Corrective Action Plans

FINDING 2023-003 Finding Subject: Child􀀃Nutrition􀀃Cluster􀀃􀍲􀀃Activities􀀃Allowed􀀃or􀀃Unallowed,􀀃Allowable􀀃Costs/Cost􀀃Principles,􀀃Special􀀃 Tests􀀃and􀀃Provisions􀀃􀍲􀀃School􀀃Food􀀃Service􀀃Accounts􀀃 Summary of Finding: An􀀃effective􀀃internal􀀃control􀀃system􀀃was􀀃not􀀃in􀀃place􀀃at􀀃the􀀃School􀀃Corporation􀀃to􀀃ensure􀀃compliance􀀃with􀀃 requirements􀀃related􀀃to􀀃the􀀃grant􀀃agreement􀀃and􀀃the􀀃Activities􀀃Allowed􀀃or􀀃Unallowed,􀀃the􀀃Allowable􀀃Costs/Cost􀀃 Principles,􀀃and􀀃the􀀃Special􀀃Tests􀀃and􀀃Provisions􀀃􀍲􀀃School􀀃Food􀀃Service􀀃Accounts􀀃compliance􀀃requirements.􀀃 Contact Person Responsible for Corrective Action: Lela Simmons Contact Phone Number and Email Address: (219) 391- 4100, lesimmons@ecps.org Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: The􀀃Food􀀃Service􀀃director􀀃responsibilities􀀃is􀀃to􀀃overseeing􀀃all􀀃function􀀃of􀀃the􀀃Food􀀃Management􀀃Company.􀀃Food􀀃 Service􀀃Director􀀃will􀀃be􀀃required􀀃to􀀃draft􀀃internal􀀃controls􀀃and􀀃detail􀀃instruction􀀃for􀀃the􀀃school􀀃corporation􀀃to􀀃ensure􀀃 all􀀃documentation􀀃procedures􀀃match􀀃the􀀃FSMC􀀃invoice.􀀃The􀀃school􀀃corporation􀀃will􀀃not􀀃pay􀀃any􀀃unallowable􀀃cost􀀃by􀀃 state􀀃regulation􀀃and􀀃rules.􀀃All􀀃state􀀃reporting􀀃documents􀀃and􀀃invoice􀀃will􀀃continue􀀃to􀀃be􀀃reviewed􀀃and􀀃signed􀀃off􀀃by􀀃 the􀀃district􀀃CFO.􀀃A􀀃copy􀀃of􀀃all􀀃documents􀀃will􀀃be􀀃held􀀃in􀀃the􀀃food􀀃director􀀃office.􀀃 Anticipated Completion Date: We anticipate having the above corrective action plan in place by September 30, 2024.

Federal Agency Name: Department of Homeland Security & Emergency Management passed through State of Iowa department of Homeland Security and Emergency Management Assistance Listing Number: 97.3036, 4642DRIAP00000501 Program Name: Disaster Grants – Public Assistance Finding Summary: The Cooperative did not have any formally documented review and approval over the material and transportation costs claimed for reimbursement under the program. Corrective Action Plan: The Cooperative will document the review and approval of expenses for transportation and material that we are already doing. This will include initials and e-mails documenting the review process that was completed. For transportation the person reviewing the transportation logs with the payroll logs will initial the transportation logs. The person tying the transportation logs to the computer system and the vehicle’s actual ending mileage will also initial the transportation logs. For material transactions, a summary of transactions for the month will go to the appropriate department supervisor to sign off on those transactions. The person approving the transaction will depend on the department. Responsible Individuals: Department Supervisors who have inventory, Jaylen Heinz - Accountant, Kari Rubel - Accountant and other accountants. Anticipation Completion date: March 2024

