Corrective Action Plans

We agree with the auditor's comments, and the following actions have been taken to ensure all expenditures are allocated to the correct programs: 1. Prior to submitting the monthly meal claims to the California Nutrition Information & Payment System (CNIPS), a monthly meal count report is generated from MealTime, the point of sale program for each school site. 2. The montly meal count numbers are entered into CNIPS, and then the MealTime report is used to verify the meal counts match. 3.The Office Assistnant verifies the site claim numbers to ensure there are no errors or typos. Jason Hill, Director of Nutrition Services, is responsible for implementing this corrective action.

Recommendation Number - 2024-001 Finding - The School District's food service fund net cash resources exceeded its three month average expenditures by $113,996.16. Recommendation- That the School District develop a plan to reduce the food service fund's net cash resources below its three-month average expenditures. Method of Implementation - Monitor net cash resources, working with cafeteria staff and administration to identify and spend necessary funds on allowable purchases to reduce net cash. Responsible for Implementation - Mr. Matt Sheehan, Superintendent Implementatoin Date - 6/30/2025

2024-003 Reporting Federal Assistance Listing Number: 10.553, 10.555, and 10.559 Program: Child Nutrition Cluster Federal Agency: U.S. Department of Education Pass-Through Agency: Arizona Department of Education Pass-Through Number: ADE ED09-0001 Compliance Requirement: L. Reporting Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Noncompliance (Other Matter), significant deficiency in internal control Questioned Costs: $4,397.30 of underreported claims Repeat Finding: This is not a repeat finding. Condition/Context: The District did not properly calculate, and report meal claims accurately for three of 4 months selected during the current year. This led to the District under-reporting $4,397.30 in student meal claims. Criteria: The Uniform Guidance compliance supplement. Local educational agencies (LEAs), institutions, and sponsors determine eligibility by comparing the data reported by the child’s household to published income eligibility guidelines. Child Nutrition Program claim forms should be supported by documentation showing the number of meals for which reimbursement was requested and document that the meals were served prior to the date of the reimbursement request. The claim reports should be filed on a timely basis. Corrective Action: The District will implement review procedures as part of the meal claim process to ensure claims reported match with District records. The District will ensure any over/under reporting is investigated and resolved in a timely manner. The District will review reports from FY24 and ensure any unclaimed meals are properly reconciled, as applicable. Planned completion date for corrective action plan: For the period ending June 30, 2025. Name of the contact person responsible for corrective action: Lori Wilson, Business Manager

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: Tom McFarland Contact Phone Number: 574-342-2255 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Following eligibility guidelines being entered into the food service software, a secondary reviewer will sign off that the data was entered accurately. Anticipated Completion Date: immediate (12/11/24)

The School District will implement monitoring control procedures to review software system eligibility determinations to ensure compliance with federal income guidelines. Anticipated Completion Date: 6/30/2025 Responsible Contact Person: Mara Powell

Condition: Pertaining to the Nutrition Cluster, there were 8 cases where the household size was larger than the number of household members listed in Step 1 and Step 3 on the free/reduced application. In 3 cases there was no change in the free/reduced status if the smaller number of household members were used. In 5 cases there were changes in the status. There was an additional case where the listed income put the family in the reduced status but they were listed as free. Recommendation: We recommend reviewing applications to ensure that the household size and the listed household members in Step 1 and Step 3 match. Management Response: The Food Service Department will implement a triple check process to ensure that all household data matches and the appropriate criteria is being used to calculate household eligibility. Anticipated Date of Completion: June 30, 2025

Nutrition Services staff process will run as follows: 1. NS Kitchen Staff: Ensure accurate daily meal count recording and initial review. 2. Intermediate Account Clerk: Perform detailed reconciliations and edit checks. 3. NS Account Technician: Reviews and verifies the final reports for compliance. This process will be overseen by the Director and or Assistant Director, Nutrition Services. This procedure will allow for accurate recording, reporting and verifying of meal counts.

