Corrective Action Plans

This is repeat Finding from 2022. Key personnel have since been replaced at the RPC and those in in the new positions understand the importance of proper and timely reporting and accurate financial records. The Auditor’s Office will meet with the new executive director, the current (new) finance director, and board members to emphasize the importance of deadlines and financial accountability when working with Grants. Additional Controls will be emphasized to assist with timely filing, as well as Invoice Entry to ensure duplicate payments are not made.

2023- 007 - Material Weakness in Internal Control and Material Noncompliance – Sub-recipient Monitoring and Management WPHW understands this finding and recognizes that correction that were planned for FY23 were not able to be fully implemented. One of the significant challenges WPHW had over the past couple of year, in addition to IT system challenges, is staffing. WPHW has hired three individuals to develop our contracting process and had performance issues with all three individuals. In addition to the difficulties with the NetSuite implementation, we have had to re-evaluate our sub-recipient monitoring and management business process. The following process will address this finding: 1) Director of Accounting and the Accounting Manager will review CFR 200.332 and develop a revised business process for the WPHW contract system a. Accounting Team will hire 2 Accounting Specialists who will each have specific sub-recipient monitoring responsibilities 2) Director of Accounting and the Accounting Manager will review all current contract to ensure the following: a. Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes: i. Federal, State or other award identification. ii. Subrecipient name (which must match the name associated with its unique entity identifier); iii. Subrecipient's unique entity identifier; iv. Award Identification Number (FAIN/SAIN); v. Award Date of award to the recipient by the Federal agency; vi. Subaward Period of Performance Start and End Date; vii. Subaward Budget Period Start and End Date; viii. Amount of Federal Funds (if applicable) Obligated by this action by the pass-through entity to the subrecipient; ix. Total Amount of Federal Funds Obligated, if applicable, to the subrecipient by the pass-through entity including the current financial obligation; x. Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; xi. Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA); xii. Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity; xiii. Assistance Listings number and Title; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; xiv. Identification of whether the award is R&D; and xv. Indirect cost rate for the Federal, State, or other award (including if the de minimis rate is charged) per § 200.414. b. All requirements imposed by the pass-through entity on the subrecipient are in accordance with Federal, State, Local statutes, regulations and the terms and conditions of the award; c. Determines and ensure completion of required financial and performance reports; d. Has an approved federally recognized indirect cost rate negotiated between the subrecipient and the Federal Government or utilizes the de minimus. e. States that subrecipient permit the pass-through entity and auditors to have access to the subrecipient's records and financial statements as necessary for the pass-through entity to meet the requirements of this part f. Details appropriate terms and conditions concerning closeout of the subaward. g. Subrecipient risk assessment that accesses: i. prior experience with the same or similar subawards; ii. previous audits iii. personnel or substantially changed systems iv. Prior monitoring results 1. Subaward conditions will be placed if issues arise 3) Implement sub-recipient monitoring process. a. Conduct invoice review monthly i. All invoices must include full back up and support for expenses ii. All invoices will be reviewed as they are received to ensure expenses are allowable iii. Any issues that arise will be addressed prior to invoice payment b. Conduct contract monitoring visit annually i. Hold a meeting with the sub-recipient to review the following: 1. Reviewing financial and performance reports 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the subaward. 3. Training and technical assistance on program-related matters 4. Determine corrective action for any deficiencies or findings and determine risk 5. Discussion of enforcement action against noncompliant subrecipient This process will be reviewed, and implementation will begin during Q4 FY24. All current FY24 contracts will be reviewed, and monitoring visits scheduled. For FY25, all contracts will be in compliance with requirements.

The City of Scottsboro will adopt and implement policies in regards to federal award compliance, including subrecipient monitoring compliance.

Finding 2023 – 006 CONDITION During the current audit period, the Cook County Department of Public Health (DPH) did not perform adequate monitoring of its subrecipients as required by Federal regulations. CORRECTIVE ACTIONS DPH will implement procedures to ensure that the subrecipient monitoring process is adequately documented to ensure financial monitoring is performed, the subrecipient’s risk of noncompliance is evaluated, and the process includes the review of single audit reports. Management Approval of the Policy and Tools have been shared with the auditors. Implementation Phase includes but will not be limited to 1) identifying designated personnel team/consultant, 2) training staff, and 3) monitoring plan to ensure that the policy is followed. Anticipated completion of the corrective action is estimated to be December 31, 2024. The corrective action will be coordinated by the Director of Grants Accounting.

