Corrective Action Plans

Department: Education Title: Internal control over CNC claim reimbursements needs improvement Questioned Costs: Known: ALN 10.555 $1,605 ALN 10.582 $9,535 ALN 10.559 $117,259 Likely: Undeterminable Status: Corrective action in progress Corrective Action: Child Nutrition Services will create a procedure for reviewing applications and making sure they are approved prior to participation. For the Summer Food Service Program (SFSP), the Child Nutrition Services will create an additional application, outside of CNPWeb to further assess non-congregate operations and eligibility to prevent duplicative services. Child Nutrition Services has submitted a ticket to create an edit check on the SFSP Application to ensure that all specific eligibility information is submitted. Child Nutrition Services will create a procedure to address that session specific information is received prior to claim approval for sites. Child Nutrition Services will require a site sheet for SFSP applications for each location and each enrollment period. Child Nutrition Services will submit a ticket to CNPWeb to allow for documentation to be added to the site information sheet when revisions are made to the system. Child Nutrition Services will add documentation to the activities tab, while we wait for the enhancement to be completed. Child Nutrition Services will create a procedure to ensure that allocations to schools fall between $50.00 - $75.00. Child Nutrition Services has provided training to the National School Lunch Program reviewers on the Fresh Fruit and Vegetable Program questions within the Administrative Review process to ensure that those questions are asked during the Administrative Review. Completion Date: May 1, 2025, first and fourth items, April 1, 2025, second, fifth, sixth, and seventh items, June 1, 2025, third item, March 1, 2025, eight item, and February 10, 2025, for nineth item Agency Contact: Jane McLucas, Director of Child Nutrition, DOE, 207-624-6880

Department: Education Title: Internal control over CNC eligibility needs improvement Questioned Costs: Known: ALN 10.559 $628,924 Likely: Undeterminable Status: Corrective action in progress Corrective Action: The Department will create procedures for Application Approvals with site classification, eligibility and non-congregate plan requirements. The Department will develop procedures for Revisions on Claims and Applications. For the Summer Food Service Program, the Department will request an edit check enhancement in CNPWeb to add actual enrollment be added to claims. Completion Date: May 1, 2025, first and second item, and May 1, 2026, third item Agency Contact: Jane McLucas, Director of Child Nutrition, DOE, 207-624-6880

FINDING 2024-004 (Section III-Federal Award Findings and Questioned Costs) Finding Subject: Child Nutrition Cluster- Internal Controls Contact Person Responsible for Corrective Action: Brian Leitch, Holly Singleton and Roger Urick Contact Phone Number and Email Address: 260-347-2502 bleitch@eastnoble.net, hsingleton@eastnoble.net rurick@eastnoble.net Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The monthly meal reimbursement claims are calculated by the Food Service Director (Roger Urick) with documentation from Meal Magic. The document is printed and reviewed by the Deputy Treasurer (Holly Singleton). Both parties sign the report, and it is recorded. Reimbursement is submitted by the Food Service Director (Roger Urick). Once reimbursement is received, the Deputy Treasurer (Holly Singleton) gives updates to the Food Service department to verify that the amounts received match the amounts requested. The Director of Food Service uses the Federal Income Guidelines to input into the Meal Magic software. The Deputy Treasurer oversees him inputting the information and they both sign the documentation verifying the numbers in the system. When the Director of Food Service downloads the direct certification monthly and enters them into Meal Magic, a report will be ran by the Food Service secretary to verify that the certified students were properly processed. Documentation of the state’s report and the meal magic report will be signed and retained as evidence. Anticipated Completion Date: The corrective action plan regarding reporting has been established since the 2023-2024 fiscal year. The corrective action plan regarding eligibility will be established immediately.

