Corrective Action Plans

FINDING 2023-001 Information on the federal program: Subject: Child Nutrition Cluster Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program, and 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: 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 IDOE review, a total of $1,299,365 was disallowed from the Summer Food Service Program. The School Corporation and IDOE agreed to a repayment plan to repay the disallowed costs identified. The School Corporation completed the repayment to IDOE 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.

This error was due to clerical oversight. The program has reviewed the processes in place with the appropriate staff and has implemented additional layers of review to ensure compliance.

Finding Number: 2023-001 Planned Corrective Action: In 2022- 2023, Aramark hired a new Food Service Supervisor. The Supervisor failed to report the numbers correctly. She was told to pull the POS report and use the Aramark calendar, which differs from a monthly calendar. Once she had the numbers, they would be manually input into the Aramark program. She was using these numbers to report to the ODE. When doing this, she made several errors, which resulted in us reporting more meals than we actually served. Correction : 1) Report numbers to the ODE using the CN6 and CN7 reports. 2) Correct our reported number to ODE using the CN6 and CN7 reports for August - November 2023. Anticipated Completion Date: 1) We started in December 2023 using the correct report s, the CN6 and CN 7, to report our numbers to the ODE for reimbursement. 2) In February, we put in the correct numbers for August- November 2023 with the ODE, so our numbers will balance for the 2023-2024 school year. Responsible Contact Person : Michael Pissini, Treasurer Leslie McKimmie, Food Service Director

Department: Education Title: Internal control over CNC subrecipient monitoring procedures needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Child Nutrition supervisor will review details of the findings from the state auditors to assess where errors occurred in both administrative review completion and tracking. Clear separation of duties will be created between administrative staff responsibilities for review tracking and reviewer staff responsibilities. Staff will be trained on review tracking spreadsheet responsibilities. Staff will be trained on administrative review tool completion. Training will highlight areas where data was missing, more information was needed or errors were made. This will occur at monthly staff meetings. Special Provision 2 base year review staff will be trained on the need to ensure SFAs revise claims as required due to base year review findings. It will be recommended that a tracking document be created to validate that claim adjustments have been made. If the adjustment is over the 60 day late claim window, the financial specialist will track the reason for the claim exception. Completion Date: March 15, 2024 (first, second and third items), June 10, 2024 (fourth item) and March 14, 2024 (sixth item) Agency Contact: Adriane Ackroyd, Assistant Director Child Nutrition, DOE, 207-592-1722

Department: Education Title: Internal control over CNC donated food inventory needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Department found a ticketing issue in CNPWeb, and a ticket was issued to remediate the problem. The Department staff will continue to provide paper back up until the computer system is found to be reliable. Completion Date: December 31, 2024 and March 18, 2024 respectively Agency Contact: Jane McLucas, Director of Child Nutrition, DOE, 207-624-6880

Department: Education Title: Internal control over the submission of CNC Schedule of Expenditures of Federal Awards information needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Department will work with auditors to find the SEFA numbers. The Department director will create a procedure to report the SEFA numbers to DOE Finance. The Department will review with DOE Finance for approval of the procedure. Completion Date: March 1, 2024, May 1, 2024 and June 1, 2024 respectively Agency Contact: Jane McLucas, Director of Child Nutrition, DOE, 207-624-6880

Department: Education Title: Internal control over CNC claim reimbursements needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Department will adjust the one-time exception procedure to include the procedure for downward adjustments and tracking of sponsor requested downward adjustments. The Department will adjust the SFSP application/site information sheet approval and update procedures to include instructions on documentation needs. Requests for site information sheet changes will be documented and maintained in CNPweb. CNPweb ticket requests have been submitted to ensure downward adjustments are tracked in CNPweb. CNPweb ticket requests have been submitted to ensure site information sheet changes are date stamped. Completion Date: March 12, 2024 (first and second items), March 1, 2025 (third item) and June 9, 2022 (fourth item) Agency Contact: Adriane Ackroyd, Assistant Director Child Nutrition, DOE, 207-592-1722

