Corrective Action Plans

2024-004 FINDING Contact Person – Dave Kerkvliet, Superintendent Corrective Action Plan – The District will begin reviewing and approving reports prior to submission for reimbursement. Completion Date – November 1, 2024

Corrective Action Plan School District management agrees with condition, cause, and recommendation. With this overage, the School District has purchased some new equipment for the cafeteria. Since the School District is CEP, there is no option to change the revenue. The School District will continue upgrading the kitchens with the excess. Expected Correction Date: June 30, 2025 Contact: Kathy Rote, School Business Administrator (607) 565-2841 15 Frederick St. Waverly, NY 14892

The Food Service Director will coordinate the on-site monitoring reviews and its completion to Michigan Department of Education standards, and make sure the required forms are completed before deadlines. Contact person responsible for corrective action: Darlene, Food Service Director Anticipated Completion Date: 02/01/2025

Corrective Action Plan: The District recognizes that due to increased reimbursement during the past few years, the District has an excess of cash on hand over the permitted levels. Over the course of the 2023-24 school year, the district reviewed the program’s needs to develop a strategy to utilize these funds by the food service program to coincide with the capital project approved by the voters in December of 2022. To date, the District has purchased and installed multiple equipment items by the Cafeteria Fund totaling over $189,000. Along with these purchases the district has ordered and is in the process of receiving and installing an additional $125,000 of equipment including new serving line stations. Estimated Completion Date: June 30, 2025 Contact Information Jennifer Dattoria, School Business Executive Susquehanna Valley Central School District 1040 Conklin Road Conklin, New York 13748

2024-003 Child Nutrition Cluster – Assistance Listing No. 10.CNC Recommendation: CLA recommends the District designate an individual to review student lunch statuses. Having an appropriate reviewer over student status is intended to prevent, detect, and correct a potential error in the food service system. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: Management will designate an individual to review student lunch statuses. Name of the contact person responsible for corrective action: Kathy Stankewicz, Business Manager Planned completion date for corrective action plan: June 30, 2025

Condition: The School District did not complete an on-site monitoring review for one building operating a school lunch program during the year ended June 30, 2024. Corrective Steps Taken: At this time, there have been some corrective steps taken to limit this from happening again which includes the Food Service Director better familiarizing herself with MDE’s requirements for on-site reviews. Corrective Steps to be Taken: The Food Service Director will coordinate the on-site monitoring reviews and its completion to Michigan Department of Education requirements. Monitoring: The plan for monitoring adherence is for the Superintendent to check in with he Food Service Director prior to the February 1st deadline to ensure all required on-site reviews were performed. Name of Responsible Person for Further Information: Tami Eisenga, Food Service Director and Scott Akom, Superintendent. Questioned Costs Related to this Finding: None.

Condition: The School District does not currently have a control in place whereby a review of the meal counts entered into the Michigan Nutrition Data (MiND) system takes place, which could result in an incorrect reporting of the number of free and reduced priced meals, which could result in the School District being reimbursed an incorrect amount by the Michigan Department of Education. Planned Corrective Action: The Business Office has implemented a formalized internal control procedure for the Food Service Department to adhere, alongside performing a thorough review of the monthly claims reimbursement submission. The formalized internal control procedure will accompany the supporting documentation submitted to the Business Office monthly (Attachment A). The procedure involves a review of inputted meal counts, prior to the claim submission. The Food Service Department Administrator responsible for meal claim input will provide corroboration of input accuracy, as documented by signoff from a secondary reviewer. In addition, the Business Office has prepared a Meal Claim Check Tool spreadsheet to utilize, on a monthly basis, as another layer of validation. The Meal Claim Check Tool spreadsheet allows the Business Office to input meal count figures from the Food Service POS system report and compare against the figures from the claims submission report. Any discrepancy identified would be immediately addressed with the Food Service Department and would require an amended claim submission. Contact person responsible for corrective action: Danielle Jacobs, Director of Business Services Anticipated Completion Date: 08/01/2024

