Corrective Action Plans

The District will implement an internal procedure to ensure that the eligibility verification is completed prior to the November 15th due date.

CONTACT PERSON: Robin Stack, Chief Finance Officer, rstack@greenville.k12.sc.us CORRECTIVE ACTION: The School District will review the food service and accounting software programs and interface to determine why meals served data did not transfer properly for certain locations. In the meantime, the School District will manually review the meal count transfer totals for propriety and will notate differences and adjust for any significant differences. PROPOSED COMPLETION DATE: December 31, 2023

Name of Contact Person: Daniel Schuler, Business and Operations Manager Corrective Action Plan: The District did identify in late spring/early summer that the existing relationship with US Foods had not been bid in the prior year. In order to address this issue, the District Administration identified, recommended and received Board of Education approval to access a US Foods State of Alaska Contract with the State of Alaska Department of Corrections. This action, coupled with the one-year extension of an existing agreement with Alaskan & Proud Markets for the purchase of milk, will bring the District into compliance with procurement procedures as outlined by the National School Lunch Program and DEED. Proposed Completion Date: December 2023.

Name of Contact: Daniel Schuler, Business and Operations Manager Corrective Action Plan: The corrective action plan noted above for Finding 2023-001 will resolve Finding 2023-002 as well. The prior Business and Operations Manager started the annual verification process, however, did not follow through on finishing the process prior to her resignation from the District. Upon her departure from the District, she did not communicate that the process had not been completed. I am currently working on the annual verification process as prescribed by DEED and the National School Lunch Program and that process will be completed in accordance with the applicable November 15th deadline. In addition, the District has been selected and is currently working on an Onsite Review of the Child Nutrition Program which includes covering the same population of students that should have been verified during the FY2022-2023 verification process. Proposed Completion Date: December 2023.

Name of Contact Person: Daniel Schuler, Business and Operations Manager Corrective Action Plan: The prior Business and Operations Manager started the annual verification process, however, did not follow through on finishing the process prior to her resignation from the District. Upon her departure from the District, she did not communicate that the process had not been completed. I am currently working on the annual verification process as prescribed by the State of Alaska, Department of Education and Early Development (DEED) and the National School Lunch Program and that process will be completed in accordance with the applicable November 15th deadline. In addition, the District has been selected and is currently working on an Onsite Review of the Child Nutrition Program which includes covering the same population of students that should have been verified during the FY2022-2023 verification process. That review will be completed in December 2023. Proposed Completion Date: December 2023

CORRECTIVE ACTION PLAN October 2023 Section III: Federal Award Findings and Questioned Costs Findings and questioned costs related to Federal awards which are required to be reported in accordance with the Uniform Guidance 2 CFR 200.516(a): Significant Deficiency 2023-001 Child Nutrition Cluster - Procurement Views of the Responsible Officials and Planned Corrective Actions: The District has reviewed the requirements of 2 CFR Section 200.213. The District is in agreement with the recommendation to implement a procedure to document the process used to verify the eligibility of potential vendors to participate in Federal assistance programs. The verification of excluded parties will be accomplished by accessing the System for Award Management (SAM.gov) website and selecting the “Excluded Entity” filter on the “Exclusions” search page to search for exclusions by Unique Entity ID or CAGE/NCAGE code as follows: 1. Select “Search” from the header menu from any page on SAM.gov 2. In the filters, under “Select Domain”, select “Entity Information”, then select Exclusions 3. Use the filters or keyword box to enter the search criteria and view the results 4. Document the results in the vendor file. Other alternatives for verification may include collecting a certification from the entity or adding a clause or condition to the covered transaction or contract with that entity. The Purchasing Agent is charged with the responsibility of monitoring and ensuring compliance with the suspension and debarment procedures and maintaining documentation that contracts expected to equal or exceed $25,000 have been verified on the System for Award Management (SAM) website before purchases are made. Responsible Person(s): Matt Leon, Assistant Superintendent for Business & Operations and Michael DeSantis, Purchasing Agent Deadline for Completion: On or before 12/1/23 for covered transactions with contracts or purchase orders meeting the threshold during the time period 7/1/22 - 10/31/23. Prior to contract approval or purchase order issuance for contracts or purchase orders meeting the threshold on or after 11/1/23.

