Corrective Action Plans

CORRECTIVE ACTION PLAN November 11, 2022 Michigan Department of Education Lansing, Ml Greenville Public Schools is in agreement with the findings identified and respectfully submits the following Corrective Action Plan for the year ended June 30, 2022. 2022-003 The cash balance in the District's food service fund exceeded the allowable 3 month expenditure amount as of June 30, 2022. The district employee responsible for this area is Matt Andres, Director of Finance. There was a change of leadership in the Finance department at the end of September, 2022. The food service fund balance had not been properly communicated to department leadership, resulting in a surplus of funds. Implementation and Monitoring The District has identified deficiencies in our current processes. A plan has been initiated between the Director of Finance and the Director of Food Service to spend our fund balance within the allowable guidelines during the 2022-2023 fiscal year. If the Michigan Department of Education has any questions regarding this plan, please contact Matt Andres at 616-225-1025?or matt.andres@gpsjackets.org Matt Andres Director of Finance

FINDING 2022-006 Contact Person Responsible for Corrective Action: Tyler C. Osenbaugh Contact Phone Number: 260-336-0217 Views of Responsible Official: Agree with the finding Description of Corrective Action Plan: Meal counts differed from the Meal Magic generated Z report and the Chartwells Profit and Loss statement. These meal counts are reconciled by dividing the a la carte purchases by $2.70 to equate to a meal served. Future Z reports will have the a la carte meal equivalents indicated. These figures will be reviewed and validated during the monthly meeting between School Food Authority and Food Service Director (Chartwells? Director of Dining Services). Anticipated Completion Date: April 2023

Contact Person Responsible for Corrective Action: Tyler C. Osenbaugh Contact Phone Number: 260-336-0217 Views of Responsible Official: Agree with the finding Description of Corrective Action Plan: The School Food Authority and Food Service Director (Chartwells? Director of Dining Services) review and validate the supporting documentation for all food service-related purchases. The documentation, include payroll information and non-payroll expenditures, including vendor deliveries. Copies of the supporting data have been retained by the Business Manager to ensure records are available for audits. The review occurs prior to the SFA submitting for reimbursement into CNPWeb. These steps have been in place correcting the previous finding (2020-002). Future reviews will include supporting vendor (Gordon Food, Piazza, Prairie Farms) price lists in effect during the support period. The prices paid for commodities from these vendors will be compared to Chartwells Operations Ledger to ensure charges are consistent with the costs. Anticipated Completion Date: May 2023

Views of Responsible Officials and Planned Corrective Action: Management agrees with this finding. As noted, a turnover in staff happened right at the time when the verification for FY22 was due and the new staff member did not realize the required verification had not occurred. The School followed proper procedures each year prior to FY22. The School identified the FY22 error at the beginning of the 2022-2023 school year prior to the audit. Immediate action was taken to ensure this error would not reoccur in the future when the School experienced a staffing change. In so doing, the School implemented a step-by-step tutorial of procedures, including reporting dates and deadlines. Necessary staff members have attended, and will continue to attend, training for items related to the application of Educational Benefits. The verification process was checked by a supervisor to ensure proper processes were followed for the 2022-2023 school year and they were.

Condition: The District did not obtain debarment certification or check the System for Award Management website for vendors contracted in excess of $25,000 related to the grant program. Upon further review, it was determined that the vendors were not suspended or debarred. Plan: Procedures need to be implemented to ensure all vendors contracted with have not been suspended or debarred or otherwise excluded from doing business, prior to procuring their services. Anticipated Date of Completion: June 1,2023 Name of Contact Person: Dr. Chad Allaman Management's response: There is no disagreement with this finding and procedures will be implemented to ensure all vendors contracted with have not been suspended or debarred or otherwise excluded from doing business, prior to procuring their services.

Purchase Needed Equipment

FINDING 2022-004 CONTACT PERSON RESPONSIBLE FOR CORRECTIVE ACTION: Lacey Sturgeon/Melissa Bell CONTACT PHONE NUMBER: 765-762-2500 VIEWS OF RESPONSIBLE OFFICIAL: We concur with the finding. DESCRIPTION OF CORRECTIVE ACTION PLAN: All claims will be compiled by the Director of Food Services and validated by the Assistant Food Service Manager. ANTICIPATED COMPLETION DATE: March 2023

FINDING 2022-002 CONTACT PERSON RESPONSIBLE FOR CORRECTIVE ACTION: Lacey Sturgeon/Melissa Bell CONTACT PHONE NUMBER: 765-762-2500 VIEWS OF RESPONSIBLE OFFICIAL: We concur with the finding. DESCRIPTION OF CORRECTIVE ACTION PLAN: All claims/invoices will be reviewed by the Food Service Director and validated by the Assistant Food Service Director for correct contractual prices. ANTICIPATED COMPLETION DATE: March 2023

See corrective action plan

CORRECTIVE ACTION PLAN 2022-001 This finding is caused by the District not having the proper controls in place to prevent, detect, or correct an incorrect monthly meal claim. There was lack of consistency and communication between the Food Service Director and the Business Manager during the fiscal year in relation to meal claims. The persons responsible for the corrective action are Janet Killingsworth, the food service director and Dr. Lori Haven, the superintendent. 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 finance director will work together to ensure that monthly meals served are being reconciled prior to any meal reimbursement requests are made.

