Corrective Action Plans

Finding 2023-004 – Child Nutrition Cluster – Eligibility Contact Person Responsible for Corrective Action: Felicia Wolfington/Sasha Robison Contact Phone Number: (812) 936-4474 x232 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 eligibility determinations to ensure they meet the grant agreement and eligibility compliance requirements. Anticipated Completion Date: 08/31/2024

Finding 2023-003 – Child Nutrition Cluster – Reporting Contact Person Responsible for Corrective Action: Felicia Wolfington/Sasha Robison Contact Phone Number: (812) 936-4474 x232 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 the reporting to ensure they are meeting the grant agreement and cash management compliance requirements. Anticipated Completion Date: 02/16/2024

Finding 2023-002 – Child Nutrition Cluster – Activities Allowed or Unallowed, Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Felicia Wolfington/Sasha Robison Contact Phone Number: (812) 936-4474 x232 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: 02/16/2024

Audit Finding Reference: 2023-001 Management's View and Planned Corrective Action: Due to the extension of the federal funding for free school meals in the prior year, the District is aware of the fund balance greater than three (3) months of its average expenditures. We are looking to reserve the program fund balance to support the potential renovation that will take place over the summer of 2024 should Warrant Article 6 Renovate the Checkers Kitchen at Alvirne pass. This special warrant article is recommended by both the Hudson School Board and Budget Committee. This is allowable from the NH Department of Education's Office of Nutrition Programs and Services (ONPS). Name of Contact Person and Completion Date: Karen Atherton, Food Service Director Melissa Van Sickle, Finance Director Anticipated completion date: If supply issues are not a factor, December 31, 2024; otherwise, June 30, 2025.

The District will update the annual calculation to include a comparison of the base used for the indirect cost adjustment. Upon identification of the overcharge, the District posted a correcting entry to reduce the indirect costs of the program.

Unified School District #446 Independence, Kansas Corrective Action Plan January 17, 2024 Cognizant or Oversight Agency for Audit Unified School District #446 respectfully submits the following corrective action plan for the year ended June 30, 2023. Name and address of independent public accounting firm: Jarred, Gilmore & Phillips, PA, P.O. Box 779, 1815 S Santa Fe, Chanute, Kansas 66720. Audit period: Year ended June 30, 2023 The findings from the January 17, 2024 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Finding: 2023-001 – Verification Condition: During our testing of verification of income of households sampled during the year, we tested all households chosen for verification. During this testing, we noted households whose net income was used to calculate their eligibility instead of their gross income. Recommendation: Procedures should be implemented requiring that all income should be verified using proper documentation and verification results review by at least two or more qualified individuals. Action Taken: We are in agreement with the recommendation and the District has updated review procedures to ensure that free and reduced lunch verifications are reviewed by at least two people and that gross wages are used in the calculations. Anticipated Complete Date: November 8, 2023 Should the Oversight Agency for Audit have questions regarding this plan, please contact Gina Godinez, Director of Finance, at (620) 332-1800. Sincerely Unified School District #446 Unified School District #446

Corrective Action Plan Year Ended June 30, 2023 2023-01 Finding: Eligibility Status: Corrective action in progress Corrective Action: Training and additional oversight Person Responsible for Implementing: Lisa Clark, Director of Finance Implementation Date: January 2024 It was found that an application was identified as reduced status when it should have been free status. When the parent filled out the application in our online applications system, one of the students listed was not matching. This was due to the student not being in our Student Information System at that point. The secretary processed the application without the match. This resulted in the reduced status based on income and the number of members in the household. The student that did not match remained outstanding in the online application portal. Later when the unmatched student was entered into the Student Information System, matched and processed in the online application portal, the system did not update the original application to add the additional member. With the addition of the additional family member, the application resulted in a free status. The corrective action will include additional training for the staff members processing the applications. This will be done during January of 2024. We will implement a secondary check after each upload to catch any applications that may have unmatched students and make the corrections. There will be continued oversight and training. Lisa Clark Director of Finance

Finding Number: 2023‐001 Program Name/Assistance Listing Title: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 Contact Person: Vanessa Bonfim Anticipated Completion Date: March 6, 2024 Planned Corrective Action: • In order to ensure that correct claim numbers are submitted to AZ Department of Education, the Food Services Department will perform double monthly checks when claims are entered into ADEConnect website, before actual submission. • Claims are entered into ADEConnect by the Food Service Liaison and double check will occur at the same time by the food service supervisor. • Monthly scheduled time will be set once a month to process claims.

