Corrective Action Plans

Finding: Expenditures for certain services exceeding the simplified acquisition threshold were made, and an approved procurement method was not utilized within Assistance Listing #10.555 and #10.553. Response: The Board will implement the following corrective action plan: 1. The Board will use an approved procurement method for these services. 2. The Board will determine if services are provided in this area by other vendors. 3. If other vendors are available, the Board will distribute and advertise request for bids for these services. Anticipated Completion Date: 09-30-2023

Finding #2022-006 ? Child Nutrition Cluster ? Supporting Documentation (#10.553 and #10.555) Federal Grantor ? U.S. Department of Agriculture Pass-through Award Numbers ? 2022-304627-DPI-SB-546 and 2022-3046247-DPI-NSL-547 Pass-through Entity ? Wisconsin Department of Public Instruction Condition: The federal program annually requires performance of sampling and verification of free and reduced price applications. Supporting documentation supporting verification of applicants for free or reduced meals was not available for review. District could not provide documentation supporting that a verification of 3% of all applicants submitted for free or reduced meals was performed. Effect: Sampling and verification procedures are required to be performed annually. Potential to receive an incorrect amount of aid per meal served and students could be charged the wrong price for meals. Cause: The accounting system had notes indicating that sampling and verification procedures may have taken place, however, no supporting documentation was able to be retrieved. Turnover in the business office occurred. Criteria: The District is required to test 3% of all applications submitted for free or reduced meals to ensure their eligibility has not changed since they applied. If their eligibility has changed, then the District must change the student?s status appropriately. Supporting documentation of these sampling and verification procedures should be maintained for future reference. Recommendation: Policies and procedures should be implemented to ensure proper sampling and verification of applicants is performed and that the supporting documentation be maintained. Response: The District will establish policies and procedures proper sampling and verification procedures are performed and the supporting documentation is maintained. Contact Person: Robert Antholine, Phone number: 262-537-2211, Email: rantholine@randall.k12.wi.us Anticipated Completion: June 30, 2023

Finding #2022-005 ? Child Nutrition Cluster ? Unclaimed Meals (#10.553 and #10.555) Federal Grantor ? U.S. Department of Agriculture Pass-through Award Numbers ? 2022-304627-DPI-SB-546 and 2022-3046247-DPI-NSL-547 Pass-through Entity ? Wisconsin Department of Public Instruction Condition: Food service claims were not prepared by the District within the 60-day window for November 2021 breakfast meals and December 2021 lunch meals served. The auditor brought to the District?s attention during August 2022 fieldwork. Based on meals served, the November 2021 breakfast claim was calculated to be for $9,665 and the December 2021 lunch claim was calculated as $23,751. Effect: District did not receive reimbursement for meals served during November 2021 for breakfast meals served and December 2021 lunch meals served. Cause: The District did not have proper procedures in place for submitting monthly claims. The District began contracting with a Food Service Management Company starting in 2021-2022. Criteria: Monthly breakfast and lunch reimbursement claims should be made within the 60-day time frame. Procedures should be in place to ensure accurate claims are made timely. Recommendation: Policies and procedures should be implemented to ensure meals are claimed in compliance with federal requirements and within the 60-day time frame. Response: On January 30, 2023, the District requested a one-time waiver requests with DPI to claim the meals that were previously missed. The November 2021 breakfast claim was for $9,665 and the December 2021 lunch claim was for $23,751. DPI approved payment on the one-time exceptions in February 2023 and payments were made to the District in March 2023. The District will establish policies and procedures to ensure meals are claimed in a timely manner and in compliance with requirements. Contact Person: Robert Antholine, Phone number: 262-537-2211, Email: rantholine@randall.k12.wi.us Anticipated Completion: June 30, 2023

Summary Description - The School District?s food service fund net cash resources exceeded its three months average expenditures by $155,201.99. Corrective Action Plan - That the School District develop a plan to reduce the food service fund's net cash resources below its three (3) month average expenditures. Method of Implementation - Monitor net cash resources. Work with cafeteria staff and administration to identify and create plan to use funds on allowable purchases to reduce net cash. Person Responsible for Implementation - Mr. Matt Sheehan, Superintendent Estimate Completion Date - March 2023, ongoing.

