Corrective Action Plans

Response: The School District has begun taking action to address this issue, as follows: Equipment Improvement - School Food Service Director, Joe Kilmer, Food Service Manager, Ann Overhiser, and School Business Administrator have plans to improve and replace cafeteria equipment. The replacement plan will be completed in conjunction with the District?s Capital Project which is scheduled to be completed by June 30, 2023. Retained Balance for Pending Settlements - Increased wages (extending into 2022 and beyond) The minimum wage in New York State is expected to continue to rise over the next several years according to legislation. The rate will rise to $14.20 per hour by the end of 2022. Annual increases will continue until the rate reaches $15.00 per hour (a 66% increase from 2015-2016 levels). Annual increases will be published by the Commissioner of Labor and based on a number of economic factors. Due to the critical labor shortage, the District recently increased hourly wages for food service helpers and cooks in order to attract additional workers to maintain operations. Enhanced Meals - Food Service Director Joseph Kilmer and Food Service Manager, Ann Overhiser, continue to take steps to improve food options. They include making improvements to center of the plate options and improving local food options as well. In addition, the District plans to spend a portion of the School Lunch excess cash on cafeteria equipment as a part of its ongoing Capital Project which is expected to be completed by June 30, 2023.

Identifying Number: 2022-003: U.S. Department of Education: Education Stabilization Fund: Student Aid Portion ? 84.425E (HEERF); U.S. Department of Agriculture: Child Nutrition Cluster ? 10.553, 10.555, and 10.559 (CNC) Finding: For one vendor paid with HEERF funding and one vendor paid from CNC funding, there was no documentation to support that the District had verified that the vendors were not suspended or debarred prior to purchases. Corrective Action Taken or Planned: This relates to the Entity Exclusion (Suspension/Debarment) list maintained on the federal SAM.GOV website. Access to the website and specifically the Entity search functions is limited to authorized/registered users. The corrective action plan for HEERF will include the designation of a Southeast Technical College employee with SAM.GOV access that will be the initial point of contact for vendor exclusion information for all Southeast Technical College employees. Additionally, the designated employee will periodically download, and post debarment lists to the Southeast Technical College internal website (myTech) that will be available to all employees purchasing goods/services that would be charged to federal programs. Additional corrective actions will include a review of existing Southeast Technical College procurement policies contained within Section D: Fiscal Management. Policies will be reviewed/revised to expand and reflect current federal procurement requirements under 2CRF200. Revised policies, debarment lists, and training will be provided to all employees on a periodic and ongoing basis. For the Child Nutrition Cluster, this particular vendor was not expected to go over $25,000 and was used for emergency purchases that did not go over $25,000 until the last purchase in June, 2022. It was recommended that all purchases with amounts expected to go over $25,000 be vetted through the District?s purchase order process. Since this vendor was not expected to go over $25,000, it did not go through the purchase order process. The District will continue to use the purchase order process for vendors expected to go over $25,000 to ensure debarment requirements are being followed. Contact person: HEERF: Rich Kluin, Vice President ? Finance and Operations, Southeast Technical College. CNC: Gay Anderson, Child Nutrition Supervisor. Status of finding ? HEERF procedures will continue to be followed. The CNC procedures will continue to be followed.

#2022-006 Untimely Data Collection Form and Single Audit Reporting Submission U.S. Department of Agriculture Child Nutrition Cluster School Breakfast Program AL #10.553 National School Lunch Program #10.555 Summer Food Service Program for Children AL#10.559 Fresh Fruit and Vegetable Program #10.582 U.S. Department of Education Education Stabilization Fund (ESF) AL# 84.425 Recommendation: We recommend that Management of the Board of Education take the necessary steps to ensure that the year-end financial statements arc supported by accurate reconciliations and documentation in a timely manner o that the reporting package and data collection form can be submitted as required. Action Taken: Management of the Board of Education will properly plan and take the necessary steps to ensure that year-end financial statements are supp01ted by accurate reconciliations and other documentation so that the reporting package and data collection form can be submitted as required by the Uniform Guidance. Whitni Kines, Chief Financial Officer/Treasurer, hired on April 10, 2023, will be responsible for implementing these procedures by March 31, 2024.

Auditor?s Recommendation - When performing the paid lunch equity calculation the District must use the entire food service revenues and expenses to determine if the District meets an exemption from raising student lunch prices for the current school year. Action Taken - The National School Lunch Program is a new program for the District with the District starting participation in the program during the 2020-2021 school year. We now understand how the paid lunch equity calculation works and have calculated that correctly for the upcoming year. Our calculation for the upcoming year was confirmed with the District's auditors. Anticipated Completion Date - This has been completed. Contact Adam Englebretson, District Administrator, 920-876-3381.

See corrective action plan

CORRECTIVE ACTION PLAN 2022-001 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 be before the end of the 2022-23 fiscal year. The person responsible for the corrective action is Dana Reilly, Business Manager. The plan for monitoring adherence is the Business Manager will assess where the fund balance is after all of the projects from the spend down plan are completed.

