Corrective Action Plans

FINDING 2025-001 Subject: Child Nutrition Cluster (CNC) - Internal Controls Federal Agency: Department of Education Federal Program: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children Assistance Listing Number: 10.553, 10.555, 10.559 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs - Cost Principles Audit Finding: Significant Deficiency Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Activities Allowed or Unallowed, Allowable Costs - Cost Principles compliance requirements. Context: During testing payroll disbursements charged to CNC grants, we noted: One selection in a sample of 40 for which the employee was paid above their contracted hourly rate. One selection in a sample of 40 for which the contract sheet for fiscal year 2025 did not include an accurate breakdown for cafeteria employees employed for less than one year and employees employed more than one year. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Management will ensure controls surrounding salary/hour rate schedules are implemented/enhanced and that rate changes are properly reviewed when instituted. Responsible Party and Timeline for Completion: Betty Huddleston, July 1, 2026

FINDING 2025-004 Finding Subject: Child Nutrition Cluster-Reporting Contact Person Responsible for Corrective Action: Greg Miller, Food Service Director Contact Phone Number and Email Address: 424 East South A Street, Gas City, IN 46933 (765)-677- 4423 Views of Responsible Officials: Mississinewa Community School Corporation concurs with the finding 2025-004. Description of Corrective Action Plan: An effective internal control system, which would include segregation of duties, was not in place at the School Corporation to ensure compliance with requirements related to the monthly reimbursement claim process for the audit period. Corrective Action: Internal Controls regarding the monthly reimbursement claim process will be implemented to be completed each month. The High School Kitchen Manager, along with the Food Service Director, will review the sale reports, attendance factor, and edit checks to calculate the total claim count for each federal program. The Manager and Food Service Director will approve and sign the total meal counts to claim prior to entering data into the CNP website. Anticipated Completion Date: January 31, 2026.

FINDING 2025-003 Finding Subject: Child Nutrition Cluster-Suspension and Debarment Contact Person Responsible for Corrective Action: Greg Miller, Food Service Director Contact Phone Number and Email Address: 424 East South A Street. Gas City, IN 46933 (765)-677- 4423 Views of Responsible Officials: Mississinewa Community School Corporation concurs with the finding 2025-003. Description of Corrective Action Plan: An effective internal control system, which would include segregation of duties, was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Corrective Action: Internal Controls regarding Procurement and Suspension and Debarment will be implemented to maintain reasonable assurance of compliance with the Procurement and Suspension and Debarment by requiring the Certification Regarding Debarment, Suspension, Ineligibility and Voluntary Exclusion Form as part of the procurement process. Once returned with the RFQ/RFP (request for quote or proposal), the Food Service Director will review with the Business Manager for approval, including both signatures. Additionally, the Business Manager will look up all vendors on the pre-approved Suspension and Debarment vendor website, and those results will be shared with the Food Service Director before the procurement process. All completed forms will be filed with the Business Manager. In addition, CN Director will provide a template letter to the vendor stating that they have not been suspended or debarred from procurement with federal entities. Vendor will be asked to sign the letter and return to the Food Service Director to keep on file at Mississinewa Community Schools. Anticipated Completion Date: January 23, 2026.

Management concurs with Audit Finding 2025-003 and will strengthen controls over USDA Food Distribution Cluster reporting to ensure accuracy, completeness, and compliance with federal and State requirements. Management will implement the following corrective actions: 1. Monthly USDA Reporting Reconciliation Process Management will implement a formal monthly reconciliation process that includes: o Reviewing confirmed USDA receipts and reconciling them to internal inventory records in CERES; and o Reconciling all TEFAP distribution reports submitted to the States to CERES data prior to submission. All reconciliations will be documented, reviewed, and retained. 2. Documentation of Shortages and Inventory Adjustments Shortages noted on signed agency invoices will be promptly documented and resolved through credit memos or inventory adjustments in CERES. Supporting documentation will be retained to substantiate all adjustments. 3. 48-Hour Receipt Confirmation Tracking Management will establish a tracking mechanism (e.g., log or checklist) to monitor submission of all required 48-hour receipt confirmations. The tracking tool will document submission dates and ensure confirmations are submitted timely and retained in accordance with record retention requirements. 4. Assignment of Reporting Responsibility Management will formally assign primary responsibility for preparation and submission of Food Distribution Cluster reports to a designated individual. Roles and responsibilities will be clearly documented. 5. Supervisory Review and Oversight A supervisory reviewer will perform documented reviews of reconciliations, supporting documentation, and reports prior to submission. Supervisory review will confirm that: o Reconciliations are completed. o Differences are investigated and resolved; and o Reports comply with applicable federal and State requirements. 6. Monitoring and Training Management will periodically monitor compliance with these procedures and provide refresher training to staff involved in inventory, distribution, and reporting to ensure consistent application of controls. Expected Completion Date: Within 60–90 days Responsible Parties: Donavann Brooks, Inventory Control Manager (901-527-0422)

