Corrective Action Plans

3. Finding 2023-003. Fund Balance Management Corrective Action: Previous audit year expenses were classified as “General” funds when they should have classified as “Food Service”. This, in aggregate, has led to an excess fund balance. Management, will work with the state on how to transfer the large arrear fund balances between accounts. Management will also endeavor to assure that all ongoing expenses are allocated to the correct fund. Responsible Person/Position: Rod Iberg/COO and Linda Heidrich/Staff Accountant

The Center did not retain the eligibility documentation for one student and there was an incorrect computation for one student. Response and Planned Corrective Action: The Center acknowledges this finding, and will take the steps necessary to ensure that the information in the system is updated regularly. Planned Corrective Action: to be implemented immediately. o The Director of Food Service will review the controls currently in place and revise accordingly to ensure that accuracy and completeness of data is maintained. o Proper documentation will be maintained by school staff and will be reviewed regularly by the Director of Food Services and or the Business Manager/Asst. Business Manager.

The Bookkeeper will look at and sign off on all final food service claims before being submitted.

The District will develop a plan to reduce the food service fund's net cash resources below its three month average expenditures as required by CFR Section 210.14 Resource Management (b) Net Cash Resources.

Condition: The District submitted claims for meal reimbursements that were higher than the meals actually served. Plan: Management will review and implement procedures to ensure the reports used for daily counts match the reports used for submitting the claim to ISBE. Anticipated Date of Completion: 6/30/2024 Name of Contact Person: Annie Mulvaney, Assistant Superintendent Management Response: N/A

FINDING 2023-007 Compliance Requirement(s): Non-Profit School Food Service Accounts Audit Findings: Material Weakness, Other Matters Summary of Finding: There was no documented control in place over the receipt of monthly meal reimbursements. One individual received notification of deposit, received funds into accounting software, and prepared bank reconciliations. There was no documented review of the receipt of monthly meal reimbursements by a second individual not involved in the original receipt process. Views of Responsible Officials: We Concur with this finding. Description of Corrective Action Plan: The Business Manager and Cafeteria Manager will meet monthly to review the deposit statement from the bank to verify all deposits are accurate and accounted for the Food Service Fund. The bank statement will be initialed by both parties and retained on file in the business office. Anticipated Completion Date: Immediately

FINDING 2023-006 Compliance Requirement(s): Reporting Audit Findings: Material Weakness, Other Matters Summary of Finding: An effective internal control system, which would include segregation of duties, was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the following compliance requirements: Reporting There was no documented control in place over the review of monthly reimbursement claims. Claims were prepared and submitted by one individual without documentation that they were being reviewed by a second person not involved in the original process. The lack of controls resulted in overstatements in the number of meal counts used for reimbursement purposes when compared to School Corporation supporting documentation. Views of Responsible Officials: We Concur with this finding. Description of Corrective Action Plan: The food service director will enter the claims into CNPWeb Claim reimbursement site using the information from the Point of Sale system reports for reimbursable meals. The Business Manager will then confirm the meal counts before submitting the Claims. The FSMC food service director meets with the Superintendent monthly to review all claims and food service financials. A meeting agenda will be signed by all parties involved and retained on file in the business office. Anticipated Completion Date: Immediately

FINDING 2023-005 Compliance Requirement(s): Allowable Activities, Allowable Costs / Cost Principles Audit Findings: Material Weakness, Other Matters Summary of Finding: An effective internal control system, which would include segregation of duties, was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the following compliance requirements: Allowable Activities, Allowable Costs / Cost Principles The School Corporation paid trash removal services from the School Lunch fund without a methodology or supporting documentation for the amount charged. Without a reasonable methodology for the expenses paid, the amount was considered a questioned cost. The total amount charged to the School Lunch fund was $15,448. Internal controls over vendor disbursements were in place but were not operating effectively during the audit period. Additionally, there was no documentation indicating that payroll disbursements were reviewed or approved by a second individual not involved in the original payroll process. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Views of Responsible Officials: We Concur with this finding. Description of Corrective Action Plan: The School will start to divide trash removal services between cafeteria accounts and building accounts when being paid monthly. Verification of percentage coming from each account will be discussed. Internal controls will be put in place to document that payroll disbursements are being reviewed by a second individual. Payroll disbursement reports will be presented to the correct central office employee. Anticipated Completion Date: Immediately

Plan: The District will keep physical copies of reports and claims submitted. As students switched categories (free, reduced, and paid), the electronic system failed to keep that in account, leading to discrepancies.

