Corrective Action Plans

FINDING 2023-007 Finding Subject: Child Nutrition Cluster - Reporting Summary of Finding: Monthly reimbursement claims for breakfast and lunch meals served are prepared and submitted without documented review or approval by a second individual not involved in the preparation of the reimbursement claim. Contact Person Responsible for Corrective Action: Drew Cooper, Business Manager Contact Phone Number and Email Address: 765-425-7889 dcooper@shenandoah.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Food Service Director will calculate the monthly claims to be submitted to the DOE/CNP and email this information to the Business Manager for review before submittal. Anticipated Completion Date: March 31, 2024

FINDING 2023-005 Finding Subject: Child Nutrition Cluster - Eligibility Summary of Finding: The School Corporation stated that 100% of Free/Reduced lunch applications were reviewed during the audit period. However, testing of controls indicated that 100% of Free/Reduced lunch applications were not being reviewed by an individual other than the individual making the initial determination. As a result, three of forty sampled students received the incorrect eligibility status in the system software when compared to supporting documentation (Direct Certifications and/or income-based applications). Contact Person Responsible for Corrective Action: Drew Cooper, Business Manager Contact Phone Number and Email Address: 765-425-7889 dcooper@shenandoah.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Currently all income based applications for free/reduced lunch status are processed by Pam Frost and then reviewed by the Business Manager. Beginning in the 2024-2025 school year Direct Certification students will also be reviewed by the Business Manager. Anticipated Completion Date: August 31, 2024

FINDING 2023-004 Finding Subject: Child Nutrition Cluster – Allowable Costs/Cost Principles Summary of Finding: The School Corporation did not have internal controls in place over payroll disbursements charged to the food service program. Payroll disbursements were paid without evidence that the detailed report of payroll disbursements was reviewed and approved by another person not involved in the original payroll process. The School Corporation paid $23,682 of administrative salaries that were allocated to the School Lunch fund based on fixed percentages. There was no supporting documentation to indicate how the percentages were determined or time records indicating time spent on the program by the applicable administrators. INDIANA STATE BOARD OF ACCOUNTS 40 􀀃 “Meeting􀀃students􀀃where􀀃they􀀃are􀀃and􀀃leading􀀃them􀀃forward…every􀀃student,􀀃every􀀃day”􀀃 Contact Person Responsible for Corrective Action: Drew Cooper, Business Manager Contact Phone Number and Email Address: 765-425-7889 dcooper@shenandoah.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Currently 50% of Pam Frost’s salary is paid from the Lunch Fund. A new internal control will be created to document that 50% of her time is spent on food service work and 50% of her time is spent as the ECA treasurer for the elementary school. Anticipated Completion Date: August 31, 2024

FINDING 2023-003 Finding Subject: Child Nutrition Cluster – Activities Allowed or Unallowed Summary of Finding: The School Corporation did not have internal controls in place over payroll disbursements charged to the food service program. Payroll disbursements were paid without evidence that the detailed report of payroll disbursements was reviewed and approved by another person not involved in the original payroll process. Contact Person Responsible for Corrective Action: Drew Cooper, Business Manager Contact Phone Number and Email Address: 765-425-7889 dcooper@shenandoah.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Currently the Business Manager and Food Service Director hold a monthly financial meeting to review the status of finances for the Food Service. A review of the payroll distribution reports for the previous month will be added to the agenda of this meeting. Anticipated Completion Date: March 31, 2024

Corrective Action Plan Findings - Federal Award Program Audits Department of Agriculture Finding 2023-001 - Child Nutrition Cluster - School Breakfast Program - Assistance Listing Number 10.553, National School Lunch Program - Assistance Listing Number 10.555, Summer Food Service Program for Children - Assistance Listing Number 10.559 Condition: The year-end financial reports contained several errors related to the recording of receipts and expenses of the Major Federal Award Program. Auditors’ Recommendation: The District should implement a process that includes monitoring activity related to Federal Programs. It is recommended that individuals within the District obtain training related to internal control systems or consider the use of a 3rd party specialist. Planned Corrective Action: The District has had turnover since the completion of the previous audit (June 30, 2022), staff in key positions have turned over multiple times. As of the date of this report, the District has hired and implemented training for key staff to ensure proper grant management in the future.

