STATE OF TENNESSEE DEPARTMENT OF HUMAN SERVICES

0048 Avon Lennox- ESY1425 Belle ForestCommunity School- SSLA0111 Community CenterBert Ferguson1480 Crump ES- SSLA0698 Havenview MSSCS Summer School1728 Getwell- SSLA0821 Kingsbury ES- MTRCamp0321 Knowledge QuestCollege Park0325 LaGoshen M B.Church- Summer Camp0351 Lily Roze Studios1825 Manassas HighSchool- SSLA1906 Memphis BusinessAcademy1914 MY- SBE SummerCamp1746 NeighborhoodChristian CenterRidgecrest1874 New BinghamptonAssociation Group1409 Northhaven ESSSLA0443 Northwest PrepAcademy0449 Olympic CareerTraining Institute- City ofMemphis0456 Park ServiceGaisman0460 Park ServicesCherokee0465 Park ServicesGooch Pool1892 Park ServicesWinridge1921 Park ServicesSouthside0516 ResurrectionCatholic School1845 SAOOM0558 St AugustineCatholic School-6 Lunch meals6/28/18V-1-5 Lunch meals6/26/18W-1-1 Lunch meal6/25/18B-2-13 Lunchmeals6/22/18G-2-4 Lunch meals6/13/18,6/19/186/20/18,6/29/18N-2-8 Lunch meals-32 Lunchmeals6/22/18I-26/18/18Q-2-6 Lunch meals6/15/18,6/25/186/29/18R-2-4 Lunch meals6/11/18,6/14/18S-2-1 Lunch meals6/6/18W-2-2 Lunch meals6/11/18Z-2-4 Lunch meals6/14/18, 6/20/18B-3-4 Lunch meals6/25/18Y-4-1 Lunch meal6/19/18F-3-1 Lunch meal6/20/18H-3-2 Lunch meals6/25/18,6/27/18M-3-4 Lunch meals6/29/18N-3-54 Lunchmeals6/14/18,6/26/18P-3-2 Lunch meals6/15/18,6/27/18R-3-21 Lunchmeals6/13/18,6/26/18,6/27/18S-3-1 Lunch meal6/11/18T-3-2 Lunch meals6/25/18V-3-1 Lunch meal6/14/18W-3 8 Lunch meal6/14/18,6/20/18Y-3-1 Lunch meal6/15/18Z-3-7 Lunch meal6/4/18,6/8/18C-47

0584 Street ReachJackson0588 Street ReachNational0590 Street ReachRosamond1897 T O. Fuller StateParkConservation/Preservation& Youth CareerReadiness0631 Unity Church of Godin Christ-Summer Camp1736 Vollentine- SSLA1737 W.H. BrewsterSSLA0649 Walden PointeApartments1482 Whitehaven ESSSLA1573 Whitehaven Library1739 Willow Oaks- SSLA0673 Winridge ESSummer School-2 Lunch meals6/29/18D-4-1 Lunch meal6/4/18E-4-2 Lunch meal6/5/18F-4-1 Lunch meal6/19/18H-4-1 Lunch meal6/19/18J-4-15 lunch meal6/19/18M-4-2 Lunch meals6/14/18N-4-3 Lunch meals6/19/180-4-1 Lunch meal6/13/18Q-4 4 Lunch meals-2 Lunch meals-13 /18,6/19/18,6/22/18,6/29/18R-4U-4V-4As a result, 233 lunch meals were disallowed.PM Supplement MealsSite1820 Two Steps AheadLearning1839 Montgomery Plaza0704 Knowledge QuestGaston CommunityCenter0715 World OvercomersOutreach Ministries0111 Community CenterBert Ferguson0107 Community CenterHollywood0116 Community CenterGlenview0121 Community CenterMcFarland0321 Knowledge Quest-Meals Allowed/DisallowedDates of Meal Allowance/DisallowanceExhibit-1 PM Snack6/6/18D-3 PM Snacks6/6/18N-4 PM Snacks6/26/18, 6/28/18K-1-14 PM Snacks6/6/18,6/13/18,6/18/18, 6/26/186/27/18T-1-2 PM Snacks6/22/18B-2-1 PM Snack-7 PM Snacks-6 PM Snack-1 PM Snack6/14/186/21/18, 6/22/186/12/18, 6/22/186/15/18A-2C-2D-2R-28

