Audit 299959

FINDING 2023-005 Information on the federal program: Federal Agency: Department of Labor Pass-Through Entity: Indiana Department of Workforce Development Federal Program: WIOA Assistance Listing Number: 17.258, 17.259, 17.278 Compliance Requirement: Activities Allowed or Unallowed Audit Findings: Material Weakness, Qualified Opinion Criteria: 2 CFR 200.403 establishes principles and standards for determining costs for federal awards carried out through grants, cost reimbursement contracts, and other agreements with state and local governments. To be allowable, under federal awards, cost must meet certain criteria: a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. g) Be adequately documented. h) Cost must be incurred during the approved budget period. Additionally, 2 CFR 200.303 indicates that non-Federal Entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations and terms and conditions of the Federal award. Condition: For 15 of the 60 samples selected, EmployIndy was unable to provide adequate support for the selection amounts. As a result, we were unable to determine the allowability of these sample selections under the WIOA grant. Cause: The condition was caused by a lack of internal controls over WIOA subrecipient/service provider claims for accrued expenditures and indirect costs. Effect: As a result of these matters, expenditures could be inaccurately charged to the federal grant. Questioned costs: There are $45,619 of known questioned costs as this is the amount of the WIOA expenditures tested that could not be reconciled to source documents. Context: During our testing procedures over WIOA disbursements for the activities allowed or unallowed compliance requirement, the following were identified: • For two of our 60 non-payroll selections management was unable to provide adequate supporting documentation for the expenditure. These selections pertained to the subrecipient, Eckerd Connects. Questioned costs of $7,303 were noted. • For four of our 60 non-payroll selections, management was able to provide a summary listing of charges by category (AER report), however, supporting invoices or other documents for the summary of charges was not provided. Questioned costs of $20,501 were noted. • For two of our 60 non-payroll selections in which expenditures related to personnel and fringe expenses, we noted the expenses allocated to WIOA Youth, Adult, and Dislocated Worker grants based on a set percentage rather than time actually spent working on grant related projects. Both instances pertain to charges incurred by the subrecipient, Eckerd Connects. No questioned costs were noted. • For six of our 60 non-payroll selections, we noted indirect costs charged by subrecipients that did not have proper support for the indirect cost rate for the period under audit. Five of the selections were Eckerd Connects and one related to Telamon Corporation. Per inquiry of management, Eckerd and Telamon have a federally approved indirect cost rate. Management provided a signed contract with Eckerd that covers the period January 1, 2020 to June 30, 2021 that lists the federally approved rate. The Telamon contract/application provided covers the period of July 1, 2021 to June 30, 2022. Management was unable to provide support stating the federally approved rate for Eckerd and Telamon for the period under audit. No questioned costs were noted. • One of our 60 non-payroll selections was for EmployIndy indirect costs of $17,815. Management provided a calculation of the indirect costs, from which we selected specific charges from the cost pool that the indirect cost was calculated from. Management was unable to provide support for any of the selected charges. Questioned costs of $17,815 were noted. Identification as a repeat finding, if applicable: This is a repeat finding. Appeared as finding 2022-005 in the prior report. Recommendation: We recommend that management implement a consistent multi-stage review process for expenditures that are to be allocated to the WIOA cluster and that management clearly organize and retain records of purchase to support amounts being listed as expenditures on their SEFA. Views of responsible officials and planned corrective actions: Management acknowledges the finding. See management’s corrective action plan attached to this audit report.

FINDING 2023-005 Information on the federal program: Federal Agency: Department of Labor Pass-Through Entity: Indiana Department of Workforce Development Federal Program: WIOA Assistance Listing Number: 17.258, 17.259, 17.278 Compliance Requirement: Activities Allowed or Unallowed Audit Findings: Material Weakness, Qualified Opinion Criteria: 2 CFR 200.403 establishes principles and standards for determining costs for federal awards carried out through grants, cost reimbursement contracts, and other agreements with state and local governments. To be allowable, under federal awards, cost must meet certain criteria: a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. g) Be adequately documented. h) Cost must be incurred during the approved budget period. Additionally, 2 CFR 200.303 indicates that non-Federal Entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations and terms and conditions of the Federal award. Condition: For 15 of the 60 samples selected, EmployIndy was unable to provide adequate support for the selection amounts. As a result, we were unable to determine the allowability of these sample selections under the WIOA grant. Cause: The condition was caused by a lack of internal controls over WIOA subrecipient/service provider claims for accrued expenditures and indirect costs. Effect: As a result of these matters, expenditures could be inaccurately charged to the federal grant. Questioned costs: There are $45,619 of known questioned costs as this is the amount of the WIOA expenditures tested that could not be reconciled to source documents. Context: During our testing procedures over WIOA disbursements for the activities allowed or unallowed compliance requirement, the following were identified: • For two of our 60 non-payroll selections management was unable to provide adequate supporting documentation for the expenditure. These selections pertained to the subrecipient, Eckerd Connects. Questioned costs of $7,303 were noted. • For four of our 60 non-payroll selections, management was able to provide a summary listing of charges by category (AER report), however, supporting invoices or other documents for the summary of charges was not provided. Questioned costs of $20,501 were noted. • For two of our 60 non-payroll selections in which expenditures related to personnel and fringe expenses, we noted the expenses allocated to WIOA Youth, Adult, and Dislocated Worker grants based on a set percentage rather than time actually spent working on grant related projects. Both instances pertain to charges incurred by the subrecipient, Eckerd Connects. No questioned costs were noted. • For six of our 60 non-payroll selections, we noted indirect costs charged by subrecipients that did not have proper support for the indirect cost rate for the period under audit. Five of the selections were Eckerd Connects and one related to Telamon Corporation. Per inquiry of management, Eckerd and Telamon have a federally approved indirect cost rate. Management provided a signed contract with Eckerd that covers the period January 1, 2020 to June 30, 2021 that lists the federally approved rate. The Telamon contract/application provided covers the period of July 1, 2021 to June 30, 2022. Management was unable to provide support stating the federally approved rate for Eckerd and Telamon for the period under audit. No questioned costs were noted. • One of our 60 non-payroll selections was for EmployIndy indirect costs of $17,815. Management provided a calculation of the indirect costs, from which we selected specific charges from the cost pool that the indirect cost was calculated from. Management was unable to provide support for any of the selected charges. Questioned costs of $17,815 were noted. Identification as a repeat finding, if applicable: This is a repeat finding. Appeared as finding 2022-005 in the prior report. Recommendation: We recommend that management implement a consistent multi-stage review process for expenditures that are to be allocated to the WIOA cluster and that management clearly organize and retain records of purchase to support amounts being listed as expenditures on their SEFA. Views of responsible officials and planned corrective actions: Management acknowledges the finding. See management’s corrective action plan attached to this audit report.

FINDING 2023-005 Information on the federal program: Federal Agency: Department of Labor Pass-Through Entity: Indiana Department of Workforce Development Federal Program: WIOA Assistance Listing Number: 17.258, 17.259, 17.278 Compliance Requirement: Activities Allowed or Unallowed Audit Findings: Material Weakness, Qualified Opinion Criteria: 2 CFR 200.403 establishes principles and standards for determining costs for federal awards carried out through grants, cost reimbursement contracts, and other agreements with state and local governments. To be allowable, under federal awards, cost must meet certain criteria: a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. g) Be adequately documented. h) Cost must be incurred during the approved budget period. Additionally, 2 CFR 200.303 indicates that non-Federal Entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations and terms and conditions of the Federal award. Condition: For 15 of the 60 samples selected, EmployIndy was unable to provide adequate support for the selection amounts. As a result, we were unable to determine the allowability of these sample selections under the WIOA grant. Cause: The condition was caused by a lack of internal controls over WIOA subrecipient/service provider claims for accrued expenditures and indirect costs. Effect: As a result of these matters, expenditures could be inaccurately charged to the federal grant. Questioned costs: There are $45,619 of known questioned costs as this is the amount of the WIOA expenditures tested that could not be reconciled to source documents. Context: During our testing procedures over WIOA disbursements for the activities allowed or unallowed compliance requirement, the following were identified: • For two of our 60 non-payroll selections management was unable to provide adequate supporting documentation for the expenditure. These selections pertained to the subrecipient, Eckerd Connects. Questioned costs of $7,303 were noted. • For four of our 60 non-payroll selections, management was able to provide a summary listing of charges by category (AER report), however, supporting invoices or other documents for the summary of charges was not provided. Questioned costs of $20,501 were noted. • For two of our 60 non-payroll selections in which expenditures related to personnel and fringe expenses, we noted the expenses allocated to WIOA Youth, Adult, and Dislocated Worker grants based on a set percentage rather than time actually spent working on grant related projects. Both instances pertain to charges incurred by the subrecipient, Eckerd Connects. No questioned costs were noted. • For six of our 60 non-payroll selections, we noted indirect costs charged by subrecipients that did not have proper support for the indirect cost rate for the period under audit. Five of the selections were Eckerd Connects and one related to Telamon Corporation. Per inquiry of management, Eckerd and Telamon have a federally approved indirect cost rate. Management provided a signed contract with Eckerd that covers the period January 1, 2020 to June 30, 2021 that lists the federally approved rate. The Telamon contract/application provided covers the period of July 1, 2021 to June 30, 2022. Management was unable to provide support stating the federally approved rate for Eckerd and Telamon for the period under audit. No questioned costs were noted. • One of our 60 non-payroll selections was for EmployIndy indirect costs of $17,815. Management provided a calculation of the indirect costs, from which we selected specific charges from the cost pool that the indirect cost was calculated from. Management was unable to provide support for any of the selected charges. Questioned costs of $17,815 were noted. Identification as a repeat finding, if applicable: This is a repeat finding. Appeared as finding 2022-005 in the prior report. Recommendation: We recommend that management implement a consistent multi-stage review process for expenditures that are to be allocated to the WIOA cluster and that management clearly organize and retain records of purchase to support amounts being listed as expenditures on their SEFA. Views of responsible officials and planned corrective actions: Management acknowledges the finding. See management’s corrective action plan attached to this audit report.

