Ojai Unified School DistrictLocal Government

50000 – Reporting Federal Agency: U.S. Department of Agriculture Pass-Through Entity: California Department of Education (CDE) Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555 Compliance Requirement: L (Reporting) Type of Finding: Material Weakness, Material Noncompliance Criteria or Specific Requirements Per Title 7, U.S. Code of Federal Regulations, Subtitle B, Chapter II, Subchapter A, Parts 210.8 and 220.11, School Food Authorities (SFA) must establish internal controls which ensure the accuracy of meal counts prior to the submission of the monthly Claim for Reimbursement. Prior to submission of a monthly Claim for Reimbursement, each school food authority shall review the breakfast and lunch count data for each school under its jurisdiction to ensure the accuracy of the monthly Claim for Reimbursement. The objective of this review is to ensure that monthly claims include only the number of free, reduced price and paid breakfasts and lunches served on any day of operation to children currently eligible for such meals. SFA staff shall maintain on file each month's Claim for Reimbursement and all data used in the claims review process, by school. Condition The District did not have sufficient controls in place to ensure that monthly Claims for Reimbursement accurately reflected the numbers of meals served. There is no indication that a second person reviews data submissions. We noted discrepancies between the daily meal counts and the monthly Claims for Reimbursement. The system reports provided to the auditor for the six months selected for testing did not agree to the meal counts reported on the Claims for Reimbursement. Discrepancies included the misclassification of 2,054 breakfast meals as severe need rather than basic in each month tested and a misstatement of the number of 163 lunch meals served. The misclassification of breakfast meals resulted in excess revenue of $418. The misstatement of the number of lunch meals served resulted in understated revenue of $867. Cause The condition identified appears to have materialized due to the District’s lack of established procedures to ensure compliance with the requirements under Title 7, U.S. Code of Federal Regulations, Subtitle B, Chapter II, Subchapter A, Parts 210.8 and 220.11. Effect The District has not complied with the requirements identified in Title 7, U.S. Code of Federal Regulations, Subtitle B, Chapter II, Subchapter A, Parts 210.8 and 220.11. Questioned Costs There were no questioned costs associated with the identified condition. Context/Sampling The condition was identified through inquiry with District personnel and through review of available supporting documentation for the monthly Claims for Reimbursement. A nonstatistical sample of 3 months out of 12 months were selected for reporting testing, with an additional 3 months selected to include an element of unpredictability. Repeat Finding Yes, see prior-year finding 2023-003. Recommendation The District should review the requirements stated in Title 7, U.S. Code of Federal Regulations, Subtitle B, Chapter II, Subchapter A, Parts 210.8 and 220.11 and implement procedures to address the control deficiencies currently identified. The District should retain all supporting documentation used to complete the monthly Claims for Reimbursements and ensure the number of meals reported on the Claims for Reimbursements agree to the supporting system reports.

50000 – Eligibility Federal Agency: U.S. Department of Agriculture Pass-Through Entity: California Department of Education (CDE) Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555 Compliance Requirement: E (Eligibility) Type of Finding: Material Weakness, Material Noncompliance Criteria or Specific Requirements Per Title 7, U.S. Code of Federal Regulations, Subtitle B, Chapter II, Subchapter A, Part 245.6(c) (4) states 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. When a household submits an application containing complete documentation, as defined in § 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 § 245.2, the children in that household must be approved for free or reduced price benefits, as applicable. Per Title 7, U.S. Code of Federal Regulations, Subtitle B, Chapter II, Subchapter A, Part 245.6(e) states that the local educational agency must maintain documentation substantiating eligibility determinations on file for 3 years after the date of the fiscal year to which they pertain, except that if audit findings have not been resolved, the documentation must be maintained as long as required for resolution of the issues raised by the audit. Condition The District did not have sufficient controls in place to ensure that students were accurately included as eligible to receive free or reduced-price meals. There was no evidence that meal applications had been reviewed by the Director of Nutrition Services. Of 40 students selected for testing, six had been determined to be eligible for reduced-price meals while the audit determined that they were eligible for free meals. No application could be located for one student. Cause The condition identified appears to have materialized due to the District’s lack of established internal control procedures to ensure compliance with the requirements under Title 7, U.S. Code of Federal Regulations, Subtitle B, Chapter II, Subchapter A, Part 245.6 (c) and Part 245.6 (e). Effect The District has not complied with the requirements identified in Title 7, U.S. Code of Federal Regulations, Subtitle B, Chapter II, Subchapter A, Part 245.6 (c) and Part 245.6 (e). Questioned Costs There were no questioned costs associated with the identified condition. Context/Sampling The condition was identified through inquiry with District personnel and through review of available supporting documentation for the student eligibility for free or reduced-price meals. A nonstatistical sample of 40 out of 847 students were selected for eligibility testing. Repeat Finding No. Recommendation The District should review the requirements stated in Title 7, U.S. Code of Federal Regulations, Subtitle B, Chapter II, Subchapter A, Part 245.6 (c) and Part 245.6 (e) and implement procedures to address the control deficiencies currently identified. The District should retain all supporting documentation used to complete the eligibility determination for a minimum of three years as required by the Code.

