Corrective Action Plans

Finding Number Planned Corrective Action Anticipated Completion Date Responsible Contact Person 2022-001 We will continue to discuss and review the issue with our GAAP converter to make sure adjustments are properly made to the financial statements. May 31, 2023 County Auditor 2022-002 We will implement procedures to ensure all quarterly reports are submitted timely under this grant. December 31, 2023 Director of Morrow County Job and Family Services and Morrow County Area Transit

CORRECTIVE ACTION PLAN FINDING 2022-005 Contact Person Responsible for Corrective Action: Special Education Cluster/Heidi Sprunger Contact Phone Number: 260-589-3133 Views of Responsible Official: We concur with the finding. The district is working with Special Education Cluster to obtain the corrective action plan that was submitted previously. Description of Corrective Action Plan: We will monitor this with Adams-Wells Special Services Co-op to ensure that the corrective action plan that was submitted will be followed. Anticipated Completion Date: Immediately

FINDING 2022-011 Contact Person Responsible for Corrective Action: Tricia Malone Hudson, District Curriculum Specialist Contact Phone Number: 812-279-3521 Views of Responsible Official: We concur with the audit finding. Description of Corrective Action Plan: The district has established a process for tracking expenses for homeless and parental involvement funds. In addition, a process has been established to ensure all expenses are coded properly. Anticipated Completion Date: North Lawrence Community Schools implemented this procedure beginning in March 2023.

FINDING 2022-008 Contact Person Responsible for Corrective Action: Melissa Hinds, Director of Special Education Contact Phone Number: 812-279-3521 Views of Responsible Official: We concur with the audit finding. Description of Corrective Action Plan: A print out of the current expenses and balances will be reviewed by the Special Education Director and District?s Treasurer before the cash request is emailed to the state to ensure there is proper compliance with grant agreement and the matching, level of effort, earmarking and reporting compliance Anticipated Completion Date: February 2023

FINDING 2022-002 Information on the federal program: Subject: Special Education Cluster (IDEA) - Earmarking Federal Agency: Department of Education Federal Program: Special Education Grants to States Assistance Listing Number: 84.027 Federal Award Number: 20611-001-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking Audit Findings: Significant Deficiency Condition: The School Corporation is a member of the Adams Wells Special Services Cooperative (Cooperative). During fiscal year 2021-2022, the Cooperative operated the special education programs and spent the federal money on behalf of all its member schools. 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. 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 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 Non-Public Proportionate Share expenditures for the 20611-001-PN01 grant award could not be verified for the individual member schools. Total non-public expenditures were posted as expended. The member school proportionate share expenditures were then determined by applying a budgeted percentage to the total non-public expenditures. These were the amounts reported to IDOE. As such, we were unable to identify if the minimum amount per member school was expended and properly reported to IDOE as required. The School Corporation?s Non-Public Proportionate Share for the 20611-001-PN01 grant application was $9,319. Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Our corrective action plan is following the AWSSC plan of: Co-ops cannot combine proportionate share funds. Funds must be spent within each LEA?s geographic boundary. We will not receive a repeat finding for FY21. We will correct for FY22 and forward. Time and Effort Logs are being completed to show how many hours personnel are servicing Non-Pub students with a service plan. If Materials and Equipment are purchased for a specific student?s need, per the service plan, then those expenditures are 100% school specific. Per the DOE, Materials used by our Speech Language Pathologist for Speech Therapy for all six school corporations, those expenditures are split evenly across all school corporations with a non-pub proportionate share allocation. Responsible Party and Timeline for Completion: The Superintendent and Corporation Treasurer will work with the Adams Wells Special Services Cooperative to monitor and verify those expenditures are allocated appropriately across all school corporations with a non-pub proportionate share allocation.

