Corrective Action Plans

Finding 2023-002 - Employee Record Retention and Health and Safety Training Federal Program: CCDF Cluster: AL# 93.575 - Child Care and Development Block Grant AL# 93.596 - Child Care Mandatory and Matching Funds of the CCDF U.S. Department of Health and Human Services MATERIAL WEAKNESS NONCOMPLIANCE Special Tests and Provisions Name of Contact Person: Juanita GreggCorrective Action: • Upon hire and through the SWCDC onboarding process for new child care center employees, Center Directors will review the attached Health and Safety Training document as part of the orientation process. Tablets are available for those individuals who do not have access to laptops. • New teachers will be directed to contact the Learning and Development Director with questions upon registration to SWCDC’s online training system which holds all required Health and Safety Trainings and is approved by NC DCDEE. All courses are approved by DCDEE, meet hourly requirements and are CEU worthy. Electronic certificates are submitted to the individual electronically through a personal email address. The following link is a list of Health and Safety courses: H&S Training Course List • Upon completion of Health and Safety courses, the employee will document their completion on the appropriate SWCDC orientation documentation and submit to the Center Director via email. • The Center Director will be responsible for ensuring receipt of the certificate, maintain in the staff file, and then document accordingly for annual compliance monitoring. • As onboarding continues for the new employee, periodic monitoring from Direct Services Manager, Child Care Resource and Referral, and other identified individuals will review staff files and monitor timely completion and compliance for Health and Safety Trainings. We have hired a position into Workforce Development to provide this service and serve as a resource to our Center Directors. This individual will do spot checks for these trainings on-site. For those child care center employees who maintain in good standing with successful completion of Health and Safety Trainings, he/she will be eligible for incentive based awards quarterly. Such as: quarterly drawing for classroom supplies, gift cards, self-care resources, etc. • For those child care center employees who are challenged with successful completion, those individuals will be targeted to create an action plan to meet the requirements. Resulting in opportunities to discuss technology needs, limitations or content area concerns, or other areas of concern that administration may be unaware of at the time of hire. • SWCDC created Orientation Notebooks for each center director. These notebooks contain all SWCDC documents needed for successful onboarding and training for new staff. These notebooks contain the updated forms attached. During orientation, new center staff are now required to create an online learning account through ON24, which SWCDC manages. This training account gives new staff access to the H&S trainings they need, as well as, provides additional resources and access to other trainings not owned by SWCDC to complete the H&S requirements as well. • SWCDC Hired a Fidelity Coach through Workforce Development. While this is a new position for SWCDC, part of her job duties will be to randomly check employee files for H&S training completion. These random checks will be in conjunction with each center’s annual compliance visit. Completion Date: January 22, 2024

FINDING 2023-007 Subject: COVID-19 – Education Stabilization Fund – Special Tests and Provisions – Wage Rate Requirements Summary of Finding: The School Corporation had not properly designed or implemented an effective system of internal controls to prevent, or detect and correct, noncompliance. Recommendation We recommended that management of the School Corporation design and implement a proper system of internal control, including policies and procedures that would provide segregation of duties to ensure appropriate reviews, approvals and oversight are taking place. Contact Person Responsible for Corrective Action: Casey Howard Contact Phone Number: 574-842-3364 x806 Views of the Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The corporation will create and implement an effective system to prevent, or detect and correct, noncompliance. We will create an oversight or review process to obtain the required certified payrolls. Anticipated Completion Date: Completed as of January 2024

FINDING 2023-006 Subject: COVID-19 – Education Stabilization Fund – Reporting Summary of Finding: The School Corporation did not submit annual reports in a timely manner during the first year of the audit period. Reimbursement requests included invoices which had been reimbursed previously and some request did not agree with supporting documentation. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure reports are submitted timely and supporting documentation is used and retained for reimbursement requests. Contact Person Responsible for Corrective Action: Casey Howard Contact Phone Number: 574-842-3364 x806 Views of the Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Reporting – The Treasurer and Deputy Treasurer will review and approve all grant reporting with Komputrol reports and grant approval. All deadlines will be submitted prior to due dates. The Superintendent, Treasurer, Deputy-Treasurer and/or Grant Writer will review all grant reimbursement requests prior to submission for accuracy. Anticipated Completion Date: Completed March 2023 – February 2024 INDIANA STATE

