Corrective Action Plans

The District will establish and maintain internal controls that will safeguard District assets to the best of their abilities.

Planned Corrective Action: ● Since learning of this issue, our Food Service Director has manually checked every application. ● Our Food Service Director is rewriting our policy to include reviewing at least 2 applications per week for any week in which 2 or more applications are received through PaySchools. We intend to fully implement this policy with the start of the 2025-26 school year. ● This new policy will allow us to randomly verify applications throughout the year to be sure that all Federal guidelines are being met. Anticipated Completion Date: In Process Responsible Contact Person: Tim Walker, Treasurer

As of result of finding for federal procurement requirements the District has reviewed the procurement requirements with the food service director and staff. In addition, the district has reviewed current spending with vendors within food services to determine procurement requirements for 25-26 fiscal year. This review will be done on an annual basis. In the future the district will review and document the requirements of the awarding agency to ensure they align with our own requirements based on local spending patterns. The district did implement these changes for 2024-2025 Fiscal Year.

Daily meal county reports will be reviewed and verified that it agrees to the edit check worksheets prior to monthly reimbursement submission. Any differences will be properly investigated and resolved.

Edit Check Worksheets will be matched to requests for State of NJ Division of Agriculture reimbursement on a monthly basis for accuracy.

Corrective Action: Coastal Harvest will begin tracking all inventory on hand by source, including receipts, distributions, waste/loss, and any other adjustments, and will perform periodic reconciliations of amounts recorded in the inventory system and amounts recognized in the general ledger to ensure accurate USDA food commodities inventory recordkeeping compliance. Further, Coastal Harvest will include specific inventory policies and procedure in the manual discussed in the corrective action for finding 2022-001. Anticipated Completion Date: June 30, 2025

Beginning in fiscal year 2025, the District has implemented the Community Eligibility Provision (CEP) at all three of its school buildings. The CEP program is in place for four years and it will not be necessary for the District to verify income for free and reduced school lunches during that time period. If in the future the District no longer participates in CEP, control procedures will be implemented to ensure that all students selected for income verification are being correctly categorized and reported to ODEW. This will include the Cafeteria Manager reviewing the free and reduced lunch applications and forwarding any without necessary documentation to the Superintendent and Treasurer for additional verification for eligibility.

All electronic free and reduced meal applications are completed in the PaySchools system. Since PaySchools does not have a SOC1 for Ohio eligibility, all applications will be sent to a pending folder requiring the Food Service Director to review and approve the determination before providing it to the parents/guardians. They began this process reaching out to PaySchools 3/5/2025 and making the change to the account. Because this process started mid-year, the School District will review all of the approved applications prior to 3/31/2025 to avoid a comment in the future.

The district has reviewed the time and effort issues with the new food service director, and going forward the Treasurer will see that all time and effort sheets are signed by both the employee and supervisor.

Finding No.: 2024-001S Condition: The Confirmation Review and Verification Tracking Form was filled out incorrectly and was incomplete. Plan:Management will implement procedures to ensure that the review and verification process is done correctly. Anticipated Date of Completion: 6/30/2026 Name of Contact Person: Kreg Wesley, Executive Director of Finance and Operations

The District has already been in contact with PaySchools. PaySchools will now put all application information in "Pending Status" and the District will be responsible for review and verification. The District did go back and verify that all applications that were approved by PaySchools did in fact meet the threshold levels for all benefits that were approved and denied.

RIDE is currently evaluating third-party consultants in order to have the following services performed: • A cybersecurity assessment performed of the overall agency using the NIST Framework • A cybersecurity assessment of our internal applications including CNP Connect & Accelegrants • An updated business continuity plan • A Vendor Risk Assessment Program Development Through the above deliverables from the selected consultant, RIDE will be able to have a better understanding of gaps in IT/ Cybersecurity throughout the agency, as well as the applications cited by the Auditor General. Anticipated Completion Date: December 31, 2025 Contact Person: Brandon Bohl, Finance Director, Department of Elementary and Secondary Educationbrandon.bohl@ride.ri.gov

RIDE’s Office of School Health & Wellness will develop a guidance document for LEAs regarding Paid Lunch Equity calculations and send communication at least annually to ensure LEAs have complied with 7 CFR Sec. 210.14(e). Anticipated Completion Date: June 30, 2026 Contact Persons: Brandon Bohl, Finance Director, Department of Elementary and Secondary Education brandon.bohl@ride.ri.gov Rosemary Reilly-Chammat, Director – Office of School Health & Wellness, Department of Elementary and Secondary Education rosemary.reilly-chammat@ride.ri.gov Jennifer Goodwin, School Health Specialist, Department of Elementary and Secondary Education jennifer.goodwin@ride.ri.gov

