Corrective Action Plans

2024-008 Material Weakness in Internal Control over Compliance The Child Nutrition Cluster: 10.555 – National School Lunch Program and 10.559 – Summer Food Service Program Commonwealth of Pennsylvania, Department of Education Contract Number: 359-46-477-8 Condition: As part of the reporting requirements for the CBS Food Program under the National School Lunch Program (NSLP) and Summer Food Service Program (SFSP), management is responsible for submitting the FNS 10 (NSLP) and FNS 418 (SFSP) reports within 30 days after month-end. However, management was unable to provide five (5) monthly NSLP reports and one (1) monthly SFSP report requested for audit testing. Recommendation: The Organization should establish and enforce strengthened internal controls over federal reporting to ensure that all required monthly reports (FNS 10 and FNS 418) are: (a) completed accurately, (b) submitted on time, and (c) retained in accordance with federal record retention requirements (2 CFR 200.334). Management should designate responsible personnel and implement a monitoring process to ensure compliance. Repeat Finding: No Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. Action taken in response to finding: Effective, July 1, 2024, Community Benefit Solutions no longer administers the National School Lunch Program. In the event Community Benefit Solutions should begin administering the NSLP, Community Benefit Solutions will develop and implement requisite policies and procedures to ensure proper reporting requirements including, but not limited to, completion and submission of the FNS10. Planned completion date for corrective action plan: June 30, 2025

FA-2024-003 Strengthen Controls over Expenditures Compliance Requirement: Internal Control Impact: Compliance Impact: Federal Awarding Agency: Pass-Through Entity: AL Numbers and Title: Federal Award Number: Questioned Costs: Activities Allowed or Unallowed Allowable Cost/Cost Principles Significant Deficiency Nonmaterial Noncompliance U.S. Department of Agriculture Georgia Department of Education 10.553 - School Breakfast Program 10.555 - National School Lunch Program COVID-19-10.555 - National School Lunch Program 245GA324N1199 (Year: 2024), 225GA324N1099 (Year:2024) $2,641.33 Description: A review of expenditures charged to the Child Nutrition Cluster revealed that the School District's internal control procedures were not operating to ensure that expenditures were appropriately reviewed, approved, and documented. Corrective Action Plan: A bookkeeper has been hired for the School Nutrition Program. Bookkeeper keeps alphabetical organized files for each vendor to monitor and track revenue and expenditures. The bookkeeper prepares voucher packets for payments and credits for each vendor on a monthly basis. The bookkeeper signs the voucher package for accuracy. The Nutrition Director signs the voucher package for accuracy. Records are maintained under lock and key for a period of five years. Estimated Completion Date: July 1, 2025 Contact Person: Danny Durham, Director of School Nutrition Telephone:478-994-2031 Email: danny.durham@mcschools.org Title: Director of Financial Services

FA 2024-002 Strengthen Controls over Journal Entries Compliance Requirement: Activities Allowed or Unallowed 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 Title: 10.553 – School Breakfast Program 10.555 – National School Lunch Program COVID-19-10.555 – National School Lunch Program Federal Award Number: 245GA324N1199 (Year: 2024), 225GA324N1099 (Year: 2024) Questioned Costs: Unknown Description: The policies and procedures of the School District were insufficient to ensure that journal entries made for the Child Nutrition Cluster were properly documented. Corrective Action Plan: All journal entries transferring cash from the School Nutrition Fund to the General fund will be done on a more frequent basis and include the detail of amounts used to arrive at the amount of the transfer. Estimated Completion Date: October 17, 2025 Contact Person: Danny Durham, Director of School Nutrition Telephone: 478-994-2031 Email: danny.durham@mcschools.org

FA-2024-001 Strengthen Controls over Special Reporting Compliance Requirement: Reporting Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Agriculture Pass-Through Entity: Georgia Department of Education AL Numbers and Title: 10.553 – School Breakfast Program 10.555 – National School Lunch Program COVID-19-10.555 – National School Lunch Program Federal Award Number: 245GA324N1199 (Year: 2024), 225GA324N1099 (Year: 2024) Questioned Costs: None Identified Repeat of Prior Year Finding: FA 2023-001, FA 2022-001 Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over the monthly Claims for Reimbursement process. Corrective Action Plan: Monroe County School Nutrition will print a Meal Participation Report from Primero Edge software for the school district and each school every month. The report mirrors the DE112 and DE118 forms. The software report has been approved by the Georgia Department of Education Area Coach. Breakfast and Lunch totals for each school and district will be entered for claims to complete the DE106 and DE107. Managers will print the Meal Participation Report and verify information is correct by providing a signature on the document. The report is then submitted to the Central Office for review. Edit checks in the software and both will sign off on the Meal Participation Report. Estimated Completion Date: July 1, 2025 Contact Person: Danny Durham, Director of School Nutrition Telephone: 478-994-2031 Email: danny.durham@mcschools.org

