Corrective Action Plans

The District develop a plan to eliminate the excess of net resources in the Food Service Fund.

The Business Administrator will ensure meals and snacks claimed for reimbursement be in agreement with the meals and snacks served per the daily sheets.

FINDING 2022-003 Contact Person Responsible for Corrective Action: Nicole Wolverton, CFO Contact Phone Number: 219-881-5536 Views of Responsible Official: We concur with the audit finding. Description of Corrective Action Plan: As it relates to reporting of meal claims, a policy and procedure will be created and implemented to ensure that accurate meal counts are recorded and entered CNP web by Sodexo based off reports from Skyward recording daily meal counts, documentation and entry then reviewed by the GCSC Food Service Manager for accuracy prior to submission of claims and then reviewed by the CFO for completeness. Anticipated Completion Date: Gary Community School Corporation will implement this procedure by September 2023. INDIANA STATE

FINDING 2022-002 Contact Person Responsible for Corrective Action: Nicole Wolverton, CFO Contact Phone Number: 219-881-5536 Views of Responsible Official: We concur with the audit finding. Description of Corrective Action Plan: As it relates to activities allowed or unallowed for Child Nutrition, a new policy and procedure will be implemented for requiring appropriate documentation from the Food Service Vendor. The policy will require the vendor to provide all supporting invoices for food purchased and time sheets for time and labor records. In addition, this policy and procedure will ensure the correct indirect cost allocation when submitting the application and required documentation to the Office of School Finance. This application submission will be prepared by the Chief Financial Officer and reviewed by the GCSC Manager to ensure accuracy and completion. The policy will contain language specific to the consideration of direct and indirect cost calculations and providing all supporting documentation for the determination of allowable and unallowable costs. GCSC will ensure indirect costs are charged according to the approved indirect cost rate. As it relates to special test and provisions to the School Food Accounts, a procedure will be implemented for the recording of receipts and expenditures within the food service accounts and the timeliness of the account reconciliations to be completed by the District Treasurer. Anticipated Completion Date: Gary Community School Corporation will implement this procedure by September 2023.

Formal finding #1: CNU Administrative finding- Monthly meals overreported on claims from August 2021 through April of 2022. Response: The overclaim was repaid in February of 2023 and the district has put into place steps to prevent this from happening in the future by making sure overclaim does not occur again.

The Superintendent, Director of Finance and Food Service Director will meet regularly to review food service revenue and expenditures during the course of the year. Adjustments will be made as deemed necessary.

The Superintendent, Director of Finance and Food Service Director have met with the Board of Education to seek approval for kitchen remodeling projects. The district Architect is working on a remodeling plan that should be completed during the 2022-2023 school year with major construction starting in the 2023/2024 continuing through 2024/2025 school year with completion set for the start of the 2025/2026 school year.

Finding 2022-003 ? Child Nutrition Cluster - Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Scott Miller, Jill Pollard Contact Phone Number: 765-659-1339 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Finding 2022-003 Child Nutrition Cluster - Cafe will gather information and more bids and notate going forward. Anticipated Completion Date: June 30, 2023

Information on the federal program: Subject: Child Nutrition Cluster - Procurement Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553 and 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY2021, FY2022 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 grant agreement and the Procurement and Suspension and Debarment compliance requirements. Context: For the audit period, there were four vendors that fell within the small purchases procurement threshold. Small purchases are those vendors that the School Corporation has purchased between $10,000 - $150,000 of products and goods. During the testing of Procurement and Suspension and Debarment, we noted one instance in a sample of one, where the School Corporation did not obtain three price or rate quotations from other vendors or document the basis for purchasing form the vendor that was utilized. The School Corporation compared the prices from the selected vendor to one vendor from their purchasing cooperative but did not obtain any additional quotes to meet the three-quote requirement for the small purchases procurement threshold. The lack of controls and noncompliance occurred throughout the audit period. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Food Service Director (FSD) will obtain a minimum of three price or rate quotes for each vendor with expected purchases of $10,000 to $150,000 each school year. Those quotes may be from vendors within and/or outside of the purchasing cooperative. Those quotes will be sent to the Assistant Superintendent who will then present those quotes with a recommendation to the School Board at a meeting open to the public. The School Board will award the appropriate vendor with the purchase of goods for the school year. The discussion, vote and award will be noted in the minutes of the school board meeting. The Assistant Superintendent will notify the FSD of the school board?s decision via email with signed & dated quotes attached. The FSD will maintain copies of all quotes including the quotes that were not accepted in each school year folder. The FSD will send suspension & debarment documents to the Assistant Superintendent for review, signature and date within three business days of selection of the vendor. The Assistant Superintendent will return the suspension & debarment documents to the FSD within three business days of receipt of the documents. The FSD will maintain all reviewed, signed & dated documents in each school year folder. Responsible Party and Timeline for Completion: The corrective action plan will take effect immediately. All tasks will be completed before each new school year begins. The FSD is responsible to obtain three rate or price quotes. The FSD will conduct the suspension & debarment search. The FSD is responsible A District Accredited School Corporation Since 2007 to maintain the files for each school year. The FSD will send all required information to the Assistant Superintendent. The Assistant Superintendent will present and make recommendations to the School Board. The Assistant Superintendent will notify the FSD of the School Board?s decision. SUMMARY

