Corrective Action Plans

The Haddon Heights School District will monitor the fiscal condition of the Food Service Enterprise Fund in the 2022-2023 school year to ensure that the net cash resources do not exceed three months average expenditures.

#2022-003 - Significant Deficiency in Controls over Compliance: Lack of Review over Reporting Recommendations: We understand that many, if not all locations participating in the meal programs have since either reverted back to using the electronic system for counting students, or plan to do so in the near term. We recommend that any remaining manual reports/tally sheets be reviewed prior to submitting counts for reimbursement. Views of Responsible Officials and Planned Corrective Actions: ? Because student meals are no longer free in the 2022-23 school year, GRCS is returning to the electronic system for counting student meals.

#2022-002: Material Weakness in Controls over Compliance: Administrative Requirements of Uniform Guidance -Administrative Policies Recommendations: Grand Rapids Christian Schools should consider the following written policy additions or updates: ? Financial Management (2 CFR 200.302) The financial management policy should include records documenting compliance, and the tracking of funds to determine that expenditures are in accordance with the terms and conditions of the federal awards. The financial management and reporting system must provide the following : ? Identification - Title of the award, CFDA number ? Complete disclosure of accurate and current financial results of each federal award ? Source and application of funds for federal award activity ? Record retention and access - define the time period for which records must be kept (can vary by grant agreement), and who has the ability access the records (?200.333 - ?200.337) ? Written procedure to implement cash management requirements (see below) ? Written procedures for determining the allowability of costs (see below) ? Cash Management (2 CFR 200.305) A written policy is required by Uniform Guidance detailing the Organization's procedures to minimize the time that elapses between draw and expenditure of federal dollars. ? Allowable Costs (2 CFR 200.302(b)(7)) The Organization must have written procedures for determining the allowability of costs in accordance with Subpart E - Cost Principles of Uniform Guidance and the terms and conditions of the Federal award. This includes the determination of allowable costs and the review of this determination. The standard assumes policies and procedures are in place for disbursements, and the allowable cost policy will demonstrate how the Organization ensures compliance. The criteria for costs to be considered allowable are documented within 2 CFR 200.403. ? Procurement Standards (2 CFR 200.317 - 200.326) The Organization must have a written policy that promotes full and open vendor competition, conflict of interest policies should cover employees as well as the organization, and general purchase requirements with specific thresholds as set forth by the Uniform Guidance. There are five allowable procurement methods as described in ?200.320, depending upon the dollar value of the purchase or contract. Views of Responsible Officials and Planned Corrective Actions: ? Grand Rapids Christian Schools follows procurement and record retention standards provided by the USDA. ? GRCS does not have actual written policies and procedures for Financial Management, Cash Management, Allowable Costs, and Procurement Standards, but do have practices in place to follow USDA guidelines. In the case of cash management, the only location that takes cash is GRCHS. In that instance, along with Meal Magic, cash registers are zeroed out and balanced to Meal Magic and cash deposits are made daily. ? GRCS Business Office will work with the Food Service Director to begin formulating written policies and procedures specific to Grand Rapids Christian Schools. GRCS will utilize the resources from Uniform Guidance and Code of Federal Regulations (CFR) to develop policies that are compliant with those requirements prior to June 30, 2023.

St. Louis Public Schools Correction Action Plan for audit finding number (2022-001) Responsible party: Charles Clevenger, Stacey Haag and Jennifer McKittrick Expected completion date: June 30, 2023 Excess fund balance of $48,421 in Food Service Fund To Whom it May Concern, The Superintendent and the Food service director will be working together to purchase the following items immediately to spend down the excess fund balance in our food service fund prior to June 30, 2023. We will be looking at areas of improvement in our food service program such as replacing sections of ceiling. We will also be looking to purchase some additional equipment during this time frame, including garbage disposals.

Since June 30, 2022, the District has purchased and replaced kitchen equipment, painted the cafeteria and kitchen area and charged cafeteria aides to reduce Net Cash by $87,195. This is in excess of the Net Cash Resources Finding of $83,790.

Child Nutrition Cluster Reporting Child Nutrition Cluster - Assistance Listing No. 10.553, 10.555 Recommendation: We recommend the District implement a review procedure over reimbursement requests where someone other than the preparer reviews the claim to ensure accounts agree back to supporting documentation prior to the reimbursement request being filed with the grating agency. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action Planned/Taken: Food service reports are now reviewed and initialed monthly. Food service director would initially run the report and it would be reconciled by the Business Manager. Final claims are reconciled before the report is submitted and initialed by the Superintendent. Name(s) of the contact person(s) responsible for corrective action: Nimisha Patel, Business Manager Planned completion date for corrective action plan: January 1, 2023

