Corrective Action Plans

Finding 1182827 (2025-008)

Material Weakness 2025

State of Vermont

VT

Questioned Costs Special Tests & Provisions Eligibility § 200.303

Reference Number: 2025-008 Prior Year Finding: No Federal Agency: U.S. Department of Labor State Department Name: Department of Labor Federal Program: Unemployment Insurance Assistance Listing Number: 17.225 Award Number and Year: 23A60UI038010 (1/1/2022 – 9/30/2024) 23A60UR000010 (1/1/2023 – 9/30/2...

Reference Number: 2025-008 Prior Year Finding: No Federal Agency: U.S. Department of Labor State Department Name: Department of Labor Federal Program: Unemployment Insurance Assistance Listing Number: 17.225 Award Number and Year: 23A60UI038010 (1/1/2022 – 9/30/2024) 23A60UR000010 (1/1/2023 – 9/30/2025) 24A60UR000093 (1/1/2024 – 9/30/2026) Compliance Requirement: Special Tests and Provisions: UI Reemployment Programs: RESEA Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Recommendation: The Department should update its internal controls to ensure that RESEA procedures are followed, that cases are properly documented and appropriate actions are taken when participants fail to meet program requirements. Views of responsible officials: Management agrees with the finding. Corrective Acton Plan: In September of 2025, the RESEA program in Vermont was transitioned from the VDOL Unemployment Insurance division to the VDOL Workforce Development division. This transition included a change of supervision for the RESEA Facilitators from a centralized supervisor to supervision by the VDOL American Job Center Regional Managers. Training was provided to these Regional Job Center Managers to help them to support their new RESEA staff. The RESEA Program Administrator will meet with the specific RESEA Facilitator, and the Regional Manager associated with these cases to provide additional technical assistance. This will include on-site visits and virtual follow-up meetings. Additionally, the RESEA Program Administrator is reviewing the current program monitoring plan and will be making some changes to include a quarterly case monitoring requirement for the regional managers in addition to the current monthly Peer Review monitoring. Scheduled Completion Date of Corrective Action Plan: March 31, 2026 Contacts for Corrective Action Plan: Jay Ramsey, Director, Workforce Development, jay.ramsey@vermont.gov

View Audit 394235

Finding 1182826 (2025-007)

Material Weakness 2025

State of Vermont

VT

Questioned Costs Allowable Costs / Cost Principles Period of Performance § 200.303 § 200.308 § 200.309 § 200.403

Reference Number: 2025-007 Prior Year Finding: 2024-010; 2023-008: and 2022-017 Federal Agency: U.S. Department of Labor State Agency: Vermont Department of Labor Federal Program: Unemployment Insurance Assistance Listing Number: 17.225 Award Number and Period: 25A55UI000119 (10/1/2024 – 12/31/2027)...

Reference Number: 2025-007 Prior Year Finding: 2024-010; 2023-008: and 2022-017 Federal Agency: U.S. Department of Labor State Agency: Vermont Department of Labor Federal Program: Unemployment Insurance Assistance Listing Number: 17.225 Award Number and Period: 25A55UI000119 (10/1/2024 – 12/31/2027) Compliance Requirement: Period of Performance Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Recommendation: We recommend the Department review and enhance its procedures and controls to ensure that, prior to charging costs to the program, they are incurred within an award’s allowable period of performance and that payments are reviewed and approved by a supervisor who has knowledge of costs that are allowable under the program. Views of responsible officials: Management agrees with the finding. Corrective Acton Plan: The Department will review its procedures and internal controls and update as necessary to ensure that all expenditures incurred on an award fall within the allowable period of performance. Scheduled Completion Date of Corrective Action Plan: June 30, 2026 Contacts for Corrective Action Plan: Chad Wawrzyniak, Chief Financial Officer, chad.wawrzyniak@vermont.gov

View Audit 394235

Finding 1182825 (2025-006)

Material Weakness 2025

State of Vermont

VT

Internal Control / Segregation of Duties Questioned Costs Material Weakness § 200.303

Reference Number: 2025-006 Prior Year Finding: 2024-008; 2023-005; and 2022-012 Federal Agency: Department of Labor State Agency: Vermont Department of Labor Federal Program: Unemployment Insurance Assistance Listing Number: 17.225 Award Number and Period: 25A55UI000119 (10/1/2024 – 12/31/2027) 24A5...

