Corrective Action Plans

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 (2021-004) 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.

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

Audit Finding Reference: 2022-005 Limit Federal Cash on Hand (Significant Deficiency) Planned Corrective Action: The district is aware of this finding and will be taking steps to address this in the coming months. The City needs to decrease the cash balance in the school lunch fund so that it falls within acceptable Federal guidelines. Name of Contact Person and Completion Date Kevin McHugh, City of Lynn School Business Manager December 31, 2024

The Business Administrator and Accountant will review monthly net cash resources in the Food Service Fund to ensure year-end does not exceed three-month average.

1. Receive the CACFP check, and book all revenue to CACFP Budget line(5230) 2. Generate an invoice based on the IPV tool and rates laid forth in EUSD inter program agreement 3. Create JE debiting CACFP(5320) expense account and crediting NSLP(5310) expense account These steps will track funding sources and revunes by progrm in which it follows Child and Adult Care Food Program, Child Nutrition Cluster, National School Lunch Program Guidelines. Contacts: Bao Ho and Anna Scimone

The responsible officials agree with the finding and will address the matter as part of their corrective action plan. The District will purchase needed equipment and supplies to reduce the net cash.

FINDING # 2022-002No finding in prior yearThe Department of Agriculture, Division of Food and Nutrition (DOA) was delinquent in submitting required reporting in the FFFATA Subaward Reporting System (FSRS) due to the inability to make system updates for the UEI change during the pandemic. This prevented the DOA from pulling data to submit the reports to the FSRS. The DOA has two technical staff members assigned to query the data fields required to upload the report. Once the query is complete the data is converted to a CSV file and uploaded to FSRS. As of December 2022, monthly reporting has resumed. Successful monthly upload documentation will now be provided and monitored by the Assistant Division Director and Fiscal Coordinator.COMPLETION DATE/CONTACT PERSON December 2022Melissa Pajak(609) 690-8880Melissa.Pajak@ag.nj.gov

FINDING 2022-006Contact Person Responsible for Corrective Action: Kristin CharlesContact Phone Number: 765-866-0203Views of the Responsible Official: The School Corporation is in agreement with the Finding.Description of Corrective Action Plan: This was the best process at the time. We are now doing negative expenditures to move the funds. The CAP is to contact another Komputrol school and see how they are processing the movement of funds from 8400 which is where the prepaid lunch money is supposed to go and how it is being moved into fund 800. The board has in essence through the superintendent for me to make posting corrections to get the amount into the proper funds. As the CFO/HR as well as the named treasurer, since this is not enough then we will work together to make sure it is clearly stated in resolution that the CFO/HR or named treasurer has the authority to make these moves in the funds.Anticipated Completion Date: ASAP

FINDING 2022-001Contact Person Responsible for Corrective Action: Matt TomrellContact Phone Number: (812) 349-4762 ext 51598Views of Responsible Official: We concur with this finding. This finding has been remediated as of the completion dateshown below.Description of Corrective Action Plan:MCCSC hired a new Food Services Director in July of 2021 who was unaware of the existing internal control. The importanceof the internal control has been communicated to the Food Service Director who now prints and signs the state claimreimbursement requests and files with the rest of the monthly paperwork.Completion Date: March 8, 2023

FINDING 2022-004Subject: Child Nutrition Cluster - ReportingFederal Agency: Department of AgricultureFederal Programs: School Breakfast Program, COVID-19 School Breakfast Program, National School LunchProgram, COVID-19 National School Lunch Program, Summer Food Service Program for Children, COVID-19Summer Food Service Program for ChildrenAssistance Listings Numbers: 10.553, 10.555, 10.559Federal Award Numbers and Years (or Other Identifying Numbers): FY21, FY22Pass-Through Entity: Indiana Department of EducationCompliance Requirement: ReportingAudit Findings: Material WeaknessContact Person Responsible for Corrective Action: Shelley Kemp, Food Service DirectorContact Phone Number: 765-348-7564Views of Responsible Official: We agree with this audit findingDescription of Corrective Action Plan:BCS had moved away from a daily point of sale system after qualifying for the Community EligibilityProvision Free meal program, and had utilized clickers to record the number of students eating daily. Wealso utilized meals claiming number sheets daily.BCS will revert to the point of sale system for the beginning of the 2023-2024 school year to better verifythe student count and to provide more detailed records. We will revise procedures for this process when point ofsale reports are reinstituted.Procedures:1. Daily, Cafeteria Managers at each BCS location will complete an Edit Check report to certify thenumber of meals served at that school for that day.2. Monthly, Cafeteria Managers compile the Edit Checks to determine monthly total meals served.This monthly report will be sent to the Food Service Director for review.3. The Food Service Director will verify the reports from each cafeteria manager, and then compile theinformation for the CNP website that lists the district totals for reimbursement.4. The BJSHS Cafeteria Manager will review and verify the totals compiled by the Food ServiceDirector prior to submission to the IDOE. The BJSHS will sign off prior to submission, verifying thetotals.Anticipated Completion Date: September 2023

