Corrective Action Plans

Finding No.: 2025-005 Condition: The District did not maintain sufficient records to detail the history of procurement. The organization did not ensure that vendors complied with all contract terms, conditions and specifications. Plan: The district is currently running a Food Service Management Company bid that complies with the state’s procurement. Anticipated Date of Completion: August 1, 2026 Name of Contact Person: Nicholas Valderas, Business Manager Management Response: See plan above

FA 2025-001 Improve Controls over Procurement and Suspension and Debarment Compliance Requirement: Procurement and Suspension and Debarment Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Federal Awarding Agency: U.S. Department of Agriculture Pass-Through Entity: Georgia Department of Education AL Numbers and Titles: 10.553 School Breakfast Program 10.555 National School Lunch Program Federal Award Numbers: 255GA324N1199 (Year: 2025) Questioned Costs: $7536 Description: A review of expenditures charged to the Child Nutrition Cluster revealed that the School District's internal control procedures were not operating appropriately to ensure that the School District's procurement and suspension and debarment procedures were followed. Corrective Action Plans: An annual Invitation for Bid (IFB) for equipment repair services will be issued to a minimum of two or more vendors for quotes. Final vendor selection will be made by the SNP Director and communicated to the Board for approval. These steps will ensure compliance with procurement regulations and proper documentation of services. In addition, the Federal Programs Manual will be amended to state that all vendors are reviewed annually to verify their suspension and debarment status. Estimated Completion Date: 6/30/2026 Contact Person: Joshua Worth , CFO Telephone: 912-699-7030 Email: joshua.worth@jeff-davis.k12.ga.us

2025-003 – Controls Over Disbursements Federal Program Information: Department of Education – Special Education Cluster (IDEA) CFDA – 84.027/84.173 Department of Education – Child Nutrition Cluster CFDA – 10.553/10.555/10.556/10.559/10.579/10.582 Criteria: 2 CFR 200.303 Internal Controls Condition: During audit procedures, it was identified that the Supervisory Union did not have internal controls in place to ensure that invoices were properly approved and paid in a timely manner. Cause: Unknown Effect: The Supervisory Union did not always properly approve invoices, could not always locate invoices, and paid invoices beyond the due date. Identification of Questioned Costs: None identified. Context: Between both programs, a total of 43 disbursements were chosen for testing. 11 were adjusting entries. Of the remaining 32, 4 were not paid in a timely manner; 21 were missing either invoices or PO’s or not properly approved. Repeat Finding: This is a repeat finding. Recommendation: It is recommended that the Supervisory Union implement controls to ensure that invoices are managed and paid appropriately. Management Response: Management agrees with the recommendation and will implement controls to ensure that invoices are managed and paid appropriately. Anticipated completion date 7/1/2026

U.S. Department of Agriculture 2025-008 Weakness in Internal Control Over Compliance of Suspension and Debarment Federal Program: Child Nutrition Cluster — USDA Commodities (15.550), School Breakfast Program (10.553), National School Lunch Program (10.555), Summer Food Service Program for Children (10.559) Management agrees with the finding and will update the Child Nutrition Procurement Plan and related procedures to ensure suspension and debarment requirements are clearly applied to all covered transactions, including those executed through various procurement methods. Management will also work to design and implement internal controls to ensure suspension and debarment verifications are consistently performed and documented for covered transactions under the Child Nutrition Cluster. Person responsible: Christin Legros, Director of Finance Expected completion date: June 2026

U.S. Department of Agriculture 2025-007 Weakness in Internal Controls Over Compliance of Allowable Costs/Cost Principles of Payroll Disbursements Federal Program: Child Nutrition Cluster — USDA Commodities (15.550), School Breakfast Program (10.553), National School Lunch Program (10.555), Summer Food Service Program for Children (10.559) Management agrees with the finding and has reviewed the payroll items identified during the audit and has taken corrective action to address schedule discrepancies and unsupported payroll entries. Management has conducted a review of employee schedules within the timekeeping system to ensure alignment with payroll records and has corrected errors identified. Management plans to continue performing periodic reviews of payroll data to identify potential discrepancies and to take corrective action as needed. Management will also evaluate identified payroll discrepancies on a case‑by‑case basis to determine whether recovery or adjustment is appropriate. Person responsible: Christin Legros, Director of Finance Expected completion date: June 2026

