Corrective Action Plans

Corrective Action: After the Food and Nutrition Director reviews the monthly claims, she will send an email noting her approval, before the claim is submitted to the state. This email approval will be attached to the journal entry support that is posted in the financial system when recording the revenue. Contact Person: Amanda Miller, Director of Food & Nutrition Services and Logistics / Ray Serrano - Accountant Anticipated Completion Date: June 30, 2024

The contact for this plan is Monica Merchant. The School will implement procedures to establish proper internal controls related to the submission of meal counts to the Child Nutrition Management System effective March 15, 2024, allowing for proper segregation of duties and review prior to submission. Meal Counts will continue to be tracked daily. Monthly participation counts, by meal type and location, will be reviewed and entered on the Child Nutrition Management System by the School’s financial consultant. Prior to submission, these data elements will be reviewed, verified and submitted by the organization’s Data and Special Projects Manager. The addition of a second layer of approval should allow for adequate internal control over monthly meal claims.

FINDING 2023-002 Finding Subject: Child Nutrition Cluster - Eligibility, Special Tests and Provisions - Verification of Free and Reduced Price Applications (NSLP) Summary of Finding: Eligibility The School Corporation had not properly designed or implemented a system of internal controls, which would include segregation of duties, that would prevent or detect and correct noncompliance relating to the eligibility determination of a child receiving meals. There was no oversight or review to ensure the eligibility determination was correct. Special Tests and Provisions - Verification of Free and Reduced Price Applications (NSLP) The Account Specialist performed the verification of free and reduced price applications. There was no documentation that an oversight, review, or approval process, or other compensating control, had been established to ensure the proper number of applications were verified for accuracy. Contact Person Responsible for Corrective Action: Josh Sinclair, Food Service Director and Allison Vanover, Corporation Treasurer. Contact Phone Number and Email Address: 812-246-3375 jsinclair@scsc.school avanover@scsc.school Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We will use the proposed USDA form that has two signatures required. Mr. Sinclair will ensure that all signatures are collected for proof of verification. Mr. Sinclair and Ms. Susan Westfall will be a second check on the eligibility determination. One will do paper applications and the other will do online applications. Then, they will check each other for accuracy. Anticipated Completion Date: March 2024

2023-001. Procurement United States Department of Education, passed through New York State Department of Education Title I Grants to Local Educational Agencies ALN: 84.010A Special Education Cluster Special Education Grants to States: IDEA, Part B ALN: 84.027A Special Education Grants to States: IDEA 611 ARP Allocations ALN: 84.027X Special Education Preschool Grants: IDEA Preschool ALN: 84.173A Special Education Preschool Grants: IDEA 619 ARP Allocations ALN: 84.173X Education Stabilization Fund COVID-19: Governor’s Emergency Education Relief Fund ALN: 84.425C COVID-19: Elementary and Secondary School Emergency Relief Fund ALN: 84.425D COVID-19: American Rescue Plan – Elementary and Secondary School Emergency Relief (ARP ESSER) Fund ALN: 84.425U United States Department of Agriculture, passed through New York State Department of Education Child Nutrition Cluster School Breakfast Program ALN: 10.553 National School Lunch Program ALN: 10.555 COVID-19: National School Lunch Program ALN: 10.555 COVID-19: Summer Food Service Program for Children ALN: 10.559 Condition: The District has not updated its existing policies and written procedures to conform to Uniform Guidance requirements. Planned Corrective Action: The District’s Assistant Superintendent for Business and Operations will work on updating all policies and procedures relating to U.S. Office of Management and Budget Uniform Guidance to ensure that District policies are in compliance with these guidelines. Responsible Contact Person: Jeremy Feder Assistant Superintendent for Business and Operations Lawrence Union Free School District 2 Reilly Road Cedarhurst, NY 11516 Anticipated completion date: June 30, 2024.

