Corrective Action Plans

U.S Department of Agriculture 2023-004 Child Nutrition Cluster – Assistance Listing No. 10.533, 10.555, 10.555C, 10.559 Recommendation: CLA recommends the District follow its procurement policies as well as requirements within the Uniform Guidance to perform the proper verification procedures on all covered transactions entered into with federal funds. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The District will work to revise its procedures as necessary to ensure that all procurements which are charged to federal programs are fully documented. Name(s) of the contact person(s) responsible for corrective action: Marie Schrul, Executive Director of Finance Planned completion date for corrective action plan: January 31, 2024

Lack of Proper Review Federal agency: U.S. Department of Agriculture Federal program Title: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.556 Federal Award Identification Number and Year: 212MN061N1199- 2023 Pass-Through Agency: Minnesota Department of Education Pass-Through Number(s): 1-2342-000 Award Period: June 30, 2023 Type of Finding: Material Weakness in Internal Control Over Compliance Recommendation: We recommend the District review paper applications. The District should ensure that these controls are properly documented. Views of Responsible Officials: There is no disagreement with the audit finding. Action Taken in Response to Finding: The District will implement procedures to ensure all paper transactions are properly reviewed once completed. Name of the Contact Person Responsible for Corrective Action Plan: Paul Brownlow, Superintendent Planned Completion Date for Corrective Action Plan: June 30, 2024.

The District will assign someone in the Business Office to review the Child Nutrition claims. Due to the size of the District, it is not cost effective to have more than one person in the food service department working with the claims. A school business official will review all claims. Responsible Person: Sue Shakal Anticipated Completion Date: Ongoing

Finding 2023-02 Internal Control Over Compliance of Special Tests and Provisions – Non-Profit School Food Service Accounts View of Responsible Official: The School agrees to solely use the food service bank account for all revenues and expenses related to the food service program. The School will begin the process of transitioning bank information to respective vendors and governmental agencies to ensure the monies received for the food service program are deposited into the account and expenses for the food service program are paid out of this account. Contact Person: Tory Jones, Finance Director Expected Implementation Date: February 2024

Finding 2023-01 Internal Control Over Compliance of Special Tests and Provisions – Non-Profit School Food Service Accounts View of Responsible Official: The School agrees to solely use the food service bank account for all revenues and expenses related to the food service program. The School will begin the process of transitioning bank information to respective vendors and governmental agencies to ensure the monies received for the food service program are deposited into the account and expenses for the food service program are paid out of this account. Contact Person: Tory Jones, Finance Director Expected Implementation Date: February 2024

District Contact Person: Marsha Taylor, Business Manager Finding – Federal Award Finding and Question Cost Finding 2023-001 – Considered a significant deficiency Recommendation: The District should verify that all required components of meal applications are completed fully and accurately and that income eligibility is recalculated accurately prior to approval. Action to be taken: The District concurs with the facts of this finding and will verify that all income eligibility is recalculated accurately prior to approval.

Corrective Action Plan: The District will ensure that all food service applications are signed after the eligibility detennination is complete. Anticipated Corrective Action Plan Completion Date: Ongoing. Contact Information: For additional infonnation regarding this finding please contact Ben Prather, Business Manager, at 262-472-8705.

Finding 2023-007 Special Tests and Provision – Child Nutrition Cluster Material Weakness in Internal Control Over Compliance and Material Noncompliance Finding Summary: The District does not have an internal control system designed to review and maintain documentation for verification of eligibility status. Responsible Individuals: Shannon Hunstad, Superintendent Corrective Action Plan: The District will review and strengthen the controls to ensure the required verification process is being completed and ensuring proper eligibility status for the Child Nutrition Cluster program. Anticipated Completion Date: June 30, 2024

Finding 2023-006 Eligibility – Child Nutrition Cluster Material Weakness in Internal Control Over Compliance and Material Noncompliance Finding Summary: The District does not have an internal control system designed to review and maintain documentation for eligibility of program participants. Responsible Individuals: Shannon Hunstad, Superintendent Corrective Action Plan: The District will review and strengthen the controls surrounding the review and approval of eligibility applications for the Child Nutrition Cluster to ensure they are supported, approved, and accurate. Anticipated Completion Date: June 30, 2024

Finding 2023-004 Support for Free and Reduced Meal Applications 1. Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. 2. Actions Planned in Response to Finding The District will adopt policies and procedures to retain all applications and support in the District’s records. 3. Official Responsible Mr. Michael Malmberg, Superintendent, 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.

