Corrective Action Plans

We were previously found to be compliant with time and effort based on a single annual survey, although DEW’s guidance states it should be done semi-annually. We will be changing time and effort reporting to at least twice annually, resolving this issue. One was completed September 2024 and another will be completed by February 2025.

Maywood-Melrose Park-Broadview School District 89 06-016-0890-02 CORRECTIVE ACTION PLAN FOR CURRENT YEAR AUDIT FINDINGS22 Year Ending June 30, 2024 Corrective Action Plan Finding No.: 2024- 005 Condition: It was noted during the audit that ineligible expenditures were charged to the food service expenditure function. These expenditures were for a back-to-school picnic and consisted of backpacks with school supplies that were provided to students. These expenditures should not have been charged to the food service function in the District’s general ledger system. Plan: The district is reviewing all expenditures monthly to ensure all of them are recorded with the proper account code. Any changes needed will get a journal entry through the Proviso Treasurer’s Office. Anticipated Date of Completion: June 30, 2025 Name of Contact Person: Scott Wold, Business Manager

Maywood-Melrose Park-Broadview School District 89 06-016-0890-02 CORRECTIVE ACTION PLAN FOR CURRENT YEAR AUDIT FINDINGS22 Year Ending June 30, 2024 Corrective Action Plan Finding No.: 2024- 004 Condition: The District has a contract with Open Kitchens for meals served under the Child Nutrition Cluster. In early fiscal year 2024, the District received notice that the method of payment to this vendor was to change to ACH. After further correspondence, the District remitted an ACH payment for three months of services for $936,828. The District subsequently discovered that the ACH was remitted to a fraudulent vendor. Plan: The district’s plan is any request through ACH will first get a call to the accounts receivable department at the company to ensure this is the proper way of making payment. The district will also follow up with a second call to our account rep to verify that the information is correct. The original payment to the vendor will be a small portion of the payment to verify the information. After this payment, a call will be made to accounts receivable to ensure payment. Anticipated Date of Completion: June 30, 2025 Name of Contact Person: Scott Wold, Business Manager

Context: For 5 selections, in a sample of 5 payroll transactions, the School Corporation did not have time and effort logs to support the portion of the employees’ time charged to the grant. The employees’ time was split with a non-federal fund; however, the School Corporation did not have support for the allocation of the time charged to the School Lunch fund. Contact Person Responsible for Corrective Action: Chris Scott Contact Phone Number: 765-544-2246 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The School Corporation will implement a formal time and effort reporting system for all employees whose salaries are partially funded by federal grants. Our Café department has since revised our process and no longer charge any SES employee payroll to the Café Account for cleaning. As a result, this issue has been fully addressed and should not recure in future reporting periods Anticipated Completion Date: July 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: Chris Scott Contact Phone Number: 765-544-2246 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: A new Food Service Director has been hired and will take responsibility for ensuring compliance with eligibility requirements. Additionally, the Business Manager will oversee the corrective actions and implement a formal secondary review process. The Business Manager will conduct and document secondary reviews for all applications entered into the food service software to verify eligibility determinations. This ensures compliance with regulatory standards and addresses the deficiencies noted in the audit findings. Anticipated Completion Date: June 2025

The District will reduce net cash resources by investing in capital equiment where necessary and allocating direct cost overhead expenditures.

CORRECTIVE ACTION PLAN Department of Education: The Baldwin-Whitehall School District respectfully submits the following corrective action plan for the year ended June 30, 2024. Name and address of the independent public accounting firm: J. Martin and Associates, LLC P.O. Box 498 Beaver, PA 15009 Audit period: June 30, 2024 The findings for the year ended June 30, 2024 schedule of findings are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Section B – Financial Statement Findings 2024-1 Best Practices Recommendation: Ideally, the District would hire the number of staff necessary to segregate all duties. However, we realize segregation of duties is not practical, if not impossible. Because of this internal control situation, the responsibility of the Business Manager is greatly increased because the Board must rely on his knowledge of the everyday operations to discover any material changes in the School District’s financial position. Management’s Response: The School District recognizes that the limited number of staff adds to the risk associated with the daily operations. To mitigate this risk, the Business Manager has to take an active role in the day-to-day operations of the Business Unit. He actively reviews all reconciliations and receipts to ensure they are posted to the accounting system properly. In addition, he approves all check disbursements through the Positive Pay process and physically signs every accounts payable check that is issued by the School District. Recommendation: We recommend that the District strongly encourage the tax collectors to obtain a SOC report in order to ensure proper controls are in place. Management’s Response: The School District understands the importance of obtaining SOC reports from service organizations and will continue to inquire of the appropriate entities to ensure they obtain the proper reports. In discussion with the Delinquent Tax Collector, they notified the District that it is extremely cost prohibitive for them to go through a review that would end with the issuance of a SOC report. Section C – Major Federal Award Findings 2024-2 Segregation of Duties – Child Nutrition, Title I, ESSER Recommendation: Ideally, the District would hire the number of staff necessary to segregate all duties. However, we realize segregation of duties is not practical, if not impossible. Because of this internal control situation, the responsibility of the Business Manager is greatly increased because the Board must rely on his knowledge of the everyday operations to discover any material changes in the School District’s financial position. Management’s Response: The School District recognizes that the limited number of staff adds to the risk associated with the daily operations. To mitigate this risk, the Business Manager has to take an active role in the day-to-day operations of the Business Unit. He actively reviews all reconciliations and receipts to ensure they are posted to the accounting system properly. In addition, he approves all check disbursements through the Positive Pay process and physically signs every accounts payable check that is issued by the School District. If you have questions about this report or need additional financial information, please contact Mark Cherpak, Business Manager at: 4900 Curry Road Pittsburgh, PA 15236 412-884-6300

