Corrective Action Plans

FINDING 2024- 003 Finding Subject: Covid 19-Emergency Connectivity Fund Program-Special Tests and Provisions-Restricted Purpose Contact Person Responsible for Corrective Action: Alexandria Eckert/Tyler Haskough Contact Phone Number: 260-356-8312 Email Address: aeckert@hccsc.k12.in.us/thaskough@hccsc.k12.in.us Views of Responsible Officials: We concur with the findings. Description of Corrective Action Plan: Huntington County Community School Corporation will establish an Internal Control Standards manual by July 1, 2025, along with the Segregation of Duties chart by August 1, 2025. These standards will include items that detail the procedures and processes along with the checks and balances needed to ensure proper oversight, prevention, detection, correction, or errors. Our process will also ensure reporting compliance is followed. The Internal Control Standards manual will include special tests and provisions for restricted purposes. This provision will detail asset inventory for purchased equipment by equipment invoices by the Information Technology department. Details will be outlined on how student devices are assigned to students and tracked. Anticipated Completion Date: Huntington County Community School Corporation will establish the Internal Control Standards by July 1, 2025, and train administration and staff in August 2025.

2024-003 Program: Nationally Significant Freight and Highway Projects Financial Assistance Listing Number: 20.934 Federal Agency: U.S. Department of Transportation Pass-through: California Department of Transportation Award Year: Multiple Grant Award Number: Multiple Compliance Requirements: Special Tests and Provisions - Wage Rate Requirements Type of Finding: Material Weakness in Internal Control over Compliance and Material Instance of Noncompliance Management's Response: We concur. Views of Responsible Officials and Corrective Action: The City will further strengthen its internal controls to ensure timely reviews of certified payroll submissions are performed. This will include procedures to ensure that the information provided to the City by its consultant project manager is accurate. Additionally, ensure that the contractors and subcontractors submit the required certified payroll in a timely manner and in case of delinquencies, appropriate actions are taken. Name of Responsible Person: Jennifer Hennessy, Director of Finance Projected Implementation Date: 6.30.2025

2024-004 Program: Highway Planning and Construction Financial Assistance Listing Number: 20.205 Federal Agency: U.S. Department of Transportation Pass-through: California Department of Transportation Award Vear: Multiple Grant Award Number: Multiple Compliance Requirements: Special Tests and Provisions -Wage Rate Requirements Type of Finding: Material Weakness in Internal Control over Compliance and Instance of Noncompliance Management's Response: We concur. Views of Responsible Officials and Corrective Action: The City will further strengthen its internal controls to ensure timely reviews of certified payroll submissions are performed. This will include procedures to ensure that the information provided to the City by its consultant project manager is accurate. Additionally, ensure that the contractors and subcontractors submit the required certified payroll in a timely manner and in case of delinquencies, appropriate actions are taken. Name of Responsible Person: Jennifer Hennessy, Director of Finance Projected Implementation Date: 6.30.2025

2024-002 – Special Tests and Provisions (repeat of Finding 2023-002) Corrective action planned: Management will implement a series of corrective actions to address the findings to ensure consistent application of sliding fee discount. Actions to be taken are as follows: * Review of the sliding fee application to facilitate data collection for sliding fee discount program. * Implement a self-declaration or attestation for patients who cannot provide proof of income * Comprehensive training on the sliding fee program for all relevant staff * Implement monthly internal audits for sliding fee claims and provide feedback to staff based on findings and observations. Anticipated Completion Date: June 2025 Person Responsible for Corrective Action: Elizabeth David, CFO

Regent University agrees with this finding. The University will engage with the National Student Clearinghouse audit support office and will establish a working group with appropriate Regent stakeholders to review suggested changes made by the NSC to reporting methods, time buffers between reports, reporting frequency, and other “upstream” preventative measures that may be taken to prevent file backlogs. Internally, the University will establish formalized communication protocols between departments to be enacted in the case of an NSC enrollment reporting file delay that could result in noncompliance with enrollment reporting requirements. Regent University will establish a reporting process directly between the University and NSLDS to be used in the event of an NSC backlog that cannot be mitigated within the compliance window. Regent University will implement the first and second parts of this plan by June 30, 2025 and the final component (NSLDS direct file reporting process) by September 30, 2025. Name of responsible parties: Elizabeth Bayless (University Registrar) & Tameka Lyons (Associate Registrar)