FINDING 2023-005 Information on the federal program: Federal Agency: Department of Labor Pass-Through Entity: Indiana Department of Workforce Development Federal Program: WIOA Assistance Listing Number: 17.258, 17.259, 17.278 Compliance Requirement: Activities Allowed or Unallowed Audit Findings: Material Weakness, Qualified Opinion Criteria: 2 CFR 200.403 establishes principles and standards for determining costs for federal awards carried out through grants, cost reimbursement contracts, and other agreements with state and local governments. To be allowable, under federal awards, cost must meet certain criteria: a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. g) Be adequately documented. h) Cost must be incurred during the approved budget period. Additionally, 2 CFR 200.303 indicates that non-Federal Entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations and terms and conditions of the Federal award. Condition: For 15 of the 60 samples selected, EmployIndy was unable to provide adequate support for the selection amounts. As a result, we were unable to determine the allowability of these sample selections under the WIOA grant. Cause: The condition was caused by a lack of internal controls over WIOA subrecipient/service provider claims for accrued expenditures and indirect costs. Effect: As a result of these matters, expenditures could be inaccurately charged to the federal grant. Questioned costs: There are $45,619 of known questioned costs as this is the amount of the WIOA expenditures tested that could not be reconciled to source documents. Context: During our testing procedures over WIOA disbursements for the activities allowed or unallowed compliance requirement, the following were identified: • For two of our 60 non-payroll selections management was unable to provide adequate supporting documentation for the expenditure. These selections pertained to the subrecipient, Eckerd Connects. Questioned costs of $7,303 were noted. • For four of our 60 non-payroll selections, management was able to provide a summary listing of charges by category (AER report), however, supporting invoices or other documents for the summary of charges was not provided. Questioned costs of $20,501 were noted. • For two of our 60 non-payroll selections in which expenditures related to personnel and fringe expenses, we noted the expenses allocated to WIOA Youth, Adult, and Dislocated Worker grants based on a set percentage rather than time actually spent working on grant related projects. Both instances pertain to charges incurred by the subrecipient, Eckerd Connects. No questioned costs were noted. • For six of our 60 non-payroll selections, we noted indirect costs charged by subrecipients that did not have proper support for the indirect cost rate for the period under audit. Five of the selections were Eckerd Connects and one related to Telamon Corporation. Per inquiry of management, Eckerd and Telamon have a federally approved indirect cost rate. Management provided a signed contract with Eckerd that covers the period January 1, 2020 to June 30, 2021 that lists the federally approved rate. The Telamon contract/application provided covers the period of July 1, 2021 to June 30, 2022. Management was unable to provide support stating the federally approved rate for Eckerd and Telamon for the period under audit. No questioned costs were noted. • One of our 60 non-payroll selections was for EmployIndy indirect costs of $17,815. Management provided a calculation of the indirect costs, from which we selected specific charges from the cost pool that the indirect cost was calculated from. Management was unable to provide support for any of the selected charges. Questioned costs of $17,815 were noted. Identification as a repeat finding, if applicable: This is a repeat finding. Appeared as finding 2022-005 in the prior report. Recommendation: We recommend that management implement a consistent multi-stage review process for expenditures that are to be allocated to the WIOA cluster and that management clearly organize and retain records of purchase to support amounts being listed as expenditures on their SEFA. Views of responsible officials and planned corrective actions: Management acknowledges the finding. See management’s corrective action plan attached to this audit report.

FINDING 2023-006 Information on the federal program: Federal Agency: Department of Labor Pass-Through Entity: Indiana Department of Workforce Development Federal Program: WIOA Assistance Listing Number: 17.258, 17.259, 17.278 Compliance Requirement: Activities Allowed or Unallowed Audit Findings: Material Weakness, Internal Controls Criteria: 2 CFR 200.403 establishes principles and standards for determining costs for federal awards carried out through grants, cost reimbursement contracts, and other agreements with state and local governments. To be allowable, under federal awards, cost must meet certain criteria: a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. g) Be adequately documented. h) Cost must be incurred during the approved budget period. Additionally, 2 CFR 200.303 indicates that non-Federal Entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations and terms and conditions of the Federal award. Condition: EmployIndy did not formally review and approve 12 selected WIOA non-payroll expenditures in a sample of 60 to determine that they are allowable under the WIOA federal regulations. Cause: The condition was caused by a lack of internal controls over WIOA subrecipient/service provider claims for accrued expenditures. Effect: As a result of these matters, expenditures could be inaccurately charged to the federal grant. Questioned costs: There are no questioned costs. Context: During our testing procedures over WIOA disbursements for the activities allowed or unallowed compliance requirement, we identified expenditures that are not formally reviewed by management for allowability under the WIOA grant. Identification as a repeat finding, if applicable: This is a repeat finding. Appeared as finding 2022-006 in the prior report. Recommendation: We recommend that management implement a consistent multi-stage review process for expenditures that are to be allocated to the WIOA cluster and that management clearly organize and retain records of purchase to support amounts being listed as expenditures on their SEFA. Views of responsible officials and planned corrective actions: Management acknowledges the finding. See management’s corrective action plan attached to this audit report.

FINDING 2023-006 Information on the federal program: Federal Agency: Department of Labor Pass-Through Entity: Indiana Department of Workforce Development Federal Program: WIOA Assistance Listing Number: 17.258, 17.259, 17.278 Compliance Requirement: Activities Allowed or Unallowed Audit Findings: Material Weakness, Internal Controls Criteria: 2 CFR 200.403 establishes principles and standards for determining costs for federal awards carried out through grants, cost reimbursement contracts, and other agreements with state and local governments. To be allowable, under federal awards, cost must meet certain criteria: a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. g) Be adequately documented. h) Cost must be incurred during the approved budget period. Additionally, 2 CFR 200.303 indicates that non-Federal Entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations and terms and conditions of the Federal award. Condition: EmployIndy did not formally review and approve 12 selected WIOA non-payroll expenditures in a sample of 60 to determine that they are allowable under the WIOA federal regulations. Cause: The condition was caused by a lack of internal controls over WIOA subrecipient/service provider claims for accrued expenditures. Effect: As a result of these matters, expenditures could be inaccurately charged to the federal grant. Questioned costs: There are no questioned costs. Context: During our testing procedures over WIOA disbursements for the activities allowed or unallowed compliance requirement, we identified expenditures that are not formally reviewed by management for allowability under the WIOA grant. Identification as a repeat finding, if applicable: This is a repeat finding. Appeared as finding 2022-006 in the prior report. Recommendation: We recommend that management implement a consistent multi-stage review process for expenditures that are to be allocated to the WIOA cluster and that management clearly organize and retain records of purchase to support amounts being listed as expenditures on their SEFA. Views of responsible officials and planned corrective actions: Management acknowledges the finding. See management’s corrective action plan attached to this audit report.

FINDING 2023-006 Information on the federal program: Federal Agency: Department of Labor Pass-Through Entity: Indiana Department of Workforce Development Federal Program: WIOA Assistance Listing Number: 17.258, 17.259, 17.278 Compliance Requirement: Activities Allowed or Unallowed Audit Findings: Material Weakness, Internal Controls Criteria: 2 CFR 200.403 establishes principles and standards for determining costs for federal awards carried out through grants, cost reimbursement contracts, and other agreements with state and local governments. To be allowable, under federal awards, cost must meet certain criteria: a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. g) Be adequately documented. h) Cost must be incurred during the approved budget period. Additionally, 2 CFR 200.303 indicates that non-Federal Entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations and terms and conditions of the Federal award. Condition: EmployIndy did not formally review and approve 12 selected WIOA non-payroll expenditures in a sample of 60 to determine that they are allowable under the WIOA federal regulations. Cause: The condition was caused by a lack of internal controls over WIOA subrecipient/service provider claims for accrued expenditures. Effect: As a result of these matters, expenditures could be inaccurately charged to the federal grant. Questioned costs: There are no questioned costs. Context: During our testing procedures over WIOA disbursements for the activities allowed or unallowed compliance requirement, we identified expenditures that are not formally reviewed by management for allowability under the WIOA grant. Identification as a repeat finding, if applicable: This is a repeat finding. Appeared as finding 2022-006 in the prior report. Recommendation: We recommend that management implement a consistent multi-stage review process for expenditures that are to be allocated to the WIOA cluster and that management clearly organize and retain records of purchase to support amounts being listed as expenditures on their SEFA. Views of responsible officials and planned corrective actions: Management acknowledges the finding. See management’s corrective action plan attached to this audit report.

FINDING 2023-006 Information on the federal program: Federal Agency: Department of Labor Pass-Through Entity: Indiana Department of Workforce Development Federal Program: WIOA Assistance Listing Number: 17.258, 17.259, 17.278 Compliance Requirement: Activities Allowed or Unallowed Audit Findings: Material Weakness, Internal Controls Criteria: 2 CFR 200.403 establishes principles and standards for determining costs for federal awards carried out through grants, cost reimbursement contracts, and other agreements with state and local governments. To be allowable, under federal awards, cost must meet certain criteria: a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. g) Be adequately documented. h) Cost must be incurred during the approved budget period. Additionally, 2 CFR 200.303 indicates that non-Federal Entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations and terms and conditions of the Federal award. Condition: EmployIndy did not formally review and approve 12 selected WIOA non-payroll expenditures in a sample of 60 to determine that they are allowable under the WIOA federal regulations. Cause: The condition was caused by a lack of internal controls over WIOA subrecipient/service provider claims for accrued expenditures. Effect: As a result of these matters, expenditures could be inaccurately charged to the federal grant. Questioned costs: There are no questioned costs. Context: During our testing procedures over WIOA disbursements for the activities allowed or unallowed compliance requirement, we identified expenditures that are not formally reviewed by management for allowability under the WIOA grant. Identification as a repeat finding, if applicable: This is a repeat finding. Appeared as finding 2022-006 in the prior report. Recommendation: We recommend that management implement a consistent multi-stage review process for expenditures that are to be allocated to the WIOA cluster and that management clearly organize and retain records of purchase to support amounts being listed as expenditures on their SEFA. Views of responsible officials and planned corrective actions: Management acknowledges the finding. See management’s corrective action plan attached to this audit report.

FINDING 2023-007 Information on the federal program: Federal Agency: Department of Labor Pass-Through Entity: Indiana Department of Workforce Development Federal Program: WIOA Assistance Listing Number: 17.258, 17.259, 17.278 Compliance Requirement: Subrecipient Monitoring Audit Findings: Material Weakness, Qualified Opinion Criteria: Title 2 Subtitle A Chapter II Part 200 Subpart D, Section 200.331 and 200.332, establishes requirements that pass-through entities must adhere to in regard to their subrecipient grant agreements and the monitoring processes of those subrecipients. Condition: The EmployIndy subrecipient, Eckerd Connects, was reimbursed for personnel and fringe expenses that were allocated to the WIOA grants based off of a fixed allocation percentage for each Assistance Listing Number (ALN) instead of actual time worked on the grant. Cause: The condition was caused by a lack of internal controls over WIOA subrecipient/service provider claims for accrued expenditures. Effect: As a result of these matters, expenditures could be inaccurately charged to the federal grant. Questioned costs: There are no questioned costs. Context: During testing, Crowe identified monthly accrued expenditures of the Eckerd Connects subrecipient in which a fixed allocation for the separate WIOA grants was used each month to allocate personnel and fringe expenses. Identification as a repeat finding, if applicable: This is a repeat finding. Appeared as finding 2022-008 in the prior report. Recommendation: We recommend EmployIndy review subrecipient source documents to ensure accrued expenditures are appropriately supported by invoices or time-records showing time on task spent on specific grants. Views of responsible officials and planned corrective actions: Management acknowledges the finding. See management’s corrective action plan attached to this audit report.

FINDING 2023-007 Information on the federal program: Federal Agency: Department of Labor Pass-Through Entity: Indiana Department of Workforce Development Federal Program: WIOA Assistance Listing Number: 17.258, 17.259, 17.278 Compliance Requirement: Subrecipient Monitoring Audit Findings: Material Weakness, Qualified Opinion Criteria: Title 2 Subtitle A Chapter II Part 200 Subpart D, Section 200.331 and 200.332, establishes requirements that pass-through entities must adhere to in regard to their subrecipient grant agreements and the monitoring processes of those subrecipients. Condition: The EmployIndy subrecipient, Eckerd Connects, was reimbursed for personnel and fringe expenses that were allocated to the WIOA grants based off of a fixed allocation percentage for each Assistance Listing Number (ALN) instead of actual time worked on the grant. Cause: The condition was caused by a lack of internal controls over WIOA subrecipient/service provider claims for accrued expenditures. Effect: As a result of these matters, expenditures could be inaccurately charged to the federal grant. Questioned costs: There are no questioned costs. Context: During testing, Crowe identified monthly accrued expenditures of the Eckerd Connects subrecipient in which a fixed allocation for the separate WIOA grants was used each month to allocate personnel and fringe expenses. Identification as a repeat finding, if applicable: This is a repeat finding. Appeared as finding 2022-008 in the prior report. Recommendation: We recommend EmployIndy review subrecipient source documents to ensure accrued expenditures are appropriately supported by invoices or time-records showing time on task spent on specific grants. Views of responsible officials and planned corrective actions: Management acknowledges the finding. See management’s corrective action plan attached to this audit report.

