Corrective Action Plans

Boston Public Schools (BPS) Food and Nutrition Services (FNS) has implemented various procedures in order to accurately report meal counts and claims.  Anticipated Completion Date: June 30, 2024 Responsible Contact Person: Colin Musto, Assistant City Auditor, Grants Monitoring Unit colin.musto@boston.gov

The Division will ensure evidence of review is maintained for the inventory work sheets. Anticipated Completion Date: October 2024. Responsible Contact Person: Yohannes Gedlu, Northwest Division Divisional Finance Director

Finding No.: 2023‐003S Condition: Applications for free or reduced meals were not appropriately filled out and signed by the student’s parent or guardian. Plan: Procedures will be implemented, and followed, to ensure applications are appropriately filled out by the student’s parent or guardian. Anticipated Date of Completion: 6/30/2025 Name of Contact Person: Kreg Wesley, Executive Director of Finance and Operations

Finding No.: 2023‐002S Condition: The average price of paid meals for the fiscal year was less than the minimum required amount and the paid lunch equity calculation was not completed. Plan: Procedures will be implemented to monitor the average price of paid meals and complete the paid lunch equity calculation, if required. Anticipated Date of Completion: 6/30/2025 Name of Contact Person: Kreg Wesley, Executive Director of Finance and Operations

Finding No.: 2023‐001S Condition: The confirmation review and verification tracking were not reviewed by someone other than the determining official, and the verification was not submitted before the due date. Plan: Procedures will be followed to ensure that there is an additional review of the verification process and that verification is submitted timely. Anticipated Date of Completion: 6/30/2025 Name of Contact Person: Kreg Wesley, Executive Director of Finance and Operations

Berrien County BOE FA 2023-001 Strengthen Controls over Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principle 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: 225GA324N1199 (Year: 2023), 225GA324N1199 (Year: 2023) Questioned Costs: $3,381 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 expenditures were reviewed and approved and that the School District's procurement and suspension and debarment procedures were followed. Corrective Action Plans: The new program director will attend training and review compliance requirements to ensure appropriate documentation is maintained. Estimated Completion Date: 30-Jun-24 Contact Person: Jolyn Schultz, Finance Director Telephone: 229-686-2081 Email: jolyn.schultz@berrien.k12.ga.us

ALN: 10.553, 10.555, 10.559, 10.582, Corrective Action Plan: Noncompliant FFATA Reports - Nutrition - OPI - The values were being duplicated due to an error in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). The Office of Public Instruction has reached out to its federal partners who are correcting their system to allow the office to report monthly without duplicating the reported values. The office will then begin reporting monthly as required. Person(s) Responsible for Corrective Measures: April Grady, Chief Financial Officer, Montana Office of Public Instruction, Target Date: 10/31/2024

All paper application will be organized, filed, and stored in the Food Service office/storage for review and auditing needs.

Our current DFN will attend both the Food Service Management Company (FSMC) annual training and ODEW’s provided state training on school meal applications.  All paper application will be organized, filed, and stored in the Food Service office/storage for review and auditing needs. Online/electronical applications will be held on the SFA server and detailed reports will be printed, organized, and stored with manual versions.

Audit Reference: 23-002 Non-Compliance Issue: lack of confirming signature on free/reduced applications. Applications must be confirmed by the confirming official listed on the Free & Reduced Price Meals Policy submitted to ESE. Root Cause Analysis: All applications were not printed and signed by confirming official. Corrective Action(s): Printing and signing all applications as they come in including online applications. 2. Action Item: o Description: Setting plans in place to make sure all applications are signed as printed or passed in and making sure that all signed applications are passed in to auditor not electronic copies. o Responsible Person/Department: Christina Poquette o Expected Completion Date: On going Name: Christina Poquette Title: Director of Food and Nutrition Signature: Date: 5/20/2024 Acknowledgement by Responsible Parties: Name: Title: Signature: Date: 5/20/2024