CORRECTIVE ACTION PLAN Finding 2022-002: Subrecipient Monitoring Public Allies has developed a Risk Assessment tool that will be implemented with subgrantees ("local sites") for Program Year '23. The tool?s development was driven by noted best practices and guidance shared with AmeriCorps grantees and Public Allies? prior monitoring findings. The tool includes a self-assessment by local sites and the results will drive the level of monitoring and training and assistance each site receives. Public Allies will also be piloting a new Progress Report, that will provide an at-a-glance assessment of site performance based upon metrics determined in collaboration with subgrantees. The programmatic monitoring process will be led by a dedicated monitoring team that is supported by staff that provide direct programmatic training and technical assistance to sites. For fiscal monitoring, Public Allies has shifted from outsourcing all accounting and financial management to bringing all accounting in-house. As described above, this staff now includes a Finance Director, a Staff Accountant and Senior Accountant. This shift was the result of an evaluation of internal operations and financial management systems. The addition of multiple full-time accounting staff has improved our capacity to monitor and manage subgrantees, effectively track and manage process improvements, ensure fiscal-related grants compliance, and efficiently manage our federal grant funding requests and reports. A fiscal Grants Manager was hired to review subgrantee financial reporting, provide technical assistance, and implement financial monitoring of subrecipients. Finally, a desk audit will be implemented in FY23. The number of files to be reviewed for each site will be determined based upon risk factors assessed, including: AmeriCorps Monitoring Common Findings, staff retention data, prevalence of turnover in AmeriCorps members, and length of time since the site underwent an audit. Requested programmatic and fiscal documents will include: ? Ally/Member Leadership Journal Position Descriptions ? Time Logs ? Ally/Member Evaluations ? Exit Documentation ? Ally/Member Payroll Register, and ? Operating Partner Due Diligence ? Annual Financial Statement ? Separation of Duties Survey ? Internal Controls Questionnaire The Public Allies Network will be notified of the Desk-Based Audit by May 26th and the desk audit will conclude by fiscal year end. Findings of the audit, in the form of a Monitoring Report will be shared with subrecipients, including required follow-up necessary to remediate compliance findings. Results of the desk audit will be used to determine future training needs, policy recommendations, and future monitoring Person Responsible: Najah Woods, Apprenticeship Program Grants Manager Implementation Date: August 31, 2023

Contact Person Responsible for Corrective Action: Patsy Hess, Corporation Treasurer, and Lindsey Goshorn, Special Education Director Contact Phone Number: 812-358-4271 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: During fiscal year 2020-2021, Brownstown Central Community School Corporation (School) was a member of Orange-Lawrence-Jackson-Martin-Greene Joint Services Cooperative (Cooperative). The Cooperative operated the special education programs and spent the federal money on behalf of all its member schools. At the end of fiscal year 2020-2021 the Cooperative disbanded. Subsequent to fiscal year 2020-2021, the School has operated the special education programs. The Special Education Director maintains records ensuring that the required level of expenditures for nonpublic school students with disabilities has been met. The records involving level of expenditures for nonpublic school students with disabilities will be reviewed by the Corporation Treasurer or other employee with knowledge of the compliance requirement. Anticipated Completion Date: Immediate

Management?s View and Corrective Action Plan Finding 2022-001 ? Cash Management Cluster: Research and Development Cluster Grantor: National Cancer Institute and National Science Foundation Assistance Listing #: 93.397, Cancer Centers Support Grants and 47.049, Mathematical and Physical Sciences Title: Case GI SPORE, Case Comprehensive Cancer Support Grant, MRI: Acquisition of an SEM instrumented to conduct in-operando observations of materials performance under external stimuli Award Year and Number: 08/21/21-07/31/22 (CA150964), 04/01/21-03/31/22 (CA043703), 08/01/20-07/31/23 (DMR-2018167) The University believes it is in compliance and currently follows regulations pertinent to cash management in 2 CFR Part 200.305(b) (Uniform Guidance) which requires "payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity." As such, organizations are to minimize the time difference between vendor payment and requesting reimbursement from the sponsoring agencies. We acknowledge that there are discrepancies in the interpretation of the Office of Management and Budget (0MB) cash management compliance requirements and the Uniform Guidance Part 200.305(b). In October 2017, the Council on Governmental Relations (COGR) sent a letter to the Office of Federal Financial Management (OFFM) expressing concerns that the cash management requirement language in the 2017 Compliance Supplement was not aligned with the requirements for cash management included in the Uniform Guidance Part 200.305(b). COGR's stance is for the Compliance Supplement to be updated to correspond with the cash management requirements as written in the Uniform Guidance Part 200.305(b). In August 2021, COGR sent a follow-up letter to OFFM regarding the 2021 Compliance Supplement emphasizing the inconsistency has yet to be addressed or resolved and most recently followed-up again in June 2022. In September 2022, The Office of Research Administration (ORA) sent a letter in support of COGR's June 2022 Comment Letter and followed up in November 2022 as well, with no response. The Office of Research Administration is sincerely devoted to ensuring institutional compliance with Uniform Guidance and the Compliance Supplement. It is important to note that these exceptions pertain to accounts payable transactions only. ORA will be cognizant of OMB's current interpretation of the Cash Management requirements and will continue to monitor for additional guidance regarding discrepancies in the Compliance Supplement. Primary responsibility for implementing this corrective action plan for this finding rests with Diane Domanovics, Assistant Vice President for Sponsored Projects. Sincerely, Joan Schenkel Associate Vice President for Research

