Corrective Action Plans

Findings and Questioned Costs Related to Federal Awards Finding Number: 2022-001 Program Name/Assistance Listing Title: Child Nutrition Cluster Assistance Listing Numbers: 10.559 Contact Person: Venessa Beecroft, Business Manager Anticipated Completion Date: June 30, 2023 Planned Corrective Action: The District will implement a tracking tool to ensure that all new hires return their work agreements as they are hired on throughout the year.

Views of Responsible Officials and Planned Corrective Actions: The District will implement a new process for calculating and accumulating total meal counts using Excel. The new meal count process will include the Cafeteria Lead and Business Manager doing comparison checks to ensure monthly totals are accurately reported.

2022-005 Reporting Federal agency: U.S. Department of Agriculture Federal program title: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.556, and 10.559 Pass-Through Agency: Minnesota Department of Education Pass-Through Number(s): 1-2908-000 Award Period: July 1, 2021 ? June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance Recommendation: We recommend that the District implement a policy to support the review and approval of CLiCs reports. Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Action Taken in Response to Finding: The District will implement a policy to have a review and approval process in place over the CLiCs reports. Name of the Contact Person Responsible for Corrective Action Plan: Kate Fernholz, Business Manager Planned Completion Date for Corrective Action Plan: June 30, 2023

Peck Community School respectfully submits the following corrective action plan for the year ended June 30, 2022. Auditor: Anderson, Tuckey, Bernhardt & Doran, PC 715 E Frank St Caro, MI 48723 Audit Period: Year ended June 30, 2022 District responsible individual to implement this plan: Shelley Bullis, Business Manager The finding from the June 30, 2022 schedule of findings and questioned costs are discussed below. The finding is numbered consistently with the number assigned in the schedule. Finding ? Federal Award Finding and Questioned Cost 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 making needed upgrades to equipment.

Management?s Response/Corrective Action Plan: The York School Nutrition Department followed recommended USDA & State guidelines to perform meal counting during the COVID 19 period with tick sheets. The data was entered into a spreadsheet so Whitney, the Nutrition Director, could apply for the funding. There were some data entry errors going from the manual sheet to the spreadsheet at the building level. Going forward we are back to using our POS system which declares a name with each and every meal, therefore meal counts are left to the computer system and error-free. We have corrected and moved forward in making sure we are claiming the meals on our sheets. As Tick Sheets are no longer allowable our entries are now accurate and will be moving forward as well.

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 Tricia Connell, 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.

Corrective Action Plan Yeshiva of Phoenix This corrective action plan is in response to the audit conducted by Price Kong. There were some items that were requested for the audit that we did not have receipts or backup. From now on: - We will not issue any reimbursement without a receipt to match. - We will require receipts for all purchases made with school funds. If we do not get receive a receipt we will send text messages and phone the purchaser/merchant until we do. If we still do not receive a receipt we will bill the purchaser for the item. - All receipts will be scanned and then matched to the purchase when we do the monthly reconciliation. - Any payroll change will be documented in writing, preferably signed by both parties. Alternatively, an email will be sent to both parties documenting the change. The email will be filed and stored. - Any new employee will receive a contract or an email confirming their salary. - In addition to storing our bank statements, we will also keep a digital record of any checks that we receive, and we will match these checks to our accounts. - We will keep formal minutes of all board meetings. These minutes will be distributed to all board members and stored. - We will request an updated depreciation schedule from our accountant every year. - We will meet with an accountant from Price Kong who will help us establish a formal accounting manual so that we will have set standards for all bookkeeping. Thank you for conducting the audit for us. Gaby Friedman, Vice President On behalf of Yeshiva of Phoenix.

CORRECTIVE ACTION PLAN Corrective Action Plan (CAP) Name of Auditee: Allentown School District Auditee Identi?cation Number: 23-6003488 Name of Audit Firm: Zelenkofske Axelrod LLC Period covered by Audit: July 1, 2021 ? June 30, 2022 CAP prepared by: Diane Richards, Chief Financial Of?cer Telephone number: 484-765-4011 A. Current Finding on the Schedule of Finding, Questioned Costs, and Recommendations: 1. Of the 25 expenditures selected for testing, 11 expenditures were not properly approved a. Action(s) Taken or Planned on the Finding The School District agrees with the ?nding and is working towards implementing better controls in the Child Nutrition Services Department. b. Name and Title of the person responsible for resolution: Gina Giarratana, Director of Student Nutrition c. Anticipated completion date: July 1, 2023 2. Of the 25 employees selected for testing, 1 employee did not have proper clearances. a. Action(s) Taken or Planned on the Finding The School District agrees with the ?nding and is working towards implementing better controls in the Human Resources Department. b. Name and Title of the person responsible for the resolution: William Seng, Executive Director of Human Resources c. Anticipated completion date: July 1, 2023

