Corrective Action Plans

CORRECTIVE ACTION PLAN Walkerville Public Schools is in agreement with the finding identified and respectfully submits the following Corrective Action Plan for the year ended June 30, 2022. 2022-001 Excess Food Service Fund Balance The food service fund balance ended June 30, 2022 with an excess allowable fund balance. This occurred due to delays in the global supply chain which did not allow us to complete our cafeteria and kitchen remodels as planned. The district's responsible parties include the Food Service Supervisor (Sheri Boes), the Superintendent (Dr. Thomas Langdon) and the Business Manager (Sandra Oomen). All of these individuals have been made aware of the issue and discussed the possibilities to reduce the fund balance for the 2022-2023 school year. The focus of the District to reduce the fund balance will be to: ? Complete the remodel of the kitchen and cafeteria area ? Continue to purchase supplies, equipment, and services that add value to our food service program Implementation and Monitoring: The district will be implementing the purchase of these items throughout the 2022-2023 school year, with all purchases being received no later than June 30, 2023. The Business Manager will monitor the process to determine if additional fund balance will need to be spent throughout the fiscal year to comply with current regulations. The Business Manager will continue dialogue with the Food Service Supervisor and Superintendent throughout the year to keep all parties current on the fund balance status and will update the plan on spending fund balance if needed. If the Michigan Department of Education has any questions regarding this plan, please contact Sandra Oomen at 231-873-4850 ext. 3323 or soomen@walkerville.kl2.mi.us.

2022-001 Child Nutrition Cluster ? Assistance Listing No. 10.553 & 10.555 Recommendation: Recommendation: We recommend the School review its procedures to ensure it retains documentation sufficient to detail the history of all procurements in accordance with the Uniform Guidance. We also recommend the School review its procedures over procurement controls to ensure all controls are also sufficiently documented with records that include, but are not necessarily limited to, the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Review policies and procedures to ensure compliance with Uniform Guidance and MN Statute regarding contract and bid laws. Institute a schedule of periodic review of existing contracts to determine if contract costs are still competitive. We will ensure all award documentation is retained for five years or until the contract is reawarded. Name(s) of the contact person(s) responsible for corrective action: Lynn Peterson, CEO Planned completion date for corrective action plan: September 1, 2023

FINDING 2022-008: Audit Report Deadline Response: The district had difficulty finding an auditor who would be available to contract with us for the 2022-23 school year. Since our last auditor was no longer in business, we had to share significant documentation with our new auditor. Additionally, there was a change in personnel with the hiring of a new Business Manager. Some of the requested information and files were not immediately available to our new Business Manager. We currently have an auditor under contract and will have all requested documentation to them in a timely manner to meet deadlines.

The corrective action for Findings 2022-001 and 2022-002: The District will review current needs for equipment and other direct food service costs. A Corrective Action Plan will be developed to reduce excess cash balances in the Child Nutrition Program.

Responsible Official?s Response: Rochester Prep is implementing procedures to ensure accurate and timely submission of federal nutrition claims. Specifically: To ensure claims for reimbursement are accurately consolidated, the Charter School will evaluate their point of service accountability system and implement appropriate changes. The Charter School will also conduct edit checks to ensure accountability. Effective July 20, 2022, the school implemented a Meal Counting and Claiming Implementation Plan with the purpose of submitting accurate meal claims to the state and federal child nutrition programs. This implementation plan seeks to eliminate discrepancies between meal counting at the homeroom level, reporting at the school level, and claiming at the state and federal levels.

Contact Person ? Mark Lundin, Superintendent. Corrective Action Plan ? The District will review polices and procedures for submitting meal counts for reimbursement. Completion Date ? September 1, 2022.

Finding #2022-001 - Segregation of Duties (Prior Year Finding #2021-001) Condition: Proper segregation of duties is an important aspect of any control system. Management is responsible for the design, installation and maintenance of an appropriate system of internal control. The limited size of the District?s office staff prevents the ideal segregation of functions. The following duties lack adequate segregation of duties: The District uses e-signatures to approve purchase orders. Two individuals have access to the e-signatures and have the ability to create new vendors, enter invoices, print checks, record journal entries and record activity on the general ledger. Both individuals also have access to the payroll system. The person reviewing free and reduced food service eligibility can also enter information into the system to determine eligibility. Effect: Errors or intentional fraud could occur and not be detected timely by other employees in the normal course of their responsibilities as a result of the lack of segregation of duties. Cause: Limited number of personnel. Criteria: Segregation of duties is an aspect of internal control intended to prevent or decrease opportunities of intentional and unintentional errors and fraud. Duties and responsibilities are properly segregated if no single individual either has control over all phases of a transaction or has the ability to both make and conceal an error, whether such error is intentional or unintentional. Recommendation: The Board of Education and the Superintendent should continue to monitor the transactions and the financial records of the District. We also encourage the District to continue to identify cost effective opportunities to improve the design of the internal control structure. Response: We agree with this finding but do not believe it is cost effective to increase the office staff in an attempt to bring about a more effective segregation of duties. The Superintendent approves purchase orders and the Board of Education approves monthly accounts payable checks, and one of the school secretaries or the board treasurer reviews the bank reconciliations. The Board of Education and Superintendent will continue to monitor transactions of the District. Finding #2022-001 - Segregation of Contact Person: Heather Droessler Anticipated Completion: Not applicable

