Corrective Action Plans

Condition: The School District's internal controls did not effectively identify all of the required components necessary in formal solicitation documents for food service/cost reimbursable contracts and when using a third party entity (e.g., consortium) and did not utilize competitive procurement methods. Planned Corrective Action: The School District is revising its food service procurement documents to explicitly include all required contract provisions under the Uniform Guidance. The School District is also incorporating recent interpretations and guidance from the U.S. Department of Agriculture (USDA), as communicated through MDE, particularly regarding cooperative purchasing and pricing structures for federal compliance. These actions are intended to strengthen the procurement controls to ensure all future food service contracts meet the compliance requirements of the Uniform Guidance and USDA regulations. Contact person responsible for corrective action: Danielle Jacobs, Director of Business Services Anticipated Completion Date: 8/15/2025

Federal Award - Finding Number: 2025-002 Responsible Person: Director of Finance Condition: The district charged to the food service fund the cost of an asset that was not included on the approved equipment list from Michigan Department of Education and did not obtain approval from Michigan Department of Education prior to purchase. Corrective Action Plan: All food service fund asset purchases made going forward will be compared to the approved equipment list or approved by the Michigan Department of Education prior to purchase. Anticipated Correction Date: Immediate and Ongoing

Finding 2025-002 Approval of Free and Reduced Meal Applications 1. Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. 2. Actions Planned in Response to Finding The District will adopt policies and procedures to perform thorough reviews of the applications. 3. Official Responsible Mr. Kurt Stumpf, Superintendent, is the official responsible for ensuring corrective action. 4. Planned Completion Date June 30, 2026. 5. Plan to Monitor Completion The Board of Education will be monitoring this Corrective Action Plan.

Finding 2025-001 School Nutrition Program Meal Claims 1. Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. 2. Actions Planned in Response to Finding The District will evaluate current procedures for accurately monitoring, recording, and reporting the number and type of meals served. 3. Official Responsible Mr. Kurt Stumpf, Superintendent, is the official responsible for ensuring corrective action. 4. Planned Completion Date June 30, 2026. 5. Plan to Monitor Completion The Board of Education will be monitoring this Corrective Action Plan.

Condition: The Academy does not currently have a control in place where a review of the meal counts entered into the Michigan Nutrition Data (MiND) system takes place, which could result in incorrect reporting of the number of free and reduced priced meals, which could result in the Academy being reimbursed an incorrect amount by the Michigan Department of Education. Planned Corrective Action: The Academy will implement proper procedures and controls to ensure meal counts are reviewed and agree to underlying records of meals served prior to submitting meal claims. Contact person responsible for corrective action: Molly Brown Anticipated Completion Date: 12/01/2025

Condition: The Academy does not currently have a control in place where a review of the meal counts entered into the Michigan Nutrition Data (MiND) system takes place, which could result in incorrect reporting of the number of free and reduced priced meals, which could result in the Academy being reimbursed an incorrect amount by the Michigan Department of Education. Planned Corrective Action: The Academy will implement proper procedures and controls to ensure meal counts are reviewed and agree to underlying records of meals served prior to submitting meal claims. Contact person responsible for corrective action: Molly Brown Anticipated Completion Date: 12/01/2025

Condition: The Academy does not currently have a control in place where a review of the meal counts entered into the Michigan Nutrition Data (MiND) system takes place, which could result in incorrect reporting of the number of free and reduced priced meals, which could result in the Academy being reimbursed an incorrect amount by the Michigan Department of Education. Planned Corrective Action: The Academy will implement proper procedures and controls to ensure meal counts are reviewed and agree to underlying records of meals served prior to submitting meal claims. Contact person responsible for corrective action: Molly Brown Anticipated Completion Date: 12/01/2025

Condition: The Academy does not currently have a control in place where a review of the meal counts entered into the Michigan Nutrition Data (MiND) system takes place, which could result in incorrect reporting of the number of free and reduced priced meals, which could result in the Academy being reimbursed an incorrect amount by the Michigan Department of Education. Planned Corrective Action: The Academy will implement proper procedures and controls to ensure meal counts are reviewed and agree to underlying records of meals served prior to submitting meal claims. Contact person responsible for corrective action: Molly Brown Anticipated Completion Date: 12/01/2025

Criteria: According to 2CFR 200.431(c) the recipient or subrecipient must allocate fringe benefits to Federal awards and all other activities in a manner consistent with the pattern of benefits attributable to the individuals or group(s) of employees whose salaries and wages are chargeable to such Federal awards and other activities, and charged as direct or indirect costs following the recipient's or subrecipient's accounting practices. Condition: The School over-allocated health insurance benefits to the Child Nutrition Cluster.Cause: The School was using an outdated allocation formula that did not reflect changes to personnel in the program. Effect: The School over-allocated health insurance benefits to the Child Nutrition Cluster. Recommendation: We recommend that the School review fringe benefit allocations at the start of each school year, and then at least quarterly throughout the year to monitor for personnel changes that may impact allocations so that allocations may be adjusted timely. Action: As of the date of this exit conference, we will adopt the recommendation. Health benefits will no longer be allocated to the Child Nutrition Cluster. All other fringe benefit costs will be directly allocated.

The Academy has already resolved this process, since we did get the current Food Service contract for the 25-26 school year approved by the Board in August 2025 and will continue to do so every year going forward.

The Academy has now put a control in place in which the Business Manager at each district reviews the monthly reimbursement request to ensure it agrees to the daily counts' spreadsheet.

