Corrective Action Plans

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

FINDING 2024‐005 Finding Subject: Special education Cluster (IDEA) ‐ Procurement and Suspension and Debarment Summary of Finding: When the value of the procurement for property or services are within the small purchase threshold, or a lower threshold established by a nonfederal entity, quotes and a contract are required. The small purchase threshold is between $10,000 and $150,000 however the threshold between $10,000 and $50,000 require quotes from an adequate number of qualified sources. Indiana Code 5‐22‐8 has more restrictive requirements for the small purchase threshold between $50,000 and $150,000, which require three quotes and a contract to be awarded. The Cooperative had five vendors which fell within the small purchase threshold and all five vendors were tested. The Cooperative did not obtain quotes or competitive proposals, nor was a circumstance met that would have allowed for a noncompetitive procurement for the purchases. Three vendors paid from the grant funds were identified as being covered transactions during the audit period. All three vendors, provided goods or services which equaled or exceeded $25,000 and were selected for testing. For all three vendors, the Cooperative did not verify the vendors’ suspension and debarment status prior to payment. Contact Person Responsible for Corrective Action: Tim Scott Contact Phone Number and Email Address: 574‐654‐7273 tscott@npusc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Due to several changes in personnel in the Special Education office, obtaining quotes and checking SAMS.gov was an oversight. The Special Ed Administrative Assistant and/or the Special Ed Director is now making sure these things are complete before a purchase order is entered or services are rendered. A copy of SAMS.gov and the quote are attached to the purchase order. Anticipated Completion Date: October 2024

FINDING 2024-003 Finding Subject: Child Nutrition Cluster – Procurement and Suspension and Debarment Summary of Finding: Documented evidence of the implementation of the control process was not maintained. Due to the lack of controls, it could not be determined that the school corporation ensured compliance with the grant agreement. Proper safeguards were not in place to ensure that documentation was properly maintained, causing the CFO and Food Service Director to be unable to locate the documentation for each procurement method. Contact Person Responsible for Corrective Action: Allison Pund and Margaret Leavitt Contact Phone Number and Email Address: 812-683-3971 x5002; punda1@swdubois.k12.in.us; leavittm@swdubois.k12.in.us Views of Responsible Officials: We concur with the finding. Explanation and Reasons for Disagreement: NA Description of Corrective Action Plan: The School Corporation will establish a proper system of internal control and develop policies and procedures to ensure all requirements are followed. Creation of these policies and procedures will be created by the CFO and Food Service Director. Internal controls will be put in place to ensure these policies and procedures are followed. In addition, the Food Service Director will maintain all bids, contracts, and other documentation to support the procurement methods used and will verify suspension and debarment prior to entering into covered transactions of $25,000 or more. Anticipated Completion Date: August 2025

FINDING 2024‐002 Subject: Special Education Cluster (IDEA) – Procurement Summary of Finding: During the 2023-2024 fiscal year, federal grant funds were to pay for contracted speech services. The vendors used exceeded the Simplified Acquisition Threshold and sealed bids or competitive proposals were not obtained. Contact Person Responsible for Corrective Action: Adam C. Minth Contact Phone Number: 219-374-3504 Views of Responsible Official: The school corporation concurs with the finding and will be implementing corrective procedures by the end of this fiscal year. Description of Corrective Action Plan: As a member of the Northwest Indiana Special Education Cooperative (NISEC), Hanover Community School Corporation 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, Hanover was notified that we didn’t follow the procurement procedures when expending out of the federal grant. This finding was due to Hanover not going out and receiving multiple bids for contracted companies that provide services to our students. Hanover 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. 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. Anticipated Completion Date: 4/30/2025

FINDING 2024-004 Finding Subject: Special Education Cluster (IDEA) – Procurement and Suspension and Debarment Summary of Finding: Procurement- Small Purchase In fiscal year 2023, the Cooperative had five vendors which fell within the small purchase threshold (between $10,000 and $150,000). The Cooperative did not obtain quotes or competitive proposals, nor was a circumstance met that would have allowed for a noncompetitive procurement for the purchases. The total amount spent in was $292,806. Suspension and Debarment Verification to verify that contractors and subrecipients are not suspended, debarred, or otherwise under a nonprocurement transaction through SAM was not being completed. Three vendors each fiscal year provided goods or services which equaled or exceeded $25,000 were selected for testing. The total amount spent on covered transactions was $266,063 and $142,639 for fiscal years 2023 and 2024. For all six vendors, the Cooperative did not verify the vendors’ suspension and debarment status prior to payment. Contact Person Responsible for Corrective Action: Greg Hunt Contact Phone Number: (219) 362-7056 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Our Special Education Administrative Assistant has already begun checking on SAM for any federal purchases to verify suspension and debarment. She has also been provided with the LaPorte Community School Corporation’s Procurement Policy number po6325 and will adhere to those guidelines for any future purchases. Anticipated Completion Date: January 2025

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. Contact Person Responsible for Corrective Action: Brittany Treesh Contact Phone Number: 260-357-3185 Views of Responsible Official: The school corporation concurs with the finding. Description of Corrective Action Plan: Garrett-Keyser-Butler’s Business Manager will work closely with the Special Education Cooperative Treasurer and DeKalb Eastern Business Manager during the grant process and make sure all required documents are collected. Anticipated Completion Date: The Business Manager will implement this procedure March 2025.

FINDING 2024-002 Finding Subject: Child Nutrition - Procurement, Suspension, and Debarment Summary of Finding: There were no controls in place to ensure that the School Corporation complied with the small purchase requirements. The School Corporation obtained quotes for the two vendors that qualified for the small purchase threshold, but no oversight performed. There were no controls in place to ensure that the vendors included a suspension and debarment clause or check the Sam.gov website. Contact Person Responsible for Corrective Action: Micah Williams Contact Phone Number and Email Address: 765-832-2426/mwilliams@svcs.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The finance department will work in conjunction with the Food Services Director to ensure that quotes are obtained from vendors that are listed on Sam.gov or have a suspension and debarment clause before making in purchases. There will be an email thread detailing the request, the quotes, and the process for ensuring suspension and debarment. Anticipated Completion Date: Immediate.

MANAGEMENT’S CORRECTIVE ACTION PLAN 2 CFR § 200.511(c) June 30, 2024 Finding Number: 2024-001 – Internal Control over Compliance and Compliance with Period of Performance Planned Corrective Action: The errors identified took place during September 2023, during a period when the financial management of Council’s grants, including subrecipient monitoring and allowable cost review, were under the purview of the program teams. In May 2024, these responsibilities were deemed to be more appropriately aligned with the Finance and Business Operations Team’s skill sets and brought under that team’s management. Additionally, in December 2023, the accounts payable process was automated, enabling a more thorough review of each reimbursement package. Anticipated Completion Date: May 6, 2024 Responsible Contact Person: Stan Harrell, Chief Financial Officer

The district will establish a system of internal controls with the Cooperative (NISEC) to ensure formal procurement methods are properly followed.

New York State Education Department will update the payment processing procedures and provide training to staff involved in preparing or processing payment forms to understand the appropriate application of cost centers to align with the Period of Performance for Federal awards, including the VR grant. Additional controls will be explored to ensure that the accounting details on the payment form are accurate and entered correctly into the Statewide Financial System.