Corrective Action Plans

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.

A 100% review of applications was completed on October 10, 2025. The Food Service Supervisor will run an original direct certification before school starts and import that into Linq system. A 100% verification is completed in the fall. Each month a new direct certification is ran to catch any changes.

FA 2025·001 Improve Controls over Procurement and Suspension and Debarment Compliance Requirement: Internal Control Impact: Compliance Impact: Federal Awarding Agency: Pass-Through Entity: Assistance Listing Number and Titte: Federal Award Number: Questioned Costs: Description: Procurement Suspension and Debarment Significant Deficiency Nonmaterial Noncompliance U.S Department of Agriculture Georgia Department of Education 10.553 - School Breakfast Program 10.555 - National School Lunch Program 10.582 - Fresh Fruit and Vegetable Program 255GA324N1199 (Year: 2025), 255GA324L1603 (Year: 2025) $6,267 A review of expenditures charged to the Child Nutrition Cluster revealed that the School District's internal control procedures were not operating appropriately to ensure that the School District's procurement and suspension and debarment procedures were followed. Corrective Action Plans: To address this deficiency and prevent recurrence, the District will implement the following corrective actions: 1. Immediate Reinforcement of Quote Requirements Effective immediately, all School Nutrition and applicable district staff will be required to obtain and document price or rate quotations from a minimum of two qualified sources for all. 2. Pre-Approval and Verification Controls A pre-payment review process will be enforced requiring verification that: o Required quotes are documented o Procurement method aligns with federal thresholds o Vendor selection is properly justified o Payments will not be approved without complete documentation. 3. Staff Training and Accountability Mandatory training will be conducted for all School Nutrition Managers and staff involved in procurement to reinforce: o Federal procurement requirements o Documentation expectations o Internal control procedures Estimated Completion Date: July 31, 2026 Contact Person: Matoshia Grant, School Nutrition Director Telephone: 478-986-1390 Email: Matoshia.grant@jones.k12.ga.us Signature:Tonya Merritt Title: Cheir Financial Officer

VIEWS OF RESPONSIBLE OFFICIALS The Puerto Rico Department of Education (PRDE) acknowledges the audit finding presented by the auditors regarding the timeliness of FFATA reporting to the FSRS portal under the Child Nutrition Cluster (ALN 10.553, 10.555, and 10.559). As noted by the auditors, PRDE staff have continued implementing corrective measures in response to this requirement since it was first identified as Finding 2024-011. The delays identified during the current fiscal year were related primarily to the reporting of contract amendments, and the PRDE recognizes the need to fully resolve this repeat condition. The Child Nutrition program has already developed and begun implementing its corrective action plan, which includes reinforced monitoring procedures and designated tracking responsibilities for all subaward and contract amendment reporting obligations. With these measures in place, the PRDE expects to submit all required FFATA reports for subaward obligations and contract amendments within the timeframe established under 2 CFR Part 170 going forward. IMPLEMENTATION DATE Implemented on Fiscal Year 2025-2026 RESPONSIBLE PERSON Odalis Menard AESAN Director Lourdes García Santiago AESAN Sub-Director

VIEWS OF RESPONSIBLE OFFICIALS The Puerto Rico Department of Education (PRDE) acknowledges the audit findings presented by the auditors regarding the Activities Allowed or Unallowed// Allowable Costs/Cost Principles (ALN 10.553, 10.555, 10.559, 10.582, 84.010, 84.027, 84.425D, 84.425U. The PRDE recognizes that the recoup procedures established in the "Manual de Procedimiento de Nómina" are in place; however, the Department acknowledges that the detail of Accounts Receivable shows $3,756,580 corresponding to invoices generated during the audit year. The PRDE is working with the existing manuals, along with the new changes being implemented, to strengthen the recoup process for these overpayments. As such, the PRDE has implemented several procedures which have helped in this collection process. The PRDE is committed to strengthening its documentation practices and internal oversight mechanisms to ensure full compliance with 2 CFR § 200.403(g) and other applicable federal requirements. The PRDE further acknowledges that this is a repeat finding (prior year Finding 2024-005) and accepts the auditors’ recommendation to establish and implement formal procedures to obtain and review subrecipient audit reports in a timely manner, follow up on relevant audit findings, and maintain documentation of all monitoring activities performed IMPLEMENTATION DATE Fiscal Year 2025-2026 RESPONSIBLE PERSON Giovanni Siarez Deputy Director of Payroll Wilfredo Falcón Negrón Human Resources Area Director Office Time Attendance & Leave Evelyn E. Rodríguez Cardé Finance Director

