Corrective Action Plans

District management will adopt sound accounting policies and establish and maintain internal controls that will initiat e, authorize, record , process and report transactions consistent with management ' s assertions embodied in the financial statements and that will safeguard District assets. The District will assess and implement corrective action(s) immediately by reviewing procedures and make changes by September 1, 2025.

Condition: Supporting documentation for the monthly food service meals provided did not align with the claims reported for reimbursement by free, reduced, and paid categories. Plan: The District will keep physical copies of reports and claims submitted. As students switched categories (free, reduced, and paid), the electronic system failed to keep that in account, leading to discrepancies. Anticipated Date of Completion: The District anticipates completion during the 2024-2025 fiscal year. Name of Contact Person: Nathan Knitt, Director of Business Services

Managements Response: Academy of Accelerated Learning, Inc. leadership will develop, along with new financial management a plan for improvement to be presented to the Board which includes a review of its internal control procedures over financial reporting to ensure controls are in place to designate the preparer and approver, to properly and timely record all accounts in accordance with generally accepted accounting principles. Academy of Accelerated Learning, Inc. will establish timelines and training for the expense approval process. Leadership and the new financial management will designate staff to align with a segregation of duties and hold staff accountable. Timeline and Responsible Position: By August 31, 2026. Board of Directors, Superintendent, and Chief Financial Officer.

Finding Synopsis: One of 40 students selected for testing received free or reduced meals without having an application on file. Action Steps: Management will establish and reinforce procedures to ensure all applications are retained (paper and digital copies). Contact Person: Kenya Austin Asst. Superintendent of Business/CSBO 847-568-7632 Anticipated Completion Date: 6/30/2025

FA 2024-001 Strengthen Controls over Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principle Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial 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: $77,285 Prior Year Finding: FA 2023-001 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 expenditures were reviewed and approved and that the School District's procurement and suspension and debarment procedures were followed. Corrective Action Plans: Berrien will look at the current procedures for expenditures and make sure that every program is following the same protocols. We have a system in place to ensure that we can check suspension and debarment. Also, we have protocols in place to make sure all contracts are current. Estimated Completion Date: 9/30/2025 Contact Person: Jamie Taylor, Finance Director Telephone: 229-686-2081 Email: jamie.taylor@berrien.k12.ga.us

Finding: 2024-027 - DEED did not comply with Federal Funding Accountability and Transparency Act reporting requirements applicable to Child Nutrition Cluster (CNC) FY 24 subawards. Questioned Costs: None Assistance Listing Number: 10.553, 10.555, 10.559, 10.582 Assistance Listing Title: CNC Views of Responsible Officials (state whether your agency agrees or disagrees with the finding; if you disagree, briefly explain why): The department partially agrees with Finding 2024-0027. While it is accurate that no FFATA reporting was accomplished for the Child Nutrition Cluster in FY2024, the department disagrees with the specific dollar amount. The methodology used for determining the dollar amount is overly simplistic and does not take each award into account, as specified in 2CFR17O.220. The methodology also excludes awards to other State agencies when 2CFR17O.300 specifically includes State entities. Corrective Action (corrective action planned): The department will continue to work to improve its ability to report timely by attempting to streamline manual determination of amounts to be reported. Completion Date (list anticipated completion date): Completion date is unknown. The department is still in the process of training the newest Finance Officer who has primary responsibility for the reporting. Due to the complexity of the reporting requirements and the limitations of the State’s financial systems it is a very manual process to determine accurate amounts to report. This manual process takes more time than knowledgeable staff have available due to other higher priority responsibilities. The system used to report also changed in Spring of 2025. Department procedures need to be overhauled again to take into account the move to SAM.gov. Agency Contact (name of person responsible for corrective action): Monigue Siverly, Division Operations Manager, Division of Administrative Services

