Corrective Action Plans

The District will discuss the results of this audit with our ESC to establish protocols and receive copies of their annual audit reports for review.

CORRECTIVE ACTION PLAN - Recognizing the need/requirement to maintain property records appropriately, the district is working to schedule/complete a comprehensive physical inventory that should assist in identifying the location of equipment funded by the Education Stabilization Fund (ESF), resulting in questioned costs of $2,186,066 per this finding (in addition to all other equipment carried by the district regardless of funding source). The district plans are to continue to work with NEFEC to enact property records within Skyward to capture accurate information and a base starting point per completion of a physical inventory. All property records will then be maintained in Skyward to capture all information required under Federal funding provisions and a reconciliation to physical inventory counts will be prepared no less than every 2 years. Anticipated Completion Date: June 30, 2025 Responsible Contact Person: Walter Copeland, Interim CFO

FINDING 2024-001 Finding Subject: Special Education Cluster (IDEA) – Procurement and Suspension and Debarment Summary of Finding: Federal Agency: Department of Education Federal Programs: COVID-19 - Special Education Grants to States; COVID-19 - Special Education Preschool Grants Assistance Listings Numbers: 84.027; 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 22611-042-ARP; 22619-042-ARP Pass-Through Entity: Indiana Department of Education Compliance Requirement(s): Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Dawn Mason, Business Manager, DeKalb Co. Eastern CSD Contact Phone Number and Email Address: 260-868-2125; dmason@dkeschools.com Views of Responsible Officials: We concur with the findings. Description of Corrective Action Plan: The expenditures referenced in the finding were expended from the American Rescue Plan Special Education grant funds which were fully expended during the audit period. All future expenditures triggering procurement and suspension and debarment requirements will include implementing the following procurement policies. Reference Procurement Standards 2 CFR 200.318 Districts may not enter into contracts with entities that have been suspended or debarred from participating in contracts with federal funds. For contracts over $25,000, districts must verify a contractor is not excluded or disqualified. Contractors must be verified in one of three ways: 1. Checking the System for Award Management (SAM) (www.SAM.gov) 2. Collecting a certificate from that contractor. 3. Adding a clause or condition to the covered transaction with that contractor. (Recommended) **Proper verification and documentation must be sent to the LEA for audit purposes. Methods of Procurement Where specific EDGAR/UG thresholds apply, Districts must meet baseline requirements for procurement. If State or local rules have more restrictive thresholds, the most restrictive rule must be followed. E INDIANA STATE BOARD OF ACCOUNTS 25 Informal Procurement Procedures 1. Micro-purchase (0-$50,000) Dekalb County Eastern CSD has self-certified micro-purchases for up to $50,000 Micro-purchases may be awarded without soliciting competitive quotes if the district considers the price to be reasonable. Quotes must be attached to the invoice/checks for proper documentation and retained by the LEA. 2. Small Purchase ($50,000 – $150,000) Three quotes are required prior to purchase unless the purchase comes from a “Sole Source” vendor. Small purchases are required to be ordered under a purchase order unless in an emergency. Additional quotes must be presented along with the purchase order prior to being approved by the LEA. Formal Procurement Procedures 1. Sealed Bids (above $150,000) Bids must be solicited from an adequate number of suppliers, providing them with sufficient response time prior to the opening of the bids. Proper advertisement and procedures must be followed per IC 5-22 and corresponding documentation must be presented to the LEA prior to any final approval or purchases being made. 2. Competitive Proposals (above $150,000) The Request for Proposal method is used for procurements in which factors other than cost play a significant role. Per IC 5-22-9, when a purchasing agent makes a written determination that the use of competitive sealed bidding is either not practicable or not advantageous to the governmental body, the purchasing agent may award a contract using this procedure instead of competitive sealed bidding. This provides a formal process for the procurement of goods and/or services for which price is not the sole factor in the selection of a vendor or vendors. Proper advertisement and procedures must be followed per IC 5-22 and corresponding documentation must be presented to the LEA prior to any final approval or purchases being made. Noncompetitive (Sole Source) All sole source procurements require adequate written justification and must be attached to the corresponding purchase order or payment. Anticipated Completion Date: All expenditures initiated after March 12, 2025

