Corrective Action Plans

Finding Type: Material Weakness. Name of Contact Person: Eric Witges, Superintendent. Recommendation: We recommend that the District check the Excluded Parties List System or collect certifications from any vendor that the District expects to spend more than $25,000 for the year. Corrective Action: The District will begin making all significant vendors sign a certification. Proposed Completion Date: Immediately.

See corrective action plan.

State of Missouri Single Audit Corrective Action Plan Year Ended June 30, 2022 State Agency: Department of Social Services (DSS) ? Family Support Division (FSD) Audit Finding Number: 2022-005 ? Pandemic Electronic Benefit Transfer Food Benefits Name of the contact person responsible for corrective action: Elizabeth Roberts-Smith Anticipated completion date for corrective action: Completed Recommendation: The DSS through the FSD strengthen internal controls to ensure P-EBT program benefit issuances are in accordance with the state plan, and review and correct the overpayments for the children identified in this finding. DSS Response: The DSS agrees with this finding. The DSS agrees that the two children identified in the report were incorrectly issued benefits. Recognizing the complexity for families seeking to appropriately access the benefit, the process by which school children are determined eligible and issued P-EBT benefits was modified in the state plan submitted by the State of Missouri to the Food and Nutrition Service (FNS) for the 2021-2022 school year. The P-EBT state plan for the 2021-2022 school year was approved by FNS on June 6, 2022. Eligibility for P-EBT is now determined at the individual child level based on COVID-related absences and qualification for federal free and reduced lunch benefits. For the 2021-2022 school year, local education authorities (LEA?s) submit lists of students determined eligible to the Missouri Department of Elementary and Secondary Education (DESE). DESE then submits the approved eligibility file to DSS with the name of each eligible child and the amount of benefit to be issued on a P-EBT card. DSS then issues the benefit. Corrective Action is as follows: DSS has reviewed the overpayments and referred the children identified in this finding to the Missouri Program Integrity Unit (PIU) for claims processing, if the funds can be recovered. This is outlined in the FNS approved Missouri P-EBT state plan.

See Corrective Action Plan for chart/table

Response and Corrective Action Plan: The District will require the food service software to be used for verification data and selection of applications. The District will require documented supervisory approval of verification conclusions and reports submitted to the state of Illinois.

Pleasantdale School District 107 Corrective Action Plan for Current Year Audit Findings Year Ending June 30, 2022 Corrective Action Plan Finding No: 2022-001 Condition: For the February 2022 claim reimbursement, the amount of reimbursement received did not agree to the underlying supporting documentation. The District?s February claim in the amount of $30,010 for the Elementary School was rejected as it was submitted with an error and further rejected by ISBE. Plan: The District filed a one-time extension with Illinois State Board of Education in order to capture funds for the February claim for the Elementary School. Anticipated Date of Completion: November 7, 2022 Name of Contact Person: Griffin Sonntag, Business Manager/CSBO (708) 784-2172

FINDING 2022-003 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, Summer Food Service Program for Children Assistance Listing Number: 10.553, 10.555, 10.559 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Material Weakness Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the Child Nutrition Program and Procurement and Suspension and Debarment compliance requirements for purchases made outside of the purchasing cooperative. Context: During the audit period, the School Corporation had purchases between $10,000 and $150,000 from two vendors which fall under the small purchase method for federal and state procurement regulations and were charged to Fund 0800 ? School Lunch Fund. For one vendor selected for testing, documentation was not presented to verify the School Corporation had performed checks to assure the vendor was not suspended or debarred prior to entering into the transaction in order to satisfy the suspended and debarment requirements. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Superintendent and Business Manager will modify the procedures for Suspension & Debarment for all bidders related to any contract to be funded under the Federal Grants within the System For Award Management (SAM). The Business Manager will keep a log in the grant file to certify compliance of vendors. The Business Manager will have the Superintendent review this log, along with presenting it to the School Board annually for their review. Responsible Party and Timeline for Completion: Amy Milner, Business Manager. Timeline for Completion: April 14, 2023.

