Corrective Action Plans

Views of Responsible Offocials and Corrective Action Plan: Management agrees with the finding. Corrective Action Plan – Non-Public Proportionate Share Finding (FY 2024) • Revised Procedures o Internal procedures will be updated to plan, track, and ensure non-public proportionate share expenditures meet minimum requirements before grant funds are fully expended. • Monitoring and Verification o Fiscal staff will monitor non-public expenditures throughout the grant period and verify documentation demonstrates direct benefit to eligible non-public students. • Staff Training o Staff and Cooperative personnel will receive training on non-public proportionate share requirements and allowable expenditures. • Future Compliance Measures o Strategies will be implemented to prevent shortfalls in future grant periods, including early adjustments to spending plans to ensure full compliance. Responsible Party and Timeline for Completion: Corrective action plan has been implemented as this finding impacted fiscal year 2024 but did not recur in fiscal year 2025. The Director of Special Education, Cooperative School Services Bookkeeper, and Rensselaer Central Treasurer will oversee the corrective action plan to monitor the eligibility requirements on an ongoing basis.

Information on the federal program: Subject: Special Education Cluster (IDEA) –Earmarking Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 22611-047-PN01, 22611-047-ARP, 23611-047-PN01, 22619-047-PN01, 22619-047-ARP, 23619-047-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, and Earmarking Audit Finding: Significant Deficiency, Other Matters Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the earmarking portion of the Matching, Level of Effort, Earmarking compliance requirement. Context: The School Corporation did not meet the earmarking requirements for the grants, which concluded during the audit period. Both the Special Education Grants to States and Special Education Preschool Grants required a proportionate share of their funding to be spent on non-public school students with disabilities. The 22611-047-PN01, 22611-047-ARP, 23611-047-PN01, 22619-047-PN01, 22619-047-ARP, and 23619-047-PN01 grant awards were fully expended during the audit period with minimum Non-Public Proportionate Share earmarking requirements of $27,189, $5,074, $26,124, $1,171, $453, and $1,929, respectively. There were not sufficient non-public school expenditures incurred to meet the non-public proportionate share requirement for any of the six grants. The non-public school expenditures fell short of the minimum requirement by $11,679, $3,176, $16,405, $1,171, $4, and $1,929, respectively. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. The cooperative has developed a written procedure for documenting expenditures related to the proportionate share earmarking requirement at the School Corporation level to address this issue going forward. The School Corporation will maintain the proper documentation to support the Non-Public Proportionate Share earmarking requirement and validate the earmarking requirement is met at the end of the grant’s period of performance or once fully expended. Responsible Party and Timeline for Completion: The corrective action plan has been put into place for the 2025-26 school year. Tracy Albertson, Director of Finance, and Sarah Claton, Director of Cooperative School Services, will oversee the corrective action plan.

Program: AL 84.126 – Rehabilitation Services Vocational Rehabilitation Grants to States – Reporting Corrective Action Plan: An additional review will be completed by NDE Budget and Grant Management staff to ensure accuracy. Contact: Cathy Callaway Anticipated Completion Date: Completed

Finding Number: 2024-003 Planned Corrective Action: The District will closely review the Final Expenditure Report for all grants to ensure accuracy. Anticipated Completion Date: 6/30/26 Responsible Contact Person: Kaitlin Huck, Treasurer/CFO

Program: AL 84.126 – Rehabilitation Services Vocational Rehabilitation Grants to States – Period of Performance Corrective Action Plan: A validation will be added into the case management system (QE2) that prevents an obligation from being created in a federal fiscal year with a service start date in a previous federal fiscal year. Contact: Cathy Callaway Anticipated Completion Date: April 1, 2025

Program: AL 84.126 – Rehabilitation Services Vocational Rehabilitation Grants to States – Reporting Corrective Action Plan: Instructions for completing the RSA-17 report have been updated to ensure unliquidated obligations for indirect costs are correctly reported, and the correct payroll periods are included with the appropriate supporting documentation. Unliquidated obligations will not include contract amounts unless the contracts have been completed. As noted above, administrative costs will be reported using the sub ledgers/subsidiaries already set up in E1. Contact: Cathy Callaway Anticipated Completion Date: Done