FINDING 2024-003 Finding Subject: Special Education Cluster (IDEA) – Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Bethany Cmar Contact Phone Number and Email Address: 765-641-2126 (Bcmar@acsc.net) Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: When it comes to procurements thresholds, ACS will prepare a policy to follow the necessary federal guidelines. For small purchases, three quotes or bids will be obtained to ensure compliance with the procurement guidelines. For all vendors expected to exceed over $25,000 in expenditures will be kept in a binder by the Special Ed Director to ensure that they are not suspended or debarred from federal awards. The CFO will then review and approve the documentation supporting this via signature. Anticipated Completion Date: June 30, 2025

FINDING 2024-007 (Section III-Federal Award Findings and Questioned Costs) Finding Subject: Special Education Cluster (IDEA) - Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Dawn Mason, Business Manager, DeKalb Co. Eastern CSD Contact Phone Number and Email Address: 260-868-2125; dmason@dkeschools.com Views of Responsible Officials: We concur with the findings. Description of Corrective Action Plan: The expenditures referenced in the finding were expended from the American Rescue Plan Special Education grant funds which were fully expended during the audit period. All future expenditures triggering procurement and suspension and debarment requirements will include implementing the following procurement policies. Reference Procurement Standards 2 CFR 200.318 Districts may not enter into contracts with entities that have been suspended or debarred from participating in contracts with federal funds. For contracts over $25,000, districts must verify a contractor is not excluded or disqualified. Contractors must be verified in one of three ways: 1. Checking the System for Award Management (SAM) (www.SAM.gov) 2. Collecting a certificate from that contractor. 3. Adding a clause or condition to the covered transaction with that contractor. (Recommended) **Proper verification and documentation must be sent to the LEA for audit purposes. Methods of Procurement Where specific EDGAR/UG thresholds apply, Districts must meet baseline requirements for procurement. If State or local rules have more restrictive thresholds, the most restrictive rule must be followed. Informal Procurement Procedures 1. Micro-purchase (0-$50,000) Dekalb County Eastern CSD has self-certified micro-purchases for up to $50,000 Micro-purchases may be awarded without soliciting competitive quotes if the district considers the price to be reasonable. Quotes must be attached to the invoice/checks for proper documentation and retained by the LEA. 2. Small Purchase ($50,000 – $150,000) Three quotes are required prior to purchase unless the purchase comes from a “Sole Source” vendor. Small purchases are required to be ordered under a purchase order unless in an emergency. Additional quotes must be presented along with the purchase order prior to being approved by the LEA. Per Uniform Guidance: 2 CFR § 200.511(a) – “The auditee is responsible for follow-up and corrective action on all audit findings. . .The auditee must also prepare a corrective action plan for current year audit findings. . . The corrective action plan and summary schedule of prior audit findings must include findings relating to the financial statements which are required to be reported in accordance with GAGAS. ” 2 CFR § 200.511(c) – “At the completion of the audit, the auditee must prepare, in a document separate from the auditor's findings described in § 200.516, a corrective action plan to address each audit finding included in the current year auditor's reports. The corrective action plan must provide the name(s) of the contact person(s) responsible for corrective action, the corrective action planned, and the anticipated completion date. If the auditee does not agree with the audit findings or believes corrective action is not required, then the corrective action plan must include an explanation and specific reasons.” Formal Procurement Procedures 1. Sealed Bids (above $150,000) Bids must be solicited from an adequate number of suppliers, providing them with sufficient response time prior to the opening of the bids. Proper advertisement and procedures must be followed per IC 5-22 and corresponding documentation must be presented to the LEA prior to any final approval or purchases being made. 2. Competitive Proposals (above $150,000) The Request for Proposal method is used for procurements in which factors other than cost play a significant role. Per IC 5-22-9, when a purchasing agent makes a written determination that the use of competitive sealed bidding is either not practicable or not advantageous to the governmental body, the purchasing agent may award a contract using this procedure instead of competitive sealed bidding. This provides a formal process for the procurement of goods and/or services for which price is not the sole factor in the selection of a vendor or vendors. Proper advertisement and procedures must be followed per IC 5-22 and corresponding documentation must be presented to the LEA prior to any final approval or purchases being made. Noncompetitive (Sole Source) All sole source procurements require adequate written justification and must be attached to the corresponding purchase order or payment. Anticipated Completion Date: All expenditures initiated after March 12, 2025