Federal Program Affected Federal Agency: U.S. Department of Agriculture Pass-Through Entity: California Department of Education (CDE) Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555 Compliance Requirement: I (Procurement) Criteria or Specific Requirements Per Title 2, U.S. Code of Federal Regulations, Subtitle A, Chapter II, Part 200, Subpart D, Section 200.320(a)(2), the non-Federal entity must have and use documented procedures, for informal procurement methods when the value of the procurement for property or services under a Federal award does not exceed the simplified acquisition threshold (SAT). Small purchases up to $250,000 require small purchase procedures to be used, which involves price or rate quotations must be obtained from an adequate number of qualified sources. Condition The District did not have sufficient controls in place to ensure that small purchase procedures are followed in accordance with federal requirements. The District was unable to provide price or rate quotations for 1 of the 3 vendors tested. Questioned Costs There were no questioned costs associated with the identified condition. Context The condition was identified through inquiry with District personnel and through review of available supporting documentation. A nonstatistical sample of 3 vendors out of 7 vendors were selected for procurement testing. Effect The District has not complied with the requirements identified in Title 2, U.S. Code of Federal Regulations, Subtitle A, Chapter II, Part 200, Subpart D, Section 200.320(a)(2). Cause The condition identified appears to have materialized due to the Districts lack of adherence to the established procedures to ensure compliance. Repeat Finding No. Recommendation The District should review the established procurement policies with the staff and provide necessary training.

Federal Program Affected Federal Agency: U.S. Department of Agriculture Pass-Through Entity: California Department of Education (CDE) Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555 Compliance Requirement: L (Reporting) Criteria or Specific Requirements Per Title 7, U.S. Code of Federal Regulations, Subtitle B, Chapter II, Subchapter A, Parts 210.8 and 220.11, School Food Authorities (SFA) must establish internal controls which ensure the accuracy of meal counts prior to the submission of the monthly Claim for Reimbursement. Prior to submission of a monthly Claim for Reimbursement, each school food authority shall review the breakfast and lunch count data for each school under its jurisdiction to ensure the accuracy of the monthly Claim for Reimbursement. The objective of this review is to ensure that monthly claims include only the number of free, reduced price and paid breakfasts and lunches served on any day of operation to children currently eligible for such meals. SFA staff shall maintain on file each month's Claim for Reimbursement and all data used in the claims review process, by school. The above-noted CFR section also states that the SFA shall compare each school's daily counts of meals served against the product of the number of children in that school currently eligible for free, reduced price and paid lunches, respectively, times an attendance factor. Condition The District did not have sufficient controls in place to ensure that monthly Claims for Reimbursement accurately reflected the numbers of meals served. We noted discrepancies between the daily meal counts and the monthly Claims for Reimbursement. It is not clear what records were used to file the monthly Claims for Reimbursement, as the system reports provided to the auditor for the months of August 2022, October 2022, and January 2023 did not agree to the meal counts reported on the Claims for Reimbursement. For the three months noted, the District overclaimed 151 meals, which is approximately $7,141 of excess reimbursement. Questioned Costs There were no questioned costs associated with the identified condition. Context The condition was identified through inquiry with District personnel and through review of available supporting documentation for the monthly Claims for Reimbursement. A nonstatistical sample of 4 months out of 12 months were selected for reporting testing. Effect The District has not complied with the requirements identified in Title 7, U.S. Code of Federal Regulations, Subtitle B, Chapter II, Subchapter A, Parts 210.8 and 220.11. Cause The condition identified appears to have materialized due to the District’s lack of established procedures to ensure compliance with the requirements under Title 7, U.S. Code of Federal Regulations, Subtitle B, Chapter II, Subchapter A, Parts 210.8 and 220.11. Repeat Finding Yes, see prior year finding 2022-007. Recommendation The District should review the requirements stated in Title 7, U.S. Code of Federal Regulations, Subtitle B, Chapter II, Subchapter A, Parts 210.8 and 220.11 and implement procedures to address the control deficiencies currently identified. The District should retain all supporting documentation used to complete the monthly Claims for Reimbursements and ensure the number of meals reported on the Claims for Reimbursements agree to the supporting system reports.

