Corrective Action Plans

Finding 2024-004 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 will evaluate current procedures for accurately monitoring, recording, and reporting the number and type of meals served. 3. Official Responsible Mr. Michael Malmberg, Superintendent, 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 Number: 2024-002 Finding Synopsis: The District submitted a claim for meals higher than the count actually served for the month due to a clerical error. The District did not have someone, other than the preparer of the monthly claim, review the claim before it was submitted to ensure its accuracy. Action Steps: Management plans to implement a review process to ensure the claim forms are filled out correctly. Contact Person: Jeffrey Schubert Chief School Business Official 779-244-1000 Anticipated Completion Date: 6/30/2025

Finding Number: 2024-001 Finding Synopsis: In the population of 40 applications selected for testing, an exception was noted on 1 of the applications. This exception stemmed from the "pay frequency" section of the application, where the person filling out the application left this section blank, thereby creating an issue where it was not possible to calculate the household's annual income. However, the District still approved the application for free status. The District noted that the frequency was confirmed verbally, however failed to obtain physical documentation. It does appear, however, that the student was appropriately classified as free status. Action Steps: Management plans to implement procedures to ensure applications are appropriately reviewed for completeness before approving. Contact Person: Jeffrey Schubert Chief School Business Official 779-244-1000 Anticipated Completion Date: 6/30/2025

2024-003 – Eligibility. Auditor Description of Condition and Effect. In our sample of 40 applications from all students receiving free or reduced cost meals during the year, we noted one instance in which the point of sale (POS) system used by the District classified a student to be free, however, application reviewed by the District indicated ineligible to receive free and reduce meal. The student received free-price meals during the 2024 school year. As a result of this condition, the District granted free lunch to a student that did not meet the eligibility requirements. Auditor Recommendation. The district should perform a review of the POS system to match with the application to ensure only eligible students are provided with free and reduced meal. Responsible Person: Scott Leach, Superintendent and Crystal Lee, Food Service Director.Corrective Action. Management concurs with the finding. The district has already put in multiple checks and procedures for food service. The Point of Sale now has custom reports to help make sure students are in the Point-of-Sale system correctly. The Eligibility listing will be verified multiple times throughout the year. The district has set up weekly meetings with the Food Service Director, Superintendent Administrative Assistant, and the Business Manager. Anticipated Completion Date: June 30, 2025.

Finding 2024-004 - Material Weakness and Material Noncompliance: Eligibility and Reimbursement Request for Child and Adult Care Food Program Corrective Action: The District will collaborate with MDE Nutrition staff to complete training, staff assistance visits, and previously established corrective actions. The Business Director and Food Service Director will schedule additional training and visits with Nutrition liaisons and MDE PAL partners. The District will implement electronic point-of-sale devices and digital filing systems to improve recordkeeping and sharing. Documented training for YCS Food Service Staff will be ongoing. District monitoring will be reinstated to ensure compliance with pre-COVID standards. Responsible Person: Director of Finance and Food Service Director

Finding 2024-002 - Material Weakness: Budget Violations Corrective Action: The Finance Director and Business Office will undergo additional training with Tyler Technologies, Michigan School Business Officials and others to optimize financial processes and transaction processing. The team will adhere to the state business calendar for timely reconciliations, budget amendments, and internal control reviews. Responsible Person: Director of Finance

Finding 2024-004 – Child Nutrition Cluster – Special Tests and Provisions – Paid Lunch Equity Contact Person Responsible for Corrective Action: Marsha Bohannon, Controller Contact Phone Number: (317) 867-8000 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The food service director will complete the Paid Lunch Equity spreadsheet, provide the spreadsheet and all supporting documents to the controller for review. Once approved, it will be submitted to the Indiana Department of Education. The supporting documents will either be scanned in or paper documents will be retained for future audit. Anticipated Completion Date: November 19, 2024

Finding 2024-003 – Child Nutrition Cluster – Procurement Contact Person Responsible for Corrective Action: Marsha Bohannon, Controller Contact Phone Number: (317) 867-8000 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We will contact our educational service center and see if they are able to either do an RFI or RFP for food service equipment maintenance or we will otherwise request three quotes for small purchases. We are currently under a contract with SmartCare for food service equipment maintenance until the end of this current school year. Anticipated Completion Date: July 1, 2025

Finding 2024-002 – Child Nutrition Cluster – Reporting Contact Person Responsible for Corrective Action: Marsha Bohannon, Controller Contact Phone Number: (317) 867-8000 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The food service director will pull the End of Day Summary Reports from Lunchtime and input the information into the Child Nutrition Portal. All reports will be provided to the controller to confirm accuracy. Once reviewed and approved, the food service director will submit the report through the Child Nutrition Portal. All documents will be scanned together and be retained for audit. Anticipated Completion Date: October 2, 2024

Finding 2024-001 – Child Nutrition Cluster – Eligibility Contact Person Responsible for Corrective Action: Marsha Bohannon, Controller Contact Phone Number: (317) 867-8000 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: School corporation personnel will conduct an annual review of the income eligibility guidelines used by the food service software. The review will ensure that the guidelines are current, accurate, and consistent with federal and state requirements. The results of the review will be documented, and any necessary updates or changes will be implemented promptly. Anticipated Completion Date: November 13, 2024

To allocate direct cafeteria overhead costs and plan capital equipment purchases for cafeteria equipment to enhance delivery of student meals which will ensure reduction of net cash resources so as to not exceed three months of expenditures. In addition to the current mechanisms in place to utilize net cash resources, a formula was obtained and will be used to ensure the correct amount is spent. During the 23-24 school year, the district received additional covid related funding which also contributed to excess net cash resources.

