Corrective Action Plans

On behalf of the finding 24-03 the following changes will be implemented: The Food Program Directors will ensure that the separation of Food Purchases will be reinforced. 1) Establish a strict policy mandating that all program food purchases for the USDA Nutrition Cluster (Breakfast and Lunch programs/ CACFP) be processed separately for each program. Orders for Breakfast, Lunch and Supper will be on separate invoices. 2) All food program invoices will be evaluated by Food Program Director to ensure the correct allocation by program and forwarded to bookkeeper to allow the proper program disbursement. 3) All program foods invoices will be paid separately using program bank accounts. The enforcement of the procedure of business credit card purchases will be in effect starting October 2025.

The District will train food service administrative staff regarding adequate internal controls involving monthly downloads of the Department of Social and Health Services DSHS direct certifications, including training at least 2 administrative staff members in order to ensure compliance in the absence of the primary staff member performing the necessary internal control. Should Supply Chain Assistance funds become available in the future, the District will retrain food service administrative staff regarding the tracking of qualifying food products to reconcile to the funds received, and complete that tracking prior to the end of the qualifying fiscal year.

Finding 2024-002 Recommendation: We recommend controls be strengthened to ensure all donations are supported with verification of count, weight, product identification, and other inspection of the product as evidenced through signature of the person(s) receiving inventory items. This could be made through a checklist attached to the bill of lading and used with entering the items into the inventory system that includes verification was properly made and items properly set up in inventory. Corrective Action: A majority of TEFAP orders arrive with a BOL that will have the USDA secondary 5000 PO number as well as a 4000 Customer sales number and many times a 2000 Solicitation number. These are requirements the USDA has with the vendors supplying the items. We report both the 5000 and 4000 numbers to GA DHS/SC Dept of Ag upon receipt of the goods. If either or both numbers are missing from the BOL, we note that in the receipt report sent to these agencies. These numbers, although unique to USDA product, are not the only designation we use for TEFAP loads. We can access the TEFAP Requisition Status Report that indicates items that we have ordered and the status such as approved and delivery period. By contract the vendors/delivery brokers are required to give us a 48-hour notice prior to delivery. Moving forward, we will attach the TEFAP report sent to the respective state agencies in the event that either the 4000 or 5000 number is not on the BOL to the required retention paperwork for audit purposes. Person Responsible for Corrective Action: Norman Stafford, VP of Operations Anticipated Completion Date for Corrective Action: 8/14/25

Finding 2024-003 Recommendation: We recommend original records relating to the requirements for distributed foods be retained for the required period. Corrective Action: Dates not matching shipping and receipt by agency can be attributed to two main reasons. A majority of the date discrepancies are deliveries that are made on weekends when the warehouse office is closed. Trucks are loaded out Friday afternoon and the required paperwork is generated and put in the truck for the next day. Occasionally on the date of delivery, agencies contact us as we are loading out and the paperwork has been generated informing us that due to some issue on their end, they cannot accept delivery and it is rescheduled. On these occasions, paperwork and product are set to the side until the next available day when the agency is capable of receiving the order. In the future, we will annotate on our copy of the documents if the delivery was on a Saturday or if the delivery date was moved at the request of t he agency. Person Responsible for Corrective Action: Norman Stafford, VP of Operations Anticipated Completion Date for Corrective Action: 8/14/25

The Board of Health WIC personnel will implement additional control practices for the review and approval for WIC eligibility for participants. In addition, WIC personnel will ensure all supporting documentation has been obtained in order to determine participant eligibility.

The District beginning in FY 2025 became part of the Community Eligibility Program allowing for all students to receive free lunch and breakfast. As such, the District is not using Pay Schools to determine eligibility.