Identifying Number: 2022-002 Finding: In our sample of ten schools, Kansas City Public Schools (the District) obtained the requisite two food safety inspections at each school during the school year; however the food safety inspection reports identified critical violations at four schools, which were not corrected by a specified date. The District did not comply with food storage, preparation, and service standards established by the KCMO Health Department. Corrective Actions Taken or Planned: The Child Nutrition Services Department and the Facilities Departments will perform training with staff regarding the Health Department requires to address violations. Procedures will be updated to reflect the responsibilities with CNS staff to report violations, monitor work order progress and escalated resolution to meet Health Department deadlines. The CNS Director will contact the Health Department to provide documentation the violation has been corrected. The corrective action plan has been implemented. The contact person responsible for the corrective action plan is Erin Thompson, Interim Chief Finance and Operations Officer.

Purchase Needed Equipment

Finding ref number: 2022-002 Finding caption: The District did not have adequate internal controls to ensure compliance with federal Title I requirements for allocating funds to school buildings. Name, address, and telephone of District contact person: Gabriela Chacon, 411 E Saddle Mountain Dr. Mattawa, WA 99349 Tel: (509) 932-4565 Ext: 3031 Corrective action the auditee plans to take in response to the finding: (If the auditee does not concur with the finding, the auditee must list the reasons for disagreement). The Wahluke School District concurs with this finding. The following corrective actions will be taken: ? The Title I Program Director will work closely with the Grants Manager and Director of Finance to ensure that the annual application is completed correctly, including the allocations to school buildings. ? An action plan was submitted to OSPI which includes initial planning with the District Office team prior to the beginning of the school year, as well as monthly meetings with the Title I Program Director to ensure ranking and allocations are maintained. ? The district now has a Grants Manager that is working closely with the Title I Program Director to ensure that the buildings are within ranking order. Anticipated date to complete the corrective action: 08/31/2023

CORRECTIVE ACTION PLAN JUNE 30, 2022 Finding 2022-001: Material Noncompliance Finding Condition: As of June 30, 2022, the District?s fund balance exceeded three months? average of operating expenses. Corrective Steps Taken: The District has ordered equipment that costs approximately $237,800, but due to supply chain issues, the equipment is not available yet. Corrective Steps to be Taken: The business manager has created and submitted a spend down plan in a timely manner and has been approved by the Michigan Department of Education. The spend down plan will alleviate the excess fund balance and it is anticipated the completion date for the corrective action plan will be before the end of the 2022-2023 fiscal year. Monitoring: The business manager, along with the superintendent, will work together to assess where the fund balance is after all the projects from the spend down plan are completed. Reasons Corrective Action Plan Note Necessary: None Name of Responsible Person for Further Information: Cheri Bush, Business Manager Questioned Costs Related to this Finding: None

Corrective Action Plan: The Agency of Education?s new Child Nutrition grants management system, Harvest, now has the reports to back up the Federal FNS-10's built-in. In addition, Harvest now also retains a copy of each report created along with the backup for each report. Position Responsible for Implementation of Corrective Action Name: Sean Cousino Position: Deputy CFO Email: sean.couisno@vermont.gov Phone Number: 802 595-3693 Date of Implementation of Corrective Action: April 1, 2023

Corrective Action Plan: The AOE CNP team will be implementing a new procedure starting 3/1/23, which adds an additional internal control (quarterly review by a Grants Program Manager) and outlines specific steps that the Grants Management Specialist and Grants Program Manager will take in the event that there is a discrepancy. Position Responsible for Implementation of Corrective Action Name: Conor Floyd Position: Grant Programs Manager, Child Nutrition Programs Email: conor.floyd@vermont.gov Phone Number: 802-828-0310 Date of Implementation of Corrective Action: 3/1/23

Corrective Action Plan: To address the accuracy and timeliness of our entries into the FFATA system, we will use the USASPENDING.GOV website to assist us in reconciling what has been entered into the FFATA system. This will allow us to ensure that our grant ledgers agree with what is entered into FFATA. This will be a reconciliation completed at least quarterly (following SOV fiscal year quarters) and will be completed by the Deputy CFO or position assigned by the Deputy CFO. We will also implement a process that will have all the steps necessary for a grant award or an amendment to ensure it is posted properly within our internal files and the external systems. This will ensure that new awards and amendments get routed and entered in the FFATA system timely. Our finance team also attended a FFATA training on February 3, 2023 for additional training on the FFATA system. We will look into the Batch upload process which was described in that training. Position Responsible for Implementation of Corrective Action Name: Sean Cousino Position: Deputy Chief Financial Officer Email: sean.cousino@vermont.gov Phone Number: 802 595-3693 Date of Implementation of Corrective Action: First Reconciliation to be completed March/April 2023 Full Implementation June 1,2023

Sandusky Community School respectfully submits the following corrective action plan for the year ended June 30, 2022. Auditor: Anderson, Tuckey, Bernhardt & Doran, PC 715 E Frank St Caro, MI 48723 Audit Period: Year ended June 30, 2022 District responsible individual to implement this plan: Kendra Messing, Business Director Finding ? Federal Award Finding and Question Cost Finding 2022-001 ? Considered a 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: The District concurs with the facts of this finding and is in the process of continue the development of a long-term plan to continue to spend down the food service balance. Items being considered is improving outdated equipment and enhancing, plus expanding, the food options available in the District. The District has also discussed expanding staff and raising wages for contracted staff to continue to run the program

See corrective action plan.

