Corrective Action Plans

2022-002 Child Nutrition Cluster ? Assistance Listing No. 10.553/10.555/10.559 Recommendation: We recommend that the School Corporation ensures that documentation of Procurement's decisions on any purchases that are excluded from the requirements noted in the Procurement Policy are retained for audit purposes. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: This finding was an unusual situation and will be corrected. The procurement transaction in question was originally include in a large building project and would not have been paid with federal dollars. Due to issues with the general contractor, timeliness of completion, and the beginning of the school year, one portion of the project in the school kitchen was pulled from the general contractor and a quote was obtained from one vendor. Quotes from at least three (3) vendors and documentation of any unusual circumstances will be maintained for auditor review. Name(s) of the contact person(s) responsible for corrective action: Louise S. Smith and Jennifer Niese Planned completion date for corrective action plan: March 31, 2023

FINDING 2022-001 ? Material Weakness and Material Noncompliance ? Budget Variances / Allowable Costs Corrective Action Plan: Analyze actual expenditures monthly, review the budget to actual numbers monthly and use data from this review to prepare a more accurate final budget revision. Responsible Parties: Rod Livingston, Business Manager Anticipated complete date of June 30, 2023 Rod Livingston Business Manager

2022-001 Significant Deficiency: Internal control over maintenance of documentation of procedures performed Planned Corrective Action: Management will implement additional procedures to maintain documentation of the review and approval of expenses allocated to federal programs. Anticipated Completion Date: March 31, 2023 Responsible Party: Hasan Suzuk (Executive Director)

Finding 2022-030 Food Distribution Cluster, ALN 10.565, 10.568, and 10.569 - Accountability for USDA Foods Management Views MDE agrees with the finding. During fiscal year 2022, MDE determined that The Emergency Food Assistance Program (TEFAP) State Plan was inefficient and discontinued reviewing eligible recipient agencies (ERA) as outlined in the plan. MDE modified its TEFAP State Plan for fiscal year 2023 to be more reflective of TEFAP inventory movement and still meet the requirements of federal regulation 7 CFR 251.10(e). Planned Corrective Action MDE revised the fiscal year 2023 Michigan TEFAP State Plan, effective October 2022, to require MDE to review ERAs that are considered ?subdistributing agencies? onsite annually and all TEFAP ERAs to submit inventory records and TEFAP foods documentation to MDE as requested twice a year. The change was announced to TEFAP ERAs during the annual All Agency Meetings at the end of August 2022 and through follow up emails and communications. Anticipated Completion Date MDE has already completed the majority of fiscal year 2023 desk and on-site reviews under the revised process and will have completed all of the required fiscal year 2023 inventory reviews by July 31, 2023. Responsible Individual(s) Aimee Alaniz, MDE

This finding has been addressed in fiscal year 2023. ASGDOE school lunch Is working with a representative who oversees civil rights for the USDA wester region. Civil rights training for all SLP staff continues yearly with sign-in sheets and agendas for documentation purposes. Reports are submitted to USDA for inventory and mean counts on the 15th of each month. Special dietary accomodations have since been rolled out and schools have been notified of the process should a student require accomodation. USDA has an on-site visit scheduled not that borders are open. Key individuals responsible: SLP Assistant Director Christina Fualaau. Will be completed and closed in 2023.

Finding Summary: The Hollis Brookline Cooperative School District?s Food Service Fund net cash resources were in excess of the maximum allowable amount by $395,282. Responsible Individual: Kelly Seeley, Business Administrator Corrective Action Plan: The School District has developed a spend-down plan for reducing the Food Service Fund Balance to compliance level during the 2022-23 fiscal year, and has submitted the plan to the State of New Hampshire Department of Education for approval. Anticipated Completion Date: June 30, 2023

Child Nutrition Cluster Segregation of Duties Child Nutrition Cluster ? Assistance Listing No. 10.553, 10.555, 10.559 and 10.582 Recommendation: CLA recommends that the District implement a formal review process over the reporting and verification requirements related to the Child Nutrition Cluster during the fiscal year and properly retain the documentation. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: This process was completed in the fall of 2022. The person handling this for 2021-22 didn?t complete this process because lunches and breakfasts were all free.. Name(s) of the contact person(s) responsible for corrective action: Lisa Hinker Planned completion date for corrective action plan: Fall of 2022