FA 2024-001 Strengthen Controls over Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principle Procurement and Suspension and Debarment 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: 245GA324N1199 (Year: 2024), 235GA32N1099 (Year: 2023) Questioned Costs: $7,388 Description: A review of expenditures charged to the Child Nutrition Cluster revealed that the School District's internal control procedures were not operating appropriately to ensure that expenditures were reviewed and approved and that the School District's procurement and suspension and debarment procedures were followed. Corrective Action Plans: The following corrective actions will be implemented by the School District: 1. Implement Strengthened Pre-Approval and Documentation Procedures: a. All Child Nutrition purchases will require a completed purchase request form that clearly identifies the funding source, purpose, and allowability under federal guidelines. b. Documentation (invoices, quotes, purchase orders) must be attached and reviewed by the School Nutrition Director and CFO or designee before approval. 2. Enhance Segregation of Duties: a. The individual initiating a purchase or expenditure will not be the same person approving or reconciling it. b. Monthly expenditure reviews will be performed jointly by the Finance Department and School Nutrition leadership to ensure accuracy and compliance. 3. Establish an Internal Monitoring Checklist: a. The School Nutrition Department will implement a monthly internal monitoring checklist that includes documentation review, reconciliation of expenditures, and verification of procurement compliance. The CFO will meet with the Nutrition director monthly. 4. Update Written Polices and Procedures: a. The district's Financial Procedures Manual and the School Nutrition Operations Manual will be updated by December 2025 to reflect all new internal control steps and approval requirements specific to federal expenditures. Estimated Completion Date: June 30, 2026 Contact Person: Tiffany Crockett, Chief Financial Officer Telephone: 478-946-5521 Email: tiffany.crockett@wilkinson.k12.ga.us

Management concurs with the finding and will revise procedures to ensure detailed, timely recording of USDA Foods distributions. Staff will receive training on documentation requirements, and management will implement periodic compliance reviews. These corrective actions are expected to be completed by March 1, 2025.

Contact Person: Steven Dolak, Business Administrator. Recommendation: The District should revise procedures to ensure the data entered into the claim for reimbursement is reviewed for accuracy prior to the report being submitted. Evidence of the approval of submission should be documented in writing, such as with an initial, to demonstrate the review of the information has been performed. Action: The Business Administrator will prepare the reports for submission. Prior to submitting the report through the reimbursement system, a second individual will review the information entered. Upon satisfactory completion of the review, the second individual will acknowledge review by initialing and dating the document(s). Date of Completion: This procedure will be implemented at the beginnign of the 2025-26 school year.

Reference # and title: 2024-005 Controls and Compliance over Reporting Federal program and specific federal award identification: AL Number Award Year FEDERAL GRANTER/ PASS THROUGH GRANTOR/PROGRAM NAME United States Department of Education; passed through Louisiana Department of Education Title I 84.010A 2024 COVID-19 Education Stabilization Funds: Education Stabilization (ESSER II) 84.425D 2021 Education Stabilization (ESSER III) 84.425U 2021 United States Department of Agriculture; passed through Louisiana Department of Education Child Nutrition Cluster: School Breakfast Program 10.553 2024 National School Lunch Program 10.555 2024 Criteria or specific requirement: Good internal controls require that all requests for reimbursement submitted to the Louisiana Department of Education (LDOE) are adequately reviewed and approved either before submission or after submission, but in a timely manner, to ensure amounts reported are complete and accurate. Condition found: In testing a sample of a requests for reimbursements for the Child Nutrition Program and periodic expense reports for the Title I and ESSER programs the following was noted: Title I: Total expenditures per the general ledger did not agree to the amounts reported in the final periodic expense report, which resulted in the School Board over requesting $71,386. It was also noted there is no review and approval process by a second person over the periodic expense report submissions. Child Nutrition: Although there were no exceptions noted in the information submitted to LDOE, it was noted there is no review and approval process by a second person over the claims for reimbursement. Education Stabilization: Total expenditures per the general ledger did not agree to the amounts reported in the fiscal year end’s periodic expense report submission. It was also noted that the School Board had over requested $118,103 in the current fiscal year. There is no review and approval process by a second person over the periodic expense report submissions. In testing the special reporting for the ESSER program, it was noted that the School Board had not maintained the supporting documentation for this report and therefore could not be adequately tested. Corrective action planned: The School Board will correct this immediately. We were aware of the Title I and ESSER issues and had been in contact with LDOE to correct them. We were unaware of Child Nutrition needing someone to review and approve those claims; however, we will implement that requirement moving forward.

