Corrective Action Plans

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 Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY2023, FY2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Material Weakness Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the Child Nutrition Program and Procurement compliance requirements. Context: For one of 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. The sample item amount disbursed was $126,265 in FY23 and $59,748 in FY24 for food service equipment. The School Corporation was unable to provide support for the number of quotes obtained and a signed contract. The School Corporation was also not able to provide support that a suspension and debarment check was performed on the vendor. Corrective Action Plan: The School Corporation will implement internal control procedures to ensure the School Corporation is following their procurement policy to comply with state and federal requirements pertaining to procurement and suspension and debarment. The School Corporation will ensure that suspension and debarment checks are performed on vendors before entering into a contract and support will be maintained to show that the School Corporation followed policy and met state and federal compliance requirements. Person responsible for implementation and projected implementation date: The Food Services Director, Treasurer and Superintendent will oversee the implementation of the corrective action plan. The corrective action plan will be implemented immediately.

FINDING 2024-004 Finding Subject: Child Nutrition Cluster- Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Julie Remschneider Contact Phone Number and Email Address: julie.r@nn.k12.in.us, 219-285-2228 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The business official or superintendent will review and sign off and date the procurement and suspension and debarment documents. We will follow the internal control procedures beginning on p. 41 of the internal controls manual. Anticipated Completion Date: September 30, 2025

FINDING 2024-003 Finding Subject: Child Nutrition Cluster- Eligibility Contact Person Responsible for Corrective Action: Julie Remschneider Contact Phone Number and Email Address: julie.r@nn.k12.in.us, 219-285-2228 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The business official or superintendent will review and sign off and date the eligibility reports. Anticipated Completion Date: September 30, 2025

Action Plan: The determining official, Sherry Newman, Bookkeeper, will print each application and approve by initialing the application upon review. We have also submitted a request to the software company for an online approval process or check box to be added to the software.

Completion date of this action: Immediately

Corrective Action Plan Finding Number 2024-002 Condition: At June 30, 2024, the District maintained fund balances in excess of three months’ average expenditures. Management Response/Plan: The District has created a Spend Down Plan for the food service program based off guidance from the Illinois State Board of Education. The District is working on replacing equipment and renovating cafeterias. Anticipated Date of completion: June 2025 Name of Contact Person: Melissa Geyman Sell

Finding 2024-003 – Child Nutrition Cluster – Activities Allowed or Unallowed, Allowable Costs/Cost Principles 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 employee’s 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: Brad DeRome Contact Phone Number: 765-747-5222 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We will ensure all payroll amounts recorded to food service are reviewed to ensure they represent food service payroll activity only. Anticipated Completion Date: March 2025

2024-003 Contact Person–Brandon Baumbach, Business Manager Corrective Action Plan–The District will collect Worksheet G forms monthly from our nonpublic schools mirroring the process used for public schools through our child nutrition system. This will ensure consistent documentation and verification of data, and prevent future discrepancies. Completion Date - June 30, 2025

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

The food pantry acknowledges the finding and agrees with the recommendations. The responsible officials have committed to implementing the following corrective actions: develop and implement a comprehensive inventory management policy that includes the requirement for an annual physical inventory of donated foods, schedule and conduct the annual inventory observation for the current fiscal year and ensure it is completed by the end of the fiscal year, provide training to staff involved in the inventory process to ensure they understand and follow the new procedures and perform periodic internal audits to ensure ongoing compliance with the inventory management policy and address any issues identified.

Edit Check Worksheets will be matched to requests for State of NJ Division of Agriculture reimbursement on a monthly basis for accuracy.

