Corrective Action Plans

Finding 2022-001 Lack of Internal Controls over Reporting Federal Agency: U.S. Department of Agriculture (passed through the State of Alaska) Federal Program: Child Nutrition Cluster Assistance Listing Number: 10.553/10.555/10.582 Award Year: 2022 Type of Finding Material weakness in internal control over compliance and noncompliance. Name of Contact Person: Dennis Niedermeyer Corrective Action Plan: The District will make changes in personnel to provide for the accurate entry and reporting of meal counts into the state?s reporting and claims system. The NSBSD will hired an experienced and qualified food service administrator who will review, monitor and verify compliance with accurate reporting of meal counts. Proposed Completion Date: October 28, 2022.

Finding: 2022-004 Name of Contact Person: Matt Farup, Superintendent Corrective Action: Management has contacted the Nebraska Department of Education subsequent to yearend to determine the status of the duplicate claim for reimbursement. The duplicate payment of $19,529 will be returned to the Nebraska Department of Education. We will review processes and implement procedures as necessary to address the issue in the future. Proposed Completion Date: Immediately

FINDING 2022-003 (Auditor Assigned Reference Number) Contact Person Responsible for Corrective Action: Philip McKelvey Contact Phone Number: 219-759-2531 Views of Responsible Official: we concur with the finding. Description of Corrective Action Plan: Reimbursement reports and claims will be signed off on between the submitter and the Food Service Consultant or Kitchen Manager(s) in order to ensure accuracy. Anticipated Completion Date: January 23, 2023.

FINDING:2022-004 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 of Corrective Action Plan: The Corporation Treasure and I discussed this matter and we will be more mindful in the future to get the reimbursement claims receipted in a timely manner. Anticipated Completion Date: February 2023

FINDING 2022-002 Contact Person Responsible for Corrective Action: Tamara L. Asdell Contact Phone Number: 812-726-4440 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan The food service director will prepare and sign the monthly reimbursement claim then have the claim reviewed by another cafeteria worker or the corporation treasurer who will then sign off on the claim to be submitted. Anticipated Completion Date. Immediately

CORRECTIVE ACTION PLAN FINDING 2022-003 Contact Person Responsible for Corrective Action: Heidi Sprunger Contact Phone Number: 260-589-3133 Views of Responsible Official: We concur with the finding. The district is working with Region 8 to obtain the corrective action plan that was submitted previously. Description of Corrective Action Plan: We will monitor this with Region 8 to ensure that the corrective action plan that was submitted is followed. Anticipated Completion Date: Immediately

CORRECTIVE ACTION PLAN FINDING 2022-002 Contact Person Responsible for Corrective Action: Heidi Sprunger Contact Phone Number: 260-589-3133 Views of Responsible Official: We concur with the finding the documentation supporting employees? time charged to the Child Nutrition Cluster program for custodians and grant specialist was not properly maintained. However, we disagree that they would be considered an indirect cost according to the definition of indirect cost: (Indirect costs are sometimes referred to as ?overhead costs? and more recently as ?facilities and administrative costs.?) Examples include executive oversight, accounting, grants management, legal expenses, utilities, technology support, and facility maintenance. Description of Corrective Action Plan: The district will evaluate and determine which employees will continue to be charged under the Child Nutrition Cluster Program. Only those employees spending direct physical time in the cafeteria doing work will continue to be under the Child Nutrition Cluster Program. Once identified those employees will be required to fill out a separate time sheet for hours worked under the Child Nutrition Cluster program. Those time sheets will then be approved by the Food Service Director. Once approved they will be submitted to Payroll Coordinator. Anticipated Completion Date: March 20, 2023