Department: Health and Human Services Title: Internal control over P-EBT Food Benefits needs improvement Questioned Costs: Known: $4,271 Likely: $4,862,998 Status: Management’s opinion is that corrective action is not required Corrective Action: The Department disagrees with the following Conditions: For 22 students, MDOE was not able to identify the specific student whose continuous absence established those students’ schools’ eligibility date. The P-EBT state plan required at least one student to be absent or remote for at least five consecutive days to establish a school eligibility date and MDOE in fact applied this test and established a school eligibility start date at the time the eligibility files were generated. While the school eligibility start date was captured and preserved in the original files provided to OSA, no student was named. The name of the student was not relevant to other students’ eligibility, and creating or preserving a record of the particular student whose absence conferred eligibility was not a requirement of Maine’s P-EBT plan with FNS, the Department’s MOU with MDOE, or federal P-EBT policy. Further attaching that kind of Personal Identifying Information (PII) to other students’ records would not be appropriate. Additionally, since local educational agencies (LEAs) update the core database throughout the school year and beyond, the results could not be replicated in the course of this audit to retrospectively identify the particular students whose absences conferred eligibility. Neither the omission of the students’ names in the original file nor DOE’s inability to identify such students during the audit establishes that it was improper to issue P-EBT benefits in connection with those students. These students were found eligible based on the best data available to MDOE at the time. Likewise, the Department acknowledges that for four students, MDOE was unable – when requested to do so by the OSA – to locate their economically disadvantaged status in the database updated by LEAs throughout the school year. That does not mean, however, that it was improper to issue P-EBT benefits in connection with those students. These students’ economically disadvantaged status was verified by MDOE and captured in the files at the time of issuance. The Department disagrees that tracking benefit issuance by child identification number is inadequate to monitor benefit issuances and ensure benefits are not duplicated. Child identification numbers are the most reliable way to track and deduplicate issuance. As pointed out in this finding, many households had more than one child. Additionally, some children may have moved from one household to another during the period in question. The Department disagrees with the Context and Likely Questioned Costs: For the reasons detailed above, only three – not 29 – of the students sampled were established to have been issued benefits in error. OSA’s calculations should be adjusted accordingly. The Department disagrees with the Causes: OSA is incorrect to conclude that OFI should have reviewed, reconciled, and verified data provided by MDOE prior to issuance for at least two reasons. First, contrary to OSA’s characterization of the partnership, the Department and MDOE were jointly responsible for administering the P-EBT program, with delegated duties defined in the state plan. That federally approved plan considered MDOE data to be accurate and actionable, and it did not contemplate OFI independently validating such data. Second, the Department is not permitted access to the local educational agency data that would have been necessary for the type of review and reconciliation proposed. The Department disagrees with the Recommendations: The three bulleted recommendations cannot be implemented. The P-EBT program ended December 31, 2023. It will not be possible to take corrective action in the implementation of a program that no longer exists. The State is confident that all issuances in the audit period, including those raised by OSA, were issued correctly based on the best information available at the time by the Departments responsible for implementing the P-EBT program. As such and following FNS guidance that no benefits are to be recouped unless the household applied for them directly, OFI will not revisit prior P-EBT decisions as suggested in OSA’s additional recommendation. Completion Date: N/A Agency Contact: Ian Yaffe, Director, Office for Family Independence, DHHS, 207- 592-1481

FINDING 2023-001 Finding Subject: Child Nutrition Cluster – Eligibility, Procurement and Suspension and Debarment , Special Tests and Provisions – Verification of Free and Reduced Price Applications (NSLP) Summary of Finding: Material Weakness Contact Person Responsible for Corrective Action: Steve Nauman, Treasurer Contact Phone Number and Email Address: Phone: 812-522-3340 Email: naumans@scsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The SCSC management team will design and implement a proper system of internal control, including policies and procedures that would provide segregation of duties to ensure appropriate reviews, approvals and oversight are taking place concerning the Eligibility, Procurement and Suspension and Debarment, and Special Tests and Provisions - Verification of Free and Reduced Price Applications (NSLP) compliance requirements. Anticipated Completion Date: The projected date of completion is March 31, 2024.

District will work with legal counsel to establish parameters to execute verification for cause as outlined in USDA Food and Nutrition Services, Child Nutrition Programs Eligibility Manual for School Meals - Determining and Verifying Eligibility, Section 6 - Verification. District will work within established parameters to verify district employee salaries of approved applications submitted by district employees

FINDING 2023‐004 Finding Subject: Child Nutrition Cluster ‐ Procurement and Suspension and Debarment Summary of Finding: The School Corporation designed and implemented a process to ensure that costs charged for the procurement of goods and services to the food service program were properly procured. The process was for vendor claims to be reviewed and approved by the department head or Food Service Director and the Treasurer. Prior to entering subawards and covered transactions with federal award funds, recipients are required to verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded. “Covered transactions” include but are not limited to contracts for goods and services awarded under a non‐procurement transaction (i.e. grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the SAMs exclusions, collecting a certification from that vendor, or adding a clause or condition to the covered transaction with that vendor. Recommendation: We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure that contractors are not suspended, debarred or otherwise excluded prior to entering into any contracts or subawards. Contact Person Responsible for Corrective Action: Tim Garland, Superintendent Contact Phone Number: 574‐626‐2525 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: During the audit period, sufficient internal controls were deficient in specific areas which prevented comprehensive program compliance. To address and rectify the issues as presented, vendor verification will be completed on an annual basis. The Food Service Director and Treasurer will confirm through documentation that vendors are not suspended or debarred using resources available. Documentation representing oversight and compliance will be retained and referenced as needed for verification. Anticipated Completion Date: Q2 2024 (6/30/2024)