Planned Corrective Action: The Department of Public Instruction (DPI) will complete and submit reports for subaward information in the FFATA Subaward Reporting System (FSRS) for the Child Nutrition Cluster (CNC) starting in fiscal year 2025. The internal processes established to ensure proper reporting of subaward information did not include payments made for Child Nutrition Cluster grants, as the Department did not believe the FFATA requirement applied to these awards. Upon notification that DPI is required to include these awards, the written policies and procedures are being updated to include processes to identify which subawards and subrecipients have exceeded $30,000 and complete the monthly FFATA reporting as required. Anticipated Completion Date: Person responsible for corrective action: Michael Brendel, Assistant Director School Financial Services Team Division of Finance and Management Department of Public Instruction michael.brendel@dpi.wi.go

Finding 2024-001 Written Procurement Polley- This finding impacts the procurement and suspension and debarment compliance requirement for the major program, Assistance Listing Number 10.555 National School Lunch Program (Child Nutrition Cluster) funded by the Commonwealth of Massachusetts Department of Elementary and Secondary Education (DESE). Nurtury should revise its procurement policy to comply with Uniform Guidance requirements and implement policies and procedures to search for suspended or debarred vendors on Sam.gov. Fiscal Year 2025. Procurement policy is in accordance with Uniform Guidance requirements. Management and the finance committee of the board will ensure that revised procurement policies are in accordance with Uniform Guidance requirements. Tubi Olatubosun, V.P. of Finance

Description of Corrective Action Plan: Shoals Community School Corporation’s Director of School Nutrition, Tamara Florio, will ensure that all time cards are signed by the employee and by herself before submitting to the Payroll Administrator, Darla Holt. Responsible Party and Time and Timeline for Completion: Tamara Florio, Director of School Nutrition-this will be implemented immediately, this 2024-2025 school year.

Boston Public Schools Food and Nutrition Services has begun implementing advanced policies including additional segregation of duties and additional documentation to ensure that all deposits made have clear and accurate cash receipt forms. Anticipated Completion Date: June 30, 2025 Responsible Contact Person: Colin Musto, Assistant City Auditor, Grants Monitoring Unit colin.musto@boston.gov

The School Corporation will establish an internal control process to esnure detailed records are maintained and an audit trail is evident to comply with federal compliance requirements. The Treasuer and the Deputy Treasurer will oversee the implementation of the corrective action plan, which will go into effect 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, Material Noncompliance, Qualified 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 eligibility compliance requirement. During the testing of internal controls over eligibility determinations via the application process and related compliance, we noted the School Corporation was not able to provide the application or any documentation to support the eligibility status for 6 out of the 8 applicant students selected for tested for the 2022-2023 school year. There were no issues identified for students selected for testing whose eligibility was directly certified. Additionally, for the 2023-2024 school year, for 2 out of 30 students selected for the testing, the income eligibility determinations were not properly implemented. One student was determined to be eligible for "Free" meals per their free/reduced application but, the School Corporation incorrectly entered the eligibility as "Reduced" within the food service software. Another student was eligible for "Reduced" benefits per the direct certified download file but was entered into the food service software as eligible for "Free" benefits. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Moving forward, the corporation will take more time in reviewing free and reduced applications to ensure student free or reduced status is listed correctly and supporting documentation is maintained. Applications are now completed online limiting paper copies. A review of applications by another member of the corporation staff will also be conducted. Responsible Party for Corrective Action: Terri Roesler, Treasurer, will oversee the implementation of the corrective action plan. Timeline for Completion: Immediately.

FINDING 2024-003 Finding Subject: Child Nutrition Cluster – Procurement and Suspension and Debarment Summary of Finding: The School Corporation did not have effective internal controls in place to ensure contracted vendors were not suspended or debarred or otherwise excluded from participation in federal award programs. The School Corporation could not provide evidence of verification for Resolve Tech during the engagement period. Contact Person Responsible for Corrective Action: Teresa Whitesel Contact Phone Number and Email Address: 765-358-4006 twhitesel@wes-del.org Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: The Corporation Treasurer was not aware of this requirement. This will be completed by the next audit period of FY2025 FY2026

