Corrective Action Plans

Condition: The same individual is responsible for preparing and submitting monthly reimbursement claims for the Child Nutrition Program without an independent review or approval prior to submission. Plan: A second person (superintendent) compares the meal counts in the claim to the SDS daily meal count reports, monthly participation summary, eligibility rosters (free, reduced, paid) and USDA reimbursement rates. The reviewer will then sign and date a reconciliation sheet before submission. Anticipated date of completion: June 30, 2026. Name of contact person: Brett Elliott, Superintendent. Management response: The corrective action plan was discussed with the employee responsible for filing the claim, the business manager, and the superintendent. After discussion, the plan was approved by the superintendent.

Condition: The same individual is responsible for preparing and submitting monthly reimbursement claims for the Child Nutrition Program without an independent review or approval prior to submission. Plan: A second person (chief financial & operations officer) compares the meal counts in the claim to the Skyward daily meal count reports, monthly participation summary, eligibility rosters (free, reduced, paid) and USDA reimbursement rates. The reviewer will then sign and date a reconciliation sheet before submission. Anticipated date of completion: December 7, 2025. Name of contact person: Cassandra Schug, Superintendent. Management response: The corrective action plan was discussed with the business services coordinator and the chief financial & operations officer. After discussion, the plan was approved.

Contact Person – Dr. Noel Schmidt, Superintendent Corrective Action Plan – The District will establish procedures to review meal reimbursement submissions. Completion Date – January 31, 2026

Federal regulations require that verification of applications be conducted by separate officials and that proper documentation and procedures are followed (7 CFR 245.6a). The same individual served as both the confirming and determining/reviewing official. The District did not maintain documentation of confirmation reviews, and some applications were not verified correctly, resulting in incorrect eligibility determinations. The ensure adherence to the separation-of-duties requirement outlinked in 7 CFR 245.6a, the District has designated a separate confirmining official. The verification process will now follow a two-step reivew; the Child Nutrition Secretary will conduct the initial verification of selected applications, and the Child Nutrition Director will complete the independent confirmation review. This structure ensures that two distinct individuals verify the accuracy of eligibility determinations and that proper oversight is maintained. Both the Child Nutrition Secretary and the Child Nutrition Director attended formal verification training in September 2025. This training reinforces correct procedures and supports proper documentation of all confirmation reviews moving forward.

Federal regulations require that eligibility determinations for free and reduced-priced meals be accurate and that benefit issurance documents are updated timely and accurately (7 CFR 245.6, 245.10). Several student applications were incorrectly approved. Additionally, benefit issuance documents were not updated in a timely manner for students newly eligible through Direct Certification. To ensure full compliance with 7 CFR 245.6 and 245.10, the Child Nutrition Director and Child Nutrition Secretary will jointly review each Direct Certification (DC) list to verify that all eligible students are accurately identified and that eligibility status in the point-of-sale (POS) system is update promptly. This dual-review process will service as a verificaiton measure to prevent omissions and ensure the benefit issuance document remains current and accurate. In August 2025, both the Child Nutrition Director and Secretary completed formal training on eligibility determination procedures. Moving forward, detailed notes- including dates and explanations of status changes- will be documented in each student's account to ensure clear tracking of all updates to support accurate recordkeeping for future reviews.

Condition: The same individual is responsible for preparing and submitting monthly reimbursement claims for the Child Nutrition Program without an independent review or approval prior to submission. Plan: A second person (superintendent or associate superintendent) compares the meal counts in the claim to the Skyward and RevTrak daily meal count reports, monthly participation summary, eligibility rosters (free, reduced, paid) and USDA reimbursement rates. The reviewer will then sign and date a reconciliation sheet before submission. Anticipated date of completion: June 30, 2026. Name of contact person: Tony Ingold, Superintendent. Management response: The corrective action plan was discussed with the employee responsible for filing the claim, the associate superintendent, and the superintendent. After discussion, the plan was approved and will be implemented.

