Corrective Action Plans

The District will continue to enhance procedures and controls over the verification compliance requirement with adequate oversight and will identify and train additional individual(s) to ensure appropriate back-up is in place, that is also knowledgeable of its requirements. Responsible official: Cory Kaisler, Data Systems Coordinator – ckaisler@shawanoschools.org Anticipated Completion Date: June 30, 2024

The District will continue to enhance procedures and controls over the eligibility requirements with adequate oversight of both manual and electronic processes and will identify and train additional individual(s) to ensure appropriate back-up is in place, that is also knowledgeable of its requirements. Responsible official: Cory Kaisler, Data Systems Coordinator – ckaisler@shawanoschools.org Anticipated Completion Date: June 30, 2024

FINDING 2023-005 Finding Subject: Child Nutrition Cluster - Eligibility Summary of Finding: Material Weakness Condition and Context There was no evidence that the Direct Certifications were correctly and properly included in the software system, or that there was an oversight, review, or approval process over the Direct Certifications. Contact Person Responsible for Corrective Action: Lori Boyce Contact Phone Number and Email Address: 765-653-3148 lboyce@sputnam.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: The Food Service Director will have the Guidance Secretary check and initial that the Food Service Director has completed the Direct Certification correctly. Anticipated Completion Date: 2/2024

Finding 2023-002 – Child Nutrition Cluster – Activities Allowed or Unallowed, Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Eric Speicher Contact Phone Number: 574-598-2768 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The school corporation’s management will establish a documented, secondary review of all accounts payable claims to ensure the accuracy of the claims and will ensure underlying support or details of the claims will be included. Anticipated Completion Date: 2/22/2024

Finding 2023-003 – Child Nutrition Cluster – Special Tests and Provisions – Verification of Free and Reduced Price Applications Contact Person Responsible for Corrective Action: Kimberly Nieves Contact Phone Number: 219-508-0504 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: As an internal control, the Director of Business Affairs and Human Resources has reviewed the process for Verification of Free and Reduced Price Applications. We have now contracted with a Food Service Director through NIESC. They will perform the Verification of Free and Reduced Price Applications and the Director of Business Affairs & HR will review these documents for accuracy. Anticipated Completion Date: FY24 Verification of Free and Reduced Price Application Review Period

Finding 2023-002 – Child Nutrition Cluster – Reporting Contact Person Responsible for Corrective Action: Kimberly Nieves Contact Phone Number: 219-508-0504 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: As an internal control, the Food Service Manager or Director of Food Service will prepare the reimbursement claim and the Director of Business Affairs and HR or Treasurer will review and initial the claims. This will ensure the accuracy of the reimbursement claim. Anticipated Completion Date: This Corrective Action was put into place in September 2022 following our prior audit. The Claim that was not signed for this Audit was from October 2021.

Recommendation: Internal controls for accounting for nonprofit school food service funds should be implemented. A separate class in the accounting software for the program could be utilized. Action Taken: One City Schools developed a new financial class for School Nutrition, and all grant funds and expenditures will be classed to School Nutrition so these funds are clearly segregated from others. One City Schools implemented these new class designations as of January 1, 2024. Additionally, OCS added relevant tasks in our monthly accounting procedures to check for miscodes and ensure grant funds and expenditures are correctly coded.

Recommendation: One City Schools, Inc. should design and implement appropriate internal controls for retaining support for claims in accordance with federal requireents. Action Taken: One City Schools has developed a new process to document meal counts per month, attendance and enrollment numbers per month, submission of claims, and the signature of a designated second approver, the COO. As each claim is made, the associated backup documentation will be presented to the second approver for their review and signature. Once approved, the entire packet of information will be retained. This process was initiated in December 2023.OCS completed the second designated approver review retroactively for all claims in the months of July, September, October, and November 2023.

Recommendation: One City Schools, Inc. should design and implement appropriate internal controls for reviewing funding claims. Action Taken: One City Schools has developed a new process for submission where a second approver, the COO, reviews the claims for accuracy. This process started in December 2023, however OCS also completed this second approver review retroactively for all claims in July 2023, September 2023, October 2023, and November 2023.

Recommendation: Additional training should be provided to individuals responsible for the development of written policies and procedures in accordance with the Uniform Guidance. Action Taken: One City Schools is in the process of identifying a required training program for all staff members involved in the submission, review and/or approval of the schedule of expenditures of federal awards. This includes One City’s Executive Chef, Executive Director of K-8, COO and VP of Government Relations (who oversees compliance). Designated staff will take advantage of all DPI-provided training seminars and resources available, and we will track attendance of relevant staff members. This process will be in place by June, 2024.

