Corrective Action Plans

F.       The amount of current income by each member and the source of the income.

G.      The last four of the social security number of the adult household member who signs the application or an indication that the household member does not have a social security number (box checked for “no social security number”) Indication that the child is a foster child

Program: AL 10.553 – School Breakfast Program; AL 10.555 – National School Lunch Program; AL 10.556 – Special Milk Program for Children; AL 10.559 – Summer Food Service Program for Children; and AL 10.582 – Fresh Fruit and Vegetable Program – Reporting Corrective Action Plan: NDE has been able to identify and correct the reporting errors and has begun working to submit all the required reports immediately. Additionally, FFATA reporting procedures will be updated and a monthly calendar reminder set each month to ensure the reports are submitted in a timely fashion. Contact: Kayte Partch / Kayte.partch@nebraska.gov Anticipated Completion Date: April 30, 2025

Due to the recent audit performed on the 23/24 school year a corrective action plan is needed to ensure internal controls are in place for applications entered in Payschools. This will ensure that all applications are properly marked as paid, free or reduced in the Payschools system. As the food service supervisor, I will verify that Payschools has the correct income guidelines provided by ODE for the current school year in the system. Furthermore, I will randomly pull 10% of portal applications that are entered through Payschools Central to ensure the correct determination was processed according to the income guidelines. Documentation will be kept on file of the applications that are reviewed. This plan will meet the necessary requirement to ensure that Payschools determined the proper eligibility status based on the information provided on the applications. Anticipated completion date: 6/30/2025

The District beginning in FY 2025 became part of the Community Eligibility Program allowing for all students to receive free lunch and breakfast. As such, the District is not using Pay Schools to determine eligibility.

Corrective Action: Child Nutrition will incorporate separation of duties when calculating the reimbursement for meals. At least one on—site review of the meal counting and claiming system for each school. Avery Johnson, Business Manager Robert Sanders, Superintendent Corrective Action Start Date: February 18, 2025

Corrective Action: The Business Manager will calculate the indirect \ cost rate using the rate provided by MDE for the expenditures occurred. The calculation will be reviewed and signed off on by the Federal Programs Director and Child Nutrition Director. This calculation will take place at year end once expenditures are booked. Avery Johnson, Business Manager Robert Sanders, Superintendent Corrective Action Start Date: February 18, 2025

Corrective Action: The district will strengthen internal controls on the employee contract and employee board approval process. There will be checks and balances between Human Resources and the Business Office before any recommendations are presented to the board. Avery Johnson, Business Manager Robert Sanders, Superintendent Corrective Action Start Date: February 18, 2025

Corrective Action: Child Nutrition will provide proof of documentation on all vendors illustration that they are not suspended or debarred. Also, invoices will be a part of the procurement packet. lt will be uploaded to the financial software system for primary filing and filed physically as a secondary method. Avery Johnson, Business Manager Robert Sanders, Superintendent Linda Little, Child Nutrition Director Corrective Action Start Date: February 18, 2025

Corrective Action Plan Finding 2024-001 Criteria: Recipients of federal awards must follow the procurement standards set out at 2 CFR section 200.317 through 200.326. They must use their own documented procurement procedures, which reflect applicable State laws and regulations, provided that the procedures conform to applicable Federal law and the procurement requirements identified in 2 CFR part 200. Recipients “must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price” 2 CFR section 200.318(i). The School’s procurement procedures include the requirement to maintain sufficient documentation of the history of procurement. The School also has procedures to identify procurement transactions requiring competitive bids or proposals. Auditor Recommendation: We recommend the Academy ensure it 1) maintains documentation of the history of procurement and 2) monitors compliance with documentation requirements. Auditee Response/ Corrective Action Plan: The Academy will review its procurement policies and internal controls and ensure timely action is taken when noncompliance is identified. Person Responsible: Dane Roberts, Executive Director and Randi Limb, Business Manager Timeline: All future contract solicitations will follow the required procurement standards.