FINDING 2025-002 Finding Subject: Child Nutrition Cluster - Suspension and Debarment Contact Person Responsible for Corrective Action: Lori Bennett Contact Phone Number and Email Address: 317-539-9200, LBennett@mccsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The School Corporation will require that suspension and debarment verification be done for all appropriate vendors prior entering into and paying an invoice at the start of each year. The verification is to be done by checking the SAM exclusions, collecting a certification from that person, or adding a clause or condition to the covered transaction with that person. Documentation will be included with the first voucher each year for that qualifying vendor. Anticipated Completion Date: January 2026

Condition: The same individual is responsible for preparing and submitting monthly reimbursement claims for the Child Nutrition Program without an independent review or approval prior to submission. Plan: A second person will compare the meal counts in the claim to: (1) the daily meal counts prepared by cafeteria staff and (2) the monthly enrollment reports from the accounting software. The reviewer will then sign and date the supporting documentation before the meal claim is submitted. Anticipated date of completion: December 2025. Name of contact person: Jake Flowers, Superintendent. Management response: The corrective action plan was discussed with the employees responsible for filing the claim and the superintendent. After discussion, the plan was approved by the superintendent and will be adopted.

A plan was developed by the District to eliminate the excess of net resources in the Food Service Fund. The plan includes a review of the excess of net resources on a monthly basis for determination of areas to improve the foods svc department relating to equipment purchases and staff.

Finding 2025-002: Allowable cost-Significant deficiency in internal controls over compliance. Management Response The District purchased supplies on the District credit card. There was no purchasing requisition entered or approval prior to making the purchase. The District conducted procurement training in August 2025. The District will conduct another training in October 2025 to discuss procurement requirements regarding credit card purchases. If a credit card purchase is made without a requisition, the accounts payable staff will notify the management prior to the credit card payment.

Finding 2025-001: Reporting – Significant deficiency in internal controls over compliance. Management Response: The District’s Child Nutrition Assistant Director (AD) prepared the claims data submitted into the Tx-UNPS System to receive Child Nutrition federal funding. The claims data was submitted without management approval. The District will implement procedures to ensure that monthly claim reports are reviewed by the Chief Operations Officer (COO) prior to being submitted into Tx-UNPS System. The AD will prepare the claims report documentation, which includes the point of sale and attendance reports. The claims report and supporting documentation will be emailed to the COO. Once the reports are reviewed and determined to be accurate, the COO will email approval. Once the AD receives approval via email from the COO, the email will be printed or digitally saved with the claims reports. The AD will submit claims data into the Tx-UNPS System and print the NSLP Claim for Reimbursement Summary. The Summary will be sent to the COO for confirmation. The new process will begin in October 2025.

Subject: Management response to Fiscal Year 2025 Audit Findings The management of Village Tech Schools acknowledges receipt of the following findings for the FY25 audit and has developed a corrective action plan response to address the findings. Finding 2025-001: Reporting – Significant deficiency in internal controls over compliance. Management Response: The District’s Child Nutrition Supervisor (CNS) prepared the claims data submitted into the Tx-UNPS System to receive Child Nutrition federal funding. The claims data was submitted without management approval. The District will implement procedures to ensure that monthly claim reports are reviewed by the Chief Operations Officer (COO) prior to being submitted into Tx-UNPS System. The CNS will prepare the claims report documentation, which includes the point of sale and attendance reports. The claims report and supporting documentation will be emailed to the COO. Once the reports are reviewed and determined to be accurate, the COO will email approval. Once the CNS receives approval via email from the COO, the email will be printed or digitally saved with the claims reports. The CNS will submit claims data into the Tx-UNPS System and print the NSLP Claim for Reimbursement Summary. The Summary will be sent to the COO for confirmation. The new process will begin in October 2025.

The payments made with grant funding have been reclassed to the general fund and all future expenditures for the subgrant will be made through the general fund.

Child Nutrition Cluster (School Breakfast Program, National School Lunch Program, and Summer Food Service Program for Children) – Assistance Listing No. 10.553, 10.555, and 10.559 Recommendation: CLA recommends that the District review its internal controls and implement a procedure to ensure all reports required under the grant have a designated reviewer that is different from the individual responsible for preparing, even when there are gaps of coverage in preparer and reviewer positions, and that the review and approval happens prior to submitting the reports to the granting agency. Explanation of disagreement with audit finding: There is no disagreement with this finding. Action planned/taken in response to finding: The Food Service Director and the Executive Administrative Assistant will work together to ensure that procedures are in place to review and confirm for accuracy. Name(s) of the contact person(s) responsible for corrective action: Frankie Soto, Dawn Rausch Planned completion date for corrective action plan: September 1, 2026.

