Corrective Action Plans

2024-002 Timely Time and Effort Approvals The Center continues to evaluate its processes related to time and effort. Our Time and Effort electronic system has been evaluated and enhancements are forthcoming to include robust functionalities to include timely supervisor approval notifications. Proposed Completion Date: May 31, 2025 Name of contact person: Rumalda Ruiz, Deputy Director – Business, Operations, & School Finance Support Contact: (956) 984-6290

2024-004 Lack of Retention of Student Applications Condition: In our testing of 40 applications for free and reduced lunch, 1 applications was missing. All other applications properly determined received free or reduced meals as eligibility determined. Criteria: As part of determining student eligibility for free or reduced meals, the District receives applications from student families. Federal requirements require the Distict official making the eligibility determination to retain all applications. Cause: Administrative oversight led to one application not being retained. Effect: The District was not in compliance with the requirements of the Child Nutrition Cluster. Recommendation: We recommend the District implement a process that requires immediate filing and retention of all applications after eligibility is determined. View of responsible officials: See attachment for District’s corrective action plan.

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

FINDING 2024-001 Child Nutrition Cluster - Eligibility School Breakfast program, National School Lunch Program, Eligibility, Significant Deficiency Contact Person Responsible for Corrective Action: Contact Phone Number: Kim Pusateri 219-659-0656 ext. 157 Views of Responsible Official: We concur with the finding. Internal Controls and procedures will be implemented to ensure accurate eligibility determinations for free and reduced-price meals by implementing internal controls, segregation of duties, and documented reviews. Description of Corrective Action Plan: Applications (eligibility): • Maintain records of all reviews for audit purposes. o Take a picture of the eligibility grid for review and date it. o Require two staff members (Director of Food Services and designee) to sign off on the review. Direct Certifications • The direct certification report will be run monthly and uploaded into the school point-of-sale system. A copy of the report will be saved, printed and checked that it was uploaded properly. A copy of the student's application and history will be printed and stapled to the direct cert report to verify that the change was made. It will be dated and initialed and saved in a folder. Anticipated Completion Date: Immediately

a. Significant Deficiency | Single Audit – “We recommend the District record reimbursements in the correct fiscal year.” b. Plan of Action – The District will establish a multi-step review process for all NSLP monthly meal claims to ensure accuracy. For the year-end claims (May/June) – should they be received after the end of the fiscal year they were claimed for – a journal entry that recognizes Accounts Receivable for the claim amount will be created and be reviewed for accuracy before being approved. c. Timeframe for (or date of) implementation – The multi-step review process for monthly NSLP meal claims has already been established (started in September 2024). The year-end journal entry process/review will be implemented in June 2025.

a. Significant Deficiency | Single Audit – “We recommend the District use someone other than the claim preparer to review the claims before being submitted, and document said review with initials and dates.” b. Plan of Actions – The District will establish a multi-step review process for all NSLP monthly meal claims to ensure accuracy. This process will include data input/review by the Nutrition Services Coordinator and review by the Director of Finance/Senior Accountant before submission to the state. c. Timeframe for (or date of) implementation - The multi-step review process for monthly NSLP meal claims has already been established (started in September 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, 10.555, AND 10.559) 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. The District did not have sufficient controls in place within its child nutrition cluster 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. 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 – Bryan Hennekens, Director of Finance and Operations. Planned Completion Date – June 30, 2025. Disagreement With or Explanation of Finding – The District is in agreement with this finding. Plan to Monitor – Bryan Hennekens, Director of Finance and Operations, will work with the financial auditors to review specific weaknesses identified during the annual audit and actions needed to eliminate or mitigate this internal control weakness.

FINDING 2024-003 Finding Subject: Child Nutrition Cluster (School Lunch) – Allowable Cost Summary of Finding: The payroll for non-certified employees for the 2023-2024 school year has not been approved by the board, leading to a lack of verification for salaries paid from fund 800. As a result, any payroll for non-certified employees paid after August 1, 2023 from fund 800 cannot be verified. Contact Person Responsible for Corrective Action: Robin Popejoy Contact Phone Number and Email Address: 317.758.4172 – rpopejoy@sheridan.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The salary schedules will be submitted to the board for approval. Anticipated Completion Date: May – August 2025

FINDING 2024-005 Finding Subject: Child Nutrition Cluster (School Lunch) – Eligibility Summary of Finding: Café Director uploaded the Direct Certification reports from the state into the software system without following a documented oversight or review process to ensure that direct certified students were accurately processed. This highlights a lack of documented controls for directly certified students. Contact Person Responsible for Corrective Action: Robin Popejoy Contact Phone Number and Email Address: 317.758.4172 – rpopejoy@sheridan.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Data Department will collaborate with the Café Department to input and ensure the accuracy of the information. Anticipated Completion Date: Already started in August of 2024.

