Corrective Action Plans

Finding 2023-002 Information on the federal program: Subject: Education Stabilization Fund – Special Tests and Provisions - Wage Rate Requirements Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Number: 84.425D Federal Award Number: S425D210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Wage Rate Requirements Audit Findings: Material Weakness Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Special Tests and Provisions – Wage Rate Requirements compliance requirements. The School Corporation did not include Davis Bacon wage rate requirements in its contract with vendor which includes labor. The School Corporation did not obtain the weekly wage reports timely from vendor and its subcontractors for projects funded by ESSER funds. Context: The School Corporation expended ESSER II funds (84.425D) on playground equipment and HVAC Air Handlers which included labor costs for installation. The amount disbursed for equipment which includes labor costs totaled $54,195 during the audit period. The School Corporation did not have contracts in place with these vendors which included clauses for federal wage rate requirements applicable to projects funded with federal grant funds. The School Corporation also did not have an internal control in place to collect and review weekly wage reports from the vendor during the project period. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. 1. Include Davis-Bacon wage requirements in vendor contracts which are federally funded 2. Request weekly payroll report certifications from vendor and reviewed by the grant manager to ensure compliance (sign off). Responsible Party and Timeline for Completion: The grant awards manager (Tim Drake) will include the Davis-Bacon wage requirements in vendor contracts which are federally funded as well as request and review weekly payroll report certifications from vendor and sign off. This will start on March 6, 2024 moving forward

Finding 2023-002 - ESSER I, II, III Audit Findings: Material Weakness Condition and Context: 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 compiled, prepared and submitted by the Superintendent without an oversight or review process in place to prevent or detect and correct errors. The lack of internal controls was a systemic issue which occurred throughout the audit period. Views of responsible officials and planned corrective action: Management concurs with the finding. Internal control plan is as follows: A. Superintendent approves payment of expenditures and approves reimbursement receipts. B. Treasurer pays invoices, requests reimbursements and records receipts. C. Superintendent uses reports provided by Treasurer to prepare annual data reports and submit to IDOE. D. Treasurer will review Data Report before submission. Responsible Party overseeing corrective action plans and date for completion: Roger Bane, Superintendent Teresa Brewer, Treasurer Finding 2023-002 Effective implementation March 2024

Due to unexpected turnover, a secondary review was not performed to verify the preparation of the ESSER reporting. To strengthen the oversight of financial management of the School, Academica Nevada, the School’s management company, filled all open positions and realigned staff responsibilities to reduce individual workloads and provide additional oversight and review. In addition, a financial controller has been added to ensure that secondary reviews occur on all required filings and reconciliations.Nachum Golodner, Academica Director of Accounting Anticipated Completion Date: June 30, 2024

Condition: The School District did not complete on-site monitoring reviews for any buildings operating school lunch and breakfast programs within the School District during the year ended June 30, 2023. Planned Corrective Action: Southfield Public Schools contracts its food service with Southwest Food Service. Going forward, the Food Service Director (Southwest Food Service), and Food Service Purchasing (Southfield Public Schools) will coordinate the on-site monitoring reviews and its completion to Michigan Department of Education standards, and make sure the required forms are completed before deadlines. Contact person responsible for corrective action: Marc Ingram, Chief Financial Officer Anticipated Completion Date: 02/01/2024

Finding - The School District failed to maintain proper time and activity reports for employees charged to the Title I grant. Recommendation - That the School District ensure proper time records for Federal supported salaries are being maintained as required by the Appendix to 2 CFR Part 225. Method of Implementation - Maintain proper files of the supported salaries time records for audit review. Person Responsible for Implementation - Lisa Schulz, Business Administrator / Board Secretary Implementation Date - February 1, 2024

The newly hired CFO has Federal Grant Compliance experience and will implement a process for identification and oversight of subrecipients in line with Uniform Guidance 2 CFR § 200.331. The Organization will ensure there are written policies to comply with this provision and will monitor its subrecipients on a quarterly basis and will obtain written agreements by and between the Organization and its subrecipients.