FINDING 2022-002 (Auditor Assigned Reference Number) Contact Person Responsible for Corrective Action: Austin Fruits Contact Phone Number: 317-535-7579 Views of Responsible Official: We concur with the finding that there was not an effective internal control system in place to ensure compliance with the Matching, Level of Effort, and Earmarking requirements in the Special Education grant. Description of Corrective Action Plan: The school corporation will continue to hold regular meetings with the nonpublic schools in our district to ensure they spend their allocations appropriately and timely. If the non-public schools do not spend their allocations within the grant period, Clark-Pleasant will request a waiver from the DOE to repurpose those funds in the grant. Anticipated Completion Date: 4/30/23

Information on the federal program: Subject: Special Education Cluster - Earmarking Federal Agency: Department of Education Federal Program: Special Education Grants to States, Special Education Preschool Grants ALN: 84.027, 84.173 Federal Award Numbers and Years: 19611-045-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Matching, Level of Effort, Earmarking Audit Findings: Material Weakness Context: The School Corporation is a member of the Northwest Indiana Special Education Cooperative (Cooperative). During fiscal years 2020-2021 and 2021-2022, 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, and Earmarking compliance requirements. 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. The lack of internal controls and noncompliance was isolated to the 19611-045-PN01 and 20611-045-PNO1 grant awards. The Non-Public Proportionate Share expenditures for the 19611-045-PN01 grant award could not be verified for the individual member schools. The non-public school share funds for all member schools were comingled and the aggregate amount of expenditures was then allocated to the member schools ona percentage basis. 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. The School Corporation?s minimum earmarking requirement for the 19611-045-PNO1 grant award was $6,228. The Non-Public Proportionate Share expenditures for the 20611-045-PN01 and 21611-045-PNO1 grant awards could not be verified for the individual member schools. The non-public school share funds for all member schools were comingled and the aggregate amount of expenditures was then allocated to the member schools on a percentage basis. 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.Views of Responsible Officials and Planned Corrective Actions: The district agrees with the finding and notes as a member of the Northwest Indiana Special Education Cooperative (NISEC), Tri-Creek School Corporation reported their proportionate share based on a percentage of expenditures and had successful audits in doing so. When the Tri-Creek 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's 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 Tri-Creek Non-Public schools. The time and effort reports are then used to submit the reimbursement request to the Department of Education for Tri Creek?s proportionate share. Additionally, any IDEA Part B nonpublic material expense is broken out in detail with Tri-Creek?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: Responsible parties: Lisa Rosinko, Northwest Indiana Special Education Cooperative Chief Financial Officer Anticipated Completion Date: The Northwest Indiana Special Education Cooperative discontinued 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 was implemented as of the 2022-2023 school year.

Finding #2022-009: regarding subrecipient monitoring were not performed on the Health Equity Grant, Award# 11442, CFDA # 93.391 as required by CCH Policy and Federal Regulations. Cause: The cause of this finding resulted from subrecipients being identified as vendors in the Grant application. The Program Lead informed Finance late which did not allow sufficient time to mobilize CCH staff and/or external consultant to perform subrecipient monitoring. Correction Action: The CCH Director of Grant Accounting will engage an outside consultant to conduct subrecipient monitoring for the grant and collaboratively work to modify the established policy. Anticipated completion of the corrective action will be December 31, 2023.

