Corrective Action Plans

FINDING 2024-002 Contact Person Responsible for Corrective Action: Rachel Dutoi Contact Phone Number: 574-254-4503 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Assistant Food Service Director will print out the Direct Certification report and review for its accuracy. She will then provide the report to the Food Service Director for her review. After both individuals have reviewed the reports that were produced, they both will sign and date the reports to provide the documentation that the information was reviewed and verified. Anticipated Completion Date: This new process will begin at month end of February 2025.

FINDING 2024-001 Contact Person Responsible for Corrective Action: Rachel Dutoi Contact Phone Number: 574-254-4503 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The amount transferred during the time period of July 1, 2024-December 31, 2024 will be transferred back to Fund 0800. This transfer will be done once the Form 9 for period 2 of 2024 is complete and the month of December is closed. An indirect cost rate for Fiscal Year 2026 has been applied for and this rate will be used to capture these costs from Fund 800 if approved beginning 7.1.2025. Anticipated Completion Date: The fund transfer back to Fund 0800 will occur by March 31, 2025. The claiming of the indirect cost rate will begin 7.31.2025 dependent upon the approval of the corporation’s indirect cost rate application.

FINDING 2024-003 Finding Subject: Child Nutrition Cluster – Internal Controls Summary of Finding: The School Corporation had not established internal controls over the suspension and debarment compliance requirement, specifically contracts with vendors that do not include the suspension and debarment clause with the contract. Contact Person Responsible for Corrective Action: Jennifer Lindsey, School Lunch Director Contact Phone Number and Email Address: (812) 937-2400, jlindsey@nspencer.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: For contracts with vendors that do not include the suspension and debarment clause with the contract, the Food Service Director will provide documentation that she verified the vendor was not suspended or debarred to the Corporation Treasurer or governance for review/approval. Anticipated Completion Date: July 2025

FINDING 2024-002 Finding Subject: Child Nutrition Cluster- Special Tests and Provisions-Non-Profit School Food Service Accounts Summary of Finding: Finding 2024-002 indicates a failure to maintain adequate internal control systems with regards to requirements related to the grant agreement and the Special Tests and Provisions-Non-Profit School Food Service Accounts compliance requirement. As a result of these inadequate internal control systems, the corporation did not prevent, detect, and/or correct errors prior to submission. It has been recommended that a system of internal control be implemented which would include multiple individuals with a segregation of duties. This system should include signatures of each person involved along with their role in the internal control system process. Contact Person Responsible for Corrective Action: Katie King, Food Services Director Contact Phone Number and Email Address: 812-866-6254, kking@swjcs.us Views of Responsible Officials: We concur with this audit finding. Description of Corrective Action Plan: Action taken to remedy finding 2024-002 includes, but is not limited to, the following: 􀁸 Beginning immediately, Assistant Treasurer 1 will prepare a DocuSign envelope monthly with the following financial reports to be reviewed: o Appropriation Report o Expenditure Report o Revenue Report o Fund Detail Report o Fund Report 􀁸 The DocuSign Envelope will be routed to the Food Services Director, for the initial review. 􀁸 The Food Service Director will complete his/her review, adding comments and suggestions as needed. An eSignature will confirm that the data appears accurate. 􀁸 The DocuSign Envelope will then be routed to Assistant Treasurer 2 for an additional review. 􀁸 Assistant Treasurer 2 will complete his/her review, adding comments and suggestions as needed. An eSignature will confirm that the data appears accurate. 􀁸 If corrections to the report are required: o The Food Service Director and/or Assistant Treasurer 2 will decline to sign and discuss the changes needed with Assistant Treasurer 1. o Assistant Treasurer 1 will then create a second DocuSign Envelope, with the needed corrections and begin the process again. 􀁸 If no corrections are needed, the Chief Financial Officer, designated as monitor, will confirm that both the Food Service Director and Assistant Treasurer 2 reviews have been completed and indicates as such via eSignatures. 􀁸 After the above steps have been taken, the report will be submitted 􀁸 The Grant Coordinator indicates its completion by eSignature in the appropriate location. INDIANA STATE BOARD OF ACCOUNTS 33 􀀃 􀀃 Anticipated Completion Date: March 1, 2025

