Corrective Action Plans

Finding Number: 2022-016 ? SEFA Preparation Corrective Action Plan: In 2022, the office had downsized due to turnover in staff. While a process was in place for reconciling, a secondary review was not performed to verify accuracy of the residual value calculations. To strengthen the oversight of financial management in the School, Academica Nevada, the School?s management company, has filled all the open positions and realigned staff responsibilities to reduce individual workloads and provide additional oversight and review. The grant manager will reconcile all grants to ensure proper cutoff, with a secondary review performed by a member of management. Responsible Individuals: Nachum Golodner, Director of Accounting Anticipated Completion Date: June 30, 2023

Finding Number: 2022-014 ? Procurement, Suspension, and Debarment Corrective Action Plan: Academica Nevada, the School?s management company, and the School will complete an update of the procurement policies to ensure that federal law and standards are clearly detailed and defined. Responsible Individuals: Nachum Golodner, Director of Accounting Anticipated Completion Date: June 30, 2023

District Response and Corrective Action Plan: The Business Office has implemented new procedures requiring requisitions prior to every purchase. All purchases for the 2022-2023 school will have approval. Timecards are approved in Skyward via the Organizational Chart by each employee?s supervisor.

District Response and Corrective Action Plan: The district will perform the sampling prior to November 15th to meet the reporting deadline.

District Response and Corrective Action Plan: The Business Office will monitor the list at SAM.gov monthly and will check new vendors against the suspendered and debarment list. The District will not work with debarred vendors.

2022-01 This finding is caused by the District not having the proper controls in place to prevent, detect, or correct an incorrect monthly meal claim. Due to COVID, the District could not use their typical internal controls as it related to meal counts. In the elementary and middle schools, the cooks had to hand count meals served rather than using meal counting software, which is what was used in prior years. These hand counts were hard to follow which caused issues when doing monthly reconciliations prior to making meal claim reimbursements. The District will also be returning to using meal counting software for all schools and eliminating hand count sheets all together. The persons responsible for the corrective action are Cathy Clarke Karwowicz, the Food Service Director and Rod Fullerton, the Chief Financial Officer. 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 Chief Financial Officer will work together to ensure that monthly meals served are being reconciled prior to any meal reimbursements being claimed.

Corrective Action: When the District expands the food service program under any circumstances, the District will adapt internal controls to monitor costs for their allowability and level of effort in the food service program as being incurred. Method of Implementation: Formal communication between food service director and school business administrator during any circumstances when the District expands the food service program. Person(s) Responsible for Implementation: Sue Prusko, Food Service Director; Anthony Dragona, School Business Administrator Completion Date of Implementation: June 30, 2023

The income verification process has been reviewed the Director of Food Service. She understands that the verification must be an official document of earnings (i.e. paystub).

Finding: The Office of Superintendent of Public Instruction did not have adequate internal controls over accountability for USDA-donated foods. Questioned Costs: Assistance Listing # 10.553 10.555 10.555 COVID-19 10.556 10.559 10.582 Amount $0 Status: Corrective action in progress Corrective Action: The Office has taken the following corrective action to strengthen internal controls over accounting for USDA-donated foods: ? Reviewed current process for monthly inventory. ? Reviewed process for inventory discrepancies follow up. ? Implemented a process for documenting follow-up efforts. The Office is following the USDA requirements for conducting annual inventory and reconciliation in June of each year. In addition, the Office has contracted with a vendor for a new and updated Food Distribution Management System. The current timeline for system launch is as follows: ? November 2023 ? Data migration and system set up ? February 2024 ? Survey period ? August 2024 ? Ordering of food, receiving, and inventory management The conditions noted in this finding were previously reported in findings 2021-003, 2020-004 and 2019-005. Completion Date: Estimated July 2023 Agency Contact: Leanne Eko Chief Nutrition Officer PO Box 47200 Olympia, WA 98504-7200 (360) 725-0410 leanne.eko@k12.wa.us