Reference Number: 2025-006 Prior Year Finding: 2024-008; 2023-005; and 2022-012 Federal Agency: Department of Labor State Agency: Vermont Department of Labor Federal Program: Unemployment Insurance Assistance Listing Number: 17.225 Award Number and Period: 25A55UI000119 (10/1/2024 – 12/31/2027) 24A55UI000063 (10/1/2023 – 12/31/2026) UI370952155A50 (9/1/2021 – 5/22/2025) 23A60UB000019 (8/3/2023 – 5/22/2025) 23A60UB000024 (4/1/2023 – 5/22/2025) 24A60UD000052 (8/20/2024 – 8/20/2027) UI347462055A50 (8/20/2024 – 8/20/2027) 23A60UD000013 (7/14/2023 – 7/14/2026) 25A60UD000067 (10/1/2024 – 9/30/2027) Compliance Requirement: Reporting Type of Finding: Material Weakness in Internal Control over Compliance Recommendation: We recommend that policies and procedures be implemented to ensure that all reports are reviewed by an authorized State official prior to submission and that supporting documentation providing evidence of supervisory review is maintained and available for audit. Views of responsible officials: Management agrees with the finding. Corrective Acton Plan: These reports are filed by our Labor Market Information division on behalf of the UI Division. The LMI employee responsible for these reports takes the data from a server/system generated report and enters it into a federal reporting system. Department will review internal controls and update as necessary to ensure that all required reports are filed timely and accurately and that reports are reviewed and approved by authorized State officials prior to submission. From now on the employee responsible for these reports will have their immediate supervisor review both reports to certify and signoff that the submitted report matches the system generated report and that they were submitted timely. Scheduled Completion Date of Corrective Action Plan: March 31, 2026 Contacts for Corrective Action Plan: Kristine Murphy, Director, Unemployment Insurance, kristin.murphy@vermont.gov Chad Wawrzyniak, Chief Financial Officer, chad.wawrzyniak@vermont.gov

View Audit 394235

Finding 1182824 (2025-005)

Material Weakness 2025

State of Vermont

VT

Questioned Costs Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

Reference Number: 2025-005 Prior Year Finding: No Federal Agency: U.S. Department of Housing and Urban Development State Agency: Agency of Commerce and Community Development Federal Program: Community Development Block Grants/State's Program and Non-Entitlement Grants in Hawaii Assistance Listing Nu...

Reference Number: 2025-005 Prior Year Finding: No Federal Agency: U.S. Department of Housing and Urban Development State Agency: Agency of Commerce and Community Development Federal Program: Community Development Block Grants/State's Program and Non-Entitlement Grants in Hawaii Assistance Listing Number: 14.228 Award Number and Year: B-20-RH-50-0001 (1/17/2022 - 2/1/2029) B-22-RH-50-0001 (3/27/2023 - 9/1/2029) B-23-RH-50-0001 (7/1/2023 - 9/1/2030) B-22-DC-50-0001 (7/1/2022 - 9/1/2029) Compliance Requirement: Reporting – Federal Funding Accountability and Transparency Act (FFATA) Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Recommendation: We recommend the Agency review its procedures and internal controls to ensure that all required subawards and subaward modifications are reported in accordance with FFATA requirements. Views of responsible officials: Management agrees with the finding. Corrective Acton Plan: We have developed specific fields in the online grants management system, GEARS to manage the process of input into SAM.GOV of grant agreements and amendments by the execution date. In addition, the SAM.GOV system clearly identifies the “Subaward Date” stating “enter the date you have signed the subaward.” Staff have been trained appropriately on both GEARS and SAM.GOV to ensure the correct Subaward Date is entered. Scheduled Completion Date of Corrective Action Plan: Completed Contacts for Corrective Action Plan: Ann Karlene Kroll, DHCD Federal Programs Director, annkarlene.kroll@vermont.gov

View Audit 394235

Finding 1182823 (2025-004)

Material Weakness 2025

State of Vermont

VT

Eligibility Reporting Questioned Costs § 200.303

Reference Number: 2025-004 Prior Year Finding: 2024-004 Federal Agency: U.S. Department of Agriculture State Agency: Agency of Human Services Federal Program: SNAP Cluster Assistance Listing Number: 10.551, 10.561 Award Number and Year: 4VT402513 (10/1/2023 – 9/30/2024) 4VT433933 (10/1/2023 – 9/30/2...

