Corrective Action Plans

In response to the late audit submission finding, the District is working with the auditors to ensure the 2023 financial statement audit is submitted on time.

2022-003 Child Nutrition Cluster ? Assistance Listing No. 10.553 and 10.555 Recommendation: We recommend that the School implement formally documented procedures and controls in relation to the required child nutrition cluster CLiCS reports, to ensure they are completed accurately going forward. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Operations Manager will verify that the numbers of meals served matches the number inputted into CLICS is accurate. Operations Manager with verify monthly by checking Infinite Campus against the meals served spreadsheet prior to submitting for reimbursement. Reimbursement claim has been corrected with MDE. Name(s) of the contact person(s) responsible for corrective action: Karen Conner Planned completion date for corrective action plan: 2/1/2023

For the 2021-22 school year, the District failed to correctly allocate expenditures to the CACFP accounts. In order to correct this action for the 2022-23 School Year, the Director of Fiscal Services will work with the Director of Child Nutrition to reconcile each program and complete the Cost Allocation Worksheet. The District utilizes a direct cost vending agreement, which will allocate costs in an allowable manner. The Director of Fiscal services will be responsible for making the transfer of expenditures from the NSLP accounts to the CACFP accounts. The Director of Child Nutrition will verify the transfers have been completed correctly befor the books are closed. Contacts: Kevin Olson, Lori Toms(Director of Fiscal Services), and Suzanne Stamp(Director of Child Nutrition).

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 four claims in a sample of four, the Food Services Director prepared the reimbursement claim without a secondary, documented review to ensure the accuracy of the reimbursement claim. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The School Corporation?s management will review and formulate procedures to ensure compliance with requirements related to the grant agreement and the reporting compliance requirement. Responsible Party and Timeline for Completion: The School Corporation?s management will ensure the Food Service Department implements a secondary document review to ensure accuracy prior to submitting the reimbursement claim. This action will begin immediately with the March of 2023 claim submission.

Name of Contact Person: Dr. Amy Jackson, Chief Financial Officer Recommendation: The District should monitor the Child Nutrition profit made and ensure all expenditures used to operate the program are properly charged to the program. Corrective Action: We will ensure that all eligible costs are charged to the program and modernize the equipment to reduce the accumulated carry-over. We have submitted a written plan to the Missouri Department of Elementary and Secondary Education outlining our plan to purchase supplies and equipment and the estimated completion time. Proposed Completion Date: Immediately

Recommendation: CLA recommended that the District implement a review process over the reporting requirements related to the Child Nutrition Cluster during the fiscal year. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management has begun reviewing food service claims prior to submission to DPI Name(s) of the contact person(s) responsible for corrective action: Cari Guden, Administrator Planned completion date for corrective action plan: June 30, 2022

Views of Responsible Officials, Corrective Action Plans, and Contact Information For the 2021-22 school year, the Food Services Division used federal waivers to support students and families by providing meals under multiple programs. Starting August 2021, COVID concerns resulted in the district discontinuing breakfast in the classroom. USDA waivers permitted the distribution of breakfast and supper meals to students as they left campus for consumption at home. As the school year progressed, the after-school supper program was reinstated for a small group of students at some schools, and this group of students was given a breakfast to take home. Additionally, we distributed weekend meals comprising of supper and snacks. Lastly, the district requested Food Services to serve a morning snack (at the District?s expense) for hungry students. The snacks were tracked manually for reimbursement from ESSER funds by the district. Each meal service required a different form to count meals and multiple sheets for the same meal period depending on how the meal bags were distributed (exit gate vs. classroom). The managers had many forms that had to be put together and summed up to come up with the reimbursable counts. Manually compiling and uploading the information is the reason for the variances. Each time there was a change in the operation, the Food Service team had to create a new training module for the change in operation, which created additional forms leading to the errors seen in the audit review. We want to state respectfully that our error rate for meal counts was 0.4% which, given the multiple food distribution channels to support students, is understandable. To address the audit findings, Food Services will review and modify our procedures and be stringent in monitoring our existing systems and procedures: 1. Food Services Division will add steps to our current meal claiming procedures to ensure accuracy of claims. a. Food Service Manager will utilize the Meal Count Consolidation Form for meal periods that have more than one meal count sheet. b. Food Service Manager will input meal counts into CMS based on information from the Consolidation Form. c. Food Service Manager will run a weekly Meal Counts Report generated from CMS. d. Food Service Manager will compare daily meal count documents to the five-day Meal Count Report for accuracy. e. Area Food Services Supervisors (AFSS) will randomly check meal counts entered in CMS and compare them with the numbers entered in daily meal count sheets. Each school will have a random review every 2-3 months, and where errors are found there will be additional follow up. 2. Food Services will follow the review steps as indicated in Corrective Action Response #1 and confirm the claim for accuracy prior to submission to CNIPS. a. Food Services Central Office Staff will provide a daily meal count report to all Supervisors for review to identify any inputting errors. b. Food Service Managers will review and adjust meal counts prior to the CNIPS claim submission, based on AFSS feedback. The target date for the implementation of the above corrective action plan is by the end of February 2023. Name: Manish Singh Title: Director, Food Services Division Telephone: (213) 241-2993

