Corrective Action Plans

U.S. Department of Education 10/22/2024 Marshall Public Schools respectfully submits the following Corrective Action Plan for the year ended June 30, 2024. Contact information for the individual responsible for the corrective action: Caleb Petet, SuperintendentMarshall Public Schools Independent Public Accounting Firm: Gerding, Korte & Chitwood, P.C., 723 Main Street, Boonville, MO 65233 Audit Period: Year ended June 30, 2024 The findings from the June 30, 2024, Schedule of Findings and Questioned Costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule Significant Deficiency 2024-001 Segregation of Duties Recommendation: We realize that because of limited resources and personnel, management may not be able to achieve a proper segregation of duties; however, our professional standards require that we bring this lack of segregation of duties to your attention in this report. Action Taken: The cost associated with hiring additional personnel does not support the justification to hire for the means. However, the District will continue to monitor the situation and implement recommendations as practical. Completion Date: June 30, 2025 Sincerely,Caleb Petet, Superintendent Marshall Public Schools

Berkeley School District No. 87 CORRECTIVE ACTION PLAN FOR CURRENT YEAR FINDINGS Year ending June 30, 2024 Corrective Action Plan Finding No.: 2024-002 Condition: During our audit of the Child Nutrition Cluster, we identified that the client did not have adequate disbursement controls in place. Specifically, duplicate invoices on multiple occasions were entered into the client’s software system due to typographical errors, resulting in payments being made twice to each vendor for the same service. Plan: The District will implement stronger internal controls over the disbursement process. This includes establishing a review and approval process for all invoices before payment, implementing software controls to detect duplicate invoices, and/or providing training to staff on proper invoice processing procedures to minimize typographical errors. Anticipated Date of Completion: 06/30/2025 Name of Contact Person: Irene Daciuk Management Response: See above

AAPS has corrected for this finding at the beginning of FY25 by having offer letters issued by our HR Manager to all employees. Offer letters are securely stored in individual employees’ personnel folders.

Finding Type: Significant Deficiency. Name of Contact Person: Jonathan Green, Superintendent. Recommendation: We recommend the District expand their internal controls to require a responsible official to review the daily meal count reports for accuracy prior to submission of the reports to the Illinois State Board of Education. Corrective Action: Daily meal counts will be rectified by administration on a monthly basis. Proposed Completion Date: Immediately.

Contact Person Darin Scherr, Business and Operations Manager Corrective Action Plan The District agrees with the finding as presented. The child nutrition department will ensure both that the months are closed out in our software system so that data does not change after the fact and that original meal count reports ran from the system that match the claims filed with ND DPI are kept on file for the required time period. Corrective action has already taken place on a go forward basis starting when this was identified during audit testing. Completion Date Immediately

No. 2024-004 Subject: Reporting - Significant deficiency in internal control over compliance Name of Contact Person: Ingmar Berg, CFO Phone Number: (480) 270-5438 x1091 Anticipated Completion Date: June 30, 2025 Corrective Action: Management will implement internal controls related to documentation of approval for all monthly NSLP claims for reimbursement prior to submission. We will establish a formalized procedure to ensure that all monthly claims for reimbursement undergo documented management review and approval before submission. This procedure will clearly define the review process and designate responsible personnel for each step to maintain accountability. All reviewed and approved claims will be accompanied by signed documentation as evidence of compliance. All Food Service personnel involved in the reimbursement submission process will receive training on the new procedure to ensure understanding and adherence to the documentation requirements.

Name of Contact Person: Cindy Crabb, Superintendent. Recommendation: We recommend the District monitor the Child Nutrition profit made and ensure all expenditures used to operate the program are properly charged to the program. Corrective Action: We will ensure that all eligible costs are charged to teh program and modernize the equipment to reduce the accumulated carry-over. Proposed Completion Date: Immediately.

Name of Contact Person: Cindy Crabb, Superintendent. Recommendation: We recommend Food Service claims be submitted in a timely manner in order to maintain compliance with the requirements of the National School Breakfast/Lunch programs. Corrective Action: We will ensure that all future food service claims are submitted in a timely manner. Proposed Completion Date: Immediately.