Recommendation The cost of additional personnel to properly segregate accounting and financial responsibilities would appear to outweigh the benefits received. However, the management and Board of Education should constantly be aware of the possibility that errors, or fraud could occur, and continue current practices mitigating these possibilities and examine and implement other mitigating controls when appropriate. Action Taken The District has assessed the benefits and costs associated with proper segregation of duties for the District and has determined that costs would outweigh benefits received. The District understands the Inherent risks associated with improper segregation of accounting functions. Management has communicated the need for transactions to be well supported by documentation as well as seeking appropriate authorization when appropriate. The District requires monthly reporting to the Board of Education for all disbursements to ensure transactions are proper and potential errors and irregularities are identified on a timely basis. The District will continue to review accounting procedures and processes to further mitigate this internal control deficiency whenever possible and feasible.

Name of Contact Person: Matt Lacy, Chief Financial Officer Recommendation: We recommend the District 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. Proposed Completion Date: Immediately

Name of Contact Person: Matt Lacy, Chief Financial Officer Recommendation: We recommend the District verify a vendor?s status by checking the System for Award Management (SAM) maintained by the General Services Administration before making purchases expected to exceed $25,000. Corrective Action: We will verify all vendors? status using the System for Award Management (SAM) maintained by the General Services Administration before making purchases expected to exceed $25,000. Proposed Completion Date: Immediately

Finding 2022-002: Activities Allowed or Unallowed Federal Agency: U.S. Department of Agriculture Child Nutrition Cluster Federal Assistance Listing Number 10.553, School Breakfast Program Federal Assistance Listing Number 10.555, National School Lunch Program Federal Assistance Listing Number 10.559, Summer Food Service Program for Children Condition During our review of the meals submitted for reimbursement compared to the meals served by the School District, it was noted that the actual meals served did not agree to the meals submitted to New York State for reimbursement. Corrective Action Planned The District will double check all figures entered into the program for reimbursement. Anticipated Completion Date November 2022 Individual Responsible for Corrective Action Plan Lisa Raymond, Assistant Superintendent of Business

Finding Number 2022-004: Corrective Action Required by the Board: Prior to submitting reimbursement claims to the New Jersey Department of Agriculture, the meals claimed should be verified to the meal count activity records and Edit Check Worksheets and/or tally sheets. Method of Implementation: The Food Manager will verify all meal counts and reconcile all discrepancies prior to the submission of claims on a monthly basis. All claims and the reconciliation of meals must be submitted to the BA prior to the certification of claims on a monthly basis. Person Responsible for Implementation: Business Administrator, Assistant Business Administrator, Food Service Manager. Planned Completion Date of Implementation: May 1, 2023

Finding Number: 2022-003. Corrective Action Required by Board: The district should maintain the completed valid New Jersey Household Information Survey Form or documentation of direct certification for all students reported as low income. Method of Implementation: The Food Service manager will produce and properly file all required reports and forms for direct certification for all students. Person Responsible for Implementation: Food Service Manager. Planned Completion Date of Implementation: May 1, 2023

Finding: 2022-006 Verification Federal agency: U.S. Department of Agriculture Federal program Title: Child Nutrition Cluster Federal Assistance Listing Number: 10.553, 10.555 and 10.559 Federal Award Identification Number and Year: 212MN061N1199- 2022 Pass-Through Agency: Minnesota Department of Education Pass-Through Number(s): 1-213-000 Award Period: June 30, 2022 Type of Finding: Significant Deficiency in Internal Control Over Compliance Recommendation: We recommend that District designate a second person to review applications. Views of Responsible Officials: There is no disagreement with the audit finding. Action Taken in Response to Finding: The District will designate a second person to review applications. Name of the Contact Person Responsible for Corrective Action Plan: Randy Bergquist, Superintendent Planned Completion Date for Corrective Action Plan: June 30, 2023

Finding ref number: 2022-001 Finding caption: The District?s internal controls were inadequate for ensuring compliance with federal procurement requirements. Name, address, and telephone of District contact person: Laurie Seymour, Business Manager 2987 W Matlock Brady Rd. Elma, WA 98541 Corrective action the auditee plans to take in response to the finding: The Mary M. Knight School District will implement controls to ensure they comply with procurement requirements. Anticipated date to complete the corrective action: 5/25/2023

Agency: U.S. Department of Agriculture passed through State Department of Education

School District No. 55-0145, Waverly, 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 October 31, 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. 2022-002 Deposit Risk Recommendation: Obtain adequate pledged securities from the financial institution. Action Taken: District personnel will contact the bank about getting additional coverage. 2022-003 Disbursements in Excess of Budget Recommendation: Either not approve disbursements over budgeted amounts or amend the budget if extra disbursements are needed. Action Taken: The District will monitor funds closer and either not approve disbursements over budgeted amounts or amend the budget if needed in the future. FINDINGS ? FEDERAL AWARD PROGRAM AUDIT Nebraska Department of Education 2022-004 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. If the Nebraska Department of Education has questions regarding this plan, please call Mikal Shalikow at (402) 786-2321.

See Corrective Action Plan for chart/table"

Purchase Needed Equipment

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.