Corrective Action Plans

Management agrees with the finding. The necessary reports will be filed as soon as they are available.

Management agrees with the finding. The necessary written documentation to comply will be prepared by December 31, 2024 as well as conducting internal quarterly audits of the food service invoices.

Management agrees with the finding. The necessary written documentation to comply with the Uniform Guidance will be prepared by December 31, 2024.

FA2022-001: Improve Controls over Equipment Compliance Requirement: Equipment and Real Property Management Internal Control Impact: Significant Deficiency Compliance Requirement: Nonmaterial Noncompliance Federal Award Agency: U.S. Department of Agriculture Pass-through Entity: Georgia Department of Education Assistance Listing Number and Title: 10.553 – School Breakfast Program, 10.555 – National School Lunch Program Federal Award Number: 225GA324N1199 Federal Awarding Agency: U.S. Department of Education Pass-through Entity: Georgia Department of Education Assistance Listing Number and Title: COVID-19 – 84.425D-Elementary and Secondary School Emergency Relief Fund, COVID-19 – 84.425U-American Rescue Plan Elementary and Secondary School Emergency Relief Fund, COVID-19 – 84.425W-American Rescue Plan Elementary and Secondary School Emergency Relief Fund Federal Award Number: S425D200012 (Year: 2020), S425D210012 (Year: 2021), S425U120012 (Year: 2021), S425W210011 (Year: 2021) Questioned Costs: None Identified Repeat of Prior Year Findings: FA2021-001, FA2020-001, FA2019-003, FA2018-002, FA2017-004 Description: The policies and procedures for the School District were insufficient to provide adequate internal controls over equipment and real property management as it relates to the Child Nutrition Cluster and Elementary and Secondary School Emergency Relief Fund programs. Corrective Action Plan: We concur with this finding. Management has strengthened controls over equipment to ensure that the records are complete, accurate and reflect all required information. We are currently in the process of developing a physical inventory list of equipment. The inventory listing will have all identifying information such as an item description, an identifying number, the source of the funding, the title holder, the acquisition date, the cost, the percentage of federal participation in the project costs, the location of the equipment, the use and condition of the equipment, and any ultimate disposal date for each piece of equipment. A complete physical inventory will be performed each year and reconciled with the equipment listing. Estimated Completion Date: June 30, 2024 Contact Person: Christopher Stephens Telephone: 229-268-4761 Email: Christopher.stephens@dooly.k12.ga.us

Sysco Lincoln refunded the amount owed to us due to their overbilling. The bills are reviewed by the nutrition supervisor and the accounting assistant when paying the bills.

Program Affected-Child Nutrition Cluster-Assistance Listing No. 10.555, 10.556, 10.559 Criteria: The Uniform Guidance requires the local program operator to submit monthly claims for reimbursement to the administering agency. All meals claimed for reimbursement must meet federal requirements and be served to eligible children. Condition: Audit sampling revealed variances between total meals claimed in monthly food service claims and the meal cotmt sheets that the District used to track meals served to students. Cause: Meal counts were not accurately reported on the claim forms in the months sampled. Effect: Excess reimbursement amounts claimed may be disallowed and, if any, the excess may need to be returned to the federal agency. Questioned Cost: Unknown. Repeat Finding: Yes. Auditor's Recommendation: We recommend the District set up a review procedure to review the claims and reconcile the claims to actual meals served. Grantee Response: The District has reviewed procedures and implemented a system to review the claims and reconcile the claims to actual meals served. This will be done by entering the actual meals served in our computer system (Skyward) on an ongoing basis at the point of service, meaning the meals are entered daily into the system as students/staff go through the food service line at their school. This is a change from the past--<luring COVID, when all meals were served free to all students. At that time, our previous food service director used a manual, "tally" method, as a result of being short staffed. Now, we have a new food service director and we are going to keep all of our meal counts up to date in Skyward, as opposed to using the manual, "tally" method from the past two years. Contact Person: District Administrator Terry Slack Anticipated Completion: December 31, 2023

