Corrective Action Plans

Allegan Public Schools 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 District Contact Person: Amy Christman, Director of Finance and Operations Finding 2024-001: Considered a significant deficiency in internal control over compliance. Recommendation: The District should consistently utilize a point-of-sale system to track and claim the number of meals served. Action to be Taken: Management agrees with the finding and had already changed procedures during the school year to better track and claim meals.

This finding is due to the District not having the proper controls in place to prevent, detect, or correct incomplete applications and incorrect eligibility guideline thresholds for the Household Application for Free and Reduced Priced School Meals. This was the first full year for the District’s new Food Service Director, and she was unaware that the income level guidelines for eligibility were not already updated in Meal Magic at the start of the school year. The District is now aware that this is a manual change that needs to be made on an annual basis prior to the start of the next school year. The District is implementing additional procedures to ensure that applications are filled out completely and that the eligibility income thresholds are updated annually before any applications are processed. The persons responsible for the corrective action are Tamie Gillespie, the Food Service Director, and Dina Schmidt, the Business Manager. The anticipated completion date of the corrective action plan is immediate. The plan for monitoring adherence is the Food Service Director will ensure that eligibility income level guidelines are properly input each year and monitor each application to ensure they are complete.

Auditor Description of Condition and Effect. One of three meal claim reimbursement reports selected for testing did not agree to underlying meal count sheets. On the one report that did not agree, the District understated claims for all of its facilities. As a result of this condition, the District submitted inaccurate claims for reimbursement, resulting in a reimbursement less than what the District should have received. Auditor recommendation. We recommend that the District implement a thorough review process of entered data prior to certification of claims data. We also recommend that a secondary review of claims data be done by a District finance department staff to ensure proper claims data. Corrective Action. The District will implement a thorough review process of entered data prior to certification of claims data. The District will also implement a secondary review of claims data that will be done by a District finance department staff to ensure proper claims data. Responsible Person. Gail Enders, Finance Director Anticipated Completion Date. June 30, 2025

Auditor Description of Condition and Effect. Throughout the year journal entries were posted without independent approval. As a result of this condition, the District is exposed to an increased risk that misstatements or misappropriations might occur and not be detected by management in a timely manner. Auditor Recommendation. We recommend that the District's journal entries be independently reviewed, signed and dated, as evidence of this control. Corrective Action. The District will implement a new procedure to ensure each journal entry goes through a review process before being posted. Responsible Person. Gail Enders, Finance Director Anticipated Completion Date. June 30, 2025

October 11, 2024 10.553, 10.555, 10.559 - Child Nutrition Cluster 2024-001 Net Cash Resources Corrective Action Plan: The School District will review cafeteria operations throughout 2024-25 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, 2025. Contact Information Michael Pavlovich, Director of Operations and Finance Chenango Forks Central School District 1 Gordon Drive Binghamton, New York 13901

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

Finding Number: 2024-001. Responsible Person:Daniel Kuk, Food Service Director. Management View: Management agrees with the finding and is in the process of implementing the recommendation. Corrective Action: The District has already changed its meal reimbursement process to use data from Meal Magic to submit the meal claim reports. Anticipated Completion Date: Immediate Implementation.

The District will review the requirements of 2 CFR Section 200.213 and ensure that procurement procedures are being followed and perform a review of the eligibility of potential vendors to ensure they are eligible to participate in Federal assistance programs.

