Corrective Action Plans

FINDING 2022-004 Subject: Child Nutrition Cluster ? Activities Allowed or Unallowed, Allowable Costs/Cost Principles Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program, After School Snack Program, Summer Food Service Program for Children Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY2021, FY2022 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Findings: Material Weakness Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with the requirements related to the grant agreement and the Activities Allowed or Unallowed and Allowable Costs/Cost Principles compliance requirements. Context: The School Corporation had not designed or implemented adequate internal controls to ensure that payroll disbursements were only for food service-related services. Payroll disbursements comprise approximately 45% of the program costs charged to the Child Nutrition Cluster. One employee was responsible for processing payroll. Payroll reports were submitted to the School Board and Treasurer for review and approval; however, the reports only provided a total gross amount paid from each fund. The reports did not list the employees who were paid from the fund. In March 2021, the Treasurer implemented a review of the payroll distribution report, which is broken out by fund and individual employee. The lack of controls related to payroll disbursements was isolated to the 2020-21 year. Additionally, payroll disbursements for custodial employees were allocated to the Child Nutrition Cluster based on a percentage of the custodial employees? salaries. However, there were no time and effort logs or other documentation maintained to support the percentage of the custodial salaries allocated to the Child Nutrition Cluster. The custodial salaries make up approximately 3% of the total payroll disbursements charged to the Child Nutrition Cluster. This was an issue throughout the audit period. Views of Responsible Officials and Planned Corrective Actions: We concur with the finding. Description of Corrective Action Plan: The NJ-SP School Corporation will implement internal controls to ensure compliance with the activities allowed or unallowed and allowable costs/cost principles compliance requirements. This will consist of maintaining documentation to support that payroll disbursements are only for food service operating costs by having supporting timesheets and timecards or time and effort reports for all employees paid from the School lunch fund. These controls will be implemented by July 1, 2023. Responsible Party and Timeline for Completion: Dalton C. Tunis ? Corporation Business Manager/Treasurer Anticipated Completion Date: July 1, 2023

Finding 2022-004 Contact Person Responsible for Corrective Action: Rhonda Morgan, FSD Contact Phone Number: 765-240-2386 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Frontier School Corporation will have the Elementary and Jr/Sr High Kitchen Managers pull the monthly reports from eTrition for breakfast and lunch meals served for their respective schools. A blank Monthly Worksheet will be provided to each Kitchen Manager to be filled out using the data report from eTrition, the foodservice software. The reports and worksheets from each school will be given to the Food Service Director. The FSD will have independently prepared a complete report using data pulled from eTrition including both schools. The FSD will then compare the elementary Kitchen Manager?s report with the Master Report. The FSD will then compare the Jr/Sr High Kitchen Manager?s report with the Master Report. The Master Report will then be presented to each Kitchen Manager for their approval after checking to see that the data matches, initialing and dating the Master Report. The Food Service Director will then submit the Monthly Claims Report to CNPweb. The Corporation Treasurer will also have access to all data collected to ensure proper reportig. All data and internal checks will be filed in the Food Service Director?s office.. Anticipated Completion Date: The CAP will be in place by March 24, 2023 in preparation for the Monthly Claim of March 2023 to be the first month these internal controls will be implemented.

2022-004 Child Nutrition Cluster (10.55X) Condition and Cause: The District was required to verify one application for program eligibility and properly report results. During our review, the District did not properly update the School Food Authority Verification Collection Report for 2021-2022 based on the results of the verification sample. Criteria: By November 15th of each school year, the District must verify the current free and reduced price eligibility of households selected from a sample of applications that it has approved for free and reduced price meals. Results of this verification must be properly reported in the School Food Authority Verification Collection Report. Effect: Because of improper reporting, the District?s verification report did not accurately reflect the results of the verification sample. In addition, the District could be inaccurately providing free or reduced lunches to students. Auditor?s Recommendation: The District should review the federal requirements for completing verification of applications to ensure that future verifications completed by the District are complete and appropriate and properly report on the verification report. Grantee Response: A new process will be put in place for future income verifications to ensure the entire verification process will be completed accurately and timely. Contact Person: David Boland Anticipated Completion: On-going

FINDING 2022-002 Contact Person Responsible for Corrective Action: Cortney Parrish, Corporation Treasurer Contact Phone Number: 765-240-2346 Views of Responsible Official: We agree with the finding Description of Corrective Action Plan: As of fiscal year 2022, the School Corporation no longer pays teachers or aides from the School Lunch Fund, with the exception of one teacher being paid from the School Lunch Fund until December of 2022. As of January 1, 2023, only cafeteria employees are paid from the School Lunch Fund. Anticipated Completion Date: Completed