FINDING 2023-005 Subject: COVID-19 – Education Stabilization Fund – Equipment Summary of Finding: The School Corporation utilized Education Stabilization Funds to pay for equipment. The equipment was not included in the capital asset records. The capital asset listing provided did not identify which assets were purchased with federal dollars. Recommendation: We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure asset records include all the necessary information and new assets are added. Contact Person Responsible for Corrective Action: Casey Howard Contact Phone Number: 574-842-3364 x806 Views of the Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Our corporation has a company that updates our fixed assets every two years. Between the two years our Deputy-Treasurer with the assistance of the Treasurer will work in an excel document to track all additions/deletions, identification, location, etc. All assets regarding equipment will be identified if purchased with federal grant funds. Anticipated Completion Date: February 2024

FINDING 2023-002 Finding Subject: Subject: COVID-19 - Education Stabilization Fund - Reporting Summary of Finding: Reports submitted were not substantiated by the ledgers. Contact Person Responsible for Corrective Action: Kellie Romer (Corporation Treasurer/Finance Director) Contact Phone Number and Email Address: 765-653-9771 Ext. 1010, kromer@greencastle.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: The school corporation will establish a proper system for internal controls and develop procedures to ensure reports are supported by the financial records. Anticipated Completion Date: Immediately 2/8/2024

Corrective Action Plan For the Year Ended May 31, 2023 Finding 2023-001 Assistance Listing Number(s), Federal Agency and Program Name: 84.063, 84.007, 84.033, and 84.268; United States Department of Education (DOE), Student financial assistance cluster. Finding Type: Noncompliance and material weakness in internal control over compliance relating to special tests. Criteria: The Institute is responsible for designing, implementing, and maintaining internal control over compliance for special tests and provisions and for accurately and timely reporting significant data elements under the Campus- Level and Program-Level records within the National Student Loan Data System (NSLDS) that DOE considers high risk. Statement of Condition: Management implemented controls that specifically addressed the circumstances surrounding prior year finding 2022-001. Management's review of the enrollment reporting did not detect other errors on certain student data elements or timely reporting. Certain student records within the NSLDS were identified with inaccurate data elements and not timely reported. Questioned Costs: Questioned costs could not be determined. Context: 10 students were identified with inaccurate data elements and not timely reported out of a total of 25 students tested. Cause: The Institute’s internal control over compliance did not detect and correct the errors. The preparer incorrectly input the student's effective date and status into NSLDS resulting in inaccuracies in significant Campus- Level and Program-Level enrollment data elements that DOE considers high risk. Effect: The Institute incorrectly reported certain Campus-Level and Program-Level records in NSLDS which is information that DOE considers high risk and the Institute’s internal controls over compliance did not detect and correct the errors. Recommendation: We recommend management review policies and procedures surrounding enrollment reporting submissions to ensure the accuracy of data elements reported to DOE. A review performed by an appropriate individual separate from the preparer prior to the submission of the enrollment reports to NSLDS may improve the accuracy of enrollment reporting. Status: Completed February 2024 Corrective Action: Management agrees with the finding. Through internal investigation, it was determined that there was a procedural issue with the manual entry of two date fields which both need to be the same when submitted to National Student Clearinghouse (NSC). Human error during these manual checks caused one data field to be correct, and the other incorrect. This error has been fixed so that both fields will always be the same and accurate. We have also updated our enrollment reporting procedures to have the registrar log into NSLDS monthly to confirm that the prior month NSC status changes are properly recorded in NSLDS. Contact Jean Weimer Registrar 414-847-3272 jeanweimer@miad.edu Submitted Feb 23, 2024

Name of Contact Person: Candice Gobble, DSS Director Corrective Action/Management’s Response: Management concurs with this finding. Caseworkers will be reminded of appropriate signatures needed within the application process. Training and refresher training on voice and telephonic signatures will be provided to Energy staff. Supervisors and/or Quality Assurance staff will continue to perform monthly second party reviews. Emphasis will be placed on forms requiring applicant signatures to ensure all signatures are secured and documented accordingly. Proposed Completion Date: The above procedures are currently in place and will be monitored on an ongoing basis.

