Corrective Action Plans

The City will implement additional control procedures to ensure all reports are filed in a timely manner.

Subject: 2025 Single Audit Finding 2025-004 2025-004 Management Response: Management acknowledges the finding. DEMRS did not submit the required quarterly financial and performance reports to the Illinois Emergency Management Agency (IEMA) for the Homeland Security Grant Program during the fiscal year. Root Cause Analysis: Over multiple years, DEMRS experienced significant turnover in key finance and grant management positions, which created gaps in continuity and delayed the department's transition to IEMA's Amplifund reporting system. As prior management departed and new staff were onboarded, the department faced operational challenges that affected the consistency of its grant reporting processes. Due to Amplifund's requirement that reimbursement requests be submitted sequentially before performance reports can be filed, the delays in prior period submissions prevented DEMRS from accessing and submitting the quarterly reports. Statewide pauses in FEMA and IEMA grant processing further contributed to the backlog. Corrective Action: DEMRS will complete and submit all outstanding reimbursement requests and performance reports for UASI 2022, UASI 2023, and UASI 2024 to bring the County into full compliance with grantor requirements. Preventive Action: DEMRS will implement a grants compliance calendar that tracks all reporting deadlines. Future reports will be prepared by the Manager of Grants & Contracts and reviewed and approved by the Associate Director of Finance, with documented evidence of review. Responsible Party: Damian Albert, Associate Director of Finance, damian.albert@cookcountyil.gov. 312.603.8177 Tina Bhaga, Manager, Grants & Contracts, tina.bhaga@cookcountyil.gov, 312.603.8543 Planned Completion Date: January 1, 2027

The City will create a federal cash management policy. A review of cash will be done monthly.

Contact Person Patricia Heraty, Accountant Corrective Action Plan Management plans to review its internal control procedures to ensure a quality control review is performed to verify all required documentation and calculations are maintained in the tenant files. Planned Completion Date for CAP Immediately.

Finding Number: 2025-001 Planned Corrective Action: City of Norton will comply with all federal grant compliance requirements – including reporting requirements and deadlines. Anticipated Completion Date: June 2026 Responsible Contact Person: Pamela Keener, Finance Director

FINDING 2025-003 Finding Subject: Contact Person Responsible for Corrective Action: Tracey Haas, Business Manager Contact Phone Number and Email Address: 219-873-2000 x 8346 thaas@mcas.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We will implement a system of internal controls to ensure that the Form 9 and all underlying expenditures are properly documented. Anticipated Completion Date: We anticipate that this correction will be in place by July 2027

FINDING 2025-002 Finding Subject: Contact Person Responsible for Corrective Action: Tracey Haas, Business Manager Contact Phone Number and Email Address: 219-873-2000 x 8346 thaas@mcas.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We will implement a system of internal controls to ensure that the Form 9 and all underlying expenditures are properly documented. Anticipated Completion Date: We anticipate that this correction will be in place by July 2027

FINDING 2025-003 Finding Subject: Special Education Cluster (IDEA) - Earmarking Contact Person Responsible for Corrective Action: Ann Higgins and Dr. Amy K. Sivley Contact Phone Number and Email Address: 2 260-563-8871, higginsa@msdwc.k12.in.us; 60-563- 2151, sivleya@apaches.k12.in.us Views of Responsible Officials: We concur with the finding. Explanation and Reasons for Disagreement: n/a Description of Corrective Action Plan: The following procedure has been put into practice effective March 1, 2024: 1. A proportionate Share Working Spreadsheet was developed and is distributed annually to service providers working with non-pub students. 2. Service providers document the following information for each corporation: Student name, Date of service, Time of Service, Number of hours, Type of Service, and any other required information. 3. Documentation is reviewed monthly. 4. Reimbursement for non-pub services is requested when reimbursement amounts reach $1,000.00 or annually, whichever comes first. Superintendent/CFO will attend monthly co-op meeting and request documentation that corrective action plan is being followed. Anticipated Completion Date: Upon approval, this corrective action plan item is completed.

