Corrective Action Plans

The Chief Financial Officer will ensure staff retain documentation of review and approval of the indirect costs charged to the federal programs, effective immediately. Date of implementation - effective immediately, January 30, 2026.

Response and Corrective Action Plan prepared by: Leanne Green Person Responsible for Implementing the Corrective Action: Leanne Green Anticipated Completion Date of Corrective Action: Vickie Dunaway, School Nutrition Director, corrected and resubmitted the claim in question, as soon as the issue was revealed. USDA paid the difference owed on October 28, 2025. Planned Corrective Action: Once the School Nutrition Director completes the monthly claim, Leanne Green, Finance Director, reviews the paperwork, verifying that all is correct before the claim is filed.

Finding Number: 2025‐001 Program Name/Assistance Listing Title: Child Nutrition Cluster Assistance Listing Numbers: 10.553, 10.555, 10.559 Contact Person: Jessica Johnston, Chief Financial Officer Anticipated Completion Date: August 20, 2025, immediately following the determination that the number of meals reported for reimbursement for the January and March claims did not agree to supporting documentation. Planned Corrective Action: The District has modified its internal controls related to child nutrition claims. The revised procedures include a secondary verification of reimbursable meals, which is completed and submitted by personnel independent of the data entry process.

The organization will revise and reinforce its procurement policies to ensure compliance with 2 CFR 200.318–200.320. Staff involved in procurement will receive training in federal procurement standards, including competitive bidding and documentation requirements. Internal controls will be strengthened to ensure consistent application of procedures and oversight. Anticipated Completion Date: January 31, 2026. Responsible Contact Person: Alfred D. Ivy, Director of Business Affairs & Operations.

FINDING 2025-001 Finding Subject: Child Nutrition Cluster – Internal Controls Contact Person(s) Responsible for Corrective Action: Mendy Shrout & Billy Boyette Contact Phone Number and Email Address(es): (765) 795-4664 / mshrout@cloverdale.k12.in.us & bboyette@cloverdale.k12.in.us Views of Responsible Officials: Option 1: We concur with the finding. Description of Corrective Action Plan: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Payroll distribution reports will be periodically reviewed and initialed by the Corporation Treasurer to assure employees paid are working in the cafeteria. Eligibility Cafeteria Managers will initially enter eligibility information into the POS (Harmony). The Food Service Director or Café Office Manager will sign off on the reports as records are entered. Reporting Food Service Director will provide the reports to the Corporation Treasurer or the Café Office Manager on a monthly basis for review. The reviewer will then initial the documents. Anticipated Completion Date: February 1, 2026

Background and Context: The District has a long-standing history of strong financial compliance and has not previously received audit findings related to internal controls or reporting. The error was isolated, not systemic, and was identified without evidence of intentional misreporting or ongoing risk. The District has implemented additional review steps as identified below to ensure continued accuracy in future submissions. Subject: Finding 2025-001: The finding indicates 2 errors were made in transferring data from the Daily Accuclaim Report to the Monthly Record of Meals Served at the East Campus resulting in an inaccurate request for reimbursement in the amount of approximately $55.00; these errors were made in 2 separate monthly reports during the 2025 fiscal year. Management response to FY 2025-001 Audit Findings The management of the Organization acknowledges the need for stronger internal controls in the administration of the Child Nutrition Meal Reimbursement Task Cluster. The agency implemented refresher training with the Administrative Assistant and the Campus Principal at the East Campus. Training was completed on November 18, 2025. Additionally, the agency has implemented stringent internal controls to ensure that all data regarding meal counts and reimbursement claims will be verified to ensure accuracy. It was noted that this weakness resulted in errors when the Administrative Assistant transferred data from the Daily Accuclaim to the Monthly Record of Meals Served. To prevent any errors in future claims, the following Standard Operating Procedure for all campuses was created: 1. The Administrative Assistant will tabulate meals served and enter daily totals on the Daily Accuclaim Report. The Campus Principal will provide a second count for daily totals and verify that the correct total was entered on the Daily Accuclaim Report. Both the Administrative Assistant and the Campus Principal will initial the Daily Accuclaim Report when verifications have been completed. 2. Data from the Daily Accuclaim Report will be transferred to the Monthly Record of Meals Served. Both the Administrative Assistant and the Campus Principal will verify that data has been correctly transferred and totaled accurately. Both the Administrative Assistant and the Campus Principal will initial the Monthly Record of Meals Served. 3. At the end of each month, Weekly Student Rosters, Daily Accuclaim Reports and the Monthly Record of Meals Served will be forwarded to the Director of Child Nutrition who will verify and initial all reports and enter data in TXUNPS for reimbursement. When all data for the month has been entered, a Summary Report will be printed and submitted to the Superintendent along with all documents for review and approval. Upon Superintendent written approval, the CNP Director will submit requests for reimbursement through TXUNPS. The agency will implement these Standard Operating Procedures beginning with the December 2025, Reimbursement Claim. It is believed that procedures requiring two personnel to review and sign off on all daily and monthly data and before final submission will ensure accuracy in Reimbursement Claims.

