WOODLAND PARK SCHOOL DISTRICT RE-2

Eligibility for the Child Nutrition Cluster

Federal program: ALN 10.553, 10.555 Child Nutrition Cluster Federal agency: U.S. Department of Agriculture Pass-through entity: Colorado Department of Education

Criteria: School food authorities must maintain accurate records supporting eligibility determinations for free, reduced‑price, and paid meals, and claims for reimbursement must be based on eligible children and correct eligibility categories. Eligibility determinations and records must be made and maintained.

Condition: During our testing of income‑based free meal applications for the Child Nutrition Cluster, we identified five instances in which the same approved free‑meal application information was entered more than once in the District’s eligibility records (duplicate eligibility entries for the same household or student). These duplicate entries resulted in multiple eligibility records in the meal accounting system for a single underlying application rather than one unduplicated record per student or household. The underlying documentation for these cases supported free eligibility, but the eligibility records themselves were not maintained in an accurate manner.

Cause: The District does not have adequate controls to prevent or detect duplicate eligibility entries when processing and maintaining free and reduced‑price meal applications in the food service software. There is no routine review designed specifically to identify and resolve duplicate records in the eligibility file.

Effect: Duplicate eligibility entries increase the risk of errors in eligibility reporting, verification processes, or other analyses that rely on counts of free or reduced‑price eligible students, and of potential misstatement in the eligibility data used to support meal claims, even though our testing did not identify unsupported eligibility based on the underlying applications. These weaknesses in eligibility record maintenance represent a significant deficiency in internal control over compliance with the Eligibility requirements for the Child Nutrition Cluster.

Questioned costs: None noted. The underlying applications for the duplicate entries supported free eligibility. However, the condition reflects a control deficiency in how eligibility records are maintained.

Context: We tested a sample of income‑based free applications as part of our Eligibility (E) procedures for the Child Nutrition Cluster. Five of the sampled items represented duplicate entries in the eligibility records for the same student. The District was able to reconcile the overall eligibility roster to current‑year enrollment, so this finding is limited to the accuracy and duplication of entries in the eligibility file rather than the completeness of the population.

Recommendation: We recommend that the District implement system edits or procedural checks to prevent duplicate eligibility entries for the same student (for example, by using unique student identifiers and warning messages when a duplicate is entered), periodically run and review reports that identify potential duplicate eligibility records (such as those with the same student ID, name, and date of birth) and investigate and clear any duplicates identified, and provide training to Nutrition Services staff responsible for entering and maintaining eligibility determinations on the importance of maintaining an unduplicated eligibility file and the procedures for correcting errors.

Views of responsible officials and planned corrective action: Management agrees with this finding. The District acknowledges that five duplicate eligibility entries were identified in its meal accounting records, and that while the underlying applications supported free eligibility, the eligibility records were not maintained in an accurate, unduplicated manner. To correct this condition, the District will implement system edits or procedural checks designed to prevent duplicate eligibility entries for the same student, including the use of unique student identifiers and warning prompts when a potential duplicate is entered. Nutrition Services will periodically run and review reports that identify potential duplicate records, such as those sharing the same student ID, name, and date of birth, and will investigate and clear any duplicates identified. The District will also provide training to Nutrition Services staff responsible for entering and maintaining eligibility determinations on maintaining an unduplicated eligibility file and on the procedures for correcting errors.

2024-016 Reporting for Education Stabilization Fund

Federal program: ALN 84.425U&D Education Stabilization Fund Federal agency: U.S. Department of Education Pass-through entity: Colorado Department of Education

Criteria: ESSER grantees must submit an annual performance report with data on expenditures, planned expenditures, subrecipients, and uses of funds, including for mandatory reservations. An LEA is required to submit certain annual financial reports to its SEA on an annual basis.

Condition: The District did not timely file the annual financial report and the filed report did not agree to the general ledger. The District did not file its annual financial report for grant 4414 until February of 2025. The District has not filed its annual financial report for the ARP-Mentor grant.

Cause: As reported in finding 2024-010 the District does not have staff with the skills, knowledge, or resources to properly report on grants that are obtained through CDE .

Effect: There is a material weakness in internal controls over grant reporting to CDE, the District’s SEA. Additionally, material non-compliance exists for Reporting due to the lack of reporting to the SEA.

Questioned costs: None noted.

Context: Testing was performed over the total population of required reports. Statistical sampling was not used.

Recommendation: We recommend that management ensures that there is a system of controls in place that requires grant reporting to be done timely and accurately. Additionally, we recommend that the District hire an experienced grant accountant to oversee grant accounting.

Views of responsible officials and planned corrective action: Grant accounting was performed by a part-time contractor who left at beginning of the fiscal year. The CFO absorbed those accounting tasks within the remaining finance team. Failure to file ESSER reporting timely was communicated by Superintendent to CFO when the CDE sent notice, but reporting was not completed before dismissal. Management will ensure controls are in place to confirm grant accounting and reporting are reviewed, completed, correct, and timely. Management will further ensure grant accounting expertise is again employed or contracted in the district.