FINDING 2024-005 Finding Subject:. 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 was required to submit five annual data reports as outlined below. Fund Applicable Reporting Period ESSER I July 1, 2021 – June 30, 2022 ESSER II July 1, 2021 – June 30, 2022 ESSER III July 1, 2021 – June 30, 2022 ESSER II July 1, 2022 – June 30, 2023 ESSER III July 1, 2022 – June 30, 2023 All five annual data reports were selected for testing. Two of the five annual data reports did not include the correct expenditure information. Specifically the ESSER II and ESSER III annual data reports with an applicable reporting period of July 1, 2022, to June 30, 2023, did not include expenditure data for this period. Instead, the annual reports incorrectly reported expenditures from the previous period of July 1, 2021 to June 30, 2022. Contact Person Responsible for Corrective Action: Greg Elkins, CFO Contact Phone Number and Email Address: (317) 485-3100, greg.elkins@mvcsc.k12.in.us Views of Responsible Officials: We agree with the finding. Description of Corrective Action Plan: Since the conclusion of the 2020-2022 SBOA audit, the CFO and Corporation Treasurer have archived numerous email threads and other evidence of communication which documents the process for pulling ESSER financial data from the Skyward Finance system and submitting the required reports. This documentation shows the CFO and Treasurer regularly communicating, checking and rechecking the data, and verifying the timely submission of that data. The school received periodic requests from the Indiana Department of Education, Office of Federal Grants asking it to submit financial data for all ESSER funds. Originally, the data requests were submitted through JotForms which do not have the capability of notifying any individuals other than the recipient. The school was required to create its own documents for proof of submission and did so. In subsequent requests, IDOE provided Excel spreadsheets to be completed and returned electronically. Those emails and spreadsheets have been curated by the school. The school has documented unclear instructions provided by IDOE, the pass through agency. The school accepts responsibility to report grant activity for the federally required reporting periods regardless. The school will ask for explicit instructions from IDOE and reconfirm the reporting data required and time period(s) in question. This additional layer of internal controls will be added to the process currently utilized by the CFO and Corporation Treasurer. The school has not expended any dollars from any ESSER fund since 2023. Anticipated Completion Date: TBD based on when the next reporting submission is requested by IDOE (all ESSER grants activities have ceased and the funds have been closed out locally.)

FINDING 2024-006 Finding Subject: Education Stabilization Fund--Reporting Contact Person Responsible for Corrective Action: Andrew McDaniel, Chief Financial and Operations Officer Contact Phone Number and Email Address: 260.894.3191 and mcdaniela@westnoble.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Chief Financial Operations Officer will prepare the reports and have the Curriculum Director review for accuracy. Anticipated Completion Date: July 1, 2026

FINDING 2024-004 Finding Subject: Child Nutrition Cluster--Eligibility Contact Person Responsible for Corrective Action: Deb Rodriguez, Food Service Director Contact Phone Number and Email Address: 260.894.3191 and rodriguezd@westnoble.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Food Service Director will review the directly certified student list from the state and verify that is correctly entered into the school’s software. The Chief Financial Officer will review the list from the state and review the list that is inputted into the school’s software to ensure accuracy. Anticipated Completion Date: September 30, 2025

Oversight of Internal Controls - Completeness and Existence of Federal Expenditures Type of Finding: Material Weakness in Internal Control over Financial Reporting/ Compliance • Contact Person Responsible: Frank Antuono, Business Manager • Corrective Action to be Taken: The District will implement a centralized, documented review process for all federal expenditure tracking. To address turnover-related gaps and avoid data inconsistency: o Internally prepared spreadsheets will be reconciled monthly and locked once reviewed o All federal award-related spreadsheets will be reviewed by a staff member other than the preparer o Changes to prior-year data will require approval and documentation o A documented checklist will be used for month-end reconciliations. Additionally, the Business Manager will oversee staff training on federal compliance requirements related to documentation and review processes.

