School Meal Programs:

Improved Reviews, Federal Guidance, and Data Collection Needed to Address Counting and Claiming Errors

GAO-09-814: Published: Sep 9, 2009. Publicly Released: Sep 22, 2009.

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In fiscal year 2008, the National School Lunch Program and School Breakfast Program provided meals to 30.9 million and 10.5 million children, respectively. Recently, the U.S. Department of Agriculture (USDA) issued the first estimate of improper payments due to meal counting and claiming errors in these programs, which was approximately $860 million (8.6 percent of federal program reimbursements) in school year 2005-2006. These errors include: (1) cashier errors, such as those made in determining if a meal meets the federal menu planning and nutrition requirements (meal counting), and (2) aggregation errors made when officials count and total meals for federal reimbursement (meal claiming). GAO was asked to review (1) actions taken by states and school food authorities (SFA) to identify and address meal counting and claiming errors; and (2) actions taken by USDA to help states and SFAs identify and address meal counting and claiming errors. GAO's steps included analyzing data on state administrative reviews of SFAs; surveying all states; conducting site visits; and interviewing federal, state, and SFA officials.

Although states and SFAs conduct program integrity reviews of the school meal programs, gaps in federal requirements for these reviews limit their effectiveness at identifying meal counting and claiming errors. States and SFAs are generally not required to review the School Breakfast Program, and 21 states reported through GAO's survey that they do not review the breakfast program. However, USDA estimates that the percentage of meal counting and claiming errors is higher in the breakfast program than the lunch program. Further, some states reported that SFA reviews of the meal programs are ineffective at identifying and reducing errors, which may be due, in part, to the self-assessment design of these reviews. When state and SFA reviews identify errors, meal counting and claiming errors persist. For example, in several SFAs that GAO visited, the same errors were identified during consecutive reviews. States and SFAs identified multiple factors that hinder efforts to address these errors, such as staff turnover, inadequate training, and school policies that complicate meal service. USDA has taken some actions to improve state reviews of SFAs, but it has not directly focused on oversight of meal counting and claiming. USDA recently provided new review forms and nationwide training to strengthen state reviews and also simplified the application process for state grants to conduct additional reviews of SFAs. However, USDA has not targeted its oversight efforts to identify or address meal counting and claiming errors. For example, USDA regional offices' reviews of state administration of the school meal programs do not focus on these errors, and some regional officials could not provide information on the extent of these errors in the states they oversee. USDA also has not updated its meal counting and claiming manual since it was first issued in 1991. Further, while USDA collects annual data on findings from state reviews of SFAs, the agency has not used these data for oversight purposes or to assess risks associated with meal counting and claiming errors.

Recommendations for Executive Action

  1. Status: Closed - Implemented

    Comments: In FY 2011, the Department of Agriculture reported (USDA) that it is amenable to exploring the feasibility of requiring school food authorities (SFAs) to conduct third-party annual onsite reviews, although they expressed concern about the cost that would be imposed on SFAs by such a requirement. USDA explored the feasibility of implementing this recommendation. They determined that it was not feasible to implement and federal law does not mandate such a requirement.

    Recommendation: To help states and SFAs improve their ability to identify and address meal counting and claiming errors, the Secretary of Agriculture should explore the feasibility of requiring SFAs to conduct third-party annual on-site reviews to ensure independence.

    Agency Affected: Department of Agriculture

  2. Status: Closed - Implemented

    Comments: On January 24, 2011, the Department of Agriculture issued Policy Memo SP-14-2011, which provides a prototype checklist for school food authorities to use in conducting annual onsite reviews. This checklist provides the minimum requirements for assessing counting and claiming procedures, system accuracy, and point of service.

    Recommendation: To help states and SFAs improve their ability to identify and address meal counting and claiming errors, the Secretary of Agriculture should develop additional guidance and technical assistance for federally-required SFA annual on-site reviews. For example, USDA, through its Web site, could provide a model form to be used for on-site reviews that indicates the aspects of meal counting and claiming procedures to review, or the Department could work through the National Food Service Management Institute or another organization to provide SFAs with technical assistance aimed at improving the quality of on-site reviews.

    Agency Affected: Department of Agriculture

  3. Status: Closed - Implemented

    Comments: The Department of Agriculture provided updated guidance on meal counting and claiming procedures to program administrators in the new version of the Coordinated Review Effort (CRE) Manual. The new version of the Manual, which complements CRE forms and instructions that were issued in July 2008, was issued in January 2012.

    Recommendation: To help states and SFAs improve their ability to identify and address meal counting and claiming errors, the Secretary of Agriculture should update the 1991 USDA manual on meal counting and claiming procedures to ensure that current guidance is reflected.

    Agency Affected: Department of Agriculture

  4. Status: Closed - Implemented

    Comments: In April 2010, the Department of Agriculture issued a policy memo to regional and state directors of school nutrition programs reminding states of their general obligation to oversee the School Breakfast Program, indicating methods for accomplishing this oversight, and requesting that states emphasize to School Food Authorities (SFAs) the need to provide oversight of their schools that participate in the program. In FY 2011, Congress enacted the Healthy, Hunger-Free Kids Act (P.L. 111-296), which required the Department to establish an accountability system for states to ensure that SFAs participating in the School Breakfast Program comply with regulations, including participating in monitoring once every three years. In spring 2013, USDA provided training to all states on the new administrative review process, which includes reviews of the School Breakfast Program in all SFAs providing the program.

    Recommendation: To help states and SFAs improve their ability to identify and address meal counting and claiming errors, the Secretary of Agriculture should require states to include the School Breakfast Program in their state administrative reviews of SFAs and require SFAs to include this program in their annual on-site reviews.

    Agency Affected: Department of Agriculture

  5. Status: Closed - Implemented

    Comments: Since 2011, the Department of Agriculture has issued annual reports on state administrative review findings, which include analyses of program errors related to meal counting and claiming. In addition, as of spring 2013, a Department workgroup is in the process of assessing overall data collection efforts for the school meal programs to ensure that the most appropriate data is reported to states and to USDA to ensure program compliance, assess risks, and target assistance. As the new state administrative review system required by the Healthy, Hunger-Free Kids Act of 2010 (P.L. 111-296) is implemented over the next two school years, a new version of the form on which review findings are reported to the Department will be implemented as well. The Department reported that the revised form will include identification of SFAs reviewed in each year and information on School Breakfast Program reviews.

    Recommendation: To assist federal efforts to target resources to states and SFAs at the greatest risk for these errors, the Secretary of Agriculture should develop procedures for using state administrative review data reported to Food and Nutrition Service (FNS) to assess risks and target oversight efforts associated with meal counting and claiming errors, and modify the FNS form on which states report the data so that it includes identification of which SFAs were reviewed each year and information from School Breakfast Program reviews.

    Agency Affected: Department of Agriculture

 

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