Audit 348989

FINDING 2024-001 Subject: Special Education Cluster (IDEA) - Suspension and Debarment Federal Agency: Department of Education Federal Programs: Special Education Grants to States, COVID-19 - Special Education Grants to States, Special Education Preschool Grants, COVID-19 - Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.027X, 84.173, 84.173X Federal Award Numbers and Years (or Other Identifying Numbers): H027A190084, 22611-093-ARP, H173A180104, H173A210104, 22619-093-ARP Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Condition and Context Prior to entering into a covered transaction for goods and services equal to or over $25,000 that were paid with Special Education Cluster funds, recipients are required to verify that such contractors or vendors are not suspended, debarred, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. The verification is to be done by checking SAM Exclusions, collecting a certification from that person, or adding a clause or condition to the covered transaction with that person. Upon inquiry of the School Corporation, the procedures in place over suspension and debarment during the audit period were to verify new vendors, when being entered into the system, were not excluded on SAM.gov. However, the School Corporation did not retain documentation of SAM.gov verifications, nor were checks done each year to verify that applicable vendors were still considered eligible under federal requirements. A population of six covered transactions for goods or services, totaling $569,754, that equaled or exceeded $25,000 paid from Special Education funds during the audit period was identified. No documentation was available to verify that the School Corporation performed the required checks. The lack of effective internal controls and noncompliance were systemic issues throughout the audit period. 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). . . ." INDIANA STATE BOARD OF ACCOUNTS 16 KOKOMO SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 31 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 if allowed by this rule; or (c) Adding a clause or condition to the covered transaction with that person." Cause A proper system of internal controls was not designed by the management of the School Corporation. The School Corporation was unable to provide documentation to demonstrate it checked SAM.gov or received certification from applicable vendors to verify that contractors and vendors were not suspended or debarred. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. No documentation existed to ensure vendors to whom payments equal to or in excess of $25,000 were verified to not be suspended, debarred, or otherwise excluded. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation strengthen its system of internal controls to ensure that all vendors that are paid $25,000 or more, all or in part with federal funds, are not suspended or debarred from participating in federal program before entering into any covered transactions and retain documentation to support the performance of these procedures. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2024-001 Subject: Special Education Cluster (IDEA) - Suspension and Debarment Federal Agency: Department of Education Federal Programs: Special Education Grants to States, COVID-19 - Special Education Grants to States, Special Education Preschool Grants, COVID-19 - Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.027X, 84.173, 84.173X Federal Award Numbers and Years (or Other Identifying Numbers): H027A190084, 22611-093-ARP, H173A180104, H173A210104, 22619-093-ARP Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Condition and Context Prior to entering into a covered transaction for goods and services equal to or over $25,000 that were paid with Special Education Cluster funds, recipients are required to verify that such contractors or vendors are not suspended, debarred, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. The verification is to be done by checking SAM Exclusions, collecting a certification from that person, or adding a clause or condition to the covered transaction with that person. Upon inquiry of the School Corporation, the procedures in place over suspension and debarment during the audit period were to verify new vendors, when being entered into the system, were not excluded on SAM.gov. However, the School Corporation did not retain documentation of SAM.gov verifications, nor were checks done each year to verify that applicable vendors were still considered eligible under federal requirements. A population of six covered transactions for goods or services, totaling $569,754, that equaled or exceeded $25,000 paid from Special Education funds during the audit period was identified. No documentation was available to verify that the School Corporation performed the required checks. The lack of effective internal controls and noncompliance were systemic issues throughout the audit period. 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). . . ." INDIANA STATE BOARD OF ACCOUNTS 16 KOKOMO SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 31 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 if allowed by this rule; or (c) Adding a clause or condition to the covered transaction with that person." Cause A proper system of internal controls was not designed by the management of the School Corporation. The School Corporation was unable to provide documentation to demonstrate it checked SAM.gov or received certification from applicable vendors to verify that contractors and vendors were not suspended or debarred. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. No documentation existed to ensure vendors to whom payments equal to or in excess of $25,000 were verified to not be suspended, debarred, or otherwise excluded. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation strengthen its system of internal controls to ensure that all vendors that are paid $25,000 or more, all or in part with federal funds, are not suspended or debarred from participating in federal program before entering into any covered transactions and retain documentation to support the performance of these procedures. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2024-001 Subject: Special Education Cluster (IDEA) - Suspension and Debarment Federal Agency: Department of Education Federal Programs: Special Education Grants to States, COVID-19 - Special Education Grants to States, Special Education Preschool Grants, COVID-19 - Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.027X, 84.173, 84.173X Federal Award Numbers and Years (or Other Identifying Numbers): H027A190084, 22611-093-ARP, H173A180104, H173A210104, 22619-093-ARP Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Condition and Context Prior to entering into a covered transaction for goods and services equal to or over $25,000 that were paid with Special Education Cluster funds, recipients are required to verify that such contractors or vendors are not suspended, debarred, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. The verification is to be done by checking SAM Exclusions, collecting a certification from that person, or adding a clause or condition to the covered transaction with that person. Upon inquiry of the School Corporation, the procedures in place over suspension and debarment during the audit period were to verify new vendors, when being entered into the system, were not excluded on SAM.gov. However, the School Corporation did not retain documentation of SAM.gov verifications, nor were checks done each year to verify that applicable vendors were still considered eligible under federal requirements. A population of six covered transactions for goods or services, totaling $569,754, that equaled or exceeded $25,000 paid from Special Education funds during the audit period was identified. No documentation was available to verify that the School Corporation performed the required checks. The lack of effective internal controls and noncompliance were systemic issues throughout the audit period. 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). . . ." INDIANA STATE BOARD OF ACCOUNTS 16 KOKOMO SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 31 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 if allowed by this rule; or (c) Adding a clause or condition to the covered transaction with that person." Cause A proper system of internal controls was not designed by the management of the School Corporation. The School Corporation was unable to provide documentation to demonstrate it checked SAM.gov or received certification from applicable vendors to verify that contractors and vendors were not suspended or debarred. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. No documentation existed to ensure vendors to whom payments equal to or in excess of $25,000 were verified to not be suspended, debarred, or otherwise excluded. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation strengthen its system of internal controls to ensure that all vendors that are paid $25,000 or more, all or in part with federal funds, are not suspended or debarred from participating in federal program before entering into any covered transactions and retain documentation to support the performance of these procedures. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2024-001 Subject: Special Education Cluster (IDEA) - Suspension and Debarment Federal Agency: Department of Education Federal Programs: Special Education Grants to States, COVID-19 - Special Education Grants to States, Special Education Preschool Grants, COVID-19 - Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.027X, 84.173, 84.173X Federal Award Numbers and Years (or Other Identifying Numbers): H027A190084, 22611-093-ARP, H173A180104, H173A210104, 22619-093-ARP Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Condition and Context Prior to entering into a covered transaction for goods and services equal to or over $25,000 that were paid with Special Education Cluster funds, recipients are required to verify that such contractors or vendors are not suspended, debarred, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. The verification is to be done by checking SAM Exclusions, collecting a certification from that person, or adding a clause or condition to the covered transaction with that person. Upon inquiry of the School Corporation, the procedures in place over suspension and debarment during the audit period were to verify new vendors, when being entered into the system, were not excluded on SAM.gov. However, the School Corporation did not retain documentation of SAM.gov verifications, nor were checks done each year to verify that applicable vendors were still considered eligible under federal requirements. A population of six covered transactions for goods or services, totaling $569,754, that equaled or exceeded $25,000 paid from Special Education funds during the audit period was identified. No documentation was available to verify that the School Corporation performed the required checks. The lack of effective internal controls and noncompliance were systemic issues throughout the audit period. 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). . . ." INDIANA STATE BOARD OF ACCOUNTS 16 KOKOMO SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 31 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 if allowed by this rule; or (c) Adding a clause or condition to the covered transaction with that person." Cause A proper system of internal controls was not designed by the management of the School Corporation. The School Corporation was unable to provide documentation to demonstrate it checked SAM.gov or received certification from applicable vendors to verify that contractors and vendors were not suspended or debarred. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. No documentation existed to ensure vendors to whom payments equal to or in excess of $25,000 were verified to not be suspended, debarred, or otherwise excluded. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation strengthen its system of internal controls to ensure that all vendors that are paid $25,000 or more, all or in part with federal funds, are not suspended or debarred from participating in federal program before entering into any covered transactions and retain documentation to support the performance of these procedures. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2024-001 Subject: Special Education Cluster (IDEA) - Suspension and Debarment Federal Agency: Department of Education Federal Programs: Special Education Grants to States, COVID-19 - Special Education Grants to States, Special Education Preschool Grants, COVID-19 - Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.027X, 84.173, 84.173X Federal Award Numbers and Years (or Other Identifying Numbers): H027A190084, 22611-093-ARP, H173A180104, H173A210104, 22619-093-ARP Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Condition and Context Prior to entering into a covered transaction for goods and services equal to or over $25,000 that were paid with Special Education Cluster funds, recipients are required to verify that such contractors or vendors are not suspended, debarred, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. The verification is to be done by checking SAM Exclusions, collecting a certification from that person, or adding a clause or condition to the covered transaction with that person. Upon inquiry of the School Corporation, the procedures in place over suspension and debarment during the audit period were to verify new vendors, when being entered into the system, were not excluded on SAM.gov. However, the School Corporation did not retain documentation of SAM.gov verifications, nor were checks done each year to verify that applicable vendors were still considered eligible under federal requirements. A population of six covered transactions for goods or services, totaling $569,754, that equaled or exceeded $25,000 paid from Special Education funds during the audit period was identified. No documentation was available to verify that the School Corporation performed the required checks. The lack of effective internal controls and noncompliance were systemic issues throughout the audit period. 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). . . ." INDIANA STATE BOARD OF ACCOUNTS 16 KOKOMO SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 31 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 if allowed by this rule; or (c) Adding a clause or condition to the covered transaction with that person." Cause A proper system of internal controls was not designed by the management of the School Corporation. The School Corporation was unable to provide documentation to demonstrate it checked SAM.gov or received certification from applicable vendors to verify that contractors and vendors were not suspended or debarred. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. No documentation existed to ensure vendors to whom payments equal to or in excess of $25,000 were verified to not be suspended, debarred, or otherwise excluded. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation strengthen its system of internal controls to ensure that all vendors that are paid $25,000 or more, all or in part with federal funds, are not suspended or debarred from participating in federal program before entering into any covered transactions and retain documentation to support the performance of these procedures. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2024-001 Subject: Special Education Cluster (IDEA) - Suspension and Debarment Federal Agency: Department of Education Federal Programs: Special Education Grants to States, COVID-19 - Special Education Grants to States, Special Education Preschool Grants, COVID-19 - Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.027X, 84.173, 84.173X Federal Award Numbers and Years (or Other Identifying Numbers): H027A190084, 22611-093-ARP, H173A180104, H173A210104, 22619-093-ARP Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Condition and Context Prior to entering into a covered transaction for goods and services equal to or over $25,000 that were paid with Special Education Cluster funds, recipients are required to verify that such contractors or vendors are not suspended, debarred, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. The verification is to be done by checking SAM Exclusions, collecting a certification from that person, or adding a clause or condition to the covered transaction with that person. Upon inquiry of the School Corporation, the procedures in place over suspension and debarment during the audit period were to verify new vendors, when being entered into the system, were not excluded on SAM.gov. However, the School Corporation did not retain documentation of SAM.gov verifications, nor were checks done each year to verify that applicable vendors were still considered eligible under federal requirements. A population of six covered transactions for goods or services, totaling $569,754, that equaled or exceeded $25,000 paid from Special Education funds during the audit period was identified. No documentation was available to verify that the School Corporation performed the required checks. The lack of effective internal controls and noncompliance were systemic issues throughout the audit period. 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). . . ." INDIANA STATE BOARD OF ACCOUNTS 16 KOKOMO SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 31 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 if allowed by this rule; or (c) Adding a clause or condition to the covered transaction with that person." Cause A proper system of internal controls was not designed by the management of the School Corporation. The School Corporation was unable to provide documentation to demonstrate it checked SAM.gov or received certification from applicable vendors to verify that contractors and vendors were not suspended or debarred. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. No documentation existed to ensure vendors to whom payments equal to or in excess of $25,000 were verified to not be suspended, debarred, or otherwise excluded. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation strengthen its system of internal controls to ensure that all vendors that are paid $25,000 or more, all or in part with federal funds, are not suspended or debarred from participating in federal program before entering into any covered transactions and retain documentation to support the performance of these procedures. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2024-001 Subject: Special Education Cluster (IDEA) - Suspension and Debarment Federal Agency: Department of Education Federal Programs: Special Education Grants to States, COVID-19 - Special Education Grants to States, Special Education Preschool Grants, COVID-19 - Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.027X, 84.173, 84.173X Federal Award Numbers and Years (or Other Identifying Numbers): H027A190084, 22611-093-ARP, H173A180104, H173A210104, 22619-093-ARP Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Condition and Context Prior to entering into a covered transaction for goods and services equal to or over $25,000 that were paid with Special Education Cluster funds, recipients are required to verify that such contractors or vendors are not suspended, debarred, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. The verification is to be done by checking SAM Exclusions, collecting a certification from that person, or adding a clause or condition to the covered transaction with that person. Upon inquiry of the School Corporation, the procedures in place over suspension and debarment during the audit period were to verify new vendors, when being entered into the system, were not excluded on SAM.gov. However, the School Corporation did not retain documentation of SAM.gov verifications, nor were checks done each year to verify that applicable vendors were still considered eligible under federal requirements. A population of six covered transactions for goods or services, totaling $569,754, that equaled or exceeded $25,000 paid from Special Education funds during the audit period was identified. No documentation was available to verify that the School Corporation performed the required checks. The lack of effective internal controls and noncompliance were systemic issues throughout the audit period. 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). . . ." INDIANA STATE BOARD OF ACCOUNTS 16 KOKOMO SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 31 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 if allowed by this rule; or (c) Adding a clause or condition to the covered transaction with that person." Cause A proper system of internal controls was not designed by the management of the School Corporation. The School Corporation was unable to provide documentation to demonstrate it checked SAM.gov or received certification from applicable vendors to verify that contractors and vendors were not suspended or debarred. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. No documentation existed to ensure vendors to whom payments equal to or in excess of $25,000 were verified to not be suspended, debarred, or otherwise excluded. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation strengthen its system of internal controls to ensure that all vendors that are paid $25,000 or more, all or in part with federal funds, are not suspended or debarred from participating in federal program before entering into any covered transactions and retain documentation to support the performance of these procedures. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2024-001 Subject: Special Education Cluster (IDEA) - Suspension and Debarment Federal Agency: Department of Education Federal Programs: Special Education Grants to States, COVID-19 - Special Education Grants to States, Special Education Preschool Grants, COVID-19 - Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.027X, 84.173, 84.173X Federal Award Numbers and Years (or Other Identifying Numbers): H027A190084, 22611-093-ARP, H173A180104, H173A210104, 22619-093-ARP Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Condition and Context Prior to entering into a covered transaction for goods and services equal to or over $25,000 that were paid with Special Education Cluster funds, recipients are required to verify that such contractors or vendors are not suspended, debarred, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. The verification is to be done by checking SAM Exclusions, collecting a certification from that person, or adding a clause or condition to the covered transaction with that person. Upon inquiry of the School Corporation, the procedures in place over suspension and debarment during the audit period were to verify new vendors, when being entered into the system, were not excluded on SAM.gov. However, the School Corporation did not retain documentation of SAM.gov verifications, nor were checks done each year to verify that applicable vendors were still considered eligible under federal requirements. A population of six covered transactions for goods or services, totaling $569,754, that equaled or exceeded $25,000 paid from Special Education funds during the audit period was identified. No documentation was available to verify that the School Corporation performed the required checks. The lack of effective internal controls and noncompliance were systemic issues throughout the audit period. 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). . . ." INDIANA STATE BOARD OF ACCOUNTS 16 KOKOMO SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 31 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 if allowed by this rule; or (c) Adding a clause or condition to the covered transaction with that person." Cause A proper system of internal controls was not designed by the management of the School Corporation. The School Corporation was unable to provide documentation to demonstrate it checked SAM.gov or received certification from applicable vendors to verify that contractors and vendors were not suspended or debarred. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. No documentation existed to ensure vendors to whom payments equal to or in excess of $25,000 were verified to not be suspended, debarred, or otherwise excluded. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation strengthen its system of internal controls to ensure that all vendors that are paid $25,000 or more, all or in part with federal funds, are not suspended or debarred from participating in federal program before entering into any covered transactions and retain documentation to support the performance of these procedures. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2024-002 Subject: Special Education Cluster (IDEA) - Equipment Federal Agency: Department of Education Federal Programs: Special Education Grants to States, COVID-19 - Special Education Grants to States Assistance Listings Numbers: 84.027, 84.027X Federal Award Numbers and Years (or Other Identifying Numbers): H027A190084, 22611-093-ARP Pass-Through Entity: Indiana Department of Education Compliance Requirement: Equipment and Real Property Management Audit Findings: Material Weakness, Other Matters INDIANA STATE BOARD OF ACCOUNTS 17 KOKOMO SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Repeat Finding The same finding also appeared in prior Report B60713 as Finding 2022-001. Condition and Context Per federal requirements property records must contain the following information about the equipment: description (including serial number or other identification number), source of funding for the property (including the federal award identification number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property (2 CFR 200.313(d)(1)). An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Equipment and Real Property Management compliance requirement. The School Corporation purchased $243,903 of equipment with Special Education funds. Equipment, totaling $78,874, was not added to the School Corporation's capital asset record. The School Corporation's capital asset record did not include an allocation or designation of what items were purchased with federal funds. The School Corporation had another system, called Destiny, in place to track special education equipment purchases. This system did include the required federal parameters to satisfy the property record requirements; however, equipment, totaling $220,149, was not added to this record. Additionally, one equipment item added to the Destiny system for a stander had discrepancies. It was listed at a purchase price of $3,059 and an acquisition date of June 23, 2023. The School Corporation's capital asset listed it at $7,430 with an acquisition date of January 30, 2024. The lack of effective internal controls and noncompliance were systemic issues throughout the audit period. 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 200.313(d)(1) states: "Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the FAIN), who holds title, the acquisition date, and cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property." INDIANA STATE BOARD OF ACCOUNTS 18 KOKOMO SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Cause A proper system of internal controls was not designed and implemented by the management of the School Corporation. The School Corporation's policies and procedures for tracking equipment purchased with federal funds was not sufficient and/or properly implemented to ensure all equipment was properly recorded. