Corrective Action Plans

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

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Cheney School District No. 360 September 1, 2024 through August 31, 2025 This schedule presents the corrective action planned by the District for findings reported 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: 2025-001 Finding caption: The District did not have adequate internal controls and did not comply with federal Title I assessment system security and eligibility requirements.Name, address, and telephone of District contact person: Jamie Reed, Director of Finance and Operations 12414 S. Andrus Road (509) 559-4501 Corrective action the auditee plans to take in response to the finding: Assessment system security: Assessment Administration Procedures have been reviewed for the 2025-2026 school year by Building Assessment Coordinators (BAC). They will ensure a Test Security Building Plan (TSBP) will be provided for the WIDA assessment administered in their building this school year. BAC Assessment Google folders for 2026-2027 school year are currently being adjusted to provide additional organization to ensure all required documents are completed by BAC's then submitted to the District Assessment Coordinator (DAC) upon completion of the assessment window. Eligibility: The District has already begun corrective actions to address these concerns. District staff have reviewed federal Title I ranking and allocation requirements, including OSPI guidance related to poverty ranking methodology and the 75 percent rule. The District will implement additional review procedures during the annual Title I application and budgeting process to verify poverty calculations, school rankings, and allocation methodologies prior to submission. The District will also document comparability and supplemental funding determinations for any qualifying schools not directly served with Title I funds. Additionally, the District will provide targeted training for staff responsible for federal program administration and budgeting to ensure ongoing compliance with federal and OSPI Title I requirements. Anticipated date to complete the corrective action: Corrective review for the end of the 25-26 school year and full corrective action for the 26-27 school year.

Finding No. 2025-005 Condition – The District did not prepare bank reconciliations during fiscal year 2025. As a result, a portion of National School Lunch and School Breakfast program receipts were not promptly credited to the appropriate food service revenue accounts, and those reimbursements that were recorded incorrectly recorded to the Evidence-Based Funding revenue account in error. Plan – The District will perform bank reconciliations in a timely manner and ensure that National School Lunch and School Breakfast program receipts are appropriately recorded to the proper food service revenue accounts. Anticipated Date of Completion: 7/1/2025 - current Name of Contact Person: Matt Stines, Superintendent

Finding No. 2025-004 Condition – Claims submitted for reimbursement did not reconcile with the District’s internally prepared monthly claim summary report. Plan – The District will ensure that meal counts are thoroughly reviewed prior to submission. Meal counts are entered into the computer by the FSMC, and has been a place where errors have occurred. The district secretary is responsible for entering the meal counts into the state system. She is verifying the counts from the FSMC, comparing to attendance and invoices, and ensuring correct data goes into IWAS. This was started last spring, when we became aware of FSMC inconsistencies. The current year, FY26, has been much more accurate. Anticipated Date of Completion: current – 9/1/2026 Name of Contact Person: Matt Stines, Superintendent

The District experienced a transition in the Business Manager position in February 2025. Following this personnel change, the District began implementing procedural adjustments to strengthen internal controls and improve segregation of duties. Because all three district office staff members were either new to their roles or new to the District during this transition, implementation of these changes took additional time while staff became familiar with their responsibilities. With staff now established in their respective positions and gaining experience, the District has reassigned certain duties and implemented additional oversight procedures to better segregate financial responsibilities and strengthen internal controls moving forward.

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: Name: John Hassell Address: 1105 Dale. Ave. Benton City, WA 99320 Phone Number: 509-588-2004 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 agrees with the auditor’s finding. The District did not have adequate controls to ensure we followed our policy to comply with the procurement requirements required by the Child Nutrition Cluster. The District is committed to maintaining strong internal controls and ensuring all future expenditures of federal funds fully comply with procurement mandates. The District is conducting a comprehensive review of our procurement policies with all relevant staff to ensure we follow our policies regarding federal compliance requirements. The District will ensure that the start of each fiscal year that The District will follow a competitive procurement process based on the estimated spend for the vendor. Anticipated date to complete the corrective action: June 1, 2026

2025-002 Child Nutrition Cluster - Assistance Listing No. 10.555, 10.582 Recommendation: We recommend the Department develop procedures and internal controls to ensure that all required subawards are reported timely and accurately to SAM.gov no later than the end of the month following the month of issuance of each subaward. If the Department is unable to complete reporting in SAM.gov, it should follow up with the Service Desk and consult with their federal award contacts for assistance and guidance. Action taken in response to finding: The Department is reviewing and updating internal procedures to ensure all required subawards are reported timely and accurately in SAM.gov. While there have been some technical challenges with SAM.gov reporting, the Department is actively coordinating with U.S. Department of Agriculture contacts to resolve issues and ensure compliance and maintaining a record of each outreach attempt. Staff responsibilities and monitoring procedures are being strengthened to support accurate reporting. Name(s) of the contact person(s) responsible for corrective action: Julia Jou, Budget Director, Rob Curtin, Deputy Commissioner, Erica Gonzales, Associate Commissioner Data & Accountability, Rob Leshin, Director, Food and Nutrition Programs Joseph Valchuis, Audit Supervisor Planned completion date for corrective action plan: April 15, 2026

As of August 2025, we transferred all FFATA reporting duties to the Director of Operations and Systems. The Director of Operations and Systems hired a staff member in January 2026 to assist with FFATA reporting. All FFATA reporting moved from USA Spending to SAM.gov during fiscal year 2025. The migration to SAM.gov caused delays as a result of the account setup process that were out of our control, but we anticipate being current on all FFATA reporting by June 30, 2026.

