Corrective Action Plans

Finding 2023-001 – Significant Deficiency: Reporting - Compliance Finding Personnel Responsible for Corrective Action: CFO and Accounting department staff Anticipated Completion Date: Completed September 2023 Corrective Action Plan: A Safe Place will implement internal control procedures to ensure timely submission of all future reports. The CFO will review financial reporting prior to submission. Update: A Safe Place developed an infrastructure and implemented internal control procedures to ensure timely submission of all future reports. The CFO will review financial reporting prior to submission. The Program Administrative Manager will ensure all program performance reports (PPR) will be reviewed and submitted timely.

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF EDUCATION, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, CAREER AND TECHNICAL EDUCATION – BASIC GRANTS TO STATES – FEDERAL ALN 84.048 2023-001 Internal Control Over Compliance With Subrecipient Monitoring Requirements Finding Summary 2 CFR § 200.332 requires Intermediate District No. 287 (the District) as a pass-through entity, to have written subrecipient monitoring policies and procedures that include a written risk assessment of each subrecipient and documentation of the District’s monitoring of the subrecipient. Additionally, as a pass-through entity, the District is required to verify that every subrecipient is audited as required by 2 CFR § 200 Subpart F when it is expected that the subrecipient’s federal awards expended during the respective fiscal year equaled or exceeded the threshold for a federal Single Audit. During our audit, we noted that the District did have documented written controls to ensure compliance with the U.S. Office of Management and Budget’s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) subrecipient monitoring requirements. The District did not maintain documentation of its evaluation of each subrecipient’s risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward, nor did the District maintain documentation of the results of the subrecipients’ Single Audit, if any, for purposes of determining the appropriate subrecipient monitoring. Corrective Action Plan Actions Planned – The District will review its policies and procedures relating to subrecipient monitoring for its federal programs to ensure compliance with the Uniform Guidance in the future. Official Responsible – The District’s Executive Director of Business Services, Brian Schultz. Planned Completion Date – June 30, 2024. Disagreement With or Explanation of Finding – The District agrees with the finding. Plan to Monitor – The District’s Executive Director of Business Services, Brian Schultz, will assure appropriate internal controls and procedures are updated and in place to ensure compliance with subrecipient monitoring requirements.

Condition: Obligations were overstated by $1,502,835 on the March 31, 2023 Project and Expenditure report. Corrective Action Planned: Obligations and commitments were mistakenly considered the same. A correction will take place with our next Annual Submission that is due April 2024. Anticipated Completion Date: April 2024 Contact: Seth Knipe, Fire Chief

Condition: The Town has not documented in writing its policies regarding federal awards. Corrective Action Planned: A written federal policy has been prepared and is in the process of final acceptance by the Board of Selectmen. Anticipated Completion Date: June 2024 Contact: Austin Cyganiewicz, Town Administrator

Hagerstown Community College respectfully submits the following corrective action plan for the year ended June 30, 2023. Audit period: July 1, 2022 - June 30, 2023 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS- FEDERAL AWARD PROGRAMS AUDITS U.S. Department of Education 2023-001 NSLDS Enrollment Reporting Student Financial Aid Cluster-Assistance Listing No. 84.063, 84.268 Condition: During testing of enrollment status reporting, we noted that the incorrect enrollment status and effective date was reported to NSLDS. Recommendation: The College should evaluate their procedures and policies related to reporting status changes to NSLDS and enhance as deemed necessary to ensure that accurate information is reported to NSLDS. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Cause-Enrollment Status Reporting: Hagerstown Community College utilizes the National Student Clearinghouse (NSC) as a third-party provider in order to submit student information to the NSLDS. Student enrollment status corrections were uploaded to NSC timely and correctly; however, monitoring of the upload through success was inconsistent, resulting in error reports preventing the accurate and timely update to the enrollment statuses in NSLDS. No review was completed to ensure the upload was completed in NSLDS. Cause for Effective Date Reporting - Hagerstown Community College utilizes the National Student Clearinghouse (NSC) as a third-party provider in order to submit student information to the NSLDS. Student effective date corrections were uploaded to NSC correctly; however, monitoring of the upload through success was inconsistent, resulting in error reports preventing the accurate update of the status effective date NSLDS. No review was completed to ensure the upload was completed in NSLDS. The following actions have been implemented to resolve the deficiencies: The Director of Financial Aid has reached out to NSC to determine the errors in the file transmissions. NSC responded back with the issues that need to be research by HCC's Student Financial Aid Office and Registrar's office. Both offices will collaborate to identify the error and develop procedures to minimize the error from happening again. HCC plans to review the reporting procedures for withdrawn and graduating students. NSC sent HCC a detailed explanation of what needs to be reviewed to make sure the correct information is transmitted. Name(s) of the contact person(s) responsible for corrective action: Dr. Charles M. Scheetz, Director of Financial Aid and W. Christopher Baer, Registrar Planned completion date for corrective action plan: Summer 2024

