Corrective Action Plans

FINDING 2023‐004 Finding Subject: Child Nutrition Cluster ‐ Procurement and Suspension and Debarment Summary of Finding: The School Corporation designed and implemented a process to ensure that costs charged for the procurement of goods and services to the food service program were properly procured. The process was for vendor claims to be reviewed and approved by the department head or Food Service Director and the Treasurer. Prior to entering subawards and covered transactions with federal award funds, recipients are required to verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded. “Covered transactions” include but are not limited to contracts for goods and services awarded under a non‐procurement transaction (i.e. grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the SAMs exclusions, collecting a certification from that vendor, or adding a clause or condition to the covered transaction with that vendor. Recommendation: We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure that contractors are not suspended, debarred or otherwise excluded prior to entering into any contracts or subawards. Contact Person Responsible for Corrective Action: Tim Garland, Superintendent Contact Phone Number: 574‐626‐2525 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: During the audit period, sufficient internal controls were deficient in specific areas which prevented comprehensive program compliance. To address and rectify the issues as presented, vendor verification will be completed on an annual basis. The Food Service Director and Treasurer will confirm through documentation that vendors are not suspended or debarred using resources available. Documentation representing oversight and compliance will be retained and referenced as needed for verification. Anticipated Completion Date: Q2 2024 (6/30/2024)

FINDING 2023‐003 Finding Subject: Child Nutrition Cluster ‐ Internal Controls Summary of Finding: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Allowable Costs/Cost Principles, Activities Allowed and Unallowed. Recommendation: We recommended that management of the School Corporation design and implement a proper system of internal control, including policies and procedures that would provide segregation of duties to ensure appropriate reviews, approvals and oversight are taking place regarding vendor claims. Contact Person Responsible for Corrective Action: Tim Garland, Superintendent Contact Phone Number: 574‐626‐2525 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Lewis Cass Schools makes every effort to ensure proper documentation is obtained before processing vendor claims. To prevent oversight and strengthen internal controls, each level of management oversight has implemented stringent safeguards. All food service vendor claims will not be processed for payment without the authorization of the Food Service Director. Upon confirmation of the Food Service Director’s documented authorization, the Deputy Treasurer will document the authorization, and prepare the claim for the Treasurer. The Treasurer will ensure documented authorization of the Food Service Director and the Deputy Treasurer, along with the proper budget account code applied before releasing authorization for payment. The application of the procedures above will apply to all vendor claims for payment. Therefore, vendors meeting the thresholds for suspension and debarment will also be included. Anticipated Completion Date: Q2 2024 (6/30/2024)

Finding # 2023-021 Title of Finding Special Tests and Provisions Contact Person Anthony McDaniels Anticipated Completion Date FY 2024 Corrective Action planned to be taken: The Board will develop a Food Service Collection Policy and attempt to collect the outstanding balances on the receivables related to the National School Lunch Program.

The Director of Food Service will continue to review monthly expenditures and plan accordingly.

CContact Person – Thomas A. Jerome, Superintendent Corrective Action Plan – The District will implement policies and procedures to ensure all students who receive a free or reduced meal have a current and accurate application on file. Completion Date – December 29, 2023

Contact Person – Thomas A. Jerome, Superintendent Corrective Action Plan – The District will implement policies and procedures for verifying free and reduced applications. Completion Date – December 29, 2023

Contact Person – Thomas A. Jerome, Superintendent Corrective Action Plan – The District has implemented new meal count procedures effective May 2023. Completion Date – May 1, 2023

FINDING 2023-001 Finding Subject: Child Nutrition Cluster – Procurement and Suspension and Debarment Summary of Finding: During the SBOA audit, our School Corporation did not have a policy nor the internal controls to review vendors to ensure they were not suspended or debarred. Our School Corporation was unable to provide evidence or support to show that one contracted vendor tested was reviewed before we entered a covered transaction with the vendor. Contact Person Responsible for Corrective Action: Cynthia Alward, Treasurer Contact Phone Number and Email Address: (765)294-2254 alwardc@sefschools.org Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Our School Corporation intends to verify the eligibility of vendors that will be paid more than $25,000.00 in federal funds with SAMS.gov. We will check that the vendor has not been debarred or suspended from participating in federal programs. Anticipated Completion Date: Immediately