Child Nutrition Cluster (School Breakfast Program, National School Lunch Program, and Summer Food Service Program for Children) – Assistance Listing No. 10.553, 10.555, and 10.559 Recommendation: CLA recommends the District review its procurement process to ensure that there is adequate segregation of duties in regards to initiating, authorizing, reviewing for grant allowability and approving all procurement transactions. CLA also recommends that the District review and update policies and procedures to help ensure that all federal grants with covered transactions have vendors reviewed for suspension and debarment status prior to entering into the transaction and that documentation of the status is maintained with the procurement history of each transaction that it is required for. Explanation of disagreement with audit finding: There is no disagreement with this finding. Action planned/taken in response to finding: The Food Service Director and the Executive Administrative Assistant and District Administrator will work together to ensure that procedures are in place to review and confirm for accuracy. Name(s) of the contact person(s) responsible for corrective action: Frankie Soto, Dawn Rausch, Adrian Foster Planned completion date for corrective action plan: September 1, 2026.

Child Nutrition Cluster (School Breakfast Program, National School Lunch Program, and Summer Food Service Program for Children) – Assistance Listing No. 10.553, 10.555, and 10.559 Recommendation: CLA recommends that the District implement formal procedures to strengthen controls over eligibility determinations. These procedures should include ensuring timely updates to eligibility listings when students become ineligible, retaining all required documentation for the applicable retention period, and conducting periodic reviews of benefit issuance listings to confirm accuracy. Additionally, CLA recommends the District implement procedures to ensure staff receive training on proper eligibility determination and recordkeeping requirements. Finally, CLA recommends the District establish monitoring controls to verify that benefits are discontinued promptly for students who no longer qualify. Eligibility determinations should be reviewed and approved by someone other than the person entering the applications and direct certification information into the software. Explanation of disagreement with audit finding: There is no disagreement with this finding. Action planned/taken in response to finding: The Food Service Director, high school secretary and the Executive Administrative Assistant will work together to ensure that procedures are in place to review and confirm for accuracy. Name(s) of the contact person(s) responsible for corrective action: Frankie Soto, Dawn Rausch, Emily Krzyzanowski Planned completion date for corrective action plan: September 1, 2026.

The administrative assistant will prepare the "claims summary" forms by obtaining the number of meals served directly from the "Meal Count Edit Form." The Treasurer or Superintendent will also review the "claims summary" forms and supporting documentation for accuracy prior to the electronic submissions. Corresponding documents will be manually signed and dated to indicate approval.

Reviewing the fund balance monthly and purchasing necessary supplies and staff to keep the balance down.

Finding 2025-001, Reporting- Significant deficiency in internal controls over compliance Cause: The finding resulted from the lack of a formalized, documented review process to verify the accuracy of claim data between Skyward, PrimeroEdge, and TXUNPS. Historically, the claim reporting relied on single-entry verification without a defined cross-check procedure or document retention system to confirm alignment across platforms. Corrective Action: NYOS Charter School has implemented a new monthly verification process to ensure accuracy and transparency in the meal count reporting workflow. - The PEIMS Manager will generate the Average Daily Attendance (ADA) report from Skyward each month. - The Food Service Manager will use this report to enter claim data into PrimeroEdge. - The Director of Operations will then cross-reference the claim information from PrimeroEdge with the ADA report from Skyward before entering final claim data into TXUNPS. - Copies of the ADA report, the PrimeroEdge claim summary, and the TXUNPS submission confirmation will be downloaded and stored in the Food Services Google Drive for audit documentation and ongoing internal control review. - Staff involved in this process will receive annual training on verification procedures, documentation standards, and data integrity best practices. Timeline: Updated verification process implemented in October 2025; full rollout and training completed by December 2025. Responsible Party: - Chief of Operations & HR -Director of Operations - PEIMS Manager - Food Service Manager Monitoring: Quarterly internal reviews will be conducted by the Chief of Operations & HR to ensure consistent application of the cross-verification process and proper retention of supporting documentation in the Food Services Google Drive.