Reference Number: 2025-004 Prior Year Finding: 2024-004 Federal Agency: U.S. Department of Agriculture State Agency: Agency of Human Services Federal Program: SNAP Cluster Assistance Listing Number: 10.551, 10.561 Award Number and Year: 4VT402513 (10/1/2023 – 9/30/2024) 4VT433933 (10/1/2023 – 9/30/2026) 4VT437533 (10/1/2023 – 9/30/2025) Compliance Requirement: Special Tests and Provisions – ADP System for SNAP Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance Recommendation: We recommend that the Agency review and enhance procedures and controls to ensure that eligibility case reviews are performed timely, accurately, and are properly documented. Views of responsible officials: Management agrees with the finding. Corrective Action Plan: A majority of the findings from the 2025 audit predate the completion of corrective actions associated with Audit 2024-004. Because the corrective action completion date was April 18, 2025, these issues resulted in repeat findings related to supervisory case reviews. To address this, the 3SquaresVT Food and Nutrition Team will review the findings with ESD Operations and present examples, along with refresher training on the Supervisor Case Review (SCR) process, at the District Directors Meeting on February 11, 2026. In addition, a new column will be added to the SCR tracking spreadsheet to allow supervisors to document the date corrective actions were completed when revisions are required following a review. The refresher training and the updated SCR tracking spreadsheet are expected to prevent the recurrence of these findings during the 2026 Single Audit. Scheduled Completion Date of Corrective Action Plan: February 11, 2026 Contacts for Corrective Action Plan: Jessica Duranleau, ESD Program Manager, jessica.duranleau@vermont.gov Leslie Wisdom, Food and Nutrition Program Director, leslie.wisdom@vermont.gov Peter Moino, AHS Director of Internal Audit, peter.moino@vermont.gov

View Audit 394235

Finding 1182821 (2025-003)

Material Weakness 2025

State of Vermont

VT

Questioned Costs Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

Reference Number: 2025-003 Prior Year Finding: 2024-003 Federal Agency: U.S. Department of Agriculture State Agency: Agency of Agriculture Federal Program: Dairy Business Innovation Initiatives Assistance Listing Number: 10.176 Award Number and Year: 21DBIVT1004 (10/31/2021 – 10/30/2024), AM22DBIVT1...

Reference Number: 2025-003 Prior Year Finding: 2024-003 Federal Agency: U.S. Department of Agriculture State Agency: Agency of Agriculture Federal Program: Dairy Business Innovation Initiatives Assistance Listing Number: 10.176 Award Number and Year: 21DBIVT1004 (10/31/2021 – 10/30/2024), AM22DBIVT1015 (9/30/2022 – 9/29/2025), AM21DBIVT1011 (9/30/2022 – 9/29/2026), Compliance Requirement: Reporting – Federal Funding Accountability and Transparency Act (FFATA) Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Recommendation: We recommend the Agency complete implementation of its corrective action plan from the prior year. It should review its procedures and internal controls to ensure that all required subawards and subaward modifications are reported timely to SAM.gov in accordance with FFATA requirements and that all previously issued subawards are reported. Views of responsible officials: Management agrees with the finding. Corrective Action Plan: The business office will ensure that subrecipient grants containing federal funding that meet the FFATA reporting threshold are marked as “FFATA reportable” upon grant execution in the Agency’s grants and contracts workbook. The Financial Directors will then confirm that all executed agreements that meet the FFATA reporting requirement have been entered and submitted into the appropriate Federal system by the last business day of each month. Scheduled Completion Date of Corrective Action Plan: 4/30/26 Contacts for Corrective Action Plan: Amy Mercier, Financial Director, amy.mercier@vermont.gov Karen Mae Smith, Financial Director, karenmae.smith@vermont.gov

View Audit 394235

Finding 1182816 (2025-002)

Material Weakness 2025

Southwestern Oregon Community College

OR

Matching / Level of Effort / Earmarking Questioned Costs Student Financial Aid § 200.303

Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College evaluate its policies and procedures around reporting to COD to ensure that information is reported accurately and timely and to retain evidence of the key control having occurred. E...

Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College evaluate its policies and procedures around reporting to COD to ensure that information is reported accurately and timely and to retain evidence of the key control having occurred. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Additional staff member will review COD reports before they are submitted via EdConnect. Name(s) of the contact person(s) responsible for corrective action: Laura Sneddon Planned completion date for corrective action plan: April 2026

View Audit 394224

Finding 1182814 (2025-001)

Material Weakness 2025

Southwestern Oregon Community College

OR

Student Financial Aid Matching / Level of Effort / Earmarking Reporting § 200.303

Student Financial Assistance Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the College implement changes in process and procedures for NSLDS enrollment reporting and implement an internal control that ensures reporting is both timely and accurate. Expla...