The District will develop a plan to reduce the food service fund's net cash resources below its three month average expenditures as required by CFR Section 210.14 Resource Management (b) Net Cash Resources.

Finding 2023-004 - Corrective Action Plan CHSD - 2022-2023 Audit Findings Finding 2023-004 – SPECIAL TESTS AND PROVISIONS (repeat comment) Type: Significant Deficiency in Internal Control / Noncompliance Program: Child Nutrition Cluster (ALN 10.553, 10.555 and 10.559) Condition: As of year-end the District had a fund balance in the non-profit food service fund in excess of three months’ operating expenses by approximately $157,881. Criteria: The USDA requires that the District limit its net cash resources to an amount that does not exceed 3 months average expenditures of the non-profit food service fund per requirements in 7 CFR Part 210.14(b). Cause: This condition was caused by the meal claims increasing and having more reimbursements come in than anticipated. Corrective action to be taken: Over the 2023-2024 school year, the District will continue to leverage the excess fund balance to improve the quality of the food service program. Efforts to address the ongoing excess fund balance condition are ongoing and, while planning started in the 2022-2023 school year, an aggressive food service capital reinvestment project is scheduled to be completed in the 2023-2024 school year. This $220,000+ project will address equipment replacement and student service improvements in both the High School and the Middle School. The spend down associated with this project is anticipated to offset the excess fund balance on June 30, 2023, as noted in this finding. However, anticipating the potential for continued Food Service Program funding support at a state and federal level, the CHSD food service department will continue to monitor the fund balance with the goal of proactively managing any forecasted excess balance by continuing to offer more new food choices and improve the quality of the food served (including more fresh produce and better-quality ingredients). These improvements will continue to be in conjunction with the Michigan Department of Education's Office of School Support Services which will again approve the spending plan. The corrective action timeline is as follows: The corrective action is effective immediately and encompasses the ongoing efforts on the part of the District to comply with program criteria while balancing unpredictable statutory revenue streams against spending forecasts in the highly volatile food service market conditions. The District anticipates compliance with the Fund Balance condition set forth in the program by 6-30-2024. District Leader Responsible for Corrective Action Plan: The Food Service Administrator will be responsible for ensuring compliance with this corrective action. Respectfully submitted, Marc Forrest, Director of Finance

Contact Person Responsible for Corrective Action: Nicole Fortier, Director of Finance and Operations Corrective Action: During our audit it was identified that MMUUSD overpaid an employee for four charges under the Food Service program and charged the work to the program that was not specific to Food Service. To be more specific, Food Service subs were paid at a higher rate ($.50 higher) than the stated rate for a Food Service substitute. Additionally, there were instances noted where a maintenance substitute was charged to a Food Service budget unit. The first step in our corrective action plan was a review with our Senior Payment Specialist of the importance of slowing down and verifying the correct hourly rate being input for our substitutes. This step has already been completed. Additionally, we are in the process of implementing a more thorough payroll review process, which will include a preliminary review by Christal Clark, Accountant in the Business Office. Once Christal has completed her review, this will go to Nicole Fortier, Director of Finance for a final, high‐level review and sign off. We are hopeful to begin the process at the end of FY24, with full implementation in FY25. Anticipated Completion Date: 7/01/2024

The District will reduce net cash resources by investing in capital equiment where necessary and allocating direct cost overhead expenditures.

