Giving Youth A Chance Initiative

Condition: During our testing of monthly reimbursement claims, we identified multiple instances where the number of meals claimed for reimbursement exceeded the number documented on daily meal count sheets maintained by site supervisors or participant rosters. These differences indicate that the claims submitted were not fully supported by the required underlying documentation. Criteria: Title 7 CFR §225.9(d)(5) requires that sponsors certify claims for reimbursement are accurate and supported by available records. Claims that are not substantiated by meal count records do not meet this regulatory requirement. Cause: The control process designed to reconcile daily meal count sheets to the monthly internal summaries prior to claim submission was not operating effectively. Although management performs a second review within 60 days of month-end, initial claims were submitted based on unreconciled summaries due to timing pressures. Effect: Claims for reimbursement were submitted that included meal counts not supported by source documentation. This resulted in noncompliance with the Activities Allowed or Unallowed compliance requirement. Known and likely questioned costs related to these discrepancies were below the Uniform Guidance reporting threshold of $25,000. Context: A sample of 60 daily meal count entries was tested. Of those, 20 (33%) reflected discrepancies between the reported meals on the monthly reimbursement claim and the documented meals served per the corresponding daily meal count sheet. Recommendation: We recommend management strengthen and adhere to internal control procedures that ensure all reimbursement claims are fully reconciled to original daily meal count documentation prior to submission. Where timing constraints necessitate early filing, controls should ensure that amendments are consistently and promptly submitted within the allowable revision window. Management’s Response: See accompanying management’s corrective action plan.

Condition: We identified instances in which the number of meals reported as served on the daily meal count forms exceeded the number of participants listed on the daily participant rosters. Since participants must be documented on the roster to be eligible, the number of meals reimbursed exceeded the number of eligible recipients on those days. Criteria: Per 7 CFR §225.9(d)(5), sponsors must certify that claims for reimbursement are accurate and supported by available records. Reimbursement may only be claimed for meals served to eligible participants as documented by daily rosters. Cause: Each site maintains a daily roster to document eligible participants. However, the reconciliation between the roster and meal counts was not functioning effectively, resulting in excess meals reported without adequate participant support. Effect: Reimbursement claims included meals served to individuals not documented as eligible participants on the daily rosters, resulting in noncompliance with the Eligibility requirement. Known and likely questioned costs were below the $25,000 reporting threshold under Uniform Guidance. Context: A sample of 60 daily meal count records was tested. For 9 of those (15%), the number of meals reported exceeded the number of participants documented on the corresponding daily roster. Recommendation: We recommend that management reinforce controls to ensure that daily meal count submissions are reconciled to participant rosters before claims for reimbursement are filed. Specifically, each site should confirm that the number of meals served does not exceed the number of eligible participants recorded for that date. Management’s Response: See accompanying management’s corrective action plan.

2023-002 – Reimbursement Claims Not Supported by Meal Count Sheets Significant Deficiency in Internal Controls over Compliance and on Compliance Award 10.558; Compliance Requirement A – Activities Allowed and Unallowed Condition: For the monthly meal reimbursement claims, we noted several instances in which the amount requested for reimbursement exceeded the underlying daily meal count forms provided by site supervisors or participant rosters. Criteria: Title 7 of the Code of Federal Regulations, Section 225.9 (d)(5) states, “In submitting a claim for reimbursement, the sponsor shall certify that the claim is correct and that records are available to support this claim.” Cause: The primary internal control over compliance for submitting claims for reimbursement and reviewing the claim reimbursement against monthly internal spreadsheets failed. Effect: Incorrect claims for reimbursement were submitted which resulted in noncompliance with the Activities Allowed and Unallowed compliance requirement of the Uniform Guidance. Total known and questioned costs were less than the reportable threshold of $25,000. Context: A sample of sixty (60) daily meal counts were selected for testing. The daily meal count for the specific day and location per the monthly internal summary did not agree to the meal count reported on the monthly claims reimbursement for (7) of the selections. Recommendation: Currently, management has a process to reconcile daily meal count sheets to the reimbursement claims. Due to cash management needs, claims are originally reported within a few days of month end. The claims are later amended as a part of a second review to be completed within 60 days of month end for the timely filing of claim reimbursement amendments. We recommend that current internal controls over compliance be reviewed and followed. Management’s Response: See accompanying management’s corrective action plan.

