RIALTO UNIFIED SCHOOL DISTRICTLocal Government

Federal Agency: U.S. Department of Agriculture Pass-Through Entity: California Department of Education Program Name: Child Nutrition Cluster Federal Financial Assistance Listing: 10.553, 10.555, 10.559 Award Identification Number: 15323,15324,13526, 13004 Award Year: 2021-2022, 2022-2023 Compliance Requirement: L. Reporting Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Criteria 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. We noted per review of the results of a forensic investigation, discrepancies between the daily meal counts and the monthly Claims for Reimbursement for various months from December 2021 through June 2023. The discrepancies in meal counts resulted in an approximate excess claim of $3,043,824. Cause The condition identified above resulted from lack of sufficient internal controls over compliance to prevent fraudulent activity related to meal claims. 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 The condition identified resulted in questioned costs of $3,043,824. Context/Sampling: The condition was identified by the District through the results of a forensic investigation reviewing monthly meal claims and supporting documentation for the fiscal years of 2021-2022, 2022-2023, and 2023-2024. 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, 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 Agency: U.S. Department of Agriculture Pass-Through Entity: California Department of Social Services Program Name: Child and Adult Care Food Program (CACFP) Federal Financial Assistance Listing: 10.558 Award Identification Number: 13529, 13534 Award Year: 2024-2025 Compliance Requirement: M. Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control over Compliance, Noncompliance Criteria Title 7, Code of Federal Regulations, Part 226.16(d)(4)(iii) requires sponsoring organizations to review each subrecipient facility a minimum of three times per year. Additionally, at least two of the three reviews must be unannounced. Condition At eight of 10 sites tested, the District has not met the minimum monitoring requirements. Five of 10 sites tested had no monitoring visits completed during the year, one of 10 sites tested had only one monitoring visit during the year, and two of 10 sites had only two monitoring visits during the year. Through further discussions with management, it was noted that the District does not perform monitoring visits on the secondary school sites, of which there are seven sites. This resulted in an additional three deviations for a total of 11 deviations noted. Cause The cause appears to be due to lack of internal controls over compliance for subrecipient monitoring. Effect The District is not in compliance with the provisions of Title 7, Code of Federal Regulations, Part 226.16(d)(4)(iii). Questioned Costs None reported. Context/Sampling: A nonstatistical sample of five out of 26 sites was initially tested. This resulted in four instances of noncompliance as follows: three sites had no monitoring visits completed, and one site had only one of the three required monitoring visits completed. In response to this noncompliance, five additional sites were tested for a total of 10 out of 26 sites. This resulted in four additional instances of noncompliance as follows: two sites had no monitoring visits completed, and two sites had only two of the three required monitoring visits completed. Repeat Finding No. Recommendation The District should implement internal controls over subrecipient monitoring to ensure that an adequate number of monitoring visits of each type are made during each year.

2024-001 50000 – Title I, Part A – Annual Report Card, High School Graduation Rate Federal Agency: U.S. Department of Education Pass-Through Entity: California Department of Education Program Name: Title I, Part A, Basic Grants Low-Income and Neglected and School Improvement Funding for LEAs Federal Financial Assistance Listing: 84.010 Compliance Requirement(s): N (Special Tests & Provisions) Annual Report Card, High School Graduation Rate Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or Specific Requirements Local Education Agencies (LEAs) must report graduation rate data for all public high schools at the school and LEA levels using the four-year adjusted cohort rate and, at an LEA’s discretion, one or more extended year adjusted cohort rates. Graduation rate data must be reported both in the aggregate and disaggregated by the subgroups in Section 1111(c)(2) of the Elementary and Secondary Education Act (ESEA), homeless status, status as a child in foster care using a four-year adjusted cohort graduation rate (and any extended-year adjusted cohort rates) (ESEA sections 1111(h)(1)(C)(iii)(II) and 8101(23), (25)(20 USC 6311(h)(1)(C)(iii)(II) and 7801(23), (25))). Written documentation must be maintained to remove a student from the cohort. Condition The District did not adequate maintain written documentation for two of the seven sampled students that were removed from the cohort. Cause The condition arose due to lack of sufficient internal controls over compliance related to removal of students from the cohort. Effect The District has not complied with the requirement to maintain written documentation to remove a student from the cohort. Questioned Costs None reported. Context/Sampling The condition was identified through review of supporting documentation for a sample of students who were identified as removed from the cohort on the California Longitudinal Pupil Achievement Data System (CALPADS) 15.2 Cohort Outcome report. Two of the seven sampled students identified as removed from the cohort on the CALPADS 15.2 Cohort Outcome report did not have adequate written documentation to support the removal of the students from the cohort. We determined the condition to be systematic for students transferring to schools within the United States. Repeat Finding Yes. See prior year finding 2023-001. Recommendation The District should ensure that they meet all of the requirements of ESEA. The District should revise their procedures to ensure that adequate written documentation for all students removed from the cohort is maintained and data inputted into the system is accurate. Corrective Action Plan and Views of Responsible Officials The District has revised its drop protocol documentation to provide a clearer, more streamlined process for staff, ensuring all required documentation is collected before processing drop codes in CALPADS. Additionally, comprehensive training has been provided to all staff responsible for this task to support accurate and efficient implementation.

2023-001 50000 – Title I, Part A – Annual Report Card, High School Graduation Rate Federal Program Affected Federal Agency: U.S. Department of Education Pass-Through Entity: California Department of Education Program Name: Title I, Part A, Basic Grants Low-Income and Neglected and School Improvement Funding for LEAs Assistance Listing Number: 84.010 Compliance Requirement: N (Special Tests & Provisions) Annual Report Card, High School Graduation Rate Criteria or Specific Requirements Local Education Agencies (LEAs) must report graduation rate data for all public high schools at the school and LEA levels using the four-year adjusted cohort rate and, at an LEA’s discretion, one or more extended-year adjusted cohort rates. Graduation rate data must be reported both in the aggregate and disaggregated by the subgroups in Section 1111(c)(2) of the Elementary and Secondary Education Act (ESEA), homeless status, status as a child in foster care using a four-year adjusted cohort graduation rate (and any extended-year adjusted cohort rates) (ESEA sections 1111(h)(1)(C)(iii)(II) and 8101(23), (25)(20 USC 6311(h)(1)(C)(iii)(II) and 7801(23), (25))). Written documentation must be maintained to remove a student from the cohort. Condition The District did not adequate maintain written documentation for five of the nine sampled students that were removed from the cohort. Questioned Costs There are no questioned costs associated with the condition identified. Context The condition was identified through review of supporting documentation for a sample of students who were identified as removed from the cohort on the California Longitudinal Pupil Achievement Data System (CALPADS) 15.2 Cohort Outcome report. Five of the nine sampled students identified as removed from the cohort on the CALPADS 15.2 Cohort Outcome report did not have adequate written documentation to support the removal of the students from the cohort. We determined the condition to be systematic for students transferring to schools within the United States. Effect The District has not complied with the requirement to maintain written documentation to remove a student from the cohort. Cause The condition arose due to lack of sufficient internal controls over compliance related to removal of students from the cohort. For students transferring to other schools within the United States, the District was not aware of the requirement to maintain documentation from the receiving school regarding the transfer. Repeat Finding No. Recommendation The District should ensure that they meet all of the requirements of ESEA. The District should revise their procedures to ensure that adequate written documentation for all students removed from the cohort is maintained and data inputted into the system is accurate. Corrective Action Plan and Views of Responsible Officials The District will revisit the drop protocols with staff to ensure that all required documentation is on file prior to processing drop code in the calpads.