Corrective Action Plans

The School Lunch fund has excess fund balance on hand due to the additional reimbursements provided during the COVID-19 pandemic. The District is currently reviewing the programs aging equipment and will create a plan to use these funds to support the program's infrastructure in addition to it facilitating minimal increases in school lunch prices.

Corrective Action The current School Business Administrator started mid-way through the audited year. Corrective action has already been implemented to ensure that reimbursement claims are submitted timely. The claimed meals will be addressed with the Food Service Company that submits the claims. Person(s) Responsible Kristina Edgar, School Business Administrator Planned Completion Date June 30, 2023

2022-001. Procurement United States Department of Education, passed through New York State Department of Education Title I Grants to Local Educational Agencies ALN: 84.010 Special Education Cluster Special Education Grants to States ALN: 84.027A Special Education Preschool Grants ALN: 84.173A Education Stabilization Fund 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 COVID-19: American Rescue Plan ? Elementary and Secondary School Emergency Relief - Homeless Children and Youth ALN: 84.425W United States Department of Agriculture, passed through New York State Department of Education Child Nutrition Cluster COVID-19: School Breakfast Program (SSO) ALN: 10.553 National School Lunch Program ALN: 10.555 COVID-19: National School Lunch Program ALN: 10.555 COVID-19: Summer Food Service Program for Children ALN: 10.559 Condition: The District has not updated its existing policies and written procedures to conform to Uniform Guidance requirements. Planned Corrective Action: The District?s Assistant Superintendent for Business and Operations will work on updating all policies and procedures relating to U.S. Office of Management and Budget Uniform Guidance to ensure that District policies are in compliance with these guidelines. Responsible Contact Person: Jeremy Feder Assistant Superintendent for Business and Operations Lawrence Union Free School District 2 Reilly Road Cedarhurst, NY 11516 Anticipated completion date: June 30, 2023.

October 7, 2022 10.553, 10.555, 10.559 - Child Nutrition Cluster 2022-001 Net Cash Resources Corrective Action Plan: The District will review cafeteria operations throughout 2022-23 and ensure any excess funds will be used to provide additional support to the cafeteria program. The School District expects to alleviate this finding by June 30, 2023.

CORRECTIVE ACTION PLAN JUNE 30, 2022 Finding 2022-003: Immaterial Compliance Finding This finding is caused by the District?s Food Service Fund?s fund balance being over the USDA?s threshold of three 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 Tami Eisenga, Food Service Director and Scott Akom, Superintendent. The plan for monitoring adherence is the food service director and superintendent will work together to assess where the fund balance is after all of the projects from the spend down plan are completed. Condition: 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 USDA requires that the ending balance of the non-profit school food service fund does not exceed three months? average of operating expenses [7 CFR Part 210.14 (b)]. Corrective Steps Taken: At this time, the District has a spend down plan in place with the State of Michigan to help alleviate the excess fund balance down to a reasonable level. Anticipated Completion Date: At the end of the 2022-23 Fiscal Year. Monitoring: The Plan for monitoring adherence is the food service director and superintendent will work together to assess where the fund balance is after all of the projects from the spend down plan are completed. Name of Responsible Person for Further Information: Scott Akom, Superintendent Questioned Costs Related to this Finding: None

Corrective Action Plan Finding No.: 2022-_ 005__ Condition: The District's lunch program net cash resources exceeded 3 months average expenditures for its nonprofit school food service. Plan: Formal calculation of the net cash resources of the nonprofit school food service should be periodically prepared to ensure compliance with 7 CFR 210.14. In the event of noncompliance, the District should incur allowable expenditures or reduce their food service prices as necessary. Anticipated Date of Completion: 6/30/2023 Name of Contact Person: Tip Reedy Management Response: Management will implement the auditor's recommendation for the fiscal year ending June 30, 2023.