Finding: 2024-052 - DOH’s Division of Public Assistance (DPA) did not determine or distribute benefits to school children or children in child care in accordance with the process and timeframes in the federally approved state plan. The audit identified the following deficiencies in FY 24: • The children in child care beneficiaries were not identified as required by the school year 2020—2021 state plan. • The per child benefit amount paid to the 15,697 children in child care was understated by $6.21 and 125 children were included in both the student and the child care benefit eligibility lists. • Issuance records provided by DPA’s Electronic Benefits Transfer (EBT) contractor, Fidelity National Information Services (FIS), were $795,659 more than DPA reported issuances. Furthermore, the FIS report included $28,992 in duplicate summer 2021 benefit issuances to school children. • School year 2020—2021 student beneficiaries paid in FY 24 received benefits at least two years late and the children in child care beneficiaries were paid benefits at least 20 months late. Summer of 2021 beneficiaries paid in FY24 received benefits at least 20 months late. Questioned Costs: AL 10.542: Indeterminate Assistance Listing Number: 10.542 Assistance Listing Title: Pandemic Electronic Benefit Transfer Food Benefits (P-EBT) COVID-19 Views of Responsible Officials (state whether your agency agrees or disagrees with the finding; if you disagree, briefly explain why): The department partially agrees with the finding. The Division of Public Assistance disagrees with the finding regarding issuance timelines. The division communicated with FNS regarding manual benefit issuance for Alaska expressing timelines would be affected and FNS did not request an updated timeline. Communication with FNS regarding issuance remained consistent, with no indication to alter our issuance plan. Corrective Action (corrective action planned): Shall the department agree to administer this federal program in the future, the Commissioner will allocate the resources necessary to prevent the necessity to manually administer the federal program. Completion Date (list anticipated completion date): Not applicable. This federal program is complete. Agency Contact (name of person responsible for corrective action): Pam Halloran, Assistant Commissioner

Finding: 2024-026 — Department of Education and Early Development’s (DEED) child nutrition services management authorized Summer 2021 Pandemic Electronic Benefit Transfer Food Benefits (P-EBT) benefits for ineligible children. Questioned Costs: AL 10.542: $62,816 Assistance Listing Number: 10.542 Assistance Listing Title: P-EBT COVID- 19 Views of Responsible Officials (state whether your agency agrees or disagrees with the finding; if you disagree, briefly explain why): The department agrees with Finding 2024-026. Corrective Action (corrective action planned): As the program is complete no corrective action can be taken for the Summer P-EBT program. If a new Summer EBT program is implemented, the department would work to implement a combination of standard operating procedures and automated electronic data validation processes to prevent erroneous benefit issuance. The department did not have sufficient time or resources to establish such features when implementing Pandemic EBT due to the urgent nature of the program. Completion Date (list anticipated completion date): n/a Agency Contact (name of person responsible for corrective action): Gavin Northey, Child Nutrition Programs Manager

The Organization feels that it made a good faith attempt to correct the deficiencies noted by the State Agency. On November 8, 2024, the Organization received notification that the State agency proposed to terminate the Organization’s agreement to participate in CACFP. The Organization decided not to appeal the decision. Effective December 1, 2024, the Organization ended the CACFP program and notified the day care homes that they would need to find a new sponsor.

Management of the School agrees with the findings and will coordinate with the State of Florida, Department of Agriculture the repayment of the contractually non-reimbursable use of funds.

2024-001 - Material Weakness and Noncompliance, Completeness and Accuracy of Schedule of Expenditures of Federal and State Awards (Repeat Finding 2023-001) Audit Finding: There were several adjustments to the basic financial statements, Schedule of Expenditure of Federal Awards (SEFA) and Schedule of Expenditures of State Awards (SESA) as originally provided by the Town. The SEFA and SESA balances are required to be reconciled to the basic financial statements prepared in accordance with generally accepted accounting principles in the United States (US GAAP). The Town has failed to adequately perform such reconciliation and as a result of procedures performed by RSM a number of adjustments to expenditures reported on the SEFA and SESA as well as to intergovernmental Revenues reported on the basic financial statements had to be performed. Corrective Action Taken: The Town Finance Department has placed an emphasis on educational meetings with the Board of Education within the area of receiving grants. These issues have resulted from the continual problem of employee turnover of personnel working within the areas of responsibility of grants accounting. All positions in the BOE Finance Department have now been filled, and the Director of Finance at the BOE has implemented monthly reconciliation procedures. From the Town side, the reconciliations between the GAAP financial statements and amounts reported on the SEFA and SESA will be overseen by the Town Comptroller. The Deputy Comptroller and BOE Director of Finance meet regularly to discuss updates and issues and will reconcile the June 30, 2025 reports in the first quarter of FY2026. Name and Phone # of Person Responsible for Implementation Mr. Peter Mynarski, Comptroller 203-622-2226

The Division will ensure evidence of review is maintained for the inventory worksheets. This was also reviewed during the NW Division’s Social Service conference in April 2025. Anticipated Completion Date: 10/1/25. Responsible Contact Person: Julie Luft, NW Social Services Director

The District will continue to reduce net cash resources in the Food Service Fund. Additionally, the District reduced the guaranteed profit in the 2024-2025 FSCM contract renewal.

