Corrective Action Plans

Department: Education Title: Internal control over CNC claim reimbursements needs improvement Questioned Costs: Known: ALN 10.559 $61,336 ALN 10.582 $12,215 Likely: ALN 10.559 undeterminable ALN 10.582 undeterminable Status: Corrective action in progress Corrective Action: The Department will create a business requirements document for the SFSP site sheet and claims camp/closed enrolled eligibility edit checks. The non-congregate application now requires sponsors’ to have a written procedure to address site proximity, this is captured in an offline form in the checklist document. The Department submitted a ticket to update the FNS report so it will collect the data needed. For the FFVP, a tracking procedure is in place for SFY 2026 to stay within the $50-75/student rate. A spreadsheet is being used to track this information and has been implemented. Completion Date: March 4, 2026 (first item), June 30, 2025 (second and fourth items), and March 19, 2025 (third item) Agency Contact: Jane McLucas, Director of Child Nutrition, DOE, 207-624-6880

Department: Education Title: Internal control over CNC eligibility needs improvement Questioned Costs: Known: ALN 10.555 $73,683 ALN 10.559 $226,773 Likely: ALN 10.555 undeterminable ALN 10.559 undeterminable Status: Corrective action in progress Corrective Action: The Department will create a business requirements document for the SFSP site sheet and claims camp/closed enrolled eligibility edit checks. The Department will create a user guide to approve the site info sheet and apps to address oversite errors with the approval process. A financial eligibility edit check in the software will be implemented for program year 2026. A policy statement for non-congregate was a required document with an edit check in program year 2025. Completion Date: March 2, 2026, April 30, 2026, April 15, 2026, and May 1, 2025, respectively Agency Contact: Jane McLucas, Director of Child Nutrition, DOE, 207-624-6880

The District will strengthen controls to ensure all service contracts, including those charged to federal programs, are approved by the Board of Education and entered into the official minutes prior to execution and payment, in accordance with 2 C.F.R. § 200.318(a), state law, and District policy. Effective immediately, all service contracts will be submitted for Board approval before services begin. No contract will be executed and no purchase order will be issued without documented Board approval. Accounts payale will verify Board approval prior to processing payment. Procurement personnel and Federal program staff will receive training on Uniform Guidance procurement requirements, including suspension and debarment procedures. The Business Manager will perform reviews on Federal program expenditures to ensure ongoing compliance. The District believes these measures will correct the defiency and prevent recurrence.

Corrective Action Plan: The Department is a partnering agency for this program and does not manage the disbursement of funds. However, as a partnering agency for the program, the Department will continue updating its internal controls over the Summer Electronic Benefits Transfer (EBT) program’s eligibility determinations to ensure only eligible students are receiving benefits. These procedures will include regular communication to school districts, expanded data fields, school submission of a single combined enrollment and benefits file, and additional verification of the accuracy and completeness of the student data submitted by the districts to ensure only eligible students are approved to receive benefits. Since the questioned costs were isolated to calendar year 2024, and the Department has taken steps to correct the issue, this issue should not reoccur. The Department will work with Job and Family Services (JFS) to resolve the identified questioned costs. If needed, this will include evaluating the projected questionable costs to determine the actual amount that may have been disbursed to ineligible students and assisting JFS efforts to address those disbursements. Anticipated Completion Date for Corrective Action: May 2026 Contact Person Responsible for Corrective Action: Name: Corey Fronk Title: Administrator of Audits and Risk Management Address: 25 S. Front Street, 7th Floor; Columbus, OH 43215 Phone Number: (614) 644-7812 E-Mail Address: Corey.Fronk@education.ohio.gov

Corrective Action Plan: The Department has designated and implemented additional internal controls over Transparency Act reporting to ensure that the Child Nutrition Cluster expenditures are timely and accurately entered into the SAM.gov website. These procedures include several edit checks of the data before it is uploaded as well as a reconciliation of the reported data to ensure compiance with federal regulations. Anticipated Completion Date for Corrective Action: Completed December 2025 Contact Person Responsible for Corrective Action: Name: Corey Fronk Title: Administrator of Audits and Risk Management Address: 25 S. Front Street, 7th Floor; Columbus, OH 43215 Phone Number: (614) 644-7812 E-Mail Address: Corey.Fronk@education.ohio.gov

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 10.556) 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, including maintaining appropriate documentation. Official Responsible – Dawn Duevel, Business Services Director. Planned Completion Date – June 30, 2026. Disagreement With or Explanation of Finding – The District agrees with this finding. Plan to Monitor – Dawn Duevel, Business Services Director, will assure appropriate internal controls and procedures are in place to ensure compliance with suspension and debarment requirements.

