Corrective Action Plans

Contact Person Responsible for Corrective Action: Kelsi Hall Contact Phone Number: 765-641-2096 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Meal counts are gathered and printed off of NutriKids by the food service Bookkeeper and given to the Director. The Director reviews the information and enters the numbers in CNPweb for each school individually. Before submitting the claims, the Director cross references the combined totals from NutriKids with the totals on the CNPweb Sponsor Claims page to ensure they match. If they do not match, this would alert the Director if there were any typos or errors in CNPweb. The meal count papers are then returned to the Bookkeeper to double check that the numbers entered in CNPweb match the numbers that were printed off from NutriKids. Anticipated Completion Date: July 1, 2023

Contact Person Responsible for Corrective Action: Kelsi Hall Contact Phone Number: 765-641-2096 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: At the beginning of each calendar year, the Food Service Director will receive suspension and debarment statements for each applicable vendor that the food service department uses throughout the year. The Food Service Director will obtain suspension and debarment statements from new vendors as they are used. Statements verifying that the vendor is not suspended or debarred from federal awards will be initialed by two individuals within the food service department. A complete list of vendors checked for suspension and debarment will be kept in the Food Service Director's office for safekeeping. Anticipated Completion Date: July 1, 2023

Corrective Action: The Bookkeeper will look at and sign off on all final food service claims before being submitted. Responsible Person: Brooke Rosemeyer, Bookkeeper Anticipated Completion Date: Ongoing

Department of Public Instruction Finding: 2022-022 Department of Public Instruction Response/Corrective Action Plan: We agree with the finding. Currently, USDA and DOE sub-awards are reported after the obligation or sub-award has been approved by all parties according to the requirements established by FSRS?s website. The Block Award, or the federal award which reimburses for meals claimed, will be reported after the meals have been claimed in NDFoods and paid in Peoplesoft. NDDPI will report the payments already made for FY 2023 and will work with our NDIT programmers to allow us to create an auto-generated report from NDFoods that will upload into the FSRS website according to FSRS?s template. To enter expenditure data by month in FSRS, Awardees are encouraged to complete a template to upload the required data. Unfortunately, NDDPI is aware of an issue with this template caused by the need for a 4-digit extension number. The lack of 4-digit zip code extensions with our rural sub-recipients is responsible for throwing this error in the upload. To complete a successful upload, NDDPI will omit any sub-recipients missing the 4-digit zip code extension from the monthly data or template and add them to the report with a manual entry on the website. The Director of CN and the CN Technology Coordinator will work with NDIT to program the needed reports from NDFoods. The Administrative Officer and the Account/Budget Specialist from the Fiscal Management office will be responsible for completing the upload and entering any manual data. After we have a defined set of steps to follow, we will create a written process and edit as needed. Contact Person Linda Schloer, Director, Child Nutrition and Food Distribution Programs Scott Egge, Technology Coordinator, Child Nutrition Kim Vega, Administrative Officer III, Fiscal Management Leon Rauser, Account/Budget Specialist, Fiscal Management Anticipated Completion Date Begin manual process procedure, 04/01/2023, enter sub-recipient data monthly from October 2022 forward until an automated process can be obtained. Autogenerated process date is uncertain, NDDPI will work with NDIT to establish an automated process as soon as IT?s schedule allows and testing is completed.

Condition: The District has not adequately established internal controls to ensure that net cash resources are being properly monitored. Plan: Internal controls will be established and implemented related to the cash management compliance requirement, including monitoring accumulated cash balances and ensuring that balance does not exceed 3 months of the average progam expenditures. Anticipated Date of Completion: 6/30/2023 Name of Contact Person: Brian Dukes, Superintendent Management Response: There is no disagreement with this finding and internal controls will be developed to monitor the net cash resources of the nonprofit school food service.