FINDING 2025-001 – Significant Deficiency in Internal Control over Compliance Description of Finding: The State Funding Agency audited the Child Nutrition program and found that the school food authority (SFA) was charged an indirect cost rate less than provided for in the indirect cost rate agreement and there was no document explaining how the difference would be handled with the nonprofit school food service account. They also identified that food expenses were included in the direct cost base. Food is considered a distorted fund and is not to be included in the direct cost base. Statement of Concurrence or Nonconcurrence: The Agency agrees with this finding during the Audit period and has made the necessary corrections. Corrective Action: The Organization has implemented procedures outlining how discrepancies will be managed. These procedures will be shared with relevant personnel, and training sessions will be conducted to ensure full compliance. Additionally, we have recalculated the indirect costs for FY2025, excluding the food expenses from the direct cost base. This recalculated amount was reflected in the revised financial reporting. Name of Contact Person: Richard Carmelich, Chief Operations Officer Projected Completion Date: June 30, 2025 QUESTIONED COSTS 1. There was $41,868 in questioned costs as a result of the 2025-001 audit finding. The Organization agreed that the cost was unallowable and revised the financial reporting to the satisfaction of the auditing State agency.

Condition: The same individual is responsible for preparing and submitting monthly reimbursement claims for the Child Nutrition Program without an independent review or approval prior to submission. Plan: A second person (business manager) compares the meal counts in the claim to the SDS daily meal count reports, monthly participation summary, eligibility rosters (free, reduced, paid) and USDA reimbursement rates. The reviewer will then sign and date a reconciliation sheet before submission. Anticipated date of completion: June 30, 2026. Name of contact person: Todd Hellrigel, Superintendent. Management response: The corrective action plan was discussed with the employee responsible for filing the claim, the business manager, and the superintendent. After discussion, the plan was approved by the superintendent.

Condition: The same individual is responsible for preparing and submitting monthly reimbursement claims for the Child Nutrition Program without an independent review or approval prior to submission. Plan: A second person (superintendent) compares the meal counts in the claim to the SDS daily meal count reports, monthly participation summary, eligibility rosters (free, reduced, paid) and USDA reimbursement rates. The reviewer will then sign and date a reconciliation sheet before submission. Anticipated date of completion: June 30, 2026. Name of contact person: Brett Elliott, Superintendent. Management response: The corrective action plan was discussed with the employee responsible for filing the claim, the business manager, and the superintendent. After discussion, the plan was approved by the superintendent.

Condition: The same individual is responsible for preparing and submitting monthly reimbursement claims for the Child Nutrition Program without an independent review or approval prior to submission. Plan: A second person (chief financial & operations officer) compares the meal counts in the claim to the Skyward daily meal count reports, monthly participation summary, eligibility rosters (free, reduced, paid) and USDA reimbursement rates. The reviewer will then sign and date a reconciliation sheet before submission. Anticipated date of completion: December 7, 2025. Name of contact person: Cassandra Schug, Superintendent. Management response: The corrective action plan was discussed with the business services coordinator and the chief financial & operations officer. After discussion, the plan was approved.

Contact Person – Dr. Noel Schmidt, Superintendent Corrective Action Plan – The District will establish procedures to review meal reimbursement submissions. Completion Date – January 31, 2026

Federal regulations require that verification of applications be conducted by separate officials and that proper documentation and procedures are followed (7 CFR 245.6a). The same individual served as both the confirming and determining/reviewing official. The District did not maintain documentation of confirmation reviews, and some applications were not verified correctly, resulting in incorrect eligibility determinations. The ensure adherence to the separation-of-duties requirement outlinked in 7 CFR 245.6a, the District has designated a separate confirmining official. The verification process will now follow a two-step reivew; the Child Nutrition Secretary will conduct the initial verification of selected applications, and the Child Nutrition Director will complete the independent confirmation review. This structure ensures that two distinct individuals verify the accuracy of eligibility determinations and that proper oversight is maintained. Both the Child Nutrition Secretary and the Child Nutrition Director attended formal verification training in September 2025. This training reinforces correct procedures and supports proper documentation of all confirmation reviews moving forward.