FINDING 2024-002 Finding Subject: Child Nutrition Cluster - Eligibility Contact Persons Responsible for Corrective Action: Lacey Sturgeon, Food Service Director & Melissa Bell, Assistant Food Service Director Contact Phone Number and Email Addresses: (765) 893-4445 / lsturgeon@msdwarco.k12.in.us & mbell@msdwarco.k12.in.us Views of Responsible Officials: Option 1: We concur with the findings Description of Corrective Action Plan: Stronger internal controls are needed in regards to verification of Direct Certifications. We plan to make sure once the certifications are entered that the Food Service Director will check the work of the Assistant Food Service Director and show her approval by signing and dating each final report. Anticipated Completion Date: Effective Immediately

FINDING 2024-004 Finding Subject: Child Nutrition Cluster-Activities Allowed or Unallowed, Allowable Costs/Cost Principles Summary of Finding: Payments made based on statements or no supporting documentation. The School corporation did not properly implement a process to identify and assess internal and external risks, or monitor internal control activities to ensure they were operating effectively. Contact Person Responsible for Corrective Action: Melissa Embry Contact Phone Number and Email Address: 812-547-2637 melissa.embry@cannelton.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Invoices are already being given to the Corporation Treasurer monthly and are being attached to each Accounts Payable Voucher to show exactly what is being paid for. Cannelton management will establish a proper system of internal controls including policies and procedures related to risk assessment and monitoring activities within the federal program. Anticipated Completion Date: The noncompliance was corrected as of January 2025. The additional controls will be implemented by August 2025.

FINDING 2024-003 Finding Subject: Child Nutrition Cluster – Internal Controls Summary of Finding: There was a lack of internal controls. Additionally, the School corporation did not properly implement a process to identify and assess internal and external risks, or monitor internal control activities to ensure they were operating effectively. Contact Person Responsible for Corrective Action: Melissa Embry Contact Phone Number and Email Address: 812-547-2637 melissa.embry@cannelton.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The food service director now gets all the reports and appropriate supporting documentation, including receipts and disbursements reports, together and goes over it with the high school secretary/deputy treasurer and is then submitted by the secretary/deputy treasurer, printed off and given to the corporation treasurer. The corporation treasurer has a copy of the submission and compares that to what is deposited. All claims have always been approved by the School Board. Cannelton management will establish a proper system of internal controls including policies and procedures related to risk assessment and monitoring activities within the federal program. Anticipated Completion Date: August 2025

Condition: The Disrict did not maintain documentation supporting that the required calculations for PLE were completed. Plan: Policies and procedures will be implemented to ensure that the required PLE calculations are being made and documented. Anticipated Date of Completion: June 30, 2025. Name of Contact: James Dunlap, Superintendent. Management Response: Management does not disagree with this finding. In future years, the District will document their PLE calculations.

Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program AL Numbers: 10.553, 10.555 Federal Award Numbers and Years: FY2023, FY2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Qualified Opinion Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the simplified acquisitions procurement method of the Procurement and Suspension and Debarment compliance requirement. Context: During the audit period, we tested two vendors that fell within the Small Purchase procurement threshold. Small purchases are those vendors that the School Corporation has purchased between $10,000 and $150,000 of products and goods from during the fiscal year. For one of the two vendors selected for testing, we noted the School Corporation did not obtain price or rate quotations from other vendors or document the basis for purchasing from the vendor that was utilized. The School Corporation had $134,542 and $117,589 of expenditures with the vendor for fiscal years 2023 and 2024, respectively. Corrective Action Plan: To meet the conditions of the grant agreement, Caston School Corporation will keep record of all vendors that are outside of our NIESC buying agreement. Vendors on this list will be identified as having an RFP on file or requiring an RFP to purchase. The director or the director’s purchasing designee will consult the list before ordering from the vendor. The School Corporation will ensure that the appropriate number or bids are obtained or will document the reasoning behind why the appropriate number of bids could not be obtained. The School Corporation will run a suspension and debarment check on vendors prior to entering into a contract. Person responsible for implementation and projected implementation date: The Food Services Director and/or the Director’s designee, as well as the Treasurer will be responsible for implementation of the corrective action plan, which will be done immediately.