Finding #2022-001- Segregation of Duties (Prior Year Finding #2021-001) Condition: A properly designed system of internal control includes adequate staffing, policies, and procedures to properly segregate duties. This includes systems that are designed to limit access or control of any one individual to your government?s assets, and to achieve a higher likelihood that errors or irregularities in your processes would be discovered by your staff. There are key controls related to significant transaction cycles that are important in reducing the risk of errors or irregularities. At this time, the District does not have the following controls in place: -Persons processing accounts payable are not always separate from those ordering or receiving goods or services. -Persons initiating electronic fund transfers are not separate from those authorizing, confirming, or reconciling the transactions. -There are no procedures in place for review and approval of new vendors. -Persons preparing the payroll also maintain employee records, change employee rates, and change data in the payroll system. -The person reviewing free and reduced food service eligibility can also modify information entered into the system to determine eligibility. -Account reconciliations are not performed by someone independent of the processing of transactions in the account. Effect: Errors or intentional fraud could occur and not be detected timely by other employees in the normal course of their responsibilities as a result of the lack of segregation of duties. Cause: Limited number of personnel. Criteria: Segregation of duties is an aspect of internal control intended to prevent or decrease opportunities of intentional and unintentional errors and fraud. Duties and responsibilities are properly segregated if no single individual either has control over all phases of a transaction or has the ability to both make and conceal an error, whether such error is intentional or unintentional. Recommendation: We recommend that the District consider the benefits of implementing additional policies and procedures to address key controls related to its significant transaction cycles as noted. Response: We agree with this finding but do not believe it is cost effective to increase the office staff in an attempt to bring about a more effective segregation of duties. The Building Principals and the Business Manager approve purchase orders and the Business Manager approves monthly accounts payable checks. Also, the Building Principals or department supervisors approve payroll timesheets prior to processing payroll. The payroll along with the time sheets are then approved by the Business Manager. The Business Manager, Building Principals, and department supervisors will continue to monitor transactions of the District. Contact Person: Greg Benz Anticipated Completion: Not applicable

UNITED STATED DEPARTMENT OF EDUCATION Education Stabilization Fund? 84.425D/84.425W Corrective Action Plan ? Noncompliance with Reporting Requirements Finding No.: 2022-004 Condition: The District has inadequate controls over reviewing and approving quarterly ?historical expenditure reports? filed with the Illinois State Board of Education. Plan: The superintendent will review and approve quarterly ?historical expenditure reports? and supporting documentation on a regular basis prior to electronic submissions. Corresponding documents will be manually signed and dated to indicate approval. Anticipated Date of Completion: January 1, 2023 Management Response: The District intends to implement the recommendations in FY 2023. Name of Contact Person: Michelle Meese, District Superintendent (P): 618-592-3933

UNITED STATED DEPARTMENT OF AGRICULTURE Child Nutrition Cluster ? 10.553/10.555/10.559 Corrective Action Plan ? Noncompliance with Reporting Requirements Finding No.: 2022-003 Condition: The District has inadequate controls over reviewing and approving child nutrition monthly ?claims summary? forms. Plan: The administrative assistant will prepare the ?claims summary? forms by obtaining the number of meals served directly from the "Food Service: Reimbursement" reports on Skyward?s website. The Treasurer or Superintendent will also review the "claims summary" forms and supporting documentation for accuracy prior to the electronic submissions. Corresponding documents will be manually signed and dated to indicate approval. Anticipated Date of Completion: January 1, 2023 Management Response: The District intends to implement the recommendations in FY 2023. Name of Contact Person: Michelle Meese, District Superintendent (P): 618-592-3933

10.558 Child and Adult Care Food Program Allowable Cost 2022-027 Strengthen Controls to Ensure Compliance with Allowable Costs Requirements of the Child and Adult Care Food Program (CACFP). Response: The MDE does not concur with this finding. The OSA did not identify weaknesses in the MDE subrecipient monitoring process, such as in the selection of organizations, the monitoring cycle, or monitoring procedures. Instead, OSA identified potential errors made by individual participating organizations. The MDE has a robust system of internal controls and subrecipient monitoring system for the CACFP. In addition to meeting USDA requirements for monitoring, the MDE Office of Child Nutrition (OCN) also employs a risk -based process to select CACFP subrecipients for review and to determine the scope of monitoring. The MDE routinely exceeds the USDA requirement to monitor 33.3% of participating organizations annually. For Program Year (PY) 2021-2022, 60.3% of participating organizations were reviewed to provide additional oversight of subrecipients. When the MDE identifies instances of noncompliance, it requires participating organizations to take appropriate corrective action. For organizations that are very high-risk, the MDE employs the USDA Serious Deficiency process in accordance with 7 C.F.R. 226.6. The MDE already has a process to recover funds from an organization if an error is discovered during subrecipient monitoring. In PY 2022, the MDE assessed $132,207 in repayments of USDA funds and required an additional $40,577 in unallowable costs to be returned to local CACFP accounts. Finally, MDE staff was not included in the reviews of subrecipients by OSA, so the MDE was unable to verify the accuracy of the proposed unallowable costs before publication of the report from OSA. MDE staff will need to review documentation from OSA, and source documentation retained at CACFP sites before it can make a final determination regarding the potential unallowable cost determinations against sponsors. Corrective Action Plan: A. The MDE will review documentation provided by OSA of potential questioned costs and review source documentation held by the subrecipients to determine the amount of unallowable costs. If confirmed, the MDE will recover any unallowable costs in accordance with USDA policies. This review will be completed by January 22, 2024. Susie Evans, CACFP Director for the MDE OCN, will oversee the review. B. The MDE will continue to assess its CACFP monitoring and continue to strengthen the process while remaining in compliance with USDA regulations.

