Corrective Action Plans

Noncompliance Finding 2022-004 (Net Cash Resources) Federal Program: Child Nutrition Cluster ALN: 10.553, 10.555 Condition: The District?s current net cash resources of $566,723 is in excess of its three months average expenditures of $443,634. Recommendation: We have advised management to resolve the current noncompliance finding by any means necessary that is in compliance with federal regulations. Corrective Action: During the 2021-2022 school year, the USDA extended the universal free breakfast and lunch program for K - 12 students. This greatly impacted the number of meals the District served students. In addition to the increased participation, the subsidy reimbursement rate increased and all meals were subsidized by the Federal government. While serving more meals, our Food Service Department struggled to fully staff operations. The department was understaffed by about seven employees and the department operated with roughly 75 percent of its staffing needs. The combination of additional subsidy revenue and understaffing resulted in the department?s profitability. The District will address the excess net cash resources by further investing in the food service program. First, the District will continue its efforts to attract and retain employees to fully staff the unfilled positions. Hourly rates were increased for both new and existing staff in the 2022-2023 fiscal year. As those positions are filled, the Food Service Department?s average expenditures will increase, which also increases the acceptable level of net cash resources permitted. Additionally, the Food Service Department is planning purchases of additional and replacement equipment for the kitchens, resulting in a decrease in the Fund?s net cash resources. These actions will bring the District?s net cash resources within the acceptable range as set forth in 7 CFR ? 210.19. Person Responsible: Daniel Direso, CPA Proposed Completion Date: April 1, 2023

Purchase Needed Equipment

OLIVET COMMUNITY SCHOOLS CORRECTIVE ACTION PLAN YEAR ENDED JUNE 30, 2022 Olivet Community 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: Gail Williams, Business Office Manager 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 ? Federal Award Findings and Question Costs Finding 2022-001 Considered a significant deficiency Recommendation: The District should submit and implement a 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 we are in the process of developing a plan to spend down the food service fund balance. Anticipated Completion Date: June 30, 2023

2022-008 Federal Agency: U.S. Department of Agriculture Pass Thro Entity: Oklahoma State Department of Education Program: Child Nutrition Cluster Assistance Listing: 10.553 & 10.555 Grant Period: Year ending June 30, 2022 Recommendation: The auditor recommended that written contracts need to be obtained on an annual basis for contract services provided by outside companies on a recurring basis. Controls need to be implemented to insure those amounts paid under these contracts agrees with detail supporting invoices. Action Taken: FY23 Food Service Management contract has been reviewed. Finance Director will compare monthly invoices and detail with the meals claimed to contract terms. Also note that FY24, the District is returning to a self-managed Child Nutrition program.

2022-007 Federal Agency: U.S. Department of Agriculture Pass Thru Entity: Oklahoma State Department of Education Program: Child Nutrition Cluster Assistance Listing: I 0.553 & I 0.555 Grant Period: Year ending June 30, 2022 Recommendation: The auditor recommended that meal counts submitted for reimbursement need to agree with supporting documentation. Secondary review procedures should be implemented to verily agreement with claim submission and claims are certified. Action Taken: Director of Child Nutrition will have a secondary person review claim before submitting to state department, to ensure accurate keying of data. Director of Finance will match up the Payment Notice of funds received to the monthly claims, to ensure all funds have been claimed and received. Anticipated Completion Date: May 2023 Responsible Official: Director of Finance

Finding ref number:2022-002 Finding caption: The District lacked adequate internal controls for ensuring compliance with federal suspension and debarment requirements. Name, address, and telephone of District contact person: Name: Drew Raab Address: 1105 Dale Ave. Benton City, WA 99320 Phone: 509-588-2000 Corrective action the auditee plans to take in response to the finding: It was stated that the District paid a subcontractor, and staff did not know that suspension and debarment verifications must be performed when a contract is subcontracted. The District however does know that a verification needs to happen, but when the change happened in FY 2022, that was the same year of several staffing changes. The documents requested were difficult to locate as the Director of Finance at the time had retired and the Districts Food Service Director is currently out on a leave of absence. A suspension and debarment verification was provided for the audit, however it was not allowed as it did not reflect a print date. Moving forward, the District will ensure that all verifications have a date, with all documentation to be filed with the Director of Finance. Anticipated date to complete the corrective action: 5/26/2023

Finding 2022-002: Verification of Free & Reduced Price Application (NSLP) Recommendation: We recommend the District perform the verification of free & reduced price applications by the deadline published by DESE. Planned Corrective Action: The District will ensure future verifications of free & reduced price applications will be completed by the deadline published by DESE.

