Corrective Action Plans

Management Plans to develop proper written policies and procedures over the elibility process that ensures indivdiuals are eligible and proper documentation is maintained

Finding Type: Non Compliance 10.553 and 10.555. Name of Contact Person: Dr. Judy Kaegi, Superintendent. Recommendation: We recommend that all food solicitations include the proper language to ensure that food products comply with the Buy American provision. Corrective Action: The District will ensure this language is included in all food solicitations going forward. Proposed Completion Date: Immediately.

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF AGRICULTURE – PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION – CHILD NUTRITION CLUSTER (ALN 10.555 AND 10.553) 2025-001 Internal Control Over Compliance With Federal Suspension and Debarment Requirements Finding Summary 2 CFR § 180 and 2 CFR § 200.318-327 requires Independent School District No. 719, Prior Lake-Savage Area Schools (the District) to establish and maintain effective internal control over compliance with requirements applicable to federal program expenditures, including suspension and debarment requirements applicable to the child nutrition cluster federal programs. During our audit, we noted the District did not have sufficient controls in place within its child nutrition cluster federal programs to ensure compliance with federal requirements related to assuring that the District was not contracting for goods or services with parties that are suspended or debarred, or whose principals are suspended or debarred from participating in contracts involving the expenditures of federal program funds. Corrective Action Plan Actions Planned – The District will review its policies and procedures relating to suspension and debarment for its federal programs to ensure compliance with the Uniform Guidance in the future. The review of procedures will also include steps to assure that district personnel are following the requirements of the Uniform Guidance related to suspension and debarment, including maintaining appropriate documentation. Official Responsible – The District’s Executive Director of Business Services, Lisa Rider. Planned Completion Date – June 30, 2026. Disagreement With or Explanation of Finding – The District agrees with this finding. Plan to Monitor – The District’s Executive Director of Business Services, Lisa Rider, will assure appropriate internal controls and procedures are in place to ensure compliance with suspension and debarment requirements.

Department: Health and Human Services Title: Internal control over Summer EBT eligibility needs improvement Questioned Costs: Known; $1,680 Likely: Undeterminable Status: Corrective action complete Corrective Action: Documentation and Records Retention: The Department replaced manual notification with automation through the statewide database. Database generated letters are both retained appropriately and easily retrievable for individual clients. Inaccurate certifications through database errors: Database cleanup and streamline certification logic updates were necessary to resolve inaccurate certifications. This process was completed prior to issuance for summer of 2025. Completion Date: May 1, 2025 Agency Contact: Evan Denno, Program Manager – SNAP, DHHS, 207-446-3201

Department: Education Title: Internal control over CNC subrecipient audit monitoring needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: Fiscal Review and Compliance Consultant: The Policy and Procedure manual will be updated to include regular monthly notifications in a system (such as Microsoft Outlook) to update the audit tracking spreadsheet for accuracy. Regionalization and Compliance Coordinator: The Policy and Procedure manual will be updated to add a step to set up regular monthly notifications in a system (such as Microsoft Outlook) for the supervisor to review the audit tracking spreadsheet for accuracy and completion. Completion Date: April 30, 2026 Agency Contact: Nicole Denis, Director of Finance, DOE, 207-530-2161

Department: Education Title: Internal control over CNC donated food inventory needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Department will continue with monthly inventory check-ins with the vendor that were instituted beginning in SY25. This check-in reviews all items in the warehouse. If the monthly check-in variance is above 2% then the items will be manually counted at the warehouse. The Department submitted a ticket for inventory errors, and it is monitored regularly. Completion Date: June 30, 2025, October 1, 2026, and December 3, 2026, respectively Agency Contact: Jane McLucas, Director of Child Nutrition, DOE, 207-624-6880

Department: Education Title: Internal control over CNC special reporting needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Department has reported the previously unreported items through a batch upload process. The Department will review batch uploads for accuracy by the Director of Finance prior to submission, as was done under the previous reporting system. Completion Date: August 31, 2025, and March 4, 2026, respectively Agency Contact: Nicole Denis, Director of Finance, DOE, 207-530-2161

Department: Education Title: Internal control over CNC subrecipient monitoring procedures needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Department will review and monitor the tracking spreadsheet monthly. The Department will hold monthly meetings to ensure CNP web questions and tools are completed, and documents are saved in the appropriate location. The Department will conduct training with NSLP reviewers on expectations for saving documentation Conduct training with NSLP reviewers on how to answer SFSP procurement questions for schools. The Department will update the Special Provision 2 base year review and validation procedure to include where to save documents and show the completion in CNP web. The Special Provision 2 base year reviews will be included in Step 2, starting SFY 2027. Completion Date: May 1, 2026 (first to third items), June 15, 2026 (fourth item), June 30, 2026 (fifth item), and October 30, 2026 (sixth item) Agency Contact: Jane McLucas, Director of Child Nutrition, DOE, 207-624-6880

