Corrective Action Plans

CORRECTIVE ACTION PLAN October 2023 Section III: Federal Award Findings and Questioned Costs Findings and questioned costs related to Federal awards which are required to be reported in accordance with the Uniform Guidance 2 CFR 200.516(a): Significant Deficiency 2023-001 Child Nutrition Cluster - Procurement Views of the Responsible Officials and Planned Corrective Actions: The District has reviewed the requirements of 2 CFR Section 200.213. The District is in agreement with the recommendation to implement a procedure to document the process used to verify the eligibility of potential vendors to participate in Federal assistance programs. The verification of excluded parties will be accomplished by accessing the System for Award Management (SAM.gov) website and selecting the “Excluded Entity” filter on the “Exclusions” search page to search for exclusions by Unique Entity ID or CAGE/NCAGE code as follows: 1. Select “Search” from the header menu from any page on SAM.gov 2. In the filters, under “Select Domain”, select “Entity Information”, then select Exclusions 3. Use the filters or keyword box to enter the search criteria and view the results 4. Document the results in the vendor file. Other alternatives for verification may include collecting a certification from the entity or adding a clause or condition to the covered transaction or contract with that entity. The Purchasing Agent is charged with the responsibility of monitoring and ensuring compliance with the suspension and debarment procedures and maintaining documentation that contracts expected to equal or exceed $25,000 have been verified on the System for Award Management (SAM) website before purchases are made. Responsible Person(s): Matt Leon, Assistant Superintendent for Business & Operations and Michael DeSantis, Purchasing Agent Deadline for Completion: On or before 12/1/23 for covered transactions with contracts or purchase orders meeting the threshold during the time period 7/1/22 - 10/31/23. Prior to contract approval or purchase order issuance for contracts or purchase orders meeting the threshold on or after 11/1/23.

The Shared Business Services employees will work with the Management Company of the Food Services program to ensure that in situations where missed meals are identified, that proper documentation (including original tally sheets) be maintained and kept on hand to support the additional meals being claimed. In addition, they will ensure that staff are properly trained to not recreate tally sheets, but to properly document on the original copies, to ensure that meal counts are not duplicated.

October 24, 2023 Finding Number: 2023-004 – Material weakness in Internal Control – Reporting (Repeat Finding) Condition: In six of the eleven months tested, the number of meals included on the reimbursement claim reports were not supported by the District’s internal count sheets. Responsible Person: Kim Gagne – Director of Food Service Implementation Date: 10-24-2023 This year we have partnered with Meal Magic, for reporting claims. Every student must enter an identification number or scan an ID card so that students cannot be missed or over-claimed. The Direct Certification students are compared monthly against the state information provided to make sure students are claimed at the correct rate. Sincerely, Stephen Grubaugh Director of Business Service

October 24, 2023 Finding Number: 2023-003 – Significant Deficiency in Internal Control – Eligibility Condition: Of the 22 applications for reduced meals that were selected for testing, 3 did not document evidence of review by staff. Responsible Person: Kim Gagne – Director of Food Service Implementation Date: 10-24-2023 This year we have a 2-person checking system, Kim Gagne initially completes the applications with a signature and Jody King double checks every application for errors and oversites and adds her signature also. Both have been through the MDE training on the applications and the required information they need. Sincerely, Stephen Grubaugh Director of Business Services

October 24, 2023 Finding Number: 2023-002 – Significant Deficiency in Internal Control / Noncompliance – On-Site Reviews Condition: An on-site review was not completed for all sites in which lunches were served. Responsible Person: Kim Gagne – Director of Food Service Implementation Date: 10-24-2023 On-site reviews for Lunch and Breakfast are mapped out on the calendar to have completed by Kim Gagne before the due date of Feb 1st, for all 5 schools. This time line will give the time to make sure deficiencies are addressed and corrected. Sincerely, Stephen Grubaugh Director of Business Services

Kenowa Hills Public Schools respectfully submits the following corrective action plan for the year ended June 30, 2023. Auditor: Maner Costerisan 2425 E. Grand River Ave., Suite 1 Lansing, Michigan 48912 Audit Period: Year ended June 30, 2023 District Contact Person: John Gilchrist, Director of Finance The findings from the June 30, 2023 schedule of findings and responses are discussed below. The findings are numbered consistently with the number assigned in the schedule. Finding - Financial Statement Audit Finding 2023-001 Considered a material weakness Recommendation: The District should ensure that reconciliations are completed in a timely manner in order to correct any potential errors sooner. Action to be Taken: Management agrees with the finding and we are in the process of developing a plan as recommended. Finding – Federal Award Findings and Question Costs Finding 2023-002 Considered a significant deficiency Recommendation: The District should thoroughly train staff on their responsibilities for how to properly count meals served to ensure accurate record keeping. Action to be Taken: Management agrees with the finding and has implemented procedures to thoroughly train staff on how to accurately count meals and maintain records.