Federal Agency Name: Department of Health and Human Services Program Name: COVID‐19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Federal Financial Assistance Listing: #93.498 Finding Summary: Audit testing identified four months of other general and administrative expenses claimed under the federal program did not consider the credit to be received back from a third‐party vendor for service time not performed by the third‐party vendor. The Period 4 report incorrectly included $64,404 of other general and administrative expenses. However, the Period 4 report also included approximately $6,077,500 of unused lost revenue. As a result, there are no questioned costs for activities allowed or unallowed and allowable costs/cost principles. Responsible Individuals: Austin Willuweit, Chief Financial Officer; Jen Schmaltz, Vice President of Finance Corrective Action Plan: Monument Health will review the third‐party vendor invoices and reduce unused lost revenue in any future federal reports. Anticipated Completion Date: June 30, 2024

FINDING 2023-005 Finding Subject: COVID-19 Education Stabilization Fund – Special Test and Provisions Summary of Finding: Test Provisions – Wage Requirements Contact Person Responsible for Corrective Action: Jim Boots Contact Phone Number and Email Address: 317-845-9400 jboots@msdwt.k12.in.us Views of Responsible Officials: We disagree with the finding Explanation and Reasons for Disagreement: The need for Wage Rate Requirements, i.e. Davis Bacon was not contemplated at the time the contracts for Construction Management services and contracting services were created, with the assistance of our legal team, and approved by the Board of Education. When it became known that Federal Assistance Funds were available to fund these existing projects, the District and our CM partners crafted language and incorporated it into the future project specific bidding documents for the appropriate projects and scopes of work that qualified for Federal Assistance Funds. The bidding documents are in the Operations Department files. The District, along with our Capital Projects Team and CM partners, developed a system of tracking, verification, reporting and internal controls to ensure the required documentation and supporting information was filed timely and accurately. Each Pay Application (invoice) contains individual line items in the project specific Schedule of Values for the scope of work that was for Federal Assistance Funding. Our established internal controls and review process pulled that information from each Pay App and identified it to be funded by Federal Assistance Funds. This information is retained in the Operations Department files. In the event our design team (Schmidt) assisted the District with additional services that were funded from Federal Assistance Funds, we are unable to determine how to document this as professional services are compensated on a lump sum/percentage complete basis. Any documentation can be provided in response to a specific request containing the specific information being requested (contractor or scope of work) and the specific project.

FINDING 2023-004 Finding Subject: COVID-19 Education Stabilization Fund Equipment and Real Property Management Summary of Finding: Inventory not included by Kroll (consultant) on Fixed Asset Ledger 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: Future Capital Asset Ledgers from Consultant will be reviewed by the Accounting and Assistant Accounting Manager. They will be compared not only to our spreadsheet of new and retired vehicles but also to all capitalized equipment, 734 & 735 object codes, listed in our financial system since the last capital asset review. Anticipated Completion Date: August 2025

FINDING 2023-003 Finding Subject: Special Education Cluster (IDEA) – Procurement, Suspension and Debarment Summary of Finding: Insufficient documentation provided for proof of Procurement and Suspension and Debarment verifications Contact Person Responsible for Corrective Action: Ghirmay Alazar (Procurement) Phyllis Ritenour (Suspension & Debarment) Contact Phone Number and Email Address: 317-845-9400 galazar@msdwt.k12.in.us pritenour@msdwt.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: Procurement - At our educational institution, we prioritize the unique leaning needs of our students by actively seeking vendors who can effectively meet our expectations. To ensure transparency and fairness in the vendor selection process, we examine total costs estimates from each vendor and analyze their reputations, experience, customer feedback, and ability to provide innovative solutions. We use this information to make informed decisions and the rationale behind our vendor selection process. When searching for vendors we will keep documentation that displays the cost from each vendor and the rational for selecting a specific vendor. Suspension and Debarment – Beginning July 2024 the Assistant Accounting Manager will run reports annually in July from sam.gov and from FMS and compare the 2 files to make sure that we don’t have vendors in our system that are on the debarment list. The files will then be forwarded to the Accounting Manager via email for review and approval. The approval email and the 2 reports will be saved in our shared drive as proof of file review. All new vendors will be checked in sam.gov before allowing purchases to be placed. The review sheets will be emailed to the Accounting Manager for review and approval, these will also be saved in our shared drive. Anticipated Completion Date: Procurement – December 2024 Suspension & Debarment – July 2024