Finding Type: Significant Deficiency. Name of Contact Person: Dr. Lisa Thomas, Superintendent. Recommendation: We recommend the District expand their internal controls to require a responsible official to review the daily meal count reports for accuracy prior to submission of the reports to the Illinois State Board of Education. Corrective Action: Daily meal counts will be rectified by administration on a monthly basis. Proposed Completion Date: Immediately.

Finding Reference: 2025-002 - Special Tests and Provisions — Accountability for USDA Foods— Questioned Costs: None Responsible Person: Todd Frease, CFO Actions & Timelines: 1. Valuation Policy (within 30 days from report issuance): Adopt an approved USDA valuation method (WBSCM price or rolling average) and document the policy. 2. Formal Inventory SOPs (within 60 days of report issuance): Issue written SOPs covering count preparation, reconciliation, and documentation retention per 7 CFR §250.19. 3. Training (within 60 days): Train finance and inventory staff on valuation requirements and new SOPs. 4. Annual Monitoring (ongoing): Review valuation application and inventory reconciliations annually and report results to leadership. Anticipated Completion Date: Initial policy and SOPs within 60 days of report issuance; ongoing monitoring thereafter.

FINDING 2025-004 Finding Subject: Child Nutrition Cluster - Allowable Costs/Cost Principles Federal Agency: Department of Agriculture Federal Program(s): School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children Assistance Listing Numbers: 10.553, 10.555, 10.559 Federal Award Numbers and Years: FY2024, FY2025 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Allowable Costs/Cost Principals Audit Finding: Material Weakness, Modified Opinion Condition and Context 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 Allowable Costs/Costs Principles compliance requirement. The School Corporation entered into a Fixed Price meal Contract with a food service management company (FSMC). For each meal type, a fixed price was established and billed by the FSMC based on meal counts served. The School Corporation failed to compare the invoices received from the FSMC to the School Corporations software reports to ensure the number of meals invoiced agreed to the meals served. Two invoices with the FSMC were selected for testing totaling $213,048.96. . Contact Person Responsible for Corrective Action: Erin Roach Contact Phone Number and Email Address: 765-653-3119 eroach@sputnam.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The food service director will compare the invoices received from the FSMC to the School Corporations software reports prior to submission for payment. Anticipated Completion Date: February, 2026

Corrective Action Plan: The School District is committed and will be diligent in preparing meals with high quality products. Regular cooked meals and expanded menu choices will be prepared which will result in an increase in expenses. There has been unpredictability with the increase of certain goods, and we expect this to continue into the 2025-2026 fiscal year as well. The School District also participates in the Community Eligibility Provision (CEP) which provides free breakfast and lunch to every student within the School District. Salaries for School Lunch employees have also been increasing year after year due to the increase of minimum wage in New York State. The minimum wage is expected to increase to $16.00 per hour and entry level wages have increased per contract. The School District does have a practice of transferring BOCES aid gained from the cost of the BOCES management contract to the School Lunch Fund; the aid will not be transferred in upcoming years. The School District has devised a NYSED approved plan to expend the excess funds in the School Lunch Fund through appropriating a substantial amount of fund balance to be planned for and used for the cafeteria and kitchen within the next planned capital project. We are currently in the planning phase of our next capital project with a vote anticipated during the 2025-2026 fiscal year. If needed, we will examine other avenues to ensure we do not exceed the allowable limit of cash at year end.

The District has separated duties to the extent possible and has implemented compensating controls to monitor the accounting activities

Catoosa Public schools accecpts full responsibility for the deficiences identified in this audit finding related to the Child Nutrition program. The district acknowledges that internal controls surrounding manual adjustments to student meal accounts were insufficient and that adjustments totaling approximately $36,740 were made without adequate documentation. The District has implemented a corrective action plan that is available upon request because it could not be properly upload to this excel spreadsheet.