FINDING 2022-003 Subject: Child Nutrition Cluster ? Reporting Federal Agency: Department of Agriculture Federal Program: Summer Food Service Program for Children Assistance Listing Number: 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY2021, FY2022 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the reporting compliance requirement. Context: For all four monthly claims selected for testing, there was no formal evidence of the sponsor claim reimbursement summary being reviewed by someone independent of who prepared the sponsor claim reimbursement summary prior to submission. Views of Responsible Officials and Planned Corrective Actions: We concur with the finding. Description of Corrective Action Plan: Tamara Florio, Director of School Nutrition, will prepare and submit the claims after they have been signed and reviewed by Kendra Wright, Treasurer. Kendra Wright, Treasurer, will also compare claims with reimbursements and will sign prepared monthly reimbursement claim reports. Responsible Party and Timeline for Completion: Tamara Florio, Director of School Nutrition, and Kendra Wright, Treasurer ? these changes will be implemented effective immediately.

FINDING 2022-001 Contact Person Responsible for Corrective Action: Food Service Director Contact Phone Number: 574-598-8000 ext. 327 Views of Responsible Official: We concur with the finding Description of Corrective Action Plan: To meet the conditions of the grant agreement, Caston School Corporation will keep record of all vendors that are outside of our NIESC buying agreement. Vendors on this list will be identified as having an RFP on file or requiring an RFP to purchase. The director or the director's purchasing designee will consult the list before ordering from the vendor. Anticipated Completion Date: From this point forward, if Caston School Corporation must make a purchase outside of the vendors in our NIESC buying agreement, our food service director or the director's purchasing designee will check the record of outside vendors. This will ensure that we obtain an RFP before an order is placed with the vendor. List will be complied by 2-21-23 and vendors will be added as needed. Food Service Director Title 2/16/2023

FINDING 2022-005 Contact Person Responsible for Corrective Action: Camryn Fender, Director of Food Service Contact Phone Number: 812-279-3521 Views of Responsible Official: We concur with the audit finding. Description of Corrective Action Plan: The claims for reimbursement are first checked with the Food Management Company then sent to the NLCS Food Service Administrative Assistant. Once the Food Service Admin Assistant double checks the claims, it is sent to the Food Service Director for approval. North Lawrence Community Schools has a procurement plan in place as of March 2023. Anticipated Completion Date: North Lawrence Community Schools implemented this procedure in 2023.

FINDING 2022-004 Contact Person Responsible for Corrective Action: Robyn Muder, Director of Business Contact Phone Number: 812-279-3521 Views of Responsible Official: We concur with the audit finding. Description of Corrective Action Plan: Supporting documentation for all transfers out of the Food Service account are kept in a labeled folder. Anticipated Completion Date: North Lawrence Community Schools implemented this procedure in 2022.

FINDING 2022-003 Contact Person Responsible for Corrective Action: Robyn Muder, Director of Business Contact Phone Number: 812-279-3521 Views of Responsible Official: We concur with the audit finding. Description of Corrective Action Plan: Internal controls were updated in 2022. All supporting documentation is attached to vouchers for more efficient and effective business practices. The financial software was updated in January of 2023 to keep fringe benefit information retained. North Lawrence Community Schools has implemented a new procedure to pay mileage as a vendor payment instead of reimbursement through payroll to keep it separate from employees? gross earnings. North Lawrence Community Schools has implemented new practice to send all salary employees contracts which must be signed and kept in their personnel files. North Lawrence Community Schools has implemented new practices to prevent employees from being off of the board approved hourly pay schedule. North Lawrence Community Schools no longer utilizes paper timesheets. We now use an electronic time clock system. North Lawrence Community Schools is updating direct deposit information for all employees. Anticipated Completion Date: North Lawrence Community Schools implemented this procedure in 2023.

A plan to spend down the excess Food Service Fund balance was submitted and approved by the Michigan Department of Education Office of Health and Nutrition Services to be implemented during the FY 2023 school year by or before 6/30/2023. The Chief Operations Officer along with the Chief Financial Officer will work together to ensure these plans are implemented.

