Corrective Action Plans

Child Nutrition Cluster – Assistance Listing No. 10.553, 10.555 and 10.559 Recommendation: We recommend the District retain all direct certification reports from the State and for the District to review applications submitted electronically through food service system to determine correct eligibility determination is made. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: Direct Cert files received from the State starting in August 2024 will be kept on the Food Service Google drive. Names of the contact persons responsible for corrective action: Wesley Haselhorst and Dawn Koshio Planned completion date for corrective action plan: June 30, 2025

Finding 2024-001 Condition: Two vendors were awarded a contract without an appropriate procurement process. Corrective Action Planned: Comply with federal procurement regulations by setting up a quote system and seek quotes for anticipated spending of over $10,000. Anticipated Completion Date: May 1, 2025 Contact: Marie Znamierowski

2024-003 Preparation of and Internal controls over Schedule of Expenditures of Federal Awards Preparation (Material Weakness) Federal Agency: U.S Department of Education Program Name: Child Nutrition Cluster; Education Stabilization Fund Assistance Listing Number: 10.553, 10.555 and 10.559; 84.425 Award Period: June 30, 2024 Recommendation: The Board of Education and management should review the financial reporting process. Once this review is complete, the District should then perform a risk assessment to determine the best way to implement appropriate internal controls over financial reporting to ensure that the District prepares the schedule conformity with Uniform Guidance. Action Taken (Unaudited): Management plans to have the Board Clerk and the Board Treasurer complete the Schedule of Expenditures together and to ensure that the correct expenses are being reported. Contact Name – Kristy Dyche Expected Completion Date – 6/30/2025

FINDING 2024-001 Finding Subject: Child Nutrition Cluster - Reporting Summary of Finding: There were no controls in place to ensure that the School Corporation complied with the reporting requirements. The reimbursement request reports were prepared and submitted by the Food Service Director without any oversight, review or approval process to ensure accuracy of the reports. There was no oversight to make sure that the number of meals served matched the report filed. The lack of internal controls was systemic throughout the audit period. Contact Person Responsible for Corrective Action: Amanda Myers Contact Phone Number and Email Address: 765-832-3551/amyers@svcs.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Amanda Myers, Food Services Director, will continue to receive the information for the monthly meals served from the cafeteria managers at each school. Once she enters the information, the HS cafeteria manager will review the numbers to ensure that the information was entered correctly. The reimbursement forms and information that was entered will be submitted to the finance department to ensure the reimbursement process is correctly receipted. Anticipated Completion Date: Immediate.

Context: For one sponsor claim reimbursement in a sample of four claims, the Food Service Director prepared the sponsor claim reimbursement summary without a secondary, documented review before the submission of the claim to ensure the accuracy of the sponsor claim reimbursement summary. Contact Person Responsible for Corrective Action: Melissa Dempsey Contact Phone Number: 812-546-2000 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: I have spoken to the Food Service Director to ensure that 2 individuals are signing off on all the claims. Anticipated Completion Date: 3/1/2025

Context: During testing over controls for eligibility, we noted there was no formal, secondary review for the applications entered in the food service software determining eligibility. Additionally, there was no documented annual review by School Corporation personnel of the income eligibility guidelines used by the food service software. Contact Person Responsible for Corrective Action: Melissa Dempsey Contact Phone Number: 812-546-2000 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: I have spoken to the Food Service Director and she will begin printing the Skyward threshold guidelines and sign off on those/confirm they match the federal poverty guidelines. Anticipated Completion Date: August 2025

1. Corrective Action Step A. Strengthening Internal Controls Over Determination of Applications Demonstrating Questionable Eligibility The School Corporation will develop and implement a segregation of duties, ensuring that current individuals approve applications, perform Direct Certification checks, and conduct follow-up verifications of questionable applicatoins in a more directed manor. If an applicant provides a case number that does not appear on the Direct Certification list the School Corporation will: 1. Review the application based on standard income eligibility requirements, while confirming the application will remain subject to verification. 2. If $0 income is provided or the application is otherwise 'questionable' then the reviewing individual will add the following to the application comments field: reviewing individual name, reason for review request, to whom the application will be escalated. 3. Apply benefits to siblings, if appropriate. 4. Not complete the final step of marking the application as processed, rather leave it 'pending' and notify Director of School Nutrition of the need for this application to be reviewed. 5. Director of School Nutrition or designee will review and either confirm the DC status by downloading the certification or conduct follow-up verification. In either case, approved or verification for cause, the Director of School Nutrition or Designee will mark the application as processed. 6. If the verification for cause is not responded to in a timely manner, the status will revert to 'Paid' status as per 'verification for cause' guidelines. 2. Corrective Follow-Up and Reporting The School Corporation will review all applications from current year (FY 24-25) to identify any applications not subject to verification process. Management will report progress on implementing these corrective actions to the School Board and maintain records for review by auditors and state officials. 3. Anticipated Completion Date The review of current year (FY 24-25) applications will be completed March 21, 2025. The school board report will be completed April 11, 2025.