CORRECTIVE ACTION PLAN

2024-004 FINDING Contact Person – Thomas A. Jerome, Superintendent Corrective Action Plan – The District will implement policies and procedures to ensure all students who receive a free or reduced meal have a current and accurate application on file. Completion Date – March 31, 2025

2024-003 FINDING Contact Person – Thomas A. Jerome, Superintendent Corrective Action Plan – The District will implement policies and procedures for verifying free and reduced applications. Completion Date – March 31, 2025

Finding 2024-003 School Nutrition Program Meal Claims 1. Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. 2. Actions Planned in Response to Finding The District has already begun evaluating current procedures for accurately monitoring, recording, and reporting the number and type of meals served. 3. Official Responsible Mr. Greg Johnson, Superintendent, is the official responsible for ensuring corrective action. 4. Planned Completion Date The planned completion date is June 30, 2025. 5. Plan to Monitor Completion The Board of Directors will be monitoring this Corrective Action Plan.

The District took immediate steps to remedy the issue, new reviews are required before and after submission. The Business Manager and Food Services Director have implemented the changes.

FINDING 2024-001 Finding Subject: Child Nutrition Cluster – Procurement and Suspension and Debarment Summary of Finding: The School Corporation did not verify that a vendor was neither suspended nor debarred. Contact Person Responsible for Corrective Action: Jessica Espinoza Contact Phone Number and Email Address: (219)836-9111 jbespinoza@munster.us Views of Responsible Officials: We concur with the finding. All vendors have been verified for suspension and debarment, thereafter. This was the only vendor that was missed. All employees have been trained to check for vendor suspension or debarment. Description of Corrective Action Plan: The School Corporation will ensure that the vendor is either listed in SAM.gov or states in their contract that they are neither suspended nor debarred. Anticipated Completion Date: March 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, Summer Food Service Program for Children, Fresh Fruit and Vegetable Program Assistance Listing Number: 10.553, 10.555, 10.559, 10.582 Federal Award Numbers and Years (or Other Identifying Numbers): FY 22-23, FY 23-24 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Significant Deficiency Context: For the two small purchase method procurements sampled for testing, we noted that the School Corporation did not obtain quotes from an adequate number of qualified sources. Additionally, the School Corporation did not perform a suspension and debarment check on the vendors. The sample items were for $76,200 and $31,639 worth of repair supplies in FY2023 and FY2024, respectively. Contact Persons Responsible for Corrective Action: Andrew J Nicodemus, Business Manager Amber Reed, Director of Food Services Contact Phone Number: 765-362-2342 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Crawfordsville Community School Corporation plans to review all internal control procedures, including the controls over Procurement and Suspension and Debarment for the Child Nutrition Cluster. After this review, we will implement a system to ensure that the proper procedures are completed and fully integrated into our internal control structure. We will implement additional training for all staff involved and will have a designated place where this support is kept. Anticipated Completion Date: We expect this Corrective Action to be implemented by the end of March 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, Summer Food Program, School Summer Food Service Program, Fresh Fruit and Vegetable Program Assistance Listing Number: 10.553, 10.555, 10.559, 10.582 Federal Award Numbers and Years (or Other Identifying Numbers): FY2023, FY2024 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. Additionally, there was no documented annual review by School Corporation personnel of the FY23 income eligibility guidelines used by the food service software. The School Corporation did formally review the FY24 income eligibility guidelines used in the food service software. Contact Persons Responsible for Corrective Action: Andrew J Nicodemus, Business Manager Amber Reed, Director of Food Services Contact Phone Number: 765-362-2342 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Crawfordsville Community School Corporation plans to review all internal control procedures, including the controls over Eligibility for the Child Nutrition Cluster. After this review, we will implement a system to ensure that the Eligibility and Application review procedures are appropriate and fully integrated into our internal control structure. We will implement additional training for all staff involved and will have a designated place where this support is kept. Anticipated Completion Date: We expect this Corrective Action to be implemented by July 31, 2025.