FINDING 2022-003Contact Person Responsible for Corrective Action: Allison Pund and Ora Lee CottonContact Phone Number: 812-683-3971Views of Responsible Official: We concur to the finding.Description of Corrective Action Plan: Southwest Dubois will develop a system of internal controls that will ensurereporting compliance requirements are met. The corporation will assure one individual is completing the claims/reportsand another is verify the reports.Anticipated Completion Date: March 2023

Finding Number: 2022-004Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: COVID-19 - Elementary and Secondary Schools EmergencyRelief Fund (ESSER)Assistance Listing: 84.425C, D, U, WPass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:201787-01 (3/13/20 ? 9/30/22)Compliance Requirement: Allowable Costs/Cost PrinciplesType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersRecommendation:We recommend that the Board review its policies and procedures to verify that controls are inplace to ensure expenditures are not reimbursed under more than one Federal Program.Explanation of disagreement with audit finding: There is no disagreement with the auditfinding.Action taken in response to finding: ESSER funds will no longer be used for Food and NutritionServices.Name(s) of the contact person(s) responsible for corrective action: BCPS grant managers,and Fiscal Services staff.Planned completion date for corrective action plan: For immediate implementation andongoing

FINDING 2022-004Contact Person Responsible for Corrective Action: Robin PopejoyContact Phone Number: 317.758.4172Views of Responsible Official: We concur with the finding.Description of Corrective Action Plan: Those procedures and errors were discussed and adjustments have beenmade. To cover oversight of the School Food Service Accounts, at the close of the month the Director of Business willsend Director of Food Service reports to approve all activity of School Food Service Accounts.Anticipated Completion Date: February 2023

FINDING 2022-003Contact Person Responsible for Corrective Action: Kim DeVaney/Robin PopejoyContact Phone Number: 317.758.4172Views of Responsible Official: We concur with the finding.Description of Corrective Action Plan: Those procedures and errors were discussed and adjustments have beenmade. To prevent errors the Payroll Specialist will make sure the employee timesheets that was signed off by the Directormatches with the hours they were approved to work when hired.Anticipated Completion Date: February 2023

2022-005 Accounts payable testing and internal controlsA. Name of contact person responsible for corrective action:Name: Kenyatta McClainTitle: Business ManagerB. Corrective action planned:The District will implement policies and procedures to establish an internalcontrol system that will require accountability with regard to accountspayable and purchasing. That will also ensure proper safeguarding ofassets and accurate accounting records. C. Anticipated completion date:June 30, 2023

Lawton Community Schools respectfully submits the following corrective action plan for the year ended June 30, 2022.Auditor: Seber Tans, PLC555 W. Crosstown Pkwy, STE 304Kalamazoo, MI 49008Audit Period: Year ended June 30, 2022District Contact Person: Dianne Webster, Business Office ManagerThe findings from the June 30, 2022 schedule of findings and responses are discussed below. The findings are numbered consistently with the number assigned in the schedule.Finding ? Federal Award Findings and Questioned CostsFinding 2022-01 ? Significant DeficiencyRecommendation: The District should implement a budget, as well as the required corrective action plan for the 2022-2023 school year that will adequately reduce the food service fund balance.Action to be Taken: Management concurs with the facts of this finding and we are in the process of developing and implementing a plan to spend down the food service fund balance.

Name of Contact Person: Sue Nickerson, Town Accountant

Corrective Action Plan: The District has had turnover of personnel in the Business Office this past fiscal year. As the new Director of Business and Finance there will be procedures implemented to ensure that sufficient documentation for transactions for costs charged to federal programs is supported by documentation as required by the Uniform Guidance regulations. Additionally, there will be a review of current purchasing policies, to add or amend, which will further help support meeting the federal guidelines. Lastly, it should be noted that the Town/School financial system will be converting/upgrading to MUNIS ERP Solution for the Public Sector. This upgrade will be very instrumental in maintaining the necessary information to meet audit requirements.

