Corrective Action Plans

Views of the Responsible Officials and Planned Corrective Actions: The Business Administrator will work closely with the new Food Service Director to verify and record any company/vendor that is paid with Federal money.

The District will monitor vendors to ensure they are able to accept federal monies. By Ashley Simmons, Accounts Payable clerk by 6/30/2024.

Finding: 2023-001 – Reporting – Meal Claim Reimbursement Noncompliance Auditor Description of Condition and Effect. Two of three meal claim reimbursement reports selected for testing did not agree to underlying meal count sheets and on all three reports tested, the District understated claims for one 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 thoroughly review its monthly reports to count sheets and familiarize itself with allowable reimbursement claims. Corrective Action. Management concurs with finding. The District will utilize a thorough review of entered data prior to certification of claims data. A secondary review of claims data will be reviewed by a District finance department staff to ensure proper claims data. Responsible Person: Emili Jones, Director of Business and Finance Anticipated Completion Date: November 1, 2023

Condition: During the testing of internal controls surrounding the child nutrition program claims reimbursement reporting, it was identified that review of the meal counts and monthly claims reports is not taking place. Planned Corrective Action: The 2022-23 school year returned to students having to pay for their school meals since COVID. The district had a FS bookkeeper who was hired in the spring of 2020. The 2022-23 school year was her first-time filing school meal claims based on if students were free, reduced, or full pay. She started by exporting student counts from Skyward then adjusting them for GSRP and Heartwood student meal claims. Since this was a manual process, a few errors occurred. This FS bookkeeper resigned in the spring of 2023. The district hired a new FS Bookkeeper. She will be exporting the count information directly from Skyward, then using an Excel spreadsheet to adjust for GSRP and Heartwood students. The FS Bookkeeper will enter the counts into School Meal Claims website. The counts will be reviewed by the FS Director who will complete the actual submission of the meal claims. The entire process will be audited by the district accountant monthly. Contact person responsible for corrective action: Tracey Wooden, CFO Anticipated Completion Date: 07/12/2023

Child Nutrition Cluster - Assistance Listing nos. 10.553 and 10.555 Recommendation: CLA recommends the District review and update policies and procedures over review of certain transactions to ensure that all federal grants with covered transaction have vendors reviewed for suspension and debarment status. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: All food service vendors will be checked for suspension and debarment on the Sam.gov website. Name(s) of the contact person(s) responsible for corrective action: Morgan Mueller, Bookkeeper Planned completion date for corrective action plan: July 1st 2023

Condition: In a population of 3 error prone applications selected for verification, exceptions were noted on 1 of the applications selected for verification. The 1 verification documentation received determined the student should be changed from reduced lunch to paid lunch and this change was not made. Plan: Management will review and implement procedures to ensure the free or reduced lunch status is properly updated during the application verification process. Anticipated Date of Completion: 6/30/2024 Name of Contact Person: LeeAnn Taylor, Assistant Superintendent of Finance & Business Operations Management Response: N/A

Condition: The determining official did not complete the form and did not sign the form for all applications selected. Plan: Management will review and implement procedures to ensure the verification forms are completed correctly. Anticipated Date of Completion: 6/30/2024 Name of Contact Person: LeeAnn Taylor, Assistant Superintendent of Finance & Business Operations Management Response: N/A

Material Weakness, Internal Control over Compliance Personnel Responsible for Corrective Action: Julie Whitmore, Director of Nutrition Services and Leon Hanhardt, Superintendent of Schools Anticipated Completion Date: June 30, 2024 Corrective Action Plan: The District will document the review of a sampling of eligibility determinations for program participants.

2023-002 - Child Nutrition Cluster - Special Tests and Provisions - Verification Condition Of the six households selected for testing of verification compliance, two were found to have been incorrectly calculated as being eligible for reduced price meals. Recommendation We recommend that the District review its controls related to verification in order to ensure that only eligible households receive free or reduced price meals. Comment on the Finding Recommendation The District is aware of the errors and has taken extra care with the verifications completed for the ongoing school year. Action Taken Kristy Alvord and Cindy Clark attended training in the Fall of 2023 that was conducted by the Kansas State Department of Education, regarding verification compliance. In addition, all verification calculations will be double-checked by a staff member who did not perform the initial calculation.

SIGNIFICANT DEFICIENCIES 2023-001 - Child Nutrition Cluster - Allowable Activities and Costs/Cost Principles and Reporting Condition During testing of the sponsor claim reimbursement reports, it was found that the District submitted inaccurate meal counts on two monthly reports. Recommendation We recommend that the District review its controls related to monthly reimbursement requests for the Child Nutrition Cluster in order to ensure that accurate meal counts are submitted. Comment on the Finding Recommendation The District is aware of the errors and will continue to strive to improve its processes and controls related to meal counts. Action Taken As of the date of this notice, staff members involved in recording manual meal counts for the Summer Food Service Program and Afterschool Snack Program have undergone training regarding the importance of submitting accurate numbers. In addition, meal counts are now required to be summed twice, in order to ensure that there are no calculation errors.