Federal Grants Management/Procurement Policy Recommendation: We recommend the District follow its procurement policy related to small purchases. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: District personnel will solicit, obtain, and maintain a minimum number of price quotes from adequate food service vendors (at least 2, if received). Names of the contract person(s) responsible for corrective action: Milissa Lundin, Food Service Director; Laurie Oliver, Food Service Head Cook; Holly Kruger, Food Service Clerk; Jen Steber, Finance Manager Planned completion date for corrective action plan: January 31, 2023.

Finding 2022-002 ? Child Nutrition Cluster ? Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Serena Francis, Business Manager Contact Phone Number: (765) 226-0603 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We have joined the Food 2 School consortium beginning with 2022-2023 school year. Both our Food Service Director and our Business Manager receive all emails and communication. This will allow internal control and oversight to ensure that the consortium is compliment with all state and federal procedures. We also have moved all of our small purchases into this purchasing consortium system. Anticipated Completion Date: August 1, 2023

CORRECTIVE ACTION PLAN Walkerville Public Schools is in agreement with the finding identified and respectfully submits the following Corrective Action Plan for the year ended June 30, 2022. 2022-001 Excess Food Service Fund Balance The food service fund balance ended June 30, 2022 with an excess allowable fund balance. This occurred due to delays in the global supply chain which did not allow us to complete our cafeteria and kitchen remodels as planned. The district's responsible parties include the Food Service Supervisor (Sheri Boes), the Superintendent (Dr. Thomas Langdon) and the Business Manager (Sandra Oomen). All of these individuals have been made aware of the issue and discussed the possibilities to reduce the fund balance for the 2022-2023 school year. The focus of the District to reduce the fund balance will be to: ? Complete the remodel of the kitchen and cafeteria area ? Continue to purchase supplies, equipment, and services that add value to our food service program Implementation and Monitoring: The district will be implementing the purchase of these items throughout the 2022-2023 school year, with all purchases being received no later than June 30, 2023. The Business Manager will monitor the process to determine if additional fund balance will need to be spent throughout the fiscal year to comply with current regulations. The Business Manager will continue dialogue with the Food Service Supervisor and Superintendent throughout the year to keep all parties current on the fund balance status and will update the plan on spending fund balance if needed. If the Michigan Department of Education has any questions regarding this plan, please contact Sandra Oomen at 231-873-4850 ext. 3323 or soomen@walkerville.kl2.mi.us.

2022-001 Child Nutrition Cluster ? Assistance Listing No. 10.553 & 10.555 Recommendation: Recommendation: We recommend the School review its procedures to ensure it retains documentation sufficient to detail the history of all procurements in accordance with the Uniform Guidance. We also recommend the School review its procedures over procurement controls to ensure all controls are also sufficiently documented with records that include, but are not necessarily limited to, the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Review policies and procedures to ensure compliance with Uniform Guidance and MN Statute regarding contract and bid laws. Institute a schedule of periodic review of existing contracts to determine if contract costs are still competitive. We will ensure all award documentation is retained for five years or until the contract is reawarded. Name(s) of the contact person(s) responsible for corrective action: Lynn Peterson, CEO Planned completion date for corrective action plan: September 1, 2023

FINDING 2022-008: Audit Report Deadline Response: The district had difficulty finding an auditor who would be available to contract with us for the 2022-23 school year. Since our last auditor was no longer in business, we had to share significant documentation with our new auditor. Additionally, there was a change in personnel with the hiring of a new Business Manager. Some of the requested information and files were not immediately available to our new Business Manager. We currently have an auditor under contract and will have all requested documentation to them in a timely manner to meet deadlines.

