Corrective Action Plans

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Cheney School District No. 360 September 1, 2024 through August 31, 2025 This schedule presents the corrective action planned by the District for findings reported in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Finding ref number: 2025-001 Finding caption: The District did not have adequate internal controls and did not comply with federal Title I assessment system security and eligibility requirements.Name, address, and telephone of District contact person: Jamie Reed, Director of Finance and Operations 12414 S. Andrus Road (509) 559-4501 Corrective action the auditee plans to take in response to the finding: Assessment system security: Assessment Administration Procedures have been reviewed for the 2025-2026 school year by Building Assessment Coordinators (BAC). They will ensure a Test Security Building Plan (TSBP) will be provided for the WIDA assessment administered in their building this school year. BAC Assessment Google folders for 2026-2027 school year are currently being adjusted to provide additional organization to ensure all required documents are completed by BAC's then submitted to the District Assessment Coordinator (DAC) upon completion of the assessment window. Eligibility: The District has already begun corrective actions to address these concerns. District staff have reviewed federal Title I ranking and allocation requirements, including OSPI guidance related to poverty ranking methodology and the 75 percent rule. The District will implement additional review procedures during the annual Title I application and budgeting process to verify poverty calculations, school rankings, and allocation methodologies prior to submission. The District will also document comparability and supplemental funding determinations for any qualifying schools not directly served with Title I funds. Additionally, the District will provide targeted training for staff responsible for federal program administration and budgeting to ensure ongoing compliance with federal and OSPI Title I requirements. Anticipated date to complete the corrective action: Corrective review for the end of the 25-26 school year and full corrective action for the 26-27 school year.

Finding No. 2025-005 Condition – The District did not prepare bank reconciliations during fiscal year 2025. As a result, a portion of National School Lunch and School Breakfast program receipts were not promptly credited to the appropriate food service revenue accounts, and those reimbursements that were recorded incorrectly recorded to the Evidence-Based Funding revenue account in error. Plan – The District will perform bank reconciliations in a timely manner and ensure that National School Lunch and School Breakfast program receipts are appropriately recorded to the proper food service revenue accounts. Anticipated Date of Completion: 7/1/2025 - current Name of Contact Person: Matt Stines, Superintendent

Finding No. 2025-004 Condition – Claims submitted for reimbursement did not reconcile with the District’s internally prepared monthly claim summary report. Plan – The District will ensure that meal counts are thoroughly reviewed prior to submission. Meal counts are entered into the computer by the FSMC, and has been a place where errors have occurred. The district secretary is responsible for entering the meal counts into the state system. She is verifying the counts from the FSMC, comparing to attendance and invoices, and ensuring correct data goes into IWAS. This was started last spring, when we became aware of FSMC inconsistencies. The current year, FY26, has been much more accurate. Anticipated Date of Completion: current – 9/1/2026 Name of Contact Person: Matt Stines, Superintendent

The District experienced a transition in the Business Manager position in February 2025. Following this personnel change, the District began implementing procedural adjustments to strengthen internal controls and improve segregation of duties. Because all three district office staff members were either new to their roles or new to the District during this transition, implementation of these changes took additional time while staff became familiar with their responsibilities. With staff now established in their respective positions and gaining experience, the District has reassigned certain duties and implemented additional oversight procedures to better segregate financial responsibilities and strengthen internal controls moving forward.

Finding ref number: 2025-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with federal procurement requirements. Name, address, and telephone of District contact person: Name: John Hassell Address: 1105 Dale. Ave. Benton City, WA 99320 Phone Number: 509-588-2004 Corrective action the auditee plans to take in response to the finding: (If the auditee does not concur with the finding, the auditee must list the reasons for disagreement). The District agrees with the auditor’s finding. The District did not have adequate controls to ensure we followed our policy to comply with the procurement requirements required by the Child Nutrition Cluster. The District is committed to maintaining strong internal controls and ensuring all future expenditures of federal funds fully comply with procurement mandates. The District is conducting a comprehensive review of our procurement policies with all relevant staff to ensure we follow our policies regarding federal compliance requirements. The District will ensure that the start of each fiscal year that The District will follow a competitive procurement process based on the estimated spend for the vendor. Anticipated date to complete the corrective action: June 1, 2026

2025-002 Child Nutrition Cluster - Assistance Listing No. 10.555, 10.582 Recommendation: We recommend the Department develop procedures and internal controls to ensure that all required subawards are reported timely and accurately to SAM.gov no later than the end of the month following the month of issuance of each subaward. If the Department is unable to complete reporting in SAM.gov, it should follow up with the Service Desk and consult with their federal award contacts for assistance and guidance. Action taken in response to finding: The Department is reviewing and updating internal procedures to ensure all required subawards are reported timely and accurately in SAM.gov. While there have been some technical challenges with SAM.gov reporting, the Department is actively coordinating with U.S. Department of Agriculture contacts to resolve issues and ensure compliance and maintaining a record of each outreach attempt. Staff responsibilities and monitoring procedures are being strengthened to support accurate reporting. Name(s) of the contact person(s) responsible for corrective action: Julia Jou, Budget Director, Rob Curtin, Deputy Commissioner, Erica Gonzales, Associate Commissioner Data & Accountability, Rob Leshin, Director, Food and Nutrition Programs Joseph Valchuis, Audit Supervisor Planned completion date for corrective action plan: April 15, 2026