Program: AL 84.048 – Career and Technical Education – Basic Grants to States – Allowability Corrective Action Plan: The Nebraska Department of Education’s Office of Career, Technical, and Adult Education will carry out the following actions to improve procedures to ensure that all payments are supported by adequate documentation: Provide ongoing technical assistance to subrecipients and NDE staff to ensure they are familiar with and fully informed on the documentation necessary to process reimbursement for all types of expenditures. Ensure all subrecipients have a stipend policy in writing. Conduct regular desk audits to ensure subrecipients are adhering to all applicable state and federal laws and regulations. Contact: Katie Graham, Sydney Kobza, Teri Sloup Anticipated Completion Date: June 2025

All Final Expenditure Reports will include the appropriate expenditure amounts associated with the grant year.

Finding Number: 2023-002 Planned Corrective Action: We are confident that our ESSER expenditures align with the allowable purposes and intents of the grant application that was submitted in the CCIP. We also stand by the integrity of our identification of expenses in total in the American Rescue Plan ESSER Federal Grant Program despite differences identified between grant years. The FER process and the reallocation of funds by grant year was confusing. However, as in the response above, we recognize the responsibility to adhere to the strict timelines was our responsibility. All ESSER funds have now been expended and we are confident they are allowable expenses per the guidelines provided. The Treasurer, Superintendent, and Federal Funds Coordinator agree to work more collaboratively to ensure our expenditures are within the grant timeframes prior to FER submissions. Anticipated Completion Date: 03/08/2024 Responsible Contact Person: Lance A. Erlwein, Treasurer

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

FINDING 2023-002 Information on the federal program: Subject: Special Education Cluster (IDEA) –Earmarking Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 20611-047-PN01, 21611-047-PN01, 20619-047-PN01, 21619-047-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, and Earmarking Audit Finding: Material Weakness, Other Matters Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the earmarking portion of the Matching, Level of Effort, Earmarking compliance requirement. Context: The School Corporation did not meet the earmarking requirements for the grants, which concluded during the audit period. Both the Special Education Grants to States and Special Education Preschool Grants required a proportionate share of their funding to be spent on non-public school students with disabilities. The 20611-047-PN01, 20619-047-PN01, 21611-047-PN01, 21619-047-PN01 grant awards were fully expended during the audit period with minimum Non-Public Proportionate Share earmarking requirements of $24,977, $1,171, $22,088, and $866, respectively. There was no supporting documentation provided to support any non-public school expenditures were incurred towards the meeting the non-public proportionate share requirement. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding. The Cooperative has developed a written procedure for documenting expenditures related to the proportionate share earmarking requirement at the School Corporation level to address this issue going forward. The School Corporation will maintain the proper documentation to support the Non-Public Proportional Share earmarking requirement and validate the earmarking requirement is met at the end of the grant’s period of performance or once fully expended. Responsible party and timeline for completion: The correction action plan has been put into place for the 2023-24 school year. Tracy Albertson, Director of Finance and Sarah Claton, Director of Cooperative School Services, will oversee the corrective action plan.

Program: AL 84.287 – Twenty-First Century Community Learning Centers – Subrecipient Monitoring Corrective Action Plan: The NDE was provided written guidance from the U.S. Department of Education (USED) regarding source documentation required for the NDE’s review of preliminary documentation required to make payment whereas this effort is not associated with the NDE’s Grant Compliance Section performing the fiscal monitoring activities applying the required pass-through activities contained within 2 CFR 200.332. To make payment, the USED guidance states, “Uniform Guidance does not require the NDE to obtain specific source documentation from its subrecipient prior to making payments and the NDE’s Grant Guidance states that for certain reimbursement requests, such as credit card purchases, travel expenses, and personal reimbursements, subrecipient are always required to submit supporting documentation. For other expenditures, including personnel costs, and time and effort certification, supporting documents need to be retained by the subrecipient for at least three years and must be available for auditing and monitoring purposes”. For the reimbursement request tested to make payment, additional source documentation was acquired from the subrecipient upon the APA’s request and submitted for review on March 1, 2024. Contact: Jen Utemark, Administrator, Office of Budget & Grants Management Anticipated Completion Date: March 1, 2024