Federal Award Findigs and Questioned Costs - Finding 2023-002 The School District must verify eligibility of children in a sample of househould applications approved for free and reduced prices meal benefits for that school year. Verification was not performed for one of the School District's sub recipients. Adequate oversight of the verification process was not in place in order to ensure verification process occurred related to one of the School District's sub recipients. Corrective Action: The software that the District uses for the school lunch program randomly chooses applications in which to verify each year. Prior to the 2023-24 shcool year, the District's sub recipient, Holy Family, was not included in the District's school lunch software and was manually tracked. Beginning 9/6/23, Holy Family is now included in the District's Software and will be part of the random selection process that will be competed by 11/5/23 and each year's due date thereafter.

Finding Number: 2023-005 Finding Synopsis: During the audit, we determined that the District did not complete the 3% verification of applications procedures by the due date. Action Steps: The District will update the timelines used on the verification letters being sent to families so they are in line with what ISBE recommends so that verification testing can be completed by the deadline. Contact Person: Jeffrey Schubert, Chief School Business Official, 779-244-1000 Anticipated Completion Date: 6/30/2024

Finding Number: 2023-004 Finding Synopsis: During the audit, we determined that in a population of 4 error prone applications selected for verification, exceptions were noted on 2 of the applications selected for verification. One of the exceptions stemmed from verification documentation received determined the student should be changed from reduced lunch to paid lunch and this change was not made. The other exception also resulted from verification documentation received determined the student should be changed from free lunch to reduced lunch and this change was not made. Action Steps: The District will implement review procedures to ensure the free or reduced lunch status is properly calculated and updated during the application verification process. Contact Person: Jeffrey Schubert, Chief School Business Official, 779-244-1000 Anticipated Completion Date: 6/30/2024

Finding: 2023-002 – Eligibility U.S. Department of Agriculture – Child Nutrition Cluster (ALN 10.CNC); Passed through MDE; All project numbers. 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 student's eligibility determination was not supported by a properly completed application or direct certification. As a result of this condition, the District requested grant reimbursements without the proper support. Auditor Recommendation: We recommend that management ensures all documentation is retained and properly supports the determination for all free and reduced lunch applications and direct certification lists. Corrective Action: The Food Services Director will verify that the documentation supports the determination for all free and reduced lunch applications and direct certification lists. All documentation will be kept on file in the Food Services Director's Office for no less than the current fiscal year plus 3 years as required by the Michigan Department of Education. Responsible Person: Shelley Miller, Food Service Director and Daniel Pena, Business Manager Anticipated Completion Date: June 30, 2024

10.553, 10.555, 10.559 - Child Nutrition Cluster 2023-001 Net Cash Resources Corrective Action Plan: The School District will review cafeteria operations throughout 2023-24 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, 2024.

Finding Number: 2023-001 Condition: The Michigan Nutrition Data (MiND) system auto calculates the number of full-paid meals after the district enters the free, reduced and total number of meals. Therefore, if the number of free or reduced meals is typed incorrectly, the difference automatically adds or subtracts to the number of fullpaid meals. While there is review and approval of amounts prior to entering meal counts into the MiND system, the district did not consider that once free and reduced meals are entered into the system, the number of full pay meals auto fills to the number required to match/balance the total meals served. This resulted in the District not identifying that two claims requests undercounted reimbursable meals which shorted the District receiving additional funding of $7,639. Planned Corrective Action: After an in-depth review of the circumstances that led to the incorrect (under count) request for meal reimbursement error, an additional review and approval procedure has been implemented. This will ensure the final meal claims data, including the MiND system auto calculated data reflects the district’s internal meal count data reporting. Contact person responsible for corrective action: John Fitzgerald, Assistant Superintendent for Business & Finance Completion Date: July 31, 2023

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE AND REPORTABLE INCIDENCE OF NONCOMPLIANCE – U.S. DEPARTMENT OF AGRICULTURE, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, CHILD NUTRITION CLUSTER – FEDERAL ALN 10.553 AND 10.555 2023-001 Internal Control Over Compliance and Noncompliance With Federal Eligibility Requirements Finding Summary 7 CFR § 245 requires management to establish and maintain effective internal control over compliance with requirements applicable to federal program eligibility requirements. Independent School District No. 885 (the District) did not have sufficient controls in place within its child nutrition cluster federal program to ensure compliance with federal eligibility to accurately update the meal-type eligibility classification for direct-certification students whose eligibility category changed during the year. Corrective Action Plan Actions Planned – The District will review policies and procedures relating to eligibility for its child nutrition cluster federal programs to ensure the eligibility status for all students are appropriately updated in the District’s system as eligibility classification changes occur in accordance with federal program eligibility guidelines. Official Responsible – Kris Crocker, Director of Business Services. Planned Completion Date – June 30, 2024. Disagreement With or Explanation of Finding – The District agrees with this finding. Plan to Monitor – Kris Crocker, Director of Business Services, will assure appropriate internal controls and procedures are updated and in place to ensure compliance for future federal awards expenditures.

