Audit 351125

FINDING 2024-001 Subject: Economic Adjustment Assistance - Special Tests and Provisions - Wage Rate Requirements Federal Agency: US Department of Commerce Federal Program: Economic Adjustment Assistance Assistance Listings Number: 11.307 Federal Award Number and Year (or Other Identifying Number): 06-79-06301 URI: 116544 Pass-Through Entity: Direct Compliance Requirements: Special Tests and Provisions - Wage Rate Requirements Audit Finding: Significant Deficiency Condition and Context An effective internal control system was not in place at the College in order to ensure compliance with the following compliance requirement: Special Tests and Provisions - Wage Rate Requirement. The College could not provide documentation or evidence to verify a review that the weekly certified payrolls were submitted by the contractor. The lack of effective internal controls was an isolated issue to one contractor during 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). . . ." Cause The College's management was unable to provide documentation to verify a review that certified payrolls were submitted by the contractor due to policies and procedures not being adequate to retain the documentation for the special tests and provisions - wage rate requirement. Effect Without the proper implementation of an effectively designed system of internal controls, the College cannot ensure the wage rate requirement is met. Noncompliance with the Special Tests and Provisions - Wage Rate Requirements compliance requirement could have resulted in the loss of federal funds to the College. Questioned Costs There were no questioned costs identified. INDIANA STATE BOARD OF ACCOUNTS 18 IVY TECH COMMUNITY COLLEGE OF INDIANA SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Recommendation We recommended that the College's management strengthen the internal controls related to the compliance requirement listed above. We also recommended strengthening its policies and procedures to ensure appropriate supporting documentation for evidence of review and other internal controls procedures for federal programs is retained to be presented for audit. 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: TRIO Cluster - Eligibility Federal Agency: US Department of Education Federal Programs: Student Support Services, Talent Search, Upward Bound Assistance Listings Numbers: 84.042A, 84.044, 84.047 Federal Award Numbers and Years (or Other Identifying Numbers): P042A200749, P042A200690, P042A201220, P042A201222, P044A220683, P047A221086, P047A221077 Compliance Requirement: Eligibility Audit Finding: Significant Deficiency Condition and Context An effective internal control system was not in place at the College to ensure compliance with the eligibility requirements. The following internal control deficiencies over determination of eligibility were noted:  For TRIO Student Support Services, 2 of the 42 students tested from the Richmond Campus did not have evidence of internal controls over admission to the program.  For TRIO Talent Search, 1 of the 40 students tested from the Northwest (Lake) Campus did not have evidence of internal controls over admission to the program.  For TRIO Upward Bound, 4 of the 26 students tested from the Indianapolis Campus did not have evidence of internal controls over admission to the program. The lack of internal controls was isolated to three of the seven campuses that host a TRIO program. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: INDIANA STATE BOARD OF ACCOUNTS 19 IVY TECH COMMUNITY COLLEGE OF INDIANA SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (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). . . ." Cause The College's management was unable to provide documentation that a review of students being properly admitted into the TRIO Program was performed. This was due to policies and procedures not being adequate to retain the documentation for TRIO Eligibility. Effect The failure to establish an effective internal control system could enable material noncompliance to go undetected. Noncompliance with the Eligibility compliance requirement could have resulted in the loss of federal funds to the College. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the College's management strengthen the internal controls related to the compliance requirement listed above. We also recommended strengthening its policies and procedures to ensure appropriate supporting documentation for evidence of review and other internal control procedures for federal programs are retained to be presented for audit. 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: TRIO Cluster - Eligibility Federal Agency: US Department of Education Federal Programs: Student Support Services, Talent Search, Upward Bound Assistance Listings Numbers: 84.042A, 84.044, 84.047 Federal Award Numbers and Years (or Other Identifying Numbers): P042A200749, P042A200690, P042A201220, P042A201222, P044A220683, P047A221086, P047A221077 Compliance Requirement: Eligibility Audit Finding: Significant Deficiency Condition and Context An effective internal control system was not in place at the College to ensure compliance with the eligibility requirements. The following internal control deficiencies over determination of eligibility were noted:  For TRIO Student Support Services, 2 of the 42 students tested from the Richmond Campus did not have evidence of internal controls over admission to the program.  For TRIO Talent Search, 1 of the 40 students tested from the Northwest (Lake) Campus did not have evidence of internal controls over admission to the program.  