Student Financial Assistance Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the College implement changes in process and procedures for NSLDS enrollment reporting and implement an internal control that ensures reporting is both timely and accurate. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Continue to review policies and procedures for accurate reporting. Investigate and identify discrepancies being exported by the Student Information System (Jenzabar). Have additional staff member review file and sign off before the data is submitted. Name(s) of the contact person(s) responsible for corrective action: Laura Sneddon Planned completion date for corrective action plan: June 2026

View Audit 394224

Finding 1182790 (2025-001)

Material Weakness 2025

City of Temecula

CA

Matching / Level of Effort / Earmarking Special Tests & Provisions Subrecipient Monitoring § 200.303 § 200.326

2025-001 Program: Nationally Significant Freight and Highway Projects Financial Assistance Listing Number: 20.934 Federal Agency: U.S. Department of Transportation Pass-through: California Department of Transportation Award Year: 2019 Grant Award Number: INFRALUL-5459(031) Compliance Requirements: S...

2025-001 Program: Nationally Significant Freight and Highway Projects Financial Assistance Listing Number: 20.934 Federal Agency: U.S. Department of Transportation Pass-through: California Department of Transportation Award Year: 2019 Grant Award Number: INFRALUL-5459(031) Compliance Requirements: Special Tests and Provisions – Wage Rate Requirements Type of Finding: Material Weakness in Internal Control over Compliance and Material Instance of Noncompliance Management’s Response: We concur. Views of Responsible Officials and Corrective Action: During most of the fiscal year (July through April), the City monitored certified payroll reports (CPRs) monthly as part of its construction oversight procedures. Documentation of this monitoring was maintained through email communications and supporting records. In April 2025, following the FY24 Single Audit, the City evaluated its procedures and implemented enhanced controls to better align with federal requirements by requiring weekly monitoring and tracking of CPR submissions. These enhanced procedures were implemented to strengthen internal controls over compliance with federal prevailing wage requirements. Beginning in May 2025, CHA Consulting (formerly Falcon Engineering), the City’s outside consultant, began providing a weekly certified payroll tracking spreadsheet and the requested payroll documentation for selected contractors to the City’s Project Manager for review. The City documented the receipt, review, and follow-up actions through email correspondence and maintained supporting records of these activities. In addition, Public Works staff and the City’s consultants responsible for contract administration and labor compliance monitoring were provided updated guidance regarding federal prevailing wage requirements, including the requirement for weekly certified payroll submissions and documentation of review. Project Manager oversight was incorporated into the process to verify the accuracy of the certified payroll tracking log and ensure that reviews are performed consistently. This oversight provides an additional level of verification that monitoring procedures are conducted in accordance with federal requirements. Although the City enhanced its monitoring procedures, contractors and subcontractors did not always submit certified payroll reports within seven days as required under 29 CFR §3.4. The City continues to reinforce timely submission requirements with contractors and monitors compliance through the weekly tracking process. When certified payroll submissions are not received within the required timeframe, the City follows up with the contractor requesting immediate submission and documents the corrective actions taken. The City remains committed to strengthening its monitoring procedures to ensure timely submission, tracking, and documented review of certified payroll reports. In the event of payroll delinquencies, the City will take appropriate follow-up actions with contractors and may withhold progress payments when necessary to enforce compliance. In addition, the City is implementing new contract provisions in federally funded Public Works contracts to establish clear authority and enforce compliance with federal labor standards. These provisions include: • Requiring weekly certified payroll reporting in accordance with federal regulations • Authorizing the withholding of progress payments for non-compliance • Requiring contractors to communicate labor compliance requirements to all subcontractors • Requiring the use of electronic certified payroll reporting systems, where applicable • Allowing the City to conduct payroll audits and worker interviews as permitted under federal labor compliance regulations These contract provisions are intended to further strengthen the City’s internal controls and ensure compliance with federal prevailing wage requirements on federally funded projects. The City will continue to monitor the effectiveness of these procedures and will update its internal controls as necessary to ensure ongoing compliance with federal labor compliance requirements. Name of Responsible Person: Jennifer Hennessy, Director of Finance Projected Implementation Date: 6.30.2026

View Audit 394175

Finding 1182675 (2025-008)

Material Weakness 2025

School City of East Chicago

IN

Matching / Level of Effort / Earmarking Allowable Costs / Cost Principles Equipment & Real Property Management § 200.1 § 200.302 § 200.303 § 200.305 § 200.313

FINDING 2025-008 Finding Subject: COVID-19 - Education Stabilization Fund – Condition of Records Federal Agency: Department of Education Audit Findings: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Lela Simmons, CFO Contact Phone Number and Email Address: 219...

