Corrective Action Plans

March 21, 2024 U.S. Department of Education Washington, D.C. Unified School District No. 321 respectfully submits the following corrective action plan for the year ended June 30, 2023. SSC CPAs, P.A. 3025 Cortland Circle, Suite 201 Salina, Kansas 67401 Audit period: Year ended June 30, 2023 The findings from the June 30, 2023 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Section I of the schedule, Summary of Audit Results, does not include findings and is not addressed. FINDINGS-FINANCIAL STATEMENT AUDIT 2023-001 Internal Controls over Financial Statement Presentation (Material Weakness) Recommendation: The Board of Education and management should review the financial reporting process. Once this review is complete, the District should then perform a risk assessment to determine the best way to implement appropriate internal controls over financial reporting to ensure conformity with the regulatory basis of accounting. Action Taken (Unaudited): Management plans to review the financial reporting process and implement appropriate internal controls over financial reporting to ensure conformity with the regulatory basis of accounting. Contact Name – Kristy Dyche Expected Completion Date - 06/30/2024 2023-002 Internal Controls over Adjustments to Expenditures (Material Weakness) Recommendation: The Board of Education and management should review the process of moving expenditures between funds so that negative (credit) balances are not reported in general ledger accounts. Adjustments to expenditure accounts in the general ledger should be supported by proper documentation and allocation of expenditures. Action Taken (Unaudited): Management plans to review the process of moving expenditures and develop appropriate internal controls to ensure adjustments to expenditure accounts in the general ledger are supported by proper documentation. Contact Name – Kristy Dyche Expected Completion Date - 06/30/2024 2023-003 Internal Controls over Compliance with Kansas Statutes (Significant Deficiency) Recommendation: The Board of Education and management should review the expenditures in funds to ensure that no indebtedness is created in excess of budget limits. Action Taken (Unaudited): Management plans to review the process or tracking expenditures and develop appropriate internal controls to ensure that no indebtedness is created in excess of budget limits in budgeted funds. FINDINGS-FEDERAL AWARD PROGRAMS AUDIT 2023-004 Preparation of and Internal controls over Schedule of Expenditures of Federal Awards Preparation (Material Weakness) Federal Agency: U.S. Department of Education Program Names: Child Nutrition Cluster Assistance Listing Numbers: 10.553, 10.555 and 10.559 Award Period: June 30, 2023 Recommendation: The Board of Education and management should review the financial reporting process. Once this review is complete, the District should then perform a risk assessment to determine the best way to implement appropriate internal controls over financial reporting to ensure that the District prepares the schedule conformity with Uniform Guidance. Action Taken (Unaudited): Management plans to develop proper written policies and procedures for the internal control over compliance to ensure accuracy and completeness in the preparation of the schedule as required by Uniform Guidance. Contact Name – Kristy Dyche Expected Completion Date - 06/30/2024 If the U.S. Department of Education has questions regarding this plan, please call Kristy Dyche at 785-437-2254. Sincerely yours, Kristy Dyche Board Clerk Unified School District No. 321