Findings #2024-002 and #2024-004 – Significant Deficiency. Applicable federal programs: U. S. Department of Agriculture, Passed through Texas Department of Agriculture: School Breakfast Program, AL#10.553, Contract #’s: 202423N109946 and 202120N19946, National School Lunch Program, AL#10.555, Contract #’s: 202423N109946 and 202222N109946, U. S. Department of Education, Passed through Texas Education Agency: Special Education Grants to States, AL#84.027A, Contract #: H027A230008. Recommendation: Reemphasize the need for timely analysis and reconciliations of the balance sheet accounts. Planned corrective action: The School will perform timely analysis and reconciliation of the balance sheet accounts in accordance with the organization’s policies and procedures. Responsible officer: Kevin Byrne, Vice President of Finance. Estimated completion date: January 1, 2025.

Findings #2024-001 and #2024-003 – Significant Deficiency. Applicable federal programs: U. S. Department of Agriculture, Passed through Texas Department of Agriculture: School Breakfast Program, AL#10.553, Contract #’s: 202423N109946 and 202120N19946, National School Lunch Program, AL#10.555, Contract #’s: 202423N109946 and 202222N109946, U. S. Department of Education, Passed through Texas Education Agency: Special Education Grants to States, AL#84.027A, Contract #: H027A230008. Recommendation: Develop procedures to reconcile accounts payable batches to the related check run, restrict set up of vendors in the check processing application, and develop budget versus actual reporting for the corporate office. Planned corrective action: Management has already developed a process to reconcile accounts payable batches extracted from the Concur system to the related check run in the Ascender general ledger system. In addition, management will create a separation of duties for bank reconciliations and the setup of new vendors. Our financial analyst will also consistently develop budget versus actual reports for the corporate office as is done for the schools. Responsible officer: Kevin Byrne, Vice President of Finance. Estimated completion date: January 1, 2025.

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF AGRICULTURE, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, CHILD NUTRITION CLUSTER – FEDERAL ALN 10.553, 10.555, AND 10.559 2024-001 Internal Control Over Compliance With Federal Suspension and Debarment Requirements Finding Summary - 2 CFR § 180 requires Independent School District No. 834 (the District) to establish and maintain effective internal control over compliance with requirements applicable to its federal program expenditures, including applicable suspension and debarment requirements. The District did not have sufficient controls in place within the child nutrition cluster federal programs to assure that it 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 policies and procedures relating to suspension and debarment for child nutrition cluster federal programs and will ensure that all parties with which it contracts for goods or services are eligible to participate in contracts involving the expenditures of federal program funding. Official Responsible – The District’s Executive Director of Operations, Mark Drommerhausen. Planned Completion Date – June 30, 2025. Disagreement With or Explanation of Finding – The District agrees with this finding. Plan to Monitor – The District’s Executive Director of Finance, Marie Schrul, will monitor the implementation of these corrective actions to ensure appropriate controls are in place to verify that any vendor with which the District contracts for federal program goods or services exceeding $25,000 is not listed as suspended or debarred on the federal Excluded Parties List System website.

Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. 2. Actions Planned in Response to Finding: The District will obtain proper documentation to pay increases and online food service applications. 3. Official Responsible for Ensuring CAP: Megan Gracia, Business Manager, is the official responsible for ensuring corrective action for compliance. 4. Planned Completion Date for CAP: The planned completion date is June 30, 2025. 5. Plan to Monitor Completion of CAP: The School Board of ISD No. 508 will be monitoring this corrective action plan.

