Corrective Action Plans

2025-001 Reporting US Department of Education – AL #s10.553, 10.555, 10.559 and 10.582 Child Nutrition Cluster Condition: The District submitted monthly child nutrition reimbursement claims that contained inaccurate meal counts for multiple months during the fiscal year. Specifically, the District overstated reimbursable meal counts due to errors in including non-reimbursable meals served. Additionally, the claims were not subject to an independent review prior to submission to ensure accuracy and completeness. Name of Contact Person: Ann Berman, Business Manager Plan of Action: The District will revisit the internal control processes surrounding the grant reporting and reimbursement process to ensure meal count information submitted is within program requirements of Child Nutrition Cluster programs. In the event there are questions surrounding meal count and other information subject to reporting, the District will continue to rely on timely guidance from external governmental accounting consultants, the Oregon Department of Revenue, and the Oregon Department of Education.

The District is correcting the eligibility status of student participants and is providing training to those that determine the eligibility status to ensure proper eligibility determination in the future.

No. 2025-001 Subject: Allowable Costs and Activities ‐ Significant deficiency in internal control over compliance and compliance finding. Name of Contact Person: Byron Jones, CFO Phone Number: (480) 270-5438 Anticipated Completion Date: June 30, 2026 Corrective Action: We will strengthen internal controls over employee time coding by implementing enhanced review procedures to ensure only allowable Child Nutrition activities are charged to the grant. Supervisors and the accounting team will review all payroll coding charged to the Child Nutrition Cluster to verify that the employee’s position and duties align with approved grant activities. These improved internal procedures will provide proper compliance over allowable costs. We will also conduct an annual audit of all grant-funded employee positions at the start of each school year, reviewed by the grants team, HR, and accounting, to verify the accuracy of all employee costing allocations to federal grants and to ensure any miscoding errors are identified and corrected in a timely manner.

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.

Finding 2025-003 Eligibility for Individuals Criteria: Per 7 CFR Part 245.6 local educational agencies must accurately determine eligibility based on income information provided in free and reduced lunch applications. Audit Recommendation: The District should strengthen controls surrounding eligibility determination by including a review process to ensure correct determinations have been made. Corrective Action Planned: The District will have two reviewers for all paper applications to ensure compliance and accurately determine eligibility. Person Responsible: Jason Sundberg, Business Administrator Anticipated Completion Date: December 31, 2025

Finding 2025-002 Reporting Criteria: Per 2 CFR Part 200 and the USDA Child Nutrition Program regulations, local educational agencies must ensure that claims for reimbursement are accurate, supported by documentation, and reviewed prior to submission to the administering agency. Audit Recommendation: The District should strengthen controls surrounding reporting by including a review process to ensure claims submitted agree to underlying records. Corrective Action Planned: The District will include another individual in the reporting process to review and ensure claims submitted agree to underlying records to ensure compliance. Person Responsible: Jason Sundberg, Business Administrator Anticipated Completion Date: December 31, 2025

2025-001 Ineligible Student Approved for Food and Nutrition Program U.S. Department of Agriculture – Child Nutrition Cluster CORRECTIVE ACTION PLAN (CAP): 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 implement review of household applications. 3. Official Responsible for Ensuring CAP: Maria Bezdicek, Business Manager, is the official responsible for ensuring corrective action for compliance. 4. Planned Completion Date for CAP: The planned completion date is June 30, 2025. 5. Plan to Monitor Completion of CAP: The School Board of ISD No. 2895 will be monitoring this corrective action plan.

Finding Number Federal Programs Audit: 2025-001; Responsible Person: Rachelle Roby; Management Views: Management agrees with the finding and is in the process of implementing the recommendation.; Corrective Action: The District will collaborate with the Director of Food Service to ensure that, when a physical count is conducted, the figures are verified by a second staff member for accuracy. Additionally, it will be required that all supporting documentation be submitted to the Chief Financial Officer (CFO) along with the claim figures. The CFO will review and compare the documentation against the data entered into the claiming system prior to the submission of the claim.; Anticipated Completion Date: 08/01/2025

Contact Person – Thomas A. Jerome, Superintendent Corrective Action Plan – The District will implement policies and procedures to ensure all students who receive a free or reduced meal have a current and accurate application on file. Completion Date – March 31, 2026

Views of Responsible Officials and Planned Corrective Actions: The District will implement a secondary review process for verifying, entering, and confirming the status of the free and reduced applications. Documentation will be maintained to indicate the individuals performing completion and secondary review of required steps to verify timeliness and accuracy of eligibility determination and reporting.