FINDING 2022-004 Contact Person Responsible for Corrective Action: Steve Snider, CFO Contact Phone Number: 260-920-1011 Views of Responsible Official: We disagree with the finding. The entire premise of the cooperative agreement and appointing a lead education agency is to have someone providing the services and managing the grants for those districts who participate. Description of Corrective Action Plan: DeKalb County Central United School District will work with the Northeast Indiana Special Education Cooperative to implement the procedures detailed below. The Northeast Indiana Special Education Cooperative (NEISEC) Treasurer will reach out to member schools during the writing process of the IDEA 611 and 619 grants in order for each member school to submit their plans for their allocation of proportionate share money. NEISEC will provide the allocation amounts to each cooperative school. These submissions will include a proportionate share budget and include proportionate share staff names and any necessary information for the budget categories. The NEISEC Treasurer will then compile the proportionate share information and include on the grant submission. The LEA Treasurer will be given a copy of the grant application and budget upon approval of the grant. Any NEISEC employee being paid out of proportionate share grant funds for salary and benefits will be paid from the LEA?s financial software. The LEA Treasurer will keep a spreadsheet of employee proportionate share expenses and this spreadsheet will be updated monthly based on time and effort logs that are submitted by all cooperative schools to the LEA and NEISEC. Any employee utilizing proportionate share funds that is not an employee of NEISEC, but rather a direct employee of a member school, will be paid directly by that member school. Time and effort logs will still be submitted to the LEA and NEISEC Treasurers for these employees in order to generate a direct reimbursement from the grant fund to the member school. For any expenses for a category outside of salary and benefits, a member school will need to submit an invoice and proof of purchase for equipment, supplies, etc. to NEISEC and the LEA in order to be directly reimbursed for those proportionate share expenses. If the request was not in the initial grant budget, the member school must submit all relevant information to NEISEC in order for a grant modification to be completed. Per IDOE the grant modification must be approved first prior to purchasing the items. Time and effort logs as well as invoice and proof of payment must be sent to the LEA Treasurer in order to completed the grant reimbursement requests. At the end of the grant period, any school with remaining proportionate share money will be required to complete a waiver. As of this date (2/10/2023) the LEA (DeKalb County Eastern CSD) and NEISEC are still in communication with SBOA and IDOE to review the proportionate share plan and ensure all necessary requirements will be satisfied. Anticipated Completion Date: Changes discussed above will be implemented for the remainder of the FY23 grant period starting 07/01/2023.

Contact Person Responsible for Corrective Action: Tyler Osenbaugh Contact Phone Number: 260-636-2175 Views of Responsible Official: Agree with the finding Description of Corrective Action Plan: Central Noble will work with the Northeast Indiana Special Education Cooperative to implement the procedures detailed below. The Northeast Indiana Special Education Cooperative (NEISEC) Treasurer will reach out to member schools during the writing process of the IDEA 611 and 619 grants in order for each member school to submit their plans for their allocation of proportionate share money. NEISEC will provide the allocation amounts to each cooperative school. These submissions will include a proportionate share budget and include proportionate share staff names and any necessary information for the budget categories. The NEISEC Treasurer will then compile the proportionate share information and include on the grant submission. The LEA Treasurer will be given a copy of the grant application and budget upon approval of the grant. Any NEISEC employee being paid out of proportionate share grant funds for salary and benefits will be paid from the LEA?s financial software. The LEA Treasurer will keep a spreadsheet of employee proportionate share expenses and this spreadsheet will be updated monthly based on time and effort logs that are submitted by all cooperative schools to the LEA and NEISEC. Any employee utilizing proportionate share funds that is not an employee of NEISEC, but rather a direct employee of a member school, will be paid directly by that member school. Time and effort logs will still be submitted to the LEA and NEISEC Treasurers for these employees in order to generate a direct reimbursement from the grant fund to the member school. For any expenses for a category outside of salary and benefits, a member school will need to submit an invoice and proof of purchase for equipment, supplies, etc. to NEISEC and the LEA in order to be directly reimbursed for those proportionate share expenses. If the request was not in the initial grant budget, the member school must submit all relevant information to NEISEC in order for a grant modification to be completed. Per IDOE the grant modification must be approved first prior to purchasing the items. Time and effort logs as well as invoice and proof of payment must be sent to the LEA Treasurer and NEISEC Treasurer in order to completed the grant reimbursement requests. At the end of the grant period, any school with remaining proportionate share money will be required to complete a waiver. As of this date (2/10/2023) the LEA (Central Noble) and NEISEC are still in communication with SBOA and IDOE to review the proportionate share plan and ensure all necessary requirements will be satisfied. Anticipated Completion Date: JUL 2023

2022-001: Procurement and Suspension and Debarment Corrective Action: Northwest College will perform a review of its current procurement policy, including purchasing thresholds, record retention of supporting documentation regarding method of procurement utilized, and maintaining supporting documentation regarding suspension and debarment for all contracts or purchases expected to equal or exceed $25,000 of Federal funds. Northwest College will revise its procurement policy as determined necessary and in accordance with Northwest College?s policies. Anticipated Completion Date: June 30, 2023 Contact Persons: Brad Bowen, Finance Director