Corrective Action Taken or Planned: Child Nutrition, Inc. is in contact with the Virginia Department of Health (VDH) awaiting official written notification of the requirement that the three visits per year take place within the fiscal year. Immediately, for the current fiscal year (FY2024), the Executive Director analyzed the Review History Report for all active providers to ensure compliance within the current fiscal year. The Executive Director drafted and finalized Reports Required to ensure Monitor Compliance within Fiscal Year (October – September) on March 11, 2024 and trained all Organization staff on March 14, 2024. Reports Required to ensure Monitor Compliance within Fiscal Year (October – September) • Review History Report: Executive Director and Field Specialist Manager are to review quarterly and communicate with Field Specialist if there are any discrepancies or required action. Field Specialists are required to run report for their case load and review quarterly. • Provider Due Reviews: Executive Director and Field Specialist Manager are to review monthly and communicate with Field Specialist if there are any discrepancies or required action. Field Specialists are required to run report for their case load and review monthly • Providers Not Trained: Executive Director and Field Specialist Manager are to review monthly and communicate with Field Specialist if there are any discrepancies or required action. Field Specialists are required to run report for their case load and review monthly • Sponsor Review Worksheet – Past Review History Executive Director and Program Manager will review the past review history on the Sponsor Review Worksheet as reports are received and entered into Minute Menu. The Program Manager will update Review# in Minute Menu. The Executive Director will edit next review due date as necessary. Name of Contact Person: Elizabeth Wittusen, Executive Director Phone Number of Contact Person: (540) 347-3767 Projected Completion Date: March 2024

FINDINGS—FEDERAL AWARDS 2023-001: Reporting Type of Finding: Noncompliance, significant deficiency Condition/Context: The District overclaimed meals served by 16 lunches, resulting in an overpayment of $71. Action planned in response to finding: The District will evaluate its internal control procedures over the preparation of meal reimbursement claims to eliminate clerical errors to ensure that the meals claimed to the Arizona Department of Education are accurately reported. Planned completion date for corrective action plan: For the period ending June 30, 2024. Name of the contact person responsible for corrective action: Casey Hancock, Business Manager

Management has identified the incidents where an agency signature was not obtained upon two deliveries of USDA foods to that agency. Management has verified that the deliveries of USDA foods to that agency were legitimate deliveries in accordance the Compliance Requirements for the Emergency Food Assistance Program. Management believes that enhanced training and supervision will improve the application of management's documented controls that require agency signatures be obtained upon delivery of USDA foods to partnering agencies.

