Corrective Action Plans

Finding 22-06 Name of Contact Person: Jay Toland, Associate Superintendent of Business Operations Corrective Action Plan: A monthly process will be created and implemented to ensure timely and accurate sales tax refund filings. This will also be included in a yearly reconciliation process to ensure the monthly process is being completed. Requisite staff training will be provided. Proposed Completion Date: Immediately

The District concurs with the auditor?s finding. The delay in the report submission is due to unusual circumstances and events during the fiscal year. We will communicate to the appropriate personnel the importance of providing requested documents and responding to auditor inquiries in a timely manner. See Corrective Action Plan for chart/table

DCPS agrees with the conditions and recommendations of this finding. The DCPS corrective action plan includes the following steps: While the meal program review process generally works well, it has become evident that there is a need to better capture completed reviews in addition to off-boarding staff from the FNS team. In this situation, a transition of staff and incomplete off boarding and incomplete uploading of the departing staff member?s laptop was found to be the root cause for FNS? inability to produce the 2 missing reviews. Moving forward, FNS Staff will be completing a verified upload of reviews to the DCPS-FNS SharePoint site as each cycle is completed. Validation that the upload from each Field Specialist has been completed will flow from the FNS Field Operations Specialist to the FNS Operations Manager. And a confirmation email will be sent from the FNS Operations Manager to the Specialist, Nutrition & Compliance who is accountable to OSSE. A copy of the communication will be maintained with the electronic file for ease of locating. See Corrective Action Plan for chart/table

Corrective Action Plan Finding 2022-001 Finding Summary: The Hollis School District?s Food Service Fund net cash resources were in excess of the maximum allowable amount by $174,479. 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

Recommendation: We recommend 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. Action taken: The district entered into a shared services agreement with Capital Region BOCES in March of 2022 for management of the School Nutrition program. It was assumed that this was a procedure they followed; however, documentation was not provided and the external auditors included it as a finding. Todd Barker is the new School Nutrition Director with BOCES and he will provide documentation to the district that due diligence has been done to meet this requirement. Anticipated completion date: 11/1/2022

Oak Park Elementary School District 97 06-016-0970-02 CORRECTIVE ACTION PLAN FOR CURRENT YEAR AUDIT FINDINGS Year Ending June 30, 2022 Corrective Action Plan Finding No.: 2022 - 005 Condition: The Food Service Director reviewed invoices and providing them directly to the accounts payable department for processing. The District's internal control procedures require invoices to be routed to the Senior Director of Finance for review and approval. Plan: The Food Service Director will provide all invoices for review and approval to the Senior Director of Finance by scanning these invoices and importing them into the Districts accounting software system and properly route these invoices for review and approval in the system. Anticipated Date of Completion: 6/30/2023 Name of Contact Person: Patrick King, Senior Director of Finance

Oak Park Elementary School District 97 06-016-0970-02 CORRECTIVE ACTION PLAN FOR CURRENT YEAR AUDIT FINDINGS Year Ending June 30, 2022 Corrective Action Plan Finding No.: 2022 - 003 Condition: The Food Service Coordinator, prepares and submits monthly reimbursement claims to ISBE and these submissions are not reviewed or approved by anyone else. Plan: The Senior Director of Finance will review monthly reimbursement claims that are prepared by the Food Service Coordinator to ensure that amounts agree to supporting documentation prior to submission. Anticipated Date of Completion: 6/30/2023 Name of Contact Person: Patrick King, Senior Director of Finance

CORRECTIVE ACTION PLAN November 11, 2022 Michigan Department of Education Lansing, Ml Greenville Public Schools is in agreement with the findings identified and respectfully submits the following Corrective Action Plan for the year ended June 30, 2022. 2022-003 The cash balance in the District's food service fund exceeded the allowable 3 month expenditure amount as of June 30, 2022. The district employee responsible for this area is Matt Andres, Director of Finance. There was a change of leadership in the Finance department at the end of September, 2022. The food service fund balance had not been properly communicated to department leadership, resulting in a surplus of funds. Implementation and Monitoring The District has identified deficiencies in our current processes. A plan has been initiated between the Director of Finance and the Director of Food Service to spend our fund balance within the allowable guidelines during the 2022-2023 fiscal year. If the Michigan Department of Education has any questions regarding this plan, please contact Matt Andres at 616-225-1025?or matt.andres@gpsjackets.org Matt Andres Director of Finance

