Corrective Action Plans

RIDE is currently evaluating third-party consultants in order to have the following services performed: • A cybersecurity assessment performed of the overall agency using the NIST Framework • A cybersecurity assessment of our internal applications including CNP Connect & Accelegrants • An updated business continuity plan • A Vendor Risk Assessment Program Development Through the above deliverables from the selected consultant, RIDE will be able to have a better understanding of gaps in IT/ Cybersecurity throughout the agency, as well as the applications cited by the Auditor General. Anticipated Completion Date: December 31, 2025 Contact Person: Brandon Bohl, Finance Director, Department of Elementary and Secondary Educationbrandon.bohl@ride.ri.gov

RIDE’s Office of School Health & Wellness will develop a guidance document for LEAs regarding Paid Lunch Equity calculations and send communication at least annually to ensure LEAs have complied with 7 CFR Sec. 210.14(e). Anticipated Completion Date: June 30, 2026 Contact Persons: Brandon Bohl, Finance Director, Department of Elementary and Secondary Education brandon.bohl@ride.ri.gov Rosemary Reilly-Chammat, Director – Office of School Health & Wellness, Department of Elementary and Secondary Education rosemary.reilly-chammat@ride.ri.gov Jennifer Goodwin, School Health Specialist, Department of Elementary and Secondary Education jennifer.goodwin@ride.ri.gov

To eliminate the issue with stock discrepancies, the Central Distribution Center (CDC) will be incorporating updated software targeted toward minimizing inventory errors with the receipt, storage, and distribution of all commodities that come into the CDC. The CDC recently implemented handheld scanners for tracking purposes and stock management. The scanners have new upgrades that are designed to improve inventory picking procedures. The CDC is currently in the process of making this upgrade into our system and expects to have this fully implemented by May 31, 2025. In addition to the new software, we are at the beginning stages of a warehouse reorganization which will include a new storage location labeling system which is being designed with the intention of creating a more structured storage system for all products. In conjunction with the handheld scanners, the labeling system will include barcodes for inventory which will be matched to storage location. These labels are magnetic, durable, and removable and can be repositioned to any rack location in the warehouse as needed. We will immediately start automated cycle counts daily to detect and correct discrepancies early to ensure all issues with inventory are caught and addressed as early as possible. Similarly, the CDC will also be implementing a quarterly full inventory count with the first one occurring no later than May 31, 2025. Stock discrepancies are a major challenge but by incorporating the right strategies they can be eliminated. By leveraging automation, enforcing standard procedures, and continuously monitoring inventory we will improve our inventory efficiency. Anticipated Completion Date: May 31, 2025 Contact Persons: Terrence McNamara, Administrator Physical Resources, Department of Corrections terrence.mcnamara@doc.ri.gov Matthew Wiencis, Chief Distribution Officer, Department of Corrections matthew.wiencis@doc.ri.gov

RIDE has hired a full-time fiscal officer to oversee these programs from a fiscal perspective and maintain compliance with reporting requirements including the SF-425. RIDE is currently hiring for a program person who will assist the fiscal officer with reporting compliance. Anticipated Completion Date: Ongoing Contact Persons: Brandon Bohl, Finance Director, Department of Elementary and Secondary Education brandon.bohl@ride.ri.gov Rosemary Reilly-Chammat, Director – Office of School Health & Wellness, Department of Elementary and Secondary Education rosemary.reilly-chammat@ride.ri.gov

We have prepared procedures for Federal Funding Accountability and Transparency Act (FFATA) reporting specifically for USDA. We shifted a current GaDOE accounting manager's job duties to include assisting the Assistant Director of Accounting with overall FFATA reporting duties. The addition of an experienced staff member to assist with FFATA data gathering, reconciling, and reporting will allow for the Assistant Director of Accounting to focus on completing the more complex FFATA Reporting for USDA in a timely manner.

The District acknowledges this finding. Due to its size, it is not cost effective to have more than one person in the food service department working with the claims. The District will assign someone in the District office to review all claims. Shannon Grindell, Susan Mayer Ongoing

Going forward, Edison Local Schools Eligibility process to determine Free/Reduced/Denied Status of applications submitted for the National School Lunch Program are: All applications collected at Edison Local School will be reviewed prior to the data entered into pay schools to ensure the applications have all the information and data to make the correct determination. The income eligibility criteria is established by the Ohio Department of Education. The eligibility for paper applications will be made by the food service director and the superintendent is the determining official and each application is reviewed prior to entering this into the POS system, and a free/reduced and benefits issuance reports is compared to ensure all information is correct after it is entered to ensure the determination is correct, additionally annual verification is also done on free/reduced applications.