Finding: During a review by the external auditors of the tally sheets utilized by the clubs for meals served and submitted to the finance department for input into the billing system used by the Department of Education (DOE) for reimbursement, it was discovered that an incorrect number of meals was keyed into the system for one club. The number of meals submitted was higher than what the club had originally reported and resulted in an overpayment received from DOE. Corrective Actions Taken or Planned: The organization, with oversight from Kay Ridgard, Controller, immediately contacted DOE and let them know of the error. DOE made the corrective adjustment in their system and recovered the overpayment by reducing the upcoming September 2022 payment due to the organization by the amount of the overpayment received. There was a complete review of the internal process used in the billing of DOE for meals for each location. The process for submission for reimbursement is outlined below with changes highlighted: 1. Tally sheets sent from the clubs are reviewed by the Accounts Payable Associate (Procurement Coordinator when hired) to ensure that there are no addition errors. 2. Numbers from the tally sheets are entered into an Excel file to give summary totals for the organization and this is used by the Accounts Payable Associate to input data into the DOE system. 3. The Controller (or Manager) reviews the excel file before the data is input into the DOE system to ensure it accurately reflects the tally sheets. 4. Data is input in the DOE system and reports are generated showing the accepted submission that will be reimbursed. 5. The Controller (or Manager) performs a second review to ensure the submitted data match the previously reviewed Excel file.

Finding 2022-002 ? Federal and State Findings and Questioned Costs Corrective Action Plan: Edit check reports from the district?s student information syste, Infinite Campus, will be provided on a monthly basis, no later than the 5th of the month for the preceding month. Any errors listed on the reports will be researched and corrected by the Food Service Director or Assisitant Food Service Director. After all meal sales errors are corrected the final reports will be provided to the Director of Business Services no later than the 10th of the month. These reports will be used to make the monthly federal (USDA) food service claims and retained as documentation for the claims. Person(s) Responsible: Director of Business Services and Food Service Director. Timing for Implementation: August 2022.

CORRECTIVE ACTION PLAN - JUNE 30, 2022 Finding 2022-002: Immaterial Compliance Federal Award Finding 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 persons responsible for the corrective action are Cathy Kierczynski, the food service director and Katy Xenakis-Makowski, Superintendent. 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. Condition: 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 USDA requires that the ending balance of the non-profit school food service fund does not exceed three months? average of operating expenses [7 CFR Part 210.14(b)]. Corrective Steps Taken: At this time, the District has a spend down plan in place with the State of Michigan to help alleviate the excess fund balance down to a reasonable level. Anticipated Completion Date: At the end of the 2022-23 Fiscal Year. Monitoring: The plan for monitoring adherence is the food service director and superintendent will work together to assess where the fund balance is after all of the projects from the spend down plan are completed. Name of Responsible Person for Further Information: Cathy Kierczynski, Food Service Director and Katy Xenakis-Makowski, Superintendent. Questioned Costs Related to this Finding: None.

Lakewood Public Schools respectfully submits the following corrective action plan for the year ended June 30, 2022. Auditor: Maner Costerisan 2425 E. Grand River Avenue, Suite 1 Lansing, MI 48912 Audit Period: Year ended June 30, 2022 District Contact Person: Pam Behling, Director of Finance The finding from the June 30, 2022 schedule of findings and responses are discussed below. The findings are numbered consistently with the number assigned in the schedule. Finding - Federal Award Findings and Question Costs 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: Management agrees with the finding and we are in the process of developing a plan to spend down the food service fund balance. Items being considered is improving outdated equipment and enhancing/expanding health food options. Date of Completion: The District?s spend down plan is anticipated to be completed by June 30, 2024. Kitchen equipment availability is severely limited due to national supply chain delays. The installation of this equipment is also limited based on times when school is not in session. These are the two primary factors why the District anticipates it will take multiple years in-order to complete its spend down plan.

Views of Responsible Officials and Planned Corrective Actions: Claims will be reviewed for accuracy by a second individual before they are submitted in the future. Also, the District reimbursed $37,145.07 to NDE in October 2022.