As of August 2025, we transferred all FFATA reporting duties to the Director of Operations and Systems. The Director of Operations and Systems hired a staff member in January 2026 to assist with FFATA reporting. All FFATA reporting moved from USA Spending to SAM.gov during fiscal year 2025. The migration to SAM.gov caused delays as a result of the account setup process that were out of our control, but we anticipate being current on all FFATA reporting by June 30, 2026.

Planned Corrective Action Plan: The District will ensure all supporting documentation is prepared and ready for Auditors. In addition, audit services will be procured with sufficient time to submit the single audit by the required timeline. Anticipated Completion Date: June 30, 2026 Responsible Contact Person: Lorna Villaruel, Business Manager

The Charter School will require the Food Service

Management Company (FSMC) to provide a current SOC 1 Type II Report in accordance with the bid and contract requirements. Written notification will be sent to the FSMC requesting the report within a specified timeframe.

Finding ref number: 2025-001 Finding caption: The District did not have adequate internal controls and did not comply with federal suspension and debarment requirements. Name, address, and telephone of District contact person: Jaime Matisons, Food Service Manager, 900 Cleveland, Aberdeen, WA. 98520 (360) 538-2256 Corrective action the auditee plans to take in response to the finding: (If the auditee does not concur with the finding, the auditee must list the reasons for non-concurrence). The cooperative provides all bid documents for the district representatives to review, this included suspension and debarment documentation. After review at a meeting of the cooperative membership, the members vote on accepting the bid. The cooperative keeps all documentation on file for review of the auditors. Documentation of this was provided to the auditor. Anticipated date to complete the corrective action: April 2026

Ocosta School District No. 172 September 1, 2024 through August 31, 2025 This schedule presents the corrective action planned by the District for findings reported in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Finding ref number: 2025-01 Finding caption: The District did not have adequate internal controls and did not comply with federal suspension and debarment requirements. Name, address, and telephone of District contact person: Robert Butler 2580 S. Montesano St. Westport, WA 98595 360.268.9125 ext. 1004 Corrective action the auditee plans to take in response to the finding: The District acknowledges the finding and appreciates the opportunity to strengthen our documentation practices related to suspension and debarment verification. We would like to clarify that the District did perform suspension and debarment checks through SAM.gov for the vendors in question on an annual basis. While these procedures were consistently completed, the District did not retain independent documentation of those checks. The District relied on SAM.gov as the authoritative federal system of record, including its historical tracking and notification features, rather than maintaining locally stored or printed copies. At the time, staff were not aware that compliance requirements required retention of documentation evidencing these checks. As a result, this finding reflects a documentation deficiency rather than the absence of the control itself. As confirmed during the audit, all vendors tested were in good standing and not suspended or debarred. Therefore, the District was not at risk of contracting with an ineligible vendor, and no questioned costs were identified.

Person responsible for the corrective action: Jim Larson-Shidler, Interim Superintendent/CFO and Cindy Szuminski, Finance Manager Corrective action planned: Actions taken to avoid future late claims include: • The district has added another authorized Level 3 person who can approve meal reimbursement requests in July 2025. This provides the district a backup approver if one is not available. • A recurring monthly task reminding authorized Level 3 approvers to certify the SNP claim has been set up in our Outlook calendars. Anticipated completion date: July 16, 2025

FINDING 2025-004 – FINANCIAL REPORTING-DEPARTMENT OF AGRICULTURE-NATIONAL SCHOOL LUNCH PROGRAM - CFDA 10.555-SCHOOL BREAKFAST PROGRAM - CFDA 10.553-CONDITION: The School District did not make the necessary monthly adjustments to the Cafeteria Fund general ledger to properly reconcile all of the balance sheet, revenue, and expense accounts to the underlying supporting documentation on hand at the School District. Accordingly, the financial position and results of operations for the Cafeteria Fund were stated incorrectly during the 2024-2025 fiscal year. This is a repeat finding (2024-003) from the previous fiscal year.CRITERIA: Prudent internal control over accounting for federal program funds requires non-federal organizations such as the School District to maintain financial records which account for federal funds in such a manner as to be able to properly track the receipt and use of federal funds as stated in Section 2 CFR Part 200 of the Uniform Guidance.RECOMMENDATION: I am recommending that the management of the School District establish written procedures for all accounting functions, but most notably for the function of making the necessary adjustments to the School District’s Cafeteria Fund general ledger in order to properly present the financial position and results of operations of this Fund over the course of the fiscal year. Consideration should be given to either performing this process in-house based on available manpower or contracted to a third-party accounting Firm quarterly or annually independent of the audit process. Management needs to ensure the performance of these procedures monthly in order to ensure its compliance with Section 2 CFR Part 200 of the Uniform Guidance.MANAGEMENT’S CORRECTIVE ACTION PLAN: District management is reviewing its current system of processing the transactions for the Cafeteria Fund to ensure that all necessary adjustments are made on a monthly basis to the balance sheet, revenue, and expense accounts in order for them to properly reflect the financial position and results of operations of this Fund during the course of the fiscal year. The timeframe for completion of this review will occur during the last four months of the 2025-2026 fiscal year to enable the School District to comply with the recordkeeping requirements for federal funds as specified in 2 CFR Part 200 of the Uniform Guidance.