December 1, 2023 U.S. Department of Education Marshall Public Schools respectfully submits the following Corrective Action Plan for the year ended June 30, 2023. Contact information for the individual responsible for the corrective action: Caleb Petet, Superintendent Marshall Public Schools Independent Public Accounting Firm: Gerding, Korte & Chitwood, P.C., 723 Main Street, Boonville, MO 65233 Audit Period: Year ended June 30, 2023 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. Significant Deficiency

2023-002 Child Nutrition Cluster Recommendation: We recommend that fund balances should be monitored to ensure that balances remain in line with child nutrition compliance requirements. Action Taken: The district has in FY24 allocated much of the funds in excess from the child nutrition cluster to invest in equipment. We have to date, spent the funds down on Freezers, cafeteria tables, coolers, and other such equipment as is allowable for the funds. After speaking with food and nutrition services at DESE, we understand that this surplus comes from the state reimbursements being higher during COVID than what they are post covid. Meaning the rate we were getting reimbursed for free/reduced was higher than the cost, which built the surplus. We are confident that this excess is going to continue being dwindled down, now that our reimbursements are less than the cost of the 3rd party vendors charges to us. However, we are not allowed to use it on unpaid lunch balances, so we have to continue running that surplus for at least another year. This excess is going to start coming down on its own through necessary investments in infrastructure. Completion Date: June 30, 2024 Sincerely, Caleb Petet, Superintendent Marshall Public Schools

Finding 2023-005: Child Nutrition Cluster Federal Reimbursement Receipting Procedures U.S. Department of Agriculture Pass-through agency: Michigan Department of Education Assistance Listing Numbers: 10.553, 10.555, and 10.559 Award numbers: 221970, 231970, 220910, 221960, 231960, 220900 and 230900 Award year ends: June 30, 2023 and September 30, 2023 Recommendation: The School District should provide training to accounting department personnel of the requirements for non-profit school food service accounts under Uniform Grant Guidance, and the School District should require payments to be timely receipted and credited to the proper food service accounts. Action Taken: The financial services staff will reconcile and record monthly transactions timely in the accounting records. We also will cross train staff and build familiarity with the process, focusing on improving our procedures during the year to streamline receipting processes. Additionally, the Superintendent and accounting department have temporarily contracted an additional accounting professional to assist the business manager in this process. Responsible Person and Anticipated Completion Date: Director of Finance, November 2023. If the Michigan Department of Education has questions regarding this plan, please call Jim Nielsen at (231) 760-1309.

U.S. Department of Education Odessa R-VII School District respectfully submits the following Corrective Action Plan for the year ended June 30, 2023. Contact information for the individual responsible for the corrective action: Jon Oetinger, Superintendent Odessa R-VII School District Independent Public Accounting Firm: Gerding, Korte & Chitwood, P.C., 723 Main Street, Boonville, MO 65233 Audit Period: Year ended June 30, 2023 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. Significant Deficiency 1023-003 Child Nutrition Cluster Recommendation: We recommend that fund balances should be monitored to ensure that balances remain in line with child nutrition compliance requirements. Action Taken: The District will take action to reduce the food service balance in a timely fashion. The completion date for this corrective action is May 31, 2024. Completion Date: June 30, 2024 Sincerely, Jon Oetinger, Superintendent Odessa R-VII School District

Action Steps: The district has hired a new food service director who has taken measures to implement a more accurate record-keeping system, which includes Accu-Claim, as recommended by ISBE. The new system provides a more detailed daily report. Also, the cashiers at the point of sale have been retrained so that the recording and reporting is accurate. Contact Person(s): Kala Dudley, Food Service Director Ruby Howard, Unit Office Secretary Darren Root, Superintendent Anticipated Completion Date: December 31, 2023

Recommendation: The District should put into place internal controls to ensure all steps of verification are completed by program management, including secondary review of the free and reduced rosters after the verification process has been completed. Action to be taken: The District concurs with the finding and will implement a review process to ensure students selected for the verification process are changed to the proper status. Additionally, the District will retain the proper documentation to support the verification process.

Recommendation: The District should put into place internal controls that ensure there is a process to verify the free and reduced students submit applications or be switched to full pay status in their software. Action to be taken: The District concurs with the finding and will put procedures in place to verify that free and reduced students all have applications on file and properly qualify for that status.

