Corrective Action Plans

2023-008 Reporting Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding. The necessary reports will be filed as soon as they are available.

2023-003 Internal Control over Compliance Requirements. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has contracted with an outside firm that specializes in SBOA compliance, as well as Federal Award Compliance in line with Uniform Guidance. The firm will assist in the development of the required manuals, policies, procedures and review processes. The current estimated completion date is February 28, 2025.

2023-002 Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has contracted with an outside firm that specializes in SBOA compliance, as well as Federal Award Compliance in line with Uniform Guidance. The firm will assist in the development of the required manuals, policies, procedures and review processes. The current estimated completion date is February 28, 2025.

Finding 2023-003 – Child Nutrition Cluster – Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Matthew Parkinson, CFO Contact Phone Number: 317-869-4364 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The CFO will send a memo to all administrators identifying quote and bid thresholds. The school district will obtain at least 3 quotes or use an alternative acceptable procurement method for large purchases. Anticipated Completion Date: 6/30/24

Finding 2023-002 – Child Nutrition Cluster – Activities Allowed or Unallowed, Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Matthew Parkinson, CFO Contact Phone Number: 317-869-4364 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Business Office and Payroll staff will review a Labor Distribution Report to verify that the staff is only paying appropriate personnel from the Food Service Fund. Anticipated Completion Date: 6/30/24

The Town and Board of Education have implemented a written policy for purchases using federal funds. This policy includes verifying that vendors have not been debarred.

The Town and the Board of Education have prepared and implemented a written policy for purchases using federal funds.

Finding ref number: 2023-001 Finding caption: The District charged unallowable costs to the Supply Chain Assistance award of the Child Nutrition Cluster. Name, address, and telephone of District contact person: Tom Laufmann, Executive Director of Business Services 1601 Ave D Snohomish, WA 98290 360-563-7239 Corrective action the auditee plans to take in response to the finding: (If the auditee does not concur with the finding, the auditee must list the reasons for disagreement). The district is making multiple checks for processed vs unprocessed foods claimed in the Supply Chain Assistance award. This includes multiple staff reviewing the claimed items and cross-checking against the 2022-23 claim. All items deemed processed are removed from the claim. Anticipated date to complete the corrective action: 8/31/2024

2023-002: Significant Deficiency in Internal Controls and Compliance Finding -Child Nutrition Cluster ALN (10.553, 10.555,10.559): The District’s school lunch office-maintained production records and manual count sheets for the elementary school and high school instead of using the point-of-sale system for tracking student meal counts. (Questioned Costs: None) The Town of Clinton/School Department will utilize and maintain the point-of-sale system consistently in all district school buildings to track student meals counts. Already implemented at the start of FY25 school year.

The Treasurer and the Food Services Supervisor will work together to complete and check the verifications for accuracy.

Finding 2023-01: The audit report was received by the FAC after the due date of May 31, 2024. Recommendation: A system should be implemented that designates multiple points of contact for the auditor, ensuring continuity in the event of key employee transitions and facilitating timely completion of future audits. Action Taken: Since being made aware of the issue, the administrator and his staff appointed additional board members to gain familiarity with the annual audit process. This will ensure that the auditor will receive all necessary information and documentation in a timely manner, even in the event of employee transitions. In addition, staff has been trained and made aware of the general audit process to ensure future compliance. Implementation Date: Corrective Action plan has been implemented as of September 6, 2024

Method of Implementation - School District personnel will continue to work closely with the Food Service Director to determine the needs of the District in an effort to reduce year end net cash resources. Person Responsible - Director of Food Servcies; Assistant Business Administrator; and Business Administrator/Board Secretary. Implementation Dates - June 30, 2024

FINDING 2023-005 Finding Subject: Child Nutrition Cluster – Reporting, Special Tests and Provisions – Verification of Free and Reduced Price Applications (NSLP) Summary of Finding: The School Corporation had not designed or implemented effective internal controls to ensure that reimbursement requests were accurately submitted. The reimbursement requests were prepared by one employee based on meals served without evidence of an oversight or review process. The School Corporation had not designed or implemented effective internal controls to ensure the Verification of Free and Reduced Price Applications were accurately completed. One employee selected and verified the required sample of approved free and reduced-price applications without an oversight or review process. Contact Person Responsible for Corrective Action: Juli Windsor Contact Phone Number:765-689-9131 Views of Responsible Official: We concur with the finding Description of Corrective Action Plan: The management of the School Corporation will establish a system of internal controls related to the grant agreement for the reporting and provisions to verify the free and reduced-price applications meet the compliance requirements. There will be responsible officials in place to comply with the report. Anticipated Completion Date: April 2024

FINDING 2023-003 Finding Subject: Child Nutrition Cluster - Eligibility Summary of Finding: The School Corporation had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance related to the eligibility determination of a child receiving meals. The School Corporation could not provide documentation supporting the eligibility for 10 of 40 students that received free or reduced-price meals for fiscal year 2022-2023. Of the 30 students for which documentation was provided, the School Corporation could not provide documentation that the one student’s benefits were calculated properly. Due to the lack of supporting documentation we were unable to determine the School Corporation's compliance with the Eligibility compliance requirement. Contact Person Responsible for Corrective Action: Juli Windsor Contact Phone Number:765-689-9131 Views of Responsible Official: We concur with the finding Description of Corrective Action Plan: This will include all reimbursements which are submitted to the treasurer must be signed by the school cafeteria managers and the food service director. The school will also implement policies to ensure that the Verification of Free and Reduced-Price applications have an adequate internal control to ensure the validity of the free and reduced applications. This will provide for segregation of duties to ensure appropriate reviews, approvals, and oversight are taking place. Anticipated Completion Date: April 2024

Management Response/Corrective Action Plan: Going forward the School Nutrition staff will keep a spreadsheet documenting meals reimbursed previous fiscal years, and in each month to compare to the number of meals calculated for the current billing month.