Information on the federal program: Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY2023, FY2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Finding: Significant Deficiency Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the eligibility compliance requirement. Context: During the testing of internal controls over eligibility determinations for free and reduced meals, we noted management was unable to provide support for three of the 60 applications selected for testing. Additionally, for one of the 60 selections, the student was improperly classified as reduced when the annual income per the student’s application exceeded the corresponding threshold for that determination. Corrective Action Plan: The School Corporation will implement internal control procedures to ensure the applications are filed and maintained in a secure manner. The School Corporation will also implement internal control procedures to ensure that applications are formally reviewed by the Food Services Director and the Treasurer, so that applicants are accurately denied or approved for free or reduced meals. Person responsible for implementation and projected implementation date: The Corporation’s Food Services Director and Treasurer will be responsible for implementing the corrective action, which will be implemented immediately.

Information on the federal program: Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY2023, FY2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Finding: Material Weakness Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the eligibility compliance requirement. Context: During the testing of internal controls over eligibility determinations for free and reduced meals, we noted there was no formal review control in place for 26 of the 60 applications selected for testing. Additionally, for one of the 60 selections, the student was improperly classified as free when the annual income per the student's application exceeded the corresponding threshold for that determination. Corrective Action Plan: The School Corporation will implement a system of internal controls to ensure that the applications are being formally reviewed by the Food Services Director and the Corporation Treasurer. Person responsible for implementation and projected implementation date: The Food Services Director and the Corporation Treasurer will be responsible for implementing the corrective action, which will begin with applications for the 2025-2026 school year.

Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY2023, FY2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Finding: Material Weakness Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the eligibility compliance requirement. Context: During testing over controls for eligibility, for 16 of the 60 applications selected, we noted there was no formal evidence that the applications had been reviewed and further, the application did not specify if the student was eligible for free or reduced lunch. We also noted for 2 of the 60 selections, management was unable to provide support for the student that was selected. Corrective Action Plan: The Food Services Director and the Treasurer will both sign off on the applications once they have completed their review to determine if the application was accurately denied or approved for free or reduced meals. The completed and reviewed applications will be maintained in a safe and secure location, so they are easily accessible in an instance where they would need to be referenced. Person responsible for implementation and projected implementation date: The Food Services Director and the Corporation Treasurer will implement the corrective action plan starting with applications received for the 2025-2026 school year.

Internal Control: When a purchase is made with any vendor over the $25,000 threshold from Fund #800, School Lunch, Fund, the superintendent along with the treasurer or deputy treasurer (minimum of two people) will require that any vendors selected are in compliance with the Procurement and Suspension and Debarment compliance requirements by completing one the of following quality checks with each vendor prior to purchase: a. Checking the federal System for Award Management (SAM) database at https://sam.gov/content/exclusions and maintain a screen shot of the search results b. Collect a certification from the vendor directly c. Adda clause or condition to the covered transaction with the vendor

Name of contact person: Mr. Joseph Gudac, Business Manager Corrective Action: We will follow our policy for ensuring the accuracy of meal counts before remitting the total meals to PDE. The district will implement a pre-submission review protocol to verify that monthly claims accurately reflect the meals served to eligible students. We also will develop a standardized checklist for reviewing and approving meal counts before submission and to ensure that discrepancies identified during review are promptly investigated and corrected. Anticipated Completion Date: The District will implement the above procedure immediately.

1. The District has consulted with the Arkansas Division of Elementary and Secondary Education, Child Nutrition Unit (DESE, CNU) for guidance and technical assistance. 2. Per CNU guidance, the District is in the process of submitting an amended claim for October 2023 to correct the $552 discrepancy. We anticipate acceptance of this claim, resolving the issue. 3. The District has fully implemented the required CEP compliance procedures and has trained personnel to ensure future claims adhere to federal and state regulations. 4. Standard Operating Procedures (SOP) for the Child Nutrition Program have been updated to prevent recurrence of this issue. The Earle School District is committed to ensuring full compliance with all federal and state regulations regarding Child Nutrition reimbursement claims. We appreciate the guidance provided by DESE, CNU and will continue to implement measures that strengthen our oversight and accountability.

