THE VILLAGE YOUTH SERVICES, INC.

Type of Finding: Deficiency Compliance Requirement: Cash Management FINDING (2019-001): INADEQUATE DOCUMENTATION FOR MEALS CLAIMED FOR REIMBURSEMENT CRITERIA: 7 CFR ?225.15 (C) provides that sponsors ?shall maintain accurate records justifying all meals claimed and documenting that all Program funds were spent on allowable Child Nutrition Program costs. Failure to maintain such records may be grounds for denial of reimbursement for meals served and/or administrative costs claimed during the period covered by the records in question. Sponsor?s records shall be available at all times for inspection and audit by representatives of the Secretary, the Comptroller General of the United States and the State agency for a period of three years following the date of the submission of the final claim for reimbursement for the fiscal year.? CAUSE: The vendor failed to provide adequate information on the meals it served to certain sites. Some of the delivery receipts were missing information such as time of delivery, signature of site representatives, and missing meal components. In addition, the Organization failed to provide the Department with legible copies of the receipts for the disallowed meals purchased during the program period. As a result, the Organization failed to provide timely and necessary information to the Department for the meals it claimed for reimbursement. CONDITION: Delivery schedules and meal count sheets provided by the Organization were missing information. 13 of the 47 files tested did not have approvals and 19 sites had missing meal components. EFFECT: As per the requirements of the USDA, the sponsor is deemed responsible for obtaining relevant information about the meals and sites it caters to. Therefore, absence of necessary site information led to discrepancies in reporting meals claimed for reimbursement. QUESTIONED COSTS: $152,349.38 ? Improper payments made to the Sponsor, which should be remitted to the Department. VIEWS OF RESPONSIBLE OFFICIALS & CORRECTIVE ACTION PLAN: Management will ensure that proper documentation will be maintained. Management has plans to implement an automation system whereby various sites can input information about meals delivered into the system/software. This will ensure that all the necessary information will be accessible and will be timely updated on a systematic basis.

Type of Finding: Deficiency Compliance Requirement: Procurement Suspension and Debarment & Cash Management FINDING (2019-002): CLAIMED MEALS FOR REIMBURSEMENT THAT DID NOT MEET THE REQUIRED MEAL PATTER AT CERTAIN SITES ? INCLUDING VENDED MEALS CRITERIA: The meal requirements for the Program are designed to provide nutritious and well-balanced meals to each child. Sponsors shall ensure that meals served meet all of the requirements. Except as otherwise provided in this section, as per the tables presented in 7 CFR ?226.16(d) the minimum requirements for meals served to children in the program. Children aged 12 and above may be served larger portions based on the greater food needs of older boys and girls. CAUSE: The Vendor provided meals to certain sites that were not in quantities as per the requirements of the SFSP program. CONDITION: Out of 47 sites selected for testing, 21 sites had meals count sheets with either missing meal components or meals that were not sufficient in quantity. In addition, instances of either lunch or snack deviations were noted. Such deviations either showed a missing meal component, or a meal component replacement that was not allowed as per the terms of the contract. EFFECT: The vendor altered quantities for some of the meals that were served, and this resulted in sites unable to serve enough meals for the children. The vendor voluntarily distributed meals that were not in compliance with the meal patter of the program. This led to inaccurate submission of meal claim reimbursements. Therefore, amounts claimed for reimbursements were not correct for the amounts submitted for invoice. As a result, the Department was unable to validate the total number of meals claimed by Sponsor for reimbursement for meals served during the June 2019 for the SFSP. QUESTIONED COSTS: Indeterminable VIEWS OF RESPONSIBLE OFFICIALS & CORRECTIVE ACTION PLAN: The Organization will no longer rely on third party vendors for serving meals to various sites. The Organization will also have proper monitoring controls in place to ensure that meals are served as per the required meal pattern and in the prescribed quantities.