Recommendation: We recommend the Department implement effective processes and procedures to ensure reported information is accurate and aligns with underlying data Views of responsible officials: Open – Views of responsible officials and management’s planned corrective actions, timeline and designation of what employee position are responsible for meeting deadlines in the timeline. The Division of Vocational Rehabilitation agrees with the findings and, as such, will implement regular reviews of federal expenditures and period of performance. The DVR General ledger team will meet quarterly with the Chief Financial Officer and review all federal expenditures to be recorded timely and accurately. DVR will also continue to meet with program field staff to ensure obligations are within the appropriate period. Position: CFO Timeline: 06/30/2025

Recommendation: We recommend the Department review the instructions for completion of the FFATA reports with training provided to the program staff who are preparing and reviewing the FFATA reports to ensure submitted reports are timely and complete. We recommend the Department implement effective processes and procedures to maintain the submitted reports and the documentation used to prepare the reports in the files of the Department. Views of responsible officials: ALN 10.555: Open – Views of responsible officials and management’s planned corrective actions, timeline and designation of what employee position are responsible for meeting deadlines in the timeline. ALN 84.425U The SSFS staff is currently working on adding all pertinent subawards. However, it has proven difficult to get access to our staff via the FFATA helpdesk. We are diligently trying to solve such issues as not knowing the previous owner of these grants in the FFATA system in order to transfer this ownership to the current staff. The Director and Deputy Director of the Student, School, and Family Support (SSFS) Bureau are responsible for ensuring the FFATA reporting is completed by March 31, 2025. ALN 21.029 Open – Views of responsible officials and management’s planned corrective actions, timeline and designation of what employee position are responsible for meeting deadlines in the timeline. ALN 84.365: Open – Views of responsible officials and management’s planned corrective actions, timeline and designation of what employee position are responsible for meeting deadlines in the timeline. ALN 84.367: Open – Views of responsible officials and management’s planned corrective actions, timeline and designation of what employee position are responsible for meeting deadlines in the timeline. The Division of Vocational Rehabilitation agrees with the findings and, as such, will implement regular reviews of federal expenditures and period of performance. The DVR General ledger team will meet quarterly with the Chief Financial Officer and review all federal expenditures to be recorded timely and accurately. DVR will also continue to meet with program field staff to ensure obligations are within the appropriate period. Position: CFO Timeline: 06/30/2025

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 Program, School Summer Food Service Program, School Fresh Fruit & Vegetable Program Assistance Listing Number: 10.553, 10.555, 10.559, 10.582 Federal Award Numbers and Years (or Other Identifying Numbers): FY2024, FY2025 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement Audit Finding: Significant Deficiency Context: For the two small purchase method procurements sampled for testing, we noted that the School Corporation did not obtain quotes from any other qualified sources. The sample items amount disbursed was $102,648 in FY24 and $102,083 in FY25 for the purchase of refrigerators and flooring upgrades. The School Corporation did properly perform a suspension and debarment check on both vendors. Contact Person Responsible for Corrective Action: Laura Hubinger Contact Phone Number: 812-288-4802 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Continued training for staff, when other quotes cannot be obtained additional documentation of such will be kept and provided. Anticipated Completion Date: Resolved, March 2026

Management agrees with the finding. MSDWC will continue to review and verify that applications and direct certifications are accurate and are coded correctly in the Skyward SIS/FS system. Corrective action plan has been implemented as this finding impacted fiscal year 2024 but did not recur in fiscal year 2025. The district’s CFO will oversee the corrective action plan, in coordination with the Food Service Director, to monitor the eligibility requirements on an ongoing basis.

Management agrees with the finding. MSDWC will obtain the required number of qualified quotes whenever possible and maintain documentation of each quote for each purchase for the duration of the audit period. Corrective action plan has been implemented as this finding impacted fiscal year 2024 but did not recur in fiscal year 2025. The district’s CFO will oversee the corrective action plan, in coordination with the Food Service Director, to monitor the procurement process requirements on an ongoing basis.

The Tennessee Department of Agriculture concurs. To ensure effective internal controls over inventory at storage locations for school food distribution, the Tennessee Department of Agriculture added the risk of not complying with inventory requirements for school food to our Financial Integrity Act risk assessment along with the following mitigating controls: 1 - Monthly inventory reports are required to be sent by each of the three school food warehouses to the Commodities team. 2 - Developed monitoring guides and have begun using those guides to assist with warehouse visits. The Tennessee Department of Agriculture has a plan to begin observing inventory annually. We completed our first warehouse visit in February 2026 and anticipate completing visits to the other two warehouses by September 30, 2026. In addition to the annual on-site inventory observation, internal monthly inventory monitoring has been added to the duties of the Commodities team. Warehouses are now required to submit monthly inventory reports by the 10th of each month which are then analyzed by the team. The Tennessee Department of Agriculture is looking at ways to add a permanent position to the Commodities team. We have tried getting an additional position approved in the budget and we are exploring the possibility of repurposing vacant positions within the department. Finally, the Tennessee Department of Agriculture's special projects team has been looking at SOPs in place as well as the need for SOPs in areas without them. The Commodities team is next on the list for special projects to help with drafting and revising SOPs. The department plans to use this opportunity to establish written procedures that outline responsibilities for the school food program to help us ensure compliance with federal requirements. The Commodity Distribution Administrator will be responsible for ensuring corrective actions are implemented by the anticipated completion date of December 31, 2026.

