Corrective Action Plans

Finding 2025-001: Allowable cost and activities – Significant deficiency in internal controls over compliance. Management Response: The School has implemented procedures to ensure that invoices are approved prior to being paid. Expenses are reviewed and approved through the PO process within the Ascender System. Each request is evaluated for accurate account coding, appropriateness, and compliance with Federal Grant allowable costs (when necessary). Spending and allowable costs are closely monitored on an ongoing basis. Once orders have been placed, products have been received/services rendered, and invoices received, the accounting clerk will prepare documents for the check run. A “check payments” report is provided which lists all transactions for the check run. The “check payments” document clearly displays the vendor, account code, and amount of each transaction. The “check payments” report is approved by Superintendent. Once “check payment” report is approved by Superintendent, the check run will be initiated. Documentation of prior approval will be kept on file. The new process began in March 2025. Responsible Party: Kemlyn Williams, Superintendent Dynamic Support Solutions, Contract CFO

Finding Number 2025-003 Condition: The District could not provide free and reduced-price meal applications for two (2) students selected for testing. Additionally, two (2) students were provided free lunches when, based on eligibility information, they should have been classified and provided benefits at the reduced-price level. One (1) student was provided reduced lunches, when, based upon eligibility information, they should have been classified as free lunches. Management Response/Plan: The District acknowledges the finding and has strengthened internal controls over eligibility determination and document retention for the National School Lunch Program by implementing centralized recordkeeping procedures and a secondary review of all applications prior to approval. Staff have been retrained, and the District will perform periodic monitoring to ensure applications are properly retained and student benefit levels are accurately assigned. Anticipated Date of completion: June 2026 Name of Contact Person: Dr. Joe Mullikin

Finding Number 2025-001 Condition: The District was unable to provide documentation for three invoices charged to the program. The District was also unable to provide supporting documentation for one employee time card. Management Response/Plan: The District acknowledges the finding and has strengthened internal controls over disbursements by implementing centralized invoice retention procedures and requiring verification of supporting documentation prior to payment approval. Staff have been retrained on documentation requirements, and periodic monitoring will be conducted to ensure all expenditures are properly supported and maintained. Anticipated Date of completion: June 2026 Name of Contact Person: Dr. Joe Mullikin

Finding 2025-003 School Nutrition Program Meal Claims 1. Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. 2. Actions Planned in Response to Finding The District has already begun evaluating current procedures for accurately monitoring, recording, and reporting the number and type of meals served. 3. Official Responsible Mr. Greg Johnson, Superintendent, is the official responsible for ensuring corrective action. 4. Planned Completion Date The planned completion date is June 30, 2026. 5. Plan to Monitor Completion The Board of Directors will be monitoring this Corrective Action Plan.

While the District maintained the requisite supporting documentation, limitations arising from the internal record retention policies in place at the time, coupled with the retirement of key personnel, resulted in certain enrollment records not being readily locatable. The District acknowledges that these factors limited the availability of prior-year supporting data. This issue has since been addressed through updated retention practices to ensure that this does not occur going forward. Beginning with the next fiscal year cycle, the District has implemented a documented procedure that specifies the data sources, query parameters, and data pull dates; requires that all supporting extracts and calculations be retained in a centralized, version-controlled folder; and establishes a formal review and approval process to verify that enrollment and low-income counts reconcile to source documentation before submission to ADE. Staff in Federal Programs and Finance have been trained on the new procedure, and an annual internal review has been established to confirm compliance. The Director of Finance and the Director of Federal Programs are responsible for implementing and monitoring this corrective action, which will be completed prior to the next Title I eligibility submission.

Reviewing the fund balance monthly and purchasing necessary supplies and staff to keep the balance down.