FINDING 2023-003 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 failed, due to the lack of internal controls, to provide adequate oversight to ensure that the parameters that were entered into the student information software system were accurate. The School Corporation failed to maintain adequate documentation of the on-line and paper applications that were reviewed so that documentation was available for audit. The School Corporation failed, due to the lack of internal controls, to provide adequate oversight of the direct certification process to ensure that the Direct Certification Reports were generated and input accurately into the student information software system. Verifications of Free and Reduced Price Applications The School Corporation failed, due to the lack of internal controls, to provide adequate oversight to ensure that the verification process was properly performed. Contact Person Responsible for Corrective Action: Carla Gambill Contact Phone Number and Email Address: 812-847-6020 ext. 1004 cgambill@lssc.k12.in.us Views of Responsible Officials: We concur with the finding. INDIANA STATE BOARD OF ACCOUNTS 32 Description of Corrective Action Plan: Eligibility - Income guidelines will be entered by the Director of Food Services and reviewed by the Director of School Finance to ensure accuracy. Review by the Director of School Finance will be noted on the July monthly checklist completed by the Director of School Finance. Direct certification - The direct certification process will be completed monthly by the Director of Food Services and will be reviewed by the Director of School Finance. Review by the Director of School Finance will be noted on the monthly checklist completed by the Director of School Finance. Review of Applications - The Director of Food Services will compile and maintain a spreadsheet of all free and reduced applications received. The spreadsheet will include pertinent information from the application as well as information regarding what benefits were assigned to the student based on the application. The spreadsheet will be reviewed periodically by the Director of School Finance and that review will be documented on the spreadsheet. Verification - Verification will be completed by the Student Data Coordinator and a review of the verification documentation will be completed by the Director of Food Services evidenced by signature on the documentation. Anticipated Completion Date: This Corrective Action Plan will be put in effect March 2024.

FINDING 2023-009 Finding Subject: Child Nutrition Cluster – Internal Controls Summary of Finding: Eligibility determinations were made by the Cafeteria Secretary, and are now reviewed by the Food Service Director. However, this control was not in place for the majority of the audit period. Contact Person Responsible for Corrective Action: Nancy Schroeder Contact Phone Number and Email Address: 765-932-3901 schroedern@rushville.k12.in.us Views of Responsible Officials: We concur with the finding. Explanation and Reasons for Disagreement: N/A Description of Corrective Action Plan: Since the 2019 audit, the responsibility of the Free/Reduced lunch applications was shifted to the middle school cafeteria secretary, Connie Amos. Mrs. Amos reviews information in the application and designates if it meets the criteria for Free, Reduced, or Paid lunches. The Food Service Director, Nancy Schroeder will also review the applications and confirm the results calculated by Mrs. Amos. This control was brought to our attention late in the application process so only part of the applications were reviewed. Now 100% of all applications will be reviewed by two people. Anticipated Completion Date: April 2024

FINDING 2023-008 Finding Subject: Child Nutrition Cluster - Special Tests and Provisions - Verification of Free and Reduced Price Applications INDIANA STATE BOARD OF ACCOUNTS 48 Summary of Finding: One employee was responsible for performing the required verification of the free and reduced price applications. While the verification was reviewed by a second person, that control was not effective. All six of the required verified applications in the fiscal year 2022-23 were tested. Two of the six verified applications were calculated incorrectly resulting in improper eligibility status changes. Contact Person Responsible for Corrective Action: Nancy Schroeder Contact Phone Number and Email Address: 765-932-3901 schroedern@rushville.k12.in.us Views of Responsible Officials: We concur with the finding. Explanation and Reasons for Disagreement: N/A Description of Corrective Action Plan: The middle school cafeteria secretary, Connie Amos, will contact parents regarding verification of their free/reduced lunch application. This information will then be reviewed by the Food Service Director, Nancy Schroeder, to determine the information is accurate. Parents are always notified on any changes to the lunch status. Anticipated Completion Date: April 2024

FINDING 2023-007 Finding Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment 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 Procurement and Suspension and Debarment compliance requirement. Procurement The School Corporation did not complete or submit the fiscal year 2023 Procurement Plan as required to the Indiana Department of Education. Suspension and Debarment The School Corporation was a member of the East Central Educational Service Center (ECESC) during fiscal years 2021-2022 and 2022-2023. ECESC verified that vendors were not suspended or debarred when securing bids for food, dairy, and bread products on behalf of the member schools. However, for purchases of goods and services exceeding $25,000 handled by the School Corporation, 3 of the 5 vendors selected for testing were not verified for suspension and debarment to ensure vendors were not suspended or debarred from participation in federal programs. Contact Person Responsible for Corrective Action: Julie Cramer Contact Phone Number and Email Address: 765-932-4186 cramej@rushville.k12.in.us Views of Responsible Officials: We concur with the finding. Explanation and Reasons for Disagreement: N/A Description of Corrective Action Plan: Due to turnover in the Superintendent position and Food Service Director, position there was no access to SAM to verify vendor. This has been now been corrected and the Superintendent and Assistant Superintendent have access to SAM. They will verify for the Food Service Director any company will wish to deal with over $25,000. Future purchases will meet the school corporation’s procurement policy. All vendors in which expenditure exceed $25,000 will reviewed by the Food Service Director and either the Superintendent or Assistant Superintendent. Procurement – A 2023 procurement plan has been developed and will be sent to the Indiana Department of Education. Anticipated Completion Date: April 2024