January 23,2025 Kentucky Department of Education Caverna Independent School District, respectfully submits the following corrective action plan for the year ended June 30, 2024. Campbell, Myers & Rutledge, PLLC 410 South Broadway Glasgow, Kentucky 42141 Audit Period: June 30, 2024 The findings from the June 30, 2024 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS- FINANCIAL STATEMENT AUDIT NONE. FINDINGS- FEDERAL AWARDS PROGRAM AUDITS DEPARTMENT OF EDUCATION- CHILD NUTRITION CLUSTER 2020-001 Child Nutrition Cluster National School Lunch Program- CFDA NO. 10.555 Summer Food Service Program- CFDA NO. 10.559 National School Breakfast Program- CFDA NO. 10.553 Significant Deficiencies: See Finding 2024-001. Recommendation: Caverna Independent School District should ensure that all staff fill out purchase orders and must be approved before expenditures are incurred. Action Taken: Procedures have been implemented to ensure that purchase orders are completed and approved before any purchases are made. If Kentucky Department of Education has questions regarding this plan, please call Lisa Austin at 270-773-2530. Sincerely Yours, Lisa Austin Finance Officer Caverna Board of Education

FINDING 2024-002 Finding Subject: Child Nutrition Cluster – Eligibility and Special Tests and Provisions – Non-Profit School Food Accounts Summary of Finding: Documented evidence of the implementation of the internal controls was not maintained. Due to the lack of controls, it could not be determined if the School Corporation ensured compliance with Eligibility and Non-Profit School Food Accounts. Contact Person Responsible for Corrective Action: Allison Pund and Margaret Leavitt Contact Phone Number and Email Address: 812-683-3971 x5002; punda1@swdubois.k12.in.us; leavittm@swdubois.k12.in.us Views of Responsible Officials: We concur with the finding. Explanation and Reasons for Disagreement: NA Description of Corrective Action Plan: The School Corporation will document the internal controls that are in place. This will be completed by ensuring signatures or initials are acquired for internal controls that are in place. Anticipated Completion Date: August 2025

Corrective Action Plan 2024-006 – Unallowable Expenditures National School Lunch Program (Significant Deficiency) Federal Program Information: Funding Agency: U.S. Department of Agriculture Title: National School Lunch Program FAL Number: 10.555 & 10.553 Passthrough: N/A Award Year: 2024 Responsible Official’s Plan: Due to the timing of the finding, the District is performing a permanent cash transfer in March to be compliant with the National School Lunch Program. Additionally, the specific corrective action plan provides details for how we have ensured the unallowable expenses for the National School Lunch Program will not occur again. Specific corrective action plan for finding: This was the result of an error in changing an employee's position from one department to another. Moving forward, the Human Resources Department will notify Payroll of any changes in position and will require TWO SIGNATURES prior to making any changes in pay coding. The two signatures are from the Director of Human Resources and the Director of Finance. Timeline for completion of corrective action plan: The permanent cash transfer process has begun and will be completed by March 31, 2025. The form to ensure two signatures are captured prior to making changes in pay coding is already created and being utilized. Employee positions responsible for meeting the timeline: Director of Finance – Cooper Jones Director of Human Resources – Lisa Salazar

FINDING 2024‐001 Subject: Child Nutrition Cluster‐Suspension and Debarment Summary of Finding The School Corporation did not verify that three of three vendors tested were neither suspended nor debarred, or otherwise excluded or disqualified from participating in federal assistance programs. Contact Person Responsible for Corrective Action: Adam C. Minth Contact Phone Number: 219-374-3504 Views of Responsible Official: The school corporation concurs with the finding and will be implementing corrective procedures by the end of this fiscal year. Description of Corrective Action Plan: Our Child Nutrition Director will conduct the necessary suspension and debarment check via Sam.gov to make certain that we are in compliance with each vendor throughout the entire fiscal year. This will be in addition to our Food, Dairy and Bakery vendors that are contracted, as their suspension and debarment information is checked by a third-party purchaser. Anticipated Completion Date: 4/30/2025

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): FY 22-23, FY 23-24 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Context: We noted that for two claims in a sample of six, the Food Service Director prepared the reimbursement claim without a secondary, documented review to ensure the accuracy of the reimbursement claim. The lack of controls was isolated to fiscal year 2023. Contact Person Responsible for Corrective Action: Cara Cornell Contact Phone Number: 765-379-2990 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: In March 2023, the School Corporation implemented a secondary review/signoff to ensure accuracy of the reimbursement claim form. Anticipated Completion Date: March 2023

