Corrective Action Plans

Recommendation We recommend the District implement documented daily edit checks reconciling meal counts to attendance records and maintain records of this review. For food inventory, the District should establish a formal inventory system, including perpetual inventory records, monthly physical counts, and supervisory review. Staff involved in Child Nutrition operations should receive training on USDA and federal compliance requirements Management Response Corrective Action The Food Service Director will implement the federally required daily edit check process. This will include comparing daily meal counts against the attendance and enrollment figures to ensure that claims do not exceed the number of students present. Any discrepancies identified during this process will be investigated and documented prior to submission of the monthly claim. The District will also change the tracking of meals served by using an official meal tracking device or by having students use their badge/ID cards to get a more accurate meal count each day. The District has a formal inventory process for all food service supplies including canned goods, dry goods, and freezer items. This system tracks items from receipt through consumption. The District conducts monthly physical inventory counts of all food service assets. These counts are reconciled and any significant variances are reviewed by the Food Service Director and reported to the Business Manager. The District will ensure that all nutrition staff is trained on these procedures as well. Due Date of Completion: June 30, 2026 Responsible Party Business Manager, Food Service Director

The auditor has confirmed in the ACFR that we have worked with the software provider and identified the issue with the edit check worksheets not correctly reporting meals on a daily basis. The software has been adjusted.

We have followed up with PaySchools and they have a target date of 4/30/26 for release of SOC Type II report, which should provide documentation on the effectiveness of their controls upon which we can rely when it comes to using their automated free and reduced application processing. In the meantime, our Food Service Supervisor will be reviewing all applications retroactive to the beginning of 2025-26.

Finding 2025-003 Federal Agency Name: U.S. Department of Agriculture Program Name and FALN # : Child Nutrition Cluster Federal Financial Assistance Listing #10.555 National School Lunch Program Federal Financial Assistance Listing #10.553 School Breakfast Program Finding Summary: The Region Schools do not have an internal control system designed to retain the appropriate review documentation for each meal count reported to the State of Iowa for reimbursement. Responsible Individuals: Bryan Jordan, Controller Corrective Action Plan: The Region Schools will retain a documented review of meal counts at each location completed prior to submission of the reports to the State of Iowa. Anticipated Completion Date: Fiscal year ended June 30, 2026

Finding 2025-002 Federal Agency Name: U.S. Department of Agriculture Program Name and FALN # : Child Nutrition Cluster Federal Financial Assistance Listing #10.555 National School Lunch Program Federal Financial Assistance Listing #10.553 School Breakfast Program Finding Summary: The Region Schools do not have an internal control system designed to retain the appropriate review documentation related to student eligibility within the student file. Responsible Individuals: Bryan Jordan, Controller Corrective Action Plan: The Region Schools will retain documentation related to the review of eligibility of the students participating in the Program within the student file going forward. Anticipated Completion Date: Fiscal year ended June 30, 2026

Finding 2025-001 Federal Agency Name: U.S. Department of Agriculture Program Name and FALN # : Child Nutrition Cluster Federal Financial Assistance Listing #10.555 National School Lunch Program Federal Financial Assistance Listing #10.553 School Breakfast Program Finding Summary: The Region Schools do not have an internal control system designed to retain the appropriate documentation related to direct certification from the State of Iowa (State). Responsible Individuals: Bryan Jordan, Controller Corrective Action Plan: The Region Schools will retain all Direct Certification information within the file for the students eligible to participate in the program going forward. Anticipated Completion Date: Fiscal year ended June 30, 2026

Condition: The District's supporting documentation for any students who filled out an online application was not properly maintained. Plan: The District will print and save copies of all online applications to enhance record retention. Anticipated Date of Completion: The District will correct this for the 2025-2026 school year. Name of Contact Person: John Belter, Business Manager Management Response: The District acknowledges the lack of supporting documentation for those students who completed online applications. The online applications did not transfer when the District rolled their systems and we no longer have access to the old system in which they were stored. The District notes this and will work to correct it in the future.