Auditors? Recommendation: The auditor recommends that the District implement controls for documenting and retaining information to indicate the District follows the requirements over 2 CFR section 200.430(i). Action Taken: The district will expand the internal controls over the timekeeping and payroll processes by requiring all employee pay applications for the Child Nutrition program be reviewed and approved by the Human Resources Department. A schedule of Pay Rates will be created and submitted to the Board of Education for formal approval, along with the other Salary Schedules approved with the annual budget. In addition, the district is moving to an electronic timekeeping system that will eliminate the use of paper timesheets that must be manually processed for payroll purposes. All Board approved pay rates will be programmed into the electronic timekeeping system so that the need for manual pay rate entry and gross pay calculations will be eliminated. Due Date for Completion: July 1, 2023 Responsible Party: Lisa Rhoades, Food Service Manager Lisa Robinson, Assistant Superintended for Talen Acquisition, and Laura Garcia, Chief Financial Officer

COUNTY OF DEL NORTE CORRECTIVE ACTION PLAN FOR THE YEAR ENDED JUNE 30, 2022 FROM: Clinton Schaad, Auditor-Controller SUBJECT: Response to Audit finding 2022 2022-001 Management Response The County agrees with the finding that the Probation Department was delayed in the billing for reimbursement as it relates to the National School Lunch Program. The County (Probation Department) is required to submit for reimbursement within 60 days following the last day of the month covered by the claim. Unfortunately due to staffing issues the Probation Department had to submit a late billing in June. This was the only billing that was past the 60 day required billing timeframe. Fortunately, this was the first and only time this has happened with this program. This delayed billing did not have any financial impact on the reimbursed amounts. The County Auditor-Controller has reached out to the Probation Department to discuss the cause of this delayed billing. If the Probation Department faces decreased staffing to the point they are delayed on program billings in the future the Auditor-Controller will assist as needed. Anticipated Completion date This corrective action plan has already been put in place. Responsible party Ultimately the County as an entity is responsible for all program activities but his particular program is 100% managed by the County Probation Department both fiscally and programmatically.

Tecumseh Public Schools respectfully submits the following corrective action plan for the year ended June 30, 2022. Auditor: Maner Costerisan 2425 E. Grand River Ave., Suite 1 Lansing, Michigan 48912 Audit Period: Year ended June 30, 2022 District contact person: Kelli Glenn, Director of Business Services The findings from the June 30, 2022 schedule of findings and responses are discussed below. The findings are numbered consistently with the number assigned in the schedule. Finding ? Federal Award Findings and Question Costs Finding 2022-001 ? Significant Deficiency Recommendation: The District should implement a budget, as well as the required corrective action plan, for the 2022-2023 school year that will adequately reduce the food service fund balance. Action to be taken: Management agrees with the finding and we are in the process of developing a spend down plan. We are looking at expanding food choices, expanding healthy food options, as well as needed upgrades to equipment.

In response to the late audit submission finding, the District is working with the auditors to ensure the 2023 financial statement audit is submitted on time.

2022-003 Child Nutrition Cluster ? Assistance Listing No. 10.553 and 10.555 Recommendation: We recommend that the School implement formally documented procedures and controls in relation to the required child nutrition cluster CLiCS reports, to ensure they are completed accurately going forward. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Operations Manager will verify that the numbers of meals served matches the number inputted into CLICS is accurate. Operations Manager with verify monthly by checking Infinite Campus against the meals served spreadsheet prior to submitting for reimbursement. Reimbursement claim has been corrected with MDE. Name(s) of the contact person(s) responsible for corrective action: Karen Conner Planned completion date for corrective action plan: 2/1/2023

For the 2021-22 school year, the District failed to correctly allocate expenditures to the CACFP accounts. In order to correct this action for the 2022-23 School Year, the Director of Fiscal Services will work with the Director of Child Nutrition to reconcile each program and complete the Cost Allocation Worksheet. The District utilizes a direct cost vending agreement, which will allocate costs in an allowable manner. The Director of Fiscal services will be responsible for making the transfer of expenditures from the NSLP accounts to the CACFP accounts. The Director of Child Nutrition will verify the transfers have been completed correctly befor the books are closed. Contacts: Kevin Olson, Lori Toms(Director of Fiscal Services), and Suzanne Stamp(Director of Child Nutrition).

