Corrective Action Plans

CORRECTIVE ACTION PLAN 2022-001 This finding is caused by the District not having the proper controls in place to prevent, detect, or correct an incorrect monthly meal claim. There was lack of consistency and communication between the Food Service Director and the Business Manager during the fiscal year in relation to meal claims. The persons responsible for the corrective action are Janet Killingsworth, the food service director and Dr. Lori Haven, the superintendent. 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 finance director will work together to ensure that monthly meals served are being reconciled prior to any meal reimbursement requests are made.

Corrective Action Plan 2022-001 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 Michigan Department of Education approved 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 Shelley Ritchie, the food service director and Nadia Hoover, 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 2022-003 Finding Summary: The Organization did not have adequate controls to ensure household income was properly certified and may have allowed ineligible households to receive USDA Foods. Responsible Individuals: Administrative assistant (Wendy Matheney) and Front Desk Supervisor (Shannon Thackeray) Corrective Action Plan: Signature paperwork will be verified individually for each client by the front desk staff. The Admin Assistant will supervise data collection and integrity from a big picture standpoint. Anticipated Completion Date: 1/15/2023

2022-004 Special Tests and Provisions ? Verification of Free and Reduced Price Applications Federal Assistance Listing Number: 10.CNC District is in the process of establishing procedures and controls by the Business Manager to oversee the retention of verification documentation and information obtained through the verification process. Responsible Official: Karl Volkmann, Business Manager Anticipated Completion Date: June 30, 2023

2022-003 Segregation of Duties ? Reporting Federal Assistance Listing Number: 10.CNC Management is cognizant of the District?s internal control structure and continues to evaluate cost effective opportunities to further improve segregation of duties. It is the District?s plan to train an individual in the process of submitting claims in order to create a review process of the grant management process. Responsible Official: Karl Volkmann, Business Manager Anticipated Completion Date: June 30, 2023

Current Year Finding #2022-001- Repeat Finding for 2021-001 According to 2 CFR section 200.305(b)(5), when non-federal entities are funded under the reimbursement method, the entity should pay for costs for which reimbursement was requested prior to the date of the reimbursement request. During our audit, we noted the monthly claims for reimbursement were not compared to reports from the point of sale ("POS") system by an individual other than the preparer of the claims report prior to submission. We recommended that the district have an individual other than the preparer of the claims report, review the reports from the POS system prior to submission to verify that the number of meals claim based on actual meals served. Corrective Action: Effective July 30th, 2022, the Food Service Manager will prepare and review the meal count and meal reimbursement to the reports from the point-of-sale system, then prior to submittal will give to the reports from the POS system to the Business Administrator, Mr. Salvatore Carambia to verify and approve the reports from the POS system that the number of meals claimed was based on actual meals served.

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE ? U.S. DEPARTMENT OF AGRICULTURE, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, CHILD NUTRITION CLUSTER ? FEDERAL ALN 10.553, 10.555, AND 10.559 2022-002 Internal Control Over Compliance With Suspension and Debarment Requirements Finding Summary 2 CFR ? 180 requires the Academy to establish and maintain effective internal control over compliance with requirements applicable to federal program expenditures, including suspension and debarment requirements applicable to the child nutrition cluster program. The Academy did not have sufficient controls in place within its child nutrition cluster of federal programs to ensure that it was not contracting for goods or services with parties that are suspended or debarred, or whose principals are suspended or debarred, from participating in contracts involving the expenditures of federal program funds. Corrective Action Plan Actions Planned ? The Academy will review policies and procedures relating to suspension and debarment for its federal programs and will ensure that all parties with which it contracts for goods or services exceeding $25,000 are eligible to participate in contracts involving the expenditures of federal program funding. Official Responsible ? The Academy?s Interim Executive Director, Holly Fischer. Planned Completion Date ? June 30, 2023. Disagreement With or Explanation of Finding ? The Academy agrees with this finding. Plan to Monitor ? The Academy?s Interim Executive Director, Holly Fischer, will ensure appropriate internal controls are in place to verify that any vendor with which the Academy contracts for goods or services exceeding $25,000 is not listed as suspended or debarred on the federal Excluded Parties List System website.

Finding 2022-001 Corrective Action Plan a. Contact person responsible for corrective action: Stacey Graves, CFO b. Description of correction action to be taken: The district will exercise caution in ensuring calculations for indirect cost will calculated as directed by the Mississippi Department of Education. c. Anticipated completion date of corrective action: 3-24-23

FINDING 2022-002 Subject: Child Nutrition Cluster ? Internal Controls 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 contracts with a food service management company for the majority of food costs, labor costs, and operational costs, however in some cases the School Corporation will handle their own additional minor procurements outside of the food service management company. During the audit period, the School Corporation made one purchase between $10,000 and $150,000 which fell under the small purchase method for federal and state procurement regulations and was charged to Fund 0800 ? School Lunch Fund. For that purchase, 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. The transaction was incurred in July 2021 in the amount of $21,668. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Quotes will be sought for all purchases that fall within the small purchase threshold according to federal and state procurement regulations. Responsible Party and Timeline for Completion: Zach Dennis, CFO, 7/1/2022

