Corrective Action Plans

Inadequate Physical Inventory Procedures - Nutrition - OPI - The Montana Office of Public Instruction partially concurs with this finding. The 1,000 cases of beef arrived on June 12 for the next fiscal year, while the physical inventory count occurred on June 3. The order had been entered into MAPS before the count, but the product had not yet arrived at the warehouse. When MAPS reporting was run after June 12, during verification, the beef appeared in the system even though it was not present during the physical count. The product was distributed during the following school year. This discrepancy was due solely to timing between delivery, system entry, and the inventory count. Because of staff turnover, the employee entering inventory into MAPS was not aware that items should only be entered once they are physically received. The invoice was entered before delivery, while inventory was being performed, creating a short‑term difference between the MAPS count and the actual inventory. This was a training issue, and staff have now been instructed on correct inventory procedures. Responsible Party - April Grady, Chief Financial Officer, Montana Office of Public Instruction Target Implementation Date - 12/31/2026

Managementconcurswiththefindingandwillimplementadailypoint-of-servicemealcountlogforeachmealservice,reconciledtoclaimsbeforesubmissionfor reimbursement. A designated staff member will maintain and retain these records for at least three years.

SIGNIFICANT DEFICIENCIES IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF AGRICULTURE, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, CHILD NUTRITION CLUSTER – FEDERAL ALN 10.555, 10.559, AND 10.553 2025-006 Internal Control Over Compliance With Allowable Activities Requirements Finding Summary Criteria – 7 CFR § 210.8 requires the District to establish and maintain effective internal control over compliance with requirements applicable to federal program allowable activities, including meal count requirements applicable to child nutrition cluster federal programs. Condition – The District did not have sufficient controls in place within its child nutrition cluster to assure that it was accurately reporting meals counts for federal reimbursement, specifically pre-K students at non-public schools and summer meals served at apartment building sites. Corrective Action Plan Actions Planned – The District will review its policies and procedures relating to meal counts for its federal programs and will ensure that accurate meal counts are documented and submitted for federal reimbursement. Official Responsible – Brian Schultz, the District’s Finance Director. Planned Completion Date – December 31, 2026. Disagreement With or Explanation of Finding – The District agrees with this finding. Plan to Monitor – Brian Schultz, the District’s Finance Director, will review and update the District’s policies and procedures relating to eligible meal tracking and reimbursement submission for its child nutrition cluster federal program to ensure compliance with the Uniform Guidance in the future.

SIGNIFICANT DEFICIENCIES IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF AGRICULTURE, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, CHILD NUTRITION CLUSTER – FEDERAL ALN 10.555, 10.559, AND 10.553 2025-005 Internal Control Over Compliance With Federal Suspension and Debarment Requirements Finding Summary Criteria – 2 CFR § 180 requires the District to establish and maintain effective internal control over compliance with requirements applicable to federal program expenditures, including suspension and debarment requirements applicable to the child nutrition cluster. Condition – The District did not have sufficient controls in place within its child nutrition cluster to assure that it was not contracting for goods or services with parties that are suspended or debarred, or whose principals are suspended or debarred from participating in contracts involving the expenditures of federal program funds. Corrective Action Plan Actions Planned – The District will review its policies and procedures relating to suspension and debarment for its federal programs and will ensure that all parties with which it contracts for goods or services are eligible to participate in contracts involving the expenditures of federal program funding. Official Responsible – Brian Schultz, the District’s Finance Director. Planned Completion Date – December 31, 2026. Disagreement With or Explanation of Finding – The District agrees with this finding. Plan to Monitor – Brian Schultz, the District’s Finance Director, will ensure appropriate controls are in place to verify that any vendor with which the District contracts for federal program goods or services exceeding $25,000 is not listed as suspended or debarred on the federal Excluded Parties List System website.

The Organization should develop a compliance calendar that includes financial reporting deadlines and set automatic reminders in advance of each deadline to aid in properly planning and timing submission of reporting packages. Additionally, the Organization should engage the audit firm well before the fiscal year end, and the auditors should put this engagement on their calendar well in advance of the due date. The Organization should establish a timeline with the auditors that aligns with internal deadlines to ensure sufficient time to conduct the audit. The Organization’s Board of Directors should be more actively engaged in the auditing and reporting process to establish a greater degree of accountability and oversight. Anticipated Completion Date: 03/31/2027. Actions Taken: The Organization has begun implementing the above-mentioned recommendations. The Organization will ensure that it has a working compliance calendar to assist in meeting the reporting deadline. Additionally, the Organization has engaged the audit firm for their upcoming fiscal year-end, and the audit firm has put it on its calendar to begin the audit process well in advance. The Organization’s board of directors has agreed to oversee the auditing and reporting processes to a greater extent. With these actions, the Organization expects to comply with the Uniform Guidance for single audits deadline for the fiscal year end 06/30/2026. Mr. Moshe Weiss, Food Program director, has been designated to monitor the plan of corrective action for this finding. He can be reached at 845-425-0909. Contact Person Responsible for Corrective Action: Moshe Weiss, Food Program Director