The Shared Business Services employees will work with the Management Company of the Food Services program to ensure that in situations where missed meals are identified, that proper documentation (including original tally sheets) be maintained and kept on hand to support the additional meals being claimed. In addition, they will ensure that staff are properly trained to not recreate tally sheets, but to properly document on the original copies, to ensure that meal counts are not duplicated.

October 24, 2023 Finding Number: 2023-004 – Material weakness in Internal Control – Reporting (Repeat Finding) Condition: In six of the eleven months tested, the number of meals included on the reimbursement claim reports were not supported by the District’s internal count sheets. Responsible Person: Kim Gagne – Director of Food Service Implementation Date: 10-24-2023 This year we have partnered with Meal Magic, for reporting claims. Every student must enter an identification number or scan an ID card so that students cannot be missed or over-claimed. The Direct Certification students are compared monthly against the state information provided to make sure students are claimed at the correct rate. Sincerely, Stephen Grubaugh Director of Business Service

October 24, 2023 Finding Number: 2023-003 – Significant Deficiency in Internal Control – Eligibility Condition: Of the 22 applications for reduced meals that were selected for testing, 3 did not document evidence of review by staff. Responsible Person: Kim Gagne – Director of Food Service Implementation Date: 10-24-2023 This year we have a 2-person checking system, Kim Gagne initially completes the applications with a signature and Jody King double checks every application for errors and oversites and adds her signature also. Both have been through the MDE training on the applications and the required information they need. Sincerely, Stephen Grubaugh Director of Business Services

October 24, 2023 Finding Number: 2023-002 – Significant Deficiency in Internal Control / Noncompliance – On-Site Reviews Condition: An on-site review was not completed for all sites in which lunches were served. Responsible Person: Kim Gagne – Director of Food Service Implementation Date: 10-24-2023 On-site reviews for Lunch and Breakfast are mapped out on the calendar to have completed by Kim Gagne before the due date of Feb 1st, for all 5 schools. This time line will give the time to make sure deficiencies are addressed and corrected. Sincerely, Stephen Grubaugh Director of Business Services

Kenowa Hills Public Schools respectfully submits the following corrective action plan for the year ended June 30, 2023. Auditor: Maner Costerisan 2425 E. Grand River Ave., Suite 1 Lansing, Michigan 48912 Audit Period: Year ended June 30, 2023 District Contact Person: John Gilchrist, Director of Finance The findings from the June 30, 2023 schedule of findings and responses are discussed below. The findings are numbered consistently with the number assigned in the schedule. Finding - Financial Statement Audit Finding 2023-001 Considered a material weakness Recommendation: The District should ensure that reconciliations are completed in a timely manner in order to correct any potential errors sooner. Action to be Taken: Management agrees with the finding and we are in the process of developing a plan as recommended. Finding – Federal Award Findings and Question Costs Finding 2023-002 Considered a significant deficiency Recommendation: The District should thoroughly train staff on their responsibilities for how to properly count meals served to ensure accurate record keeping. Action to be Taken: Management agrees with the finding and has implemented procedures to thoroughly train staff on how to accurately count meals and maintain records.

OKEMOS PUBLIC SCHOOLS FOR THE YEAR ENDED JUNE 30, 2023 Okemos Public Schools respectfully submits the following corrective action plan for the year ended June 30, 2023. Auditor: Maner Costerisan 2425 E. Grand River Avenue, Suite 1 Lansing, MI 48912 Audit Period Year ended June 30, 2023 District Contact Person: Liz Lentz, Executive Director of Finance Finding 2023-001: Considered a significant deficiency in internal control over compliance. Recommendation: The District should consistently utilize a point-of-sale system to track and claim the number of meals served. Action to be Taken: Management agrees with the finding and had already changed procedures during the school year to better track and claim meals.

