Corrective Action Plans

Finding 2022-001: 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: As of September 14, 2022, the School District has received items ordered prior to the fiscal year ended June 30, 2022 and will also develop and implement a spend-down plan to reduce the Food Service Fund net cash resources below the maximum allowable amount. Responsible Person and Anticipated Completion Date: The Superintendent will ensure the spend-down plan has been accomplished by June 30, 2023. If the Michigan Department of Education has questions regarding this plan, please call Paul Shoup at (231) 757-3733.

Reporting 2022-002 Significant Deficiency in Internal Control over Compliance Condition/context: During the audit of the School's, we noted that the School is maintaining excess reserve levels without an appropriately approved spending plan in place Auditors? Recommendation: Management should perform quarterly reviews of their reserve levels and modify their expenditure patterns to ensure reserves are maintained within approved limits. The required approvals should be obtained from the funder to expend excess funds. Management?s Response: The Organization had earmarked the reserve funds for the purchase of additional kitchen equipment associated with its new high school. Due to permit delays the opening of the high school was delayed by a year. Management anticipates that the excess funds will be spent during fiscal year 2023 and the Organization will be within the 90-day reserve level.

Reporting 2022-001 Significant Deficiency in Internal Control over Compliance Condition/context: During our audit of the School's major programs, we detected certain deficiencies in internal control over compliance. The School submitted vouchers for September 2021 and October 2021 late. The submission exceeded the required 60 days following the last day of the month covered by the claim. The September 2021 voucher could not be accessed and verified by auditors. Auditors? Recommendation: Management should maintain a checklist of all specific due dates associated with Uniform Guidance (?UG?) compliance, including credential renewals, voucher submissions, UG report due date, and other reporting requirements. Management?s Response: Management is aware of the reporting deadlines associated with voucher claims. Unfortunately, a staff member left the Organization and failed to file the annual renewal report, which resulted in the Organization being locked out of the vouchering system. The Organization immediately filed to renew but due to the time it took for the renewal process the September and October vouchers were filed beyond the reporting deadline. This has been rectified and procedures have been implemented whereby the Organization CFO reviews the renewal application to ensure timely filing.

Child Nutrition Cluster ? Segregation of Duties ? Grant Reporting Recommendation: We recommend that the District implement a review process over the reporting requirements related to the Child Nutrition Cluster Explanation of Disagreement with Audit Finding: There is no disagreement with this finding. Action Planned/Taken in Response to Finding: The District will implement a process by which the monthly grant reports are approved by a secondary position prior to submission. Name of the Contact Person Responsible for Corrective Action: Rod Huther, Business Manager Planned Completion Date for Corrective Action Plan: 12/15/2022

UNITED STATES 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 Manual ?Meal Count Edit Form?. The 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: Jon Julius, District Superintendent (P): 217-932-2184

Views of responsible officials and planned corrective actions: The District will implement procedures in the 22-23 fiscal year to correct this compliance issue. District staff will follow procedures to verify that the District is not using vendors who are either suspended or debarred by the federal government, using the SAM.gov website. The following language has been communicated to CUSD staff and added to the District?s Business Users Guidelines Document. To process a requisition using Federal Monies (resource codes 3000-5999), staff shall perform the following procedures: Non-federal entities are subject to the non-procurement debarment and suspension regulations. These regulations restrict awards, sub-awards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities (2 CFR 200.213). To check if a vendor is disbarred or suspended: a. Go to the website at www.sam.gov (you do not need to register). b. Verify the status of the vendor by performing the following: ? Click on the search records icon on the top left. ? Use the "quick search" box and enter the vendor's name (leave remaining classifications blank) c. Click search at the bottom of the web page. d. Print a copy of the search results including if results were not found. e. If the vendor is not debarred, note on the requisition and / or contract if applicable, that the vendor has been checked in the SAM system and is not debarred. Include a copy of the printed page with the requisition. f. If a vendor search produces no results, print the page and attach as supporting documentation to the requisition. Note on the requisition and / or contract is applicable that the vendor has been checked in the SAM system. ? The District is prohibited from doing business with a vendor or individual that is debarred or suspended.