Method of Implementation - The School District shall obtain and provide necessary training to personnel regarding A.S.S.A. reporting guidelines and low income eligibility guidelines; the School District shall ensure student lunch statuses are documented appropriately throughout the District's online databases {PowerSchool, PaySchools, IEP Direct, etc.). Responsible for Implementation - Food Service Director, School Accountant & School Business Administrator. Implementation Date - Immediate

Method of Implementation - The School District shall allow an internal control procedure that completes a verification of a report prior to submission. This will allow the Business Office (Accountant & SBA) to verify the data prior to submittal. Person Responsible for Implementation - Food Service Director, School Accountant & School Business Administrator. Implementation Date - Immediate

Method of Implementation - The Food Service Director shall maintain a listing of necessary food service operational enhancements and capital expenditures. By April of each year, the Food Service Director will review cash and expenditures for prior months. If cash is expected to accumulate in excess of 3 months average expenditures, the Food Service Director will begin to purchase items for the Food Service operation contained on the list referenced above. A plan is in place for expending the funds but it is in the review process. The SBA has also began budgeting percentages of different salaries in the cafeteria budget (custodial, accountant, etc). Person Responsible for Implementation - Food Service Director & School Business Administrator. Implementation Date - 6/30/2024

Planned Corrective Action Plan: Upon initial notification of the verification findings, the District Food Services department immediately began corrective action to ensure the success of the SY 23-24 Verification. Specifically, three Food Services Office staff members were actively involved in the Verification training offered by the governing State agency, as well as, the software provider. All questions throughout the verification process were immediately asked of the State agency and/or software provider as appropriate. All supporting documents were reviewed by two staff members at the time of submission. Once verification was completed on November 15, 2023, a report was pulled to show change in status. The change in status for families that did and did not respond was reviewed by two staff members to ensure accuracy. Anticipated Completion: 11/16/2023 Responsible Contact Person: Jaleena Davis, Director - School Food Services

The Shenandoah Valley 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 2023-001: Reporting: Child Nutrition Cluster Contact Person: Anthony Demalis, Business Manager Recommendation: The District should establish internal control procedures over reporting requirements. Action: Cafeteria Manager will meet with Business Manager or Assistant Business Manager to review child nutrition reports prior to submission for reimbursements. Date for Completion: December 1, 2023

Condition: The District’s school lunch office maintained production records and manual count sheets instead of using the point-of-sale system for tracking student meal counts. Corrective Action Planned: The District has implemented a point-of-sale system for sales of meals and will use system reports as support for the monthly claims for reimbursement. Anticipated Completion Date: September 2023 Contact: Ann-Marie Geyster, School Business Manager

Child Lane management staff re-assessed program staff access to determine the changes that needed to be made in order to protect program integrity. To ensure valid DCH claims are submitted the following steps were taken:1. Employment was terminated for the staff person involved in the invalid DCH nutrition claims.2. Child Lane changed Field Representatives from working from home and provided work stations at the Administrative Office instead effective July 1, 2023. 3. A police report was filed with the Signal Hill Police Department.4. A claim was submitted with Great American under Child Lane’s employee fraud insurance policy.5. User names and passwords were reset for all staff and staff were re-trained.6. Child Lane added a Quality Assurance Specialist whose responsibility is to assist in enforcing all CACFP program policies, procedures, and guidelines. 7. Child Lane management re-assigned providers to a different Field Representative.8. Child Lane staff conducted household contact verification to approximately 150 provider enrollments out of the approximate 450 providers that were claiming at the time.9. Child Lane limited access for CACFP Field Representatives so that they are not able to make changes to provider profiles. Only the nutrition program manager is able to make changes.10. All prospective DCH providers speak to the program manager and only the program manager and one other staff person are responsible for signing new providers.11. The direct deposit procedure was updated so that DCH providers complete the electronic forms themselves directly to their individual Paycom account, complete an electronic signature and complete a two-step verification process through Paycom when changes are made. Nutrition program staff is not able to make changes to direct deposit for DCH providers.12. Downward adjustment claims were submitted through Child Lane’s CNIPS account for the invalid claims that were identified. The downward adjustments were reduced from current claim reimbursements. An email was received on November 17, 2023 by the California Department of Social Services, (CDSS) Fiscal Policy and Analysis Bureau verifying that all the associated downward adjustment claims were processed and deducted from current claim reimbursements. 13. Entries were made on Child Lane’s GL to recognize the reduction in income due to the downward adjustment claims submitted to agree with CDSS claim reimbursements for 2022-2023 Fiscal Year. The amount for previous Fiscal Years was posted to Contracts Settlements under the Management and General cost center. An entry was made as of June 30, 2023 to reduce the Family Day Care Contracts CACFP expense for the invalid claims for Fiscal Year 2022-2023 and offset to the Family Day Care Contracts expense under the Management and General cost center. Name of Contact Person Responsible for Planned Corrective Actions: Maria Almeida, Contracts & Compliance Manager Anticipated Completion Date: November 30, 2023

Recommendation: We recommend that the District implement added controls to prevent the lapse in self-monitoring reviews from occurring in the future. Action to be taken: The District concurs with the facts of this finding and will strive to improve controls to ensure that self-monitoring reviews are completed on a timely basis.