Corrective Action Plan: The Business Administrator will create a check list and monitor dates on an annual basis to ensure all requried deadlines are met. Responsible Individual: Business Administrator. Anticipated Completion Date: June 30, 2023.

Finding 2022-001 Federal Agency Name: U.S. Department of Agriculture Program Name: Child Nutrition Cluster Federal Financial Assistance Listing #10.555 Compliance Requirement: Preparation of Schedule of Expenditures of Federal Awards - Other Finding Summary: The High School does not have an internal control system designed to provide for the preparation of the Schedule of Expenditures of Federal Awards (Schedule). Eide Bailly, LLP was requested to assist with the preparation of the Schedule. Responsible Individuals: Brenda Wheeler, Business Manager Corrective Action Plan: It is not cost effective to have an internal control system designed to provide for the preparation of the Schedule and accompanying notes. We requested that our auditors, Eide Bailly LLP, prepared the Schedule and the accompanying notes as a part of their single audit. We have designated a member of management to review the drafted Schedule and accompanying notes. Anticipated Completion Date: Ongoing

FINDING 2022-002: CHILD NUTRITION PROGRAM - MEAL COUNTS (CODE 30000) Name of contact person: Becky MacQuarrie Corrective Action: The District will ensure the computations in our excel forms are correct and accurate. One site secretary will be in charge of creating and tallying the meal count excel document, and the second site secretary will ensure the numbers are accurate when entered into the CNIPS platform. Proposed Completion Date: March 8, 2023, immediately

Finding #2022-001 ? Overclaimed Breakfast Meals Served Child Nutrition Cluster ? Food Service Aid ? Breakfast (10.553) Federal Grantor ? U.S. Department of Agriculture Pass-through Award Number ? 2022-565100-DPI-SB-546 Pass-through Entity ? Wisconsin Department of Public Instruction Condition: The May 2022 breakfast claim was originally made for 12,564 more meals served than actually occurred. This resulted in the District being reimbursed $32,729 too much. Criteria: District should track and claim actual meals served during each month to eligible students. Cause: The District erroneously entered the number of lunch meals in as breakfast meals when reporting May 2022 breakfast meals. Effect: More meals were reimbursed than actually served in May 2022. This resulted in a $32,729 overpayment of federal aid. Context: When claiming meals for the month of May 2022, the District erroneously entered the incorrect number of meals for the breakfast claim. The error was identified by the District?s auditors in July 2022 during performance of the June 30, 2022 audit. After the auditors brought the matter to the attention of District management, the process immediately began to bring the matter to the Wisconsin Department of Public Instruction?s attention and to refund the overclaimed amount. Recommendation: Establish controls of review to ensure the correct number of meals are being reported each month. Response: The District will work to establish controls to ensure the correct number of meals are claimed each month. Contact Person: Kathy Stoltz Anticipated Completion: June 30, 2023

Finding 2022-001: Child Nutrition Cluster Resource Management 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 will develop procedures to ensure net cash resources are below the maximum allowable amount. Responsible Person and Anticipated Completion Date: School Business Manager, June 2023 If the Michigan Department of Education has questions regarding this plan, please call Mark Mesbergen at (231) 719-4102.

Finding 2022-001 ? Reporting The District concurs with the finding 2022-001. Corrective Action: The District will implement quality control procedures that will verify and confirm that monthly meal reimbursements and counts are correct prior to submission in CNMS Contact Person: Michael Brennan, Business Manager (518) 758-7575 ext 3009 mbrennan@ichabodcrane.org

Corrective Action Plan Details A. Contact person responsible for corrective action: Name: Marc Rowe Title: Executive Director B: Description of corrective action planned: The district will implement and strengthen its internal control systems over reporting and submitting its monthly claims for reimbursement to ensure claims are submitted within established reporting deadlines. C. Anticipated completion date of corrective action: June 30, 2023