October 22, 2022 Finding Number: 2022-002 ? Reporting Condition: Meals claimed were not supported by count sheets for either breakfast or lunch for the two months meals were tested prior to MDE site visit. Responsible Person: Stephen Grubaugh ? Director of Business Services Implementation Date: 10-22-2022 During the single audit, it was discovered that Bullock Creek Food Service Department meals claimed were not supported by count sheets for either breakfast or lunch for the two months meals were tested prior to MDE site visit. To ensure that this did not continue, Bullock Creek Food Service and the Technology Department worked together to implement the use of Skyward to track the melas served to students. This transition occurred over a few months, as the implementation was rolled out to 5 individual buildings. When MDE came on campus and audited the months during the transition and found a few discrepancies whish were remedied in the software and the claims were adjusted. RPC then audited the month following the MDE reviews and found no discrepancies. Skyward was used for the rest of the year. For the 2022-2023 Scholl year, the Food Service Department may purchase Meal Magic, which is a food Service software that will streamline the recording and reporting processes even more and may reduce the chance of errors even further. Sincerely, Stephen Grubaugh Director of Business Services

October 22, 2022 Finding Number: 2022-001 ? Excess Fund Balance In Food Service Fund 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 $85,951. Responsible Person: Stephen Grubaugh ? Director of Business Services Implementation Date: 7/1/2022 During the single audit, it was discovered that Bullock Creek Food Service Department had an excess fund balance in the Food Service Fund by approximately $85,951. This was due to the meal reimbursement rate exceeding the food cost to prepare the meals. All meals served to students during the 2021-2022 school year were provided free of charge to the students, due to grants. In order to reduce the excess fund balance, the district created a spend down plan for the 2022-2023 Fiscal Year. The kitchen at Bullock Creek Elementary needs some structural repairs completed due to faulty roof drainage. The total cost of the project is approximately $73,000. Construction on the project was started in July of 2022 and finished in August. Meal Magic will be implemented during the 2022-2023 School year for tracking of the meal purchases of students and staff. This software will cost approximately $3,000 in the first year to implement and $6,000 in subsequent years. The reaming $10,000 in excess fund balance will be retained, in order to aid in the paydown of potential negative student food service account balances. Since students haven?t paid for breakfasts or lunches for the past 2 years, it is unknown how the many will families will have feel a financial burden paying for their children?s school meals. Sincerely, Stephen Grubaugh Director of Business Services

This is a plan of action that we, as a district, will be implementing in order to correct the Federal finding from our audit. ? 2022-001 - Arkansas DESE Child Nutrition Unit will be contacted for guidance before any transfer to or from Food Services to ensure Ark. Code is followed regarding the Child Nutrition Program. Deanna Clifton, District Treasurer, will contact DESE Child Nutrition Unit to obtain guidance in any action needed regarding the transfer made in Fiscal 2021/2022. Anticipated Completion Date March 15, 2023. I trust that I have covered the points discussed. If you have any questions or if further information is needed, please call me at 870-486-5411, ext. 104. Sincerely, Deanna Clifton District Treasurer/Business Manager

A plan is in place to renovate the middle school kitchen as soon as possible.

Contact Person - Thomas A. Jerome, Superintendent. Corrective Action Plan - The District will review policies and procedures for submitting meal counts for reimbursement. Completion Date - September 6, 2022.

Finding 2022-002 Document Retention (Significant Deficiency) Federal Program: Child Nutrition Cluster Finding: Per 7 CFR 200.334, ?Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.? Management Corrective Action: While the school?s annual total meals served for the 2021-22 audit year were more than the meals claimed for reimbursement, the school was unable to reconcile all of the individual months. The school has since implemented and automated system to record lunches served. This point-of-sale system will eliminate the ongoing monthly accounting required to support monthly claims assuring the numbers served reconciles with the numbers claimed. Chris Ashmore has already implemented this system and tested the subsequent year-to-date audit period to assure this corrective action has, in fact, eliminated the problem.

Finding 2022-001 Cash Management (Material Weakness) Federal Program: Child Nutrition Cluster Finding: Per 7 CFR 210.14(b) and 7 CFR 220.7(e)(1)(iv), the ?school food authority shall limit its net cash resources to an amount that does not exceed 3 months average expenditures for its nonprofit school food service or such other amount as may be approved by the State agency Management Corrective Action: Previous audit year expenses were classified as ?General? funds when they should have classified as ?Food Service?. This, in aggregate, has led to an excess fund balance. Management, specifically Rod Iberg and Linda Heidrich, will work with the state on how to transfer the large arrear fund balances between accounts. Management will also endeavor to assure that all ongoing expenses are allocated to the correct fund.