The Academy has put in place a review process within the Food Services Team to ensure future deadlines are met.

The Academy has already resolved this process, since we did get the current Food Service contract for the 25-26 school year approved by the Board in August 2025 and will continue to do so every year going forward.

The Academy has now put a control in place in which the Business Manager at each district reviews the monthly reimbursement request to ensure it agrees to the daily counts' spreadsheet.

The Academy has already resolved this process, since we did get the current Food Service contract for the 25-26 school year approved by the Board in August 2025 and will continue to do so every year going forward.

The Academy has now put a control in place in which the Business Manager at each district reviews the monthly reimbursement request to ensure it agrees to the daily counts' spreadsheet.

Effective July 1, 2025, The Executive Director of Business & Human Resources, Kevin J. Polunci will review and verify the eligibility of vendors that participate in Federal assistance programs on an annual basis. The District will review the eligibility of potential vendors that participate in Federal assistance programs and compare invoices to bidding/contracts prior to payments.

THREE OAKS PUBLIC SCHOOL ACADEMY CORRECTIVE ACTION PLAN YEAR ENDED JUNE 30, 2025 Three Oaks Public School Academy respectfully submits the following corrective action plan for the year ended June 30, 2025. Auditor: Maner Costerisan 2425 E. Grand River Avenue, Suite 1 Lansing, MI 48912 Audit Period Year ended June 30, 2025 Academy Contact Person: Robert Holst, Finance Director Finding 2025-001 – Significant deficiency Recommendation: The Academy should consistently utilize a point-of-sale system to track and claim the number of meals served. The Academy should also maintain documented reviewed records on the meal counts. Action to be Taken: The Academy concurs with the facts of this finding and has implemented procedures to prevent this in the future.

SUSPENSION AND DEBARMENT Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553 and 10.555 Award Period: Year Ended June 30, 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance Recommendation: We recommend the District implement additional procedures to ensure suspension and debarment documentation is retained. 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 evaluate their policies and procedures and retain documentation of their review. Official Responsible for Ensuring CAP: Todd Tetzlaff, Director of Finance and Human Resources. Planned Completion Date for CAP: June 30, 2026.

Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553 and 10.555 Federal Award Identification Number and Year: 212MN061N1199 - 2025 Pass-Through Agency: Minnesota Department of Education Pass-Through Number(s): 1-2174-000 Award Period: July 1, 2024 - June 30, 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance Recommendation: We recommend the District review and approve the CLiCS meals counts reports timely and before they are submitted. Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Action Taken in Response to Finding: The District will ensure that all CLiCS submissions are reviewed and approved before submission. Name of the Contact Person Responsible for Corrective Action Plan: Jolene Bengtson, Business Manager Planned Completion Date for Corrective Action Plan: June 30, 2026

Finding 2025-004 School Nutrition Program Meal Claims 1. Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. 2. Actions Planned in Response to Finding The District will evaluate current procedures for accurately monitoring, recording, and reporting the number and type of meals served. 3. Official Responsible Mr. Michael Malmberg, Superintendent, is the official responsible for ensuring corrective action. 4. Planned Completion Date June 30, 2026 5. Plan to Monitor Completion The Board of Directors will be monitoring this Corrective Action Plan.

CAP: The District will establish processes and procedures to ensure compliance with executive orders 12549 and 12689, and 2 CFR Part 180 regarding disbarred vendors. Date: June 30, 2025 Who: Michael Cavanaugh, Business Administrator

Recommendation: We recommend the District implement additional procedures to ensure suspension and debarment documentation is retained. 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 evaluate their policies and procedures and retain documentation of their review. Official Responsible for Ensuring CAP: Heather Hipp, Business Manager Planned Completion Date for CAP: June 30, 2026

Admin Offices 4301 S Cowan Rd Muncie, IN 47302 765-747-5222 office CORRECTIVE ACTION PLAN OF CURRENT AUDIT FINDINGS June 30, 2025 Information on the federal program: Subject: Child Nutrition Cluster - Internal Controls 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): FY2025 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Finding: Significant Deficiency Context: During testing of allowable activities and costs, it was observed that the School Corporation allocated payroll and benefit expenses to the school lunch fund for the employee overseeing the food service management company. Five payroll transactions totaling $5,476 were selected for testing. For each transaction tested, the School Corporation allocated 18% of the employee’s time to the school lunch fund. Although the employee completed an annual self-certification estimating time spent on food service duties, there was no detailed time and effort log to support actual hours worked. Additionally, no internal control existed to provide a documented secondary review of the self-certification for accuracy and completeness. Contact Person Responsible for Corrective Action: Brad DeRome Contact Phone Number: 765-747-5222 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The School Corporation will no longer charge any payroll and benefit expenses to the school lunch fund. Anticipated Completion Date: July 1, 2025.

1. Correcting Plan Food and Nutrition Service Coordinator will review applications and supporting documentation for completion and eligibility accuracy. 2. Explanation of Disagreement with the Audit Finding There is essentially no disagreement with the finding. 3. Official Responsible for Insuring CAP The Food and Nutrition Service Coordinator. 4. Planned Completion Date for CAP The CAP was implemented immediately during audit fieldwork performed in October 2025. 5. Plan to Monitor Completion of CAP The Food and Nutrition Service Coordinator will continually review applications and supporting documentation for completion and eligibility accuracy. Any issues noted will be communicated to appropriate staff and fixed immediately.