CORRECTIVE ACTION PLAN: The management company for the Academy will work with the Academy leadership to increase expenditures in a manner necessary to spend down the excess fund balance in an allowable and timely fashion. The spend down plan will include improvements to the food service program, including adding an additional food service support position. The number of salad bar offerings and daily hot breakfast options will be increased for all grade levels. The Academy will also explore allowable options for spending funds on supplies, equipment and initiatives that will create sustainable improvements to the food service program for future years. RESPONSIBLE DEPARTMENT: Finance department and Food Service department. RESPONSIBLE PERSONS: Melinda Benkovsky, VP of Finance Gwen Hovey, Food Service Coordinator PLANNED COMPLETION DATE (TBD OR DATE): June 30, 2023

Planned Corrective Action The district Food Service Director will verify and print supporting documentation to prove system-generated reports reconcile to the CRRS System after data entry is completed. The Food Service Director will initial and date the reports upon completing and verifying the reconciliation. Anticipated Completion Date: 3/1/2023 Responsible Contact Person: Food Service Director

The District will include the SAM.gov check on all purchases made using Federal funds on a purchase order (PO). Supporting documentation will be retained. This verification will occur prior to any payment being made. The District will ensure that POs are signed by vendors/contractors indicating their non-suspended and non-debarred status, affirming their eligibility to participate in the procurement process.

Condition: Time records provided to support salaries and wages charged to the school lunch revolving fund were not approved by supervisory personnel. Corrective Action Planned: The District has implemented procedures utilizing time clock systems. The Administrative Assistant assigned to the Food Service Program reviews the system report to verify hours worked and absences. The report is then printed, reviewed and signed-off by the Food Service Manager prior to submitting the wage/hourly report to payroll. Anticipated Completion Date: January 2023 Contact: Ronald D. Tarro, Director of Business & Finance

Williamston Community Schools respectfully submits the following corrective action plan for the year ended June 30, 2022. Auditor: Maner Costerisan 2425 E. Grand River Ave., Suite 1 Lansing, Michigan 48912 Audit Period: Year ended June 30, 2022 District contact person: Sarah Tynan, CPA, Director of Finance The findings from the June 30, 2022 schedule of findings and responses are discussed below. The findings are numbered consistently with the number assigned in the schedule. Finding ? Federal Award Findings and Question Costs 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: Management agrees with the finding and we are in the process of developing a spend down plan. We are looking at expanding food choices, expanding healthy food options, as well as needed upgrades to equipment.

Finding 2022-003 ? Child Nutrition Cluster - Reporting Contact Person Responsible for Corrective Action: Tracy Wilson Contact Phone Number: 317-936-5444 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: All claims submitted for federal reimbursement will be reviewed prior to submission. Control will be put in place to verify entries to sales reports through CNC website and initialed by two parties to confirm accuracy over the process. Anticipated Completion Date: Effective Immediately

Corrective Action Plan: The District recognizes that due to increased reimbursement during the past few years, the District has an excess of cash on hand over the permitted levels. Over the course of the 2022-23 school year, the District will review the program needs to develop a strategy to utilize these funds by the food service program. It is anticipated that food costs will continue to rise, the excess funds will allow these increases to be absorbed by the food service program. In addition, we will assess any equipment needs for items directly serving the program. Every effort will be made to use these excess funds as effectively as possible. The assessment of equipment needs will be done in conjunction with a planned Capital Project scheduled for a public vote in December of 2022.

CORRECTIVE ACTION PLAN FINDING # 2022-005 Title of Finding Expenditure Approval Contact Person Christina Mayle, Connie Mundy, Julie Bibey Anticipated Completion Date 4/01/2023 Corrective Action planned to be taken: The Board has developed procedures to ensure that all federal grant invoices are approved by the appropriate director with signature and date before payment.

2022-005 Child Nutrition - Reporting Recommendation: School Corporation needs to update its policies and procedures related to the administration of the Child Nutrition Cluster to include a system of internal control that will mitigate the risk of noncompliance with the stated criteria related to recordkeeping. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Plainfield Community School Corporation will implement a policy that mitigates the risk of noncompliance with the required recordkeeping for the Child Nutrition Cluster. Name(s) of the contact person(s) responsible for corrective action: Kelly Collins Planned completion date for corrective action plan: April 2023