FINDING 2024-004 Finding Subject: Child Nutrition Cluster (School Lunch) – Suspension and Debarment Summary of Finding: One of the vendors tested did not have documentation showing that the school corporation had verified they were not suspended or debarred before entering into a covered transaction. Contact Person Responsible for Corrective Action: Robin Popejoy Contact Phone Number and Email Address: 317.758.4172 – rpopejoy@sheridan.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Café Direction will check SAM.gov to ensure the vendor is not suspended or debarred before proceeding with any transactions. Anticipated Completion Date: January 2025

Purchases to replace outdated equipment will be pursued. We already purchased $1.1 million over the past 2 years.

Payroll disbursements will align to the approved salary schedule.

Findings and Questioned Costs Related to Federal Awards Finding Number: 2024‐001 Program Name/Assistance Listing Title: Child Nutrition Cluster Assistance Listing Numbers: 10.553, 10.555, 10.559 Contact Person: Anita Percell, Executive Director of Business Services Anticipated Completion Date: June 30, 2025 Planned Corrective Action: The District acknowledges the findings regarding the overcharging of indirect costs and is committed to ensuring full compliance with the federal cost principles and guidelines established by USDA and ADE. We will implement strengthened procedures, provide targeted training for relevant staff, and promptly reimburse the questioned costs.

The District had a positive balance in its nonprofit food service account as of June 30, 2022, therefore is exempt from the PLE pricing requirements for SY 23-24 and required to submit an exemption form. The District did not submit an exemption form for SY 23-24 to IL State Board of Education. The District will keep track of its nonprofit school food service account to determine if it is exempt from PLE pricing requirements for SY 24-25.

2024-004 FINDING Contact Person – Sue Chase, Superintendent Corrective Action Plan – The District should implement policies and procedures to ensure only allowable activities/costs are being charged against grants. Completion Date – December 30, 2024

One application was not properly approved by the verifying official: As the verifying official, the Food Service Director will check all applications going forward to ensure that the applications have been signed by the verifying official.

One application was incorrectly classified as free rather than paid: Food Service Director will send each building secretaries an email reminding them to make sure all sources of income are entered with the correct dollar amounts and frequency of pay so the eTrition system will calculate correctly to determine eligibility according to the USDA income eligibility guidelines. The determining officials and the verifying official will either attend in person or digitally a refresher class if offered by the Wilbur D Mills Education Cooperative in the summer of 2025.

One application was not available for audit inspection: All applications will be maintained for audit inspection. Going forward the Food Service Director will make sure all members of the household are listed on the application and matches the application in eTrition .

Finding 2024-001 – Child Nutrition Cluster – Eligibility Context: During sample testing of 60 students for eligibility, we noted 7 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: Mr. Patrick Culp Contact Phone Number: 219-279-2418 Views of Responsible Official: We concur with the finding. Of note, this is a new finding as we have never experienced this problem before. For this audit period, the Tri-County Food Service Director suffered a serious foot injury, requiring her to miss an extended period of time. When the accident with the Food Service Director occurred, one of the first actions the corporation took was to contact IDOE about our situation. The IDOE was aware how the review the process would look during that time. While the Food Service Director was recovering, student eligibility was not reviewed properly. Description of Corrective Action Plan: The Tri-County School Corporation food service director will complete all initial reviews of student eligibility. The initial review will be for both electronic and paper applications. Once the initial review is complete, the Tri-County central office secretary will complete a second review. The secretary works in a different building and does not have a role in eligibility determinations. Anticipated Completion Date: Our corrective action plan began in August 2024, upon the return of our food service director, and this is the plan moving forward.

Planned Corrective Action: Management will review potential uses for the net cash resources or communicate with the Louisiana Department of Education for appropriate return of funds. Person(s) Responsible: Kelly S. Batiste, CEO/Principal Estimated Completion Date: June 30, 2025

FINDING 2024-001 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: During the testing of internal controls over eligibility determinations for free and reduced meals, we noted there was no formal review control in place. There is no documented, secondary review for the applications entered in the food service software which determines eligibility. Additionally, there was no documented review by School Corporation personnel of the Income Eligibility Guidelines used by the food service software which are updated on annual basis. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Management will formally sign off on the Mosaic income guidelines annually prior to each school year. Responsible Party and Timeline for Completion: Shane Hacker, Assistant Superintendent of Operations; Corey Ebert, Director of Finance; Jordan Ryan, Director of Nutrition Services Anticipated Completion Date: February 1, 2025

Lack of documentation surrounding TEFAP eligibility. Responsible Individuals: Barbara Prather, Executive Director Corrective Action Plan: The Food Bank has implemented procedures to ensure TEFAP forms are updated annually and proper documentation is kept. Date of Completion: December 31, 2024

Child Nutrition implemented a new policy/procedure for handling free and reduced applications effective July 1, 2024.

District management agrees with above finding and has taken necessary corrective action, including the purchase of a food service vehicle, upgrade of equipment and the purchase or new equipment.

Finding 2024-001 – Child Nutrition Cluster – Eligibility 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: Tracy Wilson Contact Phone Number:317-408-1388 ext. 407 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Food Service Director will review and provide proof that multiple parties reviewed and confirmed the correct income eligibility guidelines in our software each year prior to making the applications available to parents. Anticipated Completion Date: Immediate