FA 2024-001 Strengthen Controls over Transfers Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principle Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Federal Awarding Agency: U.S. Department of Agriculture Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: 10.553 - School Breakfast Program 10.555 - National School Lunch Program COVID-19-10.555 - National School Lunch Program Federal Award Number: 245GA324N1199 (Year: 2024), 225GA324N1099 (Year: 2024) Questioned Costs: $803,845.92 Prior Year Finding: None Identified Description: The polices and procedures of the School District were insufficient to provide adequate internal controls over transfers of Child Nutrition Cluster funds. Corrective Action Plans: The School District will review current internal control procedures related to School Nutrition Fund transfers. Development and/or modification of current policies and procedures will be determined as needed to ensure that all expenditures, including transfers, are used for allowable purposes. In addition, the School District will implement a monitoring process to ensure that all expenditure activity is compliant with the School District's policies and procedures. Estimated Completion Date: June 30, 2025 Contact Person: Debbie Woerner, Finance Director/Asst Superintendent Telephone: 770-567-8489 ext. 1030 Email: woerned@pike.k12.ga.us

FINDING 2024-003 Finding Subject: Special Education Cluster – Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Marcia Fullenkamp, Treasurer Contact Phone Number and Email Address: (812) 623-2212; mfullenkamp@rodspecialed.org 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. Anticipated Completion Date: February 1, 2024

FINDING 2024-005 (Auditor Assigned Reference Number) Finding Subject: Special Education Cluster (IDEA)- Period of Performance Contact Person Responsible for Corrective Action: Julie Remschneider Contact Phone Number and Email Address: julie.r@nn.k12.in.us, 219-285-2228 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We will ensure the Special Education Co-op will have controls in place to make sure payments are made within the period of performance. Anticipated Completion Date: September 30, 2025

Corrective Action Plan Finding 2024-001 Finding Summary: The Center did not exclude charges for patient care when calculating modified total direct costs (MTDC) in accordance with Uniform Guidance and TxGMS and thus the indirect rate used in calculating the indirect amount charged to the grant was not consistently accurate. Corrective Action Plan: The Center has historically calculated the indirect amount using the same methodology over time. Given the small volume of patient receipts, the impact on the total indirect amount is minor. We believe that had we modified our calculations, we would have had enough modified total direct costs to cover the change in the calculation. The Center will modify all future calculations to ensure alignment. We will also review the fiscal year covered under this audit to understand what the impact of the change would have been on the split between cost types. Note that since we are midway through our next fiscal year, and we consider the differences minor, we have determined that we will correct for any future reimbursement requests, but will not modify prior reimbursement requests. Similarly, we will conduct a review of that fiscal year to determine the impact of the change and verify it is not significant. Responsible Individuals: Rusty Taylor, CFO Joe Carrington, Director of Financial Planning and Analysis Anticipated Completion Date: August 2025

Finding 2024‐002 Finding Subject: Special Education Cluster (IDEA) ‐ Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Todd A. Armstrong, Assistant Superintendent Contact Phone Number and Email Address: (812) 897‐6036 tarmstrong@warrick.k12.in.us Views of the Responsible Official: We concur with the finding. Additional Explanation: Although the vendors selected provided specific services outlined in the federal grant, proper documentation of how those vendors were selected was not maintained. Moreover, the department believed by following the spending allotted in the grant, they were meeting necessary purchasing guidelines. Internal controls did not identify this misstep and allowed the services to be purchased. To avoid this in the future, guidelines will be prepared for all departments submitting purchase requests, and an additional control will be put in place to verify that procedures are followed. Description of Corrective Action Plan: 1) Create and write an administrative guideline that outlines expected purchasing procedures. 2) Distribute and make available the administrative guideline to employees. 3) Create an additional internal control in the business office to verify that those procedures were met with each requisition or request for purchase. 4) Provide necessary corrections to any request that does not follow guidelines. Mr. Armstrong will oversee, direct, and coordinate this process. He will work with the Corporation administrative team to develop and write the guidelines. The Business department will distribute the guidelines to all interested parties and have guidelines available upon request. Mr. Armstrong will outline expectations and determine when they have been met satisfactorily. Anticipated Completion Date: The remedy for this finding will be in place prior to June 30, 2025.