Name of Contact Person: Candice Gobble, DSS Director Corrective Action/Management’s Response: Management concurs with this finding. Caseworkers will be reminded of appropriate documentation techniques and when IV-D referrals are necessary within the eligibility determination process. Supervisors and/or Quality Assurance staff will continue to perform monthly second party reviews. Emphasis will be placed on documentation and IV-D referrals to ensure compliance with NC Medicaid policy. Proposed Completion Date: The above procedures are currently in place and will be monitored on an ongoing basis.

Condition: The School District’s controls did not prevent or detect and correct, in a timely manner, an employee’s time being charged to the Special Education Cluster that did not have adequate documentation. Additionally, the School District’s controls did not prevent or detect and correct, in a timely manner, updates to an employee status upon termination for employees charged to the Special Education Cluster and the Education Stabilization Fund. Planned Corrective Action: The School District concurs with the audit finding. The District has worked to strengthen internal controls to eliminate errors. The District will review its internal controls and provide additional training to staff. The School District is in the process of filling a Project Manager role on the Payroll Team who will be responsible for reviewing employee terminations and identifying potential overpayments. Until the role is filled, the Senior Director of Payroll and CFO will review employee exits quarterly to identify any potential overpayments and move funds to the general fund. New procedures for employee exit were rolled out in July in an effort to improve timely exiting of employees. Contact person responsible for corrective action: Jeremy Vidito, Chief Financial Officer Anticipated Completion Date: June 30, 2024

Reconciliations and Material Adjustments Corrective Action Plan Umatilla Morrow Head Start, Inc. (UMHS, Inc.) partnered with an independent accounting firm to streamline processes and develop templates for year-end closure. The agency used this opportunity to increase knowledge and understanding of needs associated with this task. As the fiscal department moves forward, systems and tools have been implemented to ensure timely closing and accurate tracking of this process. UMHS will continue to utilize the checklists put in place last fiscal year to guide month-end processes and reconciliations. Fiscal Management will review, monthly, the completion of said duties and will address any issues with staff immediately. Ongoing training will be done to ensure all fiscal staff members understand their role and duties within the agency. Bank reconciliations will continue to be completed monthly. The Executive Director, Director of Finance, Treasurer of the Board of Directors, or Other Designee will review the information and approval will be documented. UMHS will focus on segregation of duties within the fiscal department and ensure proper documentation is maintained. Person(s) Responsible: Executive Director, Director of Finance, Treasurer of the Board of Directors, or Other Designee Timing for Implementation: Immediately and Ongoing Reconciliations and Material Adjustments Corrective Action Plan Umatilla Morrow Head Start, Inc. (UMHS, Inc.) partnered with an independent accounting firm to streamline processes and develop templates for year-end closure. The agency used this opportunity to increase knowledge and understanding of needs associated with this task. As the fiscal department moves forward, systems and tools have been implemented to ensure timely closing and accurate tracking of this process. UMHS will continue to utilize the checklists put in place last fiscal year to guide month-end processes and reconciliations. Fiscal Management will review, monthly, the completion of said duties and will address any issues with staff immediately. Ongoing training will be done to ensure all fiscal staff members understand their role and duties within the agency. Bank reconciliations will continue to be completed monthly. The Executive Director, Director of Finance, Treasurer of the Board of Directors, or Other Designee will review the information and approval will be documented. UMHS will focus on segregation of duties within the fiscal department and ensure proper documentation is maintained. Person(s) Responsible: Executive Director, Director of Finance, Treasurer of the Board of Directors, or Other Designee Timing for Implementation: Immediately and Ongoing Reconciliations and Material Adjustments Corrective Action Plan Umatilla Morrow Head Start, Inc. (UMHS, Inc.) partnered with an independent accounting firm to streamline processes and develop templates for year-end closure. The agency used this opportunity to increase knowledge and understanding of needs associated with this task. As the fiscal department moves forward, systems and tools have been implemented to ensure timely closing and accurate tracking of this process. UMHS will continue to utilize the checklists put in place last fiscal year to guide month-end processes and reconciliations. Fiscal Management will review, monthly, the completion of said duties and will address any issues with staff immediately. Ongoing training will be done to ensure all fiscal staff members understand their role and duties within the agency. Bank reconciliations will continue to be completed monthly. The Executive Director, Director of Finance, Treasurer of the Board of Directors, or Other Designee will review the information and approval will be documented. UMHS will focus on segregation of duties within the fiscal department and ensure proper documentation is maintained. Person(s) Responsible: Executive Director, Director of Finance, Treasurer of the Board of Directors, or Other Designee Timing for Implementation: Immediately and Ongoing

Finding Number: 2023-001 Program Name/Assistance Listing Title: COVID-19 Education Stabilization Fund Assistance Listing Number: 84.425U Contact Person: Mercedes Villafana, Procurement Director and Kim Polyhronakis, Purchasing & Warehouse Coordinator Anticipated Completion Date: December 31, 2024 Planned Corrective Action: The District does not believe that an internal control issue exists but does acknowledge that an error occurred while reviewing the capital project documentation. The purchasing and accounts payable departments will collaborate and review all of the capital expenditures to ensure that documentation is included in the review of the applicable capital asset reporting totals.