For TRIO Upward Bound, 4 of the 26 students tested from the Indianapolis Campus did not have evidence of internal controls over admission to the program. The lack of internal controls was isolated to three of the seven campuses that host a TRIO program. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: INDIANA STATE BOARD OF ACCOUNTS 19 IVY TECH COMMUNITY COLLEGE OF INDIANA SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (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). . . ." Cause The College's management was unable to provide documentation that a review of students being properly admitted into the TRIO Program was performed. This was due to policies and procedures not being adequate to retain the documentation for TRIO Eligibility. Effect The failure to establish an effective internal control system could enable material noncompliance to go undetected. Noncompliance with the Eligibility compliance requirement could have resulted in the loss of federal funds to the College. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the College's management strengthen the internal controls related to the compliance requirement listed above. We also recommended strengthening its policies and procedures to ensure appropriate supporting documentation for evidence of review and other internal control procedures for federal programs are retained to be presented for audit. 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: TRIO Cluster - Eligibility Federal Agency: US Department of Education Federal Programs: Student Support Services, Talent Search, Upward Bound Assistance Listings Numbers: 84.042A, 84.044, 84.047 Federal Award Numbers and Years (or Other Identifying Numbers): P042A200749, P042A200690, P042A201220, P042A201222, P044A220683, P047A221086, P047A221077 Compliance Requirement: Eligibility Audit Finding: Significant Deficiency Condition and Context An effective internal control system was not in place at the College to ensure compliance with the eligibility requirements. The following internal control deficiencies over determination of eligibility were noted:  For TRIO Student Support Services, 2 of the 42 students tested from the Richmond Campus did not have evidence of internal controls over admission to the program.  For TRIO Talent Search, 1 of the 40 students tested from the Northwest (Lake) Campus did not have evidence of internal controls over admission to the program.  For TRIO Upward Bound, 4 of the 26 students tested from the Indianapolis Campus did not have evidence of internal controls over admission to the program. The lack of internal controls was isolated to three of the seven campuses that host a TRIO program. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: INDIANA STATE BOARD OF ACCOUNTS 19 IVY TECH COMMUNITY COLLEGE OF INDIANA SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (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). . . ." Cause The College's management was unable to provide documentation that a review of students being properly admitted into the TRIO Program was performed. This was due to policies and procedures not being adequate to retain the documentation for TRIO Eligibility. Effect The failure to establish an effective internal control system could enable material noncompliance to go undetected. Noncompliance with the Eligibility compliance requirement could have resulted in the loss of federal funds to the College. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the College's management strengthen the internal controls related to the compliance requirement listed above. We also recommended strengthening its policies and procedures to ensure appropriate supporting documentation for evidence of review and other internal control procedures for federal programs are retained to be presented for audit. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2024-003 Subject: TRIO Cluster - Reporting Federal Agency: US Department of Education Federal Programs: Student Support Services, Upward Bound Assistance Listings Numbers: 84.042A, 84.047 Federal Award Numbers and Years (or Other Identifying Numbers): P042A200749, P042A200690, P042A201220, P042A201222, P044A220683, P047A221086, P047A221077 Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters INDIANA STATE BOARD OF ACCOUNTS 20 IVY TECH COMMUNITY COLLEGE OF INDIANA SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Condition and Context An effective internal control system was not in place at the College to ensure compliance with requirements related to the Reporting compliance requirement. The following errors in the reporting of key line items (per Part 4 of the Compliance Supplement) on the fiscal year 2023 Annual Performance Report (APR) were noted:  For Student Support Services at the Indianapolis campus, key line items were tested for 16 students. For 2 students, field 27 "College Grade Level (at the end of academic year)" was inaccurately reported.  For Student Support Services at the Richmond campus, key line items were tested for 17 students. o For 1 student, field 18 "Date of First Project Service" was inaccurately reported. o For 2 students, field 19 "College Grade Level (entry into project)" was inaccurately reported. o For 3 students, field 23 "Enrollment Status (at the end of academic year)" was inaccurately reported. o For 2 students, field 24 "Academic Standing" was inaccurately reported. o For 1 student, field 27 "College Grade Level (at end of academic year)" was inaccurately reported.  For Upward Bound at the Indianapolis campus, key line items were tested for 6 students. For 4 students, field 28 "Participation Level for reporting year" was inaccurately reported.  