Corrective action plan: N/A Implementation dates: N/A Responsible persons: Tim Urbanovsky, Director of Accounting & Financial Reporting Services

FINDING 2024-004 Finding Subject: Special Education Cluster (IDEA) - Procurement Contact Person Responsible for Corrective Action: Robert Glover Jr. Contact Phone Number: (219) 945-0250 Contact Email Address: rglover@hobart.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: As a member of the Northwest Indiana Special Education Cooperative (NISEC), School City of Hobart usually expends contracted services out of our general education fund. For the fiscal year 2023-2024, we included our contracted speech services into our federal grant funds. During the audit, Hobart was notified that we didn’t follow the procurement procedures when expending out of the federal grant. This finding was due to Hobart not going out and receiving multiple bids for contracted companies that provide services to our students. Hobart uses three contracted companies to provide Speech Pathologist and Speech Language Assistants. We have used these three companies for many years and have built great working relationships with these providers. After receiving the finding, and discussing with the auditor, we created a memo that we took to our board. In the memo we explained why we use the three contracted vendors instead of going out for bids. Finding Speech Pathologists and Speech Language Assistants is very difficult in the school setting, and they have created great working relationships with these three contracted companies. Within the memo, we listed all the contracted vendors that they use and why they work directly with them instead of going out for bids. If any contracted services are not bid, at the beginning of each school year, they will create a new memo with any contracted companies that they will be using during that school year and the memo will be approved by the School Board. Anticipated Completion Date: 4/30/2025

COMMONWEALTH OF PUERTO RICO CORRECTIVE ACTION PLAN MUNICIPALITY OF NARANJITO FOR THE FISCAL YEAR ENDED JUNE 30, 2024 Audit Report: Reports on Compliance and Internal Control in Accordance with Government Auditing Standards and 2 CFR 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards Audit Period: July 1, 2023 – June 30, 2024 Fiscal Year: 2023-2024 Principal Executive: Hon. Orlando Ortíz Chevres - Mayor Contact Person: Mrs. Carmen López, Interim Finance Director Phone: (787) 869 – 2200 Original Finding Number: 2024-003 Statement of Concurrence or Nonconcurrence: We concur with the finding. Corrective Action: The authorized personnel understand the reporting requirements. We are in the process of training additional personnel to have more resources to comply with all reporting requirements. The Finance Department is working with external consultants to address this situation and be able to comply with all reports as required. Implementation Date: June 30, 2025 Responsible Person: Carmen I. López – Interim Finance Director

FINDING 2024-003 Finding Subject: Childhood Nutrition Cluster – Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Ralph Shrader, Superintendent Contact Phone Number and Email Address: (765) 762-3364 / rshrader@msdwarco.k12.in.us Views of Responsible Officials: Option 1: We concur with the finding Description of Corrective Action Plan: We will obtain quotes for any purchases that qualify under the small purchases requirement Any director responsible for corporation contracts, will be responsible for checking Sam.gov to ensure the vendor is not on the suspension and disbarment list. A secondary individual will verify the findings. In addition, the micropurchase threshold will be raised to $50,000. Anticipated Completion Date: Effective Immediately

FINDING 2024-005 Finding Subject: Child Nutrition Cluster-Procurement and Suspension and Debarment Summary of Finding: The school corporation made purchases from vendors without using the procurement method and verifying that the vendor was not suspended or debarred. The School corporation did not properly implement a process to identify and assess internal and external risks, or monitor internal control activities to ensure they were operating effectively. Contact Person Responsible for Corrective Action: Melissa Embry Contact Phone Number and Email Address: 812-547-2637 melissa.embry@cannelton.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We will follow all correct procurement plans set forth in the future. We will also verify with each vendor and have a form filled out stating that they are not suspended or debarred. Cannelton management will establish a proper system of internal controls including policies and procedures related to risk assessment and monitoring activities within the federal program. Anticipated Completion Date: The School will ensure proper procurement methods are followed and that vendors are properly checked for suspension and debarment by December 2025. The additional controls will be implemented by August 2025.

Career and Technical Education Response/Corrective Action Plan: The department agrees with this recommendation The department has established a methodology for compiling and reporting financial data that is in accordance with appropriate accounting standards and principles and has corrected reporting obligations, and expenditures. The department has also worked directly with the Treasury Department to make sure the square footage being claimed is consistent with what they are looking for. Contact Person: Wayde Sick, Director and Executive Officer and Gwen Ferderer, Finance Director Anticipated Completion Date: August 2024

