Corrective Action Plans

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

FINDING 2024-002 Finding Subject: Special Education Cluster (IDEA) Earmarking Contact Person Responsible for Corrective Action: Todd Slagle Contact Phone Number and Email Address: 812-874-2243 tslagle@northposey.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Treasurer and Special Ed Grant specialist will meet monthly to discuss each grant is in compliance In the event that a shortfall is identified, the School Corporation will promptly apply for a waiver, if applicable, to remain in compliance with grant requirements. Anticipated Completion Date: We anticipate completing the Corrective Action by July 1, 2025

FINDING 2024-002 Finding Subject: Special Education Cluster (IDEA) - Earmarking Contact Person Responsible for Corrective Action: Bethany Cmar Contact Phone Number and Email Address: 765-641-2126 (Bcmar@acsc.net) Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: When it comes to expenditures for non-public schools, ACS will assign a unique tracking number to each school, allowing expenditures to be easily traced for this requirement. The overall earmarking requirements will be compiled annually by the Special Education Director and sent to the CFO for review and approval, ensuring compliance with the requirements. Anticipated Completion Date: March 31, 2025

FINDING 2024-004 Finding Subject: Special Education Cluster – Earmarking Contact Person Responsible for Corrective Action: Marcia Fullenkamp, Treasurer Contact Phone Number and Email Address: (812) 623-2212; mfullenkamp@rodspecialed.org Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: 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. Anticipated Completion Date: July 1, 2023

FINDING 2024-005 Finding Subject: Special Education Cluster (IDEA) – Earmarking Contact Person Responsible for Corrective Action: Carolyn Wallace Contact Phone Number and Email Address: 812-738-2168, extension 102 and WallaceC@shcsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The failure to expend all of the funding set aside for nonpublic schools was caused by several factors, including significant changes within the leadership of the nonpublic schools being served and parents’ refusal of services in lieu of vouchers being received to provide private services. The following corrective actions will be implemented with the intentions to fully expend the set-aside funding, account for the expenditures by location, and to document those efforts:  Attain documentation from the nonpublic schools being served to document the discussions about planned and allowable spending.  When it is projected that the nonpublic proportionate share will not be fully expended, documentation will be requested from the nonpublic school detailing the cause so that the waiver can be submitted.  Attend updates offered from the Indiana Department of Education for Special Education. Retain appropriate documentation from these meetings to support decisions made regarding the grants.  Account for all expenditures by nonpublic school location and prepare proportionate share reports utilizing the location-specific information. Anticipated Completion Date: April 1, 2025

Reference Number: 2024-011 Prior Year Finding: No Federal Agency: U.S. Department of Transportation State Agency: Agency of Transportation Federal Program: Highway Planning and Construction Assistance Listing Number: 20.205 Award Number and Year: FFY2023 – FFY2024 Compliance Requirement: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Recommendation: VTrans should review and enhance internal controls and procedures to ensure that all required federal award information is included in subawards and that on-site subrecipient monitoring is conducted timely per the terms of its subrecipient monitoring plan. Views of responsible officials: Management agrees with the finding. Corrective Action Plan: Missing Federal Award Date: The Contract Administration, Grants Unit addressed the deficiency of missing federal award dates during the FY23 State Single Audit (in effect as of 1/12/2024). As part of the updated award execution process, the Grants Unit now verifies that all awards include the federal award date and applicable FAIN number. Awards executed prior to the implementation of this process are being updated during amendments to ensure compliance. Subrecipient Monitoring: The root cause of the subrecipient monitoring deficiency was staffing shortages, which affected the Agency of Transportations (AOT) ability to meet monitoring requirements on time. The AOT monitoring requirements have been transitioned from the Audit Bureau to the Contract Administration, Grants Unit. The Grants Unit has already identified and will prioritize Subrecipients based on the last date monitored. Workflow modifications to include efficiencies are also in progress. These efficiencies will help with timeliness. The revisions to the monitoring activities will be in the VTrans Granting Plan effective July 1, 2025. Scheduled Completion Date of Corrective Action Plan: All corrective actions will be implemented as of July 1, 2025. Contacts for Corrective Action Plan: Tricia Scribner, Administrative Services Manager III tricia.scribner@vermont.gov