Audit Finding Reference: 2023-002 Management’s Views and Planned Corrective Action: Food Service Balance – We will ensure that we spend the surplus food balance funds in 23-24 and not make a transfer of the funds from the district unless needed to ensure we don’t have an excess fund balance beyond the limit allowed. Name of Contact Person and Completion Date: Name – Bridget Cross Anticipated Completion Date – will be corrected for the 23-24 Audit

􀀃 Finding􀀃2023􀍲005􀀃 􀀃 Finding􀀃Subject:􀀃Child􀀃Nutrition􀀃Cluster􀀃–􀀃Eligibility􀀃–􀀃Internal􀀃Controls􀀃 Summary􀀃of􀀃Finding:􀀃Internal􀀃Controls􀀃were􀀃not􀀃in􀀃place􀀃over􀀃direct􀀃certification􀀃of􀀃 students.􀀃 Contact􀀃Person􀀃Responsible􀀃for􀀃Corrective􀀃Action:􀀃Director􀀃of􀀃Food􀀃Service􀀃 Contact􀀃Phone􀀃Number􀀃and􀀃Email􀀃Address:􀀃(260)431􀍲2030,􀀃msnyder@sacs.k12.in.us􀀃 􀀃 Views􀀃of􀀃Responsible􀀃Official:􀀃We􀀃concur􀀃with􀀃the􀀃finding.􀀃 Description􀀃of􀀃Corrective􀀃Action􀀃Plan:􀀃 All􀀃direct􀀃certification􀀃information􀀃shall􀀃be􀀃initiated􀀃by􀀃the􀀃Director􀀃of􀀃Food􀀃Service:􀀃Pulling􀀃the􀀃 information􀀃monthly􀀃from􀀃CNP􀀃Web.􀀃The􀀃list􀀃of􀀃students􀀃to􀀃be􀀃directly􀀃certified􀀃will􀀃be􀀃printed,􀀃 signed􀀃and􀀃dated􀀃by􀀃the􀀃Director􀀃of􀀃Food􀀃Service.􀀃Once􀀃information􀀃is􀀃imported􀀃into􀀃the􀀃student􀀃 management􀀃system,􀀃the􀀃Assistant􀀃Food􀀃Service􀀃Director􀀃would􀀃then􀀃cross􀀃reference􀀃the􀀃printed􀀃list􀀃 of􀀃information􀀃to􀀃benefits􀀃assigned􀀃in􀀃the􀀃student􀀃management􀀃system􀀃to􀀃ensure􀀃accuracy.􀀃The􀀃 Assistant􀀃Food􀀃Service􀀃Director􀀃will􀀃initial􀀃next􀀃to􀀃the􀀃students􀀃they􀀃spot􀀃check􀀃on􀀃the􀀃list.􀀃The􀀃 printed􀀃document􀀃with􀀃signatures􀀃of􀀃both􀀃parties􀀃will􀀃be􀀃retained􀀃with􀀃the􀀃school􀀃years􀀃 applications.􀀃􀀃 Anticipated􀀃Completion􀀃Date:􀀃3/18/24􀀃

