Corrective Action Plans

Finding Number: 2022-002 Planned Corrective Action: The District has initiated an internal audit reconciliation system to confirm each month that all reimbursable breakfast and lunch reports agree. Anticipated Completion Date: 07/01/2022 Responsible Contact Person: Neil Laughbaum, Director of Operations

Views of Responsible Officials: During the COVID 19 pandemic the District experienced turnover in various key positions resulting from a lapse with record keeping. Management will work to ensure that records related to claim reimbursements are retained for a period of three years. Name of Responsible Person: Jennifer LaBarre, Executive Director of Student Nutrition Services Implementation Date: Fiscal Year 2023-2024

Finding: 2022-003 Cash Management Name of Contact Person: Ms. Robin Norwood Corrective Action: Automation clerk will work with NAF administration personnel to provide management of cash. Proposed Completion Date: August 21, 2023

CORRECTIVE ACTION PLAN November 28, 2022 Central City Cyberschool respectfully submits the following corrective action plan for the year ended July 31, 2022. Walkowicz, Boczkiewicz & Co 1800 East Main Street, Suite 100 Waukesha, WI 53186 Audit period: July 31, 2022 The findings from the July 31, 2022 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AND STATE AWARDS DEPARTMENT OF AGRICULTURE MATERIAL WEAKNESS 2022-001 School Breakfast Program ? CFDA No. 10.553, National School Lunch Program ?CFDA No. 10.555 Condition: There was no verification that the number of meals provided matched the monthly vendor invoice. Criteria: Internal Controls should be in place to ensure the vendor invoices were properly reviewed. Recommendation: Internal controls procedures should be established to ensure the number of meals provided match the monthly vendor invoice. Action Taken: ? Internal controls were established to ensure meals are recorded at point of service. ? Students enter their student number into the student information system (SIS) at point of service. ? Cyberschool employee monitors meals to determine if it qualifies for reimbursement in addition to clicking ?accept? with each SIS entry for a meal. ? There is a back-up paper check off system for employee monitoring to use if primary counting system (SIS) goes down during lunch hour. ? Vendor receives SIS printout the following day to confirm meals recorded. ? Vendor uses SIS printout report to invoice the school. ? When the invoice arrives, the School Operations Manager uses the SIS to confirm bill matches meals served. If questions arise regarding this plan, please call Jessica Whitaker at 414.444.2017

Reference Number: 2022-004 Description: Child Nutrition Cluster ? Reporting Corrective Action Plan: The pandemic-related policies for food service reporting ended on June 30, 2022. For the 2022-23 school year, the District has re-instituted the use of IDs and student numbers to track meal purchases by individual students. Reports from Skyward will be utilized and compared against claim data on a monthly basis . Anticipated Corrective Action Plan Completion Date: 9/1/2023 Contact Information: For additional information regarding this finding please contact Kevin Klimek, Director of Business Services, 414-371-6774

Federal Agency: U.S. Department of Agriculture Federal Program: Child Nutrition Cluster Assistance Listing Number: 10.555 and 10.559 Pass through Agency: Arizona Department of Education Pass Through Number: 7AZ300AZ3 Award Period: July 1, 2021 through June 30, 2022 Repeat Finding: Yes ? 2021-004 Type of Finding: Significant deficiency in internal controls over compliance and immaterial matter of noncompliance 2022-006 Condition: The District did not maintain documentation to support proper review and approval of the monthly meal reimbursement claims. Criteria or Specific Requirement: CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards requires compliance with cash management compliance requirements. The District should have internal controls designed to ensure compliance with those provisions. Context: For four of four monthly meal reimbursement claims tested. Corrective Action Plan: The District will retain documentation in future years to show that monthly claims summaries are reviewed. Anticipated Completion Date: June 30, 2023 Name of Contact Person: Pam Bradford, Interim Business Manager

Contact Person Responsible for Corrective Action: Brian Leitch, Chief Finance & Operations Officer / Treasurer 260-347-2502 ext.: 10017 Roger Urick, Interim Food Service Director 260-347-2502 ext.: 10011 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Internal Controls: The monthly meal reimbursement claims will be calculated by the Food Service Director by using information obtained through meal magic. Once the meal reimbursement is calculated it will be reviewed by the Deputy Treasurer before being submitted by the Food Service Director. Once the reimbursement is received the Deputy Treasurer will verify it was received as submitted. Anticipated Completion Date: April 2023

Finding 2022-002: Child Nutrition Cluster Resource Management Procedures Pass-through entity: Michigan Department of Education Assistance Listing Number(s): 10.553, 10.555 and 10.559 Award Numbers: COVID-19 211971, COVID-19 221970, COVID-19 221971, COVID-19 211961, COVID-19 220910, COVID-19 221960, COVID-19 221961, COVID-19 210904 and Entitlement Commodities Award Year Ends: June 30, 2022 Recommendation: The School District should develop and complete a spend-down plan to ensure it reduces its Food Service Fund net cash resources below the maximum allowable amount. Action Taken: The School District has started to develop a spend-down plan that it will implement and complete in the fiscal year ending June 30, 2023. Responsible Person and Anticipated Completion Date: The Superintendent is responsible for the development and execution of the spend-down plan with a completion date of June 30, 2023. If the Michigan Department of Education has questions regarding this plan, please call Mark Platt at (231) 873-6224.