Preparation of Schedule of Expenditures of Federal Awards Type of Finding: Material Weakness in Internal Control over Financial Reporting/ Compliance • Contact Person Responsible: Frank Antuono, Business Manager • Corrective Action to be Taken: The District will establish formal written policies and procedures for the preparation of the Schedule of Expenditures of Federal Awards (SEFA) in compliance with 2 CFR 200.51 0(a). These procedures will: o Identify all sources of federal revenue o We have added the assigned federal funding source codes to our district budget operation in CSIU, which will now allow us to track these expenditures back to our internally controlled spreadsheets as verification of expenditures. o Track expenditures using dedicated account codes in the general ledger o Assign responsibility for monthly reconciliation and schedule preparation o Include a secondary review of the SEFA by someone other than the preparer The Business Office will undergo training on SEFA requirements and reconciliation practices. These changes will ensure complete and accurate reporting of federal expenditures for all future reporting periods.

FINDING 2024-003 Finding Subject: Title I Grants to Local Education Agencies - Special Tests and Provisions - Assessment System Contact Person Responsible for Corrective Action: Caleb Logan, Corporation Testing Coordinator Contact Phone Number and Email Address: (260) 367-3677 caleb.logan@whitko.org . Views of Responsible Official: We concur with this finding. Summary of Finding: School Corporation is required to obtain and store the completed Indiana Testing Security and Integrity Agreements for the entire staff. The School Corporation Testing Coordinator is responsible to gather all completed forms from each building for all staff and to store them. The Corporation Testing Coordinator during this audit period was a former employee of the School Corporation. The files of the Indiana Testing Security and Integrity Agreements were unable to be located from the former Testing Coordinator’s files (electronic or printed). The School Corporation had a process with the distribution, completion, and storage of the Indiana Testing Security and Integrity Agreements. However, there was ineffective internal controls and additional oversight in place to prevent these files from being recovered. Description of Corrective Action Plan: At the Beginning of each school year, the Testing Coordinator will distribute the Indiana Testing Security and Integrity Agreements to all staff through each Building Administrator. Employee completed agreements will be returned to the Building Administrator. Each Building Administrator will store these agreements for their building, and in turn will provide a copy to the School Corporation Testing Coordinator. The Testing Coordinator will verify that all staff have completed the agreement with a staff check sheet. The Corporation Testing Coordinator will follow up with any employee who has not completed an agreement. Staff hired during the school year are required to complete the agreement as well. The Testing Coordinator has both a hard paper copy as well as a scanned pdf file saved for all the completed agreements. At the end of the school year, the hard copy of all employees along with the check sheet will be stored in the central office secured storage room. Anticipated Completion Date: Immediately

Findings and Questioned Costs Relating to Federal Awards: Energy Incentive Program Disbursement to Ineligible Providers and Beneficiaries. Similar to prior year finding 2023-003, the program “Apoyo Energético”, funded by the American Rescue Plan Act (ARPA), that resulted in this finding concluded early 2023, which lack of a complete and robust operational guidance. The guidance used to manage the process were simple, not quite restrictive, and with little internal controls for both suppliers and beneficiaries. DDEC has adopted guidelines for both suppliers and beneficiaries that are more restrictive, and specific with internal regulations that ensure data retention and storage. A second initiative of this program, being “Apoyo Energético 2.0” commenced April 2024, which is funded by a CDBG-DR funds, for registration of potential suppliers and are following the guidelines issued. No findings were noted related to this program for which controls were enhanced, as a result corrective actions related to the 2023 finding.

