Corrective Action Plans

Finding No: 2025-003 Condition: The District does not have an adequate review process in place for meal count claims prior to submission. Claims prepared by one individual are submitted without independent verification. As a result, the district reported an incorrect lunch count for January 2025. This error appears to be isolated to January; however, it would likely have been prevented if a review process were in place. Plan: The District will implement a system in which meal count claims will have secondary approval by the CSBO. Anticipated Date of Completion: June 30, 2026 Name of Contact Person: Mark Orszula, CSBO

The District will review the work performed by the individual preparing the reports before submission

The District will implement additional internal controls to ensure that all household income is properly included in the eligibility determination process for free and reduced-price meals. The Food Service Director (or authorized designee) will perform a second-level review of all applications prior to final approval, focusing on verification that all sources of income - including income earned by students - are included in the total household calculation. The District will update its internal checklist and train staff responsible for reviewing meal applications to verify that each application is complete, income sources are clearly identified, and supporting documentation (if applicable) has been properly considered. The Food Service Director will conduct a mid-year self-audit of eligibility determinations to confirm accuracy and compliance with 7 CFR 245.6 requirements. The District will maintain documentation of reviews and training to support compliance efforts in furter audits.

12/7/2026 Cognizant or Oversight Agency for Audit, Codman Academy Charter Public School and Affiliate (the School) respectfully submits the following corrective action plan for the year ended June 30, 2025. Name and address of independent public accounting firm : AAFCPAs, Inc. 50 Washington Street Westborough, MA 01581 Audit period: July I, 2024 - June 30, 2025 The finding from the June 20, 2025 Schedule of Findings and Questioned Costs is discussed below. FINDINGS-FEDERAL AWARD PROGRAMS AUDITS 2025-001 Required Payroll Forms Recommendation: AAFCPAs recommends the School implement a standardized checklist and conduct periodic internal reviews of onboarding documentation to ensure all required forms are properly completed and retained in accordance with Federal regulations. Action Taken: As of January, 2026 the staff member responsible for staff on boarding and payroll processing is no longer employed at the School. Codman, with a new staff person in charge of these tasks has instituted a standardized checklist for on boarding, has performed a backward looking audit of employee files and will conduct internal periodic reviews for completeness and accuracy. If the Cognizant or Oversight Agency for Audit has questions regarding this plan, please tell Derrick Cielsa, Executive Direct as 617-287-0770 Sincerely yours, Derrick Ciesla Excutive Director

12/7/2026 Cognizant or Oversight Agency for Audit, Codman Academy Charter Public School and Affiliate (the School) respectfully submits the following corrective action plan for the year ended June 30, 2025. Name and address of independent public accounting firm : AAFCPAs, Inc. 50 Washington Street Westborough, MA 01581 Audit period: July I, 2024 - June 30, 2025 The finding from the June 20, 2025 Schedule of Findings and Questioned Costs is discussed below. FINDINGS-FEDERAL AWARD PROGRAMS AUDITS 2025-001 Required Payroll Forms Recommendation: AAFCPAs recommends the School implement a standardized checklist and conduct periodic internal reviews of onboarding documentation to ensure all required forms are properly completed and retained in accordance with Federal regulations. Action Taken: As of January, 2026 the staff member responsible for staff on boarding and payroll processing is no longer employed at the School. Codman, with a new staff person in charge of these tasks has instituted a standardized checklist for on boarding, has performed a backward looking audit of employee files and will conduct internal periodic reviews for completeness and accuracy. If the Cognizant or Oversight Agency for Audit has questions regarding this plan, please tell Derrick Cielsa, Executive Direct as 617-287-0770 Sincerely yours, Derrick Ciesla Excutive Director

Management has reviewed this finding and indicated it will revise its procedures to ensure corrective action is taken.

Finding Number: 2025‐001 Program Name/Assistance Listing Title: Child Nutrition Cluster Assistance Listing Numbers: 10.553, 10.555, 10.559, 10.582 Contact Person: Monique Mata, Chief Financial Officer Anticipated Completion Date: August 31, 2026 Planned Corrective Action: The District was not aware of the change in calculating indirect cost for Child Nutrition Cluster. The District will review the indirect cost calculation for the affected fiscal year and confirm the amount of overcharged indirect costs. The District will determine the appropriate method for reimbursing or adjusting the $189,745 overcharge to the Child Nutrition Program. Any required repayment or journal entry correction will be completed. The District will update its indirect cost rate guidance to exclude food service management company payments exceeding $50,000 from the indirect cost base. The District will conduct an annual internal review of indirect cost calculations to ensure continued compliance with USDA and ADE guidance. The District will maintain communication with ADE School Finance and Health & Nutrition Services to stay current on guidance updates.