FINDING 2025-008 Finding Subject: COVID-19 - Education Stabilization Fund – Condition of Records Federal Agency: Department of Education Audit Findings: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Lela Simmons, CFO Contact Phone Number and Email Address: 219 391 4100 Ex 12365: lesimmons@ecps.org Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: Internal controls will be put in place to ensure all COVID 19 ESSER Funds are reported accurately to the State and Federal Department of Education. Reimbursements will be attached to State Email for disbursement. Anticipated Completion Date: We anticipate having the above corrective action plan in place by October 31, 2026

View Audit 394104

Finding 1182669 (2025-007)

Material Weakness 2025

School City of East Chicago

IN

Subrecipient Monitoring Eligibility Material Weakness § 200.303 § 200.334 § 200.77 § 200.78

FINDING 2025-007 Finding Subject: Title I Grants to Local Educational Agencies - Eligibility Federal Agency: Department of Education Audit Findings: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Lela Simmons, CFO Contact Phone Number and Email Address: 219 391...

FINDING 2025-007 Finding Subject: Title I Grants to Local Educational Agencies - Eligibility Federal Agency: Department of Education Audit Findings: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Lela Simmons, CFO Contact Phone Number and Email Address: 219 391 4100 Ex 12365: lesimmons@ecps.org Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: The district will strengthen internal controls for ensure that all documentation are obtained from the Non- Pubs and filed accordingly in the Federal Department Office. Anticipated Completion Date: We anticipate having the above corrective action plan in place by October 31, 2026

View Audit 394104

Finding 1182667 (2025-006)

Material Weakness 2025

School City of East Chicago

IN

Special Tests & Provisions Subrecipient Monitoring Material Weakness § 200.303

FINDING 2025-006 Finding Subject: Title I Grants to Local Educational Agencies - Special Tests and Provisions - Annual Report Card, High School Graduation Rate Audit Findings: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Lela Simmons, CFO Contact Phone Number...

FINDING 2025-006 Finding Subject: Title I Grants to Local Educational Agencies - Special Tests and Provisions - Annual Report Card, High School Graduation Rate Audit Findings: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Lela Simmons, CFO Contact Phone Number and Email Address: 219 391 4100 Ex 12365: lesimmons@ecps.org Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: The district will implement strengthen internal controls to ensure of that exit conference for each student withdrawal will be held and all documentation will be files. All documents will be scanned to student software. All students will be properly document to the state and local entities. Anticipated Completion Date: We anticipate having the above corrective action plan in place by October 31, 2026

View Audit 394104

Finding 1182665 (2025-005)

Material Weakness 2025

School City of East Chicago

IN

School Nutrition Programs Internal Control / Segregation of Duties § 200.302 § 200.303 § 200.328 § 200.329

FINDING 2025-005 Finding Subject: Child Nutrition Cluster - Reporting Audit Findings: Material Weakness, Other Matters Contact Person Responsible for Corrective Action: Lela Simmons, CFO Contact Phone Number and Email Address: 219 391 4100 Ex 12365: lesimmons@ecps.org Views of Responsible Officials:...

FINDING 2025-005 Finding Subject: Child Nutrition Cluster - Reporting Audit Findings: Material Weakness, Other Matters Contact Person Responsible for Corrective Action: Lela Simmons, CFO Contact Phone Number and Email Address: 219 391 4100 Ex 12365: 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 upgrade all POS software throughout the district. Students will be required to scan Student IDs to account for all meals served. Counts will be check weekly to ensure Federal report is accurate. Anticipated Completion Date: We anticipate having the above corrective action plan in place by October 31, 2026

View Audit 394104

Finding 1182659 (2025-004)

Material Weakness 2025

School City of East Chicago

IN

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.1 § 200.303 § 200.317 § 200.318 § 200.319

FINDING 2025-004 Finding Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Lela Simmons, CFO Contact Phone Number and Email Address: 219 391 4100 Ex 12365: lesimmons@ecps.o...

FINDING 2025-004 Finding Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Lela Simmons, CFO Contact Phone Number and Email Address: 219 391 4100 Ex 12365: lesimmons@ecps.org Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: All purchases that exceed the micro purchase threshold will require three quotes to ensure the vendor is in compliance and all quotes will be attached to the APV. Purchases exceeding $150,000 will require the formal bidding process. This will ensure all documents are available upon request. Anticipated Completion Date: We anticipate having the above corrective action plan in place by October 31, 2026

View Audit 394104

Finding 1182653 (2025-003)

Material Weakness 2025

School City of East Chicago

IN

Allowable Costs / Cost Principles School Nutrition Programs Internal Control / Segregation of Duties § 200.303

FINDING 2025-003 Finding Subject: Child Nutrition Cluster - Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Special Tests and Provisions - Non-Profit School Food Service Accounts Audit Findings: Material Weakness Contact Person Responsible for Corrective Action: Lela Simmons, CFO C...

