Corrective Action Plans

Finding 2023-003 – Child Nutrition Cluster – Activities Allowed or Unallowed, Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Sandy Denny – Food Service Director Contact Phone Number: 812-952-2555 ext. 250 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We will review all food service payroll charges to ensure only payroll related to food service duties is charged to the child nutrition cluster program. Anticipated Completion Date: April 2024

Finding 2023-001 – Child Nutrition Cluster – Eligibility Contact Person Responsible for Corrective Action: Sandy Denny – Food Service Director Contact Phone Number: 812-952-2555 ext. 250 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We will implement a formal review of the meal system income threshold parameters used to ensure the eligibility determinations are correct. Anticipated Completion Date: July 2024 (new school year)

CORRECTIVE ACTION PLAN (CAP): Explanation of Disagreement with Audit Findings: There is no disagreement with the audit finding as stated. Actions Planned in Response to Finding: Management will review expenditures coded to the food service program to ensure that only allowable expenditures are charged there. Official Responsible for Ensuring CAP: The Executive Director is the official responsible for ensuring corrective action of the deficiency. Planned Complete Date for CAP: The planned completion date is June 30, 2024. Plan to Monitor Completion of CAP: The Executive Director and Financial Service Provider will monitor the expenditures in the food service program.

FINDING 2023-002 Finding Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Summary of Finding: Prior to entering into subawards and covered transactions with program 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 SAM exclusions, collecting a certification from that person, or adding a clause or condition to the covered transaction with that person. Upon inquiry of the School Corporation, in order to review the procedures in place for verifying that an entity with which it plans to enter into a covered transaction is not suspended, debarred, or otherwise excluded, the School Corporation disclosed there were not adequate procedures in place to ensure this. While the suspension and debarment report is run on a yearly basis in June, this was not adequate to ensure that this verification was performed prior to a covered transaction being entered into. One covered transaction that equaled or exceeded $25,000, paid from Child Nutrition Cluster funds, was identified. The one transaction, totaling $43,599.31, was selected for testing. The School Corporation did not verify the vendor's suspension and debarment status prior to payment. INDIANA STATE BOARD OF ACCOUNTS 29 Contact Person Responsible for Corrective Action: Lana M. Miller Contact Phone Number and Email Address: Phone Number-812-689-6282 Email- lmiller@sripley.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: We will amend our current process of running Suspension and Debarment inquiries from annually in June each year to every six months and prior to check issuance when over $25,000 from federal funds. Anticipated Completion Date: Immediately, February 2024

FINDING 2023-001 Finding Subject: Child Nutrition Cluster - Special Tests and Provisions - Verification of Free and Reduced Price Applications Summary of Finding: An effective internal control system, which would include segregation of duties, was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Special Tests and Provisions - Verification of Free and Reduced Price Applications compliance requirement. Based upon the number of approved applications on file on October 1, the School Corporation was required to select a sample of three applications for fiscal year 2022- 2023 that were approved for free and reduced price meals, to verify the applicants' eligibility for the benefits received. The School Corporation requested income documentation from each applicant to perform the verifications as required. The School Corporation did not receive a response from any of the applicants. As a result, the student included in each application should have had a change in status from free or reduced to paid. However, for two of the applicants, the student was flagged in the system as no response, but the students' statuses were not updated to reflect that each was no longer eligible for free or reduced price meals. Contact Person Responsible for Corrective Action: Lana M. Miller Contact Phone Number and Email Address: Phone Number- 812-689-6282 Email- lmiller@sripley.k12.in.us INDIANA STATE BOARD OF ACCOUNTS 28 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: This finding was a result of a new staff person in the position working with software that was new to her. It was noted by the auditor that the application status was changed to paid in the verification status. The staff person involved did not know that she needed to make another change in the software other than changing the application status. We have discussed with the person responsible for this regarding the needed two-step process to change a student’s status. Additionally, the staff person has set up a process for segregation of duties. A second person will be reviewing the screens after verification changes are made. This person will also sign off on the paper/report to show the second review and segregation of duties. Anticipated Completion Date: Immediately, February 2024

FINDING 2023 004 Finding Subject: Child Nutrition Cluster – Allowable and Non allowable Activities and Costs Summary of Finding: Material Weakness FCSC did not have a review process in place to ensure that food service program funds were being used for allowable activities and allowable costs. Contact Person Responsible for Corrective Action: Tina Smith Contact Phone Number and Email Address: (765) 825 2178 tlsmith@fayette.k12.in.us Views of Responsible Officials: We concur with this finding. However, it has never been a past practice to audit the costs and activities of the food service program. This has been a recent change in audit requirements that began with the beginning of this audit period. Description of Corrective Action Plan: The Deputy Treasurer will randomly and periodically request receipts from the food service director in order to conduct a “mini audit” to ensure that all costs and activities are, in fact, allowable. Anticipated Completion Date: A new procedure is in place effective February 2024. The documented oversight will be available and provided for review with the 2025 audit.