November 4, 2024 School District No. 55-0145, Waverly, Nebraska, respectfully submits the following corrective action plan for the year ended August 31, 2024. Name and address of independent public accounting firm: Romans, Wiemer & Associates, Certified Public Accountants, P.C., 1910 N Lincoln Ave, York, NE 68467 Audit Period: September 1, 2023 through August 31, 2024 The findings from the November 4, 2024 schedule of findings and questioned cost are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS – FINANCIAL STATEMENT AUDIT MATERIAL WEAKNESS 2024-001 Internal Control Structure Design Recommendation: While considering the cost of any benefits derived, activities should be segregated and handled by different employees. Action Taken: The cost of implementing a complete set of controls far outweighs the benefits derived by such. It is not financially feasible to have a complete set of controls. COMPLIANCE 2024-002 Deposit Risk Recommendation: Obtain adequate pledged securities from the financial institution. Action Taken: District personnel will contact the bank about getting additional coverage. 2024-003 Disbursements in Excess of Budget Recommendation: Either not approve disbursements over budgeted amounts or amend the budget if extra disbursements are needed. Action Taken: The District will monitor funds closer and either not approve disbursements over budgeted amounts or amend the budget if needed in the future. FINDINGS – FEDERAL AWARD PROGRAM AUDIT Nebraska Department of Education 2024-004 Internal Control Structure Design Recommendation: While considering the cost of any benefits derived, activities should be segregated and handled by different employees. Action Taken: The cost of implementing a complete set of controls far outweighs the benefits derived by such. It is not financially feasible to have a complete set of controls. If the Nebraska Department of Education has questions regarding this plan, please call Mikal Shalikow at (402) 786-2321. Sincerely yours, Name Title School District No. 55-0145, of Waverly, Nebraska

U.S. Department of Education Clinton School District #124 respectfully submits the following Corrective Action Plan for the year ended June 30, 2024. Contact information for the individual responsible for the corrective action: Daniel Brungardt, Superintendent Clinton School District #124 Independent Public Accounting Firm: Gerding, Korte & Chitwood, P.C., 723 Main Street, Boonville, MO 65233 Audit Period: Year ended June 30, 2024 The findings from the June 30, 2024, Schedule of Findings and Questioned Costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Significant Deficiency 2024-001 Child Nutrition Cluster Recommendation: We recommend that fund balances should be monitored to ensure that balances remain in line with child nutrition compliance requirements. Action Taken: Over the last five years, the school district's fund increased due to securing a contract at a low initial rate, while also benefiting from higher reimbursement rates and increased participation. This year, the district will once again go through the rebid process, and the estimated increase in costs is expected to range from 10% to 15%. This increase will likely surpass the amount the district receives in reimbursements, leading to a budget deficit. Additionally, student participation in the lunch program has declined over the years.

Below are the participation percentage rates. Current Participation Rates for Oct 2024 (percentages) HS - 52.53 lunch with 56.38 being free/reduced 36.64 breakfast with 62.5 being free/reduced MS- 66.94 lunch with 62 being free/reduced 23.42 breakfast with 82.85 being free/reduced CIS - 65.48 lunch with 73.70 being free/reduced 44.38 breakfast with 78.07 being free/reduced HE - 70.41 lunch with 74.53 being free/reduced 47.93 breakfast with 76.72 being free/reduced Participation Rates from Oct 2019 (percentages) HS - 59.03 lunch with 52.65 being free/reduced 32.23 breakfast with 69.64 being free/reduced MS- 69.74 lunch with 68.01 being free/reduced 55.13 breakfast with 72.28 being free/reduced CIS - 77.87 lunch with 72.29 being free/reduced 44.54 breakfast with 83.43 being free/reduced HE - 76.88 lunch with 71.27 being free/reduced         45.09 breakfast with 84 being free/reduced Additionally, during the rebid process, the school district will seek companies that have successfully increased participation, as this could also impact the overall cost of the program. The district will reduce the fund based on the following: Increased Contract Costs: District administration believes that through the rebid process and the new contract, the district will achieve at least a 10% reduction in contract costs. Indirect Costs: The school district has not been claiming indirect costs as part of its food service allocation in the past. However, beginning next year, the district will start including indirect costs in its food service budget. This change will help ensure that the full scope of expenses associated with operating the food service program is accounted for, providing a more accurate reflection of the program’s financial needs New Equipment: The district operates four kitchens, with only one having received upgrades in the past 10 years. A list of necessary equipment upgrades has been compiled. Below is a forecast of additional costs for the next three years, along with the equipment that will be purchased that will reduce the food service budget by $940.874.48

