Corrective Action Plans

The Academy has now put a control in place in which the Business Manager at each district reviews the monthly reimbursement request to ensure it agrees to the daily counts' spreadsheet.

Effective July 1, 2025, The Executive Director of Business & Human Resources, Kevin J. Polunci will review and verify the eligibility of vendors that participate in Federal assistance programs on an annual basis. The District will review the eligibility of potential vendors that participate in Federal assistance programs and compare invoices to bidding/contracts prior to payments.

THREE OAKS PUBLIC SCHOOL ACADEMY CORRECTIVE ACTION PLAN YEAR ENDED JUNE 30, 2025 Three Oaks Public School Academy respectfully submits the following corrective action plan for the year ended June 30, 2025. Auditor: Maner Costerisan 2425 E. Grand River Avenue, Suite 1 Lansing, MI 48912 Audit Period Year ended June 30, 2025 Academy Contact Person: Robert Holst, Finance Director Finding 2025-001 – Significant deficiency Recommendation: The Academy should consistently utilize a point-of-sale system to track and claim the number of meals served. The Academy should also maintain documented reviewed records on the meal counts. Action to be Taken: The Academy concurs with the facts of this finding and has implemented procedures to prevent this in the future.

SUSPENSION AND DEBARMENT Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553 and 10.555 Award Period: Year Ended June 30, 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance Recommendation: We recommend the District implement additional procedures to ensure suspension and debarment documentation is retained. Explanation of Disagreement with Audit Findings: There is no disagreement with the audit finding. Actions Planned in Response to the Finding: The District will continue to evaluate their policies and procedures and retain documentation of their review. Official Responsible for Ensuring CAP: Todd Tetzlaff, Director of Finance and Human Resources. Planned Completion Date for CAP: June 30, 2026.

Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553 and 10.555 Federal Award Identification Number and Year: 212MN061N1199 - 2025 Pass-Through Agency: Minnesota Department of Education Pass-Through Number(s): 1-2174-000 Award Period: July 1, 2024 - June 30, 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance Recommendation: We recommend the District review and approve the CLiCS meals counts reports timely and before they are submitted. Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Action Taken in Response to Finding: The District will ensure that all CLiCS submissions are reviewed and approved before submission. Name of the Contact Person Responsible for Corrective Action Plan: Jolene Bengtson, Business Manager Planned Completion Date for Corrective Action Plan: June 30, 2026

Finding 2025-004 School Nutrition Program Meal Claims 1. Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. 2. Actions Planned in Response to Finding The District will evaluate current procedures for accurately monitoring, recording, and reporting the number and type of meals served. 3. Official Responsible Mr. Michael Malmberg, Superintendent, is the official responsible for ensuring corrective action. 4. Planned Completion Date June 30, 2026 5. Plan to Monitor Completion The Board of Directors will be monitoring this Corrective Action Plan.

CAP: The District will establish processes and procedures to ensure compliance with executive orders 12549 and 12689, and 2 CFR Part 180 regarding disbarred vendors. Date: June 30, 2025 Who: Michael Cavanaugh, Business Administrator

Recommendation: We recommend the District implement additional procedures to ensure suspension and debarment documentation is retained. Explanation of Disagreement with Audit Findings: There is no disagreement with the audit finding. Actions Planned in Response to the Finding: The District will continue to evaluate their policies and procedures and retain documentation of their review. Official Responsible for Ensuring CAP: Heather Hipp, Business Manager Planned Completion Date for CAP: June 30, 2026