October 21, 2022 CORRECTIVE ACTION PLAN FINDING 2022-002 EXCESS FUND BALANCE IN FOOD SERVICE FUND (repeat comment) ? Material weakness in internal control/material noncompliance ? special tests and provisions. Over the 2022-2023 school year, the District will utilize the excess fund balance to improve the quality of the food service program. Despite following the spend down plan submitted to the Department of Education last year, the District still has a food service balance that exceeds the allowable balance by $129,204. The food service department will use the excess balance to continue to offer more new food choices, and continue to improve the quality of the food served (including more fresh produce and better quality ingredients). These improvements will continue to be in conjunction with the Michigan Department of Education's Office of School Support Services which will again approve the spending plan. We will begin to implement this immediately

CORRECTIVE ACTION PLAN OF CURRENT AUDIT FINDINGS June 30, 2022 FINDING 2022-001 Subject: Child Nutrition Cluster ? Procurement and Suspension and Debarment Audit Findings: 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 for purchases made outside of the purchasing cooperative. Context: During the audit period, the School Corporation had purchases between $10,000 and $150,000 from two vendors which fall under the small purchase method for federal and state procurement regulations and were charged to Fund 0800 ? School Lunch Fund. For one vendor selected for testing, documentation was not presented to verify the School Corporation had performed checks to assure the vendor was not suspended or debarred prior to entering into the transaction in order to satisfy the suspended and debarment requirements. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: When a purchase is made at $10,000 or more using Federal Funds, the superintendent will require that any vendors selected are in compliance with the Procurement and Suspension and Debarment compliance requirement by completing one of the following quality checks with each vendor prior to purchase: a. Checking the federal System for Award Management (SAM) database at https://sam.gov/content/exclusions and maintain a screenshot of the search results. b. Collect a certification from the vendor directly c. Add a clause or condition to the covered transaction with the vendor Responsible Party and Timeline for Completion: The Superintendent and will be implemented and completed immediately with any purchase made that meets the above threshold.

The Haddon Heights School District will monitor the fiscal condition of the Food Service Enterprise Fund in the 2022-2023 school year to ensure that the net cash resources do not exceed three months average expenditures.

#2022-003 - Significant Deficiency in Controls over Compliance: Lack of Review over Reporting Recommendations: We understand that many, if not all locations participating in the meal programs have since either reverted back to using the electronic system for counting students, or plan to do so in the near term. We recommend that any remaining manual reports/tally sheets be reviewed prior to submitting counts for reimbursement. Views of Responsible Officials and Planned Corrective Actions: ? Because student meals are no longer free in the 2022-23 school year, GRCS is returning to the electronic system for counting student meals.