FINDING 2023-007 Information on the federal program: Federal Agency: Department of Labor Pass-Through Entity: Indiana Department of Workforce Development Federal Program: WIOA Assistance Listing Number: 17.258, 17.259, 17.278 Compliance Requirement: Subrecipient Monitoring Audit Findings: Material Weakness, Qualified Opinion Criteria: Title 2 Subtitle A Chapter II Part 200 Subpart D, Section 200.331 and 200.332, establishes requirements that pass-through entities must adhere to in regard to their subrecipient grant agreements and the monitoring processes of those subrecipients. Condition: The EmployIndy subrecipient, Eckerd Connects, was reimbursed for personnel and fringe expenses that were allocated to the WIOA grants based off of a fixed allocation percentage for each Assistance Listing Number (ALN) instead of actual time worked on the grant. Cause: The condition was caused by a lack of internal controls over WIOA subrecipient/service provider claims for accrued expenditures. Effect: As a result of these matters, expenditures could be inaccurately charged to the federal grant. Questioned costs: There are no questioned costs. Context: During testing, Crowe identified monthly accrued expenditures of the Eckerd Connects subrecipient in which a fixed allocation for the separate WIOA grants was used each month to allocate personnel and fringe expenses. Identification as a repeat finding, if applicable: This is a repeat finding. Appeared as finding 2022-008 in the prior report. Recommendation: We recommend EmployIndy review subrecipient source documents to ensure accrued expenditures are appropriately supported by invoices or time-records showing time on task spent on specific grants. Views of responsible officials and planned corrective actions: Management acknowledges the finding. See management’s corrective action plan attached to this audit report.

FINDING 2023-007 Information on the federal program: Federal Agency: Department of Labor Pass-Through Entity: Indiana Department of Workforce Development Federal Program: WIOA Assistance Listing Number: 17.258, 17.259, 17.278 Compliance Requirement: Subrecipient Monitoring Audit Findings: Material Weakness, Qualified Opinion Criteria: Title 2 Subtitle A Chapter II Part 200 Subpart D, Section 200.331 and 200.332, establishes requirements that pass-through entities must adhere to in regard to their subrecipient grant agreements and the monitoring processes of those subrecipients. Condition: The EmployIndy subrecipient, Eckerd Connects, was reimbursed for personnel and fringe expenses that were allocated to the WIOA grants based off of a fixed allocation percentage for each Assistance Listing Number (ALN) instead of actual time worked on the grant. Cause: The condition was caused by a lack of internal controls over WIOA subrecipient/service provider claims for accrued expenditures. Effect: As a result of these matters, expenditures could be inaccurately charged to the federal grant. Questioned costs: There are no questioned costs. Context: During testing, Crowe identified monthly accrued expenditures of the Eckerd Connects subrecipient in which a fixed allocation for the separate WIOA grants was used each month to allocate personnel and fringe expenses. Identification as a repeat finding, if applicable: This is a repeat finding. Appeared as finding 2022-008 in the prior report. Recommendation: We recommend EmployIndy review subrecipient source documents to ensure accrued expenditures are appropriately supported by invoices or time-records showing time on task spent on specific grants. Views of responsible officials and planned corrective actions: Management acknowledges the finding. See management’s corrective action plan attached to this audit report.

FINDING 2023-008 Information on the federal program: Federal Agency: Department of Labor Pass-Through Entity: Indiana Department of Workforce Development Federal Program: WIOA Assistance Listing Number: 17.258, 17.259, 17.278 Compliance Requirement: Subrecipient Monitoring Audit Findings: Material Weakness, Qualified Opinion Criteria: Title 2 Subtitle A Chapter II Part 200 Subpart D, Section 200.331 and 200.332, establishes requirements that pass-through entities must adhere to in regard to their subrecipient grant agreements and the monitoring processes of those subrecipients. Condition: Through our auditing procedures on subrecipient monitoring compliance requirements, we noted that there was missing award information in the subrecipient contracts that are required per Section 200.332 (a)(1) federal award identification. These missing pieces of information included Federal award identification such as: 1. Subrecipient’s unique identifier 2. Federal award identification number 3. Federal award date 4. Subaward period of performance start and end date 5. Assistance Listings numbers 6. Indirect cost rate for Federal award per CFA subsection 200.414 In addition, EmployIndy does not clearly distinguish within the agreement that the recipient of funding is either a “subrecipient” or a “contractor.” Cause: EmployIndy does not have an effective system of internal controls in place to effectively structure and review WIOA subaward agreements. Management uses their standard contractual agreement template. Effect: Due to lack of required information being present within the contracts and the contracts not clearly identifying between a subrecipient and a contractor, there could be noncompliance issues in how the funds are spent and recorded by the subrecipient, which could lead to noncompliance issues for EmployIndy and its subrecipients. Questioned costs: There are no questioned costs. Context: Subrecipients represented approximately 44%, $2,433,402, of the total award, $5,505,792. The condition reported was prevalent across each subrecipient participating in the award. Identification as a repeat finding, if applicable: This is a repeat finding. Appeared as finding 2022-009 in the prior report. Recommendation: We recommend that EmployIndy rework their contract agreements to clearly distinguish between subrecipients and contractors. EmployIndy should also review Title 2 Subtitle A Chapter II Part 200 Subpart D and ensure their contracts with subrecipients include all of the required information. Management should review their subrecipient monitoring and management policies for subcontractor and contractor determinations, federal award identification, and subrecipient risk assessment and monitoring procedures for each unique federal award. Views of responsible officials and planned corrective actions: Management acknowledges the finding. See management’s corrective action plan attached to this audit report.

FINDING 2023-008 Information on the federal program: Federal Agency: Department of Labor Pass-Through Entity: Indiana Department of Workforce Development Federal Program: WIOA Assistance Listing Number: 17.258, 17.259, 17.278 Compliance Requirement: Subrecipient Monitoring Audit Findings: Material Weakness, Qualified Opinion Criteria: Title 2 Subtitle A Chapter II Part 200 Subpart D, Section 200.331 and 200.332, establishes requirements that pass-through entities must adhere to in regard to their subrecipient grant agreements and the monitoring processes of those subrecipients. Condition: Through our auditing procedures on subrecipient monitoring compliance requirements, we noted that there was missing award information in the subrecipient contracts that are required per Section 200.332 (a)(1) federal award identification. These missing pieces of information included Federal award identification such as: 1. Subrecipient’s unique identifier 2. Federal award identification number 3. Federal award date 4. Subaward period of performance start and end date 5. Assistance Listings numbers 6. Indirect cost rate for Federal award per CFA subsection 200.414 In addition, EmployIndy does not clearly distinguish within the agreement that the recipient of funding is either a “subrecipient” or a “contractor.” Cause: EmployIndy does not have an effective system of internal controls in place to effectively structure and review WIOA subaward agreements. Management uses their standard contractual agreement template. Effect: Due to lack of required information being present within the contracts and the contracts not clearly identifying between a subrecipient and a contractor, there could be noncompliance issues in how the funds are spent and recorded by the subrecipient, which could lead to noncompliance issues for EmployIndy and its subrecipients. Questioned costs: There are no questioned costs. Context: Subrecipients represented approximately 44%, $2,433,402, of the total award, $5,505,792. The condition reported was prevalent across each subrecipient participating in the award. Identification as a repeat finding, if applicable: This is a repeat finding. Appeared as finding 2022-009 in the prior report. Recommendation: We recommend that EmployIndy rework their contract agreements to clearly distinguish between subrecipients and contractors. EmployIndy should also review Title 2 Subtitle A Chapter II Part 200 Subpart D and ensure their contracts with subrecipients include all of the required information. Management should review their subrecipient monitoring and management policies for subcontractor and contractor determinations, federal award identification, and subrecipient risk assessment and monitoring procedures for each unique federal award. Views of responsible officials and planned corrective actions: Management acknowledges the finding. See management’s corrective action plan attached to this audit report.

FINDING 2023-008 Information on the federal program: Federal Agency: Department of Labor Pass-Through Entity: Indiana Department of Workforce Development Federal Program: WIOA Assistance Listing Number: 17.258, 17.259, 17.278 Compliance Requirement: Subrecipient Monitoring Audit Findings: Material Weakness, Qualified Opinion Criteria: Title 2 Subtitle A Chapter II Part 200 Subpart D, Section 200.331 and 200.332, establishes requirements that pass-through entities must adhere to in regard to their subrecipient grant agreements and the monitoring processes of those subrecipients. Condition: Through our auditing procedures on subrecipient monitoring compliance requirements, we noted that there was missing award information in the subrecipient contracts that are required per Section 200.332 (a)(1) federal award identification. These missing pieces of information included Federal award identification such as: 1. Subrecipient’s unique identifier 2. Federal award identification number 3. Federal award date 4. Subaward period of performance start and end date 5. Assistance Listings numbers 6. Indirect cost rate for Federal award per CFA subsection 200.414 In addition, EmployIndy does not clearly distinguish within the agreement that the recipient of funding is either a “subrecipient” or a “contractor.” Cause: EmployIndy does not have an effective system of internal controls in place to effectively structure and review WIOA subaward agreements. Management uses their standard contractual agreement template. Effect: Due to lack of required information being present within the contracts and the contracts not clearly identifying between a subrecipient and a contractor, there could be noncompliance issues in how the funds are spent and recorded by the subrecipient, which could lead to noncompliance issues for EmployIndy and its subrecipients. Questioned costs: There are no questioned costs. Context: Subrecipients represented approximately 44%, $2,433,402, of the total award, $5,505,792. The condition reported was prevalent across each subrecipient participating in the award. Identification as a repeat finding, if applicable: This is a repeat finding. Appeared as finding 2022-009 in the prior report. Recommendation: We recommend that EmployIndy rework their contract agreements to clearly distinguish between subrecipients and contractors. EmployIndy should also review Title 2 Subtitle A Chapter II Part 200 Subpart D and ensure their contracts with subrecipients include all of the required information. Management should review their subrecipient monitoring and management policies for subcontractor and contractor determinations, federal award identification, and subrecipient risk assessment and monitoring procedures for each unique federal award. Views of responsible officials and planned corrective actions: Management acknowledges the finding. See management’s corrective action plan attached to this audit report.

FINDING 2023-008 Information on the federal program: Federal Agency: Department of Labor Pass-Through Entity: Indiana Department of Workforce Development Federal Program: WIOA Assistance Listing Number: 17.258, 17.259, 17.278 Compliance Requirement: Subrecipient Monitoring Audit Findings: Material Weakness, Qualified Opinion Criteria: Title 2 Subtitle A Chapter II Part 200 Subpart D, Section 200.331 and 200.332, establishes requirements that pass-through entities must adhere to in regard to their subrecipient grant agreements and the monitoring processes of those subrecipients. Condition: Through our auditing procedures on subrecipient monitoring compliance requirements, we noted that there was missing award information in the subrecipient contracts that are required per Section 200.332 (a)(1) federal award identification. These missing pieces of information included Federal award identification such as: 1. Subrecipient’s unique identifier 2. Federal award identification number 3. Federal award date 4. Subaward period of performance start and end date 5. Assistance Listings numbers 6. Indirect cost rate for Federal award per CFA subsection 200.414 In addition, EmployIndy does not clearly distinguish within the agreement that the recipient of funding is either a “subrecipient” or a “contractor.” Cause: EmployIndy does not have an effective system of internal controls in place to effectively structure and review WIOA subaward agreements. Management uses their standard contractual agreement template. Effect: Due to lack of required information being present within the contracts and the contracts not clearly identifying between a subrecipient and a contractor, there could be noncompliance issues in how the funds are spent and recorded by the subrecipient, which could lead to noncompliance issues for EmployIndy and its subrecipients. Questioned costs: There are no questioned costs. Context: Subrecipients represented approximately 44%, $2,433,402, of the total award, $5,505,792. The condition reported was prevalent across each subrecipient participating in the award. Identification as a repeat finding, if applicable: This is a repeat finding. Appeared as finding 2022-009 in the prior report. Recommendation: We recommend that EmployIndy rework their contract agreements to clearly distinguish between subrecipients and contractors. EmployIndy should also review Title 2 Subtitle A Chapter II Part 200 Subpart D and ensure their contracts with subrecipients include all of the required information. Management should review their subrecipient monitoring and management policies for subcontractor and contractor determinations, federal award identification, and subrecipient risk assessment and monitoring procedures for each unique federal award. Views of responsible officials and planned corrective actions: Management acknowledges the finding. See management’s corrective action plan attached to this audit report.

