Corrective Action Plans

All paper application will be organized, filed, and stored in the Food Service office/storage for review and auditing needs.

Our current DFN will attend both the Food Service Management Company (FSMC) annual training and ODEW’s provided state training on school meal applications.  All paper application will be organized, filed, and stored in the Food Service office/storage for review and auditing needs. Online/electronical applications will be held on the SFA server and detailed reports will be printed, organized, and stored with manual versions.

Audit Reference: 23-002 Non-Compliance Issue: lack of confirming signature on free/reduced applications. Applications must be confirmed by the confirming official listed on the Free & Reduced Price Meals Policy submitted to ESE. Root Cause Analysis: All applications were not printed and signed by confirming official. Corrective Action(s): Printing and signing all applications as they come in including online applications. 2. Action Item: o Description: Setting plans in place to make sure all applications are signed as printed or passed in and making sure that all signed applications are passed in to auditor not electronic copies. o Responsible Person/Department: Christina Poquette o Expected Completion Date: On going Name: Christina Poquette Title: Director of Food and Nutrition Signature: Date: 5/20/2024 Acknowledgement by Responsible Parties: Name: Title: Signature: Date: 5/20/2024

Organization Name: Sutton Public Schools Address: 16 Putnam Hill Rd Sutton MA 01590 Issue Date: 05/20/2024 Audit Reference: 23-001 Non-Compliance Issue: verification process not completed during school year 22-23 Root Cause Analysis: This was caused by lack of knowledge due to manager change over with no overlap and managers starting date after verification completion deadline. Corrective Action(s): In planning for next school year, it has been set as a calendar reminder for October 1st to start the verification process with weekly goals set as to what needs to be done each week. As well as a reminder set for November 15th to make sure verification paperwork is submitted prior to the due date of November 17th. 1. Action Item: o Description: Set plans and calendar reminders in place to ensure the verification process is start prior to the end of September and that all is completed to be completed accurately before due date o Responsible Person/Department: Christina Poquette o Expected Completion Date:10/17/2024 Name: Christina Poquette Title: Director of Food and Nutrition Signature: Date: 5/20/2024 Acknowledgement by Responsible Parties: Name: Title: Signature: Date:5/20/2024 Organization Name: Sutton Public Schools Address: 16 Putnam Hill Rd Sutton MA 01590 Issue Date: 05/20/2024

Audit Finding Reference: 2023-004 Excess Food Service Fund Balance Management's View and Planned Corrective Action: Management agrees that the Food Service Fund Balance needs to be reduced The Department of Education in FY2023 they did not require a spend down plan for the application. With that said we currently have a spend down plan in place to reduce the fund balance to a more appropriate fund balance and to meet the regulation. The spend down plan was submitted in March 2024. Name of Contact Person and Completion Date: Name 1 Amber Wheeler Name 2 Danielle Rossetti Anticipated Completion Date - December 31, 2024

Finding ref number: 2023-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with federal allowable activities and allowable costs requirements. Name, address, and telephone of District contact person: Cindy Feng, Controller 5150 220th Avenue S.E. Issaquah, WA 98029 (425)837-7139 Corrective action the auditee plans to take in response to the finding: The District used SCA funds to pay a vendor for locally produced dairy products for our schools that complied with the funding requirements. Invoices from the vendor show the total amount for each delivery but did not include item level details. With each delivery, a packing slip was provided to the Food Services Department staff members to confirm the receipt of approved items and reconcile for invoice approval. Once invoices were reconciled and properly approved with a signature indicating review, the District used the official invoice statement for payment processing and the delivery packing slip was no longer retained. To assist with the audit, the District provided auditors with the dairy vendor contract, vendor invoice statements, and an attestation letter from vendor stating the items purchased Issaquah School District 5150 220ᵗʰ Ave SE, Issaquah, WA 98029 phone: (425) 837-7000 https://www.isd411.org Page 64 Office of the Washington State Auditor sao.wa.gov conformed to the SCA item list. Unfortunately, these documents were deemed insufficient to allow SAO re-performing our internal controls to test its effectiveness. After SAO communicated the necessity for delivery packing slips in their testing, the District enhanced our current practice and began retaining all packing slips to support SAO’s internal control effectiveness review. We welcome any feedback to further strengthen our overall financial management practices moving forward. Anticipated date to complete the corrective action: June 2024