Finding 2023 – 005 CONDITION During the current audit period, the Cook County Department of Public Health (DPH) did not adequately comply with its subrecipient monitoring requirements in accordance with federal regulations. CORRECTIVE ACTIONS DPH will implement prior corrective action plan for future subrecipients awarded with federal funds. The corrective measure will include adequately documenting financial monitoring and review of single audit reports. Management Approval of the Policy and Tools have been shared with the auditors. Implementation Phase includes but will not be limited to 1) identifying designated personnel team/consultant, 2) training staff, and 3) monitoring plan to ensure that the policy is followed. Anticipated completion of the corrective action is estimated to be December 31, 2024. The corrective action will be coordinated by the Director of Grants Accounting.

Upon learning of the requirement for the Federal Funding Accountability and Transparency Act (FFATA) reporting, the Highway Safety (HS) office completed the reporting in January 2024. The highway safety office completed FFATA reporting for grants from 2019-2023 which resulted in nine sub-awards being reported. Going forward HS will complete the FFATA reporting after the subaward agreement is signed. During the year, HS will review agreements for additional obligations and update the FFATA reporting as necessary. Also, at the end of the year HS will conduct a final review to ensure all FFATA reporting was completed. Additionally, the Internal Review (IR) program has met with all of the grant administrators on January 29, 2024 to let them know about the FFATA requirements for each of their funding types. IR discussed the FFATA reporting requirement for sub-awards over $30,000. Each grant administrator will determine the best way to report their sub-awards in the Federal Subaward Reporting System (FSRS). Contact: Karson James, Highway Safety Grants Coordinator, Highway Safety and Mariá LaBorde, Internal Review Manager, Internal Review Anticipated Completion Date: January 29, 2024

FINDING 2023-003 Finding Subject: Special Education Cluster (IDEA) ‐ Earmarking Summary of Finding: Proportionate Share Reporting could not be verified Contact Person Responsible for Corrective Action: Kevin Frank Contact Phone Number and Email Address: 812-254-5536 kfrank@wcs.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Washington Community Schools will require the Director of the Daviess Martin Special Ed Cooperative to provide Proportionate Share expenditure data and emphasize the importance of having this information available for SBOA. Unfortunately, due to our configuration, WCS doesn’t have access to this data and it is up to the Coop to complete the requirements. Mr. Frank will offer training to DMSEC staff to ensure compliance. Anticipated Completion Date: 02/01/2024

FINDING 2023-009 Finding Subject: COVID -19 - Education Stabilization Fund – Cash Management Summary of Finding: The School Corporation had not properly designed or implemented a system of internal control, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting noncompliance related to the Cash Management compliance requirement. Reimbursement requests for the programs were prepared by an employee and reviewed by another employee. While the School Corporation did have a process in place to review and approve reimbursement requests, not all reimbursement requests were traceable to the fund ledger and no audit evidence was provided to indicate the reviewer verified disbursements to the School Corporation records. Three of five reimbursement requests filed during the audit period were not traceable to the Schools Corporation’s fund ledger. Due to the lack of supporting documentation it was not possible to determine if grant payments were reimbursements of expenditures or advance payment of grant funds. The lack of internal controls and noncompliance were systemic issues throughout the audit period. The noncompliance was isolated to three of the five reimbursement requests filed during the audit period. Contact Person Responsible for Corrective Action: Todd Balmer, Assistant Superintendent/CFO and Allison Vanover, Corporation Treasurer Contact Phone Number and Email Address: 812-246-3375 tbalmer@scsc.school avanover@scsc.school Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The same process will be in place to review and approve grant reimbursements. The Deputy Treasurer will verify with the person preparing the reimbursement that the proper accounting information is on the receipt and that it is then receipted into the correct account in the FMS System and sign off. The Corporation Treasurer will review all receipts and be the second signature. Each month the accounts will be checked for accuracy by the grants person and the Corporation Treasurer will again be the second check for accuracy. The grant person will verify that the reimbursements of expenditures or advance payments are clearly marked and accounted for in the FMS System and sign off. The Corporation Treasurer will be the second signature. When reimbursements are prepared, these entries will also be reviewed. Anticipated Completion Date: March 2024