2023-004 Allowable Costs Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553 and 10.555 Pass-Through Agency: Georgia Department of Education Criteria: In accordance with the terms of the Child Nutrition Grant and 2 CFR 200, Cost Principles for States, Local Governments, and Indian Tribes, specific documentation must be maintained to support salaries and wages charged to the federal program. Where employees are expected to work solely on a single Federal award or cost objective, charges for their salaries and wages will be supported by periodic certifications that the employees worked solely on that program for the period covered by the certification. These certifications will be prepared at least semi-annually and will be signed by the employee or supervisory official having first-hand knowledge of the work performed by the employee. Where employees work on multiple activities or cost objectives, a distribution of their salaries or wages will be supported by personnel activity reports or equivalent documentation. Corrective Action Plan: We concur with this finding. The District is developing corrective actions to strengthen Child Nutrition Cluster Department internal controls, policies, and procedures and ensure adherence through improved monitoring. Through collaboration, the Finance Division and the School Nutrition Department will review payroll detail reports and ensure periodic certifications for all employees are completed timely. Estimated Completion Date: Fiscal Year 2025 Contact Person: Dr. Connie Walker, School Nutrition Executive Director Telephone: 678-676-1200 E-mail: Connie_R_Walker@dekalbschoolsga.org

Federal Program Child Nutrition Cluster - Passed through the Pennsylvania Department of Education and Pennsylvania Department of Agriculture ALNs 10.555 and 10.553 Education Stabilization Fund - Passed through the Pennsylvania Department of Education ALN 84.425 Criteria Per the Uniform Guidance 2 CFR 200.510, the auditee is required to prepare a schedule of expenditures of federal awards (SEFA). Condition The District prepared a SEFA and provided information relating to the federal programs including grant agreements and other supporting documentation. However, the SEFA prepared by the auditee required material adjustments as a result of audit procedures. Cause Certain account reconciliations were not performed prior to the audit, which impacted amounts reported on the SEFA. Effect Amounts reported on the SEFA provided by the auditee were not accurate. The SEFA was subsequently updated through audit procedures, including inquiry and review of grant documentation of awards received and amounts expended. Questioned Costs None. Context A SEFA was prepared by management; however, several adjustments were required in order for the schedule to accurately reflect the current year activity. Repeat Finding Yes. See finding 2022-003. Recommendation In order to meet Uniform Guidance requirements, the District should prepare the SEFA from the grant award documentation and any other relevant information including the assistance listing numbers, grant award amounts, grant amounts received, grant amounts expended, and grant revenue recorded. The amounts reported in the SEFA should reconcile to the general ledger. Management Response The new Assistant Business Manager has been trained in Uniform Guidance requirements as well as Federal program guidelines. This should not happen in the future.

The District agrees and has already implemented processes to ensure receivables are created with each claim created in CNIPS

Contact Person Evan Peltier Planned Corrective Action Dunseith Public School Dist. #1 will implement the recommendation from Brady Martz. Planned Completion Date The planned completion date is June 30, 2025.

Contact Person Evan Peltier Planned Corrective Action Dunseith Public School Dist. #1 will implement the recommendation from Brady Martz. Planned Completion Date The planned completion date is June 30, 2025.