Significant Deficiency in Internal Controls over Compliance and on Compliance Award 10.558; Compliance Requirement A – Activities Allowed and Unallowed Condition: Amendments made to original claims for reimbursement were not submitted timely. Criteria: The Child and Adult Care Food assistance listing from sam.gov states “Institutions file monthly reports on Program operations to claim reimbursement for meals served. They must submit final claims no later than 60 days after the claiming month.” Cause: Timely amendments were not filed. Effect: Amounts owed to and from the federal program provider were not determined timely. Context: All ten (10) months of the program original and amended claim reimbursements were reviewed. Of the eight (8) months which had amended claim reimbursements, five (5) months were not filed timely, within 60 days after the claiming month. Recommendation: Currently, management has a process to review monthly claim reimbursements for a second time after the original claim reimbursement is filed. There currently is not a deadline to complete this review, other than within 60 days. We suggest that management further define this review process to include timely review and preparation of any needed amended claim reimbursements. Management’s Response: See accompanying management’s corrective action plan.

2023-004 – Reimbursement Claims Reported Meals Delivered To Unidentified Participants Significant Deficiency in Internal Controls over Compliance and on Compliance Award 10.558; Compliance Requirement E – Eligibility Condition: Reimbursement claims were made for more meals than there were participants on the specified date. Criteria: Title 7 of the Code of Federal Regulations, Section 225.9 (d)(5) states, “In submitting a claim for reimbursement, the sponsor shall certify that the claim is correct and that records are available to support this claim.” Cause: A roster of participants is maintained by each location for each day that meals are provided. Participants are not eligible for meals unless they are on the roster. The meals reported on the daily meal count forms exceeded the daily roster of participants. Effect: Meals were requested for reimbursement in excess of the number of participants included on the supporting roster of participants for the specific location and date. Total known and questioned costs were less than the reportable threshold of $25,000. Context: A sample of sixty (60) daily meal counts were selected for testing. For three (3) selections, there was no supporting roster of participants. For five (5) selections, the number of meals reported as delivered exceeded the number of participants eligible on the roster of participants. Recommendation: Currently, management has a process to require a daily roster of participants at each location in order to monitor the meals delivered and the eligibility of the participant. We recommend that current internal controls over compliance be reviewed and followed. Management’s Response: See accompanying management’s corrective action plan.

2022-003 ? Reimbursement Claims Not Supported by Meal Count Sheets Significant Deficiency in Internal Controls over Compliance Award 10.558; Compliance Requirement A ? Activities Allowed Condition: For the monthly meal reimbursement claims, we noted several instances in which the amount requested for reimbursement exceeded the underlying daily meal count forms provided by site supervisors or participant rosters. Criteria: Title 7 of the Code of Federal Regulations, Section 225.9 (d)(5) stated, ?In submitting a claim for reimbursement, the sponsor shall certify that the claim is correct and that records are available to support this claim.? Cause: Three mitigating internal controls over compliance for submitting claims for reimbursement are failed at varying rates as the internal control procedures were inconsistently followed. Effect: Incorrect claims for reimbursement were made which resulted in noncompliance with the Activities Allowed or Unallowed compliance requirement of the Uniform Guidance. As noted above, some claims were overstated and some were understated. However, amounts overstated yielded an overbilling of $2,552. Context: A sample of sixty (60) daily meal count sheets were selected for testing. The daily meal counts sheets did not agree to the monthly internal summary for three (3) selections. The daily counts reported on the internal summary did not agree to the monthly claims reimbursement for fifteen (15) selections. The daily meal counts exceeded the participant roster listing or the participant roster listing was missing for nine (9) selections. These failures resulted in noncompliance for nine (9) selections and resulted in total known and likely questioned costs of $25,485. Recommendation: Currently management has a process to reconcile daily meal count sheets to the reimbursement claims. This process includes a second review to be completed within 60 days of month end in order for the timely filing of claim reimbursement amendments. We recommend that current internal controls of compliance be reviewed and followed. Management?s Response: See accompanying management?s corrective action form.