FINDING 2023-002 Finding Subject: Child Nutrition Cluster- Allowable Activities, Allowable Costs/Cost Principals Summary of Finding: A portion of the wages for the CFO/Treasurer, the Director of Operations, the Director of Finance, and two School Secretaries were paid from the School Lunch Fund. The wages charged to the School Lunch fund were based on fixed percentages and did not provide adequate information to determine if the percentage charged was appropriate. Total wages charged to the program for the above noted employees was $31,617. Contact Person Responsible for Corrective Action: Camden Parkhurst Contact Person Phone Number and Email Address: 765-457-8101 camden.parkhurst@nwsc.k12.in.us View of Responsible Official: We concur with the finding. There was a substantial amount of turnover within the finance department. It was understood that the mentioned salaries were removed from the 0800 fund following the last audit. During review it was discovered only the Director of Operations and Assistant Treasurer salaries were removed from the child nutrition cluster. Upon discovery the Operations Assistant and Director of Finance were still having a portion of the salary paid from the 0800 fund, they were immediately removed. Description of Corrective Action Plan: The Director of Finance and the Operations Assistant’s salaries have been removed from the 0800 fund and returned to the 0300 fund. Anticipated Completion Date: Immediate and has been completed.

Finding - The School District’s net cash resources exceeded 3 months average expenditures for its nonprofit school food service. Recommendation - That the School District ensure that its net cash resources does not exceed 3 months average expenditures for its nonprofit school food service. Method of Implementation - Ensure the accounting in the enterprise fund will be monitored. In addition, the District plans to utilize the excess funds to upgrade kitchen appliances. Person Responsible for Implementation - School Business Administrator Implementation Date - March 1, 2024

Finding - The food service daily meal count report did not agree with the School District’s edit check worksheets that detail the number of meals served and provides the number of meals used to determine the amount of Federal reimbursement. Recommendation - That the School District’s food service daily meal count reports agree with the edit check worksheets in an effort to request the appropriate amount of Federal reimbursement. Method of Implementation - Review and enhance internal controls from prior administration, including an implementation of procedures that align to the recommendation. Person Responsible for Implementation - School Business Administrator Implementation Date - March 1, 2024

Finding - The documentation related to the School District's verification report was not available for audit. Recommendation - That the School District ensure that proper supporting documentation of verification is maintained. Method of Implementation - Review and enhance internal controls from prior administration. Person Responsible for Implementation - School Business Administrator Implementation Date - March 1, 2024

Name of Auditee: City School District of Albany Name of Audit Firm: EFPR Group, CPAs, PLLC Period Covered by the Audit: Year ended June 30, 2023 CAP Prepared by: Joseph Karas, Assistant Superintendent for Business and Finance Phone: 518-475-6022 (A) Current Finding on the Schedule of Findings and Responses (3) Audit Finding 2023-003 (a) Comments on the finding and recommendation: The District agrees with the finding. The District also agrees with the recommendation. See below for actions taken. (b) Actions Taken: Management will reconcile significant asset and liability accounts, including state and federal receivables, at year end to ensure accounting records accurately reflect appropriate balances. (c) Anticipated Completion Date: Management anticipates this finding will be resolved by June 30, 2024.

FINDING 2023-003 Finding Subject: Child Nutrition Cluster - Allowable Costs/Cost Principles Summary of Finding: Condition and Context Direct charges to a federal award are to be for allowable costs and made in conformance with the applicable cost principles. Payroll benefits were entered by the payroll department and reviewed by the Payroll Coordinator to ensure proper payment. However, this review was not completed on a detailed level by employee to ensure the payroll withholdings, deductions, and benefits retained from employees’ wages were for allowable costs and made in conformance with applicable cost principles. The lack of internal controls was a systemic issue throughout the audit period. Contact Person Responsible for Corrective Action: Dr. Thomas A. Keeley, Executive Director of Business Services Contact Phone Number and Email Address: (574) 258-9591 Tkeeley@phm.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The school corporation will revise job descriptions to clearly identify tasks and responsibilities for the payroll process. The school corporation will print a detailed employee wage report for each payroll with double signatures indicating a thorough review process by the payroll coordinator and the payroll accounting specialist/Food Service Manager. Finally, the Executive Director for Business Services will complete noting a final review of corresponding benefits withholdings to the corresponding vendor payments indicating the process is complete with an official signature. Anticipated Completion Date: March 1, 2024.