The Organization should develop a compliance calendar that includes financial reporting deadlines and set automatic reminders in advance of each deadline to aid in properly planning and timing submission of reporting packages. Additionally, the Organization should engage the audit firm well before the fiscal year end, and the auditors should put this engagement on their calendar well in advance of the due date. The Organization should establish a timeline with the auditors that aligns with internal deadlines to ensure sufficient time to conduct the audit. The Organization’s Board of Directors should be more actively engaged in the auditing and reporting process to establish a greater degree of accountability and oversight. Anticipated Completion Date: 05/31/2027. Actions Taken: The Organization has begun implementing the above-mentioned recommendations. The Organization will ensure that it has a working compliance calendar to assist in meeting the reporting deadline. Additionally, the Organization has engaged the audit firm for their upcoming fiscal year-end, and the audit firm has put it on its calendar to begin the audit process well in advance. The Organization’s board of directors has agreed to oversee the auditing and reporting processes to a greater extent. With these actions, the Organization expects to comply with the Uniform Guidance for single audits deadline for the fiscal year end 08/31/2026. Nisson Portnoy, Food Program director, has been designated to monitor the plan of corrective action for this finding. He can be reached at 845-368-2247. Contact Person Responsible for Corrective Action: Nisson Portnoy, Food Program Director

Condition: A competitive procurement process was not performed for one vendor selected for testing. Corrective Action Planned: The District has reviewed procurement procedures related to the Child Nutrition Program and has taken corrective action to ensure compliance with federal procurement requirements under 2 CFR 200.318-200.326. All food service vendors are now procured through appropriate procurement procedures, including solicitation and documentation of vendor selection as required by federal regulations. The District will maintain procurement records including solicitations, bids or quotes received, vendor selection documentation, contracts, invoices, and payment records. The Business Office will work with the Food Service Department to ensure that all future procurements under federal programs follow required federal, state and local procurement standards. Staff responsible for procurement will be reminded of documentation and competitive bidding requirements. Procurement documentation will be periodically reviewed by the Business Office to ensure ongoing compliance. Anticipated Completion Date: Implemented March 1, 2026 Contact: Nancy J. Konisky, Business Manager

Responsible Official: Marcos A. Rivera Sánchez, Executive Director Management acknowledges the condition identified in the audit: the perpetual inventory system calculates inventory costs using the weighted average method, while the entity's established methodology for valuing USDA Foods is FIFO. Because the system does not support FIFO, inventory costs must be recalculated manually at year end, resulting in significant adjustments and indicating that perpetual inventory records maintained during the year do not reconcile to USDA-assigned costs. To address this issue, management will implement the following corrective actions consistent with the audit recommendation: - Evaluate and configure the inventory system to apply the FIFO costing method or adopt a system capable of reflecting USDA-assigned costs. - Develop and implement formal written procedures requiring periodic reconciliation between the perpetual inventory, accounting records, and USDA costs assignments. - Document and investigate any differences identified during reconciliations to ensure accurate, complete, and compliant inventory records in accordance with 7 CFR 250.19. These actions are intended to eliminate the need for significant manual adjustments at year end, strenghten inventory valuation controls, and ensure compliance with USDA requirements. Anticipated Completion Date: December 31, 2026.

