Corrective Action Plans

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.

CORRECTIVE ACTION PLAN Arizona Department of Education/U.S. Department of Education Sierra Vista Unified School District No. 68 respectfully submits the following corrective action plan for the year ended June 30, 2024. Audit period: July 1, 2023 – June 30, 2024 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FINANCIAL STATEMENT AUDIT 2024-003 REPORTING Program: Child Nutrition Cluster CFDA Number: 10.533, 10.555, 10.559 Federal Agency: U.S. Department of Agriculture Pass-Through Agency: Arizona Department of Education Grantor Number: ADE ED09-0001 Questioned Costs: $18.50 Type of Finding: Noncompliance, significant deficiency Compliance Requirement: L. Reporting Condition/Context: For two of 3 monthly submissions tested, meal counts did not agree between the District’s records and what was reported to ADE. There was a net of 3 meals over claimed by the District. Criteria: The District must follow Uniform Guidance and ensure that meal reimbursement claims are accurately reported and adequately supported. Action planned in response to finding: The District will establish a system of internal controls to ensure meal counts reported on ADE match with District records. Planned completion date for corrective action plan: For the period ending June 30, 2025. Name of the contact person responsible for corrective action: Janet Cline, Business Office Manager, Laurel McEwan, Business Manager.

For the purpose of future audits, we will utilize a coding system for the applications we receive (i.e., the first application we receive will be coded “1”). The auditors can request a random sample based on the coding system and we will redact information on the application to protect household and student information.

FINDING 2024-004 Finding Subject: Child Nutrition Cluster - Suspension and Debarment Contact Person Responsible for Corrective Action: Heather Bontrager, Director of School Nutrition and Sheryl Graves, Purchasing Specialist Contact Phone Number: 574-533-8631 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Suspension and Debarment Verification checks will be conducted annually at the start of the new program year, or upon execution of a new vendor contract expected to exceed $25,000. 1. Verification Steps: 􀁸 Vendor List Compilation: 􀁸 The Accounts Payable Specialist will generate a list of all vendors paid from Fund 0800 in the prior fiscal year. 􀁸 Identify vendors with aggregate disbursements of $25,000 or more. 􀁸 Include new vendors anticipated to exceed $25,000 in the upcoming year based on planned purchases or contracts. 2. SAM.gov Check: 􀁸 For each vendor identified, search their legal business name or DUNS/UEI number in the SAM.gov database. 􀁸 Verify that the vendor is listed as "Active" and not debarred or suspended. 3. Documentation: 􀁸 Print or save a PDF of the SAM.gov record for each verified vendor. 􀁸 The PDF notes the date of verification and name of the staff member who completed the check. 􀁸 Maintain documentation in a central procurement or compliance folder for audit purposes. 4. Annual Certification: 􀁸 The Purchasing Specialist and Director of Nutrition Services will jointly sign an Annual Vendor Verification Certification Form confirming that all applicable vendors have been checked and meet SAM.gov requirements. 􀁸 Submit the signed form to the Business Office and retain for audit documentation. Ongoing Monitoring: For any new vendors added mid-year with expected expenditures over $25,000 or contracts amended to exceed the $25,00 threshold, repeat the above verification process before any payment is made. Anticipated Completion Date: August 2025

FINDING 2024-003 Finding Subject: Child Nutrition Cluster – Internal Controls Contact Person Responsible for Corrective Action: Heather Bontrager, Director of Nutrition and Whitney Dixon, Treasurer Contact Phone Number: 574-533-8631 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Activities Allowed or Unallowed, Allowable Costs/Cost Principles This finding was limited to payroll claims and payroll vendor disbursements and did not involve accounts payable vendor disbursements. For payroll disbursements, once payroll is processed, a distribution report is sent to the Director of Nutrition to review all employees paid from the Federal Nutrition Program (Fund 0800). The Director communicates any necessary corrections to employee distributions, which are then adjusted by the payroll specialist, if needed. During the audit period, the school corporation experienced a vacancy in the payroll specialist position. As a result, the Treasurer processed payroll and the Deputy Treasurer conducted the reviews. However, the school corporation did not obtain signatures on the payroll reports during this time. The only signed documentation was the ACH report used for the bank upload. Going forward, the school will implement the use of digital signatures whenever possible to document payroll report reviews. For payroll vendor claims, vouchers are generated from the financial system and are signed by both the payroll specialist and the Chief Financial Officer. These signed vouchers are also included on the board docket. Although this process was in place during the audit period, the school corporation did not have a fully effective internal control system to ensure that all payroll reports were consistently signed following review by the Treasurer. Anticipated Completion Date: June 2025

District Treasurer (Denise Kennedy) will adopt sound accounting policies and establish and maintain internal control that will initiate, authorize, record, process, and report transactions consistent with management’s assertions embodied in the financial statements and that will safeguard District assets during the school year 2025.