Type of Finding: Deficiency Compliance Requirement: Activities Allowed or Unallowed FINDING (2019-003): SERVED MEALS OUTSIDE APPROVED TIME PERIOD CRITERIA: 7 CFR ?225.16 (C)(3) provides that ?meals served outside of the period of approved meal service shall not be eligible for Program payments.? CAUSE: The Organization had clearly communicated to site representatives on the time and manner in which the meals should be served. However, some sites voluntarily served meals outside of the approved meal time. As a result, unapproved meal serving time was documented and reported to the Department. In addition, vendors were not punctual on meal deliveries for certain sites and this caused sites to report late deliveries. CONDITION: As per program requirements, the sponsor should maintain the time requirements outlined. The delivery schedules of 25 sites tested reported late deliveries. Most of the late deliveries occurred on 06/10/2019. EFFECT: As a result of noncompliance, children were not given food on time and Children were forced to have meals from other sources. QUESTIONED COSTS: Indeterminable VIEWS OF RESPONSIBLE OFFICIALS & CORRECTIVE ACTION PLAN: The Organization will continue to keep a check on the site meal serving time. Also, the management plans on reducing the number of serve sites to maintain a strong hold in its monitoring processes. Additionally, the Organization will conduct 1st week refresher trainings to all staff at the site to ensure all program regulations are adhered to.

Type of Finding: Deficiency Compliance Requirement: Procurement, Suspension and Debarment FINDING (2019-004): FAILURE TO MAINTAIN ADEQUATE OVERSIGHT OVER VENDORS IN ACCORDANCE WITH CONTRACT SPECIFICATIONS CRITERIA: 2 CFR 200.318(b) states that ?non-Federal entities must maintain oversight to ensure that contractors perform in accordance with the terms, conditions, and specifications of their contracts or purchase orders.? CAUSE: The vendor failed to comply with the terms and conditions of the contract set by the Organization on several occasions. The Organization failed to adequately monitor the vendors. CONDITION: From the testing conducted, 19% of sites sampled were missing delivery receipts, tally sheets, incomplete delivery schedules, served inadequate portion sizes. The Vendor also failed to maintain the right health and safety standards in its food distribution for two of the sites. EFFECT: As a result of this, several issues arose where meals were not delivered on time, insufficient quantities were reported for certain meal components, signatures were not obtained, and meal components were missing. Certain meal components were returned to the vendor either due to poor taste or inadequate temperature requirements. Also, the vendor overcharged the organization for some of the lunch meals provided. QUESTIONED COSTS: Indeterminable VIEWS OF RESPONSIBLE OFFICIALS & CORRECTIVE ACTION PLAN: The Organization does not intend on continuing its contract with the vendor. The Organization has plans on starting a catering service unit to provide meals to various sites soon. Also, prior to payment of any invoices, the Organization will make sure that invoices are reviewed thoroughly to ensure contract compliance. The Organization will also ensure that from henceforth, sites will serve complete meals, have tally sheets and/or meal counting devices, meet meal patterns and follow sanitary procedures.

Type of Finding: Deficiency Compliance Requirement: Activities Allowed or Unallowed FINDING (2019-005): INSUFFICIENT MEAL COMPONENTS CRITERIA: 2 CFR 225.16(d) states that a Sponsor must ?ensure that meals served, meet all of the requirements ? minimum amounts of food components to be served for breakfast, lunch, and snacks.? CAUSE: The Sponsor had issues with its contracted vendor. The vendor failed to adhere to the program requirements and the Sponsor was unable to effectively monitor the work performed by the vendor. Although the Sponsor tried to obtain alternate caterers, it was only able to obtain one alternate caterer to assist in rectifying some of the issues with its contracted vendor. This was because of vendors resistance to work with the program due to many program constraints. CONDITION: The Organization should ensure that meals served should meet the minimum requirements for breakfast, lunch, and snacks. The meal requirements for the program are designed to provide nutritious and well-balances meals to each child. However, 19 of the 47 sites tested failed to maintain minimum amounts of food components including disallowed meals and unauthorized substitution of meal components. EFFECT: Children were not served enough meals because of inadequate or missing meal components. As a result, some sites had to buy meals. Such purchases were reimbursed by the Organization. QUESTIONED COSTS: Indeterminable VIEWS OF RESPONSIBLE OFFICIALS & CORRECTIVE ACTION PLAN: The Organization will self-prep meals in the near future and distribute them to a reduced number of sites. The Organization believes that preparing meals without relying on third party vendors will help improve monitoring processes without compromising on the health, safety, and food standards.

