on the PrimeroEdge system and the verification process, as necessary. Additionally, it should be noted that although the results of the verification process indicated a change in status for one of the applications from free to reduced, and PrimeroEdge was not updated to reflect the change, the family submitted a subsequent application documenting their status as free in January 2020.

CONDITION: The District?s internal control over compliance failed to prevent errors in the annual verification process (see Compliance Finding #2020-002). CRITERIA: Internal controls over federal programs are to be sufficient to ensure compliance with the Child Nutrition Cluster grant requirements, including properly performed verification procedures as discussed in Compliance Finding #2020-002. CAUSE: The internal control deficiency over the verification process resulted from a lack of oversight by management. EFFECT: The effect of this deficiency in internal controls over federal programs was the District?s failure to comply with the Special Tests and Provisions requirements of the Child Nutrition Cluster pertaining to the verification process. RECOMMENDATION: We recommend that District personnel responsible for completion of the verification process obtain additional education and training on the compliance requirements. We further recommend the implementation of a review process by management to ensure accuracy in the verification procedures. MANAGEMENT RESPONSE: Management agrees with the recommendation. Additional education and training will be obtained by District personnel on the verification process. Management will implement a review process to ensure compliance with verification requirements.

CONDITION: The District failed to accurately perform the verification process. CRITERIA: In accordance with the Uniform Grant Guidance, United States Department of Agriculture, Child Nutrition Cluster, Part III, Section N., ?Special Tests and Provisions? regarding Verification of Free and Reduced Price Application, the Pennsylvania Department of Education requires local education agencies (LEAs) to verify the current free and reduced price eligibility of households selected from a sample of applications approved for free and reduced price meals. CAUSE: While District personnel obtained the household income support from the families selected for verification, the support was not examined in order to verify eligibility for the free/reduced program. Moreover, management did not have a review process in place to ensure accuracy in completion of the verification process. EFFECT: The effect of this deficiency was noncompliance with the Child Nutrition Cluster requirements regarding the verification of free and reduced applications. Further, had the household income support been examined, it would have resulted in a change in eligibility status for one of two families selected. QUESTIONED COSTS: None over reportable threshold of $25,000. PROPER PERSPECTIVE (SAMPLING): The District?s verification procedures required selection of 3% of approved applications for verification of household income, which resulted in two applications selected for verification by the District. 100% of these applications were tested for compliance. Although the District failed to identify the reduction in income reported for verification, and the resulting change in student status on one of the two applications, no other applications were available to expand testing. The audit sample was statistically valid. REPEAT FINDING: Yes. RECOMMENDATION: We recommend that management review the results of the verification process each year to ensure accuracy in the process, as well as the resulting eligibility status changes, if any. Additionally, personnel responsible for the verification process should pursue training on proper reporting within the PrimeroEdge system. MANAGEMENT RESPONSE: Management agrees with the recommendation. Management will perform a review of the verification procedures and results, including eligibility status changes, in the future to ensure accuracy. Further, essential personnel will obtain training on the PrimeroEdge system, as necessary.

CONDITION: The District?s internal control over compliance failed to prevent errors in the annual verification process (see Compliance Finding #2019-002). CRITERIA: Internal controls over federal programs are to be sufficient to ensure compliance with the Child Nutrition Cluster grant requirements, including properly performed verification procedures as discussed in Compliance Finding #2019-002. CAUSE: The internal control deficiency over the verification process resulted from a lack of oversight by management. EFFECT: The effect of this deficiency in internal controls over federal programs was the District?s failure to comply with the Special Tests and Provisions requirements of the Child Nutrition Cluster pertaining to the verification process. RECOMMENDATION: We recommend that District personnel responsible for completion of the verification process obtain additional education and training on the compliance requirements. We further recommend the implementation of a review process by management to ensure accuracy in the verification procedures. MANAGEMENT RESPONSE: Management agrees with the recommendation. Additional education and training will be obtained by District personnel on the verification process. Management will implement a review process to ensure compliance with verification requirements.

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