CFDA 10.558 — Child and Adult Care Food Program Finding Type: Noncompliance / Significant Deficiency Corrective Action Plan The YMCA acknowledges the finding related to incorrect participant meal coding and reimbursement classifications. Management has implemented the following corrective actions: 2 4 Provide refresher training to all staff responsible for determining and entering participant eligibility classifications. Develop written procedures outlining eligibility determination requirements and reimbursement coding standards. Conduct periodic internal audits of participant eligibility classifications to identify and correct errors timely. Maintain documentation of training attendance and ongoing monitoring activities. Responsible Party Sonja Williams and Site Coordinators Expected Completion Date September 30, 2026

PLANNED CORRECTIVE ACTION The Division will communicate to all units conducting USDA Foods inventory counts the requirement that inventory reports must include documented evidence of review prior to submission. The Division's Social Services department will incorporate verification of documented inventory review into its quarterly internal oversight process to ensure compliance with this requirement on an ongoing basis. ANTICIPATED COMPLETION DATE 10/1/26 RESPONSIBLE CONTACT PERSON Julie Luft, NW Social Services Director

The District will implement proper control over program expenditures. Expenditures for other programs will be paid directly from those program funds, if possible.

The Division is in the process of designing and implementing a precise control to ensure that the inventory reports are reviewed prior to being submitted to the grantor and that the backup documentation is maintained. Anticipated Completion Date: 9/30/2026 Responsible Contact Person: Michael Zielinski, Major, Divisional Commander.

Finding No.: 2025-005 Condition: The District did not maintain sufficient records to detail the history of procurement. The organization did not ensure that vendors complied with all contract terms, conditions and specifications. Plan: The district is currently running a Food Service Management Company bid that complies with the state’s procurement. Anticipated Date of Completion: August 1, 2026 Name of Contact Person: Nicholas Valderas, Business Manager Management Response: See plan above

FA 2025-001 Improve Controls over Procurement and Suspension and Debarment Compliance Requirement: Procurement and Suspension and Debarment Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Federal Awarding Agency: U.S. Department of Agriculture Pass-Through Entity: Georgia Department of Education AL Numbers and Titles: 10.553 School Breakfast Program 10.555 National School Lunch Program Federal Award Numbers: 255GA324N1199 (Year: 2025) Questioned Costs: $7536 Description: A review of expenditures charged to the Child Nutrition Cluster revealed that the School District's internal control procedures were not operating appropriately to ensure that the School District's procurement and suspension and debarment procedures were followed. Corrective Action Plans: An annual Invitation for Bid (IFB) for equipment repair services will be issued to a minimum of two or more vendors for quotes. Final vendor selection will be made by the SNP Director and communicated to the Board for approval. These steps will ensure compliance with procurement regulations and proper documentation of services. In addition, the Federal Programs Manual will be amended to state that all vendors are reviewed annually to verify their suspension and debarment status. Estimated Completion Date: 6/30/2026 Contact Person: Joshua Worth , CFO Telephone: 912-699-7030 Email: joshua.worth@jeff-davis.k12.ga.us

2025-003 – Controls Over Disbursements Federal Program Information: Department of Education – Special Education Cluster (IDEA) CFDA – 84.027/84.173 Department of Education – Child Nutrition Cluster CFDA – 10.553/10.555/10.556/10.559/10.579/10.582 Criteria: 2 CFR 200.303 Internal Controls Condition: During audit procedures, it was identified that the Supervisory Union did not have internal controls in place to ensure that invoices were properly approved and paid in a timely manner. Cause: Unknown Effect: The Supervisory Union did not always properly approve invoices, could not always locate invoices, and paid invoices beyond the due date. Identification of Questioned Costs: None identified. Context: Between both programs, a total of 43 disbursements were chosen for testing. 11 were adjusting entries. Of the remaining 32, 4 were not paid in a timely manner; 21 were missing either invoices or PO’s or not properly approved. Repeat Finding: This is a repeat finding. Recommendation: It is recommended that the Supervisory Union implement controls to ensure that invoices are managed and paid appropriately. Management Response: Management agrees with the recommendation and will implement controls to ensure that invoices are managed and paid appropriately. Anticipated completion date 7/1/2026

U.S. Department of Agriculture 2025-008 Weakness in Internal Control Over Compliance of Suspension and Debarment Federal Program: Child Nutrition Cluster — USDA Commodities (15.550), School Breakfast Program (10.553), National School Lunch Program (10.555), Summer Food Service Program for Children (10.559) Management agrees with the finding and will update the Child Nutrition Procurement Plan and related procedures to ensure suspension and debarment requirements are clearly applied to all covered transactions, including those executed through various procurement methods. Management will also work to design and implement internal controls to ensure suspension and debarment verifications are consistently performed and documented for covered transactions under the Child Nutrition Cluster. Person responsible: Christin Legros, Director of Finance Expected completion date: June 2026

