Corrective Action Plans

The Superintendent and Director of Facilities will monitor each contract that must include Davis Bacon requirements, wage rate requirements, and require the contractor to complete the prescribed Department of Labor wage rate form. Timesheets will be requested from the contractor in a timely manner. Responsible party and timeline for completion: Superintendent and Director of Facilities; Information that was requested has been provided to the best of our ability. Future contracts will have required information provided during the project, and at the completion of the project.

Finding 2023-003 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: 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 obtain the weekly payroll reports certifications from a construction company and its subcontractors for a building project. Context: The School Corporation expended $540,000 during the audit period on a construction project for the North Central High School Kitchen/Cafeteria remodel, which was charged to the ESSER III grant award (84.425U). The construction contract did 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 ensure compliance with the Davis-Bacon requirement. For the 1 sample item selected for testing ($254,377), we noted that labor costs totaled $55,299. The School Corporation did not receive the weekly payroll reports as required to ensure that pay rates complied with the federal wage rate requirements. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and will take the following corrective action. Treasurer will track future projects' labor cost. 1 - The Northeast School Corporation will ensure Davis Bacon rules are included in any RFP using federal funds. The treasurer will monitor to ensure that all documentation is received and retained. Responsible party and timeline for completion: Mark A Baker, Superintendent Angel Riley, Treasurer April 2024

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

FINDING 2023-007 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: 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: Mark A Baker, Superintendent Effective April 2024

FINDING 2023-006 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: 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 – Northeast 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: Mark A Baker, Superintendent Effective April 2024

FINDING 2023-005 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: The Superintendent and Treasurer of Northeast School Corporation will review the documentation for the Cooperative at least semi-annually. Responsible party and timeline for completion: Mark A Baker, Superintendent Angel Riley, Treasurer April 2024

Finding 2023-004 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: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013 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 $2,354,885 during the audit period on equipment acquisitions for a new HVAC system and chiller at the North White Middle-High School building which included labor installation costs subject to federal Davis Bacon wage rate requirements. Each project had a separate vendor for a total of two vendor contracts during the audit period subject to testing for Davis Bacon wage rate requirements. The vendor contracts did not include a Davis-Bacon clause prescribing federal wage rate requirements required for construction contracts with labor installation costs. The School Corporation did not have an internal control designed to collect the weekly payroll reports certifications from a construction company and its subcontractors, as applicable, for building projects 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. For the period July 1, 2021 through June 30, 2023, $925,844 was disbursed related to these building projects and charged to the ESSER II grant award (84.425D). For the period July 1, 2021 through June 30, 2023, $1,429,041 was disbursed related to these building projects and charged to the ESSER III grant award (84.425U). The construction payments represented approximately 80.1% of the Education Stabilization Fund expenditures for the audit period. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. The Corporation will make sure all contracts using federal dollars will have the Davis-Bacon clause written in the contract. The project manager will request weekly time sheets for all labor installation and verify the work has been completed. Responsible Party and Timeline for Completion: The Superintendent, Nicholas Eccles, will oversee the corrective action plan regarding the Davis-Bacon clause in future contracts which will be implemented by June 30, 2024. The Building/Maintenance Director, Dean Cook, will oversee the corrective action plan regarding the verification of time sheets for labor installation which will be implemented by June 30, 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 Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs- Cost Principles Audit Finding: Material Weakness, Other Matters 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 the ESSER I grant award, tracked in Fund 7940, and the ESSER III grant award, tracked in Fund 7932, had a positive cash balance of $2,718 and $35,661, respectively, at June 30, 2023 as a result of advance payments received during fiscal year 2023. The School Corporation submitted a request for reimbursement on November 15, 2022 for $21,745 from the ESSER I grant award and $565,876 from the ESSER III grant award, respectively. These requests for reimbursements were partially supported by disbursements incurred as of the date of the request, however, partially include requests for advance payments that were still not fully expended as of June 30, 2023. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. If there are any posting corrections after a reimbursement has been made and received, the Corporation Treasurer will contact IDOE (Indiana Department of Education) asking whether they would like the difference between the reimbursement and the new disbursement amount paid back to DOE or spent down within a specific time period. Responsible Party and Timeline for Completion: The Corporation Treasurer, Emma Conwell, will oversee the corrective action plan which will be implemented by June 30, 2024.

