Corrective Action Plans

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Winlock School District No. 232 September 1, 2023 through August 31, 2024 This schedule presents the corrective action planned by the District for findings reported in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Finding ref number: 2024-001 Finding caption: The District did not have adequate internal controls for ensuring accurate reporting of its financial statements. Name, address, and telephone of District contact person: Michelle Jeffries, Superintendent PO BOX 128 Winlock WA 98596 Corrective action the auditee plans to take in response to the finding: (If the auditee does not concur with the finding, the auditee must list the reasons for non-concurrence). The District will strengthen internal controls over financial reporting to ensure financial statements are accurate. Specifically, the District will: • Complete a more thorough secondary review of all financial statements and SEFA for reasonableness, completeness and accuracy before submitting them for audit • Maintain supporting documentation the District uses to prepare the financial statements • Ensure funds the District reports on the financial statements agree with underlying accounting records Anticipated date to complete the corrective action: July 1, 2025 Finding ref number: 2024-002 Finding caption: The District did not have adequate internal controls and did not comply with federal suspension and debarment requirements. Name, address, and telephone of District contact person: Michelle Jeffries, Superintendent PO BOX 128 Winlock WA 98596 Corrective action the auditee plans to take in response to the finding: (If the auditee does not concur with the finding, the auditee must list the reasons for non-concurrence). The District will strengthen internal controls to verify all contractors it pays $25,000 or more, all or in part with federal funds, are not suspended or debarred from participating in federal programs, and maintains documentation demonstrating this verification. Anticipated date to complete the corrective action: July 1, 2025

Finding ref number: 2024-001 Finding caption: The District did not have adequate internal controls and did not comply with federal procurement requirements. Name, address, and telephone of District contact person: Audrey Slabbert, Director of Business and Finance. PO Box 778 Long Beach, WA 98631 (360) 642-1206 Corrective action the auditee plans to take in response to the finding: The District will designate the Food Service Director to provide the Finance Director with all Food Service contracts, and The Finance Director will check each applicable vendor’s status on the System for Award Management (SAM) at https://sam.gov prior to contract execution. The Finance Director will maintain a printout of the SAM.gov verification results in procurement records. The Finance Director will provide the Superintendent with a copy of the relevant contracts for her approval. Anticipated date to complete the corrective action: June 2, 2025

Global Community Charter School recognizes the management deficiencies cited by MMB+CO as finding 2024-001 in the FY2024 Audited Financial Statements. The following procedures have been implemented to mitigate and/or eliminate further process deficiencies. ● Beginning in August 2024, all participating operations staff were retrained and given clarity on the importance of accurate and timely count management. ● At the elementary and middle school, one operations person has been designated as responsible for the monthly count. This individual coordinates all personnel involved in the process and is further responsible for ensuring coverage and accuracy when personnel are shifted around or absent. ● This designated individual also meets with the food preparer weekly to check the provider’s meal count against the school's. ● The designated individual also annotates the weekly/monthly count on a digital worksheet that compares the food providers' count against the schools. ● The Director of Finance audits the worksheet monthly for “reasonability”, accuracy, and consistency. ● Post-audit, the CFO does a final review. If anything anomalous or inconsistent is found, the team will meet to confirm if the changes reflect actual student utilization. If no changes are required, the CFO takes the monthly data and uploads it to the template provided by the NSLP consultant who submits the voucher. In addition to the process outlined above, an ongoing review of student utilization is being conducted to reduce the waste and cost to the school created when too many meals are produced and students do not consume them. This process should allow meals produced to mirror consumption going forward. We implemented this process in mid-August and expect positive realignment and consistency from November 2024 onward.

The Darrington School District acknowledges that we did not retain documentation to demonstrate compliance with federal procurement requirements for the child nutrition cluster. However, we dispute the auditors’ assertion that we did not comply with federal procurement requirements. The district sought quotes from at least three vendors via phone calls per our policy. Unfortunately, several vendors were either unable to provide the products specified in our request for quotes or do not deliver to our area, and therefore did not provide written quotes. The district documented the quotes from responsive vendors. In the future, the district will document all efforts to obtain quotes from both responsive and nonresponsive vendors. Anticipated date to complete the corrective action: 8/15/2025

Finding ref number: 2024-002 Finding caption: The District did not have adequate internal controls and did not comply with federal suspension and debarment requirements. Name, address, and telephone of District contact person: Scott McDaniel, Executive Director of Business and Operations or Lara Christopherson, Assistant Director of Business and Payroll P.O. Box 8 Silverdale, WA 98383 (360) 662-1650 Corrective action the auditee plans to take in response to the finding: CKSD will provide annual training for all staff tied to federal funding purchasing. This will include conducting SAM.gov checks on any purchase of goods or services that may meet or exceed $25,000 in total cost prior to entering into contracted services or the purchase of goods. CKSD will create a training video, made available under Business Office Tutorial Videos on staff intranet, on how to conduct an entity search for a suspension and debarment check on the SAM.gov website, as a point of reference for staff members. CKSD will ensure staff doing any federal purchasing have a SAM.gov login. CKSD will require suspension and debarment records to be included with contracts using federal funds when routed for approval. CKSD will implement a process for retaining suspension and debarment check records. This may include attaching a copy of the SAM.gov check to purchase order or credit card reconciliations report. CKSD will explore alternative purchasing cooperatives, to utilize, that provide direct access to all bid/contract documents for real time review and evaluation of compliancy. Anticipated date to complete the corrective action: 09/30/2025

