To ensure the reliability of the ConApp database fields related to the number of students enrolled at the school level, the number of those enrolled students who are eligible to receive free meals, and the number of those students who are eligible to receive reduced-price meals, Education should modify its ConApp database instructions to require local educational agencies and direct-funded charter schools to retain their documentation supporting the three data fields for a specified period of time.
Education modified its ConApp instructions to require local educational agencies and direct-funded charter schools to retain documentation supporting reported data in accordance with state and federal records retention requirements. The clause requires each recipient of federal funds to maintain records that will facilitate an effective financial or programmatic audit for three years after the completion of the activity for which the funds are used. (2012-406, p. 52)
To ensure the reliability of the ConApp database fields related to the number of students enrolled at the school level, the number of those enrolled students who are eligible to receive free meals, and the number of those students who are eligible to receive reduced-price meals, Education should establish an internal control process such as a systematic review of a sample of the local educational agencies' and direct-funded charter schools' supporting documentation.
Education considers this recommendation fully implemented. To ensure the reliability of the ConApp database fields, in fiscal year 2013-14, Education established an internal control process in which a systemic review has been incorporated in the Audit Guide requiring local educational agencies' and direct-funded charter schools' auditors to verify student count data. The 2013-14 and 2014-15 Audit Guide can be located on the Education Audit Appeals Panel website at: www.eaap.ca.gov.
Commencing in 2012-13, Education no longer collects the count of students eligible for Free or Reduced Price Meals in the ConApp. Education has transitioned to relying on the California Pupil Achievement Data System (CALPADS) as the source for these counts. CALPADS student count data can be verified by requiring the local educational agencies to provide supporting documentation. To establish a systematic review process, Education is working to incorporate audit procedures to verify student count data in the audit guide.
Education has not yet fully implemented this recommendation. Education states it will now rely on CALPADS to collect information on the number of students who are eligible to receive free or reduced-price meals. However, Education has not updated its audit guide to include audit procedures needed to verify the student information at the local educational agencies. Further, as part of its internal control processes, Education has not conducted a systematic review of a sample of the local educational agencies and direct-funded charter schools' supporting documentation.
Effective fiscal year 2011-12, the California Department of Education (CDE) revised its process to collect and verify enrollment and free and reduced price meal (FRPM) data. The FRPM data is now collected at the student-level through the California Longitudinal Pupil Achievement Data System (CALPADS) instead of aggregate data collected through the Consolidated Application (ConApp). CALPADS collects the FRPM data concurrently with the official enrollment data as part of the CALPADS Fall 1 Data Submission. All public schools, including charter schools, report the data as of the California Basic Educational Data System (CBEDS) Information Day which is the first Wednesday of each October.
Beginning in October 2012, CALPADS will provide a specific aggregate report within the system to assist LEAs in determining and certifying accurate data submission. CALPADS already contains numerous internal data checks to ensure data quality. For example, one internal data check ensures that the same student is not enrolled in two different schools on the same day. Another internal data check ensures that a school's FRPM count does not exceed the official enrollment for that school.
Provision 2 and Provision 3 schools not required to collect and report student-level data each year continue to report data through the ConApp. The CDE added an error check to the ConApp to ensure that a school's FRPM count does not exceed the official enrollment for that school as reported to CALPADS.
To ensure the accuracy of the CNIPS database, Education should direct the school food authorities to establish internal control procedures to ensure the accuracy of the application information they enter into the CNIPS database.
Educations CNIPS application includes a certification check box that school food authorities must check in order to submit the application. In addition, Education posted a notice on the first screen of the CNIPS advising sponsors of their responsibility to ensure that they report accurate information. Education also stated that beginning with the 201112 school year it will further ensure the accuracy of the application information by including a clause in the annual instructions to remind school food authorities of their responsibility to ensure that they report accurate CNIPS information, to clarify that charter schools be identified as such and not as public schools, and to suggest that a second person review the information for accuracy before the school food authorities submit the information to Education. (2012-406, p. 52)
To ensure the accuracy of the CNIPS database, Education should direct nutrition services to modify the tool used to review a sample of the school food authorities schools to include a procedure for verifying the accuracy of the CDS code and site type reflected on the schools applications.
Educations Nutrition Services Division, Data Management Unit, has a procedure in place to run a query every month that identifies charter schools and public schools that are not displaying CDS codes in the CNIPS database. In addition, the query ensures the name and address data in the CNIPS database matches the information on the Charter School Web site and in the online Public School Directory. Educations staff are to resolve any discrepancies. (2012-406, p. 53)
To ensure that it maximizes the benefits from the State's investment in the CNIPS database, Education should require the school food authorities to submit a monthly Claim for Reimbursement for each site under their jurisdiction in addition to their consolidated claims.
Beginning with the July 2012 claims for reimbursement, the CDE required all School Food Authorities (SFA) to be set at site level reporting in the Child Nutrition Information and Payment System (CNIPS).
To ensure that it maximizes the benefits from the State's investment in the CNIPS database, Education should establish a timeline for the school food authorities to comply with the requirement.
On February 21, 2012, the CDE issued the enclosed management bulletin delineating the timeline for the school food authorities to comply with the site level reporting requirement. The management bulletin is also available on CDE's Web page at http://www.cde.ca.gov/ls/nu/sn/mbnsdsnp042012.asp.
Agency responses received after June 2013 are posted verbatim.