Child Nutrition implemented a new policy/procedure for handling free and reduced applications effective July 1, 2024.

2024-031 Department of Education Implement controls to ensure FFATA reporting is completed for all required subawards Management Response: ODE agrees with this finding. To strengthen controls and ensure FFATA reporting is completed for all required subawards, ODE plans to implement the following process improvements: • Collaborate with the Child Nutrition program management and Fiscal Grants team to provide full documentation of grant awards including terms, conditions and attachments. • Update ODE’s grant profile request Smartsheet tool to: o Identify FFATA eligibility prior to setting up a new grant award in the accounting system. o Automatically notify the FFATA team of new grant awards that require reporting. Anticipated Completion Date: June 30, 2025 Contact person: Kristie Miller, Accounting Director

2024-031 Department of Education Implement controls to ensure FFATA reporting is completed for all required subawards Management Response: ODE agrees with this finding. To strengthen controls and ensure FFATA reporting is completed for all required subawards, ODE plans to implement the following process improvements: • Collaborate with the Child Nutrition program management and Fiscal Grants team to provide full documentation of grant awards including terms, conditions and attachments. • Update ODE’s grant profile request Smartsheet tool to: o Identify FFATA eligibility prior to setting up a new grant award in the accounting system. o Automatically notify the FFATA team of new grant awards that require reporting. Anticipated Completion Date: June 30, 2025 Contact person: Kristie Miller, Accounting Director

The School District will implement monitoring control procedures to review software system eligibility determinations to ensure compliance with federal income guidelines.

Child Nutrition Cluster – Eligibility The finding is a material weakness in internal control over federal awards due to incorrect eligibility determination entered into the Food Service System. The District will train individuals involved in the eligibility process on correct processes and reviews and implement controls to prevent the improper determination of eligibility. Responsible official: Janice Boucher, Finance Manager, jboucher@shawanoschools.org Anticipated Completion Date: June 30, 2025

The Board has developed procedures to ensure that all purchase orders are approved before orders are placed, all expenditures are properly authorized by the respective program director and supporting documentation is adequately maintained. The Board is using a requisition form in Droplet to achieve this goal. All employees authorized to make or approve purchases have been trained on purchasing procedures outlined in the Purchasing Policies and Procedures Manual for Local Educational Agencies in the State of West Virginia by the WVDE Office of School Finance on 2/23/2024.

The Board will establish procedures that will ensure compliance with requirements of the United States Department of Education's equipment management requirements and the WV Department of Education's inventory requirements.

The Board will develop a Food Service Collection Policy and attempt to collect the outstanding balances on the receivables related to the National School Lunch Program.

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

FINDING 2024-003 Finding Subject: Child Nutrition Cluster - Eligibility Contact Person Responsible for Corrective Action: Kelli Keith Contact Phone Number and Email Address: 812-438-2655, kkeith@risingsun.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Cafeteria Supervisor will have another employee spot-check 5 free and reduced applications per month. The other employee will review documentation of the review of the income guidelines updated in the system every year. Anticipated Completion Date: 3/3/2025

2024-002. Eligibility United States Department of Agriculture, Passed Through New York State, Department of Education: Child Nutrition Cluster School Breakfast Program ALN: 10.553 National School Lunch Program ALN: 10.555 Condition: The District has designated one employee to receive and enter the annual household applications into the District’s point of sale software. Based on our inquiries and review of thirty nine applications tested for student eligibility (free or reduced), we noted two instances where students were improperly classified to receive free or reduced meals based on the household income reported on the application. Planned Corrective Action: The District will adopt procedures that ensure there will be a secondary review of household applications to ensure they are processed properly. Responsible Contact Person: Michael I. DeVito, Esq. Assistant Superintendent for Finance and Operations Long Beach City School District 235 Lido Boulevard Lido Beach, New York 11561 Anticipated Completion Date: June 30, 2025.

FINDING 2024-004 Finding Subject: Child Nutrition Cluster--Eligibility Contact Person Responsible for Corrective Action: Deb Rodriguez, Food Service Director Contact Phone Number and Email Address: 260.894.3191 and rodriguezd@westnoble.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Food Service Director will review the directly certified student list from the state and verify that is correctly entered into the school’s software. The Chief Financial Officer will review the list from the state and review the list that is inputted into the school’s software to ensure accuracy. Anticipated Completion Date: September 30, 2025