Management concurs with Audit Finding 2025-002 and will reinforce controls over USDA food distribution documentation to ensure all distributions are properly acknowledged and supported in accordance with Food Distribution Cluster recordkeeping requirements. Management will implement the following corrective actions: 1. Required Agency Acknowledgment at Delivery Management will reinforce procedures requiring recipient agency signatures or equivalent acknowledgment on all USDA food distribution invoices at the time of delivery. Distribution staff and drivers will be reminded that unsigned delivery documentation is considered incomplete. 2. Post-Delivery Follow-Up Control Management will implement a follow-up control, such as a delivery log or checklist, to track all USDA distributions recorded at the time of delivery. The log will include verification that a signed receipt has been obtained and returned for each transaction. 3. Reconciliation of Distributions to Signed Documentation On a periodic basis, management will reconcile USDA distribution activity to signed agency invoices to identify any missing acknowledgments. Missing signatures will be promptly investigated and resolved, with documentation of follow-up retained. 4. Supervisory Review and Oversight Supervisory personnel will perform periodic documented reviews of distribution documentation to verify that signed agency receipts are obtained, complete, and retained. Evidence of review will be maintained. 5. Training and Awareness Management will provide refresher training to distribution staff and drivers on USDA documentation requirements and the importance of obtaining signed acknowledgment to support program accountability and reporting accuracy. Expected Completion Date: Within 60-90 days Responsible Parties: Andrelle Bowen, Transportation Manager, (901-373-0402)

Management concurs with Audit Finding 2025-001 and will implement enhanced internal controls over inventory adjustments to ensure accurate accounting for the receipt, distribution, and disposition of all USDA commodities in compliance with Special Tests and Provisions requirements. Management will implement the following corrective actions: 1. Formal Approval and Authorization of Inventory Adjustments Management will establish a formal policy requiring documented supervisory review and approval for all manual positive and negative inventory adjustments recorded in the general ledger and the CERES inventory system. Approval will be obtained prior to posting adjustments, and access to record adjustments will be restricted to authorized personnel. 2. Standardized Documentation for Adjustments Each inventory adjustment will be supported by standardized documentation clearly explaining the nature, reason, and calculation of the adjustment, along with applicable supporting records (e.g., receiving documents, distribution records, shortage documentation). All documentation will be retained in accordance with USDA record retention requirements. 3. Reconciliation of Inventory Activity Management will implement a periodic (at least monthly) reconciliation of inventory receipts, distributions, and adjustments to CERES and the general ledger. Reconciling items will be investigated, resolved, and documented timely. 4. Monitoring of USDA Program Inventory Management will perform periodic reviews of inventory activity related to donated inventory and Tennessee and Mississippi USDA programs to ensure that adjustments are appropriate, approved, and accurately recorded. 5. Training and Ongoing Oversight Management will provide targeted training to staff involved in inventory and accounting processes regarding USDA Special Tests and Provisions requirements and the new approval and documentation procedures. Management will monitor compliance with these controls to ensure they are operating effectively. Expected Completion Date: Within 60–90 days Responsible Parties: Donavann Brooks, Inventory Control Manager (901-527-0422)

The Academies will implement a monitoring system to ensure there are no clerical errors recording data in the system.

Corrective Action Plan Finding Number 2025-002 Condition: At June 30, 2025, the District maintained fund balances in excess of three months’ average expenditures. Management Response/Plan: The District has created a Spend Down Plan for the food service program based off guidance from the Illinois State Board of Education. The District is working on replacing equipment and renovating cafeterias. Anticipated Date of completion: June 2026 Name of Contact Person: Melissa Geyman Sell