FINDING 2025-007 Finding Subject: Special Education Cluster (IDEA) – Earmarking and Level of Effort Summary of Finding: An effective internal control system was not designed or implemented at the School Corporation to ensure compliance with requirements related to the grant agreement and the Matching, Level of Effort, Earmarking and the Reporting compliance requirement. Contact Person Responsible for Corrective Action: Kim Holmquist Contact Phone Number and Email Address: 219-924-4250 kholmquist@griffith.k12.in.us View of Responsible Officials: We concur with this finding. Description of Corrective Action Plan: Griffith Public Schools will be developing, implementing, and documenting, a system of internal controls, including policies and procedures that provide segregation of duties to ensure appropriate reviews, approvals and oversight are taking place. A grant consultant has been contracted to assist in managing grants. Anticipated Completion Date: June 30, 2026

FINDING 2025-004 Finding Subject: Special Education Cluster (IDEA) - Earmarking Contact Person Responsible for Corrective Action: Andrea Miller Contact Phone Number and Email Address: 765-564-2100 ext 1002, millera@delphi.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The School Corporation has joined the Clinton County Joint Services. The Director will provide the numbers for the proportionate share, and retain the documentation. The Corporation Treasurer will establish specific codes to track nonpublic proportionate share expenses, to ensure expenditures are clearly identifiable and readily reportable. Anticipated Completion Date: September 2026, we do not currently have any proportionate shares, but will with the next grant cycle.

FINDING 2025-003 Finding Subject: Special Education Cluster (IDEA) - Earmarking Contact Person Responsible for Corrective Action: Beth Quinn Contact Phone Number and Email Address: 260-728-3306 quinnb@nadams.k12.in.us Contact Person Responsible for Corrective Action: Abi West, Director of Special Education Contact Phone Number and Email Address: 260-824-5880 awest@awssc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Cooperative maintains a tracking spreadsheet to monitor hours worked by staff providing services to non-public students. Staff member will record K-12 and preschool hours separately on their Time and Effort Log. The Cooperative will then document these hours, distinguishing between Part B funds and Preschool funds. For kindergarten-aged students, the Speech-Language Pathologist will collaborate with the Student Record Administrative Assistant to identify students eligible under Section 5a (619 funding). Specifically, these are kindergarten students who are not yet six years old as of December 1. Such students are funded through both the 611 and 619 grants. Time and effort for preschool students, including 5a students, will be prioritized to the 619 grant until its allocated funds are fully expended. Once the 619 funds are exhausted, effort will be shifted to the 611 grant accordingly. Proportionate share reports will be based on actual expenditures within the six-month period, as reflected in our tracking spreadsheet. This process will be corrected for FY 2023 (611 and 610) and FY 2024 (611 and 910) to ensure compliance and prevent recurrence of similar findings in the next audit cycle. Anticipated Completion Date: September 1, 2025

Provider/Employee will submit payroll records/invoices by student services monthly/bi-monthly to the bookkeeper. Once payroll records or invoices are received, the CFO will prepare a spreadsheet that calculates the time/amounts serviced by the non-public school and member school. Once the total hours are calculated, a percentage based on total hours worked for each member school will be used to allocate the provider/employee time for each member school. This documentation will be attached to each reimbursement request.

FINDING 2025-003 Finding Subject: Title I, Part A - Special Tests and Provisions - Assessment System Security Contact Person Responsible for Corrective Action: Alexis Grossman Contact Phone Number and Email Address: agrossman@lakelandlakers.net Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Training for test security is completed electronically. The staff members then sign a paper form stating the training is complete. The form is now scanned and stored both electronically and physically. Anticipated Completion Date: Already completed.