􀀃 Finding􀀃2023􀍲004􀀃 􀀃 Finding􀀃Subject:􀀃Child􀀃Nutrition􀀃Cluster􀀃–􀀃Allowable􀀃Activities,􀀃Allowable􀀃Cost/Cost􀀃 Principles􀀃 Summary􀀃of􀀃Finding:􀀃Internal􀀃Controls􀀃were􀀃not􀀃effective􀀃and􀀃did􀀃not􀀃prevent􀀃unallowable􀀃 activities/cost􀀃 Contact􀀃Person􀀃Responsible􀀃for􀀃Corrective􀀃Action:􀀃Director􀀃of􀀃Food􀀃Service􀀃 Contact􀀃Phone􀀃Number􀀃and􀀃Email􀀃Address:􀀃(260)431􀍲2030,􀀃msnyder@sacs.k12.in.us􀀃 􀀃 Views􀀃of􀀃Responsible􀀃Official:􀀃We􀀃concur􀀃with􀀃the􀀃finding.􀀃 Description􀀃of􀀃Corrective􀀃Action􀀃Plan:􀀃 All􀀃claims􀀃shall􀀃be􀀃created􀀃by􀀃the􀀃Assistant􀀃Food􀀃Service􀀃Director􀀃and􀀃reviewed􀀃for􀀃 compliance􀀃within􀀃the􀀃allowable􀀃cost􀀃category􀀃prior􀀃to􀀃payment􀀃by􀀃the􀀃Director􀀃of􀀃Food􀀃 Service.􀀃In􀀃the􀀃event􀀃that􀀃the􀀃Director􀀃of􀀃Food􀀃Service􀀃must􀀃initiate􀀃a􀀃claim􀀃first,􀀃the􀀃 Assistant􀀃Food􀀃Service􀀃Director􀀃would􀀃then􀀃review􀀃the􀀃claim􀀃prior􀀃to􀀃issuance.􀀃All􀀃claims􀀃are􀀃 returned􀀃to􀀃the􀀃Assistant􀀃Food􀀃Service􀀃Director􀀃for􀀃review􀀃of􀀃accuracy􀀃after􀀃the􀀃payment􀀃 method􀀃has􀀃been􀀃authorized􀀃to􀀃ensure􀀃accuracy􀀃and􀀃compliance.􀀃Both􀀃parties􀀃will􀀃initial􀀃 documents􀀃appropriately,􀀃as􀀃well􀀃as􀀃maintain􀀃all􀀃copies􀀃of􀀃proof􀀃of􀀃purchase/service􀀃with􀀃 original􀀃claim􀀃form􀀃documents.􀀃􀀃 Anticipated􀀃Completion􀀃Date:􀀃3/18/24􀀃

Commodity Supplemental Food Program (CSFP) and The Emergency Food Assistance Program (TEFAP) have developed a tentative 2024 inventory schedule to ensure continued compliance with the annual USDA Food and Nutrition Services (FNS) requirements. The schedule was submitted to FNS as part of the state’s Management Evaluation (ME) findings response. The State received notification from FNS on January 26, 2024, noting the successful completion and close-out of the FFY 2022 Management Evaluation and its findings.

We will continuously monitor the compliance supplements for updates in order to meet all requirements. We have added additional staff to complete FFATA reporting to ensure the reports are submitted timely and accurately moving forward.

Condition - The District did not obtain debarment certification or document their vendor search in the System for Award Management website for vendors contracted in excess of $25,000 related to the grant program. Upon further review, it was determined that the vendors were not suspended or debarred. Plan - Policies and procedures will be implemented to document the verification that vendors are not suspended or debarred. Anticipated Date of Completion - June 30, 2024. Name of Contact Person - James Dunlap, Superintendent. Management Reponse - Management does not disagree with this finding. In future years, the District will document their verification that vendors are not suspended, debarred, or otherwise excluded from doing business.

Findings and Questioned Costs Related to Federal Awards Finding Number: 2023‐001 Program Name/Assistance Listing Title: Child Nutrition Cluster Assistance Listing Numbers: 10.553, 10.555, 10.559 Contact Person: Mark Ollerton, Business Manager Anticipated Completion Date: Because this has been addressed the completion date is immediate as to the corrective action plan, March 25, 2024. Planned Corrective Action: The process in the District is that two individuals reconcile the number prior to submission of claims. After evaluating what caused the error, the staff did follow best practices in that two separate individuals reconciled the numbers for the claim. After this was completed, the claim was created and submitted to be processed by the Arizona Department of Education Child Nutrition Program. In developing the claim, a number was entered incorrectly on the claim. The corrective action is already in place. The District will continue with the dual review of the numbers. The error has been discussed with staff and they will be more diligent in their part of entering the claim information.

Reviewing all areas of this finding, the District needs to assist with extra help from the district office and ensure that all student records are updated timely based on the review of income eligibility forms or direct certification information, plus additional training.