Admin Offices 4301 S Cowan Rd Muncie, IN 47302 765-747-5222 office CORRECTIVE ACTION PLAN OF CURRENT AUDIT FINDINGS June 30, 2025 Information on the federal program: Subject: Child Nutrition Cluster - Internal Controls 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): FY2025 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Finding: Significant Deficiency Context: During testing of allowable activities and costs, it was observed that the School Corporation allocated payroll and benefit expenses to the school lunch fund for the employee overseeing the food service management company. Five payroll transactions totaling $5,476 were selected for testing. For each transaction tested, the School Corporation allocated 18% of the employee’s time to the school lunch fund. Although the employee completed an annual self-certification estimating time spent on food service duties, there was no detailed time and effort log to support actual hours worked. Additionally, no internal control existed to provide a documented secondary review of the self-certification for accuracy and completeness. Contact Person Responsible for Corrective Action: Brad DeRome Contact Phone Number: 765-747-5222 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The School Corporation will no longer charge any payroll and benefit expenses to the school lunch fund. Anticipated Completion Date: July 1, 2025.

1. Correcting Plan Food and Nutrition Service Coordinator will review applications and supporting documentation for completion and eligibility accuracy. 2. Explanation of Disagreement with the Audit Finding There is essentially no disagreement with the finding. 3. Official Responsible for Insuring CAP The Food and Nutrition Service Coordinator. 4. Planned Completion Date for CAP The CAP was implemented immediately during audit fieldwork performed in October 2025. 5. Plan to Monitor Completion of CAP The Food and Nutrition Service Coordinator will continually review applications and supporting documentation for completion and eligibility accuracy. Any issues noted will be communicated to appropriate staff and fixed immediately.

Implementation plan of action: The Business Manager will review these requirements with the Sr. Account Clerk. The Sr. Account Clerk will verify that all vendors are eligible to participate in the federal assistance program on an annual basis. Specifically, a note will be entered on the vendor record in the accounting system each time a purchase order is issued, which will detail that the proper verification was performed. Person Responsible for Implementation: Jodi Birch, Business Manager and Amanda Lestage, Sr. Account Clerk Anticipated Completion Date: August 30, 2025

Views of Responsible Officials and Planned Corrective Action: The District acknowledges the finding and agrees with the recommendation. To address this issue, the following corrective actions will be implemented: The Business Office will verify all vendors used in federally funded programs at least once annually and prior to disbursing funds o Persons responsible: Michele Hogan and April Young o Anticipated Completion Date: This process will be completed by June 12th, 2026 ● Staff will review both 2 CFR Section 200.214 and 2 CFR Part 180 for understanding and compliance o Persons responsible: Michele Hogan and John Lybert o Anticipated Completion Date: This will be completed by September 30, 2025

Effective September 15, 2025 the District Treasurer will check the status of all vendors associated to the Child Nutrition program. In cooperation with the Food Service Director, the District Treasurer will review eligibility of any vendors that are requested to be used. Any vendor that is found not to be eligibility list will be reported to the Food Service Director and Purchasing Agent. This list will be updated and checked annually.

The District will review the requirements of 2 CFR Section 200.214 and 2 CFR Part 180 and ensure that a review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to disbursing funds to the vendor. This will be verified on an annual basis. Anticipated implementation date is October 1, 2025 by responsible person(s) District Business Official and District Treasurer Kelsey Reed.

CORRECTIVE ACTION PLAN Finding 2025-001 – Reporting The District concurs with the finding 2025-001. Corrective Action: Moving forward, the District Treasurer will enter the monthly claims with the Food Service Director and will verify that the meal counts and the total claims are correct for both breakfast and lunch. The anticipated completion date of the corrective action is September 29, 2025. Contact Person: Alicia D. Koster, Superintendent of Schools (518) 762-4611 akoster@johnstownschools.org