10.553, 10.555, 10.559 - Child Nutrition Cluster 2025-002 Net Cash Resources Corrective Action Plan The School Lunch Fund continues to have excess fund balance on hand due to the additional reimbursements provided during the COVID-19 pandemic. The School District is currently reviewing the equipment used by the program and will create a plan to use these funds to support the program's infrastructure. Expected Completion Date June 30, 2026 Contact: Jolean Bliss, School Business Executive Mexico Academy and Central School District 16 Fravor Road, Suite A Mexico, NY 13114 (315) 963-8400

Finding 2025-002 Finding Subject: Child Nutrition Cluster – Internal Controls Summary of Finding: The School Corporation had not properly designed or implemented an effective system of internal controls, which would include segregation of duties, that would likely be effective in preventing, or detecting and correcting material noncompliance. Contact Person Responsible for Corrective Action: Erika Horner, Director of Food Service Contact Phone Number and Email Address: (260)431-2030, ehorner@sacs.k12.in.us Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: All direct certification information shall be initiated by the Director of Food Service: pulling the information monthly from CNP Web. The list of students to be directly certified will be printed, signed and dated by the Director of Food Service. Once information is imported into the student management system, the Assistant Food Service Director would then cross reference the printed list of information to benefits assigned in the student management system to ensure accuracy. The Assistant Food Service Director will initial next to the students they spot check on the list. The printed document with signatures of both parties will be retained with the school years applications.􀯗 The Director of Food Service has the responsibility to ensure that all vendors are free from suspension, debarment, or aren’t otherwise excluded. Suspension and debarment documents are to be collected on a yearly basis. If such documents are not available through the SFA Cooperative, it will be the responsibility of the Director of Food Service to acquire them through SAM.gov website or contacting the vendor directly. All documents are to be signed, dated, and retained by school year by both the Director of Food Services and the Asst. Director of Food Services. Anticipated Completion Date: January 31, 2026 _________________________ Randi Libby_ (Signature) _______Chief Operating Officer __ (Title) __________January 7, 2026__________ (Date)

All free and reduced meal applications are completed electronically by the parent or guardian through the District's online application system. The parent/guardian inputs household and financial information used to determine eligibility in accordance with the income eligibility guidelines established by the State of Ohio and the National School Lunch Program. To ensure internal controls are in place and that eligibility determinations are accurate, the District will implement a review process whereby all electronic applications submitted by parents or guardians will be reviewed by the Cafeteria Supervisor or a designated staff member prior to final approval. The reviewer will ensure that all required fields are completed, the information provided appears reasonable, and the eligibility determination generated by the system is appropriate based on the information provided on the application. If any application appears incomplete or contains questionable information, the Cafeteria Supervisor or designee will contact the parent or guardian for clarification or correction prior to approving the application. Documentation of the review will be maintained by a checklist or retained electronically to demonstrate that the review occurred. Periodic monitoring of the process will be performed to ensure the control procedures continue to operate as intended and that applications are properly reviewed before eligibility is finalized. Anticipated Completion Date Effective immediately and ongoing. Responsible Contact Person Cafeteria Supervisor Dawn Nelson

Finding Number: 2025-004 ALN Number(s) and Program Title(s): 10.646 – Summer Electronic Benefit Transfer Program for Children Views of Responsible Officials and Planned Corrective Action: DHS concurs, in part, and disagrees, in part with this finding. The DCO ARIES team analyzed all potential duplicates for 2024 and 2025. DCO considers 59.1% of the records to not be duplicates, because the records have different SSN’s and dates of birth. A total of 35.9% of cases have the same date of birth but different SSN’s and are potential duplicates. DCO is in the process of reviewing these cases to determine if any system or process adjustments are needed to prevent potential duplicates in the future. The remaining potential duplicates identified by ALA have already been resolved or are being investigated. A refresher training will be conducted with staff who determine eligibility and issue benefits for the Summer EBT program before the program starts in 2026. DCO disagrees that it did not meet the minimum sample verification requirements. A sample of 3% of approved applications received were reviewed according to the 2025 Plan of Operational Management that was approved by FNS. Anticipated Completion Date: 6/30/2026 Contact Person: Name: Mary Franklin Title: Director, Division of County Operations Agency: Department of Human Services Address: 700 Main Street City, State, Zip: Little Rock, AR 72201 Phone Number: 501-681-8377 Email Address: Mary.Franklin@dhs.arkansas.gov

Finding Numbers: 2025‐002 Program Name/Assistance Listing Title: Child Nutrition Cluster Assistance Listing Numbers: 10.553, 10.555, 10.559 Contact Person: Eloyce Gillespie, Business Manager Anticipated Completion Date: April 30, 2026 Planned Corrective Action: Casa Blanca Community School has implemented a review process to monitor expenditures across all funds. As part of this process, Management has adopted a review process relating to expenditures of all funds to minimize any negative effect on cash for these funds. This review includes a comparison of expenditures to budgets for all funds to ensure that they do not exceed anticipated revenues. Additionally, if it is determined that the program will exceed the anticipated revenue, Management will determine if such overages (negative cash balances) are to be addressed through operating transfers using Indian School Equalization Program funding.