2023-002 ALN 14.871 – Section 8 Housing Choice Vouchers Program – Eligibility The Executive Director acknowledges the finding and is following the auditor's recommendation as listed in the Schedule of Findings and Responses. Person Responsible for Correction of Finding: N. Lee Staton, Executive Director Projected Completion Date: June 30, 2024

Contact Person Debby Marshall Planned Corrective Action The Cooperative will ensure proper subrecipient monitoring is implemented. Planned Completion Date June 30, 2024.

Finding 2023-010 Finding Subject: COVID-19 - Education Stabilization Fund - Reporting Summary of Finding: During the audit period the School Corporation submitted two ESSER I reports, two ESSER II reports and one ESSER III report, for a total of five reports. A single employee prepared and submitted each annual data report without a review or oversight process in place to prevent, or detect and correct, errors. All five reports were selected for testing, two of which were not supported by the School Corporation's records. Contact Person Responsible for Corrective Action: Terry Richey and Chrystal Street Contact Phone Number and Email Address: 812.793.2061 trichey@crothersville.k12.in.us cstreet@crothersville.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The corporation treasurer and superintendent will review current internal controls policies especially segregation of duties and the areas in which we are lacking. We will consider rotation of duties in which employees will learn different roles when possible. We will also consider using technological solutions to enhance the reliability and integrity of processes. Another individual will start to review the information entered into the required ESSER reports prior to submission and supporting documentation will be retained. Anticipated Completion Date: April 1, 2024

FINDING 2023-008 Finding Subject: Title I Grants to Local Educational Agencies - Special Tests and Provisions - Assessment System Security Summary of Finding: The School Corporation had not adopted a test security policy. Although training had been provided to staff on an annual basis, the School Corporation had not established a system of internal controls to ensure monitoring of Assessment System Security occurred and was adequate. There were no INDIANA STATE BOARD OF ACCOUNTS 40 documented internal controls in place to ensure all individuals that should have received training did receive training. Contact Person Responsible for Corrective Action: Terry Richey and Chrystal Street Contact Phone Number and Email Address: 812.793.2061 trichey@crothersville.k12.in.us cstreet@crothersville.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The corporation will implement a Test Security Policy. Currently, the board is on the first reading and the second reading will occur on April 15, 2024. Superintendent is now the Title I director and is keeping the training certifications on file and retained for future audits. Anticipated Completion Date: April 15, 2024

FINDING 2023-007 Finding Subject: Title I Grants to Local Educational Agencies - Special Tests and Provisions - Annual Report Card, High School Graduation Rate Summary of Finding: The School Corporation did not have effective internal controls in place to ensure the correct reporting requirements for the High School Graduation Rate were being followed and that documentation was retained for audit. There was no tangible evidence of a process in place over the Annual Report Card/High School Graduation Rate to ensure that mobility codes were entered correctly. Of the 11 students tested, documentation was not presented for 9 students that were removed from the high school graduation cohort. Contact Person Responsible for Corrective Action: Terry Richey and Chrystal Street Contact Phone Number and Email Address: 812.793.2061 trichey@crothersville.k12.in.us cstreet@crothersville.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The corporation treasurer and superintendent will review current internal controls policies especially segregation of duties and the areas in which we are lacking. A reminder will go to the High School guidance counselor, secretary, and principal about getting withdrawal forms from students and placing the form in their permanent records. Anticipated Completion Date: April 1, 2024