For Upward Bound at the Muncie campus, key line items were tested for 6 students. o For 2 students, field 16 "Eligibility" was inaccurately reported. o For 1 student, field 17 "At Risk: Reading Language Arts or Math Proficiency Not Achieved (at time of initial selection)" was inaccurately reported. The lack of effective internal controls and noncompliance was a systemic issue at 4 of the 7 campuses that were reported on the TRIO Program during 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 21 IVY TECH COMMUNITY COLLEGE OF INDIANA SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 2 CFR 200.329(c)(1) states in part: "The recipient or subrecipient must submit performance reports as required by the Federal award. . . ." 34 CFR 646.32(c) states in part: "Recordkeeping. A grantee must maintain participant records that show– (1) The basis for the grantee's determination that each participant is eligible to participate in the project under sec. 646.3; (2) The grantee's basis for determining the academic need for each participant; (3) The services that are provided to each participant; (4) The performance and progress of each participant by cohort for the duration of the participant's attendance at the grantee's institution . . ." Cause The College's management had not developed an effective system of internal controls that would have ensured compliance with the Reporting compliance requirement. The College had not developed policies and procedures to verify that TRIO Cluster reporting agreed with supporting records. Effect Without the proper implementation of an effectively designed system of internal control, the College cannot ensure reporting for TRIO Cluster is accurate and in agreement with supporting records. Noncompliance with the reporting requirement could have resulted in the loss of federal funds to the College. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the College's management strengthen the internal controls related to the compliance requirement listed above. We also recommended strengthening its policies and procedures to ensure reporting for the TRIO Cluster programs agree with supporting records of the College. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2024-003 Subject: TRIO Cluster - Reporting Federal Agency: US Department of Education Federal Programs: Student Support Services, Upward Bound Assistance Listings Numbers: 84.042A, 84.047 Federal Award Numbers and Years (or Other Identifying Numbers): P042A200749, P042A200690, P042A201220, P042A201222, P044A220683, P047A221086, P047A221077 Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters INDIANA STATE BOARD OF ACCOUNTS 20 IVY TECH COMMUNITY COLLEGE OF INDIANA SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Condition and Context An effective internal control system was not in place at the College to ensure compliance with requirements related to the Reporting compliance requirement. The following errors in the reporting of key line items (per Part 4 of the Compliance Supplement) on the fiscal year 2023 Annual Performance Report (APR) were noted:  For Student Support Services at the Indianapolis campus, key line items were tested for 16 students. For 2 students, field 27 "College Grade Level (at the end of academic year)" was inaccurately reported.  For Student Support Services at the Richmond campus, key line items were tested for 17 students. o For 1 student, field 18 "Date of First Project Service" was inaccurately reported. o For 2 students, field 19 "College Grade Level (entry into project)" was inaccurately reported. o For 3 students, field 23 "Enrollment Status (at the end of academic year)" was inaccurately reported. o For 2 students, field 24 "Academic Standing" was inaccurately reported. o For 1 student, field 27 "College Grade Level (at end of academic year)" was inaccurately reported.  For Upward Bound at the Indianapolis campus, key line items were tested for 6 students. For 4 students, field 28 "Participation Level for reporting year" was inaccurately reported.  For Upward Bound at the Muncie campus, key line items were tested for 6 students. o For 2 students, field 16 "Eligibility" was inaccurately reported. o For 1 student, field 17 "At Risk: Reading Language Arts or Math Proficiency Not Achieved (at time of initial selection)" was inaccurately reported. The lack of effective internal controls and noncompliance was a systemic issue at 4 of the 7 campuses that were reported on the TRIO Program during 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 21 IVY TECH COMMUNITY COLLEGE OF INDIANA SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 2 CFR 200.329(c)(1) states in part: "The recipient or subrecipient must submit performance reports as required by the Federal award. . . ." 34 CFR 646.32(c) states in part: "Recordkeeping. A grantee must maintain participant records that show– (1) The basis for the grantee's determination that each participant is eligible to participate in the project under sec. 646.3; (2) The grantee's basis for determining the academic need for each participant; (3) The services that are provided to each participant; (4) The performance and progress of each participant by cohort for the duration of the participant's attendance at the grantee's institution . . ." Cause The College's management had not developed an effective system of internal controls that would have ensured compliance with the Reporting compliance requirement. The College had not developed policies and procedures to verify that TRIO Cluster reporting agreed with supporting records. Effect Without the proper implementation of an effectively designed system of internal control, the College cannot ensure reporting for TRIO Cluster is accurate and in agreement with supporting records. Noncompliance with the reporting requirement could have resulted in the loss of federal funds to the College. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the College's management strengthen the internal controls related to the compliance requirement listed above. We also recommended strengthening its policies and procedures to ensure reporting for the TRIO Cluster programs agree with supporting records of the College. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2024-004 Subject: TRIO Cluster - Special Tests and Provisions - Core Curriculum Instruction in the Upward Bound Program Federal Agency: US Department of Education Federal Program: Upward Bound Program Assistance Listings Number: 84.047 Federal Award Numbers and Years (or Other Identifying Numbers): P047A221086, P047A221077 Compliance Requirement: Special Tests and Provisions - Core Curriculum Instruction in the Upward Bound Program Audit Finding: Significant Deficiency Condition and Context An effective internal control system was not in place at the College to ensure compliance with the Special Tests and Provisions - Core Curriculum Instruction in the Upward Bound Program compliance requirement. Applications for 15 participants in the Upward Bound Program were tested for evidence of review by 2 members of the TRIO staff. For 2 of the 15 applications tested, both from the Indianapolis campus, there was no documentation of a dual review at the Indianapolis campus. The lack of internal controls was isolated to one campus during 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). . . ." Cause The College's management was unable to provide evidence of review of applications for the TRIO Program was performed. This was due to policies and procedures not being adequate to retain the documentation for the TRIO Special Tests and Provisions - Core Curriculum Instruction in the Upward Bound Program. Effect The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the Special Tests and Provisions - Core Curriculum Instruction in the Upward Bound Program compliance requirement could have resulted in the loss of federal funds to the College. INDIANA STATE BOARD OF ACCOUNTS 23 IVY TECH COMMUNITY COLLEGE OF INDIANA SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Questioned Costs There were no questioned costs identified. Recommendation We recommended that the College's management strengthen the internal controls related to the compliance requirement listed above. We also recommended strengthening its policies and procedures to ensure appropriate supporting documentation for evidence of review and other internal control procedures for federal programs are retained to be presented for audit. 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: Economic Adjustment Assistance - Special Tests and Provisions - Wage Rate Requirements Federal Agency: US Department of Commerce Federal Program: Economic Adjustment Assistance Assistance Listings Number: 11.307 Federal Award Number and Year (or Other Identifying Number): 06-79-06301 URI: 116544 Pass-Through Entity: Direct Compliance Requirements: Special Tests and Provisions - Wage Rate Requirements Audit Finding: Significant Deficiency Condition and Context An effective internal control system was not in place at the College in order to ensure compliance with the following compliance requirement: Special Tests and Provisions - Wage Rate Requirement. The College could not provide documentation or evidence to verify a review that the weekly certified payrolls were submitted by the contractor. The lack of effective internal controls was an isolated issue to one contractor during 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). . . ." Cause The College's management was unable to provide documentation to verify a review that certified payrolls were submitted by the contractor due to policies and procedures not being adequate to retain the documentation for the special tests and provisions - wage rate requirement. Effect Without the proper implementation of an effectively designed system of internal controls, the College cannot ensure the wage rate requirement is met. Noncompliance with the Special Tests and Provisions - Wage Rate Requirements compliance requirement could have resulted in the loss of federal funds to the College. Questioned Costs There were no questioned costs identified. INDIANA STATE BOARD OF ACCOUNTS 18 IVY TECH COMMUNITY COLLEGE OF INDIANA SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Recommendation We recommended that the College's management strengthen the internal controls related to the compliance requirement listed above. We also recommended strengthening its policies and procedures to ensure appropriate supporting documentation for evidence of review and other internal controls procedures for federal programs is retained to be presented for audit. 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: TRIO Cluster - Eligibility Federal Agency: US Department of Education Federal Programs: Student Support Services, Talent Search, Upward Bound Assistance Listings Numbers: 84.042A, 84.044, 84.047 Federal Award Numbers and Years (or Other Identifying Numbers): P042A200749, P042A200690, P042A201220, P042A201222, P044A220683, P047A221086, P047A221077 Compliance Requirement: Eligibility Audit Finding: Significant Deficiency Condition and Context An effective internal control system was not in place at the College to ensure compliance with the eligibility requirements. The following internal control deficiencies over determination of eligibility were noted:  For TRIO Student Support Services, 2 of the 42 students tested from the Richmond Campus did not have evidence of internal controls over admission to the program.  