Corrective Action Plans

The District has implemented a procedure to validate the calculation of sample applications, including coordinating with the Riverside County Office of Education.

FINDING 2023-003 Finding Subject: Child Nutrition Cluster-Reporting Summary of Finding: The School Corporation did not have effective internal controls over the Child Nutrition Cluster (CNC) reporting. The Claims for Reimbursement were prepared by one employee and not reviewed by a second employee to ensure compliance. Contact Person Responsible for Corrective Action: Jamesi Lemon Contact Phone Number and Email Address: (260) 499-2400; jlemon@lakelandlakers.net Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Claims for Reimbursement will be prepared by the Food Service Director and the Director of Business Operations will review the claims for compliance. The claims will then be initialed signaling they have been reviewed. Anticipated Completion Date: Immediately

FINDING 2023-001 Finding Subject: Child Nutrition Cluster – Eligibility Summary of Finding: The Food Service Director was responsible for running the direct certification match report monthly from the Indiana Department of Education and uploading it to the school lunch point-of-sale system. The School Corporation did not have a proper system of oversight or review to ensure that all students on the direct certification match report were entered accurately into the point-of-sale system. We recommended that the School Corporation's management establish a system of internal control to ensure compliance and comply with the Eligibility compliance requirement Contact Person Responsible for Corrective Action: Nick Alessandri Contact Phone Number and Email Address: 219-962-7551 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: River Forest Community School Corporation is now part of the Community Eligibility Provision (CEP) and therefore the direct certification process will no longer take place. In the event that we are no longer CEP and begin the direct certification process, we will implement a process of internal controls that ensure proper oversight and review to ensure all students are entered accurately into our point-of-sale system. Anticipated Completion Date: July 1, 2023

Hall agrees with the Cause and Recommendation identified above. We immediately contacted the CSDE-Bureau of Child Nutrition Programs and have initiated the CACFP Invitation for Bid (IFB) process for the 2023-2024 year. We will ensure that formal IFB requirements are utilized if future contracts will or may exceed the $250,000 threshold.

PDA strives to maintain accurate and complete records with respect to the receipt, distribution, and inventory of USDA donated foods, including end products processed from donated food. To that end, PDA has already or will put the following steps in place to strengthen procedures for future periods to ensure any errors are identified and corrected when reconciling the Bureau of Food Assistance’s (BFA’s) Commodity Inventory Report: 1. The finding noted in the audit with regards to the Commodity Inventory Report has been corrected and no known issues remain. 2. BFA will cross-train an additional staff member (the NSLP Specialist) on the process of completing the monthly Commodity Inventory Report. This staff member will then serve as a back-up to the Processing Specialist and will be able to complete a monthly review of the completed Commodity Inventory Report to ensure accuracy. 3. In the event that the numbers in BFA’s Monthly Commodity Inventory Report don’t balance, the Processing Specialist will consult with the Technical Specialist managing PA Meals, who can assist with a technical review of the raw numbers. 4. Sent an email communication to select commodity processors and brokers reiterating the process for submitting Monthly Processing Reports (MPRs) to BFA and reminding them of their responsibility to provide prompt responses should questions arise. Anticipated Completion Dates: 1, 3, 4 - Completed; 2 - 06/30/2024 Contact Name: Caryn Long Earl, Director, Bureau of Food Assistance

Auditee Contact Person: Paula Powers Title of Contact Person: Food Service Coordinator Phone Number: 812 347-3905 Findings 2023-002-Child Nutrition Cluster-Eligibility Views or Responsible Official: We concur with the findings. Description of Corrective Action Plan: With future processing of free and reduced applications, the Food Authority will process the application. A second person will review and sign the application in order to maintain proper checks and balances. Anticipated Completion Date: March 2024

Program: AL 10.555 – National School Lunch Program – Allowability Corrective Action Plan: In the future, the FNS640 report will be checked monthly by two team members: Director of Child Nutrition Programs and the Program Specialist who is responsible for Administrative Review quality control effort. The FNS640 report identifies if an AR did not have the claim validation completed; if this is discovered, the Program Specialist will be notified and required to complete the claim validation and accompanying information within 10 working days. Contact: Kayte Partch, Assistant Administrator, Office of Coordinated Student Support Anticipated Completion Date: Immediately