FINDING 2023-002 Finding Subject: COVID-19 – Education Stabilization Fund - Reporting Summary of Finding: The School Corporation had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance. The School Corporation was required to submit annual data reports to the Indiana Department of Education (IDOE) via JotForm, a form/report builder. Data to be submitted included, but was not limited to, current period expenditures, prior period expenditures, and expenditures per activity. During the audit period the School Corporation submitted two ESSER I reports, two ESSER II reports and two ESSER III reports, for a total of six reports. The annual data reports were complied, prepared and submitted by the Assistant Superintendent without an oversight or review process in place to prevent, or detect and correct, errors. Furthermore, the reported data on two of the reports could not be traced back to records that accumulate or summarize the data; therefore, the accuracy and completeness of the reports could not be verified. Contact Person Responsible for Corrective Action: Jim Diagostino, Superintendent, and Lori Bennett, Treasurer Contact Phone Number: 317-539-9200 Views of Responsible Officials: We agree with the finding. Description of Corrective Action Plan: The Superintendent, or designee, will prepare the annual data reports to be reported to the IDOE by using records that accumulate or summarize the data. Prior to the submission of the reports, the Treasurer will review the records and annual data report. The Treasurer will initial and date a hard copy of the report to ensure accuracy and completeness. Anticipated Completion Date: March 31, 2024

Finding #2023-002 - Material Adjustments (Prior Year Finding #2022-002)Condition: Johnson Block and Company, Inc. proposed numerous adjusting journal entries to adjust District account balances. We deem these entries to be significant in relation to the financial statements. Since the District did not make these adjustments in the accounting system prior to the audit, a material weakness exists in the District's internal controls. Effect: This means that the proper recording and reporting of financial information may not occur within a timely manner. Cause: Financial information was not recorded in a timely manner and material adjustments were needed in order to correct various transactions. Criteria: Material adjusting journal entries not prepared by the District before the audit are considered an internal control weakness. Recommendation: Policies and procedures should be implemented to ensure account balances are properly recorded in a timely manner. Response: The District will work to establish policies and procedures to reduce the number of adjusting journal entries proposed by the auditor.