Finding Number: 2023-001 Planned Corrective Action: In previous school years the Wadsworth City School District allowed a student to charge up to $10.00 before an alternative lunch was provided. At that time the Point of Sale (POS) system only allowed student accounts to go up to a negative $10.00. Recently the district changed this policy (due to donations from community members) to allow students to charge beyond the $10.00. However, instead of changing the $10.00 limit in POS a courtesy lunch option was created. This allowed the cashier to charge a courtesy lunch to the student. Later in the day the Food Service Supervisor would override the $10.00 limit and post all courtesy lunch charges to the student’s account. During the 2022-23 school year the Food Service Director was under the understanding that charged lunches could be reimbursed at the free lunch reimbursement rate. Therefore, the Food Service director was allocating all the courtesy lunches to free and the district was receiving the full reimbursement rate. Correction: 1) The district is aware that courtesy lunches are not eligible for free lunch rate reimbursement and the Food Service Supervisor is no longer reporting lunches in this manner beginning with the 2023-24 school year. 2) The courtesy button has been removed from the electronic cash register and the POS system now allows students to go beyond $10.00 for charging purposes. This eliminates the manual process that was being done each day and eliminates the possibility that paid or reduced lunch students are reported as free lunch students. Anticipated Completion Date: 1) The change for reporting courtesy lunches as free lunches occurred at the start of the 2023-24 school year. 2) The change removing the courtesy lunch button from the cash register and allowing students to charge more than $10.00 occurred on February 23, 2024 Responsible Contact Person: Douglas D. Beeman, Treasurer Kelly Gnap, Food Service Director

On behalf of Stuttgart School District, please accept this letter as a corrective action plan and response to the Material Weakness finding EDSD00423-001 regarding Child Nutrition and CEP claiming percentage weakness. The individuals responsible for this corrective action plan are: Jessica Millerd; Child Nutrition Director, Sharon Mayville; Comptroller, and Jeff McKinney; Superintendent

The corrective action plan was implemented and resolved on April 27, 2023 and the district will continue to utilize the corrective procedures for Child Nutrition CEP claims.

Corrective Action Plan: Child Nutrition Director, claim approver and Superintendent have been made aware of the percentage claim requirement and will review all monthly claims going forward to ensure the correct allowable percentage is claimed for all campuses designation as CEP. A spreadsheet with formulas has been created to verify the monthly claim includes the correct percentage calculations. The data is reviewed by both the Child Nutrition Director and the Comptroller prior to submitting the official monthly claim to the Child Nutrition Unit.

In addition, incorrect claims for the 2023 fiscal year were modified and corrected monthly forms were submitted to the Child Nutrition Unit before fiscal year 2023 end. Excess reimbursement amounts were also repaid to the Child Nutrition department during the same year.