Reference # and title: 2024-004 Controls and Compliance over Disbursements Federal program and specific federal award identification: AL Number Award Year FEDERAL GRANTER/ PASS THROUGH GRANTOR/PROGRAM NAME United States Department of Education; passed through Louisiana Department of Education Title I 84.010A 2024 COVID-19 Education Stabilization Funds: Education Stabilization (ESSER II) 84.425D 2021 Education Stabilization (ESSER III) 84.425U 2021 United States Department of Agriculture; passed through Louisiana Department of Education Child Nutrition Cluster: School Breakfast Program 10.553 2024 National School Lunch Program 10.555 2024 Criteria or specific requirement: Sound internal controls over federal program require that expenditures be made in accordance with the federal program budgets, properly documented and recorded. Additionally, 2 CFR section 200 requires nonpayroll expenditures over the micro purchase threshold be adequately vetted with a competitive process such as quotes or bids. Additionally, for an employee who works in part on a federal program whose administrative funds have not been consolidated or on activities funded from other revenue sources, the School Board must maintain time and effort distribution records in accordance with 2 CFR section 200.430(i)(1)(vii) that support the portion of time and effort dedicated to (a) the consolidated cost objective, and (b) each program or other cost objective supported by non-consolidated Federal funds or other revenue sources. Employee pay should be reviewed to ensure that payment amount is correct. Employee attendance should be documented on a consistent basis. Condition found: In testing expenditures over federal programs, the following exceptions were noted: Title I: In testing 19 payroll transactions for the Title I program, there were 4 exceptions noted where the time certifications were completed, but not in a timely manner. Child Nutrition: In testing 17 payroll transactions for the Child Nutrition program, the following exceptions were noted:  3 exceptions noted where the time certifications were completed, but not in a timely manner.  3 exceptions noted where the timesheet for the employee was not reviewed by a Supervisor.  5 exceptions noted where the employee was not paid in accordance with the salary schedule. This related to 3 employees in which the employees were underpaid. In testing 23 vendor disbursements, it was noted that travel reimbursements are paid annually and not on a timely basis. Education Stabilization: In testing 17 payroll transactions for the ESSER programs, the following exceptions were noted:  2 exceptions noted where the employee was not paid in accordance with the salary schedule. This related to 1 employee in which the employees were underpaid. In testing 23 vendor disbursements for the ESSER programs, the following exceptions were noted:  1 exception noted in which the purchase could not be traced to the approved budget.  9 exceptions noted in which the School Board could not provide any support reflecting quotes were obtained before the purchase was made. Corrective action planned: The School Board will correct this immediately. We will have time certifications done on a timely basis and all timesheets reviewed by a supervisor. Payroll will be checked that it is being paid by the corresponding salary table. Travel will be required to be submitted and paid monthly. Quotes will be acquired when needed.

District management will adopt sound accounting policies and establish and maintain internal controls that will initiat e, authorize, record , process and report transactions consistent with management ' s assertions embodied in the financial statements and that will safeguard District assets. The District will assess and implement corrective action(s) immediately by reviewing procedures and make changes by September 1, 2025.

Condition: Supporting documentation for the monthly food service meals provided did not align with the claims reported for reimbursement by free, reduced, and paid categories. Plan: The District will keep physical copies of reports and claims submitted. As students switched categories (free, reduced, and paid), the electronic system failed to keep that in account, leading to discrepancies. Anticipated Date of Completion: The District anticipates completion during the 2024-2025 fiscal year. Name of Contact Person: Nathan Knitt, Director of Business Services

Managements Response: Academy of Accelerated Learning, Inc. leadership will develop, along with new financial management a plan for improvement to be presented to the Board which includes a review of its internal control procedures over financial reporting to ensure controls are in place to designate the preparer and approver, to properly and timely record all accounts in accordance with generally accepted accounting principles. Academy of Accelerated Learning, Inc. will establish timelines and training for the expense approval process. Leadership and the new financial management will designate staff to align with a segregation of duties and hold staff accountable. Timeline and Responsible Position: By August 31, 2026. Board of Directors, Superintendent, and Chief Financial Officer.