The administration of Texas Association for the Education of Young Children acknowledges receipt of the following audit findings for the fiscal year 2023. While in agreement with the findings, management provides the following response: Commencing in July 2023, an executive team was assembled, comprising the appointment of a Chief Financial Officer and a Director of Operations. Before this, the Executive Director managed all operations and finances, assisted by a Finance Manager and Administrative Assistant. The inclusion of over 25 years of professional leadership and Master level education of the CFO and DOO was crucial to accommodate the growth experienced by TXAEYC in preceding months and anticipated in FY23. Additionally, it led to an additional level of check and balances on operational and financial responsibilities. Upon the arrival of CFO Casey Cole, effective August 1, 2022, TXAEYC updated its accounting policies and procedures to align with GAAP and general best practices. This update guaranteed the provision of timely reports and documentation for all financial transactions, encompassing accounts payable, vendor profiles, contracts, and procurement, overseen by the DOO. The CFO collaborates with an external accounting firm tasked with managing data entry and monthly reconciliations, offering support and guidance as necessary. The involvement of the accounting firm enhances the review process and provides additional expertise to ensure the accuracy of financial records. Finding 2023-001: Internal Control Over Compliance: Federal Award Findings and Questioned Costs Management Response: The finding for not obtaining an open request for proposal was dated to fiscal year 2022 – not 2023. The request for proposal process was not followed as it was not posted to the public as policy states. Multiple vendors were sought out for quotes/RFI (request for information) due to the limited availability of qualified contractors. 1. Board Training: o Since fiscal year 2022, comprehensive board trainings have been conducted at the onset of each fiscal year. These sessions encompass a review of policies and procedures that TXAEYC must abide that include but are not limited to those that fall under the purview of the board and its committees. Both new and existing board members participate in these training to ensure alignment with organizational policies and best practices. 2. Updated Accounting Manual: o In fiscal year 2023, an updated Accounting Manual was developed. This revised manual contains clearer policies and delineates the responsibilities of staff and board members including procurement processes and adherence to established policies. o The manual was revised by the CFO, reviewed by the Finance Committee multiple times, and underwent executive staff leadership review. After extensive review, it was then sent to the board for final review and vote for unanimous approval, then implemented. 3. Enhanced Oversight with the Hiring of the CFO and DOO: o The recruitment of a Chief Financial Officer (CFO) and a Director of Operations (DOO) has strengthened oversight over procurement practices. The CFO and DOO are tasked with reviewing contracts and spearheading procurement activities, ensuring strict adherence to organizational policies and regulations. 4. Re-establishment of Finance Committee: o Recognizing the absence of a Finance Committee in fiscal year 2022, steps have been taken to re- establish this vital oversight body. The Finance Committee will play a pivotal role in monitoring procurement activities, reviewing financial processes, and providing guidance to ensure compliance with organizational policies and regulatory requirements. Additionally, further corrective measures will be implemented, including: • Conducting regular audits of procurement processes to identify and address any deviations from established policies. • Implementing a centralized procurement system to streamline and standardize procurement practices across the organization. • Providing ongoing training and guidance to staff involved in procurement to enhance their understanding of policies and procedures. • Establishing clear protocols for vendor selection and evaluation to ensure transparency and fairness in the procurement process. Parties Responsible: Oversight of Procurement: Director of Operations Board Training: Executive Director Maintaining a Finance Committee: Board of Directors Oversight of financial policies and procedures being followed: Chief Financial Officer Date of expected completion of corrective actions: The items outlined in the management response have already been put in place as of Fiscal Year 2023 and will continue to be fulfilled and monitored by responsible parties.

To Whom it May Concern: The purpose of the Corrective Action Plan (CAP) is to define corrective actions for resolving any non-conformances identified during the single audit for Fiscal Year 2023. Federal Award Findings and Questioned Costs Finding 2023-001 - Material Weakness in Internal Control - Reporting Assistance Listing Number: 93.498 COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Federal Agency: U.S. Department of Health and Human Services Pass-Through Agency: Not Applicable Award Number/Year: Not Applicable / 2023 Criteria: Non-federal entities in receipt of federal funds must comply with the requirements of 2 CFR 200.303(a), which require an entity to establish and maintain effective internal control over the Federal award to ensure compliance with Federal statutes, regulations and the terms and conditions of the Federal award. Recipients of Provider Relief Funds (PRF) payments must also comply with the reporting requirements described in the PRF terms and conditions and specified in directions issued by the U.S. Department of Health and Human Services. Condition/Context: The Company did not complete the PRF reporting in accordance with the U.S. Department of Health and Human Services guidance. For the one report filed during the award year it was noted to include incorrect lost revenue totals, due to clerical errors and the exclusion of certain affiliates. In addition, the reports tested did not contain a documented review and approval of the reports prior to submission. Effect: The amounts reported to Health Resources and Services Administration (HRSA) were not in accordance with established U.S. Department of Health and Human Services reporting guidance. Total cumulative lost revenue should be $13,893,503. Questioned Costs: None reported. Cause: Lack of management oversight. Recommendation: We recommend that management review and update, as needed, their procedure for completion of the reporting to ensure that a review and approval of such reporting is completed and documented prior to submission. Additionally, we recommend that management revise their lost revenue totals in any future submissions. Views of Responsible Officials: Management will revise policies and update cumulative lost revenue for any future HRSA PRF Reporting Portal submissions and retain documented proof that the reports were reviewed prior to filing. In addition, revised lost revenues of $13,893,503 exceed cumulative PRF payments applied to lost revenues of $1,626,560. Date of anticipated Completion – March 15, 2024 Person/Persons responsible for completion – Jarrod Leo, CFO and Michele Brown, Senior Director of Fiscal Services Sincerely, Jarrod Leo Chief Financial Officer