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

Federal Agency Name: Department of Agriculture Program Name: Community Facilities Loans and Grants CFDA #10.766 Finding Summary: There was no formal review separate from the preparer performed over reconciliations of the USDA program reserve fund. Responsible Individuals: Debra Fraser, Administrator Corrective Action Plan: Management will ensure a review separate from the preparer of the reconciliation for the program’s reserve fund is completed with formal documentation noting the review. Anticipate Completion Date: 9/27/2023

Type of Finding: Significant Deficiency in Internal Control over Compliance relating to inadequate documentation and controls in place to ensure costs are reasonable and intended for the program charged. Views of Responsible Officials: Management accepts the finding. Effective internal control over the allocation of indirect costs exceeding the de minimis cost rate of 10%, which can be attributed to a lack of communication and review of the total expenditures being charged to the federal program. Program managers were accidentally invoicing before reconciling adjustments made. More thorough training of staff, along with careful supervisory review of total expenditures being charged to the federal program, and invoicing would likely have prevented this error. Corrective Action: An annual training of all grant accountants is being developed and will cover indirect and allowable costs. In addition, a process for secondary review of all invoices is being developed.

Type of Finding: Material weakness in internal control over compliance relating to inadequate documentation and controls in place to ensure costs are reasonable and intended for the program charged. Views of Responsible Officials: Management accepts the finding. Effective internal control over the documentation of secondary review of financial reports, timely filing, and disclosed demographics contained within the reports, which can be attributed to a lack of documentation of review and controls in place for submission of a report when responsible employee is out of office during the due date. Authorized personnel review was not documented, and a performance report was not filed timely and was filed with incorrect demographics. More thorough training of staff, along with careful supervisory review and documentation of review of report submissions prior to filing would likely have prevented these errors. Corrective action: A process for secondary review of all financial and programmatic reports will be developed in each region.

2023-001 Significant Deficiency: Internal Controls over Allowable Costs Status: In progress Planned Corrective Action: Management will design, implement, and monitor controls for the retention of employee benefit election forms to adequately document costs charged to federal programs. Anticipated Completion Date: March 31, 2024 Responsible Party: Alec Lundberg, Chief Financial Officer

CORRECTIVE ACTION PLAN (Concerning Finding 2023-002) Contact Person Responsible for Corrective Action: Catrina Kemp, Business Manager Corrective Action: The Regional School Unit No. 70 will take the following actions to address finding 2023-002. Management will review standards and requirements annually to ensure that the district is following federal guidelines. Management will also develop an attendance procedure to track salaried employees. Management will also employ a signature and date on all federal grant disbursements to ensure that all criteria and requirements are met for future federal grants. Anticipated Completion Date: July 1, 2024

FINDING 2023-002 Finding Subject: COVID-19 - Education Stabilization Fund - Reporting Summary of Finding: There was not an effective oversight or review process in place to prevent, or detect and correct, errors regarding the annual data report submissions. The School Corporation’s records did not support the amounts reported for expenditures in either ESSER II annual data report. It was recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure all reports submitted on behalf of the Education Stabilization Fund program funds are supported by the School Corporation’s underlying accounting records. Contact Person Responsible for Corrective Action: Tim Armstrong Contact Phone Number and Email Address: 812.753.4230: tim.armstrong@sgibson.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Beginning with the annual data report submissions for these funds due in April 2024, the Assistant Superintendent will audit the reports as prepared by the Treasurer in order to ensure the spreadsheets are correct and reflect the financial statements’ of the school corporation. Anticipated Completion Date: 5 March 2024

