Corrective Action Plans

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 put procedures back in place to make sure we are using current eligibility procedures (applications) to determine student eligibility. Anticipated Corrective Action Plan Completion Date: August 15, 2023 Contact Information: For additional information regarding this finding please contact Bill Trewyn, Business Manager, at 262-741-9143.

Child Nutrition Reporting - Contact: Jeremy Mack, Business Agent. Completion date: June 30, 2024. The District administrator has reviewed the reporting requirements with the Child Nutrition staff and will review monthly claims for submission.

CORRECTIVE ACTION PLAN YEAR ENDED JUNE 30, 2023 Finding 2023-001 – Verification Population Criteria: Section III, P. of the grant agreement from the California Department of Education Nutrition Services Division Permanent Single Agreement, states that verification must be completed on Household meals Benefit Applications as specified by Child Nutrition Program (CNP) regulations and guidance. Local Education Agency (LEA) must select the sample by the lesser of 3% or 3000 of the approved applications on file as of October 1, selected from error prone applications. Condition: While gaining our understanding of controls over verification, management noted that they rely on their internal software, Paradox, to tally the number of applications on file as of October 1, as well as any reports considered error prone. The system does not print out a report to list out all applications and management was unable to reproduce any report to show the total number of applications to agree to the tallied applications from the Paradox system as of October 1. The paradox system is based on the applications entered into the system by the School Nutrition Program Personnel. Questioned Costs: None Corrective Actions Taken or Planned: The Paradox database system generates a report that provides a listing of students with approved applications and also provides student totals. We are working with the Applied Technology Department to develop an additional report that will populate a listing of approved applications that includes application totals. The application totals from the approved application report will be used to determine the application tally and will be used to compute the required sample size. Error prone applications have been and will continue to be used to meet the required number of application selections that are required to be verified. Responsible Official Lilia S. Chavez, Director of Externally Funded Programs lschavez@la-archdiocese.org (213) 637-7915 Anticipated Completion Date January 31, 2024

Procurement Federal agency: U.S. Department of Agriculture Federal program title: Child Nutrition Cluster CFDA Number: 10.553, 10.555, and 10.559 Pass-Through Agency: Minnesota Department of Education Pass-Through Number(s): 1-0882-000 Award Period: July 1, 2022 – June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance and Other Matters CORRECTIVE ACTION PLAN (CAP): Recommendation: It is recommended that the District implement procedures and controls to ensure proper procurement procedures are being followed. Explanation of Disagreement with Audit Findings: There is no disagreement with the audit finding. Actions Planned in Response to the Finding: The District will continue to work on establishing procedures and controls to ensure proper procurement procedures are being followed. Official Responsible for Ensuring CAP: Tina Burkholder, Director of Business Services. Planned Completion Date for CAP: June 30, 2024.

Finding Number 2023-003 — Excess in Food Service Fund — Repeat Finding - Material Weakness in Internal Control/Noncompliance — Special Tests and Provisions Condition: As of year-end, June 30, 2023, the district had a fund balance in the food service fund in excess of three months operating expenses by approximately $ 268,411. Responsible Person: Carl Seiter, Director of Business Services Implementation Date: June 30, 2024 Corrective Action: The district has filed a spend down plan with the State of Michigan. This plan includes increasing labor costs for the operation of a kitchen at Winn Elementary School. Additionally, the district will purchase much needed new equipment. Sincerely Carl Seiter Director of Business Services Shepherd Public Schools

The district has implemented procedures for the future to ensure all transacttions are recorded in the period of benefit and account reconciliations are performed in a timely manner. Anticipated Completion Date: June 30, 2023 Responsible Party: Kathy VanSchaick

2023-003 - Income Eligibility Guidelines - Contact: Sam Lehman, Director of Business Services. Completion date: June 30, 2024. The District will improve its evaluation of income eligibility for Child Nutrition Cluster program by following the income eligibility guidelines.

The District will implement controls in its meal claim process to ensure that student meals claimed for reimbursement equal student meals served. The Food Service Supervisor and/or Food Service Administrative Assistant will create a summary meal count sheet each month totaling the number of student meals seved based on the electronic and manual meal count sheets prior to submitting the meal claim in the Michigan Nutrition Data System (MiND). The monthly meal claim submitted will be filed with the supporting documentation an dsigned by the individual submitting the claim attesting that the meals claimed match the meals counted.

#2023-004 Material Weakness related internal controls and compliance with Special Tests and Provisions – Verifications: The District did not perform verification of free/reduced meal applications until March 2023. Recommendation: Auditor recommends the District maintain close communication with the Department of Education, particularly during any period when there is a change in manner in which the food service program operates. Action Taken: The Bandon School District will maintain close communication with the Department of Education, particularly during any period when there is a change in the manner in which the food service program operates. The Director of Food Services will also reach out to the verification team to make sure verifications are done promptly. They will also check regularly for incoming applications that also must be verified promptly. Effective May 2023.