Finding Number: 2022-002 Planned Corrective Action: The District has initiated an internal audit reconciliation system to confirm each month that all reimbursable breakfast and lunch reports agree. Anticipated Completion Date: 07/01/2022 Responsible Contact Person: Neil Laughbaum, Director of Operations

Views of Responsible Officials: During the COVID 19 pandemic the District experienced turnover in various key positions resulting from a lapse with record keeping. Management will work to ensure that records related to claim reimbursements are retained for a period of three years. Name of Responsible Person: Jennifer LaBarre, Executive Director of Student Nutrition Services Implementation Date: Fiscal Year 2023-2024

Finding: 2022-003 Cash Management Name of Contact Person: Ms. Robin Norwood Corrective Action: Automation clerk will work with NAF administration personnel to provide management of cash. Proposed Completion Date: August 21, 2023

CORRECTIVE ACTION PLAN November 28, 2022 Central City Cyberschool respectfully submits the following corrective action plan for the year ended July 31, 2022. Walkowicz, Boczkiewicz & Co 1800 East Main Street, Suite 100 Waukesha, WI 53186 Audit period: July 31, 2022 The findings from the July 31, 2022 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AND STATE AWARDS DEPARTMENT OF AGRICULTURE MATERIAL WEAKNESS 2022-001 School Breakfast Program ? CFDA No. 10.553, National School Lunch Program ?CFDA No. 10.555 Condition: There was no verification that the number of meals provided matched the monthly vendor invoice. Criteria: Internal Controls should be in place to ensure the vendor invoices were properly reviewed. Recommendation: Internal controls procedures should be established to ensure the number of meals provided match the monthly vendor invoice. Action Taken: ? Internal controls were established to ensure meals are recorded at point of service. ? Students enter their student number into the student information system (SIS) at point of service. ? Cyberschool employee monitors meals to determine if it qualifies for reimbursement in addition to clicking ?accept? with each SIS entry for a meal. ? There is a back-up paper check off system for employee monitoring to use if primary counting system (SIS) goes down during lunch hour. ? Vendor receives SIS printout the following day to confirm meals recorded. ? Vendor uses SIS printout report to invoice the school. ? When the invoice arrives, the School Operations Manager uses the SIS to confirm bill matches meals served. If questions arise regarding this plan, please call Jessica Whitaker at 414.444.2017

Reference Number: 2022-004 Description: Child Nutrition Cluster ? Reporting Corrective Action Plan: The pandemic-related policies for food service reporting ended on June 30, 2022. For the 2022-23 school year, the District has re-instituted the use of IDs and student numbers to track meal purchases by individual students. Reports from Skyward will be utilized and compared against claim data on a monthly basis . Anticipated Corrective Action Plan Completion Date: 9/1/2023 Contact Information: For additional information regarding this finding please contact Kevin Klimek, Director of Business Services, 414-371-6774

Federal Agency: U.S. Department of Agriculture Federal Program: Child Nutrition Cluster Assistance Listing Number: 10.555 and 10.559 Pass through Agency: Arizona Department of Education Pass Through Number: 7AZ300AZ3 Award Period: July 1, 2021 through June 30, 2022 Repeat Finding: Yes ? 2021-004 Type of Finding: Significant deficiency in internal controls over compliance and immaterial matter of noncompliance 2022-006 Condition: The District did not maintain documentation to support proper review and approval of the monthly meal reimbursement claims. Criteria or Specific Requirement: CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards requires compliance with cash management compliance requirements. The District should have internal controls designed to ensure compliance with those provisions. Context: For four of four monthly meal reimbursement claims tested. Corrective Action Plan: The District will retain documentation in future years to show that monthly claims summaries are reviewed. Anticipated Completion Date: June 30, 2023 Name of Contact Person: Pam Bradford, Interim Business Manager

Contact Person Responsible for Corrective Action: Brian Leitch, Chief Finance & Operations Officer / Treasurer 260-347-2502 ext.: 10017 Roger Urick, Interim Food Service Director 260-347-2502 ext.: 10011 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Internal Controls: The monthly meal reimbursement claims will be calculated by the Food Service Director by using information obtained through meal magic. Once the meal reimbursement is calculated it will be reviewed by the Deputy Treasurer before being submitted by the Food Service Director. Once the reimbursement is received the Deputy Treasurer will verify it was received as submitted. Anticipated Completion Date: April 2023

Finding 2022-002: Child Nutrition Cluster Resource Management Procedures Pass-through entity: Michigan Department of Education Assistance Listing Number(s): 10.553, 10.555 and 10.559 Award Numbers: COVID-19 211971, COVID-19 221970, COVID-19 221971, COVID-19 211961, COVID-19 220910, COVID-19 221960, COVID-19 221961, COVID-19 210904 and Entitlement Commodities Award Year Ends: June 30, 2022 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: The School District has started to develop a spend-down plan that it will implement and complete in the fiscal year ending June 30, 2023. Responsible Person and Anticipated Completion Date: The Superintendent is responsible for the development and execution of the spend-down plan with a completion date of June 30, 2023. If the Michigan Department of Education has questions regarding this plan, please call Mark Platt at (231) 873-6224.