Finding No.: 2023-005 AL Program: 10.555 National School Lunch Program (NSLP) Area: Reporting Questioned Costs: $-0- Views of Auditee and Corrective Action Plan: Management’s Position: PSS Management concurs with the findings. Financial and Grants Management procedures were promulgated in a SOP on September 18, 2024. The financial management system was subsequently changed to Tyler Munis to conform with CNMI central government requirements which will enhance capabilities. The SOPs and the Tyler Munis implementation are under review by an external consultant and recommendations made to improve coding of grant details and expenditures, increased frequency of reconciliations, and a specific SOP for report preparation. Corrective Action Plan: I. Implementation of a Comprehensive Grant Tracker: PSS will develop and implement a centralized Grant Lifecycle Tracker for all active federal awards. This tool will serve as the primary monitoring mechanism for compliance by recording all financial and programmatic reporting due dates, assigning specific preparers for each report, and establishing automated milestones to ensure sufficient lead time for both the preparation phase and the subsequent supervisory review. II. Deployment of Enhanced Data Analysis Tools: To ensure that quarterly program reporting is both consistent and timely, PSS will develop and implement specialized data analysis tools. these tools will streamline the aggregation of program data, reducing manual entry errors and allowing for more efficient evaluation of program performance against federal benchmarks. Proposed Completion Date: In progress for FY 2024 with completion by August 2026. Name of Contact Person and Title: Contact: Jacqueline Che, Federal Programs Officer Email Address: jacqueline.che@cnmipss.org

Finding No.: 2023-003 AL Program: 10.555 National School Lunch Program (NSLP) Area: Allowable Costs/Cost Principles Questioned Costs: $-0- Views of Auditee and Corrective Action Plan: Management’s Position: PSS Management concurs with the findings. Financial and Grants Management policies procedures were promulgated in SOPs on September 18, 2024. The financial management system was subsequently changed to Tyler Munis to conform with CNMI central government requirements which will enhance capabilities. The SOPs and the Tyler Munis implementation are under review by an external consultant and recommendations made to improve documentation of cost allowability have been received. Corrective Action Plan: I. Finalization of Allowability and Disbursement SOPs: PSS will finalize comprehensive Standard Operating Procedures (SOPs) and policies specifically governing allowability determinations and vendor payments. II. Enhanced Disbursement Controls: PSS is implementing a documented review and approval controls over the payment process. Before any check or ACH disbursement is finalized, a reviewer must verify that the payment amount agrees exactly with the approved invoice. This verification will be physically or digitally documented on the payment voucher to provide a clear audit trail of the pre-payment review. Proposed Completion Date: In progress for FY 2024 with full implementation and documentation processes expected to be completed in 2026. As part of this improvement, we are designing a standardized, documented review process to ensure all disbursements are verified against approved invoices prior to payment. Name of Contact Person and Title: Contact: Jonathan Aguon, Director of Finance Email Address: jonathan.aguon@cnmipss.org

July 28, 2026 Business Services Missoula County Public Schools 909 South Avenue West Missoula, MT 59801 Phone 406-728-2400 Ext 3021 business@mcpsmt.org Management’s Response to Auditor’s Findings and Corrective Action Plan June 30, 2023 Prepared by Management of Missoula County Public Schools Contact: Denise Williams, Executive Director of Business Operations 2023-001 Internal Controls Over Student Activity Expenditures Criteria or Specific Requirement: The State of Montana Student Activity Fund Accounting Manual requires all expenditure of funds have proper documentation. Condition: During review of student activity expenditures it was noted that documentation was not retained for all expenses. Context: We selected 50 total expenditures for testing and noted that 2 of the expenditures did not have documentation of the expense. Effect: We selected 50 total expenditures for testing and noted that 2 of the expenditures did not have documentation of the expense. Cause: The District is not in compliance with State requirements for the accounting for student activity expenditures. Auditor's Recommendation: We recommend that the District review its policies and procedures pertaining to student activity expenditures and receipts and ensure that is up to date and that it can be easily followed and replicated in case of personnel turnover. View of Responsible Officials and Corrective Action Plan: We concur with this finding. It is an on-going issue. Our policies and procedures concerning student activity funds are up to date. We have held meetings with the school bookkeepers to review the MASBO Student Activity Fund Accounting Manual and have provided electronic and paper copies to the principals, activities/athletic directors and bookkeepers. Our next meeting with this group is August 6, 2026. 2023-002 Late Submission Federal Program Information: Funding agency: U.S Department of Education U.S Department of Agriculture Title: Elementary and Secondary School Emergency Relief ESSER) Fund, American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSER), American Rescue Plan Elementary and Secondary School Emergency Relief - Homeless Children and Youth and Special Education Cluster Child Nutrition Cluster CFDA number: 84.425D, 84.425U, 84.425W, 84.027, 84.173 10.553, 10.555, 10.559 Award year and number: 32-0583-912020, 32-0584-922021, 32-0583-972021, 32-0583- 932021, 32-0584-772021, 32-0584-772022, 32-0584-79-2022 Criteria or Specific Requirement: 2 CFR section 200.512(a) requires the reporting package and data collection form be submitted to the Federal Audit Clearinghouse the earlier of 30 calendar days after the reports are received from auditors or nine months after the end of the audit period. Condition: The fiscal year audit and reporting package is being submitted after the required due date. Context: We reviewed the audit submission date in comparison to the required due date. Questioned Costs: To be determined by grantor Effect: There is a potential for suspension or cessation of federal and/or state funding. Cause: The ongoing Covid-19 pandemic caused a delay in the audit and as such the required deadline could not be met. Repeat: Yes Auditor's Recommendations: The District should take steps to ensure that its financial records are maintained on a current basis, reconciled timely, and audited within nine months after year end. View of Responsible Officials and Corrective Action Plan: In November 2022, the District was informed by its then auditor that they could not complete the audit for FY2022. By that time, most audit firms were booked solid and the District had a difficult time contracting with a new firm. Wipfli, LLC entered into a 3-year contract with the District with the understanding that the FY2022 audit would likely not be filed on time. The FY2022 audit was issued on May 7, 2024. The District committed to having financial information ready for the FY2023 audit by the end of June 2024, which was already twelve months after the end of the audit period. Unfortunately, the financial information for FY2023 was not ready as promised and this had an adverse effect on Wipfli LLC's ability to perform its work as scheduled. To further complicate matters, key accounting personnel left the District in August 2024 and June 2025. These individuals had 30 years and 20 years’ experience, respectively, in the District. Even though this will be a repeat finding for the FY2024 and FY2025 audits, the current accounting personnel and their staff are committed to maintaining the District's financial records on a current basis, reconciling accounts timely and will work to have them audited within the required deadlines.

