Corrective Action Plans

Finding ref number: 2023-001 Finding caption: The District’s internal controls were inadequate for ensuring compliance with federal suspension and debarment requirements. Name, address, and telephone of District contact person: Karen Walters, Director of Accounting 235 Sunset Ave, Wenatchee, WA 98801 509-663-8161 Corrective action the auditee plans to take in response to the finding: The District has implemented a process to ensure compliance. Purchase orders for Nutrition Services will have an electronic attachment showing a suspension and debarment check from SAM.gov. All purchase orders will be reviewed by the finance department prior to approval. Anticipated date to complete the corrective action: Implemented during audit

The District agrees that it failed to check Suspension and Debarment for one of its Child Nutrition vendors. Corrective action was taken May of 2023, at the time of the previous audit. Unfortunately, May is very late in the year, so actions that occurred prior to the Audit rolled forward into this audit period. Moving forward, just to be extra cautious, Child Nutrition will be issuing the Suspension and Debarment Attestation Form to all vendors and keeping copies on file.

The District believed they had complied with the suspension and department requirements and followed all of the bid document requirements for the Food Service Program. The District was unable to locate the specific documents related to the Food Service Program bid compliance. A recent leadership change resulted in a gap in knowledge about the previous filing system. The District thoroughly searched the former director's computer and potential filing locations, but unfortunately, didn’t find them. Going forward the Food Service Department will create a dedicated binder for these documents and place the binder in a location easily accessible to both the Director of Food Service and Administrative Assistant. Food Service will also provide copies to the Fiscal Department for their own binder.

Finding ref number: 2023-001 Finding caption: The District lacked adequate internal controls for ensuring compliance with federal suspension and debarment requirements. Name, address, and telephone of District contact person: Dan King 250 E Campus Dr. Belfair, WA 98528 (360) 277-2107 Corrective action the auditee plans to take in response to the finding: The District was experiencing high turnover with leadership roles in both its Food Service Department and Business Office when the failure to ensure compliance with federal suspension and debarment requirements occurred with one of its procurement contracts in August 2022. For corrective action the District put in place a requirement that all purchase order requests involving federal funds that amount to (or potentially could amount to) $25,000 or higher must include as an attachment in Skyward Financial Management the contract (when applicable) with verification that the vendor is not suspended and debarred and/or current documentation from Sam.gov verifying the vendor is not suspended or debarred. Any requisition involving federal funds that could amount to or exceed $25,000 that does not also include suspension and debarment verification will not be approved by the finance director and Business Office staff who process purchase order requests (as a control, both the finance director and the accounts payable technician must approve the request). Further, by requiring the suspension and debarment verification in Skyward as an attachment with the purchase order request, Business Office staff (regardless of staff turnover) will be able quickly locate and retrieve the documentation as needed for future audits and other external or internal purposes. Anticipated date to complete the corrective action: This corrective action was put into effect on April 18, 2024.

The following corrective actions have been put into place in order to address these findings:

•       The district will follow all guidelines outlined by the USDA during the verification process.

•       A change in personnel was made.

•       Child nutrition specialists from the Department of Education, Child Nutrition Unit have provided technical assistance to district employees on the verification process. This technical assistance included assistance in reviewing the correct number of applications, the process in which the confirming official confirms the applications, the correct documents that may be submitted for income documentation, the correct use of tracker forms, and the procedure for reclassifying applications after the verification process. This technical assistance was given in the spring semester this school year and will be repeated next year to ensure that the guidelines are followed.

•       District personnel will properly review the supporting documentation provided during the verification process which will include ensuring the correct number of applications are verified, that the confirming official confirms the applications, that the correct documentation of income is received, that the tracker forms are used correctly, and that the applications are reclassified after the verification process is completed, if necessary. This will be a multi layered review that will include the cafeteria managers, child nutrition director, director of federal programs, and superintendent.

There corrections had gone into effect Jan. 2024.