Federal regulations require that eligibility determinations for free and reduced-priced meals be accurate and that benefit issurance documents are updated timely and accurately (7 CFR 245.6, 245.10). Several student applications were incorrectly approved. Additionally, benefit issuance documents were not updated in a timely manner for students newly eligible through Direct Certification. To ensure full compliance with 7 CFR 245.6 and 245.10, the Child Nutrition Director and Child Nutrition Secretary will jointly review each Direct Certification (DC) list to verify that all eligible students are accurately identified and that eligibility status in the point-of-sale (POS) system is update promptly. This dual-review process will service as a verificaiton measure to prevent omissions and ensure the benefit issuance document remains current and accurate. In August 2025, both the Child Nutrition Director and Secretary completed formal training on eligibility determination procedures. Moving forward, detailed notes- including dates and explanations of status changes- will be documented in each student's account to ensure clear tracking of all updates to support accurate recordkeeping for future reviews.

Condition: The same individual is responsible for preparing and submitting monthly reimbursement claims for the Child Nutrition Program without an independent review or approval prior to submission. Plan: A second person (superintendent or associate superintendent) compares the meal counts in the claim to the Skyward and RevTrak daily meal count reports, monthly participation summary, eligibility rosters (free, reduced, paid) and USDA reimbursement rates. The reviewer will then sign and date a reconciliation sheet before submission. Anticipated date of completion: June 30, 2026. Name of contact person: Tony Ingold, Superintendent. Management response: The corrective action plan was discussed with the employee responsible for filing the claim, the associate superintendent, and the superintendent. After discussion, the plan was approved and will be implemented.

FINDING 2025-002 Finding Subject: Child Nutrition Cluster - Suspension and Debarment Contact Person Responsible for Corrective Action: Lori Bennett Contact Phone Number and Email Address: 317-539-9200, LBennett@mccsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The School Corporation will require that suspension and debarment verification be done for all appropriate vendors prior entering into and paying an invoice at the start of each year. The verification is to be done by checking the SAM exclusions, collecting a certification from that person, or adding a clause or condition to the covered transaction with that person. Documentation will be included with the first voucher each year for that qualifying vendor. Anticipated Completion Date: January 2026

Condition: The same individual is responsible for preparing and submitting monthly reimbursement claims for the Child Nutrition Program without an independent review or approval prior to submission. Plan: A second person will compare the meal counts in the claim to: (1) the daily meal counts prepared by cafeteria staff and (2) the monthly enrollment reports from the accounting software. The reviewer will then sign and date the supporting documentation before the meal claim is submitted. Anticipated date of completion: December 2025. Name of contact person: Jake Flowers, Superintendent. Management response: The corrective action plan was discussed with the employees responsible for filing the claim and the superintendent. After discussion, the plan was approved by the superintendent and will be adopted.

A plan was developed by the District to eliminate the excess of net resources in the Food Service Fund. The plan includes a review of the excess of net resources on a monthly basis for determination of areas to improve the foods svc department relating to equipment purchases and staff.

Finding 2025-002: Allowable cost-Significant deficiency in internal controls over compliance. Management Response The District purchased supplies on the District credit card. There was no purchasing requisition entered or approval prior to making the purchase. The District conducted procurement training in August 2025. The District will conduct another training in October 2025 to discuss procurement requirements regarding credit card purchases. If a credit card purchase is made without a requisition, the accounts payable staff will notify the management prior to the credit card payment.

Finding 2025-001: Reporting – Significant deficiency in internal controls over compliance. Management Response: The District’s Child Nutrition Assistant Director (AD) prepared the claims data submitted into the Tx-UNPS System to receive Child Nutrition federal funding. The claims data was submitted without management approval. The District will implement procedures to ensure that monthly claim reports are reviewed by the Chief Operations Officer (COO) prior to being submitted into Tx-UNPS System. The AD will prepare the claims report documentation, which includes the point of sale and attendance reports. The claims report and supporting documentation will be emailed to the COO. Once the reports are reviewed and determined to be accurate, the COO will email approval. Once the AD receives approval via email from the COO, the email will be printed or digitally saved with the claims reports. The AD will submit claims data into the Tx-UNPS System and print the NSLP Claim for Reimbursement Summary. The Summary will be sent to the COO for confirmation. The new process will begin in October 2025.