Finding 2022-004 ? Child Nutrition Cluster - Reporting Contact Person Responsible for Corrective Action: Melissa Dempsey Contact Phone Number: 812-546-2000 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The School Lunch reimbursement claims will be reviewed by a secondary individual prior to submission to IDOE and signed off on to document the review. Anticipated Completion Date: April 2023

Finding 2022-003 ? Child Nutrition Cluster - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Melissa Dempsey Contact Phone Number: 812-546-2000 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The School Corporation will establish a documented review of all Child Nutrition Cluster account payable claims before they are paid. Additionally, the School Corporation will transfer funds to replenish the school lunch fund. Anticipated Completion Date: June 2023

Department of Agriculture Finding 2022-001: Child Nutrition Cluster Resource Management Procedures Pass-through entity: Michigan Department of Education Assistance Listing Number: 10.553, 10.555, and 10.559 Award Numbers: COVID-19 211971, COVID-19 221971, COVID-19 211961, COVID-19 221961, COVID-19 210904, COVID-19 220904, and Entitlement Commodities Award Year End: June 30, 2022 Recommendation: The School District should continue its spend-down plan to ensure it reduces its Food Service Fund net cash resources below the maximum allowable amount. Action Taken: The School District has ordered equipment totaling approximately $390,000 that was not received by June 30, 2022. Once the equipment is received and paid for the School District will be in compliance with this requirement. Responsible Person and Anticipated Completion Date: Director of Finance, June 30, 2023 If the Michigan Department of Education has questions regarding this plan, please call Todd M. Hronek at (231) 788-7100.

The District will continue to file reimbursement for all meals served in the fiscal year.

Name of Contact Person Susan Pougher spougher@lysd.org 907-591-2411 Corrective Action Plan Finding 2022-001 Significant Deficiency in Internal Control Over Compliance - Reporting Corrective Action Plan The Director of Food Service gathers site meal count sheets, and separates by site. The Food Service Director will then perform a count for the month for each site. A second person will review the count sheets separated by site. The second person will prepare a count for the month for each site. The two separate monthly meal count sheets will be compared, and any count discrepancies will be identified and resolved. Once the two count sheets are in alignment, the period will be submitted to the state for reimbursement. Expected Completion Date June 30, 2023

Finding 2022-001: Recommendation: The School District should develop and complete a spend-down plan to ensure it reduces its Food Service Fund net cash resources below the maximum allowable amount. Action Taken: As of September 14, 2022, the School District has received items ordered prior to the fiscal year ended June 30, 2022 and will also develop and implement a spend-down plan to reduce the Food Service Fund net cash resources below the maximum allowable amount. Responsible Person and Anticipated Completion Date: The Superintendent will ensure the spend-down plan has been accomplished by June 30, 2023. If the Michigan Department of Education has questions regarding this plan, please call Paul Shoup at (231) 757-3733.

Reporting 2022-002 Significant Deficiency in Internal Control over Compliance Condition/context: During the audit of the School's, we noted that the School is maintaining excess reserve levels without an appropriately approved spending plan in place Auditors? Recommendation: Management should perform quarterly reviews of their reserve levels and modify their expenditure patterns to ensure reserves are maintained within approved limits. The required approvals should be obtained from the funder to expend excess funds. Management?s Response: The Organization had earmarked the reserve funds for the purchase of additional kitchen equipment associated with its new high school. Due to permit delays the opening of the high school was delayed by a year. Management anticipates that the excess funds will be spent during fiscal year 2023 and the Organization will be within the 90-day reserve level.

Reporting 2022-001 Significant Deficiency in Internal Control over Compliance Condition/context: During our audit of the School's major programs, we detected certain deficiencies in internal control over compliance. The School submitted vouchers for September 2021 and October 2021 late. The submission exceeded the required 60 days following the last day of the month covered by the claim. The September 2021 voucher could not be accessed and verified by auditors. Auditors? Recommendation: Management should maintain a checklist of all specific due dates associated with Uniform Guidance (?UG?) compliance, including credential renewals, voucher submissions, UG report due date, and other reporting requirements. Management?s Response: Management is aware of the reporting deadlines associated with voucher claims. Unfortunately, a staff member left the Organization and failed to file the annual renewal report, which resulted in the Organization being locked out of the vouchering system. The Organization immediately filed to renew but due to the time it took for the renewal process the September and October vouchers were filed beyond the reporting deadline. This has been rectified and procedures have been implemented whereby the Organization CFO reviews the renewal application to ensure timely filing.