Finding 2025-003 Recommendation: We recommend original records relating to the requirements for receipted foods be retained for the required period. Corrective Action: Documentation was previously being filed in hard copy. Efforts have been made to now have all documents scanned into the Operations Receipts Teams fo lder at receipt and are confirmed in Teams by designated members of the Operations management team. Person Responsible for Corrective Action: Norman Stafford, VP of Operations Anticipated Completion Date for Corrective Action: 8/14/26

Finding 2025-002 Recommendation: We recommend controls be strengthened to ensure all donations are supported with verification of count, weight, product identification, and other inspection of the product as evidenced through signature of the person(s) receiving inventory items. This could be made through a checklist attached to the bill of lading and used with entering the items into the inventory system that includes verification was properly made and items properly set up in inventory. Corrective Action: A majority ofTEFAP orders arrive with a BOL that will have the USDA secondary 5000 PO number as well as a 4000 Customer sales number and many times a 2000 Solicitation number. These are requirements t he USDA has with the vendors supplying the items. We report both the 5000 and 4000 numbers to GA OHS/SC Dept of Ag upon receipt of the goods. If either or both numbers are missing from the BOL, we note that in t he receipt report sent to these agencies. These numbers, although unique to USDA product, are not the only designation we use for TEFAP loads. We can access the TEFAP Requisition Status Report that indicates items that we have ordered and the status such as approved and delivery period. By contract the vendors/delivery brokers are required to give us a 48-hour notice prior to delivery. Moving forward, we will attach the TEFAP report sent to the respective state agencies in the event that either the 4000 or 5000 number is not on the BOL to the required retention paperwork for audit purposes. Person Responsible for Corrective Action: Norman Stafford, VP of Operations Anticipated Completion Date for Corrective Action: 8/14/26

Recommendation We recommend the District strengthen internal controls over the Child Nutrition Program reporting process by ensuring that all required documentation, including federal edit checks, Site Claim Reports by school, and evidence of supervisory review and approval of Meal Count Listings, is prepared, reviewed, approved, and retained prior to submission of reimbursement claims. Management should also implement periodic monitoring procedures to ensure consistent compliance across all school sites. Management Response Corrective Action Beginning with the 2025–2026 school year, we have implemented a requirement that all kitchen managers complete a daily meal count form provided by the New Mexico Public Education Department (NMPED) in collaboration with the Student Success and Wellness Bureau (SSWB). This documentation ensures accountability and verifies that reimbursable meals are being served for both breakfast and lunch. Additionally, we are currently exploring the implementation of a software program to further strengthen meal count accountability. The Food Service Supervisor will be working closely with the District finance department to identify funding opportunities for the 2026–2027 school year. Due Date of Completion: June 30, 2026 Responsible Party(ies): Director of Federal Programs

The Organization should implement an effective monitoring system to keep track of the compliance calendar, which includes financial reporting deadlines, and automatic reminders in advance of each deadline to aid in properly planning and timing submission of reporting packages. Additionally, the Organization should engage the audit firm well before the fiscal year end. The Organization should establish a timeline with the auditors that aligns with internal deadlines to ensure sufficient time to conduct the audit. Additionally, the Organization should implement a system that will file documents in an organized manner and make them easily accessible to the Organization and auditors. Furthermore, the Organization’s Board of Directors should be more actively engaged in the auditing and reporting process to establish a greater degree of accountability and oversight.

Views of Responsible Officials: The District will implement formal internal control procedures requiring review and documented approval of all SNP Claim for Reimbursement Summary reports prior to submission in PEARS. The following procedures will be implemented: 1. The Director of Food Services will prepare the monthly SNP Claim for Reimbursement Summary report and compile all supporting meal count documentation. 2. Prior to submission, the Administrative Assistant to the Director of Food Services or another designated individual independent of the preparation process will: a. Review the claim for mathematical accuracy; b. Verify meal counts against supporting documentation; c. Confirm claims are submitted within required timelines; and 3. Evidence of the review and approval will be documented through: a. Signature or electronic approval on the reimbursement summary report; and b. Retention of supporting documentation in accordance with federal and state record retention requirements. 4. A written standard operating procedure (SOP) outlining these review and approval responsibilities will be developed and communicated to applicable personnel. The Business Manager will periodically monitor compliance with the procedure to ensure controls remain effective.