Completion Date: June 30, 2025 Sincerely, Daniel Brungardt, Superintendent Clinton School District #124

Finding Number: 2024-001 Prior Year Finding: No Federal Agency: US Department of Education Federal Program: Child Nutrition Cluster Assistance Listing Number: 10.553/10.555/10.559 Pass-Through Entity: Maryland State Department of Education Pass-Through Award Number and Period: N/A (7/01/23 – 6/30/24) Compliance Requirement: Procurement Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Recommendation We recommend that the Carroll County Board of Education enhance its internal control procedures to ensure adherence to its procurement policy. This includes establishing a clear and consistently enforced process whereby all contracts over $25,000 are submitted for board approval prior to execution. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Food Services will review annual contracts in July to determine if the total contract value of any new contracts exceeds $25,000. Such contracts will be monitored and submitted to the BOE for approval as required. Name(s) of the contact person(s) responsible for corrective action: Karen Sarno, Supervisor of Food Services Planned completion date for corrective action plan: For immediate implementation and ongoing.

Segregation of Duties – Child Nutrition Cluster Recommendation: We recommend the district designate an individual to review eligibility determinations for accuracy and proper input into software. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: To enhance segregation of duties, we have designated a specific individual (Director of Food Services) responsible for reviewing eligibility determinations. This designated person is tasked with verifying the accuracy of information and ensuring proper input into the relevant software. These measures effectively separate key responsibilities, establishing a robust system of checks and balances. Through these implemented practices, our district aims to minimize errors, enhance accountability, and ensure the integrity of the grant management process. Name of the contact person responsible for correction action: Lavesa Glover-Verhagen Planned completion date for corrective action: June 30, 2025

Finding Type: Compliance and Material Weakness. Name of Contact Person: Brett Detering, Superintendent. Recommendation: We recommend the District follow the USDA guidelines for verification testing and income eligibility guidelines when making eligibility determinations of free and reduced breakfasts and lunches and maintain all supporting documentation for the required verifications. Corrective Action: We will ensure the Food Service Director is completing the Processes accurately and timely going forward and maintaining all documentation.

The prior Director of Nutrition Services contracted with a third party in order to collect the eligibility forms and automate the data input in our SIS system. The District will no longer use that third party, and the District has moved to a Provision 2 status, which no longer requires the collection of meal application forms. Alternative Income forms collected in the future will be clerked by the office managers at the school sites, and double checked by the Student Data specialist prior to interim auditing each year.

The District will create a procedure for monthly review of meal counts at sites and reconciliation with the monthly claims. Reports will require a second person to review and approve before filing. The Director of Nutrition Services will review the Title 7 requirements and review the new procedure for compliance.