October 29, 2022 Schedule of Findings and Questioned Costs Corrective Action Plan For: 2022-001 ? Excess Fund Balance in Food Service Condition: As of year-end the District had a fund balance in the non-profit food service fund in excess of three months? operating expenses by approximately $213,867.22. Corrective Action to Be Taken: The District is updating their Spenddown Plan for the excess fund balance. The Food Service Director and the Assistant Superintendent have already identified areas where there are needs for upgrades or enhancements needed. Over the next few months the Excess Fund Balance will get used to improve the Food Service Program. Responsible Parties for Implementation of Corrective Action: Food Service Director with follow up by the Assistant Superintendent. Date of Anticipated Completion of Corrective Action: The corrective action plan was immediately implemented during the fall of 2022. Sarah M. Glann Assistant Superintendent

2022-002 The District has insufficient procedures in place to ensure all long term liability and related expense transactions were properly recorded. Material adjustments were needed for the District's financial statements. See response and corrective action plan at 2022-002.

2022-001 The District has insufficient segregation of duties over the receipts and disbursements process. See response and corrective action plan at 2022-001.

FINDING 2022-002 Contact Person Responsible for Corrective Action: Food Service Director Billie Jo Russell Contact Phone Number: 812-755-4872 Views of Responsible Official: We concur with the finding Description of Corrective Action Plan: Procurement ? The School Corporation has established internal controls to ensure compliance with the grant agreement and the Procurement and Suspension and Debarment requirement. The Food Service Director will obtain information from the Wilson Service Center for any necessary documentation pertaining to this requirement. The School Corporation has procured any food and supply purchases that exceed $150,000 and will maintain documentation for procurement procedures for purchases under $150,000. Suspension/Debarment ? Procedures will be implemented to ensure our procurement agent is an approved procurement agent. Anticipated Completion Date: Immediately

Views of responsible officials and Corrective Action Plan: The School will implement an additional internal control to review the reimbursement meal claim to underlying support prior to submission, with evidence of review.

Corrective Action: We will be creating universal tick sheets for the elementary and secondary schools. The internal control will be more manageable when we make this change. The tick sheets will be on separate sheets for breakfast and lunch and there will be a signature line on each sheet in order to identify the employee that ticked during the meal. All Student Nutrition employees will be instructed to use the standardized tick sheet and will be advised not to make any change to the form. Due Date of Completion: December 31, 2022 Responsible Party: Director of Student Nutrition

We will contact DESE for guidance regarding this matter and implement proper controls over program expenditures. Misti Flowers, District Treasurer June 1, 2023 Action Started June 30, 2023 Action completed

School District No. 27-0595, North Bend, Nebraska, respectfully submits the following corrective action plan for the year ended August 31, 2022. Name and address of independent public accounting firm: Romans, Wiemer & Associates, Certified Public Accountants, P.C., 1910 N Lincoln Ave, York, NE 68467 Audit Period: September 1, 2021 through August 31, 2022 The findings from the November 3, 2022 schedule of findings and questioned cost are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS ? FINANCIAL STATEMENT AUDIT MATERIAL WEAKNESS 2022-001 Internal Control Structure Design Recommendation: While considering the cost of any benefits derived, activities should be segregated and handled by different employees. Action Taken: The cost of implementing a complete set of controls far outweighs the benefits derived by such. It is not financially feasible to have a complete set of controls. FINDINGS ? FEDERAL AWARD PROGRAM AUDIT Nebraska Department of Education 2022-002 Internal Control Structure Design Recommendation: While considering the cost of any benefits derived, activities should be segregated and handled by different employees. Action Taken: The cost of implementing a complete set of controls far outweighs the benefits derived by such. It is not financially feasible to have a complete set of controls.

