Corrective Action Plans

FINDING 2022-003 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 Assistance Listing Number: 10.553, 10.555 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Material Weakness 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 for purchases made outside of the purchasing cooperative. Context: During the audit period, the School Corporation had purchases between $10,000 and $150,000 from four vendors which fall under the small purchase method for federal and state procurement regulations and were charged to Fund 0800 ? School Lunch Fund. For one vendor selected for testing, documentation was not presented to verify the School Corporation had performed checks to assure the vendor was not suspended or debarred prior to entering into the transaction in order to satisfy the suspended and debarment requirements. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Moving forward, the SAMS website will be utilized to confirm that purchases from vendors that are between the $10,000 and $150,000 threshold are not suspended or debarred prior to entering into transactions. Responsible Party and Timeline for Completion: The Superintendent or Superintendent?s designee will be the responsible party. This correction will be put into effect 3/15/2023.

FINDING 2022-002 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 Assistance Listing Number: 10.553, 10.555 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Allowable Costs/Cost Principles Audit Finding: Material Weakness Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Allowable Costs/Cost Principles compliance requirements. Context: During testing of 12 vendor disbursements for allowable costs/cost principles, we noted there was one month where there was no documented review by the School Corporation?s Business Manager of expenditures paid to the Food Service Management Company by the School Corporation?s Business Manager. The only review was performed by the Food Services Director, who is a Food Service Management company employee. We tested six other monthly submissions of Food Service Management company disbursements and noted they were all appropriately reviewed by the School Corporation with supporting documentation attached. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The missing signature appears to be an uncommon oversight within our current system of internal controls. The Superintendent and FSMC Food Service Director will make it a point to review signature pages for both signatures at each monthly financial review. Responsible Party and Timeline for Completion: Superintendent and FSMC Food Service Director discussed this finding on 3/15/2023 and will put corrective action in place immediately.

CORRECTIVE ACTION PLAN OF CURRENT AUDIT FINDINGS June 30, 2022 Finding 2022-001 ? Child Nutrition Cluster ? Reporting Contact Person Responsible for Corrective Action: Thomas McFarland Contact Phone Number: 574-342-2255 Views of Responsible Official: We do not concur with the finding. Description of Corrective Action Plan: While the claim does not have a second signature indicating review before submission, the procedures that Triton follows, which include segregation of duties, justify that someone else reviewed the data, before submission. The data is compiled by the building secretary and submitted to the Business Manager. The Business Manager reviews the claim and logs into the online submission website with a secure user name and password to enter the data. While we believe that the secure user name and password is just as much proof as a signature that the data has been reviewed, we will begin having the document signed by a second person in order to satisfy this requirement Anticipated Completion Date: 3/15/23

On behalf of the finding 22-03-CFDA 10.553 and 10.555-Federal Grant Programs the following changes will be implemented: The Food Program Directors will ensure that all the food-related invoices will be separated in relation of program purchases to menu requirements. All the invoices will be approved by the Food Program Directors. All the invoices will be paid separately. All food invoices related to non-funded purchases will be allocated accordingly and paid separately. The enforcement of the purchasing procedure will be in effect starting October 2023 to ensure the separation of purchasing, inventory control, authorization and disbursement functions. The responsible party for this change will be Sharon Gardner, Food Program Director.

Contact Person Responsible for Corrective Action: Michelle Keene Contact Phone Number: (812) 384-4386 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The School Corporation will implement a formal review of the Education Stabilization Annual Report and ensure the amounts reported agree to the underlying records. Anticipated Completion Date: Effective for the next Annual Report due

Purchase needed equipment.

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 will create and submit 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 persons responsible for the corrective action are Kristy Donner, the food service director and Nicole Darby, the business manager. The anticipated completion date of the corrective action plan is before the end of the 2023 fiscal year. The District anticipates certain projects may require lead time for getting new equipment or renovation projects completed and therefore will plan accordingly to make sure projects get completed prior to the end of the 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.

Name of Contact Person: Jennifer Phillip Corrective Action Plan: Records will be reviewed monthly by two individuals to insure they are complete. Back up documentation shall be kept in a secure location where at least two other budget supervisors are aware and have access to same. Proposed Completion Date: January 31, 2023

FINDING 2022-003 Contact Person Responsible for Corrective Action: Kasey Clark Contact Phone Number: 574-772-1604 Views of Responsible Official: We concur with the findings. Description of Corrective Action Plan: The income guidelines will be uploaded into the food service system after printing off the government site and two people will have eyes on them and this has started for 2022/2023. Anticipated Completion Date: March 2023

This Corrective Action statement is to address the Auditor Finding that the number of breakfasts reported to the state in April of 2022 was mis-reported by 27 breakfasts. Our April of 2022 State Claim Report showed 2330 breakfasts served in April and our CN-6 Report showed 2303 breakfasts served. To the best of my knowledge, I transposed the 3 and the 0 on the state report causing the over reporting of breakfasts served. In the 2022 School year, we just reported the total number of meals served due to all students receiving free lunch and breakfast using the Seamless Summer Option for reporting meals served. Now that we are back on the School Nutrition Program, we report the number of free, reduced, and paid meals served making it easy to double check the total meals served against the CN-6 and CN-7 to ensure the numbers are correct. As of 2/14/23, I will double check the totals for the meals served against the reports to guarantee accuracy. I will also submit the reports to be reviewed by my supervisor, the Superintendent, prior to submission.

