Corrective Action Plans

Condition: The District's supporting documentation for any students who filled out an online application was not properly maintained. Plan: The District will print and save copies of all online applications to enhance record retention. Anticipated Date of Completion: The District will correct this for the 2025-2026 school year. Name of Contact Person: John Belter, Business Manager Management Response: The District acknowledges the lack of supporting documentation for those students who completed online applications. The online applications did not transfer when the District rolled their systems and we no longer have access to the old system in which they were stored. The District notes this and will work to correct it in the future.

10.553, 10.555, 10.559 - Child Nutrition Cluster 2025-002 Net Cash Resources Corrective Action Plan The School Lunch Fund continues to have excess fund balance on hand due to the additional reimbursements provided during the COVID-19 pandemic. The School District is currently reviewing the equipment used by the program and will create a plan to use these funds to support the program's infrastructure. Expected Completion Date June 30, 2026 Contact: Jolean Bliss, School Business Executive Mexico Academy and Central School District 16 Fravor Road, Suite A Mexico, NY 13114 (315) 963-8400

Finding 2025-002 Finding Subject: Child Nutrition Cluster – Internal Controls Summary of Finding: The School Corporation had not properly designed or implemented an effective system of internal controls, which would include segregation of duties, that would likely be effective in preventing, or detecting and correcting material noncompliance. Contact Person Responsible for Corrective Action: Erika Horner, Director of Food Service Contact Phone Number and Email Address: (260)431-2030, ehorner@sacs.k12.in.us Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: All direct certification information shall be initiated by the Director of Food Service: pulling the information monthly from CNP Web. The list of students to be directly certified will be printed, signed and dated by the Director of Food Service. Once information is imported into the student management system, the Assistant Food Service Director would then cross reference the printed list of information to benefits assigned in the student management system to ensure accuracy. The Assistant Food Service Director will initial next to the students they spot check on the list. The printed document with signatures of both parties will be retained with the school years applications.􀯗 The Director of Food Service has the responsibility to ensure that all vendors are free from suspension, debarment, or aren’t otherwise excluded. Suspension and debarment documents are to be collected on a yearly basis. If such documents are not available through the SFA Cooperative, it will be the responsibility of the Director of Food Service to acquire them through SAM.gov website or contacting the vendor directly. All documents are to be signed, dated, and retained by school year by both the Director of Food Services and the Asst. Director of Food Services. Anticipated Completion Date: January 31, 2026 _________________________ Randi Libby_ (Signature) _______Chief Operating Officer __ (Title) __________January 7, 2026__________ (Date)

All free and reduced meal applications are completed electronically by the parent or guardian through the District's online application system. The parent/guardian inputs household and financial information used to determine eligibility in accordance with the income eligibility guidelines established by the State of Ohio and the National School Lunch Program. To ensure internal controls are in place and that eligibility determinations are accurate, the District will implement a review process whereby all electronic applications submitted by parents or guardians will be reviewed by the Cafeteria Supervisor or a designated staff member prior to final approval. The reviewer will ensure that all required fields are completed, the information provided appears reasonable, and the eligibility determination generated by the system is appropriate based on the information provided on the application. If any application appears incomplete or contains questionable information, the Cafeteria Supervisor or designee will contact the parent or guardian for clarification or correction prior to approving the application. Documentation of the review will be maintained by a checklist or retained electronically to demonstrate that the review occurred. Periodic monitoring of the process will be performed to ensure the control procedures continue to operate as intended and that applications are properly reviewed before eligibility is finalized. Anticipated Completion Date Effective immediately and ongoing. Responsible Contact Person Cafeteria Supervisor Dawn Nelson

Finding Number: 2025-004 ALN Number(s) and Program Title(s): 10.646 – Summer Electronic Benefit Transfer Program for Children Views of Responsible Officials and Planned Corrective Action: DHS concurs, in part, and disagrees, in part with this finding. The DCO ARIES team analyzed all potential duplicates for 2024 and 2025. DCO considers 59.1% of the records to not be duplicates, because the records have different SSN’s and dates of birth. A total of 35.9% of cases have the same date of birth but different SSN’s and are potential duplicates. DCO is in the process of reviewing these cases to determine if any system or process adjustments are needed to prevent potential duplicates in the future. The remaining potential duplicates identified by ALA have already been resolved or are being investigated. A refresher training will be conducted with staff who determine eligibility and issue benefits for the Summer EBT program before the program starts in 2026. DCO disagrees that it did not meet the minimum sample verification requirements. A sample of 3% of approved applications received were reviewed according to the 2025 Plan of Operational Management that was approved by FNS. Anticipated Completion Date: 6/30/2026 Contact Person: Name: Mary Franklin Title: Director, Division of County Operations Agency: Department of Human Services Address: 700 Main Street City, State, Zip: Little Rock, AR 72201 Phone Number: 501-681-8377 Email Address: Mary.Franklin@dhs.arkansas.gov

Finding Numbers: 2025‐002 Program Name/Assistance Listing Title: Child Nutrition Cluster Assistance Listing Numbers: 10.553, 10.555, 10.559 Contact Person: Eloyce Gillespie, Business Manager Anticipated Completion Date: April 30, 2026 Planned Corrective Action: Casa Blanca Community School has implemented a review process to monitor expenditures across all funds. As part of this process, Management has adopted a review process relating to expenditures of all funds to minimize any negative effect on cash for these funds. This review includes a comparison of expenditures to budgets for all funds to ensure that they do not exceed anticipated revenues. Additionally, if it is determined that the program will exceed the anticipated revenue, Management will determine if such overages (negative cash balances) are to be addressed through operating transfers using Indian School Equalization Program funding.