Child Nutrition Cluster Procurement Segregation of Duties Child Nutrition Cluster ? Assistance Listing No. 10.553, 10.555, 10.559 Recommendation: CLA recommends the District review its procurement process to ensure that there is adequate segregation of duties in regards to initiating, authorizing, reviewing for grant allowability and approving micro purchases, along with adding controls to ensure that the item purchased was received by the District. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We continue to look for ways to segregate duties and will improve on the review process for grants but with the current financial situation, additional staff cannot be added. Name(s) of the contact person(s) responsible for corrective action: Lisa Miller Planned completion date for corrective action plan: Ongoing

Child Nutrition Cluster Reporting Child Nutrition Cluster ? Assistance Listing No. 10.553, 10.555, 10.559 Recommendation: CLA recommends the District implement a review procedure over reimbursement requests where someone other than the preparer reviews the claim to ensure counts agree back to supporting documentation prior to the reimbursement request being filed with the granting agency. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We continue to look for ways to segregate duties and will implement a review procedure for reimbursement requests. Name(s) of the contact person(s) responsible for corrective action: Lisa Miller Planned completion date for corrective action plan: Ongoing

2022-003 Finding 1. Correcting Plan Monthly meal counts will be calculated in a spreadsheet and the monthly meal counts will be reviewed by someone other than preparer before it is submitted for reimbursement. 2. Explanation of Disagreement with the Audit Findings There is essentially no disagreement with the finding. 3. Official Responsible for Insuring CAP The Superintendent, Todd Selk, is responsible for carrying out the corrective action plan. 4. Planned Completion Date for CAP Immediately 5. Plan to Monitor Completion of CAP The superintendent will monitor completion of the CAP, with reports to the Board of Education, on an annual basis.

FINDING 2022-001 Contact Person Responsible for Corrective Action: Tammy Breedlove, Food Service Director Contact Phone Number: 765-569-4308 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The following internal control process has been added to the Business Office Handbook Effective February 1, 2023. The Food Service Director will follow all guidelines as contained in the Child Nutrition Procurement Plan and retain all documentation in compliance with Child Nutrition regulations and State Law. Furthermore, the Food Service Director will ensure that the following procedures are in place: 1. Each School year, the Food Service Director will prepare 5 binders- 1 for each Cafeteria, 1 for the Food Service Director, and 1 for the Business Manager. These binders will contain all approved bids and price changes/vendor correspondence. It is the responsibility of the Food Service Director & Cafeteria Site Managers to update these binders as price changes occur. Audit Evidence will be the contents in each binder for each school year. 2. When invoices for goods are received, the Food Service Director is responsible for ensuring that the invoices are reviewed and crosschecked to the original order/ approved pricing by the Cafeteria Site Manager. Furthermore, the Food Service Director will also review the invoices/pricing and sign off on the claim voucher sheet as approval for the Business Manager to pay the invoice. Audit Evidence: The Cafeteria Site Manager?s signature on the invoices & the Food Service Director?s signature on the claim voucher sheet. Anticipated Completion Date: Effective February 1, 2023

FINDING 2022-003 (Auditor Assigned Reference Number) Contact Person Responsible for Corrective Action: Todd VanDerWeele Contact Phone Number: 574.223.2159 Views of Responsible Official: We concur with the finding. We have adjusted our retention practices to keep all employee records according to statute. After employees listed on the personnel report for hiring or reclassification are approved, the HR Director will provide the approved personnel report, salary schedule or CBA salary schedule, and screen shot of the entries into the school?s financial software to the Business Manager to review and approve. Anticipated Completion Date: March 31, 2023