Context: During testing of activities allowed and unallowed/allowable costs, it was noted the School Corporation transferred $48,693 from the School Lunch Fund to the JCHS Prepaid Food/Trust Acct to settle negative student balances deemed uncollectible. Outstanding student debt resulting from nonpayment of school meals or milk is an unallowable expenditure to the nonprofit school food service account and cannot be absorbed by the food service program at the end of the school year. It must be paid for with other non-federal sources. Contact Person Responsible for Corrective Action: Shannon Current Contact Phone Number: 260-726-9341 Views of Responsible Official: We concur with the finding now that we have more clarifying information. Prior to this audit, we were told we had to use non-federal funds to write off the debt. The published documentation we had was vague as it only stated non-federal funds. With the assistance of our food service company, we were told that catering, adult meals, and al a carte were all non-federal funds. They also had a calculation for figuring out the amount of non-federal funds that we had to make sure it was enough to cover the negative debt. Description of Corrective Action Plan: Moving forward, I will make sure that any negative debt is written off using the operations fund, rainy day, or other approved fund. Anticipated Completion Date: The next time we are required to write off debt. Possibly June 30, 2025.

We were previously found to be compliant with time and effort based on a single annual survey, although DEW’s guidance states it should be done semi-annually. We will be changing time and effort reporting to at least twice annually, resolving this issue. One was completed September 2024 and another will be completed by February 2025.

Maywood-Melrose Park-Broadview School District 89 06-016-0890-02 CORRECTIVE ACTION PLAN FOR CURRENT YEAR AUDIT FINDINGS22 Year Ending June 30, 2024 Corrective Action Plan Finding No.: 2024- 005 Condition: It was noted during the audit that ineligible expenditures were charged to the food service expenditure function. These expenditures were for a back-to-school picnic and consisted of backpacks with school supplies that were provided to students. These expenditures should not have been charged to the food service function in the District’s general ledger system. Plan: The district is reviewing all expenditures monthly to ensure all of them are recorded with the proper account code. Any changes needed will get a journal entry through the Proviso Treasurer’s Office. Anticipated Date of Completion: June 30, 2025 Name of Contact Person: Scott Wold, Business Manager

Maywood-Melrose Park-Broadview School District 89 06-016-0890-02 CORRECTIVE ACTION PLAN FOR CURRENT YEAR AUDIT FINDINGS22 Year Ending June 30, 2024 Corrective Action Plan Finding No.: 2024- 004 Condition: The District has a contract with Open Kitchens for meals served under the Child Nutrition Cluster. In early fiscal year 2024, the District received notice that the method of payment to this vendor was to change to ACH. After further correspondence, the District remitted an ACH payment for three months of services for $936,828. The District subsequently discovered that the ACH was remitted to a fraudulent vendor. Plan: The district’s plan is any request through ACH will first get a call to the accounts receivable department at the company to ensure this is the proper way of making payment. The district will also follow up with a second call to our account rep to verify that the information is correct. The original payment to the vendor will be a small portion of the payment to verify the information. After this payment, a call will be made to accounts receivable to ensure payment. Anticipated Date of Completion: June 30, 2025 Name of Contact Person: Scott Wold, Business Manager

Context: For 5 selections, in a sample of 5 payroll transactions, the School Corporation did not have time and effort logs to support the portion of the employees’ time charged to the grant. The employees’ time was split with a non-federal fund; however, the School Corporation did not have support for the allocation of the time charged to the School Lunch fund. Contact Person Responsible for Corrective Action: Chris Scott Contact Phone Number: 765-544-2246 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The School Corporation will implement a formal time and effort reporting system for all employees whose salaries are partially funded by federal grants. Our Café department has since revised our process and no longer charge any SES employee payroll to the Café Account for cleaning. As a result, this issue has been fully addressed and should not recure in future reporting periods Anticipated Completion Date: July 2024

Context: During testing over controls for eligibility, we noted there was no formal, secondary review for the applications entered in the food service software determining eligibility. Additionally, there was no documented annual review by School Corporation personnel of the income eligibility guidelines used by the food service software. Contact Person Responsible for Corrective Action: Chris Scott Contact Phone Number: 765-544-2246 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: A new Food Service Director has been hired and will take responsibility for ensuring compliance with eligibility requirements. Additionally, the Business Manager will oversee the corrective actions and implement a formal secondary review process. The Business Manager will conduct and document secondary reviews for all applications entered into the food service software to verify eligibility determinations. This ensures compliance with regulatory standards and addresses the deficiencies noted in the audit findings. Anticipated Completion Date: June 2025

The District will reduce net cash resources by investing in capital equiment where necessary and allocating direct cost overhead expenditures.