Purchase needed equipment

See Corrective Action Plan for chart/table

Corrective Action Planned: The annual on-site reviews required as part of the National School Lunch Program were not completed during the 2021-2022 fiscal year due to an oversight by the previous Director of Business Services. There were no questioned costs or unallowable expenditures. District staff have added this procedure to their work calendar to ensure the reviews will be completed in a timely manner in the future. Additionally, District staff will review all administrative policies issued by the State of Michigan related to the food service program. Anticipated Completion Date: February 1, 2023 ? The fiscal year 2022-2023 on-site reviews are required to be completed prior to February 1, 2023. District staff will complete the reviews prior to the due date.

Department of Education (DOE) Assistance Listing Number 10.553, 10.555, 10.556, 10.559, 10.582 Program Management will implement policies and procedures to ensure Transparency Act reporting is conducted with proper reviews and timely submissions. In order to comply with the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282) (Transparency Act), as amended by Section 6202(a) of the Government Funding Transparency Act of 2008 (Pub. L. No. 111-252), that relate to sub-award reporting, DOE is working with the Child Nutrition Claiming Software vendor to create a report that will be run on the first of each month. Staff from the Office of Internal Operations and Office of Child Nutrition will be assigned to generate, enter, and submit data as required by the Transparency Act. To meet the timelines for reporting as established by the Transparency Act, the report will pull all activity for the prior month including all original reimbursement claims, as well as amendments that occur in that month to reimbursement claims that were previously reported. Prior to submission of the data, a report of its contents will be reviewed and approved by either the Child Nutrition Program Director or the Director of Internal Operations. Once the data is approved, it will be submitted. The timeline for development and initiation of this reporting process (barring any unforeseen system limitations) is tentatively set for July 1, 2023.

Finding 2022-002 ? REPORTING Type: Significant Deficiency in Internal Control! Noncompliance ? Reporting Program: Child Nutrition Cluster (ALN 10.553, 10.555 and 10.559) Condition: Meals claimed were not supported by count sheets for lunch for one of the two months meals were tested. Criteria: The District is required to claim meals served, by category, based on reports provided from individual meal serve counts. Cause: This condition was caused by an insufficient internal control process for comparison of supporting documentation of meal counts to meal claims. Effect: Based on a comparison of meals claimed to reports provided from individual meal serve counts, the District has underclaimed reimbursement for the year by an immaterial amount. Questioned Costs: None. Recommendation: We recommend that the District review their process of meal claims and make necessary changes to ensure that all meals claimed, by category, agree to supporting documentation. Corrective Action Plan: Shepherd Public Schools Food Service Department will implement internal control review process to ensure that individual meal serve counts match identically the meals claimed by reviewing original count sheets at the time of certification of meal claims. Either the food service director or assigned designee will verify counts at the end of each month. This internal control review process will begin effective with the October 2022 claims report.