Program: AL 10.553 – School Breakfast Program; AL 10.555 – National School Lunch Program; AL 10.556 – Special Milk Program for Children; AL 10.559 – Summer Food Service Program for Children; and AL 10.582 – Fresh Fruit and Vegetable Program – Reporting Corrective Action Plan: The NDE will continue checking the status of the help desk ticket at FSRS once-weekly until reporting on the CNP block grant funds can be successfully completed. At that time, confirmation of successfully reporting on the CNP block grants will be provided to the state auditor. Contact: Kayte Partch, Assistant Administrator, Office of Coordinated Student Support Anticipated Completion Date: Pending federal response

FINDING 2023-004 Information on the federal program: Subject: Child Nutrition Cluster - Reporting Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children, Fresh Fruit and Vegetable Program Assistance Listings Numbers: 10.553, 10.555, 10.559, 10.582 Federal Award Number and Year (or Other Identifying Numbers): FY2021-2022, FY2022-2023 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Contact Person Responsible for Corrective Action: Chris Akers, Treasurer Contact Phone Number and Email Address: (219) 838-1819 cakers@lakeridgeschools.net Condition: 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 the monthly sponsor claim for reimbursement. Context: School Food Authority’s (SFA) and sponsors must submit monthly claims for reimbursement for meals and snacks served to eligible students within 60 days following the last day of the month covered by the claim. The Food Service Management Company employed Food Service Director prepared the monthly claim for reimbursement on the Indiana Department of Education Child Nutrition Program website based on meal count reports from the point-of-sale system. The School Corporation did not implement a system of internal control to ensure what was claimed for reimbursement agreed to the point-of-sale system meal count reports. Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Before the monthly claim for reimbursement is submitted by the FSMC, the Treasurer will reconcile the claim with the meal count report generated by the point-of-sale system. Anticipated Completion Date: Immediate

FINDING 2023-003 Information on the federal program: Subject: Child Nutrition Cluster - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children, Fresh Fruit and Vegetable Program Assistance Listings Numbers: 10.553, 10.555, 10.559, 10.582 Federal Award Number and Year (or Other Identifying Numbers): FY2021-2022, FY2022-2023 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Adrian Wilkerson, Chief Financial Officer Contact Phone Number and Email Address: (219) 838-1819 awilkerson@lakeridgeschools.net Condition: 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 Activities Allowed or Unallowed and the Allowable Costs/Cost Principles. Context: The School Corporation had not designed or implemented a system of internal control to ensure that program costs incurred by the Food Service Management Company were supported by proper documentation and were allowable. The School Corporation entered into a cost reimbursement contract with a food service management company (FSMC). The FSMC incurred costs and invoiced the School Corporation for reimbursement of the costs. Due to the lack of effective internal controls, the following errors were noted: In a test of 44 items, 22 items (50%) totaling $6,641 did not have proper documentation to support that the expenses were allowable and for the benefit of food service. Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: In addition to the monthly review of the FSMC invoice and budget, the Chief Financial Officer will review and approve the supporting documentation (invoices, payroll records) provided by the FSMC to ensure that expenses are allowable and for the benefit of food service. Anticipated Completion Date: Immediate

FINDING 2023 - 003 Finding Subject: Child Nutrition Cluster – Internal Controls Summary of Finding: The School Corporation had not properly designed or implemented an effective system of internal controls, which would include segregation of duties, that would likely be effective in preventing, or detecting and correcting, material noncompliance over eligibility and suspension and debarment. 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. Contact Person Responsible for Corrective Action: Steven Boyer Contact Phone Number and Email Address: 574-936-3115 sboyer@plymouth.k12.in.us Views of Responsible Officials: The Corporation concurs with the finding. Description of Corrective Action Plan: As part of month-end procedures and the documents sent to the Business Manager, the Food Services Director will include the list of students newly certified for free or reduced meals from CNPweb, Indiana’s portal for the Child Nutrition Program. The Food Services Director will also include the list of students newly certified for free or reduced meals from NutriKids. The Business Manager will review and verify the list when balancing the food program’s monthly receipts, expenditures, and reimbursements. Before contracts are awarded to vendors, the Food Services Director shall use SAM.gov to verify that vendors have not been suspended or disbarred from contracting with Indiana public schools. The Business Manager shall review and verify that the vendors have not been suspended or disbarred, and once verified, contracts will be awarded. Anticipated Completion Date: The Food Services Director and Business Manager have collaboratively reviewed and modified the month-end procedures to ensure that they prevent, detect, and correct eligibility errors, and the new procedures were implemented for February 2024 and will be used for subsequent months.