In returning to full district operations in the 2021-2022 school year, revenues significantly increased in response to district operations. While spending increased by more than 36%, revenues increased more than 90%. The significant increases to revenue can be correlated back to federal reimbursements for breakfast, lunch and snack. Pandemic reimbursement rates were used through 6/30/2022, resulting in an average increase of .55/lunch reimbursement. Coinciding with the return of in-person instruction, the district overall has seen a decrease in enrollment. The last full year we can compare is 2018-2019 where 715,000 lunches were served, in contrast, 2021-2022 had a total of 576,000 lunches served. In January of 2022, the district implemented an all staff mid year wage increase. Cafeteria wages were brought to $15/hour for all entry level positions, with additional increases on accelerated steps where appropriate. This had an overall impact of roughly 10% increase in spending in the area of payroll and benefits compared to the 2020-2021 school year. Given the current fiscal environment, the district will continue to see increases to operating costs. The 2022-23 milk bid alone came in 11.6% higher than the 2021-2022 school year. Along with an increase to operating costs and routine equipment replacements, additional planning has taken place for future spending. Initial steps in the re-design of serving line pieces at the high school have begun to take place for the next year. Plus to re-do the serving lines in grades 3-6 were put on hold during COVID. Those projects will begin to be resurrected within the 2022-2023 school year.

FINDING 2022-003 Contact Person Responsible for Corrective Action: Stephanie Haynes- Clifford, Food Service Director Contact Phone Number: 260 665 2854 Extension 1202 Views of Responsible Official: The bids for bread and milk were renewed by Region 8 for the 2020-2021 school year. The Service Center could not provide documentation that procedures were performed to verify the vendors were not suspended or debarred from participation in federal programs prior to entering into covered transactions with these vendors. Description of Corrective Action Plan: Food Service will review bid packets to ensure documentation was provided as proof that the vendors were not suspended or debarred. If such evidence is not provided, the Food Service Director will verify and request appropriate documentation Anticipated Completion Date: February 10, 2023

Contact Person Responsible for Corrective Action: Stephanie Haynes- Clifford, Food Service Director Contact Phone Number: 260 665 2854 Extension 1202 Views of Responsible Official: The School Corporation had not separated activities related to payroll withholding and benefit disbursements. These were paid without evidence of review and approval by a person not involved in the original disbursement process. Description of Corrective Action Plan: Effective immediately, Payroll initials and dates all activities related to payroll withholding and benefit disbursements. Additionally, The Business Managers reviews and approves by initialing and dating. Anticipated Completion Date: January 2023

Department: Education Title: Internal control over CACFP eligibility needs improvement Questioned Costs: Known: $50,275 Likely: Undeterminable Status: Corrective action complete Corrective Action: The Department added to the check list a space for the on-site documentation for the pre-approval site visit to be uploaded into CNPWeb. The Department made the pre-site visit mandatory before the start of the program. Completion Date: March 6, 2023 Agency Contact: Jane McLucas, Director of Child Nutrition, DOE, 207-624-6880

Department: Education Administrative and Financial Services Title: Internal control over the submission of CNC Schedule of Expenditures of Federal Awards information needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Department will report expenditures for the School Breakfast Program and Special Milk Program under the individual ALNs rather than including those expenditures in the broader ALN 10.555. The Department will report noncash assistance at the amount actually used rather than the amount authorized for use. The Department will add a note to the SEFA report indicating any COVID-19 expenditures that cannot be isolated due to waivers. Completion Date: June 30, 2023 Agency Contact: Nicole Denis, Director of Finance, DOE, 207-530-2161

Department: Education Title: Internal control over Child Nutrition claim reimbursements needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Department will offer updated SSO training to include specific procedure on meal counting and claiming by building. The Department will create a policy for oversight of claiming procedures during SSO operations. The Department will implement policies and procedures to review and approved CNP system changes. Completion Date: June 1, 2023 (first two items) and June 30, 2023 (third item) Agency Contact: Jane McLucas, Director of Child Nutrition, DOE, 207-624-6880

Department: Education Title: Internal control over CNC special reporting needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Department will develop and implement a procedure for the Child Nutrition Cluster to ensure subawards meeting or exceeding the first-tier threshold are reported accurately, timely, and in accordance with Federal regulations. Completion Date: June 30, 2023 Agency Contact: Jane McLucas, Director of Child Nutrition, DOE, 207-624-6880

Condition: The District?s school lunch office maintains production records and manual count sheets instead of using the point of sale system for tracking student meat counts. Corrective Action Planned: Due to a staffing shortage the district is unable to run the point of sale system. We are currently advertising weekly for new staff to hire. We have a low starting salary and the turnover is very high. We are in negotiations with the union to increase the starting pay and are trying to get creative to see if there is a way to add more duties to the new employees to increase the hours of the job to make the positions more attractive. We are also in the process of purchasing a new point of sale system that will help streamline the process and won?t be as staff intensive. Anticipated Completion Date: Hiring of new staff - March 2023 New POS System - September 1, 2023 Contact: Ann-Marie Geyster