FINDING 2024-003 Finding Subject: Summary of Finding: Subject: Special Education Cluster (IDEA) - Procurement and Suspension and Debarment Federal Agency: Department of Education Federal Programs: Special Education Grants to States; COVID-19 - Special Education Grants to States; Special Education Preschool Grants; COVID-19 - Special Education Preschool Grants Assistance Listings Numbers: 84.027; 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 22611-042-ARP; 22619-042-ARP Pass-Through Entity: Indiana Department of Education Compliance Requirement(s): Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Dawn Mason, Business Manager, DeKalb Co. Eastern CSD Contact Phone Number and Email Address: 260-868-2125 Views of Responsible Officials: We concur with the findings. Description of Corrective Action Plan: The expenditures referenced in the finding were expended from the American Rescue Plan Special Education grant funds which were fully expended during the audit period. All future expenditures triggering procurement and suspension and debarment requirements will include implementing the following procurement policies. Reference Procurement Standards 2 CFR 200.318 Districts may not enter into contracts with entities that have been suspended or debarred from participating in contracts with federal funds. For contracts over $25,000, districts must verify a contractor is not excluded or disqualified. Contractors must be verified in one of three ways: 1. Checking the System for Award Management (SAM) (www.SAM.gov) 2. Collecting a certificate from that contractor. 3. Adding a clause or condition to the covered transaction with that contractor. (Recommended) **Proper verification and documentation must be sent to the LEA for audit purposes. INDIANA STATE BOARD OF ACCOUNTS 32 3326 CR 427, Waterloo, IN 46793 p 260-920-1011 f 260-837-7767 Steven E. Teders, Ed.S., Superintendent Loraine K. Vaughn, Ed.S., Assistant Superintendent Mark W. Rohm, Chief Financial and Operations Officer Personalized Pathways for Success Methods of Procurement Where specific EDGAR/UG thresholds apply, Districts must meet baseline requirements for procurement. If State or local rules have more restrictive thresholds, the most restrictive rule must be followed. Informal Procurement Procedures 1. Micro-purchase (0-$50,000) Dekalb County Eastern CSD has self-certified micro-purchases for up to $50,000 Micro-purchases may be awarded without soliciting competitive quotes if the district considers the price to be reasonable. Quotes must be attached to the invoice/checks for proper documentation and retained by the LEA. 2. Small Purchase ($50,000 – $150,000) Three quotes are required prior to purchase unless the purchase comes from a “Sole Source” vendor. Small purchases are required to be ordered under a purchase order unless in an emergency. Additional quotes must be presented along with the purchase order prior to being approved by the LEA. Formal Procurement Procedures 1. Sealed Bids (above $150,000) Bids must be solicited from an adequate number of suppliers, providing them with sufficient response time prior to the opening of the bids. Proper advertisement and procedures must be followed per IC 5-22 and corresponding documentation must be presented to the LEA prior to any final approval or purchases being made. 2. Competitive Proposals (above $150,000) The Request for Proposal method is used for procurements in which factors other than cost play a significant role. Per IC 5-22-9, when a purchasing agent makes a written determination that the use of competitive sealed bidding is either not practicable or not advantageous to the governmental body, the purchasing agent may award a contract using this procedure instead of competitive sealed bidding. This provides a formal process for the procurement of goods and/or services for which price is not the sole factor in the selection of a vendor or vendors. Proper advertisement and procedures must be followed per IC 5-22 and corresponding documentation must be presented to the LEA prior to any final approval or purchases being made. Noncompetitive (Sole Source) All sole source procurements require adequate written justification and must be attached to the corresponding purchase order or payment. Anticipated Completion Date: All expenditures initiated after March 12, 2025

