SOUTH EUCLID-LYNDHURST CITY SCHOOL DISTRICT

7 CFR § 210.8(a) states, "The school food authority shall establish internal controls which ensure the accuracy of meal counts prior to the submission of the monthly Claim for Reimbursement. At a minimum, these internal controls shall include: an on-site review of the meal counting and claiming system employed by each school within the jurisdiction of the school food authority; comparisons of daily free, reduced price and paid meal counts against data which will assist in the identification of meal counts in excess of the number of free, reduced price and paid meals served each day to children eligible for such meals; and a system for following up on those meal counts which suggest the likelihood of meal counting problems." 7 CFR § 220.11(b) states in part, claims for reimbursement shall include data in sufficient detail to justify the reimbursement claimed and to enable the State Agency to provide the Reports of School Program Operations required under § 220.13(b)(2). In Ohio, the Ohio Department of Education and Workforce (DEW) requires school districts to use the Claims Reporting and Reimbursement System (CRRS) to report meal data for reimbursement. The District switched from a point-of-sale system that generates a CN-6 Report (Breakfast) and CN-7 Report (Lunch), which is used to compile the monthly reimbursement request submitted to DEW, in August and September. After learning they were 100% Nutrition Cluster eligible, they transition to a faculty operated “clicker count” system, in which a faculty member would observe students going through the cafeteria line and push a button of a clicker counter each time a student left the line with a meal. Clicker counts were then entered into a report and submitted to Food Services Department for entry into a master count. This weakness resulted in a loss of accountability over meal count reporting and could lead to a reduction or forfeiture of future funding for this program. Due to insufficient controls over CN-6 and CN-7 reporting related to breakfast and lunch meal counts, all four (100%) CN reports tested were inaccurate. This led to inaccuracies in meal counts reported in the CRRS system, as shown below: See Actual Finding for Table

2 CFR ? 3474.1 provides that the Department of Education (DOE) adopts the Office of Management and Budget (OMB) Guidance in 2 CFR part 200. Thus, this section gives regulatory effect to the OMB guidance and supplements the guidance as needed for the DOE, except as otherwise noted in that section. Appendix II to 2 CFR part 200, Paragraph D states that all contracts made by the non-Federal entity under the Federal award must contain provisions covering the following: (D) Davis-Bacon Act, as amended (40 U.S.C. 3141-3148). When required by Federal program legislation, all prime construction contracts in excess of $2,000 awarded by non-Federal entities must include a provision for compliance with the Davis-Bacon Act (40 U.S.C. 3141-3144, and 3146-3148) as supplemented by Department of Labor regulations (29 CFR Part 5, ?Labor Standards Provisions Applicable to Contracts Covering Federally Financed and Assisted Construction?). In accordance with the statute, contractors must be required to pay wages to laborers and mechanics at a rate not less than the prevailing wages specified in a wage determination made by the Secretary of Labor. In addition, contractors must be required to pay wages not less than once a week. The non-Federal entity must place a copy of the current prevailing wage determination issued by the Department of Labor in each solicitation. The decision to award a contract or subcontract must be conditioned upon the acceptance of the wage determination. The non-Federal entity must report all suspected or reported violations to the Federal awarding agency. . . The District entered into a contract with Trane Technologies for installation of HVAC equipment for Brush High School gym, in the amount of $539,585. During fiscal year 2022, the District paid Trane Technologies $269,792 with American Rescue Plan Elementary and Secondary School Emergency Relief (ARP ESSER) Fund monies related to this project. These expenditures included contractor payroll charges of $9,711 for periods prior to June 30, 2022. However, due to the lack of formal controls and procedures, the District did not obtain the certified payroll information until March 2023. This weakness resulted in the District being non-compliant with the aforementioned federal codes and could result in future reductions or loss of federal funding. The District should ensure certified payroll reports are provided weekly by the contractor. The District should obtain the necessary information from the contractor to document compliance with the program requirements and if the contractor failed to comply then they have an obligation under Appendix II to 2 CFR part 200 to report all suspected or reported violations to the Federal awarding agency.

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