VIEWS OF RESPONSIBLE OFFICIALS In response to the finding regarding the untimely submission of the Federal Funding Accountability and Transparency Act (FFATA) reports, the Puerto Rico Department of Education (PRDE) acknowledges the observation made by the auditors. While the audit notes that program staff were unaware of the FFATA reporting requirement, we would like to clarify that the staff was aware of the requirement; however, the program was in the process of gathering the necessary data and ensuring a full understanding of the report components and submission procedures in order to comply accurately with the federal guidelines. Nevertheless, PRDE recognizes that this does not justify the delay in the submission of the reports. To prevent future occurrences, PRDE is currently developing and scheduling a comprehensive training for all program and fiscal staff involved in the Child Nutrition Cluster. This training will cover the FFATA reporting requirements, data collection procedures, submission timelines, and documentation standards to ensure full and timely compliance with the reporting process moving forward. PRDE will continue strengthening internal controls and monitoring procedures to ensure that all applicable FFATA reports are submitted accurately and on time in the FSRS portal. IMPLEMENTATION DATE December 30, 2025 RESPONSIBLE PERSON Odalis Menard AESAN Director Lourdes García Santiago AESAN Sub-Director

VIEWS OF RESPONSIBLE OFFICIALS Management agrees with the audit finding and has implemented a comprehensive corrective action plan to address payroll processing errors, strengthen internal controls, and ensure accurate and timely payments. As part of PRDE’s Fiscal Plan of 2020–2021, the Department launched the official integration project between the Time, Attendance, and Leave (TAL) system and the Payroll (RHUM) system. This integration ensures that payroll disbursements are made only after the employee’s attendance has been validated through the TAL system. Employees are required to record their attendance using biometric verification or have an authorized leave properly documented and approved by their supervisor before receiving payment. If attendance is not validated, the system automatically issues a notification and applies the necessary adjustment. This project, initiated in November 2020 with the collaboration of the Puerto Rico Fiscal Oversight and Management Board (FOMB), MS Consulting, the Department of the Treasury (Hacienda), the Financial Advisory Authority (AAFAF), and the Puerto Rico Innovation and Technology Service (PRITS), was fully integrated by February 2021. As a result, PRDE has significantly reduced overpayments, duplicate payments, and other payroll inconsistencies. To reinforce this effort, PRDE issued a new Time and Attendance Policy on December 7, 2021, later updated on April 11, 2022, which clearly defines employee responsibilities, authorized leaves, disciplinary procedures, and supervisor accountability. Under this policy, employees and supervisors are required to follow strict timekeeping procedures, and noncompliance triggers automatic system notifications and salary adjustments. The PRDE’s Time and Attendance staff continues to monitor and maintain compliance through: i. Ongoing training sessions for PRDE personnel; ii. System dashboards tracking attendance behaviors; iii. Issuance of notifications and payroll adjustments as required; and iv. Regular follow-up and evaluation activities. Additionally, PRDE’s Finance Office implemented a reconciliation process that integrates data from TAL, RHUM, and SIFDE, ensuring that payroll expenditures align with validated attendance records. The system now performs cross-checks before submission to the Treasury Department, preventing disbursements for unverified time. These combined measures—technological integration, policy enforcement, staff training, and reconciliation controls—have strengthened payroll accuracy, reduced the risk of overpayments, and improved financial accountability across the Department. IMPLEMENTATION DATE Done RESPONSIBLE PERSON Evelyn Rodríguez Cardé Finance Office Director Jullymar Octtaviani Vega Sub-Secretary of Administration

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF AGRICULTURE, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, CHILD NUTRITION CLUSTER – FEDERAL ALN 10.555, 10.559, AND 10.553 2024-006 - Internal Control Over Compliance With Federal Suspension and Debarment Requirements Finding Summary Criteria – 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. Condition – The District did not have sufficient controls in place within its child nutrition cluster to assure that it was not contracting for goods or services with parties that are suspended or debarred, or whose principals are suspended or debarred from participating in contracts involving the expenditures of federal program funds. Corrective Action Plan Actions Planned – The District will review its policies and procedures relating to suspension and debarment for its federal programs and will ensure that all parties with which it contracts for goods or services are eligible to participate in contracts involving the expenditures of federal program funding. Official Responsible – Peter Olson-Skog, the District’s Superintendent. Planned Completion Date – December 31, 2025. Disagreement With or Explanation of Finding – The District agrees with this finding. Plan to Monitor – Peter Olson-Skog, the District’s Superintendent, will ensure appropriate controls are in place to verify that any vendor with which the District contracts for federal program goods or services exceeding $25,000 is not listed as suspended or debarred on the federal Excluded Parties List System website.

