Corrective Action Plans

Corrective Action: Foodbank agrees with the finding and has implemented a process to properly and accurately account for incoming USDA Foods. In March 2021, Foodbank approved the purchase of software that was designed specifically for food banks to help them account for food receipts and distributions, as well as the physical inventory accounting required for food banks. Changes in personnel delayed the full implementation of the software, which is expected to be completed by February 28, 2023. Name of Contact Person: Jeanne Cooper, President Proposed Completion Date: February 28, 2023

2022-001. Internal Control Over Compliance United States Department of Education, passed-through New York State Department of Education: Special Education Cluster Special Education Grants to States ALN: 84.027A Special Education Grants to States: IDEA 611 ARP Allocations ALN: 84.027X Special Education Preschool Grants ALN: 84.173A Special Education Preschool Grants: IDEA 619 ARP Allocations ALN: 84.173X Education Stabilization Fund (ESF) COVID-19: Governor?s Emergency Education Relief (GEER) Fund ALN: 84.425C COVID-19: Elementary and Secondary School Emergency Relief (ESSER) Fund ALN: 84.425D COVID-19: American Rescue Plan ? Elementary and Secondary School Emergency Relief (ARP ESSER) Fund ALN: 84.425U Condition: The District has not updated its existing policies and written procedures to conform to Uniform Guidance requirements. Planned Corrective Action: The District will update its existing policies and written procedures to conform to Uniform Guidance requirements. Responsible Contact Person: Dr. Rodney Asse - Assistant Superintendent for Business Riverhead Central School District 814 Harrison Avenue - Riverhead, New York, 11901 Anticipated Completion Date: The District adopted a Federal Funds Procedural Manual on January 24, 2023.

Response and Corrective Action Plan: The District will update the annual calculation to include a comparison of the base used for the indirect cost adjustment.

THE ORGANIZATION WILL MAINTAIN AND DOWNLOAD THE EXCLUSIONS EXTRACT DATA PACKAGE FROM SAM.GOV WEBSITE VERIFYING THAT VENDORS PAID OVER $25,000 ON A FEDERAL GRANT WERE NOT INCLUDED IN THE PACKAGE. WE WERE NOT ABLE TO COMPLETE THE CORRECTIVE ACTION PRIOR TO JUNE 30, 2023, AS THIS FINDING WAS JUST BROUGHT TO OUR ATTENTION. ANTICIPATED CORRECTIVE ACTION PLAN COMPLETION DATE: JUNE 30, 2024. FOR ADDITIONAL INFORMATION REGARDING THIS FINDING PLEASE CONTACT ROSANA MATEO.

FINDING 2022-004 Subject: Child Nutrition Cluster ? Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children Assistance Listing Number: 10.533, 10.555, 10.559 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 Child Nutrition Program and Procurement and Suspension and Debarment compliance requirements. Context: The School Corporation utilizes a purchasing cooperative to procure its key vendors for food service costs, however in some cases the School Corporation will handle their own additional procurements outside of the purchasing cooperative. During the audit period, there were three vendors for which the School made purchases between $10,000 and $150,000, which fell under the small purchase method for federal and state procurement regulations. For the one vendor selected for testing, documentation was not presented to verify methods or rationale used to satisfy the procurement requirements, which require three quotes to be obtained prior to entering into a transaction. Additionally, the School Corporation was not able to provide verification that the vendor is not suspended or debarred. Description of Corrective Action Plan: The treasurer and food service director will work together to check suspension and debarment on any vendor receiving school funds in the amount of $25,000 and over. This information will be reviewed and checked at the beginning of each school year and as needed with new vendors. Responsible Party and Timeline for Completion: Jennifer Blakley, Treasurer and Jenny Dunning, Food Service Director ? this information was reviewed and printed from the SAM government website on 3/21/23 and will be kept by the food service director. This will be completed at the beginning of each school year and potential new vendors will be checked prior to becoming active.

FINDING 2022-003 Subject: Child Nutrition Cluster ? Reporting Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY2021, FY2022 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: 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: We noted that for one claim in a sample of four, 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. Description of Corrective Action Plan: The food service director will have the treasurer, deputy treasurer, or an administrator review and sign off on the sponsor claim reimbursement summary prior to submission. Responsible Party and Timeline for Completion: Jenny Dunning, Food Service Director ? this will be implemented immediately following the audit in March 2023.

FINDING 2022-003 Information on the federal program: Subject: Child Nutrition Cluster ? Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program, Summer Food Service Program, Fresh Fruits & Vegetables Program Assistance Listing Numbers: 10.553, 10.555, 10.559, 10.582 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Allowable Costs/Cost Principles Audit Finding: Significant Deficiency 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 Allowable Costs/Cost Principles compliance requirements. Context: During testing of 10 payroll disbursements for allowable costs/cost principles, we noted there was one instance where the timecard for the Food Services employee displayed 79 total hours of normal pay and one hour of overtime for the two-week period. We reviewed the payroll distribution report for this time period and note that the employee was paid for 69.5 hours of normal pay and 10.5 hours of overtime. Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We will verify that the number of hours and pay rate per the payroll register agrees to the hours worked by the employee per their reviewed time sheet and their respective rate of pay. Responsible Party and Timeline for Completion: April 01, 2023