Department: Education Title: Internal control over CNC claim reimbursements needs improvement Questioned Costs: Known: ALN 10.559 $61,336 ALN 10.582 $12,215 Likely: ALN 10.559 undeterminable ALN 10.582 undeterminable Status: Corrective action in progress Corrective Action: The Department will create a business requirements document for the SFSP site sheet and claims camp/closed enrolled eligibility edit checks. The non-congregate application now requires sponsors’ to have a written procedure to address site proximity, this is captured in an offline form in the checklist document. The Department submitted a ticket to update the FNS report so it will collect the data needed. For the FFVP, a tracking procedure is in place for SFY 2026 to stay within the $50-75/student rate. A spreadsheet is being used to track this information and has been implemented. Completion Date: March 4, 2026 (first item), June 30, 2025 (second and fourth items), and March 19, 2025 (third item) Agency Contact: Jane McLucas, Director of Child Nutrition, DOE, 207-624-6880

Department: Education Title: Internal control over CNC eligibility needs improvement Questioned Costs: Known: ALN 10.555 $73,683 ALN 10.559 $226,773 Likely: ALN 10.555 undeterminable ALN 10.559 undeterminable Status: Corrective action in progress Corrective Action: The Department will create a business requirements document for the SFSP site sheet and claims camp/closed enrolled eligibility edit checks. The Department will create a user guide to approve the site info sheet and apps to address oversite errors with the approval process. A financial eligibility edit check in the software will be implemented for program year 2026. A policy statement for non-congregate was a required document with an edit check in program year 2025. Completion Date: March 2, 2026, April 30, 2026, April 15, 2026, and May 1, 2025, respectively Agency Contact: Jane McLucas, Director of Child Nutrition, DOE, 207-624-6880

The District will strengthen controls to ensure all service contracts, including those charged to federal programs, are approved by the Board of Education and entered into the official minutes prior to execution and payment, in accordance with 2 C.F.R. § 200.318(a), state law, and District policy. Effective immediately, all service contracts will be submitted for Board approval before services begin. No contract will be executed and no purchase order will be issued without documented Board approval. Accounts payale will verify Board approval prior to processing payment. Procurement personnel and Federal program staff will receive training on Uniform Guidance procurement requirements, including suspension and debarment procedures. The Business Manager will perform reviews on Federal program expenditures to ensure ongoing compliance. The District believes these measures will correct the defiency and prevent recurrence.

Corrective Action Plan: The Department is a partnering agency for this program and does not manage the disbursement of funds. However, as a partnering agency for the program, the Department will continue updating its internal controls over the Summer Electronic Benefits Transfer (EBT) program’s eligibility determinations to ensure only eligible students are receiving benefits. These procedures will include regular communication to school districts, expanded data fields, school submission of a single combined enrollment and benefits file, and additional verification of the accuracy and completeness of the student data submitted by the districts to ensure only eligible students are approved to receive benefits. Since the questioned costs were isolated to calendar year 2024, and the Department has taken steps to correct the issue, this issue should not reoccur. The Department will work with Job and Family Services (JFS) to resolve the identified questioned costs. If needed, this will include evaluating the projected questionable costs to determine the actual amount that may have been disbursed to ineligible students and assisting JFS efforts to address those disbursements. Anticipated Completion Date for Corrective Action: May 2026 Contact Person Responsible for Corrective Action: Name: Corey Fronk Title: Administrator of Audits and Risk Management Address: 25 S. Front Street, 7th Floor; Columbus, OH 43215 Phone Number: (614) 644-7812 E-Mail Address: Corey.Fronk@education.ohio.gov

Corrective Action Plan: The Department has designated and implemented additional internal controls over Transparency Act reporting to ensure that the Child Nutrition Cluster expenditures are timely and accurately entered into the SAM.gov website. These procedures include several edit checks of the data before it is uploaded as well as a reconciliation of the reported data to ensure compiance with federal regulations. Anticipated Completion Date for Corrective Action: Completed December 2025 Contact Person Responsible for Corrective Action: Name: Corey Fronk Title: Administrator of Audits and Risk Management Address: 25 S. Front Street, 7th Floor; Columbus, OH 43215 Phone Number: (614) 644-7812 E-Mail Address: Corey.Fronk@education.ohio.gov

