Corrective Action Plans

Department: Education Administrative and Financial Services Title: Internal control over the submission of CNC Schedule of Expenditures of Federal Awards information needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Department will report expenditures for the School Breakfast Program and Special Milk Program under the individual ALNs rather than including those expenditures in the broader ALN 10.555. The Department will report noncash assistance at the amount actually used rather than the amount authorized for use. The Department will add a note to the SEFA report indicating any COVID-19 expenditures that cannot be isolated due to waivers. Completion Date: June 30, 2023 Agency Contact: Nicole Denis, Director of Finance, DOE, 207-530-2161

Department: Education Title: Internal control over Child Nutrition claim reimbursements needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Department will offer updated SSO training to include specific procedure on meal counting and claiming by building. The Department will create a policy for oversight of claiming procedures during SSO operations. The Department will implement policies and procedures to review and approved CNP system changes. Completion Date: June 1, 2023 (first two items) and June 30, 2023 (third item) Agency Contact: Jane McLucas, Director of Child Nutrition, DOE, 207-624-6880

Department: Education Title: Internal control over CNC special reporting needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Department will develop and implement a procedure for the Child Nutrition Cluster to ensure subawards meeting or exceeding the first-tier threshold are reported accurately, timely, and in accordance with Federal regulations. Completion Date: June 30, 2023 Agency Contact: Jane McLucas, Director of Child Nutrition, DOE, 207-624-6880

Condition: The District?s school lunch office maintains production records and manual count sheets instead of using the point of sale system for tracking student meat counts. Corrective Action Planned: Due to a staffing shortage the district is unable to run the point of sale system. We are currently advertising weekly for new staff to hire. We have a low starting salary and the turnover is very high. We are in negotiations with the union to increase the starting pay and are trying to get creative to see if there is a way to add more duties to the new employees to increase the hours of the job to make the positions more attractive. We are also in the process of purchasing a new point of sale system that will help streamline the process and won?t be as staff intensive. Anticipated Completion Date: Hiring of new staff - March 2023 New POS System - September 1, 2023 Contact: Ann-Marie Geyster

Finding Number: 2022-002 Planned Corrective Action: If the district is required to return to tally sheets for the calculation of site claim forms, more stringent reviews will be put into place between the tally sheets and the entering of the site claim form data. The 2021 ? 2022 school year had special procedures in place due to the ongoing pandemic. Anticipated Completion Date: March 16, 2023 Responsible Contact Person: Mandy Hildebrand, Treasurer

A plan will be developed by the District to eliminate the excess of net resources in the Food Service Fund.

Management Views ? Management agrees with the finding and the recommendation. Corrective Action Planned ? Management has implemented procedures to ensure that the free and reduced price applications and the verifications are kept on file and scanned. The appropriate employees will be trained and be made aware of the requirements for these documents. Anticipated Completion Date ? This procedure has been implemented for the 2022-2023 school year and all of the appropriate employees are aware of the importance of keeping these documents.

Information on Federal Programs: U.S. Department of Agriculture Child Nutrition Cluster (COVID-19 National School Lunch Program and COVID-19 School Breakfast Program and Food Distribution, Federal Assistance Listing No. 0.553 and 10.555) passed through the New York State Education Department. Findings and questioned costs related to Federal awards which are required to be reported in accordance with the Uniform Guidance 2 CFR 200.516(a): Criteria: CFR Section 200.318 stipulates that a non -Federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws, and regulations, provided that the procurements conform to applicable Federal law and the standards identified in Part 200 Subpart D. Additionally, 2 CFR Section 200.213 stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Statement of Condition: During our discussions with management and testing of the major program, we noted that the District is not verifying the eligibility of vendors to participate in Federal assistance programs. Statement of Cause: The District did not review compliance requirements related to procurement outlined in 2 CFR Section 200.318 and Section 200.213. Statement of Effect: The District is not in compliance with 2 CFR Section 200.213. The District is not performing required procedures, as a result, vendors that are not eligible for participation in Federal assistance programs or activities could be selected or the District could be overpaying for goods and services. Questioned Cost: None. Repeat Finding: No Perspective Information: As part of testing of compliance over procurement, a selection of vendors charged to the major program was selected for testing of compliance. Of the District?s vendors charged to the program, none were suspended or debarred from participation in Federal assistance programs and activities. Recommendation: We recommend that the District review the requirements of 2 CFR Section 200.213 and ensure that a review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to disbursing funds to the vendor. Views of the Responsible Officials and Planned Corrective Actions: The District has reviewed the requirements of 2 CFR Section 200.213. The District is in agreement with the recommendation to implement a procedure to document the process used to verify the eligibility of potential vendors to participate in Federal assistance programs. The verification of excluded parties will be accomplished by accessing the System for Award Management (SAM.gov) website and selecting the ?Excluded Entity? filter on the ?Exclusions? search page to search for exclusions by Unique Entity ID or CAGE/NCAGE code as follows: 1) Select ?Search? from the header menu from any page on SAM.gov 2) In the filters, under ?Select Domain?, select ?Entity Information?, then select Exclusions 3) Use the filters or keyword box to enter the search criteria and view the results 4) Document the results in the vendor file. Other alternatives for verification may include collecting a certification from the entity or adding a clause or condition to the covered transaction or contract with that entity. The Purchasing Agent is charged with the responsibility of monitoring and ensuring compliance with the suspension and debarment procedures and maintaining documentation that contracts expected to equal or exceed $25,000 have been verified on the System for Award Management (SAM) website before purchases are made. Responsible Person(s): Kristin Chotkowski, Purchasing Agent Deadline for Completion: On or before 4/1/23 for covered transactions with contracts or purchase orders meeting the threshold during the time period 7/1/22 - 1/31/23. Prior to contract approval or purchase order issuance for contracts or purchase orders meeting the threshold on or after 2/1/23.