Harlem Consolidated School District 122 Corrective Action Plan for Current Year Audit Findings Year Ending June 30, 2022 Corrective Action Plan Finding No: 2022-001 Condition: For October, December, February, and April, there were variances between the support for meal counts maintained by the District and the number of meals claimed by the District. Plan: The District will create a process in which the elementary buildings will enter their hand tallied breakfast meal counts into a shared spreadsheet daily, and upload the backup documentation weekly. The administrative assistant will review the documents and compile the total meal counts to be entered into WINS monthly. The Director of Food and Nutritional Services will review and verify the compiled information, sign off on the totals and submit the claim to the State. Anticipated Date of Completion: January 2023 Name of Contact Person: Josh Aurand, Chief School Business Official (815) 654-4500

FINDING 2022-002 Contact Person Responsible for Corrective Action: Dawn Mason and Dana Hedges Contact Phone Number: 260-868-2125 Views of Responsible Official. We agree with the finding. Description of Corrective Action Plan: The Food Service Director with prepare the monthly sponsor claims for reimbursement. The Eastside Manager will review and sign off on the claims. The Food Service Director will submit the claims to the Indiana Department of Education after review by the Eastside Manager. Anticipated Completion Date: Ongoing - The Food Service Director and Eastside Manager will review and initial the monthly sponsor claims for reimbursement starting with the most recent month that requires submission.

Child Nutrition Cluster Suspension and Debarment Recommendation: We recommend that the District review its policies over suspension and debarment review to ensure they are maintaining compliance and controls over verifying or contracting with vendors that are allowable Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: The new business manager is aware of these federal funding requirements; additionally, he is aware of the need to continually (once per year during multi-year contract cycles) verify that contractors being paid with federal money in excess of the allowable thresholds are not on the list of debarred contractors in the S.A.M. portal. Name(s) of the contact person(s) responsible for corrective action: Edward Then, Business Manager Planned completion date for corrective action plan: 6/30/2023

Child Nutrition Cluster Reporting Recommendation: We recommend that the District review its internal controls and designate an individual other than the preparer to review and approve any grant claims. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: The business manager will sign off on claim submissions to very accuracy for monthly claims so there are two sets of eyes on the claims to maintain accuracy. Name(s) of the contact person(s) responsible for corrective action: Edward Then, Business Manager Planned completion date for corrective action plan: 6/30/2023

Corrective Action Plan Year Ended June 30, 2022 Zachary Albert Director of Finance 501 N Gulkana St Palmer, Alaska 99645 907-746-9260 ZACHARY.ALBERT@MATSUK12.US Finding 2022-001 Significant Deficiency in Internal Controls Over Compliance - Reporting Corrective Action: 1. The District will create and maintain written procedures for each school site that outline the monthly reporting expectations for the server/cashiers or leads to perform. Procedures will include expectations for data recording and reconciliations and will differentiate between CEP and Non-CEP sites. 2. The District will provide training to all server-cashiers upon hire and annually thereafter on the correct procedures for reporting and reconciling meal counts. 3. Strengthen procedures to ensure appropriate internal controls over reporting compliance, to include: a. Process for the verification of meals served at the school site. b. Procedures for the monthly monitoring of meals served prior to the submission of reimbursement to the State. c. Approval and/or verification of the reimbursement submission that will be required. d. The approval cycle that is required e. Records retention schedule Specific Actions: The District is committed to implementing improvements to our system of internal controls in order to provide reasonable assurance that the reporting of meals served accurately reflect the meal type and reimbursement rate. We anticipate procedures that will include the following: ? Monthly reconciliation of site reported meals served. o Assistant supervisors will review all site edit check reports. o A procedure for ensuring that these reports align with the daily production records will be established and completed monthly.Assistant supervisors will provide a written verification of their monthly meal edit check review to both the Supervisor and Associate Superintendent of HR . . o Supervisor will include Associate Superintendent of HR on any and all written communications with assistant supervisors related to changes to the meal counts. ? Verification of the submitted reimbursement o The Supervisor will submit the monthly reimbursement report to the State of Alaska through the online portal. o After submission the Supervisor will maintain a screen shot of the total submitted for reimbursement along with the verified edit check for the District for the appropriate month. o The Supervisor notify the Associate Superintendent of HR that reimbursement has been submitted. o Associate Superintendent of HR will verify that the meal count submission entered by Supervisor reconciles with the count verified by assistant supervisors, including any changes identified and communicated in writing by Supervisor. Verification of this review will be retained. Anticipated Completion Date: 12/1/2022 ~2ctive Action Plan has been reviewed and approved by: Luke Fulp Deputy Superintendent of Business and Operations