Finding 2022-001 ? EXCESS FUND BALANCE IN FOOD SERVICE FUND Type: Material Weakness in Internal Control / Noncompliance ? Special Tests and Provisions Program: Child Nutrition Cluster (ALN 10.553, 10.555 and 10.559) 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 $165,196. Criteria: The USDA requires that the District limit its net cash resources to an amount that does not exceed 3 months average expenditures of the nan-profit food service fund per requirements in 7 CFR Part 210. 14(b). Cause: This condition was caused by the meal claims increasing and having more reimbursements come in than anticipated. Effect: The District will be required to develop a spending plan for reducing the balance to an acceptable level during the following school year. The plan must be submitted to MDE, Office of School Support Services, for prior approval. Recommendation: We recommend that the District develop a spending plan as required by MDE, and submit the plan at their earliest convenience. Corrective Action Plan: Shepherd Public Schools will work with MDE to create a spenddown plan to address the excess fund balance in the food service fund. This plan will include allowable equipment upgrades and replacements to be crafted in collaboration with the food service director, district business manager and superintendent, as well as any other members deemed appropriate by superintendent. The process of creating the plan is expected to begin immediately, with compliance of 7CFR Part 210.14(b) to be met no later than June 30, 2023.

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, After School Snacks, Summer Food Service Program for Children Assistance Listing Number: 10.553, 10.555, 10.559 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 over/under claimed for the month. We noted that in October 2020, the School Corporation had underclaimed lunches by 212 meals and overclaimed breakfast by 42 meals. In April 2021, the School Corporation had overclaimed breakfast by 397 meals. In October 2021, the School Corporation had underclaimed lunches by 48 meals and snacks by 36 meals. In April 2022, the School Corporation had overclaimed lunches by two meals, snacks by 45 meals, and underclaimed breakfast by 2 meals. 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 are accurate and 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 will be implemented 4/1/2023.

2022-002 Federal Funding Accountability and Transparency Act Reporting View of Responsible Officials Management agrees with the finding and recommendation. Corrective Action Plan Hawaii Child Nutrition Programs (HCNP) will update its standard operating procedures to ensure that required FAFATA reports are completed in a timely and accurate manner. HCNP will reopen the affected FFATA reports to correct the noted information Contact Person: Sharlene Wong, Administrator Hawaii Child Nutrition Programs Office of Fiscal Services Anticipated Completion Date: May 31, 2023

Corrective Action Plan That the School District's edit check worksheets agree with the food service daily meal count reports in an effort to request the appropriate amount of Federal and State reimbursement. Method of Implementation Food Service meal count Edit check worksheets will be verified to the monthly request for reimbursement. Person Responsible Food Service Specialist; Food Service Director; Business Administrator

REPORTING Federal agency: U.S. Department of Agriculture Federal program title: Child Nutrition Cluster CFDA Number: 10.553, 10.555, and 10.559 Pass-Through Agency: Minnesota Department of Education Pass-Through Number(s): 1-0381-000 Award Period: June 30, 2022 Type of Finding: ? Material Weakness in Internal Control over Compliance CORRECTIVE ACTION PLAN (CAP): Recommendation: We recommend the District review and approve the CLiCS meal counts timely before they are submitted. Explanation of Disagreement with Audit Findings: There is no disagreement with the audit finding. Actions Planned in Response to the Finding: The District will continue to work on establishing a process to ensure all CLiCS meal counts are reviewed and approved timely. Official Responsible for Ensuring CAP: Tanner Spawn, Business Manager. Planned Completion Date for CAP: June 30, 2023.

