Corrective Action Plans

Corrective Action Plan: The Department has designated and implemented additional internal controls over Transparency Act reporting to ensure that the Child Nutrition Cluster expenditures are timely and accurately entered into the SAM.gov website. These procedures include several edit checks of the data before it is uploaded as well as a reconciliation of the reported data to ensure compiance with federal regulations. Anticipated Completion Date for Corrective Action: Completed December 2025 Contact Person Responsible for Corrective Action: Name: Corey Fronk Title: Administrator of Audits and Risk Management Address: 25 S. Front Street, 7th Floor; Columbus, OH 43215 Phone Number: (614) 644-7812 E-Mail Address: Corey.Fronk@education.ohio.gov

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF AGRICULTURE, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, CHILD NUTRITION CLUSTER (ALN 10.553, 10.555, AND 10.556) 2025-003 Internal Control Over Compliance With Federal Suspension and Debarment Requirements Finding Summary 2 CFR § 180 and 2 CFR § 200.318-327 requires the District to establish and maintain effective internal control over compliance with requirements applicable to federal program expenditures, including suspension and debarment requirements applicable to the child nutrition cluster federal programs. During our audit, we noted the District did not have sufficient controls in place within its child nutrition cluster federal programs to ensure compliance with federal requirements related to assuring that the District was not contracting for goods or services with parties that are suspended or debarred, or whose principals are suspended or debarred from participating in contracts involving the expenditures of federal program funds. Corrective Action Plan Actions Planned – The District will review its policies and procedures relating to suspension and debarment for its federal programs to ensure compliance with the Uniform Guidance in the future, including maintaining appropriate documentation. Official Responsible – Dawn Duevel, Business Services Director. Planned Completion Date – June 30, 2026. Disagreement With or Explanation of Finding – The District agrees with this finding. Plan to Monitor – Dawn Duevel, Business Services Director, will assure appropriate internal controls and procedures are in place to ensure compliance with suspension and debarment requirements.

Reference Number: 2025-004 No secondary review of meal claim reimbursements prior to submission Corrective Action Plan: The District will implement procedures that incorporate a second review of meal reimbursement claims before the request is submitted for reimbursement during the monthly processing. Contact Person: Cristina Campbell Implementation Time Frame: August 31, 2026

Finding 2025-400: Child Nutrition Cluster—Federal Funding Accountability and Transparency Act Reporting: Planned Corrective Action: The Department of Public Instruction (DPI) will complete and submit reports for subaward information in the FFATA Subaward Reporting System (FSRS) for the Child Nutrition Cluster (CNC) beginning in June 2025. Beginning with June 2025 awards reporting has been completed by the applicable due date (June 2025 awards, reported by July 31, 2025, etc) The internal processes established to ensure proper reporting of subaward has been updated to include payments made for Child Nutrition Cluster grants. Upon completion of the required reporting, a summary of all Child Nutrition Cluster awards is submitted to the Department of Administration, providing the FAIN, Amount, and Date Reported. Anticipated Completion Date: July 2025. Person responsible for corrective action: Michael Brendel, Section Leader Bureau of School Financial Services Division for Libraries & Technology (working title: Division of School & Library Operations) Department of Public Instruction michael.brendel@dpi.wi.gov

Name of Contact Person: Jonathan Green, Superintendent. Recommendation: We recommend the District expand their internal controls to require a responsible official to review the daily meal count reports for accuracy prior to submission of the reports to the Illinois State Board of Education. Corrective Action: Daily meal counts will be reviewed by administration on a monthly basis. Proposed Completion Date: Immediately.

Name of Contact Person: Jonathan Green, Superintendent. Recommendation: We recommend that all food solicitation include the proper language to ensure that food products comply with the Buy American Provision. Corrective Action: We will ensure this language is included in all food solicitations going forward. Proposed Completion Date: Fiscal Year 2026.