Minnesota Department of Education ISD #77 ? Mankato (the District) respectfully submits the following corrective action plan for the year ended June 30, 2022. Audit period: July 1, 2021 ? June 30, 2022 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FINANCIAL STATEMENT AUDIT There were no financial statement audit findings during fiscal year 2022. FINDINGS?FEDERAL AWARD PROGRAMS AUDITS Finding 2022 ? 001 ? Child Nutrition Cluster ? Procurement Federal Agency: U.S. Department of Agriculture and U.S. Department of Treasury Federal Program Title: Child Nutrition Cluster and Local Fiscal Recovery Funds Assistance Listing Number: 10.553, 10.555, 10.559 and 21.027 Pass-Through Agency: Minnesota Department of Education Pass-Through Number: 1-0077-000 Award Period: Year ended June 30, 2022 Type of Finding: ? Material Weakness in Internal Control over Compliance with Suspension and Debarment Recommendation: We recommend that the District reviews its related policies and procedures to ensure it is retaining Documentation showing that the District crosschecked the vendors with procurements over the threshold of $25,000 at the time of procurement, which could be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA), (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2CFR section 180.300). Views of responsible officials and planned corrective actions: Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Actions planned in response to finding: The District will implement the auditor recommendation to ensure it is retaining documentation showing that the District has controls over and is in compliance with procurement requirements. Responsible party: Darcy Stueber, Director of Food Services and Amanda Heilman, Director of Business Services. Planned completion date for corrective action plan: June 30, 2023. Plan to monitor completion of corrective action plan: The Board of Education and Superintendent will monitor the completion of this corrective action plan. FINDINGS?FEDERAL AWARD PROGRAMS AUDITS (CONTINUED) Finding 2022 ? 001 ? State and Local Fiscal Recovery Funds ? Procurement Federal Agency: U.S. Department of the Treasury Federal Program Title: State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Pass-Through Agency: Minnesota Department of Treasury Pass-Through Number: not available Award Period: Year ended June 30, 2022 Type of Finding: ? Material Weakness in Internal Control over Compliance Recommendation: It is recommended that the District creates some sort of standard procedure or form that indicates what method is being used to track all procured items over the micro-purchase threshold ($10,000) to help formally document of how open competition is being assessed and then retain documentation of any quotes, bids or direct negotiation procedures completed. Views of responsible officials and planned corrective actions: Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Actions planned in response to finding: The District will implement the auditor recommendation to ensure it is retaining documentation showing that the District has controls over and is in compliance with procurement requirements. Responsible party: Darcy Stueber, Director of Food Services and Amanda Heilman, Director of Business Services. Planned completion date for corrective action plan: June 30, 2023. Plan to monitor completion of corrective action plan: The Board of Education and Superintendent will monitor the completion of this corrective action plan. FINDINGS?MINNESOTA LEGAL COMPLIANCE FINDINGS Recommendation: We recommend that the District implement controls to ensure that all bills are paid timely and are in compliance with state statutes. Views of responsible officials and planned corrective actions: Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Actions planned in response to finding: The District will implement the auditor recommendation to ensure that bills are paid in accordance with timelines specified in state statutes. Responsible party: Amanda Heilman, Director of Business Services. Planned completion date for corrective action plan: June 30, 2023. Plan to monitor completion of corrective action plan: The Board of Education and Superintendent will monitor the completion of this corrective action plan. If the Minnesota Department of Education has questions regarding this plan, please call Amanda Heilman, Director of Business Services, at 507-387-3167.

Finding 2022-003: Significant Deficiency - Excess Fund Balance Recommendation: The District should implement a budget, as well as the required corrective action plan, for the 2022-2023 school year that will adequately reduce the food service fund balance. Action to be taken: Management agrees with the finding and we are in the process of developing a spend down plan. We are looking at expanding food choices, expanding healthy food options, as well as needed upgrades to equipment. District Contact Person: Bill Crane, Superintendent. Date of Completion: June 30, 2023.