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 and has a Michigan Department of Education approved 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 Shelley Ritchie, the food service director and Nadia Hoover, 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.

Finding 2022-003 Finding Summary: The Organization did not have adequate controls to ensure household income was properly certified and may have allowed ineligible households to receive USDA Foods. Responsible Individuals: Administrative assistant (Wendy Matheney) and Front Desk Supervisor (Shannon Thackeray) Corrective Action Plan: Signature paperwork will be verified individually for each client by the front desk staff. The Admin Assistant will supervise data collection and integrity from a big picture standpoint. Anticipated Completion Date: 1/15/2023

2022-004 Special Tests and Provisions ? Verification of Free and Reduced Price Applications Federal Assistance Listing Number: 10.CNC District is in the process of establishing procedures and controls by the Business Manager to oversee the retention of verification documentation and information obtained through the verification process. Responsible Official: Karl Volkmann, Business Manager Anticipated Completion Date: June 30, 2023

2022-003 Segregation of Duties ? Reporting Federal Assistance Listing Number: 10.CNC Management is cognizant of the District?s internal control structure and continues to evaluate cost effective opportunities to further improve segregation of duties. It is the District?s plan to train an individual in the process of submitting claims in order to create a review process of the grant management process. Responsible Official: Karl Volkmann, Business Manager Anticipated Completion Date: June 30, 2023

Current Year Finding #2022-001- Repeat Finding for 2021-001 According to 2 CFR section 200.305(b)(5), when non-federal entities are funded under the reimbursement method, the entity should pay for costs for which reimbursement was requested prior to the date of the reimbursement request. During our audit, we noted the monthly claims for reimbursement were not compared to reports from the point of sale ("POS") system by an individual other than the preparer of the claims report prior to submission. We recommended that the district have an individual other than the preparer of the claims report, review the reports from the POS system prior to submission to verify that the number of meals claim based on actual meals served. Corrective Action: Effective July 30th, 2022, the Food Service Manager will prepare and review the meal count and meal reimbursement to the reports from the point-of-sale system, then prior to submittal will give to the reports from the POS system to the Business Administrator, Mr. Salvatore Carambia to verify and approve the reports from the POS system that the number of meals claimed was based on actual meals served.

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE ? U.S. DEPARTMENT OF AGRICULTURE, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, CHILD NUTRITION CLUSTER ? FEDERAL ALN 10.553, 10.555, AND 10.559 2022-002 Internal Control Over Compliance With Suspension and Debarment Requirements Finding Summary 2 CFR ? 180 requires the Academy to establish and maintain effective internal control over compliance with requirements applicable to federal program expenditures, including suspension and debarment requirements applicable to the child nutrition cluster program. The Academy did not have sufficient controls in place within its child nutrition cluster of federal programs to ensure that it was not contracting for goods or services with parties that are suspended or debarred, or whose principals are suspended or debarred, from participating in contracts involving the expenditures of federal program funds. Corrective Action Plan Actions Planned ? The Academy will review policies and procedures relating to suspension and debarment for its federal programs and will ensure that all parties with which it contracts for goods or services exceeding $25,000 are eligible to participate in contracts involving the expenditures of federal program funding. Official Responsible ? The Academy?s Interim Executive Director, Holly Fischer. Planned Completion Date ? June 30, 2023. Disagreement With or Explanation of Finding ? The Academy agrees with this finding. Plan to Monitor ? The Academy?s Interim Executive Director, Holly Fischer, will ensure appropriate internal controls are in place to verify that any vendor with which the Academy contracts for goods or services exceeding $25,000 is not listed as suspended or debarred on the federal Excluded Parties List System website.

