Corrective Action Plans

Auditors’ Recommendation: We recommend that as part of preparing monthly bank reconciliations, the reconciliation with the balance from the general ledger should be performed. Any differences should be immediately investigated and corrected. Once completed, the reconciliation should be reviewed by someone independent of the preparer. Both, the individual preparing and reviewing the bank reconciliations should sign or initial and date the reconciliation when completed. We recommend that the District incorporate procedures to ensure that such general ledger accounts are reconciled on a monthly basis. It is important that a dual accounting system is utilized in each individual fund and transactions between funds should be booked through the interfund receivables and payables. School District’s Response: Penny Crowell, Business Manager will ensure that bank reconciliations are prepared on a timely basis throughout the year, which includes a reconciliation to the general ledger. The District will have the Superintendent review bank reconciliations. Once completed, the preparer and reviewer will sign and date each reconciliation to evidence their completion. Lastly, the District will reconcile due to/due from accounts on a monthly basis. These processes will take place during the year ending June 30, 2024.

FINDING 2023-002 Finding Subject: Child Nutrition Cluster - Verification of Free and Reduced Price Lunch Applications Summary of Finding: Management had not developed or implemented a system of internal control that would have ensured compliance with requirements related to the grant agreement and Special Tests and Provisions - Verification of Free and Reduced Price Applications (NSLP) compliance requirements. The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and Special Tests and Provisions - Verification of Free and Reduced Price Applications (NSLP) compliance requirements. A lack of segregation of duties within an internal control system could also allow noncompliance with compliance requirements and allow the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the program. We recommended that the School Corporation's management establish a system of internal controls, including segregation of duties, related to the grant agreement and Special Tests and Provisions - Verification of Free and Reduced Price Applications (NSLP) compliance requirements. Contact Person Responsible for Corrective Action: Andrea Miller Contact Phone Number and Email Address: 765-564-2100, millera@delphi.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Food Service Director or Assistant will review the applications, the other will do a second review. The Food Service Director and Assistant sign each application that is verified to ensure all information is accurate and the eligibility status is correct in Skyward. If additional verification information is provided, it will be documented and recorded in the binder with the applications. Anticipated Completion Date: August 2024

FINDING 2023-003 Finding Subject: Child Nutrition Cluster - Eligibility Summary of Finding: The School Corporation's management had not developed a system of internal controls that would have ensured compliance with the Eligibility compliance requirements. The failure to establish an effective internal control system places the School Corporation at risk of noncompliance with the grant agreement and the Eligibility compliance requirements. A lack of segregation of duties within an internal control system could also allow noncompliance with compliance requirements and allow the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the program. We recommended that the School Corporation's management establish a system of internal controls, including segregation of duties, related to the grant agreement and the Eligibility compliance requirements listed above. Contact Person Responsible for Corrective Action: Andrea Miller Contact Phone Number and Email Address: 765-564-2100, millera@delphi.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Food Service Director or Assistant will enter online and paper applications, the other will review the entries compared to the applications, and both will sign off the applications. An additional selection will be added in Skyward to document which type of classification. A legend for the codes will be kept in the front of the binder where the applications are kept for reference. Anticipated Completion Date: August 2024

FINDING 2023-004 Finding Subject: Child Nutrition Cluster - Allowable Costs/Cost Principles Summary of Finding: Management had not developed an effective system of internal control that would have ensured compliance with the grant agreement and the Allowable Costs/Cost Principles compliance requirement. The failure to establish an effective internal control system enabled noncompliance to go undetected. Noncompliance with the grant agreement and the compliance requirement could have resulted in the loss of funds to the School Corporation. We recommended that the School Corporation's management establish an effective system of internal control to ensure compliance and comply with the grant agreement and the Allowable Costs/Cost Principles compliance requirement. Contact Person Responsible for Corrective Action: Andrea Miller Contact Phone Number and Email Address: 765-564-2100, millera@delphi.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: A price list will be requested from vendors (GFS/Piazza) twice a month to reflect current pricing, and reports will be filed by school year by the Food Service Director for reference. The Food Service Director or Assistant will sample items that have been purchased and compare them to the pricing listing to verify accuracy. Anticipated Completion Date: August 2024

Findings and Questioned Costs Related to Federal Awards Finding Number: 2023‐001 Program Name/Assistance Listing Title: Child Nutrition Cluster Assistance Listing Numbers: 10.553, 10.555, 10.559 Contact Person: Krystal Burnham, Food Service Compliance Coordinator/ Danny Robbins, Interim Director of Budget and Finance Anticipated Completion Date: July 31, 2023 Planned Corrective Action: The District will ensure that monthly counts are supported by documentation and verified by a second staff member and agree to the accuracy of the reimbursement claims prior to submission to the Arizona Department of Education. The District will also ensure that reimbursement claims are submitted within the required time period after month end and any identified issues with measures that prevent their recurrence.