Proposed Completion Date: Immediately

The California Department of Public Health (Public Health) Women, Infants, and Children (WIC) Division had agreed that the WIC Web Information System Exchange (WISE) system does not currently store eligibility history that should be included in the “Cert History Report,” and the initial eligibility data is overwritten when subsequent eligibility information is keyed into WIC WISE. However, WIC WISE does include preventative internal stops or checkpoints that do not allow ineligible individuals to be certified and issued benefits (e.g., over income, not a California resident, no nutrition risk factor, etc.). User acceptance testing vetted these items prior to system implementation in 2019/20. The certification history condition discussed was remediated via a system Defect Correction to WIC WISE that was in user acceptance testing for implementation in Fall 2023. Public Health/WIC has entered Defect Correction #6972 in TFS (Team Foundation Services), the tracking system previously used to capture system changes and defects. The defect correction supports a system change to ensure initial eligibility information is retained when subsequent eligibility information is entered into WIC WISE. Estimated Implementation Date: August 2023 Contact: William Welch, Assistant Division Chief, Operations Women, Infants, and Children Division California Department of Public Health

Audit Finding Reference: 2022-12 Management’s View and Planned Corrective Action A procedure is currently in place and being followed. In 2021-2022 there were new forms sent from the State to do our meal counts, this was the second COVID year and free lunch for all students. In our one room plus a modular school housethat receives vended meals from Lisbon, Landaff, they used both the State form and MealTimes and then sometimes called and made changes at the last minute to the number of servable meals. We believe the glitch was at Landaff in terms of procedure so part of our plan will be to review with the Landaff staff how to correctly enter the information into MealTimes. I spot checked 22-23 and found that our claims are accurate to Meal Times. Name of Contact Person and Completion Date: Name 1 Toni Butterfield Name 2 Anticipated Completion Date – 6/30/2025

Audit Finding Reference: 2022-011 Management’s View and Planned Corrective Action: Management learned about 7 CFR, 210.14(b) when asked to create an Excess Food Service Fund Spend Down Plan this school year. We are now monitoring this and will make sure to spend down funds appropriately each year when operating the food service program. In addition, management is taking on a bigger role in overseeing the entire Food Service operation in regards to the Federal Regulations associated with the National School Lunch Program. Name of Contact Person and Completion Date: Name 1 Toni Butterfield Name 2 Anticipated Completion Date – 6/30/25

Audit Finding Reference: 2021-006 Cross Training of Staff and Review of Responsibilities Management’s View and Planned Corrective Action: Management does not agree with this deficiency. We do agree that Management is actively working on some changes as improvements are made each year to improve efficiency. Each position in the Business Office other than HR has been crossed trained with one-to-two other team members. Cross training throughout the business office was implemented in 2016 and has continued to exist. Each position has the ability to have someone step in case of emergency, elongated vacations and when/if someone resigns or is terminated. The positions are not covered in entirety, but the important items that must be dealt with can be and are accomplished. Examples are as such: Accounts Payable is covered by our Special Ed Bookkeeper, and other staff have the ability to review manifest once generated. Payroll has been covered by the Assistant Business Administrator when vacations or vacancies have existed, Grants can be covered by the Business Administrator when vacations or vacancies have existed. The Assistant Business Administrator is covered by the Business Administrator during vacations and vacancies. Each position continues to do their own assigned job duties and takes on the other tasks as necessary. The work may not get completed in the same timely fashion as if the actual staff member holding the position was there because they are also completing their own tasks, but the work does get accomplished. When there are multiple turnovers and/illness occurring at the sometime it makes it challenging even when cross training exists. Every year the Business Administrator reviews workloads and reassesses if changes should occur to help create efficiencies and create equivalent workload between all staff members. While some positions have more deadlines than others it can appear that their plates are larger than others, but frequently tasks are divided out throughout the team to help alleviate this. These discussions are brought forth to COLT, the Senior Leadership team at the SAU, and restructuring is finalized at that time. Name of Contact Person and Completion Date: Name 1 Amber Wheeler Name 2 Danielle Rossetti Anticipated Completion Date – Already occurs

Corrective Action: Coastal Harvest will begin tracking all inventory on hand by source, including receipts, distributions, waste/loss, and any other adjustments, and will perform periodic reconciliations of amounts recorded in the inventory system and amounts recognized in the general ledger to ensure accurate USDA food commodities inventory recordkeeping compliance. Further, Coastal Harvest will include specific inventory policies and procedure in the manual discussed in the corrective action for finding 2022-001. Anticipated Completion Date: June 30, 2024

2022-002 Reporting to the Federal Audit Clearinghouse (Material Weakness) Federal Agency: U.S. Department of Education Program Names: Child Nutrition Cluster Assistance Listing Numbers: 10.553, 10.555 and 10.559 Award Period: June 30, 2022 Recommendation: The Board of Education and management should implement internal control procedures that will ensure timely submission of the audit package and data collection form to the Federal Audit Clearinghouse within the required timeline. Action Taken (Unaudited): Management plans to develop proper written policies and procedures that will ensure timely submission of the audit package and data collections form to the Federal Audit Clearinghouse within the required timeline during years in which the District incurs federal expenditures above the threshold required by Uniform Guidance. Contact Name – Tim Beying Expected Completion Date - 06/30/2024