WESTMINSTER SCHOOL DISTRICT

Child Nutrition Cluster Assistance Listing No: 10.553 x 10.555 U.S. Department of Agriculture California Department of Education Repeat Finding? No Criteria: Code of Federal Regulations, 7 CFR sections 210.8, 220.11, 2015.10 and 225.15(c), require that monthly claims for reimbursement for meals and snacks served to eligible students be submitted within 60 days following the last day of the month covered by the claim. In conjunction each month’s claim for reimbursement and all data used in the claims review process must be maintained on file. Condition: During our testing of controls over claims for reimbursement, we discovered data entry errors in the District’s reporting of the number of meals served. Cause: The Child Nutrition department lacked a review procedure to ensure that consolidated meals are correct prior to reporting the number of meals served into the CNIPs database. Context: This deficiency was noted in seven months out of the school year. Effect: This resulted in the District being under-reimbursed by roughly $1,022. Recommendation: We recommend that the District develop and implement procedures to ensure that the meals served and reported on the CNIPS claims are accurate. This will ensure that the District is properly reimbursed at the time of submission. Views of Responsible Officials: Nutrition Services site staff implemented a new software system, Titan, in the 2023-2024 school year. Continued staff training on the reporting capabilities has been implemented. Nutrition Services site staff will run report on meals served and will turn in monthly to Nutrition Services office staff. Two members of Nutrition Services office staff will verify the number of meals served match the number of meals reported in Titan software system. Nutrition Services administrative staff will verify all meal counts prior to final CNIPS submittal

Nutrition Services staff process will run as follows: 1. NS Kitchen Staff: Ensure accurate daily meal count recording and initial review. 2. Intermediate Account Clerk: Perform detailed reconciliations and edit checks. 3. NS Account Technician: Reviews and verifies the final reports for compliance. This process will be overseen by the Director and or Assistant Director, Nutrition Services. This procedure will allow for accurate recording, reporting and verifying of meal counts.

The following finding represents a significant deficiency and instance of noncompliance that is required to be reported by the Uniform Guidance. The finding has been coded as follows: Five Digit Code AB 3627 Finding Type 50000 Federal Compliance 2023‐003 50000 – Reporting (Significant Deficiency, Noncompliance) Federal Program Affected Program Names: COVID‐19: Elementary and Secondary School Emergency Relief Funds Assistance Listing Number: 84.425D & 84.425U Pass‐Through Entity: California Department of Education (CDE) Federal Agency: U.S. Department of Education Criteria or Specific Requirements Local education agencies must comply with all reporting requirements that the Department of Education may reasonably require. Section 15011 of Division B of the Coronavirus Aid, Relief, and Economic Security (CARES) Act requires that a grantee submit quarterly and annual reports. ESSER Funds awarded under the American Rescue Plan (ARP) Act of 2021 are subject to the same quarterly and annual reporting requirements. Condition The District reported budgeted expenditures for the COVID‐19: Elementary and Secondary School Emergency Relief III (ESSER III) Fund program and the Elementary and Secondary School Emergency Relief III (ESSER III) Fund: Learning Loss program instead of actual expenditures to the California Department of Education for these programs. In addition, the District was unable to provide supporting documents that agreed to the full‐time equivalent (FTE) positions reported to the California Department of Education. 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. Effect The District has overreported expenditures for these programs and, as such, is not in compliance with the reporting requirements for the program. In addition, the District is not in compliance with maintaining supporting documents pertinent to a Federal award. Cause The identified condition appears to have materialized due to insufficient procedures related to the review process and retention of financial records. Repeat Finding No. Recommendation The District should ensure that all federal expenditures are reported on their quarterly or annual reports based on actual general ledger expenditures for the time period being reported on. In addition, the District should ensure that all federal reports are supported by supporting documentation. These records should be maintained for a period of three years from the date of submission of the reports to the awarding agency or pass‐through entity.

Business Services Staff will ensure that financial account balances are thoroughly reviewed and supported by appropriate documentation. Prior to any report submittal, an administrator will verify documentation fo raccuracy. This will create a system for verification of supporting records that will facilitate accurate tracking of balances during reporting periods.

2021-002 Code 50000 (Material Weakness, Noncompliance) Federal Program Affected COVID-19 - Coronavirus Relief Fund: Learning Loss Mitigation Assistance Listing Number: 21.019 Pass-Through Entity: California Department of Education Federal Agency: U.S. Department of the Treasury Criteria or Specific Requirements Section 110(d) of SB 98, as amended by Section 59 of SB 820, as amended by Section 4 of AB 86, and as assured to by the District prior to receipt of funds requires the District to complete quarterly expenditure reports for the Coronavirus Relief Funds (CRF). The report is required to be completed using the ten categories of allowable uses of the funds. The submission of the report should be supported by the data in the District?s accounting system. Condition During our testing over reporting of the CRF awards, we noted that the District completed the required reports; however, the District was not able to provide general ledger detail that supports the expenditures report for each of the ten allowable categories. Questioned Costs There were no questioned costs identified. Context The condition was identified as a result of inquiry with the District's Business Services personnel and through review of supporting documents. Effect The District did not comply with the reporting requirements as specified by the California Department of Education. Cause The condition identified appears to have materialized due to turnover in management in the Business Services department. The required reports were completed by external consultants and the District did not have the supporting documentation prepared by the consultants. Repeat Finding No. Recommendation The District should review the procedures related to required reporting requirements of federal awards and ensure detailed documentation is retained that supports the completed reports. Corrective Action Plan and Views of Responsible Official The District will require source documentation for reports be saved on the district shared file server. This will allow the Business Services department to research and verify the correct completion of reports.

The District will require source documentation for reports be saved on the district shared file server. This will allow the Business Services department to research and verify the correct completion of reports.