#2023-002 Material Weakness related to eligibility for free and reduced price meals: During a transitional year where all meals were being provided free to all students under various funding sources, the District did not actively solicit applications from households and did not process those applications that were received until nearly six months later. Recommendation: Auditor recommends the District maintain close communication with the Department of Education, particularly during any period when there is a change in manner in which the food service program operates. Action Taken: The Bandon School District will maintain in close communication with the Department of Education, particularly during any period when there is a change in the manner in which the food service program operates. Director of Food Services will also regularly reach out to ODE’s assigned Nutrition Specialist to verify the certification of students’ classification on free, reduced and paid students is correct. Effective May of 2023.

The District agrees with the finding and will ensure that staff follows the District’s food service program procurement procedures to ensure that TDA approval is obtained prior to all future Food Service Fund capital expenditure purchases. Relative the $221,648, the District remitted a Capital Expenditure Request with TDA on September 25, 2023 for the 2023-24 fiscal year, which TDA approved. However, this request relates to the capital expenditures incurred in January and February 2023 in the 2022-23 fiscal year.

USDA Foods Receipts: Criteria: Evidence of distribution in the form of signed invoices for USDA Foods is required to be maintained for CSFP and TEFAP. Evidence of receipt of USDA foods should be maintained to ensure compliance with the award. Condition: Signed invoices evidencing USDA food distributed were not retained. Context: Our sample of 25 distributions of USDA Foods included two instances where invoices were not properly signed and one instance where the invoice was not retained. Known and likely questioned costs are unknown. Effect: GSFB runs the risk that improper distribution will not be prevented without appropriate document retention. Cause: In all three instances, administrative issues resulted in the untimely lack of retention of signed invoices. Recommendation: We recommend that GSFB reinforce the importance of retaining signed invoices in accordance with award requirements. GSFB should further assign an individual within their organization to assume a higher level of direct responsibility for the administration of federal awards by GSFB. Contact: Bryan O'Connor, VP, Finance & Administration Corrective Actions Taken or Planned: GSFB staff audit sales order paperwork in connection with product received from Maine Department of Agriculture, Conversation, and Forestry. The audit consists of running a list of any outbound order that had DACF allocated inventory on it, comparing that list to returned paperwork, and confirming that said paperwork was signed. For any agency paperwork that can not be located and/or is not signed, a follow-up email is sent to the specific partner requesting a signature. In June 2023, GSFB staff increased the frequency of auditing from monthly to weekly, allowing a more timely follow-up on any paperwork concerns. The Customer Service and Inventory Management teams share responsibility for auditing and follow-up.

Finding 2023-002 - School Breakfast Program No. 10.553; Grant Period: Year Ended June 30, 2023 and National School Lunch Program - Assistance Listing No. 10.555; Grant Period: Year Ended June 30, 2023 Recommendation: The School should ensure that processes are in place to review and approve of invoices for purchases related to the breakfast and lunch program. Also, the meal counts and monthly claim reimbursements should be reviewed and confirmed by someone other than the person compiling the counts. These processes should be documented. Action Taken: Purchase orders for food and supply purchases will be filled out by the Cafeteria Manager and approved by the Chief Operating Officer (COO). Once the food is delivered, the Cafeteria Manager will submit the invoice to the COO and he will match it to the invoice and review and sign the invoice. On a monthly basis, the COO will review and approve the monthly meal counts, compiled by the Cafeteria Manager and submit the meal claim reimbursement. The COO, Craig Eichmann, will be responsible for implementing this updated process and it will be fully implemented by October 31, 2023.

For the Special Aid and Food Service Funds, the System for Award Management will be checked in the fall and spring for the debarment of any vendors that we expect to pay over $25,000 for the fiscal year. Summary spreadsheets will be provided to the Auditors.

Action taken: The district entered into a shared services agreement with Capital Region BOCES in March of 2022 for management of the School Nutrition program. It was assumed that this was a procedure they followed; however, documentation was not provided and the external auditors inciuded it as a finding. The School Nutrition Director resigned and was replaced by a new School Nutrition Director with BOCES (Greg Nalewjka) and he was unaware that this was necessary. He is working with his supervisors to provide documentation to the district that due diligence has been done to meet this requirement. Anticipated completion date: 11/10/2023

2023-001 Internal Control Systems Over Special Tests and Provisions (Accountability for USDA Foods) – U.S. Department of Agriculture Food Distribution Cluster, Passed Through the State of Nevada Department of Agriculture Criteria: In accordance with 2 CFR 200.303(a), the auditee must maintain a system of internal controls to provide reasonable assurance that accurate and complete records are maintained with respect to the receipt, distribution, and inventory of USDA foods. Condition: Three Square’s internal controls, as designed, require an individual to verify that the weight of each product recorded in the inventory system is accurate. During inventory observation and testing audit procedures, twelve items were sampled. Of the twelve items, a discrepancy was discovered in the weight of one product when compared to the weight of the product recorded in the inventory system. Context: Of the twelve products selected for testing, the weight of one product was improperly recorded within Three Square’s inventory system. Cause: Internal controls over accountability for USDA foods were not operating effectively. Effect: Improper implementation of internal controls could result in improper tracking and reporting of costs of USDA foods. Recommendation: We recommend that management ensure that the system of internal controls over accountability for USDA foods is followed as designed. Views of Responsible Officials and Planned Corrective Actions: The weight of inventory is recorded within Three Square’s inventory management system as part of the receiving process. To ensure that all weight is properly recorded, Three Square will implement a verification process. Inventory control specialists, who are not part of the receiving process, will verify 10% of all items received weekly. This verification process will include independent weighing of items, and a review of the item description, quantity and dimensions recorded in the inventory management system. Any discrepancies will be reported to team leads to be rectified. Three Square is committed to ensuring that the system of internal controls is sufficient to ensure all records are accurate and complete.