FINDING 2023‐003 Finding Subject: Child Nutrition Cluster ‐ Internal Controls Summary of Finding: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Allowable Costs/Cost Principles, Activities Allowed and Unallowed. Recommendation: We recommended that management of the School Corporation design and implement a proper system of internal control, including policies and procedures that would provide segregation of duties to ensure appropriate reviews, approvals and oversight are taking place regarding vendor claims. Contact Person Responsible for Corrective Action: Tim Garland, Superintendent Contact Phone Number: 574‐626‐2525 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Lewis Cass Schools makes every effort to ensure proper documentation is obtained before processing vendor claims. To prevent oversight and strengthen internal controls, each level of management oversight has implemented stringent safeguards. All food service vendor claims will not be processed for payment without the authorization of the Food Service Director. Upon confirmation of the Food Service Director’s documented authorization, the Deputy Treasurer will document the authorization, and prepare the claim for the Treasurer. The Treasurer will ensure documented authorization of the Food Service Director and the Deputy Treasurer, along with the proper budget account code applied before releasing authorization for payment. The application of the procedures above will apply to all vendor claims for payment. Therefore, vendors meeting the thresholds for suspension and debarment will also be included. Anticipated Completion Date: Q2 2024 (6/30/2024)

Finding # 2023-021 Title of Finding Special Tests and Provisions Contact Person Anthony McDaniels Anticipated Completion Date FY 2024 Corrective Action planned to be taken: The Board will develop a Food Service Collection Policy and attempt to collect the outstanding balances on the receivables related to the National School Lunch Program.

The Director of Food Service will continue to review monthly expenditures and plan accordingly.

CContact Person – Thomas A. Jerome, Superintendent Corrective Action Plan – The District will implement policies and procedures to ensure all students who receive a free or reduced meal have a current and accurate application on file. Completion Date – December 29, 2023

Contact Person – Thomas A. Jerome, Superintendent Corrective Action Plan – The District will implement policies and procedures for verifying free and reduced applications. Completion Date – December 29, 2023

Contact Person – Thomas A. Jerome, Superintendent Corrective Action Plan – The District has implemented new meal count procedures effective May 2023. Completion Date – May 1, 2023

FINDING 2023-001 Finding Subject: Child Nutrition Cluster – Procurement and Suspension and Debarment Summary of Finding: During the SBOA audit, our School Corporation did not have a policy nor the internal controls to review vendors to ensure they were not suspended or debarred. Our School Corporation was unable to provide evidence or support to show that one contracted vendor tested was reviewed before we entered a covered transaction with the vendor. Contact Person Responsible for Corrective Action: Cynthia Alward, Treasurer Contact Phone Number and Email Address: (765)294-2254 alwardc@sefschools.org Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Our School Corporation intends to verify the eligibility of vendors that will be paid more than $25,000.00 in federal funds with SAMS.gov. We will check that the vendor has not been debarred or suspended from participating in federal programs. Anticipated Completion Date: Immediately

FINDING 2023-004 Finding Subject: Child Nutrition Cluster - Eligibility Summary of Finding: Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children Assistance Listings Numbers: 10.553, 10.555, 10.559 Federal Award Number and Year (or Other Identifying Numbers): FY2021-2022, FY2022-2023 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Finding: Material Weakness Contact Person Responsible for Corrective Action: Tiffiny Ulman Contact Phone Number and Email Address: 219-924-4250 tulman@griffith.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: Establish post award internal controls surrounding grant management including, but not limited to, Eligibility. Anticipated Completion Date: 3/5/2024

FINDING 2023-003 Subject: Child Nutrition Cluster - Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Special Tests and Provisions - Non-Profit School Food Service Accounts Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, COVID-19 National School Lunch Program; Summer Food Service Program for Children Assistance Listings Numbers: 10.553, 10.555, 10.559 Federal Award Number and Year (or Other Identifying Numbers): FY2021-2022, FY2022-2023 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Special Tests and Provisions - Non-Profit School Food Service Accounts Audit Finding: Material Weakness, Modified Opinion Summary of Finding: Material Weakness, Modified Opinion Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2021- 003. Contact Person Responsible for Corrective Action: Terri Chance Contact Phone Number and Email Address: 219-924-4250 tchance@griffith.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Griffith Public Schools will be developing, implementing, and documenting, a system of internal controls, including policies and procedures that provide segregation of duties to ensure appropriate reviews, approvals and oversight are taking place to ensure compliance. Anticipated Completion Date: June 30, 2025

Management Response/Corrective Action Plan: Before the Nutrition Director submits the claim, the Business Manager will review the claim with the Nutrition Director.