PORTLAND PUBLIC SCHOOLS CORRECTIVE ACTION PLAN FOR THE YEAR ENDED JUNE 30, 2022 Portland Public Schools respectfully submits the following corrective action plan for the year ended June 30, 2022. Auditor: Maner Costerisan 2425 E. Grand River Ave., Suite 1 Lansing, Michigan 48912 Audit Period: Year ended June 30, 2022 District Contact Person: Derrick Stair, Director of Finance The findings from the June 30, 2022 schedule of findings and responses are discussed below. The findings are numbered consistently with the number assigned in the schedule. Finding - Financial statement audit 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 already has developed a spend down plan that has been approved by the Michigan Department of Education. We are looking at expanding food choices, expanding healthy food options, as well as needed upgrades to kitchen equipment. Date of Completion: The District?s spend down plan is anticipated to be completed by June 30, 2024. Kitchen equipment availability is severely limited due to national supply chain delays. The installation of this equipment is also limited based on times when school is not in session. These are the two primary factors why the District anticipates it will take multiple years in-order to complete its spend down plan.

Noncompliance Finding 2022-004 (Net Cash Resources) Federal Program: Child Nutrition Cluster ALN: 10.553, 10.555 Condition: The District?s current net cash resources of $566,723 is in excess of its three months average expenditures of $443,634. Recommendation: We have advised management to resolve the current noncompliance finding by any means necessary that is in compliance with federal regulations. Corrective Action: During the 2021-2022 school year, the USDA extended the universal free breakfast and lunch program for K - 12 students. This greatly impacted the number of meals the District served students. In addition to the increased participation, the subsidy reimbursement rate increased and all meals were subsidized by the Federal government. While serving more meals, our Food Service Department struggled to fully staff operations. The department was understaffed by about seven employees and the department operated with roughly 75 percent of its staffing needs. The combination of additional subsidy revenue and understaffing resulted in the department?s profitability. The District will address the excess net cash resources by further investing in the food service program. First, the District will continue its efforts to attract and retain employees to fully staff the unfilled positions. Hourly rates were increased for both new and existing staff in the 2022-2023 fiscal year. As those positions are filled, the Food Service Department?s average expenditures will increase, which also increases the acceptable level of net cash resources permitted. Additionally, the Food Service Department is planning purchases of additional and replacement equipment for the kitchens, resulting in a decrease in the Fund?s net cash resources. These actions will bring the District?s net cash resources within the acceptable range as set forth in 7 CFR ? 210.19. Person Responsible: Daniel Direso, CPA Proposed Completion Date: April 1, 2023

Purchase Needed Equipment

OLIVET COMMUNITY SCHOOLS CORRECTIVE ACTION PLAN YEAR ENDED JUNE 30, 2022 Olivet Community Schools respectfully submits the following corrective action plan for the year ended June 30, 2022. Auditor: Maner Costerisan 2425 E. Grand River Ave., Suite 1 Lansing, Michigan 48912 Audit Period: Year ended June 30, 2022 District Contact Person: Gail Williams, Business Office Manager The findings from the June 30, 2022 schedule of findings and responses are discussed below. The findings are numbered consistently with the number assigned in the schedule. Finding ? Federal Award Findings and Question Costs Finding 2022-001 Considered a significant deficiency Recommendation: The District should submit and implement a 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 plan to spend down the food service fund balance. Anticipated Completion Date: June 30, 2023

2022-008 Federal Agency: U.S. Department of Agriculture Pass Thro Entity: Oklahoma State Department of Education Program: Child Nutrition Cluster Assistance Listing: 10.553 & 10.555 Grant Period: Year ending June 30, 2022 Recommendation: The auditor recommended that written contracts need to be obtained on an annual basis for contract services provided by outside companies on a recurring basis. Controls need to be implemented to insure those amounts paid under these contracts agrees with detail supporting invoices. Action Taken: FY23 Food Service Management contract has been reviewed. Finance Director will compare monthly invoices and detail with the meals claimed to contract terms. Also note that FY24, the District is returning to a self-managed Child Nutrition program.