Program: Various, including AL 84.027 – Special Education Grants to States; AL 84.173 – COVID-19 Special Education Preschool Grants; AL 84.425D – COVID-19 Education Stabilization Fund – Elementary and Secondary School Emergency Relief Fund (ESSER I and ESSER II); AL 84.425U – COVID-19 Education Stabilization Fund – American Rescue Plan – Elementary and Secondary School Emergency Relief Fund (ARP ESSER) – Subrecipient Monitoring Corrective Action Plan: First SPED subrecipient – As education subrecipients have had a significant influx of subawards to mitigate post-COVID supports for Nebraska education with limited staff capacity, the Department has remained mindful of these conditions and is on schedule to complete its annual fiscal monitoring efforts within the normal timelines afforded each year. Second SPED subrecipient – Because the UNL utilizes PVS as allowed by 2 CFR 200.430 in regard to salary and wage benefit costs for employees working on a project under a contractual grant agreement, the NDE going forward will require PVS supporting documentation be submitted as a minimum semi-annually for each contract to verify the salary and benefit costs being requested for reimbursement as recommended by the U.S. Department of Education beginning with any payments occurring after March 1, 2023. Third SPED subrecipient – The documentation to support the review of purchased services and supplies during fiscal monitoring was provided to the APA on March 4, 2024. Single Audits – The Director of Grants Management and Director of Grants Compliance will work collaboratively to ensure all subrecipient audits are reviewed and applicable management decision letters are issued within the requested timeframe. Contact: Jen Utemark, Administrator, Office of Budget & Grants Management Anticipated Completion Date: July 1, 2024

Finding 2023-003 Information on the federal program: Subject: Special Education Cluster (IDEA) –Earmarking Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 20611-047-PN01, 21611-047-PN01, 20619-047-PN01, 21619-047-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, and Earmarking Audit Finding: Material Weakness, Other Matters Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the earmarking portion of the Matching, Level of Effort, Earmarking compliance requirement. Context: The School Corporation did not meet the earmarking requirements for the grants, which concluded during the audit period. Both the Special Education Grants to States and Special Education Preschool Grants required a proportionate share of their funding to be spent on non-public school students with disabilities. The 20611-047-PN01, 20619-047-PN01, 21611-047-PN01, 21619-047-PN01 grant awards were fully expended during the audit period with minimum Non-Public Proportionate Share earmarking requirements of $19,551, $2,421, $26,253, and $1,959, respectively. There was no supporting documentation provided to support any non-public school expenditures were incurred towards the meeting the non-public proportionate share requirement. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. The Cooperative Schools Service has developed a written procedure of documenting expenditures related to the proportionated share earmarking requirement and validate the earmarking requirement to met at the end of the grant’s period of performance or once fully expended. Responsible Party and Timeline for Completion: The correction action plan has been put into place for the 2023-24 school year. Treasurer, Dawn Claussen and Director of Cooperative School Services, Sarah Claton, will oversee the corrective action plan.