Corrective Action Required by The Board - The School District was not in compliance with CFR section 210.14 which requires that the net cash resources in the food service fund to be below its three month average expenditures at year end. Recommendation Number Corrective Action Required by The Board - The responsible officials are in agreement with the calculation. COVID's financial impact on the food service fund and ultimately the food service reserves has created this inflated financial position. We will use these funds to continue to invest in our food service equipment as well as upgrade our food options and meal quality, within USDA regulations.

ACFR/AMR Finding # 2023-001, Finding (Condition) - The School District's Food Service Fund Net Cash Resources exceeded its three-months average expenditures., Recommendation - That the School District develop a plan to reduce the Food Service Fund's Net Cash Resources below its three-month average expenditures. Method of Implementation - The district is purchasing updated equipment throughout the various kitchens including cameras to monitor the health and safety practices of the line. We plan to review available menu options and expand quality and offerings. Person Responsible for Implementation - Director of Food Services & School Business Administrator. Implementation Date - 6/30/2024.

Finding 2023-004 – Child Nutrition Cluster – Eligibility Contact Person Responsible for Corrective Action: Felicia Wolfington/Sasha Robison Contact Phone Number: (812) 936-4474 x232 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The school corporation’s management will establish a documented, secondary review of eligibility determinations to ensure they meet the grant agreement and eligibility compliance requirements. Anticipated Completion Date: 08/31/2024

Finding 2023-003 – Child Nutrition Cluster – Reporting Contact Person Responsible for Corrective Action: Felicia Wolfington/Sasha Robison Contact Phone Number: (812) 936-4474 x232 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The school corporation’s management will establish a documented, secondary review of the reporting to ensure they are meeting the grant agreement and cash management compliance requirements. Anticipated Completion Date: 02/16/2024

Finding 2023-002 – Child Nutrition Cluster – Activities Allowed or Unallowed, Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Felicia Wolfington/Sasha Robison Contact Phone Number: (812) 936-4474 x232 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The school corporation’s management will establish a documented, secondary review of all accounts payable claims to ensure the accuracy of the claims, and will ensure underlying support or details of the claims will be included. Anticipated Completion Date: 02/16/2024

Audit Finding Reference: 2023-001 Management's View and Planned Corrective Action: Due to the extension of the federal funding for free school meals in the prior year, the District is aware of the fund balance greater than three (3) months of its average expenditures. We are looking to reserve the program fund balance to support the potential renovation that will take place over the summer of 2024 should Warrant Article 6 Renovate the Checkers Kitchen at Alvirne pass. This special warrant article is recommended by both the Hudson School Board and Budget Committee. This is allowable from the NH Department of Education's Office of Nutrition Programs and Services (ONPS). Name of Contact Person and Completion Date: Karen Atherton, Food Service Director Melissa Van Sickle, Finance Director Anticipated completion date: If supply issues are not a factor, December 31, 2024; otherwise, June 30, 2025.

The District will update the annual calculation to include a comparison of the base used for the indirect cost adjustment. Upon identification of the overcharge, the District posted a correcting entry to reduce the indirect costs of the program.

Unified School District #446 Independence, Kansas Corrective Action Plan January 17, 2024 Cognizant or Oversight Agency for Audit Unified School District #446 respectfully submits the following corrective action plan for the year ended June 30, 2023. Name and address of independent public accounting firm: Jarred, Gilmore & Phillips, PA, P.O. Box 779, 1815 S Santa Fe, Chanute, Kansas 66720. Audit period: Year ended June 30, 2023 The findings from the January 17, 2024 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Finding: 2023-001 – Verification Condition: During our testing of verification of income of households sampled during the year, we tested all households chosen for verification. During this testing, we noted households whose net income was used to calculate their eligibility instead of their gross income. Recommendation: Procedures should be implemented requiring that all income should be verified using proper documentation and verification results review by at least two or more qualified individuals. Action Taken: We are in agreement with the recommendation and the District has updated review procedures to ensure that free and reduced lunch verifications are reviewed by at least two people and that gross wages are used in the calculations. Anticipated Complete Date: November 8, 2023 Should the Oversight Agency for Audit have questions regarding this plan, please contact Gina Godinez, Director of Finance, at (620) 332-1800. Sincerely Unified School District #446 Unified School District #446

