Corrective Action Plans

Corrective Action Plan: The Organization will maintain and download the Exclusions Extract Data Package from Sam.gov website verifying that vendors paid over $25,000 on a federal grant were not included in the package. Anticipated Corrective Action Plan Completion Date: June 30, 2024.

2023-004 The Emergency Food Assistance Program (TEFAP) and Commodity Supplemental Food Program (CSFP) Reporting Corrective action planned: This error was identified in preparation of the 2024 audit in July 2025. We have implemented a system to track federal noncash award inflows and outflows according to bills of lading provided by the Contractor. We will reconcile our inventory at a minimum annually. Anticipated completion date: October 31, 2025 Contact person responsible for corrective action: Justin Carlile Justinc@partnersinw.org

FINDING 2023-002 Finding Subject: Child Nutrition Cluster – Eligibility Summary of Finding: For one of 40 students receiving free or reduced priced lunches, the eligibility determination was incorrect. The student was classified as reduced; however, the student should have been a regular paying student. The error was due to an incorrect family size being reported, which caused the classification to be incorrect. The lack of controls and noncompliance was isolated to the one student. Contact Person Responsible for Corrective Action: Leslie Rittenhouse Contact Phone Number and Email Address: 765-395-3341 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Food Service Director will continue to review eligibility of students for the free and reduced meal program through the state level system. The district will have a secondary individual from the food service department review the eligibility determination following the initial review by the director. Both the director and the secondary individual will sign off on the determination paperwork. Entry into the state system for eligibility calculations will be reviewed for any entry errors. Anticipated Completion Date: All new determinations in the 2024-2025 school year.

Finding Number 2023-041 Subject Heading (Financial) or AL no. and program name (Federal) AL #84.425 – EDUCATION STABILIZATION FUND (ESF – 84.425V) Planned Corrective Action The Office of Title Services (OTS) used the limited federal guidance available at the time to manage the Emergency Assistance to Nonpublic Schools (EANS) funds. Due to limited guidance from the US Department of Education (USDE), OSDE allocated ARP EANS funding consistent with CRRSA EANS. After funds were allocated, USDE provided guidance on the allocation of ARP EANS funding using actual low income poverty data. In the fall of 2024, the Office of Title Services (OTS) provided documentation and adjusting journal entries to reallocate ineligible funds from ARP EANS to unspent CRSA EANS. This adjustment transferred the unallowable expenditures originally charged to ARP EANS to unspent funds under CRRSA EANS. All funds were obligated during the applicable period of availability. The United States Department of Education accepted evidence of this corrective action in an email received by OTS staff on February 5, 2025. A copy of this email was sent to the Oklahoma State Auditor and Inspector’s Office on Monday, May 19th, 2025. OSDE agrees with that low-income data used for EANS allocation was different than the low-income data used for Title I allocations. OSDE used Lowincome counts based upon data provided by nonpublic schools. The Office of Title Services (OTS) used the limited federal guidance available at the time to manage the Emergency Assistance to Nonpublic Schools (EANS) funds. EANS Proportionality In the fall of 2024, the Office of Title Services (OTS) provided documentation and adjusting journal entries to re-allocate ineligible funds from ARP EANS to unspent CRSA EANS. This adjustment transferred the unallowable expenditures originally charged to ARP EANS to unspent funds under CRRSA EANS. All funds were obligated during the applicable period of availability. The United States Department of Education accepted evidence of this corrective action in an email received by OTS staff on February 5, 2025. A copy of this email was sent to the Oklahoma State Auditor and Inspector’s Office on Monday, May 19th, 2025. As a result, these expenditures were allowable and did not result in questioned costs. EANS Low-Income If low-income data for nonpublic school participants is necessary to determine eligibility, then OTS will create a written procedure to collect and verify the data. Anticipated Completion Date August 2025 Responsible Contact Person Amber Polach

