Corrective Action Plans

10.558 Child and Adult Care Food Program Allowable Cost 2022-027 Strengthen Controls to Ensure Compliance with Allowable Costs Requirements of the Child and Adult Care Food Program (CACFP). Response: The MDE does not concur with this finding. The OSA did not identify weaknesses in the MDE subrecipient monitoring process, such as in the selection of organizations, the monitoring cycle, or monitoring procedures. Instead, OSA identified potential errors made by individual participating organizations. The MDE has a robust system of internal controls and subrecipient monitoring system for the CACFP. In addition to meeting USDA requirements for monitoring, the MDE Office of Child Nutrition (OCN) also employs a risk -based process to select CACFP subrecipients for review and to determine the scope of monitoring. The MDE routinely exceeds the USDA requirement to monitor 33.3% of participating organizations annually. For Program Year (PY) 2021-2022, 60.3% of participating organizations were reviewed to provide additional oversight of subrecipients. When the MDE identifies instances of noncompliance, it requires participating organizations to take appropriate corrective action. For organizations that are very high-risk, the MDE employs the USDA Serious Deficiency process in accordance with 7 C.F.R. 226.6. The MDE already has a process to recover funds from an organization if an error is discovered during subrecipient monitoring. In PY 2022, the MDE assessed $132,207 in repayments of USDA funds and required an additional $40,577 in unallowable costs to be returned to local CACFP accounts. Finally, MDE staff was not included in the reviews of subrecipients by OSA, so the MDE was unable to verify the accuracy of the proposed unallowable costs before publication of the report from OSA. MDE staff will need to review documentation from OSA, and source documentation retained at CACFP sites before it can make a final determination regarding the potential unallowable cost determinations against sponsors. Corrective Action Plan: A. The MDE will review documentation provided by OSA of potential questioned costs and review source documentation held by the subrecipients to determine the amount of unallowable costs. If confirmed, the MDE will recover any unallowable costs in accordance with USDA policies. This review will be completed by January 22, 2024. Susie Evans, CACFP Director for the MDE OCN, will oversee the review. B. The MDE will continue to assess its CACFP monitoring and continue to strengthen the process while remaining in compliance with USDA regulations.

October 29, 2022 Schedule of Findings and Questioned Costs Corrective Action Plan For: 2022-001 ? Excess Fund Balance in Food Service Condition: As of year-end the District had a fund balance in the non-profit food service fund in excess of three months? operating expenses by approximately $213,867.22. Corrective Action to Be Taken: The District is updating their Spenddown Plan for the excess fund balance. The Food Service Director and the Assistant Superintendent have already identified areas where there are needs for upgrades or enhancements needed. Over the next few months the Excess Fund Balance will get used to improve the Food Service Program. Responsible Parties for Implementation of Corrective Action: Food Service Director with follow up by the Assistant Superintendent. Date of Anticipated Completion of Corrective Action: The corrective action plan was immediately implemented during the fall of 2022. Sarah M. Glann Assistant Superintendent

2022-002 The District has insufficient procedures in place to ensure all long term liability and related expense transactions were properly recorded. Material adjustments were needed for the District's financial statements. See response and corrective action plan at 2022-002.

2022-001 The District has insufficient segregation of duties over the receipts and disbursements process. See response and corrective action plan at 2022-001.

FINDING 2022-002 Contact Person Responsible for Corrective Action: Food Service Director Billie Jo Russell Contact Phone Number: 812-755-4872 Views of Responsible Official: We concur with the finding Description of Corrective Action Plan: Procurement ? The School Corporation has established internal controls to ensure compliance with the grant agreement and the Procurement and Suspension and Debarment requirement. The Food Service Director will obtain information from the Wilson Service Center for any necessary documentation pertaining to this requirement. The School Corporation has procured any food and supply purchases that exceed $150,000 and will maintain documentation for procurement procedures for purchases under $150,000. Suspension/Debarment ? Procedures will be implemented to ensure our procurement agent is an approved procurement agent. Anticipated Completion Date: Immediately

Views of responsible officials and Corrective Action Plan: The School will implement an additional internal control to review the reimbursement meal claim to underlying support prior to submission, with evidence of review.