Reference # and title: 2023-003 Internal Control over Procurement Federal program and specific federal award identification: AL Number Award Year FEDERAL GRANTER/ PASS THROUGH GRANTOR/PROGRAM NAME United States Department of Agriculture; passed through Louisiana Department of Education Child Nutrition Cluster: School Breakfast Program AL #10.553 2023 National School Lunch Program AL #10.555 2023 Condition: According to 2 CFR sections 180.220 and 180.995, the School Board is required to review any vendors they are contracting with for goods and services that are expected to equal or exceed $25,000 to ensure that the vendor is not suspended or debarred from federal funds. This verification can be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA), (2) collecting a certification from the vendor or (3) adding a clause or condition to the contract with the vendor. In testing a sample of two vendors to determine if the School Board either obtained a suspension and debarment certification or reviewed the excluded parties listing, it was noted that the School Board could not provide supporting documentation for one of the vendors. However, when the auditor reviewed for the vendor, it was noted that vendor was not suspended or debarred from receiving federal funds. Corrective action planned: The CNP Supervisor has contacted all current vendors regarding the vendor suspension and debarment certification process. All vendors were asked to provide a signed certification or confirmation of no suspension or debarment is active for their business name or owner at www.SAM.gov. Also, the CNP Supervisor set up a SAM.gov account to have access to actively check vendor eligibility status multiple times per year. Several contracts have supporting documentation via the CNP NE LA Co-op purchasing as well. A file has been made to retain the Vendor SAM verification information or completed Debarment Certification Form. This information will be verified at the first of each school year (July/August) and midschool year (January/February). Person responsible for corrective action: Mr. Cody Carrico, Supervisor of Food Service Phone: (318) 255-1474 Lincoln Parish School Board Fax: (318) 254-1220 1428 Arlington Street Ruston, LA 71270 Anticipated completion date: January 31, 2023 – Process in place

Reference # and title: 2023-002 Internal Control and Compliance over Financial Reporting Federal program and specific federal award identification: AL Number Award Year FEDERAL GRANTER/ PASS THROUGH GRANTOR/PROGRAM NAME United States Department of Agriculture; passed through Louisiana Department of Education Child Nutrition Cluster: School Breakfast Program AL #10.553 2023 National School Lunch Program AL #10.555 2023 Condition: Louisiana Department of Education (LDOE) requires the School Board to complete monthly claims for reimbursement for meals and snacks served to eligible students within 60 days of the following the last day of the month covered by the claim. Required internal controls over these claims for reimbursement required that all data for the claim be maintained and complete and accurate. Additionally, internal controls require that reports be reviewed by someone other than the person completing the claim. In testing a sample of two months, it was noted that the School Board did not have a review process of the claim by a second person before the claim was submitted. It was also noted that the School Board did not include all students that received meals in requesting for reimbursement as well as the School Board used the wrong CEP percentage in the request for reimbursement. In reviewing the full year’s claims to determine the amount over/under requested, it was noted that these errors caused the School Board to under request for reimbursement in the amount of $20,044. Corrective action planned: The Lincoln Parish School Board hired a new CNP Supervisor in November, 2023 and a new CNP secretary/bookkeeper in December, 2023. CEP reimbursement claim training was conducted on-site with CNP department staff on December 13, 2023, by: - Stephanie Loup – Executive Director of Nutrition – Louisiana Department of Education - Misty Woods – Director of School Food Service– Louisiana Department of Education During this training, the CEP free claim percentage for 2023-2024 was validated as 83.78% and a mock claim worksheet was completed with new administrative staff. This percentage will be validated annually. Regarding the review process of the CEP claim, we have implemented a two-check verification method for this process. Step One is related to the bookkeeper’s responsibilities. The bookkeeper collects and fills out the CNP Reimbursement Claim form in the CNP Claim portal, prints the completed form, and then signs and dates the form before it is submitted to the CNP Supervisor. Step Two is related to the CNP Supervisor’s responsibility. The Supervisor will conduct final review of the report data. If the report is accurate, the Supervisor signs and dates the printed form and returns the form to the Bookkeeper for filing with claim records. Then, the official claim is submitted electronically by the Bookkeeper via the State CNP Claim portal. Person responsible for corrective action: Mr. Cody Carrico, Supervisor of Food Service Phone: (318) 255-1474 Lincoln Parish School Board Fax: (318) 254-1220 1428 Arlington Street Ruston, LA 71270 Anticipated completion date: December 31, 2023 – Actively in place