FINDING 2022-003 Contact Person Responsible for Corrective Action: Julia Smith, Business Manager Contact Phone Number: 317-788-4481 Views of Responsible Official: We concur with the findings Description of Corrective Action Plan: The Foodservice Director and Business Manager will refer to the Guidance for State Agencies and School Food Authorities manual to ensure compliance for allowable costs. Anticipated Completion Date: January 2023

Findings and Questioned Costs Related to Federal Awards Finding Number: 2022-001 Contact Person: Dr. Shelley Isai, Assistant Superintendent for Education Services Anticipated Completion Date: November 21, 2022 Planned Corrective Action: The District reviewed the procedures used to determine Title I, Part A eligibility in the Grants Management System as well as a process that includes maintaining records. The process was redefined for the fiscal year 2023 grant application but will change slightly in future years due to a change in the options in criteria available used to determine eligibility for fiscal year 2023 grant applications. To complete this process with accuracy, the Director of Federal Projects will communicate the required eligibility criteria to the Director of Nutrition Services. The Nutrition Services department will provide Federal Projects with the necessary information to complete the process. Supporting documentation for the basis of fiscal year 2023 and the future years will be stored in a shared file and readily accessible for reference or audits. This process has been documented to ensure consistency through any department transitions.

FINDING 2022-004 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: 10.533, 10.555, 10.559 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment 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 Child Nutrition Program and Procurement and Suspension and Debarment compliance requirements. Context: For one of our procurement selections, out of a sample of two, the School Corporation was not able to provide verification that the vendor is not suspended or debarred. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and will take the following corrective action. The Treasurer will ensure the Procurement and Suspension and Debarment requirements are met prior to purchase for the Child Nutrition Program by reviewing the quotes and checking SAM.gov. Responsible party and timeline for completion: The Corporation Treasurer will be responsible effective immediately.

FINDING 2022-003 Information on the federal program: Subject: Child Nutrition Cluster - Reporting Federal Agency: Department of Education Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 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 sponsor claim reimbursement in a sample of four claims, the Food Service Director prepared the sponsor claim reimbursement summary without a secondary, documented review before the submission of the claim to ensure the accuracy of the sponsor claim reimbursement summary. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and will take the following corrective action. The Food Service Director will have the School Nutrition Program Director review, approve and initial the sponsor claim reimbursement summary before submission. Responsible party and timeline for completion: School Nutrition Program Director and School Treasurer will be responsible effective immediately.

Compliance: Finding: 2022-007 Condition: The District does not have a process in place currently nor is using the USDA's Nonprogram Revenue Tool to monitor the District's compliance with 7 CFR 210.14(f) to ensure that costs of nonprogram foods are not being subsidized by program food revenues. Plan: The District will begin using the USDA's Nonprogram Revenue Tool as well as work with Aramark to change the presentation of the invoices received. The District will also request additional monthly reports detailing revenue from nonprogram foods. Anticipated Date of Completion: June 30, 2023 Name of Contact Person: Dr. Joel Hackney, Superintendent Management's Response: Management will begin using the USDA's Nonprogram Revenue Tool, updated invoices from Aramark, and new reports from Aramark to ensure compliance with the Code of Federal Regulations.

Compliance: Finding: 2022-006 Condition: There was no termination clause noted in the Aramark contract stating whereby either party may cancel for cause with 60-day notification as required by 7 CFR 210.16(d) and 7 CFR 220.7(d)(4). Plan: The Aramark contract will be updated to include the proper termination clause stating whereby either party may cancel for cause with 60-day notification. Anticipated Date of Completion: June 30, 2023 Name of Contact Person: Dr. Joel Hackney, Superintendent Management's Response: Management will ensure the Aramark contract has been updated with the proper termination clause before signing another contract.

Compliance: Finding: 2022-005 Condition: No on-site review was done for the National School Lunch Program or for the School Breakfast Program as required to be done prior to February 1 of each school year to remain compliant with 7 Code of Federal Regulations (CFR) 210.8(a)(1) and 7 CFR 220.11(d)(1). Plan: On-site reviews will be completed for both the National School Lunch Program and the School Breakfast Program by February 1 of each school year. Anticipated Date of Completion: June 30, 2023 Name of Contact Person: Dr. Joel Hackney, Superintendent Management's Response: Management will ensure all necessary on-site reviews are completed by February 1 of each school year.

We purchased items via an interlocal agreement, ?piggybacking? on their contract. We had relied on the documentation done by the contracting agency instead of conducting a SAM verification ourselves. Prior to the audit, we had already updated our documentation for the subsequent year. We have revised our procedure further to ensure a two person control on the completion and documentation of compliance with federal suspension and debarment requirements.