Condition: Obligations were overstated by $965,175 on the March 31, 2023 Project and Expenditure report. Corrective Action Planned: The overstated obligation error will be corrected in the next federal reporting period. Anticipated Completion Date: April 30, 2024 Contact: Denise M. Dembkoski, Town Administrator

FINDING 2023-009 Finding Subject: Education Stabilization Fund - Reporting Summary of Finding: Material Weakness, Other Matters, Qualified Opinion 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 an annual data report 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 prepared by the Chief Financial Officer and reviewed by a second knowledgeable individual; however, this process did not allow for the prevention, or detection and correction of errors prior to submission. Due to the lack of effective internal controls, one of the six annual data reports was not supported by the School Corporation’s records. For the ESSER 1, Year 2 report, which covered the period of October 1, 2020 to June 30, 2021, the School Corporation’s records did not support the data in the report. The lack of controls and noncompliance were isolated to the ESSER I, Year 2 report. Contact Person Responsible for Corrective Action: Bengamin Mann Contact Phone Number and Email Address: 765-536-0008 bmann@mgusc.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: Supporting documentation of data reported will be retained with each report filed. Anticipated Completion Date: February 2024

FINDING 2023-008 Finding Subject: Education Stabilization Fund - Activities Allowed or Unallowed Summary of Finding: Material Weakness The Elementary and Secondary School Emergency Relief (ESSER) Fund provided funding to States and school districts to combat the effects of the coronavirus, help safely reopen and sustain the safe operation of schools, and to address the impact of the coronavirus pandemic on the nation’s students. States were required to subgrant a portion of their ESSER allocation to local educational agencies (LEA). Prior to LEAs receiving their respective subgrants, LEAs were required to complete an application for ARP ESSER funding, which was submitted to the Indiana Department of Education (IDOE), the pass-through entity for approval. The application included a district level budget identifying how the LEA intended to spend program funds. The School Corporation did not have internal controls in place over payroll disbursements charged to the ESSER grant funds. Payroll disbursements were paid without evidence that the detailed report of payroll disbursements was reviewed and approved by another person not involved in the original payroll process. Contact Person Responsible for Corrective Action: Bengamin Mann Contact Phone Number and Email Address: 765-536-0008 bmann@mgusc.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: Quarterly grant meetings will be held between the CFO, Deputy Treasurer, and Grant writer. This will ensure compliance requirements continue to be met. The CFO now reviews the Org Charge report and signs off before the payroll batch being released to the bank. This report is generated by Payroll and Benefits. Also, this entire report is now included with board claims for board approval rather than a final summary sheet. Anticipated Completion Date: February 2024

Corrective Action Plan Federal Award Findings and Questioned Costs For the Fiscal Year Ended June 30, 2023 Finding 2023-001 – A. Activities Allowed or Unallowed; B. Allowable Costs/Cost Principles; H. Period of Performance Identification of the federal program: Federal Agency: U.S. Department of Homeland Security Federal Program: 97.036, COVID-19 Disaster Grants – Public Assistance (Presidentially Declared Disasters) Pass-Through Entity: Ohio Emergency Management Agency Summary of finding: UC Health did not retain supporting documentation over key aspects of its internal review and approval processes for overtime labor hours that were not directly approved by employee managers. For a portion of overtime labor costs reimbursed under the program, UC Health did not retain sufficient documentation to evidence execution of internal controls that support compliance with the terms and conditions (T&Cs) of specific projects. While management has processes in place to review overtime labor costs for compliance, evidence of all key aspects and conclusions of these reviews was not consistently retained. Planned corrective action: Management agrees with this finding and the need to update documentation policies and procedures to evidence review of compliance with program requirements. Anticipated completion date: September 30, 2024 Responsible contact person: Michael Wiedeman, Vice President and Controller