FINDING 2023-009 Information on the federal program: Federal Agency: Department of the Treasury Pass-Through Entity: The Indianapolis Foundation and The City of Indianapolis Federal Program: Coronavirus State and Fiscal Recovery Funds Assistance Listing Number: 21.027 Compliance Requirement: Subrecipient Monitoring Audit Findings: Material Weakness, Qualified Opinion Criteria: Title 2 Subtitle A Chapter II Part 200 Subpart D, Section 200.331 and 200.332, establishes requirements that pass-through entities must adhere to in regard to their subrecipient grant agreements and the monitoring processes of those subrecipients. Condition: Through our auditing procedures on subrecipient monitoring compliance requirements, we noted that management did not have support indicating monitoring of subrecipients was performed to ensure the subrecipient used the subaward for authorized purposes in compliance with federal statutes, regulations, and the terms and conditions of the subaward. This instance was noted for the subrecipient for the Education-to-Employment Pipeline and Talent Pipeline grants. Additionally, Crowe noted that Training for Success was written into the Elevation grant as EmployIndy’s partner. However, expenditures to Training for Success were not reported as subrecipient funding on the SEFA. As EmployIndy did not report Training for Success as a subrecipient, EmployIndy did not perform monitoring procedures. Cause: EmployIndy does not have an effective system of internal controls in place to effectively structure and review SLFRF subaward activity. Effect: Due to lack of required information being present, there could be noncompliance issues in how the funds are spent and recorded by the subrecipient, which could lead to noncompliance issues for EmployIndy and its subrecipients. Questioned costs: There are no questioned costs. Context: Subrecipients represented approximately 51%, $508,035, of the total ALN award, $987,698. The condition reported was prevalent across each subrecipient participating in the award. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: We recommend that EmployIndy review their subrecipient monitoring and management policies for subcontractor and contractor determinations, federal award identification, and subrecipient risk assessment and monitoring procedures for each unique federal award. Views of responsible officials and planned corrective actions: Management acknowledges the finding. See management’s corrective action plan attached to this audit report.

FINDING 2023-009 Information on the federal program: Federal Agency: Department of the Treasury Pass-Through Entity: The Indianapolis Foundation and The City of Indianapolis Federal Program: Coronavirus State and Fiscal Recovery Funds Assistance Listing Number: 21.027 Compliance Requirement: Subrecipient Monitoring Audit Findings: Material Weakness, Qualified Opinion Criteria: Title 2 Subtitle A Chapter II Part 200 Subpart D, Section 200.331 and 200.332, establishes requirements that pass-through entities must adhere to in regard to their subrecipient grant agreements and the monitoring processes of those subrecipients. Condition: Through our auditing procedures on subrecipient monitoring compliance requirements, we noted that management did not have support indicating monitoring of subrecipients was performed to ensure the subrecipient used the subaward for authorized purposes in compliance with federal statutes, regulations, and the terms and conditions of the subaward. This instance was noted for the subrecipient for the Education-to-Employment Pipeline and Talent Pipeline grants. Additionally, Crowe noted that Training for Success was written into the Elevation grant as EmployIndy’s partner. However, expenditures to Training for Success were not reported as subrecipient funding on the SEFA. As EmployIndy did not report Training for Success as a subrecipient, EmployIndy did not perform monitoring procedures. Cause: EmployIndy does not have an effective system of internal controls in place to effectively structure and review SLFRF subaward activity. Effect: Due to lack of required information being present, there could be noncompliance issues in how the funds are spent and recorded by the subrecipient, which could lead to noncompliance issues for EmployIndy and its subrecipients. Questioned costs: There are no questioned costs. Context: Subrecipients represented approximately 51%, $508,035, of the total ALN award, $987,698. The condition reported was prevalent across each subrecipient participating in the award. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: We recommend that EmployIndy review their subrecipient monitoring and management policies for subcontractor and contractor determinations, federal award identification, and subrecipient risk assessment and monitoring procedures for each unique federal award. Views of responsible officials and planned corrective actions: Management acknowledges the finding. See management’s corrective action plan attached to this audit report.

FINDING 2023-009 Information on the federal program: Federal Agency: Department of the Treasury Pass-Through Entity: The Indianapolis Foundation and The City of Indianapolis Federal Program: Coronavirus State and Fiscal Recovery Funds Assistance Listing Number: 21.027 Compliance Requirement: Subrecipient Monitoring Audit Findings: Material Weakness, Qualified Opinion Criteria: Title 2 Subtitle A Chapter II Part 200 Subpart D, Section 200.331 and 200.332, establishes requirements that pass-through entities must adhere to in regard to their subrecipient grant agreements and the monitoring processes of those subrecipients. Condition: Through our auditing procedures on subrecipient monitoring compliance requirements, we noted that management did not have support indicating monitoring of subrecipients was performed to ensure the subrecipient used the subaward for authorized purposes in compliance with federal statutes, regulations, and the terms and conditions of the subaward. This instance was noted for the subrecipient for the Education-to-Employment Pipeline and Talent Pipeline grants. Additionally, Crowe noted that Training for Success was written into the Elevation grant as EmployIndy’s partner. However, expenditures to Training for Success were not reported as subrecipient funding on the SEFA. As EmployIndy did not report Training for Success as a subrecipient, EmployIndy did not perform monitoring procedures. Cause: EmployIndy does not have an effective system of internal controls in place to effectively structure and review SLFRF subaward activity. Effect: Due to lack of required information being present, there could be noncompliance issues in how the funds are spent and recorded by the subrecipient, which could lead to noncompliance issues for EmployIndy and its subrecipients. Questioned costs: There are no questioned costs. Context: Subrecipients represented approximately 51%, $508,035, of the total ALN award, $987,698. The condition reported was prevalent across each subrecipient participating in the award. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: We recommend that EmployIndy review their subrecipient monitoring and management policies for subcontractor and contractor determinations, federal award identification, and subrecipient risk assessment and monitoring procedures for each unique federal award. Views of responsible officials and planned corrective actions: Management acknowledges the finding. See management’s corrective action plan attached to this audit report.

FINDING 2023-010 Information on the federal program: Federal Agency: Department of the Treasury Pass-Through Entity: The Indianapolis Foundation and The City of Indianapolis Federal Program: Coronavirus State and Fiscal Recovery Funds Assistance Listing Number: 21.027 Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Significant Deficiency, Internal Controls Criteria: 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.318(i) states: "The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price." 2 CFR 200.320(b) states: "Procurement by small purchase procedures. Small purchase procedures are those relatively simple and informal procurement methods for securing services, supplies, or other property that do not cost more than the Simplified Acquisition Threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources." 2 CFR 180.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person." Condition: For one selected procurement, EmployIndy was unable to provide support indicating review of procurement documents. Cause: A proper system of internal controls was not implemented by management of the Organization, which would include segregation of key functions. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the Organization’s management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect: Without the proper implementation of an effectively designed system of internal controls, including policies and procedures that provide segregation of duties and additional oversight as needed, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the organization. Questioned costs: There are no questioned costs. Context: Management was unable to provide adequate support indicating preparation and review of procurement and suspension and debarment documents for the Plaid Agency. Crowe was only able to view the bid request and bid. Documents indicating rationale for awarding the contract were not provided. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: We recommend that management establish a proper system of internal control and develop policies and procedures to ensure all required documentation is retained and provided for purchases and to ensure contractors and subrecipients, as appropriate are not suspended, debarred, or otherwise excluded prior to entering into any contracts or subawards. Views of responsible officials and planned corrective actions: Management acknowledges the finding. See management’s corrective action plan attached to this audit report.

FINDING 2023-010 Information on the federal program: Federal Agency: Department of the Treasury Pass-Through Entity: The Indianapolis Foundation and The City of Indianapolis Federal Program: Coronavirus State and Fiscal Recovery Funds Assistance Listing Number: 21.027 Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Significant Deficiency, Internal Controls Criteria: 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.318(i) states: "The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price." 2 CFR 200.320(b) states: "Procurement by small purchase procedures. Small purchase procedures are those relatively simple and informal procurement methods for securing services, supplies, or other property that do not cost more than the Simplified Acquisition Threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources." 2 CFR 180.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person." Condition: For one selected procurement, EmployIndy was unable to provide support indicating review of procurement documents. Cause: A proper system of internal controls was not implemented by management of the Organization, which would include segregation of key functions. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the Organization’s management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect: Without the proper implementation of an effectively designed system of internal controls, including policies and procedures that provide segregation of duties and additional oversight as needed, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the organization. Questioned costs: There are no questioned costs. Context: Management was unable to provide adequate support indicating preparation and review of procurement and suspension and debarment documents for the Plaid Agency. Crowe was only able to view the bid request and bid. Documents indicating rationale for awarding the contract were not provided. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: We recommend that management establish a proper system of internal control and develop policies and procedures to ensure all required documentation is retained and provided for purchases and to ensure contractors and subrecipients, as appropriate are not suspended, debarred, or otherwise excluded prior to entering into any contracts or subawards. Views of responsible officials and planned corrective actions: Management acknowledges the finding. See management’s corrective action plan attached to this audit report.

FINDING 2023-010 Information on the federal program: Federal Agency: Department of the Treasury Pass-Through Entity: The Indianapolis Foundation and The City of Indianapolis Federal Program: Coronavirus State and Fiscal Recovery Funds Assistance Listing Number: 21.027 Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Significant Deficiency, Internal Controls Criteria: 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.318(i) states: "The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price." 2 CFR 200.320(b) states: "Procurement by small purchase procedures. Small purchase procedures are those relatively simple and informal procurement methods for securing services, supplies, or other property that do not cost more than the Simplified Acquisition Threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources." 2 CFR 180.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person." Condition: For one selected procurement, EmployIndy was unable to provide support indicating review of procurement documents. Cause: A proper system of internal controls was not implemented by management of the Organization, which would include segregation of key functions. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the Organization’s management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect: Without the proper implementation of an effectively designed system of internal controls, including policies and procedures that provide segregation of duties and additional oversight as needed, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the organization. Questioned costs: There are no questioned costs. Context: Management was unable to provide adequate support indicating preparation and review of procurement and suspension and debarment documents for the Plaid Agency. Crowe was only able to view the bid request and bid. Documents indicating rationale for awarding the contract were not provided. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: We recommend that management establish a proper system of internal control and develop policies and procedures to ensure all required documentation is retained and provided for purchases and to ensure contractors and subrecipients, as appropriate are not suspended, debarred, or otherwise excluded prior to entering into any contracts or subawards. Views of responsible officials and planned corrective actions: Management acknowledges the finding. See management’s corrective action plan attached to this audit report.