Child Nutrition Cluster, National School Lunch Program – Assistance Listing 10.555; passed through the Pennsylvania Department of Education; Grant Period – Year Ended June 30, 2025 Significant deficiency: See deficiency 2025-002 listed below. 2025-002. FOOD SERVICE RECEIVABLES Planned Corrective Action: The Staff Accountant Amber Whited will review receipts after year end to ensure receivables are accurately identified and recorded as receivables. Person Responsible: Staff Accountant (Amber Whited) Anticipated Completion date: Immediately

2025-001 Reporting Federal Assistance Listing Number: 10.553, 10.555, 10.559 Program Title: Child Nutrition Cluster Federal Agency: U.S. Department of Agriculture Passthrough Entity: Arizona Department of Education Passthrough Number: ADE ED09-0001 Compliance Requirement: L. Reporting Award Period: July 1, 2024 – June 30, 2025 Finding Type: Noncompliance, Significant Deficiency in Internal Control Questioned Costs: N/A Repeat Finding: No. Condition/Context: During our review of meals claims submitted for reimbursement, we noted variances between the District’s meal counts and what was submitted to the Arizona Department of Education. For four months tested, meals claims were net under-reported by 48 lunch and breakfast meals, which calculated to $432.84. Criteria: Child Nutrition Cluster claim forms should be supported by documentation showing the number of meals for which reimbursement was requested. This documentation should be maintained to support what was requested for reimbursement by ADE. Effect: Without proper controls over applications and the filing of claims, the District could over or under claim their reimbursements from the Child Nutrition Program without detecting the error. Corrective Action Plan: Management will ensure meals claims are reviewed, approved, and tie to supporting meals served before claims are submitted. Planned completion date for corrective action plan: For the period ending June 30, 2026. Name of the contact person responsible for corrective action: Sherry Wallace, Director of Finance.

Corrective Action Plan The District is currently working on correcting this finding by ensuring the District’s internal controls related to document retention and review procedures for federal program reimbursements are complete, accurate, and readily available for audit and monitoring purposes. Proposed Completion Date – August 31, 2026 Contact Person – Melinda Chapa, Chief Financial Officer

The District acknowledges the oversight and confirms that the March 2025 claim had been properly prepared and fully supported but was inadvertently not submitted. The District has since contacted NMPED to resolve the matter and submitted the claim. To prevent future occurrences, the District is implementing a new tracking and reminder system and is providing targeted training to staff involved in the claims process. Efforts are also underway to strengthen internal controls to ensure timely submission moving forward.

2025-002 Net Cash Resources - Child Nutrition Cluster (ALN # 10.553/10.555/10.559) Corrective Action Plan School District management agrees with condition, cause, and recommendation. With this overage, the School District has purchased some new equipment for the cafeteria. Since the School District is CEP, there is no option to change the revenue. The School District will continue upgrading the kitchens with the excess. Expected Correction Date: June 30, 2026 Contact: Kathy Rote, School Business Administrator (607) 565-2841 15 Frederick St. Waverly, NY 14892

Finding Identification: 2025 – 001 Federal – Child Nutrition Cluster #50000 Name of contact person: Bricki McNulty Corrective Action: Upon identification of the finding, the Child Nutrition Director immediately contacted the Tri-County Co-op to obtain the formal "Buy American" certification and statement for the 2024-25 school year. Upon discovery that a formal statement was not currently on file from the vendors for that specific period, the SFA took proactive measures to secure the appropriate certification for the 2025-26 school year to ensure immediate and future compliance. To prevent a recurrence of this finding, the Child Nutrition Director will be responsible for verifying and obtaining the updated "Buy American" certification from the Tri-County Co-op at the start of every school year. The School Food Authority (SFA) remains committed to purchasing domestic commodities and products to the maximum extent practicable. To support this, the Child Nutrition Director will oversee the continued use of the Buy American Exception Log. This log will be used to document any non-domestic items—such as bananas or other seasonal fruits not grown in the U.S. in sufficient quantities—including the specific justification (availability or price) for each exception. By integrating these steps into our annual administrative calendar, the SFA ensures that all food served in the National School Lunch and Breakfast Programs meets the domestic requirements mandated by 7 CFR 210.21(d). Proposed Completion Date: September 2025

Condition: The District had one missing application and two instances of students being claimed in the incorrect eligibility category. Plan: The District will improve their review processes to ensure applications are all retained and eligibility information is correctly applied. Anticipated Date of Completion: The District will correct this for the 2025-2026 school year. Name of Contact Person: Andrea Havlovitz, Business Administrator Management Response: The District agrees with the finding and will correct this in future years.