The Tennessee Department of Education (TDOE) concurs. The Tennessee Department of Education State Director of School Nutrition, Senior Compliance and Data Manager, and Data Processing and Reporting Specialist have been working with the Federal Funding and Accountability Transparency Act (FFATA) System for Award Management (SAM) administrators to submit the required reports. The department is pursuing both internal practice adjustments and external collaboration with the United States Department of Agriculture (USDA) to ensure proper reporting. Internally, the department is working to develop an application programming interface (API) between the department’s nutrition data system and the recently updated federal reporting system to promote seamless report submissions. Externally, the department is collaborating with the Office of the CFO for the United States Department of Agriculture (USDA), noting the lack of more robust bulk upload options in the federal reporting system compared to the prior system. The department, alongside other states, continues to work with USDA to determine more efficient bulk upload options to streamline federal data reporting. The department will continue to leverage both these efforts to ensure reporting requirements are met. The Tennessee Department of Education has created and deployed a standard operating procedure (SOP) to inform staff of the responsibilities our office has in uploading the required reports. The department will also include a certification process in its standard operating procedures so that reports are reviewed prior to submission in the SAM platform.

Reference Number: 2025-004 No secondary review of meal claim reimbursements prior to submission Corrective Action Plan: The District will implement procedures that incorporate a second review of meal reimbursement claims before the request is submitted for reimbursement during the monthly processing. Contact Person: Cristina Campbell Implementation Time Frame: August 31, 2026

Finding 2025-400: Child Nutrition Cluster—Federal Funding Accountability and Transparency Act Reporting: Planned Corrective Action: The Department of Public Instruction (DPI) will complete and submit reports for subaward information in the FFATA Subaward Reporting System (FSRS) for the Child Nutrition Cluster (CNC) beginning in June 2025. Beginning with June 2025 awards reporting has been completed by the applicable due date (June 2025 awards, reported by July 31, 2025, etc) The internal processes established to ensure proper reporting of subaward has been updated to include payments made for Child Nutrition Cluster grants. Upon completion of the required reporting, a summary of all Child Nutrition Cluster awards is submitted to the Department of Administration, providing the FAIN, Amount, and Date Reported. Anticipated Completion Date: July 2025. Person responsible for corrective action: Michael Brendel, Section Leader Bureau of School Financial Services Division for Libraries & Technology (working title: Division of School & Library Operations) Department of Public Instruction michael.brendel@dpi.wi.gov

Name of Contact Person: Jonathan Green, Superintendent. Recommendation: We recommend the District expand their internal controls to require a responsible official to review the daily meal count reports for accuracy prior to submission of the reports to the Illinois State Board of Education. Corrective Action: Daily meal counts will be reviewed by administration on a monthly basis. Proposed Completion Date: Immediately.

Name of Contact Person: Jonathan Green, Superintendent. Recommendation: We recommend that all food solicitation include the proper language to ensure that food products comply with the Buy American Provision. Corrective Action: We will ensure this language is included in all food solicitations going forward. Proposed Completion Date: Fiscal Year 2026.

FINDING 2025-005 Finding Subject: Child Nutrition Cluster - Reporting Audit Findings: Material Weakness, Other Matters Contact Person Responsible for Corrective Action: Lela Simmons, CFO Contact Phone Number and Email Address: 219 391 4100 Ex 12365: lesimmons@ecps.org Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: The Food Service director responsibilities is to overseeing all function of the Food Management Company. Food Service Director will be required to draft internal controls and detail instruction for the school corporation to ensure all documentation procedures match the FSMC invoice. The school corporation will upgrade all POS software throughout the district. Students will be required to scan Student IDs to account for all meals served. Counts will be check weekly to ensure Federal report is accurate. Anticipated Completion Date: We anticipate having the above corrective action plan in place by October 31, 2026

FINDING 2025-003 Finding Subject: Child Nutrition Cluster - Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Special Tests and Provisions - Non-Profit School Food Service Accounts Audit Findings: Material Weakness Contact Person Responsible for Corrective Action: Lela Simmons, CFO Contact Phone Number and Email Address: 219 391 4100 Ex 12365: lesimmons@ecps.org Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: The Food Service director responsibilities are to oversee all functions of the Food Management Company. Food Service Director will be required to draft internal controls and detail instruction for the school corporation to ensure all documentation procedures match the FSMC invoice. The school corporation will not pay any unallowable cost by state regulation and rules. All state reporting documents and invoice will continue to be reviewed and signed off by the district CFO. A copy of all documents will be held in the food director office Anticipated Completion Date: We anticipate having the above corrective action plan in place by October 31, 2026

