Corrective Action Plans

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

FINDING 2025-004 Finding Subject: Child Nutrition Cluster – Suspension and Debarment Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children CFDA Numbers: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY2024, FY2025 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension & Debarment Audit Findings: Significant Deficiency Summary of Finding: The School Corporation had not properly designed or implemented an effective system of internal controls to ensure that vendors were not suspended or debarred prior to entering into a covered transaction. The School Corporation verifies through review of the SAM exclusions each time they begin doing business with a new vendor. However, a second individual does not verify the website has been reviewed. Contact Person Responsible for Corrective Action: Rachel Moore, Treasurer Contact Phone Number and Email Address: 574-457-3188 x 1369, rmoore@wawasee.k12.in.us Views of Responsible Officials: Management concurs with the finding. Description of Corrective Action Plan: The Treasurer will review the SAM exclusion data for each vendor before setting up the vendor information in the accounting software. The review will be indicated by printing the SAM exclusion data and attaching the printout to the vendor W-9 kept on file in the Treasurer’s office. The Treasurer will indicate their review of the exclusion data by their signature/initials on the printout and a secondary employee will review and sign/initial as well to document the second review. Additionally, at the start of each calendar year the Treasurer will review the SAM exclusion data prior to processing any vendor claim to a vendor for that calendar year. The annual exclusion review will be documented by the Treasurer re-printing the SAM exclusion data for the 46 INDIANA STATE BOARD OF ACCOUNTS 46 801 S. Sycamore Street, Syracuse IN 46567 (574) 457-3188 Wawasee Community School Corporation vendor and signing/initialing the printout, and second employee will verify the accuracy by their signature/initials on the printout as well. The updated printout will be attached to the vendor W-9 kept on file in the Treasurer’s office. Anticipated Completion Date: The planned corrective action will be implemented in February of 2026 with any new vendor created in the accounting software. For established vendors, the Treasurer will begin re-verifying the vendor’s exclusion data in SAM prior to processing any vendor claims and creating a spreadsheet to track the most recent SAM verification for each vendor. This corrective action will be implemented by March of 2026.

FINDING 2025-003 Finding Subject: Child Nutrition Cluster – Eligibility Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children CFDA Numbers: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY2024, FY2025 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Findings: Material Weakness, Other Matters Summary of Finding: The School Corporation had not properly designed or implemented an effective system of internal controls over review of individual free and reduced status applications and information management in the Skyward Software System used to determine and maintain eligibility status. Individual Applications The school noted individual applications for both direct certification and income eligible students would be printed and reviewed after the system makes a determination of eligibility status. Out of 40 students tested, no documentation of the review was provided for 34 students. Skyward Software System The School Corporation is required to design controls ensuring computer systems used to maintain student benefit status are secured. Currently, the Skyward system allows all school lunch employees to make changes to student benefit status, and there is no indication or record within the system as to who makes these changes. Additionally, income eligibility guidelines in the system that determine whether students are eligible based on income are updated by the system automatically every year. The school is required to perform annual review to ensure these guidelines are accurate. However, no annual review is done by school corporation staff. Contact Person Responsible for Corrective Action: Rachel Moore, Treasurer Contact Phone Number and Email Address: 574-457-3188 x 1369, rmoore@wawasee.k12.in.us 44 INDIANA STATE BOARD OF ACCOUNTS 44 801 S. Sycamore Street, Syracuse IN 46567 (574) 457-3188 Wawasee Community School Corporation Views of Responsible Officials: Management concurs with the finding. Description of Corrective Action Plan: A School Corporation employee will be designated to receive, review and process each individual application. Applications received digitally via the Skyward Software System will be printed so that a paper copy of each digital application is kept on file. The review of each application will be documented in writing on the paper copy of the application. A second School Corporation employee will perform a secondary review of every application to ensure accuracy of the eligibility determination, and the secondary review will be documented on each application. The eligibility guidelines in the Skyward Software System used to determine student eligibility will be downloaded from the School Nutrition Program’s website prior to July 1 of each year and will be uploaded into the Skyward Software System by the technology department of the School Corporation. After upload is complete, the Food Service Manager will review the data to ensure correct upload and will indicate the review on the sign-off form created by the School Corporation. The sign-off form will be retained to document the review. Anticipated Completion Date: The corrective action with regard to individual applications has already been implemented beginning with the 2025-2026 school year. For the 2025-2026 school year, the Treasurer has done the initial review of each application and the Food Service Manager has done the secondary review to ensure accuracy of each determination. Beginning in the 2026-2027 school year the process will remain the same but with the Food Service Manager performing the initial review and the Treasurer performing the secondary review. The corrective action with regard to the eligibility guidelines in Skyward will be implemented beginning with the upload of data in preparation for the 2026-2027 school year, expected to be in June of 2026.