FINDING 2023-005 Finding Subject: Child Nutrition Cluster - Eligibility Summary of Finding: Material Weakness Condition and Context There was no evidence that the Direct Certifications were correctly and properly included in the software system, or that there was an oversight, review, or approval process over the Direct Certifications. Contact Person Responsible for Corrective Action: Lori Boyce Contact Phone Number and Email Address: 765-653-3148 lboyce@sputnam.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: The Food Service Director will have the Guidance Secretary check and initial that the Food Service Director has completed the Direct Certification correctly. Anticipated Completion Date: 2/2024

FINDING 2023-003 Finding Subject: Education Stabilization Fund - Reporting Summary of Finding: Material Weakness Condition and Context Reporting The School Corporation had not designed nor implemented a system of internal controls to ensure that the six Elementary and Secondary School Emergency Relief (ESSER) annual data reports required to be filed during the audit period were complete and accurate prior to submission. Each of the reports were prepared by one employee without an oversight or review process in place to prevent, or detect and correct errors. Contact Person Responsible for Corrective Action: Hilarie Logan Contact Phone Number and Email Address: 765-653-3119 hlogan@sputnam.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: The school corporation has a new Grants Coordinator who will participate in Internal Controls Training and sign off that they have done so. We will also incorporate dual signatures on documents as an additional means of approval/oversight. Anticipated Completion Date: 3/2024

Condition: The University has discrepancies between the date utilized in the return to Title IV calculations and the date required to be utilized based on federal regulations. There were three errors that attributed to this finding: 1) Of the 60 students tested, there were 2 students with discrepancies between the date utilized in return to Title IV calculations and the date required to be utilized based on federal regulations. 2) Of the 60 students tested, there was 1 identified for whom no return to Title IV calculation was performed, and, therefore, there was no return of funds until the student was selected for testing for the audit. 3) Of the 60 students tested, there was 1 identified for whom the incorrect amount of aid was returned. Planned Corrective Action: To address the first and third errors, the following actions will be taken: • To reinforce procedural knowledge of the return of Title IV aid, the staff responsible for the calculation of return of Title IV funds will complete a training course provided by the National Association of Student Financial Aid Administrators titled Return of Title IV Funds FA23. • Each semester, return procedures will be reviewed by staff and training on the use of the review checklist will be completed. • The Director of Student Accounts will perform audits of calculations each semester. • It will be requested that the Internal Audit department assist in the same. To address the second error, the Financial Aid Office will complete a monthly reconciliation to ensure the students receiving aid are enrolled by comparing enrollment reports from the student information system (SIS) and financial aid system. Additionally, the university is implementing a new financial aid system and will ensure integration between the SIS and financial aid system are working properly. Contact person responsible for corrective action: Brian Bell, Director Student Account Services (errors 1 & 3); Sarah Kasabian-Larson, Director of Scholarships and Financial Aid (error 2) Anticipated Completion Date: 11/15/2023 for procedural changes. Implementation of the new financial aid system scheduled for the 2024-2025 academic year.

Condition: The University did not report certain students' status to the NSLDS in an accurate and timely manner during the fiscal year. There were three errors identified that attributed to this finding: 1) Of the 60 students tested, there were 2 students who withdrew whose status changes were not reported accurately to the NSLDS. The student withdrew and was reported but with an incorrect effective date. 2) Of the 60 students tested, there were 13 students who withdrew or graduated whose status changes were not reported to the NSLDS within 60 days. 3) Of the 60 students tested, there were 3 students who withdrew whose status changes were not reported to the NSLDS. Planned Corrective Action: Additional staff training will be completed by the new Assistant Registrar and other staff within Records & Registration. Some duties will be shifted to between staff to better manage project time commitments and ensure accuracy. As of August 3, Fall 2022 and Spring 2023 identified students have been corrected in NSC and/or NSLDS. The monthly process to review all withdrawals that was implemented following the 2021-2022 audit will continue with additional controls to ensure each required step has been signed off on with additional review for compliance by the Director of Student Account Services and the Registrar. Implemented improvements to monthly Student Account Services and University Billing (SASUB) and Registrar’s Office enrollment reporting communication workflow to track completion and ensure timely reporting for Fall 2023 semester including: • Date Last date of attendance is determined. • Date file is sent to Registrar’s. • Date Registrar’s reviews each student on list. • Date Registrar’s updates NSC and/or NSLDS. • Date final compliance review against mandated reporting timelines is completed. Registrar’s and Office of Scholarships & Financial Aid in collaboration with academic leadership initiated a Verification of Non-Participation process in Summer 2023. Faculty will provide notification of any student who does not complete at least one academic related activity within the first two weeks of any course. The process was fully implemented for Fall 2023 semester. Additionally, the university is implementing a new financial aid system for the 2024-2025 aid year. Functionality in the new software will be utilized to assist with timely enrollment reporting. Contact person responsible for corrective action: Keith J. Malkowski, Registrar and Brian Bell, Director Student Account Services. Anticipated Completion Date: Fall 2023 for actions implemented by the Registrar’s Office. Implementation of the new financial aid system scheduled for the 2024-2025 academic year.