Program:Various, including AL 20.509 – Formula Grants for Rural Areas and Tribal Transit Program – Reporting Corrective Action Planned: The transit will continue to provide training to all the personnel who handles the information needed to properly calculate the SEFA amounts for future audits. Anticipated Completion Date: June 30, 2024 Responsible Party: Christy Warner, Transit Administrator

Corrective Action Plan: Management concurs with the Auditor’s recommendation and will review with the third-party North Central Illinois Council of Governments (NCICG) to establish appropriate City monitoring and review. City will also review with prior City Auditors to ensure proper overall procedures are in place to ensure all grants in the aggregate are monitored. Person(s) Responsible (Name, title): Donald Harris, City Treasurer and Shelly Munks, City Clerk Timing for Implementation: 7/31/2024

Corrective Action Plan: Management concurs with the Auditor’s recommendation and will review with the third-party North Central Illinois Council of Governments (NCICG) to establish appropriate City monitoring and review. Person(s) Responsible (Name, title): Donald Harris, City Treasurer and Shelly Munks, City Clerk Timing for Implementation: 7/31/2024

Finding 2023-003 – Child Nutrition Cluster – Activities Allowed or Unallowed, Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Sandy Denny – Food Service Director Contact Phone Number: 812-952-2555 ext. 250 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We will review all food service payroll charges to ensure only payroll related to food service duties is charged to the child nutrition cluster program. Anticipated Completion Date: April 2024

Finding Number: 2023-003 Condition: The notifications related to the direct loan borrowers did not include information on the right to cancel or instructions on how to cancel the loans. Planned Corrective Action: Missing notifications to students was a result of a coding error in the automated process that was resolved on September 5, 2023. Notifications to parents didn’t begin until the Summer 2023, with an automated procedure being implemented in the Fall 2023 semester. Contact person responsible for corrective action: Kent McGowan, Assistant Director, Office of Financial Aid Anticipated Completion Date: 01/01/2024

Finding Number: 2023-002 Condition: The University used inaccurate or incomplete data in the return of Title IV calculations. Planned Corrective Action: The failure to return funds in a timely fashion is primarily a result of university withdrawal policy not aligning with the timelines required by the regulations. To that end, the university is revising its policies and procedures, specifically as they relate to “medical withdrawals” and for programs where attendance is required. As of June 2023, the University now has reports that identify all the affected students in a timely fashion. Additional resources have been allocated to assure that there is consistency and timeliness in the review of enrollment data specifically as it relates to determining attendance in dropped courses, and students who rescind their intent to withdraw, or enroll in or attend subsequent modules. Contact person responsible for corrective action: Steve Shablin - University Registrar, Matthew Lyth - Financial Aid Officer Anticipated Completion Date: 05/10/2024

Corrective Action Plan For the Year Ended May 31, 2023 Finding 2023-002 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 significant deficiency in 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 safeguarding sensitive data under the Gramm-Leach-Bliley Act, including performing an annual risk assessment that addresses three required areas noted in 16 Code of Federal Regulations (CFR) 314.4 (b). Statement of Condition: The Institute performed a risk assessment however the safeguards for the risks identified were not formally documented through a policy. A formal policy was not reviewed in fiscal year 2023 which would have addressed required areas noted in 16 CFR 314.4 (b). Questioned Costs: Questioned costs could not be determined. Context: A policy and documentation linking the safeguards to the risk assessment was not formally written. The internal controls over compliance at the Institute did not identify the noncompliance. However, the Institute performed risk assessments and has appropriate safeguards for each area identified within 16 CFR 314.4(b). Cause: The Institute did not have internal controls in place to identify the need for the policy documenting the safeguards required by the Gramm-Leach-Bliley Act. Effect: The Institute has no verifiable evidence of the policy and the related safeguards for each risk identified. Recommendation: We recommend management review 16 CFR 314.4 (b) to create a policy that addresses the three required areas, which are (1) employee training and management; (2) information systems, including network and software design, as well as information processing, storage, transmission and disposal; and (3) detecting, preventing and responding to attacks, intrusions, or other systems failures. This policy should be formalized and reviewed annually. We recommend that the Institute document the approval and acceptance of the policy. In addition, we recommend management review internal control processes for special tests and provisions on an annual basis. Status: In progress, anticipated completion September 2024 Corrective Action: Management agrees with the finding. We are currently developing a comprehensive cybersecurity policy to address 16 CFR 314.4 (b), which will be formalized, approved by Senior Staff, and reviewed annually. We are now conducting annual penetration tests, the most recent in December 2023, to address internal control processes. We have contracted with a planning team at CDW to determine best practices and perform training. We have begun providing a quarterly GLBA Compliance update to our board, with an annual comprehensive GLBA review to the board. Contact Matt Ogden Director of Technology 414.847.3223 mattogden@miad.edu Submitted Feb 23, 2024