FINDING 2025-003 Finding Subject: Child Nutrition Cluster - Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Special Tests and Provisions - Non-Profit School Food Service Accounts Audit Findings: Material Weakness Contact Person Responsible for Corrective Action: Lela Simmons, CFO Contact Phone Number and Email Address: 219 391 4100 Ex 12365: lesimmons@ecps.org Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: The Food Service director responsibilities are to oversee all functions 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 October 31, 2026

View Audit 394104

Finding 1182647 (2025-002)

Material Weakness 2025

Tri-County Community Action Partnership, Inc.

MN

Internal Control / Segregation of Duties Questioned Costs Significant Deficiency § 200.303

Head Start - AL #93.6000 Recommendation: The Organization should ensure all new board members receive training within 180 days. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We will ensure that all new and existi...

Head Start - AL #93.6000 Recommendation: The Organization should ensure all new board members receive training within 180 days. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We will ensure that all new and existing board members receive necessary training within 180 days of being seated and on an annual basis. Name(s) of the contact person(s) responsible for corrective action: Rita Zilka, Fiscal Director Planned completion date for corrective action plan: September 30, 2026

View Audit 394089

Finding 1182639 (2025-003)

Material Weakness 2025

Northeastern Oklahoma Agricultural An Mechanical College

OK

Student Financial Aid Matching / Level of Effort / Earmarking Reporting § 200.303

Student Financial Assistance Cluster– Assistance Listing No. 84.063, 84.007, 84.033, 84.268 Recommendation: We recommend the College review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported accurately and timely. Explanation of disagreement with aud...

Student Financial Assistance Cluster– Assistance Listing No. 84.063, 84.007, 84.033, 84.268 Recommendation: We recommend the College review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: NEO will perform an internal audit of enrollment reports sent to the National Student Clearinghouse (NSC) monthly to ensure NSC is submitting records on behalf of NEO in a timely manner. Name(s) of the contact person(s) responsible for corrective action: Amy Ishmael Planned completion date for corrective action plan: April 1, 2026 If the U.S. Department of Education has questions regarding this plan, please call Amy Ishmael at 918- 540-6212.

View Audit 394070

Finding 1182638 (2025-002)

Material Weakness 2025

Northeastern Oklahoma Agricultural An Mechanical College

OK

Questioned Costs Student Financial Aid Significant Deficiency § 200.303

Student Financial Assistance Cluster– Assistance Listing No. 84.063, 84.007, 84.033, 84.268 Recommendation: We recommend that the College review policies and procedures related to R2T4 calculations to ensure calculations are performed correctly and timely. We also recommend the College implement for...

Student Financial Assistance Cluster– Assistance Listing No. 84.063, 84.007, 84.033, 84.268 Recommendation: We recommend that the College review policies and procedures related to R2T4 calculations to ensure calculations are performed correctly and timely. We also recommend the College implement formal review procedures to document the Return of Title IV calculations are being performed to minimize the likelihood that errors may go undetected and not be corrected in a timely manner. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: NEO will check the scheduled break days before the beginning of each semester to make sure the correct number of days is entered into SOATBRK. Documentation will be retained to confirm that a check was performed. NEO performed the recalculations and is working with FSA to make corrections. Name(s) of the contact person(s) responsible for corrective action: David Fisher and Ashley Mayfield Planned completion date for corrective action plan: March 14, 2026.

View Audit 394070

Finding 1182637 (2025-001)

Material Weakness 2025

Northeastern Oklahoma Agricultural An Mechanical College

OK

Matching / Level of Effort / Earmarking Questioned Costs Student Financial Aid § 200.303

SIGNIFICANT DEFICIENCY 2025-001 Student Financial Assistance Cluster– Assistance Listing No. 84.063, 84.007, 84.033, 84.268 Recommendation: We recommend the College review reporting processes to ensure all students that require exit counseling receive it in a timely manner. Explanation of disagreeme...

SIGNIFICANT DEFICIENCY 2025-001 Student Financial Assistance Cluster– Assistance Listing No. 84.063, 84.007, 84.033, 84.268 Recommendation: We recommend the College review reporting processes to ensure all students that require exit counseling receive it in a timely manner. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: NEO will develop a separate report in addition to the RRREXIT report to identify students that need to be notified of their responsibility to complete exit counseling. Name(s) of the contact person(s) responsible for corrective action: David Fisher Planned completion date for corrective action plan: March 15, 2026.