For TRIO Talent Search, 1 of the 40 students tested from the Northwest (Lake) Campus did not have evidence of internal controls over admission to the program.  For TRIO Upward Bound, 4 of the 26 students tested from the Indianapolis Campus did not have evidence of internal controls over admission to the program. The lack of internal controls was isolated to three of the seven campuses that host a TRIO program. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: INDIANA STATE BOARD OF ACCOUNTS 19 IVY TECH COMMUNITY COLLEGE OF INDIANA SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (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). . . ." Cause The College's management was unable to provide documentation that a review of students being properly admitted into the TRIO Program was performed. This was due to policies and procedures not being adequate to retain the documentation for TRIO Eligibility. Effect The failure to establish an effective internal control system could enable material noncompliance to go undetected. Noncompliance with the Eligibility compliance requirement could have resulted in the loss of federal funds to the College. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the College's management strengthen the internal controls related to the compliance requirement listed above. We also recommended strengthening its policies and procedures to ensure appropriate supporting documentation for evidence of review and other internal control procedures for federal programs are retained to be presented for audit. 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: TRIO Cluster - Eligibility Federal Agency: US Department of Education Federal Programs: Student Support Services, Talent Search, Upward Bound Assistance Listings Numbers: 84.042A, 84.044, 84.047 Federal Award Numbers and Years (or Other Identifying Numbers): P042A200749, P042A200690, P042A201220, P042A201222, P044A220683, P047A221086, P047A221077 Compliance Requirement: Eligibility Audit Finding: Significant Deficiency Condition and Context An effective internal control system was not in place at the College to ensure compliance with the eligibility requirements. The following internal control deficiencies over determination of eligibility were noted:  For TRIO Student Support Services, 2 of the 42 students tested from the Richmond Campus did not have evidence of internal controls over admission to the program.  For TRIO Talent Search, 1 of the 40 students tested from the Northwest (Lake) Campus did not have evidence of internal controls over admission to the program.  For TRIO Upward Bound, 4 of the 26 students tested from the Indianapolis Campus did not have evidence of internal controls over admission to the program. The lack of internal controls was isolated to three of the seven campuses that host a TRIO program. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: INDIANA STATE BOARD OF ACCOUNTS 19 IVY TECH COMMUNITY COLLEGE OF INDIANA SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (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). . . ." Cause The College's management was unable to provide documentation that a review of students being properly admitted into the TRIO Program was performed. This was due to policies and procedures not being adequate to retain the documentation for TRIO Eligibility. Effect The failure to establish an effective internal control system could enable material noncompliance to go undetected. Noncompliance with the Eligibility compliance requirement could have resulted in the loss of federal funds to the College. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the College's management strengthen the internal controls related to the compliance requirement listed above. We also recommended strengthening its policies and procedures to ensure appropriate supporting documentation for evidence of review and other internal control procedures for federal programs are retained to be presented for audit. 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: TRIO Cluster - Eligibility Federal Agency: US Department of Education Federal Programs: Student Support Services, Talent Search, Upward Bound Assistance Listings Numbers: 84.042A, 84.044, 84.047 Federal Award Numbers and Years (or Other Identifying Numbers): P042A200749, P042A200690, P042A201220, P042A201222, P044A220683, P047A221086, P047A221077 Compliance Requirement: Eligibility Audit Finding: Significant Deficiency Condition and Context An effective internal control system was not in place at the College to ensure compliance with the eligibility requirements. The following internal control deficiencies over determination of eligibility were noted:  For TRIO Student Support Services, 2 of the 42 students tested from the Richmond Campus did not have evidence of internal controls over admission to the program.  For TRIO Talent Search, 1 of the 40 students tested from the Northwest (Lake) Campus did not have evidence of internal controls over admission to the program.  For TRIO Upward Bound, 4 of the 26 students tested from the Indianapolis Campus did not have evidence of internal controls over admission to the program. The lack of internal controls was isolated to three of the seven campuses that host a TRIO program. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: INDIANA STATE BOARD OF ACCOUNTS 19 IVY TECH COMMUNITY COLLEGE OF INDIANA SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (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). . . ." Cause The College's management was unable to provide documentation that a review of students being properly admitted into the TRIO Program was performed. This was due to policies and procedures not being adequate to retain the documentation for TRIO Eligibility. Effect The failure to establish an effective internal control system could enable material noncompliance to go undetected. Noncompliance with the Eligibility compliance requirement could have resulted in the loss of federal funds to the College. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the College's management strengthen the internal controls related to the compliance requirement listed above. We also recommended strengthening its policies and procedures to ensure appropriate supporting documentation for evidence of review and other internal control procedures for federal programs are retained to be presented for audit. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2024-003 Subject: TRIO Cluster - Reporting Federal Agency: US Department of Education Federal Programs: Student Support Services, Upward Bound Assistance Listings Numbers: 84.042A, 84.047 Federal Award Numbers and Years (or Other Identifying Numbers): P042A200749, P042A200690, P042A201220, P042A201222, P044A220683, P047A221086, P047A221077 Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters INDIANA STATE BOARD OF ACCOUNTS 20 IVY TECH COMMUNITY COLLEGE OF INDIANA SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Condition and Context An effective internal control system was not in place at the College to ensure compliance with requirements related to the Reporting compliance requirement. The following errors in the reporting of key line items (per Part 4 of the Compliance Supplement) on the fiscal year 2023 Annual Performance Report (APR) were noted:  For Student Support Services at the Indianapolis campus, key line items were tested for 16 students. For 2 students, field 27 "College Grade Level (at the end of academic year)" was inaccurately reported.  For Student Support Services at the Richmond campus, key line items were tested for 17 students. o For 1 student, field 18 "Date of First Project Service" was inaccurately reported. o For 2 students, field 19 "College Grade Level (entry into project)" was inaccurately reported. o For 3 students, field 23 "Enrollment Status (at the end of academic year)" was inaccurately reported. o For 2 students, field 24 "Academic Standing" was inaccurately reported. o For 1 student, field 27 "College Grade Level (at end of academic year)" was inaccurately reported.  For Upward Bound at the Indianapolis campus, key line items were tested for 6 students. For 4 students, field 28 "Participation Level for reporting year" was inaccurately reported.  For Upward Bound at the Muncie campus, key line items were tested for 6 students. o For 2 students, field 16 "Eligibility" was inaccurately reported. o For 1 student, field 17 "At Risk: Reading Language Arts or Math Proficiency Not Achieved (at time of initial selection)" was inaccurately reported. The lack of effective internal controls and noncompliance was a systemic issue at 4 of the 7 campuses that were reported on the TRIO Program during 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 21 IVY TECH COMMUNITY COLLEGE OF INDIANA SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 2 CFR 200.329(c)(1) states in part: "The recipient or subrecipient must submit performance reports as required by the Federal award. . . ." 34 CFR 646.32(c) states in part: "Recordkeeping. A grantee must maintain participant records that show– (1) The basis for the grantee's determination that each participant is eligible to participate in the project under sec. 646.3; (2) The grantee's basis for determining the academic need for each participant; (3) The services that are provided to each participant; (4) The performance and progress of each participant by cohort for the duration of the participant's attendance at the grantee's institution . . ." Cause The College's management had not developed an effective system of internal controls that would have ensured compliance with the Reporting compliance requirement. The College had not developed policies and procedures to verify that TRIO Cluster reporting agreed with supporting records. Effect Without the proper implementation of an effectively designed system of internal control, the College cannot ensure reporting for TRIO Cluster is accurate and in agreement with supporting records. Noncompliance with the reporting requirement could have resulted in the loss of federal funds to the College. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the College's management strengthen the internal controls related to the compliance requirement listed above. We also recommended strengthening its policies and procedures to ensure reporting for the TRIO Cluster programs agree with supporting records of the College. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2024-003 Subject: TRIO Cluster - Reporting Federal Agency: US Department of Education Federal Programs: Student Support Services, Upward Bound Assistance Listings Numbers: 84.042A, 84.047 Federal Award Numbers and Years (or Other Identifying Numbers): P042A200749, P042A200690, P042A201220, P042A201222, P044A220683, P047A221086, P047A221077 Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters INDIANA STATE BOARD OF ACCOUNTS 20 IVY TECH COMMUNITY COLLEGE OF INDIANA SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Condition and Context An effective internal control system was not in place at the College to ensure compliance with requirements related to the Reporting compliance requirement. The following errors in the reporting of key line items (per Part 4 of the Compliance Supplement) on the fiscal year 2023 Annual Performance Report (APR) were noted:  For Student Support Services at the Indianapolis campus, key line items were tested for 16 students. For 2 students, field 27 "College Grade Level (at the end of academic year)" was inaccurately reported.  