Finding 2022-001 Corrective Action Plan a. Contact person responsible for corrective action: Stacey Graves, CFO b. Description of correction action to be taken: The district will exercise caution in ensuring calculations for indirect cost will calculated as directed by the Mississippi Department of Education. c. Anticipated completion date of corrective action: 3-24-23

FINDING 2022-002 Subject: Child Nutrition Cluster ? Internal Controls 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. Context: The School Corporation contracts with a food service management company for the majority of food costs, labor costs, and operational costs, however in some cases the School Corporation will handle their own additional minor procurements outside of the food service management company. During the audit period, the School Corporation made one purchase between $10,000 and $150,000 which fell under the small purchase method for federal and state procurement regulations and was charged to Fund 0800 ? School Lunch Fund. For that purchase, documentation was not presented to verify methods or rationale used to satisfy the procurement requirements, which require three quotes to be obtained prior to entering into a transaction. The transaction was incurred in July 2021 in the amount of $21,668. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Quotes will be sought for all purchases that fall within the small purchase threshold according to federal and state procurement regulations. Responsible Party and Timeline for Completion: Zach Dennis, CFO, 7/1/2022

Finding Number: 2022-002 Planned Corrective Action: The District has initiated an internal audit reconciliation system to confirm each month that all reimbursable breakfast and lunch reports agree. Anticipated Completion Date: 07/01/2022 Responsible Contact Person: Neil Laughbaum, Director of Operations

Views of Responsible Officials: During the COVID 19 pandemic the District experienced turnover in various key positions resulting from a lapse with record keeping. Management will work to ensure that records related to claim reimbursements are retained for a period of three years. Name of Responsible Person: Jennifer LaBarre, Executive Director of Student Nutrition Services Implementation Date: Fiscal Year 2023-2024

Finding: 2022-003 Cash Management Name of Contact Person: Ms. Robin Norwood Corrective Action: Automation clerk will work with NAF administration personnel to provide management of cash. Proposed Completion Date: August 21, 2023

CORRECTIVE ACTION PLAN November 28, 2022 Central City Cyberschool respectfully submits the following corrective action plan for the year ended July 31, 2022. Walkowicz, Boczkiewicz & Co 1800 East Main Street, Suite 100 Waukesha, WI 53186 Audit period: July 31, 2022 The findings from the July 31, 2022 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AND STATE AWARDS DEPARTMENT OF AGRICULTURE MATERIAL WEAKNESS 2022-001 School Breakfast Program ? CFDA No. 10.553, National School Lunch Program ?CFDA No. 10.555 Condition: There was no verification that the number of meals provided matched the monthly vendor invoice. Criteria: Internal Controls should be in place to ensure the vendor invoices were properly reviewed. Recommendation: Internal controls procedures should be established to ensure the number of meals provided match the monthly vendor invoice. Action Taken: ? Internal controls were established to ensure meals are recorded at point of service. ? Students enter their student number into the student information system (SIS) at point of service. ? Cyberschool employee monitors meals to determine if it qualifies for reimbursement in addition to clicking ?accept? with each SIS entry for a meal. ? There is a back-up paper check off system for employee monitoring to use if primary counting system (SIS) goes down during lunch hour. ? Vendor receives SIS printout the following day to confirm meals recorded. ? Vendor uses SIS printout report to invoice the school. ? When the invoice arrives, the School Operations Manager uses the SIS to confirm bill matches meals served. If questions arise regarding this plan, please call Jessica Whitaker at 414.444.2017

Reference Number: 2022-004 Description: Child Nutrition Cluster ? Reporting Corrective Action Plan: The pandemic-related policies for food service reporting ended on June 30, 2022. For the 2022-23 school year, the District has re-instituted the use of IDs and student numbers to track meal purchases by individual students. Reports from Skyward will be utilized and compared against claim data on a monthly basis . Anticipated Corrective Action Plan Completion Date: 9/1/2023 Contact Information: For additional information regarding this finding please contact Kevin Klimek, Director of Business Services, 414-371-6774

Federal Agency: U.S. Department of Agriculture Federal Program: Child Nutrition Cluster Assistance Listing Number: 10.555 and 10.559 Pass through Agency: Arizona Department of Education Pass Through Number: 7AZ300AZ3 Award Period: July 1, 2021 through June 30, 2022 Repeat Finding: Yes ? 2021-004 Type of Finding: Significant deficiency in internal controls over compliance and immaterial matter of noncompliance 2022-006 Condition: The District did not maintain documentation to support proper review and approval of the monthly meal reimbursement claims. Criteria or Specific Requirement: CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards requires compliance with cash management compliance requirements. The District should have internal controls designed to ensure compliance with those provisions. Context: For four of four monthly meal reimbursement claims tested. Corrective Action Plan: The District will retain documentation in future years to show that monthly claims summaries are reviewed. Anticipated Completion Date: June 30, 2023 Name of Contact Person: Pam Bradford, Interim Business Manager

Contact Person Responsible for Corrective Action: Brian Leitch, Chief Finance & Operations Officer / Treasurer 260-347-2502 ext.: 10017 Roger Urick, Interim Food Service Director 260-347-2502 ext.: 10011 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Internal Controls: The monthly meal reimbursement claims will be calculated by the Food Service Director by using information obtained through meal magic. Once the meal reimbursement is calculated it will be reviewed by the Deputy Treasurer before being submitted by the Food Service Director. Once the reimbursement is received the Deputy Treasurer will verify it was received as submitted. Anticipated Completion Date: April 2023