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Castle Rock School District No. 401 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: 2023-01 Finding caption: The District did not have adequate internal controls for ensuring compliance with federal procurement requirements. Name, address, and telephone of District contact person: Shelby Garrett, CSBS, CSBO Director of Fiscal Services Castle Rock School District 600 Huntington Ave S Castle Rock, WA 98611 Phone: 360.501.3132 Corrective action the auditee plans to take in response to the finding: (If the auditee does not concur with the finding, the auditee must list the reasons for disagreement). Once the district was notified of the noncompliance regarding Child Nutrition federal procurement requirements, an interlocal agreement was immediately put in place with Longview School District for our small purchases of $150,000 or below. The agreement was approved by the Castle Rock School Board at the March 8, 2023 board meeting and approved by the Longview School District School Board on March 17, 2023. For our purchases above $150,000, the district requested to be a member of the Puget Sound Joint Purchasing Cooperative on March 6, 2023 and the membership was approved by the PSJPC Board on March 12, 2023. PSJPC provided the district with an interlocal agreement and the agreement was approved by the Castle Rock School Board at the March 22, 2023 board meeting. This agreement with PSJPC is a continuing membership and the district currently pays $150.00 to be apart of the cooperative. On August 30, 2024 Castle Rock renewed their interlocal agreements with Longview School District, however, Castle Rock did not request all of the documentation from Longview to ensure they were compliant with the required procurement laws. Castle Rock has since requested all applicable procurement documentation from Longview School District and has ensured they were compliant with procurement laws for the 2022-2023 and 2023-2024 school years. Moving forward, Castle Rock School District will request required documentation and ensure Longview School District is in compliance before entering into the interlocal agreements for the 2024-2025 school year. Anticipated date to complete the corrective action: 4.16.2024

The District relies on the auditor to propose adjustments necessary to prepare the schedule of expenditures of federal awards including the related note disclosures. The District reviews schedule of expenditures of federal awards and approves all adjustments.

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Walla Walla School District No. 140 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 to ensure compliance with federal procurement requirements. Name, address, and telephone of District contact person: Janette Jeffris, Director of Fiscal Services 364 South Park Street Walla Walla, WA 99362 (509) 526-6718 Corrective action the auditee plans to take in response to the finding: As of result of finding for federal procurement requirements the District has reviewed the procurement requirements with the food service director and staff. In addition, the district has reviewed current spending with vendors within food services to determine procurement requirements for 24-25 fiscal year. This review will be done on an annual basis. In the future the district will review and document the requirements of the awarding agency to ensure they align with our own requirements based on local spending patterns. The district did not have adequate time to implement this for the 23-24 fiscal year. Anticipated date to complete the corrective action: 9/1/2024

2023-006 Late Audit Submission Programs: Impact Aid, Education Stabilization Fund (COVID-19) Federal Assistance #: 84.041, 84.425 Federal Agency: U.S. Department of Education Grantor Number: N/A Questioned Costs: N/A Type of Finding: Noncompliance Compliance Requirement: L. Reporting Planned completion date for corrective action plan: For the period ending June 30, 2024. Name of the contact person responsible for corrective action: Contact person: Becky Tinney, Business Manager Condition: The District did not submit their audit for the fiscal year ending June 30, 2023, timely. The audit was submitted on May 16, 2024. Corrective Action Plan: The District will implement procedures to ensure that all audit documentation is available for auditing in a timely manner and the audit report is submitted within the appropriate timeframe.

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Vancouver School District No. 37 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’s internal controls were inadequate for ensuring it complied with federal procurement requirements. Name, address, and telephone of District contact person: Brett Blechschmidt 2901 Falk Road Vancouver, WA 98661 (360)313-1341 Corrective action the auditee plans to take in response to the finding: (If the auditee does not concur with the finding, the auditee must list the reasons for disagreement). Prospectively, any call for bids involving federal funds, will be reviewed and physically signed off on by the administrator overseeing the district program that is receiving the federal grant and the district's Finance Manager before being published. This review will attempt to confirm compliance with all relevant federal procurement regulations. Anticipated date to complete the corrective action: April 1, 2024

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE East Valley School District No. 361 September 1, 2022 through August 31, 2023 This schedule presents the corrective action planned by the District for findings reported 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: Neale Rasmussen 3830 N. Sullivan Road, Spokane, WA 99216 (509) 241-5042 Corrective action the auditee plans to take in response to the finding: The District has implemented changes requiring all orders paid all or in part with federal funds in an amount greater than $25,000 to be submitted on a purchase order. Before the purchase order is approved, business office staff will complete a suspension and debarment check at SAM.gov. Anticipated date to complete the corrective action: Changes have already been implemented.