FINDING 2023-005 Information on the federal program: Federal Agency: Department of Labor Pass-Through Entity: Indiana Department of Workforce Development Federal Program: WIOA Assistance Listing Number: 17.258, 17.259, 17.278 Compliance Requirement: Activities Allowed or Unallowed Audit Findings: Material Weakness, Qualified Opinion Criteria: 2 CFR 200.403 establishes principles and standards for determining costs for federal awards carried out through grants, cost reimbursement contracts, and other agreements with state and local governments. To be allowable, under federal awards, cost must meet certain criteria: a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. g) Be adequately documented. h) Cost must be incurred during the approved budget period. Additionally, 2 CFR 200.303 indicates that non-Federal Entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations and terms and conditions of the Federal award. Condition: For 15 of the 60 samples selected, EmployIndy was unable to provide adequate support for the selection amounts. As a result, we were unable to determine the allowability of these sample selections under the WIOA grant. Cause: The condition was caused by a lack of internal controls over WIOA subrecipient/service provider claims for accrued expenditures and indirect costs. Effect: As a result of these matters, expenditures could be inaccurately charged to the federal grant. Questioned costs: There are $45,619 of known questioned costs as this is the amount of the WIOA expenditures tested that could not be reconciled to source documents. Context: During our testing procedures over WIOA disbursements for the activities allowed or unallowed compliance requirement, the following were identified: • For two of our 60 non-payroll selections management was unable to provide adequate supporting documentation for the expenditure. These selections pertained to the subrecipient, Eckerd Connects. Questioned costs of $7,303 were noted. • For four of our 60 non-payroll selections, management was able to provide a summary listing of charges by category (AER report), however, supporting invoices or other documents for the summary of charges was not provided. Questioned costs of $20,501 were noted. • For two of our 60 non-payroll selections in which expenditures related to personnel and fringe expenses, we noted the expenses allocated to WIOA Youth, Adult, and Dislocated Worker grants based on a set percentage rather than time actually spent working on grant related projects. Both instances pertain to charges incurred by the subrecipient, Eckerd Connects. No questioned costs were noted. • For six of our 60 non-payroll selections, we noted indirect costs charged by subrecipients that did not have proper support for the indirect cost rate for the period under audit. Five of the selections were Eckerd Connects and one related to Telamon Corporation. Per inquiry of management, Eckerd and Telamon have a federally approved indirect cost rate. Management provided a signed contract with Eckerd that covers the period January 1, 2020 to June 30, 2021 that lists the federally approved rate. The Telamon contract/application provided covers the period of July 1, 2021 to June 30, 2022. Management was unable to provide support stating the federally approved rate for Eckerd and Telamon for the period under audit. No questioned costs were noted. • One of our 60 non-payroll selections was for EmployIndy indirect costs of $17,815. Management provided a calculation of the indirect costs, from which we selected specific charges from the cost pool that the indirect cost was calculated from. Management was unable to provide support for any of the selected charges. Questioned costs of $17,815 were noted. Identification as a repeat finding, if applicable: This is a repeat finding. Appeared as finding 2022-005 in the prior report. Recommendation: We recommend that management implement a consistent multi-stage review process for expenditures that are to be allocated to the WIOA cluster and that management clearly organize and retain records of purchase to support amounts being listed as expenditures on their SEFA. Views of responsible officials and planned corrective actions: Management acknowledges the finding. See management’s corrective action plan attached to this audit report.

FINDING 2023-005 Information on the federal program: Federal Agency: Department of Labor Pass-Through Entity: Indiana Department of Workforce Development Federal Program: WIOA Assistance Listing Number: 17.258, 17.259, 17.278 Compliance Requirement: Activities Allowed or Unallowed Audit Findings: Material Weakness, Qualified Opinion Criteria: 2 CFR 200.403 establishes principles and standards for determining costs for federal awards carried out through grants, cost reimbursement contracts, and other agreements with state and local governments. To be allowable, under federal awards, cost must meet certain criteria: a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. g) Be adequately documented. h) Cost must be incurred during the approved budget period. Additionally, 2 CFR 200.303 indicates that non-Federal Entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations and terms and conditions of the Federal award. Condition: For 15 of the 60 samples selected, EmployIndy was unable to provide adequate support for the selection amounts. As a result, we were unable to determine the allowability of these sample selections under the WIOA grant. Cause: The condition was caused by a lack of internal controls over WIOA subrecipient/service provider claims for accrued expenditures and indirect costs. Effect: As a result of these matters, expenditures could be inaccurately charged to the federal grant. Questioned costs: There are $45,619 of known questioned costs as this is the amount of the WIOA expenditures tested that could not be reconciled to source documents. Context: During our testing procedures over WIOA disbursements for the activities allowed or unallowed compliance requirement, the following were identified: • For two of our 60 non-payroll selections management was unable to provide adequate supporting documentation for the expenditure. These selections pertained to the subrecipient, Eckerd Connects. Questioned costs of $7,303 were noted. • For four of our 60 non-payroll selections, management was able to provide a summary listing of charges by category (AER report), however, supporting invoices or other documents for the summary of charges was not provided. Questioned costs of $20,501 were noted. • For two of our 60 non-payroll selections in which expenditures related to personnel and fringe expenses, we noted the expenses allocated to WIOA Youth, Adult, and Dislocated Worker grants based on a set percentage rather than time actually spent working on grant related projects. Both instances pertain to charges incurred by the subrecipient, Eckerd Connects. No questioned costs were noted. • For six of our 60 non-payroll selections, we noted indirect costs charged by subrecipients that did not have proper support for the indirect cost rate for the period under audit. Five of the selections were Eckerd Connects and one related to Telamon Corporation. Per inquiry of management, Eckerd and Telamon have a federally approved indirect cost rate. Management provided a signed contract with Eckerd that covers the period January 1, 2020 to June 30, 2021 that lists the federally approved rate. The Telamon contract/application provided covers the period of July 1, 2021 to June 30, 2022. Management was unable to provide support stating the federally approved rate for Eckerd and Telamon for the period under audit. No questioned costs were noted. • One of our 60 non-payroll selections was for EmployIndy indirect costs of $17,815. Management provided a calculation of the indirect costs, from which we selected specific charges from the cost pool that the indirect cost was calculated from. Management was unable to provide support for any of the selected charges. Questioned costs of $17,815 were noted. Identification as a repeat finding, if applicable: This is a repeat finding. Appeared as finding 2022-005 in the prior report. Recommendation: We recommend that management implement a consistent multi-stage review process for expenditures that are to be allocated to the WIOA cluster and that management clearly organize and retain records of purchase to support amounts being listed as expenditures on their SEFA. Views of responsible officials and planned corrective actions: Management acknowledges the finding. See management’s corrective action plan attached to this audit report.

FINDING 2023-005 Information on the federal program: Federal Agency: Department of Labor Pass-Through Entity: Indiana Department of Workforce Development Federal Program: WIOA Assistance Listing Number: 17.258, 17.259, 17.278 Compliance Requirement: Activities Allowed or Unallowed Audit Findings: Material Weakness, Qualified Opinion Criteria: 2 CFR 200.403 establishes principles and standards for determining costs for federal awards carried out through grants, cost reimbursement contracts, and other agreements with state and local governments. To be allowable, under federal awards, cost must meet certain criteria: a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. g) Be adequately documented. h) Cost must be incurred during the approved budget period. Additionally, 2 CFR 200.303 indicates that non-Federal Entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations and terms and conditions of the Federal award. Condition: For 15 of the 60 samples selected, EmployIndy was unable to provide adequate support for the selection amounts. As a result, we were unable to determine the allowability of these sample selections under the WIOA grant. Cause: The condition was caused by a lack of internal controls over WIOA subrecipient/service provider claims for accrued expenditures and indirect costs. Effect: As a result of these matters, expenditures could be inaccurately charged to the federal grant. Questioned costs: There are $45,619 of known questioned costs as this is the amount of the WIOA expenditures tested that could not be reconciled to source documents. Context: During our testing procedures over WIOA disbursements for the activities allowed or unallowed compliance requirement, the following were identified: • For two of our 60 non-payroll selections management was unable to provide adequate supporting documentation for the expenditure. These selections pertained to the subrecipient, Eckerd Connects. Questioned costs of $7,303 were noted. • For four of our 60 non-payroll selections, management was able to provide a summary listing of charges by category (AER report), however, supporting invoices or other documents for the summary of charges was not provided. Questioned costs of $20,501 were noted. • For two of our 60 non-payroll selections in which expenditures related to personnel and fringe expenses, we noted the expenses allocated to WIOA Youth, Adult, and Dislocated Worker grants based on a set percentage rather than time actually spent working on grant related projects. Both instances pertain to charges incurred by the subrecipient, Eckerd Connects. No questioned costs were noted. • For six of our 60 non-payroll selections, we noted indirect costs charged by subrecipients that did not have proper support for the indirect cost rate for the period under audit. Five of the selections were Eckerd Connects and one related to Telamon Corporation. Per inquiry of management, Eckerd and Telamon have a federally approved indirect cost rate. Management provided a signed contract with Eckerd that covers the period January 1, 2020 to June 30, 2021 that lists the federally approved rate. The Telamon contract/application provided covers the period of July 1, 2021 to June 30, 2022. Management was unable to provide support stating the federally approved rate for Eckerd and Telamon for the period under audit. No questioned costs were noted. • One of our 60 non-payroll selections was for EmployIndy indirect costs of $17,815. Management provided a calculation of the indirect costs, from which we selected specific charges from the cost pool that the indirect cost was calculated from. Management was unable to provide support for any of the selected charges. Questioned costs of $17,815 were noted. Identification as a repeat finding, if applicable: This is a repeat finding. Appeared as finding 2022-005 in the prior report. Recommendation: We recommend that management implement a consistent multi-stage review process for expenditures that are to be allocated to the WIOA cluster and that management clearly organize and retain records of purchase to support amounts being listed as expenditures on their SEFA. Views of responsible officials and planned corrective actions: Management acknowledges the finding. See management’s corrective action plan attached to this audit report.