Garfield County School District No. 16 respectfully submits the following corrective action plan for the year ended June 30, 2025. Finding 2025-001 Reporting Significant Deficiency in Internal Control over Compliance and Other Non-Compliance Corrective Action: The District agrees with the finding related to insufficient supporting documentation for the National School Lunch Program reimbursement claims, as it related to sack lunches/field meals. Personnel Responsible for Corrective Action: Jody Williams, Food Service Director Anticipated Completion Date: The District has corrected this issue as of the date of this report, and now requires formal written requests for all sack lunches/field meals, to ensure counts are properly documented.

2025-001 ELIGIBILITY 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 Type of Finding: Noncompliance, significant deficiency in internal control Compliance Requirement: E. Eligibility Criteria: Federal regulations require participating districts to determine student eligibility for free, reduced price, and paid meals based on household income and household size thresholds established annually by the U.S. Department of Agriculture. Applications must be reviewed and approved using the current income eligibility guidelines and appropriate calculation methods to ensure correct benefit levels. Condition: During testing of 25 student meal applications, we noted 1 instance where the District incorrectly calculated household income relative to household size when determining eligibility status. In these cases, students were approved for free price meals when the income calculations supported reduced meal status. Cause: The District did not have sufficient review controls in place to ensure that eligibility determinations were recalculated or independently verified prior to approval. Effect: As a result of the errors, certain students received free meal benefits for which they were not eligible. This may have resulted in improper program reimbursement claims and indicates that the District’s controls over eligibility determinations were not operating effectively. Questioned Costs: The projected questioned costs related to these errors are not expected to be material; however, the District may have received reimbursement at the free price rate rather than the reduced rate for affected meals. Corrective Action: The District will review their meal application process and implement a more stringent review to ensure eligibility criteria are met based on household income. Planned completion date for corrective action plan: For the period ending June 30, 2026. Name of the contact person responsible for corrective action: Erika Aguallo, Business Manager

NPS will enhance its system of internal controls by implementing a standardized, enterprise-level review and approval process for all National School Lunch Program (NSLP) and Fresh Fruit and Vegetable Program (FFVP) reimbursement reports. Effective immediately, all claims for reimbursement will require documented supervisory review and formal approval prior to submission, ensuring accuracy, completeness, and full compliance with federal and program requirements. Related policies and procedures will be revised to clearly define accountability, documentation standards, and submission timelines. In parallel, NPS will invest in targeted training for all personnel involved in the preparation and certification of claims to ensure consistent execution of these requirements. To sustain compliance and reinforce accountability, we will establish a structured monitoring framework that includes periodic, risk-based reviews of submitted claims and supporting documentation. This approach will provide ongoing assurance that all claims are properly reviewed, approved, and supported in accordance with established standards.

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. 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.

The Screven County School System Nutrition Department will submit purchase order requests in YOSS, which is the digital Accounts Payable system utilized by the district. Requests will be reviewed for approval by the Director of Operations. If approved by the Director of Operations, the request will be sent through YOSS for the Superintendent's approval and then to bookkeeping to be ordered. When the items are received, accounts payable will send the invoice through YOSS for approval for payment to the Superintendent. This will provide a multiple layer to the approval process to ensure that procurement procedures are being followed.

Finding Number: 2025-003 Planned Corrective Action: To address this finding, FNW immediately implemented a temporary solution. On or about September 8, 2025, FNW created a ticket to commence work on a permanent solution to address the audit finding. The solution deployed on March 18, 2026. Anticipated Completion Date: March 18, 2026 Responsible Contact Person: Terricka Washington, Division of Food, Nutrition and Wellness Information Office/LaSharonté Williams-Potts, Assistant Division Director