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION – CHILD NUTRITION CLUSTER (FEDERAL ALN 10.553 AND 10.555) 2024-004 Internal Control Over Compliance With Federal Reimbursement Submission Deadline Requirements Finding Summary 7 CFR § 210.8 requires the Academy to establish and maintain effective internal control over compliance with requirements applicable to federal programs, including reimbursement submission requirements applicable to the child nutrition federal program. During our audit, we noted the Academy did not have sufficient controls in place within its child nutrition cluster federal program to ensure compliance with federal submission requirements related to claims for reimbursement. Corrective Action Plan Actions Planned – The Academy is in the process of reviewing and updating its policies and procedures relating to reimbursement submission for its federal programs to ensure compliance with the Uniform Guidance in the future. The review of procedures will also include steps to ensure that Academy personnel are following the requirements of the Uniform Guidance related to reimbursement submission requirements. Official Responsible – The Academy's Executive Director, Farhiya Einte. Planned Completion Date – June 30, 2025. Disagreement With or Explanation of Finding – The Academy agrees with this finding. Plan to Monitor – The Academy’s Executive Director, Farhiya Einte, will assure appropriate internal controls and procedures are updated and in place to ensure compliance with reimbursement submission requirements.

Contact Person Evan Peltier Planned Corrective Action Dunseith Public School Dist. #1 will implement the recommendation from Brady Martz. Planned Completion Date The planned completion date is June 30, 2025.

Contact Person Evan Peltier Planned Corrective Action Dunseith Public School Dist. #1 will implement the recommendation from Brady Martz. Planned Completion Date The planned completion date is June 30, 2025.

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Finley School District No. 53 September 1, 2023, through August 31, 2024 This schedule presents the corrective action the District is planning to take for findings included in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Finding ref number: 2024-001 Finding caption: The District did not have adequate internal controls to ensure compliance with procurement requirements related to piggybacking. Name, address, and telephone of District contact person: Terri McGaughey, Business Manager 224606 E Game Farm Rd, Kennewick, WA 99337 (509) 586-3217 Corrective action the auditee plans to take in response to the finding: (If the auditee does not concur with the finding, the auditee must list the reasons for disagreement). The Finley School District has put in place internal controls to ensure compliance with procurement requirements related to piggybacking: The Food Service Director will compare invoices to the monthly price list to ensure contract pricing is used and initial invoices once reviewed. If there are discrepancies, the Food Service Director will contact the vendor for corrections. Quarterly, the Business Manager will select a sample of invoices to review for compliance. Anticipated date to complete the corrective action: May 1, 2025

In response to this finding, the Culinary Services department under the guidance of the Operations team in SPS has made the following adjustments and changes to business practices: 1. The PLE tool has been formally integrated into the annual budgeting process to ensure routine compliance with this guidance and accurate financial planning. 2. If a price increase is deemed necessary, it will undergo a thorough review and approval through the SPS board governance process. This will include a landscape review of meal prices in other districts in the Puget Sound region as well as similarly scaled districts nationally. This structured approach guarantees alignment with strategic objectives while maintaining transparency and accountability. 3. As of May 2025, the Culinary Services department under the direction of the Operations department will be taking action on a price increase for school lunches beginning for the 2025-26 school year with annual reviews scheduled for subsequent years.

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Castle Rock School District No. 401 September 1, 2023 through August 31, 2024 This schedule presents the corrective action the District is planning to take for findings included in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Finding ref number: 2024-002 Finding caption: The District did not have adequate internal controls and did not comply with federal procurement and suspension and debarment requirements. Name, address, and telephone of District contact person: Gloria Dupree, CSBS, CSBO Director of Fiscal Services Castle Rock School District 600 Huntington Ave S Castle Rock, WA 98611 Phone: 360.501.3132 Corrective action the auditee plans to take in response to the finding: (If the auditee does not concur with the finding, the auditee must list the reasons for disagreement). Conduct mandatory training for all staff involved in procurement on federal regulations, including how to check vendors against the System for Award Management (SAM.gov) for suspension or debarment. Establish a procurement review checklist to be completed by the vendor and staff. Send out yearly with request of updated w-9 the vendor acknowledgment with debarment statement. Review debarment statues yearly. Anticipated date to complete the corrective action: 6/30/2025

