Corrective Action Plans

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Walla Walla School District No. 140 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 to ensure compliance with federal procurement requirements. Name, address, and telephone of District contact person: Janette Jeffris, Director of Fiscal Services 364 South Park Street Walla Walla, WA 99362 (509) 526-6718 Corrective action the auditee plans to take in response to the finding: As of result of finding for federal procurement requirements the District has reviewed the procurement requirements with the food service director and staff. In addition, the district has reviewed current spending with vendors within food services to determine procurement requirements for 24-25 fiscal year. This review will be done on an annual basis. In the future the district will review and document the requirements of the awarding agency to ensure they align with our own requirements based on local spending patterns. The district did not have adequate time to implement this for the 23-24 fiscal year. Anticipated date to complete the corrective action: 9/1/2024

2023-006 Late Audit Submission Programs: Impact Aid, Education Stabilization Fund (COVID-19) Federal Assistance #: 84.041, 84.425 Federal Agency: U.S. Department of Education Grantor Number: N/A Questioned Costs: N/A Type of Finding: Noncompliance Compliance Requirement: L. Reporting Planned completion date for corrective action plan: For the period ending June 30, 2024. Name of the contact person responsible for corrective action: Contact person: Becky Tinney, Business Manager Condition: The District did not submit their audit for the fiscal year ending June 30, 2023, timely. The audit was submitted on May 16, 2024. Corrective Action Plan: The District will implement procedures to ensure that all audit documentation is available for auditing in a timely manner and the audit report is submitted within the appropriate timeframe.

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Vancouver School District No. 37 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’s internal controls were inadequate for ensuring it complied with federal procurement requirements. Name, address, and telephone of District contact person: Brett Blechschmidt 2901 Falk Road Vancouver, WA 98661 (360)313-1341 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). Prospectively, any call for bids involving federal funds, will be reviewed and physically signed off on by the administrator overseeing the district program that is receiving the federal grant and the district's Finance Manager before being published. This review will attempt to confirm compliance with all relevant federal procurement regulations. Anticipated date to complete the corrective action: April 1, 2024

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE East Valley School District No. 361 September 1, 2022 through August 31, 2023 This schedule presents the corrective action planned by the District for findings reported 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: Neale Rasmussen 3830 N. Sullivan Road, Spokane, WA 99216 (509) 241-5042 Corrective action the auditee plans to take in response to the finding: The District has implemented changes requiring all orders paid all or in part with federal funds in an amount greater than $25,000 to be submitted on a purchase order. Before the purchase order is approved, business office staff will complete a suspension and debarment check at SAM.gov. Anticipated date to complete the corrective action: Changes have already been implemented.

District Response and Corrective Action Plan: The Business Office will monitor the list at SAM.gov monthly and will check new vendors against the suspendered and debarment list. The District will not work with debarred vendors.

Plan: The business manager will assess the internal controls over child nutrition claims and adjust the processes to ensure accurate reporting.

The Director of Child Nutrition, Syed Zaidi, will establish an inter-program vending agreement to determine how much the National School Lunch program was charged and will submit the journal to reimburse the program. To be established as of 6/30/2024.

39-074-0250-26 CORRECTIVE ACTION PLAN FOR CURRENT YEAR AUDIT FINDINGS Year Ending June 30, 2023 Corrective Action Plan Finding No.: 2023-_ 004__ Condition: The District did not perform an on-site review of their counting and claiming system related to the Child Nutrition Cluster. Plan: The District will implement Internal controls that ensure that an on-site review of the counting and claiming system related to the Child Nutrition Cluster is performed on at least an annual basis. Anticipated Date of Completion: 06/30/2024 Name of Contact Person: Adam Clapp Management Response: Management will implement the corrective action plan for the year ended June 30, 2024.

39-074-0250-26 CORRECTIVE ACTION PLAN FOR CURRENT YEAR AUDIT FINDINGS Year Ending June 30, 2023 Corrective Action Plan Finding No.: 2023-_ 003__ Condition: The verification process was not performed. Plan: The District will complete the annual verification process by November 15th and will report the results to ISBE by December 15th. Anticipated Date of Completion: 06/30/2024 Name of Contact Person: Adam Clapp Management Response: Management will implement the corrective action plan for the year ended June 30, 2024.