FINDING 2022-003 Contact Person Responsible for Corrective Action: Julia Smith, Business Manager Contact Phone Number: 317-788-4481 Views of Responsible Official: We concur with the findings Description of Corrective Action Plan: The Foodservice Director and Business Manager will refer to the Guidance for State Agencies and School Food Authorities manual to ensure compliance for allowable costs. Anticipated Completion Date: January 2023

Findings and Questioned Costs Related to Federal Awards Finding Number: 2022-001 Contact Person: Dr. Shelley Isai, Assistant Superintendent for Education Services Anticipated Completion Date: November 21, 2022 Planned Corrective Action: The District reviewed the procedures used to determine Title I, Part A eligibility in the Grants Management System as well as a process that includes maintaining records. The process was redefined for the fiscal year 2023 grant application but will change slightly in future years due to a change in the options in criteria available used to determine eligibility for fiscal year 2023 grant applications. To complete this process with accuracy, the Director of Federal Projects will communicate the required eligibility criteria to the Director of Nutrition Services. The Nutrition Services department will provide Federal Projects with the necessary information to complete the process. Supporting documentation for the basis of fiscal year 2023 and the future years will be stored in a shared file and readily accessible for reference or audits. This process has been documented to ensure consistency through any department transitions.

FINDING 2022-004 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, Summer Food Service Program for Children Assistance Listing Number: 10.533, 10.555, 10.559 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Significant Deficiency 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: For one of our procurement selections, out of a sample of two, the School Corporation was not able to provide verification that the vendor is not suspended or debarred. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and will take the following corrective action. The Treasurer will ensure the Procurement and Suspension and Debarment requirements are met prior to purchase for the Child Nutrition Program by reviewing the quotes and checking SAM.gov. Responsible party and timeline for completion: The Corporation Treasurer will be responsible effective immediately.

FINDING 2022-003 Information on the federal program: Subject: Child Nutrition Cluster - Reporting Federal Agency: Department of Education Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Significant Deficiency 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 one sponsor claim reimbursement in a sample of four claims, the Food Service Director prepared the sponsor claim reimbursement summary without a secondary, documented review before the submission of the claim to ensure the accuracy of the sponsor claim reimbursement summary. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and will take the following corrective action. The Food Service Director will have the School Nutrition Program Director review, approve and initial the sponsor claim reimbursement summary before submission. Responsible party and timeline for completion: School Nutrition Program Director and School Treasurer will be responsible effective immediately.

Compliance: Finding: 2022-007 Condition: The District does not have a process in place currently nor is using the USDA's Nonprogram Revenue Tool to monitor the District's compliance with 7 CFR 210.14(f) to ensure that costs of nonprogram foods are not being subsidized by program food revenues. Plan: The District will begin using the USDA's Nonprogram Revenue Tool as well as work with Aramark to change the presentation of the invoices received. The District will also request additional monthly reports detailing revenue from nonprogram foods. Anticipated Date of Completion: June 30, 2023 Name of Contact Person: Dr. Joel Hackney, Superintendent Management's Response: Management will begin using the USDA's Nonprogram Revenue Tool, updated invoices from Aramark, and new reports from Aramark to ensure compliance with the Code of Federal Regulations.

Compliance: Finding: 2022-006 Condition: There was no termination clause noted in the Aramark contract stating whereby either party may cancel for cause with 60-day notification as required by 7 CFR 210.16(d) and 7 CFR 220.7(d)(4). Plan: The Aramark contract will be updated to include the proper termination clause stating whereby either party may cancel for cause with 60-day notification. Anticipated Date of Completion: June 30, 2023 Name of Contact Person: Dr. Joel Hackney, Superintendent Management's Response: Management will ensure the Aramark contract has been updated with the proper termination clause before signing another contract.

Compliance: Finding: 2022-005 Condition: No on-site review was done for the National School Lunch Program or for the School Breakfast Program as required to be done prior to February 1 of each school year to remain compliant with 7 Code of Federal Regulations (CFR) 210.8(a)(1) and 7 CFR 220.11(d)(1). Plan: On-site reviews will be completed for both the National School Lunch Program and the School Breakfast Program by February 1 of each school year. Anticipated Date of Completion: June 30, 2023 Name of Contact Person: Dr. Joel Hackney, Superintendent Management's Response: Management will ensure all necessary on-site reviews are completed by February 1 of each school year.

