Corrective Action Plans

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 10.559) 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. 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 – Ra Chhoth, Finance and Operations Executive Director. Planned Completion Date – June 30, 2026. Disagreement With or Explanation of Finding – The District agrees with this finding. Plans to Monitor – The District’s Finance and Operations Executive Director, Ra Chhoth will assure appropriate internal controls and procedures are in place to ensure compliance with suspension and debarment requirements.

Condition - The same individual is responsible for preparing and submitting monthly reimbursement claims for the Child Nutrition Program without an independent review or approval prior to submission. Plan - A second person person (business manager) compares the meal counts in the claim to: the Skyward daily meal count reports, monthly participation summary, eligibility rosters (free, reduced, paid) and USDA reimursement rates. The reviewer will then sign and date a reconciliation sheet before submission. Anticipated Date of Completion: December 7, 2025; Name of Contact Person - Dan Nolan, Business Manager; Management Response - The corrective action plan was discussed with the employee responsible for filing the claim, the business manager, and the superintendent. After discussion, the plan was approved by the superintendent.

FINDING 2025-005 Finding Subject: Child Nutrition Cluster, Special Tests and Provisions, School Food Accounts Audit Findings: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Jennifer Felke, Brittany Sabinas, Amanda Bender Contact Phone Number and Email Address: 574-936-3115, jfelke@plymouth.k12.in.us, Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Since January 2025, the internal controls that resulted in this finding have been corrected. The finding stated that “The lack of internal controls and noncompliance over Special Tests and Principles, School Food Accounts is an isolated incident.” The Business Manager/Treasurer receives deposit emails from the Indiana State Comptroller. The Business Manager codes the deposit for the Accounts Payable Specialist to receipt. The Business Manager completes a monthly bank reconciliation that is reviewed by the Deputy Treasurer and Accounts Payable Specialist as part of the month end process. Anticipated Completion Date: January, 2025 and ongoing

FINDING 2025-004 Finding Subject: Child Nutrition Cluster, Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Findings: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Jennifer Felke & Amy Kraszyk Contact Phone Number and Email Address: 574-936-3115, jfelke@plymouth.k12.in.us, Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Since January 2025, the internal controls that resulted in this finding have been corrected. The finding stated that “The lack of internal controls and noncompliance over Allowable Activities and Allowable Costs/Cost Principles is an isolated incident.” The Food Service Director and the Business Manager/Treasurer meet monthly to review the school lunch accounts and to concur with the month end balances. The Deputy Treasurer approves all monthly fund transfers completed by the Business Manager. Anticipated Completion Date: January 1, 2025 and ongoing

FINDING 2025-003 Finding Subject: Child Nutrition Cluster, Internal Controls Audit Findings: Material Weakness Contact Person Responsible for Corrective Action: Jennifer Felke & Amy Kraszyk Contact Phone Number and Email Address: 574-936-3115, jfelke@plymouth.k12.in.us, Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Food Service Director will oversee and review the process in place to ensure accuracy of eligible students. The Food Service Director will approve the uploaded Direct Certification reports after reviewing to ensure directly certified students were properly processed. The Business Manager/Treasurer will be the final approver of all Direct Certification reports. The Food Service Director will verify that contractors and subrecipients of the federal award are not suspended, debarred or otherwise excluded. The Food Service Director will complete this task for any expense expected to exceed $25,000 by checking SAMS exclusions, collecting a certification from that vendor or adding a clause or condition to the covered transaction with that vendor. The Business Manager/Treasurer will be the second reviewer/approver for suspension and disbarment. Anticipated Completion Date: March 1, 2026 and ongoing

FINDING 2025-002 Finding Subject: Child Nutrition Cluster – Procurement, Suspension, and Debarment Contact Person Responsible for Corrective Action: Kathy Bernaix, Food Service Director and Bengamin Mann, CFO Contact Phone Number and Email Address: 765-536-0008 and kbernaix@mgusc.k12.in.us and bmann@mgusc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We will have two sign offs on our print out from sam.gov evidencing multiple reviewers of the ELPS. Anticipated Completion Date: January 1, 2026

FINDING 2025-003 Finding Subject: Child Nutrition Cluster- Eligibility and Reporting Contact Person Responsible for Corrective Action: Chris Goris Contact Phone Number and Email Address: 765-395-3341, christengo@ohusc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Food Service Director will review eligibility of students for the free and reduced meal program through the state level system that identifies Direct Certification eligibility. The district will have a secondary individual from the food service department review the eligibility determination for both financial applications and through Direct Certification following the initial review by the Food Service Director. Both the director and the secondary individual will sign off on the determined eligibility status of free/ reduced applications submitted by households and Direct Certification eligibility through the Child Nutrition Program. The secondary individual will additionally review to ensure accuracy of the eligibility determination entered in the student information system by the Food Service Director. The district will prepare monthly meal claims and submit them to the Child Nutrition Program by following the listed steps: 1. The Food Service Director will prepare the meal claim numbers from the district’s student information system. 2. The CFO, or secondary individual from the food service department, will review the reports prepared by the Food Service Director. 3. The Food Service Director will enter monthly meal counts for reimbursement into CNP.4. The CFO or secondary individual from the food service department will review the CNP entry of meal claim information before submission. 5. The Food Service Director and CFO and/ or secondary individual will sign off on the preparation and entry of the monthly meal claim reimbursement. Anticipated Completion Date: 3/31/2026