FINDING 2023-006 Finding Subject: Title I Grants to Local Educational Agencies - Reporting Summary of Finding: During the audit period the School Corporation submitted three final expenditure reports. The final expenditure reports were completed and submitted by the Treasurer without an oversight or review process in place to prevent, or detect and correct, errors. In addition, the final expenditure report for the Title I School Improvement for program year 2021, due December 30, 2021, was submitted March 7, 2024. Contact Person Responsible for Corrective Action: Terry Richey and Chrystal Street Contact Phone Number and Email Address: 812.793.2061 trichey@crothersville.k12.in.us cstreet@crothersville.k12.in.us Views of Responsible Officials: We concur with the finding. INDIANA STATE BOARD OF ACCOUNTS 39 Description of Corrective Action Plan: The corporation treasurer and superintendent will review current internal controls policies especially segregation of duties and the areas in which we are lacking. We will consider rotation of duties in which employees will learn different roles when possible. We will also consider using technological solutions to enhance the reliability and integrity of processes. Another individual will start reviewing the final expenditure reports prior to submission to IDOE. Anticipated Completion Date: April 1, 2024

FINDING 2023-005 Finding Subject: Title I Grants to Local Educational Agencies - Matching, Level of Effort, Earmarking INDIANA STATE BOARD OF ACCOUNTS 38 Summary of Finding: Earmarking: There was no oversight or review process in place to ensure monitoring of each required set aside. The School Corporation did not provide documentation to show that the obligation was met or not met to service all the homeless students in the School Corporation and did not transfer the unused funds to the next grant award. Level of Effort: There was an oversight or review process at the School Corporation level over vendor expenditures; however, the oversight and review process was not documented to ensure the data used to complete the Form 9 was reported accurately in the correct fund, account, and object code. Contact Person Responsible for Corrective Action: Terry Richey and Chrystal Street Contact Phone Number and Email Address: 812.793.2061 trichey@crothersville.k12.in.us cstreet@crothersville.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The corporation treasurer and superintendent will review current internal controls policies especially segregation of duties and the areas in which we are lacking. We will consider rotation of duties in which employees will learn different roles when possible. We will also consider using technological solutions to enhance the reliability and integrity of processes. Communication from IDOE stating we do not have homeless students will start to be retained for support and we will obtain correct procedures from IDOE on proper procedures on transferring the unused funds to the next grant award. The Superintendent or Board will start to review vendor payments are paid from the proper fund, account and object code. Anticipated Completion Date: April 1, 2024

FINDING 2023-004 Finding Subject: Title I Grants to Local Educational Agencies - Eligibility Summary of Finding: One person was primarily responsible for compiling and uploading student data, including poverty status for Real Time reports. There was no additional review or verification being done to ensure that the numbers being pre-populated on the grant applications were correct. There was no internal control in place, such as an oversight, review or approval process to ensure eligibility was properly determined. There was no October 1 Real Time report presented for audit for either fiscal year 2020-2021 or 2021- 2022, which would have been used to pull in enrollment and poverty information for the 2021-2022 and 2022-2023 grants, respectively. Therefore, we were unable to verify if the amounts reported in the grant application were correct. Additionally, we were unable to verify if the correct socioeconomic status was properly reported for any of the students. Contact Person Responsible for Corrective Action: Terry Richey and Chrystal Street Contact Phone Number and Email Address: 812.793.2061 trichey@crothersville.k12.in.us cstreet@crothersville.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The corporation treasurer and superintendent will review current internal controls policies especially segregation of duties and the areas in which we are lacking. We will consider rotation of duties in which employees will learn different roles when possible. We will also consider using technological solutions to enhance the reliability and integrity of processes. Superintendent will retain the Real Time reports and other supporting documentation. Superintendent will also start verifying the numbers pre-populated on the grant application to ensure correct reporting. Another person will start reviewing the application prior to submission to IDOE. Anticipated Completion Date: April 1, 2024