2023-003 – Equipment and real property management Cluster: Research and Development Sponsoring Agency: Various Award Names: All awards for 3 campuses with federal equipment expenditures in the SEFA Award Numbers: Various Assistance Listing Titles: Various Assistance Listing Numbers: All awards for 3 campuses with equipment expenditures in the SEFA Award Year: 2022-2023 Pass-through entity: All pass-through awards for 3 campuses with equipment expenditures in the SEFA Campus One Actions already taken: • Controller’s Office-Capital Accounting had been aware of past due inventories throughout the pandemic caused by on-site restrictions departmental asset custodians faced in their accessibility to complete inventories. Once the federal state of emergency was lifted in May 2023, the Capital Accounting team presented a status update on outstanding inventory counts to UCSF’s Control Points Financial Officers (Control Points) to obtain Control Point’s assistance in bringing awareness of the need to bring inventory counts to current status, Capital Accounting began sending quarterly reports on overdue counts. Since this increased communication, there have been improvements in response rates and action taken by departmental custodians. • In October 2023, Capital Accounting also conducted outreach to departmental asset custodians in the form of a feedback survey with the goal to seek information on how our custodians have returned to work, difficulties they have with the inventories they are assigned, and if they need clarifications on the training surrounding capital asset policy and procedures. As a result of our custodian outreach, Capital Accounting learned that most custodians are on-site and can perform their physical inventories, so the shelter in place restrictions are no longer a barrier in completing these physical inventories. We also identified the need for additional training for departmental asset custodians to ensure ongoing understanding of related policy and procedures, such as physical inventory counts. • Additionally, additional metrics were added to the quarterly Controller’s Office Operational Metrics Report to now include outstanding inventories at a campus departmental level. This provides an opportunity for the Controller and other leaders within central finance administration to have better visibility on our efforts surrounding this key control. Additional Actions to be taken: • A deadline of June 30, 2024, will be communicated to all custodians to bring their inventories up to date. • The Controller’s Office has been developing content and plans to begin hosting bi-monthly town halls in March 2024 with department custodians to provide hands on support in assisting with their counts. We also plan to update our training materials surrounding the tools (Peoplesoft) department custodians utilize for updating asset information with the goal for inventory results to be entered in a more timely manner. By June 2024, we will have completed our first series of live support sessions with our custodians. By September 2024, we will roll out refreshed training materials for departmental custodians. These will be training guides that will be hosted on the Controller’s Office website and will be mandatory during the onboarding of the custodians. • The Controller’s Office will also partner with our Control Points in reviewing the custodian role at each of their departments. We will assess FTEs with the custodian role and evaluate the number of equipment assigned to each custodian. The goal of this custodian role review is to provide insight into the workload of each custodian as we have noted some custodians have up to 1,000 assets assigned, which is an obstacle in the inventory timeliness. In the upcoming months, we will work with each control point area with how the custodian role is assigned within their areas and make any changes if needed. • The Controller’s Office will continue sending quarterly reports to our Control Points on physical inventory status for support in escalation