Identifying Number: 2024-005 Reporting – Significant Deficiency U.S. Department of Agriculture Passed through Missouri Department of Elementary and Secondary Education Child Nutrition Cluster, Assistance Listing No. 10.555 (National School Lunch Program), 10.553 (School Breakfast Program), 10.582 (Fresh Fruit and Vegetable Program) Federal award year 2023-2024 U.S. Department of Education Passed through Missouri Department of Elementary and Secondary Education Education Stabilization Fund, Assistance Listing No. 84.425C (Governor’s Emergency Education Relief Fund), 84.425D (Elementary and Secondary School Emergency Relief Fund), 84.425U (American Rescue Plan-Elementary and Secondary School Emergency Relief), 84.425W (American Rescue Plan-Elementary and Secondary School Emergency Relief-Homeless Children and Youth) Federal award year 2023-2024 Summary of Finding: Criteria: The Uniform Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance retirements. This includes controls to ensure that reports submitted are timely, complete, and accurate. Condition: The District did not have internal controls in place for federal reports to be reviewed for completeness and accuracy prior to submission. Cause: A lack of controls that could reasonably ensure this review had been performed by someone other than the preparer of the information. Effect or potential effect: The potential effect is submitting incomplete or inaccurate reports. Questioned costs: None Context: For all sample selections tested in the major programs, all reports were submitted timely and appeared to be accurate, however, there was no evidence that these reports were reviewed for completeness and accuracy prior to submission. Identification as a repeat finding, if applicable: Not applicable. Corrective Action: To ensure the accuracy of Federal reports/claims, Food service will implement the following procedures: Federal reporting and claims will be reviewed for accuracy and completeness by the Food service director or designee before they are submitted. The food service director or designee will initial report to document this review. Finance department personnel will implement the following procedures for other federal programs: One employee will start the ePeGS process. This employee will forward the documentation that they used to prepare the ePeGS filing to their supervisor. The supervisor will review the documentation and the items entered into ePeGS for accuracy. Once the supervisor is satisfied that the ePeGS filing is correct, he or she will submit the ePeGS filing. This process will be documented in the ePeGS history. Anticipated Completion Date: June 2025 (for the year ending June 30, 2025). Contact Person: Steve Marriott, Controller 816-321-5000 Steve.marriott@nkcschools.org

Identifying Number: 2024-003 Suspension and Debarment—Material Weakness U.S. Department of Agriculture Passed through Missouri Department of Elementary and Secondary Education Child Nutrition Cluster, Assistance Listing No. 10.555 (National School Lunch Program), 10.553 (School Breakfast Program), 10.582 (Fresh Fruit and Vegetable Program) Federal award year 2023-2024 Summary of Finding: Criteria: The Uniform Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance retirements. Also, the Uniform Guidance (2 CFR 200.212 and 200.318(h)) stipulates that when a nonfederal entity enters into a contract or purchase with an entity (vendor or subrecipient), the nonfederal entity must verify the entity is not suspended or debarred from participation in federal programs/grants when expending $25,000 or more in a year. Condition: The District did not have controls in place to reasonably ensure any entity receiving more than $25,000 in federal grant funds was not suspended or debarred, prior to providing them with federal funds. Cause: A lack of controls to reasonably ensure this verification was performed. Effect or potential effect: The District did not have controls in place to reasonably ensure compliance with suspension and debarment requirements of the Uniform Guidance. The potential effect is submitting unallowable costs, or loss of federal funding. Corrective Action: Management has developed the following procedures to ensure that vendors are not suspended or debarred: • All current vendors will be checked against Sam.gov on a quarterly basis. • All vendors receiving Federal funds of $25,000 or greater will be checked prior to completion of any purchase requisition. • All vendor applicants will be required to sign a Certified document that they are not suspended or debarred along with the Vendor App. • All bids will have a Certified document included for vendors to submit that declares they are not suspended or debarred. Anticipated Completion Date: December 2024 (for the year ending June 30, 2025). Contact Person: Stacy Swenson, Director of Purchasing 816-321-5016 Stacy.swenson@nkcschools.org

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF AGRICULTURE, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, CHILD NUTRITION CLUSTER – FEDERAL ALN 10.553 AND 10.559 2024-001 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, Tammy Fredrickson. Planned Completion Date – June 30, 2025. Disagreement With or Explanation of Finding – The District agrees with this finding. Plan to Monitor – The District’s Executive Director of Business Services, Tammy Fredrickson, will assure appropriate internal controls and procedures are in place to ensure compliance with suspension and debarment requirements.

The District relies on the auditor to propose adjustments necessary to prepare the schedule of expenditures of federal awards including the related note disclosures. The District reviews schedule of expenditures of federal awards and approves all adjustments.

The District will monitor vendors to ensure they are able to accept federal monies. The District will also review all invoices relating to bids to verify correct charges. This will be completed by Ashley Simmons, Accounts Payable Clerk by 6/30/2025.

