Corrective Action Plans

Views of Responsible Officials and Planned Corrective Actions: During the pandemic, the TEFAP program was expanded using COVID-19 relief funds. Three Square had a misunderstanding in the classification of these supplemental commodities, and believed them to be part of COVID-19 relief and as such did not necessitate an executed TEFAP Agency Partner Services Agreement. The four entities mentioned in the finding who received TEFAP commodities only received these supplemental COVID-19 commodities. This finding was not pervasive throughout the organization, but rather isolated to a temporary program, which has now ended. To ensure effective internal controls, Three Square has designed a system to ensure an executed TEFAP Agency Partner Services Agreement is obtained prior to any TEFAP distribution to an Agency Partner. Moving forward, our agency services team will review all orders containing any federal commodity, regardless of the federal program. They will verify eligibility before approval is given to the warehouse to deliver the products.

Finding Type: Significant Deficiency of CFDA 10.553 and 10.555. Name of Contact Person: Ryan Fritch, Superintendent. Recommendation: We recommend the Food Service Director input the amounts into the Illinois State Board of Education monthly meal count report, print the report before submission, and give to the Bookkeeper or Superintendent the report along with the daily meal count sheets to review in order to ensure the amounts are accurate. The review should be documented on the report. Corrective Action: The Bookkeeper or Superintendent will begin reviewing the monthly meal count reports prepared by the Food Service Director to ensure accuracy before they are submitted. We will ensure the review is documented. Proposed Completion Date: Immediately.

See corrective action plan

Corrective action plan: TDA maintains an internal policy that requires SOC reports to be reviewed annually and document complementary user entity controls included in each SOC report. TDA?s contract with Colyar LLC requires the vendor to produce a SOC report annually. The vendor was late in providing the SOC report as a 2022 contract deliverable. TDA took actions to ensure vendor accountability for submitting the late contract deliverable and the vendor was required to complete a corrective action plan. TDA will review and assess the SOC report as soon as it is delivered by the vendor to ensure CLA?s recommendations can be followed and will consider additional procedures to ensure internal controls are assessed in the absence of a SOC report. Implementation date(s): June 2023 Responsible persons: Chief Information Officer and the Director for Food and Nutrition Program Support

There is no disagreement with the finding. Corrective action was started immediately. Arbor is responsible for sending the CSBO all of their source data and the reports to create the claim data. The CSBO will review the source data to make sure that it matches the reporting. When bills are received, they will be matched up to the claims to make sure that there aren't any discrepancies before the bill is paid. Person responsible: Heather Smith, CSBO.

Information on the Federal Program: U.S. Department of Agriculture, Assistance Listing Number 10.555/10.559, Child Nutrition Cluster, Year Ended June 30, 2022 Criteria: The Uniform Guidance requires the local program operator to perform an annual verification sample of household applications for free and reduced lunch and submit the verification report to the oversight agency. Condition: During the audit, the auditor became aware that the district did not maintain or keep the records that were used to compile and submit the annual verification report. Cause: The data submitted on the annual verification report was not supported by District records. Effect: The verification data ?submitted may not be accurate as it could not be verified against District records. Repeat Finding: Yes Auditor's Recommendation: We recommend the District keep records of all supporting documentation used for compliance reporting. Management Response: The Food Service Director is aware that all internal supporting documentation should be kept for compliance audit purposes and will maintain files for the information submitted on the verification report for the 2022/2023 reporting period. Oregon School District's Corrective Action Plan: The food service director understands that all documentation pertaining to the verification report must be kept including any notes on manual entries. Contact Person: Andrew Weiland, Business Manager Anticipated Completion Date: Complete

2022-001 - Net Food Service cash resources did exceed three months average expenditures. Corrective action - Reduce Net Food Service Cash resources to a level that does not exceed three months average expenditures. Method of Implementation - The district will purchase various kitchen and serving area equipment, make upgrades or repairs to existing equipment and serving stations, make improvements to student dining areas. Individual responsible - business administrator and/or designee. Completion date of implementation - June 30, 2023 and ongoing.

FINDING 2022-004 Contact Person Responsible for Corrective Action: Shannon Fritz, Corporation Treasurer Contact Phone Number: 219-567-9161 Views of Responsible Official: We concur with the audit findings. We have initiated corrective action as referenced below. Description of Corrective Action Plan: Monthly sponsor claims will be reviewed by the corporation treasurer after being prepared by the food service director. Anticipated Completion Date: Completed as of February 22, 2023 Cathy Rowe, Superintendent Shannon Fritz, Corporation Treasurer Date: 2-27-23 Date: 2-27-23

This issue was from a previous year, and has been corrected this current fiscal year (2022-2023) and will not be an issue moving forward.