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): FY 22-23, FY 23-24 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Finding: Material Weakness 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 for 17 of the 60 students sampled. Additionally, there was no documented annual review by School Corporation personnel of the income eligibility guidelines used by the food service software. Contact Person Responsible for Corrective Action: Cara Cornell Contact Phone Number: 765-379-2990 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan:·The School Corporation will implement a dual review/signoff for each application presented for eligibility. The School Corporation will implement a dual review/signoff for verification of the income eligibility guidelines used by the food service software. Anticipated Completion Date: February 2025

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): 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: The School Corporation’s internal controls over eligibility included an annual approval of the food service software’s eligibility guidelines and also a documented review of individual meal applications by Food Service Department staff. During testing of eligibility, we noted 7 applications, out of 60 total students tested for the audit period, that did not have a timely, documented review by Food Service Department staff. The lack of review was isolated to fiscal year 2023. Additionally, there was no documented annual review by School Corporation personnel of the fiscal year 2024 income eligibility guidelines used by the food service software. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Management will ensure all applications for free/reduced meals have a formally documented dual review. Management will also ensure that income thresholds in the student meal system are reviewed annually. Responsible Party and Timeline for Completion: Effective immediately, we have implemented procedures that Amanda Bilbrey, Food Service Assistant will periodically throughout the school year verify that all free & reduced applications are properly reviewed. Attached is the 2024-2025 meal Income Eligibility Guidelines and Titan student meal system printout of meal pricing, that has been reviewed.

Context: During sample testing of 60 students for eligibility, we noted 3 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: Tami Wyant, FSD Contact Phone Number: (765) 963-2560 Ext: 1172 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Prior the start of each school year, the FSD will verify within Skyward Food Service Management System that the eligibility guidelines that have been loaded for use in determining free & reduced lunch status are correct according to the published guidelines. During the eligibility review of applications, the Food Service Director will provide the first review to make her initial determination and the applications will have a second review done by the Asst. Food Service Director, who will put her initials on the paper applications as proof of review. For any online applications that are submitted during the school year the FSD will review online and then push the applications onward within Skyward for final processing since the guidelines have already been verified prior to the start of the school year. The FSD will keep a printed copy of the guidelines loaded in Skyward and the Assistant FSD will verify and initial as a second review and keep on file for audit purposes. Anticipated Completion Date: All paper applications that have been received since the start of the school year, 2024-25, will have a second review done and so noted by the reviewer’s initials. Moving forward, all applications received, whether in paper format or online submission, will have the review done prior to approval. Applications are received throughout the year, so action to remedy this situation will take place immediately for any new applications received.

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. Contact Person Responsible for Corrective Action: Michele Harrison/ Corporation treasurer Brian Byrum / Superintendent Contact Phone Number: M. Harrison:765-492-5101 B. Byrum: 765-492-5102 Views of Responsible Officia.l : We concur with the finding. Description of Corrective Action Plan: Prior to printing accounts payable checks, the corporation treasurer prints the AP voucher register for the superintendent to review and sign. After this internal control, the treasurer processes the checks. Once checks are printed, the voucher is paired with the invoice, initialled by the corporation treasurer and signed by the superintendent. Anticipated Completion Date: 3/7/2025