Finding Number 2023-038 Subject Heading (Financial) or AL no. and program name (Federal) CN CLUSTER – SCHOOL BREAKFAST PROGRAM; NATIONAL SCHOOL LUNCH PROGRAM, SPECIAL MILK PROGRAM FOR CHILDREN, FRESH FRUITS AND VEGETABLES PROGRAM AL #10.553, 10.555; 10.556; 10.559; 10.582 Planned Corrective Action Additional training of field-based staff will take place covering the areas of the SFSP review to ensure that meal counts and claim numbers are correct. A SFSP review will not be conducted prior to a claim being filed unless the SFSP program ends prior to a claim being filed. USDA guidance “encourages” a claim review to be conducted when an SFSP review is being conducted. If a sponsor operates for a month or less the review must take place while the program is operating therefore a claim would not be able to be validated. Anticipated Completion Date May 2025 (once SFSP reviews start for summer 2025) Responsible Contact Person Jennifer Weber

Finding Number 2023-015 Subject Heading (Financial) or AL no. and program name (Federal) CN CLUSTER – SCHOOL BREAKFAST PROGRAM; NATIONAL SCHOOL LUNCH PROGRAM, SPECIAL MILK PROGRAM FOR CHILDREN, FRESH FRUITS AND VEGETABLES PROGRAM AL #10.553, 10.555; 10.556; 10.559; 10.582 Planned Corrective Action We will update our 3-month Operating Excess form we send to schools to include more information. Any schools that are going to carryover part or all of their excess funds will need to provide us an explanation of what those funds will be spent on and then comments will be made on the log so we follow-up with the school to ensure allowable items were purchased. If they are using the excess for salaries and/or the cost of serving all students free they will need to let us know that in writing as well. Anticipated Completion Date June 2, 2025 Responsible Contact Person Jennifer Weber

Finding Number 2023-105 Subject Heading (Financial) or AL no. and program name (Federal) 10.542 - Pandemic EBT – Food Benefits Planned Corrective Action The P-EBT program is no longer issuing benefits. Should a similar program be required in the future, the DHS will ensure internal controls are in place to avoid duplicate or erroneous payments. Anticipated Completion Date N/A Responsible Contact Person Sondra Shelby

Finding Number: 2023-022 Summary of finding: Required subaward information was not reported in the FFATA Subaward Reporting System (FSRS). The Nevada Department of Agriculture (NDA) did not have internal controls to ensure subaward information was submitted in accordance with the FFATA. Recommendation: The State agency should implement internal controls to ensure subaward information is submitted in accordance with the FFATA. CAP Response: The agency agrees and accepts this finding and will take the following steps to enhance internal controls to ensure compliance: The agency will identify appropriate staff with system access to SAM.gov to report FFATA subaward information and request access for additional staff if needed. Staff will begin reporting FFATA information on October 1, 2025. Anticipated date of completion: March 31, 2026 CAP Contacts: Cathy Balcon, Administrator, Division of Administration, Patricia Hoppe, Administrator, Division of Food and Nutrition

Management will establish procedures to take and document a physical annual inventory and to maintain support for inventory distributions

Yeshiva Darkei EmunahYeshiva Darkei Emunah respectfully submits the following corrective action plan for the year ended December 31, 2023. Hirsch | Dinter & Co. CPAs: 21 Remsen Avenue, Suite #302, Monsey, New York 10952 Audit Period: January 01, 2023 - December 31, 2023 The finding from the December 31, 2023 schedule of prior audit findings is discussed below. Finding 2023-001: Federal Awards Program Audit U.S. Department of Agriculture Child Nutrition Cluster Programs Deficiency: See Finding 2023-001 Recommendation: The Organization should develop a compliance calendar that includes financial reporting deadlines and set automatic reminders in advance of each deadline to aid in properly planning and timing submission of reporting packages. Additionally, the Organization should engage the audit firm well before the fiscal year end, and the auditors should put this engagement on their calendar well in advance of the due date. The Organization should establish a timeline with the auditors that aligns with internal deadlines to ensure sufficient time to conduct the audit. The Organization’s Board of Directors should be more actively engaged in the auditing and reporting process to establish a greater degree of accountability and oversight. Anticipated Completion Date: 09/30/2026 Actions Taken: The Organization has begun implementing the above-mentioned recommendations. The Organization will ensure that it has a working compliance calendar to assist in meeting the reporting deadline. Additionally, the Organization has engaged the audit firm for their upcoming fiscal year-end, and the audit firm has put it on its calendar to begin the audit process well in advance. The Organization’s board of directors has agreed to oversee the auditing and reporting processes to a greater extent. With these actions, the Organization expects to comply with the Uniform Guidance for single audits deadline for the fiscal year end December 31, 2025. Mr. Joel Stein, executive director, has been designated to monitor the plan of corrective action for this finding. He can be reached at 845-356-2761. Contact Person Responsible for Corrective Action: Joel Stein, Executive Director