College Park0325 LaGoshen M B.Church- Summer Camp0736 New LifeCommunity OutreachSummer Camp1897 T O. Fuller StateParkConservation/Preservation & Youth CareerReadiness1794 The House ChurchMemphis- Athletic League-1 PM Snack6/13/18S-2-2 PM Snacks6/1/18J-3-19 PM Snacks6/22/18, 6/25/186/28/18H-4 1 PM Snack6/21/18I-4As a result, 60 PM Supplements were disallowed.This is a repeat finding from monitoring report dated October 13, 2017.CriteriaAccording to the USDA Administration Guide Summer Food Service Program 2016, pages66 and 184, meals must be counted at the actual point of service, i.e., meals are counted asthey are served, to ensure that an accurate count of meals served is obtained and reported.According to the USDA Administration Guide Summer Food Service Program 2016, pages139 and 184, all sponsors must use daily site records in order to document the number ofprogram meals they have served to children. The sponsor must provide all necessary recordsheets to the sites. Site supervisors are then responsible for keeping the records each day.They may have their monitors pick up site reports on designated days, or the sitesupervisors may be asked to mail the records to the sponsor’s office. When they collect thesite records, sponsors should check for the site supervisor’s signature.RecommendationThe Sponsor should ensure all site personnel complete and submit accurate meal countrecords which support the claim for reimbursement and sign before submission.3. The Sponsor did not ensure that feeding sites personnel sign all daily point of mealcount sheetsConditionThe Sponsor did not ensure that the daily point of service meal count sheets were signed byfeeding sites personnel. Several of the meal count sheets did not have the signature of thefeeding site supervisor Meals were disallowed if the point of service meal count sheet wasnot signed. Our review of the Sponsor's records revealed the following:9

Breakfast MealsSite0337 Lemoyne OwenCollege- Dream ofMemphis0306 Kate BondElementary (ImagineLearning Camp)1753 Cornerstone PrepDenver- Summer Camp1728 Getwell- SSLA1540 Great Expectations0698 Havenview MS- SCSSummer School1838 Lucie E. CampbellELOP0673 Windridge ESSummer SchoolMeals DisallowedDates of MealDisallowanceExhibit100 Breakfastmeals6/5/18F20 Breakfast meals6/28/18P-139 Breakfast meals613/18E-252 Breakfast meals6/11/18I-2278 Breakfastmeals196 Breakfastmeals6/6/18,6/7/18,6/8/18L-26/11/18N-260 Breakfast meals6/28/18Y-243 Breakfast meals6/4/18V-4As a result, 788 Breakfast meals were disallowed.Lunch MealsSiteMeals DisallowedDates of MealDisallowanceExhibit1839 Montgomery Plaza50 Lunch meals6/27/18N200 Lunch meals6/11/18,6/12/18A-250 Lunch meals6/15/18F-360 Lunch meals6/28/18Y-2150 Lunch meals6/11/18,6/12/18C-4150 Lunch meals6/20/18I-40107 Community CenterHollywood1824 Craigmont HighSSLA1838 Lucie E. CampbellELOP0558 St. AugustineCatholic School1794 The House ChurchMemphis- Athletic LeagueAs a result, 660 Lunch meals were disallowed.10

PM SupplementsSite1839 Montgomery Plaza0715 World OvercomersOutreach Ministries0107 Community CenterHollywood0121 Community CenterMcFarland223 Girls Inc of MemphisMeals Disallowed50 PMSupplements150 PMSupplements200 PMSupplements150 PMSupplements50 PMSupplementsDates of /12/18A-26/28/18D-26/29/18J-2As a result, 600 PM Supplements were disallowed.CriteriaAccording to the USDA Administration Guide Summer Food Service Program 2016, pages139 and 184, all sponsors must use daily site records in order to document the number ofprogram meals they have served to children. The sponsor must provide all necessary recordsheets to the sites. Site supervisors are then responsible for keeping the records each day.They may have their monitors pick up site reports on designated days, or the sitesupervisors may be asked to mail the records to the sponsor’s office. When they collect thesite records, sponsors should check for the site supervisor’s signature.This is a repeat finding from monitoring report dated October 13, 2017.RecommendationThe Sponsor should ensure Point of Service meal count sheets are signed by the feedingsite personnel prior to submitting the claim for reimbursement.4. The Sponsor reported the number of meals as served during a monitoring visitincorrectlyConditionThe Sponsor did not claim the correct number of meals observed by the monitors at thefollowing feeding sites:Breakfast MealsSiteDate MealObservedReportedObserved0688 Ridgeway LearningCenter6/5/18110112MealsAllowed/Disallowed 2BreakfastMealsExhibitJ11

