Corrective Action Plans

Findings #2024-002 and #2024-005 – Significant Deficiency and Other Non-Compliance - Reporting. Federal programs: U. S. Department of Agriculture, Passed through Texas Department of Agriculture, 10.553/10.555, Child Nutrition Cluster, Contract #’s: 202323N109946, 202424N109946 and 236TX400N8903. U. S. Department of Education, Passed through Texas Education Agency, 84.010, Title I Grants to Local Educational Agencies, Contract #’s: 23610101108807 and 24610101108807, 84.367, Supporting Effective Instruction State Grants. Contract #’s: 23694501108807 and 24694501108807. Condition and context: During our testing of GAAP and FASRG coding, we identified 4 of 200 payroll transactions coded to the incorrect function code and 3 of 120 non-payroll transactions coded to the incorrect object code. Additionally, during our testing of non-payroll transactions, we identified 3 of 120 nonpayroll transactions coded to the incorrect fiscal year. Recommendation: Reemphasize current policies and procedures to ensure proper coding of disbursements based on the organization’s chart of accounts and FASRG codes. Planned corrective action: IDEA will provide FASRG training to all staff with purchasing and payroll coding authority to minimize coding errors. This training will be conducted from January to May 2025. Responsible officers: Sonya Wilson, VP of Accounting and James Dworkin, VP of Accounting (Interim). Estimated completion date: May 1, 2025.

Subject: Regarding Audit Finding 2024-003: Reporting (50000) Finding 2024-003: We agree with the auditor’s comments, and the following actions will be taken to ensure proper records are maintained and reconciled: 1. The District is working with the point-of-sale vendor to be able to add a separate afterschool snack meal schedule to our system to accurately record snacks served in real-time. This will replace hand-tallied counts and reduce the risk of mathematical errors 2. Staff will conduct daily reconciliation of snack counts in the point of sale system to ensure accuracy 3. Monthly audits will be performed in against claim forms in advance of reimbursement claims tha tare submitted to the California Department of Education 4. The point-of-sale system will support the District’s ability to maintain accurate records and reconciliations for compliance purposes. The above steps will be implemented by April 2025 and the District maintains that it will continue the actions above to follow Child and Adult Care Food Program, Child Nutrition Cluster guidelines.

Nutrition Cluster – CFDA Nos. 10.553 and 10.555 Significant Deficiency in Internal Controls over Compliance: See Find-ing 2024-001

Nutrition Cluster – CFDA Nos. 10.553 and 10.555 Name of contact person – Kimberly Russian, Business Manager Recommendation: We recommend the Food Service Director more closely review all meal count information entered for reimbursement pri-or to submitting each monthly claim to ensure accuracy and consistency with supporting documentation. We recommend that the Food Service Director review all monthly claims filed in fiscal year 2024-25 that are available for revisions, to ensure reports were accurately filed. Further, we recommend that District management periodically monitor claim submissions for accuracy. Action Taken: Management agrees with the recommendations. The Food Service Director has reviewed all monthly claims submitted in school year 2024-25 and found no errors requiring revision. Further, management will implement a plan to periodically review claim submis-sions for accuracy. Proposed Completion Date: January 31, 2025

Child Nutrition Cluster – Assistance Listing No. 10.553, 10.555, 10.559 Recommendation: Auditor 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 micro purchases, along with adding controls to ensure that the item purchased was received by the District. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We continue to look for ways to segregate duties and will improve on the review process for micro purchases but with the current financial situation, additional staff cannot be added. Name(s) of the contact person(s) responsible for corrective action: Lisa Miller Planned completion date for corrective action plan: Ongoing. If the oversight agencies have questions regarding this plan, please call Lisa Miller at 715-887-9000.

District Response and Corrective Action Plan: The Business Office will monitor the list at SAM.gov monthly and will check new vendors against the suspendered and debarment list. The District will not work with debarred vendors.

2024-001 - Nonmaterial Noncompliance - Eligibility Program: Child Nutrition Cluster (ALN 10.553 and 10.555) - United States Department of Agriculture; Federal Award Year: 2024 Responsible Officials: John Wack, Chief Financial Officer, Henrico County Public Schools Planned Corrective Action: School Nutrition Services Leadership has put a new process in place, to run a report from the point-of-sale system weekly, that will catch any "Manual" updates to lunch statuses. This report will be run weekly and verified by either the Dietitian or Controller. The report will be initialized and kept on file. Expected Completion Date: 12/31/24