During our Mississippi Department of Education (MDE) Administrative Review, auditors provided technical assistance on using the Edit Check Report in Mosaic to avoid underreporting or overreporting meals. Since that review, we have implemented the use of the Edit Check Report to enter reimbursable meals in the MARS system instead of the Claim Report. This change improves the accuracy of meal counts and reimbursement claims. Additionally, we will establish a formal review process whereby a second staff member verifies montly claims before submission to further ensure accuracy and compliance.

Correction Action Plan – Finding 2023-002 “Improve Time and Effort Documentation” Correction Action to be taken: The Town is reviewing all school contracts and time sheets for inefficiencies and requiring adjustments or more documentation as necessary. Expected Completion Date: The Treasurer/Collector’s office has taken over most of the school’s payroll in FY25 and is working with our new School Business Manager to correct all of the timesheet inadequacies. We anticipate that all major inefficiencies within school payroll will be eradicated by December 31, 2025. The Town is also shifting to a new payroll system which will properly report time and attendance. Contact Person: Julie Hebert, Finance Director; Janet Jannell, Treasurer/Collector; Kaitlyn Shelar, School Business Manager

THE FORMER CLARENDON ONE AND CLARENDON FOUR AUDITS WERE ISSUED LATE AFTER CONSOLIDATION BEGAN. BEGINNING WITH THE 2024-25 AUDIT, TIMELY AUDIT SUBMISSIONS WILL BE PRACTICED.

CORRECTIVE ACTION PLAN FOR THE YEAR ENDED DECEMBER 31, 2023 Title 2, U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart F, Section 511 – Audit Findings Follow-up requires the auditee to prepare a corrective action plan to address each audit finding included in the current year auditor’s reports. The Corrective Action Plan for Current Year Findings present our corrective action plan for the Financial Statement and/or Federal Award Findings described in the accompanying Schedule of Findings and Questioned Costs for the period ended December 31, 2023. Finding 2023-001 Responsible Party Name: Gina Rice Position: Director of Accounting Telephone Number: 816-238-4511 ext 131 Federal Agency U.S. Department of Agriculture Federal Program Emergency Food Assistance Program (Food Commodities) Compliance Requirements E - Eligibility Finding Type Federal Awards Auditee’s Comment on Finding We agree with the auditor’s finding. Corrective Action We will establish a process to ensure required eligibility documentation is maintained in accordance with federal program requirements which will include periodic monitoring and review performed by personnel not directly involved with program administration. Anticipated Completion Date June 2025

2023-011 Excess Food Service Fund Balance (Material Weakness) Management’s Response: We completed and Excess Balance Use of Funds report and worked with the State to understand exactly the parameters of this/ The funds were spent down and we are working hard to make sure to stay under the three months of expenses as worded in CFR Title 7, 210.14(b). Again management is trying to take on a bigger role as this monitoring was not considered prior to COVID. Fund Balances at year end averaged no more than $10,000. Name of Contact Person and Completion Date: Toni Butterfield Anticipated Completion Date - Immediately

Child Nutrition – Report Testing Recommendation: We recommend that the District reviews its procedures and controls over reporting for the Child Nutrition Cluster program to ensure all reports are accurately reporting information and are reviewed by someone other than the preparer and that review is documented prior to submission of the report. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The District will review its procedures over its reporting of claims to MDE to ensure claims made to MDE is properly supported by the District's meals count. Name(s) of the contact person(s) responsible for corrective action: Tariro Chapinduka, Director of Business Services Planned completion date for corrective action plan: June 30, 2025