View Audit 394070

Finding 1182619 (2025-008)

Material Weakness 2025

Rush County Schools

IN

Matching / Level of Effort / Earmarking Special Tests & Provisions § 200.303

FINDING 2025-008 Finding Subject: COVID-19 Education Stabilization Fund – Special Tests and Provisions – Wage Rate Requirements Summary of Finding: One of the construction contracts tested for compliance that was to be paid from federal grant funds did not have the required prevailing wage rate caus...

FINDING 2025-008 Finding Subject: COVID-19 Education Stabilization Fund – Special Tests and Provisions – Wage Rate Requirements Summary of Finding: One of the construction contracts tested for compliance that was to be paid from federal grant funds did not have the required prevailing wage rate cause nor were certified weekly payrolls for construction services performed under the contract provided upon request. Contact Person Responsible for Corrective Action: Julie Cramer Contact Phone Number and Email Address: 765-932-4186, cramerj@rushville.k12.in.us Views of Responsible Officials: Option 1: “We concur with the finding.” Description of Corrective Action Plan: The School Corporation management will establish a system of internal controls involving the Corporation Treasurer and Superintendent and include the wage requirement clause in contracts for construction that are paid with federal grant funds. The School Corporation will also request certified payrolls that will go along with these specific types of contracts. Anticipated Completion Date: March 31, 2026

View Audit 394041

Finding 1182618 (2025-007)

Material Weakness 2025

Rush County Schools

IN

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

FINDING 2025-007 Finding Subject: Special Education Cluster (IDEA) - Suspension and Debarment Summary of Finding: Prior to entering sub-awards and covered transactions with program funds, recipients are required to verify that such contractors and sub recipients are not suspended, debarred, or other...

FINDING 2025-007 Finding Subject: Special Education Cluster (IDEA) - Suspension and Debarment Summary of Finding: Prior to entering sub-awards and covered transactions with program funds, recipients are required to verify that such contractors and sub recipients 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 sam.gov exclusion, collecting a certification from that person, or adding a clause or condition to the covered transaction with that person. Contact Person Responsible for Corrective Action: Julie Cramer Contact Phone Number and Email Address: 765-932-4186, cramerj@rushville.k12.in.us Views of Responsible Officials: Option 1: “We concur with the finding.” Description of Corrective Action Plan: Before board approval as a vendor with services over $25,000, to be paid for with federal grant funds, an internal document will be signed by the vendor with verification of good standing with sam.gov as well as an official print out from sam.gov attached that indicates whether the prospective vendor is suspended or debarred from federal payments. Payment to the vendor will be withheld until such documentation is produced. This document will be retained by the Grant Coordinator for Special Education and for bookkeeping office reference. Future purchases will be made in accordance with the School Corporation’s procurement policy that also addresses suspension and debarment requirements. Anticipated Completion Date: April 2026

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Finding 1182613 (2025-006)

Material Weakness 2025

Rush County Schools

IN

Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties Subrecipient Monitoring § 200.303 § 200.77 § 200.78

FINDING 2025-006 Finding Subject: Title I Grants to Local Educational Agencies - Eligibility Summary of Finding: An effective internal control system, which would include segregation of duties, was not in place at the School Corporation to ensure compliance with requirements related to the grant agr...

FINDING 2025-006 Finding Subject: Title I Grants to Local Educational Agencies - Eligibility Summary of Finding: An effective internal control system, which would include segregation of duties, was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Eligibility compliance requirement. Contact Person Responsible for Corrective Action: Julie Cramer Contact Phone Number and Email Address: 765-932-4186, cramerj@rushville.k12.in.us Views of Responsible Officials: Option 1: “We concur with the finding.” Description of Corrective Action Plan: The Technology Director or assigned State Reporter will supply the Title I Director and Food Services Director with rosters reports from our SIS system prior to the certification of the October 1 count each year. Applications on file will be reviewed for accuracy and updates to our SIS will be made checking for accuracy. These reports will be retained for audit purposes and used by the Grant Coordinator to determine that enrollment numbers in the Title I application have been populated correctly. The Title I Director and Food Services Director will both sign off on this document. Anticipated Completion Date: September 2026

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Finding 1182611 (2025-005)

Material Weakness 2025

Rush County Schools

IN

Internal Control / Segregation of Duties Special Tests & Provisions Subrecipient Monitoring § 200.303

FINDING 2025-005 Finding Subject: Title I Grants to Local Educational Agencies - Internal Controls over Compliance – Assessment System Security Summary of finding: An effective internal control system, which would include segregation of duties, was not in place at the School Corporation to ensure co...