Finding ref number: 2022-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with federal procurement requirements. Name, address, and telephone of District contact person: Shelby Garrett 600 Huntington Avenue S. Castle Rock WA 98611 (360) 501-2940 Corrective action the auditee plans to take in response to the finding: Once the district was notified of the noncompliance regarding Child Nutrition federal procurement requirements, an interlocal agreement was immediately put in place with Longview School District for our small purchases of $150,000 or below. The agreement was approved by the Castle Rock School Board at the March 8, 2023 board meeting and approved by the Longview School District School Board on March 17, 2023. For our purchases above $150,000, the district requested to be a member of the Puget Sound Joint Purchasing Cooperative on March 6, 2023 and the membership was approved by the PSJPC Board on March 12, 2023. PSJPC provided the district with an interlocal agreement and the agreement was approved by the Castle Rock School Board at the March 22, 2023 board meeting. Anticipated date to complete the corrective action: 3/22/2023

FINDING 2022-002 Contact Person Responsible for Corrective Action: Andrew Nicodemus Contact Phone Number: 765-362-2342 Views of the Responsible Official: We agree with the finding. Description of Corrective Action Plan: Crawfordsville Community School Corporation plans to review all internal control procedures, including the control procedures over Program Income for the Child Nutrition Cluster. After this review, we will implement a system to ensure that compliance with the federal program income requirements is met. Anticipated Completion Date: We expect this Corrective Action to be implement by the end of April 2023 to allow for a full review of all internal control processes and procedures.

FINDING 2022-005 Contact Person Responsible for Corrective Action: Brenda Layne, Food Service Director Contact Phone Number: 765-289-7323 Views of Responsible Official: We concur with the findings Description Qf Corrective Action Plan: The prompts have been fixed on the Distribution Report, so it will include all Cafeteria employees. The F.S.D. will also initial each time card and Distribution Report. In the future ALL Claims will be initialed by the F.S.D. And as additional control the Superintendent will also initial all claims prior to the School Board meeting. Anticipated Completion Date: February 2023

2022-001 Corrective Action Plan-Food Service Fund Balance This finding is caused by the District?s Food Service Fund?s fund balance exceeding 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 to be before the end of the 2022-23 fiscal year. The persons responsible for the corrective action are Maryanne Charette, the food service director and Kim Bidwell, the business manager. The anticipated completion date of the corrective action plan is before the end of the 2023 fiscal year. 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.

FINDING 2022-001 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 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: We noted that for one claim in a sample of four, the school lunch meal count was overclaimed for the month. We noted that in October 2020 the School Corporation had overclaimed lunches by 173 meals. We noted that the sponsor claim reimbursement form had been reviewed, however, the lack of an effective review allowed the error to go unnoticed. Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Going forward, we will have multiple people verifying the data before submission to reimbursement for claims to make sure all meals submitted meet the criteria and eligibility of the Child Nutrition Cluster. Responsible Party and Timeline for Completion: The Food Service Director and the Corporation Treasurer are the responsible parties for this corrective action. This has already been implemented.

Finding 2022-001 Lack of Internal Controls over Reporting Federal Agency: U.S. Department of Agriculture (passed through the State of Alaska) Federal Program: Child Nutrition Cluster Assistance Listing Number: 10.553/10.555/10.582 Award Year: 2022 Type of Finding Material weakness in internal control over compliance and noncompliance. Name of Contact Person: Dennis Niedermeyer Corrective Action Plan: The District will make changes in personnel to provide for the accurate entry and reporting of meal counts into the state?s reporting and claims system. The NSBSD will hired an experienced and qualified food service administrator who will review, monitor and verify compliance with accurate reporting of meal counts. Proposed Completion Date: October 28, 2022.

Finding: 2022-004 Name of Contact Person: Matt Farup, Superintendent Corrective Action: Management has contacted the Nebraska Department of Education subsequent to yearend to determine the status of the duplicate claim for reimbursement. The duplicate payment of $19,529 will be returned to the Nebraska Department of Education. We will review processes and implement procedures as necessary to address the issue in the future. Proposed Completion Date: Immediately

FINDING 2022-003 (Auditor Assigned Reference Number) Contact Person Responsible for Corrective Action: Philip McKelvey Contact Phone Number: 219-759-2531 Views of Responsible Official: we concur with the finding. Description of Corrective Action Plan: Reimbursement reports and claims will be signed off on between the submitter and the Food Service Consultant or Kitchen Manager(s) in order to ensure accuracy. Anticipated Completion Date: January 23, 2023.