Child Nutrition Cluster ? Segregation of Duties ? Grant Reporting Recommendation: We recommend that the District implement a review process over the reporting requirements related to the Child Nutrition Cluster Explanation of Disagreement with Audit Finding: There is no disagreement with this finding. Action Planned/Taken in Response to Finding: The District will implement a process by which the monthly grant reports are approved by a secondary position prior to submission. Name of the Contact Person Responsible for Corrective Action: Rod Huther, Business Manager Planned Completion Date for Corrective Action Plan: 12/15/2022

UNITED STATES DEPARTMENT OF AGRICULTURE Child Nutrition Cluster ? 10.553/10.555/10.559 Corrective Action Plan ? Noncompliance with Reporting Requirements Finding No.: 2022-003 Condition: The District has inadequate controls over reviewing and approving child nutrition monthly ?claims summary? forms. Plan: The administrative assistant will prepare the ?claims summary? forms by obtaining the number of meals served directly from the Manual ?Meal Count Edit Form?. The Superintendent will also review the "claims summary" forms and supporting documentation for accuracy prior to the electronic submissions. Corresponding documents will be manually signed and dated to indicate approval. Anticipated Date of Completion: January 1, 2023 Management Response: The District intends to implement the recommendations in FY 2023. Name of Contact Person: Jon Julius, District Superintendent (P): 217-932-2184

Views of responsible officials and planned corrective actions: The District will implement procedures in the 22-23 fiscal year to correct this compliance issue. District staff will follow procedures to verify that the District is not using vendors who are either suspended or debarred by the federal government, using the SAM.gov website. The following language has been communicated to CUSD staff and added to the District?s Business Users Guidelines Document. To process a requisition using Federal Monies (resource codes 3000-5999), staff shall perform the following procedures: Non-federal entities are subject to the non-procurement debarment and suspension regulations. These regulations restrict awards, sub-awards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities (2 CFR 200.213). To check if a vendor is disbarred or suspended: a. Go to the website at www.sam.gov (you do not need to register). b. Verify the status of the vendor by performing the following: ? Click on the search records icon on the top left. ? Use the "quick search" box and enter the vendor's name (leave remaining classifications blank) c. Click search at the bottom of the web page. d. Print a copy of the search results including if results were not found. e. If the vendor is not debarred, note on the requisition and / or contract if applicable, that the vendor has been checked in the SAM system and is not debarred. Include a copy of the printed page with the requisition. f. If a vendor search produces no results, print the page and attach as supporting documentation to the requisition. Note on the requisition and / or contract is applicable that the vendor has been checked in the SAM system. ? The District is prohibited from doing business with a vendor or individual that is debarred or suspended.

Child Nutrition Cluster Procurement Segregation of Duties Child Nutrition Cluster ? Assistance Listing No. 10.553, 10.555, 10.559 Recommendation: CLA recommends the District review its procurement process to ensure that there is adequate segregation of duties in regards to initiating, authorizing, reviewing for grant allowability and approving micro purchases, along with adding controls to ensure that the item purchased was received by the District. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We continue to look for ways to segregate duties and will improve on the review process for grants but with the current financial situation, additional staff cannot be added. Name(s) of the contact person(s) responsible for corrective action: Lisa Miller Planned completion date for corrective action plan: Ongoing

Child Nutrition Cluster Reporting Child Nutrition Cluster ? Assistance Listing No. 10.553, 10.555, 10.559 Recommendation: CLA recommends the District implement a review procedure over reimbursement requests where someone other than the preparer reviews the claim to ensure counts agree back to supporting documentation prior to the reimbursement request being filed with the granting agency. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We continue to look for ways to segregate duties and will implement a review procedure for reimbursement requests. Name(s) of the contact person(s) responsible for corrective action: Lisa Miller Planned completion date for corrective action plan: Ongoing

2022-003 Finding 1. Correcting Plan Monthly meal counts will be calculated in a spreadsheet and the monthly meal counts will be reviewed by someone other than preparer before it is submitted for reimbursement. 2. Explanation of Disagreement with the Audit Findings There is essentially no disagreement with the finding. 3. Official Responsible for Insuring CAP The Superintendent, Todd Selk, is responsible for carrying out the corrective action plan. 4. Planned Completion Date for CAP Immediately 5. Plan to Monitor Completion of CAP The superintendent will monitor completion of the CAP, with reports to the Board of Education, on an annual basis.