The filing of the Data Collection Form will be submitted by the required due date. In the prior year, the audit report was submitted after the Federal Audit Clearinghouse deadline. The current audit will be submitted with sufficient time to meet the Federal Audit Clearinghouse submission date requirement. Responsible party(ies) for corrective action(s): Chief Financial Officer Corrective action(s) timeline: March 15, 2024

The District has taken remedial actions to reduce net cash resources the Food Service Fund including the purchase of updated cafeteria equipment, service vehicles and brand new cafeteria tables for the High School. Additionally, the District plans to request additional staffing and more diverse menu items to suuplement the food service program.

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 10.556 2023-003 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 federal program. The District did not have sufficient controls in place within its child nutrition cluster federal program 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. Corrective Action Plan 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 – Kerstin Quigley, Business Manager. Planned Completion Date – June 30, 2024. Disagreement With or Explanation of Finding – The District agrees with this finding. Plan to Monitor – The District’s Business Manager and the Superintendent will ensure appropriate controls are in place to verify that any vendor with which the District contracts for federal program goods or services exceeding $25,000 is not listed as suspended or debarred on the federal Excluded Parties List System website.

Corrective Action Plan: All borrowed cash has been transferred back to proper accounts. Journal entries and bank transfers shown above. District Administration will assess staffing needs to determine separation of duties and to determine additional staffing needs to meet the requirements of duty separation in connection with the reconciliation process. Currently, the Finance Department consists of one Payroll/Benefits position, one Accounts Payable/Receivable Position, one Grants Specialist Position, and one Finance Director. In prior years, the Finance Department had two additional positions that have since been eliminated, causing position duties to be absorbed amongst the remaining staff. Anticipated Completion Date: March 29, 2024

Corrective Action Plan: Reimbursement of Department of Agriculture cash has been completed for year-end 2022-2023. District Administration will assess staffing needs to determine separation of duties and to determine additional staffing needs to meet the requirements of duty separation. Currently, the Finance Department consists of one Payroll/Benefits position, one Accounts Payable/Receivable Position, one Grants Specialist Position, and one Finance Director. In prior years, the Finance Department had two additional positions that have since been eliminated, causing position duties to be absorbed amongst the remaining staff. Journal postings to reimburse shown below. Anticipated Completion Date: March 29, 2024

Management's Response: We concur. View of Responsible Officials and Corrective Action Plan In the 2023-24 school year, Nutrition Services has implemented an additional step when processing meal applications to improve accuracy. Meal applications are verified a total of three times. The Nutrition Specialist is the Determining Official, the Director is the Confirming Official, and either the Secretary or Clerk is the Verifying official. Each official reviews the application for accuracy. Name of responsible individual: Brenda Zarate Implementation Date: 7/1/2023

TRANSPARENCY ACT REPORTING Department of Education (DOE) Assistance Listing Number 10.553, 10.555, 10.556, 10.559, 10.582 Setting up a process to comply with the FFATA reporting requires retrieving information from multiple systems. In addition, child nutrition reimbursements are more complex than grants that have a known subrecipient amount. Due to the complexity, DOE is relying on guidance from the USDA to complete reporting procedures. DOE is currently waiting to get answers to several questions that are preventing full development of a process. USDA is also working to help DOE find another state agency that can help with unanswered questions. A FFATA reporting process is anticipated to be in place by July 1, 2024.

FINDING 2023-002 Subject: Child Nutrition Cluster – Suspension and Debarment Summary of Finding: The School Corporation did not verify vendor suspension and debarment status prior to payment. Recommendation We recommended that management of the School Corporation establish a system of internal and develop policies and procedures to ensure contractors and subrecipients, as appropriate are not suspended, debarred, or otherwise excluded prior to entering into any contracts or subawards. Contact Person Responsible for Corrective Action: Casey Howard Contact Phone Number: 574-842-3364 x806 Views of the Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Food Service Director and/or Treasurer will utilize the procurement policy and will ensure all vendors paid with federal dollars have not been suspended or debarred. Anticipated Completion Date: Completed as of January 2024

The District will continue to enhance procedures and controls over the verification compliance requirement with adequate oversight and will identify and train additional individual(s) to ensure appropriate back-up is in place, that is also knowledgeable of its requirements. Responsible official: Cory Kaisler, Data Systems Coordinator – ckaisler@shawanoschools.org Anticipated Completion Date: June 30, 2024

The District will continue to enhance procedures and controls over the eligibility requirements with adequate oversight of both manual and electronic processes and will identify and train additional individual(s) to ensure appropriate back-up is in place, that is also knowledgeable of its requirements. Responsible official: Cory Kaisler, Data Systems Coordinator – ckaisler@shawanoschools.org Anticipated Completion Date: June 30, 2024