Finding Synopsis: One of 40 students selected for testing received free or reduced meals without having an application on file. Action Steps: Management will establish and reinforce procedures to ensure all applications are retained (paper and digital copies). Contact Person: Kenya Austin Asst. Superintendent of Business/CSBO 847-568-7632 Anticipated Completion Date: 6/30/2025

FA 2024-001 Strengthen Controls over Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principle Procurement and Suspension and Debarment 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: 225GA324N1099 (Year: 2024), 245GA324N1199 (Year: 2024) Questioned Costs: $77,285 Prior Year Finding: FA 2023-001 Description: A review of expenditures charged to the Child Nutrition Cluster revealed that the School District's internal control procedures were not operating appropriately to ensure that expenditures were reviewed and approved and that the School District's procurement and suspension and debarment procedures were followed. Corrective Action Plans: Berrien will look at the current procedures for expenditures and make sure that every program is following the same protocols. We have a system in place to ensure that we can check suspension and debarment. Also, we have protocols in place to make sure all contracts are current. Estimated Completion Date: 9/30/2025 Contact Person: Jamie Taylor, Finance Director Telephone: 229-686-2081 Email: jamie.taylor@berrien.k12.ga.us

Finding: 2024-027 - DEED did not comply with Federal Funding Accountability and Transparency Act reporting requirements applicable to Child Nutrition Cluster (CNC) FY 24 subawards. Questioned Costs: None Assistance Listing Number: 10.553, 10.555, 10.559, 10.582 Assistance Listing Title: CNC Views of Responsible Officials (state whether your agency agrees or disagrees with the finding; if you disagree, briefly explain why): The department partially agrees with Finding 2024-0027. While it is accurate that no FFATA reporting was accomplished for the Child Nutrition Cluster in FY2024, the department disagrees with the specific dollar amount. The methodology used for determining the dollar amount is overly simplistic and does not take each award into account, as specified in 2CFR17O.220. The methodology also excludes awards to other State agencies when 2CFR17O.300 specifically includes State entities. Corrective Action (corrective action planned): The department will continue to work to improve its ability to report timely by attempting to streamline manual determination of amounts to be reported. Completion Date (list anticipated completion date): Completion date is unknown. The department is still in the process of training the newest Finance Officer who has primary responsibility for the reporting. Due to the complexity of the reporting requirements and the limitations of the State’s financial systems it is a very manual process to determine accurate amounts to report. This manual process takes more time than knowledgeable staff have available due to other higher priority responsibilities. The system used to report also changed in Spring of 2025. Department procedures need to be overhauled again to take into account the move to SAM.gov. Agency Contact (name of person responsible for corrective action): Monigue Siverly, Division Operations Manager, Division of Administrative Services

Finding: 2024-052 - DOH’s Division of Public Assistance (DPA) did not determine or distribute benefits to school children or children in child care in accordance with the process and timeframes in the federally approved state plan. The audit identified the following deficiencies in FY 24: • The children in child care beneficiaries were not identified as required by the school year 2020—2021 state plan. • The per child benefit amount paid to the 15,697 children in child care was understated by $6.21 and 125 children were included in both the student and the child care benefit eligibility lists. • Issuance records provided by DPA’s Electronic Benefits Transfer (EBT) contractor, Fidelity National Information Services (FIS), were $795,659 more than DPA reported issuances. Furthermore, the FIS report included $28,992 in duplicate summer 2021 benefit issuances to school children. • School year 2020—2021 student beneficiaries paid in FY 24 received benefits at least two years late and the children in child care beneficiaries were paid benefits at least 20 months late. Summer of 2021 beneficiaries paid in FY24 received benefits at least 20 months late. Questioned Costs: AL 10.542: Indeterminate Assistance Listing Number: 10.542 Assistance Listing Title: Pandemic Electronic Benefit Transfer Food Benefits (P-EBT) COVID-19 Views of Responsible Officials (state whether your agency agrees or disagrees with the finding; if you disagree, briefly explain why): The department partially agrees with the finding. The Division of Public Assistance disagrees with the finding regarding issuance timelines. The division communicated with FNS regarding manual benefit issuance for Alaska expressing timelines would be affected and FNS did not request an updated timeline. Communication with FNS regarding issuance remained consistent, with no indication to alter our issuance plan. Corrective Action (corrective action planned): Shall the department agree to administer this federal program in the future, the Commissioner will allocate the resources necessary to prevent the necessity to manually administer the federal program. Completion Date (list anticipated completion date): Not applicable. This federal program is complete. Agency Contact (name of person responsible for corrective action): Pam Halloran, Assistant Commissioner