Planned Corrective Action Plan: The District will ensure all supporting documentation is prepared and ready for Auditors. In addition, audit services will be procured with sufficient time to submit the single audit by the required timeline. Anticipated Completion Date: June 30, 2026 Responsible Contact Person: Lorna Villaruel, Business Manager

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.

Finding ref number: 2025-001 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 District contact person: Jaime Matisons, Food Service Manager, 900 Cleveland, Aberdeen, WA. 98520 (360) 538-2256 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 non-concurrence). The cooperative provides all bid documents for the district representatives to review, this included suspension and debarment documentation. After review at a meeting of the cooperative membership, the members vote on accepting the bid. The cooperative keeps all documentation on file for review of the auditors. Documentation of this was provided to the auditor. Anticipated date to complete the corrective action: April 2026

Ocosta School District No. 172 September 1, 2024 through August 31, 2025 This schedule presents the corrective action planned by the District for findings reported 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: 2025-01 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 District contact person: Robert Butler 2580 S. Montesano St. Westport, WA 98595 360.268.9125 ext. 1004 Corrective action the auditee plans to take in response to the finding: The District acknowledges the finding and appreciates the opportunity to strengthen our documentation practices related to suspension and debarment verification. We would like to clarify that the District did perform suspension and debarment checks through SAM.gov for the vendors in question on an annual basis. While these procedures were consistently completed, the District did not retain independent documentation of those checks. The District relied on SAM.gov as the authoritative federal system of record, including its historical tracking and notification features, rather than maintaining locally stored or printed copies. At the time, staff were not aware that compliance requirements required retention of documentation evidencing these checks. As a result, this finding reflects a documentation deficiency rather than the absence of the control itself. As confirmed during the audit, all vendors tested were in good standing and not suspended or debarred. Therefore, the District was not at risk of contracting with an ineligible vendor, and no questioned costs were identified.

Person responsible for the corrective action: Jim Larson-Shidler, Interim Superintendent/CFO and Cindy Szuminski, Finance Manager Corrective action planned: Actions taken to avoid future late claims include: • The district has added another authorized Level 3 person who can approve meal reimbursement requests in July 2025. This provides the district a backup approver if one is not available. • A recurring monthly task reminding authorized Level 3 approvers to certify the SNP claim has been set up in our Outlook calendars. Anticipated completion date: July 16, 2025

FINDING 2025-004 – FINANCIAL REPORTING-DEPARTMENT OF AGRICULTURE-NATIONAL SCHOOL LUNCH PROGRAM - CFDA 10.555-SCHOOL BREAKFAST PROGRAM - CFDA 10.553-CONDITION: The School District did not make the necessary monthly adjustments to the Cafeteria Fund general ledger to properly reconcile all of the balance sheet, revenue, and expense accounts to the underlying supporting documentation on hand at the School District. Accordingly, the financial position and results of operations for the Cafeteria Fund were stated incorrectly during the 2024-2025 fiscal year. This is a repeat finding (2024-003) from the previous fiscal year.CRITERIA: Prudent internal control over accounting for federal program funds requires non-federal organizations such as the School District to maintain financial records which account for federal funds in such a manner as to be able to properly track the receipt and use of federal funds as stated in Section 2 CFR Part 200 of the Uniform Guidance.RECOMMENDATION: I am recommending that the management of the School District establish written procedures for all accounting functions, but most notably for the function of making the necessary adjustments to the School District’s Cafeteria Fund general ledger in order to properly present the financial position and results of operations of this Fund over the course of the fiscal year. Consideration should be given to either performing this process in-house based on available manpower or contracted to a third-party accounting Firm quarterly or annually independent of the audit process. Management needs to ensure the performance of these procedures monthly in order to ensure its compliance with Section 2 CFR Part 200 of the Uniform Guidance.MANAGEMENT’S CORRECTIVE ACTION PLAN: District management is reviewing its current system of processing the transactions for the Cafeteria Fund to ensure that all necessary adjustments are made on a monthly basis to the balance sheet, revenue, and expense accounts in order for them to properly reflect the financial position and results of operations of this Fund during the course of the fiscal year. The timeframe for completion of this review will occur during the last four months of the 2025-2026 fiscal year to enable the School District to comply with the recordkeeping requirements for federal funds as specified in 2 CFR Part 200 of the Uniform Guidance.

Finding Number: 2025-004 It is recommended that that district review the design of its internal control over compliance to ensure the documentation requirements are incorporated into the control design. Response: To enhance internal controls to ensure the segregation of duties, the Assistant Director of Food Services will be responsible for the initial preparation and completion of all the claims. Subsequently, a secondary review and approvable will be preformed by either the Director or the Chief School Business Official (CSBO) prior to submission.

The District will strengthen its internal control system to ensure that each entry within the Nutrition Services data management system meets required program criteria and is fully supported by appropriate documentation. A more robust process of review and verification will be implemented to safeguard the integrity of originating data and prevent compromise. System access controls will also be reinforced to ensure that granted access is appropriate and used in accordance with established protocols. Ensuring the accuracy of meal data will support accurate revenue reporting and, in turn, reliable financial reporting. Moreover, the District will continue to foster a culture of integrity in which all allegations of fraud are taken seriously and addressed promptly. The District will also enhance the visibility and accessibility of its WeTip reporting system to ensure employees, students, and community members can report concerns.

The School will prepare and submit a plan to the state agency to address excess net cash resources in the nonprofit food service account. Management will implement procedures to monitor net cash resources on a periodic basis, including timely preparation and review of the food service program’s statement of financial performance, to ensure compliance with program requirements and timely completion of any required follow-up actions.