FINDING 2024-003 Finding Subject: Special Education Cluster (IDEA) - Earmarking Contact Person Responsible for Corrective Action: Robert Glover Jr. Contact Phone Number: (219) 945-0250 Contact Email Address: rglover@hobart.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: As a member of the Northwest Indiana Special Education Cooperative (NISEC), School City of Hobart reported their proportionate share based on a percentage of expenditures and have had successful audits in doing so. When Hobart was notified that this process was no longer acceptable, we immediately implemented an internal control process with NISEC which included 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 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 School City of Hobart Non-public schools. The time and effort reports are then used to submit the reimbursement request to the Department of Education for Hobart’s proportionate share. Anticipated Completion Date: 4/30/2025

FINDING 2024-001 Finding Subject: Special Education Cluster (IDEA) - Earmarking Contact Person Responsible for Corrective Action: Lynn A. Kwilasz Contact Phone Number and Email Address: 219.983.3604; lkwilasz@duneland.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: School corporation personnel will work with PCES Cooperative personnel to appropriately review the PCES processes and procedures that have been established by PCES to ensure that the required level of expenditures for non-public school students with disabilities is tracked and met for the school corporation. Anticipated Completion Date: June 30, 2025

FINDING 2024-003 Finding Subject: Special Education Cluster (IDEA) - Earmarking Contact Person Responsible for Corrective Action: Andrea Phillips, Director of Finance Contact Phone Number and Email Address: (812) 663-4774 aphillips@greensburg.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: At the end of each nine week grading period employees will turn in actual hours worked with non-pub students to the Director of Special Education. The Director of Special Education will verify the actual hours worked with non-pub students, sign off, and then submit the information to the Director of Finance. The Director of Finance will then reconcile actual hours worked to budgeted hours estimated and make any adjustments necessary in the accounting software. Anticipated Completion Date: By April 30, 2025, the Director of Finance should be able to reconcile the 2024-2025 IDEA grants for the 2024-2025 school year thus far.

Department of Public Instruction Response/Corrective Action Plan: We agree with the issues identified. 1. NDDPI acknowledges the late reports in FSRS.gov from October 2022 to September 2023. As stated in the finding, the reports were initially reported, but according to the Helpdesk with FSRS.gov, they required removal to re-submit using the corrected FAIN numbers. NDDPI administrators were not aware that the reports initially filed would be deleted from the records, versus the incorrect reports becoming labeled as inactive and saved for historical purposes. Kim Vega, Administrative Officer with NDDPI will review current archive processes and determine where changes may be needed. The FSRS website will be eliminated as the reporting application for FFATA in the Spring of 2025, and from that time forward, will be performed in the SAM.gov application. Currently, NDDPI administrators are participating in training and presentations for the test website and will continue to watch for any changes to administrative tasks. An introduction of the new website’s capabilities did address enhancing the feature for deleted reports as a part of the user’s tasks rather than the Helpdesk’s responsibility. NDDPI will continue to follow this development while in training for SAM.gov reporting. With the changes in application sites, the future enhancement in ND Foods will include an Application Programming Interface (API) for FFATA reporting. This API will provide the capability of real-time reporting, eliminate most manual tasks, increase report accuracy, and improve team member productivity and efficiency. The new website also mentions the zip code validation as an upgraded process. This process in the current system has been an intense time drain for staff members who enter FFATA by manual entry or batch upload, so improved functionality in this area is a much-needed upgrade. 2. NDDPI acknowledges the submission of the late report leading up to March 2024 as stated in item number 1. Reports for the meal claims were not reported in FSRS.gov until the FAIN numbers and programming were corrected in ND Foods, and a new Excel report was written with the corrections. Therefore, the report was not submitted within the required deadline. NDDPI Administrative officer worked with the Child Nutrition Administrative Staff Officer and NDIT programmers to correct the programming and process new reports for batch upload. 3. NDDPI acknowledges the missing reports for November and December 2023. During the transition from one claim year to the following, multiple reports must be run in ND Foods to complete the block FFATA reports. In 2023, NDDPI administrators were not aware of the overlap of claim years and how it would affect reporting, and therefore, only the current-year reports were processed. Currently, ND Foods has been upgraded to include an automated feature for FFATA reporting to include the final claims from the prior year and the new year’s claims in its reports for batch upload. Every effort was made to report both the old claim year and the new claim year in 2024. 4. NDDPI administrators have reviewed the reporting dates and the obligation date for claims in the CN block reporting, and we have agreed on the federal guidance which indicates the awards are obligated in advance will have the date of signature or acceptance at NDDPI, and the batch upload for payments made to an award will have the action or obligation date of the approval date for payment. This process will correct the reporting dates for claim payment processing (10.559, 10.555, 10.558, 10.556, 10.553) or reporting month for an obligated award (10.582) and its required obligation date. NDDPI staff members should be able to test and implement a programming change in our current reporting system in the next 2 months. If this change proves to be more intense than planned, we will wait on a quick fix until the upcoming interface upgrade with Sam.gov. We know the interfacing upgrade will require an even greater amount of time, energy, and money, and it will be a change we must complete; therefore, if the quick fix proves to be ineffective and time-consuming, the change in reporting will wait until the programming begins for the API Interface. Currently, federal officials are reporting the transfer between reporting sites will be ‘Spring of 2025’ but are not giving users a specific date. We have consolidated the coordination of FFATA reporting to a single individual rather than having each area do their own. We will prepare and implement procedures for the FFATA reporting. Contact Person: Jamie Mertz, CFO Anticipated Completion Date: June 30, 2025