To eliminate the issue with stock discrepancies, the Central Distribution Center (CDC) will be incorporating updated software targeted toward minimizing inventory errors with the receipt, storage, and distribution of all commodities that come into the CDC. The CDC recently implemented handheld scanners for tracking purposes and stock management. The scanners have new upgrades that are designed to improve inventory picking procedures. The CDC is currently in the process of making this upgrade into our system and expects to have this fully implemented by May 31, 2025. In addition to the new software, we are at the beginning stages of a warehouse reorganization which will include a new storage location labeling system which is being designed with the intention of creating a more structured storage system for all products. In conjunction with the handheld scanners, the labeling system will include barcodes for inventory which will be matched to storage location. These labels are magnetic, durable, and removable and can be repositioned to any rack location in the warehouse as needed. We will immediately start automated cycle counts daily to detect and correct discrepancies early to ensure all issues with inventory are caught and addressed as early as possible. Similarly, the CDC will also be implementing a quarterly full inventory count with the first one occurring no later than May 31, 2025. Stock discrepancies are a major challenge but by incorporating the right strategies they can be eliminated. By leveraging automation, enforcing standard procedures, and continuously monitoring inventory we will improve our inventory efficiency. Anticipated Completion Date: May 31, 2025 Contact Persons: Terrence McNamara, Administrator Physical Resources, Department of Corrections terrence.mcnamara@doc.ri.gov Matthew Wiencis, Chief Distribution Officer, Department of Corrections matthew.wiencis@doc.ri.gov

RIDE has hired a full-time fiscal officer to oversee these programs from a fiscal perspective and maintain compliance with reporting requirements including the SF-425. RIDE is currently hiring for a program person who will assist the fiscal officer with reporting compliance. Anticipated Completion Date: Ongoing Contact Persons: Brandon Bohl, Finance Director, Department of Elementary and Secondary Education brandon.bohl@ride.ri.gov Rosemary Reilly-Chammat, Director – Office of School Health & Wellness, Department of Elementary and Secondary Education rosemary.reilly-chammat@ride.ri.gov

We have prepared procedures for Federal Funding Accountability and Transparency Act (FFATA) reporting specifically for USDA. We shifted a current GaDOE accounting manager's job duties to include assisting the Assistant Director of Accounting with overall FFATA reporting duties. The addition of an experienced staff member to assist with FFATA data gathering, reconciling, and reporting will allow for the Assistant Director of Accounting to focus on completing the more complex FFATA Reporting for USDA in a timely manner.

The District acknowledges this finding. Due to its size, it is not cost effective to have more than one person in the food service department working with the claims. The District will assign someone in the District office to review all claims. Shannon Grindell, Susan Mayer Ongoing

Going forward, Edison Local Schools Eligibility process to determine Free/Reduced/Denied Status of applications submitted for the National School Lunch Program are: All applications collected at Edison Local School will be reviewed prior to the data entered into pay schools to ensure the applications have all the information and data to make the correct determination. The income eligibility criteria is established by the Ohio Department of Education. The eligibility for paper applications will be made by the food service director and the superintendent is the determining official and each application is reviewed prior to entering this into the POS system, and a free/reduced and benefits issuance reports is compared to ensure all information is correct after it is entered to ensure the determination is correct, additionally annual verification is also done on free/reduced applications.

Child Nutrition implemented a new policy/procedure for handling free and reduced applications effective July 1, 2024.

2024-031 Department of Education Implement controls to ensure FFATA reporting is completed for all required subawards Management Response: ODE agrees with this finding. To strengthen controls and ensure FFATA reporting is completed for all required subawards, ODE plans to implement the following process improvements: • Collaborate with the Child Nutrition program management and Fiscal Grants team to provide full documentation of grant awards including terms, conditions and attachments. • Update ODE’s grant profile request Smartsheet tool to: o Identify FFATA eligibility prior to setting up a new grant award in the accounting system. o Automatically notify the FFATA team of new grant awards that require reporting. Anticipated Completion Date: June 30, 2025 Contact person: Kristie Miller, Accounting Director

2024-031 Department of Education Implement controls to ensure FFATA reporting is completed for all required subawards Management Response: ODE agrees with this finding. To strengthen controls and ensure FFATA reporting is completed for all required subawards, ODE plans to implement the following process improvements: • Collaborate with the Child Nutrition program management and Fiscal Grants team to provide full documentation of grant awards including terms, conditions and attachments. • Update ODE’s grant profile request Smartsheet tool to: o Identify FFATA eligibility prior to setting up a new grant award in the accounting system. o Automatically notify the FFATA team of new grant awards that require reporting. Anticipated Completion Date: June 30, 2025 Contact person: Kristie Miller, Accounting Director

The School District will implement monitoring control procedures to review software system eligibility determinations to ensure compliance with federal income guidelines.

Child Nutrition Cluster – Eligibility The finding is a material weakness in internal control over federal awards due to incorrect eligibility determination entered into the Food Service System. The District will train individuals involved in the eligibility process on correct processes and reviews and implement controls to prevent the improper determination of eligibility. Responsible official: Janice Boucher, Finance Manager, jboucher@shawanoschools.org Anticipated Completion Date: June 30, 2025

The Board has developed procedures to ensure that all purchase orders are approved before orders are placed, all expenditures are properly authorized by the respective program director and supporting documentation is adequately maintained. The Board is using a requisition form in Droplet to achieve this goal. All employees authorized to make or approve purchases have been trained on purchasing procedures outlined in the Purchasing Policies and Procedures Manual for Local Educational Agencies in the State of West Virginia by the WVDE Office of School Finance on 2/23/2024.

The Board will establish procedures that will ensure compliance with requirements of the United States Department of Education's equipment management requirements and the WV Department of Education's inventory requirements.