Planned Corrective Action: Management continues to follow the approved Excess Fund Balance Elimination Plan. It is expected the equipment investment will be made in the upcoming fiscal year. Quarterly reviews of the Cafeteria fund balance are planned. Anticipated completion date: June 2023. Responsible contact person: Angela Gleason, Finance Director.

Planned Corrective Action: Management has initiated a review of the payroll process and procedures and will make necessary adjustments to include verification and review of payroll servicer calculations. Anticipated completion date: January 2023. Responsible contact person: Angela Gleason, Director of Finance.

Finding 2022-004 Activities Allowed or Unallowed ? Child Nutrition Cluster Material Weakness in Internal Control Over Compliance Finding Summary: The District has no procedure in place for review of pay rates paid to employees under federal programs in the Child Nutrition Cluster. Responsible Individuals: Shannon Hunstad, Superintendent Corrective Action Plan: The District will review and strengthen the controls surrounding the review and approval of allowable costs in the Child Nutrition Cluster to ensure they are supported, approved, and accurate. Anticipated Completion Date: June 30, 2023

FINDING 2022-003 Contact Person Responsible for Corrective Action: Gretchen Berger Contact Phone Number: 812-654-2365 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Corporation Treasurer and Food Service Director will review and initial the price quotes that are received for small purchases. The Corporation Treasurer and Food Service Director will review and initial documentation that vendors paid with federal grant monies were not suspended or debarred from participation in the program. Anticipated Completion Date: 8/31/2023

FINDING 2022-002 Contact Person Responsible for Corrective Action: Gretchen Berger Contact Phone Number: 812-654-2365 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Corporation Treasurer will have the Food Service Director review and initial the monthly reimbursement request submitted to SNP. Anticipated Completion Date: 3/31/2023

Effective 2022-2023 fiscal year, the district purchased a point-of -sale system for nutrition services at all schools, except the Legacy High School (LHS), to ensure accurate reporting for reimbursable meals/snack. The Director of Nutrition Services has trained the LHS staff on the use of a bar code meal count roster to scan students that receive a reimbursable meal/snack. The roster is turned in weekly to the Matilija Middle School Cafeteria Manager, who will process the meals counts for LHS. All meal count rosters are forwarded to the Director of Nutrition Services at the end of the month for review

Finding No.: 2022-_ 004__ Condition: The District prepared analysis of the profitability of the food service program was not clerically accurate by a material amount. Plan: The profitability analysis will be reviewed by someone independent of the preparer to ensure that all food service receipts and disbursements are included in the profitability analysis. Anticipated Date of Completion: 06/30/2023 Name of Contact Person: Adam Clapp Management Response: Management will implement the corrective action plan for the year ended June 30, 2023.

Contact Person ? Jeannie Mayer, Superintendent Corrective Action Plan ? The District will review policies and procedures for submitting meal counts for reimbursement. Completion Date ? November 1, 2022

FINDING 2022-003 Contact Person Responsible for Corrective Action: Barbara Fought Contact Phone Number: 260-260-3191 Views of Responsible Official: We concur with the finding. Finding 2022-003 was corrected in January 2023. The Food Service Director and Maintenance Department met to discuss how federal purchases are to be made when repairs to kitchen are needed. Maintenance will secure at 3 quotes and share those quotes with the Food Service Director. The Food Service Director will send the selected quote back to Maintenance for ordering. Since implemented in January, repairs for the kitchens have been very smooth and seamless. Anticipated Completion Date: March 31, 2023

