Corrective Action Plans

The Bethlehem Central School District appreciates the requirements of 2 CFR Section 200.213. The District's recent review of vendors indicated that there weren't any instances of ineligibility for participation in Federal assistance programs. To ensure formalized compliance, the District is updating procurement procedures which will highlight that the Purchasing Agent will check the SAMS Debarment and Suspension website on an annual basis. Results from this annual check will be logged and shared with both the Treasurer and Chief Business and Financial Officer and will be available for access by auditors or the public. Ineligible vendors, as noted on the SAMS website, will be removed from the District's financial management system. Implementation Date - Effective immediately.

The Elmira City School District has been cited for excessive net cash resources since the onset of the pandemic in 2021 and correlated increased aid reimbursements for the school feeding programs. The most notable increase to revenues for the 2023-2024 fiscal year was interest income. The districts interest revenues were 95% greater than the 2022-2023 school year. Overall revenues within the School Lunch fund only increased 4.69% over the 2022-2023 school year, while expenditures increased at 10.64%. As part of our 2022-2023 corrective action plan, a new contract was entered within our labor union for cafeteria workers. Those efforts resulted in a 37.48% expenditure increase in 2023-24 to salaries and benefits over the 2022-23 school year. The district also can demonstrate that we closed the gap between revenues and expenses by roughly 5% over the prior fiscal year. This is the result of increased spending on equipment purchases, food purchases and wages as so outlined in prior corrective action plans. Plans for the 2024-25 fiscal year include a projected budget that equates to over 22% spending over the 2023-24 expenditures. Those increases are mainly in our equipment and salary budgets. The district has plans to put out a new capital project to vote in December of 2024. While many building and facility upgrades are included, the district plans to utilize the school lunch fund for any equipment purchases related to our cafeterias within our facilities as so allowed. Our School Food Service Director, in conjunction with our School Lunch Manager will assist in the continued upgrades to school serving lines, and new initiatives within our serving programs in response to population changes and needs. They will also continue our equipment replacement cycle throughout our buildings to ensure outdated equipment is replaced timely. The School Business Official will work in conjunction with the Food Service Director and Manager to manage fund balance and expenditures throughout the year. In prior years fund balance has been appropriated to afford increased food and equipment expenses. To combat the net cash resources, we will first look to move funds within the existing budget to afford those increased expenses, oppose to moving monies from fund balance. Our plans, as so outlined above, are targeting a completion date of this finding in June 2025. Contact Information: Lindsey Tice School Business Official Elmira City School District 430 W. Washington Ave. Elmira, NY 14901 607-735-3054 Expected Correction Date: June 30, 2025

Condition: The Michigan Nutrition Data (MiND) system auto calculates the number of full-paid meals after the district enters the total number of meals. Therefore, if the number of total meals is typed incorrectly, the difference automatically adds or subtracts to the number of full-paid meals. The School District does not currently have a control for the secondary review and approval of the meal counts entered into the MiND system. This reporting risk could result in the School District inaccurately reporting meals for reimbursement. Planned Corrective Action: After initial claim submission, the Student Nutrition Director will provide the MiStar back up along with the claim summary to the District Accountant. The District Accountant will then review the claim for accuracy. If any issues are identified, the District Accountant will notify the Student Nutrition Director, who will then need to amend the claim. Any claim amendment will be submitted back to the District Accountant for review. Documentation of this review and the related reports will be maintained each month. Contact person responsible for corrective action: Rachel Bois, CFO Anticipated Completion Date: 11/1/2024

Condition: The Academy does not currently 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 Academy being reimbursed an incorrect amount by the Michigan Department of Education. Planned Corrective Action: The Academy will implement proper procedures and controls to ensure meal counts are reviewed and agree to underlying records of meals served prior to submitting meal claims. Contact person responsible for corrective action: Molly Brown Anticipated Completion Date: 12/01/2024

Condition: The Academy does not currently 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 Academy being reimbursed an incorrect amount by the Michigan Department of Education. Planned Corrective Action: The Academy will implement proper procedures and controls to ensure meal counts are reviewed and agree to underlying records of meals served prior to submitting meal claims. Contact person responsible for corrective action: Molly Brown Anticipated Completion Date: 12/01/2024

Condition: The Academy does not currently 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 Academy being reimbursed an incorrect amount by the Michigan Department of Education. Planned Corrective Action: The Academy will implement proper procedures and controls to ensure meal counts are reviewed and agree to underlying records of meals served prior to submitting meal claims. Contact person responsible for corrective action: Molly Brown Anticipated Completion Date: 12/01/2024

Condition: The Academy does not currently 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 Academy being reimbursed an incorrect amount by the Michigan Department of Education. Planned Corrective Action: The Academy will implement proper procedures and controls to ensure meal counts are reviewed and agree to underlying records of meals served prior to submitting meal claims. Contact person responsible for corrective action: Molly Brown Anticipated Completion Date: 12/01/2024