FINDING 2023-003 Finding Subject: Child􀀃Nutrition􀀃Cluster􀀃􀍲􀀃Activities􀀃Allowed􀀃or􀀃Unallowed,􀀃Allowable􀀃Costs/Cost􀀃Principles,􀀃Special􀀃 Tests􀀃and􀀃Provisions􀀃􀍲􀀃School􀀃Food􀀃Service􀀃Accounts􀀃 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􀀃Activities􀀃Allowed􀀃or􀀃Unallowed,􀀃the􀀃Allowable􀀃Costs/Cost􀀃 Principles,􀀃and􀀃the􀀃Special􀀃Tests􀀃and􀀃Provisions􀀃􀍲􀀃School􀀃Food􀀃Service􀀃Accounts􀀃compliance􀀃requirements.􀀃 Contact Person Responsible for Corrective Action: Lela Simmons Contact Phone Number and Email Address: (219) 391- 4100, lesimmons@ecps.org Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: The􀀃Food􀀃Service􀀃director􀀃responsibilities􀀃is􀀃to􀀃overseeing􀀃all􀀃function􀀃of􀀃the􀀃Food􀀃Management􀀃Company.􀀃Food􀀃 Service􀀃Director􀀃will􀀃be􀀃required􀀃to􀀃draft􀀃internal􀀃controls􀀃and􀀃detail􀀃instruction􀀃for􀀃the􀀃school􀀃corporation􀀃to􀀃ensure􀀃 all􀀃documentation􀀃procedures􀀃match􀀃the􀀃FSMC􀀃invoice.􀀃The􀀃school􀀃corporation􀀃will􀀃not􀀃pay􀀃any􀀃unallowable􀀃cost􀀃by􀀃 state􀀃regulation􀀃and􀀃rules.􀀃All􀀃state􀀃reporting􀀃documents􀀃and􀀃invoice􀀃will􀀃continue􀀃to􀀃be􀀃reviewed􀀃and􀀃signed􀀃off􀀃by􀀃 the􀀃district􀀃CFO.􀀃A􀀃copy􀀃of􀀃all􀀃documents􀀃will􀀃be􀀃held􀀃in􀀃the􀀃food􀀃director􀀃office.􀀃 Anticipated Completion Date: We anticipate having the above corrective action plan in place by September 30, 2024.

Management's Response: We concur. View of Responsible Officials and Corrective Action Plan The District will implement a process to review, update, and verify the eligibility of students when the annual application or statement which furnishes family income and family size are received and compare the reported data to published household income eligibility guidelines. Furthermore, the District will update CALPADS with this information to ensure that the students' designation is accurately reflected in the system and matches the Free and Reduced meal application status. Implementation Date: December 2023

We agree with the auditor’s comments, and the following actions will be taken to ensure all records are maintained for reporting purposes: 1. Implement a point-of-sale system 2. Use the point-of-sale system to track all meals served by student eligibility 3. Reconcile records against claim forms on a monthly basis as reimbursement claims are submitted to the California Department of Education The above steps have been completed and implemented since January of 2023 and the District maintains that it will continue the actions above to follow Child and Adult Care Food Program, Child Nutrition Cluster guidelines.

FINDING 2023-006 Finding Subject: Child Nutrition Cluster – Procurement, Suspension, and Debarment Summary of Finding: Internal controls were not in place to ensure compliance with requirements related to the grant agreement, specifically regarding procurement, suspension, and debarment. Contact Person Responsible for Corrective Action: Scott Weltz, Amanda Brackett Contact Phone Number and Email Address: 765-654-5585, weltzs@frankfort.k12.in.us, bracketa@frankfort.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Internal controls will be established and followed to ensure compliance with requirements related to the grant agreement. The Treasurer will review procurement procedures related to vendors outside of the co-op, both related to the ‘small-purchase’ threshold as well as verifying if vendors are suspended and/or debarred. Anticipated Completion Date: Effective immediately and ongoing