Child Nutrition Cluster, ALN’s 10.553 & 10.555 Recommendation: We recommend the review and approval process over monthly claims for reimbursement be strengthened to enhance the prevention of discrepancies between the claim for reimbursement and underlying data. Explanation of disagreement with audit finding: Management agrees with the finding. Action taken in response to finding: Newton operated the National School Lunch Program (NSLP) during the Extended School Year (ESY) for the first time during the summer 2024, which created a reporting challenge. Students from across the district's 23 schools attended ESY in seven (7) schools/sites, but their school-year home schools could not be changed in the Student Information System (Aspen). Therefore, student meal counts reported to their home school on the FP9 but had to be reported on the DESE School Report for the ESY school/site they attended. Given the system interface complexities, some counts had to be manually entered, for which two (2) meal counts were incorrectly entered for breakfast versus lunch. Given that the district did not operate the School Breakfast Program (SBP) and did not serve breakfast, these two (2) manual errors were counted as lunch counts when entered for the School Report. The total meal count did match on the FP9 and School Report. For this inconsistency, the correct action should have been to manually update these two counts in the Point of Sale system (Mosaic) so that the two breakfast counts reflected correctly as lunch counts. Name(s) of the contact person(s) responsible for corrective action: Amy Mistrot, NPS Director of Business Operations. Planned completion date for corrective action plan: Newton was able to set conditional parameters in Aspen for ESY 2025 so that the student meal counts reported to their ESY school/site versus their home school, so this reporting issue was corrected the following summer.

2025-006 Material Weakness and Noncompliance, Suspension and Debarment (Repeat Finding 2024-005) Audit Finding: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards requires compliance with provisions of procurement, suspension, and debarment. Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Documentation that such a verification was done must be maintained. The Town did not have documentation to support verification that three vendors were not excluded from federal contract due to debarment or suspension. Corrective Action Taken: The Town and Board of Education (BOE) have enhanced procurement controls to ensure suspension and debarment verifications are documented in accordance with 2 CFR 200.214. BOE’s Procurement Department routinely reviews SAM.gov to verify suspension and debarment status for all contracts, regardless of the funding source. Moving forward, a verification sheet will be included with all contract documentation. Additionally, BOE personnel involved in the procurement process have received training on applicable federal compliance requirements. The Procurement Department will also require vendors to complete suspension and debarment certification forms, which will be maintained within the Munis system by the Accounting Department. Anticipated Completion Date: In Process as of July 2025. Name and Phone # of Person Responsible for Implementation Joan Lynch, Comptroller, 203-622-2226

FINDING 2025-004 Finding Subject: Child Nutrition Cluster - Reporting Contact Person Responsible for Corrective Action: Adrian Wilkerson, Chief Financial Officer Chris Akers, Treasurer Fredrick Vaughn, Food Service Director Contact Phone Number and Email Address: awilkerson@chsnewtech.com cakers@chsnewtech.com fvaughn@chsnewtech.com 219-838-1819 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The food service director will prepare the daily meal counts from the POS system and create a claim summary sheet. This sheet will show the total reimbursable breakfasts, lunches and total enrollment for the month. Included with this will be a monthly POS summary report showing these counts. This report will be reviewed and signed by the treasurer and the food service director. After the review the treasurer will submit the claim in the IDOE CNP web portal. Anticipated Completion Date: This will be implemented for the February 2026 claim.

FINDING 2025-003 Finding Subject: Child Nutrition Cluster - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Adrian Wilkerson, Chief Financial Officer Chris Akers, Treasurer Fredrick Vaughn, Food Service Director Contact Phone Number and Email Address: awilkerson@chsnewtech.com cakers@chsnewtech.com fvaughn@chsnewtech.com 219-838-1819 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The monthly review process will include detailed ledgers with receipts and invoices provided. The business manager and food service director will review 2CFR 200.403. The business manager or treasurer will review five random line items and trace them back to the source document. The monthly review will be signed by the business manager, food service director and treasurer. Anticipated Completion Date: This will be implemented with the February 2026 monthly review process.

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 Skyward 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.

CHILD NUTRITION CLUSTER – SUSPENSION AND DEBARMENT U.S. Department of Agriculture Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.556, 10.559, 10.582 Passed Through Minnesota Department of Education Pass Through Number: 10.CNC Award Period: July 1, 2024 – June 30, 2025 Recommendation: We recommend the District formalizes their suspension & debarment procedures in a policy and ensure they check suspension & debarment for all vendors prior to entering into a covered transaction. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: The District will work on educating all of the personnel involved in the procurement processes to ensure the compliance requirements are fully understood and a proper review of all procurements and procurement methods will be performed. This will be implemented by June 30, 2026, and the School Board will be responsible for monitoring the status. Name of the contact person responsible for corrective action: Tom Sager, Executive Chief of Financial Services Planned completion date for corrective action plan: 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.