Corrective Action Plans

This has been resolved.

FINDING 2023-001 – Significant Deficiency in Internal Control over Compliance – Reporting Description of Finding: Controls should be in place to ensure the accuracy of reporting submitted for federal awards programs with proper supporting documentation to agree to the reports being submitted to the Department of Education. As part of the recordkeeping process, each month’s claim for reimbursement and all data used in the claims review process must be maintained on file. Of the eleven monthly claims reports reviewed during the audit, the supporting documentation for one of the claims (April 2023) could not be located. Statement of Concurrence or Nonconcurrence: The Town agrees with this finding. Corrective Action: The Town agrees with the finding and has implemented internal controls to ensure the supporting documentation for each monthly claim are filed and maintained. Each month the monthly claims reports and supporting documentation will be filed away in a designated secure location with a checklist by month to confirm processing. Name of Contact Person: Cynthia Varricchio, MBA, Director of Finance and School Business Operations. Projected Completion Date: June 30, 2024

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

The payroll department will be trained on the proper calculation of salary and compensation rates.

Finding: Certain timecards were not properly approved prior to payment of the payroll expenditure within Assistance Listing #10.555 and #10.553 in regards to the Child Nutrition Program. Response: This took place during a period of transition in management personnel within the Child Nutrition Program. The Chief School Finance Officer (CSFO) has implemented the following procedure: If a timesheet has not been approved by a supervisor, the timesheet will be deleted from the payroll run that month and payment will be delayed until the supervisor approval is obtained or approval is granted by the CSFO. Completion date: April 1, 2024.

USD #250 has implemented new procedures to ensure that information provided to the Food Service Director is correct. Personnel have been trained in the poper way to run reports under the District's accounting system. In addition, the Director of Business Operations will review the annual food service report prepared by the Food Service Director before it is submitted to the Kansas Department of Education.

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Pomeroy School District No. 110 September 1, 2022 through August 31, 2023 This schedule presents the corrective action the District is planning to take for findings included in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Finding ref number: 2023-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with federal suspension and debarment requirements. Name, address, and telephone of District contact person: Kelly McKeirnan, Business Manager 121 S. 10th St. Pomeroy, Washington 99347 (509) 843-3393 Corrective action the auditee plans to take in response to the finding: The District is committed to ensuring grant programs comply with federal regulations regarding suspension and debarment. In response to the audit finding, the District is taking the following corrective actions to address the audit recommendations: * Program staff will check the federal System for Award Management (SAM.gov) prior to the contract execution date. The contractor verification documentation will be maintained in each contract file. Due to the audit finding being issued late in the fiscal year 2024 audit cycle, the District was not able to fully implement corrective actions during the 2024 audit period. The District anticipates full compliance with the suspension and debarment requirement by fiscal year 2025. Anticipated date to complete the corrective action: 10/31/2024

Finding 2023-007: Procurement Finding: The District did not maintain adequate records for procurement transactions in the IDEA and Child Nutrition Clusters. Corrective Actions Planned: The District will train its employees on the documentation trail needed for procurement actions and review its policies and procedures for any needed updates. Expected Implementation Date: June 30, 2024 Contact Person: Dr. Frank Williams

Finding 2023-002 Condition: Suspension and debarment compliance was not verified for six covered transactions. Corrective Action Planned: The District has incorporated the language into contracts beginning with school year 2024. The language is not in the 2023 food service contracts. Anticipated Completion Date: Completed Contact: Ellen Finelli, MS. RD., Director of Food and Nutrition

Corrective Action Plan: West Side CTC has implemented financial policies and procedures to ensure a timely independent audit process and subsequent timely filing of the audit with the Federal Audit Clearinghouse.