Recommendation: The Organization should develop a compliance calendar that includes financial reporting deadlines and set automatic reminders in advance of each deadline to aid in properly planning and timing submission of reporting packages. Additionally, the Organization should engage the audit firm well before the fiscal year end, and the auditors should put this engagement on their calendar well in advance of the due date. The Organization should establish a timeline with the auditors that aligns with internal deadlines to ensure sufficient time to conduct the audit. The Organization’s Board of Directors should be more actively engaged in the auditing and reporting process to establish a greater degree of accountability and oversight. Anticipated Completion Date: 06/30/2025. Actions Taken: The Organization has begun implementing the above-mentioned recommendations. The Organization will ensure that it has a working compliance calendar to assist in meeting the reporting deadline. Additionally, the Organization has engaged the audit firm for their upcoming fiscal year-end, and the audit firm has put it on its calendar to begin the audit process well in advance. The Organization’s board of directors has agreed to oversee the auditing and reporting processes to a greater extent. With these actions, the Organization expects to comply with the Uniform Guidance for single audits deadline for the fiscal year end 09/30/2024. Mr. Joseph Gombo, executive director, has been designated to monitor the plan of corrective action for this finding. He can be reached at 845-371-1220. Contact Person Responsible for Corrective Action: Joseph Gombo, Executive Director

Condition: Suspension and debarment compliance was not verified for five covered transactions. Corrective Action Planned: All Purchase Order requests that are associated with a federal government grant will all have an attached list showing the company is not on the debarment list. We will also update our School Contract language to include specific wording where the Vendor acknowledges the law and forfeits the contract if they are on the debarment list after the contract has been signed. A statement will be added to the contracts that states the following: ‘The Contractor (or use the term in the contract that identifies the vendor instead of Contractor) certifies under the pains and penalties of perjury, that the Contractor is not currently debarred or suspended by the Federal government, or any of its agencies, entities or subdivisions, nor is the Contractor currently debarred or suspended by the Commonwealth Massachusetts or any of its agencies, entities or subdivisions.’ If there is a section in the contract where the vendor certifies to other conditions (i.e. state taxes paid), then this language could be included under that section as another certification requirement. A Google Drive has been created to upload all supporting documents on a yearly basis. Anticipated Completion Date: 2/17/2025 Contact: Noel Velez, Director of Finance and Fiona Maxwell, Procurement Director

Condition: The Food Service Department did not perform its verification process by the date required by the state pass-through agency. Corrective Action Planned: No applications were submitted to be verified. The school district prompted caregivers on numerous occasions to return the forms without receiving any. Anticipated Completion Date: 2/17/2025 Contact: Peter Cushing, Assistant Superintendent

Condition: Free or reduced meals applications could not be provided. The Food Service Department did not process free or reduced priced meals applications for the 2022-2023 school year. Corrective Action Planned: The School District has hired a qualified leader for the School Nutrition Program in order to comply with the requirements of this program. Additionally, the school district has enrolled all but the Brooks Elementary School as Community Eligibility Provision (CEP) sites and we are no longer required to collect these forms. At the Brooks School, these forms were sent to families from the Brooks School during the FY24 school year. Despite the efforts of the school and Food Services Director, no forms were returned to the school. Presently the forms are not required for the Brooks as the CEP eligibility requirements were reduced from 40% to 25% for determination. Anticipated Completion Date: 2/15/2025 Contact: Peter Cushing, Assistant Superintendent

Condition: Claims support could only be provided by the School for two months. For one month, support was in the form of spreadsheets with tray counts in lieu of a point-of-sale system. For the other month, the tray count spreadsheets were accompanied by reports from the point-of-sale system. The point-of-sale system reports provided did not agree to the amounts claimed for reimbursement. The tray counts did not indicate whether the meal provided was paid, free or reduced. The claims for reimbursement submitted by the School used allocation percentages derived from prior year claims when estimating amounts to be claimed as paid, free and reduced. The tray count spreadsheets for the other months could not be located by the School. Corrective Action Planned: In January 2023 DESE sent an auditor to review the Medford School Nutrition Program. Before this review, there was significantly limited oversight by the central office finance team. Almost no documents were prepared before the review as required by DESE. As a result of this audit a 58-item, 19-page Corrective Action Plan was issued to the district. A new district leader was assigned for departmental oversight. The district then had weekly meetings with DESE to address the corrective action plan, for this was the single largest CAP DESE has issued to any district of our size. Nearly $1.3 million in reimbursements were withheld from the district from approximately November 2022 through the end of the Fiscal Year. DESE issued the reimbursements with a nominal penalty during the summer of 2023. At the end of FY23, the district terminated the director of the program. We are now training several individuals in the MCPPO program for enhanced oversight. DESE forced an immediate return audit for FY24. This was an exceptional action as DESE has only rarely done this. The same reviewer attended and noted significant improvements as a result of district actions undertaken. As relates to this particular finding, the School Department has purchased and is consistently using a point of sale system for students to purchase their meals. The system is used to track all transactions. Anticipated Completion Date: 2/17/2025 Contact: Peter Cushing, Assistant Superintendent