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF AGRICULTURE, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, CHILD NUTRITION CLUSTER (ALN 10.553, 10.555, AND 10.556) 2025-003 Internal Control Over Compliance With Federal Suspension and Debarment Requirements Finding Summary 2 CFR § 180 and 2 CFR § 200.318-327 requires the District to establish and maintain effective internal control over compliance with requirements applicable to federal program expenditures, including suspension and debarment requirements applicable to the child nutrition cluster federal programs. During our audit, we noted the District did not have sufficient controls in place within its child nutrition cluster federal programs to ensure compliance with federal requirements related to assuring that the District was not contracting for goods or services with parties that are suspended or debarred, or whose principals are suspended or debarred from participating in contracts involving the expenditures of federal program funds. Corrective Action Plan Actions Planned – The District will review its policies and procedures relating to suspension and debarment for its federal programs to ensure compliance with the Uniform Guidance in the future, including maintaining appropriate documentation. Official Responsible – Dawn Duevel, Business Services Director. Planned Completion Date – June 30, 2026. Disagreement With or Explanation of Finding – The District agrees with this finding. Plan to Monitor – Dawn Duevel, Business Services Director, will assure appropriate internal controls and procedures are in place to ensure compliance with suspension and debarment requirements.

Reference Number: 2025-004 No secondary review of meal claim reimbursements prior to submission Corrective Action Plan: The District will implement procedures that incorporate a second review of meal reimbursement claims before the request is submitted for reimbursement during the monthly processing. Contact Person: Cristina Campbell Implementation Time Frame: August 31, 2026

Finding 2025-400: Child Nutrition Cluster—Federal Funding Accountability and Transparency Act Reporting: Planned Corrective Action: The Department of Public Instruction (DPI) will complete and submit reports for subaward information in the FFATA Subaward Reporting System (FSRS) for the Child Nutrition Cluster (CNC) beginning in June 2025. Beginning with June 2025 awards reporting has been completed by the applicable due date (June 2025 awards, reported by July 31, 2025, etc) The internal processes established to ensure proper reporting of subaward has been updated to include payments made for Child Nutrition Cluster grants. Upon completion of the required reporting, a summary of all Child Nutrition Cluster awards is submitted to the Department of Administration, providing the FAIN, Amount, and Date Reported. Anticipated Completion Date: July 2025. Person responsible for corrective action: Michael Brendel, Section Leader Bureau of School Financial Services Division for Libraries & Technology (working title: Division of School & Library Operations) Department of Public Instruction michael.brendel@dpi.wi.gov

Name of Contact Person: Jonathan Green, Superintendent. Recommendation: We recommend the District expand their internal controls to require a responsible official to review the daily meal count reports for accuracy prior to submission of the reports to the Illinois State Board of Education. Corrective Action: Daily meal counts will be reviewed by administration on a monthly basis. Proposed Completion Date: Immediately.

Name of Contact Person: Jonathan Green, Superintendent. Recommendation: We recommend that all food solicitation include the proper language to ensure that food products comply with the Buy American Provision. Corrective Action: We will ensure this language is included in all food solicitations going forward. Proposed Completion Date: Fiscal Year 2026.

FINDING 2025-005 Finding Subject: Child Nutrition Cluster - Reporting Audit Findings: Material Weakness, Other Matters Contact Person Responsible for Corrective Action: Lela Simmons, CFO Contact Phone Number and Email Address: 219 391 4100 Ex 12365: lesimmons@ecps.org Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: The Food Service director responsibilities is to overseeing all function of the Food Management Company. Food Service Director will be required to draft internal controls and detail instruction for the school corporation to ensure all documentation procedures match the FSMC invoice. The school corporation will upgrade all POS software throughout the district. Students will be required to scan Student IDs to account for all meals served. Counts will be check weekly to ensure Federal report is accurate. Anticipated Completion Date: We anticipate having the above corrective action plan in place by October 31, 2026

FINDING 2025-003 Finding Subject: Child Nutrition Cluster - Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Special Tests and Provisions - Non-Profit School Food Service Accounts Audit Findings: Material Weakness Contact Person Responsible for Corrective Action: Lela Simmons, CFO Contact Phone Number and Email Address: 219 391 4100 Ex 12365: lesimmons@ecps.org Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: The Food Service director responsibilities are to oversee all functions of the Food Management Company. Food Service Director will be required to draft internal controls and detail instruction for the school corporation to ensure all documentation procedures match the FSMC invoice. The school corporation will not pay any unallowable cost by state regulation and rules. All state reporting documents and invoice will continue to be reviewed and signed off by the district CFO. A copy of all documents will be held in the food director office Anticipated Completion Date: We anticipate having the above corrective action plan in place by October 31, 2026