CORRECTIVE ACTION PLAN Department of Education: The Baldwin-Whitehall School District respectfully submits the following corrective action plan for the year ended June 30, 2024. Name and address of the independent public accounting firm: J. Martin and Associates, LLC P.O. Box 498 Beaver, PA 15009 Audit period: June 30, 2024 The findings for the year ended June 30, 2024 schedule of findings are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Section B – Financial Statement Findings 2024-1 Best Practices Recommendation: Ideally, the District would hire the number of staff necessary to segregate all duties. However, we realize segregation of duties is not practical, if not impossible. Because of this internal control situation, the responsibility of the Business Manager is greatly increased because the Board must rely on his knowledge of the everyday operations to discover any material changes in the School District’s financial position. Management’s Response: The School District recognizes that the limited number of staff adds to the risk associated with the daily operations. To mitigate this risk, the Business Manager has to take an active role in the day-to-day operations of the Business Unit. He actively reviews all reconciliations and receipts to ensure they are posted to the accounting system properly. In addition, he approves all check disbursements through the Positive Pay process and physically signs every accounts payable check that is issued by the School District. Recommendation: We recommend that the District strongly encourage the tax collectors to obtain a SOC report in order to ensure proper controls are in place. Management’s Response: The School District understands the importance of obtaining SOC reports from service organizations and will continue to inquire of the appropriate entities to ensure they obtain the proper reports. In discussion with the Delinquent Tax Collector, they notified the District that it is extremely cost prohibitive for them to go through a review that would end with the issuance of a SOC report. Section C – Major Federal Award Findings 2024-2 Segregation of Duties – Child Nutrition, Title I, ESSER Recommendation: Ideally, the District would hire the number of staff necessary to segregate all duties. However, we realize segregation of duties is not practical, if not impossible. Because of this internal control situation, the responsibility of the Business Manager is greatly increased because the Board must rely on his knowledge of the everyday operations to discover any material changes in the School District’s financial position. Management’s Response: The School District recognizes that the limited number of staff adds to the risk associated with the daily operations. To mitigate this risk, the Business Manager has to take an active role in the day-to-day operations of the Business Unit. He actively reviews all reconciliations and receipts to ensure they are posted to the accounting system properly. In addition, he approves all check disbursements through the Positive Pay process and physically signs every accounts payable check that is issued by the School District. If you have questions about this report or need additional financial information, please contact Mark Cherpak, Business Manager at: 4900 Curry Road Pittsburgh, PA 15236 412-884-6300

CORRECTIVE ACTION PLAN

2024-004 FINDING Contact Person – Thomas A. Jerome, Superintendent Corrective Action Plan – The District will implement policies and procedures to ensure all students who receive a free or reduced meal have a current and accurate application on file. Completion Date – March 31, 2025

2024-003 FINDING Contact Person – Thomas A. Jerome, Superintendent Corrective Action Plan – The District will implement policies and procedures for verifying free and reduced applications. Completion Date – March 31, 2025

Finding 2024-003 School Nutrition Program Meal Claims 1. Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. 2. Actions Planned in Response to Finding The District has already begun evaluating current procedures for accurately monitoring, recording, and reporting the number and type of meals served. 3. Official Responsible Mr. Greg Johnson, Superintendent, is the official responsible for ensuring corrective action. 4. Planned Completion Date The planned completion date is June 30, 2025. 5. Plan to Monitor Completion The Board of Directors will be monitoring this Corrective Action Plan.

The District took immediate steps to remedy the issue, new reviews are required before and after submission. The Business Manager and Food Services Director have implemented the changes.

FINDING 2024-001 Finding Subject: Child Nutrition Cluster – Procurement and Suspension and Debarment Summary of Finding: The School Corporation did not verify that a vendor was neither suspended nor debarred. Contact Person Responsible for Corrective Action: Jessica Espinoza Contact Phone Number and Email Address: (219)836-9111 jbespinoza@munster.us Views of Responsible Officials: We concur with the finding. All vendors have been verified for suspension and debarment, thereafter. This was the only vendor that was missed. All employees have been trained to check for vendor suspension or debarment. Description of Corrective Action Plan: The School Corporation will ensure that the vendor is either listed in SAM.gov or states in their contract that they are neither suspended nor debarred. Anticipated Completion Date: March 2025