FINDING 2024-005 Finding Subject: CHILD NUTRITION CLUSTER - SPECIAL TESTS AND PROVISIONS, PAID LUNCH EQUITY Contact Person Responsible for Corrective Action: BONNIE SANDERS, Director of Food Services Contact Phone Number and Email Address: Sandersb@nlcs.k12.in.us (812) 277-3220 ext. 48014 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Paid Lunch Equity requirements and calculations (including PLE exemptions) will be calculated and completed by the Food Service Director and will then be reviewed and signed off on by the Business Director. Any additional information requested by the Business Director will be provided to the Business Director in a timely manner for use in determining the accuracy and completeness of the PLE document. Anticipated Completion Date: Immediately (December 1, 2025)

FINDING 2024-004 Finding Subject: CHILD NUTRITION CLUSTER - PROCUREMENT, SUSPENSION AND DEBARMENT Contact Person Responsible for Corrective Action: BONNIE SANDERS, Director of Food Services Contact Phone Number and Email Address: Sandersb@nlcs.k12.in.us (812) 277-3220 ext. 48014 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The school corporation has a Procurement Plan which includes policies and procedures for procurement and also includes language around suspension and debarment; however, it does not specify purchases or contracts equal to or greater than $25,000. All purchases $25,000 or greater will involve the following process - (1) checking SAM.gov to see if there are any exclusions, (2) require Vendor supply certification that they have not been suspended or debarred OR clause will be added to agreement or contract signed by Vendor as certification. Internal controls will consist of the Food Service Director or other school corporation staff initiating the process and documentation checked by their Supervisor and the Account Payable department. A monetary value will be added to the language in the existing Procurement Plan (policies and procedures) involving the requirement for checking exclusions with SAM.gov and getting certification from the Vendor or contractual agreement with the vendor that they are not suspended or disbarred. Anticipated Completion Date: March 1, 2026 (Procurement Plan revision will need Board approval). Checking SAM.gov and adding clauses to contracts as necessary will begin immediately, December 1, 2025.

FINDING 2024-003 Finding Subject: CHILD NUTRITION CLUSTER - ACTIVITIES ALLOWED OR UNALLOWED, ALLOWABLE COSTS / COST PRINCIPLES Contact Person Responsible for Corrective Action: BONNIE SANDERS, Director of Food Services Contact Phone Number and Email Address: Sandersb@nlcs.k12.in.us (812) 277-3220 ext. 48014 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: All payments and expenditures coming out of the Food Service Fund (Fund 800) will be documented and accompanied by supporting additional documents detailing the reason and application of the funding. All payments will be accompanied by vouchers signed by 2 parties (the requestor and their supervisor), as well as an invoice and, if applicable, quote for merchandise or services. In addition, the Accounts Payable staff will also review these documents prior to signature by the Supervisor. Student meal account reimbursements will also be handled in this way, ensuring the appropriate account, Prepaid Food Account (Fund 8400), is the account these funds will be withdrawn from. Stipend requests will be in writing and approved by the Business Director and the School Board prior to being processed by payroll. This will be documented in writing along with any payment documentation. Anticipated Completion Date: Immediately (December 1, 2025)

CHILD NUTRITION CLUSTER – REPORTING U.S. Department of Agriculture Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.556, 10.559, 10.582 Passed Through Minnesota Department of Education Pass Through Number: 10.CNC Award Period: July 1, 2023 – June 30, 2024 Recommendation: We recommend that the district ensures all changes and adjustments are communicated to the accountant who performs claim submissions. When the Nutrition Service Assistant Director’s review results in additional adjustments within PrimeroEdge, the District should only make those changes before the CLiCs cutoff date to prevent differences between client records in PrimeroEdge and CLICS reporting. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: The District will work on educating all of the personnel involved in the reporting processes to ensure the compliance requirements are fully understood and a proper review of all reporting methods will be performed. This will be implemented by December 31, 2025, and the School Board will be responsible for monitoring the status. Name of the contact person responsible for corrective action: Tom Sager, Executive Chief of Financial Services Planned completion date for corrective action plan: December 31, 2025