Response and Corrective Action Plan: The District will annually prepare the indirect cost charged to the program based on the actual fiscal year trial balance and the federal government MTDC requirements. The calculation process will implement a procedure to consider other adjustments necessary to be in compliance. The District will provide an estimate to the Board each June to ensure proper approval of fund transfers.

Significant Deficiency in Internal Control over Financial Reporting Recommendation: We recommend the District continue to improve its processes and procedures surrounding reporting of claims meal summaries. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The District will work to develop processes and procedures to ensure reports tie to claims summaries for meal counts. Name of the contact person responsible for corrective action: Shari Thompson Planned completion date for corrective action plan: June 30, 2026.

Response and Corrective Action Plan: The District will annually prepare the indirect cost charged to the program based on the actual fiscal year trial balance. The District will provide an estimate to the Board each June to ensure proper approval of fund transfers.

FINDINGS- MAJOR FEDERAL AWARD PROGRAMS AUDIT Material Weakness U.S. Department of Education- Child Nutrition Cluster- AL 10.553 / 10.555 Finding No.: 2025-006 Condition: District failed to submit annual verification report and monthly claim reports for Child Nutrition Program Cluster in accordance to Illinois School Code. Recommendation: The District should review all reports to ensure they are submitted timely. Action Taken: The District concurs with the recommendation and completed a Corrective Action Plan with ISBE in accordance with the 3 year exception policy. District will work to ensure the Corrective Action Plan approved by ISBE is followed.

Finding Synopsis - Three vendor disbursements made under the Child Nutrition Cluster did not have the required purchase orders as required by the District's established internal control policies. Action Steps - The District will communicate with staff the importance of preparing purchase orders prior to making a purchase. We will establish a procedure in which the purchaser must review required documentation, inclusive of purchase orders, prior to making a purchase. Contact Person - Kevin Spain, Superintendent Anticipated Completion Date - December 31, 2025

Condition: Based upon single audit testing noted 4 applications approved in the wrong category: two applications that were approved as free but should have been reduced, one application that was approved reduced but should have been free, and one application that was approved reduced but should have been paid. Also noted that per ISBE exam, ISBE noted eight applications that were approved in the wrong category: 7 applications that were approved free but should have been reduced and one application that was approved free but should have been paid. Also, the ISBE exam noted two applications that were missing a valid SNAP case number. Recommendation: We recommend establishing a procedure to ensure household eligibility applications are approved in the appropriate category according the current income guidelines. Management Response: All household eligibility applications will be first taken be one employee, checked over by a second employee and then confirmed by a third employee. Anticipated Date of Completion: June 30, 2026

Recommendation: We recommend that the District review its internal controls and implement a procedure to ensure all applications for the Child Nutrition Cluster are provided to the Business Manger for review to ensure the eligibility determination is correct. Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Action Taken in Response to Finding: The Food Service Director and her assistant will ensure ALL application are reviewed by each of them, and then passed onto the Business Manager for a third review and approval. The Food Service Director will keep all applications on file. Name of Responsible Official: Tera Fritz, Business Manager Expected Completion Date: September 1, 2025

Recommendation: We recommend that the District review its internal controls and implement a procedure to ensure all reports required under the grant have a designated reviewer that is distinct from the individual responsible for preparing. Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Action Taken in Response to Finding: The Business Manager and School Food Service Director met regarding the finding and agreed that the Food Service Director will continue to gather the required claim data and enter the appropriate data into DPIs required Excel template monthly. All supporting documentation as well as the Excel documents will be emailed to the Business Manager monthly. The Business Manager will verify the numbers in the Excel documents using the supporting documentation. If the Business Manager agrees with the numbers in the Excel files, they will be uploaded to DPI as is. If any discrepancies are discovered, the Food Service Director and the Business Manager will work together to ensure the correct data is sent to DPI. Name of Responsible Official: Tera Fritz, Business Manager Expected Completion Date: September 1, 2025

Condition: Testing revealed that 1 of the 25 students tested were given the incorrect determination of free or reduced meal prices. Plan: The District should encourage all applications electronically. If a paper application is submitted, there should be multiple levels of review before approval. Anticipated Date of Completion: June 30, 2026 Name of Contact Person: Jason Brunaugh, Assistant Superintendent of Finance and Human Resources Management Response: The District will review procedures to determine if added steps are needed to ensure proper classification of manual applications.