Federal Program Affected Federal Agency: U.S. Department of Agriculture Pass-Through Entity: California Department of Education (CDE) Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555 Compliance Requirement: N (Special Tests and Provisions – Verification of Free and Reduced Price Applications) Criteria or Specific Requirements Per Title 7, U.S. Code of Federal Regulations, Subtitle B, Chapter II, Subchapter A, Parts 245.6a. The local education agency must verify the current free and reduced-price eligibility of households selected from a sample of applications that it has approved for free and reducedprice meals, by November 15 of each school year. The verification sample size is based on the total number of approved applications on file October 1. Condition The District did complete the verification process by November 15th of the school year. As a result, the nine students selected for verification process were incorrectly categorized as free or reduced until December 9, 2022, the date on which the District completed the verification process and changed the status of these nine students to paid. Questioned Costs There were no questioned costs associated with the identified condition, as the estimated costs for the nine overclaimed students would be below the questioned costs threshold. Context The condition was identified through inquiry with District personnel and through review of available supporting documentation. Effect The District does not appear to be in compliance with Special Test and Provision requirements for the Child Nutrition cluster. Cause The condition identified appears to have materialized due to the District’s lack of established procedures to ensure compliance with the requirements Title 7, U.S. Code of Federal Regulations, Subtitle B, Chapter II, Subchapter A, Parts 245.6a. Repeat Finding No. Recommendation The District should establish procedures to ensure the verification process is completed timely and the appropriate eligibility changes are made.

Federal Program Affected Federal Agency: U.S. Department of Education Pass-Through Entity: California Department of Education (CDE) Program Name: Education Stabilization Fund Assistance Listing Number: 84.425C, 84.425D, 84.425U, 84.425W Compliance Requirement: L (Reporting) Criteria or Specific Requirements Per Title 2, U.S. Code of Federal Regulations Part 200, Subpart D, Section 200.334, financial records and supporting documents pertinent to a Federal award must be retained for a period of three years from the date of submission of expenditure reports to the awarding agency or pass-through entity. Condition The District misreported Full-Time Equivalent (FTE) positions, for multiple date ranges, on the ESSER Annual Data Collection: General ESSER Information Report that was submitted to the California Department of Education. In addition, the District was not able to provide supporting general ledger detail reports that agreed to the quarterly ESSER and GEER reports. Questioned Costs There were no questioned costs associated with the identified condition. Context The condition was identified through inquiry with District personnel and through the review of documentation used to prepare the reports. A nonstatistical sample of 9 reports out of 26 quarterly reports and both annual reports were selected for reporting testing. Effect The District has not complied with the requirement identified in Title 2, U.S. Code of Federal Regulations Part 200, Subpart D, Section 200.333. Cause The identified condition appears to have materialized due to insufficient procedures related to the review process. Repeat Finding No. Recommendation The District should ensure that all Full-Time Equivalent (FTE) positions are reported on the District’s ESSER Annual Data Collection: General ESSER Information Report based on actual FTE Positions. In addition, the District should retain the general ledger reports that are used to complete the quarterly ESSER and GEER reports.