District Response and Corrective Action Plan: The Business Office will monitor the list at SAM.gov monthly and will check new vendors against the suspendered and debarment list. The District will not work with debarred vendors.

Plan: The business manager will assess the internal controls over child nutrition claims and adjust the processes to ensure accurate reporting.

The Director of Child Nutrition, Syed Zaidi, will establish an inter-program vending agreement to determine how much the National School Lunch program was charged and will submit the journal to reimburse the program. To be established as of 6/30/2024.

39-074-0250-26 CORRECTIVE ACTION PLAN FOR CURRENT YEAR AUDIT FINDINGS Year Ending June 30, 2023 Corrective Action Plan Finding No.: 2023-_ 004__ Condition: The District did not perform an on-site review of their counting and claiming system related to the Child Nutrition Cluster. Plan: The District will implement Internal controls that ensure that an on-site review of the counting and claiming system related to the Child Nutrition Cluster is performed on at least an annual basis. Anticipated Date of Completion: 06/30/2024 Name of Contact Person: Adam Clapp Management Response: Management will implement the corrective action plan for the year ended June 30, 2024.

39-074-0250-26 CORRECTIVE ACTION PLAN FOR CURRENT YEAR AUDIT FINDINGS Year Ending June 30, 2023 Corrective Action Plan Finding No.: 2023-_ 003__ Condition: The verification process was not performed. Plan: The District will complete the annual verification process by November 15th and will report the results to ISBE by December 15th. Anticipated Date of Completion: 06/30/2024 Name of Contact Person: Adam Clapp Management Response: Management will implement the corrective action plan for the year ended June 30, 2024.

Finding: 2023-032 - Pandemic Electronic Benefit Transfer Food Benefits (P-EBT) benefit payments were not issued in accordance with the process and timeframes outlined in the federally approved state plan. Testing a sample of 136 payments found 37 issuances (27 percent) were sent to unauthorized or unsupported addresses and one issuance included unauthorized benefits. Additionally, no benefits were issued during FY 23 to Supplemental Nutrition Assistance Program (SNAP)-enrolled children in child care. Questioned Costs: AL 10.542: $27,387 Assistance Listing Number: 10.542 Assistance Listing Title: P-EBT – COVID-19 Views of Responsible Officials (state whether your agency agrees or disagrees with the finding; if you disagree, briefly explain why): DOH partially agrees with the finding. The Division communicated with FNS regarding manual benefit issuance for Alaska expressing timelines would be affected and FNS did not request an updated timeline. Communication with FNS regarding issuance remained consistent, with no indication to alter our issuance plan. Address verifications were conducted at the time of benefit payment, because addresses are subject to change from the date of eligibility. Updates to addresses were made when more recent information became available. The division has no control over DEED eligibility records including the addresses they have on file. Corrective Action (corrective action planned): Shall the Division agree to administer this federal program in the future, the commissioner will allocate resources necessary to prevent the necessity to manually administer the federal program. Completion Date (list anticipated completion date): Not applicable. This federal program is complete. Agency Contact (name of person responsible for corrective action): Josie Stern, Assistant Commissioner

The School should complete all items in the corrective action plan provided by the CNU. Views of Responsible Officials and Planned Corrective Actions: The School has completed all items in the corrective action plan and submitted them to the CNU. The CNU accepted the corrective action plan items and closed their administrative review in May 2023.

The District understands that all documentation must be retained to support the verification process for free and reduced lunches. Procedures will be implemented to ensure the security of the documentation.

FINDING 2022/2023-008: Audit Report Deadline (Repeated 2021-003) Response: After the last couple years of Business manager and auditor turnover this finding will be easily corrected for the 23-24 audit.