FINDING 2023-003 Finding Subject:􀀃Special Education Cluster (IDEA) - Earmarking Summary of Finding: The School Corporation was a member of the Clark County Joint Services Program (Cooperative) during fiscal year 2021-2022. The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the earmarking requirements. The Non-Public Proportionate Share expenditures for all grant awards were not expended as required by IDOE for the individual member schools. The Cooperative categorized each expenditure by location and the total amount did not meet or exceed the required proportionate share as outlined on the award letter. The Cooperative was required to spend a total of $59,633 for 20611-158-PN01 and $35,470 for 20619-158- PN01. $32,798 was identified as being spent for 20611-158-PN01, which was less than the required proportionate share. The Cooperative was unable to provide documentation to identify the expenditures spent for 20619-158-PN01. Contact Person Responsible for Corrective Action: Ashley Compton, Director of Special Education and Allison Vanover, Corporation Treasurer Contact Phone Number and Email Address: 812-246-3375 alcompton@scsc.school avanover@scsc.school Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Silver Creek School Corporation does not operate under the Special Education Coop any longer. The Special Education Director has a beginning of the year consultation with the private school principal to discuss and finalize the proportionate share budget. The Corporation Treasurer and Special Education Director will review and co-complete the semi-annual prop share workbook to ensure that private school funding is expended in a timely manner. Anticipated Completion Date: March 2024

FAIN (Federal Award Identification Number) and Federal Award Date: The following action has been implemented to include the FAIN & Award date on all awards for ALN 20.509: All awards executed for Public Transit will include a “Grant Insert Sheet”. The Grant Insert Sheet will be identified on the Part 1 Grant award detail document. Box “36” titled FAIN, will include text that reads “See attachment B”. The Grant Insert Sheet is a document that is completed by the Public Transit Unit and is provided to the Grants Unit for award execution. This sheet includes detailed information related to the award. To address the deficiency, The Grant Insert sheet has been updated to include FAIN Numbers and the Federal Award Date. To ensure the Agency of Transportation meets this compliance requirement, the Grants Unit will verify this information is included prior to award execution. Anticipated completion date: This action went into effect as of January 12, 2024. Person Responsible for Corrective Action: Ross MacDonald, Public Transit Program Manager ross.macdonald@vermont.gov Tricia Scribner, Grants Unit Manager tricia.scribner@vermont.gov Management Review Schedules In the past, The Public Transit Program has used the State Fiscal year for the timing/scheduling of the 3-year Management Reviews. For example, if the completion of the last Management Review occurred in FY 2020, then we would ensure a new Management Review began at any time during FY2023. We understand this could lead to more than exactly 3 years between these reviews. Due to this finding, we will now establish a starting month/date for each provider, with 3-year intervals between the start of each Management Review. We have attached the updated schedule and will adhere to this from this day forward. Anticipated completion date: As of December 27, 2023, the updated Management Review Schedule is in effect. Person Responsible for Corrective Action: Ross MacDonald, Public Transit Program Manager ross.macdonald@vermont.gov

FINDING 2023-004 Finding Subject: Special Education Cluster (IDEA) - Earmarking Summary of Finding: The Greater Lafayette Area Special Services (GLASS) and Local Education Agency, Lafayette School Corporation, concur with the audit finding for Earmarking. GLASS 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, 2023. Contact Person Responsible for Corrective Action: Lissa Stranahan Contact Phone Number and Email Address: (Phone) 765-771-6013 (Email) lstranahan@lsc.k12.in.us Views of Responsible Officials: We concur with the finding. 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. Anticipated Completion Date: The corrective action was already put into place on July 1, 2023. The audit finding reflects the previous grant cycle prior to this action taken.