FINDING 2024-001 (Auditor Assigned Reference Number) Finding Subject: Child Nutrition Cluster Summary of Finding: Lack of an internal control system to ensure compliance with the Suspension and Debarment requirements for contractors and subrecipients Contact Person Responsible for Corrective Action: Katy Dowling Contact Phone Number and Email Address: 317-889-4060 and kdowling@gws.k12.in.us Views of Responsible Officials: The district concurs with the finding. The procurement of the item in question began with the prior Director of Food Service and was then completed at a later date by her successor. We believe this is a contributing factor to this error. The district participates in CIESC’s Region 9 Child Nutrition Cooperative. This cooperative conducts the bidding/procurement process on behalf of its members in compliance with all Federal Procurement and Suspension and Debarment requirements. From time to time, there are items needed that are not available through the cooperative. Most often, this is food service equipment purchases. Description of Corrective Action Plan: Policy 6325 covers procurement for federal grants/funds. Within this policy, procurement and suspension and debarment expectations are provided. The district plans to add an administrative guideline that will cover the process for any purchase reasonably expected to exceed $25,000 including, but not limited to, (1) how to verify if a vendor is suspended or debarred; (2) what documentation is required and how it is submitted/tracked; (3) validation process involving accounts payable for purchases over $25,000 from federal grants/funds to confirm steps 1 and 2 were properly followed. In addition, communication and direction will be provided to any staff in the district who have the ability to make purchases for grant-funded items. Anticipated Completion Date: 3/1/25 – Review of purchases from grant funds from 7/1/24 through 2/20/25 to ensure compliance. 3/1/25 – Completion of Administrative Guidelines 6325 to specify the internal control process. 3/1/25 – Communication to impacted staff regarding the policy and administrative guideline.

Context: The School Corporation had one vendor which exceeded the simplified acquisition threshold which was selected for testing. The School Corporation was unable to provide any supporting documentation for the procurement process required under School Corporation policy. The sample item amount dispersed was $160,827 for food purchases in FY 2023. Additionally, the School Corporation did not have any support to show the vendor was not disbarred or suspended. Contact Person Responsible for Corrective Action: Steve Boulanger, Food Service Director Contact Phone Number: 765-240-2372 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: As of October 2024, our Food Service Director has been running vendors through the SAM.gov website, printing the results, and filing them for audit purposes. Anticipated Completion Date: 10/01/2024

Context: We noted that for two claims in a sample of four, the Food Service Director prepared the reimbursement claim without a secondary, documented review to ensure the accuracy of the reimbursement claim. Additionally, the number of meals claimed on two of the four claims sampled did not agree to the supporting meal system reports. There was a gross overstatement of meals claimed of $349 and a gross understatement of meals claimed of $161 resulting in a net over reimbursement amount of $188. Contact Person Responsible for Corrective Action: Steve Boulanger, Food Service Director Contact Phone Number: 765-240-2372 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: As of February 2024, the Food Service Director prepares the claim for reimbursement, and the Corporation Treasurer double checks all numbers and signs the claim. Anticipated Completion Date: 02/01/2024

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. Contact Person Responsible for Corrective Action: Steve Boulanger, Food Service Director Contact Phone Number: 765-240-2372 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: As of February 2024, our new Food Service Director has implemented a second check of all applications by the High School ECA Treasurer. Additionally, the Food Service Director will print the USDA income parameters after July 1st, compare it to the income guidelines in our nutrition software, and have the High School ECA Treasurer double check the numbers as well. Both employees will sign off on the form, and it will be filed for audit purposes. Anticipated Completion Date: 07/01/2025

Child Nutrition Cluster – Assistance Listing No. 10.553, 10.555 and 10.559 Recommendation: We recommend the District retain all direct certification reports from the State and for the District to review applications submitted electronically through food service system to determine correct eligibility determination is made. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: Direct Cert files received from the State starting in August 2024 will be kept on the Food Service Google drive. Names of the contact persons responsible for corrective action: Wesley Haselhorst and Dawn Koshio Planned completion date for corrective action plan: June 30, 2025

Finding 2024-001 Condition: Two vendors were awarded a contract without an appropriate procurement process. Corrective Action Planned: Comply with federal procurement regulations by setting up a quote system and seek quotes for anticipated spending of over $10,000. Anticipated Completion Date: May 1, 2025 Contact: Marie Znamierowski

2024-003 Preparation of and Internal controls over Schedule of Expenditures of Federal Awards Preparation (Material Weakness) Federal Agency: U.S Department of Education Program Name: Child Nutrition Cluster; Education Stabilization Fund Assistance Listing Number: 10.553, 10.555 and 10.559; 84.425 Award Period: June 30, 2024 Recommendation: The Board of Education and management should review the financial reporting process. Once this review is complete, the District should then perform a risk assessment to determine the best way to implement appropriate internal controls over financial reporting to ensure that the District prepares the schedule conformity with Uniform Guidance. Action Taken (Unaudited): Management plans to have the Board Clerk and the Board Treasurer complete the Schedule of Expenditures together and to ensure that the correct expenses are being reported. Contact Name – Kristy Dyche Expected Completion Date – 6/30/2025