Recommendation: We recommend that Eastern Lancaster County School District implement procedures to ensure that SNP Claim for Reimbursement Summary reports are independently reviewed and approved prior to submission to Program Electronic Application and Reimbursement System (PEARS). This review should be performed by an individual who is not involved in the preparation of the reports and evidence of the review should be documented. School District Response: (Corrective Action) Eastern Lancaster County School District will implement formal internal control procedures requiring review and documented approval of all SNP Claim for Reimbursement Summary reports prior to submission in PEARS. The following procedures will be implemented: 1. The Director of Food Services will prepare the monthly SNP Claim for Reimbursement Summary report and compile all supporting meal count documentation. 2. Prior to submission, the Administrative Assistant to the Director of Food Services or another designated individual independent of the preparation process will: o Review the claim for mathematical accuracy. o Verify meal counts against supporting documentation. o Confirm claims are submitted within required timelines. 3. Evidence of the review and approval will be documented through: o Signature or electronic approval on the reimbursement summary report. o Retention of supporting documentation in accordance with federal and state record retention requirements. 4. A written standard operating procedure (SOP) outlining these review and approval responsibilities will be developed and communicated to applicable personnel. 5. The Chief of Finance and Operation will periodically monitor compliance with the procedure to ensure controls remain effective. Anticipated Completion Date: The corrective action procedures will be fully implemented by June 1, 2026. Responsible Person for the Corrective Action: Keith D. Ramsey, Chief of Finance and Operations

Corrective Action Plan 1. Establish Written Procedures o The District will develop and adopt written procedures outlining the process for preparing, reviewing, and approving monthly Claims for Reimbursement for all food service programs (Breakfast, Lunch, and Summer). o Procedures will specify responsible staff, required documentation, timelines, and review steps prior to submission. 2. Implement Dual Review Process o The Food Service Director ( or designee) will prepare the monthly meal count report using data from the Infinite Campus system. o The assistant to the food service coordinator will perform a secondary review before submission to DESE. o The review will confirm: • Meal counts match Infinite Campus reports. • Correct classification of free, reduced, and paid meals. • Accuracy of totals by meal type (breakfas1/lunch). o Both preparer and reviewer will sign and date the Monthly Meal Count Verification Form as documentation ofreview. 3. Post-Submission Verification o After clairo submission, the reviewer will retain a copy of the DESE Claim for Reimbursement and supporting Infinite Campus reports in a centralized digital folder. o Random quarterly spot checks will be performed to confirm continued accuracy and compliance. 4. Training o The Food Service Director and business office staff will receive annual training on meal count reporting procedures and DESE claim submission requirements. o Training records will be maintained. 5. Timeline for Implementation o Written procedures finalized and approved by December 15, 2025. o Dual review process implemented beginning with the December 2025 claim. o Staff training completed by January 31, 2026. 6. Responsible Parties o Food Service Director - preparation and initial verification. o Chief Operations Officer - review and approval. o Superintendent - oversight and policy adoption. We are committed to ensuring the accuracy and integrity of our meal count reporting and eligibility determinations. The District will implement these corrective actions in a timely manner to address the identified findings and ensure compliance with applicable federal regulations.

The staff member responsible for completing the verification process—Accounts Payable—will attend the required training/webinar to ensure full compliance with USDA regulations. Accounts Payable will complete training specifically covering the proper procedures and requirements for the verification process, as outlined by the State Agency and USDA guidelines. Documentation on the completed training will be retained on file and made available upon request. In addition to training, both Accounts Payable and Operations Manager are signed up to receive the Ohio Ed Updates SNP Items of Interest. This corrective action is being taken promptly to address the findings and to prevent future occurrences. The district is committed to ensuring all staff involved in child nutrition programs are appropriately trained and fully understand their responsibilities.

The District will pull a sample of 5% of applicants entered into the Payschools system as of October 31 and perform an independent eligibility determination. Once the eligibility determination has been completed, we will compare it to the eligibility determination made by the Payschools system and note any discrepancies.

The Charter School will require the Food Service

Management Company (FSMC) to provide a current SOC 1 Type II Report in accordance with the bid and contract requirements. Written notification will be sent to the FSMC requesting the report within a specified timeframe.