FINDING 2023-002 Finding Subject: Special Education Cluster (IDEA) - Reporting Summary of Finding: Expenditures not agreeing with ledgers Contact Person Responsible for Corrective Action: Phyllis Ritenour Contact Phone Number and Email Address: 317-845-9400 pritenour@msdwt.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: The finding was due to amounts that could not be claimed timely for reimbursement because of funds needing to be moved within grant buckets. Per a discussion with the auditors we need to tie the expenses not claimed back to a specific employee/employees or a specific purchase. beginning with our March reimbursements all adjustments to the funds ledger will have backup documents showing what items were omitted from reimbursement because of need for a budget amendment. Anticipated Completion Date: March 2024

FINDING 2023-003 Information on the federal program: Subject: Special Education Cluster (IDEA) - Earmarking Federal Agency: Department of Education Federal Program: Special Education Grants to States Assistance Listings Number: 84.027 Federal Award Numbers and Years (or Other Identifying Numbers): 19611-022-PN01, 20611-022-PN01, 21611-022-PN01, 22611-022-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking Audit Findings: Significant Deficiency Condition: 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 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. Context: The School Corporation is a member of the Greene Sullivan Special Education Cooperative (Cooperative). During fiscal year 2021-2022 and 2022-2023, the Cooperative operated the special education programs and spent the federal money on behalf of all its members.  As the grant agreements were between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. However, there was inadequate oversight performed by the School Corporation in order to ensure compliance with the Matching, Level of Effort, Earmarking compliance requirement. Although the Cooperative has a separate object code to identify expenditures for the purpose of proportionate share, there is no identifier or separate way to track which member school the funding was expended for. As such, the Non-Public Proportionate Share expenditures for the 19611-022-PN01, 20611-022-PN01, 21611-022-PN01, and 22611-022-PN01 grant awards could not be verified for the individual member schools. Additionally, the Cooperative did not obtain a waiver from the Indiana Department of Education for the amount unspent for the requirement on the 19611-022-PN01 and 20611-022-PN01 grant awards. For the 21611-022-PN01 grant award, a waiver was obtained from the IDOE which was used to cover a portion of the member school's required proportionate share amount; however, the remaining amount, which the Cooperative claimed to have expended, could not be traced to documentation that indicated which member school the expenditure was applied to. For the 22611-022-PN01 grant award, no waiver was obtained, and the amounts spent could not be traced to documentation that indicated which member school the expenditure was applied to. Also, the total amount expended for proportionate share was less than the total amount required when all member school proportionate share requirements were totaled. The lack of internal controls and noncompliance were isolated to the 19611-022-PN01, 20611-022-PN01, 21611-022-PN01, and 22611-022-PN01 grant awards. The minimum earmarking requirement for the 19611-022-PN01, 20611-022-PN01, 21611-022-PN01, and 22611-022-PN01 grant awards were $1,931, $3,486, $6,832, and $1,794, respectively. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and will take the following corrective action: 1 – Southwest School Corporation will establish a system of internal controls and procedures to ensure non-public proportionate share funds are appropriately allocated to the member school based on expenses charged directly on behalf of the member school. Supporting documentation for these expenses should be retailed for audit. 2 – Greene Sullivan Special Education Cooperative will require all staff to complete the appropriate google form following the completion of each session with Non-Public students. An example of this documentation is the Proportionate Share Service Log. This document will allow for ease of tracking funds per provider/school district. This will allow for successful usage of funds. In the event that funds are not successfully used, a waiver will be requested barring board approval. Responsible party and timeline for completion: Chris Stitzle, Superintendent, April 1, 2024