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, Summer Food Service Program for Children, Fresh Fruit and Vegetable Program Assistance Listing Number: 10.553, 10.555, 10.559, 10.582 Federal Award Numbers and Years (or Other Identifying Numbers): FY 22-23, FY 23-24 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Significant Deficiency Context: For the two small purchase method procurements sampled for testing, we noted that the School Corporation did not obtain quotes from an adequate number of qualified sources. Additionally, the School Corporation did not perform a suspension and debarment check on the vendors. The sample items were for $76,200 and $31,639 worth of repair supplies in FY2023 and FY2024, respectively. Contact Persons Responsible for Corrective Action: Andrew J Nicodemus, Business Manager Amber Reed, Director of Food Services Contact Phone Number: 765-362-2342 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Crawfordsville Community School Corporation plans to review all internal control procedures, including the controls over Procurement and Suspension and Debarment for the Child Nutrition Cluster. After this review, we will implement a system to ensure that the proper procedures are completed and fully integrated into our internal control structure. We will implement additional training for all staff involved and will have a designated place where this support is kept. Anticipated Completion Date: We expect this Corrective Action to be implemented by the end of March 2025.

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, Summer Food Program, School Summer Food Service Program, Fresh Fruit and Vegetable Program Assistance Listing Number: 10.553, 10.555, 10.559, 10.582 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 Context: During testing over controls for eligibility, we noted there was no formal, secondary review for the applications entered in the food service software determining eligibility. Additionally, there was no documented annual review by School Corporation personnel of the FY23 income eligibility guidelines used by the food service software. The School Corporation did formally review the FY24 income eligibility guidelines used in the food service software. Contact Persons Responsible for Corrective Action: Andrew J Nicodemus, Business Manager Amber Reed, Director of Food Services Contact Phone Number: 765-362-2342 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Crawfordsville Community School Corporation plans to review all internal control procedures, including the controls over Eligibility for the Child Nutrition Cluster. After this review, we will implement a system to ensure that the Eligibility and Application review procedures are appropriate and fully integrated into our internal control structure. We will implement additional training for all staff involved and will have a designated place where this support is kept. Anticipated Completion Date: We expect this Corrective Action to be implemented by July 31, 2025.

Finding #2024-008 – Significant Deficiency. Applicable federal programs: U. S. Department of Agriculture, Passed through Texas Education Agency: School Breakfast Program, AL#10.553, Contract #: 71402301, Contract period: 10/01/22 – 09/30/23, School Breakfast Program, AL#10.553, Contract #: 71402401, Contract period: 10/01/23 – 09/30/24, National School Lunch Program, AL#10.555, Contract #: 71302301, Contract period: 10/01/22 – 09/30/23, National School Lunch Program, AL#10.555, Contract #: 71302401, Contract period: 10/01/23 – 09/30/24. U. S. Department of Education, Passed through Texas Education Agency: Special Education Grants to States, AL#84.027A, Contract #: 246600011238076600, Contract period: 08/08/23 – 09/30/24, Special Education Preschool Grants, AL#84.173A, Contract #: 24660011238076610, Contract period: 08/08/23 – 09/30/24, Special Education Preschool Grants, AL#84.173X, Contract #: 24660011238076610, Contract period: 10/01/22 – 09/30/23. Condition and context: Same as finding #2024-006. Recommendation: Same as finding #2024-006. Planned corrective action: Same as finding #2024-006. Responsible officer: Chief Financial Officer – Lea Ann Hendrick. Estimated completion date: Same as finding #2024-006.

Finding #2024-007 – Significant Deficiency. Applicable federal programs: U. S. Department of Agriculture, Passed through Texas Education Agency: School Breakfast Program, AL#10.553, Contract #: 71402301, Contract period: 10/01/22 – 09/30/23, School Breakfast Program, AL#10.553, Contract #: 71402401, Contract period: 10/01/23 – 09/30/24, National School Lunch Program, AL#10.555, Contract #: 71302301, Contract period: 10/01/22 – 09/30/23, National School Lunch Program, AL#10.555, Contract #: 71302401, Contract period: 10/01/23 – 09/30/24. U. S. Department of Education, Passed through Texas Education Agency: Special Education Grants to States, AL#84.027A, Contract #: 246600011238076600, Contract period: 08/08/23 – 09/30/24, Special Education Preschool Grants, AL#84.173A, Contract #: 24660011238076610, Contract period: 08/08/23 – 09/30/24, Special Education Preschool Grants, AL#84.173X, Contract #: 24660011238076610, Contract period: 10/01/22 – 09/30/23. Condition and context: Same as finding #2024-004. Recommendation: Same as finding #2024-004. Planned corrective action: Same as finding #2024-004. Responsible officer: Chief Financial Officer –