Rolling Hills Local School DistrictLocal Government

Noncompliance and Material Weakness 7 CFR Part 245.6(c)(4) requires that the local educational agency must use the income information provided by the household on the application to calculate the household's total current income for determination if the household was eligible for free or reduced price benefits. When a household submits an application containing complete documentation, as defined in 7 CFR Part 245.2, and the household's total current income is at or below the eligibility limits specified in the Income Eligibility Guidelines as defined in 7 CFR Part 245.2, the children in that household must be approved for free or reduced price benefits, as applicable. Errors in the eligibility determination were noted with 3 out of 60 individual students tested. Errors are described as follows: ? One household submitted an application documenting weekly income totaling $900, with a household size of 4. The School District determined eligibility by incorrectly calculating the income of $900 as received monthly instead of weekly. Therefore, the student?s eligibility was incorrectly determined to be free rather than reduced based on the Income Eligibility Guidelines. This error would have led to the School District receiving less program income from providing meals as well as being over reimbursed for claimed meals relating to this student?s actual benefit usage. ? One household submitted an application documenting two income sources. The first income source listed earnings from work before deductions of $1,200, received every two weeks. The second income source listed earnings from work before deductions of $900, however the frequency (i.e. weekly, every two weeks, twice monthly or monthly) was not noted. The School District calculated the student?s eligibility as the $900 income being received monthly without any support of the accuracy of this frequency. As the frequency was not verified, the School District did not have a basis to make the assumption, and we were unable to determine if the eligibility determination of reduced was accurate or not. If the actual frequency was different than utilized in the calculation, there is a possibility the student would not have been eligible for reduced benefits. ? One student selected was receiving free benefits, however there was no supporting documentation (i.e. application or direct certification) available to support this determination. Further inquiry with the School District noted this student attended a CEP eligible school (Brook Intermediate) in the previous school year. Per 7 CFR 245.6(c)(2), an individual student?s eligibility from the previous school year carries over for up to 30 operating days into the new school year, or until new eligibility determination is made, whichever comes first. Therefore, this student?s eligibility would have been appropriately free for the first 30 days of the school year, however should have been changed to denied when an application was not received and the student was not directly certified. Therefore, the student?s eligibility was incorrectly determined to be free, and this error would have led to the School District receiving less program income from providing meals as well as being over reimbursed for claimed meals relating to this student?s actual benefit usage. The School District should ensure eligibility calculations on submitted applications are properly performed, which could include a secondary review. Additionally, a review of all free/reduced students should be performed to ensure they have an approved application on file or are directly certified. This will help to ensure that the School District properly complies with Federal regulations, properly receives all program income due to the school and is not over reimbursed with federal funding for unallowable claimed free or reduced price meals.