Corrective Action Plans

FINDING 2023-006 Finding Subject: Special Education Cluster (IDEA) – Procurement Summary of Finding: The School Corporation was a member of the Clark County Joint Services Program (Cooperative). During fiscal year 2021-2022. The School Corporation was responsible for ensuring and providing oversight of the Cooperative. However, there was inadequate oversight performed by the School Corporation to ensure compliance with the Procurement compliance requirement. Two vendors exceeded the small purchase threshold during the audit period and both vendors were selected for testing. For both vendors only the quote that was utilized was retained and no other audit evidence could be provided to show that additional quotes as required were obtained. Documentation detailing the history of procurement, which must include the reason for the procurement method used, selection of the vendor, and the basis for the price, was not retained for audit for either purchase. Contact Person Responsible for Corrective Action: Ashley Compton, Director of Special Education and Allison Vanover, Corporation Treasurer Contact Phone Number and Email Address: 812-246-3375 alcompton@scsc.school avanover@scsc.school Views of Responsible Officials: We do not concur with the finding. Explanation and Reasons for Disagreement: The two instances cited in this finding were the results of a purchase made through the cooperative purchasing agency. Silver Creek chose this vendor that IAESC manages. IAESC serves as a governmental body in which SCSC is allowed to enter into an agreement to form a cooperative purchasing organization per IC 5-22-4-7. We can provide evidence that the cooperative purchasing agency has properly conducted an RFP for these two purchases. After reviewing the purchases for CDW Government and School Outfitters, SCSC does not recognize these as small purchases since these items were listed separately on the voucher and did not cross the threshold of $10,000.00.

􀀃 Finding􀀃2023􀍲007􀀃 􀀃 Finding􀀃Subject:􀀃Special􀀃Education􀀃Cluster􀀃􀍲􀀃Procurement􀀃 Summary􀀃of􀀃Finding:􀀃The􀀃district􀀃does􀀃not􀀃have􀀃a􀀃procurement􀀃policy􀀃outlining􀀃 procurement􀀃standard􀀃for􀀃all􀀃federal􀀃programs.􀀃􀀃Internal􀀃Controls􀀃were􀀃deficient􀀃in􀀃 preventing􀀃noncompliance􀀃and􀀃not􀀃maintaining􀀃methods􀀃of􀀃procurement.􀀃 Contact􀀃Person􀀃Responsible􀀃for􀀃Corrective􀀃Action:􀀃Director􀀃of􀀃Business􀀃 Contact􀀃Phone􀀃Number􀀃and􀀃Email􀀃Address:􀀃(260)431􀍲2030,􀀃msnyder@sacs.k12.in.us􀀃 􀀃 Views􀀃of􀀃Responsible􀀃Official:􀀃We􀀃concur􀀃with􀀃the􀀃finding.􀀃 Description􀀃of􀀃Corrective􀀃Action􀀃Plan:􀀃 The􀀃school􀀃board􀀃will􀀃adopt􀀃a􀀃procurement􀀃policy􀀃for􀀃all􀀃federal􀀃programs􀀃to􀀃comply􀀃 with􀀃procurement􀀃standards􀀃and􀀃the􀀃policy􀀃will􀀃be􀀃implemented.􀀃􀀃Additionally,􀀃The􀀃 Director􀀃of􀀃Special􀀃Education􀀃and􀀃the􀀃Special􀀃Education􀀃Treasurer􀀃will􀀃ensure􀀃 procurement􀀃procedures􀀃are􀀃followed􀀃for􀀃all􀀃purchases􀀃and􀀃if􀀃the􀀃total􀀃is􀀃between􀀃 $50,000􀀃and􀀃$150,000􀀃a􀀃contract􀀃will􀀃be􀀃awarded.􀀃􀀃All􀀃documents􀀃are􀀃to􀀃be􀀃signed,􀀃 dated,􀀃and􀀃retained􀀃by􀀃school􀀃year􀀃by􀀃both􀀃the􀀃Director􀀃of􀀃Special􀀃Education􀀃and􀀃the􀀃 Special􀀃Education􀀃Treasurer.􀀃 􀀃 Anticipated􀀃Completion􀀃Date:􀀃On􀀃or􀀃before􀀃June􀀃30,􀀃2024􀀃