2025-002 Reporting Federal Assistance Listing Number: 10.553, 10.555 Program Title: Child Nutrition Cluster Federal Agency: U.S. Department of Agriculture Passthrough Entity: Arizona Department of Education Passthrough Number: ADE ED09-0001 Compliance Requirement: L. Reporting Award Period: July 1, 2024 – June 30, 2025 Finding Type: Noncompliance, Significant Deficiency in Internal Control Questioned Costs: N/A Repeat Finding: No. Condition/Context: During our review of meals claims submitted for reimbursement, we noted variances between the District’s meal counts and what was submitted to the Arizona Department of Education. For four months tested, meals claims were under-reported by 20 lunch meals, which calculated to $90.80. Criteria: Child Nutrition Cluster claim forms should be supported by documentation showing the number of meals for which reimbursement was requested. This documentation should be maintained to support what was requested for reimbursement by ADE. Effect: Without proper controls over applications and the filing of claims, the District could over or under claim their reimbursements from the Child Nutrition Program without detecting the error. Corrective Action Plan: Management will ensure meals claims are reviewed, approved, and tie to supporting meals served before claims are submitted. Planned completion date for corrective action plan: For the period ending June 30, 2026. Name of the contact person responsible for corrective action: Elizabeth Ibarra, Business Manager

FINDING 2025-001 Subject: Child Nutrition Cluster (CNC) - Internal Controls Federal Agency: Department of Education Federal Program: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children Assistance Listing Number: 10.553, 10.555, 10.559 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs - Cost Principles Audit Finding: Significant Deficiency 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 Activities Allowed or Unallowed, Allowable Costs - Cost Principles compliance requirements. Context: During testing payroll disbursements charged to CNC grants, we noted: One selection in a sample of 40 for which the employee was paid above their contracted hourly rate. One selection in a sample of 40 for which the contract sheet for fiscal year 2025 did not include an accurate breakdown for cafeteria employees employed for less than one year and employees employed more than one year. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Management will ensure controls surrounding salary/hour rate schedules are implemented/enhanced and that rate changes are properly reviewed when instituted. Responsible Party and Timeline for Completion: Betty Huddleston, July 1, 2026

FINDING 2025-004 Finding Subject: Child Nutrition Cluster-Reporting Contact Person Responsible for Corrective Action: Greg Miller, Food Service Director Contact Phone Number and Email Address: 424 East South A Street, Gas City, IN 46933 (765)-677- 4423 Views of Responsible Officials: Mississinewa Community School Corporation concurs with the finding 2025-004. Description of Corrective Action Plan: An effective internal control system, which would include segregation of duties, was not in place at the School Corporation to ensure compliance with requirements related to the monthly reimbursement claim process for the audit period. Corrective Action: Internal Controls regarding the monthly reimbursement claim process will be implemented to be completed each month. The High School Kitchen Manager, along with the Food Service Director, will review the sale reports, attendance factor, and edit checks to calculate the total claim count for each federal program. The Manager and Food Service Director will approve and sign the total meal counts to claim prior to entering data into the CNP website. Anticipated Completion Date: January 31, 2026.

FINDING 2025-003 Finding Subject: Child Nutrition Cluster-Suspension and Debarment Contact Person Responsible for Corrective Action: Greg Miller, Food Service Director Contact Phone Number and Email Address: 424 East South A Street. Gas City, IN 46933 (765)-677- 4423 Views of Responsible Officials: Mississinewa Community School Corporation concurs with the finding 2025-003. Description of Corrective Action Plan: An effective internal control system, which would include segregation of duties, was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Corrective Action: Internal Controls regarding Procurement and Suspension and Debarment will be implemented to maintain reasonable assurance of compliance with the Procurement and Suspension and Debarment by requiring the Certification Regarding Debarment, Suspension, Ineligibility and Voluntary Exclusion Form as part of the procurement process. Once returned with the RFQ/RFP (request for quote or proposal), the Food Service Director will review with the Business Manager for approval, including both signatures. Additionally, the Business Manager will look up all vendors on the pre-approved Suspension and Debarment vendor website, and those results will be shared with the Food Service Director before the procurement process. All completed forms will be filed with the Business Manager. In addition, CN Director will provide a template letter to the vendor stating that they have not been suspended or debarred from procurement with federal entities. Vendor will be asked to sign the letter and return to the Food Service Director to keep on file at Mississinewa Community Schools. Anticipated Completion Date: January 23, 2026.