FINDING 2025-005 Finding Subject: Child Nutrition Cluster - Reporting Audit Findings: Material Weakness, Other Matters Contact Person Responsible for Corrective Action: Lela Simmons, CFO Contact Phone Number and Email Address: 219 391 4100 Ex 12365: lesimmons@ecps.org Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: The Food Service director responsibilities is to overseeing all function of the Food Management Company. Food Service Director will be required to draft internal controls and detail instruction for the school corporation to ensure all documentation procedures match the FSMC invoice. The school corporation will upgrade all POS software throughout the district. Students will be required to scan Student IDs to account for all meals served. Counts will be check weekly to ensure Federal report is accurate. Anticipated Completion Date: We anticipate having the above corrective action plan in place by October 31, 2026

FINDING 2025-003 Finding Subject: Child Nutrition Cluster - Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Special Tests and Provisions - Non-Profit School Food Service Accounts Audit Findings: Material Weakness Contact Person Responsible for Corrective Action: Lela Simmons, CFO Contact Phone Number and Email Address: 219 391 4100 Ex 12365: lesimmons@ecps.org Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: The Food Service director responsibilities are to oversee all functions of the Food Management Company. Food Service Director will be required to draft internal controls and detail instruction for the school corporation to ensure all documentation procedures match the FSMC invoice. The school corporation will not pay any unallowable cost by state regulation and rules. All state reporting documents and invoice will continue to be reviewed and signed off by the district CFO. A copy of all documents will be held in the food director office Anticipated Completion Date: We anticipate having the above corrective action plan in place by October 31, 2026

Finding Number: 2025‐001 Program Name/Assistance Listing Title: Child Nutrition Cluster Assistance Listing Numbers: 10.553, 10.555, 10.559 Contact Person: Business Manager, Food Service Director, and Business Office Staff Anticipated Completion Date: June 30, 2026 Planned Corrective Action: The following corrections will be implemented. 1. Review and update procedures for calculating indirect costs in accordance with USDA Memo SP 60‐2016 and 2 CFR Part 200. 2. Ensure use of the ADE‐approved unrestricted indirect cost rate annually. 3. Implement a standardized calculation worksheet to document allowable indirect cost limits. 4. Require review and approval of indirect cost calculations by the Business Manager prior to posting. 5. Provide training to business office staff on federal cost principles and Child Nutrition requirements. 6. Perform periodic internal reviews to ensure compliance.

FINDING 2025-004 Finding Subject: Child Nutrition Cluster – Internal Controls - Procurement and Suspension and Debarment Summary of Finding: The Rush County SFA follows procurement standards in accordance with 2 CFR Part 200. All purchases are conducted using the appropriate procurement method based on dollar thresholds. For contracts exceeding $25,000, the Rush County SFA verifies vendors are not suspended or debarred through the System for Award Management (SAM) and retains documentation in the procurement file. Written procedures include conflict of interest standards and documentation requirements. Contact Person Responsible for Corrective Action: Julie Cramer Contact Phone Number and Email Address: (765) 932-4186, cramerj@rushville.k12.in.us Views of Responsible Officials: Option 1: “We concur with the finding.” Description of Corrective Action Plan: The Rush County SFA maintains written procurement procedures that include verification of suspension and debarment status in accordance with 2 CFR 200.214. These procedures apply to all federally funded child nutrition purchases, including food service equipment. Prior to awarding any contract or purchase order exceeding the $25,000 threshold for Suspension and Debarment requirements, the Rush County Schools Assistant Superintendent and or Superintendent along with the Food Service Director will verify in SAM the vendor’s status as to whether the entity is suspended or debarred from receiving federal grant funds. To ensure proper segregation of duties the Food Service Director conducts the SAM verification and maintains documentation. The Assistant Superintendent and or Superintendent will review and give approval for the purchase prior to final award. The dual review process ensures compliance and oversight with the Suspension and Debarment requirements. Anticipated Completion Date: March 31, 2026