Finding 2022-002 ? Special Education Cluster - Earmarking Contact Person Responsible for Corrective Action: Brittany Treesh Contact Phone Number: 260-357-3185 Views of Responsible Official: The school corporation concurs with the finding. Description of Corrective Action Plan: Garrett-Keyser-Butler Community School District (GKB) will work with the Northeast Indiana Special Education Cooperative to implement the procedures detailed below. The Northeast Indiana Special Education Cooperative (NEISEC) Treasurer will reach out to GKB during the writing process of the IDEA 611 and 619 grants in order for GKB to submit their plans for their allocation of proportionate share money. NEISEC will provide the allocation amounts to GKB. These submissions will include a proportionate share budget and include proportionate share staff names and any necessary information for the budget categories. The NEISEC Treasurer will then compile the proportionate share information and include on the grant submission. The LEA Treasurer will be given a copy of the grant application and budget upon approval of the grant. Any NEISEC employee being paid out of proportionate share grant funds for salary and benefits will be paid from the LEA?s financial software. The LEA Treasurer will keep a spreadsheet of employee proportionate share expenses and this spreadsheet will be updated monthly based on time and effort logs that are submitted by GKB to the LEA and NEISEC. Any employee utilizing proportionate share funds that is not an employee of NEISEC, but rather a direct employee of GKB, will be paid directly by GKB. Time and effort logs will still be submitted to the LEA and NEISEC Treasurers for these employees in order to generate a direct reimbursement from the grant fund to GKB. For any expenses for a category outside of salary and benefits, GKB will need to submit an invoice and proof of purchase for equipment, supplies, etc. to NEISEC and the LEA in order to be directly reimbursed for those proportionate share expenses. If the request was not in the initial grant budget, GKB must submit all relevant information to NEISEC in order for a grant modification to be completed. Per IDOE the grant modification must be approved first prior to purchasing the items. Time and effort logs as well as invoice and proof of payment must be sent to the LEA Treasurer in order to complete the grant reimbursement requests. At the end of the grant period, any remaining proportionate share money will require that a waiver be completed. As of this date (2/10/2023) the LEA (DeKalb County Eastern CSD) and NEISEC are still in communication with SBOA and IDOE to review the proportionate share plan and ensure all necessary requirements will be satisfied. Anticipated Completion Date: Changes discussed above will be implemented for the remainder of the FY23 grant period starting 07/01/2023.

Finding Number: 2022-002 Planned Corrective Action: The District has initiated an internal audit reconciliation system to confirm each month that all reimbursable breakfast and lunch reports agree. Anticipated Completion Date: 07/01/2022 Responsible Contact Person: Neil Laughbaum, Director of Operations

FINDING 2022-002 Contact Person Responsible for Corrective Action: Dr. William Stitt, Superintendent Contact Phone Number: 260-495-5005 Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding. Fremont Community Schools will work with NEISEC to ensure proper oversight and internal controls are in maintained. Anticipated Completion Date: Corrective action plan will be implemented by June 30, 2023.