To address the accuracy and timeliness of our entries into the FFATA system, we will use the USASPENDING.GOV website to assist us in reconciling what has been entered into the FFATA system.  This will allow us to ensure that our grant ledgers agree with what is entered into FFATA. In March 2023 we started reconciliations and plan to continue reconciling a couple times each year.  The work will be done by the Deputy CFO or position assigned by the Deputy CFO.   We will also implement a process that will have all the steps necessary for a grant award or an amendment to ensure it is posted properly within our internal files and the external systems. This will ensure that new awards and amendments get routed and entered in the FFATA system timely. We will look into the Batch upload process to allow for data to be entered into the system easier. Name: Sean Cousino Position: Deputy CFO Email: sean.couisno@vermont.gov Phone Number: 802 595-3693 Date of Implementation of Corrective Action: 5/01/2024

FINDING 2023-003 Finding Subject: Child Nutrition Cluster – Special Tests and Provision – Verification of Free and Reduced Price Applications (NSLP) Summary of Finding: The finding was isolated to school year 2023 in which one employee is to determine the number of applications to be verified, select the required applications and perform verifications of eligibility, with a second employee reviewing the verifications. Contact Person Responsible for Corrective Action: Kathy VanHoosier, ECA Manager Contact Phone Number and Email Address: 812-547-3300; kathy.vanhoosier@tellcity.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The process of selecting and performing verifications of eligibility with a second employee reviewing the verifications was refined and fully implemented for school year 2023/2024. A change in personnel since the 2022/2023 improved this process, and sign-offs were done and initialed by both the initial reviewer (the Central Office manager) as well as the final reviewer (the ECA Manager) on the 2023/24 applications. It is the intent to continue with this improved internal control process going forward. Anticipated Completion Date: Already Done in Fall 2023

a. Material Weakness - Paid Lunch Equity (NSLP) The District did not calculate its average paid lunch pricing requirement for the fiscal year ended June 30, 2023. b. LCSD7 Plan of Action - New staff hired in July of 2023 has received training from Oregon Department of Education on the calculation process for paid lunch pricing. c. The Business Manager along with the Elementary Principal will ensure this process is complete in June 2024.

a. Material Weakness-Verification of Free and Reduced Price Applications The District did not select or verify a sample of applications that it approved for free and reduced price meals during 2022-2023. b. LCSD7 Plan of Action - New staff hired in July of 2023 has received training from Oregon Department of Education on the verification of application process. In January the District received a waiver and now can offer every student free meals. c. The Business Manager along with the Elementary Principal will ensure this process is complete in June 2024.

Corrective Action Plan Finding No: 2023-002 Condition: During our audit testing we noted that the District Cashier prepares and submits monthly reimbursement claims to ISBE and that these submissions are not reviewed or approved by anyone else. No formal documentation of the review. Plan: The District will implement a process in which the Business Manager will review and approve monthly reimbursement claim submissions prior to them being submitted. Anticipated Date of Completion: June 30, 2024 Name of Contact Person: Ryan Leonard, Business Manager/CSBO (708) 496-8700 x 5004

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF AGRICULTURE, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, CHILD NUTRITION CLUSTER – FEDERAL ALN 10.555, 10.559, 10.556, AND 10.553 2023-003 Internal Control Over Compliance With Federal Suspension and Debarment Requirements Summary of Finding Criteria – 2 CFR § 180 requires the District to establish and maintain effective internal control over compliance with requirements applicable to federal program expenditures, including suspension and debarment requirements applicable to the child nutrition cluster program. Condition – The District did not have sufficient controls in place within its child nutrition cluster program to assure that it was not contracting for goods or services with parties that are suspended or debarred, or whose principals are suspended or debarred from participating in contracts involving the expenditures of federal program funds. Corrective Action Plan Actions Planned – The District will review its policies and procedures relating to suspension and debarment for its federal programs and will ensure that all parties with which it contracts for goods or services are eligible to participate in contracts involving the expenditures of federal program funding. Official Responsible – Peter Olson-Skog, the District’s Superintendent. Planned Completion Date – June 30, 2024. Disagreement With or Explanation of Finding – The District agrees with this finding. Plan to Monitor – Peter Olson-Skog, the District’s Superintendent, will ensure appropriate controls are in place to verify that any vendor with which the District contracts for federal program goods or services exceeding $25,000 is not listed as suspended or debarred on the federal Excluded Parties List System website.