2022-002 Child Nutrition Cluster ? Assistance Listing No. 10.553/10.555/10.559Recommendation: Adhere to internal control procedures over the review of meal counts. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: Summer Feeding Program Claims will be reviewed and verified before entry with same form and procedure that is currently used for National School Lunch Program claims. Name(s) of the contact person(s) responsible for corrective action: Nancy Millspaugh Planned completion date for corrective action plan: June 30, 2023.

Condition: Monthly Claim for Reimbursement included second meal claims in excess of two percent of the number of first meals served to children for each meal type. Plan: Implement additional procedures to ensure the accuracy of meal counts prior to the submission of the monthly Claim for Reimbursement such as but not limited to training and conferences. Additionally, the District should contact the Illinois State Board of Education for further recommendation on this finding. Anticipated Date of Completion: 6/30/2023 Name of Contact Person: Thomas Akers, Superintendent Management's response: There is no disagreement with this finding and procedures will be implemented. The District will contact the Illinois State Board of Education for further recommendation.

2022-004 UNTIMELY FILING OF THE DATA COLLECTION FORM ? OTHER NONCOMPLIANCE Condition: The Kindred Public School District did not submit its Data Collection Form to the Federal Audit Clearinghouse within nine months of its year-end. Corrective Action Plan: Agree?We had many things going on this year with Superintendent hiring and construction. Anticipated Completion Date: Was done as soon as audit was complete.

See corrective action plan.

October 26, 2022 Section III - Federal Award Finding 2022-001: Excess Fund Balance Marysville Public Schools? Proposed Corrective Action: The District is in the process of preparing a spend-down plan to submit to the Michigan Department of Education (MDE). Upon approval by MDE, the District will spend School Lunch excess cash reserves to reduce fund balance to comply with 7 CFR 210.19. Sincerely, Jennifer McKay Director of Business & Finance

Finding 2022-002 Compliance of Special Tests and Provisions ? Non-Profit School Food Service Accounts View of responsible official: The School agrees to solely use the food service bank account for all revenues and expenses related to the food service program. The School will begin the process of transitioning bank information to respective vendors and governmental agencies to ensure the monies received for the food service program are deposited into the account and expenses for the food service program are paid directly out of this account. Contact person: Troy Jones, Finance Director Expected implementation date: February 2023

Finding 2022-003 Internal Control over Compliance Requirements View of responsible official: The School concurs with the auditors? recommendation. The School will ensure all data used in the claims and review process is maintained for a minimum of three years. Contact person: Troy Jones, Finance Director Expected implementation date: February 2023

Finding 2022-001 Internal Control Over Compliance of Special Tests and Provisions ? Non-Profit School Food Service Accounts View of responsible official: The School agrees to solely use the food service bank account for all revenues and expenses related to the food service program. The School will begin the process of transitioning bank information to respective vendors and governmental agencies to ensure the monies received for the food service program are deposited into the account and expenses for the food service program are paid directly out of this account. Contact person: Troy Jones, Finance Director Expected implementation date: February 2023

As a result of COVID-19 and the unanticipated school closure the Food Service Fund had an increase in funding that was unexpected. As a correction action the Superintendent, Business Manager and Food Service Director will meet on a quarterly basis to review the Food Service budget and monitor the spend down plan.

Purchase needed equipment

Certain matters were brought to our attention as a result of the audit process. These are described more fully in the Schedule of Findings and Questioned Costs. We evaluated the matters noted below, and have described our planned actions as a result. 2022-001 - Program Income - Food Service Fund Balance Management Assessment - We concur with the audit assessment regarding this matter. Planned Corrective Action - The District is aware of the USDA fund balance requirements. The District operated under the Seamless Summer Option during fiscal year 2021-22 which allowed all of our students to eat both breakfast and lunch for free. The District received a large amount of federal funding which in turn resulted in more fund balance than allowed by USDA at 6/30/2022 ($5,466). The Food Service Director and Business Manager are in the process of creating a spenddown plan to be submitted to MDE which will move fund balance within an allowable range. Responsible Party - Business Manager Date of Planned Corrective Action - June 2023

Finding ref number: 2022-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with requirements for time-and-effort documentation. Name, address, and telephone of District contact person: Benjamin Rarick, Associate Superintendent of Finance 12033 SE 256th Kent, WA 98031 Corrective action the auditee plans to take in response to the finding: The Grants Administrator, under the supervision of the Director of Budget, will do interim and year-end reviews to identify any instances of positions funded by multiple federal funding sources for the purpose of assessing applicability of multi-cost objective T&E requirements and following through as appropriate. The Grants Administrator, under the supervision of the Director of Budget, and in collaboration with the program administrator, will initiate time & effort documentation in every case where there is debatable fact pattern, with the intent of adopting an “abundance of caution” approach to T&E, and will additionally seek written clarification from OSPI and/or the ESD in instances where T&E requirements are not dispositive from the relevant federal compliance supplements and guidance documents. Anticipated date to complete the corrective action: October, 2024