Corrective Action Plans

Child Nutrition Cluster, ALN’s 10.553 & 10.555 Recommendation: We recommend the review and approval process over monthly claims for reimbursement be strengthened to enhance the prevention of discrepancies between the claim for reimbursement and underlying data. Explanation of disagreement with audit finding: Management agrees with the finding. Action taken in response to finding: Newton operated the National School Lunch Program (NSLP) during the Extended School Year (ESY) for the first time during the summer 2024, which created a reporting challenge. Students from across the district's 23 schools attended ESY in seven (7) schools/sites, but their school-year home schools could not be changed in the Student Information System (Aspen). Therefore, student meal counts reported to their home school on the FP9 but had to be reported on the DESE School Report for the ESY school/site they attended. Given the system interface complexities, some counts had to be manually entered, for which two (2) meal counts were incorrectly entered for breakfast versus lunch. Given that the district did not operate the School Breakfast Program (SBP) and did not serve breakfast, these two (2) manual errors were counted as lunch counts when entered for the School Report. The total meal count did match on the FP9 and School Report. For this inconsistency, the correct action should have been to manually update these two counts in the Point of Sale system (Mosaic) so that the two breakfast counts reflected correctly as lunch counts. 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: Newton was able to set conditional parameters in Aspen for ESY 2025 so that the student meal counts reported to their ESY school/site versus their home school, so this reporting issue was corrected the following summer.

Personnel Responsible For Corrective Action: Kelly Dobell, Controller, Square Watson, Chief Operations Officer, and Spencer Winn, Director of Food and Nutrition Services Anticipated Completion Date: June 30, 2026 Corrective Action Plan: Food and Nutrition Services along with Finance will implement procedures and controls to ensure pre-approval in accordance with the Uniform Guidance compliance requirements.

Personnel Responsible For Corrective Action: Kelly Dobell, Controller, Square Watson, Chief Operations Officer, and Spencer Winn, Director of Food and Nutrition Services Anticipated Completion Date: June 30, 2026 Corrective Action Plan: Food and Nutrition Services along with Finance will implement procedures for review and reconciliation of lunch count data with claims reports in accordance with the Uniform Guidance.

Contact Person – Sue Chase, Superintendent Corrective Action Plan – The District should implement policies and procedures to ensure only allowable activities/costs are being charged against grants. Completion Date – March 31, 2026

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF AGRICULTURE – PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION – CHILD NUTRITION CLUSTER (ALN 10.553, 10.555, AND 10.559) 2025-004 Internal Control Over Compliance With Federal Suspension and Debarment Requirements Finding Summary 2 CFR § 180 and 2 CFR § 200.318-327 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 federal programs. During our audit, we noted the District did not have sufficient controls in place within its child nutrition cluster federal programs to ensure compliance with federal requirements related to assuring that the District 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 to ensure compliance with the Uniform Guidance in the future. The review of procedures will also include steps to assure that district personnel are following the requirements of the Uniform Guidance related to suspension and debarment, including maintaining appropriate documentation. Official Responsible – Bryan Hennekens, Director of Finance and Operations. Planned Completion Date – June 30, 2026. Disagreement With or Explanation of Finding – The District is in agreement with this finding. Plan to Monitor – Bryan Hennekens, Director of Finance and Operations, will assure appropriate internal controls and procedures are in place to ensure compliance with suspension and debarment requirements.

Despite the high overall accuracy rate, the District is taking immediate steps to address identified compensation and documentation issues. We have corrected pay scale deficiencies to ensure employees receive proper compensation and implemented additional review controls to prevent future errors. We have also strengthened our account coding procedures to ensure compensation charges are applied to the appropriate funding sources. Additionally, we have updated our digital time-tracking approval workflow to require contemporaneous authorization and improve documentation retention for all supplemental and retrospective compensation. Estimated Completion Date: March 31, 2026 Contact Person: Byron Schueneman, Chief Financial Officer