and follow-up with their departments. The Controller’s Office will also continue to track the metrics of late inventories within quarterly reporting to central Finance leadership. For inquiries regarding this finding, please contact Shannon Turner at Shannon.Turner@ucsf.edu who is responsible for the corrective action. Campus Two The University will implement changes to its biennial certification process that ensure adherence to the Uniform Guidance biennial equipment inventory requirements through the following changes: • Update policy to require custodians to complete the Department Inventorial Equipment Certification Form within the first 18-months of the two-year measurement period. • Implement a static measurement period (the beginning and end dates of the two-year period) for each custodian to ensure compliance with the established certification deadlines. • Increase the number of notifications sent to custodians reminding them of their responsibility to complete the certification form to begin on the six-month anniversary of the beginning of the measurement period and will continue to send notifications every 90 days thereafter for the next 12-months (i.e. the 18-month anniversary of the beginning of the measurement period). On the 18-month anniversary, the notification frequency will increase to every 30 days until certification is completed. • Enhance the existing monitoring procedures by providing compliance reports highlighting custodians who are out of compliance with the 18-month performance period and will send notifications to custodians, custodian supervisors, and department heads notifying them they are out of compliance with University policy. A project plan has been developed and the system programmer engaged with an anticipated reprogramming start date of mid-March 2024 and an estimated completion date of June 2024. Biennial submissions will be closely monitored for those under the current two-year process until they are enrolled in the new process. For inquiries regarding this finding, please contact Michael Riley at mriley5@berkeley.edu who is responsible for the corrective action. Campus Three Management has taken the following actions: • Discussed directly with the specific asset custodians the need and requirement to update the equipment management system (AMS) with the last inventory date. o It is to be noted that the two custodians who were part of the audit sample stated they had performed the physical inventory counts from downloaded excel sheet lists. However, they did not finish updating the last inventory date in AMS after completing the physical inventory. o The custodians agreed to do a more thorough job of completing this step going forward in a timely manner, as required. • As a part our normal annual process, we already cover the need to update these dates during the annual equipment management training done each Fall. Additionally, we will place stronger emphasis on this requirement and highlight the importance of this step at our next annual training in October/November 2024 for all custodians. Actions to be taken: We will follow up with e-mails to custodians and approvers who have not updated the last inventory date field. The two specific custodians are currently completing the updates to the last inventory date fields in AMS that they did not previously complete. Custodians will be asked to complete inventories by April 30, 2024. It is to be noted that our current AMS system only facilitates updating the last inventory date in the system one at a time in individual asset screens. It is a manual process that is time consuming for custodians with a large volume of equipment under their custody (hundreds in some instances). Our future inventory system scheduled to go live next year is expected to address this issue and enable more efficient updates once the physical inventory has been completed. For inquiries regarding this finding, please contact Selina Martin at selinamartin@finance.ucla.edu who is responsible for the corrective action.