FINDING 2022-001 Contact Person Responsible for Corrective Action: Tammy Breedlove, Food Service Director Contact Phone Number: 765-569-4308 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The following internal control process has been added to the Business Office Handbook Effective February 1, 2023. The Food Service Director will follow all guidelines as contained in the Child Nutrition Procurement Plan and retain all documentation in compliance with Child Nutrition regulations and State Law. Furthermore, the Food Service Director will ensure that the following procedures are in place: 1. Each School year, the Food Service Director will prepare 5 binders- 1 for each Cafeteria, 1 for the Food Service Director, and 1 for the Business Manager. These binders will contain all approved bids and price changes/vendor correspondence. It is the responsibility of the Food Service Director & Cafeteria Site Managers to update these binders as price changes occur. Audit Evidence will be the contents in each binder for each school year. 2. When invoices for goods are received, the Food Service Director is responsible for ensuring that the invoices are reviewed and crosschecked to the original order/ approved pricing by the Cafeteria Site Manager. Furthermore, the Food Service Director will also review the invoices/pricing and sign off on the claim voucher sheet as approval for the Business Manager to pay the invoice. Audit Evidence: The Cafeteria Site Manager?s signature on the invoices & the Food Service Director?s signature on the claim voucher sheet. Anticipated Completion Date: Effective February 1, 2023

FINDING 2022-003 (Auditor Assigned Reference Number) Contact Person Responsible for Corrective Action: Todd VanDerWeele Contact Phone Number: 574.223.2159 Views of Responsible Official: We concur with the finding. We have adjusted our retention practices to keep all employee records according to statute. After employees listed on the personnel report for hiring or reclassification are approved, the HR Director will provide the approved personnel report, salary schedule or CBA salary schedule, and screen shot of the entries into the school?s financial software to the Business Manager to review and approve. Anticipated Completion Date: March 31, 2023

Finding ref number: 2022-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with federal procurement requirements. Name, address, and telephone of District contact person: Shelby Garrett 600 Huntington Avenue S. Castle Rock WA 98611 (360) 501-2940 Corrective action the auditee plans to take in response to the finding: Once the district was notified of the noncompliance regarding Child Nutrition federal procurement requirements, an interlocal agreement was immediately put in place with Longview School District for our small purchases of $150,000 or below. The agreement was approved by the Castle Rock School Board at the March 8, 2023 board meeting and approved by the Longview School District School Board on March 17, 2023. For our purchases above $150,000, the district requested to be a member of the Puget Sound Joint Purchasing Cooperative on March 6, 2023 and the membership was approved by the PSJPC Board on March 12, 2023. PSJPC provided the district with an interlocal agreement and the agreement was approved by the Castle Rock School Board at the March 22, 2023 board meeting. Anticipated date to complete the corrective action: 3/22/2023

FINDING 2022-002 Contact Person Responsible for Corrective Action: Andrew Nicodemus Contact Phone Number: 765-362-2342 Views of the Responsible Official: We agree with the finding. Description of Corrective Action Plan: Crawfordsville Community School Corporation plans to review all internal control procedures, including the control procedures over Program Income for the Child Nutrition Cluster. After this review, we will implement a system to ensure that compliance with the federal program income requirements is met. Anticipated Completion Date: We expect this Corrective Action to be implement by the end of April 2023 to allow for a full review of all internal control processes and procedures.

FINDING 2022-005 Contact Person Responsible for Corrective Action: Brenda Layne, Food Service Director Contact Phone Number: 765-289-7323 Views of Responsible Official: We concur with the findings Description Qf Corrective Action Plan: The prompts have been fixed on the Distribution Report, so it will include all Cafeteria employees. The F.S.D. will also initial each time card and Distribution Report. In the future ALL Claims will be initialed by the F.S.D. And as additional control the Superintendent will also initial all claims prior to the School Board meeting. Anticipated Completion Date: February 2023

2022-001 Corrective Action Plan-Food Service Fund Balance This finding is caused by the District?s Food Service Fund?s fund balance exceeding the USDA?s threshold of 3 months average expenditures. The District is fully aware of this situation and has a spend down plan in place to help alleviate the excess fund balance down to a reasonable level and anticipates the completion date for the corrective action plan to be before the end of the 2022-23 fiscal year. The persons responsible for the corrective action are Maryanne Charette, the food service director and Kim Bidwell, the business manager. The anticipated completion date of the corrective action plan is before the end of the 2023 fiscal year. The plan for monitoring adherence is the food service director and business manager will work together to assess where the fund balance is after all of the projects from the spend down plan are completed.

FINDING 2022-001 Information on the federal program: Subject: Child Nutrition Cluster ? Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Numbers: 10.553, 10.555 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: 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 requirement. Context: We noted that for one claim in a sample of four, the school lunch meal count was overclaimed for the month. We noted that in October 2020 the School Corporation had overclaimed lunches by 173 meals. We noted that the sponsor claim reimbursement form had been reviewed, however, the lack of an effective review allowed the error to go unnoticed. Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Going forward, we will have multiple people verifying the data before submission to reimbursement for claims to make sure all meals submitted meet the criteria and eligibility of the Child Nutrition Cluster. Responsible Party and Timeline for Completion: The Food Service Director and the Corporation Treasurer are the responsible parties for this corrective action. This has already been implemented.