Finding 2024-004 Reporting – Noncompliance and Significant Deficiency in Internal Control Over Compliance Corrective Action Plan This occurrence was due to a change in management and the error was corrected when it was identified. Since then, all the documentation was submitted within parameters of the grant. Expected Completion Date 12/21/2023

PDA, Bureau of Food Assistance (BFA) has already or will put the following steps in place to address this deficiency and noncompliance finding. 1. BFA will communicate to our contractor, Hunger-Free Pennsylvania, that all required uploads of information related to the Commodity Supplemental Food Program (CSFP) must be entered in PAMeals by the final day of the month following the program month (i.e., data from May must be entered by June 30, data from June must be entered by July 31, etc.). BFA will also implement a monthly check in PAMeals to occur on the 1st of each month, to ensure that data from the previous reporting period has been entered into PAMeals timely (i.e., data from May should be entered by July 1, data from June should be entered by August 1, etc.). 2. In response to finding 2023-004, BFA cross-trained the NSLP Specialist on the process of completing the Monthly Processor Reports (MPRs) as a back up to the NSLP Processing & Procurement Specialist. The NSLP Specialist was then tasked with completing a monthly review of the completed MPRs to ensure accuracy. BFA has now added an additional layer to the process, with the Assistant Bureau Director serving as a backup to the NSLP Specialist, to ensure that should there be a vacancy in either of the two NSLP positions, there will always be a primary and a back-up to ensure accuracy. 3. BFA will add a validation step to the Distributor data import process for PAMeals to flag and disallow any transactions that are dated prior to the current fiscal year. BFA will also put in place a warning system on PAMeals to flag incorrect dates in any manual adjustments. 4. To ensure that processor inventories are accurate, BFA has programmed PAMeals to run a weekly check (on Sunday) to ensure that beginning processor inventories entered match the previous month and to ensure that ending inventories are accurate. BFA staff are also completing a 6-month periodic processor inventory review to ensure that records are accurate. 5. To ensure correct and timely data submissions from Share Food Program, one of our two contract distributors, PDA will require them to implement a corrective action plan detailing their plans to ensure that they provide timely and accurate reporting. This CAP will help to ensure that correct transactions are posted to PAMeals in a timely manner and will aid in addressing the issues with SEFA submission. Anticipated Completion Dates: 1. 06/30/2025, 2. Completed, 3. 06/30/2025, 4. Completed, 5. 06/30/2025 Contact Name: Caryn Long Earl, Director, Bureau of Food Assistance

Information on the federal program : Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY2023, FY2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Finding: Material Weakness Context : For 18 selections, in a sample of 40 payroll transactions, the School Corporation based the employees’ time charged to the grant on an annual time and effort log. The employee’s time was split with a non-federal fund. The School Corporation allocated the employee’s time based on a time and effort log completed in September of each year which was reviewed by the Superintendent. The School Corporation did not complete time and effort logs more frequently than annually to ensure the amounts being charged to food service were based on worked performed for each payroll period. Contact Person Responsible for Corrective Action: Candace McDonald Contact Phone Number: 765-734-1261 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Instead of doing a time study, we will fully implement an analysis of percentages paid by the school lunch program on a monthly basis. Anticipated Completion Date: Beginning of April 2025, fully implemented and corrected by the end of May 2025.

FINDING 2024-004 Information on the federal program: Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY2023, FY2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Finding: Material Weakness Contact Person Responsible for Corrective Action: Contact Phone Number: • Jill Pollard, 765-654-4473, ext 401 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: • There will be dual control on all applications Anticipated Completion Date: • 12/31/2025