PDOA: 1. Designing a means to follow-up and ensure timely action of deficiencies through an audit tracking log to monitor reporting submissions, document when they were received, initiated, findings requiring follow-up, and subsequent steps to finalize the audit. 2. Management decisions for applicable findings will be issued and tracked. 3. Improvements have been made with regards to regularity in reporting to more effectively monitor activities of subrecipients consistently with respect to Federal statutes and regulations. 4. PDOA is looking to fill a vacant position with a focus of tracking subrecipient expenditures in the aggregate and tracking single audit submissions on a Commonwealth-wide basis since the Aging Cluster program is material and has material sub-granted expenditures in NSIP and Title III. 5. It is PDOA’s impression that having increased oversight of the 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. Discussions have started regarding considerations to take enforcement action against noncompliance by building language into the terms and conditions of the Cooperative Block Grant Agreements to exercise ability to withhold funding as approved in the Cost Allocation Plan. 7. PDOA has reached out to the BAFM to verify all outstanding audit items for PDOA since action is required within six months of receipt. 8. Follow-up procedures resulting from this finding will be reviewed and adjusted as needed to deliver optimal outcomes. Anticipated Completion Date: 06/30/2025 Contact Name: Jennifer Cave, Fiscal Management Specialist, PDOA Audit Liaison PDA: PDA has added a Financial Management Specialist 1 (FMS1) to its complement with the primary duty of agency audit liaison. The FMS1 will report to the PDA’s Budget Office. This is a new position and role within the department and has training and certification requirements to complete which will allow the position to: 1. Evaluate 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. Issue management decisions relative to audit findings and crosscutting findings assigned to the agency for resolution, as required by 2 CFR §200.521. If responsible for the resolution of crosscutting findings, notify the affected agency or agencies upon resolution of such findings. 3. 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. The new FMS1 will help ensure effective and efficient audit resolutions. This newly created position will also be responsible for the department wide audit tracking log that is in development. Anticipated Completion Date: 06/30/2025 Contact Name: Nichole Nedinsky, Fiscal Management Specialist, PDA Audit Coordinator PDE: The PDE Audit Section is working with divisions to develop processes to ensure timely responses. A training will be conducted by April 2025 on audit procedures, best practices, and federal regulations governing single audit management decisions. Anticipated Completion Date: 04/30/2025 Contact Names: Clayton P. Carroll II, Audit Coordinator; Jessica Sites, Director, Bureau Financial Operations DEP: DEP has updated the concur subrecipient letter to include the specific language related to the management decision that was previously in our non-concur letters. This ensures whichever template is used, the management decision and related finding information will be included in the subrecipient letter. Revised letters were sent to both subrecipients, in which DEP was the lead agency and had findings for in the audited timeframe. Staff are reviewing all the steps of our standard operating procedures to ensure we will be in compliance regardless of whether DEP is or is not the lead agency and regardless of whether we are preparing a concur or non-concur letter for the subrecipient. Anticipated Completion Date: 06/30/2025 Contact Names: Jennifer Brandt, Senior Fiscal Mgmt. Specialist; Kristen Szwajkowski, Lead Fiscal Mgmt. Specialist DHS: As stated in the DHS finding response, this was the result of human oversight, and not a systemic issue with internal controls. We have reminded staff to make sure that a management decision is timely communicated to subrecipients at the time of making the management decision. Anticipated Completion Date: Completed Contact Names: David Bryan, Mgr., Audit Res. Section; Alexander Matolyak, Dir., Div. of Audit & Rev.