Finding No.: 2023-011 AL Programs: COVID-19 10.542 – Pandemic EBT Food Benefits (P-EBT) Area: Eligibility Questioned Costs: $16,635 Contact Person(s): Margaret Aldan, NAP Administrator Corrective Action Plan: Condition 1-2: The CNMI NAP agrees with the auditor’s finding and conclusions. The issues occurred because CNMI NAP lacked effective monitoring controls and systematic filing procedures over eligibility Finding No.: 2023-011, continued AL Programs: COVID-19 10.542 – Pandemic EBT Food Benefits (P-EBT) Area: Eligibility Questioned Costs: $16,635 Contact Person(s): Margaret Aldan, NAP Administrator Corrective Action Plan: determinations, attendance data verification, documentation retention, and reconciliation of data received from the Public School System. To prevent recurrence, the CNMI NAP will perform the following: • Develop and implement written standard operating procedures for eligibility verification, attendance data review, benefit computation, and documentation retention. • Create and implement a centralized electronic filing system for all eligibility supporting documents. • Establish monthly reconciliation procedures between PSS data and NAP eligibility records. • Conduct quarterly internal case file reviews (minimum 10% sample) to ensure completeness and accuracy. • Provide refresher training to all NAP eligibility and fiscal staff on the new procedures. Proposed Completion Date: September 30, 2026

Finding No.: 2023-005 AL Program: 10.555 National School Lunch Program (NSLP) Area: Reporting Questioned Costs: $-0- Views of Auditee and Corrective Action Plan: Management’s Position: PSS Management concurs with the findings. Financial and Grants Management procedures were promulgated in a SOP on September 18, 2024. The financial management system was subsequently changed to Tyler Munis to conform with CNMI central government requirements which will enhance capabilities. The SOPs and the Tyler Munis implementation are under review by an external consultant and recommendations made to improve coding of grant details and expenditures, increased frequency of reconciliations, and a specific SOP for report preparation. Corrective Action Plan: I. Implementation of a Comprehensive Grant Tracker: PSS will develop and implement a centralized Grant Lifecycle Tracker for all active federal awards. This tool will serve as the primary monitoring mechanism for compliance by recording all financial and programmatic reporting due dates, assigning specific preparers for each report, and establishing automated milestones to ensure sufficient lead time for both the preparation phase and the subsequent supervisory review. II. Deployment of Enhanced Data Analysis Tools: To ensure that quarterly program reporting is both consistent and timely, PSS will develop and implement specialized data analysis tools. these tools will streamline the aggregation of program data, reducing manual entry errors and allowing for more efficient evaluation of program performance against federal benchmarks. Proposed Completion Date: In progress for FY 2024 with completion by August 2026. Name of Contact Person and Title: Contact: Jacqueline Che, Federal Programs Officer Email Address: jacqueline.che@cnmipss.org