2022-001 Allowable Costs and Cost Principles Payroll Disbursements: Principals will be instructed on procedures for documentation of time of employees and making sure procedures are followed. New procedures will be implemented for additional inspection of the documentation. Vendor Disbursements: Persons receiving items at school cafeterias will be instructed on noting when items are not received or additional items to make sure reconciliation agrees with purchase order. Also, accounts payable persons will be retrained to make sure all procedures are followed. Estimated Completion Date: February 1, 2023

Identifying Number: 2022-101: USDA Foods Receipts Criteria: Notice of receipt of USDA Foods provided within two business days to the State of Maine Department of Agriculture for the CSFP program and within two business days for the TEFAP program. Condition: Notice of receipt of USDA Foods was not provided timely to the State of Maine Department of Agriculture in accordance with award requirements. Context: A sample of 25 receipts of USDA Foods included six instances where notification was not provided to the State of Maine Department of Agriculture within the required timeframe. Effect: Noncompliance with the provisions of the award may impact GSFB's ability to participate in the program. Cause: Increased volume and demand due to response to the global COVID-19 pandemic. Recommendation: GSFB reinforce the importance of submitting receipt tickets in accordance with award requirements. GSFB should further assign an individual within their organization to assume a higher level of direct responsibility for the administration of federal awards by GSFB. Contact: Bryan O'Connor Corrective Actions Taken or Planned: Staff commits to (1) uploading all documents in connection with each purchase order to the purchase file in our enterprise resource platform so that documentation is readily available; (2) utilizing exceptions report created to alert the inventory team if a USDA purchase order has been systematically received and documentation hasn't been uploaded within one business day from the time of receipt; and (3) instituting periodic review by Director of Inventory Management and Compliance of a sample of uploaded files to confirm that emails have been submitted to the Department within two business days of receipt.

Contact Person Responsible for Corrective Action: Kelsi Hall Contact Phone Number: 765-641-2096 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Meal counts are gathered and printed off of NutriKids by the food service Bookkeeper and given to the Director. The Director reviews the information and enters the numbers in CNPweb for each school individually. Before submitting the claims, the Director cross references the combined totals from NutriKids with the totals on the CNPweb Sponsor Claims page to ensure they match. If they do not match, this would alert the Director if there were any typos or errors in CNPweb. The meal count papers are then returned to the Bookkeeper to double check that the numbers entered in CNPweb match the numbers that were printed off from NutriKids. Anticipated Completion Date: July 1, 2023

Contact Person Responsible for Corrective Action: Kelsi Hall Contact Phone Number: 765-641-2096 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: At the beginning of each calendar year, the Food Service Director will receive suspension and debarment statements for each applicable vendor that the food service department uses throughout the year. The Food Service Director will obtain suspension and debarment statements from new vendors as they are used. Statements verifying that the vendor is not suspended or debarred from federal awards will be initialed by two individuals within the food service department. A complete list of vendors checked for suspension and debarment will be kept in the Food Service Director's office for safekeeping. Anticipated Completion Date: July 1, 2023

Corrective Action: The Bookkeeper will look at and sign off on all final food service claims before being submitted. Responsible Person: Brooke Rosemeyer, Bookkeeper Anticipated Completion Date: Ongoing