Condition: There was no termination clause noted in the Aramark contract stating whereby either party may cancel for cause with 60-day notification as required by 7 CFR 210.16(d) and 7 CFR 220.7(d)(4). Plan: The Aramark contract will be updated to include the proper termination clause stating whereby either party may cancel for cause with 60-day notification. Anticipated Date of Completion: June 30, 2025 Name of Contact Person: Dr. Joel Hackney, Superintendent Management's Response: Management will ensure the Aramark contract has been updated with the proper termination clause before signing another contract.

Corrective Action Plan: The School District has begun taking action to address this issue, as follows: Equipment Improvement - School Food Service Director, Joe Kilmer, Food Service Manager, Ann Overhiser, and the School Business Administrator have plans to improve and replace cafeteria equipment. The replacement plan will be completed in conjunction with the School District’s upcoming Capital Project. This work was originally expected to be included in a prior project but due to scheduling issues, is now included in the upcoming project which is expected to be completed by August 31, 2026. Retained Balance for Pending Settlements - Wages will increase into 2025 and beyond. The minimum wage in New York State is expected to continue to rise according to legislation. The rate will rise to $15.50 per hour by the end of 2024 and to $16.00 per hour by the end of 2025. Annual increases will be published by the Commissioner of Labor and based on a number of economic factors. Due to the critical labor shortage, the School District recently increased hourly wages for food service helpers and cooks in order to attract additional workers to maintain operations. Enhanced Meals - The Food Service Director and Food Service Manager continue to take steps to improve food options. They include making improvements to center of the plate options and improving local food options as well. In addition, the School District plans to spend a portion of the School Lunch excess cash on cafeteria equipment as a part of its upcoming Capital Project which is expected to be completed by August 31, 2026. Anticipated Correction Date: August 31, 2026 Contact Information: Lisa Kuhnel Shared School Business Administrator Odessa - Montour Central School District 300 College Avenue Odessa, New York 14869

The Board of Trustees has designated the responsibility of overseeing the accounting and financial reporting to the District’s superintendent, Jeff Byrd. See the District’s responses to this finding in the letter provided by the District on page 103. Finding 2024-002 - Significant Deficiency - Verification of Eligibility for Free or Reduced Price Meals The District has reviewed the findings and identified areas of improvement for Child Nutrition. The district will audit the Child Nutrition information after verification each year to ensure that the correct changes have been made in the software. Internal Controls will be reviewed and strengthened to ensure proper coding moving forward.

The District Corrective Action Plan is to follow the corrective action plan set forth in the site review by the State of Alaska Child Nutrition Program to have intense staff meetings with cooks and meal counters to make sure point of service meal counts in the cafeteria or in the classroom are clear and accurate for reporting. School sites visits, discuss counting at point of service, claiming, reimbursable meals, production records, ordering, safety and hygiene. Attend monthly zoom with School Meals Program (Dept. of Education).

Condition: During our review of Food Service funds, we noted that the numbers of meals served was less than the amount that was submitted for reimbursement. Criteria: When a recipient of federal food service money goes to submit for reimbursement, the amount of meals that are served should match up with the reporting out of the recipients system to ensure proper reimbursement is taking place. Cause: The Food service department did not have a proper reconciliation practices to ensure accurate reporting Effect: Funds may be overdrawn. Perspective: The majority of the buildings were accurate as we found during testing, with high turnover in the space training may not have taken place. Recommendation: We recommend training of all food service recording staff as well as the Director of Food service understand that the reimbursement of meals report should match the meals served reporting that documents each day of the meals served. It should also be noted that the meals served documents needs to have oversight to ensure those reports are accurate on a daily basis. Views of Responsible Officials and Planned Corrective Actions: Haven USD 312 staff involved are undergoing training to learn requirements. Processes and procedures are being developed to ensure proper record keeping and reporting.