Condition - The District, as the school food authority, did not establish effective internal controls to ensure that meal claims were accurately prepared and submitted. One individual was responsible for preparing and submitting meal claims, and there is no secondary review of the meal claim before it is submitted. Plan - Meal claims will prepared by the food service director based on meal counts from the student management software. The finance director will review the meal claims in comparison to the meal counts and document this process. Any variances will be discussed with the food service director, and if necessary, changes will be made to the meal claims. After this review, the food service director will submit the meal claims. Anticipated Date of Completion - December 2025; Name of Contact Person - Dr. Matthew DeBaene, Superintendent; Management Response - We will perform a secondary review of the meal claims before they are submitted for reimbursement.

Unified School District #446 Independence, Kansas Corrective Action Plan March 3, 2026 Cognizant or Oversight Agency for Audit Unified School District #446 respectfully submits the following corrective action plan for the year ended June 30, 2025. Name and address of independent public accounting firm: Jarred, Gilmore & Phillips, PA, P.O. Box 779, 1815 S Santa Fe, Chanute, Kansas 66720. Audit period: Year ended June 30, 2025 The findings from the March 3, 2026 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Finding: 2025-001 –Reporting Condition: During our testing of meal reporting, we tested two months of meal report claims submitted to the State and traced to individual count sheets per school. It was discovered that on one day, eligible student meals were overreported on the claim for reimbursement. Recommendation: Policies and procedures should be written to provide internal control over meal reporting. We recommend the District establish a review process, such as having another individual review count sheets and compare them to the number of meals submitted, to ensure all meals submitted for reimbursement are for the correct number of meals. Action Taken: We concur with the recommendation and since the 2025 fiscal audit took place, we have updated review procedures to ensure that all meal reports are reviewed to ensure that they are being properly reported. Anticipated Complete Date: November 11, 2025 Should the Oversight Agency for Audit have questions regarding this plan, please contact Gina Godinez, Director of Finance, at (620) 332-1800. Sincerely Unified School District #446 Unified School District #446

Significant Deficiency 2025-001. Procurement United States Department of Education, passed through New York State Department of Education Title I Grants to Local Educational Agencies ALN: 84.010A United States Department of Agriculture, passed through New York State Department of Education Child Nutrition Cluster Non-Cash Assistance (food distribution) National School Lunch Program ALN: 10.555 Cash Assistance School Breakfast Program ALN: 10.553 National School Lunch Program ALN: 10.555 Condition: The District has not updated its existing policies and written procedures to conform to Uniform Guidance requirements. Planned Corrective Action: The District has developed a policy entitled “Procurement: Uniform Grant Guidance for Federal Awards” that addresses the Uniform Guidance requirements related to procurement. This policy was presented to the Board of Education at the August 28, 2025 Board meeting and formally adopted by the Board of Education at the November 17, 2025 Board meeting. Responsible Contact Person: Jeremy Feder Assistant Superintendent for Business and Operations Lawrence Union Free School District 2 Reilly Road Cedarhurst, NY 11516 Anticipated completion date: The required policy was adopted by the Board of Education at its November 17, 2025 meeting.

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 compares the meal counts in the claim to the daily meal count reports. The reviewer will then sign and date both the meal count reports (prior to submission) and a printed copy of the meal claim (after submission). Anticipated Date of Completion - June 30, 2026; Name of Contact Person - Dr. Eric Heath, Superintendent; Management Response - A corrective action plan will be developed and implemented. A secondary review of the meal claim to the supporting documents will be performed before the meal claim is submitted.

FINDING 2025-002 Finding Subject: Child Nutrition Cluster – Suspension and Debarment Contact Person Responsible for Corrective Action: Felicia Wolfington Contact Phone Number and Email Address: (812) 936-4474 x 1232, fwolfington@svalley.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: In the future, the Treasurer will check the SAM exclusion list prior to entering into a covered transaction with federal awarded funds. There will also be a documented, secondary review to ensure the suspension and debarment requirement has been checked. Anticipated Completion Date: 02/04/2026

The District has existing policies to address overdue meal charges: EFAA-Meal Charging and EFC-Free and Reduced-Price Lunch. Due to staff transitions over the last several years, these policies have not been adequately enforced. The following steps will be taken to correct this: • Central Office Oversight: The central office will take a more active role in ensuring policies are executed effectively. • Policy Review: Policies will be reviewed with all staff members responsible for their implementation. • Targeted Training: Comprehensive training will be provided to all involved personnel, specifically food service workers and building principals. • Compliance Monitoring: The central office will monitor adherence to these policies and provide ongoing support to staff. • Community Partnership: The District will increase coordination with non-profit charities to secure assistance for students in need. Additionally, current policies and practices will be reviewed and updated as necessary to ensure the desired outcomes are achieved.