OKEMOS PUBLIC SCHOOLS FOR THE YEAR ENDED JUNE 30, 2023 Okemos Public Schools respectfully submits the following corrective action plan for the year ended June 30, 2023. Auditor: Maner Costerisan 2425 E. Grand River Avenue, Suite 1 Lansing, MI 48912 Audit Period Year ended June 30, 2023 District Contact Person: Liz Lentz, Executive Director of Finance Finding 2023-001: Considered a significant deficiency in internal control over compliance. Recommendation: The District should consistently utilize a point-of-sale system to track and claim the number of meals served. Action to be Taken: Management agrees with the finding and had already changed procedures during the school year to better track and claim meals.

The district has updated their spend down plan as of July 2023 to address the excess fund balance in food service. The Food Service Director and the Director of Business Services have already identified areas where there are needs for upgrades or enhancements. Over the next several months, the Excess Fund Balance will get used to improve the Food Service Porgram.

Finding No.: 2022-012 AL Programs: 10.542 - Pandemic EBT Food Benefits (P-EBT) Area: Eligibility Questioned Costs: $58,494 Contact Person(s): Margaret Aldan, NAP Administrator Corrective Action Plan: Condition 1 & 2: CNMI NAP respectfully disagrees. Audit finding states that documentation supporting eligibility determinations were not provided. Finding further states that CNMI NAP lacks monitoring control over the listing of validated eligibility roster data that were not uploaded into MAVEN eligibility system due to data entry capacity limitations (sic) were not being maintained; and Distributed coupons were not reconciled to the recorded expenditures for redeemed coupons. The resulting effect being that CNMI NAP is in noncompliance with the applicable eligibility requirements and questioned costs for condition 1. CNMI NAP was informed that this finding had been cleared so we are perplexed as to the re-emergence of this audit finding. CNMI NAP contends that: 1. Eligibility for P-EBT benefits is not determined by CNMI NAP. P-EBT eligibility was determined by identifying children who qualified for free or reduced-price school meals and then correlating that with a reduction of in-person schooling due to COVID-19. Children in households receiving SNAP and young children, under age six, were also eligible, provided their schools or childcare facilities closed or reduced hours for at least five consecutive days due to the pandemic. This data was provided by PSS, as well as the listing of eligible children that corresponded to this data set. 2. There are no “validated eligibility roster data case files” that were not uploaded into MAVEN due to data entry capacity limitations. All rosters provided by PSS were uploaded into MAVEN as this is the only way a case file can be generated in the system. 3. CNMI NAP has reconciled all benefits issued, including the P-EBT benefits for the audit year in question. This is a mandatory, non-negotiable process. Proposed Completion Date: Ongoing

Finding No.: 2022-011 AL Program: 10.542 - Pandemic EBT Food Benefits (P-EBT) Area: Activities Allowed or Unallowed Questioned Costs: $-0- Contact Person(s): Margaret Aldan, NAP Administrator Corrective Action Plan: CNMI NAP respectfully disagrees with this finding. The April 2022 Compliance Supplement referenced by the auditor states: Special Tests and Provisions. 1. Verification of Free and Reduced-Price Applications (NSLP) Compliance Requirements: By November 15th of each school year, the LEA (or state in certain cases) must verify the current free and reduced-price eligibility of households selected from a sample of applications that it has approved for free and reduced-price meals, unless the LEA is otherwise exempt from the verification requirement. The verification sample size is based on the total number of approved applications on file on October 1st. A state agency may, with FNS approval, assume from LEAs under its jurisdiction the responsibility for performing the verifications. If the LEA performs the verification function it must be in accordance with instructions provided by the state agency. The LEA must follow up on children whose eligibility status has changed as the result of verification activities to put them in the correct category. CNMI NAP response: The 2022 Compliance Supplement states that the LEA, in this instance, PSS, is responsible for verifying the current free and reduced-price eligibility of households unless the LEA is exempt from the verification requirement. PSS is not exempt from the verification requirement and the CNMI NAP has never given instructions to PSS for data collection as it is the PSS’ responsibility to supply the data to NAP for P-EBT. NAP’s role is to distribute the benefits only. Similar to the SUN Bucks (S-EBT) program, PSS furnishes the student listing to NAP, after which NAP distributes the benefits according to the listing provided by PSS. Proposed Completion Date: Ongoing