FINDING 2023-005 Information on the federal program: Federal Agency: Department of Labor Pass-Through Entity: Indiana Department of Workforce Development Federal Program: WIOA Assistance Listing Number: 17.258, 17.259, 17.278 Compliance Requirement: Activities Allowed or Unallowed Audit Findings: Material Weakness, Qualified Opinion Criteria: 2 CFR 200.403 establishes principles and standards for determining costs for federal awards carried out through grants, cost reimbursement contracts, and other agreements with state and local governments. To be allowable, under federal awards, cost must meet certain criteria: a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. g) Be adequately documented. h) Cost must be incurred during the approved budget period. Additionally, 2 CFR 200.303 indicates that non-Federal Entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations and terms and conditions of the Federal award. Condition: For 15 of the 60 samples selected, EmployIndy was unable to provide adequate support for the selection amounts. As a result, we were unable to determine the allowability of these sample selections under the WIOA grant. Cause: The condition was caused by a lack of internal controls over WIOA subrecipient/service provider claims for accrued expenditures and indirect costs. Effect: As a result of these matters, expenditures could be inaccurately charged to the federal grant. Questioned costs: There are $45,619 of known questioned costs as this is the amount of the WIOA expenditures tested that could not be reconciled to source documents. Context: During our testing procedures over WIOA disbursements for the activities allowed or unallowed compliance requirement, the following were identified: • For two of our 60 non-payroll selections management was unable to provide adequate supporting documentation for the expenditure. These selections pertained to the subrecipient, Eckerd Connects. Questioned costs of $7,303 were noted. • For four of our 60 non-payroll selections, management was able to provide a summary listing of charges by category (AER report), however, supporting invoices or other documents for the summary of charges was not provided. Questioned costs of $20,501 were noted. • For two of our 60 non-payroll selections in which expenditures related to personnel and fringe expenses, we noted the expenses allocated to WIOA Youth, Adult, and Dislocated Worker grants based on a set percentage rather than time actually spent working on grant related projects. Both instances pertain to charges incurred by the subrecipient, Eckerd Connects. No questioned costs were noted. • For six of our 60 non-payroll selections, we noted indirect costs charged by subrecipients that did not have proper support for the indirect cost rate for the period under audit. Five of the selections were Eckerd Connects and one related to Telamon Corporation. Per inquiry of management, Eckerd and Telamon have a federally approved indirect cost rate. Management provided a signed contract with Eckerd that covers the period January 1, 2020 to June 30, 2021 that lists the federally approved rate. The Telamon contract/application provided covers the period of July 1, 2021 to June 30, 2022. Management was unable to provide support stating the federally approved rate for Eckerd and Telamon for the period under audit. No questioned costs were noted. • One of our 60 non-payroll selections was for EmployIndy indirect costs of $17,815. Management provided a calculation of the indirect costs, from which we selected specific charges from the cost pool that the indirect cost was calculated from. Management was unable to provide support for any of the selected charges. Questioned costs of $17,815 were noted. Identification as a repeat finding, if applicable: This is a repeat finding. Appeared as finding 2022-005 in the prior report. Recommendation: We recommend that management implement a consistent multi-stage review process for expenditures that are to be allocated to the WIOA cluster and that management clearly organize and retain records of purchase to support amounts being listed as expenditures on their SEFA. Views of responsible officials and planned corrective actions: Management acknowledges the finding. See management’s corrective action plan attached to this audit report.

FINDING 2023-006 Information on the federal program: Federal Agency: Department of Labor Pass-Through Entity: Indiana Department of Workforce Development Federal Program: WIOA Assistance Listing Number: 17.258, 17.259, 17.278 Compliance Requirement: Activities Allowed or Unallowed Audit Findings: Material Weakness, Internal Controls Criteria: 2 CFR 200.403 establishes principles and standards for determining costs for federal awards carried out through grants, cost reimbursement contracts, and other agreements with state and local governments. To be allowable, under federal awards, cost must meet certain criteria: a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. g) Be adequately documented. h) Cost must be incurred during the approved budget period. Additionally, 2 CFR 200.303 indicates that non-Federal Entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations and terms and conditions of the Federal award. Condition: EmployIndy did not formally review and approve 12 selected WIOA non-payroll expenditures in a sample of 60 to determine that they are allowable under the WIOA federal regulations. Cause: The condition was caused by a lack of internal controls over WIOA subrecipient/service provider claims for accrued expenditures. Effect: As a result of these matters, expenditures could be inaccurately charged to the federal grant. Questioned costs: There are no questioned costs. Context: During our testing procedures over WIOA disbursements for the activities allowed or unallowed compliance requirement, we identified expenditures that are not formally reviewed by management for allowability under the WIOA grant. Identification as a repeat finding, if applicable: This is a repeat finding. Appeared as finding 2022-006 in the prior report. Recommendation: We recommend that management implement a consistent multi-stage review process for expenditures that are to be allocated to the WIOA cluster and that management clearly organize and retain records of purchase to support amounts being listed as expenditures on their SEFA. Views of responsible officials and planned corrective actions: Management acknowledges the finding. See management’s corrective action plan attached to this audit report.

FINDING 2023-006 Information on the federal program: Federal Agency: Department of Labor Pass-Through Entity: Indiana Department of Workforce Development Federal Program: WIOA Assistance Listing Number: 17.258, 17.259, 17.278 Compliance Requirement: Activities Allowed or Unallowed Audit Findings: Material Weakness, Internal Controls Criteria: 2 CFR 200.403 establishes principles and standards for determining costs for federal awards carried out through grants, cost reimbursement contracts, and other agreements with state and local governments. To be allowable, under federal awards, cost must meet certain criteria: a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. g) Be adequately documented. h) Cost must be incurred during the approved budget period. Additionally, 2 CFR 200.303 indicates that non-Federal Entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations and terms and conditions of the Federal award. Condition: EmployIndy did not formally review and approve 12 selected WIOA non-payroll expenditures in a sample of 60 to determine that they are allowable under the WIOA federal regulations. Cause: The condition was caused by a lack of internal controls over WIOA subrecipient/service provider claims for accrued expenditures. Effect: As a result of these matters, expenditures could be inaccurately charged to the federal grant. Questioned costs: There are no questioned costs. Context: During our testing procedures over WIOA disbursements for the activities allowed or unallowed compliance requirement, we identified expenditures that are not formally reviewed by management for allowability under the WIOA grant. Identification as a repeat finding, if applicable: This is a repeat finding. Appeared as finding 2022-006 in the prior report. Recommendation: We recommend that management implement a consistent multi-stage review process for expenditures that are to be allocated to the WIOA cluster and that management clearly organize and retain records of purchase to support amounts being listed as expenditures on their SEFA. Views of responsible officials and planned corrective actions: Management acknowledges the finding. See management’s corrective action plan attached to this audit report.

FINDING 2023-006 Information on the federal program: Federal Agency: Department of Labor Pass-Through Entity: Indiana Department of Workforce Development Federal Program: WIOA Assistance Listing Number: 17.258, 17.259, 17.278 Compliance Requirement: Activities Allowed or Unallowed Audit Findings: Material Weakness, Internal Controls Criteria: 2 CFR 200.403 establishes principles and standards for determining costs for federal awards carried out through grants, cost reimbursement contracts, and other agreements with state and local governments. To be allowable, under federal awards, cost must meet certain criteria: a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. g) Be adequately documented. h) Cost must be incurred during the approved budget period. Additionally, 2 CFR 200.303 indicates that non-Federal Entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations and terms and conditions of the Federal award. Condition: EmployIndy did not formally review and approve 12 selected WIOA non-payroll expenditures in a sample of 60 to determine that they are allowable under the WIOA federal regulations. Cause: The condition was caused by a lack of internal controls over WIOA subrecipient/service provider claims for accrued expenditures. Effect: As a result of these matters, expenditures could be inaccurately charged to the federal grant. Questioned costs: There are no questioned costs. Context: During our testing procedures over WIOA disbursements for the activities allowed or unallowed compliance requirement, we identified expenditures that are not formally reviewed by management for allowability under the WIOA grant. Identification as a repeat finding, if applicable: This is a repeat finding. Appeared as finding 2022-006 in the prior report. Recommendation: We recommend that management implement a consistent multi-stage review process for expenditures that are to be allocated to the WIOA cluster and that management clearly organize and retain records of purchase to support amounts being listed as expenditures on their SEFA. Views of responsible officials and planned corrective actions: Management acknowledges the finding. See management’s corrective action plan attached to this audit report.

FINDING 2023-006 Information on the federal program: Federal Agency: Department of Labor Pass-Through Entity: Indiana Department of Workforce Development Federal Program: WIOA Assistance Listing Number: 17.258, 17.259, 17.278 Compliance Requirement: Activities Allowed or Unallowed Audit Findings: Material Weakness, Internal Controls Criteria: 2 CFR 200.403 establishes principles and standards for determining costs for federal awards carried out through grants, cost reimbursement contracts, and other agreements with state and local governments. To be allowable, under federal awards, cost must meet certain criteria: a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. g) Be adequately documented. h) Cost must be incurred during the approved budget period. Additionally, 2 CFR 200.303 indicates that non-Federal Entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations and terms and conditions of the Federal award. Condition: EmployIndy did not formally review and approve 12 selected WIOA non-payroll expenditures in a sample of 60 to determine that they are allowable under the WIOA federal regulations. Cause: The condition was caused by a lack of internal controls over WIOA subrecipient/service provider claims for accrued expenditures. Effect: As a result of these matters, expenditures could be inaccurately charged to the federal grant. Questioned costs: There are no questioned costs. Context: During our testing procedures over WIOA disbursements for the activities allowed or unallowed compliance requirement, we identified expenditures that are not formally reviewed by management for allowability under the WIOA grant. Identification as a repeat finding, if applicable: This is a repeat finding. Appeared as finding 2022-006 in the prior report. Recommendation: We recommend that management implement a consistent multi-stage review process for expenditures that are to be allocated to the WIOA cluster and that management clearly organize and retain records of purchase to support amounts being listed as expenditures on their SEFA. Views of responsible officials and planned corrective actions: Management acknowledges the finding. See management’s corrective action plan attached to this audit report.

FINDING 2023-007 Information on the federal program: Federal Agency: Department of Labor Pass-Through Entity: Indiana Department of Workforce Development Federal Program: WIOA Assistance Listing Number: 17.258, 17.259, 17.278 Compliance Requirement: Subrecipient Monitoring Audit Findings: Material Weakness, Qualified Opinion Criteria: Title 2 Subtitle A Chapter II Part 200 Subpart D, Section 200.331 and 200.332, establishes requirements that pass-through entities must adhere to in regard to their subrecipient grant agreements and the monitoring processes of those subrecipients. Condition: The EmployIndy subrecipient, Eckerd Connects, was reimbursed for personnel and fringe expenses that were allocated to the WIOA grants based off of a fixed allocation percentage for each Assistance Listing Number (ALN) instead of actual time worked on the grant. Cause: The condition was caused by a lack of internal controls over WIOA subrecipient/service provider claims for accrued expenditures. Effect: As a result of these matters, expenditures could be inaccurately charged to the federal grant. Questioned costs: There are no questioned costs. Context: During testing, Crowe identified monthly accrued expenditures of the Eckerd Connects subrecipient in which a fixed allocation for the separate WIOA grants was used each month to allocate personnel and fringe expenses. Identification as a repeat finding, if applicable: This is a repeat finding. Appeared as finding 2022-008 in the prior report. Recommendation: We recommend EmployIndy review subrecipient source documents to ensure accrued expenditures are appropriately supported by invoices or time-records showing time on task spent on specific grants. Views of responsible officials and planned corrective actions: Management acknowledges the finding. See management’s corrective action plan attached to this audit report.

FINDING 2023-007 Information on the federal program: Federal Agency: Department of Labor Pass-Through Entity: Indiana Department of Workforce Development Federal Program: WIOA Assistance Listing Number: 17.258, 17.259, 17.278 Compliance Requirement: Subrecipient Monitoring Audit Findings: Material Weakness, Qualified Opinion Criteria: Title 2 Subtitle A Chapter II Part 200 Subpart D, Section 200.331 and 200.332, establishes requirements that pass-through entities must adhere to in regard to their subrecipient grant agreements and the monitoring processes of those subrecipients. Condition: The EmployIndy subrecipient, Eckerd Connects, was reimbursed for personnel and fringe expenses that were allocated to the WIOA grants based off of a fixed allocation percentage for each Assistance Listing Number (ALN) instead of actual time worked on the grant. Cause: The condition was caused by a lack of internal controls over WIOA subrecipient/service provider claims for accrued expenditures. Effect: As a result of these matters, expenditures could be inaccurately charged to the federal grant. Questioned costs: There are no questioned costs. Context: During testing, Crowe identified monthly accrued expenditures of the Eckerd Connects subrecipient in which a fixed allocation for the separate WIOA grants was used each month to allocate personnel and fringe expenses. Identification as a repeat finding, if applicable: This is a repeat finding. Appeared as finding 2022-008 in the prior report. Recommendation: We recommend EmployIndy review subrecipient source documents to ensure accrued expenditures are appropriately supported by invoices or time-records showing time on task spent on specific grants. Views of responsible officials and planned corrective actions: Management acknowledges the finding. See management’s corrective action plan attached to this audit report.