Recommendation: The Department of Social Services should strengthen internal controls to identify the agency responsible for each client’s eligibility determination and document benefit iteration approvals for the Summer Electronic Benefits Transfer Program for Children. Corrective Action Plan as Reported by the Department of Social Services: The Department disagrees with this finding. Condition #1: Eligibility for the Summer EBT program is established through multiple pathways: receipt of Supplemental Nutrition Assistance Program (SNAP) benefits, Temporary Family Assistance (TFA), or HUSKY A coverage, and through applying for and receiving an eligibility determination for either the National School Lunch Program or the Summer EBT program itself. Determining eligibility is a shared responsibility between DSS and the State Department of Education (SDE), and children qualify through multiple pathways simultaneously. DSS maintains a record within its eligibility system and compiles reports of all eligible children. When eligibility is established through any additional means, the child’s record is then analyzed against all previous issuances to ensure duplicate participation and double issuance does not occur. Title 7 CFR Part 292.16 (a)(5)(i) requires the Summer EBT agency to establish a master issuance file which contains all information needed to identify eligible children, issue Summer EBT benefits, record the participation activity for each household and supply all information necessary to fulfill reporting requirements. The agency is not required to specify which program(s) were used to determine eligibility, which is reasonable given that there may be multiple overlapping avenues of eligibility. The implication that DSS is somehow not compliant or able to identify the source of eligibility is inaccurate. DSS can identify this information on an individual basis through reviewing the child’s receipt of SNAP, TFA, HUSKY A, or through its ongoing coordination and communication with SDE. Condition #2: It is not a requirement of the business systems division to request approval for each issuance. Each year the Department issues benefits for this program in a consistent manner. Since there were no changes to the process during the audit period, approval was not sought for the issuances. Business systems would only seek approval if there was a change to the process. Anticipated Completion Date: N/A Department of Social Services Contact Person: Dan Giacomi, Program Division Director 860-424-5080

Recommendation: The State Department of Education should continue to pursue guidance from the U.S. Department of Agriculture to ensure it complies with the Federal Funding Accountability and Transparency Act reporting requirements. Corrective Action Plan as Reported by the State Department of Education: We agree with this finding. Following guidance from the U.S. Department of Agriculture, we have taken corrective actions to achieve compliance. Federal Funding Accountability and Transparency Act (FFATA) reporting has been completed for awards issued during fiscal years 2024 and 2025, with the exception of three entities that are currently experiencing delays in obtaining their respective Unique Entity Identifiers. FFATA reporting for fiscal year 2026 is currently underway, and reporting for fiscal years 2021, 2022, and 2023 will be completed as soon as all required data elements are obtained. We anticipate being fully compliant with past reporting by June 30, 2026. Anticipated Completion Date: June 30, 2026 State Department of Education Contact Person: Roger Persson, Chief of Fiscal/Administrative Services (860) 713-6667

Reference Number: 2025-002 Prior Year Finding: No Federal Agency: U.S. Department Agriculture State Agency: Department of Education Federal Program: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.556, 10.559, 10.582 Award Number and Year: 202424N109941 (10/1/2023 – 1/30/2025); 202424L160341 (10/1/2023 – 1/30/2025); 202525N109941 (10/1/2024 – 1/28/2026); 202522L160341 (10/1/2024 – 1/28/2026). Compliance Requirement: Reporting – Federal Funding Accountability and Transparency Act (FFATA) Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance Recommendation: We recommend the Department develop procedures and internal controls to ensure that all required subawards are reported timely and accurately no later than the end of the month following the month of issuance of each subaward. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Department will revise and strengthen our policies and procedures to ensure full compliance with FFATA reporting requirements. Updated procedures will require that all applicable child nutrition subawards of $30,000 or more are reported in SAM.gov no later than the end of the month following the month in which the subaward is made, in accordance with Uniform Grant Guidance. Name(s) of the contact person(s) responsible for corrective action: Drew Fioravanti Planned completion date for corrective action plan: June 30, 2026

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF AGRICULTURE – PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION – CHILD NUTRITION CLUSTER (ALN 10.553, 10.555, 10.556, 10.582, AND 10.559) 2025-002 Internal Control Over Compliance With Federal Suspension and Debarment Requirements Finding Summary 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 federal programs. During our audit, we noted the District did not have sufficient controls in place within its child nutrition cluster federal programs to ensure compliance with federal requirements related to assuring that the District 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 to ensure compliance with the Uniform Guidance in the future. The review of procedures will also include steps to assure that district personnel are following the requirements of the Uniform Guidance related to suspension and debarment, including maintaining appropriate documentation. Official Responsible – Andi Johnson, Director of Finance. Planned Completion Date – June 30, 2026. Disagreement With or Explanation of Finding – The District is in agreement with this finding. Plan to Monitor – Andi Johnson, Director of Finance, will review and update procedures relating to suspension and debarment for its federal programs to ensure compliance with the Uniform Guidance in the future.