􀀃 Finding􀀃2023􀍲006􀀃 􀀃 Finding􀀃Subject:􀀃Child􀀃Nutrition􀀃Cluster􀀃–􀀃Procurement􀀃and􀀃Suspension􀀃and􀀃Debarment􀀃 Summary􀀃of􀀃Finding:􀀃Internal􀀃Controls􀀃were􀀃not􀀃effective􀀃and􀀃did􀀃not􀀃ensure􀀃procurement􀀃 is􀀃done􀀃properly􀀃and􀀃allowed􀀃the􀀃district􀀃to􀀃enter􀀃an􀀃agreement􀀃with􀀃a􀀃vendor􀀃that􀀃did􀀃not􀀃 have􀀃proper􀀃documentation􀀃that􀀃they􀀃were􀀃not􀀃excluded.􀀃 Contact􀀃Person􀀃Responsible􀀃for􀀃Corrective􀀃Action:􀀃Director􀀃of􀀃Food􀀃Service􀀃 Contact􀀃Phone􀀃Number􀀃and􀀃Email􀀃Address:􀀃(260)431􀍲2030,􀀃msnyder@sacs.k12.in.us􀀃 􀀃 Views􀀃of􀀃Responsible􀀃Official:􀀃We􀀃concur􀀃with􀀃the􀀃finding.􀀃 Description􀀃of􀀃Corrective􀀃Action􀀃Plan:􀀃 Procurement􀀃–􀀃Region􀀃8􀀃 The􀀃Director􀀃of􀀃Food􀀃Service􀀃has􀀃the􀀃responsibility􀀃to􀀃ensure􀀃participation􀀃with􀀃IDOE􀀃 approved􀀃SFA􀀃Cooperatives􀀃only.􀀃􀀃We􀀃now􀀃utilize􀀃Food2School􀀃and􀀃have􀀃the􀀃 necessary􀀃documentation.􀀃􀀃􀀃If􀀃we􀀃consider􀀃other􀀃Cooperatives,􀀃the􀀃Director􀀃will􀀃 ensure􀀃they􀀃are􀀃approved.􀀃􀀃􀀃All􀀃documents􀀃are􀀃to􀀃be􀀃signed,􀀃dated,􀀃and􀀃retained􀀃by􀀃 school􀀃year􀀃by􀀃both􀀃the􀀃Director􀀃of􀀃Food􀀃Services􀀃and􀀃the􀀃Asst.􀀃Director􀀃of􀀃Food􀀃 Services.􀀃 􀀃 Procurement􀀃􀍲􀀃SACS􀀃 The􀀃Director􀀃of􀀃Food􀀃Services􀀃and􀀃the􀀃Asst.􀀃Director􀀃of􀀃Food􀀃Services􀀃will􀀃ensure􀀃 procurement􀀃procedures􀀃are􀀃followed􀀃for􀀃all􀀃purchases􀀃and􀀃if􀀃the􀀃total􀀃is􀀃between􀀃 $50,000􀀃and􀀃$150,000􀀃a􀀃contract􀀃will􀀃be􀀃awarded.􀀃􀀃All􀀃documents􀀃are􀀃to􀀃be􀀃signed,􀀃 dated,􀀃and􀀃retained􀀃by􀀃school􀀃year􀀃by􀀃both􀀃the􀀃Director􀀃of􀀃Food􀀃Services􀀃and􀀃the􀀃 Asst.􀀃Director􀀃of􀀃Food􀀃Services.􀀃 􀀃 Suspension􀀃and􀀃Debarment􀀃 The􀀃Director􀀃of􀀃Food􀀃Service􀀃has􀀃the􀀃responsibility􀀃to􀀃ensure􀀃that􀀃all􀀃vendors􀀃are􀀃free􀀃 from􀀃suspension,􀀃debarment,􀀃or􀀃aren’t􀀃otherwise􀀃excluded.􀀃Suspension􀀃and􀀃 debarment􀀃documents􀀃are􀀃to􀀃be􀀃collected􀀃on􀀃a􀀃yearly􀀃basis.􀀃If􀀃such􀀃documents􀀃are􀀃 not􀀃available􀀃through􀀃the􀀃SFA􀀃Cooperative,􀀃it􀀃will􀀃be􀀃the􀀃responsibility􀀃of􀀃the􀀃 Director􀀃of􀀃Food􀀃Service􀀃to􀀃acquire􀀃them􀀃through􀀃SAM.gov􀀃website􀀃or􀀃contacting􀀃the􀀃 vendor􀀃directly.􀀃All􀀃documents􀀃are􀀃to􀀃be􀀃signed,􀀃dated,􀀃and􀀃retained􀀃by􀀃school􀀃year􀀃 by􀀃both􀀃the􀀃Director􀀃of􀀃Food􀀃Services􀀃and􀀃the􀀃Asst.􀀃Director􀀃of􀀃Food􀀃Services.􀀃􀀃 􀀃 􀀃 INDIANA STATE BOARD OF ACCOUNTS 51 􀀃 Preparing today’s learners for tomorrow’s opportunities. 􀀃 Anticipated􀀃Completion􀀃Date:􀀃3/18/24􀀃

FINDING 2023-002 Finding Subject: Child Nutrition Cluster – Procurement and Suspension and Debarment Summary of Finding: We did not use the formal bid process for a vendor purchase over the simplified acquisition threshold. We did not ensure that all vendors over the $25,000 threshold were not suspended or debarred from conducting business with us. Contact Person Responsible for Corrective Action: Leeanne Koeneman Contact Phone Number and Email Address: Leeanne.Koeneman@nacs.k12.in.us; 260-637-8768 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Food Service Director will track cumulative expenditures for Vendor by Fiscal Year to ensure that compliance requirements related to procurement thresholds are met. Simultaneously, the Treasurer’s Office will provide reports to the Food Service Department on a monthly basis detailing the cumulative expenditures by vendor paid from the Food Service Fund. With thresholds being actively monitored, the Food Service Director will request quotes or bids, as applicable by individual and cumulative thresholds. Utilizing the procedures outlined above, individual and cumulative expenditures over $25,000 will be verified to ensure that the potential vendor(s) has not been suspended or debarred. Upon checking the status of vendor(s) at the Food Service Department, the results will be sent to the Treasurer’s office for review. Anticipated Completion Date: June 30, 2024