Dear Mr. Waguespack, Please accept this letter as the Louisiana Department of Education's (LDOE) official response to the draft finding submitted by your office of the financial audit for the LDOE for the fiscal year ending June 30, 2023. A review of the audit finding has been conducted, and we concur with the finding. Recommendation: While there was significant improvement in reporting for ESF, LDOE should continue to strengthen internal controls to ensure accurate information is reported and should correct all amounts and obligation dates that were previously reported incorrectly. LDOE Response: LDOE has prioritized addressing the implementation of procedures and internal controls to comply with the requirements of FFATA. As noted in the recommendation, the agency has made significant improvements with the corrective actions taken during the 2022-2023 year in regard to the internal FFATA data reporting process. To remedy the issues identified previously, LDOE hired and trained a full-time staff person in October 2022 to be responsible for the accuracy and timeliness of reporting FFATA fiscal data. In addition, LDOE developed a FFATA reporting tracker to strengthen internal controls, which has aided in improving the agency’s ability to ensure the reporting of accurate and timely data to the FFATA Subaward Reporting System (FSRS). All of these measures were in place for the FY23 FFATA reporting timelines noting that the LDOE had committed to a deadline of September 2023 to correct all prior year findings, and the LDOE met this timeline. LDOE now has the FFATA reporting infrastructure in place to ensure reports are successfully submitted accurately and timely to FSRS for the Education Stabilization Fund (ESF) and ESEA. During the current audit, it was determined that the FY2021 and FY2022 FFATA prior year findings across the majority of programs were cleared. Because of LDOE’s commitment to accurate and timely data reporting, the LDOE staff conducted its own review of fiscal data submitted to comply with FFATA. During this review, the LDOE staff identified a discrepancy in the report that is generated by an internal system used for the FFATA reporting for the Child Nutrition Cluster (CNC) and the Child and Adult Care Food Program (CACFP). It was determined that the report had been programmed in 2011 to pull cumulative totals versus monthly totals each month. Therefore, this system’s incorrect reporting had gone unnoticed by LDOE and the USDA for over a decade. This data reporting error resulted in an over-reporting of the total awards for CNC and CACFP since the creation and implementation of FFATA reporting. LDOE had received no guidance from the awarding agency regarding the FFATA reporting until contacting them recently for advice on this matter. LDOE notified the Legislative Auditors of this internal control issue during the onset of the FFATA CNC portion of the audit. The LLA has since noted this inaccuracy as a finding. Since identifying this discrepancy, LDOE has taken initiative to resolve this issue by contacting the system developer to change the generated report, contacting the awarding agency (USDA) for clarification surrounding the CNC and CACFP FFATA reporting requirements, and submitting a helpdesk ticket in the FSRS to correct the FY2023 reported amounts. During the FY23 audit of the ESF Elementary and Secondary School Emergency Relief program funded by the Coronavirus Response and Relief Supplemental Appropriation Act and the American Rescue Plan Act, a test of 474 subawards totaling $293,847,931 related to 20 subwardees showed that LDOE reported the incorrect obligation date in the FSRS for 47 subawards totaling $967,987. This one issue represents an error rate of only .3%. Although the program fiscal data was accurate, the timeliness of when it was reported could have been slightly better. This immaterial issue will be resolved with increased staff training and enhancement of verification routines. LDOE has taken the requirement to submit reports accurately and timely very seriously and continues to dedicate extra time and resources to ensure all data reporting is accurate. If you have any questions, you may contact Keisha Payton by telephone at 225-219-4426 or via email at keisha.payton@la.gov.

FINDING 2023-005 Finding Subject: Child Nutrition Cluster - Special Tests & Provisions: School Food Service Accounts 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 for Special Tests & Provisions: School Food Service Accounts. Contact Person Responsible for Corrective Action: Amy K. Sivley Contact Phone Number and Email Address: 260-563-2151; sivleya@apaches.k12.in.us Views of Responsible Officials: We concur with the finding. Explanation and Reasons for Disagreement: n/a Description of Corrective Action Plan: On a monthly basis, Corporation Treasure will print receipt postings to be reviewed, verified and signed off by Superintendent/CFO. Anticipated Completion Date: To begin immediately, March 2024

FINDING 2023-003 Finding Subject: Child Nutrition Cluster - Allowable Activities and Allowable Costs Summary of Finding: The School Corporation had not properly designed or implemented a system of internal control, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting noncompliance related to allowable activities and allowable costs. The School Corporation purchased two pieces of equipment that were over $5,000 each in Fiscal Year 2023 without approval from the Federal awarding agency or pass-through entity. The first piece of equipment was a liftgate in the amount of $6,906, and the second piece of equipment was a vehicle in the amount of $7,500 for a combined total of $14,406. The financial management system of each non-federal entity must provide written procedures for determining allowability of costs in accordance with the federal regulations and the terms and conditions of the Federal Award. The policy should provide clear guidance as to what costs constitute appropriate direct and indirect charges to federal awards as well as provide for consistency in charging practices across the School Corporation. The School Corporation did not have an allowable costs policy outlining the School Corporation's processes and policies with regards to costs charged to federal grants. Contact Person Responsible for Corrective Action: Amy K. Sivley Contact Phone Number and Email Address: 260-563-2151; sivleya@apaches.k12.in.us Views of Responsible Officials: We concur with the finding. Explanation and Reasons for Disagreement: n/a Description of Corrective Action Plan: Retrain Food Service Director and Assistant Food Service Director on the process for purchasing equipment. The district will also develop and pass an Allowable Costs Policy. Anticipated Completion Date: To be completed by July 1, 2024