FINDING 2023-003 Finding Subject: Title I Grants to Local Educational Agencies – Internal Controls Summary of Finding: The School Corporation did not have a properly developed internal control process over payroll transactions to ensure expenditures were allowed and in conformance with the cost principles. The Program Administrator reviewed a report attached to program reimbursement requests which showed the total amount paid from each fund and account; however, a detailed payroll report was not reviewed which would have identified the employee and related payroll benefits being paid from the grant fund. Contact Person Responsible for Corrective Action: Terry Richey and Chrystal Street Contact Phone Number and Email Address: 812.793.2061 trichey@crothersville.k12.in.us cstreet@crothersville.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: INDIANA STATE BOARD OF ACCOUNTS 37 The corporation treasurer and superintendent will review current internal controls policies especially segregation of duties and the areas in which we are lacking. We will consider rotation of duties in which employees will learn different roles when possible. We will also consider using technological solutions to enhance the reliability and integrity of processes. Superintendent will start to review the detailed payroll report posted to the Title I funds to match to the reimbursement request. Anticipated Completion Date: April 1, 2024

Recommendation: We recommend that the Department develop internal controls and procedures to ensure that all required subawards are reported timely to FSRS no later than the end of the month following the month of issuance in accordance with FFATA reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: HCD has made it part of a dedicated staff member to input the data into the FSRS system on a timely basis. HCD will also update their process so that all applicants must provide their UEI number. Name(s) of the contact person(s) responsible for corrective action: Sherrill Hampton Planned completion date for corrective action plan: 7/31/24

Recommendation: We recommend that the Department review and enhance its procedures and controls to ensure that expenditures charged to the program are incurred within the grant’s period of performance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A correction will be made to reduce the request by the overstated (by 1 day) amount in the 3/31 payroll report. A credit was issued to FEMA for the amount of $19,871.26 on Monday March 13, 2023 in relation to the finding noted. Name(s) of the contact person(s) responsible for corrective action: Angelia Adediran, Deputy Director City of Richmond Fire and Emergency Services