COMMONWEALTH OF PUERTO RICO MUNICIPALITY OF CATAÑO Corrective Action Plan For the Fiscal Year Ended June 30, 2023 _____________________________________________________________________________________________________________________ Audit Report: Reports on Compliance and Internal Control in Accordance with Government Auditing Standards and OMB Super Circular Uniform Guidance Audit Period: July 1, 2022 – June 30, 2023 Fiscal Year: 2022-2023 Principal Executive: Hon. Julio Alicea Vasallo, Mayor Contact Person: Mrs. Honoris Machado, Interim Finance Director Phone: (787) 788-0404 Original Finding Number: 2023-002 Statement of Concurrence or Nonconcurrence: We concur with the finding. Corrective Action: The Municipality of Cataño (Federal Programs Office) as a corrective action will use the calendar tool for notifications and reminders for the established dates so that we can submit compliance reports for ARPA Funds on time. Implementation Date: Fiscal year 2023-2024 Responsible Person: Carlos Flores Rivera, Federal Program Subdirector We concur with the finding. The Municipality of Cataño (Federal Programs Office) as a corrective action will use the calendar tool for notifications and reminders for the established dates so that we can submit compliance reports for ARPA Funds on time. Implementation Date: Fiscal year 2023-2024 Responsible Person: Carlos Flores Rivera, Federal Program Subdirector

FINDING 2023-004 Finding Subject:􀀃Child􀀃Nutrition􀀃Cluster􀀃􀍲􀀃Procurement􀀃and􀀃Suspension􀀃and􀀃Debarment Summary of Finding: An􀀃effective􀀃internal􀀃control􀀃system􀀃was􀀃not􀀃in􀀃place􀀃at􀀃the􀀃School􀀃Corporation􀀃to􀀃ensure􀀃compliance􀀃with􀀃 requirements􀀃related􀀃to􀀃the􀀃grant􀀃agreement􀀃and􀀃the􀀃Procurement􀀃and􀀃Suspension􀀃and􀀃Debarment􀀃compliance􀀃 requirement.􀀃 Contact Person Responsible for Corrective Action: Lela Simmons Contact Phone Number and Email Address: (219) 391- 4100, lesimmons@ecps.org Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: All􀀃purchases􀀃will􀀃require􀀃three􀀃quotes􀀃to􀀃ensure􀀃the􀀃Vendor􀀃is􀀃compliance􀀃with􀀃purchase􀀃of􀀃$150,000􀀃or􀀃exceed􀀃 micro􀍲purchase􀀃threshold􀀃of􀀃$10,000􀀃all􀀃quotes􀀃will􀀃be􀀃attached􀀃to􀀃the􀀃APV.􀀃This􀀃will􀀃ensure􀀃all􀀃documents􀀃are􀀃 available􀀃upon􀀃request.􀀃The􀀃School􀀃Corporation􀀃will􀀃work􀀃with􀀃State􀀃to􀀃receive􀀃approval􀀃of􀀃Food􀀃Service􀀃 Management􀀃Company.􀀃􀀃 Anticipated Completion Date: We anticipate having the above corrective action plan in place by September 30, 2024.

FINDING 2023-003 Finding Subject: Special Education Cluster (IDEA) – Procurement, Suspension and Debarment Summary of Finding: Insufficient documentation provided for proof of Procurement and Suspension and Debarment verifications Contact Person Responsible for Corrective Action: Ghirmay Alazar (Procurement) Phyllis Ritenour (Suspension & Debarment) Contact Phone Number and Email Address: 317-845-9400 galazar@msdwt.k12.in.us pritenour@msdwt.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: Procurement - At our educational institution, we prioritize the unique leaning needs of our students by actively seeking vendors who can effectively meet our expectations. To ensure transparency and fairness in the vendor selection process, we examine total costs estimates from each vendor and analyze their reputations, experience, customer feedback, and ability to provide innovative solutions. We use this information to make informed decisions and the rationale behind our vendor selection process. When searching for vendors we will keep documentation that displays the cost from each vendor and the rational for selecting a specific vendor. Suspension and Debarment – Beginning July 2024 the Assistant Accounting Manager will run reports annually in July from sam.gov and from FMS and compare the 2 files to make sure that we don’t have vendors in our system that are on the debarment list. The files will then be forwarded to the Accounting Manager via email for review and approval. The approval email and the 2 reports will be saved in our shared drive as proof of file review. All new vendors will be checked in sam.gov before allowing purchases to be placed. The review sheets will be emailed to the Accounting Manager for review and approval, these will also be saved in our shared drive. Anticipated Completion Date: Procurement – December 2024 Suspension & Debarment – July 2024