FINDING 2023-004 Finding Subject: Child Nutrition Cluster - Eligibility Summary of Finding: Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children Assistance Listings Numbers: 10.553, 10.555, 10.559 Federal Award Number and Year (or Other Identifying Numbers): FY2021-2022, FY2022-2023 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Finding: Material Weakness Contact Person Responsible for Corrective Action: Tiffiny Ulman Contact Phone Number and Email Address: 219-924-4250 tulman@griffith.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: Establish post award internal controls surrounding grant management including, but not limited to, Eligibility. Anticipated Completion Date: 3/5/2024

FINDING 2023-003 Subject: Child Nutrition Cluster - Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Special Tests and Provisions - Non-Profit School Food Service Accounts Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, COVID-19 National School Lunch Program; Summer Food Service Program for Children Assistance Listings Numbers: 10.553, 10.555, 10.559 Federal Award Number and Year (or Other Identifying Numbers): FY2021-2022, FY2022-2023 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Special Tests and Provisions - Non-Profit School Food Service Accounts Audit Finding: Material Weakness, Modified Opinion Summary of Finding: Material Weakness, Modified Opinion Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2021- 003. Contact Person Responsible for Corrective Action: Terri Chance Contact Phone Number and Email Address: 219-924-4250 tchance@griffith.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Griffith Public Schools will be developing, implementing, and documenting, a system of internal controls, including policies and procedures that provide segregation of duties to ensure appropriate reviews, approvals and oversight are taking place to ensure compliance. Anticipated Completion Date: June 30, 2025

Management Response/Corrective Action Plan: Before the Nutrition Director submits the claim, the Business Manager will review the claim with the Nutrition Director.

Management Response/Corrective Action Plan: Management should ensure all documentation is filed and maintained after it is received.

Finding 2023-003 – Child Nutrition Cluster – Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Matthew Parkinson, CFO Contact Phone Number: 317-869-4364 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The CFO will send a memo to all administrators identifying quote and bid thresholds. The school district will obtain at least 3 quotes or use an alternative acceptable procurement method for large purchases. Anticipated Completion Date: 6/30/24

Finding 2023-002 – Child Nutrition Cluster – Activities Allowed or Unallowed, Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Matthew Parkinson, CFO Contact Phone Number: 317-869-4364 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Business Office and Payroll staff will review a Labor Distribution Report to verify that the staff is only paying appropriate personnel from the Food Service Fund. Anticipated Completion Date: 6/30/24