FINDING 2023-003 Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program COVID-19 - National School Lunch Program Assistance Listings Numbers: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): SY22, SY23 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Eligibility, Special Tests and Provisions - Verification of Free and Reduced Price Applications (NSLP), Special Tests and Provisions - Non-Profit School Food Service Accounts Audit Finding: Material Weakness Condition and Context The School Corporation had not established effective internal controls that would likely be effective in preventing, or detecting and correcting, noncompliance. Eligibility The School Corporation's policy is to have the Treasurer review and initial paper applications processed by the individual school treasurers to ensure that the eligibility determination was correct. However, six of the ten applications tested lacked documentation of this review. In addition, there was no internal control in place over applications submitted online. INDIANA STATE BOARD OF ACCOUNTS 18 BORDEN-HENRYVILLE SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Special Tests and Provisions - Verification of Free and Reduced Price Applications (NSLP) The Treasurer performed the verification of free and reduced price applications without a documented review or oversight process in place to ensure that applications selected for verification were in compliance with requirements related to the program. Special Tests and Provisions - Non-Profit School Food Service Accounts The School Corporation did not have an internal control in place to ensure that reimbursements for meals served were properly credited to the School Lunch fund. The lack of internal controls for Eligibility and Special Tests and Provisions - Verification of Free and Reduced Price Applications (NSLP) was isolated to the second year of the audit period. The lack of internal controls over Special Tests and Provisions - School Food Accounts was systemic throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Cause A proper system of internal controls was not designed by management of the School Corporation, which would include segregation of key functions. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper design or implementation of the components of a system of internal controls, including policies and procedures that provide segregation of duties and additional oversight as needed, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. Questioned Costs There were no questioned costs identified. INDIANA STATE BOARD OF ACCOUNTS 19 BORDEN-HENRYVILLE SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Recommendation We recommended that management of the School Corporation design and implement a proper system of internal controls, including policies and procedures that would provide segregation of duties to ensure appropriate reviews, approvals, and oversight are taking place. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2023-005 Subject: Child Nutrition Cluster (CNC) – Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirements. Context: During testing of reporting, we identified a control breakdown in the claim submission process. Although student meal data is summarized at the school level and reviewed by both the Food Services Bookkeeper and the Food Services Director, there is not a review of the actual claim submission prior to being submitted to the portal. Due to the breakdown in controls, we identified that the October 2022 revision claim overstated breakfasts served by 10 meals. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Director of Food Services will input the monthly claims into the state reporting system. This will be checked by the bookkeeper prior to submission to ensure data was entered correctly. Responsible Party and Timeline for Completion: Beginning January 2024

FINDING 2023-004 Subject: Child Nutrition Cluster (CNC) – Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Findings: Material Weakness Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Eligibility compliance requirements. Context: During testing of eligibility, we noted that a formal documented control for the review of online student applications was not in place. Management indicated that the free and reduced parameters are updated annually in the Titan system, however, there was no documented review that the updated parameters were reviewed. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Management will document a formal review of student applications for free/reduced lunch. Management will also document a review over the thresholds for free/reduced meals within the Titan system to ensure they accurately input into the system this will be done by way of signature on the state published eligibility guidelines. This will be kept for record keeping. Responsible Party and Timeline for Completion: Beginning July 2024