#2022-002: Material Weakness in Controls over Compliance: Administrative Requirements of Uniform Guidance -Administrative Policies Recommendations: Grand Rapids Christian Schools should consider the following written policy additions or updates: ? Financial Management (2 CFR 200.302) The financial management policy should include records documenting compliance, and the tracking of funds to determine that expenditures are in accordance with the terms and conditions of the federal awards. The financial management and reporting system must provide the following : ? Identification - Title of the award, CFDA number ? Complete disclosure of accurate and current financial results of each federal award ? Source and application of funds for federal award activity ? Record retention and access - define the time period for which records must be kept (can vary by grant agreement), and who has the ability access the records (?200.333 - ?200.337) ? Written procedure to implement cash management requirements (see below) ? Written procedures for determining the allowability of costs (see below) ? Cash Management (2 CFR 200.305) A written policy is required by Uniform Guidance detailing the Organization's procedures to minimize the time that elapses between draw and expenditure of federal dollars. ? Allowable Costs (2 CFR 200.302(b)(7)) The Organization must have written procedures for determining the allowability of costs in accordance with Subpart E - Cost Principles of Uniform Guidance and the terms and conditions of the Federal award. This includes the determination of allowable costs and the review of this determination. The standard assumes policies and procedures are in place for disbursements, and the allowable cost policy will demonstrate how the Organization ensures compliance. The criteria for costs to be considered allowable are documented within 2 CFR 200.403. ? Procurement Standards (2 CFR 200.317 - 200.326) The Organization must have a written policy that promotes full and open vendor competition, conflict of interest policies should cover employees as well as the organization, and general purchase requirements with specific thresholds as set forth by the Uniform Guidance. There are five allowable procurement methods as described in ?200.320, depending upon the dollar value of the purchase or contract. Views of Responsible Officials and Planned Corrective Actions: ? Grand Rapids Christian Schools follows procurement and record retention standards provided by the USDA. ? GRCS does not have actual written policies and procedures for Financial Management, Cash Management, Allowable Costs, and Procurement Standards, but do have practices in place to follow USDA guidelines. In the case of cash management, the only location that takes cash is GRCHS. In that instance, along with Meal Magic, cash registers are zeroed out and balanced to Meal Magic and cash deposits are made daily. ? GRCS Business Office will work with the Food Service Director to begin formulating written policies and procedures specific to Grand Rapids Christian Schools. GRCS will utilize the resources from Uniform Guidance and Code of Federal Regulations (CFR) to develop policies that are compliant with those requirements prior to June 30, 2023.

St. Louis Public Schools Correction Action Plan for audit finding number (2022-001) Responsible party: Charles Clevenger, Stacey Haag and Jennifer McKittrick Expected completion date: June 30, 2023 Excess fund balance of $48,421 in Food Service Fund To Whom it May Concern, The Superintendent and the Food service director will be working together to purchase the following items immediately to spend down the excess fund balance in our food service fund prior to June 30, 2023. We will be looking at areas of improvement in our food service program such as replacing sections of ceiling. We will also be looking to purchase some additional equipment during this time frame, including garbage disposals.

Since June 30, 2022, the District has purchased and replaced kitchen equipment, painted the cafeteria and kitchen area and charged cafeteria aides to reduce Net Cash by $87,195. This is in excess of the Net Cash Resources Finding of $83,790.

Child Nutrition Cluster Reporting Child Nutrition Cluster - Assistance Listing No. 10.553, 10.555 Recommendation: We recommend the District implement a review procedure over reimbursement requests where someone other than the preparer reviews the claim to ensure accounts agree back to supporting documentation prior to the reimbursement request being filed with the grating agency. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action Planned/Taken: Food service reports are now reviewed and initialed monthly. Food service director would initially run the report and it would be reconciled by the Business Manager. Final claims are reconciled before the report is submitted and initialed by the Superintendent. Name(s) of the contact person(s) responsible for corrective action: Nimisha Patel, Business Manager Planned completion date for corrective action plan: January 1, 2023

October 22, 2022 Finding Number: 2022-002 ? Reporting Condition: Meals claimed were not supported by count sheets for either breakfast or lunch for the two months meals were tested prior to MDE site visit. Responsible Person: Stephen Grubaugh ? Director of Business Services Implementation Date: 10-22-2022 During the single audit, it was discovered that Bullock Creek Food Service Department meals claimed were not supported by count sheets for either breakfast or lunch for the two months meals were tested prior to MDE site visit. To ensure that this did not continue, Bullock Creek Food Service and the Technology Department worked together to implement the use of Skyward to track the melas served to students. This transition occurred over a few months, as the implementation was rolled out to 5 individual buildings. When MDE came on campus and audited the months during the transition and found a few discrepancies whish were remedied in the software and the claims were adjusted. RPC then audited the month following the MDE reviews and found no discrepancies. Skyward was used for the rest of the year. For the 2022-2023 Scholl year, the Food Service Department may purchase Meal Magic, which is a food Service software that will streamline the recording and reporting processes even more and may reduce the chance of errors even further. Sincerely, Stephen Grubaugh Director of Business Services

