Corrective Action Plans

Findings #2024-001 and #2024-003 – 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: Develop procedures to reconcile accounts payable batches to the related check run, restrict set up of vendors in the check processing application, and develop budget versus actual reporting for the corporate office. Planned corrective action: Management has already developed a process to reconcile accounts payable batches extracted from the Concur system to the related check run in the Ascender general ledger system. In addition, management will create a separation of duties for bank reconciliations and the setup of new vendors. Our financial analyst will also consistently develop budget versus actual reports for the corporate office as is done for the schools. Responsible officer: Kevin Byrne, Vice President of Finance. Estimated completion date: January 1, 2025.

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF AGRICULTURE, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, CHILD NUTRITION CLUSTER – FEDERAL ALN 10.553, 10.555, AND 10.559 2024-001 Internal Control Over Compliance With Federal Suspension and Debarment Requirements Finding Summary - 2 CFR § 180 requires Independent School District No. 834 (the District) to establish and maintain effective internal control over compliance with requirements applicable to its federal program expenditures, including applicable suspension and debarment requirements. The District did not have sufficient controls in place within the child nutrition cluster federal programs to assure that it was not contracting for goods or services with parties that are suspended or debarred, or whose principals are suspended or debarred from participating in contracts involving the expenditures of federal program funds. Corrective Action Plan Actions Planned – The District will review policies and procedures relating to suspension and debarment for child nutrition cluster federal programs and will ensure that all parties with which it contracts for goods or services are eligible to participate in contracts involving the expenditures of federal program funding. Official Responsible – The District’s Executive Director of Operations, Mark Drommerhausen. Planned Completion Date – June 30, 2025. Disagreement With or Explanation of Finding – The District agrees with this finding. Plan to Monitor – The District’s Executive Director of Finance, Marie Schrul, will monitor the implementation of these corrective actions to ensure appropriate controls are in place to verify that any vendor with which the District contracts for federal program goods or services exceeding $25,000 is not listed as suspended or debarred on the federal Excluded Parties List System website.

Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. 2. Actions Planned in Response to Finding: The District will obtain proper documentation to pay increases and online food service applications. 3. Official Responsible for Ensuring CAP: Megan Gracia, Business Manager, is the official responsible for ensuring corrective action for compliance. 4. Planned Completion Date for CAP: The planned completion date is June 30, 2025. 5. Plan to Monitor Completion of CAP: The School Board of ISD No. 508 will be monitoring this corrective action plan.

Identifying Number: 2024-005 Reporting – Significant Deficiency U.S. Department of Agriculture Passed through Missouri Department of Elementary and Secondary Education Child Nutrition Cluster, Assistance Listing No. 10.555 (National School Lunch Program), 10.553 (School Breakfast Program), 10.582 (Fresh Fruit and Vegetable Program) Federal award year 2023-2024 U.S. Department of Education Passed through Missouri Department of Elementary and Secondary Education Education Stabilization Fund, Assistance Listing No. 84.425C (Governor’s Emergency Education Relief Fund), 84.425D (Elementary and Secondary School Emergency Relief Fund), 84.425U (American Rescue Plan-Elementary and Secondary School Emergency Relief), 84.425W (American Rescue Plan-Elementary and Secondary School Emergency Relief-Homeless Children and Youth) Federal award year 2023-2024 Summary of Finding: Criteria: The Uniform Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance retirements. This includes controls to ensure that reports submitted are timely, complete, and accurate. Condition: The District did not have internal controls in place for federal reports to be reviewed for completeness and accuracy prior to submission. Cause: A lack of controls that could reasonably ensure this review had been performed by someone other than the preparer of the information. Effect or potential effect: The potential effect is submitting incomplete or inaccurate reports. Questioned costs: None Context: For all sample selections tested in the major programs, all reports were submitted timely and appeared to be accurate, however, there was no evidence that these reports were reviewed for completeness and accuracy prior to submission. Identification as a repeat finding, if applicable: Not applicable. Corrective Action: To ensure the accuracy of Federal reports/claims, Food service will implement the following procedures: Federal reporting and claims will be reviewed for accuracy and completeness by the Food service director or designee before they are submitted. The food service director or designee will initial report to document this review. Finance department personnel will implement the following procedures for other federal programs: One employee will start the ePeGS process. This employee will forward the documentation that they used to prepare the ePeGS filing to their supervisor. The supervisor will review the documentation and the items entered into ePeGS for accuracy. Once the supervisor is satisfied that the ePeGS filing is correct, he or she will submit the ePeGS filing. This process will be documented in the ePeGS history. Anticipated Completion Date: June 2025 (for the year ending June 30, 2025). Contact Person: Steve Marriott, Controller 816-321-5000 Steve.marriott@nkcschools.org