Finding 2024-007 Contact Person Responsible for Corrective Action: Cindy Skinner, Corporation Treasurer Contact Phone Number: 765-282-5615 View of Responsible Official: We Concur with the Findings Description of Corrective Action Plan: The Corporation Treasurer will review the Financial report more closely and make sure that internal controls are in place to ensure compliance. Anticipated Completion Date: March 2025

Finding 2024-005 Contact Person Responsible for Corrective Action: Cindy Skinner, Corporation Treasurer Contact Phone Number: 765-282-5615 View of Responsible Official: We Concur with the Findings Description of Corrective Action Plan: We will implement internal controls that will correct the Allowable Activities and Costs procedures for Federal Grants. Anticipated Completion Date: March 2025

Finding 2024-004 Contact Person Responsible for Corrective Action: Brenda Layne, Food Service Director Contact Phone Number: 765-289-7323 We concur with the finding. Corrective Action plan: As of SY 24/25 when the High School Treasurer checks the 10% of the paper applications, she will make a list of the ones she checked and it will be located in the application binder. As of March 1st, 2025 The Food Service Director will run a copy of Direct Certs that Titan has in their file, she will then cross check it with the list that is send from IDOE. She will keep both list together in a file after initialing it. Anticipated completion Date: March 2025

Audit Finding Reference: 2024-003 Improve Controls and Documentation over Payroll Process Planned Corrective Action: Halfway through FY24, the District implemented a new payroll system, ADP. Since onboarding, it has become apparent that the "crosswalk" between ADP account codes and Munis codes is not adequate for the complexity in reporting for many of the District's federal and state awards. As ADP is a highly customizable platform, the Payroll and Finance team are in the process of designing a structure for seamless integration between running payroll and posting payroll to Munis, and ultimately charging those costs to grant awards. While this is occurring, the accounting team will review and reconcile payroll as possible in alignment with budgeted grant expenses. Name of Contact Person: Lesa Beck, Senior Payroll Manager Heather Peters, Accounting Manager Anticipated Completion Date: 6/30/2025

FINDING 2024-002 Finding Subject: COVID-19 Education Stabilization Fund – Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Findings: Material Weakness Contact Person Responsible for Corrective Action: Todd Fleetwood, Director of Business and Operations Contact Phone Number: 260-244-5771 fleetwoodta@wccsonline.com Views of Responsible Official: Whitley County Consolidated Schools Todd Fleetwood Director of Business and Operations INDIANA STATE BOARD OF ACCOUNTS 21 107 North Walnut Street  Columbia City, Indiana 46725 Phone (260) 244-5771  Fax (260) 244-4590  Website http://wccsonline.com The School Corporation concurs with the finding. Description of Corrective Action Plan: The business office inadvertently omitted the reviewer’s sign-off on one of the grant reimbursement forms. This oversight will be promptly corrected. Anticipated Completion Date: 04/01/2025