Condition: Certain account balances in the School District's books and records for the 2024 fiscal year were not reconciled and reviewed properly for accounts payable cutoff and, thus, an adjustment to the School District's general ledger was discussed with management during our audit process and recorded by management as a result. Planned Corrective Action: The School District agrees with the recommendation. The School District will implement procedures and controls to ensure year-end accruals and review of accounts payable cutoff are reconciled and agreed to underlying records. Contact person responsible for corrective action: Leslie Wagner, Assistant Superintendent of Finance and Operations Anticipated Completion Date: 12/31/2024

2024-002 - Meal Claim Reimbursement Noncompliance Auditor Description of Condition and Effect. One of three meal claim reimbursement reports selected for testing did not agree to underlying meal count sheets. On the one report that did not agree, the District understated claims for all of its facilities. As a result of this condition, the District submitted inaccurate claims for reimbursement, resulting in a reimbursement less than what the District should have received. Auditor recommendation. We recommend that the District implement a thorough review process of entered data prior to certification of claims data. We also recommend that a secondary review of claims data be done by a District finance department staff to ensure proper claims data. Corrective Action. The District will implement a thorough review process of entered data prior to certification of claims data. The District will also implement a secondary review of claims data that will be done by a District finance department staff to ensure proper claims data. Responsible Person. Michelle Bennin, Chief Financial Officer Anticipated Completion Date. June 30, 2025

Condition: At June 30, 2024, net cash resources in the School Lunch Fund exceeded the allowable limit of cash by $700,631. Corrective Action Plan: The School District is committed and will be diligent in preparing meals with high quality products. Regular cooked meals and expanded menu choices will be prepared which will result in an increase in expenses. There has been unpredictability with the increase of certain goods, and we expect this to continue into the 2024-2025 fiscal year as well. The School District also participates in the Community Eligibility Provision (CEP) which provides free breakfast and lunch to every student within the School District. Salaries for School Lunch employees have also been increasing year after year due to the increase of minimum wage in New York State as well as a new collective bargaining agreement that went into effect 7/1/2025. The minimum wage is expected to increase to $15.50 per hour. The School District does have a practice of transferring BOCES aid gained from the cost of the BOCES management contract to the School Lunch Fund; the aid will not be transferred in upcoming years. The School District has devised a NYSED approved plan to expend the excess funds in the School Lunch Fund through appropriating a substantial amount of fund balance to be planned for and used for the cafeteria and kitchen capital project. That capital project vote is scheduled for December 2024. If needed, we will examine other avenues to ensure we do not exceed the allowable limit of cash at year end. The School District anticipates resolving this finding by June 30, 2025.

Allegan Public Schools 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 District Contact Person: Amy Christman, Director of Finance and Operations Finding 2024-001: Considered a significant deficiency in internal control over compliance. Recommendation: The District should consistently utilize a point-of-sale system to track and claim the number of meals served. Action to be Taken: Management agrees with the finding and had already changed procedures during the school year to better track and claim meals.

This finding is due to the District not having the proper controls in place to prevent, detect, or correct incomplete applications and incorrect eligibility guideline thresholds for the Household Application for Free and Reduced Priced School Meals. This was the first full year for the District’s new Food Service Director, and she was unaware that the income level guidelines for eligibility were not already updated in Meal Magic at the start of the school year. The District is now aware that this is a manual change that needs to be made on an annual basis prior to the start of the next school year. The District is implementing additional procedures to ensure that applications are filled out completely and that the eligibility income thresholds are updated annually before any applications are processed. The persons responsible for the corrective action are Tamie Gillespie, the Food Service Director, and Dina Schmidt, the Business Manager. The anticipated completion date of the corrective action plan is immediate. The plan for monitoring adherence is the Food Service Director will ensure that eligibility income level guidelines are properly input each year and monitor each application to ensure they are complete.

Auditor Description of Condition and Effect. One of three meal claim reimbursement reports selected for testing did not agree to underlying meal count sheets. On the one report that did not agree, the District understated claims for all of its facilities. As a result of this condition, the District submitted inaccurate claims for reimbursement, resulting in a reimbursement less than what the District should have received. Auditor recommendation. We recommend that the District implement a thorough review process of entered data prior to certification of claims data. We also recommend that a secondary review of claims data be done by a District finance department staff to ensure proper claims data. Corrective Action. The District will implement a thorough review process of entered data prior to certification of claims data. The District will also implement a secondary review of claims data that will be done by a District finance department staff to ensure proper claims data. Responsible Person. Gail Enders, Finance Director Anticipated Completion Date. June 30, 2025

Auditor Description of Condition and Effect. Throughout the year journal entries were posted without independent approval. As a result of this condition, the District is exposed to an increased risk that misstatements or misappropriations might occur and not be detected by management in a timely manner. Auditor Recommendation. We recommend that the District's journal entries be independently reviewed, signed and dated, as evidence of this control. Corrective Action. The District will implement a new procedure to ensure each journal entry goes through a review process before being posted. Responsible Person. Gail Enders, Finance Director Anticipated Completion Date. June 30, 2025