Finding #2024-008 – Significant Deficiency. Applicable federal programs: U. S. Department of Agriculture, Passed through Texas Education Agency: School Breakfast Program, AL#10.553, Contract #: 71402301, Contract period: 10/01/22 – 09/30/23, School Breakfast Program, AL#10.553, Contract #: 71402401, Contract period: 10/01/23 – 09/30/24, National School Lunch Program, AL#10.555, Contract #: 71302301, Contract period: 10/01/22 – 09/30/23, National School Lunch Program, AL#10.555, Contract #: 71302401, Contract period: 10/01/23 – 09/30/24. U. S. Department of Education, Passed through Texas Education Agency: Special Education Grants to States, AL#84.027A, Contract #: 246600011238076600, Contract period: 08/08/23 – 09/30/24, Special Education Preschool Grants, AL#84.173A, Contract #: 24660011238076610, Contract period: 08/08/23 – 09/30/24, Special Education Preschool Grants, AL#84.173X, Contract #: 24660011238076610, Contract period: 10/01/22 – 09/30/23. Condition and context: Same as finding #2024-006. Recommendation: Same as finding #2024-006. Planned corrective action: Same as finding #2024-006. Responsible officer: Chief Financial Officer – Lea Ann Hendrick. Estimated completion date: Same as finding #2024-006.

Finding #2024-007 – Significant Deficiency. Applicable federal programs: U. S. Department of Agriculture, Passed through Texas Education Agency: School Breakfast Program, AL#10.553, Contract #: 71402301, Contract period: 10/01/22 – 09/30/23, School Breakfast Program, AL#10.553, Contract #: 71402401, Contract period: 10/01/23 – 09/30/24, National School Lunch Program, AL#10.555, Contract #: 71302301, Contract period: 10/01/22 – 09/30/23, National School Lunch Program, AL#10.555, Contract #: 71302401, Contract period: 10/01/23 – 09/30/24. U. S. Department of Education, Passed through Texas Education Agency: Special Education Grants to States, AL#84.027A, Contract #: 246600011238076600, Contract period: 08/08/23 – 09/30/24, Special Education Preschool Grants, AL#84.173A, Contract #: 24660011238076610, Contract period: 08/08/23 – 09/30/24, Special Education Preschool Grants, AL#84.173X, Contract #: 24660011238076610, Contract period: 10/01/22 – 09/30/23. Condition and context: Same as finding #2024-004. Recommendation: Same as finding #2024-004. Planned corrective action: Same as finding #2024-004. Responsible officer: Chief Financial Officer –

The District took immediate steps to remedy the issue, new reviews are required before and after submission. The Business Manager and Food Services Director have implemented the changes.

Federal Single Audit for the Period Ending June 30, 2024 Corrective Action Plan February 5, 2025 ➢ The major program the finding pertained to: 2024-001. Internal Control Over Compliance, United States Department of Agriculture, Passed-through New York State Department of Education: Child Nutrition Cluster, School Breakfast Program ALN: 10.553, National School Lunch Program ALN: 10.555 ➢ Condition: The District has not yet updated its existing policies and written procedures to conform to the Uniform Guidance requirements. ➢ Planned Corrective Action: The District has already updated its policy and related procedures in order to comply with the requirements of Uniform Guidance. The Board of Education adopted its policy in May 2024. ➢ Name, Title and Contact Info of Responsible Person: Sam M. Schneider Assistant Superintendent for Business East Hampton Union Free School District 4 Long Lane East Hampton, NY 11937 (631) 329-4106 sam.schneider@ehschools.org ➢ Anticipated Completion Date: Already implemented on May 21, 2024.