To prevent future errors in reporting, the School District will establish a simple monthly reconciliation procedure in which reported meal counts are compared to daily meal service records to identify and correct discrepancies before submission.

To prevent future errors in eligibility determinations, the School District will implement a secondary review process. All eligibility applications will be reviewed by a second qualified staff member to verify household size, income calculations, and comparison to the National Income Eligibility Guidelines before final approval.

Finding 2025-004 Information on the federal program: Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Finding: Material Weakness Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the eligibility compliance requirement. Context: During the testing of internal controls over eligibility determinations for free and reduced meals, we noted there was no formal review control in place. Additionally, there was no documented review by School Corporation personnel of the Income Eligibility Guidelines used by the food service software which are updated on annual basis. The lack of review was isolated to fiscal year 2024 as the School Corporation qualified under the Community Eligibility Provision for fiscal year 2025. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: In the event the School Corporation is not eligible for the Community Eligibility provision in future periods, the Treasurer and Food Service Director will develop controls to ensure system income thresholds are reviewed annually to ensure they are in agreement with USDA income thresholds. Responsible Party and Timeline for Completion: Treasurer and Food Service Director will work together immediately to form a better internal control policy for ensuring system income thresholds are met.

Information on the federal program: Subject: Child Nutrition Cluster - Reporting Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY2024, FY2025 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness, Qualified Opinion Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the reporting compliance requirement. Questioned Costs: $164,866 (known questioned costs) Context: During the testing of meal claim reimbursements, we noted 3 monthly reimbursements in a sample of 6 claims selected where the School Corporation was unable to produce auditable support of meals served and claimed via underlying meal system reports. The claim reimbursements for these 3 months unsupported by meal claim data totaled $157,708. Additionally, we noted one month in which there were variances when comparing the reimbursement in our to sample to underlying meal system reports, resulting in $7,158 over claimed. Additionally, we noted that management has no formal, documented review control in place for monthly meal claims prior to submission to the Indiana Department of Education (IDOE). Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Treasurer and Food Service Director will enhance internal controls surrounding the Child Nutrition claim reporting process. The Treasurer and Food Service Director will ensure the preparation and review of claims is documented and correct prior to submission. Responsible Party and Timeline for Completion: Treasurer and Food Service Director will work together immediately to form a better internal control policy for the claim reporting process.

Response and Corrective Action Plan: The District will review its procedures and look into possible additional controls to be implemented.

Compliance Requirement Procurement Criteria Under 2 CFR 180.995, the School District must not enter into covered transactions with parties that are suspended or debarred. For covered transactions (generally at or above the simplified acquisition threshold), the School District must verify that vendors are not suspended or debarred by (1) checking SAM.gov, (2) collecting a vendor certification, or (3) adding a contractual clause that the vendor is not suspended or debarred and maintaining documentation of the verification. Additionally, under 2 CFR 200.318(h), the School District must maintain effective internal controls over procurement to ensure compliance with federal statutes, regulations, and the terms and conditions of federal awards. Condition During testing and confirmed with management at the School District, it was determined that the School District does not verify that vendors were not debarred or suspended. Cause The School District’s procurement procedures do not require or are not consistently followed to perform and retain documentation of suspension and debarment checks for covered transactions. Effect Without controls to verify and document vendor eligibility, the School District is at risk of expending federal funds with vendors that are suspended or debarred, resulting in noncompliance with federal requirements. This could lead to questioned costs, repayment obligations, and reputational risk. Recommendation The Bonadio Group recommended that the School District strengthen its internal controls over the procurement requirement regarding suspension and debarment requirement by implementing the following actions: (a) Update written procurement procedures to clearly require documented verification before entering any covered transactions. (b) Require procurement staff to document verification at the time of award and to retain the documentation in the procurement file. (c) Integrate a system of controls, where feasible, that prevents a purchase order or contract from being finalized unless proof of suspension/debarment verification has been uploaded. (d) Provide reoccurring training to procurement, finance and grant management staff regarding federal suspension and debarment requirements and proper documentation practices. (e) Implement periodic monitoring or internal reviews to ensure that the verification process is consistently followed and address any deviations promptly. View of Responsible Officials The School District will institute additional procedures to ensure that vendors are not debarred or suspended. Response We are in agreement with the recommendation and will be creating a federal funds procedural manual to address the issues above. Anticipated Completion Date This will be corrected by 6/30/26. Person Responsible Stephanie Fanning, Assistant Superintendent for Business