Organization Name: Sutton Public Schools Address: 16 Putnam Hill Rd Sutton MA 01590 Issue Date: 05/20/2024 Audit Reference: 23-001 Non-Compliance Issue: verification process not completed during school year 22-23 Root Cause Analysis: This was caused by lack of knowledge due to manager change over with no overlap and managers starting date after verification completion deadline. Corrective Action(s): In planning for next school year, it has been set as a calendar reminder for October 1st to start the verification process with weekly goals set as to what needs to be done each week. As well as a reminder set for November 15th to make sure verification paperwork is submitted prior to the due date of November 17th. 1. Action Item: o Description: Set plans and calendar reminders in place to ensure the verification process is start prior to the end of September and that all is completed to be completed accurately before due date o Responsible Person/Department: Christina Poquette o Expected Completion Date:10/17/2024 Name: Christina Poquette Title: Director of Food and Nutrition Signature: Date: 5/20/2024 Acknowledgement by Responsible Parties: Name: Title: Signature: Date:5/20/2024 Organization Name: Sutton Public Schools Address: 16 Putnam Hill Rd Sutton MA 01590 Issue Date: 05/20/2024

Audit Finding Reference: 2023-004 Excess Food Service Fund Balance Management's View and Planned Corrective Action: Management agrees that the Food Service Fund Balance needs to be reduced The Department of Education in FY2023 they did not require a spend down plan for the application. With that said we currently have a spend down plan in place to reduce the fund balance to a more appropriate fund balance and to meet the regulation. The spend down plan was submitted in March 2024. Name of Contact Person and Completion Date: Name 1 Amber Wheeler Name 2 Danielle Rossetti Anticipated Completion Date - December 31, 2024

Finding ref number: 2023-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with federal allowable activities and allowable costs requirements. Name, address, and telephone of District contact person: Cindy Feng, Controller 5150 220th Avenue S.E. Issaquah, WA 98029 (425)837-7139 Corrective action the auditee plans to take in response to the finding: The District used SCA funds to pay a vendor for locally produced dairy products for our schools that complied with the funding requirements. Invoices from the vendor show the total amount for each delivery but did not include item level details. With each delivery, a packing slip was provided to the Food Services Department staff members to confirm the receipt of approved items and reconcile for invoice approval. Once invoices were reconciled and properly approved with a signature indicating review, the District used the official invoice statement for payment processing and the delivery packing slip was no longer retained. To assist with the audit, the District provided auditors with the dairy vendor contract, vendor invoice statements, and an attestation letter from vendor stating the items purchased Issaquah School District 5150 220ᵗʰ Ave SE, Issaquah, WA 98029 phone: (425) 837-7000 https://www.isd411.org Page 64 Office of the Washington State Auditor sao.wa.gov conformed to the SCA item list. Unfortunately, these documents were deemed insufficient to allow SAO re-performing our internal controls to test its effectiveness. After SAO communicated the necessity for delivery packing slips in their testing, the District enhanced our current practice and began retaining all packing slips to support SAO’s internal control effectiveness review. We welcome any feedback to further strengthen our overall financial management practices moving forward. Anticipated date to complete the corrective action: June 2024

Corrective Action Required by The Board - The School District was not in compliance with CFR section 210.14 which requires that the net cash resources in the food service fund to be below its three month average expenditures at year end. Recommendation Number Corrective Action Required by The Board - The responsible officials are in agreement with the calculation. COVID's financial impact on the food service fund and ultimately the food service reserves has created this inflated financial position. We will use these funds to continue to invest in our food service equipment as well as upgrade our food options and meal quality, within USDA regulations.

The District will review the CNIPS report going forward and maintain the necessary supporting documentation of approvals.