Finding Number: 2022-002 Planned Corrective Action: If the district is required to return to tally sheets for the calculation of site claim forms, more stringent reviews will be put into place between the tally sheets and the entering of the site claim form data. The 2021 ? 2022 school year had special procedures in place due to the ongoing pandemic. Anticipated Completion Date: March 16, 2023 Responsible Contact Person: Mandy Hildebrand, Treasurer

A plan will be developed by the District to eliminate the excess of net resources in the Food Service Fund.

Management Views ? Management agrees with the finding and the recommendation. Corrective Action Planned ? Management has implemented procedures to ensure that the free and reduced price applications and the verifications are kept on file and scanned. The appropriate employees will be trained and be made aware of the requirements for these documents. Anticipated Completion Date ? This procedure has been implemented for the 2022-2023 school year and all of the appropriate employees are aware of the importance of keeping these documents.

Information on Federal Programs: U.S. Department of Agriculture Child Nutrition Cluster (COVID-19 National School Lunch Program and COVID-19 School Breakfast Program and Food Distribution, Federal Assistance Listing No. 0.553 and 10.555) passed through the New York State Education Department. Findings and questioned costs related to Federal awards which are required to be reported in accordance with the Uniform Guidance 2 CFR 200.516(a): Criteria: CFR Section 200.318 stipulates that a non -Federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws, and regulations, provided that the procurements conform to applicable Federal law and the standards identified in Part 200 Subpart D. Additionally, 2 CFR Section 200.213 stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Statement of Condition: During our discussions with management and testing of the major program, we noted that the District is not verifying the eligibility of vendors to participate in Federal assistance programs. Statement of Cause: The District did not review compliance requirements related to procurement outlined in 2 CFR Section 200.318 and Section 200.213. Statement of Effect: The District is not in compliance with 2 CFR Section 200.213. The District is not performing required procedures, as a result, vendors that are not eligible for participation in Federal assistance programs or activities could be selected or the District could be overpaying for goods and services. Questioned Cost: None. Repeat Finding: No Perspective Information: As part of testing of compliance over procurement, a selection of vendors charged to the major program was selected for testing of compliance. Of the District?s vendors charged to the program, none were suspended or debarred from participation in Federal assistance programs and activities. Recommendation: We recommend that 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. Views of the Responsible Officials and Planned Corrective Actions: The District has reviewed the requirements of 2 CFR Section 200.213. The District is in agreement with the recommendation to implement a procedure to document the process used to verify the eligibility of potential vendors to participate in Federal assistance programs. The verification of excluded parties will be accomplished by accessing the System for Award Management (SAM.gov) website and selecting the ?Excluded Entity? filter on the ?Exclusions? search page to search for exclusions by Unique Entity ID or CAGE/NCAGE code as follows: 1) Select ?Search? from the header menu from any page on SAM.gov 2) In the filters, under ?Select Domain?, select ?Entity Information?, then select Exclusions 3) Use the filters or keyword box to enter the search criteria and view the results 4) Document the results in the vendor file. Other alternatives for verification may include collecting a certification from the entity or adding a clause or condition to the covered transaction or contract with that entity. The Purchasing Agent is charged with the responsibility of monitoring and ensuring compliance with the suspension and debarment procedures and maintaining documentation that contracts expected to equal or exceed $25,000 have been verified on the System for Award Management (SAM) website before purchases are made. Responsible Person(s): Kristin Chotkowski, Purchasing Agent Deadline for Completion: On or before 4/1/23 for covered transactions with contracts or purchase orders meeting the threshold during the time period 7/1/22 - 1/31/23. Prior to contract approval or purchase order issuance for contracts or purchase orders meeting the threshold on or after 2/1/23.

Planned Corrective Action: Management continues to follow the approved Excess Fund Balance Elimination Plan. It is expected the equipment investment will be made in the upcoming fiscal year. Quarterly reviews of the Cafeteria fund balance are planned. Anticipated completion date: June 2023. Responsible contact person: Angela Gleason, Finance Director.

Planned Corrective Action: Management has initiated a review of the payroll process and procedures and will make necessary adjustments to include verification and review of payroll servicer calculations. Anticipated completion date: January 2023. Responsible contact person: Angela Gleason, Director of Finance.

Finding 2022-004 Activities Allowed or Unallowed ? Child Nutrition Cluster Material Weakness in Internal Control Over Compliance Finding Summary: The District has no procedure in place for review of pay rates paid to employees under federal programs in the Child Nutrition Cluster. Responsible Individuals: Shannon Hunstad, Superintendent Corrective Action Plan: The District will review and strengthen the controls surrounding the review and approval of allowable costs in the Child Nutrition Cluster to ensure they are supported, approved, and accurate. Anticipated Completion Date: June 30, 2023