2022-004 ? Claim Reimbursement Amendments Not Filed Timely Significant Deficiency in Internal Controls over Compliance Award 10.558; Compliance Requirement A ? Activities Allowed Condition: Amendments to monthly meal claim reimbursements were not filed timely. Criteria: The Child and Adult Care Food Program description provided that institutions ?must submit final meal claims no later than 60 days after the claiming month.? Cause: Existing internal control procedures were not followed. Effect: The Organization received $19,305 in overpaid meal reimbursements. These overpayments were not reported within the 60-day timeframe. In addition, the overpayments were not accrued at year-end. Context: All monthly reimbursement reports were reviewed. Two (2) months were not filed timely, within 60-days. Recommendation: Internal controls over compliance include procedures of a secondary review of monthly meal claims reimbursements in order to file amended claim forms within the 60-day timeframe. We recommend management review and follow current internal control procedures. Management?s Response: See accompanying management?s corrective action form.

Noncompliance and Significant Deficiency in Internal Control over Compliance 2021-001: Reimbursement Claims Not Supported by Meal Count Sheets Condition: For the monthly meal reimbursement claims, we noted several instances in which the amount requested for reimbursement did not agree to the underlying daily meal count forms provided by site supervisors. We noted instances in which the reimbursement claims requested were overstated (more meals claimed than what the daily meal count forms reported) as well as instances in which the reimbursement claims were understated (more meals reported on the daily meal count forms than claimed). Criteria: Title 7 of the Code of Federal Regulations, Section 225.9 (d)(5) stated, ?In submitting a claim for reimbursement, the sponsor shall certify that the claim is correct and that records are available to support this claim.? Cause: Controls in place for submitting claims for reimbursement are not being followed. Effect: Incorrect claims for reimbursement were made which resulted in noncompliance with the Activities Allowed or Unallowed compliance requirement of the Uniform Guidance. As noted above, some claims were overstated and some were understated. However, amounts overstated yielded an overbilling of $2,552. Context: A sample of three months was selected and from those, a total of 20 locations for each month was selected to reconcile the daily meal count forms to the reimbursement claims. The internal control over compliance for reconciling the daily meal count forms to the reimbursement claims failed 21 times which resulted in noncompliance 13 times. Recommendation: Currently management has a process to reconcile daily meal count sheets to the reimbursement claims. We recommend that a second level of review be completed before submitting claims for reimbursement to the State of Tennessee. Management?s Response: See accompanying management?s corrective action form.

2020-004: Significant Deficiency ? Meal Count Sheets Did Not Support Reimbursement Summary Condition: Meal count reimbursement forms overcounted and undercounted the number of meals reported on the daily meal count forms provided by site supervisors. Criteria: Title 7 of the Code of Federal Regulations, Section 225.9 (d)(5) stated, ?In submitting a claim for reimbursement, the sponsor shall certify that the claim is correct and that records are available to support this claim.? Cause: Giving Youth a Chance did not follow prescribed internal control policies and compliance requirements. Effect: Disallowed costs were identified, although the amount identified did not meet the threshold for reporting as a questioned cost under the Uniform Guidance. Recommendation: Management should provide additional training to all site supervisors to ensure a full understanding of the meal count form reporting requirements. Management?s Response: See management?s corrective action form.

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