Findings and Questioned Costs Related to Federal Awards Finding Number: 2022-001 Program Name/Assistance Listing Title: Child Nutrition Cluster Assistance Listing Numbers: 10.559 Contact Person: Venessa Beecroft, Business Manager Anticipated Completion Date: June 30, 2023 Planned Corrective Action: The District will implement a tracking tool to ensure that all new hires return their work agreements as they are hired on throughout the year.

Views of Responsible Officials and Planned Corrective Actions: The District will implement a new process for calculating and accumulating total meal counts using Excel. The new meal count process will include the Cafeteria Lead and Business Manager doing comparison checks to ensure monthly totals are accurately reported.

2022-005 Reporting Federal agency: U.S. Department of Agriculture Federal program title: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.556, and 10.559 Pass-Through Agency: Minnesota Department of Education Pass-Through Number(s): 1-2908-000 Award Period: July 1, 2021 ? June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance Recommendation: We recommend that the District implement a policy to support the review and approval of CLiCs reports. Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Action Taken in Response to Finding: The District will implement a policy to have a review and approval process in place over the CLiCs reports. Name of the Contact Person Responsible for Corrective Action Plan: Kate Fernholz, Business Manager Planned Completion Date for Corrective Action Plan: June 30, 2023

Peck Community School respectfully submits the following corrective action plan for the year ended June 30, 2022. Auditor: Anderson, Tuckey, Bernhardt & Doran, PC 715 E Frank St Caro, MI 48723 Audit Period: Year ended June 30, 2022 District responsible individual to implement this plan: Shelley Bullis, Business Manager The finding from the June 30, 2022 schedule of findings and questioned costs are discussed below. The finding is numbered consistently with the number assigned in the schedule. Finding ? Federal Award Finding and Questioned Cost Finding 2022-001 ? Considered a Significant Deficiency Recommendation: The District should implement a budget, as well as the required corrective action plan, for the 2022-2023 school year that will adequately reduce the food service fund balance. Action to be taken: Management agrees with the finding and we are in the process of developing a spend down plan. We are looking at expanding food choices, expanding healthy food options, as well as making needed upgrades to equipment.

Management?s Response/Corrective Action Plan: The York School Nutrition Department followed recommended USDA & State guidelines to perform meal counting during the COVID 19 period with tick sheets. The data was entered into a spreadsheet so Whitney, the Nutrition Director, could apply for the funding. There were some data entry errors going from the manual sheet to the spreadsheet at the building level. Going forward we are back to using our POS system which declares a name with each and every meal, therefore meal counts are left to the computer system and error-free. We have corrected and moved forward in making sure we are claiming the meals on our sheets. As Tick Sheets are no longer allowable our entries are now accurate and will be moving forward as well.

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 be before the end of the 2022-23 fiscal year. The person responsible for the corrective action is Tricia Connell, the food service director. The plan for monitoring adherence is the food service director will work to assess where the fund balance is after all of the projects from the spend down plan are completed.

Corrective Action Plan Yeshiva of Phoenix This corrective action plan is in response to the audit conducted by Price Kong. There were some items that were requested for the audit that we did not have receipts or backup. From now on: - We will not issue any reimbursement without a receipt to match. - We will require receipts for all purchases made with school funds. If we do not get receive a receipt we will send text messages and phone the purchaser/merchant until we do. If we still do not receive a receipt we will bill the purchaser for the item. - All receipts will be scanned and then matched to the purchase when we do the monthly reconciliation. - Any payroll change will be documented in writing, preferably signed by both parties. Alternatively, an email will be sent to both parties documenting the change. The email will be filed and stored. - Any new employee will receive a contract or an email confirming their salary. - In addition to storing our bank statements, we will also keep a digital record of any checks that we receive, and we will match these checks to our accounts. - We will keep formal minutes of all board meetings. These minutes will be distributed to all board members and stored. - We will request an updated depreciation schedule from our accountant every year. - We will meet with an accountant from Price Kong who will help us establish a formal accounting manual so that we will have set standards for all bookkeeping. Thank you for conducting the audit for us. Gaby Friedman, Vice President On behalf of Yeshiva of Phoenix.