PDE: Audits retrieved from the Federal Audit Clearinghouse are now reviewed after entry into PDE?s SharePoint website, to ensure PDE remains compliant with federal guidelines to respond to any and all findings pertaining to federal dollars it passes to subrecipients. Likewise, PDE Audit Section continues to improve upon its processes for timely determinations of those single audits with findings by multiple means, including periodic SharePoint enhancements designed to aid in timely review of single audit packages, working closely with PDE program areas to assist in timely responses and quickly addressing SharePoint access issues as they arise. Anticipated Completion Date: 06/30/2023 Contact Person and Title: Clayton P. Carroll, II, Audit Coordinator; Jessica Sites, Director, Bur. of Budget and Fiscal Mgmt DEP: BAFM now provides agencies with single audit reporting packages that have findings each week that have been accepted by the Federal Audit Clearinghouse (FAC). This allows for us to start our management decision process in a timelier manner and meet the six-month deadline for issuing our decision. This information first appeared in our notifications starting April 30, 2021. In addition, the DEP program that had been previously identifying agreements as contracts rather than subrecipient agreements has corrected this issue and all subrecipients have been notified in writing of this correction and provided the information for submitting their single audits (if necessary). The letters were sent to subrecipients on approximately May 31, 2022. DEP Fiscal Management staff will continue to monitor the BAFM SharePoint site and FAC for additional filings to attempt to avoid this issue in the future. DEP is also hiring additional staff for the oversight and monitoring of the subrecipient single audits to ensure compliance with all requirements. These positions are currently in the filing process, and we are hopeful that they will be filled, and staff trained by September 30, 2023. Anticipated Completion Date: 09/30/2023 Contact Person and Title: Jennifer L. Brandt, Senior Fiscal Management Specialist, Federal Grants and Audits DOH: NORTH Inc.?s Single Audit report for the period ending 9/30/2020 was officially submitted and showing on the FAC on 2/9/2023. Bureau of WIC staff reached out to the Director and CFO of NORTH Inc. by phone and email. Emails were sent with instructions on how to submit the report as well as the importance of submitting the report timely per their grant agreement. Each follow-up phone call included discussion on the importance of submitting their single audit as soon as possible. Moving forward the Bureau of WIC will implement the following procedure: 1 .Three months after the end of the audit period (Federal Fiscal Year), Project Officers will send an email that outlines the process for submitting a single audit reporting package to the FAC to their respective WIC local agencies. This email will provide a date that the single audit is due to be submitted to the FAC in order to stay in compliance with their current WIC grant agreement. 2. Six months after the end of the audit period (three months from the due date of the single audit reporting package) an official letter from the Bureau Director will go out to the WIC local agencies that are due to submit a single audit. The letters will include instructions on how to submit the single audit in FAC and the Audit Requirements link referenced in their grant agreement. 3. If the WIC local agency notifies the Bureau of WIC that their auditor will not be able to submit their agency?s single audit by the due date, then the Project Officer will work with the local agency to get a projected date of completion and a timeline on when the local agency?s auditor is able to finalize the audit and submit it to the FAC. The Bureau of WIC will then notify DOH?s Audit Coordinator and OB-BAFM of this information, so they are able to track it. 4. If the WIC local agency does not submit the report by the due date and fails to notify their project officer; a notice to cure letter will be sent to the agency. Concerning NORTH Inc.?s Single Audit report for the period ending September 30, 2021: 1. The Bureau of WIC will contact NORTH Inc. and request a meeting with their auditor. 2. Following the meeting with NORTH Inc.?s auditor, the Bureau Director will send an official letter to NORTH Inc. The letter will include the instructions on how to submit the single audit in the FAC and the Audit Requirements link referenced in their grant agreement. They will also be made aware of the actions that could result from them not submitting this audit by the agreed upon date. 3. If the single audit is not received by the agreed upon date, then the Bureau of WIC will send a notice to cure letter. Anticipated Completion Date: 03/24/2023 Contact Person and Title: Sally Zubairu-Cofield, Director, Bureau of WIC DHS: Regarding the timeliness of finding resolution and procedures related to the SEFA reviews, the Audit Resolution Section (ARS) hired an additional staff member in August 2021 and hired two additional staff members in February 2022, and an additional staff member in January 2023. Finally, the ARS worked with Office of the Budget, Bureau of Accounting and Financial Management to develop a risk-based approach for single audit reviews, which will greatly streamline the process of single audit reviews to gain substantial efficiencies. Regarding late audit report submissions, we will continue to follow the requirements of 2 CFR ?200.339 and Commonwealth Management Directive 325.8. We will continue to work with counties and their independent auditors to obtain any late Single Audit reports. Anticipated Completion Date: 06/30/2023 Contact Person and Title: David Bryan, Manager, ARS; Alexander Matolyak, Director, Division of Audit & Review

Department of Public Instruction Finding: 2022-022 Department of Public Instruction Response/Corrective Action Plan: We agree with the finding. Currently, USDA and DOE sub-awards are reported after the obligation or sub-award has been approved by all parties according to the requirements established by FSRS?s website. The Block Award, or the federal award which reimburses for meals claimed, will be reported after the meals have been claimed in NDFoods and paid in Peoplesoft. NDDPI will report the payments already made for FY 2023 and will work with our NDIT programmers to allow us to create an auto-generated report from NDFoods that will upload into the FSRS website according to FSRS?s template. To enter expenditure data by month in FSRS, Awardees are encouraged to complete a template to upload the required data. Unfortunately, NDDPI is aware of an issue with this template caused by the need for a 4-digit extension number. The lack of 4-digit zip code extensions with our rural sub-recipients is responsible for throwing this error in the upload. To complete a successful upload, NDDPI will omit any sub-recipients missing the 4-digit zip code extension from the monthly data or template and add them to the report with a manual entry on the website. The Director of CN and the CN Technology Coordinator will work with NDIT to program the needed reports from NDFoods. The Administrative Officer and the Account/Budget Specialist from the Fiscal Management office will be responsible for completing the upload and entering any manual data. After we have a defined set of steps to follow, we will create a written process and edit as needed. Contact Person Linda Schloer, Director, Child Nutrition and Food Distribution Programs Scott Egge, Technology Coordinator, Child Nutrition Kim Vega, Administrative Officer III, Fiscal Management Leon Rauser, Account/Budget Specialist, Fiscal Management Anticipated Completion Date Begin manual process procedure, 04/01/2023, enter sub-recipient data monthly from October 2022 forward until an automated process can be obtained. Autogenerated process date is uncertain, NDDPI will work with NDIT to establish an automated process as soon as IT?s schedule allows and testing is completed.