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

The Food Service Supervisor will verify that PaySchools contains the correct income eligibility guidelines provided by ODEW for the current school year. These income determination charts will be verified twice annually, prior to application submissions and again midway through the school year. In addition, the District will randomly sample 10% of portal applications entered in PaySchools to ensure eligibility determinations were processed correctly in accordance with program income eligibility requirements. The annual verification process conducted in November will further confirm the accuracy of selected applications. Documentation of these reviews will be maintained in spreadsheet format and printed, signed, and dated by the Food Service Supervisor by November 15 of each school year.

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

Finding ref number: 2025-002 Finding caption: The District did not have adequate internal controls for ensuring compliance with federal eligibility requirements. Name, address, and telephone of District contact person: DeeDee Buckingham, HR Director Director of Human Resources Yelm Community Schools (360) 458-6105 Corrective action the auditee plans to take in response to the finding: Mandatory Staff Training & Professional Development: • Food Services staff responsible for processing and managing student meal applications using Qmlativ will undergo training provided by ESD113 in August and online OSPI CNEEB Application and Direct Certification Training. • Training will explicitly cover federal regulations under 7 CFR Part 245.6 (Application, Eligibility, and Certification) and 2 CFR Part 200.303 (Internal Controls over federal programs). Implementation of Dual-Review Internal Controls: • The District will establish written protocols for processing online and paper applications. • In collaboration with ESD 113, a report will be developed which will be run monthly reviewing any application that have not been validated for income eligibility or direct certification provided by the state. Anticipated date to complete the corrective action: . System Controls: Fully implemented by August 1, 2026 (prior to the rollout of the 2026-27 school year application window). . Staff Training Completion: No later than September 1, 2026.

Finding ref number: 2025-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with federal eligibility requirements. Name, address, and telephone of District contact person: Marci Bannan, Director of Business Services 121 Whitesell St NE Orting, WA 98360 Corrective action the auditee plans to take in response to the finding: Eligibility: The District will document the internal controls that are in place for the monthly direct certification downloads and will print the certification download along with saving it electronically so that the files are easy to provide for future audits. Anticipated date to complete the corrective action: July 31, 2025

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

The District reviewed the existing internal controls for compliance with federal eligibility requirements and have added additional management oversight of existing processes to improve completeness. In addition, the district will implement process improvements to increase transparency of record retention.

Going forward we have already put in place the following action items: • In order to maintain eligibility records in a location that is easy to locate, we will create a main, online depository to house all eligibility forms by year so that we can readily access proof of eligibility for all future audits. • In order to ensure that we don’t exceed federal procurement thresholds due to unforeseen increases in meal demand, we will be far more conservative in our meal forecasts and follow federal procurement guidelines any time we think we might get close to meeting threshold requirements. • In order to meet federal procurement requirements around receiving three bids for purchases, we will add an additional step to our procurement process that ensures we receive at least three formal bids or can document that we placed a formal request for bids in a regional publication such as the Seattle Journal of Commerce and did not receive three formal bids. We currently request bids from all vendors that service our area but we don’t always receive at least three formal bids back. This additional step will ensure that we made every effort to reach out to all possible vendors in the state even if they do not service our area.

Condition: Multiple students were incorrectly coded as free and reduced meal status when they should have been switched to paid status. Plan: The District will ensure the direct certification list is properly maintained and put new processes in place to verify students’ meal status year over year. Anticipated Date of Completion: The District will correct this for the 2025-2026 school year. Name of Contact Person: Nathan Knitt, Director of Business Services Management Response: The School District of Fort Atkinson accepts the plan for the Corrective Action listed above and does not dispute anything.

Condition: Supporting documentation for the monthly food service meals provided did not align with the claims reported for reimbursement by free, reduced, and paid categories. Plan: The District will review supporting documentation for meals to ensure all meals are accounted for. Anticipated Date of Completion: The District will correct this for the 2025-2026 school year. Name of Contact Person: Nathan Knitt, Director of Business Services Management Response: The School District of Fort Atkinson accepts the plan for the Corrective Action listed above and does not dispute anything.