Condition: During the course of the audit, various applications were found to be imporperly completed and/or the status was improperly determined. There was also an audit conducted by the State in the current year which found the same conditions to be true. Plan: The District has received guidance from the State, as an audit was performed by them. The staff involved in approving applications has gone through additional training and a checklist was developed to follow and verify accuracy. Anticipated Date of Completion: 6/30/2026 Name of Contact Person: Beth Reich, CSBO/Business Manager Management Response: N/A

FINDING 2025-001 Finding Subject: Child Nutrition Cluster - Eligibility Contact Person Responsible for Corrective Action: Jacob Heuchan, Business Manager Contact Phone Number and Email Address: 317-878-2100, jheuchan@nhj.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Business Manager and Food Service Director will work together to implement a system of controls surrounding eligibility. The Business Manager and Food Service Director will meet on a regular basis to verify eligibility outcomes to ensure accuracy. Anticipated Completion Date: Immediate. INDIANA STATE

Condition: For the year ended June 30, 2025, it was noted that meals submitted for reimbursement included meals for students that were not eligible per the District's application for the program, resulting in the District being reimbursed in excess for an estimated $33,771. Recommendation: The District should apply for reimbursement for meals that were served to students included in their program application or take measures to amend the program application. Management Response: During the 2024-2025 school year, East Alton-Wood River Community High School District #14 began providing breakfast and lunch service for the Region III Journeys Program, an off-site alternative learning program serving students from multiple districts including EAWR. This was the first year EAWR had ever provided meals for Journeys, and the District implemented this service with the good-faith intention of ensuring that all students attending the program had access to daily nutritious meals. Because this was a new service arrangement, the District did not realize that our existing Community Eligibility Provision (CEP) approval documentation needed to be amended to include the additional educational site. The meals served to students at the Journeys Program were therefore included on the monthly reimbursement claims. The variance identified by the auditors reflects only the meals served at this second site, which are not captured in Skyward because some of the Journeys students are not enrolled at EAWR. There was no intent to misclaim meals, and the District did not receive financial benefit beyond the actual cost of preparing and providing meals. The additional breakfasts and lunches prepared for Journeys (approximately 20 breakfasts and 20-30 lunches daily) do not exceed the District's total CEP enrollment capacity and represent meals that were prepared, delivered, and made available to students. Additionally, in prior years another CEP district provided meals to the Journeys Program under similar circumstances without receiving reimbursement from Region III districts, which contributed to our understanding of customary practice within the cooperative. This was an administrative oversight associated with the first year of providing meal service to an off-site program and not the result of intentional noncompliance or an attempt to secure unearned reimbursement. No financial harm occurred to the program, as all meals claimed were prepared and made available to students in accordance with CEP expectations for universal access. To ensure future compliance, the District will amend its CEP application to include all educational centers served by EAWR in subsequent program years. Anticipated Date of Completion: June 30, 2026

SIGNIFICANT DEFICIENCIES, 2025-002 Allowable Costs and Activities: There is an audit recommendation that the District implement internal control processes and procedures to ensure that each purchase has a purchase order and an approved invoice at the time of payment, clearly indicating pre-approval for the purchase and coding to ensure it is charged to the correct accounts. Corrective Action: The District already has a requisition/purchase order system in place and will expand it to ensure purchases are pre-approved and that invoices are approved and that the purchase is coded to the appropriate fund. Anticipated Completion Date: This corrective action has already been implemented. Status: Completed.

MATERIAL WEAKNESSEs, 2025-001 - PROCUREMENT There is a material weakness identified in the audit that The District does not have the necessary internal controls over compliance and does not appear to have understanding or knowledge of the contract requirements for service contracts. Corrective Action: Central Office Staff and Staff responsible for Federal Grants and Programs will familiarize themselves with and implement the proper procedures and requirements for service contracts and procurement methods to ensure it meets the requirements in the District Policy and Federal Procurement requirements. Anticipated Completion Date: January 31, 2026

Finding Number: 2025-002 Planned Corrective Action: Claims reimbursement will be inspected monthly by a separate person from who is inputting the data to ensure accurate filing of meals served. If discrepancies are discovered, the district will maintain support for the numbers that are submitted to DEW. Anticipated Completion Date: 12/31/2025 Responsible Contact Person: Jared M Bunting, SFO