Identifying Number: 2024-003 Suspension and Debarment—Material Weakness U.S. Department of Agriculture Passed through Missouri Department of Elementary and Secondary Education Child Nutrition Cluster, Assistance Listing No. 10.555 (National School Lunch Program), 10.553 (School Breakfast Program), 10.582 (Fresh Fruit and Vegetable Program) Federal award year 2023-2024 Summary of Finding: Criteria: The Uniform Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance retirements. Also, the Uniform Guidance (2 CFR 200.212 and 200.318(h)) stipulates that when a nonfederal entity enters into a contract or purchase with an entity (vendor or subrecipient), the nonfederal entity must verify the entity is not suspended or debarred from participation in federal programs/grants when expending $25,000 or more in a year. Condition: The District did not have controls in place to reasonably ensure any entity receiving more than $25,000 in federal grant funds was not suspended or debarred, prior to providing them with federal funds. Cause: A lack of controls to reasonably ensure this verification was performed. Effect or potential effect: The District did not have controls in place to reasonably ensure compliance with suspension and debarment requirements of the Uniform Guidance. The potential effect is submitting unallowable costs, or loss of federal funding. Corrective Action: Management has developed the following procedures to ensure that vendors are not suspended or debarred: • All current vendors will be checked against Sam.gov on a quarterly basis. • All vendors receiving Federal funds of $25,000 or greater will be checked prior to completion of any purchase requisition. • All vendor applicants will be required to sign a Certified document that they are not suspended or debarred along with the Vendor App. • All bids will have a Certified document included for vendors to submit that declares they are not suspended or debarred. Anticipated Completion Date: December 2024 (for the year ending June 30, 2025). Contact Person: Stacy Swenson, Director of Purchasing 816-321-5016 Stacy.swenson@nkcschools.org

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF AGRICULTURE, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, CHILD NUTRITION CLUSTER – FEDERAL ALN 10.553 AND 10.559 2024-001 Internal Control Over Compliance With Federal Suspension and Debarment Requirements Finding Summary - 2 CFR § 180 and 2 CFR § 200.318-327 requires Independent School District No. 719, Prior Lake-Savage Area Schools (the District) to establish and maintain effective internal control over compliance with requirements applicable to federal program expenditures, including suspension and debarment requirements applicable to the child nutrition cluster federal programs. During our audit, we noted the District did not have sufficient controls in place within its child nutrition cluster federal programs to ensure compliance with federal requirements related to assuring that the District was not contracting for goods or services with parties that are suspended or debarred, or whose principals are suspended or debarred from participating in contracts involving the expenditures of federal program funds. Corrective Action Plan Actions Planned – The District will review its policies and procedures relating to suspension and debarment for its federal programs to ensure compliance with the Uniform Guidance in the future. The review of procedures will also include steps to assure that district personnel are following the requirements of the Uniform Guidance related to suspension and debarment, including maintaining appropriate documentation. Official Responsible – The District’s Executive Director of Business Services, Tammy Fredrickson. Planned Completion Date – June 30, 2025. Disagreement With or Explanation of Finding – The District agrees with this finding. Plan to Monitor – The District’s Executive Director of Business Services, Tammy Fredrickson, will assure appropriate internal controls and procedures are in place to ensure compliance with suspension and debarment requirements.

The District relies on the auditor to propose adjustments necessary to prepare the schedule of expenditures of federal awards including the related note disclosures. The District reviews schedule of expenditures of federal awards and approves all adjustments.

The District will monitor vendors to ensure they are able to accept federal monies. The District will also review all invoices relating to bids to verify correct charges. This will be completed by Ashley Simmons, Accounts Payable Clerk by 6/30/2025.

Finding 2024-004 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 will evaluate current procedures for accurately monitoring, recording, and reporting the number and type of meals served. 3. Official Responsible Mr. Michael Malmberg, Superintendent, 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 Number: 2024-002 Finding Synopsis: The District submitted a claim for meals higher than the count actually served for the month due to a clerical error. The District did not have someone, other than the preparer of the monthly claim, review the claim before it was submitted to ensure its accuracy. Action Steps: Management plans to implement a review process to ensure the claim forms are filled out correctly. Contact Person: Jeffrey Schubert Chief School Business Official 779-244-1000 Anticipated Completion Date: 6/30/2025