Finding Number: 2025-004 It is recommended that that district review the design of its internal control over compliance to ensure the documentation requirements are incorporated into the control design. Response: To enhance internal controls to ensure the segregation of duties, the Assistant Director of Food Services will be responsible for the initial preparation and completion of all the claims. Subsequently, a secondary review and approvable will be preformed by either the Director or the Chief School Business Official (CSBO) prior to submission.

The District will strengthen its internal control system to ensure that each entry within the Nutrition Services data management system meets required program criteria and is fully supported by appropriate documentation. A more robust process of review and verification will be implemented to safeguard the integrity of originating data and prevent compromise. System access controls will also be reinforced to ensure that granted access is appropriate and used in accordance with established protocols. Ensuring the accuracy of meal data will support accurate revenue reporting and, in turn, reliable financial reporting. Moreover, the District will continue to foster a culture of integrity in which all allegations of fraud are taken seriously and addressed promptly. The District will also enhance the visibility and accessibility of its WeTip reporting system to ensure employees, students, and community members can report concerns.

The School will prepare and submit a plan to the state agency to address excess net cash resources in the nonprofit food service account. Management will implement procedures to monitor net cash resources on a periodic basis, including timely preparation and review of the food service program’s statement of financial performance, to ensure compliance with program requirements and timely completion of any required follow-up actions.

The District plans to design and implement a formal month-end reconciliation and claim certification process that includes: matching food service vendor meal counts to internal District records, dual review and approval, timely corrections, training and cross-training, and monitoring.

Planned Corrective Action: To address the audit findings related to meal applications within the Child Nutrition Department, the Child Nutrition Director has taken immediate and corrective action to strengthen our processes and ensure full compliance with program requirements. The director attended formal verification training and successfully completed the accompanying quiz to confirm her understanding of proper procedures. Additionally, the director developed a meal application checklist to ensure that all required information is accurately reviewed and documented before approval. To improve timeliness and accountability, the director has implemented the use of a date-received stamp on all applications so they can be processed within required timelines. These steps will help ensure greater accuracy, consistency, and compliance moving forward. The administration office has also stepped in to double check all applications as the Child Nutrition Director completes them. Each application will be reviewed again in the central office to help prevent incomplete or inaccurate paperwork.

Finding 2025-11 Name of Contact Person: Dena Howell, Finance Officer Corrective Action Plan: Management intends to implement controls to ensure the Child Nutrition program is not charged indirect costs in excess of the allowable limit. Proposed Completion Date: As soon as possible.

Recommendation: We recommend the District establish a procedure for timely review and approval of claims prior to their submission for reimbursement by someone who is knowledgeable of the grant requirements. Additionally, we recommend the district designate an individual to review eligibility and verification determinations for accuracy and proper input into software. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: The Food Service Director will review eligibility and verification determinations for accuracy and proper input into the software. The District will continue to improve on reviewing and approval of claims. Name of the contact person responsible for correction action: Jessica Holtz Planned completion date for corrective action: June 30, 2026

Management's Response: The School District recognizes that the limited number of staff adds to the risk associated with the daily operations. To mitigate this risk, the Business Manager has to take an active role in the day-to-day operations of the Business Unit. She actively reviews all reconciliations and receipts to ensure they are posted to the accounting system properly. In addition, she approves all check disbursements and is reviewing the general ledger on a consistent basis.

1. Prior to final submission of the monthly claim to ISBE, staff will: o Print off each page of the ISBE claim entry. o Compare the printed claim data to the original backup documentation (meal counts, reimbursement worksheets, etc.). o Verify that all numbers align with the supporting records. 2. Any discrepancies found during this review will be corrected in the ISBE system before final submission.

The District will review their processes and procedures for reimbursement claims. In addition, there will be a manager level review of claims for reasonableness.

FINDING 2025-002 Finding Subject: Contact Person Responsible for Corrective Action: Tracey Haas, Business Manager Contact Phone Number and Email Address: 219-873-2000 x 8346 thaas@mcas.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We will implement a system of internal controls to ensure that the Form 9 and all underlying expenditures are properly documented. Anticipated Completion Date: We anticipate that this correction will be in place by July 2027