Finding No.: 2023-006 Federal Agency: U.S. Department of Agriculture AL Program: 10.555 Child Nutrition Cluster Federal Award No.: 7GU300GUB Area: Reporting Questioned Costs: $0 Views of Auditee and Corrective Actions: GDOE agrees with the finding. GDOE submitted monthly reimbursement claims for meals and snacks served to eligible students beyond the required 60-day reporting period and did not report sub awards of $30,000 or more to the Federal Funding Accountability and Transparency Act Sub Award Reporting System (FSRS) in FY 2023. Plan of action and completion date: At the start of FY 2024, the CNP Office added personnel to the processing of claims activity. The additional personnel to the process is to ensure the requests are reviewed and processed in a timely manner before transmitting to the GDOE Business Office for reimbursement draw and payment processing. After the transmission, the CNP Office will follow-up and confirm, via email, with the assigned personnel conducting the draws, that the requested draw/payment for claims reimbursement are completed in a timely manner. In addition, the Child Nutrition Programs Office will request for confirmation from the responsible personnel within the Business Office that the required Subaward report is submitted and posted to the respective SEFA to the FSRS. Plan to monitor and responsible officials: The CNP State Administrator, Franklin Cruz, and the Comptroller will ensure that claims are submitted and processed timely.

Finding No.: 2023-004 Federal Agency: U.S. Department of Agriculture AL Program: 10.555 Child Nutrition Cluster Federal Award No.: 7GU300GUB Area: Eligibility Questioned Costs: $0 Views of Auditee and Corrective Actions: GDOE agrees with the finding. GDOE did not published School Year 2022-2023 eligibility notifications for the community eligibility provision to the GDOE website by May 1, 2023 as required by the National School Lunch Act (NSLA). GDOE Child Nutrition Program (CNP) division is aware of the requirement and has publicly posted eligibility notifications to ensure compliance to NSLA. GDOE does not anticipate this will be an audit finding moving forward. Plan of action and completion date: The CNP Office has incorporated a calendar reminder within the CNP Office and updated the internal calendar of report due dates to facilitate the timely upload of the required information to the GDOE CNP website. Plan to monitor and responsible officials: The CNP State Administrator, Franklin Cruz, will ensure that CEP eligibility notifications are posted to the GDOE website by May 1 of every year to be in compliance with the reporting requirements of the NSLA.

Corrective Action: Coastal Harvest will begin tracking all inventory on hand by source, including receipts, distributions, waste/loss, and any other adjustments, and will perform periodic reconciliations of amounts recorded in the inventory system and amounts recognized in the general ledger to ensure accurate USDA food commodities inventory recordkeeping compliance. Further, Coastal Harvest will include specific inventory policies and procedure in the manual discussed in the corrective action for finding 2022-001. Anticipated Completion Date: June 30, 2024

2023-008 Reporting Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding. The necessary reports will be filed as soon as they are available.

2023-003 Internal Control over Compliance Requirements. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has contracted with an outside firm that specializes in SBOA compliance, as well as Federal Award Compliance in line with Uniform Guidance. The firm will assist in the development of the required manuals, policies, procedures and review processes. The current estimated completion date is February 28, 2025.

2023-002 Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has contracted with an outside firm that specializes in SBOA compliance, as well as Federal Award Compliance in line with Uniform Guidance. The firm will assist in the development of the required manuals, policies, procedures and review processes. The current estimated completion date is February 28, 2025.

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

The Town and Board of Education have implemented a written policy for purchases using federal funds. This policy includes verifying that vendors have not been debarred.

The Town and the Board of Education have prepared and implemented a written policy for purchases using federal funds.