Corrective Action Plan December 6, 2022 Cognizant or Oversight Agency for Audit Unified School District #343 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 December 6, 2022 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Finding: 2022-001 ? 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 that on one day, eligible student meals were not included in the student meals total that was claimed for reimbursement. 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. Action Taken: We concur with the recommendation and since the 2022 fiscal audit took place, we have updated review procedures to ensure that all meal reports are reviewed to ensure that they are being properly reported. Anticipated Complete Date: October 26, 2022 Should the Oversight Agency for Audit have questions regarding this plan, please contact Jenny Herschell, Business Manager/Board Clerk, at (785) 597-5138. Sincerely Unified School District #343

2022-004 -Child Nutrition Reporting Assistance Listing Number(s) 10.553, 10.555 Recommendation: CLA recommends the District implement a review procedure over reimbursement requests where someone other than the preparer reviews the claim to ensure counts agree back to supporting documentation prior to the reimbursement request being filed with the granting agency. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: Starting with the 2022-23 fiscal year, in September 2022, breakfast and lunch purchases are scanned into the software systems from which the claims are submitted rather than the hand tallies used in prior year. The Food Service Director will continue to submit the breakfast and lunch claims. Each Wednesday, the Finance Director will review an audit check printout of the breakfast and lunch counts to make sure that they are being correctly entered in the system. Name(s) of the contact person(s) responsible for corrective action: Charles Payant, Finance Director Planned completion date for corrective action plan: Winter 2022.

Management?s Response/Corrective Action Plan: The business manager and school nutrition director will ensure all documentation are maintained for each claim for audit purposes. The meal counts are now in the new point of sale system this fiscal year, which was not available last year for all students. All documents will be maintained correctly.

Management?s Response/Corrective Action Plan: The school business manager will ensure all supporting documentation supports the reported meal counts for school claims. The school manager has met with the new school nutrition director to create a plan. The correction has been made for fiscal year 2023.

CORRECTIVE ACTION PLAN - FINDING 2022-001 We have prepared the accompanying corrective action plan as required by the standards applicable to the financial audit contained in Government Auditing Standards and by the audit requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). CFDA Number Program Title Federal Agency 10.555, 10.559 Child Nutrition Cluster U.S. Department of Agriculture Condition The District did not properly review child nutrition claim forms prior to submission to the Arizona Department of Education resulting in net over claimed amount of $7,732. Corrective Action Plan The District has implemented a review of child nutrition claims to source reports prior to submission to the Arizona Department of Education. District Contact Erin Pugh, Business Manager Completion Date January 27, 2023

ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Olympia School District No. 111 September 1, 2021 through August 31, 2022 This schedule presents the corrective action planned by the District for findings reported in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Finding ref number: 2022-001 Finding caption: The District?s internal controls were inadequate for ensuring compliance with federal Title I requirements for eligibility and assessment system security. Name, address, and telephone of District contact person: Kate Davis, 111 Bethel Street N.E., Olympia WA, 98506, 360-596-6124 Corrective action the auditee plans to take in response to the finding: Title I, Part A: Ranking and Allocation The Olympia School District will utilize the Title I, Part A guide released by OSPI annually and reference the School Low-Income counts (page 52) to ensure that the District is using the correct low-income codes that should be included based on the form selected in the grant application. The District will have the Executive Director of Teaching and Learning, the Program Manager, and OSPI Title I, Part A Program contact confirm that student data is accurate prior to submitting the 2023-2024 grant. Assessment System Security Prior to the 2022 school year, Assessment Services was part of the Teaching and Learning Department. Moving forward, OSD will move responsibility of Assessment Services back to this department. Part of this transition will include the Executive Director of Teaching and Learning and Assessment Director developing written test security building plans for all standardized tests administered in OSD. Additionally, these same directors will work closely with OSPI?s Assessment Operations Department to ensure compliance with each state assessment?s training and documentation requirements.Anticipated date to complete the corrective action: Ranking and Allocation: The District will implement this corrective action immediately, and it will be reflected in the 2023-2024 Consolidated grant application. Assessment System Security: The District will implement this corrective action immediately, and it will be implemented with adjusted training for staff beginning Fall 2023.

