Corrective Action Plans

2025-001 – Allowable Activities/Allowable Costs Contact Person Responsible for Corrective Action: Wendy Bradstreet, RSU29 Business Manager Corrective Action: RSU29 has taken the following actions to address finding 2025-001: The district has been implementing new procedures and processes as of February 1, 2026, to correct the issues in question to comply with CFR(s): 2 CFR 200.303, to make sure we remain in compliance with OMB guidelines. Findings have been shared with the Food Services Director and training has been utilized from guidance and resources provided by the Maine Department of Education Nutrition Services site which include financial training and procurement practices and resources provided by the USDA School Nutrition Program regulations (7 CFR Part 210, 215, 220). Internal approvals have been revised to have not only the Food Service Director approving purchases, but an approval from the district Business Manager prior to payment of invoices to vendors. A copy of the OMB Circulars containing the CFR guidelines have been received and reviewed by the Business Manager and applicable grant managers/coordinators to implement a more stringent internal control process and procedure to ensure all requirements are followed. The Business Manager has updated the district’s Food Service Director and central office staff of applicable guidelines to ensure compliance of all projects that is being paid for by federal and/or state funding. Anticipated Completion Date: June 30, 2026.

FINDING 2025-002 Finding Subject: Subject: Child Nutrition Cluster - Eligibility Contact Person Responsible for Corrective Action: Josh Sinclair, Food Service Director and Allison Vanover, Corporation Treasurer. Contact Phone Number 812-246-3375 Email Address: jsinclair@scsc.school avanover@scsc.school Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Food Service Director will collaborate with the IT Department to verify the accuracy of income parameters and Direct Certification eligibility data within Infinite Campus. A representative sample of student records will be tested to confirm that the uploaded information was processed correctly and aligns with supporting documentation. Any discrepancies identified will be corrected promptly, and procedures will be reinforced to ensure ongoing accuracy and compliance. Anticipated Completion Date: January 2026

FINDING 2025-006 Finding Subject: Child Nutrition Cluster - Internal Controls Audit Finding: Material Weakness Contact Person Responsible for Corrective Action: Annette King and Chrystal Street Contact Phone Number and Email Address: ellenprince@crothersville.k12.in.us; aking@crothersville.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: To address this finding, the district has strengthened its internal control procedures by implementing an additional level of review and authorization. All applicable reports, reimbursement requests, and compliance documentation will now require multiple signatures, including both the preparer and a designated supervisory or administrative reviewer, prior to submission. Anticipated Completion Date: January 2026

Corrective Action Plan Finding 2025-001 Condition: A journal entry was tested during the compliance audit that reclassified $50,000 of employee health costs to the school lunch fund that did not include any documentation of the costs charged to the school lunch fund and how they were allocated. Corrective Action Planned: Effective July 1, 2025, the District began to implement a structured and documented cost allocation process for employee healthcare expenses attributable to the Food Services Department. Beginning in FY26: • Charges will be processed monthly to ensure transparency, consistency, and proper budget tracking. Anticipated Completion Date: Ongoing Contact: Richard Poor, Director of Finance & Operations

Response and Corrective Action Plan: The District will implement a process to review and retain records used in determining eligibility as outlined by the Iowa Department of Education and Office of Management and Budget.

2025-004 REPORTING – CASH MANAGEMENT IMPROVEMENT ACT WEST VIRGINIA STATE TREASURER’S OFFICE (WVSTO) Assistance Listing Numbers: 10.551/10.561/10.555/17.225/20.205/84.010/84.027/84.425/93.558/93.568/ 93.575/93.658/93.659/93.767/93.778/97.036 For the Annual Report filing deadline, December 31, 2025, WVSTO staff experienced multiple extenuating circumstances including training of newer staff members, medical treatments, illness, and the sudden unexpected passing of a close family member. Realizing that these circumstances would interfere with the timely submission of the Annual Report, an extension was requested on December 30, 2025, with the Bureau of the Fiscal Service and was granted through Friday, January 9, 2026. Regrettably, the extenuating circumstances were not fully resolved by that date, and the report was ultimately submitted on January 14, 2026. The WVSTO remained focused on completing the Report but overlooked the need to request an additional extension. WVSTO staff subsequently met with Angela Smith, Director of the Bureau of the Fiscal Service and staff members Mary Bailey and Christopher Bush from the Revenue Collections Management Team. Director Smith confirmed there will be no penalties assessed due to the late filing. Additionally, WVSTO Banking Services staff will review the internal timeline of CMIA activities and procedures to ensure that future reporting is complete and submitted in a timely manner.

2025-005 REPORTING – FEDERAL FUNDING ACCOUNTABILITY AND TRANSPARENCY ACT (FFATA) DEPARTMENT OF EDUCATION (DOE) Assistance Listing Numbers: 10.553/10.555/10.556/10.559/10.582 During FY 2025, the FFATA reporting system changed from the FSRS site to SAM.gov. Many transactions that were originally entered into the FSRS site did not transfer over and had to be re-entered into SAM.gov, making those entries appear late. In addition, we had trouble getting the SAM.gov site to accept our FFATA entries. DOE worked with SAM.gov customer support to eventually get the issues resolved, but this also resulted in late reporting. Subsequent to the systematic issues being resolved, all FFATA reports have been completed timely and will continue to be reported timely going forward.

Finding Synopsis: One employee's payroll disbursement made under the Child Nutrition Cluster was improperly calculated. Action Steps: A district staff member will review the payroll calculations so no transpositions or errors occur. Contact Person(s): Dr. Jennifer Garrison, Superintendent Anticipated Completion Date: February 11, 2026

2025-003: Internal Control over Eligibility – Child Nutrition Cluster Corrective Action: Acknowledging the lack of controls within the Child Nutrition program's eligibility process, the District has determined that hiring additional staff to resolve this internal control deficiency is not a cost-effective solution. Consequently, the Food Service Director and the Finance Director share the responsibility of reviewing student eligibility forms. Responsible Person: Danielle Mittermeyer Anticipated Completion Date: Ongoing

Finding 2025-002: Allowable cost and activities – Significant deficiency in internal controls over compliance. Management Response: The School has implemented procedures to ensure that key control documentation is retained on file. The payroll file will be approved by either the Superintendent or the CFO prior to payment, and proof of prior approval will be maintained in the School’s files. The new process began in January 2026. Responsible Party: Kemlyn Williams, Superintendent Dynamic Support Solutions, Contract CFO

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