FINDING 2023-004 Information on the federal program: Subject: Special Education Cluster (IDEA) – Procurement and Suspension and Debarment Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.027X, 84.173, 84.173X Federal Award Numbers and Years (or Other Identifying Numbers): 19611-022-PN01, 20611-022-PN01, 21611-022-PN01, 22611-022-PN01, 22611-022-ARP, 23611-022-PN01, 20619-022-PN01, 21619-022-PN01, 22619-022-PN01, 22619-022-ARP, 23619-022-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Qualified Opinion Condition: The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the procurement and suspension an debarment requirements. The Cooperative had not designed or implemented adequate policies or procedures to ensure that proper procurement procedures for micro or small purchases were followed. There was no oversight, review, or approval process in place and documented at the Cooperative to ensure proper procedures were followed and price or rate quotations were obtained, if required, or documentation to support limited procurement procedures. Context: The School Corporation is a member of the Greene-Sullivan Special Education Cooperative (Cooperative). During fiscal year 2021-2022 and 2022-2023, the Cooperative operated the special education programs and spent the federal money on behalf of all its members.  As the grant agreements were between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. However, there was inadequate oversight performed by the School Corporation in order to ensure compliance with the Procurement and Suspension and Debarment compliance requirement. Procurement Federal regulations allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisition threshold, which is set at $250,000 unless a lower, more restrictive threshold is set by a non-Federal entity. As Indiana Code has set a more restrictive threshold of $150,000, informal procurement methods are permitted when the value of the procurement does not exceed $150,000. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds. Micro-purchases, 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. For fiscal year 2022, three vendors, totaling $88,772, were identified as being less than the simplified acquisition threshold of $150,000, but exceeding the $10,000 micro-purchase threshold. One of the three vendors was a bankcard used to pay several different vendors; however, individual determinations of amount spent by vendor could not be determined, and thus it was considered under this threshold. All three vendors were tested. For all three, the Cooperative did not obtain price or rate quotes nor was there documentation detailing the history of procurement, which must include the reason for the procurement method used. For fiscal year 2023, six vendors, totaling $264,106, were identified as being less than the simplified acquisition threshold of $150,000, but exceeding the $10,000 micro-purchase threshold. One of the six vendors was a bankcard used to pay several different vendors; however, individual determinations of amount spent by vendor could not be determined, and thus it was considered under this threshold. All six vendors were tested. For five of the six, totaling $252,906, the Cooperative did not obtain price or rate quotes nor was there documentation detailing the history of procurement, which must include the reason for the procurement method used. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Suspension and Debarment Prior to entering into subawards and covered transactions with federal award 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 SAMs exclusions, collecting a certification from that vendor, or adding a clause or condition to the covered transaction with that vendor. Upon inquiry of the School Corporation in order to review the procedures in place for verifying that a vendor with which it plans to enter into a covered transaction is not suspended, debarred, or otherwise excluded, the Cooperative disclosed they relied on a clause to be included in the vendor contracts to ensure compliance. Two covered transactions that equaled or exceeded $25,000 were identified. Both transactions, totaling $192,218, were selected for testing. One of the two transactions, totaling $44,883, included the appropriate clause. For the other vendor, the Cooperative did not verify the vendor’s suspension and debarment status prior to payment. The lack of internal controls and noncompliance regarding suspension and debarment were isolated to fiscal year 2023. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and will take the following corrective action: 1 – Southwest School Corporation will ensure a system of internal control and procedures are in place and appropriate procurement procedures for goods and services are followed. 2 – The Cooperative will post any openings that exceed the small purchase threshold in the local newspapers, within the office, and on the cooperative website. Any and all proposals will be presented to the Cooperative Board of Directors for approval. Responsible party and timeline for completion: Chris Stitzle, Superintendent – April 1, 2024

2023-015. Obligation of CRF Funds Not Completed Within Proper Timeframe State Agency: Governor’s Office of Planning and Budget Federal Agency: Department of the Treasury GOPB will save copies of the Treasury Department guidance documents and the September 2022 email from the Treasury Office of the Inspector General that it used to determine that it could update the December 31, 2022 quarterly CRF report to include additional benefit payments from the Unemployment Compensation Fund made between March 1, 2020 and December 31, 2021. GOPB will also save copies of financial reports and other documentation that demonstrates the total costs incurred from the Unemployment Compensation Fund during that time frame did not exceed total deposits into the fund from the CRF, SLFRF, or other sources. Contact Person: Duncan Evans, Senior Managing Director of Budget and Operations, 801-538-1592 Anticipated Correction Date: March 31, 2024