FINDING 2023-001 Finding Subject: COVID-19 - Education Stabilization Fund - Special Tests and Provisions - Wage Rate Summary of Finding: The School Corporation had not designed nor implemented a system of internal controls to ensure that construction contracts in excess of $2,000 paid from federal grant funds included a prevailing wage rate clause. There were two contracted vendors paid in excess of $2,000 with Education Stabilization Fund grant award funds during the audit period for construction related projects. Both contracts, totaling $2,296,300, were selected for testing. Neither of the contracts included the required prevailing wage rate clause. In addition, certified payrolls were not submitted to the School Corporation by either contractor. Contact Person Responsible for Corrective Action: Tim Armstrong Contact Phone Number and Email Address: 812.753.4230: tim.armstrong@sgibson.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: This need had been communicated to the school corporation by the Indiana Department of Education in their monitoring of our ESSER funds, which are reported on a quarterly basis. This requirement was not adequately explained to school corporations but has been now. In the future, any Federal dollars used in construction over $2,000 will have this monitored by the Director of Operations, the Assistant Superintendent, as well as the Treasurer and their assistant to ensure compliance with this requirement. Anticipated Completion Date: 5 March 2024

Student Financial Aid Cluster – Gramm-Leach-Bliley Act Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Recommendation: We recommend the College ensure its written information security program addresses the required minimum elements as outlined in 16 CFR 314.4. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A CIO who has extensive experience in regulatory compliance as well as cyber security has been hired. The CIO has set forth a plan to get us in full regulatory compliance. A new information security plan has been crafted and is being published on the website. That plan will be put into practice over the next few months. Name(s) of the contact person(s) responsible for corrective action: Irving Bruckstein Planned completion date for corrective action plan: June 30, 2024

Student Financial Aid Cluster – NSLDS Reporting Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: To ensure continuity of operations, Jennifer Gallagher will be temporarily assuming responsibility for Enrollment Reporting until a new Registrar is hired and trained. She is committed to addressing any outstanding issues and improving the efficiency of our processes during this transitional period. Name(s) of the contact person(s) responsible for corrective action: Jennifer Gallagher Planned completion date for corrective action plan: June 30, 2024

Finding 2023-006 Information on the federal program: Subject: Education Stabilization Fund – Special Tests and Provisions - Wage Rate Requirements Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Number: 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Wage Rate Requirements Audit Findings: Material Weakness, Qualified Opinion Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Special Tests and Provisions – Wage Rate Requirements compliance requirements. The School Corporation did not include Davis Bacon wage rate requirements in its contract with vendor which includes labor. The School Corporation did not obtain the weekly payroll reports certifications from a construction company and its subcontractors for a building project. Context: The School Corporation expended $556,865 during the audit period on a construction project to expand the cafeteria which was charged to the ESSER III grant award (84.425U) and approved through the grant application with the Indiana Department of Education. The construction contract did not include a Davis-Bacon clause prescribing federal wage rate requirements required for construction contracts. The School Corporation did not have an internal control designed to collect the weekly payroll reports certifications from the construction company and its subcontractors, as applicable, for the construction project to verify prevailing wages were being paid during the project period. Therefore, no review was performed by management to ensure that pay rates complied with the federal wage rate requirements. The construction payments represented approximately 22.5% of the Education Stabilization Fund disbursements for the period under audit. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and will take the following corrective action: 1 - The Southwest School Corporation will ensure that Davis Bacon rules are included in any RFP using federal funds. The Development Team will monitor to ensure that all documentation is received and retained. Responsible party and timeline for completion: Chris Stitzle, Superintendent – April 2024