FINDING 2024-004 Subject: Child Nutrition Cluster - Reporting 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): FY 22-23, FY 23-24 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness, Other Matters 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 cash management compliance requirement. Context: In a sample of 5 monthly claims for reimbursement selected for testing, the following compliance exceptions were noted: • Management failed to submit the April 2023 claim for reimbursement in a timely manner (within 90 days) to the IDOE and was not reimbursed for meals served as a result. • For the other 5 claims tested, the number of meals claimed did not agree to the supporting meal system reports. There was a gross overstatement of meals claimed of $21,189 and a gross understatement of meals claimed of $538.35 resulting in a net over-reimbursement of $20,650.47. We noted that the School Corporation has a secondary review control in place designed to review claims prior to submission to the IDOE. However, the control was not operating effectively to detect and prevent errors in the amount claimed for reimbursement. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Management has revised and implemented a more thorough control process over the preparation and submission of the monthly claims for reimbursement. A reconciliation sheet has been created and implemented for verification and will be completed every month. Responsible Party and Timeline for Completion: Jessica Defossett and Kendra Franks, January 2025

FINDING 2024-003 Subject: Child Nutrition Cluster - Internal Controls over Eligibility 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): FY 22-23, FY 23-24 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, 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. Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Franklin County Community School Corporation has transitioned to the Community Eligibility Provision (CEP) as an alternative to collecting, approving, and verifying household eligibility applications. Responsible Party and Timeline for Completion: Jessica Defossett, September 2024 transition to CEP

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 Procurement Audit Finding: Material Weakness Condition and Context: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the Child Nutrition Program and Procurement compliance requirement. The School Corporation utilizes two vendors for the majority of food and supplies purchases for the food service program. One vendor is procured through a purchasing cooperative, Southwest Indiana Co-op, where the School Corporation is a member. The other vendor met the simplified acquisition threshold for fiscal year 2023 and the small purchase threshold for fiscal year 2024. The School Corporation was unable to provide any supporting documentation for the procurement process undertaken as required by the School Corporation's procurement policy. Management stated the items purchased were chosen based on a comparison of prices with two other vendors, however, management had no documented support for the rationale or process to determine which vendor would be selected for food and supplies purchases. The sample item amount disbursed was $151,511 for food purchases in FY23 and $129,583 for food purchases in FY24. The School Corporation did properly confirm the vendor was not debarred or suspended. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The treasurer will provide the food service director with quarterly vendor reports so the spending thresholds can be monitored. In the event it is known that expenditures will exceed the threshold, the food service director will work to provide rationale for the vendor choice and/or procure items using the bid/RFP process. Responsible Party for Corrective Action: Tamara L. Asdell, Treasurer Timeline for Completion: Immediately

Department: Education Administrative and Financial Services Title: Internal control over CNC cash management needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Department has developed and implemented new procedures to confirm that batch payments are paid on time. Completion Date: March 15, 2025 Agency Contact: Jane McLucas, Director of Child Nutrition, DOE, 207-624-6880

Department: Education Title: Internal control over CNC donated food inventory needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Department will follow up on open CNPWeb tickets for completion. The Department will work with the vendor to create a new computerized system to receive tickets and print them automatically to remove the manual process of writing tickets. The Department will initiate meetings each month to compare inventory numbers, if they do not match. The Department will work with the vendor to replace any missing item from their inventory with an equal product each month. Completion Date: March 31, 2025 first item, December 1, 2025 second item and April 30, 2025 third and fourth item Agency Contact: Jane McLucas, Director of Child Nutrition, DOE, 207-624-6880

Department: Education Title: Internal control over the submission of CNC Schedule of Expenditures of Federal Awards information needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Department has updated the SEFA Review Procedure to include more specific information regarding the calculation of amounts reported for the Special Milk Program and noncash assistance and the classification of payments made to a school as direct payments rather than subrecipient expenditures. Completion Date: March 10, 2025 Agency Contact: Nicole Denis, Director of Finance, DOE, 207-530-2161

Department: Education Title: Internal control over CNC subrecipient monitoring procedures needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Department will implement a monthly status check of the current tracking tool to ensure compliance with the review The Department will update the current high-risk procedure. The Department will develop a procedure for evaluating base year reviews and add a procedure for timelines for adjustments to the claims. Completion Date: July 1, 2025, September 1, 2025, and June 1, 2025, respectively Agency Contact: Jane McLucas, Director of Child Nutrition, DOE, 207-624-6880