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, equipment purchased with federal funds for the Special Education program was not accurately recorded. Noncompliance with the grant agreement and the Equipment and Real Property Management compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned cost identified. Recommendation We recommended that the School Corporation's management establish and properly implement a system of internal controls to ensure compliance with the grant agreement and the Equipment and Real Property Management compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2024-002 Subject: Special Education Cluster (IDEA) - Equipment Federal Agency: Department of Education Federal Programs: Special Education Grants to States, COVID-19 - Special Education Grants to States Assistance Listings Numbers: 84.027, 84.027X Federal Award Numbers and Years (or Other Identifying Numbers): H027A190084, 22611-093-ARP Pass-Through Entity: Indiana Department of Education Compliance Requirement: Equipment and Real Property Management Audit Findings: Material Weakness, Other Matters INDIANA STATE BOARD OF ACCOUNTS 17 KOKOMO SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Repeat Finding The same finding also appeared in prior Report B60713 as Finding 2022-001. Condition and Context Per federal requirements property records must contain the following information about the equipment: description (including serial number or other identification number), source of funding for the property (including the federal award identification number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property (2 CFR 200.313(d)(1)). An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Equipment and Real Property Management compliance requirement. The School Corporation purchased $243,903 of equipment with Special Education funds. Equipment, totaling $78,874, was not added to the School Corporation's capital asset record. The School Corporation's capital asset record did not include an allocation or designation of what items were purchased with federal funds. The School Corporation had another system, called Destiny, in place to track special education equipment purchases. This system did include the required federal parameters to satisfy the property record requirements; however, equipment, totaling $220,149, was not added to this record. Additionally, one equipment item added to the Destiny system for a stander had discrepancies. It was listed at a purchase price of $3,059 and an acquisition date of June 23, 2023. The School Corporation's capital asset listed it at $7,430 with an acquisition date of January 30, 2024. The lack of effective internal controls and noncompliance were systemic issues throughout the audit period. 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 200.313(d)(1) states: "Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the FAIN), who holds title, the acquisition date, and cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property." INDIANA STATE BOARD OF ACCOUNTS 18 KOKOMO SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Cause A proper system of internal controls was not designed and implemented by the management of the School Corporation. The School Corporation's policies and procedures for tracking equipment purchased with federal funds was not sufficient and/or properly implemented to ensure all equipment was properly recorded. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, equipment purchased with federal funds for the Special Education program was not accurately recorded. Noncompliance with the grant agreement and the Equipment and Real Property Management compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned cost identified. Recommendation We recommended that the School Corporation's management establish and properly implement a system of internal controls to ensure compliance with the grant agreement and the Equipment and Real Property Management compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2024-002 Subject: Special Education Cluster (IDEA) - Equipment Federal Agency: Department of Education Federal Programs: Special Education Grants to States, COVID-19 - Special Education Grants to States Assistance Listings Numbers: 84.027, 84.027X Federal Award Numbers and Years (or Other Identifying Numbers): H027A190084, 22611-093-ARP Pass-Through Entity: Indiana Department of Education Compliance Requirement: Equipment and Real Property Management Audit Findings: Material Weakness, Other Matters INDIANA STATE BOARD OF ACCOUNTS 17 KOKOMO SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Repeat Finding The same finding also appeared in prior Report B60713 as Finding 2022-001. Condition and Context Per federal requirements property records must contain the following information about the equipment: description (including serial number or other identification number), source of funding for the property (including the federal award identification number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property (2 CFR 200.313(d)(1)). An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Equipment and Real Property Management compliance requirement. The School Corporation purchased $243,903 of equipment with Special Education funds. Equipment, totaling $78,874, was not added to the School Corporation's capital asset record. The School Corporation's capital asset record did not include an allocation or designation of what items were purchased with federal funds. The School Corporation had another system, called Destiny, in place to track special education equipment purchases. This system did include the required federal parameters to satisfy the property record requirements; however, equipment, totaling $220,149, was not added to this record. Additionally, one equipment item added to the Destiny system for a stander had discrepancies. It was listed at a purchase price of $3,059 and an acquisition date of June 23, 2023. The School Corporation's capital asset listed it at $7,430 with an acquisition date of January 30, 2024. The lack of effective internal controls and noncompliance were systemic issues throughout the audit period. 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 200.313(d)(1) states: "Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the FAIN), who holds title, the acquisition date, and cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property." INDIANA STATE BOARD OF ACCOUNTS 18 KOKOMO SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Cause A proper system of internal controls was not designed and implemented by the management of the School Corporation. The School Corporation's policies and procedures for tracking equipment purchased with federal funds was not sufficient and/or properly implemented to ensure all equipment was properly recorded. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, equipment purchased with federal funds for the Special Education program was not accurately recorded. Noncompliance with the grant agreement and the Equipment and Real Property Management compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned cost identified. Recommendation We recommended that the School Corporation's management establish and properly implement a system of internal controls to ensure compliance with the grant agreement and the Equipment and Real Property Management compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2024-002 Subject: Special Education Cluster (IDEA) - Equipment Federal Agency: Department of Education Federal Programs: Special Education Grants to States, COVID-19 - Special Education Grants to States Assistance Listings Numbers: 84.027, 84.027X Federal Award Numbers and Years (or Other Identifying Numbers): H027A190084, 22611-093-ARP Pass-Through Entity: Indiana Department of Education Compliance Requirement: Equipment and Real Property Management Audit Findings: Material Weakness, Other Matters INDIANA STATE BOARD OF ACCOUNTS 17 KOKOMO SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Repeat Finding The same finding also appeared in prior Report B60713 as Finding 2022-001. Condition and Context Per federal requirements property records must contain the following information about the equipment: description (including serial number or other identification number), source of funding for the property (including the federal award identification number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property (2 CFR 200.313(d)(1)). An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Equipment and Real Property Management compliance requirement. The School Corporation purchased $243,903 of equipment with Special Education funds. Equipment, totaling $78,874, was not added to the School Corporation's capital asset record. The School Corporation's capital asset record did not include an allocation or designation of what items were purchased with federal funds. The School Corporation had another system, called Destiny, in place to track special education equipment purchases. This system did include the required federal parameters to satisfy the property record requirements; however, equipment, totaling $220,149, was not added to this record. Additionally, one equipment item added to the Destiny system for a stander had discrepancies. It was listed at a purchase price of $3,059 and an acquisition date of June 23, 2023. The School Corporation's capital asset listed it at $7,430 with an acquisition date of January 30, 2024. The lack of effective internal controls and noncompliance were systemic issues throughout the audit period. 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 200.313(d)(1) states: "Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the FAIN), who holds title, the acquisition date, and cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property." INDIANA STATE BOARD OF ACCOUNTS 18 KOKOMO SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Cause A proper system of internal controls was not designed and implemented by the management of the School Corporation. The School Corporation's policies and procedures for tracking equipment purchased with federal funds was not sufficient and/or properly implemented to ensure all equipment was properly recorded. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, equipment purchased with federal funds for the Special Education program was not accurately recorded. Noncompliance with the grant agreement and the Equipment and Real Property Management compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned cost identified. Recommendation We recommended that the School Corporation's management establish and properly implement a system of internal controls to ensure compliance with the grant agreement and the Equipment and Real Property Management compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2024-001 Subject: Special Education Cluster (IDEA) - Suspension and Debarment Federal Agency: Department of Education Federal Programs: Special Education Grants to States, COVID-19 - Special Education Grants to States, Special Education Preschool Grants, COVID-19 - Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.027X, 84.173, 84.173X Federal Award Numbers and Years (or Other Identifying Numbers): H027A190084, 22611-093-ARP, H173A180104, H173A210104, 22619-093-ARP Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Condition and Context Prior to entering into a covered transaction for goods and services equal to or over $25,000 that were paid with Special Education Cluster funds, recipients are required to verify that such contractors or vendors are not suspended, debarred, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. The verification is to be done by checking SAM Exclusions, collecting a certification from that person, or adding a clause or condition to the covered transaction with that person. Upon inquiry of the School Corporation, the procedures in place over suspension and debarment during the audit period were to verify new vendors, when being entered into the system, were not excluded on SAM.gov. However, the School Corporation did not retain documentation of SAM.gov verifications, nor were checks done each year to verify that applicable vendors were still considered eligible under federal requirements. A population of six covered transactions for goods or services, totaling $569,754, that equaled or exceeded $25,000 paid from Special Education funds during the audit period was identified. No documentation was available to verify that the School Corporation performed the required checks. The lack of effective internal controls and noncompliance were systemic issues throughout the audit period. 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). . . ." INDIANA STATE BOARD OF ACCOUNTS 16 KOKOMO SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 31 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 if allowed by this rule; or (c) Adding a clause or condition to the covered transaction with that person." Cause A proper system of internal controls was not designed by the management of the School Corporation. The School Corporation was unable to provide documentation to demonstrate it checked SAM.gov or received certification from applicable vendors to verify that contractors and vendors were not suspended or debarred. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. No documentation existed to ensure vendors to whom payments equal to or in excess of $25,000 were verified to not be suspended, debarred, or otherwise excluded. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation strengthen its system of internal controls to ensure that all vendors that are paid $25,000 or more, all or in part with federal funds, are not suspended or debarred from participating in federal program before entering into any covered transactions and retain documentation to support the performance of these procedures. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2024-001 Subject: Special Education Cluster (IDEA) - Suspension and Debarment Federal Agency: Department of Education Federal Programs: Special Education Grants to States, COVID-19 - Special Education Grants to States, Special Education Preschool Grants, COVID-19 - Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.027X, 84.173, 84.173X Federal Award Numbers and Years (or Other Identifying Numbers): H027A190084, 22611-093-ARP, H173A180104, H173A210104, 22619-093-ARP Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Condition and Context Prior to entering into a covered transaction for goods and services equal to or over $25,000 that were paid with Special Education Cluster funds, recipients are required to verify that such contractors or vendors are not suspended, debarred, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. The verification is to be done by checking SAM Exclusions, collecting a certification from that person, or adding a clause or condition to the covered transaction with that person. Upon inquiry of the School Corporation, the procedures in place over suspension and debarment during the audit period were to verify new vendors, when being entered into the system, were not excluded on SAM.gov. However, the School Corporation did not retain documentation of SAM.gov verifications, nor were checks done each year to verify that applicable vendors were still considered eligible under federal requirements. A population of six covered transactions for goods or services, totaling $569,754, that equaled or exceeded $25,000 paid from Special Education funds during the audit period was identified. No documentation was available to verify that the School Corporation performed the required checks. The lack of effective internal controls and noncompliance were systemic issues throughout the audit period. 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). . . ." INDIANA STATE BOARD OF ACCOUNTS 16 KOKOMO SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 31 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 if allowed by this rule; or (c) Adding a clause or condition to the covered transaction with that person." Cause A proper system of internal controls was not designed by the management of the School Corporation. The School Corporation was unable to provide documentation to demonstrate it checked SAM.gov or received certification from applicable vendors to verify that contractors and vendors were not suspended or debarred. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. No documentation existed to ensure vendors to whom payments equal to or in excess of $25,000 were verified to not be suspended, debarred, or otherwise excluded. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation strengthen its system of internal controls to ensure that all vendors that are paid $25,000 or more, all or in part with federal funds, are not suspended or debarred from participating in federal program before entering into any covered transactions and retain documentation to support the performance of these procedures. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2024-001 Subject: Special Education Cluster (IDEA) - Suspension and Debarment Federal Agency: Department of Education Federal Programs: Special Education Grants to States, COVID-19 - Special Education Grants to States, Special Education Preschool Grants, COVID-19 - Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.027X, 84.173, 84.173X Federal Award Numbers and Years (or Other Identifying Numbers): H027A190084, 22611-093-ARP, H173A180104, H173A210104, 22619-093-ARP Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Condition and Context Prior to entering into a covered transaction for goods and services equal to or over $25,000 that were paid with Special Education Cluster funds, recipients are required to verify that such contractors or vendors are not suspended, debarred, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. The verification is to be done by checking SAM Exclusions, collecting a certification from that person, or adding a clause or condition to the covered transaction with that person. Upon inquiry of the School Corporation, the procedures in place over suspension and debarment during the audit period were to verify new vendors, when being entered into the system, were not excluded on SAM.gov. However, the School Corporation did not retain documentation of SAM.gov verifications, nor were checks done each year to verify that applicable vendors were still considered eligible under federal requirements. A population of six covered transactions for goods or services, totaling $569,754, that equaled or exceeded $25,000 paid from Special Education funds during the audit period was identified. No documentation was available to verify that the School Corporation performed the required checks. The lack of effective internal controls and noncompliance were systemic issues throughout the audit period. 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). . . ." INDIANA STATE BOARD OF ACCOUNTS 16 KOKOMO SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 31 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 if allowed by this rule; or (c) Adding a clause or condition to the covered transaction with that person." Cause A proper system of internal controls was not designed by the management of the School Corporation. The School Corporation was unable to provide documentation to demonstrate it checked SAM.gov or received certification from applicable vendors to verify that contractors and vendors were not suspended or debarred. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. No documentation existed to ensure vendors to whom payments equal to or in excess of $25,000 were verified to not be suspended, debarred, or otherwise excluded. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation strengthen its system of internal controls to ensure that all vendors that are paid $25,000 or more, all or in part with federal funds, are not suspended or debarred from participating in federal program before entering into any covered transactions and retain documentation to support the performance of these procedures. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2024-001 Subject: Special Education Cluster (IDEA) - Suspension and Debarment Federal Agency: Department of Education Federal Programs: Special Education Grants to States, COVID-19 - Special Education Grants to States, Special Education Preschool Grants, COVID-19 - Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.027X, 84.173, 84.173X Federal Award Numbers and Years (or Other Identifying Numbers): H027A190084, 22611-093-ARP, H173A180104, H173A210104, 22619-093-ARP Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Condition and Context Prior to entering into a covered transaction for goods and services equal to or over $25,000 that were paid with Special Education Cluster funds, recipients are required to verify that such contractors or vendors are not suspended, debarred, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. The verification is to be done by checking SAM Exclusions, collecting a certification from that person, or adding a clause or condition to the covered transaction with that person. Upon inquiry of the School Corporation, the procedures in place over suspension and debarment during the audit period were to verify new vendors, when being entered into the system, were not excluded on SAM.gov. However, the School Corporation did not retain documentation of SAM.gov verifications, nor were checks done each year to verify that applicable vendors were still considered eligible under federal requirements. A population of six covered transactions for goods or services, totaling $569,754, that equaled or exceeded $25,000 paid from Special Education funds during the audit period was identified. No documentation was available to verify that the School Corporation performed the required checks. The lack of effective internal controls and noncompliance were systemic issues throughout the audit period. 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). . . ." INDIANA STATE BOARD OF ACCOUNTS 16 KOKOMO SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 31 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 if allowed by this rule; or (c) Adding a clause or condition to the covered transaction with that person." Cause A proper system of internal controls was not designed by the management of the School Corporation. The School Corporation was unable to provide documentation to demonstrate it checked SAM.gov or received certification from applicable vendors to verify that contractors and vendors were not suspended or debarred. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. No documentation existed to ensure vendors to whom payments equal to or in excess of $25,000 were verified to not be suspended, debarred, or otherwise excluded. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation strengthen its system of internal controls to ensure that all vendors that are paid $25,000 or more, all or in part with federal funds, are not suspended or debarred from participating in federal program before entering into any covered transactions and retain documentation to support the performance of these procedures. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2024-001 Subject: Special Education Cluster (IDEA) - Suspension and Debarment Federal Agency: Department of Education Federal Programs: Special Education Grants to States, COVID-19 - Special Education Grants to States, Special Education Preschool Grants, COVID-19 - Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.027X, 84.173, 84.173X Federal Award Numbers and Years (or Other Identifying Numbers): H027A190084, 22611-093-ARP, H173A180104, H173A210104, 22619-093-ARP Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Condition and Context Prior to entering into a covered transaction for goods and services equal to or over $25,000 that were paid with Special Education Cluster funds, recipients are required to verify that such contractors or vendors are not suspended, debarred, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. The verification is to be done by checking SAM Exclusions, collecting a certification from that person, or adding a clause or condition to the covered transaction with that person. Upon inquiry of the School Corporation, the procedures in place over suspension and debarment during the audit period were to verify new vendors, when being entered into the system, were not excluded on SAM.gov. However, the School Corporation did not retain documentation of SAM.gov verifications, nor were checks done each year to verify that applicable vendors were still considered eligible under federal requirements. A population of six covered transactions for goods or services, totaling $569,754, that equaled or exceeded $25,000 paid from Special Education funds during the audit period was identified. No documentation was available to verify that the School Corporation performed the required checks. The lack of effective internal controls and noncompliance were systemic issues throughout the audit period. 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). . . ." INDIANA STATE BOARD OF ACCOUNTS 16 KOKOMO SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 31 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 if allowed by this rule; or (c) Adding a clause or condition to the covered transaction with that person." Cause A proper system of internal controls was not designed by the management of the School Corporation. The School Corporation was unable to provide documentation to demonstrate it checked SAM.gov or received certification from applicable vendors to verify that contractors and vendors were not suspended or debarred. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. No documentation existed to ensure vendors to whom payments equal to or in excess of $25,000 were verified to not be suspended, debarred, or otherwise excluded. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation strengthen its system of internal controls to ensure that all vendors that are paid $25,000 or more, all or in part with federal funds, are not suspended or debarred from participating in federal program before entering into any covered transactions and retain documentation to support the performance of these procedures. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2024-001 Subject: Special Education Cluster (IDEA) - Suspension and Debarment Federal Agency: Department of Education Federal Programs: Special Education Grants to States, COVID-19 - Special Education Grants to States, Special Education Preschool Grants, COVID-19 - Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.027X, 84.173, 84.173X Federal Award Numbers and Years (or Other Identifying Numbers): H027A190084, 22611-093-ARP, H173A180104, H173A210104, 22619-093-ARP Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Condition and Context Prior to entering into a covered transaction for goods and services equal to or over $25,000 that were paid with Special Education Cluster funds, recipients are required to verify that such contractors or vendors are not suspended, debarred, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. The verification is to be done by checking SAM Exclusions, collecting a certification from that person, or adding a clause or condition to the covered transaction with that person. Upon inquiry of the School Corporation, the procedures in place over suspension and debarment during the audit period were to verify new vendors, when being entered into the system, were not excluded on SAM.gov. However, the School Corporation did not retain documentation of SAM.gov verifications, nor were checks done each year to verify that applicable vendors were still considered eligible under federal requirements. A population of six covered transactions for goods or services, totaling $569,754, that equaled or exceeded $25,000 paid from Special Education funds during the audit period was identified. No documentation was available to verify that the School Corporation performed the required checks. The lack of effective internal controls and noncompliance were systemic issues throughout the audit period. 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). . . ." INDIANA STATE BOARD OF ACCOUNTS 16 KOKOMO SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 31 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 if allowed by this rule; or (c) Adding a clause or condition to the covered transaction with that person." Cause A proper system of internal controls was not designed by the management of the School Corporation. The School Corporation was unable to provide documentation to demonstrate it checked SAM.gov or received certification from applicable vendors to verify that contractors and vendors were not suspended or debarred. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. No documentation existed to ensure vendors to whom payments equal to or in excess of $25,000 were verified to not be suspended, debarred, or otherwise excluded. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation strengthen its system of internal controls to ensure that all vendors that are paid $25,000 or more, all or in part with federal funds, are not suspended or debarred from participating in federal program before entering into any covered transactions and retain documentation to support the performance of these procedures. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2024-001 Subject: Special Education Cluster (IDEA) - Suspension and Debarment Federal Agency: Department of Education Federal Programs: Special Education Grants to States, COVID-19 - Special Education Grants to States, Special Education Preschool Grants, COVID-19 - Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.027X, 84.173, 84.173X Federal Award Numbers and Years (or Other Identifying Numbers): H027A190084, 22611-093-ARP, H173A180104, H173A210104, 22619-093-ARP Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Condition and Context Prior to entering into a covered transaction for goods and services equal to or over $25,000 that were paid with Special Education Cluster funds, recipients are required to verify that such contractors or vendors are not suspended, debarred, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. The verification is to be done by checking SAM Exclusions, collecting a certification from that person, or adding a clause or condition to the covered transaction with that person. Upon inquiry of the School Corporation, the procedures in place over suspension and debarment during the audit period were to verify new vendors, when being entered into the system, were not excluded on SAM.gov. However, the School Corporation did not retain documentation of SAM.gov verifications, nor were checks done each year to verify that applicable vendors were still considered eligible under federal requirements. A population of six covered transactions for goods or services, totaling $569,754, that equaled or exceeded $25,000 paid from Special Education funds during the audit period was identified. No documentation was available to verify that the School Corporation performed the required checks. The lack of effective internal controls and noncompliance were systemic issues throughout the audit period. 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). . . ." INDIANA STATE BOARD OF ACCOUNTS 16 KOKOMO SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 31 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 if allowed by this rule; or (c) Adding a clause or condition to the covered transaction with that person." Cause A proper system of internal controls was not designed by the management of the School Corporation. The School Corporation was unable to provide documentation to demonstrate it checked SAM.gov or received certification from applicable vendors to verify that contractors and vendors were not suspended or debarred. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. No documentation existed to ensure vendors to whom payments equal to or in excess of $25,000 were verified to not be suspended, debarred, or otherwise excluded. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation strengthen its system of internal controls to ensure that all vendors that are paid $25,000 or more, all or in part with federal funds, are not suspended or debarred from participating in federal program before entering into any covered transactions and retain documentation to support the performance of these procedures. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2024-001 Subject: Special Education Cluster (IDEA) - Suspension and Debarment Federal Agency: Department of Education Federal Programs: Special Education Grants to States, COVID-19 - Special Education Grants to States, Special Education Preschool Grants, COVID-19 - Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.027X, 84.173, 84.173X Federal Award Numbers and Years (or Other Identifying Numbers): H027A190084, 22611-093-ARP, H173A180104, H173A210104, 22619-093-ARP Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Condition and Context Prior to entering into a covered transaction for goods and services equal to or over $25,000 that were paid with Special Education Cluster funds, recipients are required to verify that such contractors or vendors are not suspended, debarred, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. The verification is to be done by checking SAM Exclusions, collecting a certification from that person, or adding a clause or condition to the covered transaction with that person. Upon inquiry of the School Corporation, the procedures in place over suspension and debarment during the audit period were to verify new vendors, when being entered into the system, were not excluded on SAM.gov. However, the School Corporation did not retain documentation of SAM.gov verifications, nor were checks done each year to verify that applicable vendors were still considered eligible under federal requirements. A population of six covered transactions for goods or services, totaling $569,754, that equaled or exceeded $25,000 paid from Special Education funds during the audit period was identified. No documentation was available to verify that the School Corporation performed the required checks. The lack of effective internal controls and noncompliance were systemic issues throughout the audit period. 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). . . ." INDIANA STATE BOARD OF ACCOUNTS 16 KOKOMO SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 31 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 if allowed by this rule; or (c) Adding a clause or condition to the covered transaction with that person." Cause A proper system of internal controls was not designed by the management of the School Corporation. The School Corporation was unable to provide documentation to demonstrate it checked SAM.gov or received certification from applicable vendors to verify that contractors and vendors were not suspended or debarred. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. No documentation existed to ensure vendors to whom payments equal to or in excess of $25,000 were verified to not be suspended, debarred, or otherwise excluded. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation strengthen its system of internal controls to ensure that all vendors that are paid $25,000 or more, all or in part with federal funds, are not suspended or debarred from participating in federal program before entering into any covered transactions and retain documentation to support the performance of these procedures. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2024-002 Subject: Special Education Cluster (IDEA) - Equipment Federal Agency: Department of Education Federal Programs: Special Education Grants to States, COVID-19 - Special Education Grants to States Assistance Listings Numbers: 84.027, 84.027X Federal Award Numbers and Years (or Other Identifying Numbers): H027A190084, 22611-093-ARP Pass-Through Entity: Indiana Department of Education Compliance Requirement: Equipment and Real Property Management Audit Findings: Material Weakness, Other Matters INDIANA STATE BOARD OF ACCOUNTS 17 KOKOMO SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Repeat Finding The same finding also appeared in prior Report B60713 as Finding 2022-001. Condition and Context Per federal requirements property records must contain the following information about the equipment: description (including serial number or other identification number), source of funding for the property (including the federal award identification number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property (2 CFR 200.313(d)(1)). An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Equipment and Real Property Management compliance requirement. The School Corporation purchased $243,903 of equipment with Special Education funds. Equipment, totaling $78,874, was not added to the School Corporation's capital asset record. The School Corporation's capital asset record did not include an allocation or designation of what items were purchased with federal funds. The School Corporation had another system, called Destiny, in place to track special education equipment purchases. This system did include the required federal parameters to satisfy the property record requirements; however, equipment, totaling $220,149, was not added to this record. Additionally, one equipment item added to the Destiny system for a stander had discrepancies. It was listed at a purchase price of $3,059 and an acquisition date of June 23, 2023. The School Corporation's capital asset listed it at $7,430 with an acquisition date of January 30, 2024. The lack of effective internal controls and noncompliance were systemic issues throughout the audit period. 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 200.313(d)(1) states: "Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the FAIN), who holds title, the acquisition date, and cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property." INDIANA STATE BOARD OF ACCOUNTS 18 KOKOMO SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Cause A proper system of internal controls was not designed and implemented by the management of the School Corporation. The School Corporation's policies and procedures for tracking equipment purchased with federal funds was not sufficient and/or properly implemented to ensure all equipment was properly recorded. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, equipment purchased with federal funds for the Special Education program was not accurately recorded. Noncompliance with the grant agreement and the Equipment and Real Property Management compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned cost identified. Recommendation We recommended that the School Corporation's management establish and properly implement a system of internal controls to ensure compliance with the grant agreement and the Equipment and Real Property Management compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2024-002 Subject: Special Education Cluster (IDEA) - Equipment Federal Agency: Department of Education Federal Programs: Special Education Grants to States, COVID-19 - Special Education Grants to States Assistance Listings Numbers: 84.027, 84.027X Federal Award Numbers and Years (or Other Identifying Numbers): H027A190084, 22611-093-ARP Pass-Through Entity: Indiana Department of Education Compliance Requirement: Equipment and Real Property Management Audit Findings: Material Weakness, Other Matters INDIANA STATE BOARD OF ACCOUNTS 17 KOKOMO SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Repeat Finding The same finding also appeared in prior Report B60713 as Finding 2022-001. Condition and Context Per federal requirements property records must contain the following information about the equipment: description (including serial number or other identification number), source of funding for the property (including the federal award identification number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property (2 CFR 200.313(d)(1)). An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Equipment and Real Property Management compliance requirement. The School Corporation purchased $243,903 of equipment with Special Education funds. Equipment, totaling $78,874, was not added to the School Corporation's capital asset record. The School Corporation's capital asset record did not include an allocation or designation of what items were purchased with federal funds. The School Corporation had another system, called Destiny, in place to track special education equipment purchases. This system did include the required federal parameters to satisfy the property record requirements; however, equipment, totaling $220,149, was not added to this record. Additionally, one equipment item added to the Destiny system for a stander had discrepancies. It was listed at a purchase price of $3,059 and an acquisition date of June 23, 2023. The School Corporation's capital asset listed it at $7,430 with an acquisition date of January 30, 2024. The lack of effective internal controls and noncompliance were systemic issues throughout the audit period. 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 200.313(d)(1) states: "Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the FAIN), who holds title, the acquisition date, and cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property." INDIANA STATE BOARD OF ACCOUNTS 18 KOKOMO SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Cause A proper system of internal controls was not designed and implemented by the management of the School Corporation. The School Corporation's policies and procedures for tracking equipment purchased with federal funds was not sufficient and/or properly implemented to ensure all equipment was properly recorded. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, equipment purchased with federal funds for the Special Education program was not accurately recorded. Noncompliance with the grant agreement and the Equipment and Real Property Management compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned cost identified. Recommendation We recommended that the School Corporation's management establish and properly implement a system of internal controls to ensure compliance with the grant agreement and the Equipment and Real Property Management compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2024-002 Subject: Special Education Cluster (IDEA) - Equipment Federal Agency: Department of Education Federal Programs: Special Education Grants to States, COVID-19 - Special Education Grants to States Assistance Listings Numbers: 84.027, 84.027X Federal Award Numbers and Years (or Other Identifying Numbers): H027A190084, 22611-093-ARP Pass-Through Entity: Indiana Department of Education Compliance Requirement: Equipment and Real Property Management Audit Findings: Material Weakness, Other Matters INDIANA STATE BOARD OF ACCOUNTS 17 KOKOMO SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Repeat Finding The same finding also appeared in prior Report B60713 as Finding 2022-001. Condition and Context Per federal requirements property records must contain the following information about the equipment: description (including serial number or other identification number), source of funding for the property (including the federal award identification number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property (2 CFR 200.313(d)(1)). An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Equipment and Real Property Management compliance requirement. The School Corporation purchased $243,903 of equipment with Special Education funds. Equipment, totaling $78,874, was not added to the School Corporation's capital asset record. The School Corporation's capital asset record did not include an allocation or designation of what items were purchased with federal funds. The School Corporation had another system, called Destiny, in place to track special education equipment purchases. This system did include the required federal parameters to satisfy the property record requirements; however, equipment, totaling $220,149, was not added to this record. Additionally, one equipment item added to the Destiny system for a stander had discrepancies. It was listed at a purchase price of $3,059 and an acquisition date of June 23, 2023. The School Corporation's capital asset listed it at $7,430 with an acquisition date of January 30, 2024. The lack of effective internal controls and noncompliance were systemic issues throughout the audit period. 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 200.313(d)(1) states: "Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the FAIN), who holds title, the acquisition date, and cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property." INDIANA STATE BOARD OF ACCOUNTS 18 KOKOMO SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Cause A proper system of internal controls was not designed and implemented by the management of the School Corporation. The School Corporation's policies and procedures for tracking equipment purchased with federal funds was not sufficient and/or properly implemented to ensure all equipment was properly recorded. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, equipment purchased with federal funds for the Special Education program was not accurately recorded. Noncompliance with the grant agreement and the Equipment and Real Property Management compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned cost identified. Recommendation We recommended that the School Corporation's management establish and properly implement a system of internal controls to ensure compliance with the grant agreement and the Equipment and Real Property Management compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2024-002 Subject: Special Education Cluster (IDEA) - Equipment Federal Agency: Department of Education Federal Programs: Special Education Grants to States, COVID-19 - Special Education Grants to States Assistance Listings Numbers: 84.027, 84.027X Federal Award Numbers and Years (or Other Identifying Numbers): H027A190084, 22611-093-ARP Pass-Through Entity: Indiana Department of Education Compliance Requirement: Equipment and Real Property Management Audit Findings: Material Weakness, Other Matters INDIANA STATE BOARD OF ACCOUNTS 17 KOKOMO SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Repeat Finding The same finding also appeared in prior Report B60713 as Finding 2022-001. Condition and Context Per federal requirements property records must contain the following information about the equipment: description (including serial number or other identification number), source of funding for the property (including the federal award identification number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property (2 CFR 200.313(d)(1)). An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Equipment and Real Property Management compliance requirement. The School Corporation purchased $243,903 of equipment with Special Education funds. Equipment, totaling $78,874, was not added to the School Corporation's capital asset record. The School Corporation's capital asset record did not include an allocation or designation of what items were purchased with federal funds. The School Corporation had another system, called Destiny, in place to track special education equipment purchases. This system did include the required federal parameters to satisfy the property record requirements; however, equipment, totaling $220,149, was not added to this record. Additionally, one equipment item added to the Destiny system for a stander had discrepancies. It was listed at a purchase price of $3,059 and an acquisition date of June 23, 2023. The School Corporation's capital asset listed it at $7,430 with an acquisition date of January 30, 2024. The lack of effective internal controls and noncompliance were systemic issues throughout the audit period. 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 200.313(d)(1) states: "Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the FAIN), who holds title, the acquisition date, and cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property." INDIANA STATE BOARD OF ACCOUNTS 18 KOKOMO SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Cause A proper system of internal controls was not designed and implemented by the management of the School Corporation. The School Corporation's policies and procedures for tracking equipment purchased with federal funds was not sufficient and/or properly implemented to ensure all equipment was properly recorded. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, equipment purchased with federal funds for the Special Education program was not accurately recorded. Noncompliance with the grant agreement and the Equipment and Real Property Management compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned cost identified. Recommendation We recommended that the School Corporation's management establish and properly implement a system of internal controls to ensure compliance with the grant agreement and the Equipment and Real Property Management compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.