FINDING 2024-003 (Section III-Federal Award Findings and Questioned Costs) Finding Subject: Child Nutrition Cluster - Suspension and Debarment Contact Person Responsible for Corrective Action: Brian Leitch, Holly Singleton and Roger Urick Contact Phone Number and Email Address: 260-347-2502 bleitch@eastnoble.net, hsingleton@eastnoble.net, rurick@eastnoble.net Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Any contracts or vendors with an excess of $25,000, documentation will be requested stating that the company is in good standing (the company is not suspended or debarred from receiving Federal Funds). The site Sam.gov may also be utilized to verify the company is complaint. This information is included in New World with the quote. A binder with companies that have been verified from the Sam.gov site is available for the Deputy Treasurer, Grants Coordinator and Food Service to reference. Any new vendors are added to the list and the list is printed every 6 months. Anticipated Completion Date: Immediately

FA 2024-002 Strengthen Controls over Suspension and Debarment Compliance Requirement: Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Agriculture Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: 10.553 - School Breakfast Program 10.555 - National School Lunch Program COVID-19-10.555 - National School Lunch Program Federal Award Number: 245GA324N1199 (Year: 2024), 225GA324N1099 (Year: 2024) Questioned Costs: None Identified Prior Year Finding: None Identified Description: A review of expenditures charged to the Child Nutrition Cluster revealed that the School District's internal control procedures were not operating appropriately to ensure that the School District's suspension and debarment procedures were followed. Corrective Action Plans: The School District will evaluate and improve internal control procedures to ensure that vendors are not suspended or debarred, or otherwise excluded prior to entering covered transactions and required suspension and debarment documentation is properly retained. Management will develop a monitoring process to ensure that these procedures are operating appropriately. Estimated Completion Date: June 30, 2025 Contact Person: Debbie Woerner, Finance Director/Asst Superintendent Telephone: 770-567-8489 ext. 1030 Email: woerned@pike.k12.ga.us

FA 2024-001 Strengthen Controls over Transfers Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principle Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Federal Awarding Agency: U.S. Department of Agriculture Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: 10.553 - School Breakfast Program 10.555 - National School Lunch Program COVID-19-10.555 - National School Lunch Program Federal Award Number: 245GA324N1199 (Year: 2024), 225GA324N1099 (Year: 2024) Questioned Costs: $803,845.92 Prior Year Finding: None Identified Description: The polices and procedures of the School District were insufficient to provide adequate internal controls over transfers of Child Nutrition Cluster funds. Corrective Action Plans: The School District will review current internal control procedures related to School Nutrition Fund transfers. Development and/or modification of current policies and procedures will be determined as needed to ensure that all expenditures, including transfers, are used for allowable purposes. In addition, the School District will implement a monitoring process to ensure that all expenditure activity is compliant with the School District's policies and procedures. Estimated Completion Date: June 30, 2025 Contact Person: Debbie Woerner, Finance Director/Asst Superintendent Telephone: 770-567-8489 ext. 1030 Email: woerned@pike.k12.ga.us

Response and Corrective Action Plan: The District will implement a process to retain all documentation of eligibility in the program as outlined by the Iowa Department of Education and Office of Management and Budget.

Response and Corrective Action Plan: The District will implement a process to retain all documentation of charges to the program as outlined by the Iowa Department of Education and Office of Management and Budget.