Finding Number: 2025‐001 Program Name/Assistance Listing Title: Child Nutrition Cluster Assistance Listing Numbers: 10.553, 10.555, 10.559 Contact Person: Business Manager, Food Service Director, and Business Office Staff Anticipated Completion Date: June 30, 2026 Planned Corrective Action: The following corrections will be implemented. 1. Review and update procedures for calculating indirect costs in accordance with USDA Memo SP 60‐2016 and 2 CFR Part 200. 2. Ensure use of the ADE‐approved unrestricted indirect cost rate annually. 3. Implement a standardized calculation worksheet to document allowable indirect cost limits. 4. Require review and approval of indirect cost calculations by the Business Manager prior to posting. 5. Provide training to business office staff on federal cost principles and Child Nutrition requirements. 6. Perform periodic internal reviews to ensure compliance.

FINDING 2025-004 Finding Subject: Child Nutrition Cluster – Internal Controls - Procurement and Suspension and Debarment Summary of Finding: The Rush County SFA follows procurement standards in accordance with 2 CFR Part 200. All purchases are conducted using the appropriate procurement method based on dollar thresholds. For contracts exceeding $25,000, the Rush County SFA verifies vendors are not suspended or debarred through the System for Award Management (SAM) and retains documentation in the procurement file. Written procedures include conflict of interest standards and documentation requirements. Contact Person Responsible for Corrective Action: Julie Cramer Contact Phone Number and Email Address: (765) 932-4186, cramerj@rushville.k12.in.us Views of Responsible Officials: Option 1: “We concur with the finding.” Description of Corrective Action Plan: The Rush County SFA maintains written procurement procedures that include verification of suspension and debarment status in accordance with 2 CFR 200.214. These procedures apply to all federally funded child nutrition purchases, including food service equipment. Prior to awarding any contract or purchase order exceeding the $25,000 threshold for Suspension and Debarment requirements, the Rush County Schools Assistant Superintendent and or Superintendent along with the Food Service Director will verify in SAM the vendor’s status as to whether the entity is suspended or debarred from receiving federal grant funds. To ensure proper segregation of duties the Food Service Director conducts the SAM verification and maintains documentation. The Assistant Superintendent and or Superintendent will review and give approval for the purchase prior to final award. The dual review process ensures compliance and oversight with the Suspension and Debarment requirements. Anticipated Completion Date: March 31, 2026

FINDING 2025-003 Finding Subject: Child Nutrition Cluster – Internal Controls - Eligibility Summary of Finding: There was no documented evidence of the Director of Food Service reviewing the eligibility determinations for free and reduced lunches that were made by the Cafeteria Secretary during the audit period. Contact Person Responsible for Corrective Action: Julie Cramer Contact Phone Number and Email Address: 765-932-4186, cramerj@rushville.k12.in.us Views of Responsible Officials: Option 1: “We concur with the finding.” Description of Corrective Action Plan: The Middle School Cafeteria Secretary will contact parents regarding verifications of their free/reduced lunch application information. This information will then be reviewed by the Director of Food Service, to determine whether the information is accurate. Parents are always notified on any changes to the lunch status for students. Both the Cafeteria Secretary and the Director of Food Service will sign off on each application to document that reviews were performed. Anticipated Completion Date: March 3, 2026

FINDING 2025-004 Finding Subject: Child Nutrition Cluster- Suspension and Debarment Contact Person Responsible for Corrective Action: Jeff Layden Contact Phone Number and Email Address: 765.457.8101, jeff.layden@nwsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Jeff Layden, Director of Operations, oversees our food service department. He will work with our food service vendor to ensure EPLS are checked before awarding any contract for goods or services. Anticipated Completion Date: Immediate. INDIANA STATE

FINDING 2025-003 Finding Subject: Child Nutrition Cluster- Internal Controls Contact Person Responsible for Corrective Action: Camden Parkhurst Contact Phone Number and Email Address: 765.457.8101, camden.parkhurst@nwsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Activities Allowed or Unallowed, Allowable Cost/Cost Principals E-Funds has been automatically debited from our account since its inception. The auto debt was falling at a time each month that caused us to miss adding to our Allowance of Claims. We will correct the time that this is added to our statements so that it will make the Allowance of Claims for each month. Eligibility This was a one time issue when we were switching our software to Meal Magic. This was only related to one direct certification cluster to start the 23-24 school year. We have multiple people from our food service department prepare and sign off on direct certifications on a monthly basis to ensure we are accurate and complaint. Anticipated Completion Date: Immediate. INDIANA STATE

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.