Finding Number: 2025‐001 Program Name/Assistance Listing Title: Child Nutrition Cluster Assistance Listing Numbers: 10.553, 10.555, 10.559 Contact Person: Business Manager, Food Service Director, and Business Office Staff Anticipated Completion Date: June 30, 2026 Planned Corrective Action: The following corrections will be implemented. 1. Review and update procedures for calculating indirect costs in accordance with USDA Memo SP 60‐2016 and 2 CFR Part 200. 2. Ensure use of the ADE‐approved unrestricted indirect cost rate annually. 3. Implement a standardized calculation worksheet to document allowable indirect cost limits. 4. Require review and approval of indirect cost calculations by the Business Manager prior to posting. 5. Provide training to business office staff on federal cost principles and Child Nutrition requirements. 6. Perform periodic internal reviews to ensure compliance.

FINDING 2025-004 Finding Subject: Child Nutrition Cluster – Internal Controls - Procurement and Suspension and Debarment Summary of Finding: The Rush County SFA follows procurement standards in accordance with 2 CFR Part 200. All purchases are conducted using the appropriate procurement method based on dollar thresholds. For contracts exceeding $25,000, the Rush County SFA verifies vendors are not suspended or debarred through the System for Award Management (SAM) and retains documentation in the procurement file. Written procedures include conflict of interest standards and documentation requirements. Contact Person Responsible for Corrective Action: Julie Cramer Contact Phone Number and Email Address: (765) 932-4186, cramerj@rushville.k12.in.us Views of Responsible Officials: Option 1: “We concur with the finding.” Description of Corrective Action Plan: The Rush County SFA maintains written procurement procedures that include verification of suspension and debarment status in accordance with 2 CFR 200.214. These procedures apply to all federally funded child nutrition purchases, including food service equipment. Prior to awarding any contract or purchase order exceeding the $25,000 threshold for Suspension and Debarment requirements, the Rush County Schools Assistant Superintendent and or Superintendent along with the Food Service Director will verify in SAM the vendor’s status as to whether the entity is suspended or debarred from receiving federal grant funds. To ensure proper segregation of duties the Food Service Director conducts the SAM verification and maintains documentation. The Assistant Superintendent and or Superintendent will review and give approval for the purchase prior to final award. The dual review process ensures compliance and oversight with the Suspension and Debarment requirements. Anticipated Completion Date: March 31, 2026

FINDING 2025-003 Finding Subject: Child Nutrition Cluster – Internal Controls - Eligibility Summary of Finding: There was no documented evidence of the Director of Food Service reviewing the eligibility determinations for free and reduced lunches that were made by the Cafeteria Secretary during the audit period. Contact Person Responsible for Corrective Action: Julie Cramer Contact Phone Number and Email Address: 765-932-4186, cramerj@rushville.k12.in.us Views of Responsible Officials: Option 1: “We concur with the finding.” Description of Corrective Action Plan: The Middle School Cafeteria Secretary will contact parents regarding verifications of their free/reduced lunch application information. This information will then be reviewed by the Director of Food Service, to determine whether the information is accurate. Parents are always notified on any changes to the lunch status for students. Both the Cafeteria Secretary and the Director of Food Service will sign off on each application to document that reviews were performed. Anticipated Completion Date: March 3, 2026

FINDING 2025-004 Finding Subject: Child Nutrition Cluster- Suspension and Debarment Contact Person Responsible for Corrective Action: Jeff Layden Contact Phone Number and Email Address: 765.457.8101, jeff.layden@nwsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Jeff Layden, Director of Operations, oversees our food service department. He will work with our food service vendor to ensure EPLS are checked before awarding any contract for goods or services. Anticipated Completion Date: Immediate. INDIANA STATE

FINDING 2025-003 Finding Subject: Child Nutrition Cluster- Internal Controls Contact Person Responsible for Corrective Action: Camden Parkhurst Contact Phone Number and Email Address: 765.457.8101, camden.parkhurst@nwsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Activities Allowed or Unallowed, Allowable Cost/Cost Principals E-Funds has been automatically debited from our account since its inception. The auto debt was falling at a time each month that caused us to miss adding to our Allowance of Claims. We will correct the time that this is added to our statements so that it will make the Allowance of Claims for each month. Eligibility This was a one time issue when we were switching our software to Meal Magic. This was only related to one direct certification cluster to start the 23-24 school year. We have multiple people from our food service department prepare and sign off on direct certifications on a monthly basis to ensure we are accurate and complaint. Anticipated Completion Date: Immediate. INDIANA STATE