Date: February 9, 2026 FINDING 2025-001 Finding Subject: Child Nutrition Cluster-Eligibility Contact Person Responsible for Corrective Action: Paula Powers, Food Service Coordinator Contact Phone Number and Email Address: 812-347-3905 ppowers@nhcs.k12.in.us Views or Responsible Official: We concur with the findings. Description of Corrective Action Plan: With future processing of Direct Certification downloads, the Food Authority will generate and IT department will input Direct Certification to software System (Harmony). A second person will review the approval process to ensure Direct Certification input was downloaded correctly. After reviewing, second person will sign the Direct Certification download list in order to maintain proper checks and balances. Anticipated Completion Date: August 2026

Subject: Child Nutrition Cluster (CNC) – Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Federal Award Numbers and Years (Or Other Identifying Numbers): FY23-FY24, FY24-FY25 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Findings: Material Weakness Condition : An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Eligibility compliance requirements. Context : During testing of internal controls over eligibility requirements, we noted there is no formal, documented review of the eligibility income guidelines entered into the food service software to ensure that system parameters were in agreement with USDA guidelines on an annual basis. For the 2023-2024 school year, the income eligibility guidelines were not updated timely by the School Corporation. During compliance testing of eligibility, we noted 3 instances isolated to 2023-2024, in a sample of 60 students, in which the eligibility status was incorrectly determined. In two instances, the eligibility status was changed from Reduced to Free upon updating the eligibility income guidelines. In one stance, the status changed from Pay to Reduced. The lack of internal controls over the review of the eligibility income guidelines impacted both years under audit. The noncompliance with eligibility determinations was isolated to fiscal year 2024. Views of Responsible Official : We concur with the finding. Description of Corrective Action Plan : The Student Management Specialist will print the thresholds and enter the eligibility income guidelines into the food service management software, Harmony. The Superintendent will verify that the data has been entered correctly. Responsible Party and Timeline for Completion : This has already been implemented.

Information on the federal program : Subject: Child Nutrition Cluster (CNC) Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Federal Award Numbers and Years (Or Other Identifying Numbers): FY23-FY24, FY24-FY25 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed and Unallowed, Allowable Costs Audit Findings: Material Weakness, Other Matters Condition : The School Corporation did not have adequate internal controls in place to ensure that the School Corporation complied with the allowable cost requirements. Context : During our testing of the School Corporation’s compliance with the allowable cost requirements for the Child Nutrition Cluster (CNC), we tested 40 vendor disbursement transactions and 40 payroll disbursement transactions and identified the following exceptions: 1. For one vendor disbursement, the School Corporation incorrectly recorded the disbursement for $820 to Fund 800 (School Lunch Fund) that should have been recorded to Fund 300 (Operations Fund), resulting in an unallowable cost being charged to the food service fund. 2. For one payroll disbursement, the School Corporation inaccurately entered the number of hours worked by a cafeteria employee for one pay period, resulting in an overpayment to the employee by $5,568. The employee notified the School Corporation of the overpayment and remitted the overpayment back to the School Corporation. These errors were attributable to deficiencies in the internal controls over the review and approval of vendor and payroll expenditures. Views of Responsible Official : We concur with the finding. Description of Corrective Action Plan : Management will enhance controls and review processes surrounding vendor and payroll expenditures charged to the Child Nutrition. The Food Service Director will be receiving periodic reports to review expenditures charged to the CNC to monitor charged costs. The payroll exceptions report is now checked by the Executive Assistant and Payroll. Responsible Party and Timeline for Completion : Immediately corrected

We will make sure that multiple employees are trained in and have the knowledge of federal compliance requirements so that if one employee is absent for any reason another employee will have the ability to complete the claim for reimbursement in a timely manner to remain in compliance with the Child Nutrition Cluster program requirements.

We will make sure that multiple employees are trained in and have the knowledge of federal compliance requirements so that if one employee is absent for any reason another employee will have the ability to complete the claim for reimbursement in a timely manner to remain in compliance with the Child Nutrition Cluster program requirements.