2023-002 – Transfer of costs from HEERF to FEMA not reported in HEERF quarterly report Cluster: Not applicable Sponsoring Agency: Department of Education (ED) Award Name: COVID-19 Higher Education Emergency Relief Fund (HEERF) – Institutional Portion Award Number: P425F202631 - 20B Assistance Listing Title: COVID-19 - Education Stabilization Fund Assistance Listing Number: 84.425F Award Year: 2020-2021 Pass-through entity: Not applicable The campus amended the March 31, 2021, quarterly HEERF institutional report by prominently highlighting the modifications. • A revised report has been uploaded to the campus website (UCLA Financial Aid and Scholarships – HEERF Institutional Portion Reports) alongside the other completed quarterly HEERF reports. • In accordance with ED guidelines, the old report has been replaced with the updated version, clearly indicating the date of the revision. For inquiries regarding this finding, please contact Selina Martin at selinamartin@finance.ucla.edu who is responsible for the corrective action.

FINDING 2023-001 Finding Subject: Education Stabilization Fund - Internal Controls Over Annual Data Report Summary of Finding: Significant Deficiency; A failure to establish an effective internal control system creating a risk of noncompliance with the grant agreement and the reporting compliance requirement. Contact Person Responsible for Corrective Action: Mendy Shrout Contact Phone Number and Email Address: 765-795-4664 mshrout@cloverdale.k12.in.us Views of Responsible Officials: We concur with the finding. Explanation and Reasons for Disagreement: NA Description of Corrective Action Plan: Management has created a google doc to record the reviewed by and submitted by dates of the reporting. As well as including financial reports in respective report files. Anticipated Completion Date: Google doc was created February 5, 2024

FINDING 2023-002 Finding Subject: COVID-19 – Education Stabilization Fund – Subrecipient Monitoring Summary of Finding: The School Corporation received and passed through to subrecipients $495,386 of ESF funds. The School Corporation is to clearly identify the award and applicable requirements to the subrecipients, evaluate the risk of noncompliance related to the subrecipients to determine appropriate monitoring of the subaward, and monitor the activities of the subrecipients to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. Contact Person Responsible for Corrective Action: Dr. Judi Hendrix, Director of WVEC and Michelle Cronk, CFO of West Lafayette Schools Contact Phone Number and Email Address: Dr. Judi Hendrix Michelle Cronk 765-894-0333 765-746-1602 judi.hendrix@esc5.k12.in.us cronkm@wl.k12.in.us Views of Responsible Officials: We concur with the finding regarding the informing and monitoring of subrecipients for federal grants. Description of Corrective Action Plan: We concur with the findings from the State Audit regarding the 3E grants funds; 2023-002. Our Corrective Action Plan would consist of the following:  Before ESF funds are dispersed to school districts (subrecipients), the WVEC Grant Director will ask districts for proper documentation such as receipts, college entrance letters, staff documented timesheets to support their request for funding.  The WVEC Grant Director will monitor the activities of the subrecipients to ensure that the financial subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals of the grant.  Once the school district’s information and documentation is received and approved, grant funding will be dispersed. Both the Service Center Executive Director and WVEC Grant Manager will approve and sign off on any payment made to a subrecipient.  On a biannual basis (periods ending June 30 and December 31), West Lafayette School Corporation will request the monitoring documentation from WVEC to ensure that proper monitoring is taking place. The WVEC Grant Director will create a sub-grantee reporting procedure:  Monthly spreadsheet with district allowable expense and sign off by Grant Manager, WVEC Executive Director and WVEC Treasurer approval.  This will take place every pay period to monitor the disbursement of any federal funds and to ensure that they are used for allowable expenditures under the grant.  This monitoring will begin in the month of March 2024 and continue until the end of the grant or Final Report, December 31, 2024. This procedure will also be used for other federal grants received.  On a biannual basis (periods ending June 30 and December 31), West Lafayette School Corporation will request the monitoring documentation from WVEC to ensure that proper monitoring is taking place. Anticipated Completion Date: Monthly monitoring will begin promptly (March 2024) and end with the final report of 3E grant activities on December 31, 2024.

Material Weakness - Internal Controls over Reporting and Noncompliance The Office of Financial Management (OFM) Grant Program Administrator, Heather Larson will monitor and ensure that Federal Funding Accountability and Transparency Act of 2006 (FFATA) reports are filed as required in the FSRS system. Since the recent transition of the CDBG Entitlement Cluster from an outside agency back to Sarasota County, the County has implemented a standardized form to capture needed information from current and future subrecipients to report appropriately the requirements of the Federal Funding Accountability and Transparency Act of 2006 (FFATA). The OFM Grant Analyst assigned to the funding award, upon review of any pending subaward/ subaward amendment, will create an Action Item utilizing the Grants Administration module of OnBase. The Action Item will require completion of any required FSRS reporting. Action item will be assigned and have a deadline date no late than the last day of the month following the month in which the subaward/ subaward amendment obligation was made. Implementation date for this process - On or before February 28, 2024.