Finding 2022-019: U.S. Department of Agriculture Child Nutrition Cluster: School Breakfast Program, 10.553 National School Lunch Program, 10.555 Special Milk Program for Children, 10.556 Summer Food Service Program for Children, 10.559 Fresh Fruit and Vegetable Program, 10.582 Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance The Nevada Department of Agriculture (NDA) did not have internal controls to ensure subaward information was submitted in accordance with the FFATA. Subaward obligations were not reported in the FSRS and therefore not included on the FFATA’s website for public information disclosure. A nonstatistical sample of 6 out of a population of 54 applicable subaward obligations was selected for testing. The quantity and subaward obligation errors were noted as follows: The NDA accepts these findings and will take corrective action to enhance internal controls to ensure FFATA required information is reported annually. Corrective action: The NDA will begin submitting information in accordance with FFATA at the end of the 2023 award period per direction from the federal partner that annual submittals are in compliance with FFATA for the Child Nutrition Cluster programs. The submittal of information will be done as part of the NDA’s closing procedure for these awards. Date of completion: February 28, 2024

Finding 2022-018: U.S. Department of Agriculture Child Nutrition Cluster: School Breakfast Program, 10.553 National School Lunch Program, 10.555 Special Milk Program for Children, 10.556 Summer Food Service Program for Children, 10.559 Fresh Fruit and Vegetable Program, 10.582 Reporting Significant Deficiency in Internal Control over Compliance The Nevada Department of Agriculture (NDA) did not have adequate internal controls to ensure accurate information was reported to the federal awarding agency. Inaccurate information was reported to FNS. A nonstatistical sample of seven out of a population of 36 reports was selected for testing. The October 2021 FNS-10 report includes annual information (rather than monthly). Line 12b – Membership (Enrollment) of Public Schools was reported as 13. The actual enrollment supported by the underlying documentation of public schools was 22. The NDA accepts these findings and will take corrective action to enhance internal controls to ensure amounts reported to FNS are correct. Corrective action: The NDA has new staff completing data entry and certification of these reports in the federal system that have been extensively trained on required federal reporting. NDA will ensure that additional checks and balances are put in place to review the FNS-10 reports to ensure they match up with appropriate data collected. Date of completion: June 30, 2024

(B) The Department agrees to develop and implement policies and procedures requiring Department staff to perform reconciliations of recipient agencies? and Regional Food Banks? physical inventories to the Web-based Supply Chain Management system to ensure inventory records are complete and accurate. Starting in January 2021 the Department began developing a position description for an Inventory Specialist with the focus of ensuring accurate and thorough accounting of all year-end inventory and reconciliations. The position was hired in April 2021. Due to the implementation of the inventory database and the timing of beginning and ending inventories, the Department anticipates being able to do a full reconciliation of inventories by December 2022. (C) The Department agrees to develop and implement a tracking system for food inventory at recipient agencies and Regional Food Banks using the Web Supply Chain Management system receipts as the basis of food received, including the maintenance of supporting documents. The Department is undertaking an inventory overhaul which includes implementing a new inventory database and creating and hiring an Inventory Specialist. The Department recognized the need for inventory software and started the process of obtaining it in June 2020. In May 2021, the Department received a signed licensing agreement for a new database which is expected to be implemented in six months per an OIT timeline. In addition to the database, the Department recently hired a new Inventory Specialist position. This position will lead the development of policies, procedures, inventory reconciliations, and monthly report management. Once the Inventory Specialist has a comprehensive understanding of federal and state policy and the new database software, the Department will develop policies and procedures, training for partner agencies, and roll out new requirements for the tracking and reconciliation of program inventories.

The Food Bank has updated the weight and has implemented procedures to ensure products are updated annually.

2022-007 Significant Deficiency in Controls over Compliance and Compliance Finding: Double Reporting of Student Counts. Effective January 2022, the Business Manager now reviews all count sheets and ties the counts to the summary report used to submit claims prior to submittal for reimbursement. She did not, however, review the actual claims before submittal and discovered after-the-fact that these duplicate counts had occurred. The review procedures were immediately changed to include reviewing the actual claim submittal before the Food Manager certifies their claims.

2022-006 Significant Deficiency in Controls over Compliance and Compliance Finding: Reporting We are currently working on a tracking system and are in the process of increasing the number of staff who are authorized to file claims.

