Corrective Action Plans

Finding Number: 2022-001 Planned Corrective Action: Accurate count of student meals Anticipated Completion Date: 08/01/2022 ? implementation date Responsible Contact Person: Megan Schweller, Food Service Supervisor Action Plan: To ensure accurate daily meal counts and recordkeeping, Infinite Campus, a new Point of Sale System, has been implemented into the Food Service Department, effective 08/01/2022. This system streamlines a more effective transaction process, as well as enables the department to better retain transaction histories on a daily, monthly, and yearly basis. Daily counts are recorded electronically through the system, thus eliminating the manual counting of student meals.

United States Department of Agriculture 2022-002 Emergency Food Assistance Program ? Assistance Listing Number #10.569 During the year ended March 31, 2022, Nourishing Hope did not follow USDA Signature Sheet Guidelines and retain addresses from guests or their income eligibility. Recommendation Nourishing Hope should enhance their eligibility record keeping procedures in accordance with the program guidelines. Action Taken Nourishing Hope conducted this requirement in accordance with Greater Chicago Food Depository (?GCFD?) program regulations and collected and submitted all required documentation to GCFD for review on a monthly basis. Nourishing Hope did not keep a copy of the documentation in the past since Nourishing Hope was not subject to a single audit requirement and was required to send all of the documents to GCFD. In fiscal year 2023, a new process was implemented to now scan a copy of these documents to be in compliance with USDA regulations. With this new process in place, Nourishing Hope considers the control and compliance matter remediated in fiscal year 2023.

United States Department of Agriculture 2022-001 Emergency Food Assistance Program ? Assistance Listing Number #10.569 As of the beginning of the year, April 1, 2021, Nourishing Hope did not separately identify and track USDA food inventory from total inventory. Recommendation Nourishing Hope should enhance their inventory procedures to account for USDA foods separate from foods received from other sources. Action Taken In the past, Nourishing Hope did not have requirements to record USDA foods separately in recorded inventory as the only requirement was to physically store the food separately from other, non-USDA foods. USDA foods were recorded separately on Nourishing Hope?s March 31, 2022 inventory count and will be going forward. Nourishing Hope considers the control and compliance matter remediated as of March 31, 2022.

FINDING 2022-003 Person responsible for corrective actions: Courtney Halloran, Food Service Director Contact Phone Number: 765-647-4128 Views of Responsible Official: As Director of Food Service, I concur with the finding that 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 Procurement and Suspension and Debarment compliance requirement. Description of Corrective Action Plan: Suspension and Debarment requirements will now be met with the use of the West Indy Co-op for use of dairy products. The Food Service Director will ensure that all vendors used for purchasing will be compliant and accessible. Milk procurement will now be done in assistance with the West Indy Co-op. Proper quotes will be documented and will reflect applicable state and local laws and regulations. Records will be maintained to include method of procurement, contract type, vendor selection and/or rejection, prices, and other quotes. The Food Service Director will ensure compliance before signing the bid agreement for the following school year. The purchasing group agreement will not be signed if procurement, suspension and debarment requirements are not met. Anticipated Completion Date: March 16, 2023 Courtney Halloran Director of Food Services March 16, 2023

Recommendation We recommend that the District review its controls related to meal counts to ensure that they are properly counted and documented. Action Taken Physical meal counts were discontinued for the 2022-2023 school year, and the District will go back to using their electronic processes for meal counts.

FINDING 2022-001 Contact Person Responsible for Corrective Action: Sara Reafsnyder, Food Service Director Contact Phone Number: 574-825-9425 Views of Responsible Official: We concur with this finding Description of Corrective Action Plan: Internal control established to ensure that Food Service Director reviews and signs all food service related invoices prior to payment by accounts payable personnel. Anticipated Completion Date: Immediately

Finding #2022-001 (Child Nutrition Cluster) The Charter School?s Food Service Fund Net Cash Resources exceeded its three-months average expenditures by $164,820.32. Corrective Action Plan: The Charter School will purchase equipment from the pre-approved equipment list, purchase more food, and hire more staff.

Purchase Needed Equipment.

