Corrective Action Plans

The District will improve internal controls by incorporating the involvement of a grant manager who is knowledgeable of grant requirements to approve expenditures.

The District will improve internal controls by incorporating the involvement of a grant manager who is knowledgeable of grant requirements to approve expenditures.

To Whom it may concern: This document serves as the response to the 2023-2024 Financial Audit on behalf of BELIEVE Schools, Inc. We’ve identified and addressed the comments that were included in the Uniform Guidance Major Program Findings. Please review the corrective action items in response to the Audit Results and Comments: Education Stabilization Fund (ESSER Grant): The school was unable to provide construction contracts to allow auditors to verify that the required Davis-Bacon Act wording was included. ● The Principal, Angel Jackson-Anderson, and Dean of Operations, Kayla Marshall, will ensure that the proper contracts are received and filed for all services conducted under ESSER grants. Child Nutrition: The school did not maintain tally sheets to support the number of meals served. ● The Dean of Operations, Kayla Marshall, will ensure that the proper physical files (tally sheets) are maintained and filed monthly, both in digital and paper form. The principal will review these files monthly to ensure documents are not lost or misplaced. If you have any questions, concerns, or comments, please feel free to contact me the school principal, Angel Jackson-Anderson, Aanderson@believeschools.org. Many thanks, Angel Jackson-Anderson Principal, BELIEVE Circle City High School Kayla Marshall Dean of Operations, BELIEVE Circle City High School www.believeschools.org @believeschoolsindy admin@believeschools.org 317-296-1954 Angel Jackson-Anderson 11/07/2024 02:25PM UTC

A. Revise and Strengthen Processes 1. New Software Implementation: o Replace the previous software program with a more reliable system. 2. Process Realignment: o Redefine staff roles to ensure clear responsibilities for eligibility determinations and reviews. B. Establish and Strengthen Internal Controls 1. Eligibility Review: o DeAnn Gould, Federal Programs & Grants Coordinator, and Howard Carpenter, Director of Operations, will oversee eligibility determinations using the updated software and Attachment A for reference. o Conduct a second review of all applications to verify accuracy and compliance with eligibility criteria. 2. Regular Edit Checks: o Implement weekly edit checks in the Point of Service (POS) system to confirm correct benefits distribution. C. Staff Training 1. Regular Food and Nutrition Services (FNS) Training: o Conduct quarterly training sessions on eligibility criteria, compliance requirements, and internal control processes. o Include hands-on training for using the new software and reviewing Attachment A criteria. 2. Compliance Assessments: o Assess staff understanding post-training to identify additional support needs. D. Monitoring and Evaluation 1. Audit Schedule: o Conduct monthly internal audits to evaluate compliance and report findings to leadership. 2. Performance Metrics: o Track error rates in eligibility determinations and aim for a significant reduction by June 30, 2025. E. Addressing Questioned Costs 1. Reconciliation Plan: The Missouri Department of Elementary and Secondary Education (DESE) has informed the School that the questioned costs of $20,578.74 will be withheld from future Food Service payment requests. The School will work with DESE to ensure proper adjustments and compliance with this reconciliation plan. 2. Process Transparency: Documentation of the withholdings and their impact on future payments will be maintained and reviewed to confirm accurate reconciliation of the overclaimed amount.

Name of Contact Person Travis Sweeney, SFO Business Manager Corrective Action The Business Manager and/or Superintendent will verify the eligibility information for future Title I grants prior to submitting the annual application. District Business Manager, Travis Sweeney, will obtain documentation on an annual basis that the eligibility is true and correct and the information input into the application will match the information within the District's student information system (Infinite Campus). Proposed Completion Date Fiscal year ended June 30, 2025

Corrective Action Plan: The District will ensure applications are completed and eligibility correctly assessed. Contact Information: For additional information regarding this finding please contact Ryan Bandt, Director of Business Services, at 920-675-1044.