Management concurs with Audit Finding 2025-003 and will strengthen controls over USDA Food Distribution Cluster reporting to ensure accuracy, completeness, and compliance with federal and State requirements. Management will implement the following corrective actions: 1. Monthly USDA Reporting Reconciliation Process Management will implement a formal monthly reconciliation process that includes: o Reviewing confirmed USDA receipts and reconciling them to internal inventory records in CERES; and o Reconciling all TEFAP distribution reports submitted to the States to CERES data prior to submission. All reconciliations will be documented, reviewed, and retained. 2. Documentation of Shortages and Inventory Adjustments Shortages noted on signed agency invoices will be promptly documented and resolved through credit memos or inventory adjustments in CERES. Supporting documentation will be retained to substantiate all adjustments. 3. 48-Hour Receipt Confirmation Tracking Management will establish a tracking mechanism (e.g., log or checklist) to monitor submission of all required 48-hour receipt confirmations. The tracking tool will document submission dates and ensure confirmations are submitted timely and retained in accordance with record retention requirements. 4. Assignment of Reporting Responsibility Management will formally assign primary responsibility for preparation and submission of Food Distribution Cluster reports to a designated individual. Roles and responsibilities will be clearly documented. 5. Supervisory Review and Oversight A supervisory reviewer will perform documented reviews of reconciliations, supporting documentation, and reports prior to submission. Supervisory review will confirm that: o Reconciliations are completed. o Differences are investigated and resolved; and o Reports comply with applicable federal and State requirements. 6. Monitoring and Training Management will periodically monitor compliance with these procedures and provide refresher training to staff involved in inventory, distribution, and reporting to ensure consistent application of controls. Expected Completion Date: Within 60–90 days Responsible Parties: Donavann Brooks, Inventory Control Manager (901-527-0422)

Management concurs with Audit Finding 2025-002 and will reinforce controls over USDA food distribution documentation to ensure all distributions are properly acknowledged and supported in accordance with Food Distribution Cluster recordkeeping requirements. Management will implement the following corrective actions: 1. Required Agency Acknowledgment at Delivery Management will reinforce procedures requiring recipient agency signatures or equivalent acknowledgment on all USDA food distribution invoices at the time of delivery. Distribution staff and drivers will be reminded that unsigned delivery documentation is considered incomplete. 2. Post-Delivery Follow-Up Control Management will implement a follow-up control, such as a delivery log or checklist, to track all USDA distributions recorded at the time of delivery. The log will include verification that a signed receipt has been obtained and returned for each transaction. 3. Reconciliation of Distributions to Signed Documentation On a periodic basis, management will reconcile USDA distribution activity to signed agency invoices to identify any missing acknowledgments. Missing signatures will be promptly investigated and resolved, with documentation of follow-up retained. 4. Supervisory Review and Oversight Supervisory personnel will perform periodic documented reviews of distribution documentation to verify that signed agency receipts are obtained, complete, and retained. Evidence of review will be maintained. 5. Training and Awareness Management will provide refresher training to distribution staff and drivers on USDA documentation requirements and the importance of obtaining signed acknowledgment to support program accountability and reporting accuracy. Expected Completion Date: Within 60-90 days Responsible Parties: Andrelle Bowen, Transportation Manager, (901-373-0402)

Management concurs with Audit Finding 2025-001 and will implement enhanced internal controls over inventory adjustments to ensure accurate accounting for the receipt, distribution, and disposition of all USDA commodities in compliance with Special Tests and Provisions requirements. Management will implement the following corrective actions: 1. Formal Approval and Authorization of Inventory Adjustments Management will establish a formal policy requiring documented supervisory review and approval for all manual positive and negative inventory adjustments recorded in the general ledger and the CERES inventory system. Approval will be obtained prior to posting adjustments, and access to record adjustments will be restricted to authorized personnel. 2. Standardized Documentation for Adjustments Each inventory adjustment will be supported by standardized documentation clearly explaining the nature, reason, and calculation of the adjustment, along with applicable supporting records (e.g., receiving documents, distribution records, shortage documentation). All documentation will be retained in accordance with USDA record retention requirements. 3. Reconciliation of Inventory Activity Management will implement a periodic (at least monthly) reconciliation of inventory receipts, distributions, and adjustments to CERES and the general ledger. Reconciling items will be investigated, resolved, and documented timely. 4. Monitoring of USDA Program Inventory Management will perform periodic reviews of inventory activity related to donated inventory and Tennessee and Mississippi USDA programs to ensure that adjustments are appropriate, approved, and accurately recorded. 5. Training and Ongoing Oversight Management will provide targeted training to staff involved in inventory and accounting processes regarding USDA Special Tests and Provisions requirements and the new approval and documentation procedures. Management will monitor compliance with these controls to ensure they are operating effectively. Expected Completion Date: Within 60–90 days Responsible Parties: Donavann Brooks, Inventory Control Manager (901-527-0422)