PDA: PDA is creating mechanisms to fulfill the requirements for pass-through entities within 4 to 6 months after FAC acceptance date of the audit, which include: 1. Evaluation of single audit report submissions received from BAFM to determine program purpose acceptability by verifying, at a minimum, that all agency-funded programs are properly included on the applicable financial schedules; that findings affecting the agency contain sufficient information to facilitate a management decision; and that the subrecipient has submitted an adequate corrective action plan. 2. Issuance of management decisions relative to audit findings and crosscutting findings assigned to the agency for resolution, as required by 2 CFR §200.521. 3. To impose or coordinate the imposition of remedial action in accordance with 2 CFR Part 200.339 and Management Directive 325.08 Amended, Remedies for Recipient Noncompliance with Audit Requirements, when subrecipients fail to comply with the provisions of Subpart F. PDA has developed a SEFA reconciliation process that will ensure that the SEFA is accurate, allowing for major programs to be properly identified and subjected to audit. PDA is developing a procedure for all programs to follow for any entity that is in non-compliance with the audit requirements and is failing to comply with the provisions of Subpart F. Anticipated Completion Date: 06/30/2026 Contact Name: Nichole Nedinsky, Fiscal Management Specialist, PDA Audit Coordinator PDOA: 1. Strengthen written policies and procedures governing subrecipient monitoring and audit resolution. 2. Update the audit tracker to proactively ensure the six-month management decision due date is met. 3. Implement segregation of duties between reconciliation review and management decision issuance. 4. PDOA will develop and utilize a standardized SEFA Review Checklist. 5. Conduct annual Uniform Guidance training for fiscal staff. Anticipated Completion Date: 06/30/2026 Contact Names: Jason Kavulich, Secretary of Aging; Jennifer Beck, Fiscal Management Specialist & PDOA Audit Liaison PDE: Implemented 2/17/26: Audit Coordinator verifies finding status of all single audit packages uploaded to the PDE single audit SharePoint site. Implemented 7/1/25: PDE audit section has begun to enforce timely audit submission by using remedial action within its authority as granted by federal guidelines. Implemented 7/1/25: PDE has expanded the resources available through the use of the compliance office for audit finding review and resolution in an effort to resolve all audit findings timely. Anticipated Completion Date: Completed Contact Name: Clayton P. Carroll, II, Audit Coordinator PENNVEST: PENNVEST will maintain a comprehensive tracking list that contains all equivalency projects that have disbursed any funds during the audit period. All those projects will be reviewed and reconciled to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward, including the timely submission of the single audit to the FAC. Once received, PENNVEST will reconcile the SEFA to ensure the information is accurate. PENNVEST will complete the reconciliation within six months of the FAC’s acceptance of the audit report and respond to the subrecipient with any adverse findings. Anticipated Completion Date: Completed Contact Names: Steven Anspach, Dep. Exec. Dir.; Heather Brookmyer, Loan Service Officer; Robert Boos, Exec. Dir.

FINDING 2025-004 Finding Subject: Special Education - Earmarking Contact Person Responsible for Corrective Action: Phyllis Ritenour Contact Phone Number and Email Address: 317-205-3332 x 77218 pritenour@msdwt.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Business Services will work with the Special Education team and IDOE to ensure that waivers are filed in a timely manner for any proportionate share funding not spent by nonpublic schools. Anticipated Completion Date: June 30, 2026 INDIANA STATE