0741 Longstreet UnitedMethodist Church- ProjectTransformation TN6/6/1841490678 Y-CAP-YMCA6/7/18155 8BreakfastMeals-10BreakfastMealsPZAs a result, no Breakfast meals were over or under reported due to netting.Lunch MealsSite1475 Shelby MetroFootball1769 Riverview Pre K8(Read to be Ready)1779 Divine Intervention@Raleigh Egypt HighPre- EmploymentTransition ServicesDate 185513MealsAllowed/Disallowed 72 Lunchmeals 19 LunchmealsExhibitGQ-42 LunchmealsB-1As a result, 49 Lunch meals were underreported.SupplementsSite Name1388 Miriam DaycareSummer Camp1626 Highland HillApartments1843 Ready to be ReadyDate 182120MealsAllowed/Disallowed 1 PMSnack 7 PMSnacks-1 PM SnackExhibitOJ-1M-1As a result, seven PM Supplements were underreported.This is a repeat finding from monitoring report dated October 13, 2017.CriteriaTitle 7o f the Code o f Federal Regulations, Section 225.9 (d) (5) states, ". In submitting aclaim for reimbursement, each sponsor shall certify that the claim is correct and that recordsare available to support this claim. .”According to the USDA Administration Guide Summer Food Service Program 2016, pages66 and 184, meals must be counted at the actual point of service, i.e., meals are counted asthey are served, to ensure that an accurate count of meals served is obtained and reported.RecommendationSponsors should ensure that only actual meals served are claimed for reimbursement.12

5. The Sponsor claimed meals that exceeded the feeding site’s approved level for mealserviceConditionOur review of the Sponsor’s records revealed the following:Site-1803 Gardenview Elementary-Summer School approved level: 350 (See Exhibit 8Number of mealsreported385 Lunches369 Lunches370 Lunches372 Lunches376 Lunches369 Lunches363 Lunches354 Lunches375 Lunches354 Lunches356 Lunches362 Lunches358 Lunches354 LunchesNumber of meals disallowed-35 Lunches-19 Lunches-20 Lunches-22 Lunches-26 Lunches-19 Lunches-13 Lunches-4 Lunches-25 Lunches-4 Lunches-6 Lunches-12 Lunches-8 Lunches-4 LunchesSite-1795 Dunbar Elem-Summer Camp approved level: 175 (See Exhibit X-4)Date6/1/186/4/186/5/186/6/186/7/186/8/18Number of mealsreported200 Lunches200 Lunches200 Lunches200 Lunches200 Lunches200 LunchesNumber of meals unchesLunchesLunchesSite-1766 L.Y.E Academy approved level: 100 (See Exhibit mber of mealsreported111 Breakfasts110 Breakfasts198 Breakfasts129 Breakfasts111 Breakfasts110 BreakfastsNumber of meals eakfastsBreakfastsBreakfastsBreakfasts13