FINDING 2025-003 Finding Subject: Child Nutrition Cluster – Internal Controls - Eligibility Summary of Finding: There was no documented evidence of the Director of Food Service reviewing the eligibility determinations for free and reduced lunches that were made by the Cafeteria Secretary during the audit period. Contact Person Responsible for Corrective Action: Julie Cramer Contact Phone Number and Email Address: 765-932-4186, cramerj@rushville.k12.in.us Views of Responsible Officials: Option 1: “We concur with the finding.” Description of Corrective Action Plan: The Middle School Cafeteria Secretary will contact parents regarding verifications of their free/reduced lunch application information. This information will then be reviewed by the Director of Food Service, to determine whether the information is accurate. Parents are always notified on any changes to the lunch status for students. Both the Cafeteria Secretary and the Director of Food Service will sign off on each application to document that reviews were performed. Anticipated Completion Date: March 3, 2026

FINDING 2025-004 Finding Subject: Child Nutrition Cluster- Suspension and Debarment Contact Person Responsible for Corrective Action: Jeff Layden Contact Phone Number and Email Address: 765.457.8101, jeff.layden@nwsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Jeff Layden, Director of Operations, oversees our food service department. He will work with our food service vendor to ensure EPLS are checked before awarding any contract for goods or services. Anticipated Completion Date: Immediate. INDIANA STATE

FINDING 2025-003 Finding Subject: Child Nutrition Cluster- Internal Controls Contact Person Responsible for Corrective Action: Camden Parkhurst Contact Phone Number and Email Address: 765.457.8101, camden.parkhurst@nwsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Activities Allowed or Unallowed, Allowable Cost/Cost Principals E-Funds has been automatically debited from our account since its inception. The auto debt was falling at a time each month that caused us to miss adding to our Allowance of Claims. We will correct the time that this is added to our statements so that it will make the Allowance of Claims for each month. Eligibility This was a one time issue when we were switching our software to Meal Magic. This was only related to one direct certification cluster to start the 23-24 school year. We have multiple people from our food service department prepare and sign off on direct certifications on a monthly basis to ensure we are accurate and complaint. Anticipated Completion Date: Immediate. INDIANA STATE

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF AGRICULTURE – PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION – CHILD NUTRITION CLUSTER (ALN 10.553, 10.555, AND 10.559) 2025-003 Internal Control Over Compliance With Federal Suspension and Debarment Requirements Finding Summary 2 CFR § 180 and 2 CFR § 200.318-327 requires the District to establish and maintain effective internal control over compliance with requirements applicable to federal program expenditures, including suspension and debarment requirements applicable to the child nutrition cluster federal programs. During our audit, we noted the District did not have sufficient controls in place within its child nutrition cluster federal programs to ensure compliance with federal requirements related to assuring that the District was not contracting for goods or services with parties that are suspended or debarred, or whose principals are suspended or debarred from participating in contracts involving the expenditures of federal program funds. Corrective Action Plan Actions Planned – The District will review its policies and procedures relating to suspension and debarment for its federal programs to ensure compliance with the Uniform Guidance in the future. The review of procedures will also include steps to assure that district personnel are following the requirements of the Uniform Guidance related to suspension and debarment, including maintaining appropriate documentation. Official Responsible – Ra Chhoth, Finance and Operations Executive Director. Planned Completion Date – June 30, 2026. Disagreement With or Explanation of Finding – The District agrees with this finding. Plans to Monitor – The District’s Finance and Operations Executive Director, Ra Chhoth will assure appropriate internal controls and procedures are in place to ensure compliance with suspension and debarment requirements.

Condition - The same individual is responsible for preparing and submitting monthly reimbursement claims for the Child Nutrition Program without an independent review or approval prior to submission. Plan - A second person person (business manager) compares the meal counts in the claim to: the Skyward daily meal count reports, monthly participation summary, eligibility rosters (free, reduced, paid) and USDA reimursement rates. The reviewer will then sign and date a reconciliation sheet before submission. Anticipated Date of Completion: December 7, 2025; Name of Contact Person - Dan Nolan, Business Manager; Management Response - The corrective action plan was discussed with the employee responsible for filing the claim, the business manager, and the superintendent. After discussion, the plan was approved by the superintendent.

