OCTORARA AREA SCHOOL DISTRICTLocal Government

During the audit of the 2023-2024 school year, it was determined that the expenditures reported for the 2022-2023 fiscal year did not align with the expenses recorded and reported on the Schedule of Expenditures of Federal Awards (SEFA). Cause: The discrepancy appears to be a result of coding errors or weaknesses in internal controls over the financial reporting process. Corrective Action Plan: 1. Review and Reconciliation Process Improvement - Implement a standardized reconciliation process to ensure that all expenditures reported in federal grant filings match the SEFA and general ledger records. - The reconciliation process will be conducted monthly to ensure expenditures are accurately recorded and categorized. 2. Independent Review of Reports - Assign an independent reviewer, separate from the preparer, to verify the accuracy of all grant-related reports before submission. - This reviewer will cross-check expenditures with SEFA, general ledger records, and supporting documentation to ensure consistency and compliance. 3. Enhanced Internal Controls - Develop and document a formalized grant reporting procedure that includes clear steps for expenditure tracking, coding, and verification. - Require dual sign-off on all grant expenditure reports before submission to the Pennsylvania Department of Education. 4. Staff Training and Accountability - Provide targeted training to finance and grants management personnel on proper coding procedures and federal grant compliance requirements. - Conduct annual refresher training to reinforce best practices in financial reporting and compliance. 5. Regular Monitoring and Audits - Conduct quarterly internal audits of grant expenditures to proactively identify and correct any discrepancies before external audits. - Establish a compliance checklist to ensure all reporting aligns with federal and state requirements. 6. Follow-Up and Monitoring: - A follow-up review will be conducted after the next reporting cycle to assess the effectiveness of corrective actions and ensure compliance. By implementing these corrective measures, the District aims to strengthen internal controls, improve reporting accuracy, and ensure compliance with federal grant requirements.

Federal Program COVID-19 - Education Stabilization Fund ALN 84.425; passed through the Pennsylvania Department of Education Condition/Cause We tested a sample of 8 nonpayroll invoices charged to the Education Stabilization Fund. For 1 out of the 8 invoices tested, the invoice was miscoded to the grant and should have been charged to a different program. Controls at the District did not catch this miscoding prior to the audit. The Board of Directors approves all salaried positions that are funded by the Education Stabilization Fund. For one of the individuals charged to the program, the Board did not approve their position as a grant funded position. Instead, a different individual was approved but not charged to the grant. Controls at the District did not catch this miscoding prior to the audit; however, the individual charged to the grant was in a position that was allowable under the grant requirements. Recommendation We recommend the District review their internal controls over allowable activities and allowable costs charged to the Education Stabilization Fund to ensure they are designed and operating to detect coding errors that may result in noncompliance with grant requirements. Management Response Objective Address the identified issues related to the misallocation of costs and lapses in internal controls within the Education Stabilization Fund program. 1. Immediate Actions • Correct the miscoded invoice immediately, ensuring that the $2,613 erroneously charged to the Education Stabilization Fund is properly allocated to the correct program. • Conduct a thorough review of all nonpayroll invoices charged to the Education Stabilization Fund to identify and rectify any other miscoding errors. 2. Internal Controls Enhancement • Review and strengthen internal controls over allowable activities and costs within the Education Stabilization Fund program. • Implement a systematic process for verifying the appropriateness of each cost before it is charged to the grant, including a cross-check against grant agreements and Board approvals. 3. Board Approval Process • Establish a clear and documented process for obtaining Board approval for salaried positions funded by the Education Stabilization Fund. • Ensure that all individuals charged to the program have received explicit approval from the Board, and that the approval is well-documented. 4. Training and Awareness • Provide training to relevant staff involved in coding and approving expenses related to the Education Stabilization Fund. • Enhance awareness among employees about the importance of accurately coding expenses and obtaining proper approvals. 5. Review of All Salaried Positions • Conduct a comprehensive review of all salaried positions funded by the Education Stabilization Fund, ensuring that each position aligns with Board approvals and grant requirements. • Verify that individuals charged to the program have the necessary approvals and qualifications. 6. Documentation and Record-Keeping • Establish a centralized and well-maintained repository for all documentation related to Education Stabilization Fund expenditures. • Ensure that records of Board approvals, coding decisions, and supporting documentation for all expenses are readily accessible for audit purposes. 7. Periodic Internal Audits • Implement a schedule for periodic internal audits specifically focused on the Education Stabilization Fund program. • Conduct random checks and audits to verify the accuracy of coding and compliance with internal controls. 8. Reporting and Transparency • Develop a reporting mechanism to keep the Board of Directors and relevant stakeholders informed of expenditures under the Education Stabilization Fund. • Periodically report on the status of internal controls and any corrective actions taken. 9. Continuous Monitoring: • Establish a continuous monitoring process to detect and address any deviations from established internal controls promptly. • Implement real-time alerts or notifications for potential coding errors or deviations from approved positions. 10. External Review • Consider engaging external auditors to perform an independent review of the strengthened internal controls and corrective actions taken. • Seek recommendations for further improvements and best practices. By implementing these corrective actions, we aim to enhance internal controls, ensure compliance with grant requirements, and prevent the misallocation of funds within the Education Stabilization Fund program. Regular monitoring and a commitment to continuous improvement will be critical for sustained success.

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