FINDING 2023-007 Information on the federal program: Federal Agency: Department of Labor Pass-Through Entity: Indiana Department of Workforce Development Federal Program: WIOA Assistance Listing Number: 17.258, 17.259, 17.278 Compliance Requirement: Subrecipient Monitoring Audit Findings: Material Weakness, Qualified Opinion Criteria: Title 2 Subtitle A Chapter II Part 200 Subpart D, Section 200.331 and 200.332, establishes requirements that pass-through entities must adhere to in regard to their subrecipient grant agreements and the monitoring processes of those subrecipients. Condition: The EmployIndy subrecipient, Eckerd Connects, was reimbursed for personnel and fringe expenses that were allocated to the WIOA grants based off of a fixed allocation percentage for each Assistance Listing Number (ALN) instead of actual time worked on the grant. Cause: The condition was caused by a lack of internal controls over WIOA subrecipient/service provider claims for accrued expenditures. Effect: As a result of these matters, expenditures could be inaccurately charged to the federal grant. Questioned costs: There are no questioned costs. Context: During testing, Crowe identified monthly accrued expenditures of the Eckerd Connects subrecipient in which a fixed allocation for the separate WIOA grants was used each month to allocate personnel and fringe expenses. Identification as a repeat finding, if applicable: This is a repeat finding. Appeared as finding 2022-008 in the prior report. Recommendation: We recommend EmployIndy review subrecipient source documents to ensure accrued expenditures are appropriately supported by invoices or time-records showing time on task spent on specific grants. Views of responsible officials and planned corrective actions: Management acknowledges the finding. See management’s corrective action plan attached to this audit report.

FINDING 2023-007 Information on the federal program: Federal Agency: Department of Labor Pass-Through Entity: Indiana Department of Workforce Development Federal Program: WIOA Assistance Listing Number: 17.258, 17.259, 17.278 Compliance Requirement: Subrecipient Monitoring Audit Findings: Material Weakness, Qualified Opinion Criteria: Title 2 Subtitle A Chapter II Part 200 Subpart D, Section 200.331 and 200.332, establishes requirements that pass-through entities must adhere to in regard to their subrecipient grant agreements and the monitoring processes of those subrecipients. Condition: The EmployIndy subrecipient, Eckerd Connects, was reimbursed for personnel and fringe expenses that were allocated to the WIOA grants based off of a fixed allocation percentage for each Assistance Listing Number (ALN) instead of actual time worked on the grant. Cause: The condition was caused by a lack of internal controls over WIOA subrecipient/service provider claims for accrued expenditures. Effect: As a result of these matters, expenditures could be inaccurately charged to the federal grant. Questioned costs: There are no questioned costs. Context: During testing, Crowe identified monthly accrued expenditures of the Eckerd Connects subrecipient in which a fixed allocation for the separate WIOA grants was used each month to allocate personnel and fringe expenses. Identification as a repeat finding, if applicable: This is a repeat finding. Appeared as finding 2022-008 in the prior report. Recommendation: We recommend EmployIndy review subrecipient source documents to ensure accrued expenditures are appropriately supported by invoices or time-records showing time on task spent on specific grants. Views of responsible officials and planned corrective actions: Management acknowledges the finding. See management’s corrective action plan attached to this audit report.

FINDING 2023-008 Information on the federal program: Federal Agency: Department of Labor Pass-Through Entity: Indiana Department of Workforce Development Federal Program: WIOA Assistance Listing Number: 17.258, 17.259, 17.278 Compliance Requirement: Subrecipient Monitoring Audit Findings: Material Weakness, Qualified Opinion Criteria: Title 2 Subtitle A Chapter II Part 200 Subpart D, Section 200.331 and 200.332, establishes requirements that pass-through entities must adhere to in regard to their subrecipient grant agreements and the monitoring processes of those subrecipients. Condition: Through our auditing procedures on subrecipient monitoring compliance requirements, we noted that there was missing award information in the subrecipient contracts that are required per Section 200.332 (a)(1) federal award identification. These missing pieces of information included Federal award identification such as: 1. Subrecipient’s unique identifier 2. Federal award identification number 3. Federal award date 4. Subaward period of performance start and end date 5. Assistance Listings numbers 6. Indirect cost rate for Federal award per CFA subsection 200.414 In addition, EmployIndy does not clearly distinguish within the agreement that the recipient of funding is either a “subrecipient” or a “contractor.” Cause: EmployIndy does not have an effective system of internal controls in place to effectively structure and review WIOA subaward agreements. Management uses their standard contractual agreement template. Effect: Due to lack of required information being present within the contracts and the contracts not clearly identifying between a subrecipient and a contractor, there could be noncompliance issues in how the funds are spent and recorded by the subrecipient, which could lead to noncompliance issues for EmployIndy and its subrecipients. Questioned costs: There are no questioned costs. Context: Subrecipients represented approximately 44%, $2,433,402, of the total award, $5,505,792. The condition reported was prevalent across each subrecipient participating in the award. Identification as a repeat finding, if applicable: This is a repeat finding. Appeared as finding 2022-009 in the prior report. Recommendation: We recommend that EmployIndy rework their contract agreements to clearly distinguish between subrecipients and contractors. EmployIndy should also review Title 2 Subtitle A Chapter II Part 200 Subpart D and ensure their contracts with subrecipients include all of the required information. Management should review their subrecipient monitoring and management policies for subcontractor and contractor determinations, federal award identification, and subrecipient risk assessment and monitoring procedures for each unique federal award. Views of responsible officials and planned corrective actions: Management acknowledges the finding. See management’s corrective action plan attached to this audit report.

FINDING 2023-008 Information on the federal program: Federal Agency: Department of Labor Pass-Through Entity: Indiana Department of Workforce Development Federal Program: WIOA Assistance Listing Number: 17.258, 17.259, 17.278 Compliance Requirement: Subrecipient Monitoring Audit Findings: Material Weakness, Qualified Opinion Criteria: Title 2 Subtitle A Chapter II Part 200 Subpart D, Section 200.331 and 200.332, establishes requirements that pass-through entities must adhere to in regard to their subrecipient grant agreements and the monitoring processes of those subrecipients. Condition: Through our auditing procedures on subrecipient monitoring compliance requirements, we noted that there was missing award information in the subrecipient contracts that are required per Section 200.332 (a)(1) federal award identification. These missing pieces of information included Federal award identification such as: 1. Subrecipient’s unique identifier 2. Federal award identification number 3. Federal award date 4. Subaward period of performance start and end date 5. Assistance Listings numbers 6. Indirect cost rate for Federal award per CFA subsection 200.414 In addition, EmployIndy does not clearly distinguish within the agreement that the recipient of funding is either a “subrecipient” or a “contractor.” Cause: EmployIndy does not have an effective system of internal controls in place to effectively structure and review WIOA subaward agreements. Management uses their standard contractual agreement template. Effect: Due to lack of required information being present within the contracts and the contracts not clearly identifying between a subrecipient and a contractor, there could be noncompliance issues in how the funds are spent and recorded by the subrecipient, which could lead to noncompliance issues for EmployIndy and its subrecipients. Questioned costs: There are no questioned costs. Context: Subrecipients represented approximately 44%, $2,433,402, of the total award, $5,505,792. The condition reported was prevalent across each subrecipient participating in the award. Identification as a repeat finding, if applicable: This is a repeat finding. Appeared as finding 2022-009 in the prior report. Recommendation: We recommend that EmployIndy rework their contract agreements to clearly distinguish between subrecipients and contractors. EmployIndy should also review Title 2 Subtitle A Chapter II Part 200 Subpart D and ensure their contracts with subrecipients include all of the required information. Management should review their subrecipient monitoring and management policies for subcontractor and contractor determinations, federal award identification, and subrecipient risk assessment and monitoring procedures for each unique federal award. Views of responsible officials and planned corrective actions: Management acknowledges the finding. See management’s corrective action plan attached to this audit report.

FINDING 2023-008 Information on the federal program: Federal Agency: Department of Labor Pass-Through Entity: Indiana Department of Workforce Development Federal Program: WIOA Assistance Listing Number: 17.258, 17.259, 17.278 Compliance Requirement: Subrecipient Monitoring Audit Findings: Material Weakness, Qualified Opinion Criteria: Title 2 Subtitle A Chapter II Part 200 Subpart D, Section 200.331 and 200.332, establishes requirements that pass-through entities must adhere to in regard to their subrecipient grant agreements and the monitoring processes of those subrecipients. Condition: Through our auditing procedures on subrecipient monitoring compliance requirements, we noted that there was missing award information in the subrecipient contracts that are required per Section 200.332 (a)(1) federal award identification. These missing pieces of information included Federal award identification such as: 1. Subrecipient’s unique identifier 2. Federal award identification number 3. Federal award date 4. Subaward period of performance start and end date 5. Assistance Listings numbers 6. Indirect cost rate for Federal award per CFA subsection 200.414 In addition, EmployIndy does not clearly distinguish within the agreement that the recipient of funding is either a “subrecipient” or a “contractor.” Cause: EmployIndy does not have an effective system of internal controls in place to effectively structure and review WIOA subaward agreements. Management uses their standard contractual agreement template. Effect: Due to lack of required information being present within the contracts and the contracts not clearly identifying between a subrecipient and a contractor, there could be noncompliance issues in how the funds are spent and recorded by the subrecipient, which could lead to noncompliance issues for EmployIndy and its subrecipients. Questioned costs: There are no questioned costs. Context: Subrecipients represented approximately 44%, $2,433,402, of the total award, $5,505,792. The condition reported was prevalent across each subrecipient participating in the award. Identification as a repeat finding, if applicable: This is a repeat finding. Appeared as finding 2022-009 in the prior report. Recommendation: We recommend that EmployIndy rework their contract agreements to clearly distinguish between subrecipients and contractors. EmployIndy should also review Title 2 Subtitle A Chapter II Part 200 Subpart D and ensure their contracts with subrecipients include all of the required information. Management should review their subrecipient monitoring and management policies for subcontractor and contractor determinations, federal award identification, and subrecipient risk assessment and monitoring procedures for each unique federal award. Views of responsible officials and planned corrective actions: Management acknowledges the finding. See management’s corrective action plan attached to this audit report.

FINDING 2023-008 Information on the federal program: Federal Agency: Department of Labor Pass-Through Entity: Indiana Department of Workforce Development Federal Program: WIOA Assistance Listing Number: 17.258, 17.259, 17.278 Compliance Requirement: Subrecipient Monitoring Audit Findings: Material Weakness, Qualified Opinion Criteria: Title 2 Subtitle A Chapter II Part 200 Subpart D, Section 200.331 and 200.332, establishes requirements that pass-through entities must adhere to in regard to their subrecipient grant agreements and the monitoring processes of those subrecipients. Condition: Through our auditing procedures on subrecipient monitoring compliance requirements, we noted that there was missing award information in the subrecipient contracts that are required per Section 200.332 (a)(1) federal award identification. These missing pieces of information included Federal award identification such as: 1. Subrecipient’s unique identifier 2. Federal award identification number 3. Federal award date 4. Subaward period of performance start and end date 5. Assistance Listings numbers 6. Indirect cost rate for Federal award per CFA subsection 200.414 In addition, EmployIndy does not clearly distinguish within the agreement that the recipient of funding is either a “subrecipient” or a “contractor.” Cause: EmployIndy does not have an effective system of internal controls in place to effectively structure and review WIOA subaward agreements. Management uses their standard contractual agreement template. Effect: Due to lack of required information being present within the contracts and the contracts not clearly identifying between a subrecipient and a contractor, there could be noncompliance issues in how the funds are spent and recorded by the subrecipient, which could lead to noncompliance issues for EmployIndy and its subrecipients. Questioned costs: There are no questioned costs. Context: Subrecipients represented approximately 44%, $2,433,402, of the total award, $5,505,792. The condition reported was prevalent across each subrecipient participating in the award. Identification as a repeat finding, if applicable: This is a repeat finding. Appeared as finding 2022-009 in the prior report. Recommendation: We recommend that EmployIndy rework their contract agreements to clearly distinguish between subrecipients and contractors. EmployIndy should also review Title 2 Subtitle A Chapter II Part 200 Subpart D and ensure their contracts with subrecipients include all of the required information. Management should review their subrecipient monitoring and management policies for subcontractor and contractor determinations, federal award identification, and subrecipient risk assessment and monitoring procedures for each unique federal award. Views of responsible officials and planned corrective actions: Management acknowledges the finding. See management’s corrective action plan attached to this audit report.