Significant Deficiency in Internal Control over Compliance and Instance of Noncompliance: Meal Count Reporting and Reconciliation U.S Department of Agriculture Child Nutrition Cluster Passed through State of lowa Department of Education Federal Assistance Listing Number: 10.555, 10.559, 10.553 Federal Award Year: 2025Criteria: Districts are required are required to submit accurate claims for reimbursement and maintain records supporting the number of meals claimed for reimbursement for the National School Lunch Program. Condition: During audit procedures over the School Nutrition Cluster, we identified multiple instances in the National School Lunch Program in which the number of claims submitted was incorrect. Cause: The District did not have an effective review and reconciliation control in place to compare meal-count support to the claim summary reports before reimbursement claims were submitted. In addition, meal-count and eligibility reports were not consistently generated and retained at the time the claims were prepared. As a result, subsequent changes in student eligibility status may have affected the reports available to support the meal counts claimed during the applicable reporting periods. Effect: Meal counts reported for reimbursement were not fully supported by contemporaneous records, resulting in noncompliance with reporting and recordkeeping requirements. Without an effective review and reconciliation control, errors in meal counts or claim summary reports may not be identified before reimbursement claims are submitted, increasing the risk that federal reimbursement claims could be inaccurate. Questioned Costs: Known questioned costs identified were below the reporting threshold and are not reported in this finding. Recommendation: We recommend that the District implement a documented monthly review and reconciliation process before reimbursement claims are submitted. The reconciliation should compare meal-count and eligibility support to the claim summary reports, identify and explain any differences, retain support for adjustments, and include evidence of review and approval by an individual independent of claim preparation. We also recommend that management generate and retain meal-count and eligibility report for each applicable reporting period at the time claims are prepared to ensure support reflects student eligibility status as of the applicable claim period. Management Response: Management acknowledges the finding and the District will generate and retain monthly meal-count and eligibility reports at the time reimbursement claims are prepared. The District will also implement a documented review and reconciliation process for National School Lunch Program reimbursement claims.

Reporting California Department of Education Partially Concur. The Department agrees that timely submission of FFATA reports is an important requisite. However, the circumstances that triggered the late submission were created by the control agency shifting to a new system without ensuring it met everyone’s needs, not by a lack of Department staffing or resources. Nevertheless, to strengthen existing procedures, the Department will review processes and determine if contingency procedures are appropriate and feasible. Management will also continue to monitor federal system changes, document implementation challenges, and maintain communication with federal agencies to ensure awareness of external system limitations that could affect reporting timelines. The Department will continue to work with the U.S. General Services Administration on automated reporting solutions to mitigate any future late submittals and to ensure timely submission of all FFATA reports. Estimated Implementation Date: September 30, 2026 Contact: - Yiping Hu, Accounting Administrator, Fiscal and Administrative Services Division

The Organization should implement an effective monitoring system to keep track of the compliance calendar, which includes financial reporting deadlines, and automatic reminders in advance of each deadline to aid in properly planning and timing submission of reporting packages. Additionally, the Organization should engage the audit firm well before the fiscal year end. The Organization should establish a timeline with the auditors that aligns with internal deadlines to ensure sufficient time to conduct the audit. Additionally, the Organization should implement a system that will file documents in an organized manner and make them easily accessible to the Organization and auditors. Furthermore, the Organization’s Board of Directors should be more actively engaged in the auditing and reporting process to establish a greater degree of accountability and oversight.

Eligibility for the Child Nutrition Cluster (Federal Award) Implement system edits or procedural checks to prevent duplicate eligibility entries for the same student, including unique student identifiers and warning prompts. Periodically run and review reports identifying potential duplicate records (same student ID, name, date of birth) and investigate and clear duplicates. Provide training to Nutrition Services staff on maintaining an unduplicated eligibility file and correcting errors. Responsible Party - Child Nutrition Analyst Target Completion - December 31, 2026

FS 2025-001 Internal Controls at the Central Office Internal Control Impact: Significant Deficiency Repeat of Prior Year Finding: FS 2024-001, FS 2023-001 Description: The School District's accounting procedures at the Central Office are not sufficient to ensure prevention or timely detection of errors in key financial processes, specifically those related to journal entries, cash management, capital asset tracking, and payroll processing. Corrective Action Plans: Journal Entries - All journal entries will be printed out, which show the preparer, reviewer and filed in numerical order beginning with FY26. Cash and Cash Equivalents - All bank balances are reconciled to the financial statements and are signed and dated by both preparer and reviewer. Monthly School Bookkeeper meetings are being held to ensure that all school level accounts are reconciled as well. Capital Assets - A complete physical inventory including bus titles will be completed in August of 2026. Employee Compensation - SHBP invoices starting with January 2026 have been reconciled to payroll and benefit records prior to payment and any corrections needed have been submitted to SHBP. Estimated Completion Date: January 1, 2026 Contact Person: Chris Johnson, Director of Financial Services Telephone: 478-994-2031 Email: chrisJohnson@mcschools.org