Corrective Action Plan Year Ended June 30, 2023 2023-01 Finding: Eligibility Status: Corrective action in progress Corrective Action: Training and additional oversight Person Responsible for Implementing: Lisa Clark, Director of Finance Implementation Date: January 2024 It was found that an application was identified as reduced status when it should have been free status. When the parent filled out the application in our online applications system, one of the students listed was not matching. This was due to the student not being in our Student Information System at that point. The secretary processed the application without the match. This resulted in the reduced status based on income and the number of members in the household. The student that did not match remained outstanding in the online application portal. Later when the unmatched student was entered into the Student Information System, matched and processed in the online application portal, the system did not update the original application to add the additional member. With the addition of the additional family member, the application resulted in a free status. The corrective action will include additional training for the staff members processing the applications. This will be done during January of 2024. We will implement a secondary check after each upload to catch any applications that may have unmatched students and make the corrections. There will be continued oversight and training. Lisa Clark Director of Finance

Finding Number: 2023‐001 Program Name/Assistance Listing Title: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 Contact Person: Vanessa Bonfim Anticipated Completion Date: March 6, 2024 Planned Corrective Action: • In order to ensure that correct claim numbers are submitted to AZ Department of Education, the Food Services Department will perform double monthly checks when claims are entered into ADEConnect website, before actual submission. • Claims are entered into ADEConnect by the Food Service Liaison and double check will occur at the same time by the food service supervisor. • Monthly scheduled time will be set once a month to process claims.

Federal Award Findigs and Questioned Costs - Finding 2023-002 The School District must verify eligibility of children in a sample of househould applications approved for free and reduced prices meal benefits for that school year. Verification was not performed for one of the School District's sub recipients. Adequate oversight of the verification process was not in place in order to ensure verification process occurred related to one of the School District's sub recipients. Corrective Action: The software that the District uses for the school lunch program randomly chooses applications in which to verify each year. Prior to the 2023-24 shcool year, the District's sub recipient, Holy Family, was not included in the District's school lunch software and was manually tracked. Beginning 9/6/23, Holy Family is now included in the District's Software and will be part of the random selection process that will be competed by 11/5/23 and each year's due date thereafter.

Finding Number: 2023-005 Finding Synopsis: During the audit, we determined that the District did not complete the 3% verification of applications procedures by the due date. Action Steps: The District will update the timelines used on the verification letters being sent to families so they are in line with what ISBE recommends so that verification testing can be completed by the deadline. Contact Person: Jeffrey Schubert, Chief School Business Official, 779-244-1000 Anticipated Completion Date: 6/30/2024

Finding Number: 2023-004 Finding Synopsis: During the audit, we determined that in a population of 4 error prone applications selected for verification, exceptions were noted on 2 of the applications selected for verification. One of the exceptions stemmed from verification documentation received determined the student should be changed from reduced lunch to paid lunch and this change was not made. The other exception also resulted from verification documentation received determined the student should be changed from free lunch to reduced lunch and this change was not made. Action Steps: The District will implement review procedures to ensure the free or reduced lunch status is properly calculated and updated during the application verification process. Contact Person: Jeffrey Schubert, Chief School Business Official, 779-244-1000 Anticipated Completion Date: 6/30/2024

Finding: 2023-002 – Eligibility U.S. Department of Agriculture – Child Nutrition Cluster (ALN 10.CNC); Passed through MDE; All project numbers. Auditor Description of Condition and Effect: In our sample of 40 applications from all students receiving free or reduced cost meals during the year, we noted one instance in which the student's eligibility determination was not supported by a properly completed application or direct certification. As a result of this condition, the District requested grant reimbursements without the proper support. Auditor Recommendation: We recommend that management ensures all documentation is retained and properly supports the determination for all free and reduced lunch applications and direct certification lists. Corrective Action: The Food Services Director will verify that the documentation supports the determination for all free and reduced lunch applications and direct certification lists. All documentation will be kept on file in the Food Services Director's Office for no less than the current fiscal year plus 3 years as required by the Michigan Department of Education. Responsible Person: Shelley Miller, Food Service Director and Daniel Pena, Business Manager Anticipated Completion Date: June 30, 2024

10.553, 10.555, 10.559 - Child Nutrition Cluster 2023-001 Net Cash Resources Corrective Action Plan: The School District will review cafeteria operations throughout 2023-24 and ensure any excess funds will be used to provide additional support to the cafeteria program. The School District expects to alleviate this finding by June 30, 2024.