2024-004 FINDING Contact Person – Dave Kerkvliet, Superintendent Corrective Action Plan – The District will begin reviewing and approving reports prior to submission for reimbursement. Completion Date – November 1, 2024

Corrective Action Plan School District management agrees with condition, cause, and recommendation. With this overage, the School District has purchased some new equipment for the cafeteria. Since the School District is CEP, there is no option to change the revenue. The School District will continue upgrading the kitchens with the excess. Expected Correction Date: June 30, 2025 Contact: Kathy Rote, School Business Administrator (607) 565-2841 15 Frederick St. Waverly, NY 14892

The Food Service Director will coordinate the on-site monitoring reviews and its completion to Michigan Department of Education standards, and make sure the required forms are completed before deadlines. Contact person responsible for corrective action: Darlene, Food Service Director Anticipated Completion Date: 02/01/2025

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 2023-24 school year, the district reviewed the program’s needs to develop a strategy to utilize these funds by the food service program to coincide with the capital project approved by the voters in December of 2022. To date, the District has purchased and installed multiple equipment items by the Cafeteria Fund totaling over $189,000. Along with these purchases the district has ordered and is in the process of receiving and installing an additional $125,000 of equipment including new serving line stations. Estimated Completion Date: June 30, 2025 Contact Information Jennifer Dattoria, School Business Executive Susquehanna Valley Central School District 1040 Conklin Road Conklin, New York 13748

2024-003 Child Nutrition Cluster – Assistance Listing No. 10.CNC Recommendation: CLA recommends the District designate an individual to review student lunch statuses. Having an appropriate reviewer over student status is intended to prevent, detect, and correct a potential error in the food service system. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: Management will designate an individual to review student lunch statuses. Name of the contact person responsible for corrective action: Kathy Stankewicz, Business Manager Planned completion date for corrective action plan: June 30, 2025

Condition: The School District did not complete an on-site monitoring review for one building operating a school lunch program during the year ended June 30, 2024. Corrective Steps Taken: At this time, there have been some corrective steps taken to limit this from happening again which includes the Food Service Director better familiarizing herself with MDE’s requirements for on-site reviews. Corrective Steps to be Taken: The Food Service Director will coordinate the on-site monitoring reviews and its completion to Michigan Department of Education requirements. Monitoring: The plan for monitoring adherence is for the Superintendent to check in with he Food Service Director prior to the February 1st deadline to ensure all required on-site reviews were performed. Name of Responsible Person for Further Information: Tami Eisenga, Food Service Director and Scott Akom, Superintendent. Questioned Costs Related to this Finding: None.

Condition: The School District does not currently have a control in place whereby a review of the meal counts entered into the Michigan Nutrition Data (MiND) system takes place, which could result in an 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 Business Office has implemented a formalized internal control procedure for the Food Service Department to adhere, alongside performing a thorough review of the monthly claims reimbursement submission. The formalized internal control procedure will accompany the supporting documentation submitted to the Business Office monthly (Attachment A). The procedure involves a review of inputted meal counts, prior to the claim submission. The Food Service Department Administrator responsible for meal claim input will provide corroboration of input accuracy, as documented by signoff from a secondary reviewer. In addition, the Business Office has prepared a Meal Claim Check Tool spreadsheet to utilize, on a monthly basis, as another layer of validation. The Meal Claim Check Tool spreadsheet allows the Business Office to input meal count figures from the Food Service POS system report and compare against the figures from the claims submission report. Any discrepancy identified would be immediately addressed with the Food Service Department and would require an amended claim submission. Contact person responsible for corrective action: Danielle Jacobs, Director of Business Services Anticipated Completion Date: 08/01/2024

Finding No.: 2023-011 AL Programs: COVID-19 10.542 – Pandemic EBT Food Benefits (P-EBT) Area: Eligibility Questioned Costs: $16,635 Contact Person(s): Margaret Aldan, NAP Administrator Corrective Action Plan: Condition 1-2: The CNMI NAP agrees with the auditor’s finding and conclusions. The issues occurred because CNMI NAP lacked effective monitoring controls and systematic filing procedures over eligibility Finding No.: 2023-011, continued AL Programs: COVID-19 10.542 – Pandemic EBT Food Benefits (P-EBT) Area: Eligibility Questioned Costs: $16,635 Contact Person(s): Margaret Aldan, NAP Administrator Corrective Action Plan: determinations, attendance data verification, documentation retention, and reconciliation of data received from the Public School System. To prevent recurrence, the CNMI NAP will perform the following: • Develop and implement written standard operating procedures for eligibility verification, attendance data review, benefit computation, and documentation retention. • Create and implement a centralized electronic filing system for all eligibility supporting documents. • Establish monthly reconciliation procedures between PSS data and NAP eligibility records. • Conduct quarterly internal case file reviews (minimum 10% sample) to ensure completeness and accuracy. • Provide refresher training to all NAP eligibility and fiscal staff on the new procedures. Proposed Completion Date: September 30, 2026