Finding 2023-002 – Eligibility The BOCES concurs with the finding 2023-002. Corrective Action: To prevent this in the future, in addition to the mandatory verification, a second person, School Food Service Director or Director of Shared Food Services will randomly test a sample of school meal applications. Beginning in 2023-2024, many of the school buildings will be serving meals for free under the Community Eligibility Provision which will drastically reduce the number of free and reduced meal applications needed to be processed. Between the reduction in applications and the implementation of random testing, we are confident these inaccuracies will be resolved. Additional checks and balances will be put in place immediately so that reliance is not solely on the computerized system. Contact Person: Kate Dorr, Director of Shared Food Service (315) 738-0848 kdorr@oneida-boces.org

Finding 2023-001 – Reporting The BOCES concurs with the finding 2023-001. Corrective Action: To correct this in the future 2 steps will be implemented by the BOCES: 1. A manual total of meals from the Etrition claim reports will be calculated and compared to the total meals on the CNMS claim; and 2. The School Food Service Director and Director of Shared Food Services will review and verify each other's work. Additional checks and balances will be put in place immediately so that reliance is not solely on the computerized system. Contact Person: Kate Dorr, Director of Shared Food Service (315) 738-0848 kdorr@oneida-boces.org

2023-004 Verification Federal agency: U.S. Department of Agriculture Federal program Title: Child Nutrition Cluster Federal Assistance Listing Number: 10.553, 10.555 and 10.559 Federal Award Identification Number and Year: 212MN061N1199- 2023 Pass-Through Agency: Minnesota Department of Education Pass-Through Number(s): 1-213-000 Award Period: June 30, 2023 Type of Finding: Significant Deficiency in Internal Control Over Compliance Recommendation: We recommend that District management and financial personnel have internal controls designed to ensure proper documentation of eligibility for Child Nutrition. Views of Responsible Officials: There is no disagreement with the audit finding. Action Taken in Response to Finding: The District will continue to work at ensuring there is a second person to review applications. Name of the Contact Person Responsible for Corrective Action Plan: Justin Dahlheimer, Superintendent Planned Completion Date for Corrective Action Plan: June 30, 2024

The District will implement an internal procedure to ensure that the eligibility verification is completed prior to the November 15th due date.

CONTACT PERSON: Robin Stack, Chief Finance Officer, rstack@greenville.k12.sc.us CORRECTIVE ACTION: The School District will review the food service and accounting software programs and interface to determine why meals served data did not transfer properly for certain locations. In the meantime, the School District will manually review the meal count transfer totals for propriety and will notate differences and adjust for any significant differences. PROPOSED COMPLETION DATE: December 31, 2023

Name of Contact Person: Daniel Schuler, Business and Operations Manager Corrective Action Plan: The District did identify in late spring/early summer that the existing relationship with US Foods had not been bid in the prior year. In order to address this issue, the District Administration identified, recommended and received Board of Education approval to access a US Foods State of Alaska Contract with the State of Alaska Department of Corrections. This action, coupled with the one-year extension of an existing agreement with Alaskan & Proud Markets for the purchase of milk, will bring the District into compliance with procurement procedures as outlined by the National School Lunch Program and DEED. Proposed Completion Date: December 2023.

Name of Contact: Daniel Schuler, Business and Operations Manager Corrective Action Plan: The corrective action plan noted above for Finding 2023-001 will resolve Finding 2023-002 as well. The prior Business and Operations Manager started the annual verification process, however, did not follow through on finishing the process prior to her resignation from the District. Upon her departure from the District, she did not communicate that the process had not been completed. I am currently working on the annual verification process as prescribed by DEED and the National School Lunch Program and that process will be completed in accordance with the applicable November 15th deadline. In addition, the District has been selected and is currently working on an Onsite Review of the Child Nutrition Program which includes covering the same population of students that should have been verified during the FY2022-2023 verification process. Proposed Completion Date: December 2023.

Name of Contact Person: Daniel Schuler, Business and Operations Manager Corrective Action Plan: The prior Business and Operations Manager started the annual verification process, however, did not follow through on finishing the process prior to her resignation from the District. Upon her departure from the District, she did not communicate that the process had not been completed. I am currently working on the annual verification process as prescribed by the State of Alaska, Department of Education and Early Development (DEED) and the National School Lunch Program and that process will be completed in accordance with the applicable November 15th deadline. In addition, the District has been selected and is currently working on an Onsite Review of the Child Nutrition Program which includes covering the same population of students that should have been verified during the FY2022-2023 verification process. That review will be completed in December 2023. Proposed Completion Date: December 2023