The corrective action for Findings 2022-001 and 2022-002: The District will review current needs for equipment and other direct food service costs. A Corrective Action Plan will be developed to reduce excess cash balances in the Child Nutrition Program.

Responsible Official?s Response: Rochester Prep is implementing procedures to ensure accurate and timely submission of federal nutrition claims. Specifically: To ensure claims for reimbursement are accurately consolidated, the Charter School will evaluate their point of service accountability system and implement appropriate changes. The Charter School will also conduct edit checks to ensure accountability. Effective July 20, 2022, the school implemented a Meal Counting and Claiming Implementation Plan with the purpose of submitting accurate meal claims to the state and federal child nutrition programs. This implementation plan seeks to eliminate discrepancies between meal counting at the homeroom level, reporting at the school level, and claiming at the state and federal levels.

Contact Person ? Mark Lundin, Superintendent. Corrective Action Plan ? The District will review polices and procedures for submitting meal counts for reimbursement. Completion Date ? September 1, 2022.

Finding #2022-001 - Segregation of Duties (Prior Year Finding #2021-001) Condition: Proper segregation of duties is an important aspect of any control system. Management is responsible for the design, installation and maintenance of an appropriate system of internal control. The limited size of the District?s office staff prevents the ideal segregation of functions. The following duties lack adequate segregation of duties: The District uses e-signatures to approve purchase orders. Two individuals have access to the e-signatures and have the ability to create new vendors, enter invoices, print checks, record journal entries and record activity on the general ledger. Both individuals also have access to the payroll system. The person reviewing free and reduced food service eligibility can also enter information into the system to determine eligibility. Effect: Errors or intentional fraud could occur and not be detected timely by other employees in the normal course of their responsibilities as a result of the lack of segregation of duties. Cause: Limited number of personnel. Criteria: Segregation of duties is an aspect of internal control intended to prevent or decrease opportunities of intentional and unintentional errors and fraud. Duties and responsibilities are properly segregated if no single individual either has control over all phases of a transaction or has the ability to both make and conceal an error, whether such error is intentional or unintentional. Recommendation: The Board of Education and the Superintendent should continue to monitor the transactions and the financial records of the District. We also encourage the District to continue to identify cost effective opportunities to improve the design of the internal control structure. Response: We agree with this finding but do not believe it is cost effective to increase the office staff in an attempt to bring about a more effective segregation of duties. The Superintendent approves purchase orders and the Board of Education approves monthly accounts payable checks, and one of the school secretaries or the board treasurer reviews the bank reconciliations. The Board of Education and Superintendent will continue to monitor transactions of the District. Finding #2022-001 - Segregation of Contact Person: Heather Droessler Anticipated Completion: Not applicable

Identifying Number: 2022-002 Finding: In our sample of ten schools, Kansas City Public Schools (the District) obtained the requisite two food safety inspections at each school during the school year; however the food safety inspection reports identified critical violations at four schools, which were not corrected by a specified date. The District did not comply with food storage, preparation, and service standards established by the KCMO Health Department. Corrective Actions Taken or Planned: The Child Nutrition Services Department and the Facilities Departments will perform training with staff regarding the Health Department requires to address violations. Procedures will be updated to reflect the responsibilities with CNS staff to report violations, monitor work order progress and escalated resolution to meet Health Department deadlines. The CNS Director will contact the Health Department to provide documentation the violation has been corrected. The corrective action plan has been implemented. The contact person responsible for the corrective action plan is Erin Thompson, Interim Chief Finance and Operations Officer.