FINDING 2023-002 Finding Subject: Child Nutrition Cluster – Internal Controls Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program Assistance Listing Numbers: 10.553, 10.555 Federal Award Number: 7350 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Activities Allowed and Unallowed, Allowable Costs/Costs Principles, Special Tests and Provisions-Verification of Free and Reduced Price Applications Summary of Finding: Material Weakness Internal Controls were not implemented to prevent noncompliance related to the verification of free and reduced applications and hours and wages. A new internal control procedure will be implemented for the second review of the free and reduced applications and for the hours and wages. Repeat Finding: Prior audit finding number was 2021-002. Contact Person Responsible for Corrective Action: Tammy Achenbach Contact Information: Phone: 317-835-7461 Email: tachenbach@nwshelbyschools.org Views of Responsible Officials: Management agrees with the finding. Management will ensure proper documented review of amounts billed for personnel and for the free and reduce verification 􀀃 INDIANA STATE BOARD OF ACCOUNTS 23 First ~ Best ~ Different! 􀀃 Northwestern􀀃 Consolidated􀀃School􀀃 District􀀃of􀀃Shelby􀀃County􀀃 􀀃 4920􀀃W.􀀃600􀀃N􀀃 Fairland,􀀃IN􀀃46126􀀃 􀀃 Phone:􀀃317􀍲835􀍲7461􀀃 Fax:􀀃317􀍲835􀍲4441􀀃 􀀃 www.nwshelbyschools.org􀀃 Superintendent􀀃 Mr.􀀃Chris􀀃Hoke􀀃 􀀃 Business􀀃Manager􀀃 Mrs.􀀃Tammy􀀃Achenbach􀀃 􀀃 Technology􀀃Director􀀃 Mr.􀀃Josh􀀃Landis􀀃 􀀃 Maintenance􀀃Director􀀃 Mr.􀀃Terry􀀃Coons􀀃 􀀃 Transportation􀀃Director􀀃 Mrs.􀀃Susie􀀃Childress􀀃 􀀃 Special􀀃Education􀀃Director􀀃 Mrs.􀀃Terri􀀃Branson􀀃 􀀃􀀃 School􀀃Board􀀃 Mr.􀀃David􀀃Ploog􀀃 Mrs.􀀃Brooke􀀃Lockett􀀃 Mrs.􀀃Cressa􀀃Rund􀀃 Mr.􀀃Ken􀀃Polston􀀃 Mr.􀀃Terry􀀃Morgan􀀃 Mr.􀀃Travis􀀃Hensler􀀃 Mrs.􀀃Karen􀀃Humphreys􀀃 Cont. page 2 Description of Corrective Action Plan: Review for personnel charges: During the monthly meeting to review the FSMC invoice, along with Operations Ledger, Client P&L, Monthly Reimbursements, Invoices, USDA Reconciliation, Direct Certification, The Hours and Wages will be reviewed and approved. Free and Reduced Verification: Internal Controls for the first round of Free and Reduce Applications will be verified by the Data Controller or the Business Manager and the verification of the random testing of the verifications will be done by the Business Manager or the Deputy Treasurer. Anticipated Completion Date: The district will start the new internal control procedure March 2024 to correct for the 23-24 school year.

Corrective Action: After the Food and Nutrition Director reviews the monthly claims, she will send an email noting her approval, before the claim is submitted to the state. This email approval will be attached to the journal entry support that is posted in the financial system when recording the revenue. Contact Person: Amanda Miller, Director of Food & Nutrition Services and Logistics / Ray Serrano - Accountant Anticipated Completion Date: June 30, 2024

The contact for this plan is Monica Merchant. The School will implement procedures to establish proper internal controls related to the submission of meal counts to the Child Nutrition Management System effective March 15, 2024, allowing for proper segregation of duties and review prior to submission. Meal Counts will continue to be tracked daily. Monthly participation counts, by meal type and location, will be reviewed and entered on the Child Nutrition Management System by the School’s financial consultant. Prior to submission, these data elements will be reviewed, verified and submitted by the organization’s Data and Special Projects Manager. The addition of a second layer of approval should allow for adequate internal control over monthly meal claims.

FINDING 2023-002 Finding Subject: Child Nutrition Cluster - Eligibility, Special Tests and Provisions - Verification of Free and Reduced Price Applications (NSLP) Summary of Finding: Eligibility The School Corporation had not properly designed or implemented a system of internal controls, which would include segregation of duties, that would prevent or detect and correct noncompliance relating to the eligibility determination of a child receiving meals. There was no oversight or review to ensure the eligibility determination was correct. Special Tests and Provisions - Verification of Free and Reduced Price Applications (NSLP) The Account Specialist performed the verification of free and reduced price applications. There was no documentation that an oversight, review, or approval process, or other compensating control, had been established to ensure the proper number of applications were verified for accuracy. Contact Person Responsible for Corrective Action: Josh Sinclair, Food Service Director and Allison Vanover, Corporation Treasurer. Contact Phone Number and Email Address: 812-246-3375 jsinclair@scsc.school avanover@scsc.school Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We will use the proposed USDA form that has two signatures required. Mr. Sinclair will ensure that all signatures are collected for proof of verification. Mr. Sinclair and Ms. Susan Westfall will be a second check on the eligibility determination. One will do paper applications and the other will do online applications. Then, they will check each other for accuracy. Anticipated Completion Date: March 2024