FINDING:2022-004 Contact Person Responsible for Corrective Action: Brenda Layne, Food Service Director Contact Phone Number: 765-289-7323 Views of Responsible Official: We concur with the findings Description of Corrective Action Plan: The Corporation Treasure and I discussed this matter and we will be more mindful in the future to get the reimbursement claims receipted in a timely manner. Anticipated Completion Date: February 2023

FINDING 2022-002 Contact Person Responsible for Corrective Action: Tamara L. Asdell Contact Phone Number: 812-726-4440 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan The food service director will prepare and sign the monthly reimbursement claim then have the claim reviewed by another cafeteria worker or the corporation treasurer who will then sign off on the claim to be submitted. Anticipated Completion Date. Immediately

CORRECTIVE ACTION PLAN FINDING 2022-003 Contact Person Responsible for Corrective Action: Heidi Sprunger Contact Phone Number: 260-589-3133 Views of Responsible Official: We concur with the finding. The district is working with Region 8 to obtain the corrective action plan that was submitted previously. Description of Corrective Action Plan: We will monitor this with Region 8 to ensure that the corrective action plan that was submitted is followed. Anticipated Completion Date: Immediately

CORRECTIVE ACTION PLAN FINDING 2022-002 Contact Person Responsible for Corrective Action: Heidi Sprunger Contact Phone Number: 260-589-3133 Views of Responsible Official: We concur with the finding the documentation supporting employees? time charged to the Child Nutrition Cluster program for custodians and grant specialist was not properly maintained. However, we disagree that they would be considered an indirect cost according to the definition of indirect cost: (Indirect costs are sometimes referred to as ?overhead costs? and more recently as ?facilities and administrative costs.?) Examples include executive oversight, accounting, grants management, legal expenses, utilities, technology support, and facility maintenance. Description of Corrective Action Plan: The district will evaluate and determine which employees will continue to be charged under the Child Nutrition Cluster Program. Only those employees spending direct physical time in the cafeteria doing work will continue to be under the Child Nutrition Cluster Program. Once identified those employees will be required to fill out a separate time sheet for hours worked under the Child Nutrition Cluster program. Those time sheets will then be approved by the Food Service Director. Once approved they will be submitted to Payroll Coordinator. Anticipated Completion Date: March 20, 2023

FINDING 2022-003 Subject: Child Nutrition Cluster ? Reporting Federal Agency: Department of Agriculture Federal Program: Summer Food Service Program for Children Assistance Listing Number: 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: 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. Views of Responsible Officials and Planned Corrective Actions: We concur with the finding. Description of Corrective Action Plan: Tamara Florio, Director of School Nutrition, will prepare and submit the claims after they have been signed and reviewed by Kendra Wright, Treasurer. Kendra Wright, Treasurer, will also compare claims with reimbursements and will sign prepared monthly reimbursement claim reports. Responsible Party and Timeline for Completion: Tamara Florio, Director of School Nutrition, and Kendra Wright, Treasurer ? these changes will be implemented effective immediately.

FINDING 2022-001 Contact Person Responsible for Corrective Action: Food Service Director Contact Phone Number: 574-598-8000 ext. 327 Views of Responsible Official: We concur with the finding Description of Corrective Action Plan: To meet the conditions of the grant agreement, Caston School Corporation will keep record of all vendors that are outside of our NIESC buying agreement. Vendors on this list will be identified as having an RFP on file or requiring an RFP to purchase. The director or the director's purchasing designee will consult the list before ordering from the vendor. Anticipated Completion Date: From this point forward, if Caston School Corporation must make a purchase outside of the vendors in our NIESC buying agreement, our food service director or the director's purchasing designee will check the record of outside vendors. This will ensure that we obtain an RFP before an order is placed with the vendor. List will be complied by 2-21-23 and vendors will be added as needed. Food Service Director Title 2/16/2023