2023-004 Child Nutrition Cluster – 10.555 – National School Lunch Program, 10.559 – Summer Food Service Program for Children, 10.553 – School Breakfast Program – Procurement, Suspension, and Debarment Condition One procurement was tested for the Food Service Program, and it was found to not have followed the District’s procurement plan. Recommendation The District should ensure that it follows its procurement policy for all applicable transactions. Comments on the Finding The District is aware of the oversight and has implemented procedures to prevent this, in the future. Actions Taken As of the date of this notice, staff involved with this procedure have undergone training through KASB and KSDE and have added the procedure of verifying quotes to ensure the procurement plan is followed to a monthly checklist to ensure that it occurs timely.

Finding 2023-003 – Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Michelle Babcock Contact Phone Number: 317-392-2505 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We have already established an improved internal controls procedures for procurement. We have established a checklist process to ensure the Suspension and Debarment Check has been completed for all federal purchases over the threshold. Anticipated Completion Date: October 2022

Finding 2023-002 – Child Nutrition Cluster - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Michelle Babcock Contact Phone Number: 317-392-2505 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We have established an improved internal controls procedures with internal purchases. The items requested will be submitted in writing and when the items are delivered to the perspective department or building, a signature will be obtained to confirm the items were delivered internally before the funds will be transferred to/from the respective accounts. Anticipated Completion Date: January 2024

Condition: The District did not select and verify the required sample of approved free and reduced price applications by the required deadline. Plan: The district will have a calendar reminder to begin auditing applications on Oct. 1 and complete the process with submission to ISBE by December 15. Anticipated Date of Completion: 12/31/2024 Name of Contact Person Yasmine Dada, Business Manager ________________________________________________

Views of responsible officials and Corrective Action Plan: Management of the School has noted the 2 CFR Section 200.320 to ensure that the procurement requirements are met.

FINDING 2023-002 Finding Subject: Child Nutrition Cluster - Eligibility Summary of Findings: An effective internal control system, which would include segregation of duties, was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Eligibility compliance requirement. The free and reduced-price applications were completed online by the applicants, and the information was automatically uploaded into the School Corporation's nutrition program software system. The software system then calculated the student's eligibility for free and reduced-price meals based on the parameters in the system. There was no documented oversight, review, or approval process to ensure the parameters in the system were correct and that the eligibility determination made complied with the requirements of the programs. The lack of internal controls was a systematic issue throughout the audit period. Contact Person Responsible for Corrective Action: Julie Dudley Contact Phone Number and Email Address: 812.537.7205 jdudley@lburg.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Food Service Director and Business Manager have added the verification of every 30th Free/Reduce application that is submitted during the school year to their monthly checklists. Beginning with the 2024-25 school year, the Food Service Director will enter the eligibility parameters into the school nutrition software. Once entered the Food Service Director will provide a copy of the prices entered into the system to be reviewed and approved by the Business Manager or Superintendent. Anticipated Completion Date: January 2024/July 2024

Specific corrective action plan for the finding: Carol Gonzales, Finance Director will make sure that the required reporting information is submitted to the federal audit clearinghouse by the deadline of March 31st. Timeline for completion of corrective action plan: March 31st of 2024 or earlier Employee positions(s) responsible for meeting the timeline: Carol Gonzales, Finance Director

Auditors’ Recommendation: We recommend that as part of preparing monthly bank reconciliations, the reconciliation with the balance from the general ledger should be performed. Any differences should be immediately investigated and corrected. Once completed, the reconciliation should be reviewed by someone independent of the preparer. Both, the individual preparing and reviewing the bank reconciliations should sign or initial and date the reconciliation when completed. We recommend that the District incorporate procedures to ensure that such general ledger accounts are reconciled on a monthly basis. It is important that a dual accounting system is utilized in each individual fund and transactions between funds should be booked through the interfund receivables and payables. School District’s Response: Penny Crowell, Business Manager will ensure that bank reconciliations are prepared on a timely basis throughout the year, which includes a reconciliation to the general ledger. The District will have the Superintendent review bank reconciliations. Once completed, the preparer and reviewer will sign and date each reconciliation to evidence their completion. Lastly, the District will reconcile due to/due from accounts on a monthly basis. These processes will take place during the year ending June 30, 2024.