FINDING 2025-005 Finding Subject: Title I Grants to Local Educational Agencies - Internal Controls over Compliance – Assessment System Security Summary of finding: An effective internal control system, which would include segregation of duties, was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Special Tests and Provisions – Assessment System Security compliance requirement. Contact Person Responsible for Corrective Action: Julie Cramer Contact Phone Number and Email Address: 765-932-4186, cramerj@rushville.k12.in.us Views of Responsible Officials: Option 1: “We concur with the finding.” Description of Corrective Action Plan: The Corporation’s Testing Coordinator will reiterate to our STCs in our buildings to make sure new hires are given the Test Security and Integrity sheets and follow our internal monitoring protocols to ensure that the appropriate people are trained by initialing the staff sign-in sheets verifying that the attendance information was reviewed for accuracy. These reminders for the STCs will come at least twice a year: Once in the fall before all testing begins and again in the spring before the summative tests begin. Anticipated Completion Date: March 3, 2026

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Finding 1182609 (2025-004)

Material Weakness 2025

Rush County Schools

IN

Procurement, Suspension & Debarment Subrecipient Monitoring School Nutrition Programs § 200.303

FINDING 2025-004 Finding Subject: Child Nutrition Cluster – Internal Controls - Procurement and Suspension and Debarment Summary of Finding: The Rush County SFA follows procurement standards in accordance with 2 CFR Part 200. All purchases are conducted using the appropriate procurement method based...

FINDING 2025-004 Finding Subject: Child Nutrition Cluster – Internal Controls - Procurement and Suspension and Debarment Summary of Finding: The Rush County SFA follows procurement standards in accordance with 2 CFR Part 200. All purchases are conducted using the appropriate procurement method based on dollar thresholds. For contracts exceeding $25,000, the Rush County SFA verifies vendors are not suspended or debarred through the System for Award Management (SAM) and retains documentation in the procurement file. Written procedures include conflict of interest standards and documentation requirements. Contact Person Responsible for Corrective Action: Julie Cramer Contact Phone Number and Email Address: (765) 932-4186, cramerj@rushville.k12.in.us Views of Responsible Officials: Option 1: “We concur with the finding.” Description of Corrective Action Plan: The Rush County SFA maintains written procurement procedures that include verification of suspension and debarment status in accordance with 2 CFR 200.214. These procedures apply to all federally funded child nutrition purchases, including food service equipment. Prior to awarding any contract or purchase order exceeding the $25,000 threshold for Suspension and Debarment requirements, the Rush County Schools Assistant Superintendent and or Superintendent along with the Food Service Director will verify in SAM the vendor’s status as to whether the entity is suspended or debarred from receiving federal grant funds. To ensure proper segregation of duties the Food Service Director conducts the SAM verification and maintains documentation. The Assistant Superintendent and or Superintendent will review and give approval for the purchase prior to final award. The dual review process ensures compliance and oversight with the Suspension and Debarment requirements. Anticipated Completion Date: March 31, 2026

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Finding 1182601 (2025-003)

Material Weakness 2025

Rush County Schools

IN

School Nutrition Programs Eligibility Internal Control / Segregation of Duties § 200.303

FINDING 2025-003 Finding Subject: Child Nutrition Cluster – Internal Controls - Eligibility Summary of Finding: There was no documented evidence of the Director of Food Service reviewing the eligibility determinations for free and reduced lunches that were made by the Cafeteria Secretary during the ...

FINDING 2025-003 Finding Subject: Child Nutrition Cluster – Internal Controls - Eligibility Summary of Finding: There was no documented evidence of the Director of Food Service reviewing the eligibility determinations for free and reduced lunches that were made by the Cafeteria Secretary during the audit period. Contact Person Responsible for Corrective Action: Julie Cramer Contact Phone Number and Email Address: 765-932-4186, cramerj@rushville.k12.in.us Views of Responsible Officials: Option 1: “We concur with the finding.” Description of Corrective Action Plan: The Middle School Cafeteria Secretary will contact parents regarding verifications of their free/reduced lunch application information. This information will then be reviewed by the Director of Food Service, to determine whether the information is accurate. Parents are always notified on any changes to the lunch status for students. Both the Cafeteria Secretary and the Director of Food Service will sign off on each application to document that reviews were performed. Anticipated Completion Date: March 3, 2026

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