Finding 2023-001: Procurement United States Department of Agriculture – Child Nutrition Cluster United States Department of Agriculture – Child and Adult Care Food Program Criteria: The non-federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rational for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price (2 CFR section 200.318(i)). The non-federal entity must also establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) (2 CFR section 200.303(a)). Condition: Records detailing which vendors were contacted, when they were contacted, and support for the rationale in choosing the vendor, is not documented. Questioned Costs: None Cause: Management did not maintain a detailed history of procurement and did not document a review process. Effect: There is no reasonable assurance that the Organization managed the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal award Recommendation: Purchasers should record, and keep on file, backup detailing which vendors were contacted, when they were contacted, support for the rationale in choosing the vendor. Management should implement a system of internal controls for this process. Planned Corrective Action: Shloma Weiss, Administrative Director, will establish and implement a process for documenting the procurement history and establishing a system of internal controls.

Finding 2023-003 Fed Agency Name: US Department of Agriculture Program Name: Child Nutrition Cluster – School Breakfast Program and National School Lunch Program CFDA #: 10.553 and 10.555 Finding Summary: During the Single Audit, it was discovered the District had five charges out of 40 tested where the payroll cost charged to the program did not have evidence of timecards by the employee. Corrective Action Plan: The District will improve its internal control process over the submission of timecards related to federal funds. Responsible Individual: Cassandra Stahlke Chief Financial Officer Anticipated Completion Date: June 30, 2024

Finding 2023-004 Fed Agency Name: US Department of Education, US Department of Agriculture and US Department of Treasury Program Name: Special Education Cluster – Special Education Grants to States, COVID 19 – Special Education Grants to States, Special Education Preschool Grants, and COVID-19 – Special Education Preschool Grants Child Nutrition Cluster – School Breakfast Program, National School Lunch Program and the Fresh Fruit and Vegetable Program COVID 19 - Coronavirus State and Local Fiscal Recovery Fund CFDA #: 84.027, 84.173, 10.553, 10.555, 10.582 and 21.027 Finding Summary: During the Single Audit, it was discovered the federal procurement processes required for acquiring goods and services were not followed. In addition, procedures were not always followed to maintain documentation regarding the verification of whether an entity was suspended or debarred before entering into a covered transaction. Responsible Individual: Cassandra Stahlke Chief Financial Officer Corrective Action Plan: The District will improve its internal control processes over the procurement of good and services and maintaining documentation on whether and entity is suspended or debarred relating to federal funds. Grant management staff will stay informed of Policy DHJ and corresponding procedures. ECSD has also created a Procurement Guide and will provide training to staff at the beginning of the academic year. Anticipated Completion Date: June 30, 2024

Finding ref number: 2023-001 Finding caption: The District’s internal controls were inadequate for ensuring compliance with federal suspension and debarment requirements. Name, address, and telephone of District contact person: Karen Walters, Director of Accounting 235 Sunset Ave, Wenatchee, WA 98801 509-663-8161 Corrective action the auditee plans to take in response to the finding: The District has implemented a process to ensure compliance. Purchase orders for Nutrition Services will have an electronic attachment showing a suspension and debarment check from SAM.gov. All purchase orders will be reviewed by the finance department prior to approval. Anticipated date to complete the corrective action: Implemented during audit

The District agrees that it failed to check Suspension and Debarment for one of its Child Nutrition vendors. Corrective action was taken May of 2023, at the time of the previous audit. Unfortunately, May is very late in the year, so actions that occurred prior to the Audit rolled forward into this audit period. Moving forward, just to be extra cautious, Child Nutrition will be issuing the Suspension and Debarment Attestation Form to all vendors and keeping copies on file.

The District believed they had complied with the suspension and department requirements and followed all of the bid document requirements for the Food Service Program. The District was unable to locate the specific documents related to the Food Service Program bid compliance. A recent leadership change resulted in a gap in knowledge about the previous filing system. The District thoroughly searched the former director's computer and potential filing locations, but unfortunately, didn’t find them. Going forward the Food Service Department will create a dedicated binder for these documents and place the binder in a location easily accessible to both the Director of Food Service and Administrative Assistant. Food Service will also provide copies to the Fiscal Department for their own binder.