Finding Number: 2024-001 Finding Synopsis: In the population of 40 applications selected for testing, an exception was noted on 1 of the applications. This exception stemmed from the "pay frequency" section of the application, where the person filling out the application left this section blank, thereby creating an issue where it was not possible to calculate the household's annual income. However, the District still approved the application for free status. The District noted that the frequency was confirmed verbally, however failed to obtain physical documentation. It does appear, however, that the student was appropriately classified as free status. Action Steps: Management plans to implement procedures to ensure applications are appropriately reviewed for completeness before approving. Contact Person: Jeffrey Schubert Chief School Business Official 779-244-1000 Anticipated Completion Date: 6/30/2025

2024-003 – Eligibility. Auditor Description of Condition and Effect. In our sample of 40 applications from all students receiving free or reduced cost meals during the year, we noted one instance in which the point of sale (POS) system used by the District classified a student to be free, however, application reviewed by the District indicated ineligible to receive free and reduce meal. The student received free-price meals during the 2024 school year. As a result of this condition, the District granted free lunch to a student that did not meet the eligibility requirements. Auditor Recommendation. The district should perform a review of the POS system to match with the application to ensure only eligible students are provided with free and reduced meal. Responsible Person: Scott Leach, Superintendent and Crystal Lee, Food Service Director.Corrective Action. Management concurs with the finding. The district has already put in multiple checks and procedures for food service. The Point of Sale now has custom reports to help make sure students are in the Point-of-Sale system correctly. The Eligibility listing will be verified multiple times throughout the year. The district has set up weekly meetings with the Food Service Director, Superintendent Administrative Assistant, and the Business Manager. Anticipated Completion Date: June 30, 2025.

Finding 2024-004 - Material Weakness and Material Noncompliance: Eligibility and Reimbursement Request for Child and Adult Care Food Program Corrective Action: The District will collaborate with MDE Nutrition staff to complete training, staff assistance visits, and previously established corrective actions. The Business Director and Food Service Director will schedule additional training and visits with Nutrition liaisons and MDE PAL partners. The District will implement electronic point-of-sale devices and digital filing systems to improve recordkeeping and sharing. Documented training for YCS Food Service Staff will be ongoing. District monitoring will be reinstated to ensure compliance with pre-COVID standards. Responsible Person: Director of Finance and Food Service Director

Finding 2024-002 - Material Weakness: Budget Violations Corrective Action: The Finance Director and Business Office will undergo additional training with Tyler Technologies, Michigan School Business Officials and others to optimize financial processes and transaction processing. The team will adhere to the state business calendar for timely reconciliations, budget amendments, and internal control reviews. Responsible Person: Director of Finance

Finding 2024-004 – Child Nutrition Cluster – Special Tests and Provisions – Paid Lunch Equity Contact Person Responsible for Corrective Action: Marsha Bohannon, Controller Contact Phone Number: (317) 867-8000 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The food service director will complete the Paid Lunch Equity spreadsheet, provide the spreadsheet and all supporting documents to the controller for review. Once approved, it will be submitted to the Indiana Department of Education. The supporting documents will either be scanned in or paper documents will be retained for future audit. Anticipated Completion Date: November 19, 2024

Finding 2024-003 – Child Nutrition Cluster – Procurement Contact Person Responsible for Corrective Action: Marsha Bohannon, Controller Contact Phone Number: (317) 867-8000 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We will contact our educational service center and see if they are able to either do an RFI or RFP for food service equipment maintenance or we will otherwise request three quotes for small purchases. We are currently under a contract with SmartCare for food service equipment maintenance until the end of this current school year. Anticipated Completion Date: July 1, 2025

Finding 2024-002 – Child Nutrition Cluster – Reporting Contact Person Responsible for Corrective Action: Marsha Bohannon, Controller Contact Phone Number: (317) 867-8000 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The food service director will pull the End of Day Summary Reports from Lunchtime and input the information into the Child Nutrition Portal. All reports will be provided to the controller to confirm accuracy. Once reviewed and approved, the food service director will submit the report through the Child Nutrition Portal. All documents will be scanned together and be retained for audit. Anticipated Completion Date: October 2, 2024

Finding 2024-001 – Child Nutrition Cluster – Eligibility Contact Person Responsible for Corrective Action: Marsha Bohannon, Controller Contact Phone Number: (317) 867-8000 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: School corporation personnel will conduct an annual review of the income eligibility guidelines used by the food service software. The review will ensure that the guidelines are current, accurate, and consistent with federal and state requirements. The results of the review will be documented, and any necessary updates or changes will be implemented promptly. Anticipated Completion Date: November 13, 2024

To allocate direct cafeteria overhead costs and plan capital equipment purchases for cafeteria equipment to enhance delivery of student meals which will ensure reduction of net cash resources so as to not exceed three months of expenditures. In addition to the current mechanisms in place to utilize net cash resources, a formula was obtained and will be used to ensure the correct amount is spent. During the 23-24 school year, the district received additional covid related funding which also contributed to excess net cash resources.