Corrective Action: The Food Distribution Program will take steps to submit programmatic reports in a timely manner. The accountant responsible for the grant, along with the Procurement, Grants, and Contracts program, will monitor deadlines and follow up with the program as necessary. Additionally, the Grants program has recently implemented new Grants Management software, Instrumental, which will assist in tracking grant deadlines. Person(s) Responsible: Food Distribution Director Estimated Completion Date: July 31, 2025

Management agrees with the finding and has established a monthly meeting between the Business Manager and the Cafeteria Director in order to review the monthly budget and allocate all appropriate expenses in a timely fashion. The Business Manager has implemented these accounting changes. This process was completed in October of 2022.

Management agrees with the finding and has established a monthly meeting between the Business Manager and the Cafeteria Director in order to review the monthly budget and ascertain that all appropriate expenses are disbursed only for the federally funded department. The Business Manager has implemented these accounting changes as of September 2022.

Management agrees with the finding and has developed a set of policies and documented them. The Business Manager has implemented the changes as of June 2023.

Procure the services of an accounting professional to verify the accuracy and adherence to accounting methods and reporting procedures to assist with the administration of the Child and Adult Care Food Program (CACFP)

Finding 2022-002 Corrective Action Plan Details A. Contact person responsible for corrective action: Name: Dr. Mario Willis Title: Superintendent B. Description of corrective action planned: The district will strengthen its internal control systems over reporting to ensure single audit reporting package and data collection form are submitted to the Federal Audit Clearinghouse within established timeframe and financial statements are prepared timely. C. Anticipated completion date of corrective action:

Auditee Response: The auditee agrees with the finding. This was a perfect storm of events that created this scenario including COVID requiring the discontinuation of our Point of Sale (POS) System, tally sheets by classroom being used in place of that system, a change in head cooks during the year, and a failure to communicate properly between the Director of Food Service and the new Head Cook. Action Taken: The district has and will reinstitute the use of its POS system so that a child purchasing lunch types in their number and it is credited to that child's account. This system can then be used to track meal purchases throughout the day, week, or month. Since the HeadStart classroom are not MWSD students, they do not have numbers within the system. The Director of Food Services will use this system to report meal purchases and reimbursement rather than rely on head cooks and their tally sheets. Despite this, training should be conducted annually with all head cooks as to the qualifications of a reimbursable meal within the school district, so as to provide a fail safe in the event the POS system goes down for a period of time. Timelines/Contract: Most of this has taken place already in that we have returned to using a POS system. This system has the ability to track data and run reports, so it makes it error free when available. However, people ultimately must have the knowledge too so that they understand the parameters of a reimbursable meal should the system go down. Therefore, annual trainings will be instituted regarding such operations effective immediately. The Director of Food Service will be directed to use one in-service day annually for the purpose of teaching all staff members about reimbursable meals and how the HeadStart Programs fit into that. This should be completed no later than fall of 2025. The contact person would be Joe Stroup, Superintendent.

The Organization has created a process to move all documents to cloud based storage, including recipient agency contracts for USDA and proof of tax-exempt status under Internal Revenue Code 501(c)(3).

Deficiencies in controls surrounding the cash management and program income. A. Name of contact person responsible for corrective action: Name: Courtney Bershell Title: Business Manager B. Corrective action planned: The district will implement changes to ensure child nutrition management software be used to document and support the daily meal counts that will be used for claim reimbursements. C. Anticipated completion date: June 30, 2024.