FINDING 2025-005 Finding Subject: Child Nutrition Cluster, Special Tests and Provisions, School Food Accounts Audit Findings: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Jennifer Felke, Brittany Sabinas, Amanda Bender Contact Phone Number and Email Address: 574-936-3115, jfelke@plymouth.k12.in.us, Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Since January 2025, the internal controls that resulted in this finding have been corrected. The finding stated that “The lack of internal controls and noncompliance over Special Tests and Principles, School Food Accounts is an isolated incident.” The Business Manager/Treasurer receives deposit emails from the Indiana State Comptroller. The Business Manager codes the deposit for the Accounts Payable Specialist to receipt. The Business Manager completes a monthly bank reconciliation that is reviewed by the Deputy Treasurer and Accounts Payable Specialist as part of the month end process. Anticipated Completion Date: January, 2025 and ongoing

FINDING 2025-004 Finding Subject: Child Nutrition Cluster, Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Findings: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Jennifer Felke & Amy Kraszyk Contact Phone Number and Email Address: 574-936-3115, jfelke@plymouth.k12.in.us, Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Since January 2025, the internal controls that resulted in this finding have been corrected. The finding stated that “The lack of internal controls and noncompliance over Allowable Activities and Allowable Costs/Cost Principles is an isolated incident.” The Food Service Director and the Business Manager/Treasurer meet monthly to review the school lunch accounts and to concur with the month end balances. The Deputy Treasurer approves all monthly fund transfers completed by the Business Manager. Anticipated Completion Date: January 1, 2025 and ongoing

FINDING 2025-003 Finding Subject: Child Nutrition Cluster, Internal Controls Audit Findings: Material Weakness Contact Person Responsible for Corrective Action: Jennifer Felke & Amy Kraszyk Contact Phone Number and Email Address: 574-936-3115, jfelke@plymouth.k12.in.us, Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Food Service Director will oversee and review the process in place to ensure accuracy of eligible students. The Food Service Director will approve the uploaded Direct Certification reports after reviewing to ensure directly certified students were properly processed. The Business Manager/Treasurer will be the final approver of all Direct Certification reports. The Food Service Director will verify that contractors and subrecipients of the federal award are not suspended, debarred or otherwise excluded. The Food Service Director will complete this task for any expense expected to exceed $25,000 by checking SAMS exclusions, collecting a certification from that vendor or adding a clause or condition to the covered transaction with that vendor. The Business Manager/Treasurer will be the second reviewer/approver for suspension and disbarment. Anticipated Completion Date: March 1, 2026 and ongoing

FINDING 2025-002 Finding Subject: Child Nutrition Cluster – Procurement, Suspension, and Debarment Contact Person Responsible for Corrective Action: Kathy Bernaix, Food Service Director and Bengamin Mann, CFO Contact Phone Number and Email Address: 765-536-0008 and kbernaix@mgusc.k12.in.us and bmann@mgusc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We will have two sign offs on our print out from sam.gov evidencing multiple reviewers of the ELPS. Anticipated Completion Date: January 1, 2026

FINDING 2025-003 Finding Subject: Child Nutrition Cluster- Eligibility and Reporting Contact Person Responsible for Corrective Action: Chris Goris Contact Phone Number and Email Address: 765-395-3341, christengo@ohusc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Food Service Director will review eligibility of students for the free and reduced meal program through the state level system that identifies Direct Certification eligibility. The district will have a secondary individual from the food service department review the eligibility determination for both financial applications and through Direct Certification following the initial review by the Food Service Director. Both the director and the secondary individual will sign off on the determined eligibility status of free/ reduced applications submitted by households and Direct Certification eligibility through the Child Nutrition Program. The secondary individual will additionally review to ensure accuracy of the eligibility determination entered in the student information system by the Food Service Director. The district will prepare monthly meal claims and submit them to the Child Nutrition Program by following the listed steps: 1. The Food Service Director will prepare the meal claim numbers from the district’s student information system. 2. The CFO, or secondary individual from the food service department, will review the reports prepared by the Food Service Director. 3. The Food Service Director will enter monthly meal counts for reimbursement into CNP.4. The CFO or secondary individual from the food service department will review the CNP entry of meal claim information before submission. 5. The Food Service Director and CFO and/ or secondary individual will sign off on the preparation and entry of the monthly meal claim reimbursement. Anticipated Completion Date: 3/31/2026