2023-001. Procurement United States Department of Education, passed through New York State Department of Education Title I Grants to Local Educational Agencies ALN: 84.010A Special Education Cluster Special Education Grants to States: IDEA, Part B ALN: 84.027A Special Education Grants to States: IDEA 611 ARP Allocations ALN: 84.027X Special Education Preschool Grants: IDEA Preschool ALN: 84.173A Special Education Preschool Grants: IDEA 619 ARP Allocations ALN: 84.173X Education Stabilization Fund COVID-19: Governor’s Emergency Education Relief Fund ALN: 84.425C COVID-19: Elementary and Secondary School Emergency Relief Fund ALN: 84.425D COVID-19: American Rescue Plan – Elementary and Secondary School Emergency Relief (ARP ESSER) Fund ALN: 84.425U United States Department of Agriculture, passed through New York State Department of Education Child Nutrition Cluster School Breakfast Program ALN: 10.553 National School Lunch Program ALN: 10.555 COVID-19: National School Lunch Program ALN: 10.555 COVID-19: Summer Food Service Program for Children ALN: 10.559 Condition: The District has not updated its existing policies and written procedures to conform to Uniform Guidance requirements. Planned Corrective Action: The District’s Assistant Superintendent for Business and Operations will work on updating all policies and procedures relating to U.S. Office of Management and Budget Uniform Guidance to ensure that District policies are in compliance with these guidelines. Responsible Contact Person: Jeremy Feder Assistant Superintendent for Business and Operations Lawrence Union Free School District 2 Reilly Road Cedarhurst, NY 11516 Anticipated completion date: June 30, 2024.

Audit Finding Reference: 2023-002 Management’s Views and Planned Corrective Action: Food Service Balance – We will ensure that we spend the surplus food balance funds in 23-24 and not make a transfer of the funds from the district unless needed to ensure we don’t have an excess fund balance beyond the limit allowed. Name of Contact Person and Completion Date: Name – Bridget Cross Anticipated Completion Date – will be corrected for the 23-24 Audit

􀀃 Finding􀀃2023􀍲005􀀃 􀀃 Finding􀀃Subject:􀀃Child􀀃Nutrition􀀃Cluster􀀃–􀀃Eligibility􀀃–􀀃Internal􀀃Controls􀀃 Summary􀀃of􀀃Finding:􀀃Internal􀀃Controls􀀃were􀀃not􀀃in􀀃place􀀃over􀀃direct􀀃certification􀀃of􀀃 students.􀀃 Contact􀀃Person􀀃Responsible􀀃for􀀃Corrective􀀃Action:􀀃Director􀀃of􀀃Food􀀃Service􀀃 Contact􀀃Phone􀀃Number􀀃and􀀃Email􀀃Address:􀀃(260)431􀍲2030,􀀃msnyder@sacs.k12.in.us􀀃 􀀃 Views􀀃of􀀃Responsible􀀃Official:􀀃We􀀃concur􀀃with􀀃the􀀃finding.􀀃 Description􀀃of􀀃Corrective􀀃Action􀀃Plan:􀀃 All􀀃direct􀀃certification􀀃information􀀃shall􀀃be􀀃initiated􀀃by􀀃the􀀃Director􀀃of􀀃Food􀀃Service:􀀃Pulling􀀃the􀀃 information􀀃monthly􀀃from􀀃CNP􀀃Web.􀀃The􀀃list􀀃of􀀃students􀀃to􀀃be􀀃directly􀀃certified􀀃will􀀃be􀀃printed,􀀃 signed􀀃and􀀃dated􀀃by􀀃the􀀃Director􀀃of􀀃Food􀀃Service.􀀃Once􀀃information􀀃is􀀃imported􀀃into􀀃the􀀃student􀀃 management􀀃system,􀀃the􀀃Assistant􀀃Food􀀃Service􀀃Director􀀃would􀀃then􀀃cross􀀃reference􀀃the􀀃printed􀀃list􀀃 of􀀃information􀀃to􀀃benefits􀀃assigned􀀃in􀀃the􀀃student􀀃management􀀃system􀀃to􀀃ensure􀀃accuracy.􀀃The􀀃 Assistant􀀃Food􀀃Service􀀃Director􀀃will􀀃initial􀀃next􀀃to􀀃the􀀃students􀀃they􀀃spot􀀃check􀀃on􀀃the􀀃list.􀀃The􀀃 printed􀀃document􀀃with􀀃signatures􀀃of􀀃both􀀃parties􀀃will􀀃be􀀃retained􀀃with􀀃the􀀃school􀀃years􀀃 applications.􀀃􀀃 Anticipated􀀃Completion􀀃Date:􀀃3/18/24􀀃