ACTION STEPS: Every effort will be made to ensure payments are made in a timely manner while getting board approval. In the event that an invoice is received after the monthly board meeting, the bill will be included on the next month's Bills Payable Report even if the payment has already been made. CONTACT PERSON: Dr. Lori James-Gross, Superintendent ANTICIPATED COMPLETION DATE: September 1, 2024

2024-007 – Child Nutrition Cluster – Eligibility - The District is aware of the missing eligibility documents for the Child Nutrition program and will implement new procedures and a plan to reduce the missing documentation. Responsible Officials – Joe Dawidziak, Superintendent Anticipated Completion Date – The District will correct this in the subsequent fiscal year.

Findings #2024-003 and #2024-006 – Significant Deficiency - Other. Federal programs: U. S. Department of Agriculture, Passed through Texas Department of Agriculture, 10.553/10.555, Child Nutrition Cluster, Contract #’s: 202323N109946, 202424N109946 and 236TX400N8903. U. S. Department of Education, Passed through Texas Education Agency, 84.010, Title I Grants to Local Educational Agencies, Contract #’s: 23610101108807 and 24610101108807, 84.367, Supporting Effective Instruction State Grants, Contract #’s: 23694501108807 and 24694501108807. Condition and context: During our testing of the payroll control reviews by the accounting, compensation, and benefits departments, we identified 1 of 40 payroll cycles tested was not reviewed by the compensation and benefits departments. The payroll cycle was reviewed by the accounting department. Recommendation: Reemphasize current policies and procedures to ensure proper review of the payroll by compensation and benefits departments, including subsequent review if out on holiday to ensure that errors are identified in a timely manner. Planned corrective action: IDEA requires review of each payroll by the Compensation and Benefits team without regard to school holidays. In fiscal year 2025, Payroll implemented the procedure requiring review from compensation and benefits immediately following a school holiday where payroll could not be approved in advance. Responsible officers: Sonya Wilson, VP of Accounting and James Dworkin, VP of Accounting (Interim). Estimated completion date: January 31, 2025.

Findings #2024-002 and #2024-005 – Significant Deficiency and Other Non-Compliance - Reporting. Federal programs: U. S. Department of Agriculture, Passed through Texas Department of Agriculture, 10.553/10.555, Child Nutrition Cluster, Contract #’s: 202323N109946, 202424N109946 and 236TX400N8903. U. S. Department of Education, Passed through Texas Education Agency, 84.010, Title I Grants to Local Educational Agencies, Contract #’s: 23610101108807 and 24610101108807, 84.367, Supporting Effective Instruction State Grants. Contract #’s: 23694501108807 and 24694501108807. Condition and context: During our testing of GAAP and FASRG coding, we identified 4 of 200 payroll transactions coded to the incorrect function code and 3 of 120 non-payroll transactions coded to the incorrect object code. Additionally, during our testing of non-payroll transactions, we identified 3 of 120 nonpayroll transactions coded to the incorrect fiscal year. Recommendation: Reemphasize current policies and procedures to ensure proper coding of disbursements based on the organization’s chart of accounts and FASRG codes. Planned corrective action: IDEA will provide FASRG training to all staff with purchasing and payroll coding authority to minimize coding errors. This training will be conducted from January to May 2025. Responsible officers: Sonya Wilson, VP of Accounting and James Dworkin, VP of Accounting (Interim). Estimated completion date: May 1, 2025.

Subject: Regarding Audit Finding 2024-003: Reporting (50000) Finding 2024-003: We agree with the auditor’s comments, and the following actions will be taken to ensure proper records are maintained and reconciled: 1. The District is working with the point-of-sale vendor to be able to add a separate afterschool snack meal schedule to our system to accurately record snacks served in real-time. This will replace hand-tallied counts and reduce the risk of mathematical errors 2. Staff will conduct daily reconciliation of snack counts in the point of sale system to ensure accuracy 3. Monthly audits will be performed in against claim forms in advance of reimbursement claims tha tare submitted to the California Department of Education 4. The point-of-sale system will support the District’s ability to maintain accurate records and reconciliations for compliance purposes. The above steps will be implemented by April 2025 and the District maintains that it will continue the actions above to follow Child and Adult Care Food Program, Child Nutrition Cluster guidelines.