FINDING 2025-004 CNC Procurement and Suspension and Debarment Finding Subject: Child Nutrition Cluster – Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Patty Kelley Contact Phone Number and Email Address: 812-913-9622 pkelley@bhsc.school Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: The Accounting Department will start keeping a binder that will include all the Procurement and Suspension and Debarment Certificates pertaining to the vendors in our federal programs, which includes Child Nutrition, that equal or exceed $25,000 for each school year. The A/P Clerk will alert the Treasurer when a certificate is needed, and the Treasurer will first check SAM, and then proceed with collecting a certificate from the vendor if one is not found online. When applicable, we can add a clause or condition to a contract noting this acknowledgement. Anticipated Completion Date: This process will be in place by the end of the current fiscal year, June 30, 2026.

FINDING 2025-003 CNC Eligibility Finding Subject: Child Nutrition Cluster - Eligibility Contact Person Responsible for Corrective Action: Patty Kelley Contact Phone Number and Email Address: 812-913-9622 pkelley@bhsc.school Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: The Direct Certification downloads will be done once a month by the Cafeteria Director. The Cafeteria Director will sign the report and forward it to the Treasurer for verification and a second signature. The Direct Certification reports will be kept at the central office. Anticipated Completion Date: This process will be in place by the end of the current fiscal year, June 30, 2026.

Information on the federal program: Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Material Weakness Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the Child Nutrition Program and Procurement compliance requirements. Context: The School Corporation is a member of a purchasing cooperative, who handles the procurement process and establishes competitively awarded contracts for the majority of food service purchases. For one-time purchases such as food service equipment, the School Corporation is responsible for handling the procurement process. For one of the two small purchase method procurements sampled for testing, the school disbursed $67,000 for food service equipment maintenance in fiscal year 2024. The procurement for this item was handled at the school level. We noted the School Corporation did not obtain quotes from an adequate number of qualified sources. The School Corporation also did not properly perform a suspension and debarment check on the vendor. This finding is isolated to fiscal year 2024. There were no purchases in 2025 that required a simplified acquisition or small purchase procurement other than those procured by the food service cooperative. Views of Responsible Officials and Corrective Action Plan: Moving forward, we will implement a standardized procurement checklist to ensure that quotes are obtained from the required number of vendors in accordance with the small purchase method regulations. Child Nutrition Department will also review micropurchase vendors’ cumulative annual spending on a routine basis to determine whether purchases may exceed the micropurchase threshold and require use of the small purchase method. Documentation of all quotes received will be maintained for audit verification. In addition, staff responsible for procurement have received IDOE/USDA refresher training on federal procurement requirements, including thresholds and documentation standards, to ensure full compliance. Suspension and debarment checks will continue to be conducted and documented for all applicable vendors. Responsible Party and Timeline for Completion: Corrective action plan has been implemented as this finding impacted fiscal year 2024 but did not recur in fiscal year 2025. Missy Corns, Food Service Director, and Tracy Albertson, Director of Finance, will oversee the corrective action plan to monitor the procurement and suspension and debarment requirements on an ongoing basis.

Information on the federal program: Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY23-24 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Finding: Material Weakness, Qualified Opinion Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the eligibility compliance requirement. Context: During the testing of internal controls and compliance over eligibility determinations for free and reduced meals, we selected a sample of 15 applications and 45 direct certifications for testing. For 3 of the 15 applications, the School Corporation was not able to provide any documentation to support the eligibility determination due to turnover in the food service director position. Therefore, we were unable to determine whether the School Corporation complied with the eligibility requirements. The internal control and noncompliance was isolated to fiscal year 2024. Views of Responsible Officials and Corrective Action Plan: School Corporation has implemented procedures to ensure a complete record is maintained for every free and reduced-price meal application and any subsequent eligibility status change. All applications, supporting documentation, and determination records are retained as hard copy files. An electronic Benefit Issuance Document will also be retained during the year and printed as a hard copy record. Any change in eligibility status is documented with the effective date and supporting rationale to provide a clear audit trail. These procedures are now part of the School Corporation’s standard operating practices in school food service to ensure ongoing compliance and continuity moving forward. Responsible Party and Timeline for Completion: Corrective action plan has been implemented as this finding impacted fiscal year 2024 but did not recur in fiscal year 2025. Missy Corns, Food Service Director, and Tracy Albertson, Director of Finance, will oversee the corrective action plan to monitor the eligibility requirements on an ongoing basis.