Finding 2024-004 - U.S. Department of Education (USDE) - Higher Education Institutional Aid (Title III Programs) (Material weaknesses and Significant deficiencies): A. We observed the following questioned cost of $505,004 during our testing of Title III and Future Grant drawdowns (material weaknesses): a) Adequate supporting source documents and general ledger data was not readily on file to support three (3) of eleven drawdowns tested. The University subsequently supplied adjusting journal entries to reclass expenditures previously recorded elsewhere in the general ledger. However, the total amount of the questioned cost noted above was not substantiated, resulting in excess federal cash on hand. b) We noted two (2) drawdowns for payroll were drawn 20 days and nine (9) days before the actual payroll dates. B. Our testing of Title III cash disbursements revealed questioned cost of $55,525 as stated below (significant deficiency): a) Adequate supporting source documents, such as invoices, check request, and evidence of approval were not on file or provided for one (1) of eight (8) disbursements tested. b) One (1) check contained only one signature. C. We noted the following during our review of budget versus actual reporting. a) The University did not properly and accurately maintain budget vs actual schedules to adequately validate carryover and remaining balances. The budgets for Title Ill, Future grants appear to have been overspent; however, the reasonableness of under or over prior year remaining balances could not accurately be determined. D. We noted the following during our testing of time and effort reporting (significant deficiencies): a) The University subsequently provided corrected Time and Effort Reports for nine (9) out of 12 tested which we noted were previously missing employee signatures, signatures of approval by supervisor or next level of authority, salary distribution percentages, and grant funding codes. b) Personnel Action Forms originally provided for three (3) of four (4) employees tested did not contain salary allocations as evidence that salaries were to be allocated to the program. The University subsequently corrected the forms. c) The University also provided adjusting entries to reclassify salaries that were incorrectly recorded in the general ledger; however, we were unable to trace the salary distribution to the general ledger for two (2) of 12 tested. Auditor's Recommendation – 1) We recommend all drawdowns are approved by management prior to the request being made and reviewed to assure that drawdowns and supporting expenditures are accurately and timely recorded. Federal regulations require that funds drawn down are limited to the minimum amounts needed to cover immediate project cost and not made to cover future or budgeted expenditures. 2) We recommend the University require prior approval for all disbursements, including credit card, check, wires, and electronic funds transfer, and maintain supporting source documents in a manner that’s easily accessible when needed. Proper supporting source documents include invoices, approved expense/check request, payment advice copy, etc. 3) We recommend the University implement procedures for budget versus actual reporting to include allowable carryover budgets to accurately reflect remaining balances and to assure that the University is operating within the constraints of the grant budgets. 4) We recommend that the University maintain adequate supporting source documentation as evidence that time and effort reporting is accurately completed, reviewed and approved prior to seeking reimbursement for payroll expenses from the grantor. Federal regulations require that grant recipients provide reasonable assurance that charges are accurate, allowable, and properly allocated and that salary and wages charged to federal awards are based on actual rather than budget estimates. Corrective Action – The Vice President for Fiscal Affairs has implemented standard operating procedures to ensure the following: drawdown review and approval, centralize location for all grant related documents, award letters, invoices, etc. with accessibility for both Business Office and Sponsored Programs, and grant reconciliation completion date. The SOP will be included in the update Business Office Procedure document that will completed this fiscal year. The items identified in the 23-24 audit for grant were also contributed to the down-time of the ERP as well as having a new team in Sponsored Programs and Business Office reviewing and restoring the accounting records while trying to ensure accuracy and integrity in the recording of transactions. The institution disagrees with in-adequate approval of documents. The ERP is designed to not process purchase orders without appropriate approvals. All requisitions are approved by the area Vice President with any transactions $10,000 and over requires the signature of the President.

FINDING 2024-003 (Auditor Assigned Reference Number) Finding Subject: TRIO - Reporting Contact Person Responsible for Corrective Action: Nichole Stitt, AVP Sponsored Programs Contact Phone Number and Email Address: 317-921-4800 ext. 084987 and nstitt@ivytech.edu Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The college will develop an internal control system to ensure compliance with the requirement related to the TRIO reporting compliance requirement. Anticipated Completion Date: The projected date of completion for the CAP mentioned above is June 30, 2025. The Student Support Services APR process was corrected in April 2024, a query interfacing with Banner to identify errors in the APRs submitted by each campus, was created.

FFATA Reporting Prior Year Finding: 2023-004 Recommendation: We recommend the City establish procedures and internal controls to ensure that all required sub awards are reported timely and accurately to FSRS no later than the end of the month following the month of issuance of each sub award. Explanation of disagreement with audit finding: NO Action taken in response to finding: Review City’s policy, procedures, and internal controls to ensure the required sub awards and reported timely and accurately to FSRS. Name(s) of the contact person(s) responsible for corrective action: Jeffrey Crimer, Patrick Fletcher, & Kyera Pope. Planned completion date for corrective action plan: 06/30/25

YCIPTA will make the proper journal entries within QuickBooks to reflect the bus purchase properly.