2022-007 Federal Agency: U.S. Department of Agriculture Pass Thru Entity: Oklahoma State Department of Education Program: Child Nutrition Cluster Assistance Listing: I 0.553 & I 0.555 Grant Period: Year ending June 30, 2022 Recommendation: The auditor recommended that meal counts submitted for reimbursement need to agree with supporting documentation. Secondary review procedures should be implemented to verily agreement with claim submission and claims are certified. Action Taken: Director of Child Nutrition will have a secondary person review claim before submitting to state department, to ensure accurate keying of data. Director of Finance will match up the Payment Notice of funds received to the monthly claims, to ensure all funds have been claimed and received. Anticipated Completion Date: May 2023 Responsible Official: Director of Finance

Finding ref number:2022-002 Finding caption: The District lacked adequate internal controls for ensuring compliance with federal suspension and debarment requirements. Name, address, and telephone of District contact person: Name: Drew Raab Address: 1105 Dale Ave. Benton City, WA 99320 Phone: 509-588-2000 Corrective action the auditee plans to take in response to the finding: It was stated that the District paid a subcontractor, and staff did not know that suspension and debarment verifications must be performed when a contract is subcontracted. The District however does know that a verification needs to happen, but when the change happened in FY 2022, that was the same year of several staffing changes. The documents requested were difficult to locate as the Director of Finance at the time had retired and the Districts Food Service Director is currently out on a leave of absence. A suspension and debarment verification was provided for the audit, however it was not allowed as it did not reflect a print date. Moving forward, the District will ensure that all verifications have a date, with all documentation to be filed with the Director of Finance. Anticipated date to complete the corrective action: 5/26/2023

Finding 2022-002: Verification of Free & Reduced Price Application (NSLP) Recommendation: We recommend the District perform the verification of free & reduced price applications by the deadline published by DESE. Planned Corrective Action: The District will ensure future verifications of free & reduced price applications will be completed by the deadline published by DESE.

Federal Grants Management/Procurement Policy Recommendation: We recommend the District follow its procurement policy related to small purchases. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: District personnel will solicit, obtain, and maintain a minimum number of price quotes from adequate food service vendors (at least 2, if received). Names of the contract person(s) responsible for corrective action: Milissa Lundin, Food Service Director; Laurie Oliver, Food Service Head Cook; Holly Kruger, Food Service Clerk; Jen Steber, Finance Manager Planned completion date for corrective action plan: January 31, 2023.

Finding 2022-002 ? Child Nutrition Cluster ? Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Serena Francis, Business Manager Contact Phone Number: (765) 226-0603 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We have joined the Food 2 School consortium beginning with 2022-2023 school year. Both our Food Service Director and our Business Manager receive all emails and communication. This will allow internal control and oversight to ensure that the consortium is compliment with all state and federal procedures. We also have moved all of our small purchases into this purchasing consortium system. Anticipated Completion Date: August 1, 2023

CORRECTIVE ACTION PLAN Walkerville Public Schools is in agreement with the finding identified and respectfully submits the following Corrective Action Plan for the year ended June 30, 2022. 2022-001 Excess Food Service Fund Balance The food service fund balance ended June 30, 2022 with an excess allowable fund balance. This occurred due to delays in the global supply chain which did not allow us to complete our cafeteria and kitchen remodels as planned. The district's responsible parties include the Food Service Supervisor (Sheri Boes), the Superintendent (Dr. Thomas Langdon) and the Business Manager (Sandra Oomen). All of these individuals have been made aware of the issue and discussed the possibilities to reduce the fund balance for the 2022-2023 school year. The focus of the District to reduce the fund balance will be to: ? Complete the remodel of the kitchen and cafeteria area ? Continue to purchase supplies, equipment, and services that add value to our food service program Implementation and Monitoring: The district will be implementing the purchase of these items throughout the 2022-2023 school year, with all purchases being received no later than June 30, 2023. The Business Manager will monitor the process to determine if additional fund balance will need to be spent throughout the fiscal year to comply with current regulations. The Business Manager will continue dialogue with the Food Service Supervisor and Superintendent throughout the year to keep all parties current on the fund balance status and will update the plan on spending fund balance if needed. If the Michigan Department of Education has any questions regarding this plan, please contact Sandra Oomen at 231-873-4850 ext. 3323 or soomen@walkerville.kl2.mi.us.