For Student Support Services at the Richmond campus, key line items were tested for 17 students. o For 1 student, field 18 "Date of First Project Service" was inaccurately reported. o For 2 students, field 19 "College Grade Level (entry into project)" was inaccurately reported. o For 3 students, field 23 "Enrollment Status (at the end of academic year)" was inaccurately reported. o For 2 students, field 24 "Academic Standing" was inaccurately reported. o For 1 student, field 27 "College Grade Level (at end of academic year)" was inaccurately reported.  For Upward Bound at the Indianapolis campus, key line items were tested for 6 students. For 4 students, field 28 "Participation Level for reporting year" was inaccurately reported.  For Upward Bound at the Muncie campus, key line items were tested for 6 students. o For 2 students, field 16 "Eligibility" was inaccurately reported. o For 1 student, field 17 "At Risk: Reading Language Arts or Math Proficiency Not Achieved (at time of initial selection)" was inaccurately reported. The lack of effective internal controls and noncompliance was a systemic issue at 4 of the 7 campuses that were reported on the TRIO Program during 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 21 IVY TECH COMMUNITY COLLEGE OF INDIANA SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 2 CFR 200.329(c)(1) states in part: "The recipient or subrecipient must submit performance reports as required by the Federal award. . . ." 34 CFR 646.32(c) states in part: "Recordkeeping. A grantee must maintain participant records that show– (1) The basis for the grantee's determination that each participant is eligible to participate in the project under sec. 646.3; (2) The grantee's basis for determining the academic need for each participant; (3) The services that are provided to each participant; (4) The performance and progress of each participant by cohort for the duration of the participant's attendance at the grantee's institution . . ." Cause The College's management had not developed an effective system of internal controls that would have ensured compliance with the Reporting compliance requirement. The College had not developed policies and procedures to verify that TRIO Cluster reporting agreed with supporting records. Effect Without the proper implementation of an effectively designed system of internal control, the College cannot ensure reporting for TRIO Cluster is accurate and in agreement with supporting records. Noncompliance with the reporting requirement could have resulted in the loss of federal funds to the College. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the College's management strengthen the internal controls related to the compliance requirement listed above. We also recommended strengthening its policies and procedures to ensure reporting for the TRIO Cluster programs agree with supporting records of the College. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2024-004 Subject: TRIO Cluster - Special Tests and Provisions - Core Curriculum Instruction in the Upward Bound Program Federal Agency: US Department of Education Federal Program: Upward Bound Program Assistance Listings Number: 84.047 Federal Award Numbers and Years (or Other Identifying Numbers): P047A221086, P047A221077 Compliance Requirement: Special Tests and Provisions - Core Curriculum Instruction in the Upward Bound Program Audit Finding: Significant Deficiency Condition and Context An effective internal control system was not in place at the College to ensure compliance with the Special Tests and Provisions - Core Curriculum Instruction in the Upward Bound Program compliance requirement. Applications for 15 participants in the Upward Bound Program were tested for evidence of review by 2 members of the TRIO staff. For 2 of the 15 applications tested, both from the Indianapolis campus, there was no documentation of a dual review at the Indianapolis campus. The lack of internal controls was isolated to one campus during 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). . . ." Cause The College's management was unable to provide evidence of review of applications for the TRIO Program was performed. This was due to policies and procedures not being adequate to retain the documentation for the TRIO Special Tests and Provisions - Core Curriculum Instruction in the Upward Bound Program. Effect The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the Special Tests and Provisions - Core Curriculum Instruction in the Upward Bound Program compliance requirement could have resulted in the loss of federal funds to the College. INDIANA STATE BOARD OF ACCOUNTS 23 IVY TECH COMMUNITY COLLEGE OF INDIANA SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Questioned Costs There were no questioned costs identified. Recommendation We recommended that the College's management strengthen the internal controls related to the compliance requirement listed above. We also recommended strengthening its policies and procedures to ensure appropriate supporting documentation for evidence of review and other internal control procedures for federal programs are retained to be presented for audit. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.