FINDING 2023-005 Information on the federal program: Subject: Special Education Cluster (IDEA) - Reporting Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.027X, 84.173, 84.173X Federal Award Numbers and Years (or Other Identifying Numbers): 19611-022-PN01, 20611-022-PN01, 21611-022-PN01, 22611-022-PN01, 22611-022-ARP, 23611-022-PN01, 20619-022-PN01, 21619-022-PN01, 22619-022-PN01, 22619-022-ARP, 23619-022-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Qualified Opinion Condition: The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the reporting requirements. The Cooperative had not designed or implemented adequate policies or procedures to determine that requests for reimbursement were submitted accurately and agreed to supporting documentation. There was a documented oversight, review, and approval process in place; however, the Cooperative did not adequately ensure that proper procedures were followed. Context: The School Corporation is a member of the Greene-Sullivan 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 Reporting compliance requirement. The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the reporting requirements. The Cooperative had not designed or implemented adequate policies or procedures to determine that requests for reimbursement were submitted accurately and agreed to supporting documentation. There was a documented oversight, review, and approval process in place; however, the Cooperative did not adequately ensure that proper procedures were followed. For fiscal year 2022, 51 Reimbursement Reports were tested. 14 Reimbursement Reports could not be traced to unit ledgers for expenditures, and 21 Reports did not have appropriate supporting documentation. For fiscal year 2023, 23 Reimbursement Reports were tested. Three Reimbursements Report did not agree to supporting documentation, and key line items could not be verified. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and will take the following corrective action: 1 – Greene Sullivan Special Education Cooperative will implement a procedure that includes the requirement of proper documentation for all reimbursement requests, such as the detailed history report for each request submitted. The Director will then review each request prior to submission. Responsible party and timeline for completion: Chris Stitzle, Superintendent – April 1, 2024