CHILD NUTRITION CLUSTER – SUSPENSION AND DEBARMENT U.S. Department of Agriculture Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.556, 10.559, 10.582 Passed Through Minnesota Department of Education Pass Through Number: 10.CNC Award Period: July 1, 2023 – June 30, 2024 Recommendation: We recommend the District formalizes their suspension & debarment procedures in a policy and ensure they check suspension & debarment for all vendors prior to entering into a covered transaction. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: The District will work on educating all of the personnel involved in the procurement processes to ensure the compliance requirements are fully understood and a proper review of all procurements and procurement methods will be performed. This will be implemented by December 31, 2025, and the School Board will be responsible for monitoring the status. Name of the contact person responsible for corrective action: Tom Sager, Executive Chief of Financial Services Planned completion date for corrective action plan: December 31, 2025

Views of Auditee and Corrective Actions: GDOE agrees with the finding. Plan of action and completion date: The Food and Nutrition Services Management Division (FNSMD) will implement an internal calendar reminder to ensure timely notification to School Districts and the annual upload of district-wide eligibility information for the Community Eligibility Provision (CEP) to the FNSMD and GDOE websites. Additionally, FNSMD will implement an internal process to conduct the Direct Certification Matching activity to determine student eligibility for free school meals (Lunch/Breakfast). This process will include matching student data with lists from the Department of Public Health & Social Services (DPHSS) for SNAP (Food Stamps), TANF, FDPIR, Medicaid, Foster Care, Homelessness, or Migrant status. All Direct Certification Matching activities will be completed by April 1st of each year. Plan to monitor and responsible officials: The FNSMD Administrator, Anthony S. Monforte, and FNSMD Program Coordinator, Franklin J. Cruz, will be responsible for implementation and ongoing execution of corrective actions. Corrective actions will be implemented by March 31, 2026.

Effective immediately, Berne Union will require PaySchools to provide its policies and procedures governing the eligibility determination process for free, reduced, and paid meal status. These documents will be reviewed to ensure compliance with federal standards for the Free and Reduced-Price Lunch Program.

FA 2024-001 Improve Controls over Procurement Compliance Requirement: Internal Control Impact: Compliance Impact: Federal Awarding Agency: Pass-Through Entity: AL Numbers and Titles: Federal Award Numbers: Questioned Costs: Procurement and Suspension and Debarment Material Weakness Material Noncompliance U.S. Department of Agriculture Georgia Department of Education 10.553 - School Breakfast Program 10.555 - National School Lunch Program COVID-19 - 10.555 - National School Lunch Program 10.582 - Fresh Fruit and Vegetable Program 245GA324N1199 (Year: 2024) 245GA324L1603 (Year: 2024) 245GA324l1603 (Year: 2024) $5,380.74 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 procedures were followed. Corrective Action Plans: Implement a standardized procurement checklist that must be completed. Procurements will require two levels of review (program level review by child nutrition staff and District level) to confirm compliance before processing payments. District will provide staff training to ensure federal procurement regulations, district procurement policies along with documentation and recordkeeping requirements are being met. The finance department will conduct quarterly internal reviews of Child Nutrition expenditures to verify compliance. Estimated Completion Date: November 10, 2025 Contact Person: Jon Erik Jones, Superintendent Telephone: 229.321-1487 Email:jones@quitman.ki2.ga.us

VIEWS OF RESPONSIBLE OFFICIALS In response to the finding regarding the untimely submission of the Federal Funding Accountability and Transparency Act (FFATA) reports, the Puerto Rico Department of Education (PRDE) acknowledges the observation made by the auditors. While the audit notes that program staff were unaware of the FFATA reporting requirement, we would like to clarify that the staff was aware of the requirement; however, the program was in the process of gathering the necessary data and ensuring a full understanding of the report components and submission procedures in order to comply accurately with the federal guidelines. Nevertheless, PRDE recognizes that this does not justify the delay in the submission of the reports. To prevent future occurrences, PRDE is currently developing and scheduling a comprehensive training for all program and fiscal staff involved in the Child Nutrition Cluster. This training will cover the FFATA reporting requirements, data collection procedures, submission timelines, and documentation standards to ensure full and timely compliance with the reporting process moving forward. PRDE will continue strengthening internal controls and monitoring procedures to ensure that all applicable FFATA reports are submitted accurately and on time in the FSRS portal. IMPLEMENTATION DATE December 30, 2025 RESPONSIBLE PERSON Odalis Menard AESAN Director Lourdes García Santiago AESAN Sub-Director