FINDING 2023-003 Finding Subject: Child Nutrition Cluster – Procurement and Suspension and Debarment Summary of Finding: Procurement: For one of the two vendors tested for small purchases an adequate number of price or rate quotes were not obtained. Suspension and Debarment: The School Corporation purchased bread, dairy produce and commodities through Region 8 Education Service Center (Region 8) However, Region 8 had not received the SFA – only Cooperative classification from IDOE for fiscal years 2021-2022 and 2022-2023. As such, the School Corporation could not rely on Region 8’s verification of suspension and debarment and was required to complete their own verification. One covered transaction was identified and tested that equaled or exceeded $25,000. For the noted transaction, the School Corporation did not verify that the vendor was not excluded or disqualified from participation in federal award programs. Contact Person Responsible for Corrective Action: Susan Loftain Contact Phone Number and Email Address: (260) 693-2007 loftains@sgcs.k12.in.us Views of Responsible Officials: Option 1: “We concur with the finding.” Description of Corrective Action Plan: Procurement: All vendors procured through Region 8 we will need to take action to secure bids and quotes and keeps copies and make we are within compliance Suspension and Debarment: We will be sure to complete our own verifications and not rely on Region 8 to check on suspension and debarment Anticipated Completion Date: Today 2/28/24

FINDING 2023-004 Finding Subject: Education Stabilization Fund – Equipment and Real Property Management Summary of Finding: An effective internal control system, which would include segregation of duties, was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the following compliance requirements: Equipment and Real Property Management The School Corporation hired a fixed asset consultant to provide a fixed asset report that was to contain all inventory through June 30, 2023. During fiscal year 2021-2022, the School Corporation purchased equipment a minibus for $56,225 and a band trailer for $12,234 with ESSER II and ESSER III funds. The mini bus or the band trailer were not added to the property record which would include a description of the property, a serial number or other identification number, the source of funding for the property (including the federal award identification number (FAIN)), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property. The School did not have in place documentation of reviewing or resolving discrepancies in their physical inventory at least every two years. Contact Person Responsible for Corrective Action: Amber Rushton Contact Phone Number and Email Address: Phone Number: (765) 489-4543 Email: arushton@nettlecreek.k12.in.us Views of Responsible Officials: “We concur with the finding.” Description of Corrective Action Plan: The Business Manager will develop a list of property purchased in the last two years. This list will be sent to the fixed asset consultant to update previous purchases. The Business Manager will develop an ongoing spreadsheet to submit to the fixed asset consultant annually to provide information on purchased assets. Anticipated Completion Date: June 30, 2024

FINDING 2023-003 Finding Subject: Education Stabilization Fund – Reporting Summary of Finding: An effective internal control system, which would include segregation of duties, was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the following compliance requirements: Reporting The School Corporation had not designed, nor implemented a system of internal control to ensure that the annual Elementary and Secondary School Emergency Relief (ESSER) annual Data Collection reports (Reports) were complete and accurately submitted. The Reports were prepared by one employee without an oversight or review process in place to prevent, or detect and correct, errors. Additionally, for ESSER II, Year 1, annual report tested the School Corporation could provide supporting documentation that did not agree with the ESSER II, Year 1, annual report. The lack of internal controls was a systemic issue throughout the audit period. The noncompliance was isolated from ESSER 1I, Year 1 report. Contact Person Responsible for Corrective Action: Amber Rushton Contact Phone Number and Email Address: Phone Number: (765) 489-4543 Email: arushton@nettlecreek.k12.in.us Views of Responsible Officials: “We concur with the finding.” Description of Corrective Action Plan: The Business Manager will prepare annual reports for grants and the Director of Learning and/or Superintendent will review and sign-off reports before submission. Anticipated Completion Date: June 30, 2024

The district has contracted with the ESC of Central Ohio for an accountant to help with the timely filing of all federal grant requirements. By timely completing project cash requests we will be able to see if variances require changes in the grant budgets. This will minimize correcting entries in the last week of the fiscal year where mistakes tend to happen in the rush to close the year.