Finding No.: 2023-005 AL Program: 10.555 National School Lunch Program (NSLP) Area: Reporting Questioned Costs: $-0- Views of Auditee and Corrective Action Plan: Management’s Position: PSS Management concurs with the findings. Financial and Grants Management procedures were promulgated in a SOP on September 18, 2024. The financial management system was subsequently changed to Tyler Munis to conform with CNMI central government requirements which will enhance capabilities. The SOPs and the Tyler Munis implementation are under review by an external consultant and recommendations made to improve coding of grant details and expenditures, increased frequency of reconciliations, and a specific SOP for report preparation. Corrective Action Plan: I. Implementation of a Comprehensive Grant Tracker: PSS will develop and implement a centralized Grant Lifecycle Tracker for all active federal awards. This tool will serve as the primary monitoring mechanism for compliance by recording all financial and programmatic reporting due dates, assigning specific preparers for each report, and establishing automated milestones to ensure sufficient lead time for both the preparation phase and the subsequent supervisory review. II. Deployment of Enhanced Data Analysis Tools: To ensure that quarterly program reporting is both consistent and timely, PSS will develop and implement specialized data analysis tools. these tools will streamline the aggregation of program data, reducing manual entry errors and allowing for more efficient evaluation of program performance against federal benchmarks. Proposed Completion Date: In progress for FY 2024 with completion by August 2026. Name of Contact Person and Title: Contact: Jacqueline Che, Federal Programs Officer Email Address: jacqueline.che@cnmipss.org

Finding No.: 2023-003 AL Program: 10.555 National School Lunch Program (NSLP) Area: Allowable Costs/Cost Principles Questioned Costs: $-0- Views of Auditee and Corrective Action Plan: Management’s Position: PSS Management concurs with the findings. Financial and Grants Management policies procedures were promulgated in SOPs on September 18, 2024. The financial management system was subsequently changed to Tyler Munis to conform with CNMI central government requirements which will enhance capabilities. The SOPs and the Tyler Munis implementation are under review by an external consultant and recommendations made to improve documentation of cost allowability have been received. Corrective Action Plan: I. Finalization of Allowability and Disbursement SOPs: PSS will finalize comprehensive Standard Operating Procedures (SOPs) and policies specifically governing allowability determinations and vendor payments. II. Enhanced Disbursement Controls: PSS is implementing a documented review and approval controls over the payment process. Before any check or ACH disbursement is finalized, a reviewer must verify that the payment amount agrees exactly with the approved invoice. This verification will be physically or digitally documented on the payment voucher to provide a clear audit trail of the pre-payment review. Proposed Completion Date: In progress for FY 2024 with full implementation and documentation processes expected to be completed in 2026. As part of this improvement, we are designing a standardized, documented review process to ensure all disbursements are verified against approved invoices prior to payment. Name of Contact Person and Title: Contact: Jonathan Aguon, Director of Finance Email Address: jonathan.aguon@cnmipss.org

Corrective Action Plan Details: A. Contact person responsible for corrective action: Name: Alicia Smith Title: Chief Financial Officer B. Description of corrective action planned: The district will strengthen its internal control systems over reporting to ensure single audit reporting package and data collection form are submitted to the Federal Audit Clearinghouse within established timeframe and financial statements are prepared timely. C. Anticipated completion date of corrective action: Immediately