FINDING 2023-002 Information on the federal program: Subject: Child and Adult Care Food Program Federal Agency: Department of Agriculture Federal Program: Child and Adult Care Food Program Assistance Listing Number: 10.558 Federal Award Numbers and Years (Or Other Identifying Number): FY2022, FY2023 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Procurement and Suspension and Debarment Audit Finding: Material Weakness, Qualified Opinion Condition: There was not an effective control in place to review underlying transaction detail billed by the food service management compliance to verify compliance with Activities Allowed or Unallowed requirements. There was also not an effective control in place to monitor and review the food service management company followed procurement and suspension and debarment regulations. Context: As a result of the COVID-19 pandemic, waivers from the federal government provided free meals to all students through the Summer Food Service Program and allowed meals to be consumed off-site. Due to the changing regulations, the USDA and IDOE required School Corporations to implement an Integrity Plan for any schools providing Grab and Go Meals which includes inquiring of any adult requesting meals without children present as to how many children under the age of 18 would be served. Prior to March 2020, the School Corporation was using a point-of-sale system to record meals served. Starting in March 2020, the School Corporation was authorized by IDOE to utilize a clicker to track meals served. During the summer months of 2021, the School Corporation was also authorized by IDOE to provide meal pickup service on Wednesdays from 3 – 6 p.m. for 5 days’ worth of meal for both breakfast and lunch, resulting in 10 meals being served per child under the age of 18 each week. In June 2021, the Indiana Department of Education performed an unannounced meal site observation and a second, announced meal site review noting several program compliance and administrative issues. In July 2021, the IDOE performed a targeted review of the Summer Food Service Program for the period of March 2020 through May 2021 noting the following program compliance issues. • Meals were distributed without ensuring they were going to children ages 18 and younger as required by SFSP regulations. • Meals were taken off site to be distributed/dropped off at non—approved locations. • Meals were distributed and claimed on days when no meal service was approved, • Meals were distributed outside of approved meal service times. • Some meals were not distributed in household size quantities to the parent or guardian but distributed in bulk to large groups and knowingly transported in unsafe and unsanitary ways. • Meal count records were incomplete, unsigned, or missing required information. • Meal production was not adjusted when attendance fluctuations were noted. • Different menu items were ordered for and distributed to a specific group of individuals that was not the same as the planned menu. • Menu planning did not consider food inventory on hand and MSD of Pike Township’s access to USDA Foods (commodities) to reduce overall food costs. • Unauthorized donation, distribution, and disposal of foods purchased with federal funds was made without MSD Pike administration knowledge or approval. The review also noted a lack of administrative oversight of the food service management company contract including the following issues: • Food service management company representatives were making decisions regarding child nutrition program operations without consulting MSD of Pike Township administration. This practice was ongoing and occurred over several administrations. • Potential unallowable expenditures were noted in a review of monthly itemized invoices presented to MSD of Pike Township for recent payment. Items for personal consumption of food service management employees such as coffee, energy drinks, donuts, lunches, and even unauthorized travel expenses were presented but are considered unallowable expenditures from the food service account. As a result of the review, a total of $623,724 was disallowed for unsupported meal claims from September 2020 through May 2021 from the Child and Adult Care Food Program (CACFP) for At-Risk suppers reimbursed through the CACFP program. The School Corporation and IDOE agreed to a repayment plan to repay the disallowed costs identified which was paid in December 2021. Activities Allowed or Unallowed, Allowable Costs/Cost Principles During the testing of activities allowed or unallowed and allowed costs/cost principles, we selected 6 monthly invoices from the food service management company during the audit period. We noted there was not an internal control in place by School Corporation personnel to obtain and view the underlying support of transactions charged by the food service management company to verify the transaction was for a business purpose. The School Corporation did not obtain and review source documents, such as invoices or proof of payment for vendor transactions or a schedule of employees, assigned locations, salaries, and hours to be worked for payroll transactions submitted by the food service management company for reimbursement. We also selected a sample of 40 vendor transactions charged to Fund 0800 to test which were not related to the food service management company and incurred directly by the School Corporation. For 6 of the 40 transactions tested, we noted transactions for concession fees which were charged to the School Nutrition Program from July 2021 through September 2022 and are deemed unallowable. In October 2022, the School Corporation began recording all concession activity to Fund 2180, Concessions – District. The six concession transactions in our sample total $663 which are considered known questioned costs. Procurement and Suspension and Debarment The School Corporation did not have an internal control in place to monitor the food service management company was following proper procurement standards. School Corporations that contract with a food service management company on a cost reimbursement basis should ensure they are monitoring contracts sufficiently including verifying or reviewing the following: • The School Corporation should receive contract commits to supply. • Reviewing invoices received from the food service management company compared to amounts paid by the food service management company. • Reviewing contracts for compliance with Buy American • Verifying return of discounts, rebates, or credit are properly applied to the School Corporation’s account. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. MSD of Pike Township (Pike) agrees during the audit period effective controls were not in place to review and approve meal counts tracked and submitted for reimbursement, review underlying transaction detail billed, nor monitor and review the Food Service Management Company (FSMC) followed procurement and suspension and debarment regulations. Pike has increased the Business Office oversight of the Food Service Management Company (FSMC). Pike has hired a Food Service Financial Specialist to provide more the detailed review of invoices and operations ledger and the underlying transaction details. Additionally, effective October 2022, MSD of Pike Township hired a Director of Food Service to provide oversight of the Food Service Management Company (FSMC) including but not limited to meal counts, site audits, and compliance with procurement regulations. The FSMC no longer has access to submit claims on the CNP website. Responsible Party and Timeline for Completion: Greg A. Foster, Chief Financial Officer, will oversee the corrective action plan.