U.S. Department of Agriculture 2023-002 Child Nutrition Reporting Child Nutrition Cluster – Assistance Listing No. 10.553, 10.555, 10.559 Recommendation: CLA recommends the District implement a review procedure over reimbursement requests where someone other than the preparer reviews the claim to ensure counts agree back to supporting documentation prior to the reimbursement request being filed with the granting agency. In addition, due to the size and complexity of the reporting, we recommend the District review the compiling procedures for the schools to ensure the compilation procedure is complete and accurate. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The district is implementing an internal cross check procedure to prevent errors on future claims. Name(s) of the contact person(s) responsible for corrective action: Dr. Thomas Owens Planned completion date for corrective action plan: Ongoing.

Internal Controls over distribution of USDA Foods to recipients (Material Weakness) Response and Corrective Action Plan: In addition to strides made in FY23 towards correcting the documentation of recipients in Link2Feed, Brown Bag has continued to address it in FY24 by performing the following- 1) Build communication and relationships with the remaining sites still not documenting (16 of our current 77) 2) Issued emails and phone calls asking sites to update their records. 3) Making appointments and visiting all sites still not in compliance to make an in-person plea to comply. 4) As of November 1, issue written communications warning any remaining sites that food deliveries will cease at the end of the year for any remaining sites not in compliance. No exceptions. Participants will be invited to go to the closest open MBBP site in their area. 5) Management is actively trying to close the loop on the remaining MOU’s, including SAHA, which remains unsigned. Deliveries will cease to any sites not covered with an MOU at the end of calendar year. No exceptions. Responsible Person: Janice Roberts, Program Director, under the oversight of the Mercy Executive Director. Estimated Completion Date: July 1, 2023

Internal Controls over inventory management (Material Weakness) Response and Corrective Action Plan: The impact of COVID on the Mercy Brown Bag program's execution and associated inventory documentation was significant. It necessitated the restructuring of historical food distribution practices with recipients and the increase in food provided through the TEFAP program. Priority was given to distributing food to recipients, despite limited staffing caused by the increased operational workload and social distancing requirements. Starting in FY23, the program management initiated semi-annual inventory counts, which will continue into FY24 and beyond. Additionally, an Inventory Management System was implemented at the end of FY23 and will be used throughout FY24, starting on July 1, 2023. Responsible Person: Janice Roberts, Program Director, under the oversight of the Mercy Executive Director. Estimated Completion Date: July 1, 2023

2023-004 Material weakness in internal control over compliance and compliance for suspension and debarment Recommendation: We recommend the District ensure that this suspension and debarment verification occurs before entering covered transactions and that supporting documentation of this internal control is retained. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The District will work with their departments utilizing federal dollars to ensure the proper suspension and debarment verification is performed for all covered transactions and that the process is well documented. Name(s) of the contact person(s) responsible for corrective action: Paul Bourgeois, Executive Director of Finance and Operations. Planned completion date for corrective action plan: June 30, 2024.

District is in the process of establishing procedures and controls by the Business Manager to oversee the retention of verification documentation and information obtained through the verification process.

Date 09/22/2023 Finding 2023-001 Federal Agency Name: U.S. Department of Agriculture (USDA) Program Name: Child Nutrition Program Cluster Assistance Listing # (10.553,10.555,10.559) Finding Summary The procurement of Shamrock Foods during August of 2022 was not presented to and approved by the Board as required by the District’s procurement policies. Total purchases were $419,154 during fiscal year 2023. Response from Kuna School District The districts followed the RFP bid process as outlined in CRF 200 and the Idaho Code. Shamrock Foods was the only company that responded to the RFP, and they are known as the sole vendor in the area with this capability. The Kuna School District acknowledges that the final internal step, a second presentation to the board, did not occur. In reviewing the process, the district identified the cause as a change in personnel with authority over the program. In response, the School District has added a new layer of control. Now, when different departments engage in procurement, they will go through the business department. Afterward, they must submit all approved contracts to the business department, along with a detailed completed checklist of the entire procurement process. Additionally, it will be mandatory to include all supporting documents with the contract. Anticipated Completion Date: September -October 2023: additional procurement training. Effective November 2023, it will be mandatory to include all supporting documents with the contract. The contact person responsible for implementation of the corrective action plan: Elmira Feather, CFO.

2023-001 Eligibility for Teacher and Principal Training and Recruiting Fund Federal program: ALN 84.367 Teacher and Principal Training and Recruiting Fund Federal agency: U.S. Department of Education Pass-through entity: Colorado Department of Education Criteria: An LEA applies to the SEA for program funding and the amount of the LEA’s allocation that the SEA provides is based on the poverty measure that is reported to the SEA. In this case the District used free and reduced lunch counts to as the poverty measure to report to the SEA. Condition: While we believe the District accurately reported the poverty measure to the SEA, the District was unable to timely provide supporting schedules that tied back to the data reported to the SEA. Management Response and Planned Corrective Actions Criteria: Management agrees with this finding and is working on implementing a verification and reconciliation process and will ensure that future reports are maintained at the time of reporting. Responsibility for Corrective Action: Heidi Anderson, CFO Anticipated Completion Date: Fall 2023

The District agrees with the finding and will work with TDA to develop a plan to spend the excess fund balance on approved NSBLP expenditures, and maintain an appropriate amount of fund balance in the future.