2022-003 FINDING Contact Person ? Tim Lutz, Superintendent Corrective Action Plan ? The District should review policies and procedures for submitting meal counts for reimbursement. Completion Date ? December 31, 2022

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. A spend down plan is in process 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 2022-2023 fiscal year. The persons responsible for the corrective action are Valarie Larange, the food service director and Karen Emond, 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.

The District will monitor vendors to ensure they are able to accept federal monies. Samantha Schweizer, Business Administrator by 6/30/2023.

2022-001 a. Name of contact person responsible for corrective action: Mitchell King b. Corrective action planned: Personnel and federal program directors will review coding of all employees prior to payment. Child nutrition program has been reimbursed the unallowed cost. c. Anticipated completion date: June 30, 2023

FINDING 2022-004 Finding: Non-Public School: No documentation could be found to support non-public school students qualifying for Title I on the 2020-2021 and 2021-2022 Applications. These numbers determine equitable share distributions to these non-public schools. Contact Person Responsible for Corrective Action: Carrie McGuire Contact Phone Number: (574) 875-5161 Views of Responsible Official: We concur with the finding Description of Corrective Action Plan: Non public schools will be consulted prior to the initial Title I(a) application being submitted at the start of each grant cycle. Non-public school consultation forms and spreadsheet(s) for any equitable share calculations will be uploaded into the Title I application center as attachments. These will be verified by the corporation treasurer before the Title I application is submitted annually. Prior to the submission of the Title I application annually, the federal grants coordinator with consult with all non-public schools within our district boundaries as listed by the IDOE in the grant application portal. The signed consultation forms will be uploaded to the IDOE?s Title I Programs Application Center as attachments. The corporation treasurer will verify that all consultation forms are signed and uploaded in the Application Center before the initial grant application budget can be submitted for review. A form will be created so that when files are downloaded from the Child Nutrition Program (CNP) website and subsequently uploaded into Mealtime, there will be places for a signature of the person who downloaded the file, a signature for the person who uploaded the file, and a reviewer. Anticipated Completion Date: September 15, 2023

FINDING 2022-001 Contact Person Responsible for Corrective Action: Jim Evans Contact Phone Number: (574) 875-5161 Views of Responsible Official: We concur with the finding Description of Corrective Action Plan: This finding was corrected beginning July 1, 2022. Concord Community Schools hired an additional staff member and that staff member reviews the information used to prepare the Monthly Sponsored Claims for reimbursement to verify that the claims are accurate, complete and prepared in accordance with the grant requirements. Once the review is complete, the Monthly Sponsored Claims are printed and signed by both the Food Service official who prepared the claims and the food service official who reviewed the claims for accuracy, completeness and compliance with grant requirements. Anticipated Completion Date: This finding has been corrected.

Response and Corrective Action Plan: The District will update the annual calculation to include a comparison of the base used for the indirect cost adjustment. Sarah Kautz, June 30, 2023.

FINDING 2022-002 (Auditor Assigned Reference Number) Contact Person Responsible for Corrective Action: Brook Cleaver Contact Phone Number: (765) 675-2147 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Superintendent and Treasurer will work to ensure that bids are sought and kept on file for projects exceeding the simplified acquisition threshold. Once a vendor is selected, Treasurer will search exclusions in the Sam.gov portal for vendors that may be suspended or debarred from participation in federal assistance programs and keep said documentation on file. Anticipated Completion Date: Immediately.

Department: Health and Human Services Title: Internal control over P-EBT Food Benefits needs improvement Questioned Costs: Known: $61,507,558 Likely: None Status: Management?s opinion is that corrective action is not required Corrective Action: The Department disagrees with this finding and does not believe that corrective action is warranted. During the course of the audit, the Department provided the Office of the State Auditor (OSA) with the complete population of recipients as well as the supporting information necessary for OSA to conduct testing to verify compliance with federal program requirements. The only remaining action that is required is for OSA to perform their testing. Completion Date: N/A Agency Contact: Anthony Pelotte, Director, Office for Family Independence, DHHS, 207-624-4104

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