See Corrective Action Plan for chart/table

See Corrective Action Plan for chart/table

See Corrective Action Plan for chart/table

IT - PDA?s PA Meals team will incorporate appropriate migration strategies within the policy of ITP_INF000, along with providing a migration audit plan checklist for any future data migrations. Additionally, the INF000 will be incorporated into the Delivery Center?s development framework, where appropriate. PDA added a Business Analyst to the team for assisting with future application testing and documentation. This individual will be directly involved in helping develop and orchestrate a testing strategy based on delivery center standards to include, but not limited to: - Determine appropriate criteria to be tested. - Assist in establishing a test group of qualified testers. - Coordinate with technical team on pass/fail criteria. - Utilize standard testing tasks/checklists ensuring consistency. - Assist the team, key business users and the technical team in reviewing testing results. The reports were reviewed electronically (100s of report pages) checking for various scenarios. As a result, these complete reports are similar and difficult to distinguish between without an associated checklist and specific report criteria. In the future, full test plans and execution results capturing pass/fail of the defined tests will be retained in pdf (or similar) format. The team will continue with best practices and delivery center standards, utilizing a Business Analyst as part of the testing and review process. The SEFA report had extensive testing, however, there is a timing issue that will always exist if the expectation is to provide the data in both January and September. The January report will be accurate for when it is run, along with what transactions were sent by the warehouse vendor. Subsequently, changes can and will occur to those commodities being reported on over the next 6 months. Additionally, it is reliant upon the warehouse vendor to report all transactions timely. As a result, running the same report after June 30th will consistently vary due to a physical inventory review in June, along with additional transactions being updated as part of the inventory review. PDA is recommending a one-time annual report in September, which will include all the adjustments from a June physical inventory and updated transactions. A January report is fine to run but should not be considered a fully accurate assessment due to the timing and missing data. Program - PDA strives to maintain accurate and complete records with respect to the receipt, distribution, and inventory of USDA donated foods, including end products processed from donated food. To that end, PDA has already or will put the following steps in place to strengthen procedures for future periods to ensure errors identified during the reconciliation process are corrected timely in the system: 1) All findings noted with regards to the Commodity Processors Inventory Report have been corrected and no known issues remain. 2) No further inventory balances remain on record with inactive distributors, as all product was previously transferred to active distributors. 3) Processor monthly performance reports (MPRs) will be completed and filed in accordance with USDA?s prescribed schedule (90 days after completion of month). 4) BFA will work with the Commodity Distributors and USDA to mutually resolve discrepancies and achieve reconciliation with USDA receipts. 5) Moving forward, all Commodity Distributor Inventory Reports will be reconciled by the beginning of a new federal fiscal year (October 1), and inventory balances at commodity distributors will agree with year-end physical inventory counts. Anticipated Completion Date: IT - 09/30/2023; Program 1-Completed; 2-Completed; 3-09/30/2023; 4-09/30/2023; 5-09/30/2023 Contact Person and Title: Caryn Long Earl, PDA, Director, Bureau of Food Assistance (BFA)

Management has identified the incident where an agency signature was not obtained upon delivery of USDA foods to that agency. Management has verified that the delivery of USDA foods to that agency was a legitimate delivery in accordance the Compliance Requirements for the Emergency Food Assistance Program. Management believes that enhanced training and supervision will improve the application of management's documented controls that require agency signatures be obtained upon delivery of USDA foods to partnering agencies.

Management?s Response: Management will implement safeguards to ensure responsible business office employees are held accountable for following procedures to ensure timely and complete monthly and annual financial reporting.

Management Response/Corrective Action Plan: All schools in the RSU are now using the same software and process at their point of sales. All impacted staff have been trained on this new software and the Business Department will continue to review reports for meal counts on a monthly basis.

Purchase Needed Equipment

Finding 2022-002 ? Child Nutrition Cluster - Reporting Contact Person Responsible for Corrective Action: Vicki Jones, Corporation Treasurer Contact Phone Number: 765-793-4877 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The School Lunch reimbursement claims will be reviewed by a secondary individual prior to submission to IDOE. Anticipated Completion Date: March 31, 2023

Findings and Recommendations: Finding Type: Material Noncompliance with Laws and Regulations. Condition: The Academy?s NSFSA?s fund balance exceeded the allowable three months? average expenditures at June 30, 2022. The Academy had approximately 4.61 months of expenditures as fund balance at June 30, 2022. Recommendation: The Academy should submit a spend down plan and obtain Michigan Department of Education?s prior approval to improve the food quality or take other action to improve the program in accordance with 7 CFR 210.19(a)(2). Corrective Action Plan: The Academy is aware of the finding and has implemented procedures in order to prevent further noncompliance in the future. The Academy is working towards completion of the spend down plan currently in place which was previously approved by Michigan Department of Education. Responsible Department: Business department and Food Service department. Responsible Person: Frank Patterson (Business Manager) in conjunction with the Food Service Director and the Superintendent. Planned Completion Date (TBD or Date): Spend-down plan currently implemented and expected completion prior to June 30, 2023.