FINDING 2023-006 Information on the federal program: Subject: Special Education Cluster (IDEA) – Procurement and Suspension and Debarment Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.027X, 84.173, 84.173X Federal Award Numbers: 19611-022-PN01, 20611-022-PN01, 21611-022-PN01, 22611-022-PN01, 22611-022-ARP, 23611-022-PN01, 20619-022-PN01, 21619-022-PN01, 22619-022-PN01, 22619-022-ARP, 23619-022-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Qualified Opinion Condition: The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the procurement and suspension an debarment requirements. The Cooperative had not designed or implemented adequate policies or procedures to ensure that proper procurement procedures for micro or small purchases were followed. There was no oversight, review, or approval process in place and documented at the Cooperative to ensure proper procedures were followed and price or rate quotations were obtained, if required, or documentation to support limited procurement procedures. Context: The School Corporation is a member of the Greene-Sullivan Special Education Cooperative (Cooperative). During fiscal year 2021-2022 and 2022-2023, the Cooperative operated the special education programs and spent the federal money on behalf of all its members. As the grant agreements were between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. However, there was inadequate oversight performed by the School Corporation in order to ensure compliance with the Procurement and Suspension and Debarment compliance requirement. Procurement Federal regulations allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisition threshold, which is set at $250,000 unless a lower, more restrictive threshold is set by a non-Federal entity. As Indiana Code has set a more restrictive threshold of $150,000, informal procurement methods are permitted when the value of the procurement does not exceed $150,000. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds. Micro-purchases, 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. For fiscal year 2022, three vendors, totaling $88,772, were identified as being less than the simplified acquisition threshold of $150,000, but exceeding the $10,000 micro-purchase threshold. One of the three vendors was a bankcard used to pay several different vendors; however, individual determinations of amount spent by vendor could not be determined, and thus it was considered under this threshold. All three vendors were tested. For all three, the Cooperative did not obtain price or rate quotes nor was there documentation detailing the history of procurement, which must include the reason for the procurement method used. For fiscal year 2023, six vendors, totaling $264,106, were identified as being less than the simplified acquisition threshold of $150,000, but exceeding the $10,000 micro-purchase threshold. One of the six vendors was a bankcard used to pay several different vendors; however, individual determinations of amount spent by vendor could not be determined, and thus it was considered under this threshold. All six vendors were tested. For five of the six, totaling $252,906, the Cooperative did not obtain price or rate quotes nor was there documentation detailing the history of procurement, which must include the reason for the procurement method used. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Suspension and Debarment Prior to entering into subawards and covered transactions with federal award 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 SAMs exclusions, collecting a certification from that vendor, or adding a clause or condition to the covered transaction with that vendor. Upon inquiry of the School Corporation in order to review the procedures in place for verifying that a vendor with which it plans to enter into a covered transaction is not suspended, debarred, or otherwise excluded, the Cooperative disclosed they relied on a clause to be included in the vendor contracts to ensure compliance. Two covered transactions that equaled or exceeded $25,000 were identified. Both transactions, totaling $192,218, were selected for testing. One of the two transactions, totaling $44,883, included the appropriate clause. For the other vendor, the Cooperative did not verify the vendor’s suspension and debarment status prior to payment. The lack of internal controls and noncompliance regarding suspension and debarment were isolated to fiscal year 2023. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and will take the following corrective action: 1 – Northeast School Corporation will ensure a system of internal control and procedures are in place and appropriate procurement procedures for goods and services are followed. 2 – The Cooperative will post any openings that exceed the small purchase threshold in the local newspapers, within the office, and on the cooperative website. Any and all proposals will be presented to the Cooperative Board of Directors for approval. Responsible party and timeline for completion: Mark A Baker, Superintendent Effective April 2024

FINDING 2023-003 Finding Subject: Child Nutrition Cluster – Procurement and Suspension and Debarment Summary of Finding: Procurement: For one of the two vendors tested for small purchases an adequate number of price or rate quotes were not obtained. Suspension and Debarment: The School Corporation purchased bread, dairy produce and commodities through Region 8 Education Service Center (Region 8) However, Region 8 had not received the SFA – only Cooperative classification from IDOE for fiscal years 2021-2022 and 2022-2023. As such, the School Corporation could not rely on Region 8’s verification of suspension and debarment and was required to complete their own verification. One covered transaction was identified and tested that equaled or exceeded $25,000. For the noted transaction, the School Corporation did not verify that the vendor was not excluded or disqualified from participation in federal award programs. Contact Person Responsible for Corrective Action: Susan Loftain Contact Phone Number and Email Address: (260) 693-2007 loftains@sgcs.k12.in.us Views of Responsible Officials: Option 1: “We concur with the finding.” Description of Corrective Action Plan: Procurement: All vendors procured through Region 8 we will need to take action to secure bids and quotes and keeps copies and make we are within compliance Suspension and Debarment: We will be sure to complete our own verifications and not rely on Region 8 to check on suspension and debarment Anticipated Completion Date: Today 2/28/24