Corrective Action Required by The Board - The School District was not in compliance with CFR section 210.14 which requires that the net cash resources in the food service fund to be below its three month average expenditures at year end. Recommendation Number Corrective Action Required by The Board - The responsible officials are in agreement with the calculation. COVID's financial impact on the food service fund and ultimately the food service reserves has created this inflated financial position. We will use these funds to continue to invest in our food service equipment as well as upgrade our food options and meal quality, within USDA regulations.

The District will review the CNIPS report going forward and maintain the necessary supporting documentation of approvals.

A. Name of contact person responsible for corrective action: Dr. Matilda Miller, Business Manager B. Corrective action planned: The District will implement controls and procedures to ensure that all expenditures are reasonable and necessary for proper and efficient performance and administration of the Child Nutrition Cluster. C. Anticipated completion date: Immediately

A. Name of contact person responsible for corrective action: Dr. Matilda Miller, Business Manager B. Corrective action planned: The District will implement controls and procedures to ensure that all expenditures are reasonable and necessary for proper and efficient performance and administration of the Child Nutrition Cluster. C. Anticipated completion date: Immediately

We will implement a review process to confirm all corrections before submitting claims for reimbursement. This will ensure compliance with the 60-day claim submission requirement and accurate record-keeping, guarenteeing that Program funds are spent soley on allowable Child Nutrition Program costs.

CONDITION: The District did not maintain a general ledger system of accounting for its Cafeteria Fund which reports the financial activity of the federal National School Lunch and School Breakfast Programs. The financial activity occurring in this Fund is maintained in checkbook fashion during the fiscal year. This is a repeat finding (2022-004) from the previous fiscal year. CRITERIA: Prudent internal control over accounting for federal program funds requires non-federal organizations such as the School District to maintain financial records which account for federal funds in such a manner as to be able to properly track the receipt and use of federal funds as stated in Section 2 CFR Part 200 of the Uniform Guidance. Best practices suggest that the use of a general ledger system of accounting would enable the District to aggregate financial information involving federal funds during the fiscal year in such a manner to properly manage, monitor, and report the financial activity in compliance with federal program guidelines. RECOMMENDATION: The District’s accounting software can readily account for the financial activity of all Funds in a manner like the District’s General Fund. I am recommending that the management of the School District utilize the accounting software to enter the financial activity (Receipts and Disbursements) of the Cafeteria Fund in a manner like the General Fund. This procedure will significantly enhance the District-wide internal controls over financial reporting for the Cafeteria Fund, as well as provide management the ability to produce meaningful financial reports reflecting the activity in the Cafeteria Fund for prudent oversight by the Board of Education. In addition, this procedure will enable the District to comply with the recordkeeping requirements for federal funds as specified in Section 2 CFR Part 200 of the Uniform Guidance. MANAGEMENT’S CORRECTIVE ACTION PLAN: District management is reviewing its current system of processing the transactions for the Cafeteria Fund to determine the most efficient and effective manner for implementation of a general ledger system of accounting for this Fund as opposed to its current manual process. It is anticipated that the conversion of this Fund into the District’s accounting software can be completed during the 2024-2025 fiscal year to enable the District to comply with the recordkeeping requirements for federal funds as specified in 2 CFR Part 200 of the Uniform Guidance.