FINDING 2023-008 Information on the federal program: Subject: Special Education Cluster (IDEA) - Earmarking Federal Agency: Department of Education Federal Program: Special Education Grants to States Assistance Listings Number: 84.027 Federal Award Numbers: 22611-022-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking Audit Findings: Significant Deficiency Condition: 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 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. Context: The School Corporation is a member of the Greene Sullivan Special Education Cooperative (Cooperative). During fiscal year 2022-2023, the Cooperative operated the special education programs and spent the federal money on behalf of all its members. As the grant agreements were between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. However, there was inadequate oversight performed by the School Corporation in order to ensure compliance with the Matching, Level of Effort, Earmarking compliance requirement. Although the Cooperative has a separate object code to identify expenditures for the purpose of proportionate share, there is no identifier or separate way to track which member school the funding was expended for. As such, the Non-Public Proportionate Share expenditures for the 22611-022-PN01 grant award could not be verified for the individual member schools. Additionally, the Cooperative did not obtain a waiver from the Indiana Department of Education for the 22611-022-PN01 grant award, no waiver was obtained, and the amounts spent could not be traced to documentation that indicated which member school the expenditure was applied to. Also, the total amount expended for proportionate share was less than the total amount required when all member school proportionate share requirements were totaled. The lack of internal controls and noncompliance were isolated to the 22611-022-PN01 grant award. The minimum earmarking requirement for the 22611-022-PN01 grant award was $1,620. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and will take the following corrective action: 1 – Northeast School Corporation will establish a system of internal controls and procedures to ensure non-public proportionate share funds are appropriately allocated to the member school based on expenses charged directly on behalf of the member school. Supporting documentation for these expenses should be retailed for audit. 2 – Greene Sullivan Special Education Cooperative will require all staff to complete the appropriate google form following the completion of each session with Non-Public students. An example of this documentation is the Proportionate Share Service Log. This document will allow for ease of tracking funds per provider/school district. This will allow for successful usage of funds. In the event that funds are not successfully used, a waiver will be requested barring board approval. Responsible party and timeline for completion: Mark A Baker, Superintendent Effective April 2024

Finding 2023-003 – Special Education Cluster – Earmarking Contact Person Responsible for Corrective Action: Quinnlyn Van Rys Contact Phone Number: 219-850-1914 - qvanrypces.k12.in.us Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Provider/Employee will submit payroll records by student services monthly/bi-monthly to the bookkeeper. Once payroll records are received, the CFO will prepare a spreadsheet that calculates the time 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. This documentation will be reviewed and signed off by the Director of Special Education of Portage Township Schools. Anticipated Completion Date: March 2024

PDA: PDA will be hiring a complement position to develop and maintain an audit tracking report to ensure that all single audits are properly logged and processed. In addition, this position will review the financial information in each audit report to determine if all pass-through funding is properly included and subject to audit. This position will coordinate with the bureaus within PDA to ensure all required follow-up is completed in a timely manner. Anticipated Completion Date: 06/30/2024 Contact Name: Tracee Gotwalt, Audit Coordinator PDOA: The PDOA is looking to improve management decision communications in addition to more thorough evaluations as a new Comprehensive Monitoring Process pilot is starting in April 2024 to address the noncompliance of subrecipient monitoring. This has resulted in management designing control activities to achieve timely submissions in the future by initiating the following: 1. An audit tracking log has been established to track report submissions, document when they were received, initiated, findings requiring follow-up, and subsequent steps to finalize the audit. 2. A separate tracking mechanism is in place to ensure the monitoring of subrecipient activities for compliance with federal statutes, regulations, and the terms and conditions of the Agreement for the 52 Area Agency on Aging subrecipients. 3. PDOA is looking to fill a vacant position with a focus of tracking subrecipient expenditures in the aggregate and tracks Single Audit submissions on a Commonwealth wide basis since the Aging Cluster is material and has material sub-granted expenditures. 4. Since receiving the finding, PDOA has reached out to the resource account where Subrecipient Single Audit reports are received by the Federal Audit Clearinghouse (FAC) to verify all outstanding audit items for PDOA, as action is required within six months of receipt. 5. It is PDOAs impression that having increased oversight of the Schedule of Expenditures of Federal Awards (SEFA) will allow for timely dissemination of Management Decision Letters (MDL) in the six-month timeframe for making a management decision for federal award findings. 6. Additionally, PDOA will confirm a closure letter was sent to the Philadelphia Corporation for Aging documenting PDOA’s management decision regarding federal award findings, as included in their FYE 06/30/2021 Single Audit report. 7. Follow-Up procedures resulting from this finding will be reviewed and adjusted as needed to deliver optimal outcomes. Preliminary procedures will be directed to the agency’s audit review committee for resolution of completeness. 8. In the event the audit review committee determines additional steps beyond the monitoring efforts outlined above are insufficient, additional efforts will be communicated to the AAA network. Anticipated Completion Date: 06/30/2024 Contact Name: Jennifer Cave, Fiscal Management Specialist, PDOA Audit Liaison DOH: DOH’s subrecipient single audit tracking report now includes a mechanism to monitor management decision deadlines related to each entity’s FAC submission date. The process for tracking subrecipient audit reports with findings has been updated to include and highlight subrecipients’ audit reports where DOH is the lead agency for finding resolution or the report contains findings that relate to the Department. Anticipated Completion Date: 03/31/2024 Contact Name: Steven Marsden, Chief, Audit Resolution Section PDE: PDE has implemented weekly, monthly and quarterly checks to ensure that all single audits are properly logged and processed. The clerk typist will conduct a weekly review and provide confirmation to the audit coordinator by signature. Bi-weekly, the clerk typist will follow up on any single audits that remain open. Anticipated Completion Date: Completed Contact Names: Clayton Carroll, Audit Coordinator, Bureau of Budget & Fiscal Management; Jessica Sites, Director, Bureau of Budget & Fiscal Management