FINDING 2025-002 Finding Subject: Special Education Cluster (IDEA)- Earmarking Summary of Finding: The School Corporation is a member of the Greater Lafayette Area Special Services Cooperative (Cooperative). During fiscal years 2023-2024, the Cooperative operated the special education programs and spent the federal money on behalf of all of its members. As the grant agreements were between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. However, there was inadequate oversight performed by the School Corporation in order to ensure compliance with the Matching, Level of Effort, Earmarking compliance requirement. The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the earmarking requirements. The Cooperative did not have adequate procedures in place to ensure that the required level of expenditures for nonpublic school students with disabilities was met for each member school. The Cooperative did not have effective internal controls to ensure nonpublic school expenditures were appropriately identified and reported. The Non-Public Proportionate Share expenditures for the 22611-021-PN01, 22611-021-ARP, 22619-021- ARP, 23611-021-PN01, and 23619-021-PN01 grant awards could not be verified for the individual member schools. Total grant expenditures were posted as expended. The nonpublic proportionate share expenditures were determined by applying a percentage to the nonpublic school budgeted expenditures. As such, we were unable to identify if the minimum amount per the grant awards was expended and properly reported to the IDOE as required. The lack of internal controls and noncompliance were isolated to the 22611-021-PN01, 22611-021-ARP, 22619-021-ARP, 23611-021-PN01, and 23619-021-PN01 grant awards. Contact Person(s) Responsible for Corrective Action/Contact Phone Number and Email Address: Lissa Stranahan Michelle Cronk Phone: 765-771-6013 Phone: 765-746-1602 Email: lstranahan@lsc.k12.in.us Email: cronkm@wl.k12.in.us View of Responsible Officials: West Lafayette Community School Corporation concurs with the audit finding for Earmarking. The GLASS Cooperative did not have adequate procedures in place to ensure that the required level of expenditures for non-public school students with disabilities was met for each member school. The Cooperative did not have effective internal controls to ensure non-public school expenditures were appropriately identified and reported. The methodology used by the Cooperative to monitor non-public proportionate share expenditures was based upon a percentage for each school corporation that comprises the Cooperative rather than basing the expenditures off of the grant award for each non-public school within the geographical boundaries of the school corporations. While all proportionate share funds were expended, it was problematic in determining if the minimum amount per the grant awards was expended and properly reported prior to July 1, 2024. Description of Corrective Action Plan: The former Director of GLASS retired June 30, 2023. Upon hire on July 1, 2023, the new director immediately implemented measures to correct the previous methodology used at GLASS. Non-public proportionate share funds are identified and reported based upon the grant award for each school corporation. The expenditures are based upon the geographical location of the non-public school and the corresponding public school corporation, not based upon the “home” school corporation of the student. This process was implemented and descriptions were included on the ledgers to identify non-public school proportionate share for grants that were initiated during the FY 2024-2025 school year. Anticipated Completion Date: The corrective action was already put into place on July 1, 2023 and implemented with FY 2024-2025. The audit finding reflects the previous grant cycle for 2022 grants and 2023 grants, which is prior to this action taken.

FINDING 2025-001 Finding Subject: Summary of Finding: Earmarking for Non-Public proportionate share was improperly calculated based on budgeted percentage. Contact Person Responsible for Corrective Action: Quinnlyn Van Rys Contact Phone Number and Email Address: (219) 850-1914 - qvanrys@pces.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Provider/Employee will submit payroll records/invoices by student services monthly/bi-monthly to the bookkeeper. Once payroll records or invoices are received, the CFO will prepare a spreadsheet that calculates the time/amounts serviced by the non-public school and member school. Once the total hours are calculated, a percentage based on total hours worked for each member school will be used to allocate the provider/employee time for each member school. This documentation will be attached to each reimbursement request. Anticipated Completion Date: This finding was corrected in January, 2024.

FINDING 2025-004 Subject: COVID -19 - Education Stabilization Fund - Cash Management Contact Person Responsible for Corrective Action: Allison Vanover, Corporation Treasurer. Contact Phone Number 812-246-3375 Email Address: avanover@scsc.school Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Corporation will implement and consistently apply a standardized two-level review and approval process for all grant reimbursements to ensure proper accounting, documentation, and compliance. The grants administrator (or designee) will prepare and conduct the initial review of each grant reimbursement to verify that all expenses and receipts contain the correct accounting information, are properly documented, and are recorded in the appropriate accounts within the Financial Management System (FMS). The Corporation Treasurer (or designee) will perform an independent secondary review of all grant reimbursements, including a review of supporting documentation and account coding, and will provide final approval and signature as evidence of authorization. On a monthly basis, grant accounts will be reviewed by the grants administrator for accuracy and completeness, with the Corporation Treasurer (or designee) conducting a secondary monthly review to confirm accuracy and compliance. This two-level review process ensures adequate segregation of duties, strengthens internal controls, and provides documented oversight of all grant reimbursement activity. Anticipated Completion Date: The ESSER grant is finished. If we were to receive this grant in the future, Silver Creek School Corporation would apply the procedures in the corrective action plan.

