Corrective Action Plans

Finding 2025-001 Significant Deficiency in Internal Control over Compliance - Reporting AL# 10.553 & 10.555 – Child Nutrition Cluster Corrective Action Plan Employee re-alignment and training was initiated beginning in August 2025, as well as revision to the review process for meal counts to include a second review prior to submission. In addition, the new system was evaluated for proper configuration to mitigate further issues. Person(s) Responsible M. Thorne, Operations Coordinator Anticipated Completion Date Corrective actions were substantially completed by October 2025.

Child Nutrition Cluster – Assistance Listing No. 10.553, 10.555 and 10.559 Recommendation: The District should review their internal control process for free and reduced meal applications to ensure that the proper controls are being implemented. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: The District will revise their internal control process to ensure that the District's controls for free and reduces meal applications are being implemented. Name(s) of the contact person(s) responsible for corrective action: Tim Widiker, Superintendent. Planned completion date for corrective action plan: December 2025.

The Food Services Division is committed to providing great food and maintaining rigorous internal controls and continuous monitoring to safeguard program integrity. The discrepancy found at one school is not representative of our program, as we do ongoing random audits of submitted claims to verify the accuracy of submitted data. These layered oversight measures provide multiple levels of verification to minimize and eliminate the likelihood of reporting errors and ensure compliance with applicable state and federal program requirements. At Annalee El, the school with an overclaim of 104 meals, we found that the manager had moved from the school, and in the interim, our review protocol fell short. Given the large volume of meals served annually across the District, the over-claim discrepancy identified during the FY 24-25 audit represents an isolated incident rather than a systemic deficiency in LAUSD Food Services operations. The claim verification process followed at schools is stated below: • The Food Service Manager conducts a weekly review of the prior week’s daily meal count documents to identify and correct any discrepancies. • The Food Service Manager generates and reviews a weekly Meal Counts Report from the Cafeteria Management System (CMS) to verify recorded data. • The Food Service Manager compares the daily meal count documents against the five-day Meal Counts Report to ensure data alignment and accuracy. • The Manager performs an additional verification by reconciling daily meal count documents with the five-day Meal Counts Report from CMS. Any identified errors are corrected immediately in CMS. This reconciliation process is completed prior to the submission of claims to the Child Nutrition Information and Payment System. • The Area Food Services Supervisor (AFSS) and Regional Manager (RM) conduct random weekly reviews of meal counts for accuracy, utilizing reports provided by Central Office staff to support this verification process. • Central Office staff perform a monthly audit of meal count records and prepare a draft report for review by the AFSS and RM to validate findings and confirm accuracy. Retraining of the staff at Annalee El has been completed, and the manager and supervisor teams are verifying that the above protocol is being followed consistently at all schools. Name: Manish Singh Title: Director, Food Services Division Telephone: (213) 241-2993

The Food Service Director has implemented a corrective plan focused on (1) re-training on production record requirements, (2) real-time verification and monitoring, (3) escalation for noncompliance, and (4) sustained oversight until compliance is consistent. The District will maintain documentation of monitoring and follow-up to demonstrate that corrective actions are in place and effective. Implementation: December 1, 2025

FINDING 2025-002 Contact Person Responsible for Corrective Action: Christine Clarahan Contact Phone Number: 219-663-3371 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: A monthly checklist was created that will be used by those in the Food Services administration team office. The checklist includes the task, line for initials and date that task was completed. Tasks include Direct Certification download, spot checking after the Direct Certification download, verifying Food Service deposits, and other monthly tasks. Anticipated Completion Date: November 18, 2025

Finding No: 2025-004 Condition: The District receives Title I funding and determines eligibility for schoolwide programs based on attendance numbers derived from free and reduced lunch counts. During the audit, we noted that the district’s process for compiling these attendance numbers involves the grant manager obtaining a report from the Business Office, which is generated from the food service platform as of a specific day. However, the district was unable to reproduce the report used to complete the Title I application and supporting documentation for the reported figures was not available for review. Plan: The District will maintain all reports used to compile attendance figures for the Title I grant. Anticipated Date of Completion: June 30, 2026 Name of Contact Person: Mark Orszula, CSBO

Finding No: 2025-003 Condition: The District does not have an adequate review process in place for meal count claims prior to submission. Claims prepared by one individual are submitted without independent verification. As a result, the district reported an incorrect lunch count for January 2025. This error appears to be isolated to January; however, it would likely have been prevented if a review process were in place. Plan: The District will implement a system in which meal count claims will have secondary approval by the CSBO. Anticipated Date of Completion: June 30, 2026 Name of Contact Person: Mark Orszula, CSBO

The District will review the work performed by the individual preparing the reports before submission

The District will implement additional internal controls to ensure that all household income is properly included in the eligibility determination process for free and reduced-price meals. The Food Service Director (or authorized designee) will perform a second-level review of all applications prior to final approval, focusing on verification that all sources of income - including income earned by students - are included in the total household calculation. The District will update its internal checklist and train staff responsible for reviewing meal applications to verify that each application is complete, income sources are clearly identified, and supporting documentation (if applicable) has been properly considered. The Food Service Director will conduct a mid-year self-audit of eligibility determinations to confirm accuracy and compliance with 7 CFR 245.6 requirements. The District will maintain documentation of reviews and training to support compliance efforts in furter audits.