FINDING 2022-001 Information on the federal program: Subject: Special Education Cluster (IDEA) - Earmarking Federal Agency: Department of Education Federal Program: Special Education Grants to States Assistance Listing Number: 84.027 Federal Award Number: 20611-001-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking Audit Findings: Significant Deficiency Condition: The School Corporation is a member of the Adams Wells Special Services Cooperative (Cooperative). During fiscal year 2021-2022, the Cooperative operated the special education programs and spent the federal money on behalf of all its member schools. 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. 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 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 Non-Public Proportionate Share expenditures for the 20611-001-PN01 grant award could not be verified for the individual member schools. Total non-public expenditures were posted as expended. The member school proportionate share expenditures were then determined by applying a budgeted percentage to the total non-public expenditures. These were the amounts reported to IDOE. As such, we were unable to identify if the minimum amount per member school was expended and properly reported to IDOE as required. The School Corporation?s Non-Public Proportionate Share for the 20611-001-PN01 grant application was $10,523. Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Co-ops cannot combine proportionate share funds. Funds must be spent within each LEA?s geographic boundary. We will not receive a repeat finding for FY21. We will correct for FY22 and forward. Time & Effort Logs are being completed to show how many hours personnel are servicing Non-Pub school students with a service plan. If materials and Equipment are purchased for a specific student?s need, per the service plan, then those expenditures are 100% school specific. Per the DOE, Materials used by our Speech Language Pathologist for Speech Therapy for all six school corporations, those expenditures are split evenly across all school corporations with a non-pub proportionate share allocation. Responsible Party and Timeline for Completion: Adams-Wells Special Services Cooperative is the responsible party for the timeline completion. No later than January 2023, the Cooperative will have corrected proportionate share monitoring workbooks for FY22 and the ARP grants.

FINDING 2022-005 Contact Person Responsible for Corrective Action: Kathy Bahr Contact Phone Number: 260-316-5797 Views of Responsible Official: MSD of Steuben will work in collaboration with Northeast Indiana Special Education Cooperative and the DeKalb Eastern Treasurer (LEA) Description of Corrective Action Plan: MSD of Steuben will work with the Northeast Indiana Special Education Cooperative (NEISEC) to implement the procedures detailed below. NEISEC Treasurer will reach out to MSD of Steuben during the writing process of the IDEA 611 and 619 grants in order for MSD of Steuben to submit their plans for their allocation of proportionate share money. NEISEC will provide the allocation amounts to MSD of Steuben. These submissions will include a proportionate share budget and include proportionate share staff names and any necessary information for the budget categories. The NEISEC Treasurer will then compile the proportionate share information on the grant submission. The LEA Treasurer will be given a copy of the grant application and budget upon approval of the grant. Any NEISEC employee being paid out of proportionate share grant funds for salary and benefits will be paid from the LEA?s financial software. The LEA Treasurer will keep a spreadsheet of employee proportionate share expenses and this spreadsheet will be updated monthly based on time and effort logs that are submitted by MSD of Steuben to the LEA and NEISEC. Any employee utilizing proportionate share funds that is not an employee of NEISEC, but rather a direct employee of MSD of Steuben, will be paid directly by MSD of Steuben. Time and effort logs will still be submitted to the LEA and NEISEC Treasurers for these employees in order to generate a direct reimbursement from the grant fund to the member school. For any expenses for a category outside of salary and benefits, MSD of Steuben will submit an invoice and proof of purchase for equipment, supplies, etc. to NEISEC and the LEA in order to be directly reimbursed for those proportionate share expenses. If the request was not in the initial grant budget, MSD of Steuben will submit all relevant information to NEISEC in order for a grant modification to be completed. Per IDOE, the grant modification must be approved first prior to purchasing the items. Time and effort logs as well as invoice and proof of payment will be sent to the LEA Treasurer in order to complete the grant reimbursement requests. At the end of the grant period, any remaining proportionate share money will require that a waiver be completed. As of this date (2/10/2023) the LEA (DeKalb County Eastern CSD) and NEISEC are still in communication with SBOA and IDOE to review the proportionate share plan and ensure all necessary requirements will be satisfied. This will be communicated with MSD of Steuben. Anticipated Completion Date: Changes discussed above will be implemented for the remainder of the FY23 grant period starting 07/01/2023.

