Corrective Action Plans

Condition: For the year ended June 30, 2025, it was noted that meals submitted for reimbursement included meals for students that were not eligible per the District's application for the program, resulting in the District being reimbursed in excess for an estimated $33,771. Recommendation: The District should apply for reimbursement for meals that were served to students included in their program application or take measures to amend the program application. Management Response: During the 2024-2025 school year, East Alton-Wood River Community High School District #14 began providing breakfast and lunch service for the Region III Journeys Program, an off-site alternative learning program serving students from multiple districts including EAWR. This was the first year EAWR had ever provided meals for Journeys, and the District implemented this service with the good-faith intention of ensuring that all students attending the program had access to daily nutritious meals. Because this was a new service arrangement, the District did not realize that our existing Community Eligibility Provision (CEP) approval documentation needed to be amended to include the additional educational site. The meals served to students at the Journeys Program were therefore included on the monthly reimbursement claims. The variance identified by the auditors reflects only the meals served at this second site, which are not captured in Skyward because some of the Journeys students are not enrolled at EAWR. There was no intent to misclaim meals, and the District did not receive financial benefit beyond the actual cost of preparing and providing meals. The additional breakfasts and lunches prepared for Journeys (approximately 20 breakfasts and 20-30 lunches daily) do not exceed the District's total CEP enrollment capacity and represent meals that were prepared, delivered, and made available to students. Additionally, in prior years another CEP district provided meals to the Journeys Program under similar circumstances without receiving reimbursement from Region III districts, which contributed to our understanding of customary practice within the cooperative. This was an administrative oversight associated with the first year of providing meal service to an off-site program and not the result of intentional noncompliance or an attempt to secure unearned reimbursement. No financial harm occurred to the program, as all meals claimed were prepared and made available to students in accordance with CEP expectations for universal access. To ensure future compliance, the District will amend its CEP application to include all educational centers served by EAWR in subsequent program years. Anticipated Date of Completion: June 30, 2026

SIGNIFICANT DEFICIENCIES, 2025-002 Allowable Costs and Activities: There is an audit recommendation that the District implement internal control processes and procedures to ensure that each purchase has a purchase order and an approved invoice at the time of payment, clearly indicating pre-approval for the purchase and coding to ensure it is charged to the correct accounts. Corrective Action: The District already has a requisition/purchase order system in place and will expand it to ensure purchases are pre-approved and that invoices are approved and that the purchase is coded to the appropriate fund. Anticipated Completion Date: This corrective action has already been implemented. Status: Completed.

MATERIAL WEAKNESSEs, 2025-001 - PROCUREMENT There is a material weakness identified in the audit that The District does not have the necessary internal controls over compliance and does not appear to have understanding or knowledge of the contract requirements for service contracts. Corrective Action: Central Office Staff and Staff responsible for Federal Grants and Programs will familiarize themselves with and implement the proper procedures and requirements for service contracts and procurement methods to ensure it meets the requirements in the District Policy and Federal Procurement requirements. Anticipated Completion Date: January 31, 2026

Finding Number: 2025-002 Planned Corrective Action: Claims reimbursement will be inspected monthly by a separate person from who is inputting the data to ensure accurate filing of meals served. If discrepancies are discovered, the district will maintain support for the numbers that are submitted to DEW. Anticipated Completion Date: 12/31/2025 Responsible Contact Person: Jared M Bunting, SFO

Finding 2025-001 Federal Program: Child Nutrition Cluster AL NO.: 10.553, 10.555 Federal Agency: U.S. Department of Agriculture Pass-Through Entity: Missouri Department of Elementary and Secondary Education Award No.: As listed on the Schedule of Expenditures of Federal Awards Award Period: Various Compliance Requirement: Eligibility Views of the Responsible Officials: Starting in the 2025-2026 school year, the Child Nutrition annual application process will be done online, Before being finalized, it will be required for the Food Service Director to attach an electronic signature. All applications will be stored online for easy retrieval and less risk of misplacement or loss. Any paper applications that are submitted will be reviewed and manually signed by the Food Service Director. Paper applications will be filed in the Director's office. Contact person: Robin Kluesner Anticipated Completion Date: August 22, 2025

FINDING 2025-002 Finding Subject: Child Nutrition Cluster - Internal Controls Contact Person Responsible for Corrective Action: Todd Nobbe, Corporation Treasurer Contact Phone Number and Email Address: 812-934-2194, tnobbe@batesville.k12.in Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The school corporation will establish a proper system for internal controls and develop procedures to ensure free and reduced guidelines are reviewed by the Corporation Treasurer. The school corporation will establish a proper system for internal controls and develop procedures to ensure EFTs are reviewed by the Director of Operations. Anticipated Completion Date: Immediately 12/08/2025

This finding is due to the District not having the proper controls in place to prevent, detect, or correct an incorrect monthly meal claim. The month that had the incorrect meal claim used incomplete Z-Reports which resulted in the meal claim being submitted for less than it should have been. The persons responsible for the corrective action are Lisa Newton, the Food Service Director and Corey Bordo, the Director of Business and Finance. The anticipated completion date of the corrective action plan is immediate. The plan for monitoring adherence is the Food Service Director will ensure that all meal counts are final on the Z-Report before the claim requests are made.

The District will review its procedures related to application approvals.

Name of Contact Person: Paul Taylor, Superintendent. Recommendation: We recommend the District implement internal controls to ensure their procurement policy is followed. We also recommend updating their contracts with all required language, including the Buy American clause. Correction Action: We will implement internal controls to ensure our procurement policy is followed. We will also update our contracts with all required language, including the Buy American clause. Proposed Completion Date: Immediately.