To address the issue of meal counts not being properly taken and recorded at the point of service, SCO Family of Services is reinforcing internal controls in accordance with 7 CFR 210.8 to ensure the accuracy of meal counts prior to submitting monthly claims for reimbursement. Staff involved in meal service have received refresher training on proper point-of-service meal counting procedures, and supervisors will continue to conduct routine monitoring to verify compliance. These steps will help ensure that all meal counts are accurately recorded in real-time, supporting the integrity of reimbursement claims. To ensure accountability, the agency is currently in the process of recruting a full-time Food Service Director who will have oversight over the Child Nutrition Porgram and will be responsible for continued compliance, staff training, on-site reviews, and all documentation required by both state and federal regulations. While we will recruit to fill this poistion, an interim Food Service Director will be appointed. Our PQI department will continue to support and monitor activities as well. Proposed Implementation Date: Immediately

The District will continue to reduce net cash resources in the Food Service Fund. Additionally, the District reduced the guaranteed profit in the 2024-2025 FSCM contract renewal.

CORRECTIVE ACTION PLAN Arizona Department of Education/U.S. Department of Education Sierra Vista Unified School District No. 68 respectfully submits the following corrective action plan for the year ended June 30, 2024. Audit period: July 1, 2023 – June 30, 2024 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FINANCIAL STATEMENT AUDIT 2024-003 REPORTING Program: Child Nutrition Cluster CFDA Number: 10.533, 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: $18.50 Type of Finding: Noncompliance, significant deficiency Compliance Requirement: L. Reporting Condition/Context: For two of 3 monthly submissions tested, meal counts did not agree between the District’s records and what was reported to ADE. There was a net of 3 meals over claimed by the District. Criteria: The District must follow Uniform Guidance and ensure that meal reimbursement claims are accurately reported and adequately supported. Action planned in response to finding: The District will establish a system of internal controls to ensure meal counts reported on ADE match with District records. Planned completion date for corrective action plan: For the period ending June 30, 2025. Name of the contact person responsible for corrective action: Janet Cline, Business Office Manager, Laurel McEwan, Business Manager.

For the purpose of future audits, we will utilize a coding system for the applications we receive (i.e., the first application we receive will be coded “1”). The auditors can request a random sample based on the coding system and we will redact information on the application to protect household and student information.

FINDING 2024-004 Finding Subject: Child Nutrition Cluster - Suspension and Debarment Contact Person Responsible for Corrective Action: Heather Bontrager, Director of School Nutrition and Sheryl Graves, Purchasing Specialist Contact Phone Number: 574-533-8631 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Suspension and Debarment Verification checks will be conducted annually at the start of the new program year, or upon execution of a new vendor contract expected to exceed $25,000. 1. Verification Steps: 􀁸 Vendor List Compilation: 􀁸 The Accounts Payable Specialist will generate a list of all vendors paid from Fund 0800 in the prior fiscal year. 􀁸 Identify vendors with aggregate disbursements of $25,000 or more. 􀁸 Include new vendors anticipated to exceed $25,000 in the upcoming year based on planned purchases or contracts. 2. SAM.gov Check: 􀁸 For each vendor identified, search their legal business name or DUNS/UEI number in the SAM.gov database. 􀁸 Verify that the vendor is listed as "Active" and not debarred or suspended. 3. Documentation: 􀁸 Print or save a PDF of the SAM.gov record for each verified vendor. 􀁸 The PDF notes the date of verification and name of the staff member who completed the check. 􀁸 Maintain documentation in a central procurement or compliance folder for audit purposes. 4. Annual Certification: 􀁸 The Purchasing Specialist and Director of Nutrition Services will jointly sign an Annual Vendor Verification Certification Form confirming that all applicable vendors have been checked and meet SAM.gov requirements. 􀁸 Submit the signed form to the Business Office and retain for audit documentation. Ongoing Monitoring: For any new vendors added mid-year with expected expenditures over $25,000 or contracts amended to exceed the $25,00 threshold, repeat the above verification process before any payment is made. Anticipated Completion Date: August 2025

FINDING 2024-003 Finding Subject: Child Nutrition Cluster – Internal Controls Contact Person Responsible for Corrective Action: Heather Bontrager, Director of Nutrition and Whitney Dixon, Treasurer Contact Phone Number: 574-533-8631 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Activities Allowed or Unallowed, Allowable Costs/Cost Principles This finding was limited to payroll claims and payroll vendor disbursements and did not involve accounts payable vendor disbursements. For payroll disbursements, once payroll is processed, a distribution report is sent to the Director of Nutrition to review all employees paid from the Federal Nutrition Program (Fund 0800). The Director communicates any necessary corrections to employee distributions, which are then adjusted by the payroll specialist, if needed. During the audit period, the school corporation experienced a vacancy in the payroll specialist position. As a result, the Treasurer processed payroll and the Deputy Treasurer conducted the reviews. However, the school corporation did not obtain signatures on the payroll reports during this time. The only signed documentation was the ACH report used for the bank upload. Going forward, the school will implement the use of digital signatures whenever possible to document payroll report reviews. For payroll vendor claims, vouchers are generated from the financial system and are signed by both the payroll specialist and the Chief Financial Officer. These signed vouchers are also included on the board docket. Although this process was in place during the audit period, the school corporation did not have a fully effective internal control system to ensure that all payroll reports were consistently signed following review by the Treasurer. Anticipated Completion Date: June 2025

District Treasurer (Denise Kennedy) will adopt sound accounting policies and establish and maintain internal control that will initiate, authorize, record, process, and report transactions consistent with management’s assertions embodied in the financial statements and that will safeguard District assets during the school year 2025.