U.S. Department of Agriculture Summer Food Service Program - Child Nutrition Cluster Assistance Listing Numbers: 10.559 Recommendation: While the program did perform the monthly FNS418 reporting, we recommend the program ensure follow-through with the FFATA reporting requirement by entering the data collected from the subrecipients into the FSRF portal. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: At the time of audit completion, the relevant FFATA information from the Food and Nutrition Bureau was submitted to the Grant Manager for proper reporting, ensuring compliance for FY2025. To support this process, Legal will collaborate with the program to ensure that award letters accurately identify the awardee. Additionally, the CFO conducted Federal Grant Management training in May 2024, which included FFATA documentation and reporting, along with an overview of ECECD’s final policies and procedures for Grant Management. The CFO and ASD will continue to update training materials to maintain compliance moving forward. Name(s) of the contact person(s) responsible for corrective action: Carmel Pacheco-Aragon, Chief Financial Officer; Valerie Garcia, Budget Director; Amanda Carlisle, Grants Manager; ECECD Program Managers. Planned completion date for corrective action plan: The CFO has already implemented some of the review processes in collaboration with the Budget Director, Grant Management team, and relevant programs. The remaining processes will be addressed and fully implemented by June 30, 2025. If the U.S. Department of Agriculture has questions regarding this plan, please contact: Carmel Pacheco-Aragon Chief Financial Officer New Mexico Early Childhood Education & Care Department 1120 Paseo de Peralta Santa Fe, NM 87501 Phone: (505) 901-8226 Carmel.Pacheco1@ececd.nm.gov

All electronic free and reduced meal applications are completed by parents/guardians in PaySchools. Since PaySchools does not currently have a SOC1 for Ohio, all applications will be sent to a pending folder. Aramark will ensure all applications are reported correctly in the PaySchools system. They began this process 11/25/2024. Because this process started mid-year, Treasurer Office personnel will review all of the approved applications prior to 11/25/2024.

Finding Number: 2024-002 – Approval of Payroll Expense Transactions Corrective Action Plan: A process was put in place in January 2024 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grants submitted until proper approval is received. Personnel Responsible for Corrective Action: Nachum Golodner, Academica Director of Accounting Anticipated Completion Date: June 30, 2025

Finding 2024-003 – Child Nutrition Cluster - Reporting Context: During the testing of claim reimbursements, we noted two monthly reimbursements in a sample of four claims where the number of meals claimed for reimbursement did not agree to underlying meal system reports. For one claim reimbursement, there was an overstatement of $9,976 and on another an understatement of $1,467. This resulted in a net over reimbursement $8,509 in the testing sample. Contact Person Responsible for Corrective Action: Leslie Beach, Director of Food Services Contact Phone Number: 812-542-2245 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: A new person has been hired in this position. A manager will review claim reimbursements. Anticipated Completion Date: Immediate correction.

Finding 2024-002 – Child Nutrition Cluster – Procurement Context: For one of 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. The sample item amount disbursed was $69,649 in FY23 and $110,313 in FY24 for food service technology support. The School Corporation did properly perform a suspension and debarment check on the vendor. Contact Person Responsible for Corrective Action: Leslie Beach, Director of Food Services Contact Phone Number: 812-542-2245 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: An RFP will be conducted for the technology support. Anticipated Completion Date: Summer 2025

Finding 2024-001 – Child Nutrition Cluster – Eligibility 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. Contact Person Responsible for Corrective Action: Leslie Beach, Director of Food Services Contact Phone Number: 812-542-2245 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: A manager will review eligibility determination and guidelines moving forward. Anticipated Completion Date: Immediate correction.

Management Response/Corrective Action Plan: The Administrative Assistant to the School Nutrition Director should be reviewing those claims monthly as well. The School Nutrition Director has begun showing the Business Manager claims and that process, and if this continues to be an issue, the Business Manager will also review these claims to ensure accuracy.

Recommendation: There were inadequate controls over documentation of the number of students receiving snacks that are claimed for reimbursement. Supporting documentation relating to snacks is not being properly maintained. The School Board should implement policies and procedures to ensure that supporting documentation is maintained for all snacks served. Corrective Action Plan: The child nutrition department will attempt to remedy this type of issue by recording the snack meals electronically by utilizing our existing system. The supervisor of child nutrition will determine how to implement this function.

Recommendation: There were inadequate controls over documentation of the number of students receiving snacks that are claimed for reimbursement. Supporting documentation relating to snacks is not being properly maintained. The School Board should implement policies and procedures to ensure that supporting documentation is maintained for all snacks served. Corrective Action Plan: The child nutrition department will attempt to remedy this type of issue by recording the snack meals electronically by utilizing our existing system. The supervisor of child nutrition will determine how to implement this function.