FINDING 2023-005 Finding Subject: Child Nutrition Cluster – Reporting; Special Tests and Provisions, Eligibility Summary of Finding: Internal controls were not in place to ensure compliance with requirements related to the grant agreement, specifically related to reporting and eligibility. Contact Person Responsible for Corrective Action: Scott Weltz, Amanda Brackett Contact Phone Number and Email Address: 765-654-5585, weltzs@frankfort.k12.in.us, bracketa@frankfort.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Internal controls will be established and followed to ensure compliance with requirements related to the grant agreement. The Director shall submit the report after the Treasurer reviews and verifies the information in the report. Such measures will prevent future misstatements and provide the proper internal controls. Anticipated Completion Date: Effective immediately and ongoing

FINDING 2023-004 Finding Subject: Child Nutrition Cluster – Allowable Activities & Allowable Costs / Cost Principals Summary of Finding: Internal controls were not in place to ensure compliance with requirements related to the grant agreement, specifically the requirement: Allowable Activities & Allowable Costs / Cost Principals. Contact Person Responsible for Corrective Action: Scott Weltz, Amanda Brackett Contact Phone Number and Email Address: 765-654-5585, weltzs@frankfort.k12.in.us, bracketa@frankfort.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Internal controls will be established and followed to ensure compliance with requirements related to the grant agreement. The Deputy Treasurer or designee will provide payroll distribution reports to the Director for review of payroll claims against the grant. Anticipated Completion Date: Effective immediately and ongoing

2023-003. USBE Did Not Properly Report All Required Subawards in the Federal Reporting System State Agency: Utah State Board of Education Federal Agency: Department of Agriculture Employees have been trained, and we will continue to ensure they are trained in the reconciliation processes to mitigate the risk of this occurring again. Contact Person: Scott Jones, Deputy Superintendent of Operations, Scott.jones@schools.utah.gov Anticipated Completion Date: Completed, no further action necessary.

Corrective action plan: CNC – Food and Nutrition Department revised the internal Federal Funding Accountability and Transparency Act (FFATA) reporting procedures to ensure that all subaward/subaward amendment obligations over $30,000 are identified and submitted in Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) by the last day of the month following the month in which the subaward/subaward amendment obligation was made or the subcontract award/subcontract modification was made. TDA FND provided correspondence emails and incident reports documentation with screenshots for the FSRS technical issues to CLA:  CNC_NSLP grant: TDA FND informed CLA auditors that agency has been experiencing significant technical difficulties uploading the FFATA data into FSRS. During these attempts, the system shows the following error message: "Sub-awardee Awardee Address - Congressional District could not be validated/matched from the provided address and zip+4." Unfortunately, this occurred on numerous uploads (300-400) every time an attempt was made. As a disclaimer, a single error will prevent an entire report from being uploaded into the system. TDA FND staff has contacted the FSRS helpdesk many times to no avail, resulting in reports not being uploaded and causing TDA FND to be behind on the FFATA reporting.  FFVP grant: TDA allocates FFVP funds to CEs during two periods of operation. If CEs do not spend the funds, then TDA must either (1) reallocate or (2) let the funds lapse and return to USDA. Considering the nature of the grant allocation and USDA requirements of maximizing grant spending to benefit schools during this process, it might cause a discrepancy between what was reported on the FFATA report and what was adjusted after the fact. As of today, the system error continues to occur with TDA FND staff having little to no control over it. TDA would like to emphasize that the help desk process with FSRS is not expedient and would cause the loss of employee productivity if the burden to remedy the systems issues (beyond recording unsuccessful attempts) was delegated to the state. TDA FND staff will continue to prepare the reports and attempt to submit them as required. TDA FND Staff will document instances where the upload is unsuccessful. CDBG – TDA will ensure that all FFATA reports are submitted timely. For CDBG, program staff has implemented procedures to ensure that FFATA reports are prepared, reviewed by the Director of CDBG Programs, and submitted on a monthly basis. Implementation dates: CDBG: January 2024 CNC: March 1, 2024 Responsible persons: CDBG: Suzanne Barnard, Director for CDBG Programs CNC: Anwar Sophy, Administrator, TDA FND Business Management

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