Corrective Action: We will be creating universal tick sheets for the elementary and secondary schools. The internal control will be more manageable when we make this change. The tick sheets will be on separate sheets for breakfast and lunch and there will be a signature line on each sheet in order to identify the employee that ticked during the meal. All Student Nutrition employees will be instructed to use the standardized tick sheet and will be advised not to make any change to the form. Due Date of Completion: December 31, 2022 Responsible Party: Director of Student Nutrition

We will contact DESE for guidance regarding this matter and implement proper controls over program expenditures. Misti Flowers, District Treasurer June 1, 2023 Action Started June 30, 2023 Action completed

School District No. 27-0595, North Bend, Nebraska, respectfully submits the following corrective action plan for the year ended August 31, 2022. Name and address of independent public accounting firm: Romans, Wiemer & Associates, Certified Public Accountants, P.C., 1910 N Lincoln Ave, York, NE 68467 Audit Period: September 1, 2021 through August 31, 2022 The findings from the November 3, 2022 schedule of findings and questioned cost are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS ? FINANCIAL STATEMENT AUDIT MATERIAL WEAKNESS 2022-001 Internal Control Structure Design Recommendation: While considering the cost of any benefits derived, activities should be segregated and handled by different employees. Action Taken: The cost of implementing a complete set of controls far outweighs the benefits derived by such. It is not financially feasible to have a complete set of controls. FINDINGS ? FEDERAL AWARD PROGRAM AUDIT Nebraska Department of Education 2022-002 Internal Control Structure Design Recommendation: While considering the cost of any benefits derived, activities should be segregated and handled by different employees. Action Taken: The cost of implementing a complete set of controls far outweighs the benefits derived by such. It is not financially feasible to have a complete set of controls.

Corrective Action Plan and Views of Responsible Officials The District will continue to implement the following procedures, which were initially put in place in December of 2021, after the meal counting error was identified in October of 2021: 1. Site Numbers will be collected via a clicker counter or tally sheet. This information will be documented on paper and sent to the Claim Preparer to verify and ensure accuracy. 2. The data from the counters and Tally sheet will be entered into the back-office Point of Sale software system instead of a spreadsheet. 3. Monthly reports will be generated when creating the claim and an Edit Check will include auditing daily participation numbers to ensure days have not been skipped. 4. The claim will be entered in CNIPS following standard ?Meal Counting & Collecting Procedures? as approved by the State. Implementation Date: Fiscal Year 2021-2022

U.S. Department of Agriculture: Octorara Area School District respectfully submits the following corrective action plan for the year ended June 30, 2022: Name and address of independent public accounting firm: Herbein + Company, Inc. 2763 Century Boulevard Reading, PA 19610 Audit Period: Year ended June 30, 2022 Anticipated Completion Date: December 31, 2022 Contact Person: Jeff Curtis, Business Manager Finding - Federal Award Findings and Questioned Costs 2022-001 ALLOWABLE ACTIVITIES - SIGNIFICANT DEFICIENCY Federal Program Child Nutrition Cluster COVID-19 - National School Lunch Program ALN 10.555; passed through the Pennsylvania Departments of Education and Agriculture; Grant Period 7/1/21-6/30/22 COVID-19 - School Breakfast Program ALN 10.553; passed through the Pennsylvania Department of Education; Grant Period 7/1/21-6/30/22 Criteria Title 7 CFR 210 covers the reimbursement process under the Child Nutrition Cluster. It requires the submission of claims for reimbursement that include the number of reimbursable meals served by category and type during the period (generally a month) covered by the claim. As a subrecipient of funds passed through the Pennsylvania Department of Education (PDE), Octorara Area School District must submit monthly claim forms to PDE, which include the number of reimbursable meals served by category (free, reduced, paid) and type (breakfast, lunch). Condition/Cause The District manually inputs the amount of meals served by location into a spreadsheet in order to obtain totals to type into the monthly claim reimbursement form. A data input error, failing to include a location in the spreadsheet for certain days, led to an incorrect number of meals reported on one claim report from our sample. Controls in place over claim reporting did not detect and correct this error before submission. Effect As a result of the claim report not being filed accurately, the District lost approximately $730 of federal subsidies that would have been received if the correct meal count was used. Questioned Costs Less than $25,000 Context We examined 4 of the monthly reimbursement claim reports submitted during the year by the District and noticed the deviations noted above in one of those reports. Total subsidy revenue for the District for the year ended June 30, 2022 was $981,173. Had the District filed an accurate claim report for the month noted above, subsidy revenue would have been $981,903. The lost revenue is 0.074% of total federal subsidy revenue for the year. No statistical sampling was used in our testing. Repeat Finding No. Recommendation We recommend that the District revisit the current procedure for verifying accuracy of meal counts prior to claim submission for areas where the control could be strengthened. The review should include comparison of the report to meal count reports for all locations to verify accuracy. The review should also include a comparison to prior monthly reports for reasonableness. We recommend that the reviewer initial the report draft or otherwise maintain support of this review. Management Response The Food Service management team will enhance their current procedure to include the recommendations listed in this corrective action plan. Meal count hard copy reports by location will be submitted to the Food Service Supervisor each month to be tallied and compared to the meal count summary reports in the PrimeroEdge management system. The Supervisor will also confirm that hard copy reports are received for each group of students at each location and will initial the reports after the review. After confirmation from the Supervisor, that all locations are accounted for and the totals are correct, The Food Service Director will review the reports to ensure that the total meal counts are reasonable by comparing the reports to prior monthly reports adjusted for differences in the number of days in each month. Jeff Curtis, Business Manager