October 22, 2022 Finding Number: 2022-001 ? Excess Fund Balance In Food Service Fund 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 $85,951. Responsible Person: Stephen Grubaugh ? Director of Business Services Implementation Date: 7/1/2022 During the single audit, it was discovered that Bullock Creek Food Service Department had an excess fund balance in the Food Service Fund by approximately $85,951. This was due to the meal reimbursement rate exceeding the food cost to prepare the meals. All meals served to students during the 2021-2022 school year were provided free of charge to the students, due to grants. In order to reduce the excess fund balance, the district created a spend down plan for the 2022-2023 Fiscal Year. The kitchen at Bullock Creek Elementary needs some structural repairs completed due to faulty roof drainage. The total cost of the project is approximately $73,000. Construction on the project was started in July of 2022 and finished in August. Meal Magic will be implemented during the 2022-2023 School year for tracking of the meal purchases of students and staff. This software will cost approximately $3,000 in the first year to implement and $6,000 in subsequent years. The reaming $10,000 in excess fund balance will be retained, in order to aid in the paydown of potential negative student food service account balances. Since students haven?t paid for breakfasts or lunches for the past 2 years, it is unknown how the many will families will have feel a financial burden paying for their children?s school meals. Sincerely, Stephen Grubaugh Director of Business Services

This is a plan of action that we, as a district, will be implementing in order to correct the Federal finding from our audit. ? 2022-001 - Arkansas DESE Child Nutrition Unit will be contacted for guidance before any transfer to or from Food Services to ensure Ark. Code is followed regarding the Child Nutrition Program. Deanna Clifton, District Treasurer, will contact DESE Child Nutrition Unit to obtain guidance in any action needed regarding the transfer made in Fiscal 2021/2022. Anticipated Completion Date March 15, 2023. I trust that I have covered the points discussed. If you have any questions or if further information is needed, please call me at 870-486-5411, ext. 104. Sincerely, Deanna Clifton District Treasurer/Business Manager

A plan is in place to renovate the middle school kitchen as soon as possible.

Contact Person - Thomas A. Jerome, Superintendent. Corrective Action Plan - The District will review policies and procedures for submitting meal counts for reimbursement. Completion Date - September 6, 2022.

Finding 2022-002 Document Retention (Significant Deficiency) Federal Program: Child Nutrition Cluster Finding: Per 7 CFR 200.334, ?Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.? Management Corrective Action: While the school?s annual total meals served for the 2021-22 audit year were more than the meals claimed for reimbursement, the school was unable to reconcile all of the individual months. The school has since implemented and automated system to record lunches served. This point-of-sale system will eliminate the ongoing monthly accounting required to support monthly claims assuring the numbers served reconciles with the numbers claimed. Chris Ashmore has already implemented this system and tested the subsequent year-to-date audit period to assure this corrective action has, in fact, eliminated the problem.

Finding 2022-001 Cash Management (Material Weakness) Federal Program: Child Nutrition Cluster Finding: Per 7 CFR 210.14(b) and 7 CFR 220.7(e)(1)(iv), the ?school food authority shall limit its net cash resources to an amount that does not exceed 3 months average expenditures for its nonprofit school food service or such other amount as may be approved by the State agency Management Corrective Action: Previous audit year expenses were classified as ?General? funds when they should have classified as ?Food Service?. This, in aggregate, has led to an excess fund balance. Management, specifically Rod Iberg and Linda Heidrich, will work with the state on how to transfer the large arrear fund balances between accounts. Management will also endeavor to assure that all ongoing expenses are allocated to the correct fund.

2022-002 Child Nutrition Cluster ? Assistance Listing No. 10.553/10.555/10.559Recommendation: Adhere to internal control procedures over the review of meal counts. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: Summer Feeding Program Claims will be reviewed and verified before entry with same form and procedure that is currently used for National School Lunch Program claims. Name(s) of the contact person(s) responsible for corrective action: Nancy Millspaugh Planned completion date for corrective action plan: June 30, 2023.