FINDING 2024-001 Finding Subject: Child Nutrition Cluster – Internal Controls Contact Person Responsible for Corrective Action: Annette Brown Contact Phone Number and Email Address: 812-829-2233 annettebrown@socs.k12.in.us Views of Responsible Officials: We concur with this finding that a more thorough and more fully documented process should be in place and that it needs to cover the full school year and not be done just the one time towards the beginning of the year. Description of Corrective Action Plan: The􀀃Technology􀀃and􀀃Food􀀃Service􀀃Reporting􀀃Assistant􀀃(TFSRA)􀀃is􀀃the􀀃one􀀃who􀀃does􀀃the􀀃initial􀀃processing􀀃of􀀃applications􀀃and􀀃 Direct􀀃Certification􀀃(DC). The􀀃Claims/Deputy􀀃Treasurer􀀃(C/DT)􀀃is􀀃the􀀃one􀀃who􀀃does􀀃a􀀃random􀀃check􀀃on􀀃applications􀀃to􀀃confirm􀀃that􀀃eligibility􀀃is􀀃applied􀀃 accurately. This􀀃check􀀃should􀀃happen􀀃four􀀃(4)􀀃times􀀃a􀀃year: 1. Around􀀃the􀀃Fall􀀃Membership􀀃Count􀀃Day􀀃(first􀀃few􀀃days􀀃in􀀃October)􀀃 2. Christmas􀀃Break􀀃(around)􀀃 3. Spring􀀃Break􀀃(around)􀀃 4. First􀀃part􀀃of􀀃May􀀃 The􀀃TFSRA􀀃will􀀃put􀀃the􀀃list􀀃of􀀃students􀀃and􀀃their􀀃eligibility􀀃from􀀃the􀀃food􀀃service􀀃software􀀃(currently􀀃Titan)􀀃at􀀃the􀀃point􀀃of􀀃each􀀃 check.􀀃The􀀃first􀀃pull􀀃of􀀃students􀀃in􀀃October􀀃will􀀃be􀀃all􀀃students􀀃while􀀃the􀀃subsequent􀀃pulls􀀃will􀀃be􀀃for􀀃the􀀃dates􀀃between􀀃the􀀃 previous􀀃pull􀀃and􀀃that􀀃date􀀃with􀀃the􀀃intention􀀃of􀀃catching􀀃any􀀃new􀀃students􀀃or􀀃new􀀃student􀀃eligibility. The􀀃C/DT􀀃will􀀃select􀀃a􀀃random􀀃sampling􀀃of􀀃students􀀃to􀀃verify.􀀃They􀀃will􀀃work􀀃with􀀃the􀀃TFSRA􀀃to􀀃look􀀃at􀀃the􀀃records􀀃in􀀃Titan􀀃for􀀃 applications􀀃and􀀃CNPWeb􀀃for􀀃the􀀃DC􀀃students􀀃to􀀃see􀀃applications􀀃or􀀃the􀀃DC􀀃eligibility􀀃as􀀃appropriate.􀀃Forms􀀃will􀀃be􀀃printed􀀃or􀀃 screen􀀃shot􀀃to􀀃create􀀃a􀀃file􀀃that􀀃will􀀃be􀀃saved􀀃by􀀃both􀀃parties. Anticipated Completion Date: March 14, 2025

Catholic Charities is required to conduct at least monthly inventory of USDA foods. We tested all 12 food distribution locations for inventory reporting and two of the locations were unable to provide evidence of inventory work performed for the month of June 2024. Recommendation: Management should ensure that staff at the food distribution locations are aware of the compliance requirements and provide additional training deemed necessary. Inventory processes and internal controls can be tailored to the nature and size of the location receiving and distributing the food resources. Action Taken: Management will review monthly inventory reports for each food pantry going forward and ensure reports are created to report zero amounts of inventory at month end. Name of responsible person: Daniel O'Brien, Chief Financial Officer Anticipated completion date: March 1, 2025 If there are questions regarding this plan, please call Catholic Charitie of Los Angeles's, Chief Financial Officer at (213) 251-3410. Sincerely yours, Daniel O'Brien Chief Financial Officer

Finding #2024-002- On Site Review Checklist Forms Not Available Condition: On Site Review Checklists were not made available during the year under audit. Criteria: The District is required every school year, prior to February 1, to perform an on-site review of the meal counting and claiming system and readily observable general areas of review in each school operating the National School Lunch Program (NSLP) and 50% of schools operating the School Breakfast Program (SBP). Effect: Compliance requirements were not met and Wisconsin Heights School District may be subject to additional monitoring. Cause: Compliance requirement supporting documentation was not retained and made available during the year under audit. Recommendation: Wisconsin Heights must monitor compliance requirements, update forms as needed and retain compliance supporting documentation. Response: We agree with this finding and will monitor compliance requirements, update forms as needed and retain compliance supporting documentation. Contact Person: Michelle McGrath Anticipated Completion: Prior to February 1, 2025