Method of Implementation - School District personnel will continue to work closely with the Food Service Director to determine the needs of the District in an effort to reduce year end net cash resources. Person Responsible - Director of Food Servcies; Assistant Business Administrator; and Business Administrator/Board Secretary. Implementation Dates - June 30, 2024

The Selinsgrove Area School District respectfully submits the following corrective action plan for the year ended June 30, 2023. The findings from the Single Audit Report Year Ended June 30, 2023 included in the schedule of findings and questioned costs are discussed below. Finding 2023-0001: Activities Allowed. Contact Person: Jeff Hummel, Business Manager. Recommendation: The District should follow its established internal control procedures over activities allowed requirements. Action: The District will continue to review its internal control procedures over disbursements and increase its usage of the financial accounting system to aid in the management of the approval process prior to disbursements. Date for Completion: June 30, 2024.

Condition: The District submitted claims for meal reimbursements that were higher than the meals actually served. Plan: Management will review and implement procedures to ensure the reports used for daily counts match the reports used for submitting the claim to ISBE. Anticipated Date of Completion: 6/30/2024 Name of Contact Person: Annie Mulvaney, Assistant Superintendent Management Response: N/A

1. Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. 2. Actions Planned in Response to Finding The Academy will evaluate current procedures for accurately monitoring, recording, and reporting the number and type of meals served. Current practices will be revised to ensure proper documentation is retained supporting all future reports submitted to the State. 3. Official Responsible Samuel Yigzaw, Executive Director, is the official responsible for ensuring corrective action. 4. Planned Completion Date June 30, 2024 5. Plan to Monitor Completion The Board of Education will be monitoring this Corrective Action Plan.

Nutrition Cluster – CFDA Nos. 10.553 and 10.555 Significant Deficiency: See Finding 2023-002

Nutrition Cluster – CFDA Nos. 10.553 and 10.555 Name of contact person – David Gates, Business Manager Recommendation: We recommend the Food Service Director more closely review all meal count information entered for reimbursement prior to submitting each monthly claim to ensure accuracy and consistency with supporting documentation. We recommend that the Food Service Director review all monthly claims filed in fiscal year 2023-24 available for revisions to ensure reports were accurately filed. Further, we recommend that District management periodically monitor claim submissions for accuracy. Action Taken: Management agrees with the recommendations. The Food Service Director has reviewed all monthly claims submitted in school year 2023-24 and found no errors requiring revision. Further, management will implement a plan to periodically review claim submissions for accuracy. Proposed Completion Date: January 31, 2024

CORRECTIVE ACTION PLAN The County of Bedford, Virginia respectfully submits the following corrective action plan for the year ended June 30, 2023. Name and address of independent public accounting firm: Brown, Edwards & Company, L.L.P. 828 Main Street, Suite 1401 Lynchburg, Virginia 24501 The findings from the June 30, 2023, Schedule of Findings and Questioned Costs are discussed below. The findings are numbered consistently with the numbers assigned in the Schedule. Finding 2023-001: Supplemental Nutrition Assistance Program – AL# 10.561; Child Nutrition Cluster – AL#10.553, 10.555, 10.559; Coronavirus State and Local Fiscal Recovery Fund – AL# 21.027; Title I Grants to Local Educational Agencies – AL# 84.010; Education Stabilization Fund – AL# 84.425C, 84.425D, 84.425U; Temporary Assistance for Needy Families – AL# 93.558; Medical Assistance Program – AL# 93.778; Late Filing of Data Collection Form Condition: The County did not file the data collection form for the year ended June 30, 2022 timely. Criteria: Under the requirements in the Uniform Guidance and the Office of Management and Budget (OMB), all entities are required to file the annual data collection form with the Federal Audit Clearinghouse the earlier of either 30 days after the issuance of the entity’s annual audit or twelve months after the entity’s fiscal year end (June 30th for the County of Bedford). Cause: Management did not complete and certify auditee portion of the form before the deadline. The form was not completed until June 14, 2023. Effect: The entity’s form was submitted to the Federal Audit Clearinghouse late, delaying completion of all annual audit requirements for the County. Recommendation: Management should take steps to ensure that the form is filed timely. Views of Responsible Officials and Planned Corrective Action: Response The data collection form for the year ended June 30, 2022, was not filed timely. This late filing was due to the 2022 audit being completed late because of significant staff turnover. Management has since filled vacant positions, added one position, and restructured the department to help with staff workload. The June 30, 2023, audit will be completed timely and should result in a timely filing of the June 30, 2023 data collection form. Contact Person I, Ashley Anderson, am responsible for this corrective plan. Please contact me at (540) 586-7729 x. 1303 or aanderson@bedfordcountyva.gov if you have any questions. Thank you. Sincerely, Ashley Anderson, MAcc, CPA Director of Finance County of Bedford, Virginia