FINDING 2023-001 Information on the federal program: Subject: Child Nutrition Cluster Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program, and Summer Food Service Program for Children Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Numbers and Years (Or Other Identifying Number): FY2022, FY2023 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Procurement and Suspension and Debarment Audit Finding: Material Weakness, Qualified Opinion Condition: There was not an effective control in place to review underlying transaction detail billed by the food service management compliance to verify compliance with Activities Allowed or Unallowed requirements. There was also not an effective control in place to monitor and review the food service management company followed procurement and suspension and debarment regulations. Context: As a result of the COVID-19 pandemic, waivers from the federal government provided free meals to all students through the Summer Food Service Program and allowed meals to be consumed off-site. Due to the changing regulations, the USDA and IDOE required School Corporations to implement an Integrity Plan for any schools providing Grab and Go Meals which includes inquiring of any adult requesting meals without children present as to how many children under the age of 18 would be served. Prior to March 2020, the School Corporation was using a point-of-sale system to record meals served. Starting in March 2020, the School Corporation was authorized by IDOE to utilize a clicker to track meals served. During the summer months of 2021, the School Corporation was also authorized by IDOE to provide meal pickup service on Wednesdays from 3 – 6 p.m. for 5 days’ worth of meal for both breakfast and lunch, resulting in 10 meals being served per child under the age of 18 each week. In June 2021, the Indiana Department of Education performed an unannounced meal site observation and a second, announced meal site review noting several program compliance and administrative issues. In July 2021, the IDOE performed a targeted review of the Summer Food Service Program for the period of March 2020 through May 2021 noting the following program compliance issues. • Meals were distributed without ensuring they were going to children ages 18 and younger as required by SFSP regulations. • Meals were taken off site to be distributed/dropped off at non—approved locations. • Meals were distributed and claimed on days when no meal service was approved, • Meals were distributed outside of approved meal service times. • Some meals were not distributed in household size quantities to the parent or guardian but distributed in bulk to large groups and knowingly transported in unsafe and unsanitary ways. • Meal count records were incomplete, unsigned, or missing required information. • Meal production was not adjusted when attendance fluctuations were noted. • Different menu items were ordered for and distributed to a specific group of individuals that was not the same as the planned menu. • Menu planning did not consider food inventory on hand and MSD of Pike Township’s access to USDA Foods (commodities) to reduce overall food costs. • Unauthorized donation, distribution, and disposal of foods purchased with federal funds was made without MSD Pike administration knowledge or approval. The review also noted a lack of administrative oversight of the food service management company contract including the following issues: • Food service management company representatives were making decisions regarding child nutrition program operations without consulting MSD of Pike Township administration. This practice was ongoing and occurred over several administrations. • Potential unallowable expenditures were noted in a review of monthly itemized invoices presented to MSD of Pike Township for recent payment. Items for personal consumption of food service management employees such as coffee, energy drinks, donuts, lunches, and even unauthorized travel expenses were presented but are considered unallowable expenditures from the food service account. As a result of the IDOE review, a total of $1,299,365 was disallowed from the Summer Food Service Program. The School Corporation and IDOE agreed to a repayment plan to repay the disallowed costs identified. The School Corporation completed the repayment to IDOE in December 2021. Activities Allowed or Unallowed, Allowable Costs/Cost Principles During the testing of activities allowed or unallowed and allowed costs/cost principles, we selected 6 monthly invoices from the food service management company during the audit period. We noted there was not an internal control in place by School Corporation personnel to obtain and view the underlying support of transactions charged by the food service management company to verify the transaction was for a business purpose. The School Corporation did not obtain and review source documents, such as invoices or proof of payment for vendor transactions or a schedule of employees, assigned locations, salaries, and hours to be worked for payroll transactions submitted by the food service management company for reimbursement. We also selected a sample of 40 vendor transactions charged to Fund 0800 to test which were not related to the food service management company and incurred directly by the School Corporation. For 6 of the 40 transactions tested, we noted transactions for concession fees which were charged to the School Nutrition Program from July 2021 through September 2022 and are deemed unallowable. In October 2022, the School Corporation began recording all concession activity to Fund 2180, Concessions – District. The six concession transactions in our sample total $663 which are considered known questioned costs. Procurement and Suspension and Debarment The School Corporation did not have an internal control in place to monitor the food service management company was following proper procurement standards. School Corporations that contract with a food service management company on a cost reimbursement basis should ensure they are monitoring contracts sufficiently including verifying or reviewing the following: • The School Corporation should receive contract commits to supply. • Reviewing invoices received from the food service management company compared to amounts paid by the food service management company. • Reviewing contracts for compliance with Buy American • Verifying return of discounts, rebates, or credit are properly applied to the School Corporation’s account. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. MSD of Pike Township (Pike) agrees during the audit period effective controls were not in place to review and approve meal counts tracked and submitted for reimbursement, review underlying transaction detail billed, nor monitor and review the Food Service Management Company (FSMC) followed procurement and suspension and debarment regulations. Pike has increased the Business Office oversight of the Food Service Management Company (FSMC). Pike has hired a Food Service Financial Specialist to provide more the detailed review of invoices and operations ledger and the underlying transaction details. Additionally, effective October 2022, MSD of Pike Township hired a Director of Food Service to provide oversight of the Food Service Management Company (FSMC) including but not limited to meal counts, site audits, and compliance with procurement regulations. The FSMC no longer has access to submit claims on the CNP website. Responsible Party and Timeline for Completion: Greg A. Foster, Chief Financial Officer, will oversee the corrective action plan.