The district has updated their spend down plan as of July 2023 to address the excess fund balance in food service. The Food Service Director and the Director of Business Services have already identified areas where there are needs for upgrades or enhancements. Over the next several months, the Excess Fund Balance will get used to improve the Food Service Porgram.

REFERENCE # 2022-009 SPECIAL TEST – ACCOUNTABILITY FOR USDA FOODS– MATERIAL WEAKNESS – MATERIAL NONCOMPLIANCE Program Name/ALN The Food Distribution Cluster Corrective Action Plan: The Division will ensure the documentation related to inventory counts are reviewed and maintained. Action Date: Ongoing Final Implementation Date: 09/30/2026 Name and Phone # Of Person Responsible for Implementation: Claudia Pardo, Captain, Divisional Finance Secretary (916) 563-3745

Contact Person Jackie Cordie, Business Manager Corrective Action Plan The District plans to implement the auditor's recommendation. Planned Completion Date for CAP Fiscal year beginning July 1, 2024

Contact Person Jackie Cordie, Business Manager Corrective Action Plan The District plans to implement the auditor's recommendation. Planned Completion Date for CAP Fiscal year beginning July 1, 2024

Finding No.: 2022-012 AL Programs: 10.542 - Pandemic EBT Food Benefits (P-EBT) Area: Eligibility Questioned Costs: $58,494 Contact Person(s): Margaret Aldan, NAP Administrator Corrective Action Plan: Condition 1 & 2: CNMI NAP respectfully disagrees. Audit finding states that documentation supporting eligibility determinations were not provided. Finding further states that CNMI NAP lacks monitoring control over the listing of validated eligibility roster data that were not uploaded into MAVEN eligibility system due to data entry capacity limitations (sic) were not being maintained; and Distributed coupons were not reconciled to the recorded expenditures for redeemed coupons. The resulting effect being that CNMI NAP is in noncompliance with the applicable eligibility requirements and questioned costs for condition 1. CNMI NAP was informed that this finding had been cleared so we are perplexed as to the re-emergence of this audit finding. CNMI NAP contends that: 1. Eligibility for P-EBT benefits is not determined by CNMI NAP. P-EBT eligibility was determined by identifying children who qualified for free or reduced-price school meals and then correlating that with a reduction of in-person schooling due to COVID-19. Children in households receiving SNAP and young children, under age six, were also eligible, provided their schools or childcare facilities closed or reduced hours for at least five consecutive days due to the pandemic. This data was provided by PSS, as well as the listing of eligible children that corresponded to this data set. 2. There are no “validated eligibility roster data case files” that were not uploaded into MAVEN due to data entry capacity limitations. All rosters provided by PSS were uploaded into MAVEN as this is the only way a case file can be generated in the system. 3. CNMI NAP has reconciled all benefits issued, including the P-EBT benefits for the audit year in question. This is a mandatory, non-negotiable process. Proposed Completion Date: Ongoing