Finding 2022-002 “Improve Time and Effort Documentation” Correction Action to be taken: The Town is reviewing all school contracts and time sheets for inefficiencies and requiring adjustments or more documentation as necessary. Expected Completion Date: We anticipate that all major inefficiencies within school payroll will be eradicated by June 30, 2025. Contact Person: Julie Hebert, Finance Director; Janet Jannell, Treasurer/Collector; Gale Clark, School Business Manager

2022-002 a. Name of Contact Person Responsible for Corrective Action Name: Mary Beth Sheffield Title: Child Nutrition Director Phone Number: 662-423-3206 b. Corrective Action Planned: The District will increase training to appropriate personnel and ensure all documentation is fully reviewed to make sure requirements are met before processing eligibility applications. c. Anticipated Completion Date: 10/08/2024

The District no longer exists due to consolidation. Internal controls will be practiced in the new district by the Director of Finance. Anticipated completion date: 6/30/23

here was inadequate oversight of activities and information provided by the contractor resulting in a material overstatement of meals claimed for the current year. Sufficient controls were not in place for the current fiscal year to ensure that an accurate meal count was claimed for USDA reimbursement. We recommend that a knowledgeable person be assigned responsibility for oversight of the child nutrition program. We further recommend procedures be implemented to provide oversight of contractor services and information provided including a review process for the USDA claims requests. Views of Responsible Officials and Planned Corrective Actions: The Academy has employed a supervisor responsible for overseeing the child nutrition program and the contract with the previous provider has terminated. Further, the Academy currently provides onsite meal service beginning with the 2022-23 school year provided by a new contractor.

AUDITEE’S CORRECTIVE ACTION PLAN As required by Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost principles, and Audit Requirements for Federal Awards (UG), the East Tallahatchie School District has prepared and hereby submits the following corrective action plan for the findings included in the Schedule of Findings and Questioned Cost for the year ended June 30, 2022:  Finding 2022-001 Corrective Action Plan Details A. Contact person responsible for corrective action: Name: Raymond Russell Title: Superintendent B. Description of corrective action planned: The district will implement controls and procedures to ensure that all expenditures are properly authorized prior to goods being ordered or services being rendered. C. Anticipated completion date of corrective action: Immediately 2022-002 Corrective Action Plan Details A. Contact person responsible for corrective action: Name: Raymond Russell Title: Superintendent B. Description of corrective action planned: The district will implement policies or procedures to establish an internal control system that will ensure strong financial accountability, proper safeguarding of assets and accurate accounting records. C. Anticipated completion date of corrective action: Immediately 2 2022-003 Corrective Action Plan Details A. Contact person responsible for corrective action: Name: Raymond Russell Title: Superintendent B. Description of corrective action planned: The district will implement policies or procedures to establish an internal control system that will ensure strong financial accountability, proper safeguarding of assets, and accurate accounting records. C. Anticipated completion date of corrective action: Immediately 2022-004 Corrective Action Plan Details A. Contact person responsible for corrective action: Name: Raymond Russell Title: Superintendent B. Description of corrective action planned: The district will implement policies or procedures to establish an internal control system that will ensure strong financial accountability, proper safeguarding of assets, and accurate accounting records. C. Anticipated completion date of corrective action: Immediately 2022-005 Corrective Action Plan Details A. Contact person responsible for corrective action: Name: Raymond Russell Title: Superintendent B. Description of corrective action planned: The district will implement policies or procedures to establish an internal control system that will ensure strong financial accountability, proper safeguarding of assets, and accurate accounting records. C. Anticipated completion date of corrective action: Immediately 3 2022-006 Corrective Action Plan Details A. Contact person responsible for corrective action: Name: Raymond Russell Title: Superintendent B. Description of corrective action planned: The district will implement policies or procedures to establish an internal control system that will ensure strong financial accountability, proper safeguarding of assets and accurate accounting records. C. Anticipated completion date of corrective action: Immediately 2022-007 Corrective Action Plan Details A. Contact person responsible for corrective action: Name: Raymond Russell Title: Superintendent B. Description of corrective action planned: The district will strengthen its internal control systems over reporting to ensure single audit reporting package and data collection form are submitted to the Federal Audit Clearinghouse within established timeframe and financial statements are prepared timely. C. Anticipated completion date of corrective action: Immediately

Contact Person Evan Peltier Planned Corrective Action Dunseith Public School Dist. #1 will implement the recommendation from Brady Martz. Planned Completion Date The planned completion date will be the start of FY-23.