Common Origination and Disbursement (COD) Reporting Planned Corrective Action: The University’s Financial Aid Office will update the anticipated disbursement date to reflect the actual disbursement for 2022-23. We will review the current award year to ensure that the anticipated disbursement dates reflect the actual disbursement date. Person Responsible for Corrective Action Plan: Nicholas Capodice, Director of Financial Aid Anticipated Date of Completion: April 30, 2024

Gramm-Leach-Bliley Act (GLBA) Compliance Planned Corrective Action: The University’s IT Department will work to update procedures and controls to ensure any federal regulations of the FTC Safeguards Rule (16 CFR § 314.4(b)(1) - 16 CFR § 314.4(i)) that were found to be in partial compliance are remediated and brought into compliance. Some of these have already been remediated. We will work with other departments who administer third party vendor accounts to enforce MFA where there are gaps. A penetration test and the standing up of a tool to continuously monitor our network internally and those of third party vendors are already in startup phases Our information security program and risk assessment will be updated to reflect any recommendations offered by our auditors to fill any existing gaps in the 2023 audit. Person Responsible for Corrective Action Plan: Ron Loneker, Jr., Director, IT Special Projects Anticipated Date of Completion: May 31, 2024

Student Financial Aid Cluster: Federal Supplemental Educational Opportunity Grant – Assistance Listing No. 84.007 Federal Work Study Program – Assistance Listing No. 84.033 Federal Pell Grant Program – Assistance Listing No. 84.063 Federal Direct Student Loans – Assistance Listing No. 84.268 Recommendation: CLA recommends that the College review the requirement and implement a monitoring control to monitor the checks throughout the year. In addition, for the checks outstanding greater than 240 days, the College should return the funding to the U.S. Department of Education. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: To enhance the 240 Day Outstanding refund check processing efficiency and compliance, a streamlined procedure was developed and implemented to monitor all uncashed refund checks, including those from federal aid sources. This process will involve utilizing an Informer report every two weeks to compile a comprehensive list of uncashed refund checks for current and prior terms. Upon identification, a system-generated communication will be promptly dispatched to students, notifying them of the outstanding refund check and providing clear instructions to contact the Business Office. Calculations will be performed to ascertain if the refund originates from a federal aid source. For students with federal aid-related outstanding refunds, outreach efforts will be undertaken. Additionally, a progressive maintained cumulative report will serve as a real-time monitoring mechanism to track the status of refunds and ensure timely compliance. Continuous open communication will be maintained with the Financial Aid and Compliance team, facilitating the provision of student refunds requiring action and fostering collaboration across departments to address any outstanding issues effectively. The above-detailed process has already proven effective and noticeably successful in addressing the challenges associated with uncashed refund checks, particularly those originating from federal aid sources. Moving forward, this process will be continuously optimized and refined as system enhancements allow. Regular evaluations will be conducted to identify areas for improvement and implement necessary adjustments, ensuring that the refund processing workflow remains efficient, compliant, and responsive to the evolving needs of both students and regulatory requirements. This commitment to ongoing optimization underscores our dedication to providing timely and accurate refunds while upholding the highest standards of financial stewardship and accountability. Name(s) of the contact person(s) responsible for corrective action: Renee McBride Planned completion date for corrective action plan: January 2024

2023‐014 – Reporting (Significant Deficiency) State Department of Defense AL Number: 97.067 Program Title: Homeland Security Grant Program Condition The auditing firm selected three subawards that were executed between July 1, 2022 – June 30, 2023, noting that FFATA reports for the selected subawards were not filed timely. Current Status of Corrective Action Plan Concur. It is our commitment to address this issue promptly and implement necessary measures to prevent its recurrence. We understand the importance of accurate and timely data entry in the FFATA portal for federal awards and sub awards. In response to this issue, we have developed a corrective action plan to address the root causes and prevent similar occurrences in the future: -Review of Process: We will conduct a thorough review of our current process for entering funding amounts into the FFATA portal to identify any inefficiencies or gaps in the process. -Training and Awareness: We will provide additional training to other personnel in the grant section to ensure that there is continuity in the tasks. This will include reinforcing the importance of adhering to established deadlines and protocols. -Implement Reminders: We will implement automated reminders and notifications to alert grant staff members via shared Microsoft Outlook Calendar of impending deadlines for entering new federal award into the FFATA portal. These reminders will serve as a proactive measure to prevent delays and ensure timely completion of tasks. Lastly, reminder indicators such as; receiving the official grant award and executing a memorandum of agreement with sub recipients will be an indicator for action to process FFATA reporting. The FFATA information and process already exists in our Homeland Security Procedural Manual (Page 49) that we maintain annually. We will continue to maintain and make any necessary revisions if there are any changes. Person Responsible Glen Badua, Grants Manager Anticipated Date of Completion February 20, 2024