FINDING 2023-003 Finding Subject: Special Education Cluster (IDEA) - Earmarking Summary of Finding: We recommend that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure non-public proportionate share funds are appropriately allocated to the member school based on expenditures charged directly on behalf of the member school. Supporting documentation for these expenditures should be retained for audit. Contact Person Responsible for Corrective Action: Carolyn Wallace Contact Phone Number and Email Address: (812) 738-2168, extension 1012 - WallaceC@shcsc.k12.in.us

FINDING 2023-004 Finding Subject: Special Education Cluster (IDEA) - Earmarking Summary of Finding: The School Corporation had not properly designed or implemented internal controls over Earmarking to ensure non-public school expenditures were appropriately identified and reported. Contact Person Responsible for Corrective Action Plan: Sara Harpenau Contact Phone Number and email Address: harpenaus@dspcoop.org, 812 482-6661 Views of Responsible Officials: We agree with the finding. Description of Corrective Action: The Finance Manager of the Exceptional Children’s Co-op has developed an Excel spreadsheet and workbook for each of the employees who are providing services to homeschooled children and the private school special education children. This spreadsheet enables them to document the children to whom they provide services, the dates of the services, the purpose of the encounter, and the duration of the visit. Each employee has a calculated goal of the time that is required of them throughout the school year to provide these services. Anticipated Completion Date: This method was implemented in the 2022/2023 school year and will continue with each school year as needed.

FINDING 2023-005 Finding Subject: Special Education Cluster (IDEA) - Earmarking Summary of Finding: The School Corporation had not properly designed or implemented internal controls over Earmarking. Contact Person Responsible for Corrective Action Plan: Sara Harpenau Contact Phone Number and email Address: harpenaus@dspcoop.org, 812 482-6661 Views of Responsible Officials: We agree with the finding. Description of Corrective Action: The Finance Manager of the Exceptional Children’s Co-op has developed an Excel spreadsheet and workbook for each of the employees who are providing services to the homeschooled children and the private school special education children. This spreadsheet enables them to document the children to whom they provide services, the dates of the services, the purpose of the encounter, and the duration of the visit. Each employee has a calculated goal of the time that is required of them throughout the school year to provide these services. Anticipated Completion Date: This method was implemented in the 2022/2023 school year and will continue with each school year as needed.

CORRECTIVE ACTION PLAN OF CURRENT AUDIT FINDINGS June 30, 2023 FINDING 2023-001 Subject: Special Education Cluster (IDEA) – Earmarking Federal Agency: Department of Education Federal Program: Special Education Preschool Grants Assistance Listing Number: 84.173 Federal Award Number: 22619-043-PN01 Compliance Requirement: Matching, Level of Effort, Earmarking Audit Findings: Significant Deficiency Condition: 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 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. Context: The School Corporation is a member of the Northwest Indiana Special Education Cooperative (Cooperative). During fiscal year 2022-2023, 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. 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 Non-Public Proportionate Share expenditures for the 22619-043-PN01 grant award could not be verified for the individual member schools. Total grant expenditures were posted as expended. The non-public proportionate share expenditures were determined by applying a percentage to the non-public school budgeted expenditures. As such, we were unable to identify if the minimum amount per the grant award was expended and properly reported to IDOE as required. The lack of internal controls was isolated to the 22619-043-PN01 grant award. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: As a member of the Northwest Indiana Special Education Cooperative (NISEC), Highland reported their proportionate share based on a percentage of expenditures and had successful audits in doing so. When Highland was notified that this process was no longer acceptable, we immediately implemented an internal control process with NISEC which included a detailed reporting of staff work hours for nonpublic schools related to only our school corporation. The report is then reviewed and signed by the NISEC staff working for the nonpublic school and their supervisor. The employee detailed time and effort report is then provided to the NISEC finance department for a second review and signature before being reported to payroll. NISEC payroll then charges the proportionate share to the IDEA Part B and the Special Education Pre-School grants in the payroll system bi-weekly based on the time and effort report pertinent to just Highland. The time and effort reports are then used to submit the reimbursements request to the Department of Education for Highland’s proportionate share. Additionally, any IDEA Part B nonpublic material expense is broken out in detail with Highland’s proportionate share for approval by the NISEC finance office prior to vendor payment and the reimbursement request is submitted to the Department of Education. Responsible Party and Timeline for Completion: Federal regulation requires name and title of person overseeing corrective action plan and anticipated completion date. Peyton Gilmore, NISEC CFO, indicated that NISEC stopped reporting nonpublic proportionate share expenditures by percentages as of the 2022/2023 school year. An internal control procedure to report nonpublic proportionate share expenditures by detailed time and effort work of expenditures was implemented as of September 2022.