FINDING 2022-002 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, 10.559 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 two claims in a sample of four, the meal counts were over/under claimed for the month. We noted that in October 2020 the School Corporation had overclaimed lunches by four meals and breakfast by one meal and in April 2022, the School Corporation had overclaimed breakfast by 358 meals and underclaimed lunches by 182 meals. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We had changed software from Comalex to Mosaic during the audit period. We quickly found that Mosaic did not have the capabilities, processes, or correct reporting that Comalex had. Heartland Corp. owns both software products, we were insured that Mosaic was a far superiod software ? we found the opposite within 4 months we switched back to Comales. Processes and reports are more clearly defined and ?cleaner accounting?. Responsible Party and Timeline for Completion: Amy Milner, Business Manager. Corrective action has already been in place for several months.

Type of Finding: Suspension/Debarment - Significant Deficiency in Internal Control over Compliance Condition: The District did not document the verification that vendors with expenditures expected to equal or exceed $25,000 were not suspended or debarred prior to entering into the transaction was performed. Planned completion date for corrective action plan: June 30, 2023 Corrective Action Plan: The District will review its current procedures for ensuring the verification that vendors are not suspended or debarred is performed prior to entering into the transaction. Name of the contact person responsible for corrective action: Angela Terry, Executive Director of Business Services

Corrective Action Plan Godfrey-Lee Public Schools was recently notified by our financial auditors, Vredeveld Haefner LLC, of a failure in compliance regarding the United States Department of Agriculture regulations, 7 CFR Part210.9 (b)(2). Due to our district ending the 2021-22 fiscal year with an ending food service fund balance which exceeds three months? worth of operating expenses, referenced in the audit report as 2022-001, the district?s stakeholders have met in order to resolve this matter going forth through the following corrective action plan. School Districts Comments: As a district, key stakeholders have been brought up to speed currently due to the non-compliance once the district was made aware of the findings post-audit. These key stakeholders consist of our Food Service Director (Monica Collier), Director of Operations (Scott Bergman) and Finance Director (Marcus Bradstreet). As a team and in review of our expenditures, it was noted that although the district had numerous food service purchases passed by our board of education in the 21/22 school year, the district was granted more federal and state awards than anticipated due to the COVID-19 pandemic. According to our Director of Operations, the unrestricted awards received by the district did not align with district purchasing priorities at the time during the fiscal year. In result, the revenues received increased the fund balance by almost $250,000 that was not included in the Corrective Action Plan from fiscal year 2021/22. The district fully anticipates spending down the prior year awards by purchasing a large amount of food service related equipment and lunch tables related to the new construction project at Lee Middle and High School during fiscal year 22/23. The current budgeted fund balance change as of October 2022 is ($380,000) which will align the district?s Food Service Fund Balance spending goals and will also result in being compliant with our fund balance per MDE?s guidelines. The district will continue to review and monitor our anticipated fund balance as we progress through the current school year and into the future. Implementation/Monitoring : The district will continue to work within the purchasing budget to assure that the planned decrease of fund balance will stay on track through the 22/23 school year. The district has pre-allocated over $100,000 to commit to the Lee Construction Project that is currently underway. In addition, the district will report out to our board of education on where we stand at least twice this current fiscal year. The district and the noted members above will continue to be in contact on an as needed basis to make sure we are tracking appropriately, and make adjustments as we see fit. Some adjustments that will continue to be assessed include food service quality, capital assets, and staffing to make sure we meet the needs of our student body. Responsible staff: ? Scott Bergman ? Director of Operations ? sbergman@godfrey-lee.org ? Monica Collier ? Food Service Director ? mcollier@godfrey-lee.org ? Marcus Bradstreet - Finance Director ? mbradstreet@godfrey-lee.org

CORRECTIVE ACTION PLAN OF CURRENT AUDIT FINDINGS June 30, 2022 FINDING 2022-002 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: Significant Deficiency 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 Food Services Director prepared the sponsor claim reimbursement summary without a secondary, documented review to ensure the accuracy of the sponsor claim reimbursement summary. Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We will verify that each claim has been reviewed by a secondary person for accuracy. Responsible Party and Timeline for Completion: Loretta Kimbrell, Immediately

Business Administrator/Board Secretary or designee shall monitor the cafeteria monthly reports of revenues vs. expenditures to ensure there is no excess of net cash resources in the Food Service Fund.