FINDING 2022-008 Contact Person Responsible for Corrective Action: Casey Brewster Contact Phone Number: 812-752-8935 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Quarterly reviews of parental involvement will be included in the quarterly grant reviews with the Director of Grants/Programs and the CFO. The Director will also be in engaged in IDOE provided trainings such as TitleCon, and understands the parental involvement requirements needing to be met and will monitor accordingly. In addition, the monthly reports of all revenue and expenditures shall include tracking of specific spending requirements, such as parental involvement spending. Finally, the comprehensive checklist that will be implemented will include the earmarking requirements and status. Anticipated Completion Date: May 2023

FINDING 2022-006 Contact Person Responsible for Corrective Action: Casey Brewster Contact Phone Number: 812-752-8935 Views of Responsible Official: We concur with the finding. INDIANA STATE BOARD OF ACCOUNTS 67 Description of Corrective Action Plan: Additional training related to grant budgets entered into and monitored within the financial software will occur, as will the new practice of having the program directors initiating monthly reimbursement requests informed by the accurate reports from the software (ledger), with documented review by the Treasurer or CFO. Additional training over the reporting requirements is taking place with the Treasurer, CFO and Directors overseeing federal funds provide accurate reporting. Anticipated Completion Date: June 2023

FINDING 2022-011 Contact Person Responsible for Corrective Action: Casey Brewster Contact Phone Number: 812-752-8935 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Additional training related to grant budgets entered into and monitored within the financial software will occur, as will the new practice of having the program directors initiating monthly reimbursement requests informed by the accurate reports from the software (ledger), with documented review by the Treasurer or CFO. Additional training over the reporting requirements is taking place with the Treasurer, CFO and Directors overseeing federal funds provide accurate reporting. Anticipated Completion Date: June 2023

Program: AL 84.010 ? Title I Grants to Local Educational Agencies ? Allowability and Subrecipient Monitoring Corrective Action Plan: The Department will contact the two subrecipients noted to provide one-on-one technical assistance and will also provide additional technical assistance regarding proper time and effort documentation to all subrecipients. Additionally, time and effort guidance is available to all subrecipients on the Department?s website, will be discussed at upcoming subrecipient training opportunities and supported by a dedicated Grants Management Training Specialist. The Department will ensure the identified written deficiencies noted in the subrecipient fiscal monitoring exit letter clearly identifies a finding vs. technical assistance needed; whereas a finding is supported by follow-up in accordance with federal UGG regulations and technical assistance provides knowledge of the Department?s training and resources available. Contact: Jen Utemark, Budget and Grants Management Anticipated Completion Date: December 31, 2023

FINDING 2022-007 (Auditor Assigned Reference Number) Contact Person Responsible for Corrective Action: Todd VanDerWeele Contact Phone Number: 574.223.2159 Views of Responsible Official: We concur with the finding. 1. The Curriculum Director will create a control at the beginning of the school year so that we can properly ensure all parties receive test security training. This will be a google document, separated by tabs at the bottom for each building, with the names of all staff members. The control will also contain columns that can be check marked when test security forms and training is completed. The control will also contain a box to show the date training was completed. 2. We will have this document for training on test security in each building in August and September. Each staff member will sign the document to show they received the training. 3. The Curriculum Director will create an agenda for each training to properly ensure all staff members are trained. 4. All staff members will also be required to sign the test security form provided by the IDOE at their respective training. 5. For all staff members who miss training at their building, a Google Form will be provided with all of the test security information. Staff members will be required to fill out the form and watch the training video. The form will be time and date stamped. 6. The Curriculum Director will update the control at least once a week until all staff members are trained. Anticipated Completion Date: February 2024

FINDING 2022-012 Contact Person Responsible for Corrective Action: Tricia Malone Hudson, District Curriculum Specialist Contact Phone Number: 812-279-3521 Views of Responsible Official: We concur with the audit finding. Description of Corrective Action Plan: The district will scan and save all testing security agreements for all staff. The test coordinator will be responsible for ensuring that all relative staff complete training and sign testing agreements. Anticipated Completion Date: North Lawrence Community Schools implemented this procedure beginning in September 2022.