FINDING 2023-002 Finding Subject: COVID-19 – Education Stabilization Fund – Subrecipient Monitoring Summary of Finding: The School Corporation received and passed through to subrecipients $495,386 of ESF funds. The School Corporation is to clearly identify the award and applicable requirements to the subrecipients, evaluate the risk of noncompliance related to the subrecipients to determine appropriate monitoring of the subaward, and monitor the activities of the subrecipients to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. Contact Person Responsible for Corrective Action: Dr. Judi Hendrix, Director of WVEC and Michelle Cronk, CFO of West Lafayette Schools Contact Phone Number and Email Address: Dr. Judi Hendrix Michelle Cronk 765-894-0333 765-746-1602 judi.hendrix@esc5.k12.in.us cronkm@wl.k12.in.us Views of Responsible Officials: We concur with the finding regarding the informing and monitoring of subrecipients for federal grants. Description of Corrective Action Plan: We concur with the findings from the State Audit regarding the 3E grants funds; 2023-002. Our Corrective Action Plan would consist of the following:  Before ESF funds are dispersed to school districts (subrecipients), the WVEC Grant Director will ask districts for proper documentation such as receipts, college entrance letters, staff documented timesheets to support their request for funding.  The WVEC Grant Director will monitor the activities of the subrecipients to ensure that the financial subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals of the grant.  Once the school district’s information and documentation is received and approved, grant funding will be dispersed. Both the Service Center Executive Director and WVEC Grant Manager will approve and sign off on any payment made to a subrecipient.  On a biannual basis (periods ending June 30 and December 31), West Lafayette School Corporation will request the monitoring documentation from WVEC to ensure that proper monitoring is taking place. The WVEC Grant Director will create a sub-grantee reporting procedure:  Monthly spreadsheet with district allowable expense and sign off by Grant Manager, WVEC Executive Director and WVEC Treasurer approval.  This will take place every pay period to monitor the disbursement of any federal funds and to ensure that they are used for allowable expenditures under the grant.  This monitoring will begin in the month of March 2024 and continue until the end of the grant or Final Report, December 31, 2024. This procedure will also be used for other federal grants received.  On a biannual basis (periods ending June 30 and December 31), West Lafayette School Corporation will request the monitoring documentation from WVEC to ensure that proper monitoring is taking place. Anticipated Completion Date: Monthly monitoring will begin promptly (March 2024) and end with the final report of 3E grant activities on December 31, 2024.

FINDING 2023-001 Finding Subject: Special Education Cluster (IDEA) - Earmarking Summary of Finding: The School Corporation did not have internal controls in place to ensure that the Greater Lafayette Area Special Services 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 non-public school expenditures were appropriately identified and reported. Contact Person Responsible for Corrective Action: Lissa Stranahan, GLASS Director and Michelle Cronk, CFO of West Lafayette Schools Contact Phone Number and Email Address: Lissa Stranahan Michelle Cronk 765-771-6013 765-746-1602 lstranahan@lsc.k12.in.us cronkm@wl.k12.in.us Views of Responsible Officials: We concur with the finding for earmarking. GLASS 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 nonpublic 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, 2023. 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. The school corporation will review the methodology used to calculate non-public proportionate share on the grant applications to ensure that the correct methodology is used. Anticipated Completion Date: The corrective action was already put into place on July 1, 2023. The audit finding reflects the previous grant cycle prior to the action taken.