The Academies will implement a monitoring system to ensure there are no clerical errors recording data in the system.

Corrective Action Plan Finding Number 2025-002 Condition: At June 30, 2025, the District maintained fund balances in excess of three months’ average expenditures. Management Response/Plan: The District has created a Spend Down Plan for the food service program based off guidance from the Illinois State Board of Education. The District is working on replacing equipment and renovating cafeterias. Anticipated Date of completion: June 2026 Name of Contact Person: Melissa Geyman Sell

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF AGRICULTURE, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION – CHILD NUTRITION CLUSTER – FEDERAL ALN 10.553, 10.555, AND 10.559 2025-002 Internal Control Over Compliance with Allowable Activities Requirements Finding Summary 7 CFR § 210.8 requires the District to establish and maintain effective internal control over compliance with requirements applicable to federal program allowable activities, including meal count requirements applicable to child nutrition cluster federal programs. During our audit, we noted the District did not have sufficient controls over meals counts submitted for afterschool snack reimbursement claims. For two months tested, the District’s internal tracking records for afterschool snacks served did not agree to the meal counts submitted to the Minnesota Department of Education (MDE) for reimbursement. In both cases, the internal records had been altered after the meal counts submissions to the MDE had been completed to add eligible afterschool snacks that had been missed. This resulted in underclaimed meals for eligible snacks served. Corrective Action Plan Actions Planned – The District will review and update its policies and procedures relating to eligible afterschool snack meal tracking and reimbursement submission for its child nutrition cluster federal program to ensure compliance with the Uniform Guidance in the future. Official Responsible – The District’s Director of Food Service, Dorie Pavel. Planned Completion Date – June 30, 2026. Disagreement With or Explanation of Finding – The District agrees with this finding. Plan to Monitor – The District’s Director of Food Service, Dorie Pavel, will assure appropriate internal controls and procedures are updated and in place for afterschool snack meal tracking and reimbursement submission to ensure the accuracy of District claims for eligible meal reimbursements in the future.

Corrective Action Plan The Central Columbia School District respectfully submits the following corrective action plan for the year ended June 30, 2025. The findings from the Single Audit Report Year Ended June 30, 2025 included in the schedule of findings and questioned costs are discussed below. Finding 2025-001: Reporting Contact Person: Steven Dolak, Business Administrator Recommendation: The District should revise procedures to ensure the data entered into the claim for reimbursement is reviewed for accuracy prior to the report being submitted. Evidence of the approval of submission should be documented in writing, such as with an initial, to demonstrate the review of the information has been performed. Action: The Business Administrator will prepare the reports for submission. Prior to submitting the report through the reimbursement system, a second individual will review the information entered. Upon satisfactory completion of the review, the second individual will acknowledge review by initialing and dating the document(s). Date for Completion: This procedure will be implemented at the beginning of the 2025-26 school year.

FINDING 2025-002 Information on the federal program: Subject: Child Nutrition Cluster - Reporting Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 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 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. Context: During the testing of claim reimbursements, we noted that monthly reimbursements are prepared and reconciled by Food Service Director. The reimbursements are reviewed informally by the Treasurer but this review is not formally documented and therefore, auditable evidence of the review was not available. The lack of formal, documented review existed throughout the audit period. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding. Management will implement a formal, documented review of the monthly reimbursement claims submitted by the Food Service Director prior to submission to the State. Responsible Party and Timeline for Completion: The Food Service Director will prepare and reconcile monthly claims. The FSD will forward to the cafeteria supervisor for review. Both the FSD and cafeteria supervisor will sign off before being submitted to the state for reimbursement. This measure has already been implemented beginning with the November 2025 claim submitted in January 2026.