Nutrition services is aware of the excess funds and will be filing a spend down plan with Michigan Department of Education as soon as officially notified. The Director in conjunction with Maintenance and Finance has identified necessary improvements to equipment and has formulated a plan to substantially spend the excess funds within the next fiscal year pending approval from the State.

Finding Summary: During the course of our engagement, we noted instances where documentation was not retained supporting payroll expenditures and invoices were paid in an incorrect amount that was charged to the federal Child Nutrition Cluster program. Responsible Individuals: Shane Monson, Superintendent. Corrective Action Plan: The District will review and strengthen the controls surrounding the review and approval of allowable costs to ensure they are supported, approved of, and calculations are accurate. Anticipated Completion Date: June 30, 2023

Finding Number: 2022-013 ? Activities Allowed or Unallowed and Allowable Costs/Cost Principles Corrective Action Plan: A process has been put in place for the school principal to review all RFRs prior to submission to the grantor. Approval is evidenced by email sent by principal to the Director of Grant Management, which is saved with the RFR as support. Responsible Individuals: Nachum Golodner, Director of Accounting Anticipated Completion Date: June 30, 2023

Finding Number: 2022-016 ? SEFA Preparation Corrective Action Plan: In 2022, the office had downsized due to turnover in staff. While a process was in place for reconciling, a secondary review was not performed to verify accuracy of the residual value calculations. To strengthen the oversight of financial management in the School, Academica Nevada, the School?s management company, has filled all the open positions and realigned staff responsibilities to reduce individual workloads and provide additional oversight and review. The grant manager will reconcile all grants to ensure proper cutoff, with a secondary review performed by a member of management. Responsible Individuals: Nachum Golodner, Director of Accounting Anticipated Completion Date: June 30, 2023

Finding Number: 2022-014 ? Procurement, Suspension, and Debarment Corrective Action Plan: Academica Nevada, the School?s management company, and the School will complete an update of the procurement policies to ensure that federal law and standards are clearly detailed and defined. Responsible Individuals: Nachum Golodner, Director of Accounting Anticipated Completion Date: June 30, 2023

District Response and Corrective Action Plan: The Business Office has implemented new procedures requiring requisitions prior to every purchase. All purchases for the 2022-2023 school will have approval. Timecards are approved in Skyward via the Organizational Chart by each employee?s supervisor.

District Response and Corrective Action Plan: The district will perform the sampling prior to November 15th to meet the reporting deadline.

District Response and Corrective Action Plan: The Business Office will monitor the list at SAM.gov monthly and will check new vendors against the suspendered and debarment list. The District will not work with debarred vendors.