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 four claims in a sample of four, the Food Services Director prepared the reimbursement claim without a secondary, documented review to ensure the accuracy of the reimbursement claim. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The School Corporation?s management will review and formulate procedures to ensure compliance with requirements related to the grant agreement and the reporting compliance requirement. Responsible Party and Timeline for Completion: The School Corporation?s management will ensure the Food Service Department implements a secondary document review to ensure accuracy prior to submitting the reimbursement claim. This action will begin immediately with the March of 2023 claim submission.

Name of Contact Person: Dr. Amy Jackson, Chief Financial Officer Recommendation: The District should monitor the Child Nutrition profit made and ensure all expenditures used to operate the program are properly charged to the program. Corrective Action: We will ensure that all eligible costs are charged to the program and modernize the equipment to reduce the accumulated carry-over. We have submitted a written plan to the Missouri Department of Elementary and Secondary Education outlining our plan to purchase supplies and equipment and the estimated completion time. Proposed Completion Date: Immediately

Recommendation: CLA recommended that the District implement a review process over the reporting requirements related to the Child Nutrition Cluster during the fiscal year. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management has begun reviewing food service claims prior to submission to DPI Name(s) of the contact person(s) responsible for corrective action: Cari Guden, Administrator Planned completion date for corrective action plan: June 30, 2022

Views of Responsible Officials, Corrective Action Plans, and Contact Information For the 2021-22 school year, the Food Services Division used federal waivers to support students and families by providing meals under multiple programs. Starting August 2021, COVID concerns resulted in the district discontinuing breakfast in the classroom. USDA waivers permitted the distribution of breakfast and supper meals to students as they left campus for consumption at home. As the school year progressed, the after-school supper program was reinstated for a small group of students at some schools, and this group of students was given a breakfast to take home. Additionally, we distributed weekend meals comprising of supper and snacks. Lastly, the district requested Food Services to serve a morning snack (at the District?s expense) for hungry students. The snacks were tracked manually for reimbursement from ESSER funds by the district. Each meal service required a different form to count meals and multiple sheets for the same meal period depending on how the meal bags were distributed (exit gate vs. classroom). The managers had many forms that had to be put together and summed up to come up with the reimbursable counts. Manually compiling and uploading the information is the reason for the variances. Each time there was a change in the operation, the Food Service team had to create a new training module for the change in operation, which created additional forms leading to the errors seen in the audit review. We want to state respectfully that our error rate for meal counts was 0.4% which, given the multiple food distribution channels to support students, is understandable. To address the audit findings, Food Services will review and modify our procedures and be stringent in monitoring our existing systems and procedures: 1. Food Services Division will add steps to our current meal claiming procedures to ensure accuracy of claims. a. Food Service Manager will utilize the Meal Count Consolidation Form for meal periods that have more than one meal count sheet. b. Food Service Manager will input meal counts into CMS based on information from the Consolidation Form. c. Food Service Manager will run a weekly Meal Counts Report generated from CMS. d. Food Service Manager will compare daily meal count documents to the five-day Meal Count Report for accuracy. e. Area Food Services Supervisors (AFSS) will randomly check meal counts entered in CMS and compare them with the numbers entered in daily meal count sheets. Each school will have a random review every 2-3 months, and where errors are found there will be additional follow up. 2. Food Services will follow the review steps as indicated in Corrective Action Response #1 and confirm the claim for accuracy prior to submission to CNIPS. a. Food Services Central Office Staff will provide a daily meal count report to all Supervisors for review to identify any inputting errors. b. Food Service Managers will review and adjust meal counts prior to the CNIPS claim submission, based on AFSS feedback. The target date for the implementation of the above corrective action plan is by the end of February 2023. Name: Manish Singh Title: Director, Food Services Division Telephone: (213) 241-2993

Purchase needed equipment

See Corrective Action Plan for chart/table