Purchase Needed Equipment

Finding ref number: 2022-002 Finding caption: The District did not have adequate internal controls to ensure compliance with federal Title I requirements for allocating funds to school buildings. Name, address, and telephone of District contact person: Gabriela Chacon, 411 E Saddle Mountain Dr. Mattawa, WA 99349 Tel: (509) 932-4565 Ext: 3031 Corrective action the auditee plans to take in response to the finding: (If the auditee does not concur with the finding, the auditee must list the reasons for disagreement). The Wahluke School District concurs with this finding. The following corrective actions will be taken: ? The Title I Program Director will work closely with the Grants Manager and Director of Finance to ensure that the annual application is completed correctly, including the allocations to school buildings. ? An action plan was submitted to OSPI which includes initial planning with the District Office team prior to the beginning of the school year, as well as monthly meetings with the Title I Program Director to ensure ranking and allocations are maintained. ? The district now has a Grants Manager that is working closely with the Title I Program Director to ensure that the buildings are within ranking order. Anticipated date to complete the corrective action: 08/31/2023

CORRECTIVE ACTION PLAN JUNE 30, 2022 Finding 2022-001: Material Noncompliance Finding Condition: As of June 30, 2022, the District?s fund balance exceeded three months? average of operating expenses. Corrective Steps Taken: The District has ordered equipment that costs approximately $237,800, but due to supply chain issues, the equipment is not available yet. Corrective Steps to be Taken: The business manager has created and submitted a spend down plan in a timely manner and has been approved by the Michigan Department of Education. The spend down plan will alleviate the excess fund balance and it is anticipated the completion date for the corrective action plan will be before the end of the 2022-2023 fiscal year. Monitoring: The business manager, along with the superintendent, will work together to assess where the fund balance is after all the projects from the spend down plan are completed. Reasons Corrective Action Plan Note Necessary: None Name of Responsible Person for Further Information: Cheri Bush, Business Manager Questioned Costs Related to this Finding: None

Corrective Action Plan: The Agency of Education?s new Child Nutrition grants management system, Harvest, now has the reports to back up the Federal FNS-10's built-in. In addition, Harvest now also retains a copy of each report created along with the backup for each report. Position Responsible for Implementation of Corrective Action Name: Sean Cousino Position: Deputy CFO Email: sean.couisno@vermont.gov Phone Number: 802 595-3693 Date of Implementation of Corrective Action: April 1, 2023

Corrective Action Plan: The AOE CNP team will be implementing a new procedure starting 3/1/23, which adds an additional internal control (quarterly review by a Grants Program Manager) and outlines specific steps that the Grants Management Specialist and Grants Program Manager will take in the event that there is a discrepancy. Position Responsible for Implementation of Corrective Action Name: Conor Floyd Position: Grant Programs Manager, Child Nutrition Programs Email: conor.floyd@vermont.gov Phone Number: 802-828-0310 Date of Implementation of Corrective Action: 3/1/23

Corrective Action Plan: To address the accuracy and timeliness of our entries into the FFATA system, we will use the USASPENDING.GOV website to assist us in reconciling what has been entered into the FFATA system. This will allow us to ensure that our grant ledgers agree with what is entered into FFATA. This will be a reconciliation completed at least quarterly (following SOV fiscal year quarters) and will be completed by the Deputy CFO or position assigned by the Deputy CFO. We will also implement a process that will have all the steps necessary for a grant award or an amendment to ensure it is posted properly within our internal files and the external systems. This will ensure that new awards and amendments get routed and entered in the FFATA system timely. Our finance team also attended a FFATA training on February 3, 2023 for additional training on the FFATA system. We will look into the Batch upload process which was described in that training. Position Responsible for Implementation of Corrective Action Name: Sean Cousino Position: Deputy Chief Financial Officer Email: sean.cousino@vermont.gov Phone Number: 802 595-3693 Date of Implementation of Corrective Action: First Reconciliation to be completed March/April 2023 Full Implementation June 1,2023

Sandusky Community School respectfully submits the following corrective action plan for the year ended June 30, 2022. Auditor: Anderson, Tuckey, Bernhardt & Doran, PC 715 E Frank St Caro, MI 48723 Audit Period: Year ended June 30, 2022 District responsible individual to implement this plan: Kendra Messing, Business Director Finding ? Federal Award Finding and Question Cost 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: The District concurs with the facts of this finding and is in the process of continue the development of a long-term plan to continue to spend down the food service balance. Items being considered is improving outdated equipment and enhancing, plus expanding, the food options available in the District. The District has also discussed expanding staff and raising wages for contracted staff to continue to run the program

See corrective action plan.