12/7/2026 Cognizant or Oversight Agency for Audit, Codman Academy Charter Public School and Affiliate (the School) respectfully submits the following corrective action plan for the year ended June 30, 2025. Name and address of independent public accounting firm : AAFCPAs, Inc. 50 Washington Street Westborough, MA 01581 Audit period: July I, 2024 - June 30, 2025 The finding from the June 20, 2025 Schedule of Findings and Questioned Costs is discussed below. FINDINGS-FEDERAL AWARD PROGRAMS AUDITS 2025-001 Required Payroll Forms Recommendation: AAFCPAs recommends the School implement a standardized checklist and conduct periodic internal reviews of onboarding documentation to ensure all required forms are properly completed and retained in accordance with Federal regulations. Action Taken: As of January, 2026 the staff member responsible for staff on boarding and payroll processing is no longer employed at the School. Codman, with a new staff person in charge of these tasks has instituted a standardized checklist for on boarding, has performed a backward looking audit of employee files and will conduct internal periodic reviews for completeness and accuracy. If the Cognizant or Oversight Agency for Audit has questions regarding this plan, please tell Derrick Cielsa, Executive Direct as 617-287-0770 Sincerely yours, Derrick Ciesla Excutive Director

12/7/2026 Cognizant or Oversight Agency for Audit, Codman Academy Charter Public School and Affiliate (the School) respectfully submits the following corrective action plan for the year ended June 30, 2025. Name and address of independent public accounting firm : AAFCPAs, Inc. 50 Washington Street Westborough, MA 01581 Audit period: July I, 2024 - June 30, 2025 The finding from the June 20, 2025 Schedule of Findings and Questioned Costs is discussed below. FINDINGS-FEDERAL AWARD PROGRAMS AUDITS 2025-001 Required Payroll Forms Recommendation: AAFCPAs recommends the School implement a standardized checklist and conduct periodic internal reviews of onboarding documentation to ensure all required forms are properly completed and retained in accordance with Federal regulations. Action Taken: As of January, 2026 the staff member responsible for staff on boarding and payroll processing is no longer employed at the School. Codman, with a new staff person in charge of these tasks has instituted a standardized checklist for on boarding, has performed a backward looking audit of employee files and will conduct internal periodic reviews for completeness and accuracy. If the Cognizant or Oversight Agency for Audit has questions regarding this plan, please tell Derrick Cielsa, Executive Direct as 617-287-0770 Sincerely yours, Derrick Ciesla Excutive Director

Management has reviewed this finding and indicated it will revise its procedures to ensure corrective action is taken.

Finding Number: 2025‐001 Program Name/Assistance Listing Title: Child Nutrition Cluster Assistance Listing Numbers: 10.553, 10.555, 10.559, 10.582 Contact Person: Monique Mata, Chief Financial Officer Anticipated Completion Date: August 31, 2026 Planned Corrective Action: The District was not aware of the change in calculating indirect cost for Child Nutrition Cluster. The District will review the indirect cost calculation for the affected fiscal year and confirm the amount of overcharged indirect costs. The District will determine the appropriate method for reimbursing or adjusting the $189,745 overcharge to the Child Nutrition Program. Any required repayment or journal entry correction will be completed. The District will update its indirect cost rate guidance to exclude food service management company payments exceeding $50,000 from the indirect cost base. The District will conduct an annual internal review of indirect cost calculations to ensure continued compliance with USDA and ADE guidance. The District will maintain communication with ADE School Finance and Health & Nutrition Services to stay current on guidance updates.

Response and Corrective Action Plan: The District will annually prepare the indirect cost charged to the program based on the actual fiscal year trial balance and the federal government MTDC requirements. The calculation process will implement a procedure to consider other adjustments necessary to be in compliance. The District will provide an estimate to the Board each June to ensure proper approval of fund transfers.

Significant Deficiency in Internal Control over Financial Reporting Recommendation: We recommend the District continue to improve its processes and procedures surrounding reporting of claims meal summaries. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The District will work to develop processes and procedures to ensure reports tie to claims summaries for meal counts. Name of the contact person responsible for corrective action: Shari Thompson Planned completion date for corrective action plan: June 30, 2026.

Response and Corrective Action Plan: The District will annually prepare the indirect cost charged to the program based on the actual fiscal year trial balance. The District will provide an estimate to the Board each June to ensure proper approval of fund transfers.