FINDING 2023-006 Finding Subject: COVID-19 Education Stabilization Fund – Allowable Costs/Cost Principles Summary of Finding: The School Corporation did not have effective internal controls over the ESSER funds and there was noncompliance in regards to the ESSER funds. Employee pay did not equal what transferred and supporting documentation for substitute pay and payment of sick days when school was closed. Contact Person Responsible for Corrective Action: Jamesi Lemon and Melanie Summers Contact Phone Number and Email Address: (260) 499-2400; jlemon@lakelandlakers.net/msummers@lakelandlakers.net Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: INDIANA STATE BOARD OF ACCOUNTS 30 A spreadsheet has been created to track the substitutes and the classes they are covering. Pay scales are also now included in the employee handbooks, so pay can be calculated correctly and tracked. Any transfers of payroll expenses are now completed monthly to ensure the correct amounts are being charged to the ESSER funds. Anticipated Completion Date: Immediately

FINDING 2023-005 Finding Subject: COVID-19 Education Stabilization Fund - Reporting Summary of Finding: The School Corporation had a lack of internal controls over the ESSER reporting to the IDOE. There was no review process in place to prevent, or detect and correct, errors. Contact Person Responsible for Corrective Action: Jamesi Lemon Contact Phone Number and Email Address: (260) 499-2400; jlemon@lakelandlakers.net Views of Responsible Officials: We concur with the findings. Description of Corrective Action Plan: The Director of Business Operations and Director of Staff and Student Success will meet to review the annual data reports for accuracy before they are submitted to the IDOE. The meeting will be logged and reports signed off by both individuals. Anticipated Completion Date: Immediately

FINDING 2023-004 Finding Subject: COVID-19 Education Stabilization Fund – Equipment and Real Property Management Summary of Finding: The School Corporation has a lack of internal controls over the asset records. Two floor scrubbers purchased during the audit period were missing from the asset list. Contact Person Responsible for Corrective Action: Jamesi Lemon Contact Phone Number and Email Address: (260) 499-2400; jlemon@lakelandlakers.net Views of Responsible Officials: We concur with the finding. INDIANA STATE BOARD OF ACCOUNTS 29 Description of Corrective Action Plan: The Director of Business Operations will maintain a spreadsheet of assets purchased and disposed. The spreadsheet will then be compared to the list completed by the outside asset management company to ensure assets are recorded properly in the records. Anticipated Completion Date: Immediately

FINDING 2023-003 Finding Subject: Child Nutrition Cluster-Reporting Summary of Finding: The School Corporation did not have effective internal controls over the Child Nutrition Cluster (CNC) reporting. The Claims for Reimbursement were prepared by one employee and not reviewed by a second employee to ensure compliance. Contact Person Responsible for Corrective Action: Jamesi Lemon Contact Phone Number and Email Address: (260) 499-2400; jlemon@lakelandlakers.net Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Claims for Reimbursement will be prepared by the Food Service Director and the Director of Business Operations will review the claims for compliance. The claims will then be initialed signaling they have been reviewed. Anticipated Completion Date: Immediately

Name of Contact Person: Kimberly Irvine, DSS Director Corrective Action: The County created a 2nd Party Review Error Summary Log to record all 2nd Party Reviews that require corrections to a case. 2nd Party Review forms are completed and handed out to caseworkers as previously with the exception that the Reviewer will log the ones that need corrections. This process was implemented and used from January through August 2023. After that, there was a management change which caused the log not to be followed up on. The use of the log has been reinstated as of March 13, 2024. A meeting will be held on March 21, 2024 with the Reviewers to ensure they are using this procedure. The program manager will check the log monthly to ensure that it is up to date and being used correctly. Proposed Completion Date: March 21, 2024.

Name of Contact Person: Kimberly Irvine, DSS Director Corrective Action: The County will develop a 2nd Party Review form that will be used to check completed applications for accuracy in applying policy and to assure all verifications have been uploaded to the NCFAST system. Proposed Completion Date: October 31, 2023.