FINDING 2025-002 Finding Subject: Special Education Cluster (IDEA) - Earmarking Contact Person Responsible for Corrective Action: Meghan Damron Contact Phone Number and Email Address: 219-650-5300, mdamron@mvsc.k12.in.us Views of Responsible Officials: We concur with the finding. We have taken the audit finding, conclusions and recommendations and created a corrective action plan to correct our earmarking for the future. Description of Corrective Action Plan: Although Merrillville Community School Corporation left Northwest Indiana Special Education Cooperative (NISEC) as of July 1, 2024 we continue to track time and effort logs for individuals servicing our non-public students with disabilities. These are housed in the special education office located at Pierce Middle School. Since staff are performing special education duties only, reports are logged semiannually. NISEC has reported that for the 2023-2024 school year the corrective action plan was implemented fully. Anticipated Completion Date: This was completed fully as of July 1, 2024.

FINDING 2025-003 Finding Subject: Teacher and School Leader Incentive Grants – Subrecipient Monitoring Contact Person Responsible for Corrective Action: Chris Gearlds, Assistant Superintendent Contact Phone Number and Email Address: (317) 856-5265; cgearlds@decaturproud.org Views of Responsible Official: We concur with Audit Finding Description of Corrective Action Plan: The Teacher and School Leader Incentive Grant was completed during the audit period and the school district does not plan on receiving this award in the future. Therefore, further corrective action is not required and district officials will utilize this information to ensure compliance in other federal awards. Anticipated Completion Date: February 1, 2026

Finding Number: 2025-001 Planned Corrective Action: Towpath Trail High School will comply with all federal grant compliance requirements – including reporting requirements and deadlines. Anticipated Completion Date: 2/14/2026 Responsible Contact Person: Dave Massa, Treasurer

FINDING 2025-003 Finding Subject: Special Education Cluster (IDEA) - Earmarking Contact Person Responsible for Corrective Action: Amy Silva Contact Phone Number and Email Address: 812-753-4230 amy.silva@sgibson.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The School Corporation has designated the Director of Special Education as the primary monitor responsible for overseeing nonpublic proportionate share expenditures. The Corporation Treasurer will provide the Director of Special Education and the Assistant Superintendent with a monthly budget-to-actual expenditure report for all active grants with nonpublic proportionate share requirements. This report will track the remaining unspent balance. The Director of Special Education will meet monthly with nonpublic school administrators to review the remaining fund balances, ensure services are being rendered, and project future expenditures. A final reconciliation will be performed within 30 days of each grant's end date to confirm all required funds were spent or a waiver was successfully obtained. Anticipated Completion Date: March 1, 2026

FINDING 2025-005 Finding Subject: Title I Grants to Local Educational Agencies – Special Tests and Provisions – Assessment System Security Contact Person Responsible for Corrective Action: Superintendent and Title I Program Director Mr. Todd Tanksley Contact Phone Number and Email Address: 812-849-4481 – tanksleyto@mitchell.k12.in.us Views of Responsible O􀆯icial: We concur with the finding. Description of Corrective Action Plan The School Corporation has implemented enhanced internal control procedures to ensure compliance with Assessment System Security requirements and applicable state and federal regulations. E􀆯ective immediately, the School Corporation will: 1. Require all employees who administer, handle, or have access to secure test materials to complete annual assessment security training in accordance with the Indiana Assessment Policy Manual. 2. Require all such employees to sign the Indiana Testing Security and Integrity Agreement annually by an established deadline. INDIANA STATE BOARD OF ACCOUNTS 34 3. Establish a standardized process to collect, review, and retain signed testing security agreements at the building level. 4. Maintain a centralized tracking log of all employees required to complete training and sign agreements. 5. Conduct an annual verification review to ensure that all required documentation is complete prior to the testing window. 6. Retain all assessment security training documentation and signed agreements in accordance with federal record retention requirements under 2 CFR 200.334. Planned Evidence of Correction The School Corporation will maintain the following documentation as evidence of corrective action: ● Annual assessment security training agendas and attendance record ● Signed Indiana Testing Security and Integrity Agreements for all applicable sta􀆯 ● Centralized tracking logs indicating completion of training and agreement signatures ● Building-level verification checklists signed and dated by administrators ● Written internal procedures related to assessment system security compliance Anticipated Completion Date Implemented and ongoing beginning with the FY2026 assessment cycle.