Responsible Parties: Erik Estill and Russell Raney Finding: The child nutrition program cumulative net cash resources as of September 30, 2023, totaled $401,854 which exceeded the 3-month net cash resource limit by $261,641. Corrective Action: The child nutrition program accumulated a large net cash resource balance during the COVID pandemic and the USDA extension of the seamless summer feeding program. During the ALSDE review of the FY 2024 financial statement submission and the required CNP financial profile submission, the school was notified of the net cash resource balance and was required to submit a detailed spenddown plan to bring net cash resources under the 3-month limit. The spend-down plan was approved by the ALSDE, and the school is currently operating under the plan. The spend-down plan was revised by the school, reviewed and approved by the ALSDE in conjunction with the FY 2025 financial statement submission. Expected Completion Date: August 4, 2025

Responsible Parties: Erik Estill and Russell Raney Finding: Due to the passage of time, the turnover of staff, and the use of a third-party payroll provider, supporting documentation necessary to verify and document vendor payments and payroll transactions was not available, resulting in the inability to obtain sufficient, appropriate audit evidence related to these amounts. Corrective Action: The school (LEAD Academy) contracted with New Schools for Alabama (NSFA) during 2023 to handle all their finance and accounting needs. By the end of 2023, the school also transitioned all payroll services to New Schools for Alabama. Prior to 2024, a third-party vendor was handling/processing payroll for LEAD Academy. Additionally, procedures were not in place to maintain monthly payroll data (timesheets, leave balances, documentation of annual salaries) prior to 2024. All financial records are now maintained digitally, with the original documents residing at the school. Additionally, NSFA worked with existing staff regarding proper documentation and filing of financial records and helped establish a new filing system. In 2024, payroll processing for the school was transitioned to NSFA, utilizing the state approved accounting/payroll software. Monthly procedures are now in place for the submission, approval and documentation of all payroll transactions. Expected Completion Date: September 30, 2024

2023-003 SCDA Special Tests Significant Deficiency and Non-Material Noncompliance Corrective Action: We've hired competent staff that understand how to reconcile inventory to the general ledger. Person Responsible: Stephano Blake Email: S8lake@harvesthope.org Phone: 803-636-6635

The Division will ensure the documentation related to inventory counts are maintained. September 2026 Al Agpoon, Golden State Division Controller

2022-005 Contact Person Jackie Cordie, Business Manager Corrective Action Plan The District plans to implement the auditor's recommendation. Planned Completion Date for CAP Fiscal year beginning July 1, 2026

VIDE acknowledges the audit finding regarding the Child Nutrition Cluster Period of Performance and concurs with the recommendation. We recognize that while the cost was incurred during the valid period, the liquidation payment occurred 18 days past the allowable deadline. To prevent recurrence, VIDE will enforce strict protocols for grant closeout and liquidation. To achieve this, VIDE will establish an internal hard stop deadline for invoice submission, requiring that all invoices for expiring grants be submitted to the Fiscal Office no later than 45 days prior to the federal liquidation deadline to provide a necessary buffer to resolve vendor disputes and process payments before the federal cutoff. Additionally, the State Director of Special Nutrition Programs will implement a scheduled notification system to issue closeout alerts to relevant program staff and fiscal support personnel at 90, 60, and 30 days prior to the liquidation deadline, which will trigger the immediate review of open encumbrances and the expediting of pending invoices to ensure the internal hard stop deadline is met. Furthermore, for any valid expenditures remaining unpaid within 30 days of the liquidation deadline, the Fiscal Office will generate a priority payment list and transmit it to the Department of Finance with a high-priority flag to ensure these specific vouchers are processed before the grant period closes. Finally, the Federal Grants Director and the Deputy Commissioner of Fiscal and Administrative Services will review the Grant Expiration Report monthly to identify grants approaching their liquidation deadline and ensure the internal cut-off dates are being adhered to.