Corrective Action Plans

Information on the federal program: 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): FY2023 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness 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 cash management compliance requirement. During the testing of claim reimbursements, we noted for two monthly reimbursements in a sample of six claims that the claim reimbursements were not being reviewed by an independent individual before being submitted to IDOE. In March 2023, the School Corporation implemented a review control over the monthly claim reimbursement. The lack of controls was isolated to the period of July 2022 through February 2023 during fiscal year 2023. For all six claims tested, we agreed the number of meals claimed for reimbursement to underlying meal system reports without exception. Contact Person Responsible for Corrective Action: Brisha Dunbar Contact Phone Number: 317-729-5122 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Food Service Director Brisha Dunbar will complete the claims reimbursement form each month. Once completed it will be reviewed by the business manager for correct amounts before submitting the request for reimbursement. The FSD will print out the claims and both she and the reviewer will initial the form. Anticipated Completion Date: Ongoing, effective 03/24/2025

FINDING 2024-001 (Auditor Assigned Reference Number) Finding Subject: Child Nutrition Cluster - Eligibility Contact Person Responsible for Corrective Action: Brook Cleaver Contact Phone Number and Email Address: (765) 675-2147 Ext 3316; bcleaver@tcsc.k12.in.us Views of Responsible Officials: We concur that there was not a documented control in place to ensure that timely eligibility determinations were made for direct certification eligibility determinations. Description of Corrective Action Plan: Etrition is our new system for the 2024-25 school year. Weekly, Susie Moore, kitchen manager, checks the state website for any direct certification file pulls. The file is saved by date and is used to import direct certs into the Etrition program on that same day. Each Friday, eligibility determination notices are issued via email to the parent or guardian email listed in the school’s information system, Powerschool. If such an email does not exist in the information system, a hard copy of the notice is mailed to the household. Duplicate copies will be retained in our files. Etrition syncs with PowerSchool at midnight each day successfully changing student lunch statuses. Benefit notifications will be reviewed by a second person and checked against the direct cert file pull to verify for accuracy. Income applications will work in a similar fashion, wherein we will retain evidence of the eligibility notices being sent to households. A binder of all notices will be kept on file. Anticipated Completion Date: Immediately - 3/4/2025

The Huntsville School District has developed guidelines that have been approved by our School Board for reconsidering or approving meal applications based on extenuating circumstances. The administrators have been trained and the guidelines are readily available. The district has also reimbursed DESE, CNU in the amount of $13,694 with check number 136793 dated 3/5/2024.

FINDING 2024-005 – Child Nutrition Cluster - Eligibility Context: During sample testing of 60 students for eligibility, we noted 5 instances where there was no documented review by someone other than the individual making the eligibility determination. Additionally, we noted 4 instances where the School Corporation was unable to provide the application. The issues were isolated to paper applications Contact Person Responsible for Corrective Action: Michelle L. Keene Contact Phone Number: (812) 384-4386 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The treasurer will formally review a sample of applications and the School Corporation will ensure all supporting applications and reviews are maintained. Anticipated Completion Date: March 2025

FINDING 2024-004 – Child Nutrition Cluster - Reporting Context: We noted that for all sponsor claim reimbursements in a sample of four claims, the sponsor claim reimbursement was prepared 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: Michelle L. Keene Contact Phone Number: (812) 384-4386 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The treasurer will formally review and document the review of all reimbursement claims Anticipated Completion Date: March 2025

FINDING 2024-003 - Child Nutrition Cluster - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Context: During testing we noted the following issues in a sample of forty child nutrition cluster payroll claims: ● 6 of 40 payroll transactions where a timecard was not completed by the employee to validate their hours worked and the time charged to food service. ● 19 of 40 payroll transactions where the School Corporation was unable to provide supporting documentation for approval of the hourly rate paid to employee. The noncompliance was isolated to the payroll periods through August 4, 2023. The School Corporation corrected the issues starting with the next payroll period. Contact Person Responsible for Corrective Action: Michelle L. Keene Contact Phone Number: (812) 384-4386 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: In FY24, the issue was corrected to ensure all employees were only paid for time supported by a time a card and a board approved rate schedule. Anticipated Completion Date: August 19, 2023

2024-005 Child Nutrition Cluster - Assistance Listing Numbers 10.553, 10.555 and 10.559 Recommendation: We recommend procedures to obtain and file all fully signed and executed contracts be strengthened. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Framingham Public School Finance Office will continue to follow the City of Framingham Procurement process for requesting review of all federal expenditures over $10K and do a follow up with the Procuremnt Office to ensure that a contract has been issued to the vendor. Name(s) of the contact person(s) responsible for corrective action: Jennifer Pratt, Margaret Ottaviani, Kate Fiore and Lincoln Lynch, IV Planned completion date for corrective action plan: Effective as of 07/01/2024

FINDING 2024-004 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: Suspension and Debarment Audit Finding: Material Weakness Context: For 1 of 2 items sampled, the School Corporation did not have any support to show the vendor was not debarred or suspended. The item was an equipment purchase for $56,470. No issues were noted with the procurement of the item. Contact Person Responsible for Corrective Action: Joyce Hulsman Contact Phone Number: 812-678-2781 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Gretchen Brinkman, Deputy Treasurer will notify DeAnn Meyer, Treasurer of all purchases to validate if compliance is followed. Anticipated Completion Date: Already complete.