Nutrition Cluster – CFDA Nos. 10.553 and 10.555 Significant Deficiency in Internal Controls over Compliance: See Find-ing 2024-001

Nutrition Cluster – CFDA Nos. 10.553 and 10.555 Name of contact person – Kimberly Russian, Business Manager Recommendation: We recommend the Food Service Director more closely review all meal count information entered for reimbursement pri-or to submitting each monthly claim to ensure accuracy and consistency with supporting documentation. We recommend that the Food Service Director review all monthly claims filed in fiscal year 2024-25 that are available for revisions, to ensure reports were accurately filed. Further, we recommend that District management periodically monitor claim submissions for accuracy. Action Taken: Management agrees with the recommendations. The Food Service Director has reviewed all monthly claims submitted in school year 2024-25 and found no errors requiring revision. Further, management will implement a plan to periodically review claim submis-sions for accuracy. Proposed Completion Date: January 31, 2025

Child Nutrition Cluster – Assistance Listing No. 10.553, 10.555, 10.559 Recommendation: Auditor recommends the District review its procurement process to ensure that there is adequate segregation of duties in regards to initiating, authorizing, reviewing for grant allowability and approving micro purchases, along with adding controls to ensure that the item purchased was received by the District. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We continue to look for ways to segregate duties and will improve on the review process for micro purchases but with the current financial situation, additional staff cannot be added. Name(s) of the contact person(s) responsible for corrective action: Lisa Miller Planned completion date for corrective action plan: Ongoing. If the oversight agencies have questions regarding this plan, please call Lisa Miller at 715-887-9000.

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.

2024-001 - Nonmaterial Noncompliance - Eligibility Program: Child Nutrition Cluster (ALN 10.553 and 10.555) - United States Department of Agriculture; Federal Award Year: 2024 Responsible Officials: John Wack, Chief Financial Officer, Henrico County Public Schools Planned Corrective Action: School Nutrition Services Leadership has put a new process in place, to run a report from the point-of-sale system weekly, that will catch any "Manual" updates to lunch statuses. This report will be run weekly and verified by either the Dietitian or Controller. The report will be initialized and kept on file. Expected Completion Date: 12/31/24

Condition: The School District is required to account for all revenues and expenditures of its non-profit school food service account in accordance with state and federal requirements. In order to ensure that federal reimbursement payments received monthly from the Michigan Department of Education are correctly credited to the school food service account, monthly bank reconciliations should be prepared and reviewed by individuals with requisite skill and experience. During the 2024 fiscal year, bank reconciliations and monthly reconciliations of food service revenues and expenditures of the school food service account were not being prepared and reviewed in a timely manner. As there was an unexpected reduction in staff resources in the business office, there were not adequate resources to perform these accounting reconciliations on a timely regular basis during the year. The absence of these timely regular reviews could lead to undiscovered errors in the school food service account and material noncompliance with federal regulations. Planned Corrective Action: The School District agrees that its internal control structure should ensure that accounting reconciliations are prepared and reviewed in a timely manner during the year. Although the School District had an intergovernmental Agreement with its Intermediate School District to provide business services, such services could not be rendered due to inability to find staffing. Near the end of the 2024 fiscal year, a Finance Director was directly hired into the business office. Monthly reconciliations of accounting records and closing of monthly books are now being performed and reviewed on a timely basis. Contact person responsible for corrective action: David Bergeron, Assistant Superintendent Anticipated Completion Date: July 1, 2024