Condition: There was no termination clause noted in the Aramark contract stating whereby either party may cancel for cause with 60-day notification as required by 7 CFR 210.16(d) and 7 CFR 220.7(d)(4). Plan: The Aramark contract will be updated to include the proper termination clause stating whereby either party may cancel for cause with 60-day notification. Anticipated Date of Completion: June 30, 2025 Name of Contact Person: Dr. Joel Hackney, Superintendent Management's Response: Management will ensure the Aramark contract has been updated with the proper termination clause before signing another contract.

Corrective Action Plan: The School District has begun taking action to address this issue, as follows: Equipment Improvement - School Food Service Director, Joe Kilmer, Food Service Manager, Ann Overhiser, and the School Business Administrator have plans to improve and replace cafeteria equipment. The replacement plan will be completed in conjunction with the School District’s upcoming Capital Project. This work was originally expected to be included in a prior project but due to scheduling issues, is now included in the upcoming project which is expected to be completed by August 31, 2026. Retained Balance for Pending Settlements - Wages will increase into 2025 and beyond. The minimum wage in New York State is expected to continue to rise according to legislation. The rate will rise to $15.50 per hour by the end of 2024 and to $16.00 per hour by the end of 2025. Annual increases will be published by the Commissioner of Labor and based on a number of economic factors. Due to the critical labor shortage, the School District recently increased hourly wages for food service helpers and cooks in order to attract additional workers to maintain operations. Enhanced Meals - The Food Service Director and Food Service Manager continue to take steps to improve food options. They include making improvements to center of the plate options and improving local food options as well. In addition, the School District plans to spend a portion of the School Lunch excess cash on cafeteria equipment as a part of its upcoming Capital Project which is expected to be completed by August 31, 2026. Anticipated Correction Date: August 31, 2026 Contact Information: Lisa Kuhnel Shared School Business Administrator Odessa - Montour Central School District 300 College Avenue Odessa, New York 14869

The Board of Trustees has designated the responsibility of overseeing the accounting and financial reporting to the District’s superintendent, Jeff Byrd. See the District’s responses to this finding in the letter provided by the District on page 103. Finding 2024-002 - Significant Deficiency - Verification of Eligibility for Free or Reduced Price Meals The District has reviewed the findings and identified areas of improvement for Child Nutrition. The district will audit the Child Nutrition information after verification each year to ensure that the correct changes have been made in the software. Internal Controls will be reviewed and strengthened to ensure proper coding moving forward.

The District Corrective Action Plan is to follow the corrective action plan set forth in the site review by the State of Alaska Child Nutrition Program to have intense staff meetings with cooks and meal counters to make sure point of service meal counts in the cafeteria or in the classroom are clear and accurate for reporting. School sites visits, discuss counting at point of service, claiming, reimbursable meals, production records, ordering, safety and hygiene. Attend monthly zoom with School Meals Program (Dept. of Education).

Condition: During our review of Food Service funds, we noted that the numbers of meals served was less than the amount that was submitted for reimbursement. Criteria: When a recipient of federal food service money goes to submit for reimbursement, the amount of meals that are served should match up with the reporting out of the recipients system to ensure proper reimbursement is taking place. Cause: The Food service department did not have a proper reconciliation practices to ensure accurate reporting Effect: Funds may be overdrawn. Perspective: The majority of the buildings were accurate as we found during testing, with high turnover in the space training may not have taken place. Recommendation: We recommend training of all food service recording staff as well as the Director of Food service understand that the reimbursement of meals report should match the meals served reporting that documents each day of the meals served. It should also be noted that the meals served documents needs to have oversight to ensure those reports are accurate on a daily basis. Views of Responsible Officials and Planned Corrective Actions: Haven USD 312 staff involved are undergoing training to learn requirements. Processes and procedures are being developed to ensure proper record keeping and reporting.

2024-001 – Payments to Vendors Corrective Action Plan: The School District is committed to following policy and producing the most accurate financial data possible. Once this error was identified, management quickly investigated the cause and has worked to resolve the problem. The vendor has subsequently issued a credit to the district’s account. Management has and will continue to review and train with staff on proper internal controls to prevent or lessen the possibility of error in the future. Responsible Party(ies): Assistant Superintendent Anticipated Date of Completion: November 30, 2024