Federal Program Affected Federal Agency: U.S. Department of Agriculture Pass-Through Entity: California Department of Education (CDE) Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555 Compliance Requirement: L (Reporting) Criteria or Specific Requirements Per Title 7, Code of Federal Regulations, Subtitle B, Chapter II, Subchapter A, Parts 210.8 and 220.11, School Food Authorities (SFA) must establish internal controls which ensure the accuracy of meal counts prior to the submission of the monthly Claim for Reimbursement. Prior to submission of a monthly Claim for Reimbursement, each school food authority shall review the breakfast and lunch count data for each school under its jurisdiction to ensure the accuracy of the monthly Claim for Reimbursement. The objective of this review is to ensure that monthly claims include only the number of free, reduced price and paid breakfasts and lunches served on any day of operation to children currently eligible for such meals. SFA staff shall maintain on file each month's Claim for Reimbursement and all data used in the claims review process, by school. The above-noted CFR section also states that the SFA shall compare each school's daily counts of meals serve against the product of the number of children in that school currently eligible for free, reduced price and paid lunches, respectively, times an attendance factor. Per Title 7, Code of Federal Regulations, Subtitle B, Chapter II, Subchapter A, Parts 210.8 and 220.11, SFA must submit monthly claims for reimbursement for meals and snacks served to eligible students within 60 days following the last day of the month covered by the claim. Conditions The District did not have sufficient controls in place to ensure that monthly Claims for Reimbursement accurately reflected the numbers of meals served. We noted discrepancies between the daily meal counts and the monthly Claims for Reimbursement. It is not clear what records were used to file the monthly Claims for Reimbursement, as the worksheet provided to the auditors did not include the month of July 2021 and appeared to be incomplete for several other months and/or sites. During the audit year, the District did not use a point-of-sale (POS) system to track meals served. There was no analytical review or edit check performed to determine reasonableness of meal counts, such as comparing the number of students enrolled to the number of meals served on a daily basis by site. Such analysis would allow staff to identify possible errors timely and in advance of filing a claim. Although not required, a POS system would automate these analyses, allowing for greater staff efficiencies and accuracy. Three monthly Claims for Reimbursement were filed more than 60 days following the last day of the month covered by the claim. Questioned Costs Based on the records provided, it appears that 23,195 more meals were claimed than are supported by daily meal counts. Using the reimbursement rates in place and the categories of the meals served, the District received $79,869 in excess of the amount supported by the meal counts maintained. Context The condition was identified through inquiry with District personnel and through review of available supporting documentation for the monthly Claims for Reimbursement. Effect The District has not complied with the requirements identified in Title 7, Code of Federal Regulations, Subtitle B, Chapter II, Subchapter A, Parts 210.8 and 220.11. Cause The condition identified appears to have materialized due to the District?s lack of established procedures to ensure compliance with the requirements under Title 7, Code of Federal Regulations, Subtitle B, Chapter II, Subchapter A, Parts 210.8 and 220.11. Repeat Finding No. Recommendation The District should review the requirements stated in Title 7, Code of Federal Regulations, Subtitle B, Chapter II, Subchapter A, Parts 210.8 and 220.11 and implement procedures to address the control deficiencies currently identified. Suggestions include the return to a POS system that tracks meals served. This will allow for an electronic, permanent, and auditable record of the meals served at each site. It will also allow for a reasonableness or edit check of the meals served data.