Department of Public Instruction Finding: 2022-022 Department of Public Instruction Response/Corrective Action Plan: We agree with the finding. Currently, USDA and DOE sub-awards are reported after the obligation or sub-award has been approved by all parties according to the requirements established by FSRS?s website. The Block Award, or the federal award which reimburses for meals claimed, will be reported after the meals have been claimed in NDFoods and paid in Peoplesoft. NDDPI will report the payments already made for FY 2023 and will work with our NDIT programmers to allow us to create an auto-generated report from NDFoods that will upload into the FSRS website according to FSRS?s template. To enter expenditure data by month in FSRS, Awardees are encouraged to complete a template to upload the required data. Unfortunately, NDDPI is aware of an issue with this template caused by the need for a 4-digit extension number. The lack of 4-digit zip code extensions with our rural sub-recipients is responsible for throwing this error in the upload. To complete a successful upload, NDDPI will omit any sub-recipients missing the 4-digit zip code extension from the monthly data or template and add them to the report with a manual entry on the website. The Director of CN and the CN Technology Coordinator will work with NDIT to program the needed reports from NDFoods. The Administrative Officer and the Account/Budget Specialist from the Fiscal Management office will be responsible for completing the upload and entering any manual data. After we have a defined set of steps to follow, we will create a written process and edit as needed. Contact Person Linda Schloer, Director, Child Nutrition and Food Distribution Programs Scott Egge, Technology Coordinator, Child Nutrition Kim Vega, Administrative Officer III, Fiscal Management Leon Rauser, Account/Budget Specialist, Fiscal Management Anticipated Completion Date Begin manual process procedure, 04/01/2023, enter sub-recipient data monthly from October 2022 forward until an automated process can be obtained. Autogenerated process date is uncertain, NDDPI will work with NDIT to establish an automated process as soon as IT?s schedule allows and testing is completed.

Condition: The District has not adequately established internal controls to ensure that net cash resources are being properly monitored. Plan: Internal controls will be established and implemented related to the cash management compliance requirement, including monitoring accumulated cash balances and ensuring that balance does not exceed 3 months of the average progam expenditures. Anticipated Date of Completion: 6/30/2023 Name of Contact Person: Brian Dukes, Superintendent Management Response: There is no disagreement with this finding and internal controls will be developed to monitor the net cash resources of the nonprofit school food service.

Corrective Action Plan December 6, 2022 Cognizant or Oversight Agency for Audit Unified School District #343 respectfully submits the following corrective action plan for the year ended June 30, 2022. 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, 2022 . The findings from the December 6, 2022 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Finding: 2022-001 ? Meal Reporting Condition: During our testing of meal reporting, we tested two months of meal report claims submitted to the State and traced to individual count sheets per school. It was discovered that on one day, eligible student meals were not included in the student meals total that was claimed for reimbursement. Recommendation: Policies and procedures should be written to provide internal control over meal reporting. We recommend the District establish a review process, such as having another individual review count sheets and compare them to the number of meals submitted, to ensure all meals submitted for reimbursement are for the correct number of meals. Action Taken: We concur with the recommendation and since the 2022 fiscal audit took place, we have updated review procedures to ensure that all meal reports are reviewed to ensure that they are being properly reported. Anticipated Complete Date: October 26, 2022 Should the Oversight Agency for Audit have questions regarding this plan, please contact Jenny Herschell, Business Manager/Board Clerk, at (785) 597-5138. Sincerely Unified School District #343

2022-004 -Child Nutrition Reporting Assistance Listing Number(s) 10.553, 10.555 Recommendation: CLA recommends the District implement a review procedure over reimbursement requests where someone other than the preparer reviews the claim to ensure counts agree back to supporting documentation prior to the reimbursement request being filed with the granting agency. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: Starting with the 2022-23 fiscal year, in September 2022, breakfast and lunch purchases are scanned into the software systems from which the claims are submitted rather than the hand tallies used in prior year. The Food Service Director will continue to submit the breakfast and lunch claims. Each Wednesday, the Finance Director will review an audit check printout of the breakfast and lunch counts to make sure that they are being correctly entered in the system. Name(s) of the contact person(s) responsible for corrective action: Charles Payant, Finance Director Planned completion date for corrective action plan: Winter 2022.