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF AGRICULTURE, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION – CHILD NUTRITION CLUSTER – FEDERAL ALN 10.553, 10.555, AND 10.559 2025-002 Internal Control Over Compliance with Allowable Activities Requirements Finding Summary 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. During our audit, we noted the District did not have sufficient controls over meals counts submitted for afterschool snack reimbursement claims. For two months tested, the District’s internal tracking records for afterschool snacks served did not agree to the meal counts submitted to the Minnesota Department of Education (MDE) for reimbursement. In both cases, the internal records had been altered after the meal counts submissions to the MDE had been completed to add eligible afterschool snacks that had been missed. This resulted in underclaimed meals for eligible snacks served. Corrective Action Plan Actions Planned – The District will review and update its policies and procedures relating to eligible afterschool snack meal tracking and reimbursement submission for its child nutrition cluster federal program to ensure compliance with the Uniform Guidance in the future. Official Responsible – The District’s Director of Food Service, Dorie Pavel. Planned Completion Date – June 30, 2026. Disagreement With or Explanation of Finding – The District agrees with this finding. Plan to Monitor – The District’s Director of Food Service, Dorie Pavel, will assure appropriate internal controls and procedures are updated and in place for afterschool snack meal tracking and reimbursement submission to ensure the accuracy of District claims for eligible meal reimbursements in the future.

Corrective Action Plan The Central Columbia School District respectfully submits the following corrective action plan for the year ended June 30, 2025. The findings from the Single Audit Report Year Ended June 30, 2025 included in the schedule of findings and questioned costs are discussed below. Finding 2025-001: Reporting Contact Person: Steven Dolak, Business Administrator Recommendation: The District should revise procedures to ensure the data entered into the claim for reimbursement is reviewed for accuracy prior to the report being submitted. Evidence of the approval of submission should be documented in writing, such as with an initial, to demonstrate the review of the information has been performed. Action: The Business Administrator will prepare the reports for submission. Prior to submitting the report through the reimbursement system, a second individual will review the information entered. Upon satisfactory completion of the review, the second individual will acknowledge review by initialing and dating the document(s). Date for Completion: This procedure will be implemented at the beginning of the 2025-26 school year.

FINDING 2025-002 Information on the federal program: Subject: Child Nutrition Cluster - Reporting Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY2024, FY2025 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the reporting compliance requirement. Context: During the testing of claim reimbursements, we noted that monthly reimbursements are prepared and reconciled by Food Service Director. The reimbursements are reviewed informally by the Treasurer but this review is not formally documented and therefore, auditable evidence of the review was not available. The lack of formal, documented review existed throughout the audit period. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding. Management will implement a formal, documented review of the monthly reimbursement claims submitted by the Food Service Director prior to submission to the State. Responsible Party and Timeline for Completion: The Food Service Director will prepare and reconcile monthly claims. The FSD will forward to the cafeteria supervisor for review. Both the FSD and cafeteria supervisor will sign off before being submitted to the state for reimbursement. This measure has already been implemented beginning with the November 2025 claim submitted in January 2026.

The Chief Financial Officer will ensure staff retain documentation of review and approval of the indirect costs charged to the federal programs, effective immediately. Date of implementation - effective immediately, January 30, 2026.

Response and Corrective Action Plan prepared by: Leanne Green Person Responsible for Implementing the Corrective Action: Leanne Green Anticipated Completion Date of Corrective Action: Vickie Dunaway, School Nutrition Director, corrected and resubmitted the claim in question, as soon as the issue was revealed. USDA paid the difference owed on October 28, 2025. Planned Corrective Action: Once the School Nutrition Director completes the monthly claim, Leanne Green, Finance Director, reviews the paperwork, verifying that all is correct before the claim is filed.

Finding Number: 2025‐001 Program Name/Assistance Listing Title: Child Nutrition Cluster Assistance Listing Numbers: 10.553, 10.555, 10.559 Contact Person: Jessica Johnston, Chief Financial Officer Anticipated Completion Date: August 20, 2025, immediately following the determination that the number of meals reported for reimbursement for the January and March claims did not agree to supporting documentation. Planned Corrective Action: The District has modified its internal controls related to child nutrition claims. The revised procedures include a secondary verification of reimbursable meals, which is completed and submitted by personnel independent of the data entry process.

The organization will revise and reinforce its procurement policies to ensure compliance with 2 CFR 200.318–200.320. Staff involved in procurement will receive training in federal procurement standards, including competitive bidding and documentation requirements. Internal controls will be strengthened to ensure consistent application of procedures and oversight. Anticipated Completion Date: January 31, 2026. Responsible Contact Person: Alfred D. Ivy, Director of Business Affairs & Operations.