Finding 2023-001 Planned Corrective Action: The District’s management will evaluate the grant monitoring process and ensure all reporting for federal grant requirements is accurate and timely, with a planned implementation date by the Financial Officer of December 15, 2023.

FINDING 2023-002 Finding Subject: Emergency Connectivity Fund – Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance Summary of Finding: 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 Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Period of Performance compliance requirements. The School Corporation completed reimbursement requests and submitted them online; however, there was no evidence of an oversight or review process to ensure that the reimbursement requests were for allowable activities, allowable costs, and within the period of performance. Contact Person Responsible for Corrective Action: Derek Coulombe, Director of Technology Contact Phone Number and Email Address: (317) 856-5265; dcoulombe@decaturproud.org Views of Responsible Official: We concur with Audit Finding Description of Corrective Action Plan: The School Corporation will develop procedures to ensure disbursement requests are printed out and a representative from the Business Department documents review of them for allowable activity before final submission. Anticipated Completion Date: March 1, 2024

Finding 2023-006 – Education Stabilization Fund – Special Tests and Provisions - Wage Rate Requirements Contact Person Responsible for Corrective Action: Kimberly Nieves Contact Phone Number: 219-508-0504 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: As an internal control, the Director of Business Affairs and Human Resources has reviewed the Davis-Bacon Act. We will collect weekly payroll documentation for any constructions projects where Federal Grant money is used. Anticipated Completion Date: February 2024

Finding 2023-003 – Child Nutrition Cluster – Special Tests and Provisions – Verification of Free and Reduced Price Applications Contact Person Responsible for Corrective Action: Kimberly Nieves Contact Phone Number: 219-508-0504 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: As an internal control, the Director of Business Affairs and Human Resources has reviewed the process for Verification of Free and Reduced Price Applications. We have now contracted with a Food Service Director through NIESC. They will perform the Verification of Free and Reduced Price Applications and the Director of Business Affairs & HR will review these documents for accuracy. Anticipated Completion Date: FY24 Verification of Free and Reduced Price Application Review Period

Finding Number: 2023‐010 Federal Program, Assistance Listing Number and Name: 14.218, Department of Housing and Urban Development, Community Development Block Grant/Entitlement Grants Cluster, Community Development Block Grant/Entitlement Grants (CDBG) 14.241, Department of Housing and Urban Development, Housing Opportunities for Persons With Aids (HOPWA) 14.905, Department of Housing and Urban Development, Lead Hazard Reduction Demonstration Grant Program (Lead) Condition: Original Finding Description: The City duplicated costs charged to certain grants. Contact Person Responsible for Corrective Action: Regina Greear (ODFS) and Cynthia Saxton (OGA) Anticipated Completion Date: June 2023 Planned Corrective Action: The City will review during the AFCAP process and implement additional training that includes a review of its journal entry controls and approval processes to ensure journal entries are posted accurately and no duplicates costs.

Finding Number: 2023‐008 Federal Program, Assistance Listing Number and Name: ALN 14.241, Department of Department of Housing and Urban Development, Housing Opportunities for Persons with AIDS (HOPWA) and COVID‐19 HOPWA Condition: Original Finding Description: The controls in place were not adequate to ensure that amounts reported within the CAPER were accurate and complete in relation to activity reported in the general ledger and underlying records of the City. Contact Person Responsible for Corrective Action: Regina Greear (ODFS), Cynthia Saxton (OGA) and Julie Schneider (HRD) Anticipated Completion Date: June 2023 Planned Corrective Action: The City will review during the AFCAP process and implement additional reporting controls that includes verification of expenditures, retention of supporting documentation and a timely final reconciliation of the CAPER Report to the general ledger.