Corrective Action Planned: Community Action Center of Northfield (CAC) is working with our food sourcing partners to investigate better accounting practices from their end to more accurately facilitate USDA food inventory before the food stuffs are delivered to CAC. Additionally, CAC will investigate cost-efficient models of physical inventory for in-kind donated (free) food. Name(s) of Contact Person(s) Responsible for Corrective Action: Scott Wopata, Executive Director, will be responsible for leading correct actions Anticipated Completion Date: While CAC is hopeful to receive more accurate inventory records from our food sources, this is outside of our control. Additionally, initial research into inventory management systems have proven extremely cost prohibitive as they relate to technology and/or labor, especially related to in-kind donated (free) food. We will pilot manual weekly inventory counts in the 2024/25 fiscal year with full corrective actions to reflect the outcome of those pilot studies.

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 Jackson Public 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, 2023: Finding 2023-001 Corrective Action Plan Details A.    Contact person responsible for corrective action: Name: Marc Rowe Title: Executive Director B.    Description of corrective action planned: The district will implement and strengthen its internal control systems over reporting and submitting its monthly claims for reimbursement to ensure claims are submitted within established reporting deadlines. C.    Anticipated completion date of corrective action: 6/30/2024

The Director of Nutrition Services, hired August 2023, has been trained on the verification process and procedures along with timeline compliance requirements.

The Director of Nutrition Services, hired August 2023, has been trained on the verification process and procedures along with timeline compliance requirements.

