Corrective Action Plans

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

Finding 2023-007: Procurement Finding: The District did not maintain adequate records for procurement transactions in the IDEA and Child Nutrition Clusters. Corrective Actions Planned: The District will train its employees on the documentation trail needed for procurement actions and review its policies and procedures for any needed updates. Expected Implementation Date: June 30, 2024 Contact Person: Dr. Frank Williams

Finding 2023-002 Condition: Suspension and debarment compliance was not verified for six covered transactions. Corrective Action Planned: The District has incorporated the language into contracts beginning with school year 2024. The language is not in the 2023 food service contracts. Anticipated Completion Date: Completed Contact: Ellen Finelli, MS. RD., Director of Food and Nutrition

Corrective Action Plan: West Side CTC has implemented financial policies and procedures to ensure a timely independent audit process and subsequent timely filing of the audit with the Federal Audit Clearinghouse.

Finding 2023-001: Procurement United States Department of Agriculture – Child Nutrition Cluster United States Department of Agriculture – Child and Adult Care Food Program Criteria: The non-federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rational for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price (2 CFR section 200.318(i)). The non-federal entity must also establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) (2 CFR section 200.303(a)). Condition: Records detailing which vendors were contacted, when they were contacted, and support for the rationale in choosing the vendor, is not documented. Questioned Costs: None Cause: Management did not maintain a detailed history of procurement and did not document a review process. Effect: There is no reasonable assurance that the Organization managed the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal award Recommendation: Purchasers should record, and keep on file, backup detailing which vendors were contacted, when they were contacted, support for the rationale in choosing the vendor. Management should implement a system of internal controls for this process. Planned Corrective Action: Shloma Weiss, Administrative Director, will establish and implement a process for documenting the procurement history and establishing a system of internal controls.

Finding 2023-003 Fed Agency Name: US Department of Agriculture Program Name: Child Nutrition Cluster – School Breakfast Program and National School Lunch Program CFDA #: 10.553 and 10.555 Finding Summary: During the Single Audit, it was discovered the District had five charges out of 40 tested where the payroll cost charged to the program did not have evidence of timecards by the employee. Corrective Action Plan: The District will improve its internal control process over the submission of timecards related to federal funds. Responsible Individual: Cassandra Stahlke Chief Financial Officer Anticipated Completion Date: June 30, 2024

Finding 2023-004 Fed Agency Name: US Department of Education, US Department of Agriculture and US Department of Treasury Program Name: Special Education Cluster – Special Education Grants to States, COVID 19 – Special Education Grants to States, Special Education Preschool Grants, and COVID-19 – Special Education Preschool Grants Child Nutrition Cluster – School Breakfast Program, National School Lunch Program and the Fresh Fruit and Vegetable Program COVID 19 - Coronavirus State and Local Fiscal Recovery Fund CFDA #: 84.027, 84.173, 10.553, 10.555, 10.582 and 21.027 Finding Summary: During the Single Audit, it was discovered the federal procurement processes required for acquiring goods and services were not followed. In addition, procedures were not always followed to maintain documentation regarding the verification of whether an entity was suspended or debarred before entering into a covered transaction. Responsible Individual: Cassandra Stahlke Chief Financial Officer Corrective Action Plan: The District will improve its internal control processes over the procurement of good and services and maintaining documentation on whether and entity is suspended or debarred relating to federal funds. Grant management staff will stay informed of Policy DHJ and corresponding procedures. ECSD has also created a Procurement Guide and will provide training to staff at the beginning of the academic year. Anticipated Completion Date: June 30, 2024