2022-01 This finding is caused by the District not having the proper controls in place to prevent, detect, or correct an incorrect monthly meal claim. Due to COVID, the District could not use their typical internal controls as it related to meal counts. In the elementary and middle schools, the cooks had to hand count meals served rather than using meal counting software, which is what was used in prior years. These hand counts were hard to follow which caused issues when doing monthly reconciliations prior to making meal claim reimbursements. The District will also be returning to using meal counting software for all schools and eliminating hand count sheets all together. The persons responsible for the corrective action are Cathy Clarke Karwowicz, the Food Service Director and Rod Fullerton, the Chief Financial Officer. The anticipated completion date of the corrective action plan is before the end of the 2023 fiscal year. The plan for monitoring adherence is the Food Service Director and Chief Financial Officer will work together to ensure that monthly meals served are being reconciled prior to any meal reimbursements being claimed.

Corrective Action: When the District expands the food service program under any circumstances, the District will adapt internal controls to monitor costs for their allowability and level of effort in the food service program as being incurred. Method of Implementation: Formal communication between food service director and school business administrator during any circumstances when the District expands the food service program. Person(s) Responsible for Implementation: Sue Prusko, Food Service Director; Anthony Dragona, School Business Administrator Completion Date of Implementation: June 30, 2023

The income verification process has been reviewed the Director of Food Service. She understands that the verification must be an official document of earnings (i.e. paystub).

Finding: The Office of Superintendent of Public Instruction did not have adequate internal controls over accountability for USDA-donated foods. Questioned Costs: Assistance Listing # 10.553 10.555 10.555 COVID-19 10.556 10.559 10.582 Amount $0 Status: Corrective action in progress Corrective Action: The Office has taken the following corrective action to strengthen internal controls over accounting for USDA-donated foods: ? Reviewed current process for monthly inventory. ? Reviewed process for inventory discrepancies follow up. ? Implemented a process for documenting follow-up efforts. The Office is following the USDA requirements for conducting annual inventory and reconciliation in June of each year. In addition, the Office has contracted with a vendor for a new and updated Food Distribution Management System. The current timeline for system launch is as follows: ? November 2023 ? Data migration and system set up ? February 2024 ? Survey period ? August 2024 ? Ordering of food, receiving, and inventory management The conditions noted in this finding were previously reported in findings 2021-003, 2020-004 and 2019-005. Completion Date: Estimated July 2023 Agency Contact: Leanne Eko Chief Nutrition Officer PO Box 47200 Olympia, WA 98504-7200 (360) 725-0410 leanne.eko@k12.wa.us

October 21, 2022 CORRECTIVE ACTION PLAN FINDING 2022-002 EXCESS FUND BALANCE IN FOOD SERVICE FUND (repeat comment) ? Material weakness in internal control/material noncompliance ? special tests and provisions. Over the 2022-2023 school year, the District will utilize the excess fund balance to improve the quality of the food service program. Despite following the spend down plan submitted to the Department of Education last year, the District still has a food service balance that exceeds the allowable balance by $129,204. The food service department will use the excess balance to continue to offer more new food choices, and continue to improve the quality of the food served (including more fresh produce and better quality ingredients). These improvements will continue to be in conjunction with the Michigan Department of Education's Office of School Support Services which will again approve the spending plan. We will begin to implement this immediately

CORRECTIVE ACTION PLAN OF CURRENT AUDIT FINDINGS June 30, 2022 FINDING 2022-001 Subject: Child Nutrition Cluster ? Procurement and Suspension and Debarment Audit Findings: 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 two 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: When a purchase is made at $10,000 or more using Federal Funds, the superintendent will require that any vendors selected are in compliance with the Procurement and Suspension and Debarment compliance requirement by completing one of the following quality checks with each vendor prior to purchase: a. Checking the federal System for Award Management (SAM) database at https://sam.gov/content/exclusions and maintain a screenshot of the search results. b. Collect a certification from the vendor directly c. Add a clause or condition to the covered transaction with the vendor Responsible Party and Timeline for Completion: The Superintendent and will be implemented and completed immediately with any purchase made that meets the above threshold.