Views of Responsible Officials and Planned Corrective Actions: During the pandemic, the TEFAP program was expanded using COVID-19 relief funds. Three Square had a misunderstanding in the classification of these supplemental commodities, and believed them to be part of COVID-19 relief and as such did not necessitate an executed TEFAP Agency Partner Services Agreement. The four entities mentioned in the finding who received TEFAP commodities only received these supplemental COVID-19 commodities. This finding was not pervasive throughout the organization, but rather isolated to a temporary program, which has now ended. To ensure effective internal controls, Three Square has designed a system to ensure an executed TEFAP Agency Partner Services Agreement is obtained prior to any TEFAP distribution to an Agency Partner. Moving forward, our agency services team will review all orders containing any federal commodity, regardless of the federal program. They will verify eligibility before approval is given to the warehouse to deliver the products.

Finding Type: Significant Deficiency of CFDA 10.553 and 10.555. Name of Contact Person: Ryan Fritch, Superintendent. Recommendation: We recommend the Food Service Director input the amounts into the Illinois State Board of Education monthly meal count report, print the report before submission, and give to the Bookkeeper or Superintendent the report along with the daily meal count sheets to review in order to ensure the amounts are accurate. The review should be documented on the report. Corrective Action: The Bookkeeper or Superintendent will begin reviewing the monthly meal count reports prepared by the Food Service Director to ensure accuracy before they are submitted. We will ensure the review is documented. Proposed Completion Date: Immediately.

See corrective action plan

Corrective action plan: TDA maintains an internal policy that requires SOC reports to be reviewed annually and document complementary user entity controls included in each SOC report. TDA?s contract with Colyar LLC requires the vendor to produce a SOC report annually. The vendor was late in providing the SOC report as a 2022 contract deliverable. TDA took actions to ensure vendor accountability for submitting the late contract deliverable and the vendor was required to complete a corrective action plan. TDA will review and assess the SOC report as soon as it is delivered by the vendor to ensure CLA?s recommendations can be followed and will consider additional procedures to ensure internal controls are assessed in the absence of a SOC report. Implementation date(s): June 2023 Responsible persons: Chief Information Officer and the Director for Food and Nutrition Program Support

There is no disagreement with the finding. Corrective action was started immediately. Arbor is responsible for sending the CSBO all of their source data and the reports to create the claim data. The CSBO will review the source data to make sure that it matches the reporting. When bills are received, they will be matched up to the claims to make sure that there aren't any discrepancies before the bill is paid. Person responsible: Heather Smith, CSBO.

Information on the Federal Program: U.S. Department of Agriculture, Assistance Listing Number 10.555/10.559, Child Nutrition Cluster, Year Ended June 30, 2022 Criteria: The Uniform Guidance requires the local program operator to perform an annual verification sample of household applications for free and reduced lunch and submit the verification report to the oversight agency. Condition: During the audit, the auditor became aware that the district did not maintain or keep the records that were used to compile and submit the annual verification report. Cause: The data submitted on the annual verification report was not supported by District records. Effect: The verification data ?submitted may not be accurate as it could not be verified against District records. Repeat Finding: Yes Auditor's Recommendation: We recommend the District keep records of all supporting documentation used for compliance reporting. Management Response: The Food Service Director is aware that all internal supporting documentation should be kept for compliance audit purposes and will maintain files for the information submitted on the verification report for the 2022/2023 reporting period. Oregon School District's Corrective Action Plan: The food service director understands that all documentation pertaining to the verification report must be kept including any notes on manual entries. Contact Person: Andrew Weiland, Business Manager Anticipated Completion Date: Complete

2022-001 - 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 - business administrator and/or designee. Completion date of implementation - June 30, 2023 and ongoing.

FINDING 2022-004 Contact Person Responsible for Corrective Action: Shannon Fritz, Corporation Treasurer Contact Phone Number: 219-567-9161 Views of Responsible Official: We concur with the audit findings. We have initiated corrective action as referenced below. Description of Corrective Action Plan: Monthly sponsor claims will be reviewed by the corporation treasurer after being prepared by the food service director. Anticipated Completion Date: Completed as of February 22, 2023 Cathy Rowe, Superintendent Shannon Fritz, Corporation Treasurer Date: 2-27-23 Date: 2-27-23

This issue was from a previous year, and has been corrected this current fiscal year (2022-2023) and will not be an issue moving forward.