2022-001. Reporting Child Nutrition Cluster National School Lunch Program Assistance Listing No. 10.555 COVID-19: School Breakfast Program (SSO) Assistance Listing No. 10.553 COVID-19: National School Lunch Program (SSO) Assistance Listing No. 10.555 COVID-19: National School Lunch Program (Emergency Operational Costs Reimbursement) Assistance Listing No. 10.555 COVID-19: Summer Food Service Program Assistance Listing No. 10.559 Condition: Upon testing of the monthly reimbursement claims for meals served it was noted that due to an error in how certain meals served in one elementary school were input into the District?s point of sale system in one month that not all meals served were included on the monthly breakfast reimbursement claim. This resulted in the District not receiving reimbursement for all breakfast meals served. Planned Corrective Action: The District is implementing additional procedures where all meal claims for reimbursement are reviewed and approved by an individual independent of the preparation of the reimbursement claim prior to it being submitted to the State. Responsible Contact Person: Dr. Patrick Pizzo, Assistant Superintendent for Business and Finance East Meadow Union Free School District The Leon J. Campo Salisbury Center 718 Plain Road - Westbury, NY 11590 Anticipated Completion Date: June 30, 2023.

Corrective Action Plan 2022-001 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 Lindsey Newland, the food service director and Shelly Meeder, 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.

2022-003 Child Nutrition Cluster ? Assistance Listing No. 10.553, 10.555, & 10.559 Recommendation: We recommend the District update policies related to school nutrition reporting to ensure they have appropriate reviews that would prevent or detect errors or fraud. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The School Nutrition Supervisor and Supervisor of Finance approve all expense transactions on an ongoing basis. By the third week of each month, a designated Accounting Assistant runs financial reports used to prepare the monthly school nutrition program claims. The Budget Manager has not approved the claims prior to submission, which has been the practice for all other District programs. Effective July 1, 2022, the accounting assistant schedules a meeting with the School Nutrition Supervisor to review each monthly claim, clarify questions and adjust if needed, prior to submitting a claim to DPI. Name(s) of the contact person(s) responsible for corrective action: Davita Jo Molling, Supervisor of Finance Planned completion date for corrective action plan: July 1, 2022

2022-003 Child Nutrition Cluster Recommendation: School Corporation management should establish a system of internal controls to ensure compliance with the grant agreement and program income requirements. Documentation should be retained to support the existence and accuracy of all program income earned. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: The school corporation with review existing control processes surrounding program income and strengthen procedures to ensure documentation to support program income is adequate and reviewed. Name of the contact person responsible for corrective action: Cheryl Harvey, Business Manager Planned completion date for corrective action plan: Begin immediately

Purchase Needed Equipment

FINDINGS ? FEDERAL AWARD PROGRAMS AUDIT U.S. Department of Education Passed Through Kansas State Department of Education Program Name: Child Nutrition Cluster Federal Assistance Listing Numbers: 10.553; 10.582; 10.559 Finding 2022-001 ? Internal Controls Recommendations: The District should have an employee compare the District Treasurer?s supporting documentation and the Child Nutrition report before its submission to the State of Kansas for its accuracy. After the approval by the secondary review employee, the report submitted should be printed, initialed by the secondary reviewer, stapled with the information used to compile the report and combined with all financial records for the fiscal year. Action Taken: We agree with the recommendation. Our targeted implementation date is March 2022.

FINDING 2022-002 Contact Person Responsible for Corrective Action: Shawn Spindler, Business Manager/Treasurer Contact Phone Number: 812.926.2090 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The appropriate personnel will prepare some sort of time and effort documentation which will then be approved by the Board of Trustees to have split personnel costs. Anticipated Completion Date: June 2023

FINDING 2022-002 Contact Person Responsible for Corrective Action: Dr. Michael Galvin, Superintendent Contact Phone Number: 812-874-2243 Views of Responsible Official: We concur with the finding for the period of the audit, we have since corrected the actions by the end of the 2021/2022 school year. Description of Corrective Action Plan: Aramark supplies all invoices, TDR and copies of receipts to be verified with the monthly invoice. The Food Service Director then goes through the invoices, receipts, and TDR sheets to verify all charges to the SFA are accounted for and correct. The Food Service Director initials the invoices and receipts to show they have been verified against the TDR and bill for Aramark. When the Food Service Director has completed the verification, they fill out a purchase order to have the ECA pay Aramark. Anticipated Completion Date: The corrective action plan was implemented in April of 2022.