FA 2024-001 Improve Control over Employee Compensation Compliance Requirement: Allowable Costs/Cost Principle 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 COVID-19-10.555 - National School Lunch Program Federal Award Number: 245GA324N1199 (Year: 2024), 225GA324N1099 (Year: 2024) Questioned Costs: $102,234 Prior Year Finding: 2023-004 Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over the employee compensation process as it relates to the Child Nutrition Cluster. Corrective Action Plans: The District is developing correction action to strengthen controls, policies, and procedures and ensure adherence through improved monitoring. Estimated Completion Date: June 30, 2026 Contact Person: Connie Walker, School Nutrition Executive Director Telephone: 678-676-1780 Email: Connie_R_Walker@dekalbschoolsga.org

The District has implemented controls to ensure that USDA donated foods is tracked and credited on future FSMC invoices. The District made journal entries from Operating to cover the $244,203 that had been originally approved verbally by CNU. We then found out this was not an approved expense from Child Nutrition and corrected the expense.

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: Moriah Banasick, CPA Executive Director of Finance & Budget 5150 220th Ave SE Issaquah, WA 98029 (425) 837-7139 Corrective action the auditee plans to take in response to the finding: • Staff training: The District is providing targeted training on federal procurement requirements, internal controls, and accountability practices to all federal program leads and purchasing staff. This includes comprehensive orientation for new purchasing leadership to support continuity and compliance. The recent incident is being used as a case study to strengthen shared understanding and reinforce best practices across departments. • New protocols: The District is developing updated emergency procurement protocols that include required documentation, vendor outreach logs, and pre-approval processes to ensure adherence to federal and District requirements. Anticipated date to complete the corrective action: Immediate

Finding ref number: 2024-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with federal eligibility and paid lunch equity requirements. Name, address, and telephone of Fife School District contact person: Dany Wanner, Business Services Director 1720 Oak St, Milton, WA 98354 (253) 517-1000 ext 29121 Corrective action the auditee plans to take in response to the finding: The Fife School District implemented the following to Ensure Adequate Internal Controls for Compliance with Federal Eligibility: The Business Services team and Nutrition Services staff have conducted a thorough review of the process of monthly paid lunch equity and modified its procedures including developing a checklist for the process to ensure that it is completed in a timely manner, signed/dated and saved both electronically and in hard copy on a shared district server folder. The Fife School District implemented the following to Ensure Adequate Internal Controls for the annual completion of the Paid Lunch Equity Tool. The Business Services team and Nutrition Services staff have conducted a thorough review of the process of completing both the PLE tool and GL 828 reconciliation and modified its procedures to ensure that it is completed, signed and saved both electronically and in hard copy on a shared district server folder. Further, the Business Services team and Nutrition Services staff have developed a checklist for the completion of the tool and the checking of the box that indicates that we will be opting not to increase meal prices, but instead to demonstrate using the GL 828 Reconciliation (signed and dated) that we have sufficient fund balance to offset the paid lunches and not utilize Federal funds, including calendar reminders and a shared Google Drive to hold all related documents and procedures. Anticipated date to complete the corrective action: 5/16/2025

Finding ref number: 2024-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with federal eligibility and paid lunch equity requirements. Name, address, and telephone of District contact person: Marci Bannan, Director of Business Services 121 Whitesell St NE Orting, WA 98360 Corrective action the auditee plans to take in response to the finding: Eligibility: The District will document the internal controls that are in place for the monthly direct certification downloads and will print the certification download along with saving it electronically so that the files are easy to provide for future audits. Paid Lunch Equity: The District will document the internal controls that are in place for the completion of the PLE tool and ensure that the form is completed appropriately to show the continued use of nonfederal funds that are used yearly to fund the food service account fully. The District will also make sure to ‘print’ the GL 828 tab of the Fund Balance Reporting tool that is done yearly no later than November and sign it immediately after completion of the year end process to provide for the proof that the district has and continues to contribute sufficient nonfederal funds to the food service account. Anticipated date to complete the corrective action: July 31, 2025

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Winlock School District No. 232 September 1, 2023 through August 31, 2024 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: 2024-001 Finding caption: The District did not have adequate internal controls for ensuring accurate reporting of its financial statements. Name, address, and telephone of District contact person: Michelle Jeffries, Superintendent PO BOX 128 Winlock WA 98596 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 District will strengthen internal controls over financial reporting to ensure financial statements are accurate. Specifically, the District will: • Complete a more thorough secondary review of all financial statements and SEFA for reasonableness, completeness and accuracy before submitting them for audit • Maintain supporting documentation the District uses to prepare the financial statements • Ensure funds the District reports on the financial statements agree with underlying accounting records Anticipated date to complete the corrective action: July 1, 2025 Finding ref number: 2024-002 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: Michelle Jeffries, Superintendent PO BOX 128 Winlock WA 98596 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 District will strengthen internal controls to verify all contractors it pays $25,000 or more, all or in part with federal funds, are not suspended or debarred from participating in federal programs, and maintains documentation demonstrating this verification. Anticipated date to complete the corrective action: July 1, 2025

