Corrective Action Plans

Finding 2022-002: Child Nutrition Cluster Resource Management Procedures Pass-through entity: Michigan Department of Education Assistance Listing Number(s): 10.553, 10.555 and 10.559 Award Numbers: COVID-19 211971, COVID-19 221970, COVID-19 221971, COVID-19 211961, COVID-19 220910, COVID-19 221960, COVID-19 221961, COVID-19 210904 and Entitlement Commodities Award Year Ends: June 30, 2022 Recommendation: The School District should develop and complete a spend-down plan to ensure it reduces its Food Service Fund net cash resources below the maximum allowable amount. Action Taken: The School District has started to develop a spend-down plan that it will implement and complete in the fiscal year ending June 30, 2023. Responsible Person and Anticipated Completion Date: The Superintendent is responsible for the development and execution of the spend-down plan with a completion date of June 30, 2023. If the Michigan Department of Education has questions regarding this plan, please call Mark Platt at (231) 873-6224.

FINDING 2022-003 Contact Person Responsible for Corrective Action: Julia Smith, Business Manager Contact Phone Number: 317-788-4481 Views of Responsible Official: We concur with the findings Description of Corrective Action Plan: The Foodservice Director and Business Manager will refer to the Guidance for State Agencies and School Food Authorities manual to ensure compliance for allowable costs. Anticipated Completion Date: January 2023

Findings and Questioned Costs Related to Federal Awards Finding Number: 2022-001 Contact Person: Dr. Shelley Isai, Assistant Superintendent for Education Services Anticipated Completion Date: November 21, 2022 Planned Corrective Action: The District reviewed the procedures used to determine Title I, Part A eligibility in the Grants Management System as well as a process that includes maintaining records. The process was redefined for the fiscal year 2023 grant application but will change slightly in future years due to a change in the options in criteria available used to determine eligibility for fiscal year 2023 grant applications. To complete this process with accuracy, the Director of Federal Projects will communicate the required eligibility criteria to the Director of Nutrition Services. The Nutrition Services department will provide Federal Projects with the necessary information to complete the process. Supporting documentation for the basis of fiscal year 2023 and the future years will be stored in a shared file and readily accessible for reference or audits. This process has been documented to ensure consistency through any department transitions.

FINDING 2022-004 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, Summer Food Service Program for Children Assistance Listing Number: 10.533, 10.555, 10.559 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Significant Deficiency 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: For one of our procurement selections, out of a sample of two, the School Corporation was not able to provide verification that the vendor is not suspended or debarred. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and will take the following corrective action. The Treasurer will ensure the Procurement and Suspension and Debarment requirements are met prior to purchase for the Child Nutrition Program by reviewing the quotes and checking SAM.gov. Responsible party and timeline for completion: The Corporation Treasurer will be responsible effective immediately.

FINDING 2022-003 Information on the federal program: Subject: Child Nutrition Cluster - Reporting Federal Agency: Department of Education 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: Reporting Audit Finding: Significant Deficiency Condition: 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 reporting compliance requirement. Context: We noted that for one sponsor claim reimbursement in a sample of four claims, the Food Service Director prepared the sponsor claim reimbursement summary without a secondary, documented review before the submission of the claim to ensure the accuracy of the sponsor claim reimbursement summary. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and will take the following corrective action. The Food Service Director will have the School Nutrition Program Director review, approve and initial the sponsor claim reimbursement summary before submission. Responsible party and timeline for completion: School Nutrition Program Director and School Treasurer will be responsible effective immediately.

Compliance: Finding: 2022-007 Condition: The District does not have a process in place currently nor is using the USDA's Nonprogram Revenue Tool to monitor the District's compliance with 7 CFR 210.14(f) to ensure that costs of nonprogram foods are not being subsidized by program food revenues. Plan: The District will begin using the USDA's Nonprogram Revenue Tool as well as work with Aramark to change the presentation of the invoices received. The District will also request additional monthly reports detailing revenue from nonprogram foods. Anticipated Date of Completion: June 30, 2023 Name of Contact Person: Dr. Joel Hackney, Superintendent Management's Response: Management will begin using the USDA's Nonprogram Revenue Tool, updated invoices from Aramark, and new reports from Aramark to ensure compliance with the Code of Federal Regulations.