Corrective Action Plan and Views of Responsible Officials The District will continue to implement the following procedures, which were initially put in place in December of 2021, after the meal counting error was identified in October of 2021: 1. Site Numbers will be collected via a clicker counter or tally sheet. This information will be documented on paper and sent to the Claim Preparer to verify and ensure accuracy. 2. The data from the counters and Tally sheet will be entered into the back-office Point of Sale software system instead of a spreadsheet. 3. Monthly reports will be generated when creating the claim and an Edit Check will include auditing daily participation numbers to ensure days have not been skipped. 4. The claim will be entered in CNIPS following standard ?Meal Counting & Collecting Procedures? as approved by the State. Implementation Date: Fiscal Year 2021-2022

U.S. Department of Agriculture: Octorara Area School District respectfully submits the following corrective action plan for the year ended June 30, 2022: Name and address of independent public accounting firm: Herbein + Company, Inc. 2763 Century Boulevard Reading, PA 19610 Audit Period: Year ended June 30, 2022 Anticipated Completion Date: December 31, 2022 Contact Person: Jeff Curtis, Business Manager Finding - Federal Award Findings and Questioned Costs 2022-001 ALLOWABLE ACTIVITIES - SIGNIFICANT DEFICIENCY Federal Program Child Nutrition Cluster COVID-19 - National School Lunch Program ALN 10.555; passed through the Pennsylvania Departments of Education and Agriculture; Grant Period 7/1/21-6/30/22 COVID-19 - School Breakfast Program ALN 10.553; passed through the Pennsylvania Department of Education; Grant Period 7/1/21-6/30/22 Criteria Title 7 CFR 210 covers the reimbursement process under the Child Nutrition Cluster. It requires the submission of claims for reimbursement that include the number of reimbursable meals served by category and type during the period (generally a month) covered by the claim. As a subrecipient of funds passed through the Pennsylvania Department of Education (PDE), Octorara Area School District must submit monthly claim forms to PDE, which include the number of reimbursable meals served by category (free, reduced, paid) and type (breakfast, lunch). Condition/Cause The District manually inputs the amount of meals served by location into a spreadsheet in order to obtain totals to type into the monthly claim reimbursement form. A data input error, failing to include a location in the spreadsheet for certain days, led to an incorrect number of meals reported on one claim report from our sample. Controls in place over claim reporting did not detect and correct this error before submission. Effect As a result of the claim report not being filed accurately, the District lost approximately $730 of federal subsidies that would have been received if the correct meal count was used. Questioned Costs Less than $25,000 Context We examined 4 of the monthly reimbursement claim reports submitted during the year by the District and noticed the deviations noted above in one of those reports. Total subsidy revenue for the District for the year ended June 30, 2022 was $981,173. Had the District filed an accurate claim report for the month noted above, subsidy revenue would have been $981,903. The lost revenue is 0.074% of total federal subsidy revenue for the year. No statistical sampling was used in our testing. Repeat Finding No. Recommendation We recommend that the District revisit the current procedure for verifying accuracy of meal counts prior to claim submission for areas where the control could be strengthened. The review should include comparison of the report to meal count reports for all locations to verify accuracy. The review should also include a comparison to prior monthly reports for reasonableness. We recommend that the reviewer initial the report draft or otherwise maintain support of this review. Management Response The Food Service management team will enhance their current procedure to include the recommendations listed in this corrective action plan. Meal count hard copy reports by location will be submitted to the Food Service Supervisor each month to be tallied and compared to the meal count summary reports in the PrimeroEdge management system. The Supervisor will also confirm that hard copy reports are received for each group of students at each location and will initial the reports after the review. After confirmation from the Supervisor, that all locations are accounted for and the totals are correct, The Food Service Director will review the reports to ensure that the total meal counts are reasonable by comparing the reports to prior monthly reports adjusted for differences in the number of days in each month. Jeff Curtis, Business Manager

Nutrition services is aware of the excess funds and will be filing a spend down plan with Michigan Department of Education as soon as officially notified. The Director in conjunction with Maintenance and Finance has identified necessary improvements to equipment and has formulated a plan to substantially spend the excess funds within the next fiscal year pending approval from the State.

Finding Summary: During the course of our engagement, we noted instances where documentation was not retained supporting payroll expenditures and invoices were paid in an incorrect amount that was charged to the federal Child Nutrition Cluster program. Responsible Individuals: Shane Monson, Superintendent. Corrective Action Plan: The District will review and strengthen the controls surrounding the review and approval of allowable costs to ensure they are supported, approved of, and calculations are accurate. Anticipated Completion Date: June 30, 2023

Finding Number: 2022-013 ? Activities Allowed or Unallowed and Allowable Costs/Cost Principles Corrective Action Plan: A process has been put in place for the school principal to review all RFRs prior to submission to the grantor. Approval is evidenced by email sent by principal to the Director of Grant Management, which is saved with the RFR as support. Responsible Individuals: Nachum Golodner, Director of Accounting Anticipated Completion Date: June 30, 2023