FINDING 2025-03 Finding Subject: Child Nutrition Cluster – Activities Allowed or Unallowed, Allowable Costs/Cost Principles Summary of Finding: The School Corporation had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance related to the payroll and payroll benefit costs charged to the grant or food service revenues being accounted for in the School Food Account. The lack of internal controls and noncompliance was isolated to the 2023-2024 school year. Contact Person Responsible for Corrective Action: Kim Holmquist Contact Phone Number and Email Address: 219-924-4250 kholmquist@griffith.k12.in.us View of Responsible Officials: We concur with this finding. Description of Corrective Action Plan: Griffith Public Schools will be developing, implementing, and documenting, a system of internal controls, including policies and procedures that provide segregation of duties to ensure appropriate reviews, approvals and oversight are taking place to ensure compliance. Anticipated Completion Date: June 30, 2026

Condition - The same individual is responsible for preparing and submitting monthly reimbursement claims for the Child Nutrition Program without an independent review or approval prior to submission. Plan - A second person (Superintendent) compares the meal counts in the claim to: the SDS daily meal count reports, monthly participation summary, eligibility rosters (free, reduced, paid) and USDA reimbursement rates. The reviewer will then sign and date a reconciliation sheet before submission. Anticipated Date of Completion - July 1, 2026; Name of Contact Person - Dr. Beau Fretueg, Superintendent; Management Response - The corrective action plan was discussed with the employee responsible for filing the claim, the business manager, and the superintendent. After discussion, the plan was approved by the superintendent.

FINDING 2025-002 (Auditor Assigned Reference Number) Finding Subject: Child Nutrition Cluster - Eligibility Contact Person Responsible for Corrective Action: Stefanie Grandstaff, Director of Business Services Contact Phone Number and Email Address: stefanie.grandstaff@epulaski.k12.in.us Views of Responsible Officials: We concur with the finding. Explanation and Reasons for Disagreement: N/A Description of Corrective Action Plan: The Food Service Director will continue uploading the state-provided file into Skyward and verifying the accuracy of the imported information. After this review, the Food Service Director will notify the Director of Business Services via email to independently confirm that the data from the state file was uploaded and processed correctly in Skyward. This email correspondence will serve as documentation of the verification process. In addition, we will address the issue related to the 30-day rollover and students who withdraw. We will work with Skyward to adjust system parameters so that both active and inactive students are included, ensuring the rollover is accurate. The Food Service Director will also review each newly enrolled student to confirm the eligibility status by verifying whether a parent submitted an application through the school or the state. Based on the documentation available, she will update eligibility status as needed and then email the Director of Business Services to review and confirm accuracy. Anticipated Completion Date: June 30, 2026.

FINDING 2025-003 Finding Subject: Child Nutrition Cluster - Reporting Contact Person Responsible for Corrective Action: Andrea Miller Contact Phone Number and Email Address: 765-564-2100 ext 1002, millera@delphi.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The FSD will enter the required information into CNPweb. Once entered, she will forward a screen shot of the information entered and the student meal count from Skyward to the Corporation Treasurer. The Treasurer will review the information and sign off through email to the FSD, who will then submit the claim to the State for reimbursement. Anticipated Completion Date: June 2026

FINDING 2025-001 Finding Subject: Child Nutrition Cluster - Eligibility Contact Person Responsible for Corrective Action: Andrea Miller Contact Phone Number and Email Address: 765-564-2100 ext 1002, millera@delphi.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We will implement a documented secondary review, the FSD will print a before and after report from Skyward, and the direct certification download. The MS/HS ECA Treasurer will review the reports, verify Skyward, and sign off on the reports for the second check. The FSD and MS/HS ECA Treasurer will receive annual compliance training. Anticipated Completion Date: June 2026