FINDING 2025-001 Finding Subject: Child Nutrition Cluster – Internal Controls Contact Person(s) Responsible for Corrective Action: Mendy Shrout & Billy Boyette Contact Phone Number and Email Address(es): (765) 795-4664 / mshrout@cloverdale.k12.in.us & bboyette@cloverdale.k12.in.us Views of Responsible Officials: Option 1: We concur with the finding. Description of Corrective Action Plan: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Payroll distribution reports will be periodically reviewed and initialed by the Corporation Treasurer to assure employees paid are working in the cafeteria. Eligibility Cafeteria Managers will initially enter eligibility information into the POS (Harmony). The Food Service Director or Café Office Manager will sign off on the reports as records are entered. Reporting Food Service Director will provide the reports to the Corporation Treasurer or the Café Office Manager on a monthly basis for review. The reviewer will then initial the documents. Anticipated Completion Date: February 1, 2026

Background and Context: The District has a long-standing history of strong financial compliance and has not previously received audit findings related to internal controls or reporting. The error was isolated, not systemic, and was identified without evidence of intentional misreporting or ongoing risk. The District has implemented additional review steps as identified below to ensure continued accuracy in future submissions. Subject: Finding 2025-001: The finding indicates 2 errors were made in transferring data from the Daily Accuclaim Report to the Monthly Record of Meals Served at the East Campus resulting in an inaccurate request for reimbursement in the amount of approximately $55.00; these errors were made in 2 separate monthly reports during the 2025 fiscal year. Management response to FY 2025-001 Audit Findings The management of the Organization acknowledges the need for stronger internal controls in the administration of the Child Nutrition Meal Reimbursement Task Cluster. The agency implemented refresher training with the Administrative Assistant and the Campus Principal at the East Campus. Training was completed on November 18, 2025. Additionally, the agency has implemented stringent internal controls to ensure that all data regarding meal counts and reimbursement claims will be verified to ensure accuracy. It was noted that this weakness resulted in errors when the Administrative Assistant transferred data from the Daily Accuclaim to the Monthly Record of Meals Served. To prevent any errors in future claims, the following Standard Operating Procedure for all campuses was created: 1. The Administrative Assistant will tabulate meals served and enter daily totals on the Daily Accuclaim Report. The Campus Principal will provide a second count for daily totals and verify that the correct total was entered on the Daily Accuclaim Report. Both the Administrative Assistant and the Campus Principal will initial the Daily Accuclaim Report when verifications have been completed. 2. Data from the Daily Accuclaim Report will be transferred to the Monthly Record of Meals Served. Both the Administrative Assistant and the Campus Principal will verify that data has been correctly transferred and totaled accurately. Both the Administrative Assistant and the Campus Principal will initial the Monthly Record of Meals Served. 3. At the end of each month, Weekly Student Rosters, Daily Accuclaim Reports and the Monthly Record of Meals Served will be forwarded to the Director of Child Nutrition who will verify and initial all reports and enter data in TXUNPS for reimbursement. When all data for the month has been entered, a Summary Report will be printed and submitted to the Superintendent along with all documents for review and approval. Upon Superintendent written approval, the CNP Director will submit requests for reimbursement through TXUNPS. The agency will implement these Standard Operating Procedures beginning with the December 2025, Reimbursement Claim. It is believed that procedures requiring two personnel to review and sign off on all daily and monthly data and before final submission will ensure accuracy in Reimbursement Claims.

FINDING 2025-001 – Significant Deficiency in Internal Control over Compliance Description of Finding: The State Funding Agency audited the Child Nutrition program and found that the school food authority (SFA) was charged an indirect cost rate less than provided for in the indirect cost rate agreement and there was no document explaining how the difference would be handled with the nonprofit school food service account. They also identified that food expenses were included in the direct cost base. Food is considered a distorted fund and is not to be included in the direct cost base. Statement of Concurrence or Nonconcurrence: The Agency agrees with this finding during the Audit period and has made the necessary corrections. Corrective Action: The Organization has implemented procedures outlining how discrepancies will be managed. These procedures will be shared with relevant personnel, and training sessions will be conducted to ensure full compliance. Additionally, we have recalculated the indirect costs for FY2025, excluding the food expenses from the direct cost base. This recalculated amount was reflected in the revised financial reporting. Name of Contact Person: Richard Carmelich, Chief Operations Officer Projected Completion Date: June 30, 2025 QUESTIONED COSTS 1. There was $41,868 in questioned costs as a result of the 2025-001 audit finding. The Organization agreed that the cost was unallowable and revised the financial reporting to the satisfaction of the auditing State agency.