We purchased items via an interlocal agreement, ?piggybacking? on their contract. We had relied on the documentation done by the contracting agency instead of conducting a SAM verification ourselves. Prior to the audit, we had already updated our documentation for the subsequent year. We have revised our procedure further to ensure a two person control on the completion and documentation of compliance with federal suspension and debarment requirements.

Purchase Needed Equipment

See Corrective Action Plan for chart/table

CORRECTIVE ACTION PLAN Finding 2022-001: Immaterial Noncompliance Federal Award Finding 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 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 Gennie Knapp, the director of dining and nutrition services and Emily Kearney, chief financial officer. The plan for monitoring adherence is the food service director and chief financial officer will work together to assess where the fund balance is after all of the projects from the spend down plan are completed.

FINDING 2022-002 Contact Person Responsible for Corrective Action: John Szabo, Director of Business Affairs Contact Phone Number:812-443-4461 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: In order to monitor allowable costs, the Food Services Director (currently Patricia Woolery) will review billing statements and insure that costs being billed to the school corporation are consistent with purchasing agreements that are in place. Food Services Director will communicate with vendors and review any communication from vendors in regards to price variance of items. Even though it may not be reasonable to double check each individual item ordered, Food Services Director will spot check an appropriate number of items to insure accuracy of costs. Anticipated Completion Date: August 1, 2023

DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION 2022-003 Child Nutrition Cluster ? Assistance Listing No. 10.555, 10.559, 10.582 Action taken in response to the finding: The timeliness of reporting was affected by FSRS rejecting original report submittals and correcting the errors timely. To address this issue, DESE will review, and enhance procedures and internal controls to ensure that all required subawards are reported timely to FSRS no later than the end of the month following the month of issuance. Specifically; (1) update procedures to ensure that DESE maintains all supporting documentation for report delays due to FSRS rejections and issues that arise during the reporting process that may cause delays in timely reporting; and (2) Incorporating other DESE units and staff in resolving reporting issues to avoid reporting delays. Name of the contact person responsible for corrective action: Robert Curtin, Associate Commissioner of DATA, Robert Leshin, Director of Nutrition, Robert McDonald, Federal Grants Manager, Jeffrey Benbenek, Director of Audit & Compliance Planned completion date for corrective action plan: July 1, 2023

DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION 2022-002 Child Nutrition Cluster ? Assistance Listing No. 10.555, 10.559, 10.582 Action taken in response to the finding: The Office for Food and Nutrition Programs (FNP) has moved from a paper based permanent agreement to a web form that exists on the DESE Security Portal. All existing and new Child Nutrition Sponsors will continue to sign off on the document via the web-based portal allowing for a more efficient collection and document retention process. The identified sponsors with missing permanent agreements for the time period selected now have signed permanent agreements via the web-based form. Name of the contact person responsible for corrective action: Robert Leshin, Director of Nutrition Planned completion date for corrective action plan: Action Completed

Finding 2022-004 ? Child Nutrition Cluster - Reporting Contact Person Responsible for Corrective Action: Christopher deBruyn Contact Phone Number: (219) 785-2239 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Moving forward, after the claims report has been processed by the Food Service Director a documented review will be completed by the Food Service Manager or a member of the corporation staff, Signatures will be required for proof of verification, and review. Anticipated Completion Date: Now

Corrective Action Planned: Management will review the internal controls in place to ensure disbursements are properly approved. Person Responsible for Corrective Actions: Director of Business, Ouachita Parish School Board, 1600 North 7th Street, West Monroe, LA 71291. Phone: (318)432-5234 Fax: (318)432-5221.

Condition The District submitted inaccurate meal counts for reimbursement. Recommendation We recommend that the District review its controls related to monthly reimbursement requests for the Child Nutrition Cluster in order to ensure that accurate meal counts are submitted. Action Taken The School District has resubmitted the December 2021 meal count claims, which have been approved by KSDE. As of August 2022, paper meal count sheets are no longer being used to account for meals, and the Food Service Program is back to using their POS eTrition for meal counting, which will reduce the errors of meal claims. Steps when preparing to submit meal claims will be as follows: 1. Managers at each school will ensure meal counts on their 9-A & 9-B excel forms match their eTrition meal counts. 2. The Production Records Secretary will double check that the 9-A & 9-B excel forms that were turned in match the meal counts in eTrition. 3. The Director will input the claims based off of the 9-A & 9-B excel forms. 4. The Director will have the Office Manager double check that the claims were input into KN-Claim correctly before the Director will make the final submission.