CORRECTIVE ACTION PLAN Corrective Action Plan (CAP) Name of Auditee: Allentown School District Auditee Identi?cation Number: 23-6003488 Name of Audit Firm: Zelenkofske Axelrod LLC Period covered by Audit: July 1, 2021 ? June 30, 2022 CAP prepared by: Diane Richards, Chief Financial Of?cer Telephone number: 484-765-4011 A. Current Finding on the Schedule of Finding, Questioned Costs, and Recommendations: 1. Of the 25 expenditures selected for testing, 11 expenditures were not properly approved a. Action(s) Taken or Planned on the Finding The School District agrees with the ?nding and is working towards implementing better controls in the Child Nutrition Services Department. b. Name and Title of the person responsible for resolution: Gina Giarratana, Director of Student Nutrition c. Anticipated completion date: July 1, 2023 2. Of the 25 employees selected for testing, 1 employee did not have proper clearances. a. Action(s) Taken or Planned on the Finding The School District agrees with the ?nding and is working towards implementing better controls in the Human Resources Department. b. Name and Title of the person responsible for the resolution: William Seng, Executive Director of Human Resources c. Anticipated completion date: July 1, 2023

Finding #2022-001- Segregation of Duties (Prior Year Finding #2021-001) Condition: A properly designed system of internal control includes adequate staffing, policies, and procedures to properly segregate duties. This includes systems that are designed to limit access or control of any one individual to your government?s assets, and to achieve a higher likelihood that errors or irregularities in your processes would be discovered by your staff. There are key controls related to significant transaction cycles that are important in reducing the risk of errors or irregularities. At this time, the District does not have the following controls in place: -Persons processing accounts payable are not always separate from those ordering or receiving goods or services. -Persons initiating electronic fund transfers are not separate from those authorizing, confirming, or reconciling the transactions. -There are no procedures in place for review and approval of new vendors. -Persons preparing the payroll also maintain employee records, change employee rates, and change data in the payroll system. -The person reviewing free and reduced food service eligibility can also modify information entered into the system to determine eligibility. -Account reconciliations are not performed by someone independent of the processing of transactions in the account. Effect: Errors or intentional fraud could occur and not be detected timely by other employees in the normal course of their responsibilities as a result of the lack of segregation of duties. Cause: Limited number of personnel. Criteria: Segregation of duties is an aspect of internal control intended to prevent or decrease opportunities of intentional and unintentional errors and fraud. Duties and responsibilities are properly segregated if no single individual either has control over all phases of a transaction or has the ability to both make and conceal an error, whether such error is intentional or unintentional. Recommendation: We recommend that the District consider the benefits of implementing additional policies and procedures to address key controls related to its significant transaction cycles as noted. Response: We agree with this finding but do not believe it is cost effective to increase the office staff in an attempt to bring about a more effective segregation of duties. The Building Principals and the Business Manager approve purchase orders and the Business Manager approves monthly accounts payable checks. Also, the Building Principals or department supervisors approve payroll timesheets prior to processing payroll. The payroll along with the time sheets are then approved by the Business Manager. The Business Manager, Building Principals, and department supervisors will continue to monitor transactions of the District. Contact Person: Greg Benz Anticipated Completion: Not applicable

UNITED STATED DEPARTMENT OF EDUCATION Education Stabilization Fund? 84.425D/84.425W Corrective Action Plan ? Noncompliance with Reporting Requirements Finding No.: 2022-004 Condition: The District has inadequate controls over reviewing and approving quarterly ?historical expenditure reports? filed with the Illinois State Board of Education. Plan: The superintendent will review and approve quarterly ?historical expenditure reports? and supporting documentation on a regular basis prior to electronic submissions. Corresponding documents will be manually signed and dated to indicate approval. Anticipated Date of Completion: January 1, 2023 Management Response: The District intends to implement the recommendations in FY 2023. Name of Contact Person: Michelle Meese, District Superintendent (P): 618-592-3933

UNITED STATED DEPARTMENT OF AGRICULTURE Child Nutrition Cluster ? 10.553/10.555/10.559 Corrective Action Plan ? Noncompliance with Reporting Requirements Finding No.: 2022-003 Condition: The District has inadequate controls over reviewing and approving child nutrition monthly ?claims summary? forms. Plan: The administrative assistant will prepare the ?claims summary? forms by obtaining the number of meals served directly from the "Food Service: Reimbursement" reports on Skyward?s website. 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. Anticipated Date of Completion: January 1, 2023 Management Response: The District intends to implement the recommendations in FY 2023. Name of Contact Person: Michelle Meese, District Superintendent (P): 618-592-3933