FA 2024-001 Improve Control over Employee Compensation Compliance Requirement: Allowable Costs/Cost Principle Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial 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 COVID-19-10.555 - National School Lunch Program Federal Award Number: 245GA324N1199 (Year: 2024), 225GA324N1099 (Year: 2024) Questioned Costs: $102,234 Prior Year Finding: 2023-004 Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over the employee compensation process as it relates to the Child Nutrition Cluster. Corrective Action Plans: The District is developing correction action to strengthen controls, policies, and procedures and ensure adherence through improved monitoring. Estimated Completion Date: June 30, 2026 Contact Person: Connie Walker, School Nutrition Executive Director Telephone: 678-676-1780 Email: Connie_R_Walker@dekalbschoolsga.org

The District has implemented controls to ensure that USDA donated foods is tracked and credited on future FSMC invoices. The District made journal entries from Operating to cover the $244,203 that had been originally approved verbally by CNU. We then found out this was not an approved expense from Child Nutrition and corrected the expense.

Finding caption:The District did not have adequate internal controls for ensuring compliance with federal procurement requirements. Name, address, and telephone of District contact person: Moriah Banasick, CPA Executive Director of Finance & Budget 5150 220th Ave SE Issaquah, WA 98029 (425) 837-7139 Corrective action the auditee plans to take in response to the finding: • Staff training: The District is providing targeted training on federal procurement requirements, internal controls, and accountability practices to all federal program leads and purchasing staff. This includes comprehensive orientation for new purchasing leadership to support continuity and compliance. The recent incident is being used as a case study to strengthen shared understanding and reinforce best practices across departments. • New protocols: The District is developing updated emergency procurement protocols that include required documentation, vendor outreach logs, and pre-approval processes to ensure adherence to federal and District requirements. Anticipated date to complete the corrective action: Immediate

Finding ref number: 2024-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with federal eligibility and paid lunch equity requirements. Name, address, and telephone of Fife School District contact person: Dany Wanner, Business Services Director 1720 Oak St, Milton, WA 98354 (253) 517-1000 ext 29121 Corrective action the auditee plans to take in response to the finding: The Fife School District implemented the following to Ensure Adequate Internal Controls for Compliance with Federal Eligibility: The Business Services team and Nutrition Services staff have conducted a thorough review of the process of monthly paid lunch equity and modified its procedures including developing a checklist for the process to ensure that it is completed in a timely manner, signed/dated and saved both electronically and in hard copy on a shared district server folder. The Fife School District implemented the following to Ensure Adequate Internal Controls for the annual completion of the Paid Lunch Equity Tool. The Business Services team and Nutrition Services staff have conducted a thorough review of the process of completing both the PLE tool and GL 828 reconciliation and modified its procedures to ensure that it is completed, signed and saved both electronically and in hard copy on a shared district server folder. Further, the Business Services team and Nutrition Services staff have developed a checklist for the completion of the tool and the checking of the box that indicates that we will be opting not to increase meal prices, but instead to demonstrate using the GL 828 Reconciliation (signed and dated) that we have sufficient fund balance to offset the paid lunches and not utilize Federal funds, including calendar reminders and a shared Google Drive to hold all related documents and procedures. Anticipated date to complete the corrective action: 5/16/2025

Finding ref number: 2024-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with federal eligibility and paid lunch equity requirements. Name, address, and telephone of District contact person: Marci Bannan, Director of Business Services 121 Whitesell St NE Orting, WA 98360 Corrective action the auditee plans to take in response to the finding: Eligibility: The District will document the internal controls that are in place for the monthly direct certification downloads and will print the certification download along with saving it electronically so that the files are easy to provide for future audits. Paid Lunch Equity: The District will document the internal controls that are in place for the completion of the PLE tool and ensure that the form is completed appropriately to show the continued use of nonfederal funds that are used yearly to fund the food service account fully. The District will also make sure to ‘print’ the GL 828 tab of the Fund Balance Reporting tool that is done yearly no later than November and sign it immediately after completion of the year end process to provide for the proof that the district has and continues to contribute sufficient nonfederal funds to the food service account. Anticipated date to complete the corrective action: July 31, 2025