Finding caption: The District did not have adequate internal controls and did not comply with federal suspension and debarment requirements Name, address, and telephone of School District contact person: Heather Judd 217 S Hofstetter Colville, WA 99114 (509) 684-7856 Corrective action the auditee plans to take in response to the finding: (If the auditee does not concur with the finding, the auditee must list the reasons for disagreement). The District will strengthen internal controls over suspension and debarment compliance for Nutrition Services vendors. Effective immediately, all vendors expected to meet or exceed the $25,000 federal threshold will require documented suspension and debarment verification prior to contract execution or renewal. The Nutrition Services Director will be responsible for completing and maintaining documentation of the verification; however, the Business Office will implement an annual review each September 1 to ensure all required checks are completed, properly documented, and retained. Additionally, procedures will be updated to require submission of all debarment and suspension documentation to the Business Office for centralized recordkeeping, with periodic monitoring throughout the year to ensure compliance despite staff turnover. Anticipated date to complete the corrective action: 9/1/26

Finding ref number: 2025-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with federal procurement requirements. Name, address, and telephone of District contact person: Tom Hitt, Purchasing and Compliance Manager 1215 W. Lewis Street Pasco, WA 99301 Phone: (509) 543-6700 Corrective action the auditee plans to take in response to the finding: Pasco School District concurs with the audit finding. The District has evaluated the circumstances surrounding this issue and determined that the root cause was a lack of specific procedural controls and staff training related to cooperative (“piggyback”) procurement requirements, particularly regarding vendor regional assignments under Department of Enterprise Services (DES) contracts. As noted in the audit, staff were not aware that contractors were assigned to specific geographic regions, which resulted in the selection of a vendor outside the District’s designated region. The District recognizes that the selected vendor in question was local to the District, and following the DES contract requires the District to instead order from a Spokane company, which is 2-3 hours away. The District places a strong emphasis on supporting local businesses as part of its commitment to the community, and this priority was a contributing factor in procurement decisions in this instance. However, the District recognizes that all procurement activities involving federal funds must strictly adhere to applicable federal, state, and contract requirements. Upon discovery of the issue during the audit process, Nutrition Services immediately initiated corrective action. The department transitioned to the appropriately assigned vendor, and within a short timeframe completed all necessary onboarding, ordering, and delivery processes. Procurement activities are now aligned with DES contract requirements. Additionally, while the District had been utilizing a vendor outside of the assigned DES contract region for these purchases, that vendor is an approved provider under the Office of Superintendent of Public Instruction’s Department of Defense (DoD) Fresh Produce Program. The District will continue to utilize that vendor when procuring produce through DoD-funded programs, where appropriate. To prevent recurrence, the District will implement the following corrective actions: 1. Staff Training and Capacity Building Provide training on federal procurement requirements and DES contracts Reinforce that local preference cannot override compliance requirements 2. Ongoing Monitoring and Internal Controls Conduct periodic internal reviews of procurement activity Perform documentation audits and provide corrective feedback 3. Coordination with DES and OSPI Guidance Require staff to reference DES and OSPI guidance when utilizing cooperative contracts Through these actions, the District will strengthen internal controls and ensure compliance with federal procurement requirements moving forward. Anticipated date to complete the corrective action: June 30, 2026

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Mossyrock School District No. 206 September 1, 2024 through August 31, 2025 This schedule presents the corrective action the District is planning to take for findings included in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Finding ref number: 2025-002 Finding caption: The District did not have adequate internal controls and did not comply with federal procurement and suspension and debarment requirements. Name, address, and telephone of District contact person: Jodi Spahn, Business Manager PO Box 478 Mossyrock, WA 98564 (360) 983-3181 Corrective action the auditee plans to take in response to the finding: (If the auditee does not concur with the finding, the auditee must list the reasons for disagreement). The District acknowledges the finding regarding insufficient controls that would ensure compliance with federal procurement and suspension and debarment requirements. To strengthen compliance with federal procurement requirements, the District will add a Buy American clause within procurement documents to ensure contractors are aware of the requirement. In addition to providing training and education to relevant staff, the District will update processes within the business office to ensure the proper check for exclusion records at SAM.gov is completed prior to payment to vendors or contractors meeting the $25,000 or more threshold, and that proper documentation is retained. Additionally, the District will add a clause to all contracts being paid in part or fully with federal funds, that states the contractor is not suspended or debarred. Anticipated date to complete the corrective action: Immediate