Finding ref number: 2024-001 Finding caption: The District did not have adequate internal controls and did not comply with federal procurement requirements. Name, address, and telephone of District contact person: Audrey Slabbert, Director of Business and Finance. PO Box 778 Long Beach, WA 98631 (360) 642-1206 Corrective action the auditee plans to take in response to the finding: The District will designate the Food Service Director to provide the Finance Director with all Food Service contracts, and The Finance Director will check each applicable vendor’s status on the System for Award Management (SAM) at https://sam.gov prior to contract execution. The Finance Director will maintain a printout of the SAM.gov verification results in procurement records. The Finance Director will provide the Superintendent with a copy of the relevant contracts for her approval. Anticipated date to complete the corrective action: June 2, 2025

Global Community Charter School recognizes the management deficiencies cited by MMB+CO as finding 2024-001 in the FY2024 Audited Financial Statements. The following procedures have been implemented to mitigate and/or eliminate further process deficiencies. ● Beginning in August 2024, all participating operations staff were retrained and given clarity on the importance of accurate and timely count management. ● At the elementary and middle school, one operations person has been designated as responsible for the monthly count. This individual coordinates all personnel involved in the process and is further responsible for ensuring coverage and accuracy when personnel are shifted around or absent. ● This designated individual also meets with the food preparer weekly to check the provider’s meal count against the school's. ● The designated individual also annotates the weekly/monthly count on a digital worksheet that compares the food providers' count against the schools. ● The Director of Finance audits the worksheet monthly for “reasonability”, accuracy, and consistency. ● Post-audit, the CFO does a final review. If anything anomalous or inconsistent is found, the team will meet to confirm if the changes reflect actual student utilization. If no changes are required, the CFO takes the monthly data and uploads it to the template provided by the NSLP consultant who submits the voucher. In addition to the process outlined above, an ongoing review of student utilization is being conducted to reduce the waste and cost to the school created when too many meals are produced and students do not consume them. This process should allow meals produced to mirror consumption going forward. We implemented this process in mid-August and expect positive realignment and consistency from November 2024 onward.

The Darrington School District acknowledges that we did not retain documentation to demonstrate compliance with federal procurement requirements for the child nutrition cluster. However, we dispute the auditors’ assertion that we did not comply with federal procurement requirements. The district sought quotes from at least three vendors via phone calls per our policy. Unfortunately, several vendors were either unable to provide the products specified in our request for quotes or do not deliver to our area, and therefore did not provide written quotes. The district documented the quotes from responsive vendors. In the future, the district will document all efforts to obtain quotes from both responsive and nonresponsive vendors. Anticipated date to complete the corrective action: 8/15/2025

Finding ref number: 2024-002 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: Scott McDaniel, Executive Director of Business and Operations or Lara Christopherson, Assistant Director of Business and Payroll P.O. Box 8 Silverdale, WA 98383 (360) 662-1650 Corrective action the auditee plans to take in response to the finding: CKSD will provide annual training for all staff tied to federal funding purchasing. This will include conducting SAM.gov checks on any purchase of goods or services that may meet or exceed $25,000 in total cost prior to entering into contracted services or the purchase of goods. CKSD will create a training video, made available under Business Office Tutorial Videos on staff intranet, on how to conduct an entity search for a suspension and debarment check on the SAM.gov website, as a point of reference for staff members. CKSD will ensure staff doing any federal purchasing have a SAM.gov login. CKSD will require suspension and debarment records to be included with contracts using federal funds when routed for approval. CKSD will implement a process for retaining suspension and debarment check records. This may include attaching a copy of the SAM.gov check to purchase order or credit card reconciliations report. CKSD will explore alternative purchasing cooperatives, to utilize, that provide direct access to all bid/contract documents for real time review and evaluation of compliancy. Anticipated date to complete the corrective action: 09/30/2025

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION – CHILD NUTRITION CLUSTER (FEDERAL ALN 10.553 AND 10.555) 2024-004 Internal Control Over Compliance With Federal Reimbursement Submission Deadline Requirements Finding Summary 7 CFR § 210.8 requires the Academy to establish and maintain effective internal control over compliance with requirements applicable to federal programs, including reimbursement submission requirements applicable to the child nutrition federal program. During our audit, we noted the Academy did not have sufficient controls in place within its child nutrition cluster federal program to ensure compliance with federal submission requirements related to claims for reimbursement. Corrective Action Plan Actions Planned – The Academy is in the process of reviewing and updating its policies and procedures relating to reimbursement submission for its federal programs to ensure compliance with the Uniform Guidance in the future. The review of procedures will also include steps to ensure that Academy personnel are following the requirements of the Uniform Guidance related to reimbursement submission requirements. Official Responsible – The Academy's Executive Director, Farhiya Einte. Planned Completion Date – June 30, 2025. Disagreement With or Explanation of Finding – The Academy agrees with this finding. Plan to Monitor – The Academy’s Executive Director, Farhiya Einte, will assure appropriate internal controls and procedures are updated and in place to ensure compliance with reimbursement submission requirements.