2022-002 Child Nutrition Cluster ? Assistance Listing No. 10.553/10.555/10.559 Recommendation: We recommend that the School Corporation ensures that documentation of Procurement's decisions on any purchases that are excluded from the requirements noted in the Procurement Policy are retained for audit purposes. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: This finding was an unusual situation and will be corrected. The procurement transaction in question was originally include in a large building project and would not have been paid with federal dollars. Due to issues with the general contractor, timeliness of completion, and the beginning of the school year, one portion of the project in the school kitchen was pulled from the general contractor and a quote was obtained from one vendor. Quotes from at least three (3) vendors and documentation of any unusual circumstances will be maintained for auditor review. Name(s) of the contact person(s) responsible for corrective action: Louise S. Smith and Jennifer Niese Planned completion date for corrective action plan: March 31, 2023

FINDING 2022-001 ? Material Weakness and Material Noncompliance ? Budget Variances / Allowable Costs Corrective Action Plan: Analyze actual expenditures monthly, review the budget to actual numbers monthly and use data from this review to prepare a more accurate final budget revision. Responsible Parties: Rod Livingston, Business Manager Anticipated complete date of June 30, 2023 Rod Livingston Business Manager

2022-001 Significant Deficiency: Internal control over maintenance of documentation of procedures performed Planned Corrective Action: Management will implement additional procedures to maintain documentation of the review and approval of expenses allocated to federal programs. Anticipated Completion Date: March 31, 2023 Responsible Party: Hasan Suzuk (Executive Director)

Finding 2022-030 Food Distribution Cluster, ALN 10.565, 10.568, and 10.569 - Accountability for USDA Foods Management Views MDE agrees with the finding. During fiscal year 2022, MDE determined that The Emergency Food Assistance Program (TEFAP) State Plan was inefficient and discontinued reviewing eligible recipient agencies (ERA) as outlined in the plan. MDE modified its TEFAP State Plan for fiscal year 2023 to be more reflective of TEFAP inventory movement and still meet the requirements of federal regulation 7 CFR 251.10(e). Planned Corrective Action MDE revised the fiscal year 2023 Michigan TEFAP State Plan, effective October 2022, to require MDE to review ERAs that are considered ?subdistributing agencies? onsite annually and all TEFAP ERAs to submit inventory records and TEFAP foods documentation to MDE as requested twice a year. The change was announced to TEFAP ERAs during the annual All Agency Meetings at the end of August 2022 and through follow up emails and communications. Anticipated Completion Date MDE has already completed the majority of fiscal year 2023 desk and on-site reviews under the revised process and will have completed all of the required fiscal year 2023 inventory reviews by July 31, 2023. Responsible Individual(s) Aimee Alaniz, MDE

This finding has been addressed in fiscal year 2023. ASGDOE school lunch Is working with a representative who oversees civil rights for the USDA wester region. Civil rights training for all SLP staff continues yearly with sign-in sheets and agendas for documentation purposes. Reports are submitted to USDA for inventory and mean counts on the 15th of each month. Special dietary accomodations have since been rolled out and schools have been notified of the process should a student require accomodation. USDA has an on-site visit scheduled not that borders are open. Key individuals responsible: SLP Assistant Director Christina Fualaau. Will be completed and closed in 2023.

Finding Summary: The Hollis Brookline Cooperative School District?s Food Service Fund net cash resources were in excess of the maximum allowable amount by $395,282. Responsible Individual: Kelly Seeley, Business Administrator Corrective Action Plan: The School District has developed a spend-down plan for reducing the Food Service Fund Balance to compliance level during the 2022-23 fiscal year, and has submitted the plan to the State of New Hampshire Department of Education for approval. Anticipated Completion Date: June 30, 2023

Child Nutrition Cluster Segregation of Duties Child Nutrition Cluster ? Assistance Listing No. 10.553, 10.555, 10.559 and 10.582 Recommendation: CLA recommends that the District implement a formal review process over the reporting and verification requirements related to the Child Nutrition Cluster during the fiscal year and properly retain the documentation. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: This process was completed in the fall of 2022. The person handling this for 2021-22 didn?t complete this process because lunches and breakfasts were all free.. Name(s) of the contact person(s) responsible for corrective action: Lisa Hinker Planned completion date for corrective action plan: Fall of 2022

Harlem Consolidated School District 122 Corrective Action Plan for Current Year Audit Findings Year Ending June 30, 2022 Corrective Action Plan Finding No: 2022-001 Condition: For October, December, February, and April, there were variances between the support for meal counts maintained by the District and the number of meals claimed by the District. Plan: The District will create a process in which the elementary buildings will enter their hand tallied breakfast meal counts into a shared spreadsheet daily, and upload the backup documentation weekly. The administrative assistant will review the documents and compile the total meal counts to be entered into WINS monthly. The Director of Food and Nutritional Services will review and verify the compiled information, sign off on the totals and submit the claim to the State. Anticipated Date of Completion: January 2023 Name of Contact Person: Josh Aurand, Chief School Business Official (815) 654-4500