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

All free and reduced lunch applications are entered electronically to PaySchools by the parent/guardian of the child. They input their own financial information. We as a school choose the guidelines in the program, which is the exact information given to us by the State of Ohio to determine eligibility. Because PaySchools does not have a SOC1 report for Ohio, we must physically verify all applications, so what we will start doing as of 2/26/2025 is the treasurer’s office staff and the food service director will do what we did before this technology existed and print them out on paper and do the same math the computer program did and paid money for to verify the same information the program already determined to make sure the program verified the information correctly. Because this process is starting as of 2/26/205, the treasurer’s office staff will review all of the applications prior to 2/26/2025.

Findings and Questioned Costs Related to Federal Awards Finding Number: 2024‐001 Program Name/Assistance Listing Title: Child Nutrition Cluster Assistance Listing Numbers: 10.553, 10.555, 10.559 Contact Person: Brian Lockery, Director of Finance Anticipated Completion Date: The finding was corrected as of February 18, 2025. Planned Corrective Action: District staff took the following steps to immediately remedy this finding:  Entered and approved a journal entry in the FY24 general ledger to correct the indirect cost transfer out of Fund 510 and into Fund 570 as authorized under the program.  Submitted to ADE a request to open a 15‐915 data correction to submit a revised FY24 Annual Financial Report (AFR), Food Service AFR and School by School (AFR).  ADE opened the 15‐915 window, and Kyrene submitted all three revised AFRs.  ADE processed and approved all three AFRs.  Kyrene submitted all three revised AFRs to its governing board for approval on March 25, 2025.  FY25 opening fund balances were additionally corrected to reflect the changes approved in the revised AFRs. Kyrene remedied this finding as of February 18, 2025. Kyrene now employs a new, revised calculator tool which limits the amount of the food service contract expenses to $25,000 maximum annually. This worksheet will be used to calculate the maximum allowable indirect cost rate transfer from Fund 510 Food Services to Fund 570 Indirect Costs.

FINDING 2024-004 Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program ALN Numbers: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY23, FY24 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Non-Compliance Contact Person Responsible for Corrective Action: Chad Yencer - Superintendent Contact Phone Number: 765-348-7550 Views of Responsible Official: We concur with this finding Description of Corrective Action Plan: BCS has established the following internal controls to ensure compliance: 1. Internal Control: When a purchase is made at $10,000 or more using Federal Funds, the superintendent will require that any vendors selected are in compliance with the Procurement and Suspension and Debarment compliance requirement by completing one of the following quality checks with each vendor prior to purchase: a. Checking the federal System for Award Management (SAM) database at https://sam.gov/content/exclusions and maintain a screenshot of the search results. b. Collect a certification from the vendor directly c. Add a clause or condition to the covered transaction with the vendor In this audit, the Deputy Treasurer conducted the check but misspelled the vendors name while checking so no actual check was completed. Anticipated Completion Date: This corrective action will be implemented and completed immediately with any purchase made that meets the above threshold.

Finding 2024‐003 Subject: Child Nutrition Cluster – Allowable Costs/ Cost Principles Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children Assistance Listings Numbers: 10.553, 10.555, 10.559 Compliance Requirement: Allowable Costs/ Cost Principles Audit Findings: Material Weakness, Other Matters Contact Person Responsible for Corrective Action: Julie Dodd, Treasurer Contact Phone Number: 765-348-7550 Views of Responsible Official: We concur with the finding of the auditor Description of Corrective Action Plan: This was a singular occurrence in which indirect costs were applied in the wrong year. Moving forward, no indirect costs will be charged or paid outside of the correct time period for the fiscal year. Anticipated Completion Date: Completed

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.