We have prepared the following corrective action plan as required by the standards applicable to financial audits contained in Government Auditing Standards and by the audit requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Specifically, for each finding we are providing you with the names of the contact people responsible for corrective action, the corrective action planned, and the anticipated completion date. 2025-101 Material Weakness in Internal Controls Over Compliance: Reporting Recommendation: To help ensure that monthly meal counts are mathematically accurate, management should implement a formal reconciliation process where a designated official—other than the individual who prepared the report—performs a crosscheck of the Monthly Claim for Reimbursement against the Daily Meal Count Tally Sheets. Action Taken: Management will review and update its policies and procedures, if necessary, to ensure the number of meals claimed for reimbursement agrees with the meal count sheet. Contact person: Kathy Couch, Prinicpal Completion date: Fiscal year 2026

Finding: During our audit, we identified that the District included a geographic (local) preference in a Request for Proposal (RFP) and related vendor evaluation that was funded, in whole or in part, with the federal program noted above. Federal regulations generally prohibit the use of geographic preferences in the evaluation of bids or proposals for federally funded procurements unless expressly authorized by federal statute. Corrective Action: Tulsa Public Schools acknowledges the finding and is implementing corrective measures to update existing policies and procedures regarding the Request for Proposal (RFP) process to remove geographic (local) preference as part of the evaluation for federal procurement. Implementation of these corrective measures is expected by June 30, 2026. Owner: Rachel Vejraska, Director of Procurement

Finding: During our audit, we identified that the District failed to check the suspension and debarment status of a vendor with which a new covered transaction was entered. The vendor is not currently registered as being suspended or debarred. Corrective Action: Tulsa Public Schools acknowledges the finding and is implementing corrective measures to update existing policies and procedures to perform the suspension and debarment verification for all covered transactions on a regular basis. Implementation of these corrective measures is expected by June 30, 2026. Owner: Robert Sauceda, Executive Director of Accounting

Management Plans to develop proper written policies and procedures over the elibility process that ensures indivdiuals are eligible and proper documentation is maintained

Finding Type: Non Compliance 10.553 and 10.555. Name of Contact Person: Dr. Judy Kaegi, Superintendent. Recommendation: We recommend that all food solicitations include the proper language to ensure that food products comply with the Buy American provision. Corrective Action: The District will ensure this language is included in all food solicitations going forward. Proposed Completion Date: Immediately.

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF AGRICULTURE – PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION – CHILD NUTRITION CLUSTER (ALN 10.555 AND 10.553) 2025-001 Internal Control Over Compliance With Federal Suspension and Debarment Requirements Finding Summary 2 CFR § 180 and 2 CFR § 200.318-327 requires Independent School District No. 719, Prior Lake-Savage Area Schools (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 federal programs. During our audit, we noted the District did not have sufficient controls in place within its child nutrition cluster federal programs to ensure compliance with federal requirements related to assuring that the District 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 to ensure compliance with the Uniform Guidance in the future. The review of procedures will also include steps to assure that district personnel are following the requirements of the Uniform Guidance related to suspension and debarment, including maintaining appropriate documentation. Official Responsible – The District’s Executive Director of Business Services, Lisa Rider. Planned Completion Date – June 30, 2026. Disagreement With or Explanation of Finding – The District agrees with this finding. Plan to Monitor – The District’s Executive Director of Business Services, Lisa Rider, will assure appropriate internal controls and procedures are in place to ensure compliance with suspension and debarment requirements.

Department: Health and Human Services Title: Internal control over Summer EBT eligibility needs improvement Questioned Costs: Known; $1,680 Likely: Undeterminable Status: Corrective action complete Corrective Action: Documentation and Records Retention: The Department replaced manual notification with automation through the statewide database. Database generated letters are both retained appropriately and easily retrievable for individual clients. Inaccurate certifications through database errors: Database cleanup and streamline certification logic updates were necessary to resolve inaccurate certifications. This process was completed prior to issuance for summer of 2025. Completion Date: May 1, 2025 Agency Contact: Evan Denno, Program Manager – SNAP, DHHS, 207-446-3201

Department: Education Title: Internal control over CNC subrecipient audit monitoring needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: Fiscal Review and Compliance Consultant: The Policy and Procedure manual will be updated to include regular monthly notifications in a system (such as Microsoft Outlook) to update the audit tracking spreadsheet for accuracy. Regionalization and Compliance Coordinator: The Policy and Procedure manual will be updated to add a step to set up regular monthly notifications in a system (such as Microsoft Outlook) for the supervisor to review the audit tracking spreadsheet for accuracy and completion. Completion Date: April 30, 2026 Agency Contact: Nicole Denis, Director of Finance, DOE, 207-530-2161

Department: Education Title: Internal control over CNC donated food inventory needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Department will continue with monthly inventory check-ins with the vendor that were instituted beginning in SY25. This check-in reviews all items in the warehouse. If the monthly check-in variance is above 2% then the items will be manually counted at the warehouse. The Department submitted a ticket for inventory errors, and it is monitored regularly. Completion Date: June 30, 2025, October 1, 2026, and December 3, 2026, respectively Agency Contact: Jane McLucas, Director of Child Nutrition, DOE, 207-624-6880