DHS: TANF – Child Care All applicable federal Notice of Awards (NOAs), which include the Federal Award Identification Number, will be emailed to the grantees both prior to the spending period and as they become available for the spending as indicated on the NOA. They will also be included in the annual Audit Guidelines. Anticipated Completion Date: Completed Contact Names: Nia Harris, Dir, Bur. of Early Learning Res. Center Ops.; Adrienne Smyth, Human Service Prgm. Executive; Paula Piasecky, Human Serv. Prgm. Rep. TANF – Other The DHS Office of Policy Development (OPD) will perform risk assessments for all grantees annually. Anticipated Completion Date: 06/30/2025 The DHS Office of Income Maintenance (OIM) reestablished the completion of risk assessments in the fall of 2024 and has provisionally completed them for all subrecipients, including TANF – Other, for FY23-24. The risk assessments seek to test various financial controls of subrecipients based on their risk assessment scores and will also assist in ranking subrecipients across the risk continuum. Anticipated Completion Date: Completed Contact Names: Louie Marven, OPD, Exec. Policy Splst.; Sheldon Marcus, OIM, Dir., Div. of Mgmt. & Bgt.; Ron Seliga, OIM, Mgr., Fin. Planning; Judy Alfaro, OIM, Mgr., Financial Accountability; Laura Schlagnhaufer, OIM, Dir., Div. of Contr. Progs. & Sys. Social Services Block Grant (SSBG) OPD will provide all grantees receiving federal funding with a letter identifying federal award information and applicable requirements. OPD will provide this letter annually. Anticipated Completion Date: Completed Contact Name: Louie Marven, OPD, Exec. Policy Specialist DOH: DOH planned to develop and implement a robust subrecipient monitoring program which included establishing a new section within the Budget Office. The PA Legislature did not approve a budget with funding that could accommodate a new section. Alternatively, a consulting firm was engaged to perform a review of policies and procedures across the agency, including providing a gap analysis to determine compliance. A recommendation report is to be provided to DOH by March 31, 2025. DOH will initiate a comprehensive training plan for department staff based on the recommendation report. DOH will then develop training materials with an anticipated completion of June 30, 2025, with a goal to conduct training across the department by September 30, 2025. Anticipated Completion Date: 09/30/2025 Contact Name: Andrea Race, CFO PDA: PDA’s Bureau of Food Assistance (BFA) 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. PDA will also develop and implement a system to document the evaluation of each subrecipients risk of noncompliance. Anticipated Completion Date: 09/30/2025 Contact Name: Caryn Long Earl, Director, Bureau of Food Assistance PDOA: Concerning the evaluation of each Subrecipient’s Risk of Noncompliance, PDOA has developed a new monitoring component, consisting of fifteen measurable elements, to actively monitor compliance of the 52 Area Agencies on Aging (AAA) subrecipients through a revised Phase IX monitoring tool. The revised tool, used by three Fiscal Field Representatives, includes a review of Program and Procurement, Contract Monitoring, Record Retention and Environmental Modifications. • Timelines have been established to evaluate each subrecipients risk of noncompliance with Federal statutes, regulations and the terms and conditions of their subaward. - The Bureau of Finance coordinated with the Bureau of Quality Assurance to ensure schedules do not conflict and become burdensome to the AAA network. - The Fiscal Representatives plan to follow-up on any Performance Issues identified within the succeeding 6-9 months as identified in the approved Cost Allocation Plan. - Prior to the start of a new State Fiscal Year, the Risk Assessment surveys are distributed to adequately evaluate each subrecipient’s risk of noncompliance timely. • PDOA has drafted a AAA Fiscal Monitoring process map to formally document the monitoring process which highlights the requirement to disseminate Risk Assessments. • PDOA has been working with the AAAs to correct reporting in preparation of the next round of monitoring to ensure accuracy of Financial Reporting requirements and Line-Item Budgets on record. • To avoid future deficiencies in compliance, revised risk assessments have been developed to evaluate each subrecipient’s risk of noncompliance to proactively address any weaknesses in internal controls over Federal programs. • Despite PDOA recognizing time and insufficient staffing as a barrier to achieving the goal of performing a risk assessment for every AAA, we have surpassed our expectation of reaching half at a minimum by conducting a full assessment of all 52 for fiscal year ending June 30, 2024. • PDOA confirmed the Comprehensive Aging Performance Evaluation (CAPE) approach to evaluations of aging services provided by AAAs a success and shifted it out of pilot status which features a fiscal component. • To best review internal controls for financial issues concerning the Aging Cluster, a fiscal component will be administered since multiple Federal funding streams are involved. • This finding has aided in our approach to the subrecipient section of contract language as the Cooperative Block Grants are actively being developed. The proposed policy addresses Subrecipient requirements in the Admin Chapter as opposed to the appendix as a result. Anticipated Completion Date: 06/30/2025 Contact Name: Jennifer Cave, Fiscal Management Specialist, PDOA Audit Liaison DDAP: DDAP understands the need to develop policies to ensure all required federal award information is disseminated to all subrecipients at the time of the subaward. DDAP currently includes the following federal award information in its grant agreements to subrecipients: • Subaward Period of Performance Start and End Date • Total amount of Federal funds obligated to the subrecipient • Total amount of the Federal award committed to the subrecipient • Name of Federal awarding agency, pass-through entity, and contact information for awarding official of pass-through entity • Assistance Listings Number (ALN) and title However, not all the required information is available at the time the grant agreements are executed, such as the Federal Award Identification Number (FAIN) and the Federal award date. To ensure subrecipients are compliant with the Uniform Guidance in 2 CFR Section 200 and other applicable federal regulations, DDAP will develop policies to ensure notification is sent to all subrecipients that includes all required federal award information once the information has been received through the Notice of Award from the Substance Abuse and Mental Health Services Administration (SAMHSA). • First draft of P&P and proposed letter to subrecipients: Person responsible - Ellie Stache and Tia Roebuck: Anticipated completion date - 03/28/2025 • Review of first draft and letter by Bureau Director: Person responsible - Marie Plumer, Director, Bureau of Administration: Anticipated completion date - 04/11/2025 • Revision to first drafts: Person responsible - Ellie Stache: Anticipated completion date - 04/25/2025 • Review of second drafts by Executive staff: Person responsible - Kelly Primus, Deputy Secretary: Anticipated completion date - 05/09/2025 • Revisions to second drafts: Person responsible - Ellie Stache: Anticipated completion date - 05/23/2025 • Final review by Bureau Director and Executive staff: Person responsible - Marie Plumer and Kelly Primus: Anticipated completion date - 06/06/2025 • Submission to auditor: Person responsible - Tia Roebuck: Anticipated completion date - 06/30/2025 Anticipated Completion Date: 06/30/2025 Contact Names: Tia Roebuck, Director, Division of Budget and Procurement; Ellie Stache, Section Chief, Fiscal Planning and Contractual Operations L&I: Once L&I’s Bureau of Workforce Development Administration (BWDA) identified that the incorrect funding source was listed on the Notice of Obligation (NOO) associated with the TANF Youth Development Program contract, BWDA updated the list of funding sources in the Commonwealth Workforce Development System to encompass ALN 93.558. This update was implemented on February 20, 2025, and the updated NOOs were disseminated through CWDS. This change ensures that all NOOs created under ALN 93.558 now and in the future will have the correct funding source listed for the subrecipient. Anticipated Completion Date: Completed Contact Names: Brenda Duppstadt, Director; Gordon Zook, Division Chief