Site- 673 Winridge ES- Summer School approved level: 400 (See Exhibit V-4)Number of mealsDateNumber of meals disallowedreported6/6/18465 Breakfasts-65 Breakfasts6/7/18477 Breakfasts-77 Breakfasts6/8/18485 Breakfasts-85 Breakfasts6/11/18440 Breakfasts-40 Breakfasts6/12/18445 Breakfasts-45 Breakfasts6/13/18452 Breakfasts-52 Breakfasts6/14/18407 Breakfasts-7 Breakfasts6/15/18444 Breakfasts-44 Breakfasts6/18/18430 Breakfasts-30 Breakfasts6/20/18410 Breakfasts-10 Breakfasts6/21/18409 Breakfasts-9 Breakfasts6/22/18410 Breakfasts-10 Breakfasts6/25/18415 Breakfasts-15 Breakfasts6/26/18402 Breakfasts-2 Breakfasts6/29/18405 Breakfasts-5 Breakfasts6/6/18464 Lunches-64 Lunches6/7/18503 Lunches-103 Lunches6/8/18477 Lunches-77 Lunches6/11/18440 Lunches-39 Lunches6/12/18437 Lunches-37 Lunches6/13/18439 Lunches-37 Lunches6/14/18436 Lunches-36 Lunches6/15/18445 Lunches-45 Lunches6/18/18409 Lunches-9 Lunches6/19/18414 Lunches-14 Lunches6/20/18427 Lunches-27 Lunches6/21/18427 Lunches-27 Lunches6/22/18419 Lunches-19 Lunches6/25/18-19 Lunches419 Lunches6/26/18427 Lunches-27 Lunches6/27/18424 Lunches-24 Lunches6/28/18407 Lunches-7 Lunches6/29/18403 Lunches-3 LunchesAs a result, 644 Breakfast meals and 981 Lunch meals were disallowed.CriteriaTitle 7 o f the Code o f Federal Regulations, Section 225.6 (d)(2) states, “the State agencyshall establish for each meal service an approved level for the maximum number ofchildren’s meals which may be served under the Program.”According to the USDA Administration Guide Summer Food Service Program 2016, page133, “Sponsors may claim reimbursement only for those meals that meet SFSP14

requirements. Reimbursement may not be claimed for meals in excess of the site’sapproved level of meal service.”RecommendationThe Sponsor should ensure that meals are not claimed above the maximum approved levelof meal service. The Sponsor should request from Food Program management approval forincreasing the number of participants.6. Meals were served outside of the Sponsor’s approved meal service timeConditionDuring our onsite reviews to observe meal service at several feeding sites, we observedmeals that were served outside of the approved meal service time. We did not disallowmeals that we observed serving outside the approved meal service time and the mealcomponents were in compliance; however, some feeding sites are listed for observationpurposes and should only be served during the approved meal service time. The followingfeeding sites served meals outside of the approved meal service time:0596 Summer Enrichment Camp The approved meal service time for Breakfast was 10 a m. to 10:30 am. A monitorarrived on June 5, 2018, at approximately 9:35 am and observed meals being servedbetween 9:35 am through 10:00 am. No meals were disallowed due to meals beingobserved.0729 Urban Community Ministries The approved meal service time for breakfast is 9:30 am -10:30 am. A monitor arrived onJune 6, 2018, at approximately 9:23 am and left at 10:30 am. Staff stated meals wereserved at 9 am for breakfast. As a result, 25 breakfast meals were disallowed.See Exhibit L-41779 Divine Intervention @ Raleigh Egypt High - Pre Employment Transition Services The approved meal service time for lunch was 10:30 am - 11:30 am. A monitor arrivedon June 7, 2018, at approximately 10:10 am and spoke with site supervisor on thephone and was informed lunch meals were served at 9:30 am. The site agreement fromSCS listed meal approved time is from 9:30 am - 10:30 am. Per TIPS applicationagreement approved lunch meal service time is 10:30-1130 am. As a result, 61 lunchmeals were disallowed. See Exhibit B-1 Monitoring staff returned on June 8, 2018, and observed 13 lunch meals served at 9:30am, again outside of the approved meal service time. Those meals were not disallowedsince they were observed.1803 Gardenview Elementary Summer School15