FINDING 2023-003 Subject: Child Nutrition Cluster (CNC) – Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Allowable Costs Audit Findings: Material Weakness Condition: The School Corporation did not have adequate internal controls in place to ensure that the School Corporation complied with the allowable cost requirements. Context: During our testing of the School Corporation’s compliance with the allowable costs requirements for CNC, we noted the following exceptions in our testing of 120 disbursements (60 vendor and 60 payroll): 1. The School Corporation paid $233 of sales tax across three vendor food purchases. 2. For two employee payroll selections, we were unable to trace their rate of pay to a Board approved wage rate ordinance or contract. The total amount paid out to the two employees was $2,635. FINDING 2023-003 (Continued) 3. We identified one employee that the School Corporation incorrectly paid one hour more than what the timecard stated, resulting in an overpayment of $14. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Food Service Director will review and signature all fund 800 expenditures prior to disbursement. All Food Service employee wages will align with the board approved rates. Payroll will be signed as reviewed by direct supervisors and the Business Office prior to remittance. Responsible Party and Timeline for Completion: Implement immediately

FINDING 2023-002 Subject: Child Nutrition Cluster (CNC) – Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Allowable Costs Audit Findings: Material Weakness Condition: The School Corporation did not have adequate internal controls in place to ensure that the School Corporation complied with the allowable cost requirements. Context: During testing of vendor disbursements for the CNC program, we identified 9 disbursements in a sample of 60, for which there was no evidence of a formal documented review of the disbursement taking place prior to the disbursement. Additionally, during testing of CNC payroll disbursements, we selected 8 pay periods for controls testing and noted that none of the 8 pay periods had proof of a formal review of the payroll distribution prior to remittance. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Food Service Director will review and signature all fund 800 expenditures prior to disbursement. Payroll will be signed as reviewed by direct supervisors and the Business Office prior to remittance. Responsible Party and Timeline for Completion: Implement immediately

Finding 2023-003 Finding Subject: Child Nutrition Cluster-Eligibility Summary of Finding: (suggestion: The School Corporation had not properly designed or implemented internal controls over eligibility.) Contact Person Responsible for Corrective Plan: Dr. Tracy Lorey, Monica Young, April Hopf Contact Phone Number and Email Address 812-482-1801 tlorey@gjcs.k12.in.us myoung@gjcs.k12.in.us ahopf@gjcs.k12.in.us Views of Responsible Officials: We agree with the Finding. Description of Corrective Action Plan: The corporation meets virtually each year with the software vendor to set up all free/reduced lunch applications, federal income guidelines and forms. A certified and signed copy of the income guidelines will be kept on file to show the match between the guidelines and point of sale. The applications that are flagged by the system will be reviewed for approval or denied and a copy will be maintained for The State Board of Accounts for audit. Anticipation Completion Date: February 2024

Finding 2023-004 – Child Nutrition Cluster – Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Laura Hubinger, CFO-Greater Clark County Schools lhubinger@gccschools.com Beverly Woodring, GM Student Nutrition-Aramark bwoodring@gccschools.com Jennifer Cato, Deputy Treasurer-Greater Clark County Schools jcato@gccschools.com Contact Phone Number: 812-288-4802 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: During the last audit period this was noted but due to the timing of that audit completion, the contract only had a small amount to be paid out therefore the timing between the last audit discovery and the current audit period it did not allow for a correction, however, the new director was able to secure three quotes from reputable companies for repair and maintenance services. A procedure is in place for checking and providing evident for Disbarment, Suspension and Ineligibility. Anticipated Completion Date: Immediately

Finding 2023-003 – Child Nutrition Cluster - Reporting Contact Person Responsible for Corrective Action: Laura Hubinger, CFO-Greater Clark County Schools lhubinger@gccschools.com Beverly Woodring, GM Student Nutrition-Aramark bwoodring@gccschools.com Jennifer Cato, Deputy Treasurer-Greater Clark County Schools jcato@gccschools.com Contact Phone Number: 812-288-4802 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The FSMC Food Service Director will ensure that they obtain a secondary review signature by the Deputy Treasurer to ensure accuracy of the reimbursement claim. Anticipated Completion Date: Immediately