Management?s Response/Corrective Action Plan: The business manager and school nutrition director will ensure all documentation are maintained for each claim for audit purposes. The meal counts are now in the new point of sale system this fiscal year, which was not available last year for all students. All documents will be maintained correctly.

Management?s Response/Corrective Action Plan: The school business manager will ensure all supporting documentation supports the reported meal counts for school claims. The school manager has met with the new school nutrition director to create a plan. The correction has been made for fiscal year 2023.

CORRECTIVE ACTION PLAN - FINDING 2022-001 We have prepared the accompanying corrective action plan as required by the standards applicable to the financial audit contained in Government Auditing Standards and by the audit requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). CFDA Number Program Title Federal Agency 10.555, 10.559 Child Nutrition Cluster U.S. Department of Agriculture Condition The District did not properly review child nutrition claim forms prior to submission to the Arizona Department of Education resulting in net over claimed amount of $7,732. Corrective Action Plan The District has implemented a review of child nutrition claims to source reports prior to submission to the Arizona Department of Education. District Contact Erin Pugh, Business Manager Completion Date January 27, 2023

ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Olympia School District No. 111 September 1, 2021 through August 31, 2022 This schedule presents the corrective action planned by the District for findings reported in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Finding ref number: 2022-001 Finding caption: The District?s internal controls were inadequate for ensuring compliance with federal Title I requirements for eligibility and assessment system security. Name, address, and telephone of District contact person: Kate Davis, 111 Bethel Street N.E., Olympia WA, 98506, 360-596-6124 Corrective action the auditee plans to take in response to the finding: Title I, Part A: Ranking and Allocation The Olympia School District will utilize the Title I, Part A guide released by OSPI annually and reference the School Low-Income counts (page 52) to ensure that the District is using the correct low-income codes that should be included based on the form selected in the grant application. The District will have the Executive Director of Teaching and Learning, the Program Manager, and OSPI Title I, Part A Program contact confirm that student data is accurate prior to submitting the 2023-2024 grant. Assessment System Security Prior to the 2022 school year, Assessment Services was part of the Teaching and Learning Department. Moving forward, OSD will move responsibility of Assessment Services back to this department. Part of this transition will include the Executive Director of Teaching and Learning and Assessment Director developing written test security building plans for all standardized tests administered in OSD. Additionally, these same directors will work closely with OSPI?s Assessment Operations Department to ensure compliance with each state assessment?s training and documentation requirements.Anticipated date to complete the corrective action: Ranking and Allocation: The District will implement this corrective action immediately, and it will be reflected in the 2023-2024 Consolidated grant application. Assessment System Security: The District will implement this corrective action immediately, and it will be implemented with adjusted training for staff beginning Fall 2023.

8. Deficiency 2022-008 ? Instance of Noncompliance ? Meal County Tally a. An instance of noncompliance was identified over compliance requirement L from the 2022 Office of Management and Budget (OMB) Compliance Supplement. Recordkeeping of the daily supporting documentation for the monthly claims was found to not be in compliance with federal requirements. The District should develop and implement policies and procedures to ensure that all original daily meal counts and tallies used to support reimbursement reports are maintained for the appropriate amount of time. b. Plan of Action: The District will review, develop and implement procedures to provide the required reporting. c. Timeframe: Fiscal year 2023-24

7. Deficiency 2022-007 ? Instance of Noncompliance ? Procurement Policy a. An instance of noncompliance was identified over compliance requirement 1(a) from the 2022 Office of Management and Budget (OMB) Compliance Supplement. The District does not have a documented procurement policy. The District should develop and implement a formal procurement policy consistent with Federal, State, and local laws and regulations. b. Plan of Action: The District will undertake a review of best practices regarding procurement policy and will advance resulting recommendations. c. Timeframe: Fiscal year 2023-24

6. Deficiency 2022-006 ? Material Weakness ? Eligibility Verification Review a. A material weakness in controls over compliance was identified for controls over compliance requirement N.1 from the 2022 Office of Management and Budget (OMB) Compliance Supplement. Controls over eligibility verification were found not to be implemented. The District should develop and implement policies and procedures to ensure that all eligibility verifications are review in a timely manner and documented appropriately. b. Plan of Action: The District will develop procedures to ensure all eligibility verifications are reviewed timely by an administrator and documented appropriately. c. Timeframe: August 2023