Finding No.: 2023-003 AL Program: 10.555 National School Lunch Program (NSLP) Area: Allowable Costs/Cost Principles Questioned Costs: $-0- Views of Auditee and Corrective Action Plan: Management’s Position: PSS Management concurs with the findings. Financial and Grants Management policies procedures were promulgated in SOPs on September 18, 2024. The financial management system was subsequently changed to Tyler Munis to conform with CNMI central government requirements which will enhance capabilities. The SOPs and the Tyler Munis implementation are under review by an external consultant and recommendations made to improve documentation of cost allowability have been received. Corrective Action Plan: I. Finalization of Allowability and Disbursement SOPs: PSS will finalize comprehensive Standard Operating Procedures (SOPs) and policies specifically governing allowability determinations and vendor payments. II. Enhanced Disbursement Controls: PSS is implementing a documented review and approval controls over the payment process. Before any check or ACH disbursement is finalized, a reviewer must verify that the payment amount agrees exactly with the approved invoice. This verification will be physically or digitally documented on the payment voucher to provide a clear audit trail of the pre-payment review. Proposed Completion Date: In progress for FY 2024 with full implementation and documentation processes expected to be completed in 2026. As part of this improvement, we are designing a standardized, documented review process to ensure all disbursements are verified against approved invoices prior to payment. Name of Contact Person and Title: Contact: Jonathan Aguon, Director of Finance Email Address: jonathan.aguon@cnmipss.org

Corrective Action Plan Details: A. Contact person responsible for corrective action: Name: Alicia Smith Title: Chief Financial Officer B. Description of corrective action planned: The district will strengthen its internal control systems over reporting to ensure single audit reporting package and data collection form are submitted to the Federal Audit Clearinghouse within established timeframe and financial statements are prepared timely. C. Anticipated completion date of corrective action: Immediately

Responsible Parties: Erik Estill and Russell Raney Finding: The child nutrition program cumulative net cash resources as of September 30, 2023, totaled $401,854 which exceeded the 3-month net cash resource limit by $261,641. Corrective Action: The child nutrition program accumulated a large net cash resource balance during the COVID pandemic and the USDA extension of the seamless summer feeding program. During the ALSDE review of the FY 2024 financial statement submission and the required CNP financial profile submission, the school was notified of the net cash resource balance and was required to submit a detailed spenddown plan to bring net cash resources under the 3-month limit. The spend-down plan was approved by the ALSDE, and the school is currently operating under the plan. The spend-down plan was revised by the school, reviewed and approved by the ALSDE in conjunction with the FY 2025 financial statement submission. Expected Completion Date: August 4, 2025

Responsible Parties: Erik Estill and Russell Raney Finding: Due to the passage of time, the turnover of staff, and the use of a third-party payroll provider, supporting documentation necessary to verify and document vendor payments and payroll transactions was not available, resulting in the inability to obtain sufficient, appropriate audit evidence related to these amounts. Corrective Action: The school (LEAD Academy) contracted with New Schools for Alabama (NSFA) during 2023 to handle all their finance and accounting needs. By the end of 2023, the school also transitioned all payroll services to New Schools for Alabama. Prior to 2024, a third-party vendor was handling/processing payroll for LEAD Academy. Additionally, procedures were not in place to maintain monthly payroll data (timesheets, leave balances, documentation of annual salaries) prior to 2024. All financial records are now maintained digitally, with the original documents residing at the school. Additionally, NSFA worked with existing staff regarding proper documentation and filing of financial records and helped establish a new filing system. In 2024, payroll processing for the school was transitioned to NSFA, utilizing the state approved accounting/payroll software. Monthly procedures are now in place for the submission, approval and documentation of all payroll transactions. Expected Completion Date: September 30, 2024

2023-003 SCDA Special Tests Significant Deficiency and Non-Material Noncompliance Corrective Action: We've hired competent staff that understand how to reconcile inventory to the general ledger. Person Responsible: Stephano Blake Email: S8lake@harvesthope.org Phone: 803-636-6635

The Division will ensure the documentation related to inventory counts are maintained. September 2026 Al Agpoon, Golden State Division Controller

2022-005 Contact Person Jackie Cordie, Business Manager Corrective Action Plan The District plans to implement the auditor's recommendation. Planned Completion Date for CAP Fiscal year beginning July 1, 2026