Contact Person Evan Peltier Planned Corrective Action Dunseith Public School Dist. #1 will implement the recommendation from Brady Martz. Planned Completion Date The planned completion date is June 30, 2025.

Contact Person Evan Peltier Planned Corrective Action Dunseith Public School Dist. #1 will implement the recommendation from Brady Martz. Planned Completion Date The planned completion date is June 30, 2025.

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Finley School District No. 53 September 1, 2023, through August 31, 2024 This schedule presents the corrective action the District is planning to take for findings included 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: 2024-001 Finding caption: The District did not have adequate internal controls to ensure compliance with procurement requirements related to piggybacking. Name, address, and telephone of District contact person: Terri McGaughey, Business Manager 224606 E Game Farm Rd, Kennewick, WA 99337 (509) 586-3217 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 Finley School District has put in place internal controls to ensure compliance with procurement requirements related to piggybacking: The Food Service Director will compare invoices to the monthly price list to ensure contract pricing is used and initial invoices once reviewed. If there are discrepancies, the Food Service Director will contact the vendor for corrections. Quarterly, the Business Manager will select a sample of invoices to review for compliance. Anticipated date to complete the corrective action: May 1, 2025

In response to this finding, the Culinary Services department under the guidance of the Operations team in SPS has made the following adjustments and changes to business practices: 1. The PLE tool has been formally integrated into the annual budgeting process to ensure routine compliance with this guidance and accurate financial planning. 2. If a price increase is deemed necessary, it will undergo a thorough review and approval through the SPS board governance process. This will include a landscape review of meal prices in other districts in the Puget Sound region as well as similarly scaled districts nationally. This structured approach guarantees alignment with strategic objectives while maintaining transparency and accountability. 3. As of May 2025, the Culinary Services department under the direction of the Operations department will be taking action on a price increase for school lunches beginning for the 2025-26 school year with annual reviews scheduled for subsequent years.

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Castle Rock School District No. 401 September 1, 2023 through August 31, 2024 This schedule presents the corrective action the District is planning to take for findings included 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: 2024-002 Finding caption: The District did not have adequate internal controls and did not comply with federal procurement and suspension and debarment requirements. Name, address, and telephone of District contact person: Gloria Dupree, CSBS, CSBO Director of Fiscal Services Castle Rock School District 600 Huntington Ave S Castle Rock, WA 98611 Phone: 360.501.3132 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). Conduct mandatory training for all staff involved in procurement on federal regulations, including how to check vendors against the System for Award Management (SAM.gov) for suspension or debarment. Establish a procurement review checklist to be completed by the vendor and staff. Send out yearly with request of updated w-9 the vendor acknowledgment with debarment statement. Review debarment statues yearly. Anticipated date to complete the corrective action: 6/30/2025

Finding ref number: 2024-001 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: Brandon Rose PO Box 98 Pateros, WA 98846 (509) 923-2751 Corrective action the auditee plans to take in response to the finding: The District has ensured the current staff are aware of the issue regarding the Interlocal Agreement to purchase food commodities and the need to verify those documents annually regardless of ongoing business with the entity. The District will annually check the leading entity in August to ensure the suspension and debarment was completed. If the District office does not locate the information on the leading entity, the District will go out to SAM.gov to check the suspension and debarment and save proof that it was completed. Anticipated date to complete the corrective action: 4/8/2025

Management response: Warren Easton is reviewing and updating the procurement section of the policy manual to explicitly include procedures for verifying the suspension and debarment status of all vendors and contractors receiving federal funds. Documentation of each vendor's verification will be maintained in procurement files. A printed or PDF record from SAM.gov showing the vendor's status will be retained as audit evidence.

Finding Number: 2024‐001 Program Names/Assistance Listing Titles: Assistance Listing Numbers: Title I Grants 84.010 Child Nutrition Cluster 10.553, 10.555, 10.559 Impact Aid 84.041 Education Stabilization Fund 84.425 Contact Person: Arlene Laughter, Business Coordinator Anticipated Completion Date: December 30, 2025 Planned Corrective Action: The District will implement better controls over financial reporting and records retention to ensure all documents are prepared and available for the timely completion of the financial reports.