Condition: Proper segregation of duties is an important aspect of any control system. Management is responsible for the design, installation and maintenance of an appropriate system of internal control. The limited size of the District's office staff prevents the ideal segregation of functions. The following duties lack adequate segregation of duties: ► The District uses e-signatures to approve purchase orders. Two individuals have access to the e-signatures and have the ability to create new vendors, enter invoices, print checks, record journal entries and record activity on the general ledger. Both individuals also have access to the payroll system.Recommendation: The Board of Education and the Superintendent should continue to monitor the transactions and the financial records of the District. We also encourage the District to continue to identify cost effective opportonities to improve the design of the internal control structure. Response: We agree with this finding but do not believe it is cost effective to increase the office staff in an ► The person reviewing free and reduced food service eligibility can also enter information into the system to detennine eligibility.Effect: Errors or intentional fraud could occur and not be detected timely by other employees in the nonnal course of their responsibilitie􀀩 as a result of the lack of segregation of duties. attempt to bring about a more effective segregation of duties. The Superintendent approves purchase orders and the Board of Education approves monthly accounts payable checks, and one of the school secretaries or the board treasurer reviews the bank reconciliations. The Board of Education and Superintendent will continue to monitor transactions of the District. Cause: Limited number of personnel. Criteria: Segregation of duties is an aspect of internal control intended to prevent or decrease. opportunities of intentional and unintentional errors and fraud. Duties and responsibilities are properly segregated if no single individual either has control over all phases of a transaction or has the ability to both make and conceal an error, whether such error is intentional or unintentional. Recommendation: The Board of Education and the Superintendent should continue to monitor the transactions and the financial records of the District. We also encourage the District to continue to identify cost effective opportonities to improve the design of the internal control structure. Response: We agree with this finding but do not believe it is cost effective to increase the office staff in an attempt to bring about a more effective segregation of duties. The Superintendent approves purchase orders and the Board of Education approves monthly accounts payable checks, and one of the school secretaries or the board treasurer reviews the bank reconciliations. The Board of Education and Superintendent will continue to monitor transactions of the District.

Training was provided to staff reviewing applications. District has since joined the CEP and is streamlining the internal processes for identifying eligibility as low income.

See response and correction action plan at 2023-004. Response and correction action plan: Beginning in March 2023, the District received certification of suspension and debarment as outlined by the Office of Management and Budget and will request certification as part of the process for future bids. In spring 2023, the district joined the Area Education Agency purchasing program for the Child Nutrition Program.

The Food Bank has updated the weight and has implemented procedures to ensure products are updated annually.

The District now reviews the work performed by the individual preparing the reports before submission.

Program Name/Assistance Listing Title: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 Contact Person: Linda Cordova, Business Manager Anticipated Completion Date: December 1, 2023 Planned Corrective Action: The food service liaison is responsible for submitting meal claims and verifying meal that counts agree with the supporting documentation. Supporting documentation will be retained in the Business Services Department.

2023-001 Net Cash Resources 10.553, 10.555, 10.559 - Child Nutrition Cluster Corrective Action Plan: The School District will review cafeteria operations throughout 2023-2024 and ensure any excess funds be used to provide additional support to the cafeteria program, including the utilization of excess funds for equipment and operational efficiencies. The School District expects to resolve this issue by June 30, 2024.

Accurate count of student meals

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 2022-23 school year, the district reviewed the program's needs to develop a strategy to utilize these funds by the food service program. To date the District has identified over thirty items for purchase by the Cafeteria Fund totaling in excess of $280,000. Along with these purchases, further equipment needs are currently being assessed in conjunction with the capital project approved by the voters in December of 2022. We expect such purchases will expend the entire amount of the excess fund balance if not more. The District expects to begin these purchases before the end of the 2023 - 2024 school year (June 30, 2023).

Finding Number 2023-002 Condition: At June 30, 2023, the District maintained fund balances in excess of three months’ average expenditures. Management Response/Plan: The District is working on a Spend Down Plan for the food service program based off guidance from Illinois State Board of Education. The District is working on replacing equipment and renovating cafeterias. Anticipated Date of completion: June 2024 Name of Contact Person: Melissa Geyman Sell