FINDING 2024-001 Finding Subject: Child Nutrition Cluster - Reporting Summary of Finding: There were no controls in place to ensure that the School Corporation complied with the reporting requirements. The reimbursement request reports were prepared and submitted by the Food Service Director without any oversight, review or approval process to ensure accuracy of the reports. There was no oversight to make sure that the number of meals served matched the report filed. The lack of internal controls was systemic throughout the audit period. Contact Person Responsible for Corrective Action: Amanda Myers Contact Phone Number and Email Address: 765-832-3551/amyers@svcs.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Amanda Myers, Food Services Director, will continue to receive the information for the monthly meals served from the cafeteria managers at each school. Once she enters the information, the HS cafeteria manager will review the numbers to ensure that the information was entered correctly. The reimbursement forms and information that was entered will be submitted to the finance department to ensure the reimbursement process is correctly receipted. Anticipated Completion Date: Immediate.

Context: For one sponsor claim reimbursement in a sample of four claims, the Food Service Director prepared the sponsor claim reimbursement summary 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: Melissa Dempsey Contact Phone Number: 812-546-2000 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: I have spoken to the Food Service Director to ensure that 2 individuals are signing off on all the claims. Anticipated Completion Date: 3/1/2025

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. Contact Person Responsible for Corrective Action: Melissa Dempsey Contact Phone Number: 812-546-2000 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: I have spoken to the Food Service Director and she will begin printing the Skyward threshold guidelines and sign off on those/confirm they match the federal poverty guidelines. Anticipated Completion Date: August 2025

1. Corrective Action Step A. Strengthening Internal Controls Over Determination of Applications Demonstrating Questionable Eligibility The School Corporation will develop and implement a segregation of duties, ensuring that current individuals approve applications, perform Direct Certification checks, and conduct follow-up verifications of questionable applicatoins in a more directed manor. If an applicant provides a case number that does not appear on the Direct Certification list the School Corporation will: 1. Review the application based on standard income eligibility requirements, while confirming the application will remain subject to verification. 2. If $0 income is provided or the application is otherwise 'questionable' then the reviewing individual will add the following to the application comments field: reviewing individual name, reason for review request, to whom the application will be escalated. 3. Apply benefits to siblings, if appropriate. 4. Not complete the final step of marking the application as processed, rather leave it 'pending' and notify Director of School Nutrition of the need for this application to be reviewed. 5. Director of School Nutrition or designee will review and either confirm the DC status by downloading the certification or conduct follow-up verification. In either case, approved or verification for cause, the Director of School Nutrition or Designee will mark the application as processed. 6. If the verification for cause is not responded to in a timely manner, the status will revert to 'Paid' status as per 'verification for cause' guidelines. 2. Corrective Follow-Up and Reporting The School Corporation will review all applications from current year (FY 24-25) to identify any applications not subject to verification process. Management will report progress on implementing these corrective actions to the School Board and maintain records for review by auditors and state officials. 3. Anticipated Completion Date The review of current year (FY 24-25) applications will be completed March 21, 2025. The school board report will be completed April 11, 2025.

Context: During testing of activities allowed and unallowed/allowable costs, it was noted the School Corporation transferred $48,693 from the School Lunch Fund to the JCHS Prepaid Food/Trust Acct to settle negative student balances deemed uncollectible. Outstanding student debt resulting from nonpayment of school meals or milk is an unallowable expenditure to the nonprofit school food service account and cannot be absorbed by the food service program at the end of the school year. It must be paid for with other non-federal sources. Contact Person Responsible for Corrective Action: Shannon Current Contact Phone Number: 260-726-9341 Views of Responsible Official: We concur with the finding now that we have more clarifying information. Prior to this audit, we were told we had to use non-federal funds to write off the debt. The published documentation we had was vague as it only stated non-federal funds. With the assistance of our food service company, we were told that catering, adult meals, and al a carte were all non-federal funds. They also had a calculation for figuring out the amount of non-federal funds that we had to make sure it was enough to cover the negative debt. Description of Corrective Action Plan: Moving forward, I will make sure that any negative debt is written off using the operations fund, rainy day, or other approved fund. Anticipated Completion Date: The next time we are required to write off debt. Possibly June 30, 2025.