FINDING 2023-004 Information on the federal program: Subject: Special Education Cluster (IDEA) – Procurement and Suspension and Debarment Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.027X, 84.173, 84.173X Federal Award Numbers and Years (or Other Identifying Numbers): 19611-022-PN01, 20611-022-PN01, 21611-022-PN01, 22611-022-PN01, 22611-022-ARP, 23611-022-PN01, 20619-022-PN01, 21619-022-PN01, 22619-022-PN01, 22619-022-ARP, 23619-022-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Qualified Opinion Condition: The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the procurement and suspension an debarment requirements. The Cooperative had not designed or implemented adequate policies or procedures to ensure that proper procurement procedures for micro or small purchases were followed. There was no oversight, review, or approval process in place and documented at the Cooperative to ensure proper procedures were followed and price or rate quotations were obtained, if required, or documentation to support limited procurement procedures. 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 Procurement and Suspension and Debarment compliance requirement. Procurement Federal regulations allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisition threshold, which is set at $250,000 unless a lower, more restrictive threshold is set by a non-Federal entity. As Indiana Code has set a more restrictive threshold of $150,000, informal procurement methods are permitted when the value of the procurement does not exceed $150,000. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds. Micro-purchases, typically for those purchases $10,000 or under, and small purchase procedures for those purchases above the micro-purchase threshold, but below the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. For fiscal year 2022, three vendors, totaling $88,772, were identified as being less than the simplified acquisition threshold of $150,000, but exceeding the $10,000 micro-purchase threshold. One of the three vendors was a bankcard used to pay several different vendors; however, individual determinations of amount spent by vendor could not be determined, and thus it was considered under this threshold. All three vendors were tested. For all three, the Cooperative did not obtain price or rate quotes nor was there documentation detailing the history of procurement, which must include the reason for the procurement method used. For fiscal year 2023, six vendors, totaling $264,106, were identified as being less than the simplified acquisition threshold of $150,000, but exceeding the $10,000 micro-purchase threshold. One of the six vendors was a bankcard used to pay several different vendors; however, individual determinations of amount spent by vendor could not be determined, and thus it was considered under this threshold. All six vendors were tested. For five of the six, totaling $252,906, the Cooperative did not obtain price or rate quotes nor was there documentation detailing the history of procurement, which must include the reason for the procurement method used. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Suspension and Debarment Prior to entering into subawards and covered transactions with federal award funds, recipients are required to verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded. “Covered transactions” include but are not limited to contracts for goods and services awarded under a non-procurement transaction (i.e., grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the SAMs exclusions, collecting a certification from that vendor, or adding a clause or condition to the covered transaction with that vendor. Upon inquiry of the School Corporation in order to review the procedures in place for verifying that a vendor with which it plans to enter into a covered transaction is not suspended, debarred, or otherwise excluded, the Cooperative disclosed they relied on a clause to be included in the vendor contracts to ensure compliance. Two covered transactions that equaled or exceeded $25,000 were identified. Both transactions, totaling $192,218, were selected for testing. One of the two transactions, totaling $44,883, included the appropriate clause. For the other vendor, the Cooperative did not verify the vendor’s suspension and debarment status prior to payment. The lack of internal controls and noncompliance regarding suspension and debarment were isolated to fiscal year 2023. 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 ensure a system of internal control and procedures are in place and appropriate procurement procedures for goods and services are followed. 2 – The Cooperative will post any openings that exceed the small purchase threshold in the local newspapers, within the office, and on the cooperative website. Any and all proposals will be presented to the Cooperative Board of Directors for approval. Responsible party and timeline for completion: Chris Stitzle, Superintendent – April 1, 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 2023-002 Information on the federal program: Subject: Special Education Cluster (IDEA) - Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.027X, 84.173, 84.173X Federal Award Numbers and Years (or Other Identifying Numbers): 19611-022-PN01, 20611-022-PN01, 21611-022-PN01, 22611-022-PN01, 22611-022-ARP, 23611-022-PN01, 20619-022-PN01, 21619-022-PN01, 22619-022-PN01, 22619-022-ARP, 23619-022-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance Audit Finding: Material Weakness, Qualified Opinion Condition: The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Period of Performance compliance requirements. The Cooperative had not designed or implemented adequate policies or procedures to determine that grant expenditures were for the excess costs of providing special education and related services to children with disabilities, were in conformance with the applicable cost principles and were obligated during the award period of performance. There was no documented oversight, review, or approval process in place at the Cooperative to ensure expenditures were allowable, conformed with cost principles and were incurred during the period of performance. 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 Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Period of Performance compliance requirements. The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Period of Performance compliance requirements. The Cooperative had not designed or implemented adequate policies or procedures to determine that grant expenditures were for the excess costs of providing special education and related services to children with disabilities, were in conformance with the applicable cost principles and were obligated during the award period of performance. There was no documented oversight, review, or approval process in place at the Cooperative to ensure expenditures were allowable, conformed with cost principles and were incurred during the period of performance. The lack of internal controls was a systemic issue throughout the audit period. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and will take the following corrective action: 1 – All invoices, as well as receipts, will be documented upon receipt by the Director of Special Education at Greene Sullivan Special Education Cooperative. After this takes place, The Director of Finance at Greene Sullivan Special Education Cooperative will then create vouchers and receipts accordingly. Prior to submission, the Director of Special Education of Greene Sullivan Special Education Cooperative will verify all documents for accuracy. The Superintendent and Treasurer of Southwest School Corporation will review the documentation for the Cooperative at lease semi-annually. Responsible party and timeline for completion: Chris Stitzle, Superintendent – April 1, 2024