A. Name of contact person responsible for corrective action: Dr. Matilda Miller, Business Manager B. Corrective action planned: The District will implement controls and procedures to ensure that all expenditures are reasonable and necessary for proper and efficient performance and administration of the Child Nutrition Cluster. C. Anticipated completion date: Immediately

A. Name of contact person responsible for corrective action: Dr. Matilda Miller, Business Manager B. Corrective action planned: The District will implement controls and procedures to ensure that all expenditures are reasonable and necessary for proper and efficient performance and administration of the Child Nutrition Cluster. C. Anticipated completion date: Immediately

We will implement a review process to confirm all corrections before submitting claims for reimbursement. This will ensure compliance with the 60-day claim submission requirement and accurate record-keeping, guarenteeing that Program funds are spent soley on allowable Child Nutrition Program costs.

CONDITION: The District did not maintain a general ledger system of accounting for its Cafeteria Fund which reports the financial activity of the federal National School Lunch and School Breakfast Programs. The financial activity occurring in this Fund is maintained in checkbook fashion during the fiscal year. This is a repeat finding (2022-004) from the previous fiscal year. CRITERIA: Prudent internal control over accounting for federal program funds requires non-federal organizations such as the School District to maintain financial records which account for federal funds in such a manner as to be able to properly track the receipt and use of federal funds as stated in Section 2 CFR Part 200 of the Uniform Guidance. Best practices suggest that the use of a general ledger system of accounting would enable the District to aggregate financial information involving federal funds during the fiscal year in such a manner to properly manage, monitor, and report the financial activity in compliance with federal program guidelines. RECOMMENDATION: The District’s accounting software can readily account for the financial activity of all Funds in a manner like the District’s General Fund. I am recommending that the management of the School District utilize the accounting software to enter the financial activity (Receipts and Disbursements) of the Cafeteria Fund in a manner like the General Fund. This procedure will significantly enhance the District-wide internal controls over financial reporting for the Cafeteria Fund, as well as provide management the ability to produce meaningful financial reports reflecting the activity in the Cafeteria Fund for prudent oversight by the Board of Education. In addition, this procedure will enable the District to comply with the recordkeeping requirements for federal funds as specified in Section 2 CFR Part 200 of the Uniform Guidance. MANAGEMENT’S CORRECTIVE ACTION PLAN: District management is reviewing its current system of processing the transactions for the Cafeteria Fund to determine the most efficient and effective manner for implementation of a general ledger system of accounting for this Fund as opposed to its current manual process. It is anticipated that the conversion of this Fund into the District’s accounting software can be completed during the 2024-2025 fiscal year to enable the District to comply with the recordkeeping requirements for federal funds as specified in 2 CFR Part 200 of the Uniform Guidance.

The Director of Food Service will continue to review monthly expenditures and plan accordingly.

Corrective Action Plan: Testing of procurement, suspension, and debarment was accomplished timely in most cases and leadership will continue to engage and teach agency staff to follow existing procurement policies to assure compliance. No further policy is necessary. Staff training will be strengthened. Responsible Individuals: Dr. Kenneth D. Varble – Vice President of Accounting Anticipated Completion Date: December 2024

Corrective Action Plan: Review and approval of invoices, meal count sheets, and reimbursement requests will be more closely monitored, and leadership will continue to engage and teach agency staff to follow existing policies to assure compliance. No further policy revisions are necessary. Staff training will be strengthened. Responsible Individuals: Dr. Kenneth D. Varble – Vice President of Accounting Anticipated Completion Date: December 2024

Corrective Action Plan: Material adjustments were related to funds that were not clearly identified as Federal Funds that came to use from State agencies. States have a responsibility to indicate when they are providing pass-thru funding from federal sources. No further action deemed appropriate by Nexus leadership. Responsible Individuals: Dr. Kenneth D. Varble – Vice President of Accounting Anticipated Completion Date: December 2024

Contact Person Rhonda Zastoupil, Business Manager Planned Corrective Action The Business Manager will review the monthly reimbursement reports and supporting data prepared by Business Office staff for accuracy and sign off on the reimbursement request prior to submittal to the Department of Public Instruction. Planned Completion Date Immediately

FINDING 2023 -003: Audit Report Deadline Response: The District does not feel this will be an issue going forward as the prior auditor was only one person and was a bit overwhelmed with his work load.