Management Response/Corrective Action Plan: Management should ensure all documentation is filed and maintained after it is received.

Finding 2023-003 – Child Nutrition Cluster – Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Matthew Parkinson, CFO Contact Phone Number: 317-869-4364 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The CFO will send a memo to all administrators identifying quote and bid thresholds. The school district will obtain at least 3 quotes or use an alternative acceptable procurement method for large purchases. Anticipated Completion Date: 6/30/24

Finding 2023-002 – Child Nutrition Cluster – Activities Allowed or Unallowed, Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Matthew Parkinson, CFO Contact Phone Number: 317-869-4364 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Business Office and Payroll staff will review a Labor Distribution Report to verify that the staff is only paying appropriate personnel from the Food Service Fund. Anticipated Completion Date: 6/30/24

FINDING 2023-002 Finding Subject: Child Nutrition Cluster – Internal Controls Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program Assistance Listing Numbers: 10.553, 10.555 Federal Award Number: 7350 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Activities Allowed and Unallowed, Allowable Costs/Costs Principles, Special Tests and Provisions-Verification of Free and Reduced Price Applications Summary of Finding: Material Weakness Internal Controls were not implemented to prevent noncompliance related to the verification of free and reduced applications and hours and wages. A new internal control procedure will be implemented for the second review of the free and reduced applications and for the hours and wages. Repeat Finding: Prior audit finding number was 2021-002. Contact Person Responsible for Corrective Action: Tammy Achenbach Contact Information: Phone: 317-835-7461 Email: tachenbach@nwshelbyschools.org Views of Responsible Officials: Management agrees with the finding. Management will ensure proper documented review of amounts billed for personnel and for the free and reduce verification 􀀃 INDIANA STATE BOARD OF ACCOUNTS 23 First ~ Best ~ Different! 􀀃 Northwestern􀀃 Consolidated􀀃School􀀃 District􀀃of􀀃Shelby􀀃County􀀃 􀀃 4920􀀃W.􀀃600􀀃N􀀃 Fairland,􀀃IN􀀃46126􀀃 􀀃 Phone:􀀃317􀍲835􀍲7461􀀃 Fax:􀀃317􀍲835􀍲4441􀀃 􀀃 www.nwshelbyschools.org􀀃 Superintendent􀀃 Mr.􀀃Chris􀀃Hoke􀀃 􀀃 Business􀀃Manager􀀃 Mrs.􀀃Tammy􀀃Achenbach􀀃 􀀃 Technology􀀃Director􀀃 Mr.􀀃Josh􀀃Landis􀀃 􀀃 Maintenance􀀃Director􀀃 Mr.􀀃Terry􀀃Coons􀀃 􀀃 Transportation􀀃Director􀀃 Mrs.􀀃Susie􀀃Childress􀀃 􀀃 Special􀀃Education􀀃Director􀀃 Mrs.􀀃Terri􀀃Branson􀀃 􀀃􀀃 School􀀃Board􀀃 Mr.􀀃David􀀃Ploog􀀃 Mrs.􀀃Brooke􀀃Lockett􀀃 Mrs.􀀃Cressa􀀃Rund􀀃 Mr.􀀃Ken􀀃Polston􀀃 Mr.􀀃Terry􀀃Morgan􀀃 Mr.􀀃Travis􀀃Hensler􀀃 Mrs.􀀃Karen􀀃Humphreys􀀃 Cont. page 2 Description of Corrective Action Plan: Review for personnel charges: During the monthly meeting to review the FSMC invoice, along with Operations Ledger, Client P&L, Monthly Reimbursements, Invoices, USDA Reconciliation, Direct Certification, The Hours and Wages will be reviewed and approved. Free and Reduced Verification: Internal Controls for the first round of Free and Reduce Applications will be verified by the Data Controller or the Business Manager and the verification of the random testing of the verifications will be done by the Business Manager or the Deputy Treasurer. Anticipated Completion Date: The district will start the new internal control procedure March 2024 to correct for the 23-24 school year.