FINDING 2025-03 Finding Subject: Child Nutrition Cluster – Activities Allowed or Unallowed, Allowable Costs/Cost Principles Summary of Finding: The School Corporation had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance related to the payroll and payroll benefit costs charged to the grant or food service revenues being accounted for in the School Food Account. The lack of internal controls and noncompliance was isolated to the 2023-2024 school year. Contact Person Responsible for Corrective Action: Kim Holmquist Contact Phone Number and Email Address: 219-924-4250 kholmquist@griffith.k12.in.us View of Responsible Officials: We concur with this finding. Description of Corrective Action Plan: Griffith Public Schools will be developing, implementing, and documenting, a system of internal controls, including policies and procedures that provide segregation of duties to ensure appropriate reviews, approvals and oversight are taking place to ensure compliance. Anticipated Completion Date: June 30, 2026

Condition - The same individual is responsible for preparing and submitting monthly reimbursement claims for the Child Nutrition Program without an independent review or approval prior to submission. Plan - A second person (Superintendent) compares the meal counts in the claim to: the SDS daily meal count reports, monthly participation summary, eligibility rosters (free, reduced, paid) and USDA reimbursement rates. The reviewer will then sign and date a reconciliation sheet before submission. Anticipated Date of Completion - July 1, 2026; Name of Contact Person - Dr. Beau Fretueg, Superintendent; Management Response - The corrective action plan was discussed with the employee responsible for filing the claim, the business manager, and the superintendent. After discussion, the plan was approved by the superintendent.

FINDING 2025-002 (Auditor Assigned Reference Number) Finding Subject: Child Nutrition Cluster - Eligibility Contact Person Responsible for Corrective Action: Stefanie Grandstaff, Director of Business Services Contact Phone Number and Email Address: stefanie.grandstaff@epulaski.k12.in.us Views of Responsible Officials: We concur with the finding. Explanation and Reasons for Disagreement: N/A Description of Corrective Action Plan: The Food Service Director will continue uploading the state-provided file into Skyward and verifying the accuracy of the imported information. After this review, the Food Service Director will notify the Director of Business Services via email to independently confirm that the data from the state file was uploaded and processed correctly in Skyward. This email correspondence will serve as documentation of the verification process. In addition, we will address the issue related to the 30-day rollover and students who withdraw. We will work with Skyward to adjust system parameters so that both active and inactive students are included, ensuring the rollover is accurate. The Food Service Director will also review each newly enrolled student to confirm the eligibility status by verifying whether a parent submitted an application through the school or the state. Based on the documentation available, she will update eligibility status as needed and then email the Director of Business Services to review and confirm accuracy. Anticipated Completion Date: June 30, 2026.

FINDING 2025-003 Finding Subject: Child Nutrition Cluster - Reporting Contact Person Responsible for Corrective Action: Andrea Miller Contact Phone Number and Email Address: 765-564-2100 ext 1002, millera@delphi.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The FSD will enter the required information into CNPweb. Once entered, she will forward a screen shot of the information entered and the student meal count from Skyward to the Corporation Treasurer. The Treasurer will review the information and sign off through email to the FSD, who will then submit the claim to the State for reimbursement. Anticipated Completion Date: June 2026

FINDING 2025-001 Finding Subject: Child Nutrition Cluster - Eligibility Contact Person Responsible for Corrective Action: Andrea Miller Contact Phone Number and Email Address: 765-564-2100 ext 1002, millera@delphi.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We will implement a documented secondary review, the FSD will print a before and after report from Skyward, and the direct certification download. The MS/HS ECA Treasurer will review the reports, verify Skyward, and sign off on the reports for the second check. The FSD and MS/HS ECA Treasurer will receive annual compliance training. Anticipated Completion Date: June 2026

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

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

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

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

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

Condition - The same individual is responsible for preparing and submitting monthly reimbursement claims for the Child Nutrition Program without an independent review or approval prior to submission. Plan - A second person compares the meal counts in the claim to the daily meal count reports. The reviewer will then sign and date both the meal count reports (prior to submission) and a printed copy of the meal claim (after submission). Anticipated Date of Completion - June 30, 2026; Name of Contact Person - Dr. Eric Heath, Superintendent; Management Response - A corrective action plan will be developed and implemented. A secondary review of the meal claim to the supporting documents will be performed before the meal claim is submitted.

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

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

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

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

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

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

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