Finding 2023-002 – Child Nutrition Cluster - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Laura Hubinger, CFO-Greater Clark County Schools lhubinger@gccschools.com Beverly Woodring, GM Student Nutrition-Aramark bwoodring@gccschools.com Jennifer Cato, Deputy Treasurer-Greater Clark County Schools jcato@gccschools.com Contact Phone Number: 812-288-4802 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The FSMC company will provide detail ledger and invoice sampling to the Deputy Treasurer to be reviewed digitally, which will be saved digitally and provided as evidence for next audit period. Anticipated Completion Date: February 2024

Finding 2023-001 – Child Nutrition Cluster – Eligibility Contact Person Responsible for Corrective Action: Laura Hubinger, CFO-Greater Clark County Schools lhubinger@gccschools.com Beverly Woodring, GM Student Nutrition-Aramark bwoodring@gccschools.com Jennifer Cato, Deputy Treasurer-Greater Clark County Schools jcato@gccschools.com Contact Phone Number: 812-288-4802 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Currently hand completed lunch applications are verified by the food service department, and reviewed by Deputy Treasurer/Food Service Liaison. The task of random verification for this process will be assigned to a staff position in the business office to check for eligibility compliance requirements. Anticipated Completion Date: April 2024

Condition: The School District did not complete on-site monitoring reviews for any buildings operating school lunch and breakfast programs within the School District during the year ended June 30, 2023. Planned Corrective Action: Southfield Public Schools contracts its food service with Southwest Food Service. Going forward, the Food Service Director (Southwest Food Service), and Food Service Purchasing (Southfield Public Schools) will coordinate the on-site monitoring reviews and its completion to Michigan Department of Education standards, and make sure the required forms are completed before deadlines. Contact person responsible for corrective action: Marc Ingram, Chief Financial Officer Anticipated Completion Date: 02/01/2024

FINDING 2023-003 Finding Subject: Child Nutrition Cluster – Activities Allowed or Unallowed Summary of Finding: Material Weakness A cash reimbursement is provided to the School Corporation based on meals served under the School Breakfast Program, National School Lunch Program, and Summer Food Service Program for Children. The cash reimbursement is to be used for the benefit of the food service program. The School Corporation did not have internal controls in place over payroll disbursements charged to the food service program. Payroll disbursements were paid without evidence that the detailed report of payroll disbursements was reviewed and approved by another person not involved in the original payroll process. Contact Person Responsible for Corrective Action: Benjamin Mann Contact Phone Number and Email Address: 765-536-0008 bmann@mgusc.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: The CFO now reviews the Org Charge report and signs off before the payroll batch being released to the bank. This report is generated by Payroll and Benefits. Also, this entire report is now included with board claims for board approval rather than a final summary sheet. Anticipated Completion Date: February 2024

FINDING 2023-002 Finding Subject: Child Nutrition Cluster – Allowable Costs/Cost Principles Summary of Finding: Material Weakness, Other Matters A cash reimbursement is provided to the School Corporation based on meals served under the School Breakfast Program, National School Lunch Program, and Summer Food Service Program for Children. The cash reimbursement is to be used for the benefit of the food service program. The School Corporation did not have internal controls in place over payroll disbursements charged to the food service program. Payroll disbursements were paid without evidence that the detailed report of payroll disbursements was reviewed and approved by another person not involved in the original payroll process. Contact Person Responsible for Corrective Action: Bengamin Mann Contact Phone Number and Email Address: 765-536-0008 bmann@mgusc.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: The CFO now reviews the Org Charge report and signs off before the payroll batch being released to the bank. This report is generated by Payroll and Benefits. Also, this entire report is now included with board claims for board approval rather than a final summary sheet. Anticipated Completion Date: February 2024.

II. FEDERAL FINDINGS AND QUESTIONED COSTS 2023-001 50000 - ELIGIBILITY Management's Response: We concur. View of Responsible Officials and Corrective Action Plan In the 2023-24 school year, Nutrition Services has implemented an additional step when processing meal applications to improve accuracy. Meal applications are verified a total of three times. The Nutrition Specialist is the Determining Official, the Director is the Confirming Official, and either the Secretary or Clerk is the Verifying official. Each official reviews the application for accuracy. Name of responsible individual: Brenda Zarate Implementation Date: 7/1/2023