Corrective Action Plans

FINDING 2023-003 Finding Subject: Child Nutrition Cluster - Eligibility Summary of Finding: The School Corporation had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance related to the eligibility determination of a child receiving meals. The School Corporation could not provide documentation supporting the eligibility for 10 of 40 students that received free or reduced-price meals for fiscal year 2022-2023. Of the 30 students for which documentation was provided, the School Corporation could not provide documentation that the one student’s benefits were calculated properly. Due to the lack of supporting documentation we were unable to determine the School Corporation's compliance with the Eligibility compliance requirement. Contact Person Responsible for Corrective Action: Juli Windsor Contact Phone Number:765-689-9131 Views of Responsible Official: We concur with the finding Description of Corrective Action Plan: This will include all reimbursements which are submitted to the treasurer must be signed by the school cafeteria managers and the food service director. The school will also implement policies to ensure that the Verification of Free and Reduced-Price applications have an adequate internal control to ensure the validity of the free and reduced applications. This will provide for segregation of duties to ensure appropriate reviews, approvals, and oversight are taking place. Anticipated Completion Date: April 2024

Management Response/Corrective Action Plan: Going forward the School Nutrition staff will keep a spreadsheet documenting meals reimbursed previous fiscal years, and in each month to compare to the number of meals calculated for the current billing month.

Management Response/Corrective Action Plan: Going forward the School Nutrition staff will keep a spreadsheet documenting meals reimbursed previous fiscal years, and in each month to compare to the number of meals calculated for the current billing month.

FA 2023-001 Improve Internal Control Activities Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principle Eligibility Reporting Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: 10.553 - School Breakfast Program 10.555 - National School Lunch Program Federal Award Number: 225GA324N1099 (Year:2022), 235GA324N1199 (Year: 2023) Questioned Costs: None Identified Description: A review of expenditures, free and reduced meal applications, and reporting requirements related to the Childe Nutrition Cluster revealed that the School District's internal control procedures were not operating appropriately to ensure that appropriate reviews and approvals occurred. Corrective Action Plans: For review of expenditures, Child Nutrition Cluster (CNC) invoices will be sent to the CNC Director to review, approve, and sign. Singed invoices will then be provided to the CNC Bookkeeper for payment processing and filing. For review of free and reduced meal applications, applications will be received electronically in Infinite Campus and manually. The manual applications will be entered into Infinite Campus and both types will be approved and processed by the CNC Director. This approval will be stored in Infinite Campus with a time/date and approver electronic stamp. For review of reporting requirements, meal count information from Infinite Campus will be provided to the CNC Bookkeeper to enter in the Georgia Department of Education portal. CNC Director will approve and sign the final report prior to submittal. Estimated Completion Date: August 1,2023 Contact Person: Kim Navas, Financial Officer Telephone: 706-367-2782 Email: kim.navas@jeffcityschools.org

On behalf of the finding 23-03-the following changes will be implemented: The Food Program Directors will ensure that the separation of Food Purchases will be reinforced. 1) Establish a strict policy mandating that all program food purchases for the USDA Nutrition Cluster (Breakfast and Lunch programs/ CACFP) be processed separately from non-programmatic food purchases. 2) Implement a clear process where program-related food purchases are charged directly to the respective program bank accounts and non-programmatic items are billed separately to non-program accounts. 3) Require management to review and approve all food purchase orders before submission to vendors, ensuring that food intended for program use is properly categorized and separated from other purchases. 4) Ensure that only approved program foods are charged to the USDA Nutrition Cluster, with regular cross-checks against menu requirements. 5) Require separate invoices for non-programmatic food purchases to ensure clean and distinct accounting entries, minimizing the need for corrections through journal entries. The enforcement of the procedures for food purchases will be in effect starting October 2024.

FA 2023-002 Strengthen Controls over Suspension and Debarment Compliance Requirement: Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Agriculture Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: 10.553 - School Breakfast Program 10.555 - National School Lunch Program Federal Award Number: 235GA324N1199 Questioned Costs: None Identified Prior Year Finding: FA 2022-002 Description: A review of expenditures charged to the Child Nutrition Cluster revealed that the School District's internal control procedures were not operating appropriately to ensure that the School District's suspension and debarment procedures were followed. Corrective Action Plans: The School District has returned to following its approved procurement procedures. Estimated Completion Date: July 1, 2024 Contact Person: Chris Johnson, Director of Financial Services Telephone: 478-994-2031 Email: chris.johnson@mcschools.org

FA 2023-001 Strengthen Controls over Special Reporting Compliance Requirement: Reporting Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Agriculture Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: 10.553 - School Breakfast Program 10.555 - National School Lunch Program Federal Award Number: 235GA324N1199 Questioned Costs: None Identified Prior Year Finding: FA 2022-001 Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over the monthly Claims for Reimbursement process. Corrective Action Plans: The School District has returned to collecting Free and Reduce applications and recording the student meals accordingly. Estimated Completion Date: July 1, 2024 Contact Person: Chris Johnson, Director of Financial Services Telephone: 478-994-2031 Email: chris.johnson@mcschools.org

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

Management response/corrective action: The Nutrition Director will update student eligibility when verification requests are not returned. The Director will participate in Department of Education professional development to stay abreast of all requirements of School Nutrition.