Garfield County School District No. 16 respectfully submits the following corrective action plan for the year ended June 30, 2025. Finding 2025-001 Reporting Significant Deficiency in Internal Control over Compliance and Other Non-Compliance Corrective Action: The District agrees with the finding related to insufficient supporting documentation for the National School Lunch Program reimbursement claims, as it related to sack lunches/field meals. Personnel Responsible for Corrective Action: Jody Williams, Food Service Director Anticipated Completion Date: The District has corrected this issue as of the date of this report, and now requires formal written requests for all sack lunches/field meals, to ensure counts are properly documented.

2025-001 ELIGIBILITY 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 Type of Finding: Noncompliance, significant deficiency in internal control Compliance Requirement: E. Eligibility Criteria: Federal regulations require participating districts to determine student eligibility for free, reduced price, and paid meals based on household income and household size thresholds established annually by the U.S. Department of Agriculture. Applications must be reviewed and approved using the current income eligibility guidelines and appropriate calculation methods to ensure correct benefit levels. Condition: During testing of 25 student meal applications, we noted 1 instance where the District incorrectly calculated household income relative to household size when determining eligibility status. In these cases, students were approved for free price meals when the income calculations supported reduced meal status. Cause: The District did not have sufficient review controls in place to ensure that eligibility determinations were recalculated or independently verified prior to approval. Effect: As a result of the errors, certain students received free meal benefits for which they were not eligible. This may have resulted in improper program reimbursement claims and indicates that the District’s controls over eligibility determinations were not operating effectively. Questioned Costs: The projected questioned costs related to these errors are not expected to be material; however, the District may have received reimbursement at the free price rate rather than the reduced rate for affected meals. Corrective Action: The District will review their meal application process and implement a more stringent review to ensure eligibility criteria are met based on household income. Planned completion date for corrective action plan: For the period ending June 30, 2026. Name of the contact person responsible for corrective action: Erika Aguallo, Business Manager

NPS will enhance its system of internal controls by implementing a standardized, enterprise-level review and approval process for all National School Lunch Program (NSLP) and Fresh Fruit and Vegetable Program (FFVP) reimbursement reports. Effective immediately, all claims for reimbursement will require documented supervisory review and formal approval prior to submission, ensuring accuracy, completeness, and full compliance with federal and program requirements. Related policies and procedures will be revised to clearly define accountability, documentation standards, and submission timelines. In parallel, NPS will invest in targeted training for all personnel involved in the preparation and certification of claims to ensure consistent execution of these requirements. To sustain compliance and reinforce accountability, we will establish a structured monitoring framework that includes periodic, risk-based reviews of submitted claims and supporting documentation. This approach will provide ongoing assurance that all claims are properly reviewed, approved, and supported in accordance with established standards.

Condition: The same individual is responsible for preparing and submitting monthly reimbursement claims for the Child Nutrition Program without an independent review or approval prior to submission. Plan: A second person (superintendent) compares the meal counts in the claim to the SDS daily meal count reports, monthly participation summary, eligibility rosters (free, reduced, paid) and USDA reimbursement rates. The reviewer will then sign and date a reconciliation sheet before submission. Management Response: The corrective action plan was discussed with the employee responsible for filing the claim, the business manager, and the superintendent. After discussion, the plan was approved by the superintendent.

The Screven County School System Nutrition Department will submit purchase order requests in YOSS, which is the digital Accounts Payable system utilized by the district. Requests will be reviewed for approval by the Director of Operations. If approved by the Director of Operations, the request will be sent through YOSS for the Superintendent's approval and then to bookkeeping to be ordered. When the items are received, accounts payable will send the invoice through YOSS for approval for payment to the Superintendent. This will provide a multiple layer to the approval process to ensure that procurement procedures are being followed.

Finding Number: 2025-003 Planned Corrective Action: To address this finding, FNW immediately implemented a temporary solution. On or about September 8, 2025, FNW created a ticket to commence work on a permanent solution to address the audit finding. The solution deployed on March 18, 2026. Anticipated Completion Date: March 18, 2026 Responsible Contact Person: Terricka Washington, Division of Food, Nutrition and Wellness Information Office/LaSharonté Williams-Potts, Assistant Division Director

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