FINDING 2023-004 Finding Subject: Child Nutrition Cluster – Internal Controls Summary of Finding: This is a repeat finding for Eligibility from the immediately prior audit report. The prior audit finding number was 2021-005. The School Corporation did not properly design or implement 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. The free and reduced-price applications were processed by one employee and updated within the software without an oversight or review process in place to ensure accuracy. Additionally, one employee uploaded the Direct Certification reports from the state into the software system without a documented oversight or review process in place to ensure directly certified students were properly processed. One employee at the School Corporation submitted meal reimbursement claim reports on a monthly basis with no review or oversight process in place to ensure the reports were properly and timely submitted. Contact Person Responsible for Corrective Action: Jessica Murray Contact Phone Number and Email Address: 574-457-3188 x 3234, jmurray@wawasee.k12.in.us Views of Responsible Officials: Management concurs with the finding. Description of Corrective Action Plan: The meal reimbursement claim reports will be prepared by the Food Service Director and reviewed and verified by the Treasurer prior to submission. The Food Service Director will submit the reports and the Treasurer will review the submitted reports to verify accuracy in submission. An internal sign-off form will be created and implemented to document the secondary review of the report data. The direct certification lists will be downloaded monthly by the Food Service Director and uploaded into the software system. A secondary person will review the data following upload into the software system to ensure data was uploaded correctly and that direct certified students were correctly processed. An internal sign-off form will be created and implemented to document the secondary review of the upload data. The free and reduced-price applications will be processed by the Food Service Director. The Treasurer will review each application to ensure it has been accurately processed and will sign off on each application to indicate completion of the secondary review. Anticipated Completion Date: The projected date of completion is August 2024.

Finding 2023-002 Condition The Director of Food Services prepares and submits monthly reimbursement claims to ISBE. These submissions are not reviewed or approved by anyone else. No documented evidence exists of an independent reviewer examining meal claim reports beyond the preparer. Corrective Action Plan Corrective Action Planned: The Director of Food Service will review monthly claims with the CFO at their standing meeting each month. Name(s) of Contact Person(s) Responsible for Corrective Action: Lyndl Schuster, Assistant Superintendent for Business Services Anticipated Completion Date: 2/1/2024

Finding 2023-001 Condition The District failed to perform and submit the required PLE calculation. Corrective Action Plan Corrective Action Planned: The PLE for the following school year, FY24, was performed and submitted. Name(s) of Contact Person(s) Responsible for Corrective Action: Lyndl Schuster, Assistant Superintendent for Business Services Anticipated Completion Date: April 2023, for FY24

FINDING 2023-001 Finding Subject: Child Nutrition Cluster – Internal Controls Summary of Finding: We did not properly design internal controls to prevent, detect or correct noncompliance over Eligibility, Direct Certifications, or Reporting Claims Submissions. Contact Person Responsible for Corrective Action: Leeanne Koeneman Contact Phone Number and Email Address: Leeanne.Koeneman@nacs.k12.in.us; 260-637-8768 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Board has already taken action and approved an additional staff member to the Food Service Department to ensure segregation of duties. By adding the Food Service Administration Assistant to the department, their role will add a level of review to ensure compliance with Direct Certification eligibility status for students that are uploaded by the Assistant Food Service Director. The review will ensure that the upload of data is correct and complete. The duties of the added position with also include a review of monthly reporting of Sponsorship Claims, prepared by the Food Service Director prior to submission to the Indiana Department of Education (IDOE). Anticipated Completion Date: June 30, 2024

10.553, 10.555, 10.559 - Child Nutrition Cluster 2023-001 Net Cash Resources Corrective Action Plan: The School Lunch fund continues to have excess fund balance on hand due to the additional reimbursements provided during the COVID-19 pandemic. The District is currently reviewing the equipment used by the program and will create a plan to use these funds to support the program's infrastructure. Expected Completion Date: June 30, 2024