FINDING 2022-006 Contact Person Responsible for Corrective Action: Tyler C. Osenbaugh Contact Phone Number: 260-336-0217 Views of Responsible Official: Agree with the finding Description of Corrective Action Plan: Meal counts differed from the Meal Magic generated Z report and the Chartwells Profit and Loss statement. These meal counts are reconciled by dividing the a la carte purchases by $2.70 to equate to a meal served. Future Z reports will have the a la carte meal equivalents indicated. These figures will be reviewed and validated during the monthly meeting between School Food Authority and Food Service Director (Chartwells? Director of Dining Services). Anticipated Completion Date: April 2023

Contact Person Responsible for Corrective Action: Tyler C. Osenbaugh Contact Phone Number: 260-336-0217 Views of Responsible Official: Agree with the finding Description of Corrective Action Plan: The School Food Authority and Food Service Director (Chartwells? Director of Dining Services) review and validate the supporting documentation for all food service-related purchases. The documentation, include payroll information and non-payroll expenditures, including vendor deliveries. Copies of the supporting data have been retained by the Business Manager to ensure records are available for audits. The review occurs prior to the SFA submitting for reimbursement into CNPWeb. These steps have been in place correcting the previous finding (2020-002). Future reviews will include supporting vendor (Gordon Food, Piazza, Prairie Farms) price lists in effect during the support period. The prices paid for commodities from these vendors will be compared to Chartwells Operations Ledger to ensure charges are consistent with the costs. Anticipated Completion Date: May 2023

Views of Responsible Officials and Planned Corrective Action: Management agrees with this finding. As noted, a turnover in staff happened right at the time when the verification for FY22 was due and the new staff member did not realize the required verification had not occurred. The School followed proper procedures each year prior to FY22. The School identified the FY22 error at the beginning of the 2022-2023 school year prior to the audit. Immediate action was taken to ensure this error would not reoccur in the future when the School experienced a staffing change. In so doing, the School implemented a step-by-step tutorial of procedures, including reporting dates and deadlines. Necessary staff members have attended, and will continue to attend, training for items related to the application of Educational Benefits. The verification process was checked by a supervisor to ensure proper processes were followed for the 2022-2023 school year and they were.

Condition: The District did not obtain debarment certification or check the System for Award Management website for vendors contracted in excess of $25,000 related to the grant program. Upon further review, it was determined that the vendors were not suspended or debarred. Plan: Procedures need to be implemented to ensure all vendors contracted with have not been suspended or debarred or otherwise excluded from doing business, prior to procuring their services. Anticipated Date of Completion: June 1,2023 Name of Contact Person: Dr. Chad Allaman Management's response: There is no disagreement with this finding and procedures will be implemented to ensure all vendors contracted with have not been suspended or debarred or otherwise excluded from doing business, prior to procuring their services.

Purchase Needed Equipment

FINDING 2022-004 CONTACT PERSON RESPONSIBLE FOR CORRECTIVE ACTION: Lacey Sturgeon/Melissa Bell CONTACT PHONE NUMBER: 765-762-2500 VIEWS OF RESPONSIBLE OFFICIAL: We concur with the finding. DESCRIPTION OF CORRECTIVE ACTION PLAN: All claims will be compiled by the Director of Food Services and validated by the Assistant Food Service Manager. ANTICIPATED COMPLETION DATE: March 2023

FINDING 2022-002 CONTACT PERSON RESPONSIBLE FOR CORRECTIVE ACTION: Lacey Sturgeon/Melissa Bell CONTACT PHONE NUMBER: 765-762-2500 VIEWS OF RESPONSIBLE OFFICIAL: We concur with the finding. DESCRIPTION OF CORRECTIVE ACTION PLAN: All claims/invoices will be reviewed by the Food Service Director and validated by the Assistant Food Service Director for correct contractual prices. ANTICIPATED COMPLETION DATE: March 2023

See corrective action plan

CORRECTIVE ACTION PLAN 2022-001 This finding is caused by the District not having the proper controls in place to prevent, detect, or correct an incorrect monthly meal claim. There was lack of consistency and communication between the Food Service Director and the Business Manager during the fiscal year in relation to meal claims. The persons responsible for the corrective action are Janet Killingsworth, the food service director and Dr. Lori Haven, the superintendent. 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 finance director will work together to ensure that monthly meals served are being reconciled prior to any meal reimbursement requests are made.

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 Michigan Department of Education approved 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 Shelley Ritchie, the food service director and Nadia Hoover, 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.