􀀃 Finding􀀃2023􀍲004􀀃 􀀃 Finding􀀃Subject:􀀃Child􀀃Nutrition􀀃Cluster􀀃–􀀃Allowable􀀃Activities,􀀃Allowable􀀃Cost/Cost􀀃 Principles􀀃 Summary􀀃of􀀃Finding:􀀃Internal􀀃Controls􀀃were􀀃not􀀃effective􀀃and􀀃did􀀃not􀀃prevent􀀃unallowable􀀃 activities/cost􀀃 Contact􀀃Person􀀃Responsible􀀃for􀀃Corrective􀀃Action:􀀃Director􀀃of􀀃Food􀀃Service􀀃 Contact􀀃Phone􀀃Number􀀃and􀀃Email􀀃Address:􀀃(260)431􀍲2030,􀀃msnyder@sacs.k12.in.us􀀃 􀀃 Views􀀃of􀀃Responsible􀀃Official:􀀃We􀀃concur􀀃with􀀃the􀀃finding.􀀃 Description􀀃of􀀃Corrective􀀃Action􀀃Plan:􀀃 All􀀃claims􀀃shall􀀃be􀀃created􀀃by􀀃the􀀃Assistant􀀃Food􀀃Service􀀃Director􀀃and􀀃reviewed􀀃for􀀃 compliance􀀃within􀀃the􀀃allowable􀀃cost􀀃category􀀃prior􀀃to􀀃payment􀀃by􀀃the􀀃Director􀀃of􀀃Food􀀃 Service.􀀃In􀀃the􀀃event􀀃that􀀃the􀀃Director􀀃of􀀃Food􀀃Service􀀃must􀀃initiate􀀃a􀀃claim􀀃first,􀀃the􀀃 Assistant􀀃Food􀀃Service􀀃Director􀀃would􀀃then􀀃review􀀃the􀀃claim􀀃prior􀀃to􀀃issuance.􀀃All􀀃claims􀀃are􀀃 returned􀀃to􀀃the􀀃Assistant􀀃Food􀀃Service􀀃Director􀀃for􀀃review􀀃of􀀃accuracy􀀃after􀀃the􀀃payment􀀃 method􀀃has􀀃been􀀃authorized􀀃to􀀃ensure􀀃accuracy􀀃and􀀃compliance.􀀃Both􀀃parties􀀃will􀀃initial􀀃 documents􀀃appropriately,􀀃as􀀃well􀀃as􀀃maintain􀀃all􀀃copies􀀃of􀀃proof􀀃of􀀃purchase/service􀀃with􀀃 original􀀃claim􀀃form􀀃documents.􀀃􀀃 Anticipated􀀃Completion􀀃Date:􀀃3/18/24􀀃

Commodity Supplemental Food Program (CSFP) and The Emergency Food Assistance Program (TEFAP) have developed a tentative 2024 inventory schedule to ensure continued compliance with the annual USDA Food and Nutrition Services (FNS) requirements. The schedule was submitted to FNS as part of the state’s Management Evaluation (ME) findings response. The State received notification from FNS on January 26, 2024, noting the successful completion and close-out of the FFY 2022 Management Evaluation and its findings.

We will continuously monitor the compliance supplements for updates in order to meet all requirements. We have added additional staff to complete FFATA reporting to ensure the reports are submitted timely and accurately moving forward.

Condition - The District did not obtain debarment certification or document their vendor search in the System for Award Management website for vendors contracted in excess of $25,000 related to the grant program. Upon further review, it was determined that the vendors were not suspended or debarred. Plan - Policies and procedures will be implemented to document the verification that vendors are not suspended or debarred. Anticipated Date of Completion - June 30, 2024. Name of Contact Person - James Dunlap, Superintendent. Management Reponse - Management does not disagree with this finding. In future years, the District will document their verification that vendors are not suspended, debarred, or otherwise excluded from doing business.