Condition: The same individual is responsible for preparing and submitting monthly reimbursement claims for the Child Nutrition Program without an independent review or approval prior to submission. Plan: A second person (business manager) compares the meal counts in the claim to the SDS daily meal count reports, monthly participation summary, eligibility rosters (free, reduced, paid) and USDA reimbursement rates. The reviewer will then sign and date a reconciliation sheet before submission. Anticipated date of completion: June 30, 2026. Name of contact person: Todd Hellrigel, Superintendent. Management response: The corrective action plan was discussed with the employee responsible for filing the claim, the business manager, and the superintendent. After discussion, the plan was approved by the superintendent.

Condition: The same individual is responsible for preparing and submitting monthly reimbursement claims for the Child Nutrition Program without an independent review or approval prior to submission. Plan: A second person (superintendent) compares the meal counts in the claim to the SDS daily meal count reports, monthly participation summary, eligibility rosters (free, reduced, paid) and USDA reimbursement rates. The reviewer will then sign and date a reconciliation sheet before submission. Anticipated date of completion: June 30, 2026. Name of contact person: Brett Elliott, Superintendent. Management response: The corrective action plan was discussed with the employee responsible for filing the claim, the business manager, and the superintendent. After discussion, the plan was approved by the superintendent.

Condition: The same individual is responsible for preparing and submitting monthly reimbursement claims for the Child Nutrition Program without an independent review or approval prior to submission. Plan: A second person (chief financial & operations officer) compares the meal counts in the claim to the Skyward daily meal count reports, monthly participation summary, eligibility rosters (free, reduced, paid) and USDA reimbursement rates. The reviewer will then sign and date a reconciliation sheet before submission. Anticipated date of completion: December 7, 2025. Name of contact person: Cassandra Schug, Superintendent. Management response: The corrective action plan was discussed with the business services coordinator and the chief financial & operations officer. After discussion, the plan was approved.

Contact Person – Dr. Noel Schmidt, Superintendent Corrective Action Plan – The District will establish procedures to review meal reimbursement submissions. Completion Date – January 31, 2026

Federal regulations require that verification of applications be conducted by separate officials and that proper documentation and procedures are followed (7 CFR 245.6a). The same individual served as both the confirming and determining/reviewing official. The District did not maintain documentation of confirmation reviews, and some applications were not verified correctly, resulting in incorrect eligibility determinations. The ensure adherence to the separation-of-duties requirement outlinked in 7 CFR 245.6a, the District has designated a separate confirmining official. The verification process will now follow a two-step reivew; the Child Nutrition Secretary will conduct the initial verification of selected applications, and the Child Nutrition Director will complete the independent confirmation review. This structure ensures that two distinct individuals verify the accuracy of eligibility determinations and that proper oversight is maintained. Both the Child Nutrition Secretary and the Child Nutrition Director attended formal verification training in September 2025. This training reinforces correct procedures and supports proper documentation of all confirmation reviews moving forward.

Federal regulations require that eligibility determinations for free and reduced-priced meals be accurate and that benefit issurance documents are updated timely and accurately (7 CFR 245.6, 245.10). Several student applications were incorrectly approved. Additionally, benefit issuance documents were not updated in a timely manner for students newly eligible through Direct Certification. To ensure full compliance with 7 CFR 245.6 and 245.10, the Child Nutrition Director and Child Nutrition Secretary will jointly review each Direct Certification (DC) list to verify that all eligible students are accurately identified and that eligibility status in the point-of-sale (POS) system is update promptly. This dual-review process will service as a verificaiton measure to prevent omissions and ensure the benefit issuance document remains current and accurate. In August 2025, both the Child Nutrition Director and Secretary completed formal training on eligibility determination procedures. Moving forward, detailed notes- including dates and explanations of status changes- will be documented in each student's account to ensure clear tracking of all updates to support accurate recordkeeping for future reviews.

Condition: The same individual is responsible for preparing and submitting monthly reimbursement claims for the Child Nutrition Program without an independent review or approval prior to submission. Plan: A second person (superintendent or associate superintendent) compares the meal counts in the claim to the Skyward and RevTrak daily meal count reports, monthly participation summary, eligibility rosters (free, reduced, paid) and USDA reimbursement rates. The reviewer will then sign and date a reconciliation sheet before submission. Anticipated date of completion: June 30, 2026. Name of contact person: Tony Ingold, Superintendent. Management response: The corrective action plan was discussed with the employee responsible for filing the claim, the associate superintendent, and the superintendent. After discussion, the plan was approved and will be implemented.