FINDING 2023-004 Finding Subject: Special Education Cluster (IDEA) – Earmarking Summary of Finding: The Non-Public Proportionate Share expenditures for the 21611-048-PN01 grant award could not be verified for the individual member schools. The non-public school share funds for the participating member schools were allocated based on the yearly budget for certified staff instead of time charged to the non-public schools. These allocations were the amounts reported to IDOE. As such, we were unable to identify which expenditures were for each school in order to verify the minimum amount per the grant award was expended and properly reported to IDOE as required. Contact Person Responsible for Corrective Action: Lana M. Miller Contact Phone Number and Email Address: Phone Number-812-689-6282 Email- lmiller@sripley.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: INDIANA STATE BOARD OF ACCOUNTS 31 Expenses for non-public schools are tracked and charged to the appropriate corporation. Staff record time spent at each non-public school, sign and date the form and turn it into the treasurer. The expenses are then moved to the correct expense line on the grant after receiving this information. Materials that are purchased are charged to the correct expense account when paid. ROD’s treasurer will prepare a report showing compliance with the earmarking requirement on a monthly basis. These reports will be provided to the ROD board for review, and our Superintendent is a member of that board. Anticipated Completion Date: July 1, 2023

FINDING 2023-006 Finding Subject: Special Education Cluster (IDEA) – Earmarking Summary of Finding: The Non-Public Proportionate Share expenditures for the 21611-048-PN01 grant award could not be verified for the individual member schools. The non-public school share funds for the participating member schools were allocated based on the yearly budget for certified staff instead of time charged to the non-public schools. These allocations were the amounts reported to IDOE. As such, we were unable to identify which expenditures were for each school in order to verify the minimum amount per the grant award was expended and properly reported to IDOE as required. Contact Person Responsible for Corrective Action: Julie Dudley Contact Phone Number and Email Address: 812.537.7205 jdudley@lburg.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Expenses for non-public schools are tracked and charged to the appropriate corporation. Staff record time spent at each non-public school, sign and date the form and turn it into the treasurer. The expenses are then moved to the correct expense line on the grant after receiving this information. Materials that are purchased are charged to the correct expense account when paid. ROD’s treasurer will prepare a report showing compliance with the earmarking requirement on a monthly basis. These reports will be provided to the ROD board for review, and our Superintendent is a member of that board. Anticipated Completion Date: July 1, 2023

FINDING 2023-002 Finding Subject: Special Education Cluster - Earmarking Summary of Finding: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Meghan Damron Contact Phone Number and Email Address: 219-650-5300 x5361 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: As a member of the Northwest Indiana Special Education Cooperative (NISEC), Merrillville Community School Corporation reported their proportionate share based on a percentage of expenditures, and had successful audits in doing so. When Merrillville Community School Corporation was notified that this process was no longer acceptable, we immediately implemented an internal control process with NISEC which included a detailed reporting of staff work hours for nonpublic schools related to only our school corporation. The report is then reviewed and signed by the NISEC staff working for the nonpublic school and their supervisor. The employee detailed time and effort report are then provided to the NISEC finance department for a second review and signature before being provided to payroll. NISEC payroll then charges the proportionate share to the IDEA Part B grant in the payroll system bi-weekly based on the time and effort report pertinent to just Merrillville Community School Corporation. The time and effort reports are then used to submit the reimbursement request to the Department of Education for Merrillville Community School Corporation’s proportionate share. Additionally, any IDEA Part B nonpublic material expense is broken out in detail with Merrillville Community School Corporation proportionate share for approval by the NISEC finance office prior to vendor payment and the reimbursement request is submitted to the Department of Education. 􀀃􀀃 Anticipated Completion Date: The Northwest Indiana Special Education Cooperatives Chief Financial Officer stopped reporting nonpublic proportionate share expenditures by percentage as of the 2022-2023 school year. An internal control procedure to report nonpublic proportionate share expenditures by detailed time and effort work and expenditures were implemented as of the 2023-2024 school year.