Type of Finding: Noncompliance Compliance Requirement: Cash Management FINDING (2019-006): CLAIMED MEALS FOR REIMBURSEMENT THAT WERE REJCTED AT SITE CRITERIA: 7 CFR ?210.8 (a) (2) states that prior to the submission of monthly claim for reimbursement, each SFA shall review the lunch count data for each school under its jurisdiction to ensure the accuracy of the monthly claim for reimbursement. CAUSE: Some of the meals delivered by the vendor were not served within the right temperatures. This caused the sites to return certain meal components back to the vendor. CONDITION: 4 of the 47 files testes had meal components that were not served within the right temperature settings. EFFECT: As a result, the Department is unable to validate the total number of meals claimed by Sponsor for reimbursement were served by Sponsor and its sites during June 2019 for SFSP. QUESTIONED COSTS: $152,349.38 ? Improper payments made to the Sponsor, which should be remitted to the Department. VIEWS OF RESPONSIBLE OFFICIALS & CORRECTIVE ACTION PLAN: From henceforth, the Organization will prepare and deliver meals to various sites. The purpose behind this step is to avoid third party vendor issues. The Organization will ensure that meals to be prepared in the SFSP program will be maintained and delivered in the right temperatures. Additionally, the Organization will ensure that no meals rejected, nor meals delivered after approved meal service times are claimed.

Type of Finding: Noncompliance Compliance Requirement: Activities Allowed or Unallowed FINDING (2019-007): FAILURE TO ENSURE PROPER SANITATION AND HEALTH STANDARDS CRITERIA: 2 CFR 225.16(a) states that in storing, preparing, and serving food, proper sanitation and health standards must be met which conform with all applicable State and local laws and regulations. CAUSE: The Vendor failed to maintain certain meals prepared within the prescribed temperature controls. The Vendor also failed to report the temperature information for the meals it provided to one of the sites. CONDITION: The Organization should ensure that adequate facilities are available to store food or hold meals. Meal Count sheets provided by the Organization indicated that the Vendor did not follow temperature requirements of certain meals. 3 out of the 47 sites tested reported that a specific meal component was not maintained within the required settings. EFFECT: A meal component that did not meet the required temperature standards was returned to the vendor. This also happened to a meal component that was served to another site during the 2019 summer program. The participants from both the sites reported a bad taste in these meal components as a result improper temperature management. Some site representatives also informed the Organization that the vendor failed to properly seal and secure its meals before serving them to the sites. Due to this, spoilage, spillage, unpleasant smell of certain meal components was reported and resulted in meals being rejected at the site. QUESTIONED COSTS: Indeterminable VIEWS OF RESPONSIBLE OFFICIALS & CORRECTIVE ACTION PLAN: Meals cooked will be prepared and distributed in the right temperature settings within clean and well-maintained premise of all the sites.

Type of Finding: Noncompliance Compliance Requirement: Special Tests and Provisions FINDING (2019-008): FAILURE TO COMPLY WITH PROVISIONS IN CHILD NUTITRION PROGRAMS AGREEMENT CRITERIA: Sub-subparagraph 5P-1.004(1)(a)1. a., FAC, provides that a Sponsor is seriously deficient if it ?fails to comply with provisions outlined in the Child Nutrition Programs Agreement.? CAUSE: The Sponsor had issues with its contracted vendor. The vendor failed to adhere to the program requirements and the Sponsor was unable to effectively monitor the work performed by the vendor. Although the Sponsor tried to obtain alternate caterers, it was only able to obtain one alternate caterer to assist in rectifying some of the issues with its contracted vendor, which caused the meals delivered to be inadequate or unacceptable at some of the sites served CONDITION: During the review out of 47 files selected, 55% of sites sampled had issues regarding meal delivery and/or adequate documentation for claims for reimbursement EFFECT: The failure to comply with the provisions outlined in the Child Nutrition Program agreement led to the Organization to be suspended for one year and listed as seriously deficient. QUESTIONED COSTS: Indeterminable VIEWS OF RESPONSIBLE OFFICIALS & CORRECTIVE ACTION PLAN: : The Organization will self-prep meals in the near future and distribute them to a reduced number of sites. The Organization believes that preparing meals without relying on third party vendors will help improve monitoring processes without compromising on the health, safety, and food standards.