PDA: For federal programs within the Food Distribution Cluster (ALNs 10.565, 10.568, and 10.569), PDA will put the following steps in place for (1) identifying the federal award information and applicable requirements and (2) evaluating each subrecipient’s risk of noncompliance as Required by the Uniform Grant Guidance. 1) PDA will ensure that FAIN numbers are now included in all new subaward agreements. (For currently existing agreements, PDA will send letters by June 30 to provide the FAIN and reiterate Single Audit requirements.) 2) For those subaward agreements that are permanent and/or cover multiple funding years, PDA will develop procedures to ensure that annual notices are sent to each subrecipient notifying them of the updated FAIN for their agreement and reminding them of the Single Audit requirements that are laid out in the terms of their initial signed agreement. 3) PDA will develop a process to evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. The evaluation will be based on Key Performance Indicators, such as leadership tenure; prior incidents of food spoilage; or qualitative feedback from clients served. If the evaluation determines that additional monitoring tools beyond the routine performance of on-site reviews of the subrecipient's program operations are necessary, such conditions will be laid out in a separate letter communication to the sub-awardee. Anticipated Completion Date: 06/30/2024 Contact Name: Caryn Long Earl, Director, Bureau of Food Assistance PDOA: PDOA will implement the following steps to evaluate each subrecipient’s risk of noncompliance as required by the uniform grant guidance. 1. Evaluation is ongoing for the impacted Aging Cluster programs. 2. A risk assessment is being developed to evaluate each subrecipient’s risk of noncompliance to proactively address any weaknesses in internal controls over federal programs. - Pointed questions regarding the Organization included to gauge management’s ability to follow all terms and conditions of the contract. - General Policies will be reviewed for adherence to all federal and state regulations and competence of personnel administering the programs. - Since multiple federal funding streams are involved, a fiscal component will also be administered to review internal controls for financial issues. 3. Performance check-ins are launching in April of 2024 as part of a statewide comprehensive monitoring as a new form of regulatory measure. 4. Follow-Up procedures resulting from this finding will be reviewed and adjusted as needed to deliver optimal outcomes. Preliminary procedures will be directed to the agency’s audit review committee for resolution of completeness. 5. In the event the audit review committee determines additional steps beyond the monitoring efforts outlined above are insufficient, additional efforts will be communicated to the AAA network. Anticipated Completion Date: 06/30/2024 Contact Name: Jennifer Cave, Fiscal Management Specialist, PDOA Audit Liaison DOH: DOH plans to develop and implement a robust subrecipient monitoring program which includes establishing a new section within the Budget Office pending enacted budget funds and complement to support the creation of the section. Initiative goals/milestones include: 1. Educate Department: Budget Office is developing a bulletin that will outline the subrecipient monitoring requirements with links to state and federal sources. The bulletin will be shared with all program office staff. The Budget Office will develop the following templates and provide to all program offices: - Determination of vendor status: Subrecipient or Contractor - Risk Assessment Form - Internal Control Self-Assessment for Subrecipient Template - Subrecipient Monitoring Template 2. Implementation of full compliance initiative: Recommendations provided in the assessment will be used to develop and implement comprehensive policies and procedures lead by a new section in the Budget Office. Anticipated Completion Dates: 1 - 03/31/2024; 2 - 03/31/2025 Contact Name: Andrea Race, CFO DHS: Foster Care 1. For the portion of the audit finding that indicates State Agencies Did Not Identify the Federal Award Information and Applicable Requirements at the Time of the Subaward. Beginning state fiscal year 2024-2025, OCYF will begin sending out the required information to the Foster Care non-profit contractor. 2. Separately, OCYF will be developing a risk assessment process for the Foster Care non-profit contractor in state fiscal year 2024-2025. Anticipated Completion Dates: 1 - 06/30/2024; 2 - 06/30/2025 Contact Name: Melissa Erazo, Director, Bureau of Budget and Fiscal Support TANF and SSBG Effective December 31, 2023, DHS’ grant contract with Real Alternatives ended. We have no contract for services with them going forward. Despite repeated attempts and efforts to engage this grantee in ongoing monitoring activities, as well as monitoring after the end of the grant for previous years, they were uncooperative and unresponsive to our requests and therefore regular monitoring was not completed. Due to the Covid-19 global pandemic as well as staff turnover and vacancies in the Office of Policy Development, regular monitoring of SSBG grant recipients was not performed on schedule. However, with the hiring of a full complement of staff for the DHS Policy Office, including a Grant Administrator, we are in the process of creating and implementing a robust monitoring plan for all 19 of our grantees for calendar year 2024, including risk assessments, in person monitoring, desk monitoring, data collection and analysis. Anticipated Completion Date: 12/31/2024 Contact Name: Jessica Schneider, Executive Policy Specialist I, Grants

Program: AL 21.026 – COVID-19 Homeowner Assistance Fund – Subrecipient Monitoring Corrective Action Plan: The Military Department will continue to modify the Memorandum of Understanding between the parties to identify NIFA as a subrecipient and advise of them of any additional requirements. Contact: Erv Portis Anticipated Completion Date: ongoing

Program: AL 20.509 – Formula Grants for Rural Areas – Subrecipient Monitoring Corrective Action Plan: NDOT updated the supplemental agreement template to include the Federal Award Identification information, including Federal award date and subaward period of performance start and end dates. A draft template has been provided to the APA. Current 5311 agreements are effective July 1, 2024 to June 30, 2025, when additional supplemental agreements are needed, the updated template which includes FAIN information will be provided to the subrecipients. Contact: Jodi Gibson Anticipated Completion Date: Complete

Program: AL 17.225 – Unemployment Insurance – State – Allowability & Eligibility Corrective Action Plan: The Department has worked with its vendor to implement changes to the wage crossmatch process. The Department has increased the size of its Benefit Integrity Unit and implemented further fraud prevention tools. The Department is working with the unit and individuals to properly prioritize workloads. The Department continues to work extensively with their vendor to address and resolve the issues related to separation information requests. The Department has also revised its adjudication process to manually address issues related to separation information requests pending the vendor completion of the needed corrections. The Department been working to improve its quality and has coached the adjudication team on ETA requirements for follow-up with employers. The Department also implemented a new work model in consultation with a vendor. Since implementing the new process, the Department has met first payment timeliness and nonmonetary determination timeliness for October, November, and December 2023 and January 2024. Separation issues as a cause of improper payment decreased from 6.245% in FFY 2022 to 3.173% in FFY 2023, and overall improper payment rate for FFY is down from 16.014% to 14.862%. Contact: Andi Bridgmon, UI Director Anticipated Completion Date: Ongoing – overall adjudication quality is an ongoing focus of the Department and will be continuously reviewed for continued improvement.