2022-001 Child Nutrition Cluster ? Assistance Listing No. 10.553 & 10.555 Recommendation: Recommendation: We recommend the School review its procedures to ensure it retains documentation sufficient to detail the history of all procurements in accordance with the Uniform Guidance. We also recommend the School review its procedures over procurement controls to ensure all controls are also sufficiently documented with records that include, but are not necessarily limited to, the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Review policies and procedures to ensure compliance with Uniform Guidance and MN Statute regarding contract and bid laws. Institute a schedule of periodic review of existing contracts to determine if contract costs are still competitive. We will ensure all award documentation is retained for five years or until the contract is reawarded. Name(s) of the contact person(s) responsible for corrective action: Lynn Peterson, CEO Planned completion date for corrective action plan: September 1, 2023

FINDING 2022-008: Audit Report Deadline Response: The district had difficulty finding an auditor who would be available to contract with us for the 2022-23 school year. Since our last auditor was no longer in business, we had to share significant documentation with our new auditor. Additionally, there was a change in personnel with the hiring of a new Business Manager. Some of the requested information and files were not immediately available to our new Business Manager. We currently have an auditor under contract and will have all requested documentation to them in a timely manner to meet deadlines.

The corrective action for Findings 2022-001 and 2022-002: The District will review current needs for equipment and other direct food service costs. A Corrective Action Plan will be developed to reduce excess cash balances in the Child Nutrition Program.

Responsible Official?s Response: Rochester Prep is implementing procedures to ensure accurate and timely submission of federal nutrition claims. Specifically: To ensure claims for reimbursement are accurately consolidated, the Charter School will evaluate their point of service accountability system and implement appropriate changes. The Charter School will also conduct edit checks to ensure accountability. Effective July 20, 2022, the school implemented a Meal Counting and Claiming Implementation Plan with the purpose of submitting accurate meal claims to the state and federal child nutrition programs. This implementation plan seeks to eliminate discrepancies between meal counting at the homeroom level, reporting at the school level, and claiming at the state and federal levels.

Contact Person ? Mark Lundin, Superintendent. Corrective Action Plan ? The District will review polices and procedures for submitting meal counts for reimbursement. Completion Date ? September 1, 2022.

Finding #2022-001 - Segregation of Duties (Prior Year Finding #2021-001) Condition: Proper segregation of duties is an important aspect of any control system. Management is responsible for the design, installation and maintenance of an appropriate system of internal control. The limited size of the District?s office staff prevents the ideal segregation of functions. The following duties lack adequate segregation of duties: The District uses e-signatures to approve purchase orders. Two individuals have access to the e-signatures and have the ability to create new vendors, enter invoices, print checks, record journal entries and record activity on the general ledger. Both individuals also have access to the payroll system. The person reviewing free and reduced food service eligibility can also enter information into the system to determine eligibility. 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: The Board of Education and the Superintendent should continue to monitor the transactions and the financial records of the District. We also encourage the District to continue to identify cost effective opportunities to improve the design of the internal control structure. 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 Superintendent approves purchase orders and the Board of Education approves monthly accounts payable checks, and one of the school secretaries or the board treasurer reviews the bank reconciliations. The Board of Education and Superintendent will continue to monitor transactions of the District. Finding #2022-001 - Segregation of Contact Person: Heather Droessler Anticipated Completion: Not applicable

Identifying Number: 2022-002 Finding: In our sample of ten schools, Kansas City Public Schools (the District) obtained the requisite two food safety inspections at each school during the school year; however the food safety inspection reports identified critical violations at four schools, which were not corrected by a specified date. The District did not comply with food storage, preparation, and service standards established by the KCMO Health Department. Corrective Actions Taken or Planned: The Child Nutrition Services Department and the Facilities Departments will perform training with staff regarding the Health Department requires to address violations. Procedures will be updated to reflect the responsibilities with CNS staff to report violations, monitor work order progress and escalated resolution to meet Health Department deadlines. The CNS Director will contact the Health Department to provide documentation the violation has been corrected. The corrective action plan has been implemented. The contact person responsible for the corrective action plan is Erin Thompson, Interim Chief Finance and Operations Officer.

Purchase Needed Equipment