Condition: The School District must submit monthly claims for reimbursement for meals served to eligible students within 60 days following the last day of the month covered by the claim (7 CFR sections 210.8, 220.11, 215.10, and 225.15 (c)). Upon preparation of meal reimbursement claims, the School District is required to have controls in place to ensure the accuracy of the request for reimbursement. The School District did not have a documented review process in place over the reimbursement requests. Meal counts entered into the Michigan Nutrition Data (MIND) system took place without a secondary review, which could result in incorrect reporting of the number of meals. The preparation of the request without a secondary review could result in incorrect reporting of the number of free and reduced priced meals, which could result in the School District being reimbursed an incorrect amount by the Michigan Department of Education. Planned Corrective Action: The School District's business office performed a detailed review of all meal claim submissions for the 2023-2024 fiscal year. Claims were accurately completed as was the amount of reimbursement paid by the Michigan Department of Education. The business office has since implemented a formalized internal control procedure beginning in July 2024, whereby a formal documented review of the meal claim submission is performed. Contact person responsible for corrective action: David Bergeron, Assistant Superintendent Anticipated Completion Date: July 1, 2024

Response and Corrective Action Plan: The District will annually prepare the indirect cost charged to the program based on the actual fiscal year trial balance. The District will provide an estimate to the Board each June to ensure proper approval of fund transfers.

Corrective Action Plan: The District established written procedures to ensure that we are using current eligibility verification through our Skyward Food Service Program. Anticipated Corrective Action Plan Completion Date: June 27, 2024 Contact Information: For additional information regarding this finding please contact Bill Trewyn, Business Manager, at 262-741-9143.

Finding 2024-001 Child 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 Academy will evaluate current procedures for accurately monitoring, recording, and reporting the number and type of meals served. 3. Official Responsible Jennifer Geraghty, Superintendent/Principal, is the official responsible for ensuring corrective action. 4. Planned Completion Date June 30, 2025. 5. Plan to Monitor Completion The Board of Directors will be monitoring this Corrective Action Plan.

Finding 2024-001 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 Academy will evaluate current procedures for accurately monitoring, recording, and reporting the number and type of meals served. 3. Official Responsible Thomas Thao, Executive Director, is the official responsible for ensuring corrective action. 4. Planned Completion Date June 30, 2025. 5. Plan to Monitor Completion The School Board will be monitoring this Corrective Action Plan.

To Whom It May Concern, Please accept this letter as a formal Corrective Action Plan for the district regarding the audit finding 2024-003, as listed in the FY 2024 Audit. During the 2024-2025 school year either a free and reduced application was misplaced/lost or the district incorrectly qualified the household children of a foster residence to be automatically qualified for free meals as is done with homeless households. Regardless, the district will take the following corrective actions to address the issue in the future: 1. The district has already begun using an electronic lunch application process through the new Student Information System, which should address the issue moving forward. This started with enrollment in the Fall of 2024. AND 2. The superintendent will review the qualification requirements with all staff members that are involved with the free and reduced lunch application process, as well as the district foster care liaison. The person responsible to provide this training will be the superintendent and the training will be completed by December 21, 2024. Sincerely, John French Superintendent of Schools Lewis County C-1 School District

Child Nutrition Cluster - Assistance Listing Nos. 10.553, 10.555, 10.559 Recommendation: We recommend the District review their controls and procedures surrounding procurement to ensure their purchasing policy is followed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The District will review the Sole Soure form on an annual basis to make sure the form has not expired. Name(s) of the contact person(s) responsible for corrective action: Debrah Jones, Director of Strategic Sourcing and Contract Management (SSCM) Planned completion date for corrective action plan: 12/31/2024

Finding 2024-004 Reporting – Child Nutrition Cluster Material Weakness in Internal Control Over Compliance Finding Summary: The District does not have an internal control system designed to review and ensure submitted free and reduced meal counts agree to underlying records. Responsible Individuals: Shannon Hunstad, Superintendent Corrective Action Plan: The District will review and strengthen the controls surrounding the review and submission of free and reduced meal counts to ensure they are supported and accurate. Anticipated Completion Date: June 30, 2025