FINDING 2022-002 Information on the federal program: Subject: Child Nutrition Cluster Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program, Summer Food Service Program, Fresh Fruits & Vegetables Program Assistance Listing Numbers: 10.553, 10.555, 10.559, 10.582 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: We noted that for four claims in a sample of four, the meal counts were overclaimed for the month. We noted that in October 2020, the School Corporation had overclaimed lunches by 823 meals and breakfast by 512 meals, in April 2021, had overclaimed lunches by 210 meals and breakfast by 58 meals, in October 2021, had overclaimed lunches by 90 meals and breakfast by 632 meals, and in April 2022, had overclaimed breakfast by 984 meals and fresh fruits and vegetables by 114. Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We will verify that each claim has been reviewed by a secondary person for accuracy and that the claim agrees to underlying detail for meals served. Responsible Party and Timeline for Completion: April 01, 2023

Finding 2022-001 ? Child Nutrition Cluster -Activities Allowed or Unallowed, Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Mr. Patrick Culp, Superintendent Contact Phone Number: 219-279-2418 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Tri-County School Corporation will establish a documented review of all Child Nutrition Cluster account payable claims before they are paid. Anticipated Completion Date: March 29, 2023

The District will evaluate all aspects and needs of the food service program including personnel, equipment such as stoves, freezers, etc. and determine the best and legally proper use of the excess funds.

We have been and are budgeting to spend more money in 2023 than we have collected or will collect in revenues. We are anticipating a deficit in 2023 for the Child Nutrition Program. This will cause our Net Cash Resources to decrease.

The District is aware of this deficiency and continues to take steps to ensure safeguarding of relevant compliance documentation with respect to federal awards. The District feels the finding for this year is an anomaly and does not expect this condition to continue in the future.

Finding/Recommendation Number - 1; Finding - Net Food Service cash resources did exceed three months average expenditures; Corrective Action - Reduce Net Food Service cash resources to a level that does not exceed three months average expenditures; Method of Implementation - The district will purchase various kitchen and serving area equipment, make upgrades or repairs to existing equipment and serving stations, make improvements to student dining areas; Individual Responsible for Implementation - Business Administrator and/or designee; Completion Date of Implementation - June 30, 2023 and ongoing.

Management will review time and effort documentation requirements with applicable employees.

Response and Corrective Action Plan: The District will review current processes to routinely reconcile the point of sale system and the general ledger. Kevin Posekany, June 30, 2023

2022-002 Condition and Criteria: The U.S. Department of Agriculture regulation located at 7 CFR Part 210, Subpart C, Section 210.14(b) states that the food service fund is to limit its net cash resources to an amount that does not exceed 3 months average expenditures. The cash and due from other funds balances in the Academy's food service fund exceeded the allowable amount at June 30, 2022. Cause: While the appropriate Academy employees were aware of the applicable compliance requirements, the Academy did not spend the necessary amount to reduce fund balance to the allowable limit. Effect: Noncompliance with the requirements of the Code of Federal Regulations. Recommendation: The Academy should develop and implement a plan to reduce its net cash resources to the allowable limit. Management Response: The The Academy through its management company has developed processes to ensure all costs related to the operation of the food service fund are properly recorded. Additionally, the Academy subsequent to year, made significant purchases to upgrade the kitchen equipment further spending the necessary amount to reduce the fund balance to the allowable limit.

FINDING 2022-004 Subject: Child Nutrition Cluster ? Activities Allowed or Unallowed, Allowable Costs/Cost Principles Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program, After School Snack Program, Summer Food Service Program for Children Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY2021, FY2022 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Findings: Material Weakness Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with the requirements related to the grant agreement and the Activities Allowed or Unallowed and Allowable Costs/Cost Principles compliance requirements. Context: The School Corporation had not designed or implemented adequate internal controls to ensure that payroll disbursements were only for food service-related services. Payroll disbursements comprise approximately 45% of the program costs charged to the Child Nutrition Cluster. One employee was responsible for processing payroll. Payroll reports were submitted to the School Board and Treasurer for review and approval; however, the reports only provided a total gross amount paid from each fund. The reports did not list the employees who were paid from the fund. In March 2021, the Treasurer implemented a review of the payroll distribution report, which is broken out by fund and individual employee. The lack of controls related to payroll disbursements was isolated to the 2020-21 year. Additionally, payroll disbursements for custodial employees were allocated to the Child Nutrition Cluster based on a percentage of the custodial employees? salaries. However, there were no time and effort logs or other documentation maintained to support the percentage of the custodial salaries allocated to the Child Nutrition Cluster. The custodial salaries make up approximately 3% of the total payroll disbursements charged to the Child Nutrition Cluster. This was an issue throughout the audit period. Views of Responsible Officials and Planned Corrective Actions: We concur with the finding. Description of Corrective Action Plan: The NJ-SP School Corporation will implement internal controls to ensure compliance with the activities allowed or unallowed and allowable costs/cost principles compliance requirements. This will consist of maintaining documentation to support that payroll disbursements are only for food service operating costs by having supporting timesheets and timecards or time and effort reports for all employees paid from the School lunch fund. These controls will be implemented by July 1, 2023. Responsible Party and Timeline for Completion: Dalton C. Tunis ? Corporation Business Manager/Treasurer Anticipated Completion Date: July 1, 2023