8. Deficiency 2022-008 ? Instance of Noncompliance ? Meal County Tally a. An instance of noncompliance was identified over compliance requirement L from the 2022 Office of Management and Budget (OMB) Compliance Supplement. Recordkeeping of the daily supporting documentation for the monthly claims was found to not be in compliance with federal requirements. The District should develop and implement policies and procedures to ensure that all original daily meal counts and tallies used to support reimbursement reports are maintained for the appropriate amount of time. b. Plan of Action: The District will review, develop and implement procedures to provide the required reporting. c. Timeframe: Fiscal year 2023-24

7. Deficiency 2022-007 ? Instance of Noncompliance ? Procurement Policy a. An instance of noncompliance was identified over compliance requirement 1(a) from the 2022 Office of Management and Budget (OMB) Compliance Supplement. The District does not have a documented procurement policy. The District should develop and implement a formal procurement policy consistent with Federal, State, and local laws and regulations. b. Plan of Action: The District will undertake a review of best practices regarding procurement policy and will advance resulting recommendations. c. Timeframe: Fiscal year 2023-24

6. Deficiency 2022-006 ? Material Weakness ? Eligibility Verification Review a. A material weakness in controls over compliance was identified for controls over compliance requirement N.1 from the 2022 Office of Management and Budget (OMB) Compliance Supplement. Controls over eligibility verification were found not to be implemented. The District should develop and implement policies and procedures to ensure that all eligibility verifications are review in a timely manner and documented appropriately. b. Plan of Action: The District will develop procedures to ensure all eligibility verifications are reviewed timely by an administrator and documented appropriately. c. Timeframe: August 2023

5. Deficiency 2022-005 ? Material Weakness ? Evidence of Review Needed a. A material weakness in controls over compliance was identified for controls over compliance requirement L from the 2022 Office of Management and Budget (OMB) Compliance Supplement. Controls over reporting were found not to be implemented. The District should develop and implement policies and procedures to ensure that all monthly reimbursement reports are reviewed in a timely manner and documented appropriately. b. Plan of Action: The District will implement internal controls to address the need for additional oversight of monthly meal reimbursement reports. c. Timeframe: August 2023

4. Deficiency 2022-004 ? Material Weakness ? Federal Vendor Status Check a. A material weakness in controls over compliance was identified for controls over compliance requirement I(b) from the 2022 Office of Management and Budget (OMB) Compliance Supplement. Controls over suspension and debarment determinations were found not to be implemented. The District should develop and implement policies and procedures to ensure that all suspension and debarment determinations are reviewed in a timely manner and documented appropriately. b. Plan of Action: The District is implementing new protocols to ensure vendors receiving federal dollars are appropriately vetted for suspension or debarment, using SAM.gov. c. Timeframe: New protocols are underway to be established for school year 2023-24.

3. Deficiency 2022-003 ? Material Weakness ? Eligibility Determination a. A material weakness in controls over compliance was identified for controls over compliance requirement E from the 2022 Office of Management and Budget (OMB) Compliance Supplement. Controls over eligibility determinations were found not to be implemented. The District should develop and implement policies and procedures to ensure that all eligibility determinations are reviewed in a timely manner and documented appropriately. b. Plan of Action: The District will develop procedures to ensure all eligibility determinations are reviewed timely and documented appropriately by an administrator. c. Timeframe: Beginning August 2023

2022-006 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 disbursement funds to the vendor. Views of the Responsible Officials and Planned Corrective Actions: The District has created a sams.gov account to verify any company that is paid with Federal money. Implementation Plan: The Interim Business Administrator will work closely with the new Food Service Director to verify and record any company/vendor that is paid with Federal money. Implementation Date: November 2022. Person Responsible for Implementation: Interim Business Administrator - Brenda Leitt.

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 Assistance Listing Number: 10.553, 10.555 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness 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 two claims in a sample of four, there was no formal evidence of the sponsor claim reimbursement summary being reviewed by someone independent of who prepared the sponsor claim reimbursement summary prior to submission. We noted that for one claim in a sample of four, the meal counts were over/under claimed for the month. We noted that in October 2020 the School Corporation had overclaimed lunches by 175 meals and underclaimed breakfast by 156 meals. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Superintendent is now utilizing the personalized login on CNP Web to review claims before final submission. The superintendent will also email approval of claims to the FSMC Food Service Director upon submission and approval by the superintendent on CNP Web. Responsible Party and Timeline for Completion: The Superintendent and FSMC Food Service Director will be the responsible parties and the corrective action will take place immediately (3/15/2023).

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.