FINDING 2023-009 Information on the federal program: Federal Agency: Department of the Treasury Pass-Through Entity: The Indianapolis Foundation and The City of Indianapolis Federal Program: Coronavirus State and Fiscal Recovery Funds Assistance Listing Number: 21.027 Compliance Requirement: Subrecipient Monitoring Audit Findings: Material Weakness, Qualified Opinion Criteria: Title 2 Subtitle A Chapter II Part 200 Subpart D, Section 200.331 and 200.332, establishes requirements that pass-through entities must adhere to in regard to their subrecipient grant agreements and the monitoring processes of those subrecipients. Condition: Through our auditing procedures on subrecipient monitoring compliance requirements, we noted that management did not have support indicating monitoring of subrecipients was performed to ensure the subrecipient used the subaward for authorized purposes in compliance with federal statutes, regulations, and the terms and conditions of the subaward. This instance was noted for the subrecipient for the Education-to-Employment Pipeline and Talent Pipeline grants. Additionally, Crowe noted that Training for Success was written into the Elevation grant as EmployIndy’s partner. However, expenditures to Training for Success were not reported as subrecipient funding on the SEFA. As EmployIndy did not report Training for Success as a subrecipient, EmployIndy did not perform monitoring procedures. Cause: EmployIndy does not have an effective system of internal controls in place to effectively structure and review SLFRF subaward activity. Effect: Due to lack of required information being present, there could be noncompliance issues in how the funds are spent and recorded by the subrecipient, which could lead to noncompliance issues for EmployIndy and its subrecipients. Questioned costs: There are no questioned costs. Context: Subrecipients represented approximately 51%, $508,035, of the total ALN award, $987,698. The condition reported was prevalent across each subrecipient participating in the award. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: We recommend that EmployIndy review their subrecipient monitoring and management policies for subcontractor and contractor determinations, federal award identification, and subrecipient risk assessment and monitoring procedures for each unique federal award. Views of responsible officials and planned corrective actions: Management acknowledges the finding. See management’s corrective action plan attached to this audit report.

FINDING 2023-009 Information on the federal program: Federal Agency: Department of the Treasury Pass-Through Entity: The Indianapolis Foundation and The City of Indianapolis Federal Program: Coronavirus State and Fiscal Recovery Funds Assistance Listing Number: 21.027 Compliance Requirement: Subrecipient Monitoring Audit Findings: Material Weakness, Qualified Opinion Criteria: Title 2 Subtitle A Chapter II Part 200 Subpart D, Section 200.331 and 200.332, establishes requirements that pass-through entities must adhere to in regard to their subrecipient grant agreements and the monitoring processes of those subrecipients. Condition: Through our auditing procedures on subrecipient monitoring compliance requirements, we noted that management did not have support indicating monitoring of subrecipients was performed to ensure the subrecipient used the subaward for authorized purposes in compliance with federal statutes, regulations, and the terms and conditions of the subaward. This instance was noted for the subrecipient for the Education-to-Employment Pipeline and Talent Pipeline grants. Additionally, Crowe noted that Training for Success was written into the Elevation grant as EmployIndy’s partner. However, expenditures to Training for Success were not reported as subrecipient funding on the SEFA. As EmployIndy did not report Training for Success as a subrecipient, EmployIndy did not perform monitoring procedures. Cause: EmployIndy does not have an effective system of internal controls in place to effectively structure and review SLFRF subaward activity. Effect: Due to lack of required information being present, there could be noncompliance issues in how the funds are spent and recorded by the subrecipient, which could lead to noncompliance issues for EmployIndy and its subrecipients. Questioned costs: There are no questioned costs. Context: Subrecipients represented approximately 51%, $508,035, of the total ALN award, $987,698. The condition reported was prevalent across each subrecipient participating in the award. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: We recommend that EmployIndy review their subrecipient monitoring and management policies for subcontractor and contractor determinations, federal award identification, and subrecipient risk assessment and monitoring procedures for each unique federal award. Views of responsible officials and planned corrective actions: Management acknowledges the finding. See management’s corrective action plan attached to this audit report.

FINDING 2023-009 Information on the federal program: Federal Agency: Department of the Treasury Pass-Through Entity: The Indianapolis Foundation and The City of Indianapolis Federal Program: Coronavirus State and Fiscal Recovery Funds Assistance Listing Number: 21.027 Compliance Requirement: Subrecipient Monitoring Audit Findings: Material Weakness, Qualified Opinion Criteria: Title 2 Subtitle A Chapter II Part 200 Subpart D, Section 200.331 and 200.332, establishes requirements that pass-through entities must adhere to in regard to their subrecipient grant agreements and the monitoring processes of those subrecipients. Condition: Through our auditing procedures on subrecipient monitoring compliance requirements, we noted that management did not have support indicating monitoring of subrecipients was performed to ensure the subrecipient used the subaward for authorized purposes in compliance with federal statutes, regulations, and the terms and conditions of the subaward. This instance was noted for the subrecipient for the Education-to-Employment Pipeline and Talent Pipeline grants. Additionally, Crowe noted that Training for Success was written into the Elevation grant as EmployIndy’s partner. However, expenditures to Training for Success were not reported as subrecipient funding on the SEFA. As EmployIndy did not report Training for Success as a subrecipient, EmployIndy did not perform monitoring procedures. Cause: EmployIndy does not have an effective system of internal controls in place to effectively structure and review SLFRF subaward activity. Effect: Due to lack of required information being present, there could be noncompliance issues in how the funds are spent and recorded by the subrecipient, which could lead to noncompliance issues for EmployIndy and its subrecipients. Questioned costs: There are no questioned costs. Context: Subrecipients represented approximately 51%, $508,035, of the total ALN award, $987,698. The condition reported was prevalent across each subrecipient participating in the award. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: We recommend that EmployIndy review their subrecipient monitoring and management policies for subcontractor and contractor determinations, federal award identification, and subrecipient risk assessment and monitoring procedures for each unique federal award. Views of responsible officials and planned corrective actions: Management acknowledges the finding. See management’s corrective action plan attached to this audit report.

FINDING 2023-010 Information on the federal program: Federal Agency: Department of the Treasury Pass-Through Entity: The Indianapolis Foundation and The City of Indianapolis Federal Program: Coronavirus State and Fiscal Recovery Funds Assistance Listing Number: 21.027 Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Significant Deficiency, Internal Controls Criteria: 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.318(i) states: "The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price." 2 CFR 200.320(b) states: "Procurement by small purchase procedures. Small purchase procedures are those relatively simple and informal procurement methods for securing services, supplies, or other property that do not cost more than the Simplified Acquisition Threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources." 2 CFR 180.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person." Condition: For one selected procurement, EmployIndy was unable to provide support indicating review of procurement documents. Cause: A proper system of internal controls was not implemented by management of the Organization, which would include segregation of key functions. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the Organization’s management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect: Without the proper implementation of an effectively designed system of internal controls, including policies and procedures that provide segregation of duties and additional oversight as needed, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the organization. Questioned costs: There are no questioned costs. Context: Management was unable to provide adequate support indicating preparation and review of procurement and suspension and debarment documents for the Plaid Agency. Crowe was only able to view the bid request and bid. Documents indicating rationale for awarding the contract were not provided. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: We recommend that management establish a proper system of internal control and develop policies and procedures to ensure all required documentation is retained and provided for purchases and to ensure contractors and subrecipients, as appropriate are not suspended, debarred, or otherwise excluded prior to entering into any contracts or subawards. Views of responsible officials and planned corrective actions: Management acknowledges the finding. See management’s corrective action plan attached to this audit report.

FINDING 2023-010 Information on the federal program: Federal Agency: Department of the Treasury Pass-Through Entity: The Indianapolis Foundation and The City of Indianapolis Federal Program: Coronavirus State and Fiscal Recovery Funds Assistance Listing Number: 21.027 Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Significant Deficiency, Internal Controls Criteria: 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.318(i) states: "The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price." 2 CFR 200.320(b) states: "Procurement by small purchase procedures. Small purchase procedures are those relatively simple and informal procurement methods for securing services, supplies, or other property that do not cost more than the Simplified Acquisition Threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources." 2 CFR 180.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person." Condition: For one selected procurement, EmployIndy was unable to provide support indicating review of procurement documents. Cause: A proper system of internal controls was not implemented by management of the Organization, which would include segregation of key functions. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the Organization’s management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect: Without the proper implementation of an effectively designed system of internal controls, including policies and procedures that provide segregation of duties and additional oversight as needed, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the organization. Questioned costs: There are no questioned costs. Context: Management was unable to provide adequate support indicating preparation and review of procurement and suspension and debarment documents for the Plaid Agency. Crowe was only able to view the bid request and bid. Documents indicating rationale for awarding the contract were not provided. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: We recommend that management establish a proper system of internal control and develop policies and procedures to ensure all required documentation is retained and provided for purchases and to ensure contractors and subrecipients, as appropriate are not suspended, debarred, or otherwise excluded prior to entering into any contracts or subawards. Views of responsible officials and planned corrective actions: Management acknowledges the finding. See management’s corrective action plan attached to this audit report.

FINDING 2023-010 Information on the federal program: Federal Agency: Department of the Treasury Pass-Through Entity: The Indianapolis Foundation and The City of Indianapolis Federal Program: Coronavirus State and Fiscal Recovery Funds Assistance Listing Number: 21.027 Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Significant Deficiency, Internal Controls Criteria: 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.318(i) states: "The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price." 2 CFR 200.320(b) states: "Procurement by small purchase procedures. Small purchase procedures are those relatively simple and informal procurement methods for securing services, supplies, or other property that do not cost more than the Simplified Acquisition Threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources." 2 CFR 180.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person." Condition: For one selected procurement, EmployIndy was unable to provide support indicating review of procurement documents. Cause: A proper system of internal controls was not implemented by management of the Organization, which would include segregation of key functions. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the Organization’s management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect: Without the proper implementation of an effectively designed system of internal controls, including policies and procedures that provide segregation of duties and additional oversight as needed, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the organization. Questioned costs: There are no questioned costs. Context: Management was unable to provide adequate support indicating preparation and review of procurement and suspension and debarment documents for the Plaid Agency. Crowe was only able to view the bid request and bid. Documents indicating rationale for awarding the contract were not provided. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: We recommend that management establish a proper system of internal control and develop policies and procedures to ensure all required documentation is retained and provided for purchases and to ensure contractors and subrecipients, as appropriate are not suspended, debarred, or otherwise excluded prior to entering into any contracts or subawards. Views of responsible officials and planned corrective actions: Management acknowledges the finding. See management’s corrective action plan attached to this audit report.