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

Corrective Action Plan: Testing of procurement, suspension, and debarment was accomplished timely in most cases and leadership will continue to engage and teach agency staff to follow existing procurement policies to assure compliance. No further policy is necessary. Staff training will be strengthened. Responsible Individuals: Dr. Kenneth D. Varble – Vice President of Accounting Anticipated Completion Date: December 2024

Corrective Action Plan: Review and approval of invoices, meal count sheets, and reimbursement requests will be more closely monitored, and leadership will continue to engage and teach agency staff to follow existing policies to assure compliance. No further policy revisions are necessary. Staff training will be strengthened. Responsible Individuals: Dr. Kenneth D. Varble – Vice President of Accounting Anticipated Completion Date: December 2024

Corrective Action Plan: Material adjustments were related to funds that were not clearly identified as Federal Funds that came to use from State agencies. States have a responsibility to indicate when they are providing pass-thru funding from federal sources. No further action deemed appropriate by Nexus leadership. Responsible Individuals: Dr. Kenneth D. Varble – Vice President of Accounting Anticipated Completion Date: December 2024

Contact Person Rhonda Zastoupil, Business Manager Planned Corrective Action The Business Manager will review the monthly reimbursement reports and supporting data prepared by Business Office staff for accuracy and sign off on the reimbursement request prior to submittal to the Department of Public Instruction. Planned Completion Date Immediately

FINDING 2023 -003: Audit Report Deadline Response: The District does not feel this will be an issue going forward as the prior auditor was only one person and was a bit overwhelmed with his work load.

This has been resolved.

FINDING 2023-001 – Significant Deficiency in Internal Control over Compliance – Reporting Description of Finding: Controls should be in place to ensure the accuracy of reporting submitted for federal awards programs with proper supporting documentation to agree to the reports being submitted to the Department of Education. As part of the recordkeeping process, each month’s claim for reimbursement and all data used in the claims review process must be maintained on file. Of the eleven monthly claims reports reviewed during the audit, the supporting documentation for one of the claims (April 2023) could not be located. Statement of Concurrence or Nonconcurrence: The Town agrees with this finding. Corrective Action: The Town agrees with the finding and has implemented internal controls to ensure the supporting documentation for each monthly claim are filed and maintained. Each month the monthly claims reports and supporting documentation will be filed away in a designated secure location with a checklist by month to confirm processing. Name of Contact Person: Cynthia Varricchio, MBA, Director of Finance and School Business Operations. Projected Completion Date: June 30, 2024

Federal Agency Review *Significant Deficiency in Internal Controls over Compliance; Noncompliance Federal Program - CFDA 10.555 – National School Lunch Program ASDOE School Lunch Program (SLP) continues to work with the representative who oversees civil rights for the USDA Western region. SLP continues to have training to correct the issues in their USDA FNS report. POC  SLP Assistant Director Christina Fualaau

The payroll department will be trained on the proper calculation of salary and compensation rates.

Finding: Certain timecards were not properly approved prior to payment of the payroll expenditure within Assistance Listing #10.555 and #10.553 in regards to the Child Nutrition Program. Response: This took place during a period of transition in management personnel within the Child Nutrition Program. The Chief School Finance Officer (CSFO) has implemented the following procedure: If a timesheet has not been approved by a supervisor, the timesheet will be deleted from the payroll run that month and payment will be delayed until the supervisor approval is obtained or approval is granted by the CSFO. Completion date: April 1, 2024.

USD #250 has implemented new procedures to ensure that information provided to the Food Service Director is correct. Personnel have been trained in the poper way to run reports under the District's accounting system. In addition, the Director of Business Operations will review the annual food service report prepared by the Food Service Director before it is submitted to the Kansas Department of Education.

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Pomeroy School District No. 110 September 1, 2022 through August 31, 2023 This schedule presents the corrective action the District is planning to take for findings included in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Finding ref number: 2023-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with federal suspension and debarment requirements. Name, address, and telephone of District contact person: Kelly McKeirnan, Business Manager 121 S. 10th St. Pomeroy, Washington 99347 (509) 843-3393 Corrective action the auditee plans to take in response to the finding: The District is committed to ensuring grant programs comply with federal regulations regarding suspension and debarment. In response to the audit finding, the District is taking the following corrective actions to address the audit recommendations: * Program staff will check the federal System for Award Management (SAM.gov) prior to the contract execution date. The contractor verification documentation will be maintained in each contract file. Due to the audit finding being issued late in the fiscal year 2024 audit cycle, the District was not able to fully implement corrective actions during the 2024 audit period. The District anticipates full compliance with the suspension and debarment requirement by fiscal year 2025. Anticipated date to complete the corrective action: 10/31/2024