FINDING 2022-007 Contact Person Responsible for Corrective Action: Melissa Hinds, Director of Special Education Contact Phone Number: 812-279-3521 Views of Responsible Official: We concur with the audit finding. Description of Corrective Action Plan: As it relates to cash management for the Special Education Cluster (IDEA), the District?s Treasurer and Special Education Director will review all cash balances quarterly to verify compliance with the grant agreement. As of July 2022, internal controls were put into place to ensure supporting documentation was attached to all reimbursements. Anticipated Completion Date: March 2023

The University is currently following and believes it is in compliance with the cash management regulations as written in 2 CFR Part 200.305(b) which require the organization to minimize the time lapse between request for reimbursement from sponsoring agencies and vendor payment. We understand that variations remain in the interpretation of the cash management compliance requirement. For example, on October 20, 2017, the Council On Governmental Relations (COGR) wrote a letter to the Office of Financial Management expressing concern that the cash management requirement language in the 2017 Compliance Supplement was not aligned with the requirements for cash management as currently written in 2 CFR Part 200.305(b). COGR?s position is that the Compliance Supplement should be revised to conform with the cash management requirements as written in 2 CFR 200.305(b). The University agrees with COGR?s position and believes the language in the Compliance supplement leads to an unrealistic and unreasonable administrative burden for universities and possibly a reconfiguration of smoothly running electronic process or a complete replacement of electronic processes with an inefficient, manual one in efforts to ensure each vendor has been paid prior to requesting reimbursement from the sponsoring agency. The University will continue to monitor the OMB interpretation of the Cash Management requirements. For FY22, we note that the overall number of exceptions has decreased. Furthermore, the payments identified as exceptions in the FY22 audit were almost all made to vendors within our institutional standard terms of net 45 days, with the exception of 1 which was made 51 days after the request for reimbursement. The Office of Research Services remains committed to ensuring that the federal government is not unfairly disadvantaged by our processes. To that end, during the fall of 2022, the University implemented certain enhancements to further minimize the time lapse between request for reimbursement from sponsoring agencies and vendor payment. A custom process was implemented in the University?s financial system to update payment terms to `immediate? for vendor invoices on Line of Credit sponsored awards. In addition, the University added a new metric to the reporting dashboard for its Procure-to-Pay system to specifically highlight Purchase Order invoices for sponsored awards which were on hold, to assist the university business and grant managers in prioritizing the resolution of those holds preventing 2 invoices on sponsored awards from being paid immediately. We expect to see the impact of these enhancements in the FY23 audit.

FINDING 2022-006 Contact Person Responsible for Corrective Action: Dan Durrwachter Contact Phone Number: 765-473-3081 Views of Responsible Official: We agree with these findings. Description of Corrective Action Plan: Corporation Test Coordinator will train the site test coordinators. The STCs will then train staff and have staff sign they have been trained. The STC will then give all signed agreements to the CTC who will then check with all signed agreement to all employees who work in the testing schools. Anticipated Completion Date: 6/01/2023

FINDING 2022-007 Contact Person Responsible for Corrective Action: Whitney Dixon, Treasurer Contact Phone Number: 574-533-8631 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Requests for Reimbursements including supporting documentation, including financial and programmatic records, will be retained for a period no less than three years from the date of submission of the final expenditure report. Reimbursement Requests will be accompanied by supporting documentation to ensure expenditures are from the correct fund. Anticipated Completion Date: May 2023

FINDING 2022-006 Contact Person Responsible for Corrective Action: Whitney Dixon, Treasurer Contact Phone Number: 574-533-8631 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Coordinated Early Intervening Services (CEIS): This finding is no longer applicable. If GCS is identified with significant disproportionality and CEIS does apply, in the future, GCS will ensure that exactly 15% of our total 611 and 619 allocation on CEIS expenses. Documentation to support expenses and submitted monitoring reports will be retained by the business office. Non-Public Proportionate Share: Supporting documentation will be provided at the time of submission of any reports. Documentation will be retained by the business office. All expenditures will be reviewed and monitored by the business office to ensure that GCS will spend the required amount. All budgeted earmarked line items for items such as non-public schools will be entered into the financial software as individual line items in order to properly expense and reimburse earmarked funds. Anticipated Completion Date: May 2023