Finding 2022-003 Finding Summary: The Organization did not have adequate controls to ensure household income was properly certified and may have allowed ineligible households to receive USDA Foods. Responsible Individuals: Administrative assistant (Wendy Matheney) and Front Desk Supervisor (Shannon Thackeray) Corrective Action Plan: Signature paperwork will be verified individually for each client by the front desk staff. The Admin Assistant will supervise data collection and integrity from a big picture standpoint. Anticipated Completion Date: 1/15/2023

2022-004 Special Tests and Provisions ? Verification of Free and Reduced Price Applications Federal Assistance Listing Number: 10.CNC District is in the process of establishing procedures and controls by the Business Manager to oversee the retention of verification documentation and information obtained through the verification process. Responsible Official: Karl Volkmann, Business Manager Anticipated Completion Date: June 30, 2023

2022-003 Segregation of Duties ? Reporting Federal Assistance Listing Number: 10.CNC Management is cognizant of the District?s internal control structure and continues to evaluate cost effective opportunities to further improve segregation of duties. It is the District?s plan to train an individual in the process of submitting claims in order to create a review process of the grant management process. Responsible Official: Karl Volkmann, Business Manager Anticipated Completion Date: June 30, 2023

Current Year Finding #2022-001- Repeat Finding for 2021-001 According to 2 CFR section 200.305(b)(5), when non-federal entities are funded under the reimbursement method, the entity should pay for costs for which reimbursement was requested prior to the date of the reimbursement request. During our audit, we noted the monthly claims for reimbursement were not compared to reports from the point of sale ("POS") system by an individual other than the preparer of the claims report prior to submission. We recommended that the district have an individual other than the preparer of the claims report, review the reports from the POS system prior to submission to verify that the number of meals claim based on actual meals served. Corrective Action: Effective July 30th, 2022, the Food Service Manager will prepare and review the meal count and meal reimbursement to the reports from the point-of-sale system, then prior to submittal will give to the reports from the POS system to the Business Administrator, Mr. Salvatore Carambia to verify and approve the reports from the POS system that the number of meals claimed was based on actual meals served.

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE ? U.S. DEPARTMENT OF AGRICULTURE, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, CHILD NUTRITION CLUSTER ? FEDERAL ALN 10.553, 10.555, AND 10.559 2022-002 Internal Control Over Compliance With Suspension and Debarment Requirements Finding Summary 2 CFR ? 180 requires the Academy to establish and maintain effective internal control over compliance with requirements applicable to federal program expenditures, including suspension and debarment requirements applicable to the child nutrition cluster program. The Academy did not have sufficient controls in place within its child nutrition cluster of federal programs to ensure that it was not contracting for goods or services with parties that are suspended or debarred, or whose principals are suspended or debarred, from participating in contracts involving the expenditures of federal program funds. Corrective Action Plan Actions Planned ? The Academy will review policies and procedures relating to suspension and debarment for its federal programs and will ensure that all parties with which it contracts for goods or services exceeding $25,000 are eligible to participate in contracts involving the expenditures of federal program funding. Official Responsible ? The Academy?s Interim Executive Director, Holly Fischer. Planned Completion Date ? June 30, 2023. Disagreement With or Explanation of Finding ? The Academy agrees with this finding. Plan to Monitor ? The Academy?s Interim Executive Director, Holly Fischer, will ensure appropriate internal controls are in place to verify that any vendor with which the Academy contracts for goods or services exceeding $25,000 is not listed as suspended or debarred on the federal Excluded Parties List System website.

Finding 2022-001 Corrective Action Plan a. Contact person responsible for corrective action: Stacey Graves, CFO b. Description of correction action to be taken: The district will exercise caution in ensuring calculations for indirect cost will calculated as directed by the Mississippi Department of Education. c. Anticipated completion date of corrective action: 3-24-23

FINDING 2022-002 Subject: Child Nutrition Cluster ? Internal Controls Audit Finding: 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. Context: The School Corporation contracts with a food service management company for the majority of food costs, labor costs, and operational costs, however in some cases the School Corporation will handle their own additional minor procurements outside of the food service management company. During the audit period, the School Corporation made one purchase between $10,000 and $150,000 which fell under the small purchase method for federal and state procurement regulations and was charged to Fund 0800 ? School Lunch Fund. For that purchase, documentation was not presented to verify methods or rationale used to satisfy the procurement requirements, which require three quotes to be obtained prior to entering into a transaction. The transaction was incurred in July 2021 in the amount of $21,668. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Quotes will be sought for all purchases that fall within the small purchase threshold according to federal and state procurement regulations. Responsible Party and Timeline for Completion: Zach Dennis, CFO, 7/1/2022