Compliance: Finding: 2022-006 Condition: There was no termination clause noted in the Aramark contract stating whereby either party may cancel for cause with 60-day notification as required by 7 CFR 210.16(d) and 7 CFR 220.7(d)(4). Plan: The Aramark contract will be updated to include the proper termination clause stating whereby either party may cancel for cause with 60-day notification. Anticipated Date of Completion: June 30, 2023 Name of Contact Person: Dr. Joel Hackney, Superintendent Management's Response: Management will ensure the Aramark contract has been updated with the proper termination clause before signing another contract.

Compliance: Finding: 2022-005 Condition: No on-site review was done for the National School Lunch Program or for the School Breakfast Program as required to be done prior to February 1 of each school year to remain compliant with 7 Code of Federal Regulations (CFR) 210.8(a)(1) and 7 CFR 220.11(d)(1). Plan: On-site reviews will be completed for both the National School Lunch Program and the School Breakfast Program by February 1 of each school year. Anticipated Date of Completion: June 30, 2023 Name of Contact Person: Dr. Joel Hackney, Superintendent Management's Response: Management will ensure all necessary on-site reviews are completed by February 1 of each school year.

We purchased items via an interlocal agreement, ?piggybacking? on their contract. We had relied on the documentation done by the contracting agency instead of conducting a SAM verification ourselves. Prior to the audit, we had already updated our documentation for the subsequent year. We have revised our procedure further to ensure a two person control on the completion and documentation of compliance with federal suspension and debarment requirements.

Purchase Needed Equipment

See Corrective Action Plan for chart/table

CORRECTIVE ACTION PLAN Finding 2022-001: Immaterial Noncompliance Federal Award Finding 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 has 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 to be before the end of the 2022-23 fiscal year. The persons responsible for the corrective action are Gennie Knapp, the director of dining and nutrition services and Emily Kearney, chief financial officer. The plan for monitoring adherence is the food service director and chief financial officer will work together to assess where the fund balance is after all of the projects from the spend down plan are completed.

FINDING 2022-002 Contact Person Responsible for Corrective Action: John Szabo, Director of Business Affairs Contact Phone Number:812-443-4461 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: In order to monitor allowable costs, the Food Services Director (currently Patricia Woolery) will review billing statements and insure that costs being billed to the school corporation are consistent with purchasing agreements that are in place. Food Services Director will communicate with vendors and review any communication from vendors in regards to price variance of items. Even though it may not be reasonable to double check each individual item ordered, Food Services Director will spot check an appropriate number of items to insure accuracy of costs. Anticipated Completion Date: August 1, 2023

DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION 2022-003 Child Nutrition Cluster ? Assistance Listing No. 10.555, 10.559, 10.582 Action taken in response to the finding: The timeliness of reporting was affected by FSRS rejecting original report submittals and correcting the errors timely. To address this issue, DESE will review, and enhance procedures and internal controls to ensure that all required subawards are reported timely to FSRS no later than the end of the month following the month of issuance. Specifically; (1) update procedures to ensure that DESE maintains all supporting documentation for report delays due to FSRS rejections and issues that arise during the reporting process that may cause delays in timely reporting; and (2) Incorporating other DESE units and staff in resolving reporting issues to avoid reporting delays. Name of the contact person responsible for corrective action: Robert Curtin, Associate Commissioner of DATA, Robert Leshin, Director of Nutrition, Robert McDonald, Federal Grants Manager, Jeffrey Benbenek, Director of Audit & Compliance Planned completion date for corrective action plan: July 1, 2023

DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION 2022-002 Child Nutrition Cluster ? Assistance Listing No. 10.555, 10.559, 10.582 Action taken in response to the finding: The Office for Food and Nutrition Programs (FNP) has moved from a paper based permanent agreement to a web form that exists on the DESE Security Portal. All existing and new Child Nutrition Sponsors will continue to sign off on the document via the web-based portal allowing for a more efficient collection and document retention process. The identified sponsors with missing permanent agreements for the time period selected now have signed permanent agreements via the web-based form. Name of the contact person responsible for corrective action: Robert Leshin, Director of Nutrition Planned completion date for corrective action plan: Action Completed

Finding 2022-004 ? Child Nutrition Cluster - Reporting Contact Person Responsible for Corrective Action: Christopher deBruyn Contact Phone Number: (219) 785-2239 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Moving forward, after the claims report has been processed by the Food Service Director a documented review will be completed by the Food Service Manager or a member of the corporation staff, Signatures will be required for proof of verification, and review. Anticipated Completion Date: Now

Corrective Action Planned: Management will review the internal controls in place to ensure disbursements are properly approved. Person Responsible for Corrective Actions: Director of Business, Ouachita Parish School Board, 1600 North 7th Street, West Monroe, LA 71291. Phone: (318)432-5234 Fax: (318)432-5221.

Condition The District submitted inaccurate meal counts for reimbursement. Recommendation We recommend that the District review its controls related to monthly reimbursement requests for the Child Nutrition Cluster in order to ensure that accurate meal counts are submitted. Action Taken The School District has resubmitted the December 2021 meal count claims, which have been approved by KSDE. As of August 2022, paper meal count sheets are no longer being used to account for meals, and the Food Service Program is back to using their POS eTrition for meal counting, which will reduce the errors of meal claims. Steps when preparing to submit meal claims will be as follows: 1. Managers at each school will ensure meal counts on their 9-A & 9-B excel forms match their eTrition meal counts. 2. The Production Records Secretary will double check that the 9-A & 9-B excel forms that were turned in match the meal counts in eTrition. 3. The Director will input the claims based off of the 9-A & 9-B excel forms. 4. The Director will have the Office Manager double check that the claims were input into KN-Claim correctly before the Director will make the final submission.

Corrective Action Plan - 55 - January 25, 2023 Cognizant or Oversight Agency for Audit Unified School District #244 respectfully submits the following corrective action plan for the year ended June 30, 2022. Name and address of independent public accounting firm: Jarred, Gilmore & Phillips, PA, P.O. Box 779, 1815 S Santa Fe, Chanute, Kansas 66720. Audit period: Year ended June 30, 2022. The findings from the January 25, 2023 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Finding 2022-001 ? Misreported Checks Condition: During our review of Accounts Payable, it was noted that the use of split checks led to a check number designated for supplies being used to pay a different vendor for payroll taxes. Recommendation: Procedures should be implemented the only allow for check numbers to be used for one vendor only and those encumbered funds that aren?t fully spent be credited back to the original funds. Action Taken: Split checks will no longer be used and all current outstanding split check numbers have been reviewed in the accounting software to ensure that the checks have only been written to the appropriate vendor and that those outstanding split checks were only used on the appropriate vendors as stated in the original purchase order. Anticipated Completion Date: February 2023 Finding: 2022-002 ? Meal Reporting Condition: During our testing of meal reporting, we tested two months of meal report claims submitted to the State and traced to individual count sheets per school. It was discovered in one month three meals were over reported and six meals the second month were over reported. Recommendation: Policies and procedures should be written to provide internal control over meal reporting. We recommend the District establish a review process, such as having another individual review count sheets and compare them to the number of meals submitted, to ensure all meals submitted for reimbursement are for the correct number of meals. - 56 - Action Taken: We are in agreement and since the 2022 fiscal audit took place, the District has updated their processes to include a review of all count sheets to ensure that the correct number of meals are being submitted for reimbursement. Anticipated Completion Date: October 24, 2022 Should the Oversight Agency for Audit have questions regarding this plan, please contact Christy Hess, Business Manager/Board Clerk, at (620) 364-8478. Sincerely Unified School District #244 Unified School District #244

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