U.S. Department of Agriculture 2025-007 Weakness in Internal Controls Over Compliance of Allowable Costs/Cost Principles of Payroll Disbursements Federal Program: Child Nutrition Cluster — USDA Commodities (15.550), School Breakfast Program (10.553), National School Lunch Program (10.555), Summer Food Service Program for Children (10.559) Management agrees with the finding and has reviewed the payroll items identified during the audit and has taken corrective action to address schedule discrepancies and unsupported payroll entries. Management has conducted a review of employee schedules within the timekeeping system to ensure alignment with payroll records and has corrected errors identified. Management plans to continue performing periodic reviews of payroll data to identify potential discrepancies and to take corrective action as needed. Management will also evaluate identified payroll discrepancies on a case‑by‑case basis to determine whether recovery or adjustment is appropriate. Person responsible: Christin Legros, Director of Finance Expected completion date: June 2026

Recommendation: We recommend that Eastern Lancaster County School District implement procedures to ensure that SNP Claim for Reimbursement Summary reports are independently reviewed and approved prior to submission to Program Electronic Application and Reimbursement System (PEARS). This review should be performed by an individual who is not involved in the preparation of the reports and evidence of the review should be documented. School District Response: (Corrective Action) Eastern Lancaster County School 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: o Review the claim for mathematical accuracy. o Verify meal counts against supporting documentation. o Confirm claims are submitted within required timelines. 3. Evidence of the review and approval will be documented through: o Signature or electronic approval on the reimbursement summary report. o 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. 5. The Chief of Finance and Operation will periodically monitor compliance with the procedure to ensure controls remain effective. Anticipated Completion Date: The corrective action procedures will be fully implemented by June 1, 2026. Responsible Person for the Corrective Action: Keith D. Ramsey, Chief of Finance and Operations

Corrective Action Plan 1. Establish Written Procedures o The District will develop and adopt written procedures outlining the process for preparing, reviewing, and approving monthly Claims for Reimbursement for all food service programs (Breakfast, Lunch, and Summer). o Procedures will specify responsible staff, required documentation, timelines, and review steps prior to submission. 2. Implement Dual Review Process o The Food Service Director ( or designee) will prepare the monthly meal count report using data from the Infinite Campus system. o The assistant to the food service coordinator will perform a secondary review before submission to DESE. o The review will confirm: • Meal counts match Infinite Campus reports. • Correct classification of free, reduced, and paid meals. • Accuracy of totals by meal type (breakfas1/lunch). o Both preparer and reviewer will sign and date the Monthly Meal Count Verification Form as documentation ofreview. 3. Post-Submission Verification o After clairo submission, the reviewer will retain a copy of the DESE Claim for Reimbursement and supporting Infinite Campus reports in a centralized digital folder. o Random quarterly spot checks will be performed to confirm continued accuracy and compliance. 4. Training o The Food Service Director and business office staff will receive annual training on meal count reporting procedures and DESE claim submission requirements. o Training records will be maintained. 5. Timeline for Implementation o Written procedures finalized and approved by December 15, 2025. o Dual review process implemented beginning with the December 2025 claim. o Staff training completed by January 31, 2026. 6. Responsible Parties o Food Service Director - preparation and initial verification. o Chief Operations Officer - review and approval. o Superintendent - oversight and policy adoption. We are committed to ensuring the accuracy and integrity of our meal count reporting and eligibility determinations. The District will implement these corrective actions in a timely manner to address the identified findings and ensure compliance with applicable federal regulations.

The staff member responsible for completing the verification process—Accounts Payable—will attend the required training/webinar to ensure full compliance with USDA regulations. Accounts Payable will complete training specifically covering the proper procedures and requirements for the verification process, as outlined by the State Agency and USDA guidelines. Documentation on the completed training will be retained on file and made available upon request. In addition to training, both Accounts Payable and Operations Manager are signed up to receive the Ohio Ed Updates SNP Items of Interest. This corrective action is being taken promptly to address the findings and to prevent future occurrences. The district is committed to ensuring all staff involved in child nutrition programs are appropriately trained and fully understand their responsibilities.

The District will pull a sample of 5% of applicants entered into the Payschools system as of October 31 and perform an independent eligibility determination. Once the eligibility determination has been completed, we will compare it to the eligibility determination made by the Payschools system and note any discrepancies.