FINDINGS- MAJOR FEDERAL AWARD PROGRAMS AUDIT Material Weakness U.S. Department of Education- Child Nutrition Cluster- AL 10.553 / 10.555 Finding No.: 2025-006 Condition: District failed to submit annual verification report and monthly claim reports for Child Nutrition Program Cluster in accordance to Illinois School Code. Recommendation: The District should review all reports to ensure they are submitted timely. Action Taken: The District concurs with the recommendation and completed a Corrective Action Plan with ISBE in accordance with the 3 year exception policy. District will work to ensure the Corrective Action Plan approved by ISBE is followed.

Finding Synopsis - Three vendor disbursements made under the Child Nutrition Cluster did not have the required purchase orders as required by the District's established internal control policies. Action Steps - The District will communicate with staff the importance of preparing purchase orders prior to making a purchase. We will establish a procedure in which the purchaser must review required documentation, inclusive of purchase orders, prior to making a purchase. Contact Person - Kevin Spain, Superintendent Anticipated Completion Date - December 31, 2025

Condition: Based upon single audit testing noted 4 applications approved in the wrong category: two applications that were approved as free but should have been reduced, one application that was approved reduced but should have been free, and one application that was approved reduced but should have been paid. Also noted that per ISBE exam, ISBE noted eight applications that were approved in the wrong category: 7 applications that were approved free but should have been reduced and one application that was approved free but should have been paid. Also, the ISBE exam noted two applications that were missing a valid SNAP case number. Recommendation: We recommend establishing a procedure to ensure household eligibility applications are approved in the appropriate category according the current income guidelines. Management Response: All household eligibility applications will be first taken be one employee, checked over by a second employee and then confirmed by a third employee. Anticipated Date of Completion: June 30, 2026

Recommendation: We recommend that the District review its internal controls and implement a procedure to ensure all applications for the Child Nutrition Cluster are provided to the Business Manger for review to ensure the eligibility determination is correct. Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Action Taken in Response to Finding: The Food Service Director and her assistant will ensure ALL application are reviewed by each of them, and then passed onto the Business Manager for a third review and approval. The Food Service Director will keep all applications on file. Name of Responsible Official: Tera Fritz, Business Manager Expected Completion Date: September 1, 2025

Recommendation: We recommend that the District review its internal controls and implement a procedure to ensure all reports required under the grant have a designated reviewer that is distinct from the individual responsible for preparing. Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Action Taken in Response to Finding: The Business Manager and School Food Service Director met regarding the finding and agreed that the Food Service Director will continue to gather the required claim data and enter the appropriate data into DPIs required Excel template monthly. All supporting documentation as well as the Excel documents will be emailed to the Business Manager monthly. The Business Manager will verify the numbers in the Excel documents using the supporting documentation. If the Business Manager agrees with the numbers in the Excel files, they will be uploaded to DPI as is. If any discrepancies are discovered, the Food Service Director and the Business Manager will work together to ensure the correct data is sent to DPI. Name of Responsible Official: Tera Fritz, Business Manager Expected Completion Date: September 1, 2025

Condition: Testing revealed that 1 of the 25 students tested were given the incorrect determination of free or reduced meal prices. Plan: The District should encourage all applications electronically. If a paper application is submitted, there should be multiple levels of review before approval. Anticipated Date of Completion: June 30, 2026 Name of Contact Person: Jason Brunaugh, Assistant Superintendent of Finance and Human Resources Management Response: The District will review procedures to determine if added steps are needed to ensure proper classification of manual applications.

CHILD NUTRITION CLUSTER - REPORTING Recommendation: Management should ensure their key controls are operating effectively and they should document the review and approval of all the reports. Explanation of Disagreement with Audit Findings: There is no disagreement with the audit finding. Action planned/taken in response to finding: The District will evaluate its control processes in place prior to meal claims being reported to the state for reimbursement and ensure they properly review and approve the claims being reported prior to reporting them and document that approval. The District also understands the person reviewing and approving the claims to be reported should be different from the individual compiling that amount to be reported so two individuals are involved in the process. Name of the contact person responsible for corrective action: Trisha Zajicek, Director of Finance Planned completion date for corrective action plan: June 30, 2026

2025-006 - Child Nutrition Cluster – Eligibility - The District is aware of the missing eligibility documents for the Child Nutrition program and will implement new procedures and a plan to reduce the missing documentation. Responsible Officials – Joe Dawidziak, Superintendent Anticipated Completion Date – The District will correct this in the subsequent fiscal year.

Condition During testing, auditor determined that 24 students had an incorrect eligibility status utilized for a portion of the school year. Recommendation We recommend that the District look for training opportunities for food service staff members to ensure that they have a good understanding of the program’s compliance requirements. Additionally, all students receiving free or reduced price meal benefits should be reviewed to ensure that they have a valid application or direct certification on file. Comments on the Finding The District agrees with the finding and has implemented procedures to prevent this, in the future. Actions Taken As of the date of this notice, training opportunities will be sought out to further food service staff members’ educations regarding the program compliance requirements. Eligibility for all students will be reset each year to ensure that only those who are direct certified or that have submitted an application and are eligible for free or reduced meals will receive those benefits.