2023‐013 – Subrecipient Monitoring (Material Weakness) State Department of Labor and Industrial Relations AL Numbers and Program Title: 17.258 – WIOA Adult Program 17.259 – WIOA Youth Activities 17.278 – WIOA Dislocated Worker Formula Grant (WIOA Cluster) Condition No evidence of evaluation of the subrecipients’ risk of noncompliance at the time of the subawards, and no evidence of on‐site monitoring procedures of the subrecipients. Current Status of Corrective Action Plan Concur. -The ASO will come up with a checklist of pertinent reports that are due for WIOA programs including but not limited to Risk Assessment Report to include the following information: - Subrecipient’s prior experience with the same or similar subawards. - Results of previous Single Audit of the same or similar program that has been audited as major program. - New and Departing Personnel Record. - Systems Changes/Update. - Completion of Subrecipient Monitoring Report. - A formal analysis of each subrecipient’s risk of noncompliance with each of the respective subaward requirements shall be performed at the time of the subaward. - In‐person, onsite monitoring of the activities of the subrecipient shall take place annually to ensure that the subaward is used for authorized purposes, in accordance with federal statute and regulations. Person Responsible Ferdinand Casabay, Accountant VI Anticipated Date of Completion May 31, 2024

2023‐012 – Reporting (Material Weakness) State Department of Labor and Industrial Relations AL Numbers and Program Title: 17.258 – WIOA Adult Program 17.259 – WIOA Youth Activities 17.278 – WIOA Dislocated Worker Formula Grant (WIOA Cluster) Condition Reporting required by Section 2, Full Disclosure of Entities Receiving Federal Funding, of the FFATA was not completed. Current Status of Corrective Action Plan Concur. -Due to changes in program personnel, there was miscommunication between the parties responsible for filing the FFATA reports. -Previous ASO left abruptly in 2023 with limited to no cross‐training. Other positions vacated in 2023 as well. The ASO and Accountant VI vacancies were filled on December 1, 2023 and February 1, 2024, respectively. -The ASO will come up with a checklist of pertinent reports that are due for WIOA programs including FFTA reporting and have the responsible staffs (Accountant and Supervisor) report to ASO Officer and WDD Administrator monthly for verification. Person Responsible Lynn Araki‐Regan, Administrative Services Officer Anticipated Date of Completion March 15, 2024

Finding No. 2023‐011 – Earmarking (Significant Deficiency) State Department of Labor and Industrial Relations AL Numbers and Program Title: 17.258 – WIOA Adult Program 17.259 – WIOA Youth Activities 17.278 – WIOA Dislocated Worker Formula Grant (WIOA Cluster) Condition The auditing firm noted the following instances of noncompliance: -A total of 15.61% of funds were allocated for employment and training activities for adults and dislocated workers. -A total of 74.60% of funds were allocated for services to out of school youth. Current Status of Corrective Action Plan Concur. -Administrative Services Office (ASO) has communicated with Workforce Development Division (WDD) that no more than 15% of funds shall be allocated to provide employment training activities for Adults and Dislocated Workers. If there are recaptured funds to spend from the local areas for the program year, ASO and WDD will make sure that recaptured funds will not exceed the maximum requirements of 15%. -WDD shall monitor the progress of subrecipients to meet the minimum 75% expenditure for out of school youth. If necessary, a monthly or bi‐monthly meeting with subrecipients shall be scheduled to monitor the progress and take pro‐active recommendations and action to meet the requirements. Person Responsible Maricar Pilotin‐Freitas, Workforce Development Division Administrator Anticipated Date of Completion March 2024