Type of Finding: Noncompliance Compliance Requirement: Special tests and provisions FINDING (2019-009): FAILURE TO MAINTAIN ADEQUATE RECORDS CRITERIA: Sponsor has violated sub-subparagraph 5P-1.004(a)1.f.(II), FAC, which provides that a sponsor is seriously deficient if 10 percent or 10 of its sites, whichever is greater, ?failed to maintain adequate records in accordance with Section 2 CFR 200.? CAUSE: The documentation supplied by the Organization showed several errors, missing information, deviation from required meal reporting, absence of missing receipts, and copies of purchase receipts during the program. In addition, some sites were required to purchase food items for themselves, which would be reimbursed by the Organization upon proof of purchase. In one file sampled, the site failed to submit a copy of the receipt which did not have the dates included. This resulted in the food items purchased being classified as disallowed. CONDITION: A Sponsor or Recipient Agency, and the officials identifies on the Sponsor or Recipient Agency?s application, may be declared by the Department as Seriously Deficient if it fails to maintain adequate documentation. EFFECT: Sponsor and its officer LaMekka Noble are declared Seriously Deficient pursuant to 7 CFR part 225 and subsection 5P-1.004(1), FAC due to the violations and the Department?s findings. Therefore, the Sponsor is suspended for a period of one year from participation in the SFSP. QUESTIONED COSTS: Indeterminable VIEWS OF RESPONSIBLE OFFICIALS & CORRECTIVE ACTION PLAN: The Organization will make sure that the receipts are dated accordingly. The Organization will also ensure that a staff member remains in any reviews always performed by the Agency. In this way, the staff can account and provide all requested documentation.

Type of Finding: Noncompliance Compliance Requirement: Special Tests and Provisions FINDING (2019-010): FAILURE TO COMPLETE A CORRECTIVE ACTION PLAN CRITERIA: Sponsor violated sub-subparagraph 5P-1.004(1)(a)1.a., F.A.C., which provides that a sponsor is seriously deficient if it has ?failed to complete a Corrective Action included in a previously issued Administrative Review.? CAUSE: Two of the sites? reviewed were rescinded last summer, 2018. For one of the sites, the reviewer did not notate how many meals were served outside of the meal service time, and those meals were not disallowed. Since the reviewer failed to notate the meals served, the review was incomplete and as a result, rescinded from review for 2018. Moreover, the Organization mentioned that one of the reviewers included fraudulent information in one of the site?s review. Upon exposing this information to the Department, the Organization was informed that the review would be rescinded. However, the review was not cancelled and was continuously referenced for reviews. CONDITION: The Sponsor was required to submit and comply with a corrective action plan. The corrective action plan required that sponsor upload all meal count sheets and training sign-in sheets into FANS. EFFECT: The Organization was misinformed about the reviews that would be conducted despite being told that those sites were rescinded for monitoring for 2018. This led to an increase in deficiencies noted by the Department. As a result, Sponsor was found seriously deficient for its participation in the 2017-2018 SFSP as set forth in the Notice issued by the Department dated March 21, 2019. The Department also suspended the sponsor for a period of one year following the administrative review conducted by the Department. QUESTIONED COSTS: Indeterminable VIEWS OF RESPONSIBLE OFFICIALS & CORRECTIVE ACTION PLAN: The sponsor will ensure that a corrective action plan will be provided.

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