Department: Education Title: Internal control over CNC special reporting needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Department has reported the previously unreported items through a batch upload process. The Department will review batch uploads for accuracy by the Director of Finance prior to submission, as was done under the previous reporting system. Completion Date: August 31, 2025, and March 4, 2026, respectively Agency Contact: Nicole Denis, Director of Finance, DOE, 207-530-2161

Department: Education Title: Internal control over CNC subrecipient monitoring procedures needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Department will review and monitor the tracking spreadsheet monthly. The Department will hold monthly meetings to ensure CNP web questions and tools are completed, and documents are saved in the appropriate location. The Department will conduct training with NSLP reviewers on expectations for saving documentation Conduct training with NSLP reviewers on how to answer SFSP procurement questions for schools. The Department will update the Special Provision 2 base year review and validation procedure to include where to save documents and show the completion in CNP web. The Special Provision 2 base year reviews will be included in Step 2, starting SFY 2027. Completion Date: May 1, 2026 (first to third items), June 15, 2026 (fourth item), June 30, 2026 (fifth item), and October 30, 2026 (sixth item) Agency Contact: Jane McLucas, Director of Child Nutrition, DOE, 207-624-6880

Department: Education Title: Internal control over CNC claim reimbursements needs improvement Questioned Costs: Known: ALN 10.559 $61,336 ALN 10.582 $12,215 Likely: ALN 10.559 undeterminable ALN 10.582 undeterminable Status: Corrective action in progress Corrective Action: The Department will create a business requirements document for the SFSP site sheet and claims camp/closed enrolled eligibility edit checks. The non-congregate application now requires sponsors’ to have a written procedure to address site proximity, this is captured in an offline form in the checklist document. The Department submitted a ticket to update the FNS report so it will collect the data needed. For the FFVP, a tracking procedure is in place for SFY 2026 to stay within the $50-75/student rate. A spreadsheet is being used to track this information and has been implemented. Completion Date: March 4, 2026 (first item), June 30, 2025 (second and fourth items), and March 19, 2025 (third item) Agency Contact: Jane McLucas, Director of Child Nutrition, DOE, 207-624-6880

Department: Education Title: Internal control over CNC eligibility needs improvement Questioned Costs: Known: ALN 10.555 $73,683 ALN 10.559 $226,773 Likely: ALN 10.555 undeterminable ALN 10.559 undeterminable Status: Corrective action in progress Corrective Action: The Department will create a business requirements document for the SFSP site sheet and claims camp/closed enrolled eligibility edit checks. The Department will create a user guide to approve the site info sheet and apps to address oversite errors with the approval process. A financial eligibility edit check in the software will be implemented for program year 2026. A policy statement for non-congregate was a required document with an edit check in program year 2025. Completion Date: March 2, 2026, April 30, 2026, April 15, 2026, and May 1, 2025, respectively Agency Contact: Jane McLucas, Director of Child Nutrition, DOE, 207-624-6880

The District will strengthen controls to ensure all service contracts, including those charged to federal programs, are approved by the Board of Education and entered into the official minutes prior to execution and payment, in accordance with 2 C.F.R. § 200.318(a), state law, and District policy. Effective immediately, all service contracts will be submitted for Board approval before services begin. No contract will be executed and no purchase order will be issued without documented Board approval. Accounts payale will verify Board approval prior to processing payment. Procurement personnel and Federal program staff will receive training on Uniform Guidance procurement requirements, including suspension and debarment procedures. The Business Manager will perform reviews on Federal program expenditures to ensure ongoing compliance. The District believes these measures will correct the defiency and prevent recurrence.

Corrective Action Plan: The Department is a partnering agency for this program and does not manage the disbursement of funds. However, as a partnering agency for the program, the Department will continue updating its internal controls over the Summer Electronic Benefits Transfer (EBT) program’s eligibility determinations to ensure only eligible students are receiving benefits. These procedures will include regular communication to school districts, expanded data fields, school submission of a single combined enrollment and benefits file, and additional verification of the accuracy and completeness of the student data submitted by the districts to ensure only eligible students are approved to receive benefits. Since the questioned costs were isolated to calendar year 2024, and the Department has taken steps to correct the issue, this issue should not reoccur. The Department will work with Job and Family Services (JFS) to resolve the identified questioned costs. If needed, this will include evaluating the projected questionable costs to determine the actual amount that may have been disbursed to ineligible students and assisting JFS efforts to address those disbursements. Anticipated Completion Date for Corrective Action: May 2026 Contact Person Responsible for Corrective Action: Name: Corey Fronk Title: Administrator of Audits and Risk Management Address: 25 S. Front Street, 7th Floor; Columbus, OH 43215 Phone Number: (614) 644-7812 E-Mail Address: Corey.Fronk@education.ohio.gov