FINDING 2024-004 Finding Subject: Special Education Cluster (IDEA) - Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Dawn Mason, Business Manager, DeKalb Co. Eastern CSD Contact Phone Number and Email Address: 260-868-2125 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The expenditures referenced in the finding were expended from the American Rescue Plan Special Education grant funds which were fully expended during the audit period. All future expenditures triggering procurement and suspension and debarment requirements will include implementing the following procurement policies. Reference Procurement Standards 2 CFR 200.318 Districts may not enter into contracts with entities that have been suspended or debarred from participating in contracts with federal funds. For contracts over $25,000, districts must verify a contractor is not excluded or disqualified. Contractors must be verified in one of three ways: 1. Checking the System for Award Management (SAM) (www.SAM.gov) 2. Collecting a certificate from that contractor. 3. Adding a clause or condition to the covered transaction with that contractor. (Recommended) **Proper verification and documentation must be sent to the LEA for audit purposes. Methods of Procurement Where specific EDGAR/UG thresholds apply, Districts must meet baseline requirements for procurement. If State or local rules have more restrictive thresholds, the most restrictive rule must be followed. Informal Procurement Procedures 1. Micro-purchase (0-$50,000) Dekalb County Eastern CSD has self-certified micro-purchases for up to $50,000 Micro-purchases may be awarded without soliciting competitive quotes if the district considers the price to be reasonable. Quotes must be attached to the invoice/checks for proper documentation and retained by the LEA. 2. Small Purchase ($50,000 – $150,000) Three quotes are required prior to purchase unless the purchase comes from a “Sole Source” vendor. Small purchases are required to be ordered under a purchase order unless in an emergency. Additional quotes must be presented along with the purchase order prior to being approved by the LEA. Formal Procurement Procedures 1. Sealed Bids (above $150,000) Bids must be solicited from an adequate number of suppliers, providing them with sufficient response time prior to the opening of the bids. Proper advertisement and procedures must be followed per IC 5-22 and corresponding documentation must be presented to the LEA prior to any final approval or purchases being made. 2. Competitive Proposals (above $150,000) The Request for Proposal method is used for procurements in which factors other than cost play a significant role. Per IC 5-22-9, when a purchasing agent makes a written determination that the use of competitive sealed bidding is either not practicable or not advantageous to the governmental body, the purchasing agent may award a contract using this procedure instead of competitive sealed bidding. This provides a formal process for the procurement of goods and/or services for which price is not the sole factor in the selection of a vendor or vendors. Proper advertisement and procedures must be followed per IC 5-22 and corresponding documentation must be presented to the LEA prior to any final approval or purchases being made. Noncompetitive (Sole Source) All sole source procurements require adequate written justification and must be attached to the corresponding purchase order or payment. Anticipated Completion Date: All expenditures initiated after March 12, 2025