FINDING 2025-03 Finding Subject: Special Education Cluster (IDEA) - Earmarking Contact Person Responsible for Corrective Action: Dr. Emily Dykstra Contact Phone Number and Email Address: 812-849-4481 / dykstrae@mitchell.k12.in.us Views of Responsible Officials: “We concur with the finding.” Description of Corrective Action Plan: Mitchell Community Schools will utilize time and effort logs to track time that personnel spend working with non-public students. These logs will be turned into the Director of Special Education at the end of each school year, so that they will be available for future audits. A time and effort log template will be created by March 6, 2026 to be utilized with personnel for future IDEA grants. Anticipated Completion Date: March 6, 2026

2025-002: Student Financial Audit Cluster - Special Tests: Return of T itle IV Funds and NSLDS Reporting Anticipated completion date: done - June 18, 2025 Contact person: Brandi Payne Cervera Corrective actions: The two late aid returns were made under the following circumstances. Student's effective date of the withdrawal was March 25, 2025. However, the withdrawal was not processed in our Colleague system until April 9, 2025. The backdated effective date of the withdrawal in Colleague did not appear on our enrollment activity report that is used to identify complete withdrawals because this report is run weekly using a defined date range. As a result, the student's withdrawal was not identified in a timely manner. The withdrawal was identified by our Assistant Director upon her review of students with all non-passing grades at the end of the semester prior to the audit testing (see existing procedure/internal control below). The return-of-funds was processed as soon as the withdrawal was discovered, but it was out of the 45-day required timeframe. We have implemented a new procedure, as follows. New procedure (backdated withdrawal): The Registrar's Office will immediately notify Financial Aid of any withdrawals received by the Registrar's Office that require a backdated effective date in Colleague to ensure that we are returning funds within the required timeframe. The Financial Aid Director, Assistant Director of Financial Aid, and the Registrar met and developed this new procedure. The procedure was implemented on June 18, 2025. An institution must certify enrollment information to the National Student Loan Data System (NSLDS) every 60 days. Because of the issue with the backdated effective date of the withdrawal described above, the enrollment reporting for this student was made outside of the 60-day reporting window. I request the removal of the NSLDS reporting deficiency since the late processing of the student's withdrawal and return-of-funds was the root cause of the late NSLDS reporting, and there were no other enrollment reporting issues. The second late return was due to human error. After a R2T4 calculation has been performed, there is an "Update Student Aid" button on the ROFC screen in Colleague that must be manually marked "yes" in order for the return of- funds to post to the student's account. This step was missed for one student which caused the late return-of-funds outside of the required 45-day timeframe. New procedure (human error): Assistant Director has put a standing item on her calendar to review RT24's every Wednesday with a notation to check the "Update Student Aid" box in Colleague so that the return will occur. The Assistant Director will also check the list of withdrawals after each weekly aid transmittal to make sure the aid returns have all posted to the student accounts as expected. This procedure was put into place on June 18, 2025. Existing Procedure/Internal Control: We can say with certainty that out of the 165 withdrawals for the 2024/2025 award year, the two students identified in the audit were the only two late returns. The Assistant Director of Financial Aid reviews all students with non-passing grades at the end of each semester to identify unofficial withdrawals and to ensure that all returns were made appropriately and that no R2T4 calculations were missed. Potential issues are identified through this end-of-semester review. This is how the issue with the backdated withdrawal date described above was discovered. She will continue this effective internal control process each semester which will confirm that our new procedures are working as intended.