Corrective Action: Foodbank agrees with the finding and has implemented a process to properly and accurately account for incoming USDA Foods. In March 2021, Foodbank approved the purchase of software that was designed specifically for food banks to help them account for food receipts and distributions, as well as the physical inventory accounting required for food banks. Changes in personnel delayed the full implementation of the software, which is expected to be completed by February 28, 2023. Name of Contact Person: Jeanne Cooper, President Proposed Completion Date: February 28, 2023

2022-001. Internal Control Over Compliance United States Department of Education, passed-through New York State Department of Education: Special Education Cluster Special Education Grants to States ALN: 84.027A Special Education Grants to States: IDEA 611 ARP Allocations ALN: 84.027X Special Education Preschool Grants ALN: 84.173A Special Education Preschool Grants: IDEA 619 ARP Allocations ALN: 84.173X Education Stabilization Fund (ESF) COVID-19: Governor?s Emergency Education Relief (GEER) Fund ALN: 84.425C COVID-19: Elementary and Secondary School Emergency Relief (ESSER) Fund ALN: 84.425D COVID-19: American Rescue Plan ? Elementary and Secondary School Emergency Relief (ARP ESSER) Fund ALN: 84.425U Condition: The District has not updated its existing policies and written procedures to conform to Uniform Guidance requirements. Planned Corrective Action: The District will update its existing policies and written procedures to conform to Uniform Guidance requirements. Responsible Contact Person: Dr. Rodney Asse - Assistant Superintendent for Business Riverhead Central School District 814 Harrison Avenue - Riverhead, New York, 11901 Anticipated Completion Date: The District adopted a Federal Funds Procedural Manual on January 24, 2023.

Response and Corrective Action Plan: The District will update the annual calculation to include a comparison of the base used for the indirect cost adjustment.

THE ORGANIZATION WILL MAINTAIN AND DOWNLOAD THE EXCLUSIONS EXTRACT DATA PACKAGE FROM SAM.GOV WEBSITE VERIFYING THAT VENDORS PAID OVER $25,000 ON A FEDERAL GRANT WERE NOT INCLUDED IN THE PACKAGE. WE WERE NOT ABLE TO COMPLETE THE CORRECTIVE ACTION PRIOR TO JUNE 30, 2023, AS THIS FINDING WAS JUST BROUGHT TO OUR ATTENTION. ANTICIPATED CORRECTIVE ACTION PLAN COMPLETION DATE: JUNE 30, 2024. FOR ADDITIONAL INFORMATION REGARDING THIS FINDING PLEASE CONTACT ROSANA MATEO.

FINDING 2022-004 Subject: Child Nutrition Cluster ? Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children Assistance Listing Number: 10.533, 10.555, 10.559 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Material Weakness Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the Child Nutrition Program and Procurement and Suspension and Debarment compliance requirements. Context: The School Corporation utilizes a purchasing cooperative to procure its key vendors for food service costs, however in some cases the School Corporation will handle their own additional procurements outside of the purchasing cooperative. During the audit period, there were three vendors for which the School made purchases between $10,000 and $150,000, which fell under the small purchase method for federal and state procurement regulations. For the one vendor selected for testing, documentation was not presented to verify methods or rationale used to satisfy the procurement requirements, which require three quotes to be obtained prior to entering into a transaction. Additionally, the School Corporation was not able to provide verification that the vendor is not suspended or debarred. Description of Corrective Action Plan: The treasurer and food service director will work together to check suspension and debarment on any vendor receiving school funds in the amount of $25,000 and over. This information will be reviewed and checked at the beginning of each school year and as needed with new vendors. Responsible Party and Timeline for Completion: Jennifer Blakley, Treasurer and Jenny Dunning, Food Service Director ? this information was reviewed and printed from the SAM government website on 3/21/23 and will be kept by the food service director. This will be completed at the beginning of each school year and potential new vendors will be checked prior to becoming active.