Finding 2025-001 Federal Program: Child Nutrition Cluster AL NO.: 10.553, 10.555 Federal Agency: U.S. Department of Agriculture Pass-Through Entity: Missouri Department of Elementary and Secondary Education Award No.: As listed on the Schedule of Expenditures of Federal Awards Award Period: Various Compliance Requirement: Eligibility Views of the Responsible Officials: Starting in the 2025-2026 school year, the Child Nutrition annual application process will be done online, Before being finalized, it will be required for the Food Service Director to attach an electronic signature. All applications will be stored online for easy retrieval and less risk of misplacement or loss. Any paper applications that are submitted will be reviewed and manually signed by the Food Service Director. Paper applications will be filed in the Director's office. Contact person: Robin Kluesner Anticipated Completion Date: August 22, 2025

FINDING 2025-002 Finding Subject: Child Nutrition Cluster - Internal Controls Contact Person Responsible for Corrective Action: Todd Nobbe, Corporation Treasurer Contact Phone Number and Email Address: 812-934-2194, tnobbe@batesville.k12.in Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The school corporation will establish a proper system for internal controls and develop procedures to ensure free and reduced guidelines are reviewed by the Corporation Treasurer. The school corporation will establish a proper system for internal controls and develop procedures to ensure EFTs are reviewed by the Director of Operations. Anticipated Completion Date: Immediately 12/08/2025

This finding is due to the District not having the proper controls in place to prevent, detect, or correct an incorrect monthly meal claim. The month that had the incorrect meal claim used incomplete Z-Reports which resulted in the meal claim being submitted for less than it should have been. The persons responsible for the corrective action are Lisa Newton, the Food Service Director and Corey Bordo, the Director of Business and Finance. The anticipated completion date of the corrective action plan is immediate. The plan for monitoring adherence is the Food Service Director will ensure that all meal counts are final on the Z-Report before the claim requests are made.

The District will review its procedures related to application approvals.

Name of Contact Person: Paul Taylor, Superintendent. Recommendation: We recommend the District implement internal controls to ensure their procurement policy is followed. We also recommend updating their contracts with all required language, including the Buy American clause. Correction Action: We will implement internal controls to ensure our procurement policy is followed. We will also update our contracts with all required language, including the Buy American clause. Proposed Completion Date: Immediately.

Recommendation: We recommend that the District implement procedures and controls to ensure that all paper applications are being reviewed. 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 work on establishing procedures and controls to ensure that all paper applications are being reviewed. Official Responsible for Ensuring CAP: Tanner Spawn, Business Manager. Planned Completion Date for CAP: June 30, 2026.

U.S. Department of Education Clinton School District #124 respectfully submits the following Corrective Action Plan for the year ended June 30, 2025. Contact information for the individual responsible for the corrective action: Daniel Brungardt, Superintendent Clinton School District #124 Independent Public Accounting Firm: Gerding, Korte & Chitwood, P.C., 723 Main Street, Boonville, MO 65233 Audit Period: Year ended June 30, 2025 The findings from the June 30, 2025, Schedule of Findings and Questioned Costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Significant Deficiency 2025-001 Child Nutrition Cluster Recommendation: We recommend that fund balances should be monitored to ensure that balances remain in line with child nutrition compliance requirements.

Action Taken: As part of corrective actions, the District has prioritized overdue infrastructure and equipment needs. Since July1, 2025 the District has invested $118,901.50 in equipment upgrades, including: rebuilding the 17 year-old walk-in cooler and freezer at Clinton High School; installing new refrigerator and freezer units at CMS and Henry Schools; decentralizing cold storage operations to improve reliability and delivery efficiency, replacing a failing centralized system; replacing the serving line at Henry School, which is outdated and no longer meets the operating needs of a modern cafeteria; ongoing replacement of aged and non-functional food service equipment across multiple sites; review options for replacing or upgrading centralized walk-in freezer unit. These upgrades are critical to ensuring food safety, operational efficiency, and service quality for students. The District will also continue to track expenditures and ensure fund usage aligns with NSLP guidelines. Upon fully expending the excess fund balance, the District will submit detailed documentation by June 30, 2026 outlining how funds were used and the impact of those actions.

Completion Date: June 30, 2026