FINDING 2023-002 Information on the federal program: Subject: Child and Adult Care Food Program Federal Agency: Department of Agriculture Federal Program: Child and Adult Care Food Program Assistance Listing Number: 10.558 Federal Award Numbers and Years (Or Other Identifying Number): FY2022, FY2023 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Procurement and Suspension and Debarment Audit Finding: Material Weakness, Qualified Opinion Condition: There was not an effective control in place to review underlying transaction detail billed by the food service management compliance to verify compliance with Activities Allowed or Unallowed requirements. There was also not an effective control in place to monitor and review the food service management company followed procurement and suspension and debarment regulations. Context: As a result of the COVID-19 pandemic, waivers from the federal government provided free meals to all students through the Summer Food Service Program and allowed meals to be consumed off-site. Due to the changing regulations, the USDA and IDOE required School Corporations to implement an Integrity Plan for any schools providing Grab and Go Meals which includes inquiring of any adult requesting meals without children present as to how many children under the age of 18 would be served. Prior to March 2020, the School Corporation was using a point-of-sale system to record meals served. Starting in March 2020, the School Corporation was authorized by IDOE to utilize a clicker to track meals served. During the summer months of 2021, the School Corporation was also authorized by IDOE to provide meal pickup service on Wednesdays from 3 – 6 p.m. for 5 days’ worth of meal for both breakfast and lunch, resulting in 10 meals being served per child under the age of 18 each week. In June 2021, the Indiana Department of Education performed an unannounced meal site observation and a second, announced meal site review noting several program compliance and administrative issues. In July 2021, the IDOE performed a targeted review of the Summer Food Service Program for the period of March 2020 through May 2021 noting the following program compliance issues. • Meals were distributed without ensuring they were going to children ages 18 and younger as required by SFSP regulations. • Meals were taken off site to be distributed/dropped off at non—approved locations. • Meals were distributed and claimed on days when no meal service was approved, • Meals were distributed outside of approved meal service times. • Some meals were not distributed in household size quantities to the parent or guardian but distributed in bulk to large groups and knowingly transported in unsafe and unsanitary ways. • Meal count records were incomplete, unsigned, or missing required information. • Meal production was not adjusted when attendance fluctuations were noted. • Different menu items were ordered for and distributed to a specific group of individuals that was not the same as the planned menu. • Menu planning did not consider food inventory on hand and MSD of Pike Township’s access to USDA Foods (commodities) to reduce overall food costs. • Unauthorized donation, distribution, and disposal of foods purchased with federal funds was made without MSD Pike administration knowledge or approval. The review also noted a lack of administrative oversight of the food service management company contract including the following issues: • Food service management company representatives were making decisions regarding child nutrition program operations without consulting MSD of Pike Township administration. This practice was ongoing and occurred over several administrations. • Potential unallowable expenditures were noted in a review of monthly itemized invoices presented to MSD of Pike Township for recent payment. Items for personal consumption of food service management employees such as coffee, energy drinks, donuts, lunches, and even unauthorized travel expenses were presented but are considered unallowable expenditures from the food service account. As a result of the review, a total of $623,724 was disallowed for unsupported meal claims from September 2020 through May 2021 from the Child and Adult Care Food Program (CACFP) for At-Risk suppers reimbursed through the CACFP program. The School Corporation and IDOE agreed to a repayment plan to repay the disallowed costs identified which was paid in December 2021. Activities Allowed or Unallowed, Allowable Costs/Cost Principles During the testing of activities allowed or unallowed and allowed costs/cost principles, we selected 6 monthly invoices from the food service management company during the audit period. We noted there was not an internal control in place by School Corporation personnel to obtain and view the underlying support of transactions charged by the food service management company to verify the transaction was for a business purpose. The School Corporation did not obtain and review source documents, such as invoices or proof of payment for vendor transactions or a schedule of employees, assigned locations, salaries, and hours to be worked for payroll transactions submitted by the food service management company for reimbursement. We also selected a sample of 40 vendor transactions charged to Fund 0800 to test which were not related to the food service management company and incurred directly by the School Corporation. For 6 of the 40 transactions tested, we noted transactions for concession fees which were charged to the School Nutrition Program from July 2021 through September 2022 and are deemed unallowable. In October 2022, the School Corporation began recording all concession activity to Fund 2180, Concessions – District. The six concession transactions in our sample total $663 which are considered known questioned costs. Procurement and Suspension and Debarment The School Corporation did not have an internal control in place to monitor the food service management company was following proper procurement standards. School Corporations that contract with a food service management company on a cost reimbursement basis should ensure they are monitoring contracts sufficiently including verifying or reviewing the following: • The School Corporation should receive contract commits to supply. • Reviewing invoices received from the food service management company compared to amounts paid by the food service management company. • Reviewing contracts for compliance with Buy American • Verifying return of discounts, rebates, or credit are properly applied to the School Corporation’s account. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. MSD of Pike Township (Pike) agrees during the audit period effective controls were not in place to review and approve meal counts tracked and submitted for reimbursement, review underlying transaction detail billed, nor monitor and review the Food Service Management Company (FSMC) followed procurement and suspension and debarment regulations. Pike has increased the Business Office oversight of the Food Service Management Company (FSMC). Pike has hired a Food Service Financial Specialist to provide more the detailed review of invoices and operations ledger and the underlying transaction details. Additionally, effective October 2022, MSD of Pike Township hired a Director of Food Service to provide oversight of the Food Service Management Company (FSMC) including but not limited to meal counts, site audits, and compliance with procurement regulations. The FSMC no longer has access to submit claims on the CNP website. Responsible Party and Timeline for Completion: Greg A. Foster, Chief Financial Officer, will oversee the corrective action plan.

FINDING 2023-003 Information on the federal program: Subject: Child Nutrition Cluster – Suspension and Debarment Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Numbers and Years (Or Other Identifying Number): FY2022, FY2023 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Material Weakness Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the Child Nutrition Program and Procurement and Suspension and Debarment compliance requirements. Context: During the audit period, the School Corporation had purchases over $25,000 from three vendors charged to Fund 0800 – School Lunch Fund which requires suspension and debarment procedures. For one of two vendors selected for testing, there was no evidence provided to verify that the vendor was checked for suspension and debarment prior to entering into the transaction. The total amount disbursed to the vendor during the audit period was $141,128. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. Specifically, regarding Suspension and Debarment, for contracts over $25,000, MSD of Pike Township will obtain a Certification or include a Suspension and Debarment clause in the contract. Absent Certification, the Director of Grants will review for “Suspension and debarment” and maintain documentation. This review will continue annually. Responsible Party and Timeline for Completion: Greg A. Foster, Chief Financial Officer, will oversee the corrective action plan.