Audit Report: Reports on Compliance and Internal Control in Accordance with Government Auditing Standards and OMB Super Circular Uniform Guidance Audit Period: July 1, 2022 – June 30, 2023 Fiscal Year: 2022-2023 Principal Executive: Hon. Marcos Cruz Molina, Mayor Contact Person: Mr. Edgardo Pérez, Department of Management, Administration and Budget Director Phone: (787)855-2500 Original Finding Number: 2023-002 Statement of Concurrence or Non concurrence: We concur with the finding. Corrective Action: During the quarters from January to March and April to June 2023, there were differences between the reports submitted to the Treasury Department and the accounting reports of the SIMA system. This happened because obligations that were cancelled were included in the submitted reports and not corrected within the corresponding quarter. The personnel assigned to work on the quarterly reports became aware of these situations after the submission of the reports. As a corrective measure, an internal work sheet was created where monthly cancellations and adjustments are verified. In this way, the quarterly report submitted to the Treasury Department will agree with the accounting system. Before submitting the reports, a meeting is held to validate that the worksheet is in accordance with the accounting system. After validating the accuracy of the worksheet, the report is submitted to the Treasury Department with information consistent with the accounting system. As of today, the differences identified have been corrected in subsequent quarters. Implementation Date: Fiscal Year 2023-2024. Responsible Person: Bárbara Castro Viruet Accountant

FIDING NO. 2023-003 PROCUREMENT SUSPENSION AND DEBARMENT CONDITION We examined one hundred percent (100%) of the disbursed made and charged to HEERF Institutional Aid for the fiscal year 2022-2023 and noted the following: 1) UPM did not have documentation related Schools are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. 2) UPM made five (5) payments for $100,406.71 in advance for goods or services not received at the disbursement date. RECOMMENDATION The Institution should reinforce the established procedures and adhere to them before any payment is made for goods or services. The amount of $100,406.71 should be reimbursed to the U.S. Department of Education. In addition, UPM should be included in its procedures steps to adopting regulations, to verify that the vendor entity is not suspended or debarred or otherwise excluded from participating in the transaction. Corrective Action Plan: The UPM requested the documents from potential vendors that authorized them to do business in Puerto Rico. The selected company, Vitaltek, provided documents showing that it was established and compliant with the law, precisely the evidence that they were not debarred or suspended. The UPM has a procurement process titled " Reglamento para la Adquisici6n de Equipos, Materiales y Servicios No Personales de la Universidad Pentecostal MIZPA" that states the process for verifying debarment and suspension. Prepayments The UPM has analyzed each prepayment, and we have evidence that the services, equipment. and materials have been received. In addition to having the purchase orders, contract, and invoices, we have the equipment in our facilities in good condition and inspected per our internal procedures, titled "Reglamento para la Administraci6n de Propiedad Mueble (Equipo) de la Universidad Pentecostal Mizpa." Vitaltek was the only company that provided a quote and was selected due to the COVID-19 emergency. Their purchase condition required a prepayment for ordering and obtaining products. Regarding the Service Contract for the photocopiers, we recognize that it was paid in advance; however, to date, all services related to this contract that we have required have been offered in compliance with each of the clauses and agreements signed. The acquisition of this type of equipment comes with a multiyear plan and maintenance services included in the package, which is the industry standard and necessary for the institution's administrative and academic operations. Understanding the seriousness of the correct administration of these funds, the Dean of Administration will periodically evaluate compliance with any contract. If it is not complied with, we will proceed through legal action to quickly recover these funds. The UPM understands that it should not reimburse this money to the United States Department of Education because there is sufficient evidence to demonstrate that the funds have been used within legal parameters, that they have strengthened the University in academic and administrative and that from now on we will observe the following to comply with such an essential and necessary reservation. Corrective action plan to follow: All employees. including those in the office of the presidency, have been finally and firmly alerted that advance payments should be avoided or only considered in emergency situations. All employees authorized to reach contractual agreements will be trained on this topic, and the internal procedures will be reviewed and edited to address prepayments and emergency processes. We will appoint an employee in charge of managing all compliance documentation so that, together with the Dean of Administration and Finance, they can locate and group all the relevant standards and regulatory procedures and have the power to guide so that each of its recommendations is willingly observed. This will be supported by the requirements that always accompany each award. In addition, these officers will have the power to make external consultations with professionals familiar with these matters.