2024-002. Payroll (Improper Payments) United States Department of Education, Passed-through New York State Department of Education: Education Stabilization Funds COVID 19: American Rescue Plan – Elementary and Secondary School Emergency Relief ALN: 84.425U Condition: During the current year, the audit identified instances of duplicate salary payments being charged to Federal awards. These payments resulted in certain employees being charged to multiple grants for federal reimbursement. Our audit review revealed that payroll records including transactions where employees’ salaries were recorded more than once, leading to noncompliance with 2 CFR §200.1 regarding improper payments. Planned Corrective Action: The District acknowledges the findings and will implement stronger internal controls to ensure that salary payments are accurately recorded and reconciled to prevent duplicate submissions of reimbursement to the federal funding source. In addition, management is in the process of contacting the funding award agency to determine whether reimbursement for the improper payments charged to the grant is necessary. Responsible Contact Person: Jean Mingot Assistance Superintendent for Business Southampton Union Free School District 70 Leland Lane Southampton, New York 11968-5089 Anticipated Completion Date: June 30, 2025

Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance (Modified Opinion) Condition: The Kansas Division of Emergency Management (Management) did not report subawards to FSRS during SFY 2024 in compliance with FSRS reporting requirements. Recommendation: We recommend that Management continue to implement its corrective action plan from the prior year. Management should review and update its procedures and internal controls to ensure that subawards are accurate, reported timely and reviewed timely to FSRS. Views of responsible officials: There is no disagreement with the audit finding. Action taken in response to finding: Management will download awards every 2 weeks to ensure that the data is reviewed and entered timely. Name(s) of the contact person(s) responsible for corrective action: Jennifer Deal, Fiscal & Grants Management Section Chief Planned completion date for corrective action plan: Ongoing

Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Condition: The Kansas State Department of Health and Environment (Department) reported awards issued to contractors to FSRS when contractor agreements are not considered subawards and should not be reported. Recommendation: We recommend that the Department develop procedures and internal controls to ensure that required subawards are reported accurately to FSRS and that contractor agreements are not reported to FSRS as subawards. Views of responsible officials: Management agrees with the finding. Action taken in response to finding: Process has been updated so that only POs coded as Aid To Local (550100, 550600) will be submitted on FFATA reports. Name(s) of the contact person(s) responsible for corrective action: Shelley Russell, Lead Fiscal Analyst, Division of Public Health Planned completion date for corrective action plan: Immediately. New process will be used for any reports moving forward. Reports that have already been submitted will be reviewed and updated so that only ATL obligations are reflected on the reports.

Context: The School Corporation is a member of the Northeast Indiana Special Education Cooperative (Cooperative). During fiscal years 2022-2023 and 2023-2024, the Cooperative operated the special education program and spent the federal money on behalf of all its members. As the grant agreement was between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. Description of Corrective Action Plan: School Corporation will reach out to the Cooperative to discuss internal controls over procurement, and suspension and debarment and request annual listing of vendors exceeding federal and state procurement thresholds to ensure Cooperative adheres to regulations and established procurement policy and request that procurement policies are written, and all procurements are fully documented based upon the applicable federal and state standards Anticipated Completion Date: The School Corporation will implement the actions noted above quarterly to ensure proper internal controls are in place. The treasurer will request this information starting in April of 2025 for the first quarter of the calendar year.

Finding 2024-002 Finding Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Beverly Hindes Contact Phone Number: 219-996-4771 x128 Views of Responsible Officials: We agree with the finding. Description of Corrective Action Plan: The Treasurer will ensure compliance with the Procurement and Suspension and Debarment requirement. Anticipated Completion Date: March 3, 2025

FINDING 2024-002 Finding Subject: Child Nutrition Cluster - Procurement Contact Person Responsible for Corrective Action: Kyle Zahn & Jack Lazar Contact Phone Number and Email Address: (765) 883-5576 kzahn@western.k12.in.us jlazar@western.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: At a coming leadership meeting the Finance Director will review procurement rules and procedures with the leadership team. Additionally, the Director of Finance and Food Service Director will conduct an audit of the vendors used for the Child Nutrition Cluster and revise as necessary current systems for identifying vendors who exceed $50,000 during a school year. Anticipated Completion Date: March 31, 2025