Corrective Action Plans

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.

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