Finding 2025-003 a. Name of Contact Person Responsible for Corrective Action: Jeff Jones, Business Manager b. Corrective Action Planned: Additional Training has been provided during professional development sessions to keep in the forefront the importance of preventing conflicts of interest as well as possible nepotism as defined by Miss. Code Ann. § 25-1-53 and Miss. Code Ann. § 25-4-105(1). New hires are required to disclose possible conflicts of interest during the application process. Department heads making recommendations for hire are required to disclose if they are related to the person they are recommending for hire. c. Anticipated Completion Date: Training was provided in February, 2026, after disclosures were added to the employment applications in the human resource software asking the applicant to disclose if they are aware if they are related to anyone currently working in the district. As soon as the violation was identified, the Office of Child Nutrition at the Mississippi Department of Education was notified

Condition: the District did not provide an updated capital asset report including additions, deletions, and depreciation expense which is to be reported as a direct expense. Recommendation: The District's capital asset accounting and reporting system be updated to reflect additions, deletions and depreciation expense on an annual basis Method of Implementaton: Capital asset records will be reviewed annually and updated to reflect all additions, deletions, and depreciation. The inventory will be reconciled to the general ledger before year-end financial reporting.

Views of Responsible Officials: The District will implement formal internal control procedures requiring review and documented approval of all SNP Claim for Reimbursement Summary reports prior to submission in PEARS. The following procedures will be implemented: 1. The Director of Food Services will prepare the monthly SNP Claim for Reimbursement Summary report and compile all supporting meal count documentation. 2. Prior to submission, the Administrative Assistant to the Director of Food Services or another designated individual independent of the preparation process will: a. Review the claim for mathematical accuracy; b. Verify meal counts against supporting documentation; c. Confirm claims are submitted within required timelines; and 3. Evidence of the review and approval will be documented through: a. Signature or electronic approval on the reimbursement summary report; and b. Retention of supporting documentation in accordance with federal and state record retention requirements. 4. A written standard operating procedure (SOP) outlining these review and approval responsibilities will be developed and communicated to applicable personnel. The Business Manager will periodically monitor compliance with the procedure to ensure controls remain effective.

Current policy and procedure in place will be followed. The Daily meal count sheets will be reconciled to the dummary spreadsheet and the reimburement claims, including a second review prior to submitting the claim for reinburement.

Current policy and precedure in place will be followed. The Executive Director of Nutrition Services and the Food Compliance Officer will review Summer Food Service Program sited and serving windows prior to the start of the program as well as reinbursements prior to the completion of the SFSP program period each year.

2025-006: STUDENT MEAL APPLICATIONS Program: Child Nutrition Cluster Federal Assistance Listing Number: 10.553, 10.555, 10.559 Federal Agency: U.S. Department of Agriculture Pass-Through Agency: Arizona Department of Education Grantor Number: ADE ED09-0001 Questioned Costs: $-0- Type of Finding: Noncompliance (Other Matter), significant deficiency in internal control Compliance Requirement: E. Eligibility Condition: During our testing of eligibility determinations under the Child Nutrition Cluster, we selected 40 student meal applications for review. Of the 40 applications tested, two applications were incorrectly classified based on the information provided on the applications. Specifically, one application was approved as free when it should have been approved as reduced, and one application was approved as reduced when it should have been approved as paid based on applicable eligibility guidelines. Action planned in response to finding: The District will ensure nutrition applications are reviewed to determine they meet the appropriate classification criteria. In addition, applications will be reviewed and approved by someone other than the initial individual that is recording the classification type. Planned completion date for corrective action plan: For the period ending June 30, 2026. Name of the contact person responsible for corrective action: Edward Dickie, Business Manager.

2025-005: REPORTING Program: Child Nutrition Cluster Federal Assistance Listing Number: 10.553, 10.555, 10.559 Federal Agency: U.S. Department of Agriculture Pass-Through Agency: Arizona Department of Education Grantor Number: ADE ED09-0001 Questioned Costs: $-0- Type of Finding: Noncompliance (Other Matter), significant deficiency in internal control Compliance Requirement: L. Reporting Condition/Context: During our review of meals claims submitted for reimbursement, we noted variances between the District’s meal counts and what was submitted to the Arizona Department of Education. For four months tested, meals claims were net under-reported by 10,403 lunch and breakfast meals, which calculated to $3,616.29. Additionally, for three of 4 months tested, the District did not maintain any documentation to support that the claims were reviewed by a second person. Action planned in response to finding: The District will ensure a second employee verifies and approves all NSLP Claim forms to ensure the claims submitted are accurate and complete prior to submission. Planned completion date for corrective action plan: For the period ending June 30, 2026. Name of the contact person responsible for corrective action: Jim Serbin, CFO.