Finding 2024-005 Finding Subject: Special Education Cluster (IDEA) - Earmarking Contact Person Responsible for Corrective Action: Beverly Hindes Contact Phone Number: 219-996-4771 x128 Views of Responsible Officials: We agree with the finding. Description of Corrective Action Plan: The Treasurer will work with the Special Education Co- op to ensure compliance with the Earmarking requirement. Anticipated Completion Date: March 31, 2025

FINDING 2024-003 Contact Person Responsible for Corrective Action: Rachel Dutoi Contact Phone Number: 574-254-4503 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Exceptional Learner Departmental staff going forward will work with the Payroll department to account for all individuals that are to be paid from Federally Funded Grants and other funding sources. From these lists of employees, the EL Departmental staff will designate the individuals working public and non-public students. Time and Effort records will be kept for all employees along with documents listing the impacted employees. These lists will then be reviewed during the certification process by the person creating the listing with Payroll personnel, the Exceptional Learner Director and the Director of Business Services to ensure that all employees are accounted for. Anticipated Completion Date: This new process will begin with the next semi-certification process.

FINDING 2024-003 Finding Subject: Special Education Cluster (IDEA) Summary of Finding: The non-public proportionate share expenditures for the preschool grant was not spent in full. Additionally, the corporation had not filed a waiver to move the funds to the corporation program. Contact Person Responsible for Corrective Action: Austin Fruits Contact Phone Number and Email Address: 317-535-7579; afruits@cpcsc.k12.in.us Views of Responsible Officials: We concur with the finding. Explanation and Reasons for Disagreement: N/A Description of Corrective Action Plan: We have formulated a plan to include the business office in Non-pub meetings moving forward so that open funds are being clearly communicated with the Non-public schools. If the funds are not spent, we will apply for the waiver to move the budget to the corporation. Anticipated Completion Date: March 1, 2025

FINDING 2024‐004 Finding Subject: Special education Cluster (IDEA) ‐ Earmarking Summary of Finding: Due to the timing of the Cooperative’s corrective action, the non‐public expenditures spent did not meet the earmarking requirements for grant award number 22611‐053‐PN01. From the beginning of the grant awards until March 2023, 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. Beginning in March 2023, the Cooperative began tracking expenditures by member school for the non‐public services. As such, we were unable to identify if the minimum amount per the grant award was expended and properly reported to IDOE from the beginning of the grant awards through March 2023, as required. Contact Person Responsible for Corrective Action: Tim Scott Contact Phone Number and Email Address: 574‐654‐7273 tscott@npusc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Beginning in March 2023, the Cooperative began tracking expenditures by member school for the nonpublic services instead of applying a percentage. The minimum amount per the grant award will be expended and properly report to the IDOE. New Prairie also plans on requesting biannual reports from the Cooperative on expenditures for nonpublic services. Anticipated Completion Date: March 2023

FINDING 2024‐003 Subject: Special Education Cluster (IDEA) – Earmarking Summary of Finding: Lack of effective internal controls to ensure earmarking requirements were met for grants that began prior to September 2022 Contact Person Responsible for Corrective Action: Adam C. Minth Contact Phone Number: 219-374-3504 Views of Responsible Official: The school corporation concurs with the finding and will be implementing corrective procedures by the end of this fiscal year. Description of Corrective Action Plan: As a member of the Northwest Indiana Special Education Cooperative (NISEC), Hanover Community School Corporation reported their proportionate share based on a percentage of expenditures and have successful audits in doing so. When Hanover was notified that this process was no longer acceptable, we immediately implemented an internal control process with NISEC which included 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 School Corporation Non-public schools. The time and effort reports are then used to submit the reimbursement request to the Department of Education for Hanover’s proportionate share. Anticipated Completion Date: 4/30/2025

FINDING 2024-004 Finding Subject: Special Education Cluster (IDEA) - Earmarking Summary of Finding: The Non-Public Proportionate Share expenditures for the 22611-048-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: Trina Huff Contact Phone Number and Email Address: (812) 689-4114, thuff@jaccendel.k12.in.us INDIANA STATE BOARD OF ACCOUNTS 27 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. Anticipated Completion Date: July 1, 2023