Finding 2023-004 Finding Subject: Child Nutrition Cluster-Procurement and Suspension and Debarment Summary of Finding: The School Corporation had not properly designed or implemented internal controls over procurement and suspension and debarment Contact Person Responsible for Corrective Action: Dr. Tracy Lorey, Monica Young, April Hopf Contact Phone Number and Email Address: tlorey@gjcs.k12.in.us myoung@gjcs.k12.in.us ahopf@gjcs.k12.in.us 812-482-1801 Views of Responsible Officials: We agree with the finding. Description of Corrective Action Plan: The school corporation will follow our Procurement policy in the future. Anticipation Completion Date: August 2024—Beginning of New School Year

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 2023-004 Finding Subject: Child Nutrition Cluster – Procurement, Suspension, and Debarment Summary of Finding: Material Weakness, Other Matters The School Corporation had not properly designed or implemented an effective system of internal controls to prevent, or detect and correct, noncompliance. Procurement: A School Nutrition Cooperative (Co-ops, Education Service Center, Group Purchasing Organization, etc.) that would like to be classified as a School Food Authority (SFA) Cooperative must complete a questionnaire and submit it to the Indiana Department of Education (IDOE). Once a questionnaire is received IDOE will review the answers to determine a Cooperative’s classification. Only Cooperatives that submit the questionnaire and receive a SFA-only Cooperative classification from IDOE in writing will be considered a SFA only Cooperative for the purposes of the procurement process and procurement reviews. When the value of goods or services exceeds the simplified acquisition threshold, the proper purchasing method would be the bidding process, unless the purchase meets certain other qualifications. 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. Micro-purchases, 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 School Corporation purchased milk through Region 8 Education Service Center (Region 8). However, Region 8 had not received the SFAonly Cooperative classification from IDOE for fiscal years 2021–2022 and 2022-2023. As such, the School Corporation could not rely on the procurement done by Region 8. Region 8 could be considered one quote for procurement; however, the School Corporation did not obtain any other quotes related to the purchase of milk, therefore, an adequate number of quotes from qualified sources was not obtained. Suspension and Debarment: Prior to entering into subawards and covered transactions with federal award 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 SAMs exclusions, collecting a certification from that vendor, or adding a clause or condition to the covered transaction with that vendor. INDIANA STATE BOARD OF ACCOUNTS 47 MADISON-GRANT UNITED SCHOOL CORPORATION Steve Vore., Superintendent Ben Mann, Chief Financial Officer Kristy Drewitz, Transportation Allison McGuire, Payroll/Benefits Anna Richards, Corp Secretary/Deputy Treasurer Inspire, Cultivate, and Promote excellence in every Argyll. Upon inquiry of the School Corporation in order to review the procedures in place for verifying that a vendor with which it plans to enter into a covered transaction is not suspended, debarred, or otherwise excluded, the School Corporation noted that vendor’s were checked against Sam. Gove and verified to not be suspended or debarred. Four covered transactions that equaled or exceeded $25,000 were identified. All for transactions, totaling $213,795, were selected for testing. For three of the four vendors, the School Corporation did not verify the vendor’s suspension and debarment status prior to payment. The total amount spent with the three vendors was $162,733. Contact Person Responsible for Corrective Action: Kathy Bernaix Contact Phone Number and Email Address: 765-536-0008 kbernaix@mgusc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Procurement: Three quotes will be requested for “small purchases” and the process will be reviewed to ensure it is performed. Suspension and Debarment: Before purchasing goods that total $25,000 or more from a vendor, the Food Service Director will look up the vendor on SAM.gov for debarment activity. Anticipated Completion Date: February 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.

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

Condition: The College did not have a control system in place to monitor performance measures as outlined in the subrecipient and grant agreements. The College was also not completing any site visits of the subrecipients or requiring annual financial reporting be submitted. Planned Corrective Action: Below are three items implemented to address the subrecipient monitoring requirement: 1. To address the finding of noncompliant subrecipient agreements, Grand Rapids Community College has implemented a new Grants Administration Guide. This guide can be found on the Grand Rapids Community College website. 2. To address the finding of lack of progress monitoring, subrecipient partners have been given monthly metric reports which include planned vs actual outcomes as a means of outlining their progress. The reports also include historical data for each category. This information is broken down by month and to be reviewed with subrecipients on a bi-weekly basis. This bi-weekly monitoring will provide oversight and help manage performance. Each grant partner will submit quarterly outreach plans that will be balanced against planned vs actual outcomes. These outreach plans will consist of detailed information highlighting the purpose of the event, target audiences, and updates from previous events. 3. To address the finding of lack of subrecipient monitoring, Grand Rapids Community College has scheduled formal site visits with subrecipients. Within the meetings they will discuss the following topics: Narrative Visit Overview, Financial Status Discussions, Metrics Verification, Narrative Overview, Participant Records and Revenue and Evaluation. Contact person responsible for corrective action: C. Dennis Triggs II- Program. Manager – One Workforce Grant. Anticipated Completion Date: 7/31/2023

FINDING 2023-005 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. Micro-purchases, 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 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: Julie Dudley Contact Phone Number and Email Address: 812.537.7205 jdudley@lburg.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 2023-005 Finding Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Summary of Finding: Management had not developed a system of internal controls that would have ensured compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. The failure to establish an effective internal controls system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement could result in the loss of future federal funds to the School Corporation. We recommended that the School Corporation's management establish a system of internal controls to ensure compliance with the Procurement and Suspension and Debarment compliance requirement. Contact Person Responsible for Corrective Action: Andrea Miller Contact Phone Number and Email Address: 765-564-2100, millera@delphi.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Food Service Director will obtain 3 quotes for any purchase over $10,000 from different vendors, in addition if the purchase is over $50,000 a contract will be awarded. Vendors will be verified by SAM.gov for suspension and disbarment, a record of these searches will be printed and kept in the vendor file. In addition, a vendor list will be provided annually to the school board for approval. Anticipated Completion Date: July 2024