Federal Program Affected Federal Agency: U.S. Department of Agriculture Pass-Through Entity: California Department of Education (CDE) Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555 Compliance Requirement: A/B (Activities Allowed or Unallowed and Allowable Costs/Cost Principles) Criteria or Specific Requirements Per Title 2, Code of Federal Regulations, Subtitle A, Part 200, Subpart E, Section 200.403(a), in order for costs to be allowable under Federal awards, they must be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. Per Title 2, Code of Federal Regulations, Part 200, Subpart E, Section 200.430(i)(1)(vii), Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. A semi-annual certification may be completed if 100% of an employee?s time if charged to one Federal award. Conditions The District did not have sufficient controls in place to ensure that expenditures charged to the Child Nutrition program were allowable in accordance with federal requirements. The District uses the program administrator?s signature on invoices to document the administrator?s approval to charge expenditures to specific accounts, including those for child nutrition funds. We noted the following: ? Three of 20 non-payroll items selected for allowability testing, in the amount of $6,421, did not have the food service director?s signature indicating approval of the expenditure. ? Two of 20 non-payroll expenditures, in the amount of $1,233, were not allowable for the child nutrition program. Both were for HVAC projects not related to food service facilities. ? One of 20 did not include an itemized receipt, in the amount of $95, which prevented us from determining if the expenditure was allowable. The District did not have sufficient controls in place to ensure that employees who were charged to Child Nutrition program completed time accounting documentation in accordance with federal requirements. The District was not able to provide time accounting documentation for one of 40 employees selected for testing. Questioned Costs There were no questioned costs associated with the identified condition. Context The condition was identified through inquiry with District personnel and through review of available supporting documentation. Effect The District has not complied with the requirements identified in Title 2, Code of Federal Regulations, Subtitle A, Part 200, Subpart E, Section 200.403(a) and Title 2, Code of Federal Regulations, Part 200, Subpart E, Section 200.430(i)(1)(vii). Cause The condition identified appears to have materialized due to the District?s lack of established procedures to ensure compliance with the requirements under Title 2, Code of Federal Regulations, Subtitle A, Part 200, Subpart E, Section 200.403(a) and Title 2, Code of Federal Regulations, Part 200, Subpart E, Section 200.430(i)(1)(vii). Repeat Finding No. Recommendation The District should review the requirements stated in Title 2, Code of Federal Regulations, Subtitle A, Part 200, Subpart E, Section 200.403(a) and Title 2, Code of Federal Regulations, Part 200, Subpart E, Section 200.430(i)(1)(vii) and implement a procedure to address the control deficiency currently identified with the District?s time accounting documentation as it relates to employees working on multiple activities or cost objectives.

Federal Program Affected Federal Agency: U.S. Department of Education Pass-Through Entity: California Department of Education (CDE) Program Name: Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Compliance Requirement: A/B (Activities Allowed or Unallowed and Allowable Costs/Cost Principles) Criteria or Specific Requirements Per Title 2, Code of Federal Regulations, Part 200, Subpart E, Section 200.430(i)(1)(vii), Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. A semi-annual certification may be completed if 100% of an employee?s time if charged to one Federal award. Conditions The District uses the HRA form to document the administrator?s approval to charge employee costs to specific accounts, including those for restricted funds. We noted the following: ? HRAs for two of the 31 employees selected for the test of payroll charged to ESF did not include the resource code to which the employees were charged. ? One HRA did not document the employee?s authorized step and column placement on the salary schedule. ? The salary paid an employee was not properly documented on the HRA and could not be traced to a salary schedule. The District did not have sufficient controls in place to ensure that employees who were charged to Education Stabilization Fund programs completed time accounting documentation in accordance with federal requirements. The District was not able to provide time accounting documentation for one of 31 employees selected for testing. Questioned Costs There were no questioned costs associated with the identified condition. Context The condition was identified through inquiry with District personnel and through review of available supporting documentation. Effect The District has not complied with the requirements identified in Title 2, Code of Federal Regulations, Part 200, Subpart E, Section 200.430(i)(1)(vii). Cause The condition identified appears to have materialized due to the District?s lack of established procedures to ensure compliance with the requirements under Title 2, Code of Federal Regulations, Part 200, Subpart E, Section 200.430 (i)(1)(vii). Repeat Finding No. Recommendation The District should review the requirements stated in Title 2, Code of Federal Regulations, Part 200, Subpart E, Section 200.430 (i)(1)(vii) and implement a procedure to address the control deficiency currently identified with the District?s time accounting documentation as it relates to employees working on multiple activities or cost objectives.