Condition: The School District is required to account for all revenues and expenditures of its non-profit school food service account in accordance with state and federal requirements. In order to ensure that federal reimbursement payments received monthly from the Michigan Department of Education are correctly credited to the school food service account, monthly bank reconciliations should be prepared and reviewed by individuals with requisite skill and experience. During the 2024 fiscal year, bank reconciliations and monthly reconciliations of food service revenues and expenditures of the school food service account were not being prepared and reviewed in a timely manner. As there was an unexpected reduction in staff resources in the business office, there were not adequate resources to perform these accounting reconciliations on a timely regular basis during the year. The absence of these timely regular reviews could lead to undiscovered errors in the school food service account and material noncompliance with federal regulations. Planned Corrective Action: The School District agrees that its internal control structure should ensure that accounting reconciliations are prepared and reviewed in a timely manner during the year. Although the School District had an intergovernmental Agreement with its Intermediate School District to provide business services, such services could not be rendered due to inability to find staffing. Near the end of the 2024 fiscal year, a Finance Director was directly hired into the business office. Monthly reconciliations of accounting records and closing of monthly books are now being performed and reviewed on a timely basis. Contact person responsible for corrective action: David Bergeron, Assistant Superintendent Anticipated Completion Date: July 1, 2024

Condition: The School District must submit monthly claims for reimbursement for meals served to eligible students within 60 days following the last day of the month covered by the claim (7 CFR sections 210.8, 220.11, 215.10, and 225.15 (c)). Upon preparation of meal reimbursement claims, the School District is required to have controls in place to ensure the accuracy of the request for reimbursement. The School District did not have a documented review process in place over the reimbursement requests. Meal counts entered into the Michigan Nutrition Data (MIND) system took place without a secondary review, which could result in incorrect reporting of the number of meals. The preparation of the request without a secondary review could result in incorrect reporting of the number of free and reduced priced meals, which could result in the School District being reimbursed an incorrect amount by the Michigan Department of Education. Planned Corrective Action: The School District's business office performed a detailed review of all meal claim submissions for the 2023-2024 fiscal year. Claims were accurately completed as was the amount of reimbursement paid by the Michigan Department of Education. The business office has since implemented a formalized internal control procedure beginning in July 2024, whereby a formal documented review of the meal claim submission is performed. Contact person responsible for corrective action: David Bergeron, Assistant Superintendent Anticipated Completion Date: July 1, 2024

Response and Corrective Action Plan: The District will annually prepare the indirect cost charged to the program based on the actual fiscal year trial balance. The District will provide an estimate to the Board each June to ensure proper approval of fund transfers.

Corrective Action Plan: The District established written procedures to ensure that we are using current eligibility verification through our Skyward Food Service Program. Anticipated Corrective Action Plan Completion Date: June 27, 2024 Contact Information: For additional information regarding this finding please contact Bill Trewyn, Business Manager, at 262-741-9143.

Finding 2024-001 Child 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 Academy will evaluate current procedures for accurately monitoring, recording, and reporting the number and type of meals served. 3. Official Responsible Jennifer Geraghty, Superintendent/Principal, is the official responsible for ensuring corrective action. 4. Planned Completion Date June 30, 2025. 5. Plan to Monitor Completion The Board of Directors will be monitoring this Corrective Action Plan.

Finding 2024-001 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 Academy will evaluate current procedures for accurately monitoring, recording, and reporting the number and type of meals served. 3. Official Responsible Thomas Thao, Executive Director, is the official responsible for ensuring corrective action. 4. Planned Completion Date June 30, 2025. 5. Plan to Monitor Completion The School Board will be monitoring this Corrective Action Plan.

To Whom It May Concern, Please accept this letter as a formal Corrective Action Plan for the district regarding the audit finding 2024-003, as listed in the FY 2024 Audit. During the 2024-2025 school year either a free and reduced application was misplaced/lost or the district incorrectly qualified the household children of a foster residence to be automatically qualified for free meals as is done with homeless households. Regardless, the district will take the following corrective actions to address the issue in the future: 1. The district has already begun using an electronic lunch application process through the new Student Information System, which should address the issue moving forward. This started with enrollment in the Fall of 2024. AND 2. The superintendent will review the qualification requirements with all staff members that are involved with the free and reduced lunch application process, as well as the district foster care liaison. The person responsible to provide this training will be the superintendent and the training will be completed by December 21, 2024. Sincerely, John French Superintendent of Schools Lewis County C-1 School District

Child Nutrition Cluster - Assistance Listing Nos. 10.553, 10.555, 10.559 Recommendation: We recommend the District review their controls and procedures surrounding procurement to ensure their purchasing policy is followed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The District will review the Sole Soure form on an annual basis to make sure the form has not expired. Name(s) of the contact person(s) responsible for corrective action: Debrah Jones, Director of Strategic Sourcing and Contract Management (SSCM) Planned completion date for corrective action plan: 12/31/2024

Finding 2024-004 Reporting – Child Nutrition Cluster Material Weakness in Internal Control Over Compliance Finding Summary: The District does not have an internal control system designed to review and ensure submitted free and reduced meal counts agree to underlying records. Responsible Individuals: Shannon Hunstad, Superintendent Corrective Action Plan: The District will review and strengthen the controls surrounding the review and submission of free and reduced meal counts to ensure they are supported and accurate. Anticipated Completion Date: June 30, 2025