FINDING 2023-003 Information on the federal program: Subject: Education Stabilization Fund – Advance Draws Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs- Cost Principles Audit Finding: Material Weakness, Qualified Opinion Condition: The School Corporation requested reimbursement prior to incurring expenditures under federal grant awards. An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Activities Allowed or Unallowed, Allowable Costs- Cost Principles compliance requirements. Context: During testing disbursements charged to ESF grants, we noted advance payments were received during the audit period prior to allowable costs being incurred by the School Corporation impacting the following Education Stabilization Fund grant awards: ● The School Corporation submitted a claim for reimbursement for $43,864 from the ESSER I grant award (84.425D) which was receipted on August 24, 2021. As of August 24, 2021, the School Corporation had incurred $41,674 of grant expenditures. The remaining $2,190 was disbursed on April 12, 2022. ● The School Corporation submitted a claim for reimbursement for $148,822 from the ESSER II grant award (84.425D) which was receipted on July 28, 2021. There were no expenditures incurred as of the date of the reimbursement request. The School Corporation began incurring expenditures after the advance payment, however, as of June 30, 2022, the School Corporation had an unspent cash balance of $24,613 in the ESSER II fund because of the advance payment. The School Corporation did not request any reimbursements for the period of July 1, 2022 through June 30, 2023 and continued to incur expenditures. As of June 30, 2023, the School Corporation had an unspent cash balance of $16,145. FINDING 2023-003 (Continued) ● The School Corporation submitted two claims for reimbursements from the ESSER III grant award (84.425U) during fiscal year 2022. The first claim reimbursement was receipted on November 24, 2021, in the amount of $52,210. The second claim reimbursement request was receipted on June 22, 2022, in the amount of $144,649. The School Corporation had incurred expenditures as of the date of each claim reimbursement requests, however, the amount claimed for reimbursement exceeded expenditures incurred resulting in advance payments being received. As of June 30, 2022, the School Corporation had an unspent cash balance of $88,348 in the ESSER III fund as a result of the advance payment. The School Corporation did not request any claims for reimbursements for the period of July 1, 2022 through June 30, 2023 and continued to incur expenditures. As of June 30, 2023, the School Corporation had an unspent cash balance of $21,842 in the ESSER III fund because of the advance payments. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. Going forward the reimbursement will be prepared by the Assistant Superintendent once the funds have been spent and the Corporation Treasurer will review the reimbursement before it is submitted. Responsible Party and Timeline for Completion: The Assistant Superintendent, David Hobaugh, and the Corporation Treasurer, Kristina James, will oversee the corrective action plan and will be implemented immediately.

FINDING 2023-006 Finding Subject: Child Nutrition Cluster – Procurement, Suspension, and Debarment Summary of Finding: Internal controls were not in place to ensure compliance with requirements related to the grant agreement, specifically regarding procurement, suspension, and debarment. Contact Person Responsible for Corrective Action: Scott Weltz, Amanda Brackett Contact Phone Number and Email Address: 765-654-5585, weltzs@frankfort.k12.in.us, bracketa@frankfort.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Internal controls will be established and followed to ensure compliance with requirements related to the grant agreement. The Treasurer will review procurement procedures related to vendors outside of the co-op, both related to the ‘small-purchase’ threshold as well as verifying if vendors are suspended and/or debarred. Anticipated Completion Date: Effective immediately and ongoing

FINDING 2023-005 Finding Subject: Child Nutrition Cluster – Reporting; Special Tests and Provisions, Eligibility Summary of Finding: Internal controls were not in place to ensure compliance with requirements related to the grant agreement, specifically related to reporting and eligibility. Contact Person Responsible for Corrective Action: Scott Weltz, Amanda Brackett Contact Phone Number and Email Address: 765-654-5585, weltzs@frankfort.k12.in.us, bracketa@frankfort.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Internal controls will be established and followed to ensure compliance with requirements related to the grant agreement. The Director shall submit the report after the Treasurer reviews and verifies the information in the report. Such measures will prevent future misstatements and provide the proper internal controls. Anticipated Completion Date: Effective immediately and ongoing

FINDING 2023-004 Finding Subject: Child Nutrition Cluster – Allowable Activities & Allowable Costs / Cost Principals Summary of Finding: Internal controls were not in place to ensure compliance with requirements related to the grant agreement, specifically the requirement: Allowable Activities & Allowable Costs / Cost Principals. Contact Person Responsible for Corrective Action: Scott Weltz, Amanda Brackett Contact Phone Number and Email Address: 765-654-5585, weltzs@frankfort.k12.in.us, bracketa@frankfort.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Internal controls will be established and followed to ensure compliance with requirements related to the grant agreement. The Deputy Treasurer or designee will provide payroll distribution reports to the Director for review of payroll claims against the grant. Anticipated Completion Date: Effective immediately and ongoing