The approved meal service time for breakfast was 7:30 am -8 am. A monitor arrived onJune 7, 2018, at approximately 7:05 am and 325 breakfasts were observed being servedfrom 7:20 am -8:10 am. No meals were disallowed due to being observed.As a result, 25 breakfast meals and 61 lunch meals were disallowed.This is a repeat finding from monitoring report dated October 13, 2017.CriteriaTitle 7 o f the Code of Federal Regulations, Section 225.16 (c) (3) and (4) states, “Mealsserved outside of the period of approved meal service shall not be eligible for Programpayments. Any permanent or planned changes in meal service periods must be approved bythe State agency.According to the USDA Administration Guide Summer Food Service Program 2016, page133 “Sponsors may claim reimbursement only for those meals that meet SFSPrequirements. Reimbursement may not be claimed for meals served outside of approvedtimeframes or approved dates of operation.”RecommendationThe Sponsor should ensure that feeding site personnel serve meals during the approvedmeal service time and if changes are necessary, the information should be updated the DHSTennessee Information Payment System (TIPS) for approval.7. The Sponsor provided meals that did not meet the USDA meal pattern requirementsduring a meal observationConditionDuring our on-site visit to observe a meal service at 1802 Craigmont Middle SCS SummerSchool on June 12, 2018, we observed 65 breakfast meals served. Of the meals served, weobserved 57 meals met the USDA meal pattern requirements and consisted of a whole graincinnamon bun, 100% orange juice and milk, or Cinnamon toaster cereal, 100% orange juiceand milk. However, five breakfast meals did not include milk, and three participants onlyreceived 100% orange juice.As a result, eight breakfast meals were disallowed.See Exhibit M-1CriteriaTitle 7 o f the Code o f Federal Regulations, Section 225.16 (c) (6) (d) states, ". The mealrequirements for the Program are designed to provide nutritious and well-balanced meals toeach child. Sponsors shall ensure that meals served meet all of the requirements. .”According to the Administration Guide Summer Food Service Program 2016 edition, page133 “Sponsors may claim reimbursement only for those meals that meet SFSPrequirements. . Reimbursement may not be claimed for meals not served as a complete16

unit (except in “offer versus serve “sites where complete meals must be offered toparticipants) and meals missing/inadequate component.”RecommendationThe Sponsor should ensure that meals are being served as one unit which includes allcomponents.8. The Sponsor delivery tickets did not support meal count recordsConditionOur review of the Sponsor’s meal count records and supporting meal delivery ticketsrevealed that the delivery tickets for the feeding site 0476 Park Services- Westwood Pooldid not support the meal counts. The number of meals reported as served exceeded mealsdelivered and leftover meals by 350 lunch meals.CriteriaTitle 1 o f the Code of Federal Regulations 7 CFR 225.15 (c) states, “Sponsors shallmaintain accurate records which justify all costs and meals claimed. .”As a result, 350 Lunch meals were disallowed. See Exhibit U-3RecommendationThe Sponsor should ensure the feeding sites personnel are properly trained on recordkeeping. The Sponsor should ensure that delivery tickets support the meal count records.9. The Sponsor served meals outside the approved serving time at several feeding sitesConditionOur review of the Sponsor’s Point of Service (POS) sheets, we noted that several feedingsites were serving meals outside the approved serving. See Table below:Site1808 Lester PrepMiddle- SummerFootball1808 Lester PrepMiddle- SummerFootball0345 Life Change andMinistries1746 NeighborhoodChristian CenterRidgecrestApprovedMeal ServiceTimeLunch12 pm-1 pmServing TimeListedMeals DisallowedExhibit1:00 pm-1:15 pm-595 Lunch mealsU-2PMSupplement2 pm-3 pmPMSupplement12:30 pm-1pm12 pm -1:30 pm-700 PMSupplementsU-211:30 am -12:15pm-20 PMSupplementsV-2Breakfast9 am-9:45 am12 pm, and 8:00am-8:40 am-256 BreakfastMealsF-317

1746 NeighborhoodChristian CenterRidgecrest0443 NorthwestPreparatory AcademyLunch11:45 am 12:45 pmBreakfastMondayFriday9:30am, 10am,1pm-1:30 pm-252 Lunch MealsF-3Saturday-180 BreakfastMealsN-3As a result, 436 Breakfast meals, 847 Lunch meals, and 720 PM Supplements weredisallowed.CriteriaTitle 7 o f the Code of Federal Regulations, Section 225.16 (c) (3) and (4) states, “Mealsserved outside of the period of approved meal service shall not be eligible for Programpayments. Any permanent or planned changes in meal service periods must be approved bythe State agency.The USDA Administration Guide Summer Food Service Program 2016, page 60 states“Serve meals during the meal service times submitted on t

Site 0306 Kate Bond Elementary(lmagine Learning Camp), Site 0310 Keystone Elementary, Site 0704 Knowledge Quest- Gaston Community Center, Site 0337 Lemoyne Owen College- Dream of Memphis, Site 0344 Libertas, Site 0741 Longstreet United Methodist Church- Project Transformation TN, Site 0705 Memphis Catholic- Extended