VIDE acknowledges the audit finding regarding the Child Nutrition Cluster Period of Performance and concurs with the recommendation. We recognize that while the cost was incurred during the valid period, the liquidation payment occurred 18 days past the allowable deadline. To prevent recurrence, VIDE will enforce strict protocols for grant closeout and liquidation. To achieve this, VIDE will establish an internal hard stop deadline for invoice submission, requiring that all invoices for expiring grants be submitted to the Fiscal Office no later than 45 days prior to the federal liquidation deadline to provide a necessary buffer to resolve vendor disputes and process payments before the federal cutoff. Additionally, the State Director of Special Nutrition Programs will implement a scheduled notification system to issue closeout alerts to relevant program staff and fiscal support personnel at 90, 60, and 30 days prior to the liquidation deadline, which will trigger the immediate review of open encumbrances and the expediting of pending invoices to ensure the internal hard stop deadline is met. Furthermore, for any valid expenditures remaining unpaid within 30 days of the liquidation deadline, the Fiscal Office will generate a priority payment list and transmit it to the Department of Finance with a high-priority flag to ensure these specific vouchers are processed before the grant period closes. Finally, the Federal Grants Director and the Deputy Commissioner of Fiscal and Administrative Services will review the Grant Expiration Report monthly to identify grants approaching their liquidation deadline and ensure the internal cut-off dates are being adhered to.

Audit Finding Reference: 2023-002 Improve Controls and Documentation Over Allowability of Costs (Significant Deficiency) Planned Corrective Action: We try our best to have proper paperwork in order prior to processing invoices. In the time of COVID, we had some issues with staff working off site which could of lead to this finding, I strongly feel that we are improving on this finding as we progress in stressing internal controls. Management is striving to have this finding removed prior to the next review due to the protocols they have implemented. Name of Contact Person and Completion Date Stephen T. Spencer, City Comptroller December 31, 2025

Audit Finding Reference: 2023-001 Improve Controls and Documentation Over Payroll Process (Material Weakness) Planned Corrective Action: The School Payroll Department is working to supply all applicable back up for staff being funded by Federal Funds. This has been an issue and we have been stressing that this is a finding and more diligence needs to occur in order to remove this finding. Management is striving to have this finding removed prior to the next review due to the protocols they have implemented. Name of Contact Person and Completion Date Kevin McHugh, School Business Administrator December 31, 2025

Condition: The School District did not complete on-site monitoring reviews for any buildings operating school lunch and breakfast programs within the School District during the year ended June 30, 2023. Planned Corrective Action: Southfield Public Schools contracts its food service with Southwest Food Service. To address the noncompliance, the Food Service Director (Southwest Food Service), and Food Service Purchasing (Southfield Public Schools) will coordinate the on-site monitoring reviews and its completion to Michigan Department of Education standards, and make sure the required forms are completed before deadlines. Contact person responsible for corrective action: Marc Ingram, Chief Financial Officer Anticipated Completion Date: 02/01/2024

FA 2024-001 Improve Controls over Equipment Compliance Requirement: Equipment and Real Property Management Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial 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: 235GA32N1199 Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: COVID-19 - 84.425D - Elementary and Secondary School Emergency Relief Fund COVID-19 - 84.425U - American Rescue Plan Elementary and Secondary School Emergency Relief Fund COVID-19 - 84.425W - American Rescue Plan Elementary and Secondary School Emergency Relief Fund - Homeless Children and Youth Federal Award Number: S425D200012 (Year: 2020), S425D210012 (Year: 2021) S425U210012 (Year: 2021), S425W210011 (Year: 2021) Questioned Costs: None identified Prior Year Finding: FA 2022-001, FA 2021-001, FA 2020-001, FA 2019-003, FA 2018-002, FA 2017-004 Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over equipment and real property management as it relates to the Child Nutrition Cluster and Elementary and Secondary School Emergency Relief Fund programs. Corrective Action Plans: Management has strengthened controls over equipment to ensure that the records are complete, accurate and r reflect all required information. We are in the process of developing a physical inventory list of equipment. The inventory listing will have all identifying information such as an item description, an identifying number, the source of funding, the title holder, the acquisition date, the cost, the percentage of federal participation in the project costs, the location of the equipment, the use and condition of the equipment, and any ultimate disposal data for each piece of equipment. A complete physical inventory will be performed each year and reconciled with the equipment listing. Estimated Completion Date: 12/31/2025 Contact Person: Christopher Stephens, Chief Financial Officer Telephone: 229-268-4761 Email: christopher.stephens@dooly.k12.ga.us

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.