Finding ref number: 2023-001 Finding caption: The District lacked adequate internal controls for ensuring compliance with federal suspension and debarment requirements. Name, address, and telephone of District contact person: Dan King 250 E Campus Dr. Belfair, WA 98528 (360) 277-2107 Corrective action the auditee plans to take in response to the finding: The District was experiencing high turnover with leadership roles in both its Food Service Department and Business Office when the failure to ensure compliance with federal suspension and debarment requirements occurred with one of its procurement contracts in August 2022. For corrective action the District put in place a requirement that all purchase order requests involving federal funds that amount to (or potentially could amount to) $25,000 or higher must include as an attachment in Skyward Financial Management the contract (when applicable) with verification that the vendor is not suspended and debarred and/or current documentation from Sam.gov verifying the vendor is not suspended or debarred. Any requisition involving federal funds that could amount to or exceed $25,000 that does not also include suspension and debarment verification will not be approved by the finance director and Business Office staff who process purchase order requests (as a control, both the finance director and the accounts payable technician must approve the request). Further, by requiring the suspension and debarment verification in Skyward as an attachment with the purchase order request, Business Office staff (regardless of staff turnover) will be able quickly locate and retrieve the documentation as needed for future audits and other external or internal purposes. Anticipated date to complete the corrective action: This corrective action was put into effect on April 18, 2024.

The following corrective actions have been put into place in order to address these findings:

•       The district will follow all guidelines outlined by the USDA during the verification process.

•       A change in personnel was made.

•       Child nutrition specialists from the Department of Education, Child Nutrition Unit have provided technical assistance to district employees on the verification process. This technical assistance included assistance in reviewing the correct number of applications, the process in which the confirming official confirms the applications, the correct documents that may be submitted for income documentation, the correct use of tracker forms, and the procedure for reclassifying applications after the verification process. This technical assistance was given in the spring semester this school year and will be repeated next year to ensure that the guidelines are followed.

•       District personnel will properly review the supporting documentation provided during the verification process which will include ensuring the correct number of applications are verified, that the confirming official confirms the applications, that the correct documentation of income is received, that the tracker forms are used correctly, and that the applications are reclassified after the verification process is completed, if necessary. This will be a multi layered review that will include the cafeteria managers, child nutrition director, director of federal programs, and superintendent.

There corrections had gone into effect Jan. 2024.

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Castle Rock School District No. 401 September 1, 2022 through August 31, 2023 This schedule presents the corrective action the District is planning to take for findings included in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Finding ref number: 2023-01 Finding caption: The District did not have adequate internal controls for ensuring compliance with federal procurement requirements. Name, address, and telephone of District contact person: Shelby Garrett, CSBS, CSBO Director of Fiscal Services Castle Rock School District 600 Huntington Ave S Castle Rock, WA 98611 Phone: 360.501.3132 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). Once the district was notified of the noncompliance regarding Child Nutrition federal procurement requirements, an interlocal agreement was immediately put in place with Longview School District for our small purchases of $150,000 or below. The agreement was approved by the Castle Rock School Board at the March 8, 2023 board meeting and approved by the Longview School District School Board on March 17, 2023. For our purchases above $150,000, the district requested to be a member of the Puget Sound Joint Purchasing Cooperative on March 6, 2023 and the membership was approved by the PSJPC Board on March 12, 2023. PSJPC provided the district with an interlocal agreement and the agreement was approved by the Castle Rock School Board at the March 22, 2023 board meeting. This agreement with PSJPC is a continuing membership and the district currently pays $150.00 to be apart of the cooperative. On August 30, 2024 Castle Rock renewed their interlocal agreements with Longview School District, however, Castle Rock did not request all of the documentation from Longview to ensure they were compliant with the required procurement laws. Castle Rock has since requested all applicable procurement documentation from Longview School District and has ensured they were compliant with procurement laws for the 2022-2023 and 2023-2024 school years. Moving forward, Castle Rock School District will request required documentation and ensure Longview School District is in compliance before entering into the interlocal agreements for the 2024-2025 school year. Anticipated date to complete the corrective action: 4.16.2024

The District relies on the auditor to propose adjustments necessary to prepare the schedule of expenditures of federal awards including the related note disclosures. The District reviews schedule of expenditures of federal awards and approves all adjustments.