Finding 2022-004 Contact Person Responsible for Corrective Action: Rhonda Morgan, FSD Contact Phone Number: 765-240-2386 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Frontier School Corporation will have the Elementary and Jr/Sr High Kitchen Managers pull the monthly reports from eTrition for breakfast and lunch meals served for their respective schools. A blank Monthly Worksheet will be provided to each Kitchen Manager to be filled out using the data report from eTrition, the foodservice software. The reports and worksheets from each school will be given to the Food Service Director. The FSD will have independently prepared a complete report using data pulled from eTrition including both schools. The FSD will then compare the elementary Kitchen Manager?s report with the Master Report. The FSD will then compare the Jr/Sr High Kitchen Manager?s report with the Master Report. The Master Report will then be presented to each Kitchen Manager for their approval after checking to see that the data matches, initialing and dating the Master Report. The Food Service Director will then submit the Monthly Claims Report to CNPweb. The Corporation Treasurer will also have access to all data collected to ensure proper reportig. All data and internal checks will be filed in the Food Service Director?s office.. Anticipated Completion Date: The CAP will be in place by March 24, 2023 in preparation for the Monthly Claim of March 2023 to be the first month these internal controls will be implemented.

2022-004 Child Nutrition Cluster (10.55X) Condition and Cause: The District was required to verify one application for program eligibility and properly report results. During our review, the District did not properly update the School Food Authority Verification Collection Report for 2021-2022 based on the results of the verification sample. Criteria: By November 15th of each school year, the District 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. Results of this verification must be properly reported in the School Food Authority Verification Collection Report. Effect: Because of improper reporting, the District?s verification report did not accurately reflect the results of the verification sample. In addition, the District could be inaccurately providing free or reduced lunches to students. Auditor?s Recommendation: The District should review the federal requirements for completing verification of applications to ensure that future verifications completed by the District are complete and appropriate and properly report on the verification report. Grantee Response: A new process will be put in place for future income verifications to ensure the entire verification process will be completed accurately and timely. Contact Person: David Boland Anticipated Completion: On-going

FINDING 2022-002 Contact Person Responsible for Corrective Action: Cortney Parrish, Corporation Treasurer Contact Phone Number: 765-240-2346 Views of Responsible Official: We agree with the finding Description of Corrective Action Plan: As of fiscal year 2022, the School Corporation no longer pays teachers or aides from the School Lunch Fund, with the exception of one teacher being paid from the School Lunch Fund until December of 2022. As of January 1, 2023, only cafeteria employees are paid from the School Lunch Fund. Anticipated Completion Date: Completed

Finding 2022-004 ? Child Nutrition Cluster - Reporting Contact Person Responsible for Corrective Action: Melissa Dempsey Contact Phone Number: 812-546-2000 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The School Lunch reimbursement claims will be reviewed by a secondary individual prior to submission to IDOE and signed off on to document the review. Anticipated Completion Date: April 2023

Finding 2022-003 ? Child Nutrition Cluster - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Melissa Dempsey Contact Phone Number: 812-546-2000 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The School Corporation will establish a documented review of all Child Nutrition Cluster account payable claims before they are paid. Additionally, the School Corporation will transfer funds to replenish the school lunch fund. Anticipated Completion Date: June 2023

Department of Agriculture Finding 2022-001: Child Nutrition Cluster Resource Management Procedures Pass-through entity: Michigan Department of Education Assistance Listing Number: 10.553, 10.555, and 10.559 Award Numbers: COVID-19 211971, COVID-19 221971, COVID-19 211961, COVID-19 221961, COVID-19 210904, COVID-19 220904, and Entitlement Commodities Award Year End: June 30, 2022 Recommendation: The School District should continue its spend-down plan to ensure it reduces its Food Service Fund net cash resources below the maximum allowable amount. Action Taken: The School District has ordered equipment totaling approximately $390,000 that was not received by June 30, 2022. Once the equipment is received and paid for the School District will be in compliance with this requirement. Responsible Person and Anticipated Completion Date: Director of Finance, June 30, 2023 If the Michigan Department of Education has questions regarding this plan, please call Todd M. Hronek at (231) 788-7100.

The District will continue to file reimbursement for all meals served in the fiscal year.

Name of Contact Person Susan Pougher spougher@lysd.org 907-591-2411 Corrective Action Plan Finding 2022-001 Significant Deficiency in Internal Control Over Compliance - Reporting Corrective Action Plan The Director of Food Service gathers site meal count sheets, and separates by site. The Food Service Director will then perform a count for the month for each site. A second person will review the count sheets separated by site. The second person will prepare a count for the month for each site. The two separate monthly meal count sheets will be compared, and any count discrepancies will be identified and resolved. Once the two count sheets are in alignment, the period will be submitted to the state for reimbursement. Expected Completion Date June 30, 2023