Finding Number: 2022-002 Planned Corrective Action: If the district is required to return to tally sheets for the calculation of site claim forms, more stringent reviews will be put into place between the tally sheets and the entering of the site claim form data. The 2021 ? 2022 school year had special procedures in place due to the ongoing pandemic. Anticipated Completion Date: March 16, 2023 Responsible Contact Person: Mandy Hildebrand, Treasurer

FINDING 2022-004 Information on the federal program: Subject: Special Education Cluster - Earmarking Federal Agency: Department of Education Federal Program: Special Education Grants to States, Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.173 Federal Award Number and Year (or Other Identifying Numbers): 19611-042-PN01, 19619-042-PN01, 20611-042-PN01, 20619-042-PN01, 21611-042-PN01, 20619-042-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking Audit Finding: Significant Deficiency Condition: The School Corporation is a member of the Northeast Indiana Special Education Cooperative (Cooperative). During fiscal year 2021-2022, 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. 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 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 Non-Public Proportionate Share expenditures for 19611-042-PN01, 19619-042-PN01, 20611-042-PN01, 20619-042-PN01, 21611-042-PN01, 20619-042-PN01 grant awards could not be verified for the individual schools to verify the minimum amount per the grant awards was expended and properly reported to IDOE as required. The lack of internal controls and noncompliance were isolated to the 19611-042-PN01, 19619-042-PN0l, 20611-042-PN01, 20619-042-PN01, 21611-042-PN01, 20619-042-PN01 grant awards. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and will take the following corrective action ... Responsible party and timeline for completion: Brian L Christner, director of finance, will follow-up with the Northeast Indiana Special Education Cooperative to ensure that nonpublic expenditures are properly reported. Completion date will be April 30, 2023.

FINDING 2022-004 Contact Person Responsible for Corrective Action: Barbara Fought Contact Phone Number: 260-260-3191 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: West Noble School Corporation will work with the Northeast Indiana Special Education Cooperative to implement the procedures detailed below. The Northeast Indiana Special Education Cooperative (NEISEC) Treasurer will reach out to member schools during the writing process of the IDEA 611 and 619 grants in order for each member school to submit their plans for their allocation of proportionate share money. NEISEC will provide the allocation amounts to each cooperative school. These submissions will include a proportionate share budget and include proportionate share staff names and any necessary information for the budget categories. The NEISEC Treasurer will then compile the proportionate share information and include on the grant submission. The LEA Treasurer will be given a copy of the grant application and budget upon approval of the grant. Any NEISEC employee being paid out of proportionate share grant funds for salary and benefits will be paid from the fiscal agent?s financial software. The LEA Treasurer will keep a spreadsheet of employee proportionate share expenses and this spreadsheet will be updated monthly based on time and effort logs that are submitted by all cooperative schools to the LEA and NEISEC. Any employee utilizing proportionate share funds that is not an employee of NEISEC, but rather a direct employee of a member school, will be paid directly by that member school. Time and effort logs will still be submitted to the LEA and NEISEC Treasurers for these employees in order to generate a direct reimbursement from the grant fund to the member school. For any expenses for a category outside of salary and benefits, a member school will need to submit an invoice and proof of purchase for equipment, supplies, etc. to NEISEC and the LEA in order to be directly reimbursed for those proportionate share expenses. If the request was not in the initial grant budget, the member school must submit all relevant information to NEISEC in order for a grant modification to be completed. Per IDOE the grant modification must be approved first prior to purchasing the items. Time and effort logs as well as invoice and proof of payment must be sent to the LEA Treasurer and NEISEC in order to complete the grant reimbursement requests. INDIANA STATE BOARD OF ACCOUNTS 29 TELEPHONE (260) 894-3191 - 5050 N US HIGHWAY 33 - LIGONIER, IN 46767-9606 - FAX (260) 894-3260 - 1-800-488-3191 - WNSC@WESTNOBLE.K12.IN.US At the end of the grant period, any school with remaining proportionate share money will be required to complete a waiver. As of this date (2/10/2023) DeKalb County Eastern CSD and NEISEC are still in communication with SBOA and IDOE to review the proportionate share plan and ensure all necessary requirements will be satisfied. Anticipated Completion Date: Changes discussed above will be implemented for the remainder of the FY23 grant period starting 07/01/2023.

FINDING 2022-005 (Auditor Assigned Reference Number) Contact Person Responsible for Corrective Action: Greg Hunt, Assistant Superintendent of Business & Operations Contact Phone Number: (219) 362-7056 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: LaPorte Community School Corporation will review more closely the submission of costs of the Federal Special Education Grant to ensure that earmarking requirements of the Matching, Level of Effort, Earmarking compliance is followed. Anticipated Completion Date: May 15, 2023