FINDING 2024-003 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 Context: During sample testing of 60 students for eligibility, we noted 14 instances where there was no documented review by someone other than the individual making the eligibility determination. The lack of review was isolated to paper applications. Contact Person Responsible for Corrective Action: Joyce Hulsman Contact Phone Number: 812-678-2781 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: A procedure has been established to ensure dual validation and paper copies are in compliance. Anticipated Completion Date: Already completed.

Views of Responsible Officials and Planned Corrective Action: The Arkansas Department of Education (ADE), Division of Elementary and Secondary Education (DESE), Health and Nutrition Unit (HNU), concur with the finding. The HNU Finance staff implemented procedures for meal claim payment requests which include an initial and final review of all requests to be conducted by two (2) staff. The review process includes, but is not limited to, ensuring expenditures are assigned correct codes related to the appropriate funding source within the appropriate grant year, mitigating the Child Nutrition Program (CNP), Child and Adult Care Food Program (CACFP) Sponsor Administrative expenditure errors going forward. When the request is determined to be compliant, the Associate Director of Finance and Training approves payments before being forwarded to the ADE Finance team for payment. Anticipated Completion Date: March 15, 2025 Contact Person: Sheila Chastain Associate Director Arkansas Department of Education, DESE, Nutrition Services #4 Capitol Mall, Box #12 Little Rock, AR 72201 (501) 324-9502 Sheila.Chastain@ade.arkansas.gov Pamela Burton Director Arkansas Department of Education, DESE, Nutrition Services #4 Capitol Mall, Box #19 Little Rock, AR 72201 (501) 320-8978 Pamela.Burton@ade.arkansas.gov

Views of Responsible Officials and Planned Corrective Action: Director of Child Nutrition will have a secondary person review claim before submitting to state department, to ensure accurate keying of data.

The Midland School District will ensure all criteria and specific requirements are met for the District in processing free and reduced price meals for the District’s child nutrition program and classify them in accordance with federal guidelines established by the U.S. Department of Agriculture. Applications will include the required information to be considered for free and reduced price meals.

A.      The District will establish controls to ensure free and reduced price meal applications are properly completed by the applicant before processing.

B.      The District will ensure that a complete application includes the names of children for whom the application is made.

C.      A SNAP case number of the household for whom the application is made if person has SNAP.

D.      The signature of an adult household member has been submitted on the paperwork. (this may be a foster parent or an official of a court or other agency with responsibility for the child.

E.       The names of all household members.

F.       The amount of current income by each member and the source of the income.

G.      The last four of the social security number of the adult household member who signs the application or an indication that the household member does not have a social security number (box checked for “no social security number”) Indication that the child is a foster child

Program: AL 10.553 – School Breakfast Program; AL 10.555 – National School Lunch Program; AL 10.556 – Special Milk Program for Children; AL 10.559 – Summer Food Service Program for Children; and AL 10.582 – Fresh Fruit and Vegetable Program – Reporting Corrective Action Plan: NDE has been able to identify and correct the reporting errors and has begun working to submit all the required reports immediately. Additionally, FFATA reporting procedures will be updated and a monthly calendar reminder set each month to ensure the reports are submitted in a timely fashion. Contact: Kayte Partch / Kayte.partch@nebraska.gov Anticipated Completion Date: April 30, 2025

Due to the recent audit performed on the 23/24 school year a corrective action plan is needed to ensure internal controls are in place for applications entered in Payschools. This will ensure that all applications are properly marked as paid, free or reduced in the Payschools system. As the food service supervisor, I will verify that Payschools has the correct income guidelines provided by ODE for the current school year in the system. Furthermore, I will randomly pull 10% of portal applications that are entered through Payschools Central to ensure the correct determination was processed according to the income guidelines. Documentation will be kept on file of the applications that are reviewed. This plan will meet the necessary requirement to ensure that Payschools determined the proper eligibility status based on the information provided on the applications. Anticipated completion date: 6/30/2025

The District beginning in FY 2025 became part of the Community Eligibility Program allowing for all students to receive free lunch and breakfast. As such, the District is not using Pay Schools to determine eligibility.

Corrective Action: Child Nutrition will incorporate separation of duties when calculating the reimbursement for meals. At least one on—site review of the meal counting and claiming system for each school. Avery Johnson, Business Manager Robert Sanders, Superintendent Corrective Action Start Date: February 18, 2025

Corrective Action: The Business Manager will calculate the indirect \ cost rate using the rate provided by MDE for the expenditures occurred. The calculation will be reviewed and signed off on by the Federal Programs Director and Child Nutrition Director. This calculation will take place at year end once expenditures are booked. Avery Johnson, Business Manager Robert Sanders, Superintendent Corrective Action Start Date: February 18, 2025

Corrective Action: The district will strengthen internal controls on the employee contract and employee board approval process. There will be checks and balances between Human Resources and the Business Office before any recommendations are presented to the board. Avery Johnson, Business Manager Robert Sanders, Superintendent Corrective Action Start Date: February 18, 2025