Finding Number: 2024-001 Planned Corrective Action: Towpath Trail High School will comply with all federal grant compliance requirements – including reporting requirements and deadlines. Anticipated Completion Date: 2/14/2025 Responsible Contact Person: Dave Massa, Treasurer

2024-003: Student Financial Audit Cluster - Reporting (Significant Deficiency) Corrective Action: Controls have been implemented to retain the documentation used in preparing the FISAP. All documentation for all pieces of the FISAP are now being stored electronically in a shared drive as well as on paper to be held in the Director’s office. Anticipated Completion Date: 9/13/2024 Contact Person: Laurie Johnstone

2024-005: Student Financial Audit Cluster - Special Tests and Provisions: Enrollment Reporting (Significant Deficiency) Corrective Action: Upon investigation, we discovered that even though Casper College is reporting our enrollment to the National Student Clearinghouse (NSC) in a timely fashion, those reports are not always being sent to the National Student Loan Data System (NSLDS) swiftly. We understand that NSC is a third-party servicer and ultimately, the institution is responsible for ensuring NSLDS is being updated properly. As a failsafe, Casper College has developed an internal audit procedure to manually update students in NSLDS to be in compliance with CFR 690.83. Anticipated Completion Date: 9/18/2024 Contact Person: Laurie Johnstone

2024-004: Student Financial Audit Cluster - Special Tests and Provisions: Disbursements to or on Behalf of Students (Significant Deficiency) Corrective Action: Casper College’s award notifications have been updated to include when funds will be disbursed. In addition, the award notifications reference the Important Dates URL on the Casper College website for parents and students to refer to that include award disbursement dates. Anticipated Completion Date: 9/6/2024 Contact Person: Laurie Johnstone

Cash Management Management agrees with the finding and the auditor's recommendation. There was confusion at the time of this agreement as the nature of the work was in line with providing institutional services rather than a federal grant agreement. This led to a misunderstanding of cash management requirements due to the nature of the award. Mass General Brigham (MGB) has removed the $215K of questioned costs from the Schedule of Expenditures of Federal Awards (SEFA). The funding will be returned to Advanced Regenerative Manufacturing Institute, Inc. in January 2025. Additionally, management will review the limited instances where departments have been previously approved to request federal cash. This review is to confirm that an exception to the standard practice of managing this through the central Research Finance team is appropriate. Based on results of this review, to be completed by March 2025, management will determine criteria and prior approval requirements for departments to request federal cash if MGB concludes this practice will continue on a limited exception basis. The review will be conducted with oversight by the MGB Vice President of Research Management and Research Finance and the MGB Research Controller.

The District will have a policy to never hold checks or prepare checks prior to completion of applicable work. Checks will be sent out immediately upon approval by the Board of Education. Furthermore, the District will ensure there is proper oversight to ensure checks are not being held.

2024-001: Reporting This finding is the result of human error when completing the Fiscal Operations Report and Application to Participate (FISAP). An extra digit was added to the tuition/fees charged, changing the tuition and fees charged from $6,880,369 to $68,880,369. This was missed in the review of the FISAP prior to submission. Corrective Action: The Financial Aid Office took great care in reviewing the 2023-2024 (for 2025-2026) FISAP for accuracy. Additionally, the amount requested for SEOG and FWS is the exact same as requested on the 2022-2023 (for 2024-2025) FISAP, rather than the inflated fair share. The Financial Aid Office will request up to the fair share on the 2024-2025 (for 2026-2027) FISAP. This issue has been successfully addressed. Anticipated Date of Correction: 9/30/2024 Contact Person: Shanna Vargas, Director of Financial Aid

2024-002: Reporting This finding is a result of transferring Primary Data Point Administration from Amy Murphy to Shanna Vargas. Part of this issue reflected SAIG/CPS/COD/NSLDS access from being set up correctly and resulted in many hours of contact and meetings with SAIG professionals to correct. Corrective Action: The Financial Aid Office has worked with SAIG professionals to correct this issue. The Financial Aid Office has developed a schedule and process to complete monthly direct loan reconciliation, as well as ensuring other members have access to complete this should the PDPA’s access not be available. Anticipated Date of Correction: Immediately Contact Person: Shanna Vargas, Director of Financial Aid