To: Laura Sitrin, Director of Finance, Town of Falmouth From: Paul Dart, Director of Finance & Operations Date: March 31, 2025 RE: IDEA 240 Grant Expenditures The following outlines the findings, resolution and ongoing corrective actions for the IDEA FY24 Grant and FY25 Grant. Findings: Federal Award Findings and Questioned Costs 2024-001 U.S. Department of Education Passed-through the Commonwealth of Massachusetts’ Department of Elementary and Secondary Education Special Education Cluster (IDEA) – ALN 84.027 & 84.173 COVID-19 – Special Education Cluster (IDEA) – ALN 84.027X Resolution: The following corrective actions have been taken to immediately address this finding and ensure compliance with federal procurement regulations going forward: ● Journal entries have been submitted to the Town Accountant in order to move all FY24 expenses originally charged to the FY24 240 IDEA grant to either the School Choice Contracted Services account or Circuit Breaker Contracted Services account, as appropriate. ● A grant amendment is in process to reallocate funds in the FY24 240 grant originally intended for these specialized vendors to out of district tuition instead, ensuring compliance with procurement requirements. ● In addition to the above corrective actions related to the FY24 grant spending, any expenses for goods and services incurred in FY25 that did not meet federal procurement requirements have been corrected for FY24 grants that remain open. ● Grant amendments and journal entries for the FY25 240 grant and FY25 262 grant are in process for the current fiscal year to maintain compliance. These actions resolve the issue in the current fiscal year for all grants that are currently open. To strengthen internal controls and prevent recurrence, the Business Office is updating the District procurement policies and procedures to ensure the most restrictive procurement provision is followed for all purchases made with federal funds. All procurement and grant management staff have met to review training on the federal procurement process including thresholds, methods, documentation/justification for non-competitive procurements, and the differences between state and federal regulations. The district is committed to ensuring continued compliance through ongoing staff training, monitoring and policy updates. For further information or questions regarding this corrective action plan, please do not hesitate to contact me.

2024-006 Student Financial Assistance Cluster – Federal Assistance Listing Nos. 84.007, 84.063, 84.033 and 84.268 – Gramm-Leach-Bliley Act (GLBA) Recommendation: We recommend the University review is policies and procedures and update the information security plan to be GLBA compliant. Explanation of disagreement with audit finding: There is no disagreement to the audit finding. Action taken in response to finding: The Division of Information Technology will implement a comprehensive user account deactivation procedure. The user account deactivation procedure will significantly reduce security risks, ensure compliance with regulatory requirements, and protect sensitive information from unauthorized access. Name(s) of the contact person(s) responsible for corrective action: Executive Director of Network Services, Russell Weaver & Vice President / CIO, Darrell McMillon Planned completion date for corrective action plan: June 2025

2024-003 Student Financial Assistance Cluster – Federal Assistance Listing Nos. 84.063, and 84.268 – Enrollment Reporting Recommendation: We recommend the University evaluate its procedures and review policies in overseeing submissions to the NSLDS completed by the third-party servicer. Additionally, we recommend the University review its policies and procedures on reporting enrollment information to the NSLDS to ensure that all relevant information is being captured and reported timely in accordance with applicable regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Registrar’s Office will review and strengthen the enrollment report to ensure it pulls all required information according to the needs of the National Student Clearinghouse (NSCL) and the National Student Loan Data System (NSLDS). The Registrar’s Office will continue to work with the National Student Clearinghouse (NSCL) and National Student Loan Data System (NSLDS) on the specific enrollment submission scenarios that require a different submission/update requirement. Name(s) of the contact person(s) responsible for corrective action: University Registrar, Dr. Genita Mangum Planned completion date for corrective action plan: December 2025

Finding Number: 2024‐001 Program Name/Assistance Listing Title: Education Stabilization Fund Assistance Listing Number: 84.425 Contact Person: Brianne Ford, Business Manager Anticipated Completion Date: April 7,2025 Planned Corrective Action: WUSD2 has designed and implemented an effective internal control procedure to ensure that the federal reporting is tracked and completed in a timely manner. The Business Manager and Federal Programs Director will meet monthly to review grant funding and reporting. This will include any deadlines for submissions of grants and reporting.