Finding: 2023-032 - Pandemic Electronic Benefit Transfer Food Benefits (P-EBT) benefit payments were not issued in accordance with the process and timeframes outlined in the federally approved state plan. Testing a sample of 136 payments found 37 issuances (27 percent) were sent to unauthorized or unsupported addresses and one issuance included unauthorized benefits. Additionally, no benefits were issued during FY 23 to Supplemental Nutrition Assistance Program (SNAP)-enrolled children in child care. Questioned Costs: AL 10.542: $27,387 Assistance Listing Number: 10.542 Assistance Listing Title: P-EBT – COVID-19 Views of Responsible Officials (state whether your agency agrees or disagrees with the finding; if you disagree, briefly explain why): DOH partially agrees with the finding. The Division communicated with FNS regarding manual benefit issuance for Alaska expressing timelines would be affected and FNS did not request an updated timeline. Communication with FNS regarding issuance remained consistent, with no indication to alter our issuance plan. Address verifications were conducted at the time of benefit payment, because addresses are subject to change from the date of eligibility. Updates to addresses were made when more recent information became available. The division has no control over DEED eligibility records including the addresses they have on file. Corrective Action (corrective action planned): Shall the Division agree to administer this federal program in the future, the commissioner will allocate resources necessary to prevent the necessity to manually administer the federal program. Completion Date (list anticipated completion date): Not applicable. This federal program is complete. Agency Contact (name of person responsible for corrective action): Josie Stern, Assistant Commissioner

The School should complete all items in the corrective action plan provided by the CNU. Views of Responsible Officials and Planned Corrective Actions: The School has completed all items in the corrective action plan and submitted them to the CNU. The CNU accepted the corrective action plan items and closed their administrative review in May 2023.

The District understands that all documentation must be retained to support the verification process for free and reduced lunches. Procedures will be implemented to ensure the security of the documentation.

FINDING 2022/2023-008: Audit Report Deadline (Repeated 2021-003) Response: After the last couple years of Business manager and auditor turnover this finding will be easily corrected for the 23-24 audit.

3. Finding 2023-003. Fund Balance Management Corrective Action: Previous audit year expenses were classified as “General” funds when they should have classified as “Food Service”. This, in aggregate, has led to an excess fund balance. Management, will work with the state on how to transfer the large arrear fund balances between accounts. Management will also endeavor to assure that all ongoing expenses are allocated to the correct fund. Responsible Person/Position: Rod Iberg/COO and Linda Heidrich/Staff Accountant

The Center did not retain the eligibility documentation for one student and there was an incorrect computation for one student. Response and Planned Corrective Action: The Center acknowledges this finding, and will take the steps necessary to ensure that the information in the system is updated regularly. Planned Corrective Action: to be implemented immediately. o The Director of Food Service will review the controls currently in place and revise accordingly to ensure that accuracy and completeness of data is maintained. o Proper documentation will be maintained by school staff and will be reviewed regularly by the Director of Food Services and or the Business Manager/Asst. Business Manager.

The Bookkeeper will look at and sign off on all final food service claims before being submitted.

The District will develop a plan to reduce the food service fund's net cash resources below its three month average expenditures as required by CFR Section 210.14 Resource Management (b) Net Cash Resources.

Condition: The District submitted claims for meal reimbursements that were higher than the meals actually served. Plan: Management will review and implement procedures to ensure the reports used for daily counts match the reports used for submitting the claim to ISBE. Anticipated Date of Completion: 6/30/2024 Name of Contact Person: Annie Mulvaney, Assistant Superintendent Management Response: N/A

FINDING 2023-007 Compliance Requirement(s): Non-Profit School Food Service Accounts Audit Findings: Material Weakness, Other Matters Summary of Finding: There was no documented control in place over the receipt of monthly meal reimbursements. One individual received notification of deposit, received funds into accounting software, and prepared bank reconciliations. There was no documented review of the receipt of monthly meal reimbursements by a second individual not involved in the original receipt process. Views of Responsible Officials: We Concur with this finding. Description of Corrective Action Plan: The Business Manager and Cafeteria Manager will meet monthly to review the deposit statement from the bank to verify all deposits are accurate and accounted for the Food Service Fund. The bank statement will be initialed by both parties and retained on file in the business office. Anticipated Completion Date: Immediately

FINDING 2023-006 Compliance Requirement(s): Reporting Audit Findings: Material Weakness, Other Matters 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: Reporting There was no documented control in place over the review of monthly reimbursement claims. Claims were prepared and submitted by one individual without documentation that they were being reviewed by a second person not involved in the original process. The lack of controls resulted in overstatements in the number of meal counts used for reimbursement purposes when compared to School Corporation supporting documentation. Views of Responsible Officials: We Concur with this finding. Description of Corrective Action Plan: The food service director will enter the claims into CNPWeb Claim reimbursement site using the information from the Point of Sale system reports for reimbursable meals. The Business Manager will then confirm the meal counts before submitting the Claims. The FSMC food service director meets with the Superintendent monthly to review all claims and food service financials. A meeting agenda will be signed by all parties involved and retained on file in the business office. Anticipated Completion Date: Immediately