FINDING 2023-002 Information on the federal program: Subject: Special Education Cluster (IDEA) –Earmarking Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 20611-047-PN01, 21611-047-PN01, 20619-047-PN01, 21619-047-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, and Earmarking Audit Finding: Material Weakness, Other Matters 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 earmarking portion of the Matching, Level of Effort, Earmarking compliance requirement. Context: The School Corporation did not meet the earmarking requirements for the grants, which concluded during the audit period. Both the Special Education Grants to States and Special Education Preschool Grants required a proportionate share of their funding to be spent on non-public school students with disabilities. The 20611-047-PN01, 20619-047-PN01, 21611-047-PN01, 21619-047-PN01 grant awards were fully expended during the audit period with minimum Non-Public Proportionate Share earmarking requirements of $24,977, $1,171, $22,088, and $866, respectively. There was no supporting documentation provided to support any non-public school expenditures were incurred towards the meeting the non-public proportionate share requirement. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding. The Cooperative has developed a written procedure for documenting expenditures related to the proportionate share earmarking requirement at the School Corporation level to address this issue going forward. The School Corporation will maintain the proper documentation to support the Non-Public Proportional Share earmarking requirement and validate the earmarking requirement is met at the end of the grant’s period of performance or once fully expended. Responsible party and timeline for completion: The correction action plan has been put into place for the 2023-24 school year. Tracy Albertson, Director of Finance and Sarah Claton, Director of Cooperative School Services, will oversee the corrective action plan.

CORRECTIVE ACTION PLAN OF CURRENT AUDIT FINDINGS June 30, 2023 Finding 2023-001 Information on the federal program: Subject: Special Education Cluster – Suspension and Debarment Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 20611-047-PN01, 21611-047-PN01, 22611-047-PN01, 20619-047-PN01, 21619-047-PN01, 22619-047-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Material Weakness Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the program grant agreements and the compliance requirements related to suspension and debarment. Context: The School Corporation is a member of the Cooperative School Services (Cooperative). The Cooperative operated the special education programs on behalf of the School Corporation and managed the special education grant funds. As the grant agreement was between the Indiana Department of Education and the School Corporation, the School Corporation was responsible for compliance with the grant agreement and the Suspension and Debarment compliance requirements. During fiscal year 2022, The School Corporation did not have adequate internal controls in place to ensure the Cooperative complied with the suspension and debarment requirements. The Special Education Director obtained suspension and debarment certifications for contracted vendors over $25,000 without an oversight or review process. The lack of controls over suspension and debarment requirements was isolated to fiscal year 2022. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding. Two Cooperative employees will check and initial the Procurement and Suspension and Debarments documentation. Management of the School Corporation will request supporting documentation from Cooperative to validate procurement and suspension and debarment procedure were performed to satisfy federal regulations. Responsible party and timeline for completion: The corrective action plan has been put into place by both parties. Sarah Claton, Director of Cooperative School Services, will oversee the corrective action plan.

Finding 2023-007 – Education Stabilization Fund - Special Tests and Provisions - Wage Rate Requirement Contact Person Responsible for Corrective Action: Brad DeRome Contact Phone Number: X Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We will ensure all construction projects using federal funding will meet the wage rate requirements. Anticipated Completion Date: March 2024

Finding 2023-006 – Education Stabilization Fund - Reporting Contact Person Responsible for Corrective Action: Brad DeRome Contact Phone Number: X Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We will ensure all ESSER reports include accurate information that agree to the underlying disbursement records. Anticipated Completion Date: Next ESSER reports due in FY24

Finding 2023-005 – Title I Grants to Local Educational Agencies - Maintenance of Effort Contact Person Responsible for Corrective Action: Brad DeRome Contact Phone Number: X Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We will ensure all expenses are recorded correctly and any capital items over the threshold are properly recorded to capital object codes. Anticipated Completion Date: March 2024

Finding 2023-004 – Title I Grants to Local Educational Agencies - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Brad DeRome Contact Phone Number: X Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We will ensure all payroll amounts recorded to Title I are reviewed to ensure they represent Title I payroll activity only. Anticipated Completion Date: March 2024

FINDING 2023-001 Finding Subject: Child Nutrition Cluster – Eligibility Summary of Finding: The Food Service Director was responsible for running the direct certification match report monthly from the Indiana Department of Education and uploading it to the school lunch point-of-sale system. The School Corporation did not have a proper system of oversight or review to ensure that all students on the direct certification match report were entered accurately into the point-of-sale system. We recommended that the School Corporation's management establish a system of internal control to ensure compliance and comply with the Eligibility compliance requirement Contact Person Responsible for Corrective Action: Nick Alessandri Contact Phone Number and Email Address: 219-962-7551 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: River Forest Community School Corporation is now part of the Community Eligibility Provision (CEP) and therefore the direct certification process will no longer take place. In the event that we are no longer CEP and begin the direct certification process, we will implement a process of internal controls that ensure proper oversight and review to ensure all students are entered accurately into our point-of-sale system. Anticipated Completion Date: July 1, 2023