FINDING 2023-005 Finding Subject: Child Nutrition Cluster - Eligibility Summary of Finding: Material Weakness Condition and Context There was no evidence that the Direct Certifications were correctly and properly included in the software system, or that there was an oversight, review, or approval process over the Direct Certifications. Contact Person Responsible for Corrective Action: Lori Boyce Contact Phone Number and Email Address: 765-653-3148 lboyce@sputnam.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: The Food Service Director will have the Guidance Secretary check and initial that the Food Service Director has completed the Direct Certification correctly. Anticipated Completion Date: 2/2024

Finding 2023-002 – Child Nutrition Cluster – Activities Allowed or Unallowed, Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Eric Speicher Contact Phone Number: 574-598-2768 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The school corporation’s management will establish a documented, secondary review of all accounts payable claims to ensure the accuracy of the claims and will ensure underlying support or details of the claims will be included. Anticipated Completion Date: 2/22/2024

Finding 2023-003 – Child Nutrition Cluster – Special Tests and Provisions – Verification of Free and Reduced Price Applications Contact Person Responsible for Corrective Action: Kimberly Nieves Contact Phone Number: 219-508-0504 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: As an internal control, the Director of Business Affairs and Human Resources has reviewed the process for Verification of Free and Reduced Price Applications. We have now contracted with a Food Service Director through NIESC. They will perform the Verification of Free and Reduced Price Applications and the Director of Business Affairs & HR will review these documents for accuracy. Anticipated Completion Date: FY24 Verification of Free and Reduced Price Application Review Period

Finding 2023-002 – Child Nutrition Cluster – Reporting Contact Person Responsible for Corrective Action: Kimberly Nieves Contact Phone Number: 219-508-0504 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: As an internal control, the Food Service Manager or Director of Food Service will prepare the reimbursement claim and the Director of Business Affairs and HR or Treasurer will review and initial the claims. This will ensure the accuracy of the reimbursement claim. Anticipated Completion Date: This Corrective Action was put into place in September 2022 following our prior audit. The Claim that was not signed for this Audit was from October 2021.

Recommendation: Internal controls for accounting for nonprofit school food service funds should be implemented. A separate class in the accounting software for the program could be utilized. Action Taken: One City Schools developed a new financial class for School Nutrition, and all grant funds and expenditures will be classed to School Nutrition so these funds are clearly segregated from others. One City Schools implemented these new class designations as of January 1, 2024. Additionally, OCS added relevant tasks in our monthly accounting procedures to check for miscodes and ensure grant funds and expenditures are correctly coded.

Recommendation: One City Schools, Inc. should design and implement appropriate internal controls for retaining support for claims in accordance with federal requireents. Action Taken: One City Schools has developed a new process to document meal counts per month, attendance and enrollment numbers per month, submission of claims, and the signature of a designated second approver, the COO. As each claim is made, the associated backup documentation will be presented to the second approver for their review and signature. Once approved, the entire packet of information will be retained. This process was initiated in December 2023.OCS completed the second designated approver review retroactively for all claims in the months of July, September, October, and November 2023.

Recommendation: One City Schools, Inc. should design and implement appropriate internal controls for reviewing funding claims. Action Taken: One City Schools has developed a new process for submission where a second approver, the COO, reviews the claims for accuracy. This process started in December 2023, however OCS also completed this second approver review retroactively for all claims in July 2023, September 2023, October 2023, and November 2023.

Recommendation: Additional training should be provided to individuals responsible for the development of written policies and procedures in accordance with the Uniform Guidance. Action Taken: One City Schools is in the process of identifying a required training program for all staff members involved in the submission, review and/or approval of the schedule of expenditures of federal awards. This includes One City’s Executive Chef, Executive Director of K-8, COO and VP of Government Relations (who oversees compliance). Designated staff will take advantage of all DPI-provided training seminars and resources available, and we will track attendance of relevant staff members. This process will be in place by June, 2024.

Corrective Action Required by The Board - The School District was not in compliance with CFR section 210.14 which requires that the net cash resources in the food service fund to be below its three month average expenditures at year end. Recommendation Number Corrective Action Required by The Board - The responsible officials are in agreement with the calculation. COVID's financial impact on the food service fund and ultimately the food service reserves has created this inflated financial position. We will use these funds to continue to invest in our food service equipment as well as upgrade our food options and meal quality, within USDA regulations.

ACFR/AMR Finding # 2023-001, Finding (Condition) - The School District's Food Service Fund Net Cash Resources exceeded its three-months average expenditures., 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 - The district is purchasing updated equipment throughout the various kitchens including cameras to monitor the health and safety practices of the line. We plan to review available menu options and expand quality and offerings. Person Responsible for Implementation - Director of Food Services & School Business Administrator. Implementation Date - 6/30/2024.