U.S. Department of Agriculture Significant Deficiency in Internal Control over Compliance The Emergency Food Assistance Program (Administrative); Commodity Supplemental Food Program (Administrative)– Assistance Listing No. 10.569 and 10.565 Condition: CACLV does not have formal procedures in place to determine the Second Harvest Food Bank expenses incurred during the fiscal year that should be allocated to the TEFAP/CSFP administrative revenue received. CACLV has historically recognized revenue based on when cash is received which is not appropriate. Recommendation: We recommend the allocation of allowable costs and activities be completed at a minimum on a quarterly basis. Also, any direct expenses related to program activities should be recorded to the respective identifying program fund number within the accounting software. The amount of revenue recognized for the programs should be reflected of the expenses incurred up to the administrative funds received from the respective funders. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: The organization will implement a standard allocation to be completed on a quarterly basis at the minimum. This process will be reviewed by management to ensure implementation. Name(s) of the contact person(s) responsible for corrective action: Dawn Godshall, Executive Director Planned completion date for corrective action plan: Planned completion date is June 2025.

FINDING 2023-009 Finding Subject: Child Nutrition Cluster – Non-Profit School Food Service Accounts Summary of Finding: Receipts for the grant were posted to the ledger by one individual without an oversight or review process in place to ensure the remitter, amount, fund, and receipt classification were accurate. Additionally, the same individual received the ACH notifications when monies from monthly meal reimbursements were credited to the School Corporation's bank account and performed the bank reconciliations. Contact Person Responsible for Corrective Action: Drew Cooper, Business Manager Contact Phone Number and Email Address: 765-425-7889 dcooper@shenandoah.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Currently the Food Service Director and Business Manager hold a monthly financial meeting to review the food service finances. A report listing all receipts for the previous month to the food service fund will be reviewed at this meeting. This item will be added to the agenda. Anticipated Completion Date: March 31, 2024

FINDING 2023-008 Finding Subject: Child Nutrition Cluster – Special Tests & Provisions - Verification Summary of Finding: One individual performs the verification process without documented review/oversight by a second employee not involved in this process. The lack of controls resulted in non-compliance in which the procedures performed at the School Corporation and the resulting supporting documentation provided were insufficient to verify the student's eligibility status of one of three students which were verified during the audit period. Contact Person Responsible for Corrective Action: Drew Cooper, Business Manager Contact Phone Number and Email Address: 765-425-7889 dcooper@shenandoah.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The verification process will be performed by Pam Frost and reviewed by the Business Manager. Anticipated Completion Date: December 31, 2024

FINDING 2023-007 Finding Subject: Child Nutrition Cluster - Reporting Summary of Finding: Monthly reimbursement claims for breakfast and lunch meals served are prepared and submitted without documented review or approval by a second individual not involved in the preparation of the reimbursement claim. Contact Person Responsible for Corrective Action: Drew Cooper, Business Manager Contact Phone Number and Email Address: 765-425-7889 dcooper@shenandoah.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Food Service Director will calculate the monthly claims to be submitted to the DOE/CNP and email this information to the Business Manager for review before submittal. Anticipated Completion Date: March 31, 2024

FINDING 2023-005 Finding Subject: Child Nutrition Cluster - Eligibility Summary of Finding: The School Corporation stated that 100% of Free/Reduced lunch applications were reviewed during the audit period. However, testing of controls indicated that 100% of Free/Reduced lunch applications were not being reviewed by an individual other than the individual making the initial determination. As a result, three of forty sampled students received the incorrect eligibility status in the system software when compared to supporting documentation (Direct Certifications and/or income-based applications). Contact Person Responsible for Corrective Action: Drew Cooper, Business Manager Contact Phone Number and Email Address: 765-425-7889 dcooper@shenandoah.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Currently all income based applications for free/reduced lunch status are processed by Pam Frost and then reviewed by the Business Manager. Beginning in the 2024-2025 school year Direct Certification students will also be reviewed by the Business Manager. Anticipated Completion Date: August 31, 2024