Management Response/Corrective Action Plan: Going forward the School Nutrition staff will keep a spreadsheet documenting meals reimbursed previous fiscal years, and in each month to compare to the number of meals calculated for the current billing month.

FA 2023-001 Improve Internal Control Activities Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principle Eligibility Reporting Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: 10.553 - School Breakfast Program 10.555 - National School Lunch Program Federal Award Number: 225GA324N1099 (Year:2022), 235GA324N1199 (Year: 2023) Questioned Costs: None Identified Description: A review of expenditures, free and reduced meal applications, and reporting requirements related to the Childe Nutrition Cluster revealed that the School District's internal control procedures were not operating appropriately to ensure that appropriate reviews and approvals occurred. Corrective Action Plans: For review of expenditures, Child Nutrition Cluster (CNC) invoices will be sent to the CNC Director to review, approve, and sign. Singed invoices will then be provided to the CNC Bookkeeper for payment processing and filing. For review of free and reduced meal applications, applications will be received electronically in Infinite Campus and manually. The manual applications will be entered into Infinite Campus and both types will be approved and processed by the CNC Director. This approval will be stored in Infinite Campus with a time/date and approver electronic stamp. For review of reporting requirements, meal count information from Infinite Campus will be provided to the CNC Bookkeeper to enter in the Georgia Department of Education portal. CNC Director will approve and sign the final report prior to submittal. Estimated Completion Date: August 1,2023 Contact Person: Kim Navas, Financial Officer Telephone: 706-367-2782 Email: kim.navas@jeffcityschools.org

On behalf of the finding 23-03-the following changes will be implemented: The Food Program Directors will ensure that the separation of Food Purchases will be reinforced. 1) Establish a strict policy mandating that all program food purchases for the USDA Nutrition Cluster (Breakfast and Lunch programs/ CACFP) be processed separately from non-programmatic food purchases. 2) Implement a clear process where program-related food purchases are charged directly to the respective program bank accounts and non-programmatic items are billed separately to non-program accounts. 3) Require management to review and approve all food purchase orders before submission to vendors, ensuring that food intended for program use is properly categorized and separated from other purchases. 4) Ensure that only approved program foods are charged to the USDA Nutrition Cluster, with regular cross-checks against menu requirements. 5) Require separate invoices for non-programmatic food purchases to ensure clean and distinct accounting entries, minimizing the need for corrections through journal entries. The enforcement of the procedures for food purchases will be in effect starting October 2024.

FA 2023-002 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 Federal Award Number: 235GA324N1199 Questioned Costs: None Identified Prior Year Finding: FA 2022-002 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 has returned to following its approved procurement procedures. Estimated Completion Date: July 1, 2024 Contact Person: Chris Johnson, Director of Financial Services Telephone: 478-994-2031 Email: chris.johnson@mcschools.org

FA 2023-001 Strengthen Controls over Special Reporting Compliance Requirement: Reporting 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 Federal Award Number: 235GA324N1199 Questioned Costs: None Identified Prior Year Finding: FA 2022-001 Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over the monthly Claims for Reimbursement process. Corrective Action Plans: The School District has returned to collecting Free and Reduce applications and recording the student meals accordingly. Estimated Completion Date: July 1, 2024 Contact Person: Chris Johnson, Director of Financial Services Telephone: 478-994-2031 Email: chris.johnson@mcschools.org

Federal Agency Review *Significant Deficiency in Internal Controls over Compliance; Noncompliance Federal Program - CFDA 10.555 – National School Lunch Program ASDOE School Lunch Program (SLP) continues to work with the representative who oversees civil rights for the USDA Western region. SLP continues to have training to correct the issues in their USDA FNS report. POC  SLP Assistant Director Christina Fualaau

Management response/corrective action: The Nutrition Director will update student eligibility when verification requests are not returned. The Director will participate in Department of Education professional development to stay abreast of all requirements of School Nutrition.

Management’s Response/Corrective Action Plan: We agree with RKO's recommendation that there are no provisions in the regulations that provide for large scale reclassifications through administrative override. There was some confusion on the part of Maine School Administrative District No. 35 when a communication from the State of Maine was received in November of 2022, that the rate of Free and Reduced children identified at Maine School Administrative District No. 35 had dropped dramatically from the prior year (due to the meals being free to all) and that it may negatively impact our subsidy. At that point, Maine School Administrative District No. 35 asked its building administrators to identify needy families based on conversations they had previously had with parents, from speaking with their guidance counselors, from knowledge they had working with outside community agencies (68 Hours of Hunger) to help identify families potentially in need. From there the lists provided by the building administrators were compared with the families who had already submitted applications, and the directly certified students, and any students who were not identified in either of those cohorts were added to the free and reduced list per administrative override. When RKO arrived in May 2023 to perform interim testing, they let us know that this was not appropriate. At that time, we removed those students from the free and reduced list, and adjusted all of our previously submitted claim forms to account for the change. Maine School Administrative District No. 35 is now clear on the rules with regards to the use of administrative override, and will not use it again in the future.

Finding Number: 2023-003 Planned Corrective Action: The accounts payable clerk will double check all claims submitted to the state for accuracy. Anticipated Completion Date: 08/30/2024 Responsible Contact Person: Stacy Bolden

Boston Public Schools (BPS) Food and Nutrition Services (FNS) has implemented advanced policies including additional segregation of duties to ensure that all deposits made have clear and accurate cash receipt forms. Anticipated Completion Date: June 30, 2024 Responsible Contact Person: Colin Musto, Assistant City Auditor, Grants Monitoring Unit colin.musto@boston.gov