CHILD NUTRITION CLUSTER - REPORTING Recommendation: Management should ensure their key controls are operating effectively and they should document the review and approval of all the reports. Explanation of Disagreement with Audit Findings: There is no disagreement with the audit finding. Action planned/taken in response to finding: The District will evaluate its control processes in place prior to meal claims being reported to the state for reimbursement and ensure they properly review and approve the claims being reported prior to reporting them and document that approval. The District also understands the person reviewing and approving the claims to be reported should be different from the individual compiling that amount to be reported so two individuals are involved in the process. Name of the contact person responsible for corrective action: Trisha Zajicek, Director of Finance Planned completion date for corrective action plan: June 30, 2026

2025-006 - Child Nutrition Cluster – Eligibility - The District is aware of the missing eligibility documents for the Child Nutrition program and will implement new procedures and a plan to reduce the missing documentation. Responsible Officials – Joe Dawidziak, Superintendent Anticipated Completion Date – The District will correct this in the subsequent fiscal year.

Condition During testing, auditor determined that 24 students had an incorrect eligibility status utilized for a portion of the school year. Recommendation We recommend that the District look for training opportunities for food service staff members to ensure that they have a good understanding of the program’s compliance requirements. Additionally, all students receiving free or reduced price meal benefits should be reviewed to ensure that they have a valid application or direct certification on file. Comments on the Finding The District agrees with the finding and has implemented procedures to prevent this, in the future. Actions Taken As of the date of this notice, training opportunities will be sought out to further food service staff members’ educations regarding the program compliance requirements. Eligibility for all students will be reset each year to ensure that only those who are direct certified or that have submitted an application and are eligible for free or reduced meals will receive those benefits.

2025-003 – Child Nutrition Cluster – Activities Allowed or Unallowed and Allowable Costs and Cost Principles and Reporting Condition During testing of the sponsor claim reimbursement reports, it was found that the District submitted inaccurate meal counts on two monthly reports. Recommendation We recommend that the District review its controls related to monthly reimbursement requests for the Child Nutrition Cluster in order to ensure that accurate meal counts are submitted. Comments on the Finding The District agrees with the finding and has implemented procedures to prevent this, in the future. Actions Taken As of the date of this notice, reimbursement claims will be prepared using the Power School software’s meal counts, and the claim will be reviewed by an individual other than the preparer before being submitted.

Monitoring of federal compliance information by management and the Board of Education will continue at the District. The District will verify vendors are not suspended or debarred prior to entering into covered transactions.

Monitoring of federal compliance information by management and the Board of Education will continue at the District. The District will conduct a documented review of monthly claim reports.

FINDING 2025-001 Information on the federal program: Subject: Child Nutrition Cluster - Internal Controls over Eligibility Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY2024, FY2025 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Finding: Material Weakness Context: During the testing of internal controls over eligibility determinations for free and reduced meals, we noted there was no formal, documented review control in place. There is no documented, secondary review for the applications entered in the food service software which determines eligibility. Additionally, there was no documented review by School Corporation personnel of the Income Eligibility Guidelines used by the food service software which are updated on annual basis Contact Person Responsible for Corrective Action: Amber Swinehart, Food Services Director Contact Phone Number: 765-759-2592 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Food Services Director will provide evidence of review for the eligibility parameters from Titan at least once a year prior to the start of the school year Anticipated Completion Date: 6/30/2026

Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Actions Planned in Response to Finding: Staff have been retrained, and additional monitoring procedures have been implemented. The Food Service Director will oversee ongoing compliance. Official Responsible for Ensuring CAP: Dan Anderson, Superintendent, is the official responsible for ensuring corrective action. Planned Completion Date for CAP: June 30, 2026. Plan to Monitor Completion of CAP: The Board of Education will be monitoring this corrective action plan. Dan Anderson Superintendent

2025-001 Reporting US Department of Education – AL #s10.553, 10.555, 10.559 and 10.582 Child Nutrition Cluster Condition: The District submitted monthly child nutrition reimbursement claims that contained inaccurate meal counts for multiple months during the fiscal year. Specifically, the District overstated reimbursable meal counts due to errors in including non-reimbursable meals served. Additionally, the claims were not subject to an independent review prior to submission to ensure accuracy and completeness. Name of Contact Person: Ann Berman, Business Manager Plan of Action: The District will revisit the internal control processes surrounding the grant reporting and reimbursement process to ensure meal count information submitted is within program requirements of Child Nutrition Cluster programs. In the event there are questions surrounding meal count and other information subject to reporting, the District will continue to rely on timely guidance from external governmental accounting consultants, the Oregon Department of Revenue, and the Oregon Department of Education.