FINDING 2023-002 Finding Subject: Child Nutrition Cluster - Verification of Free and Reduced Price Lunch Applications Summary of Finding: Management had not developed or implemented a system of internal control that would have ensured compliance with requirements related to the grant agreement and Special Tests and Provisions - Verification of Free and Reduced Price Applications (NSLP) compliance requirements. The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and Special Tests and Provisions - Verification of Free and Reduced Price Applications (NSLP) compliance requirements. A lack of segregation of duties within an internal control system could also allow noncompliance with compliance requirements and allow the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the program. We recommended that the School Corporation's management establish a system of internal controls, including segregation of duties, related to the grant agreement and Special Tests and Provisions - Verification of Free and Reduced Price Applications (NSLP) compliance requirements. Contact Person Responsible for Corrective Action: Andrea Miller Contact Phone Number and Email Address: 765-564-2100, millera@delphi.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Food Service Director or Assistant will review the applications, the other will do a second review. The Food Service Director and Assistant sign each application that is verified to ensure all information is accurate and the eligibility status is correct in Skyward. If additional verification information is provided, it will be documented and recorded in the binder with the applications. Anticipated Completion Date: August 2024

FINDING 2023-003 Finding Subject: Child Nutrition Cluster - Eligibility Summary of Finding: The School Corporation's management had not developed a system of internal controls that would have ensured compliance with the Eligibility compliance requirements. The failure to establish an effective internal control system places the School Corporation at risk of noncompliance with the grant agreement and the Eligibility compliance requirements. A lack of segregation of duties within an internal control system could also allow noncompliance with compliance requirements and allow the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the program. We recommended that the School Corporation's management establish a system of internal controls, including segregation of duties, related to the grant agreement and the Eligibility compliance requirements listed above. Contact Person Responsible for Corrective Action: Andrea Miller Contact Phone Number and Email Address: 765-564-2100, millera@delphi.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Food Service Director or Assistant will enter online and paper applications, the other will review the entries compared to the applications, and both will sign off the applications. An additional selection will be added in Skyward to document which type of classification. A legend for the codes will be kept in the front of the binder where the applications are kept for reference. Anticipated Completion Date: August 2024

FINDING 2023-004 Finding Subject: Child Nutrition Cluster - Allowable Costs/Cost Principles Summary of Finding: Management had not developed an effective system of internal control that would have ensured compliance with the grant agreement and the Allowable Costs/Cost Principles compliance requirement. The failure to establish an effective internal control system enabled noncompliance to go undetected. Noncompliance with the grant agreement and the compliance requirement could have resulted in the loss of funds to the School Corporation. We recommended that the School Corporation's management establish an effective system of internal control to ensure compliance and comply with the grant agreement and the Allowable Costs/Cost Principles compliance requirement. Contact Person Responsible for Corrective Action: Andrea Miller Contact Phone Number and Email Address: 765-564-2100, millera@delphi.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: A price list will be requested from vendors (GFS/Piazza) twice a month to reflect current pricing, and reports will be filed by school year by the Food Service Director for reference. The Food Service Director or Assistant will sample items that have been purchased and compare them to the pricing listing to verify accuracy. Anticipated Completion Date: August 2024

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: Krystal Burnham, Food Service Compliance Coordinator/ Danny Robbins, Interim Director of Budget and Finance Anticipated Completion Date: July 31, 2023 Planned Corrective Action: The District will ensure that monthly counts are supported by documentation and verified by a second staff member and agree to the accuracy of the reimbursement claims prior to submission to the Arizona Department of Education. The District will also ensure that reimbursement claims are submitted within the required time period after month end and any identified issues with measures that prevent their recurrence.

The filing of the Data Collection Form will be submitted by the required due date. In the prior year, the audit report was submitted after the Federal Audit Clearinghouse deadline. The current audit will be submitted with sufficient time to meet the Federal Audit Clearinghouse submission date requirement. Responsible party(ies) for corrective action(s): Chief Financial Officer Corrective action(s) timeline: March 15, 2024