FINDING 2023-004 Finding Subject: Child Nutrition Cluster – Allowable Costs/Cost Principles Summary of Finding: The School Corporation did not have internal controls in place over payroll disbursements charged to the food service program. Payroll disbursements were paid without evidence that the detailed report of payroll disbursements was reviewed and approved by another person not involved in the original payroll process. The School Corporation paid $23,682 of administrative salaries that were allocated to the School Lunch fund based on fixed percentages. There was no supporting documentation to indicate how the percentages were determined or time records indicating time spent on the program by the applicable administrators. INDIANA STATE BOARD OF ACCOUNTS 40 􀀃 “Meeting􀀃students􀀃where􀀃they􀀃are􀀃and􀀃leading􀀃them􀀃forward…every􀀃student,􀀃every􀀃day”􀀃 Contact Person Responsible for Corrective Action: Drew Cooper, Business Manager Contact Phone Number and Email Address: 765-425-7889 dcooper@shenandoah.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Currently 50% of Pam Frost’s salary is paid from the Lunch Fund. A new internal control will be created to document that 50% of her time is spent on food service work and 50% of her time is spent as the ECA treasurer for the elementary school. Anticipated Completion Date: August 31, 2024

FINDING 2023-003 Finding Subject: Child Nutrition Cluster – Activities Allowed or Unallowed Summary of Finding: The School Corporation did not have internal controls in place over payroll disbursements charged to the food service program. Payroll disbursements were paid without evidence that the detailed report of payroll disbursements was reviewed and approved by another person not involved in the original payroll process. Contact Person Responsible for Corrective Action: Drew Cooper, Business Manager Contact Phone Number and Email Address: 765-425-7889 dcooper@shenandoah.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Currently the Business Manager and Food Service Director hold a monthly financial meeting to review the status of finances for the Food Service. A review of the payroll distribution reports for the previous month will be added to the agenda of this meeting. Anticipated Completion Date: March 31, 2024

Corrective Action Plan Findings - Federal Award Program Audits Department of Agriculture Finding 2023-001 - Child Nutrition Cluster - School Breakfast Program - Assistance Listing Number 10.553, National School Lunch Program - Assistance Listing Number 10.555, Summer Food Service Program for Children - Assistance Listing Number 10.559 Condition: The year-end financial reports contained several errors related to the recording of receipts and expenses of the Major Federal Award Program. Auditors’ Recommendation: The District should implement a process that includes monitoring activity related to Federal Programs. It is recommended that individuals within the District obtain training related to internal control systems or consider the use of a 3rd party specialist. Planned Corrective Action: The District has had turnover since the completion of the previous audit (June 30, 2022), staff in key positions have turned over multiple times. As of the date of this report, the District has hired and implemented training for key staff to ensure proper grant management in the future.

2023-004 Allowable Costs Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553 and 10.555 Pass-Through Agency: Georgia Department of Education Criteria: In accordance with the terms of the Child Nutrition Grant and 2 CFR 200, Cost Principles for States, Local Governments, and Indian Tribes, specific documentation must be maintained to support salaries and wages charged to the federal program. Where employees are expected to work solely on a single Federal award or cost objective, charges for their salaries and wages will be supported by periodic certifications that the employees worked solely on that program for the period covered by the certification. These certifications will be prepared at least semi-annually and will be signed by the employee or supervisory official having first-hand knowledge of the work performed by the employee. Where employees work on multiple activities or cost objectives, a distribution of their salaries or wages will be supported by personnel activity reports or equivalent documentation. Corrective Action Plan: We concur with this finding. The District is developing corrective actions to strengthen Child Nutrition Cluster Department internal controls, policies, and procedures and ensure adherence through improved monitoring. Through collaboration, the Finance Division and the School Nutrition Department will review payroll detail reports and ensure periodic certifications for all employees are completed timely. Estimated Completion Date: Fiscal Year 2025 Contact Person: Dr. Connie Walker, School Nutrition Executive Director Telephone: 678-676-1200 E-mail: Connie_R_Walker@dekalbschoolsga.org