Finding ref number: 2022-001 Finding caption: The District?s internal controls were inadequate for ensuring it complied with federal procurement requirements and its own policy. Name, address, and telephone of District contact person: Tammy Thompson (509) 854-3172 701 E Avenue Granger, WA 98932 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 District did contract with Hobart Corp. to install a new dishwasher. The installation expenditure was coded to the Food Service Department. The district used local state dollars for the installation, therefore District Management did not obtain 3 quotes. The original quote from Hobart was in the amount of $81,466.36 which included electrical and plumbing. The district used Hobart only for the dishwasher installation and used a local plumbing and electrical company that saved the district $17,176.94. In the future district management will follow District federal requirements for goods and services. Anticipated date to complete the corrective action: 5/18/2023

Excess Cash in the Food Service Fund Corrective Action Plan (CAP). 1. Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. 2. Actions Planned in Response to Finding: The District has developed a plan that has been approved by the School Board. The plan includes the purchase of food service equipment, increased quantity and quality of food purchases, and other allowable alternative uses of these excess funds. The District has made a significant investment in purchasing new food service equipment in recent years. The District will continue to work to spend down the Food Service Fund within the allowable uses. 3. Official Responsible for Ensuring CAP: Tom Anderson, Finance Director, is the official responsible for ensuring corrective action. 4. Planned Completion Date for CAP: Fiscal year end 2023. 5. Plan to Monitor Completion of CAP: The District will continue to review and monitor this Food Service fund going forward.

The District develop a plan to eliminate the excess of net resources in the Food Service Fund.

The Business Administrator will ensure meals and snacks claimed for reimbursement be in agreement with the meals and snacks served per the daily sheets.

FINDING 2022-003 Contact Person Responsible for Corrective Action: Nicole Wolverton, CFO Contact Phone Number: 219-881-5536 Views of Responsible Official: We concur with the audit finding. Description of Corrective Action Plan: As it relates to reporting of meal claims, a policy and procedure will be created and implemented to ensure that accurate meal counts are recorded and entered CNP web by Sodexo based off reports from Skyward recording daily meal counts, documentation and entry then reviewed by the GCSC Food Service Manager for accuracy prior to submission of claims and then reviewed by the CFO for completeness. Anticipated Completion Date: Gary Community School Corporation will implement this procedure by September 2023. INDIANA STATE

FINDING 2022-002 Contact Person Responsible for Corrective Action: Nicole Wolverton, CFO Contact Phone Number: 219-881-5536 Views of Responsible Official: We concur with the audit finding. Description of Corrective Action Plan: As it relates to activities allowed or unallowed for Child Nutrition, a new policy and procedure will be implemented for requiring appropriate documentation from the Food Service Vendor. The policy will require the vendor to provide all supporting invoices for food purchased and time sheets for time and labor records. In addition, this policy and procedure will ensure the correct indirect cost allocation when submitting the application and required documentation to the Office of School Finance. This application submission will be prepared by the Chief Financial Officer and reviewed by the GCSC Manager to ensure accuracy and completion. The policy will contain language specific to the consideration of direct and indirect cost calculations and providing all supporting documentation for the determination of allowable and unallowable costs. GCSC will ensure indirect costs are charged according to the approved indirect cost rate. As it relates to special test and provisions to the School Food Accounts, a procedure will be implemented for the recording of receipts and expenditures within the food service accounts and the timeliness of the account reconciliations to be completed by the District Treasurer. Anticipated Completion Date: Gary Community School Corporation will implement this procedure by September 2023.

Formal finding #1: CNU Administrative finding- Monthly meals overreported on claims from August 2021 through April of 2022. Response: The overclaim was repaid in February of 2023 and the district has put into place steps to prevent this from happening in the future by making sure overclaim does not occur again.