VIEWS OF RESPONSIBLE OFFICIALS Management agrees with the audit finding and has implemented a comprehensive corrective action plan to address payroll processing errors, strengthen internal controls, and ensure accurate and timely payments. As part of PRDE’s Fiscal Plan of 2020–2021, the Department launched the official integration project between the Time, Attendance, and Leave (TAL) system and the Payroll (RHUM) system. This integration ensures that payroll disbursements are made only after the employee’s attendance has been validated through the TAL system. Employees are required to record their attendance using biometric verification or have an authorized leave properly documented and approved by their supervisor before receiving payment. If attendance is not validated, the system automatically issues a notification and applies the necessary adjustment. This project, initiated in November 2020 with the collaboration of the Puerto Rico Fiscal Oversight and Management Board (FOMB), MS Consulting, the Department of the Treasury (Hacienda), the Financial Advisory Authority (AAFAF), and the Puerto Rico Innovation and Technology Service (PRITS), was fully integrated by February 2021. As a result, PRDE has significantly reduced overpayments, duplicate payments, and other payroll inconsistencies. To reinforce this effort, PRDE issued a new Time and Attendance Policy on December 7, 2021, later updated on April 11, 2022, which clearly defines employee responsibilities, authorized leaves, disciplinary procedures, and supervisor accountability. Under this policy, employees and supervisors are required to follow strict timekeeping procedures, and noncompliance triggers automatic system notifications and salary adjustments. The PRDE’s Time and Attendance staff continues to monitor and maintain compliance through: i. Ongoing training sessions for PRDE personnel; ii. System dashboards tracking attendance behaviors; iii. Issuance of notifications and payroll adjustments as required; and iv. Regular follow-up and evaluation activities. Additionally, PRDE’s Finance Office implemented a reconciliation process that integrates data from TAL, RHUM, and SIFDE, ensuring that payroll expenditures align with validated attendance records. The system now performs cross-checks before submission to the Treasury Department, preventing disbursements for unverified time. These combined measures—technological integration, policy enforcement, staff training, and reconciliation controls—have strengthened payroll accuracy, reduced the risk of overpayments, and improved financial accountability across the Department. IMPLEMENTATION DATE Done RESPONSIBLE PERSON Evelyn Rodríguez Cardé Finance Office Director Jullymar Octtaviani Vega Sub-Secretary of Administration

SIGNIFICANT DEFICIENCY 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 2024-006 - 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 – Peter Olson-Skog, the District’s Superintendent. Planned Completion Date – December 31, 2025. Disagreement With or Explanation of Finding – The District agrees with this finding. Plan to Monitor – Peter Olson-Skog, the District’s Superintendent, 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.

Name of Contact Person: Mr. Mitch Nanney, Superintendent. Recommendation: We recommend the District verify a vendor's status by checking the System for Award Management (SAM) maintained by the General Services Administration before making purchases expected to exceed $25,000 and to keep all supporting documentation of the verification of the vendor's status. Corrective Action: We will verify all vendor's status using the System for Award Management (SAM) maintained by the General Services Administration before making purchases expected to exceed $25,000 and keep all supporting documentation. Proposed Completion Date: Immediately.n

A procedure has been created for this and will be implemented and looked at 1/4ly so funds can be spent down during the school year. Immediate steps were taken to do a spenddown plan and the food serviced fund was used for the program to bring down the fund balance to less than the three-month average expenditures.

Management Response/Corrective Action Plan: Effective November 2024, a new procedure is in place to verify school lunch counts are reported accurately. The School Nutrition Director documents data in spreadsheets and uses this for completing reimbursement requests. The Business Manager also reviews the provided spreadsheets before approving claims for reimbursement.