Recommendation: We recommend that the District implement procedures and controls to ensure that all paper applications are being reviewed. Explanation of Disagreement with Audit Findings: There is no disagreement with the audit finding. Actions Planned in Response to the Finding: The District will continue to work on establishing procedures and controls to ensure that all paper applications are being reviewed. Official Responsible for Ensuring CAP: Tanner Spawn, Business Manager. Planned Completion Date for CAP: June 30, 2026.

U.S. Department of Education Clinton School District #124 respectfully submits the following Corrective Action Plan for the year ended June 30, 2025. Contact information for the individual responsible for the corrective action: Daniel Brungardt, Superintendent Clinton School District #124 Independent Public Accounting Firm: Gerding, Korte & Chitwood, P.C., 723 Main Street, Boonville, MO 65233 Audit Period: Year ended June 30, 2025 The findings from the June 30, 2025, Schedule of Findings and Questioned Costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Significant Deficiency 2025-001 Child Nutrition Cluster Recommendation: We recommend that fund balances should be monitored to ensure that balances remain in line with child nutrition compliance requirements.

Action Taken: As part of corrective actions, the District has prioritized overdue infrastructure and equipment needs. Since July1, 2025 the District has invested $118,901.50 in equipment upgrades, including: rebuilding the 17 year-old walk-in cooler and freezer at Clinton High School; installing new refrigerator and freezer units at CMS and Henry Schools; decentralizing cold storage operations to improve reliability and delivery efficiency, replacing a failing centralized system; replacing the serving line at Henry School, which is outdated and no longer meets the operating needs of a modern cafeteria; ongoing replacement of aged and non-functional food service equipment across multiple sites; review options for replacing or upgrading centralized walk-in freezer unit. These upgrades are critical to ensuring food safety, operational efficiency, and service quality for students. The District will also continue to track expenditures and ensure fund usage aligns with NSLP guidelines. Upon fully expending the excess fund balance, the District will submit detailed documentation by June 30, 2026 outlining how funds were used and the impact of those actions.

Completion Date: June 30, 2026

Sincerely, Daniel Brungardt, Superintendent Clinton School District #124

The District will implement a secondary review process for the nutrition reimbursement reports and will monitor the monthly financials to ensure revenue is reasonable based on meal counts.

Management will review the claims list for completeness and accuracy before presenting the list to the board for approval.

The District will implement a secondary review process for the nutrition reimbursement reports and will monitor the monthly financials to ensure revenue is reasonable based on meal counts.

Management will review the claims list for completeness and accuracy before presenting the list to the board for approval.

View of the Responsible Official: We agree with the significant deficiency identified. Responsible Persons: School-based food service coordinators and Management director of food service Management Response: Training is conducted annually with school-based food service coordinators to ensure proper understanding of reporting requirements. During the 2025-2026 year standardized forms have been distributed to all school food service locations to ensure accurate counting and calculations, which will align with the monthly claim reimbursement reports submitted for reimbursement. It is the expectation that all school-based food service coordinators will properly utilize the updated forms and will receive training as necessary to ensure a thorough understanding of the importance of accurate reporting. Management’s food service director will increase oversight of the meal counts and claims reports to verify the accuracy of the reporting, and to ensure that the count records agree to the claims submitted. Anticipated Completion Date: June 30, 2026

2025-004 – MEAL COUNT REPORTING Corrective Action Plan: We were running two different options within the Summer Food Service program each week - one food distribution for 7 days and one for 3 days. Starting in August, we simplified it to one distribution of 7 days, so that only one report is needed to be completed and handed in for each week. This makes it easier for the team preparing the food and filling out the reports, and also more obvious when all the reporting has been done vs. not. Responsible Party(ies): • Business Manager Anticipated Completion Date: August 31, 2025

2025-003 – UNALLOWABLE COSTS Corrective Action Plan: We have implemented a new policy that requires the Superintendent to review and sign-off on all outgoing EFT and ACH payments. We have implemented a new policy that requires the Superintendent to review and sign-off on all bank statements. Responsible Party(ies): • Superintendent and Board of Education Anticipated Completion Date: June 30, 2026

Corrective Action Plan: The District will ensure free and reduced meal applications with a case number in Step 2 of the application are part of a program that makes them immediately qualify for free or reduced meals. In addition, approved applications will be reviewed by a 2nd party to ensure accurate approval has taken place. Anticipated Corrective Action Plan Completion Date: December 2025 Contact Information: For additional information regarding this finding please contact Erica Pickett, Director of Business Services, at 608-877-5011.

The District will provide food service staff with additional training on the federal verification process and sampling requirements. The District will conduct an internal review, at least twice a year, of a sample of verifications to ensure it is meeting the verification requirements.

The District agrees with this finding and will be implementing a new policy which includes a Finance Office verification of the meal counts submitted when the deposits come in through Child Nutrition to ensure that the reports match the deposit and the reports match the internal reports for meal counts The District was able to recoup the funds from the missing months by submitting corrected claims.

Finding No. Corrective Action Plan 2025-002 Segregation of Duties – Monthly claims Recommendation: We recommend the District designate an individual to review monthly claims prior to submitting. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: Management will review and approve monthly claims prior to submitting. Name of responsible official: Jesse Brinkmann, Superintendent Expected Completion Date: 06/30/2026