Finding No.: 2022-011 AL Program: 10.542 - Pandemic EBT Food Benefits (P-EBT) Area: Activities Allowed or Unallowed Questioned Costs: $-0- Contact Person(s): Margaret Aldan, NAP Administrator Corrective Action Plan: CNMI NAP respectfully disagrees with this finding. The April 2022 Compliance Supplement referenced by the auditor states: Special Tests and Provisions. 1. Verification of Free and Reduced-Price Applications (NSLP) Compliance Requirements: By November 15th of each school year, the LEA (or state in certain cases) must verify the current free and reduced-price eligibility of households selected from a sample of applications that it has approved for free and reduced-price meals, unless the LEA is otherwise exempt from the verification requirement. The verification sample size is based on the total number of approved applications on file on October 1st. A state agency may, with FNS approval, assume from LEAs under its jurisdiction the responsibility for performing the verifications. If the LEA performs the verification function it must be in accordance with instructions provided by the state agency. The LEA must follow up on children whose eligibility status has changed as the result of verification activities to put them in the correct category. CNMI NAP response: The 2022 Compliance Supplement states that the LEA, in this instance, PSS, is responsible for verifying the current free and reduced-price eligibility of households unless the LEA is exempt from the verification requirement. PSS is not exempt from the verification requirement and the CNMI NAP has never given instructions to PSS for data collection as it is the PSS’ responsibility to supply the data to NAP for P-EBT. NAP’s role is to distribute the benefits only. Similar to the SUN Bucks (S-EBT) program, PSS furnishes the student listing to NAP, after which NAP distributes the benefits according to the listing provided by PSS. Proposed Completion Date: Ongoing

Corrective Action: The Food Distribution Program will take steps to submit programmatic reports in a timely manner. The accountant responsible for the grant, along with the Procurement, Grants, and Contracts program, will monitor deadlines and follow up with the program as necessary. Additionally, the Grants program has recently implemented new Grants Management software, Instrumental, which will assist in tracking grant deadlines. Person(s) Responsible: Food Distribution Director Estimated Completion Date: July 31, 2025

Management agrees with the finding and has established a monthly meeting between the Business Manager and the Cafeteria Director in order to review the monthly budget and allocate all appropriate expenses in a timely fashion. The Business Manager has implemented these accounting changes. This process was completed in October of 2022.

Management agrees with the finding and has established a monthly meeting between the Business Manager and the Cafeteria Director in order to review the monthly budget and ascertain that all appropriate expenses are disbursed only for the federally funded department. The Business Manager has implemented these accounting changes as of September 2022.

Management agrees with the finding and has developed a set of policies and documented them. The Business Manager has implemented the changes as of June 2023.

Procure the services of an accounting professional to verify the accuracy and adherence to accounting methods and reporting procedures to assist with the administration of the Child and Adult Care Food Program (CACFP)

Finding 2022-002 Corrective Action Plan Details A. Contact person responsible for corrective action: Name: Dr. Mario Willis Title: Superintendent B. Description of corrective action planned: The district will strengthen its internal control systems over reporting to ensure single audit reporting package and data collection form are submitted to the Federal Audit Clearinghouse within established timeframe and financial statements are prepared timely. C. Anticipated completion date of corrective action:

Auditee Response: The auditee agrees with the finding. This was a perfect storm of events that created this scenario including COVID requiring the discontinuation of our Point of Sale (POS) System, tally sheets by classroom being used in place of that system, a change in head cooks during the year, and a failure to communicate properly between the Director of Food Service and the new Head Cook. Action Taken: The district has and will reinstitute the use of its POS system so that a child purchasing lunch types in their number and it is credited to that child's account. This system can then be used to track meal purchases throughout the day, week, or month. Since the HeadStart classroom are not MWSD students, they do not have numbers within the system. The Director of Food Services will use this system to report meal purchases and reimbursement rather than rely on head cooks and their tally sheets. Despite this, training should be conducted annually with all head cooks as to the qualifications of a reimbursable meal within the school district, so as to provide a fail safe in the event the POS system goes down for a period of time. Timelines/Contract: Most of this has taken place already in that we have returned to using a POS system. This system has the ability to track data and run reports, so it makes it error free when available. However, people ultimately must have the knowledge too so that they understand the parameters of a reimbursable meal should the system go down. Therefore, annual trainings will be instituted regarding such operations effective immediately. The Director of Food Service will be directed to use one in-service day annually for the purpose of teaching all staff members about reimbursable meals and how the HeadStart Programs fit into that. This should be completed no later than fall of 2025. The contact person would be Joe Stroup, Superintendent.