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF AGRICULTURE, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, CHILD NUTRITION CLUSTER – FEDERAL ALN 10.553 AND 10.555 2024-002 Internal Control Over Compliance With Federal Suspension and Debarment Requirements Finding Summary 2 CFR § 180 requires the District to establish and maintain effective internal control over compliance with requirements applicable to federal program expenditures, including suspension and debarment requirements applicable to the child nutrition cluster federal program. The District did not have sufficient controls in place within its child nutrition cluster federal program to assure that it was not contracting for goods or services with parties that are suspended or debarred, or whose principals are suspended or debarred from participating in contracts involving the expenditures of federal program funds. Corrective Action Plan Actions Planned – The District will review policies and procedures relating to suspension and debarment for its federal programs and will ensure that all parties with which it contracts for goods or services are eligible to participate in contracts involving the expenditures of federal program funding. Official Responsible – Kerstin Quigley, Business Manager. Planned Completion Date – June 30, 2025. Disagreement With or Explanation of Finding – The District agrees with this finding. Plan to Monitor – The District’s Business Manager and the Superintendent will ensure appropriate controls are in place to verify that any vendor with which the District contracts for federal program goods or services exceeding $25,000 is not listed as suspended or debarred on the federal Excluded Parties List System website.

Daily meal county reports will be reviewed and verified that it agrees to the edit check worksheets prior to monthly reimbursement submission. Any differences will be properly investigated and resolved.

FINDING 2024-001 Finding Subject: Child Nutrition Cluster-Eligibility Summary of Finding: An effective internal control system, which would include segregation of duties, was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the following compliance requirements for Eligibility related to income guidelines and Direct Certifications. No controls were in place to ensure the Food Service Director was inputting the income guidelines into the Harmony software correctly and that direct certification reports were run at the start of the school year and monthly thereafter, and that the student statuses were updated, accordingly. No one verified that the year-to-date direct certification reports were run to catch any students that were missing. Contact Person Responsible for Corrective Action: Vonessia Harmon, Business Manager Contact Phone Number and Email Address: 765-569-4195 harmonv@ncp.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Food Service Director is responsible for ensuring the annual Free & Reduced income guidelines are entered into the student software system prior to Online Registration each school year. The Food Service Director will provide a copy of the income guidelines to the Business Manager for review. The Business Manager will review the income guidelines for accuracy and keep the documentation on file. The Food Service Director is responsible for running the Direct Certification reports. Direct Certification Reports shall be completed at the start of each school year and on a monthly basis thereafter. The Food Service Director is responsible for ensuring that student records are updated to the proper eligibility status in the student software system. The Business Manager is responsible for reviewing the Direct Certification Reports on a monthly basis and confirming that the student records have been updated. Audit Evidence: Copies of annual income guidelines and all Direct Certification Reports signed by both the Food Service Director and the Business Manager will be kept on file along with proof of the updated student record(s). Anticipated Completion Date: Effective immediately

Finding 2024-002: Eligibility – Significant Deficiency in Internal Control over Compliance, Other Matter Compliance Finding Condition: During eligibility testing, we found instances of non-compliance, as follows: TEFAP – We noted that for one out of 20 participants sampled for TEFAP, an ineligible community partner organization was able to order approximately 100 pounds of TEFAP food from CAFB’s website. CSFP – We noted that for one out of 40 individual participants sampled for CSFP, one participant’s original enrollment documents supporting eligibility was missing. The organization did have the participant’s re-enrollment documents for the subsequent fiscal year. This is related to a person being eligible to receive food. Views of Responsible Officials and Planned Corrective Actions: The Organization's investigation into the root causes of the two incidents revealed clerical errors. For the TEFAP incident, a mistake in the partner organization's profile allowed access to USDA food via our online ordering portal. Regarding the CSFP participant, the initial eligibility documents were misplaced, but subsequent reauthorization documents were available. The Organization’s planned corrective actions with respect to the two instances include the following: TEFAP partner eligibility:  Review and enhance existing procedures for establishing partner organization profiles; and  Establish a periodic reconciliation of partner organization’s authorized to access TEFAP commodities in the online ordering portal with a listing of authorized TEFAP partners CSFP eligibility:  Review and enhance existing procedures for filing individual eligibility documents; and  Continued internal reviews by the Organization’s compliance department covering the filing of individual eligibility documents Anticipated Completion Date: March 2025

Action Taken: The district concurs with this finding. The staff of the district has been properly trained to use the Paid Lunch Equity (PLE) Tool provided by USDA to determine adequate price for paid lunches. The CFO will make the calculation annually and will take to the board any changes that need to be made to ensure compliance with TDA pricing regulations.

Action Taken: The district concurs with this finding. Management has clear job duties established and the CFO will be responsible for obtaining approval from TDA for capital asset purchases of $5000 or above.