Corrective Action Plans

School District No. 27-0595, North Bend, Nebraska, respectfully submits the following corrective action plan for the year ended August 31, 2022. Name and address of independent public accounting firm: Romans, Wiemer & Associates, Certified Public Accountants, P.C., 1910 N Lincoln Ave, York, NE 68467 Audit Period: September 1, 2021 through August 31, 2022 The findings from the November 3, 2022 schedule of findings and questioned cost are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS ? FINANCIAL STATEMENT AUDIT MATERIAL WEAKNESS 2022-001 Internal Control Structure Design Recommendation: While considering the cost of any benefits derived, activities should be segregated and handled by different employees. Action Taken: The cost of implementing a complete set of controls far outweighs the benefits derived by such. It is not financially feasible to have a complete set of controls. FINDINGS ? FEDERAL AWARD PROGRAM AUDIT Nebraska Department of Education 2022-002 Internal Control Structure Design Recommendation: While considering the cost of any benefits derived, activities should be segregated and handled by different employees. Action Taken: The cost of implementing a complete set of controls far outweighs the benefits derived by such. It is not financially feasible to have a complete set of controls.

Corrective Action Plan and Views of Responsible Officials The District will continue to implement the following procedures, which were initially put in place in December of 2021, after the meal counting error was identified in October of 2021: 1. Site Numbers will be collected via a clicker counter or tally sheet. This information will be documented on paper and sent to the Claim Preparer to verify and ensure accuracy. 2. The data from the counters and Tally sheet will be entered into the back-office Point of Sale software system instead of a spreadsheet. 3. Monthly reports will be generated when creating the claim and an Edit Check will include auditing daily participation numbers to ensure days have not been skipped. 4. The claim will be entered in CNIPS following standard ?Meal Counting & Collecting Procedures? as approved by the State. Implementation Date: Fiscal Year 2021-2022

U.S. Department of Agriculture: Octorara Area School District respectfully submits the following corrective action plan for the year ended June 30, 2022: Name and address of independent public accounting firm: Herbein + Company, Inc. 2763 Century Boulevard Reading, PA 19610 Audit Period: Year ended June 30, 2022 Anticipated Completion Date: December 31, 2022 Contact Person: Jeff Curtis, Business Manager Finding - Federal Award Findings and Questioned Costs 2022-001 ALLOWABLE ACTIVITIES - SIGNIFICANT DEFICIENCY Federal Program Child Nutrition Cluster COVID-19 - National School Lunch Program ALN 10.555; passed through the Pennsylvania Departments of Education and Agriculture; Grant Period 7/1/21-6/30/22 COVID-19 - School Breakfast Program ALN 10.553; passed through the Pennsylvania Department of Education; Grant Period 7/1/21-6/30/22 Criteria Title 7 CFR 210 covers the reimbursement process under the Child Nutrition Cluster. It requires the submission of claims for reimbursement that include the number of reimbursable meals served by category and type during the period (generally a month) covered by the claim. As a subrecipient of funds passed through the Pennsylvania Department of Education (PDE), Octorara Area School District must submit monthly claim forms to PDE, which include the number of reimbursable meals served by category (free, reduced, paid) and type (breakfast, lunch). Condition/Cause The District manually inputs the amount of meals served by location into a spreadsheet in order to obtain totals to type into the monthly claim reimbursement form. A data input error, failing to include a location in the spreadsheet for certain days, led to an incorrect number of meals reported on one claim report from our sample. Controls in place over claim reporting did not detect and correct this error before submission. Effect As a result of the claim report not being filed accurately, the District lost approximately $730 of federal subsidies that would have been received if the correct meal count was used. Questioned Costs Less than $25,000 Context We examined 4 of the monthly reimbursement claim reports submitted during the year by the District and noticed the deviations noted above in one of those reports. Total subsidy revenue for the District for the year ended June 30, 2022 was $981,173. Had the District filed an accurate claim report for the month noted above, subsidy revenue would have been $981,903. The lost revenue is 0.074% of total federal subsidy revenue for the year. No statistical sampling was used in our testing. Repeat Finding No. Recommendation We recommend that the District revisit the current procedure for verifying accuracy of meal counts prior to claim submission for areas where the control could be strengthened. The review should include comparison of the report to meal count reports for all locations to verify accuracy. The review should also include a comparison to prior monthly reports for reasonableness. We recommend that the reviewer initial the report draft or otherwise maintain support of this review. Management Response The Food Service management team will enhance their current procedure to include the recommendations listed in this corrective action plan. Meal count hard copy reports by location will be submitted to the Food Service Supervisor each month to be tallied and compared to the meal count summary reports in the PrimeroEdge management system. The Supervisor will also confirm that hard copy reports are received for each group of students at each location and will initial the reports after the review. After confirmation from the Supervisor, that all locations are accounted for and the totals are correct, The Food Service Director will review the reports to ensure that the total meal counts are reasonable by comparing the reports to prior monthly reports adjusted for differences in the number of days in each month. Jeff Curtis, Business Manager

Nutrition services is aware of the excess funds and will be filing a spend down plan with Michigan Department of Education as soon as officially notified. The Director in conjunction with Maintenance and Finance has identified necessary improvements to equipment and has formulated a plan to substantially spend the excess funds within the next fiscal year pending approval from the State.

Finding Summary: During the course of our engagement, we noted instances where documentation was not retained supporting payroll expenditures and invoices were paid in an incorrect amount that was charged to the federal Child Nutrition Cluster program. Responsible Individuals: Shane Monson, Superintendent. Corrective Action Plan: The District will review and strengthen the controls surrounding the review and approval of allowable costs to ensure they are supported, approved of, and calculations are accurate. Anticipated Completion Date: June 30, 2023

Finding Number: 2022-013 ? Activities Allowed or Unallowed and Allowable Costs/Cost Principles Corrective Action Plan: A process has been put in place for the school principal to review all RFRs prior to submission to the grantor. Approval is evidenced by email sent by principal to the Director of Grant Management, which is saved with the RFR as support. Responsible Individuals: Nachum Golodner, Director of Accounting Anticipated Completion Date: June 30, 2023

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