Finding ref number: 2024-001 Finding caption: The District did not have adequate internal controls and did not comply with federal suspension and debarment requirements. Name, address, and telephone of District contact person: Brandon Rose PO Box 98 Pateros, WA 98846 (509) 923-2751 Corrective action the auditee plans to take in response to the finding: The District has ensured the current staff are aware of the issue regarding the Interlocal Agreement to purchase food commodities and the need to verify those documents annually regardless of ongoing business with the entity. The District will annually check the leading entity in August to ensure the suspension and debarment was completed. If the District office does not locate the information on the leading entity, the District will go out to SAM.gov to check the suspension and debarment and save proof that it was completed. Anticipated date to complete the corrective action: 4/8/2025

Management response: Warren Easton is reviewing and updating the procurement section of the policy manual to explicitly include procedures for verifying the suspension and debarment status of all vendors and contractors receiving federal funds. Documentation of each vendor's verification will be maintained in procurement files. A printed or PDF record from SAM.gov showing the vendor's status will be retained as audit evidence.

Finding Number: 2024‐001 Program Names/Assistance Listing Titles: Assistance Listing Numbers: Title I Grants 84.010 Child Nutrition Cluster 10.553, 10.555, 10.559 Impact Aid 84.041 Education Stabilization Fund 84.425 Contact Person: Arlene Laughter, Business Coordinator Anticipated Completion Date: December 30, 2025 Planned Corrective Action: The District will implement better controls over financial reporting and records retention to ensure all documents are prepared and available for the timely completion of the financial reports.

The District will establish and maintain internal controls that will safeguard District assets to the best of their abilities.

Planned Corrective Action: ● Since learning of this issue, our Food Service Director has manually checked every application. ● Our Food Service Director is rewriting our policy to include reviewing at least 2 applications per week for any week in which 2 or more applications are received through PaySchools. We intend to fully implement this policy with the start of the 2025-26 school year. ● This new policy will allow us to randomly verify applications throughout the year to be sure that all Federal guidelines are being met. Anticipated Completion Date: In Process Responsible Contact Person: Tim Walker, Treasurer

As of result of finding for federal procurement requirements the District has reviewed the procurement requirements with the food service director and staff. In addition, the district has reviewed current spending with vendors within food services to determine procurement requirements for 25-26 fiscal year. This review will be done on an annual basis. In the future the district will review and document the requirements of the awarding agency to ensure they align with our own requirements based on local spending patterns. The district did implement these changes for 2024-2025 Fiscal Year.

Daily meal county reports will be reviewed and verified that it agrees to the edit check worksheets prior to monthly reimbursement submission. Any differences will be properly investigated and resolved.

Edit Check Worksheets will be matched to requests for State of NJ Division of Agriculture reimbursement on a monthly basis for accuracy.

Corrective Action: Coastal Harvest will begin tracking all inventory on hand by source, including receipts, distributions, waste/loss, and any other adjustments, and will perform periodic reconciliations of amounts recorded in the inventory system and amounts recognized in the general ledger to ensure accurate USDA food commodities inventory recordkeeping compliance. Further, Coastal Harvest will include specific inventory policies and procedure in the manual discussed in the corrective action for finding 2022-001. Anticipated Completion Date: June 30, 2025

Beginning in fiscal year 2025, the District has implemented the Community Eligibility Provision (CEP) at all three of its school buildings. The CEP program is in place for four years and it will not be necessary for the District to verify income for free and reduced school lunches during that time period. If in the future the District no longer participates in CEP, control procedures will be implemented to ensure that all students selected for income verification are being correctly categorized and reported to ODEW. This will include the Cafeteria Manager reviewing the free and reduced lunch applications and forwarding any without necessary documentation to the Superintendent and Treasurer for additional verification for eligibility.

All electronic free and reduced meal applications are completed in the PaySchools system. Since PaySchools does not have a SOC1 for Ohio eligibility, all applications will be sent to a pending folder requiring the Food Service Director to review and approve the determination before providing it to the parents/guardians. They began this process reaching out to PaySchools 3/5/2025 and making the change to the account. Because this process started mid-year, the School District will review all of the approved applications prior to 3/31/2025 to avoid a comment in the future.

The district has reviewed the time and effort issues with the new food service director, and going forward the Treasurer will see that all time and effort sheets are signed by both the employee and supervisor.

Finding No.: 2024-001S Condition: The Confirmation Review and Verification Tracking Form was filled out incorrectly and was incomplete. Plan:Management will implement procedures to ensure that the review and verification process is done correctly. Anticipated Date of Completion: 6/30/2026 Name of Contact Person: Kreg Wesley, Executive Director of Finance and Operations

The District has already been in contact with PaySchools. PaySchools will now put all application information in "Pending Status" and the District will be responsible for review and verification. The District did go back and verify that all applications that were approved by PaySchools did in fact meet the threshold levels for all benefits that were approved and denied.