2024-001 – Payments to Vendors Corrective Action Plan: The School District is committed to following policy and producing the most accurate financial data possible. Once this error was identified, management quickly investigated the cause and has worked to resolve the problem. The vendor has subsequently issued a credit to the district’s account. Management has and will continue to review and train with staff on proper internal controls to prevent or lessen the possibility of error in the future. Responsible Party(ies): Assistant Superintendent Anticipated Date of Completion: November 30, 2024

Finding: 2024-004 Eligibility Federal agency: U.S. Department of Agriculture Federal program Title: Child Nutrition Cluster Federal Assistance Listing Number: 10.553 and 10.555 Federal Award Identification Number and Year: 212MN061N1199- 2024 Pass-Through Agency: Minnesota Department of Education Pass-Through Number(s): 1-213-000 Award Period: June 30, 2024 Type of Finding: Significant Deficiency in Internal Control Over Compliance Recommendation: We recommend that District management and financial personnel have internal controls designed to ensure proper documentation of eligibility for Child Nutrition. Views of Responsible Officials: There is no disagreement with the audit finding. Action Taken in Response to Finding: The District will continue to work at ensuring there is a second person to review applications. Name of the Contact Person Responsible for Corrective Action Plan: Justin Dahlheimer, Superintendent Planned Completion Date for Corrective Action Plan: June 30, 2025

10.553, 10.555, 10.559 - Child Nutrition Cluster 2024-001 Net Cash Resources Corrective Action Plan: The School Lunch Fund continues to have excess fund balance on hand due to the additional reimbursements provided during the COVID-19 pandemic. The School District is currently reviewing the equipment used by the program and will create a plan to use these funds to support the program's infrastructure. Expected Completion Date: June 30, 2025 Contact: Jolean Bliss, School Business Executive Mexico Academy and Central School District 16 Fravor Road, Suite A Mexico, NY 13114 (315) 963-8400

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. For certain periods during the year the School District asserts there was a review process in place over the reimbursement requests; however, the review was not documented, and therefore we were not able to verify if the control was in place and operating effectively. For other periods during the year, the School District did not have a control in place where a review of the meal counts entered into the Michigan Nutrition Data (MiND) system takes place, which 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. Ultimately, the lack of a review control during the 2023-2024 fiscal year did not result in inaccurate reporting or incorrect 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: Kevin Taratuta, Chief Financial and Operations Officer Anticipated Completion Date: August 1, 2024

District responsible individual to implement this plan: Mike Klosowski, CFO The findings from the June 30, 2024 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the number assigned in the schedule. Finding – Federal Award Finding Finding 2024-001: Considered a significant deficiency in internal control over compliance. Recommendation: The District should perform annual on-site reviews of buildings where breakfast and lunch are served prior to February 1st each year as required by Michigan Department of Education. This should be documented by using the Michigan Department of Education’s School Nutrition Program On-Site Review Form. Action to be Taken: Management agrees with the finding and has implemented procedures to make sure the on-site reviews are completed annually by the due date.

Management will take the steps necessary to ensure matching requirements are met.

Action taken in response to finding: The employee responsible for eligibility processing and verification is new to the process. The employee attended all of the trainings provided by CDE prior to conducting verification. The employee misinterpreted “net wages” vs “gross wages” on the paystub, which led to this discrepancy. The household had listed net wages on their application this year and prior years. The student’s status was corrected and backdated to the verification response date. April and May 2024 claims are not affected by overpayment due to the student’s status having been updated before claims were sent to the state for payment. USDA disregards overpayment of reimbursement if the amount does not exceed $600 annually (Section 119c). Since the amount is not over $600, CDE is not required to collect the discrepancy. The District will move into 100% Community Eligibility Provision (CEP) for SY 2024-2025, and continuing for up to 5 consecutive years following enrollment into the provisional program. CEP does not require income application submittal, thus does not host an annual verification certification because data is received solely through Direct Certification reports provided by CDE monthly. Staff responsible for eligibility determination will continue to take the online trainings from CDE and our Nutrition Software annually as required. Name(s) of the contact person(s) responsible for corrective action: Kari Jacobs Planned completion date for corrective action plan: 5/2/2024

2CFR 200.510(b) requires organizations to prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements, which must include the total of federal awards as determined in accordance with 2 CFR 200.502. The original SEFA prepared by the School District was not complete and accurate. The School District will implement a procedure to ensure that accounting records are closed timely, internal accounts are reconciled, and appropriate workpapers are prepared to support SEFA balances. The School District will implement these procedures for the 2025 fiscal year end.

Charlton Heston Academy respectfully submits the following corrective action plan for the year ended June 30, 2024. Auditor: Maner Costerisan 2425 E. Grand River Avenue, Suite 1 Lansing, MI 48912 Audit Period Year ended June 30, 2024 Academy Contact Person: Frank Patterson, Chief Financial Officer Finding 2024-001 – Significant deficiency Recommendation: We recommend the Academy establish improved controls for preparing and reviewing year-end reconciliations. The Academy should ensure that reconciliations are completed in a timely manner and agree to the general ledger. Actions to be taken: The Academy concurs with the facts of this finding and are in the process of adding human capital/capacity, developing a revised formal timeline, and checklist of year-end procedures as recommended. Finding 2024-002 – Significant deficiency Recommendation: The Academy should consistently utilize a point-of-sale system to track and claim the number of meals served. Action to be Taken: The Academy concurs with the facts of this finding and has implemented procedures to prevent this in the future.