October 11, 2024 10.553, 10.555, 10.559 - Child Nutrition Cluster 2024-001 Net Cash Resources Corrective Action Plan: The School District will review cafeteria operations throughout 2024-25 and ensure any excess funds will be used to provide additional support to the cafeteria program. The School District expects to alleviate this finding by June 30, 2025. Contact Information Michael Pavlovich, Director of Operations and Finance Chenango Forks Central School District 1 Gordon Drive Binghamton, New York 13901

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

Finding Number: 2024-001. Responsible Person:Daniel Kuk, Food Service Director. Management View: Management agrees with the finding and is in the process of implementing the recommendation. Corrective Action: The District has already changed its meal reimbursement process to use data from Meal Magic to submit the meal claim reports. Anticipated Completion Date: Immediate Implementation.

The District will review the requirements of 2 CFR Section 200.213 and ensure that procurement procedures are being followed and perform a review of the eligibility of potential vendors to ensure they are eligible to participate in Federal assistance programs.

2024-004 FINDING Contact Person – Dave Kerkvliet, Superintendent Corrective Action Plan – The District will begin reviewing and approving reports prior to submission for reimbursement. Completion Date – November 1, 2024

Corrective Action Plan School District management agrees with condition, cause, and recommendation. With this overage, the School District has purchased some new equipment for the cafeteria. Since the School District is CEP, there is no option to change the revenue. The School District will continue upgrading the kitchens with the excess. Expected Correction Date: June 30, 2025 Contact: Kathy Rote, School Business Administrator (607) 565-2841 15 Frederick St. Waverly, NY 14892

The Food Service Director will coordinate the on-site monitoring reviews and its completion to Michigan Department of Education standards, and make sure the required forms are completed before deadlines. Contact person responsible for corrective action: Darlene, Food Service Director Anticipated Completion Date: 02/01/2025

Corrective Action Plan: The District recognizes that due to increased reimbursement during the past few years, the District has an excess of cash on hand over the permitted levels. Over the course of the 2023-24 school year, the district reviewed the program’s needs to develop a strategy to utilize these funds by the food service program to coincide with the capital project approved by the voters in December of 2022. To date, the District has purchased and installed multiple equipment items by the Cafeteria Fund totaling over $189,000. Along with these purchases the district has ordered and is in the process of receiving and installing an additional $125,000 of equipment including new serving line stations. Estimated Completion Date: June 30, 2025 Contact Information Jennifer Dattoria, School Business Executive Susquehanna Valley Central School District 1040 Conklin Road Conklin, New York 13748

2024-003 Child Nutrition Cluster – Assistance Listing No. 10.CNC Recommendation: CLA recommends the District designate an individual to review student lunch statuses. Having an appropriate reviewer over student status is intended to prevent, detect, and correct a potential error in the food service system. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: Management will designate an individual to review student lunch statuses. Name of the contact person responsible for corrective action: Kathy Stankewicz, Business Manager Planned completion date for corrective action plan: June 30, 2025

Condition: The School District did not complete an on-site monitoring review for one building operating a school lunch program during the year ended June 30, 2024. Corrective Steps Taken: At this time, there have been some corrective steps taken to limit this from happening again which includes the Food Service Director better familiarizing herself with MDE’s requirements for on-site reviews. Corrective Steps to be Taken: The Food Service Director will coordinate the on-site monitoring reviews and its completion to Michigan Department of Education requirements. Monitoring: The plan for monitoring adherence is for the Superintendent to check in with he Food Service Director prior to the February 1st deadline to ensure all required on-site reviews were performed. Name of Responsible Person for Further Information: Tami Eisenga, Food Service Director and Scott Akom, Superintendent. Questioned Costs Related to this Finding: None.

Condition: The School District does not currently have a control in place whereby a review of the meal counts entered into the Michigan Nutrition Data (MiND) system takes place, which could result in an 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 Business Office has implemented a formalized internal control procedure for the Food Service Department to adhere, alongside performing a thorough review of the monthly claims reimbursement submission. The formalized internal control procedure will accompany the supporting documentation submitted to the Business Office monthly (Attachment A). The procedure involves a review of inputted meal counts, prior to the claim submission. The Food Service Department Administrator responsible for meal claim input will provide corroboration of input accuracy, as documented by signoff from a secondary reviewer. In addition, the Business Office has prepared a Meal Claim Check Tool spreadsheet to utilize, on a monthly basis, as another layer of validation. The Meal Claim Check Tool spreadsheet allows the Business Office to input meal count figures from the Food Service POS system report and compare against the figures from the claims submission report. Any discrepancy identified would be immediately addressed with the Food Service Department and would require an amended claim submission. Contact person responsible for corrective action: Danielle Jacobs, Director of Business Services Anticipated Completion Date: 08/01/2024