Finding 2024-004 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, 2025 5. Plan to Monitor Completion The Board of Directors will be monitoring this Corrective Action Plan.

Finding Number: 2024-002 Finding Synopsis: The District submitted a claim for meals higher than the count actually served for the month due to a clerical error. The District did not have someone, other than the preparer of the monthly claim, review the claim before it was submitted to ensure its accuracy. Action Steps: Management plans to implement a review process to ensure the claim forms are filled out correctly. Contact Person: Jeffrey Schubert Chief School Business Official 779-244-1000 Anticipated Completion Date: 6/30/2025

Finding Number: 2024-001 Finding Synopsis: In the population of 40 applications selected for testing, an exception was noted on 1 of the applications. This exception stemmed from the "pay frequency" section of the application, where the person filling out the application left this section blank, thereby creating an issue where it was not possible to calculate the household's annual income. However, the District still approved the application for free status. The District noted that the frequency was confirmed verbally, however failed to obtain physical documentation. It does appear, however, that the student was appropriately classified as free status. Action Steps: Management plans to implement procedures to ensure applications are appropriately reviewed for completeness before approving. Contact Person: Jeffrey Schubert Chief School Business Official 779-244-1000 Anticipated Completion Date: 6/30/2025

2024-003 – Eligibility. Auditor Description of Condition and Effect. In our sample of 40 applications from all students receiving free or reduced cost meals during the year, we noted one instance in which the point of sale (POS) system used by the District classified a student to be free, however, application reviewed by the District indicated ineligible to receive free and reduce meal. The student received free-price meals during the 2024 school year. As a result of this condition, the District granted free lunch to a student that did not meet the eligibility requirements. Auditor Recommendation. The district should perform a review of the POS system to match with the application to ensure only eligible students are provided with free and reduced meal. Responsible Person: Scott Leach, Superintendent and Crystal Lee, Food Service Director.Corrective Action. Management concurs with the finding. The district has already put in multiple checks and procedures for food service. The Point of Sale now has custom reports to help make sure students are in the Point-of-Sale system correctly. The Eligibility listing will be verified multiple times throughout the year. The district has set up weekly meetings with the Food Service Director, Superintendent Administrative Assistant, and the Business Manager. Anticipated Completion Date: June 30, 2025.

Finding 2024-004 - Material Weakness and Material Noncompliance: Eligibility and Reimbursement Request for Child and Adult Care Food Program Corrective Action: The District will collaborate with MDE Nutrition staff to complete training, staff assistance visits, and previously established corrective actions. The Business Director and Food Service Director will schedule additional training and visits with Nutrition liaisons and MDE PAL partners. The District will implement electronic point-of-sale devices and digital filing systems to improve recordkeeping and sharing. Documented training for YCS Food Service Staff will be ongoing. District monitoring will be reinstated to ensure compliance with pre-COVID standards. Responsible Person: Director of Finance and Food Service Director

Finding 2024-002 - Material Weakness: Budget Violations Corrective Action: The Finance Director and Business Office will undergo additional training with Tyler Technologies, Michigan School Business Officials and others to optimize financial processes and transaction processing. The team will adhere to the state business calendar for timely reconciliations, budget amendments, and internal control reviews. Responsible Person: Director of Finance

Finding 2024-004 – Child Nutrition Cluster – Special Tests and Provisions – Paid Lunch Equity Contact Person Responsible for Corrective Action: Marsha Bohannon, Controller Contact Phone Number: (317) 867-8000 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The food service director will complete the Paid Lunch Equity spreadsheet, provide the spreadsheet and all supporting documents to the controller for review. Once approved, it will be submitted to the Indiana Department of Education. The supporting documents will either be scanned in or paper documents will be retained for future audit. Anticipated Completion Date: November 19, 2024

Finding 2024-003 – Child Nutrition Cluster – Procurement Contact Person Responsible for Corrective Action: Marsha Bohannon, Controller Contact Phone Number: (317) 867-8000 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We will contact our educational service center and see if they are able to either do an RFI or RFP for food service equipment maintenance or we will otherwise request three quotes for small purchases. We are currently under a contract with SmartCare for food service equipment maintenance until the end of this current school year. Anticipated Completion Date: July 1, 2025