2022-004 Material Weakness in Controls over Compliance: Activities Allowed or Unallowed We agree with the recommendations and have made improvements to our procedures. The schools were not prepared for the rapid expansion of the food program, not only at our two high schools, but our partner schools' which requested contracted breakfast/lunch food services for their students as well. This unprecedented growth coupled with supply chain issues from food wholesalers, and shortage of employees in the hiring pool, only exacerbated our issues. The audit sample showed a large error rate for one of the schools. We have gone through the entire year for the school(s) individual count sheets. In the event the Michigan Department of Education determines that the identified discrepancies warrant a repayment we have recorded an allowance in the financial statements for the year ended June 30, 2021. Staff were not properly trained in how to complete the count sheets; however, supervisors did not take the time once they saw there was a problem due to everyone trying to simply get the meals served to the children. In addition, there was a lack of oversight of the Food Service Manager by her direct supervisor. At the time of the 2021 audit, when the issue was brought to our attention, we developed new procedures. School staff performing counts have been trained in how to properly complete the count sheets. The Business Manager now reviews all count sheets and ties counts to the summary report used to submit claims prior to submittal for reimbursement. Given that training and implementation of procedures did not fully occur until January 2022, there are errors in counts prior to implementation of the procedures and repeat findings in fiscal year 2021-22. In addition, with the end of the pandemic, beginning with the 2022-23 school year, the schools were able to resume using electronic software to accurately capture the meal counts.

U.S. DEPARTMENT OF AGRICULTURE SIGNIFICANT DEFICIENCY 2022-003: Child Nutrition Cluster ? CFDA No. 10.553, 10.555 and 10.559 Grant period: Year Ended June 30, 2022 Condition and Context: Per review of the Summer Food Service Program summary sheet for April, the incorrect number of breakfasts was reported. Criteria: The District is required to submit the number of breakfasts and lunches served in order to receive reimbursement for them. Cause: The number of meals entered for reimbursement on the summary sheet was incorrect. Effect: If the correct number of meals is not reported the District will not be reimbursed the correct amount. Recommendation: We recommend that the summary sheets used to compile the request for reimbursement is double checked for accuracy as to the number of meals on the daily count sheets. Grantee Response: We concur with the recommendation. In addition, someone will be reviewing all summary sheets before the request for reimbursement is submitted.

Finding 2022-002 (ACFR 2022-001): There were instances in which the number of meals claimed did not agree with the meal count records resulting in an over/under claim. Corrective Action Approved by the Board: Prior to submitting reimbursement claims to the NJ Department of Agriculture, the meals claimed should be verified to the meal count activity records. Method of Implementation: More care will be taken to ensure meals claimed are verified to meal count activity records. Person Responsible for Implementation: Joanne Origoni, Secretary to the Business Administrator. Completion Date of Implementation: 3/9/2023.

Corrective Action Plan 2022-001 This finding is caused by the District?s Food Service Fund?s fund balance being over the USDA?s threshold of 3 months average expenditures. The District is fully aware of this situation and has a 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 be before the end of the 2022-23 fiscal year. The person responsible for the corrective action is Michelle Adams, the food service director. The plan for monitoring adherence is the food service director will work to assess where the fund balance is after all of the projects from the spend down plan are completed.

PROCUREMENT Name of contact person: Lenore Bricco Corrective Action: The district will strive to comply with the procurement statutes. Proposed Completion Date: Immediate.

FINDING 2022-003 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: 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: For all four monthly claims selected for testing, 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. Additionally, we noted that for one claim in the sample of four, the meal counts were overclaimed for the month. In October 2020, the School Corporation overclaimed breakfast by 43 meals and underclaimed lunch by 11 meals. Views of Responsible Officials and Planned Corrective Actions: We concur with the finding. Description of Corrective Action Plan: Food Service Director, Brisha Dunbar will verify that the numbers she pulls from E-trition match the amounts that she is claiming for reimbursement. FSD completes a daily edit check form and compares totals to the monthly E-trition report. Once the food service director has the monthly forms completed Southwestern ECA treasurer, Amber Mitchell will review and compare totals before the numbers are submitted to the State. She will initial the totals form along with the FSD and these forms will be kept on file in the FSD?s office. Responsible Party and Timeline for Completion: Food Service Director, Brisha Dunbar and ECA Treasurer, Amber Mitchell ? these changes will be implemented effective March 2023.