FA 2024-001 Strengthen Controls over Expenditures 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 Assistance Listing Number and Title: 10.553 - School Breakfast Program 10.555 - National School Lunch Program Federal Award Number: 225GA324N1099 (Year: 2024), 245GA324N1199 (Year: 2024) Questioned Costs: $46,878 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 procedures were followed. Corrective Action Plans: Responsible Parties: Superintendent, School Nutrition Manager, To address this finding and prevent recurrence, the Superintendent and School Nutrition Manager will implement the following corrective measures in accordance with Terrell County Board of Education policy and applicable federal/state guidelines: 1. Staff Training-Provide training for School Nutrition staff on federal procurement requirements, the district's Procurement Plan, and Board policy related to financial management, procurement, and record retention. Training will be documented and updated annually or as requirements or Board policies are revised. 2. Process Monitoring-Establish written procedures aligned with board-approved procurement policies to ensure all required bids and quotes are obtained, documented, and retained. Maintain both electronic and hard-copy procurement files, with oversight responsibilities clearly assigned. 3. Internal Compliance Reviews-Conduct quarterly internal reviews between the Schol Nutrition Department and Finance to verify procurement documentation and adherence to Board policy and the Procurement Plan. Provide review summaries to the Superintendent and report systemic issues to the Board, if necessary. 4. Accountability Measures-Incorporate procurement documentation and retain responsibilities into departmental expectations, evaluations, and supervisory reviews, consistent with Board policies on accountability and internal controls. Noncompliance with documentation procedures will be addressed under established Board personnel and accountability policies. Estimated Completion Date: June 30, 2026 Contact Person: Shereca R. Harvey, Superintendent Telephone: (229) 995-4425 Email: srharvey@terrell.k12.ga.us

No. 2024-004 Subject: Reporting - Significant deficiency in internal control over compliance Name of Contact Person: Ingmar Berg, CFO Phone Number: (480) 270-5438 x1091 Anticipated Completion Date: June 30, 2025 Corrective Action: Management will implement internal controls related to documentation of approval for all monthly NSLP claims for reimbursement prior to submission. We will establish a formalized procedure to ensure that all monthly claims for reimbursement undergo documented management review and approval before submission. This procedure will clearly define the review process and designate responsible personnel for each step to maintain accountability. All reviewed and approved claims will be accompanied by signed documentation as evidence of compliance. All Food Service personnel involved in the reimbursement submission process will receive training on the new procedure to ensure understanding and adherence to the documentation requirements.

State of Missouri Single Audit Corrective Action Plan Year Ended June 30, 2024 State Agency: MO Department of Elementary and Secondary Education (DESE) Audit Finding Number: 2024-014 - DESE FFATA Reporting Name of the contact person responsible for corrective action: Shelley Woods Anticipated completion date for corrective action: 7/1/2025 Corrective action planned is as follows: The agency agrees with the auditor's finding. DESE has changed internal procedures to ensure FFATA reporting follows applicable requirements. DESE is designating a Federal Compliance Coordinator to submit all FFATA reporting as opposed to each section Fiscal Liaison uploading the report. The terms and conditions for each grant award will be reviewed by the Federal Compliance Coordinator to determine if FFATA is applicable, and then the Federal Compliance Coordinator will work the Fiscal Liaison to collect and report the information required under FFATA.

Management concurs with the findings. The closing process will be improved; physical inventory will be taking and improvements for documentation will be made.

On behalf of the finding 24-03 the following changes will be implemented: The Food Program Directors will ensure that the separation of Food Purchases will be reinforced. 1) Establish a strict policy mandating that all program food purchases for the USDA Nutrition Cluster (Breakfast and Lunch programs/ CACFP) be processed separately for each program. Orders for Breakfast, Lunch and Supper will be on separate invoices. 2) All food program invoices will be evaluated by Food Program Director to ensure the correct allocation by program and forwarded to bookkeeper to allow the proper program disbursement. 3) All program foods invoices will be paid separately using program bank accounts. The enforcement of the procedure of business credit card purchases will be in effect starting October 2025.

The District will train food service administrative staff regarding adequate internal controls involving monthly downloads of the Department of Social and Health Services DSHS direct certifications, including training at least 2 administrative staff members in order to ensure compliance in the absence of the primary staff member performing the necessary internal control. Should Supply Chain Assistance funds become available in the future, the District will retrain food service administrative staff regarding the tracking of qualifying food products to reconcile to the funds received, and complete that tracking prior to the end of the qualifying fiscal year.

Finding 2024-002 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 of TEFAP 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 the USDA has with the vendors supplying the items. We report both the 5000 and 4000 numbers to GA DHS/SC Dept of Ag upon receipt of the goods. If either or both numbers are missing from the BOL, we note that in the 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: 8/14/25