VICTOR VALLEY UNION HIGH SCHOOL DISTRICTLocal Government

Finding 2024-009: Reporting (50000) Assistance Listing # 10.553, 10.555 – U.S. Department of Agriculture, California Department of Education, Child Nutrition Cluster Repeat Finding? No Criteria: SFAs and sponsors 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 (7 CFR sections 210.8, 220.11, 215.10, and 225.15(c)). Each month’s claim for reimbursement and all data used in the claims review process must be maintained on file. Accurate records must be maintained justifying all meals claimed. Failure to maintain such records may be grounds for denial of reimbursement for meals served and/or administrative costs claimed during the period covered by the records in question. Records are required to be retained for a period of three years after submission of the final Claim for Reimbursement for the fiscal year. Condition: The District uses a point-of-sale system to track lunches and breakfasts served as well as how many meals in each category are free, reduced or paid. From August 2023 to September 2023, one school site’s meals were coded to paid in the point of sales system, but the District applied a rate to the total meals to arbitrarily determine how many meals to report as free, reduced or paid. Cause: Lack of oversight procedures to ensure that data being entered into CNIPS from the point of sales system is accurate. Context: Discrepancies were noted for August 2023 and September 2023, the two months tested. Effect: Meals reported could not be reconciled to total meals served. This could cause inaccurately claimed meal counts and inappropriate reimbursement. Questioned Cost: There is insufficient documentation to determine the total meals served which have been reported as free, reduced, or paid. As a result, we were unable to determine the questioned cost amount. Recommendation: We recommend that all meal service records be reconciled against claim forms on a monthly basis. Views of Responsible Officials: Nutrition Services has implemented a new procedure of checks and balances before submitting monthly meal claims in CNIPS. The Director generates the monthly meal count report from our point of sales program, MealTime, for each site. The meal count numbers are then entered into CNIPS. Before submission the numbers are reconciled by the Office Assistant III to ensure accuracy.

Federal Program Affected Program Name: COVID-19: Elementary and Secondary School Emergency Relief II (ESSER II) Fund Assistance Listing Number: 84.425D Pass-Through Entity: California Department of Education (CDE) Federal Agency: U.S. Department of Education Criteria or Specific Requirements The Uniform Guidance 2 CFR ? 200.430(i)(1)(viii) states that budget estimates alone may not be used to allocate compensation charges to Federal awards. When using budget estimates for interim accounting purposes, entities must also establish internal controls to identify significant changes in corresponding work activities and review and adjust after-the-fact interim charges to reflect accurate, allowable, and properly allocated charges. Condition The District charged multi-funded employees based on budget estimates. There was not a system of monitoring and internal controls to identify significant changes in corresponding work activities nor to adjust budgeted charges to reflect the actual percentage of work performed for the grant. Cause The condition identified appears to be due to lack of sufficient internal controls to monitor and adjust after-the-fact employee budgeted time to actual time reflected on approved employee time certifications.

Federal Program Affected Program Name: COVID-19: Emergency Connectivity Fund (ECF) Program Assistance Listing Number: 32.009 Pass-Through Entity: N/A ? Direct Award Federal Agency: Federal Communications Commission Criteria or Specific Requirements In accordance with Federal Communications Commission (FCC) Report and Order 21-58 paragraphs 116-118, COVID-19 Emergency Connectivity Fund (ECF) Program participants are required to maintain asset and service inventories of the devices and services purchased with ECF Program support. Asset inventories are required to contain the following elements: (a) device type, (b) device make/model, (c) equipment serial number, (d) the name of the person to whom the device was provided, and (e) the dates the device was loaned out and returned to the school. In accordance with FCC Report and Order 21-58 paragraph 5, ECF Program support shall be used by schools to meet the otherwise unmet connectivity needs of students and school staff during the COVID-19 pandemic. In accordance with FCC Report and Order 21-58 paragraph 54, ECF Program support shall not be used to fund more than one connected device and more than one Wi-Fi hotspot per students or school staff member during the COVID-19 emergency period. Condition The District did not maintain adequate asset inventories for devices purchased using ECF support, as inventory records do not contain all of the aforementioned required elements. The District was not able to substantiate unmet need for all devices for which reimbursement was requested. Cause The condition identified appears to be due to lack of sufficient internal controls to ensure that program requirements are met.

Federal Program Affected Program Name: COVID-19: Emergency Connectivity Fund (ECF) Program Assistance Listing Number: 32.009 Pass-Through Entity: N/A ? Direct Award Federal Agency: Federal Communications Commission Criteria or Specific Requirements In accordance with 2 CFR ?200.214 of the Uniform Guidance, non-Federal entities must verify that vendors are nor suspended or debarred prior to entering into covered transactions. Condition The District did not maintain documentation to demonstrate that they verified whether a vendor was suspended or debarred prior to entering into a covered transaction. Cause The condition identified appears to be due to lack of sufficient internal controls to ensure that program requirements are met.

2020-001 Code 50000 Federal Program Affected Program Name: Title I, Part A, Basic Grants Low-Income and Neglected CFDA Number: 84.010 Pass-Through Entity: California Department of Education Federal Agency: U.S. Department of Education Criteria or Specific Requirements Per Title 34, Code of Federal Regulations, Part 200, Subpart A, Section 200.63(a), local education agencies (LEAs) must provide timely and meaningful consultations with appropriate officials of private schools. LEAs must be able to demonstrate that eligible private schools were contacted and notified of the opportunity to participate in the Title I, Part A program. Condition Through inquiry with District personnel, it appears that records were not maintained to demonstrate that all private schools had been contacted and notified of the opportunity to participate in the Title I, Part A program for the 2019-2020 school year. Questioned Costs There were no questioned costs identified. Context The condition was identified as a result of the auditor's inquiry with District personnel. Effect The District was not in compliance with Title 34, Code of Federal Regulations, Part 200, Subpart A, Section 200.63(a). Cause The condition identified appears to have materialized due to private school correspondence records not being maintained by the District for certain private schools for the 2019-2020 school year. Repeat Finding Yes Recommendation It is recommended that the District maintain private school correspondence records, minutes from meetings with private school representatives, and written affirmations from private school officials to demonstrate compliance with provisions under Title 34, Code of Federal Regulations, Part 200, Subpart A, Section 200.63(a).

2019-002 50000 Federal Program Affected Program Name: Title II, Part A ? Supporting Effective Instruction CFDA Number: 84.367 Pass-Through Entity: California Department of Education Federal Agency: U.S. Department of Education Criteria or Specific Requirements Title 34, Code of Federal Regulations, Part 299, Section 299.6, requires that local education agencies (LEAs) provide timely and meaningful consultations with appropriate officials of private schools. LEAs must be able to demonstrate that eligible private schools were contacted and notified of the opportunity to participate in the Title II, Part A program. Condition Through inquiry with District personnel, it appears that records were not maintained to demonstrate that private schools had been contacted and notified of the opportunity to participate in the Title II, Part A program for the 2018-2019 school year. Questioned Costs There were no questioned costs identified. Context The condition was identified as a result of the auditor?s inquiry with District personnel. Effect The District was not in compliance with Title 34, Code of Federal Regulations, Part 299, Section 299.6. Cause The condition identified appears to have materialized due to private school correspondence records not being maintained by the District for the 2018-2019 school year.