The excess Food Service fund balance was due to the additional funding received while the school operated the SFSP, SSO and CACFP programs, along with an excess fund balance from the prior year. Our prior year spend down plan included equipment replacement for the High School cafeteria and food service areas. Due to delays with shipping and manufacturing, the equipment wasn?t delivered and paid for until July 2022, after our fiscal year end. Had the equipment been delivered and paid for prior to year-end, the District would not have incurred an excess fund balance.

Finding Number 2022-002 Internal controls over distributions of USDA Foods to recipients (Material Weakness) Response and Corrective Action Plan: Given the change in distribution approach, use of the Link2Feed website by food recipients was hard to enforce compliance. However, effective immediately, processes will be put in place to ensure all food recipients register on Link2Feed as required. Responsible Person: Janice Roberts, Program Director, under the oversight of John Cruz, Mercy Executive Director. Estimated Completion Date: November 30, 2022

Finding Number 2022-001 Internal Controls over inventory management (Material Weakness) Response and Corrective Action Plan: COVID impacts on the Mercy Brown Bag program's execution and associated inventory documentation was profound, given the need to restructure historical food distribution practices with recipients and the increase of the food provided through the TEFAP program. Priority was given to distribution of the food to recipients, with limited staffing caused by the increased operational workload and social distancing requirements. Program management will implement written documentation standards and processes to ensure all inventory movement is documented and retained, effective immediately. Additionally, periodic inventories will be conducted to ensure that all transactions have been captured. Exploration of a technology solution to enable these processes will be conducted and implemented if determined to be cost-effective. Responsible Person: Janice Roberts, Program Director, under the oversight of John Cruz, Mercy Executive Director. Estimated Completion Date: January 31, 2023

Corrective Action Plan Finding No.: 2022-001 Subrecipient Eligibility Federal Program Name: Food Distribution Cluster CFDA Numbers: 10.565, 10.568, 10.569 Federal Agency: U.S. Department of Agriculture Requirement: The Organization must enter into written agreements with their subrecipient agencies that includes certain information, including references to 7 CFR section 247.4 and a statement that subrecipient agencies are responsible for certain losses. Finding: During the testing of 37 subrecipient agency agreements, we noted 6 that did not have all required information. Questioned Costs: N/A Systemic or Isolated: This instance of noncompliance is systemic with regard to CSFP subrecipient agreements in Kentucky and Illinois. Effect of Finding: The Organization is not in compliance with applicable regulations. Recommendation: We recommend that the Organization update all agreements to include all required information and references. Corrective Action Plan: Management will immediately update all Illinois CSFP contracts with the required language that references 7 CFR section 247.4 and send the updated contracts to all participating Illinois sites for signature and return to Tri-State Food Bank. Contact Person Responsible for Corrective Action: Glenn Roberts, Executive Director Anticipated Completion Date: January 31, 2022

2022-001 Net Cash Resources Corrective Action Plan: The School District will review cafeteria operations throughout 2022-23 and ensure any excess funds will be used to provide additional support to the cafeteria program.

FINDING 2022-003 Contact Person Responsible for Corrective Action: Sue Hart Contact Phone Number: 812-752-8921 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: If the district is a member of, and purchases through, a purchasing cooperative for food and/or supplies, at least one invoice per month from a vendor/cooperative will be reviewed by the Director of Food Services and compared to the approved price lists. A copy of those documents shall be made and shall include any notes/markings made as a part of the review. If discrepancies are identified, the Director of Food Services will communicate the need for correction to the vendor/cooperative and the district Treasurer and CFO. In addition, another invoice will be pulled and reviewed using the same process, continuing until a subsequent invoice is determined to have no discrepancies when compared to the approved price lists. Documentation showing evidence of these reviews will be filed appropriately by the Director of Food Services for easy access throughout the year and for examination during audits. Anticipated Completion Date: May 2023

Child Nutrition Cluster, COVID-19 National School Lunch Program - Assistance Listing 10.555; passed through the Pennsylvania Department of Education; Grant Period - Year Ended June 30, 2022. Planned Corrective Action: Going forward, the Staff Accountant, Kyle Winton, will review food service related grant expenditures schedules with the Food Service Director, Beth Hufnagel, to ensure the schedules are complete and accurate. Person Responsible: Staff Accountant (Kyle Winton) Anticipated Completion Date: Immediately