Subject: Management response to Fiscal Year 2025 Audit Findings The management of Village Tech Schools acknowledges receipt of the following findings for the FY25 audit and has developed a corrective action plan response to address the findings. Finding 2025-001: Reporting – Significant deficiency in internal controls over compliance. Management Response: The District’s Child Nutrition Supervisor (CNS) prepared the claims data submitted into the Tx-UNPS System to receive Child Nutrition federal funding. The claims data was submitted without management approval. The District will implement procedures to ensure that monthly claim reports are reviewed by the Chief Operations Officer (COO) prior to being submitted into Tx-UNPS System. The CNS will prepare the claims report documentation, which includes the point of sale and attendance reports. The claims report and supporting documentation will be emailed to the COO. Once the reports are reviewed and determined to be accurate, the COO will email approval. Once the CNS receives approval via email from the COO, the email will be printed or digitally saved with the claims reports. The CNS will submit claims data into the Tx-UNPS System and print the NSLP Claim for Reimbursement Summary. The Summary will be sent to the COO for confirmation. The new process will begin in October 2025.

The payments made with grant funding have been reclassed to the general fund and all future expenditures for the subgrant will be made through the general fund.

Child Nutrition Cluster (School Breakfast Program, National School Lunch Program, and Summer Food Service Program for Children) – Assistance Listing No. 10.553, 10.555, and 10.559 Recommendation: CLA recommends that the District review its internal controls and implement a procedure to ensure all reports required under the grant have a designated reviewer that is different from the individual responsible for preparing, even when there are gaps of coverage in preparer and reviewer positions, and that the review and approval happens prior to submitting the reports to the granting agency. Explanation of disagreement with audit finding: There is no disagreement with this finding. Action planned/taken in response to finding: The Food Service Director and the Executive Administrative Assistant will work together to ensure that procedures are in place to review and confirm for accuracy. Name(s) of the contact person(s) responsible for corrective action: Frankie Soto, Dawn Rausch Planned completion date for corrective action plan: September 1, 2026.

Child Nutrition Cluster (School Breakfast Program, National School Lunch Program, and Summer Food Service Program for Children) – Assistance Listing No. 10.553, 10.555, and 10.559 Recommendation: CLA recommends the District review its procurement process to ensure that there is adequate segregation of duties in regards to initiating, authorizing, reviewing for grant allowability and approving all procurement transactions. CLA also recommends that the District review and update policies and procedures to help ensure that all federal grants with covered transactions have vendors reviewed for suspension and debarment status prior to entering into the transaction and that documentation of the status is maintained with the procurement history of each transaction that it is required for. Explanation of disagreement with audit finding: There is no disagreement with this finding. Action planned/taken in response to finding: The Food Service Director and the Executive Administrative Assistant and District Administrator will work together to ensure that procedures are in place to review and confirm for accuracy. Name(s) of the contact person(s) responsible for corrective action: Frankie Soto, Dawn Rausch, Adrian Foster Planned completion date for corrective action plan: September 1, 2026.

Child Nutrition Cluster (School Breakfast Program, National School Lunch Program, and Summer Food Service Program for Children) – Assistance Listing No. 10.553, 10.555, and 10.559 Recommendation: CLA recommends that the District implement formal procedures to strengthen controls over eligibility determinations. These procedures should include ensuring timely updates to eligibility listings when students become ineligible, retaining all required documentation for the applicable retention period, and conducting periodic reviews of benefit issuance listings to confirm accuracy. Additionally, CLA recommends the District implement procedures to ensure staff receive training on proper eligibility determination and recordkeeping requirements. Finally, CLA recommends the District establish monitoring controls to verify that benefits are discontinued promptly for students who no longer qualify. Eligibility determinations should be reviewed and approved by someone other than the person entering the applications and direct certification information into the software. Explanation of disagreement with audit finding: There is no disagreement with this finding. Action planned/taken in response to finding: The Food Service Director, high school secretary and the Executive Administrative Assistant will work together to ensure that procedures are in place to review and confirm for accuracy. Name(s) of the contact person(s) responsible for corrective action: Frankie Soto, Dawn Rausch, Emily Krzyzanowski Planned completion date for corrective action plan: September 1, 2026.

The administrative assistant will prepare the "claims summary" forms by obtaining the number of meals served directly from the "Meal Count Edit Form." The Treasurer or Superintendent will also review the "claims summary" forms and supporting documentation for accuracy prior to the electronic submissions. Corresponding documents will be manually signed and dated to indicate approval.