Action taken in response to finding: The September 2023 claiming error was caused in part by the Food Service Management Company manually entering the claims in the DESE Portal incorrectly. Newton took responsibility for entering the claims for the balance of FY24. For FY25, Newton now uploads the meal count data from Mosaic, the point-of-sale software, directly into the DESE portal. That upload is done by the Business Operations Analyst and then approved by the Director of Business Operations, which removes substantial exposure for human error during data entry and creates two levels of review prior to approval and submission. The other five discrepancies between the source counts and what was submitted for the DESE claim was to address identified human error in advance to ensure that the monthly claim was accurate. For the September 2023 error, Newton has submitted a Claim Adjustment Form to DESE to provide guidance for the necessary action steps. Name(s) of the contact person(s) responsible for corrective action: Amy Mistrot, NPS Director of Business Operations. Planned completion date for corrective action plan: The internal controls to reduce data entry errors have been implemented and are consistently being used. DESE will provide guidance for the Claim Adjustment Request to address the September 2023 error, which Newton will then implement.

Preparation of Schedule of Expenditures of Federal Awards Type of Finding: Material Weakness in Internal Control over Financial Reporting/ Compliance • Contact Person Responsible: Frank Antuono, Business Manager • Corrective Action to be Taken: The District will establish formal written policies and procedures for the preparation of the Schedule of Expenditures of Federal Awards (SEFA) in compliance with 2 CFR 200.51 0(a). These procedures will: o Identify all sources of federal revenue o We have added the assigned federal funding source codes to our district budget operation in CSIU, which will now allow us to track these expenditures back to our internally controlled spreadsheets as verification of expenditures. o Track expenditures using dedicated account codes in the general ledger o Assign responsibility for monthly reconciliation and schedule preparation o Include a secondary review of the SEFA by someone other than the preparer The Business Office will undergo training on SEFA requirements and reconciliation practices. These changes will ensure complete and accurate reporting of federal expenditures for all future reporting periods.

For the unallowable loans from the School Food Service (SFS) account, we will execute a repayment agreement with terms and interest per the original agreement and annually submit proof of repayment and an assurance statement to the State Agency. To prevent recurrence, we will adopt policies prohibiting loans from the SFS account and train staff on fund restrictions under Uniform Guidance. We will also enhance review processes to ensure timely recording of interest receivable and proper structuring of amortization schedules. Policies for periodic reconciliation and agreement validation will be implemented, supported by financial software and accounting expertise, to ensure compliance with GAAP.

Finding 2024-004 Contact Person Responsible for Corrective Action: Brenda Layne, Food Service Director Contact Phone Number: 765-289-7323 We concur with the finding. Corrective Action plan: As of SY 24/25 when the High School Treasurer checks the 10% of the paper applications, she will make a list of the ones she checked and it will be located in the application binder. As of March 1st, 2025 The Food Service Director will run a copy of Direct Certs that Titan has in their file, she will then cross check it with the list that is send from IDOE. She will keep both list together in a file after initialing it. Anticipated completion Date: March 2025

Audit Finding Reference: 2024-003 Improve Controls and Documentation over Payroll Process Planned Corrective Action: Halfway through FY24, the District implemented a new payroll system, ADP. Since onboarding, it has become apparent that the "crosswalk" between ADP account codes and Munis codes is not adequate for the complexity in reporting for many of the District's federal and state awards. As ADP is a highly customizable platform, the Payroll and Finance team are in the process of designing a structure for seamless integration between running payroll and posting payroll to Munis, and ultimately charging those costs to grant awards. While this is occurring, the accounting team will review and reconcile payroll as possible in alignment with budgeted grant expenses. Name of Contact Person: Lesa Beck, Senior Payroll Manager Heather Peters, Accounting Manager Anticipated Completion Date: 6/30/2025

FINDING 2024-003 Finding Subject: Child Nutrition Cluster – Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Todd Fleetwood, Director of Business and Operations Contact Phone Number: 260-244-5771 fleetwoodta@wccsonline.com Views of Responsible Official: The School Corporation concurs with the finding Description of Corrective Action Plan: To ensure compliance with federal procurement regulations, prior to entering into a purchase agreement using federal funds exceeding $25,000, the Food Service Director or Assistant Food Service Director will take one of the following actions: 1. Verify Vendor Status: Check the System for Award Management (SAM) Exclusions List to confirm the vendor is not suspended or debarred. 2. Obtain Certification: Collect a written certification from the vendor affirming their eligibility to receive federal funds. 3. Include Contractual Safeguard: If applicable, incorporate a clause or condition in the purchase agreement requiring compliance with federal suspension and debarment regulations. These steps will be documented and retained for audit purposes to ensure full compliance with federal procurement requirements. INDIANA STATE BOARD OF ACCOUNTS 22 107 North Walnut Street  Columbia City, Indiana 46725 Phone (260) 244-5771  Fax (260) 244-4590  Website http://wccsonline.com Anticipated Completion Date: 07/01/2025