Management’s Response/Corrective Action Plan: We agree with RKO's recommendation that there are no provisions in the regulations that provide for large scale reclassifications through administrative override. There was some confusion on the part of Maine School Administrative District No. 35 when a communication from the State of Maine was received in November of 2022, that the rate of Free and Reduced children identified at Maine School Administrative District No. 35 had dropped dramatically from the prior year (due to the meals being free to all) and that it may negatively impact our subsidy. At that point, Maine School Administrative District No. 35 asked its building administrators to identify needy families based on conversations they had previously had with parents, from speaking with their guidance counselors, from knowledge they had working with outside community agencies (68 Hours of Hunger) to help identify families potentially in need. From there the lists provided by the building administrators were compared with the families who had already submitted applications, and the directly certified students, and any students who were not identified in either of those cohorts were added to the free and reduced list per administrative override. When RKO arrived in May 2023 to perform interim testing, they let us know that this was not appropriate. At that time, we removed those students from the free and reduced list, and adjusted all of our previously submitted claim forms to account for the change. Maine School Administrative District No. 35 is now clear on the rules with regards to the use of administrative override, and will not use it again in the future.

Finding Number: 2023-003 Planned Corrective Action: The accounts payable clerk will double check all claims submitted to the state for accuracy. Anticipated Completion Date: 08/30/2024 Responsible Contact Person: Stacy Bolden

Boston Public Schools (BPS) Food and Nutrition Services (FNS) has implemented advanced policies including additional segregation of duties to ensure that all deposits made have clear and accurate cash receipt forms. Anticipated Completion Date: June 30, 2024 Responsible Contact Person: Colin Musto, Assistant City Auditor, Grants Monitoring Unit colin.musto@boston.gov

Boston Public Schools (BPS) Food and Nutrition Services (FNS) has implemented various procedures in order to accurately report meal counts and claims.  Anticipated Completion Date: June 30, 2024 Responsible Contact Person: Colin Musto, Assistant City Auditor, Grants Monitoring Unit colin.musto@boston.gov

The Division will ensure evidence of review is maintained for the inventory work sheets. Anticipated Completion Date: October 2024. Responsible Contact Person: Yohannes Gedlu, Northwest Division Divisional Finance Director

Finding No.: 2023‐003S Condition: Applications for free or reduced meals were not appropriately filled out and signed by the student’s parent or guardian. Plan: Procedures will be implemented, and followed, to ensure applications are appropriately filled out by the student’s parent or guardian. Anticipated Date of Completion: 6/30/2025 Name of Contact Person: Kreg Wesley, Executive Director of Finance and Operations

Finding No.: 2023‐002S Condition: The average price of paid meals for the fiscal year was less than the minimum required amount and the paid lunch equity calculation was not completed. Plan: Procedures will be implemented to monitor the average price of paid meals and complete the paid lunch equity calculation, if required. Anticipated Date of Completion: 6/30/2025 Name of Contact Person: Kreg Wesley, Executive Director of Finance and Operations

Finding No.: 2023‐001S Condition: The confirmation review and verification tracking were not reviewed by someone other than the determining official, and the verification was not submitted before the due date. Plan: Procedures will be followed to ensure that there is an additional review of the verification process and that verification is submitted timely. Anticipated Date of Completion: 6/30/2025 Name of Contact Person: Kreg Wesley, Executive Director of Finance and Operations

Berrien County BOE FA 2023-001 Strengthen Controls over Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principle Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Agriculture Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: 10.553 - School Breakfast Program 10.555 - National School Lunch Program Federal Award Number: 225GA324N1199 (Year: 2023), 225GA324N1199 (Year: 2023) Questioned Costs: $3,381 Description: A review of expenditures charged to the Child nutrition Cluster revealed that the School District's internal control procedures were not operating appropriately to ensure that expenditures were reviewed and approved and that the School District's procurement and suspension and debarment procedures were followed. Corrective Action Plans: The new program director will attend training and review compliance requirements to ensure appropriate documentation is maintained. Estimated Completion Date: 30-Jun-24 Contact Person: Jolyn Schultz, Finance Director Telephone: 229-686-2081 Email: jolyn.schultz@berrien.k12.ga.us

ALN: 10.553, 10.555, 10.559, 10.582, Corrective Action Plan: Noncompliant FFATA Reports - Nutrition - OPI - The values were being duplicated due to an error in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). The Office of Public Instruction has reached out to its federal partners who are correcting their system to allow the office to report monthly without duplicating the reported values. The office will then begin reporting monthly as required. Person(s) Responsible for Corrective Measures: April Grady, Chief Financial Officer, Montana Office of Public Instruction, Target Date: 10/31/2024

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