FINDING 2022-003 Subject: Child Nutrition Cluster ? Reporting Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch 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: 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: We noted that for one claim in a sample of four, 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. Description of Corrective Action Plan: The food service director will have the treasurer, deputy treasurer, or an administrator review and sign off on the sponsor claim reimbursement summary prior to submission. Responsible Party and Timeline for Completion: Jenny Dunning, Food Service Director ? this will be implemented immediately following the audit in March 2023.

FINDING 2022-003 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, Summer Food Service Program, Fresh Fruits & Vegetables Program Assistance Listing Numbers: 10.553, 10.555, 10.559, 10.582 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Allowable Costs/Cost Principles Audit Finding: Significant Deficiency Condition: 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 Allowable Costs/Cost Principles compliance requirements. Context: During testing of 10 payroll disbursements for allowable costs/cost principles, we noted there was one instance where the timecard for the Food Services employee displayed 79 total hours of normal pay and one hour of overtime for the two-week period. We reviewed the payroll distribution report for this time period and note that the employee was paid for 69.5 hours of normal pay and 10.5 hours of overtime. Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We will verify that the number of hours and pay rate per the payroll register agrees to the hours worked by the employee per their reviewed time sheet and their respective rate of pay. Responsible Party and Timeline for Completion: April 01, 2023

FINDING 2022-002 Information on the federal program: Subject: Child Nutrition Cluster Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program, Summer Food Service Program, Fresh Fruits & Vegetables Program Assistance Listing Numbers: 10.553, 10.555, 10.559, 10.582 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 meal counts were overclaimed for the month. We noted that in October 2020, the School Corporation had overclaimed lunches by 823 meals and breakfast by 512 meals, in April 2021, had overclaimed lunches by 210 meals and breakfast by 58 meals, in October 2021, had overclaimed lunches by 90 meals and breakfast by 632 meals, and in April 2022, had overclaimed breakfast by 984 meals and fresh fruits and vegetables by 114. Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We will verify that each claim has been reviewed by a secondary person for accuracy and that the claim agrees to underlying detail for meals served. Responsible Party and Timeline for Completion: April 01, 2023

Finding 2022-001 ? Child Nutrition Cluster -Activities Allowed or Unallowed, Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Mr. Patrick Culp, Superintendent Contact Phone Number: 219-279-2418 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Tri-County School Corporation will establish a documented review of all Child Nutrition Cluster account payable claims before they are paid. Anticipated Completion Date: March 29, 2023

The District will evaluate all aspects and needs of the food service program including personnel, equipment such as stoves, freezers, etc. and determine the best and legally proper use of the excess funds.

We have been and are budgeting to spend more money in 2023 than we have collected or will collect in revenues. We are anticipating a deficit in 2023 for the Child Nutrition Program. This will cause our Net Cash Resources to decrease.

The District is aware of this deficiency and continues to take steps to ensure safeguarding of relevant compliance documentation with respect to federal awards. The District feels the finding for this year is an anomaly and does not expect this condition to continue in the future.

Finding/Recommendation Number - 1; Finding - Net Food Service cash resources did exceed three months average expenditures; Corrective Action - Reduce Net Food Service cash resources to a level that does not exceed three months average expenditures; Method of Implementation - The district will purchase various kitchen and serving area equipment, make upgrades or repairs to existing equipment and serving stations, make improvements to student dining areas; Individual Responsible for Implementation - Business Administrator and/or designee; Completion Date of Implementation - June 30, 2023 and ongoing.