U.S. Department of Education 10/22/2024 Marshall Public Schools respectfully submits the following Corrective Action Plan for the year ended June 30, 2024. Contact information for the individual responsible for the corrective action: Caleb Petet, SuperintendentMarshall Public Schools Independent Public Accounting Firm: Gerding, Korte & Chitwood, P.C., 723 Main Street, Boonville, MO 65233 Audit Period: Year ended June 30, 2024 The findings from the June 30, 2024, Schedule of Findings and Questioned Costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule Significant Deficiency 2024-001 Segregation of Duties Recommendation: We realize that because of limited resources and personnel, management may not be able to achieve a proper segregation of duties; however, our professional standards require that we bring this lack of segregation of duties to your attention in this report. Action Taken: The cost associated with hiring additional personnel does not support the justification to hire for the means. However, the District will continue to monitor the situation and implement recommendations as practical. Completion Date: June 30, 2025 Sincerely,Caleb Petet, Superintendent Marshall Public Schools

Berkeley School District No. 87 CORRECTIVE ACTION PLAN FOR CURRENT YEAR FINDINGS Year ending June 30, 2024 Corrective Action Plan Finding No.: 2024-002 Condition: During our audit of the Child Nutrition Cluster, we identified that the client did not have adequate disbursement controls in place. Specifically, duplicate invoices on multiple occasions were entered into the client’s software system due to typographical errors, resulting in payments being made twice to each vendor for the same service. Plan: The District will implement stronger internal controls over the disbursement process. This includes establishing a review and approval process for all invoices before payment, implementing software controls to detect duplicate invoices, and/or providing training to staff on proper invoice processing procedures to minimize typographical errors. Anticipated Date of Completion: 06/30/2025 Name of Contact Person: Irene Daciuk Management Response: See above

AAPS has corrected for this finding at the beginning of FY25 by having offer letters issued by our HR Manager to all employees. Offer letters are securely stored in individual employees’ personnel folders.

Finding Type: Significant Deficiency. Name of Contact Person: Jonathan Green, 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.

Contact Person Darin Scherr, Business and Operations Manager Corrective Action Plan The District agrees with the finding as presented. The child nutrition department will ensure both that the months are closed out in our software system so that data does not change after the fact and that original meal count reports ran from the system that match the claims filed with ND DPI are kept on file for the required time period. Corrective action has already taken place on a go forward basis starting when this was identified during audit testing. Completion Date Immediately

No. 2024-004 Subject: Reporting - Significant deficiency in internal control over compliance Name of Contact Person: Ingmar Berg, CFO Phone Number: (480) 270-5438 x1091 Anticipated Completion Date: June 30, 2025 Corrective Action: Management will implement internal controls related to documentation of approval for all monthly NSLP claims for reimbursement prior to submission. We will establish a formalized procedure to ensure that all monthly claims for reimbursement undergo documented management review and approval before submission. This procedure will clearly define the review process and designate responsible personnel for each step to maintain accountability. All reviewed and approved claims will be accompanied by signed documentation as evidence of compliance. All Food Service personnel involved in the reimbursement submission process will receive training on the new procedure to ensure understanding and adherence to the documentation requirements.

Name of Contact Person: Cindy Crabb, Superintendent. Recommendation: We recommend the District monitor the Child Nutrition profit made and ensure all expenditures used to operate the program are properly charged to the program. Corrective Action: We will ensure that all eligible costs are charged to teh program and modernize the equipment to reduce the accumulated carry-over. Proposed Completion Date: Immediately.

Name of Contact Person: Cindy Crabb, Superintendent. Recommendation: We recommend Food Service claims be submitted in a timely manner in order to maintain compliance with the requirements of the National School Breakfast/Lunch programs. Corrective Action: We will ensure that all future food service claims are submitted in a timely manner. Proposed Completion Date: Immediately.

Findings #2024-002 and #2024-004 – Significant Deficiency. Applicable federal programs: U. S. Department of Agriculture, Passed through Texas Department of Agriculture: School Breakfast Program, AL#10.553, Contract #’s: 202423N109946 and 202120N19946, National School Lunch Program, AL#10.555, Contract #’s: 202423N109946 and 202222N109946, U. S. Department of Education, Passed through Texas Education Agency: Special Education Grants to States, AL#84.027A, Contract #: H027A230008. Recommendation: Reemphasize the need for timely analysis and reconciliations of the balance sheet accounts. Planned corrective action: The School will perform timely analysis and reconciliation of the balance sheet accounts in accordance with the organization’s policies and procedures. Responsible officer: Kevin Byrne, Vice President of Finance. Estimated completion date: January 1, 2025.