Finding: 2024-026 — Department of Education and Early Development’s (DEED) child nutrition services management authorized Summer 2021 Pandemic Electronic Benefit Transfer Food Benefits (P-EBT) benefits for ineligible children. Questioned Costs: AL 10.542: $62,816 Assistance Listing Number: 10.542 Assistance Listing Title: P-EBT COVID- 19 Views of Responsible Officials (state whether your agency agrees or disagrees with the finding; if you disagree, briefly explain why): The department agrees with Finding 2024-026. Corrective Action (corrective action planned): As the program is complete no corrective action can be taken for the Summer P-EBT program. If a new Summer EBT program is implemented, the department would work to implement a combination of standard operating procedures and automated electronic data validation processes to prevent erroneous benefit issuance. The department did not have sufficient time or resources to establish such features when implementing Pandemic EBT due to the urgent nature of the program. Completion Date (list anticipated completion date): n/a Agency Contact (name of person responsible for corrective action): Gavin Northey, Child Nutrition Programs Manager

The Organization feels that it made a good faith attempt to correct the deficiencies noted by the State Agency. On November 8, 2024, the Organization received notification that the State agency proposed to terminate the Organization’s agreement to participate in CACFP. The Organization decided not to appeal the decision. Effective December 1, 2024, the Organization ended the CACFP program and notified the day care homes that they would need to find a new sponsor.

Management of the School agrees with the findings and will coordinate with the State of Florida, Department of Agriculture the repayment of the contractually non-reimbursable use of funds.

2024-001 - Material Weakness and Noncompliance, Completeness and Accuracy of Schedule of Expenditures of Federal and State Awards (Repeat Finding 2023-001) Audit Finding: There were several adjustments to the basic financial statements, Schedule of Expenditure of Federal Awards (SEFA) and Schedule of Expenditures of State Awards (SESA) as originally provided by the Town. The SEFA and SESA balances are required to be reconciled to the basic financial statements prepared in accordance with generally accepted accounting principles in the United States (US GAAP). The Town has failed to adequately perform such reconciliation and as a result of procedures performed by RSM a number of adjustments to expenditures reported on the SEFA and SESA as well as to intergovernmental Revenues reported on the basic financial statements had to be performed. Corrective Action Taken: The Town Finance Department has placed an emphasis on educational meetings with the Board of Education within the area of receiving grants. These issues have resulted from the continual problem of employee turnover of personnel working within the areas of responsibility of grants accounting. All positions in the BOE Finance Department have now been filled, and the Director of Finance at the BOE has implemented monthly reconciliation procedures. From the Town side, the reconciliations between the GAAP financial statements and amounts reported on the SEFA and SESA will be overseen by the Town Comptroller. The Deputy Comptroller and BOE Director of Finance meet regularly to discuss updates and issues and will reconcile the June 30, 2025 reports in the first quarter of FY2026. Name and Phone # of Person Responsible for Implementation Mr. Peter Mynarski, Comptroller 203-622-2226

The Division will ensure evidence of review is maintained for the inventory worksheets. This was also reviewed during the NW Division’s Social Service conference in April 2025. Anticipated Completion Date: 10/1/25. Responsible Contact Person: Julie Luft, NW Social Services Director

The District will continue to reduce net cash resources in the Food Service Fund. Additionally, the District reduced the guaranteed profit in the 2024-2025 FSCM contract renewal.

To address the issue of meal counts not being properly taken and recorded at the point of service, SCO Family of Services is reinforcing internal controls in accordance with 7 CFR 210.8 to ensure the accuracy of meal counts prior to submitting monthly claims for reimbursement. Staff involved in meal service have received refresher training on proper point-of-service meal counting procedures, and supervisors will continue to conduct routine monitoring to verify compliance. These steps will help ensure that all meal counts are accurately recorded in real-time, supporting the integrity of reimbursement claims. To ensure accountability, the agency is currently in the process of recruting a full-time Food Service Director who will have oversight over the Child Nutrition Porgram and will be responsible for continued compliance, staff training, on-site reviews, and all documentation required by both state and federal regulations. While we will recruit to fill this poistion, an interim Food Service Director will be appointed. Our PQI department will continue to support and monitor activities as well. Proposed Implementation Date: Immediately