FINDING 2023-005 Compliance Requirement(s): Allowable Activities, Allowable Costs / Cost Principles Audit Findings: Material Weakness, Other Matters 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: Allowable Activities, Allowable Costs / Cost Principles The School Corporation paid trash removal services from the School Lunch fund without a methodology or supporting documentation for the amount charged. Without a reasonable methodology for the expenses paid, the amount was considered a questioned cost. The total amount charged to the School Lunch fund was $15,448. Internal controls over vendor disbursements were in place but were not operating effectively during the audit period. Additionally, there was no documentation indicating that payroll disbursements were reviewed or approved by a second individual not involved in the original payroll process. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Views of Responsible Officials: We Concur with this finding. Description of Corrective Action Plan: The School will start to divide trash removal services between cafeteria accounts and building accounts when being paid monthly. Verification of percentage coming from each account will be discussed. Internal controls will be put in place to document that payroll disbursements are being reviewed by a second individual. Payroll disbursement reports will be presented to the correct central office employee. Anticipated Completion Date: Immediately

Plan: The District will keep physical copies of reports and claims submitted. As students switched categories (free, reduced, and paid), the electronic system failed to keep that in account, leading to discrepancies.

The District will develop a plan to reduce the food service fund's net cash resources below its three month average expenditures as required by CFR Section 210.14 Resource Management (b) Net Cash Resources.

Finding 2023-004 - Corrective Action Plan CHSD - 2022-2023 Audit Findings Finding 2023-004 – SPECIAL TESTS AND PROVISIONS (repeat comment) Type: Significant Deficiency in Internal Control / Noncompliance Program: Child Nutrition Cluster (ALN 10.553, 10.555 and 10.559) Condition: As of year-end the District had a fund balance in the non-profit food service fund in excess of three months’ operating expenses by approximately $157,881. Criteria: The USDA requires that the District limit its net cash resources to an amount that does not exceed 3 months average expenditures of the non-profit food service fund per requirements in 7 CFR Part 210.14(b). Cause: This condition was caused by the meal claims increasing and having more reimbursements come in than anticipated. Corrective action to be taken: Over the 2023-2024 school year, the District will continue to leverage the excess fund balance to improve the quality of the food service program. Efforts to address the ongoing excess fund balance condition are ongoing and, while planning started in the 2022-2023 school year, an aggressive food service capital reinvestment project is scheduled to be completed in the 2023-2024 school year. This $220,000+ project will address equipment replacement and student service improvements in both the High School and the Middle School. The spend down associated with this project is anticipated to offset the excess fund balance on June 30, 2023, as noted in this finding. However, anticipating the potential for continued Food Service Program funding support at a state and federal level, the CHSD food service department will continue to monitor the fund balance with the goal of proactively managing any forecasted excess balance by continuing to offer more new food choices and improve the quality of the food served (including more fresh produce and better-quality ingredients). These improvements will continue to be in conjunction with the Michigan Department of Education's Office of School Support Services which will again approve the spending plan. The corrective action timeline is as follows: The corrective action is effective immediately and encompasses the ongoing efforts on the part of the District to comply with program criteria while balancing unpredictable statutory revenue streams against spending forecasts in the highly volatile food service market conditions. The District anticipates compliance with the Fund Balance condition set forth in the program by 6-30-2024. District Leader Responsible for Corrective Action Plan: The Food Service Administrator will be responsible for ensuring compliance with this corrective action. Respectfully submitted, Marc Forrest, Director of Finance

Contact Person Responsible for Corrective Action: Nicole Fortier, Director of Finance and Operations Corrective Action: During our audit it was identified that MMUUSD overpaid an employee for four charges under the Food Service program and charged the work to the program that was not specific to Food Service. To be more specific, Food Service subs were paid at a higher rate ($.50 higher) than the stated rate for a Food Service substitute. Additionally, there were instances noted where a maintenance substitute was charged to a Food Service budget unit. The first step in our corrective action plan was a review with our Senior Payment Specialist of the importance of slowing down and verifying the correct hourly rate being input for our substitutes. This step has already been completed. Additionally, we are in the process of implementing a more thorough payroll review process, which will include a preliminary review by Christal Clark, Accountant in the Business Office. Once Christal has completed her review, this will go to Nicole Fortier, Director of Finance for a final, high‐level review and sign off. We are hopeful to begin the process at the end of FY24, with full implementation in FY25. Anticipated Completion Date: 7/01/2024