Name of Contact Person: Mr. Mitch Nanney, Superintendent. Recommendation: We recommend the District verify a vendor's status by checking the System for Award Management (SAM) maintained by the General Services Administration before making purchases expected to exceed $25,000 and to keep all supporting documentation of the verification of the vendor's status. Corrective Action: We will verify all vendor's status using the System for Award Management (SAM) maintained by the General Services Administration before making purchases expected to exceed $25,000 and keep all supporting documentation. Proposed Completion Date: Immediately.n

A procedure has been created for this and will be implemented and looked at 1/4ly so funds can be spent down during the school year. Immediate steps were taken to do a spenddown plan and the food serviced fund was used for the program to bring down the fund balance to less than the three-month average expenditures.

Management Response/Corrective Action Plan: Effective November 2024, a new procedure is in place to verify school lunch counts are reported accurately. The School Nutrition Director documents data in spreadsheets and uses this for completing reimbursement requests. The Business Manager also reviews the provided spreadsheets before approving claims for reimbursement.

FA 2024-001 Strengthen Controls over Expenditures 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 Assistance Listing Number and Title: 10.553 - School Breakfast Program 10.555 - National School Lunch Program Federal Award Number: 225GA324N1099 (Year: 2024), 245GA324N1199 (Year: 2024) Questioned Costs: $46,878 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 procedures were followed. Corrective Action Plans: Responsible Parties: Superintendent, School Nutrition Manager, To address this finding and prevent recurrence, the Superintendent and School Nutrition Manager will implement the following corrective measures in accordance with Terrell County Board of Education policy and applicable federal/state guidelines: 1. Staff Training-Provide training for School Nutrition staff on federal procurement requirements, the district's Procurement Plan, and Board policy related to financial management, procurement, and record retention. Training will be documented and updated annually or as requirements or Board policies are revised. 2. Process Monitoring-Establish written procedures aligned with board-approved procurement policies to ensure all required bids and quotes are obtained, documented, and retained. Maintain both electronic and hard-copy procurement files, with oversight responsibilities clearly assigned. 3. Internal Compliance Reviews-Conduct quarterly internal reviews between the Schol Nutrition Department and Finance to verify procurement documentation and adherence to Board policy and the Procurement Plan. Provide review summaries to the Superintendent and report systemic issues to the Board, if necessary. 4. Accountability Measures-Incorporate procurement documentation and retain responsibilities into departmental expectations, evaluations, and supervisory reviews, consistent with Board policies on accountability and internal controls. Noncompliance with documentation procedures will be addressed under established Board personnel and accountability policies. Estimated Completion Date: June 30, 2026 Contact Person: Shereca R. Harvey, Superintendent Telephone: (229) 995-4425 Email: srharvey@terrell.k12.ga.us

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

State of Missouri Single Audit Corrective Action Plan Year Ended June 30, 2024 State Agency: MO Department of Elementary and Secondary Education (DESE) Audit Finding Number: 2024-014 - DESE FFATA Reporting Name of the contact person responsible for corrective action: Shelley Woods Anticipated completion date for corrective action: 7/1/2025 Corrective action planned is as follows: The agency agrees with the auditor's finding. DESE has changed internal procedures to ensure FFATA reporting follows applicable requirements. DESE is designating a Federal Compliance Coordinator to submit all FFATA reporting as opposed to each section Fiscal Liaison uploading the report. The terms and conditions for each grant award will be reviewed by the Federal Compliance Coordinator to determine if FFATA is applicable, and then the Federal Compliance Coordinator will work the Fiscal Liaison to collect and report the information required under FFATA.

Management concurs with the findings. The closing process will be improved; physical inventory will be taking and improvements for documentation will be made.