FINDING 2023-003 Finding Subject: Special Education Cluster (IDEA) – Procurement and Suspension and Debarment Summary of Finding: Procurement Federal regulations allow for informal procurement methods when the value of the procurement for goods or services does not exceed the simplified acquisition threshold, which is customarily set at $250,000. However, Indiana Code 5-22-8 has a more restrictive threshold of $150,000 or less for when small purchase procedures may be used. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds. Micropurchases, typically for those purchases $10,000 or under, and small purchase procedures for those purchases above the micro-purchase threshold, but below the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. If it is determined a single source provider can be used for a small purchase, documentation must be retained supporting the determination. The Cooperative did not adhere to the requirements necessary for them to be in compliance with the procurement of small purchases during the audit period. Suspension and Debarment The School Corporation did not have internal controls in place to ensure compliance with the suspension and debarment requirement. The Cooperative did not have adequate internal controls in place to ensure all applicable vendors were not suspended or debarred prior to entering into a covered transaction. As such, the Cooperative never entered into a contract, although their payments to the vendor exceeded $50,000. The INDIANA STATE BOARD OF ACCOUNTS 30 Cooperative did not perform procedures to ensure that the vendor was not suspended or debarred from participation in federal programs. Contact Person Responsible for Corrective Action: Lana M. Miller Contact Phone Number and Email Address: Phone Number-812-689-6282 Email- lmiller@sripley.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The ROD Special Education Cooperative will make notes in the Board Minutes regarding the fact that only one vendor can provide specific services prior to entering into a contract or purchasing said services. Each company providing services will be checked on the SAM.gov website to ensure that the vendor has not been suspended or debarred. This documentation will be provided to the ROD board for review, and our Superintendent is a member of that board. Anticipated Completion Date: February 1, 2024

FINDING 2023-002 Finding Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Summary of Finding: Prior to entering into subawards and covered transactions with program funds, recipients are required to verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded. "Covered transactions" include, but are not limited to contracts for goods and services awarded under a non-procurement transaction (i.e., grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the SAM exclusions, collecting a certification from that person, or adding a clause or condition to the covered transaction with that person. Upon inquiry of the School Corporation, in order to review the procedures in place for verifying that an entity with which it plans to enter into a covered transaction is not suspended, debarred, or otherwise excluded, the School Corporation disclosed there were not adequate procedures in place to ensure this. While the suspension and debarment report is run on a yearly basis in June, this was not adequate to ensure that this verification was performed prior to a covered transaction being entered into. One covered transaction that equaled or exceeded $25,000, paid from Child Nutrition Cluster funds, was identified. The one transaction, totaling $43,599.31, was selected for testing. The School Corporation did not verify the vendor's suspension and debarment status prior to payment. INDIANA STATE BOARD OF ACCOUNTS 29 Contact Person Responsible for Corrective Action: Lana M. Miller Contact Phone Number and Email Address: Phone Number-812-689-6282 Email- lmiller@sripley.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: We will amend our current process of running Suspension and Debarment inquiries from annually in June each year to every six months and prior to check issuance when over $25,000 from federal funds. Anticipated Completion Date: Immediately, February 2024

Responsible Contact Person(s): Kassandra Bullock, Director of Grants Management DeAndrea Williams, Grants Admin Supervisor Joseph Thompson, Grants Compliance Supervisor John Colligan, Director of Finance and Administration Corrective Action Planned: An internal compliance review has been implemented to ensure accuracy and timely reporting of FFATA data. Data is confirmed prior to upload by the Grants Compliance Team to address errors, missing information, and conflicting dates. Training has occurred via the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) by Grants Admin staff. Additionally all changes in statements of grant awards (SOGA) will be reviewed and reissued when needed and data re-entered to ensure FFATA correlates with SOGA. Estimated Completion Date: 1/26/2024