Corrective Action Plans

FINDING 2024-005 Finding Subject: SPECIAL EDUCATION CLUSTER (IDEA) – PROCUREMENT AND SUSPENSION AND DEBARMENT Summary of Finding: 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; 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 22611-042-ARP; 22619-042-ARP Pass-Through Entity: Indiana Department of Education Compliance Requirement(s): Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Dawn Mason, Business Manager, DeKalb Co. Eastern CSD Contact Phone Number and Email Address: 260-868-2125; Andrew McDaniel, Chief Financial and Operations Officer, West Noble School Corporation, 260-894-3191, mcdaniela@westnoble.k12.in.us Views of Responsible Officials: We concur with the findings. Description of Corrective Action Plan: The expenditures referenced in the finding were expended from the American Rescue Plan Special Education grant funds which were fully expended during the audit period. All future expenditures triggering procurement and suspension and debarment requirements will include implementing the following procurement policies. Reference Procurement Standards 2 CFR 200.318 Districts may not enter into contracts with entities that have been suspended or debarred from participating in contracts with federal funds. For contracts over $25,000, districts must verify a contractor is not excluded or disqualified. Contractors must be verified in one of three ways: 1. Checking the System for Award Management (SAM) (www.SAM.gov) 2. Collecting a certificate from that contractor. 3. Adding a clause or condition to the covered transaction with that contractor. (Recommended) **Proper verification and documentation must be sent to the LEA for audit purposes. Methods of Procurement Where specific EDGAR/UG thresholds apply, Districts must meet baseline requirements for procurement. If State or local rules have more restrictive thresholds, the most restrictive rule must be followed. Informal Procurement Procedures 1. Micro-purchase (0-$50,000) Dekalb County Eastern CSD has self-certified micro-purchases for up to $50,000 Micro-purchases may be awarded without soliciting competitive quotes if the district considers the price to be reasonable. Quotes must be attached to the invoice/checks for proper documentation and retained by the LEA. 2. Small Purchase ($50,000 – $150,000) Three quotes are required prior to purchase unless the purchase comes from a “Sole Source” vendor. Small purchases are required to be ordered under a purchase order unless in an emergency. Additional quotes must be presented along with the purchase order prior to being approved by the LEA. Formal Procurement Procedures 1. Sealed Bids (above $150,000) Bids must be solicited from an adequate number of suppliers, providing them with sufficient response time prior to the opening of the bids. Proper advertisement and procedures must be followed per IC 5-22 and corresponding documentation must be presented to the LEA prior to any final approval or purchases being made. 2. Competitive Proposals (above $150,000) The Request for Proposal method is used for procurements in which factors other than cost play a significant role. Per IC 5-22-9, when a purchasing agent makes a written determination that the use of competitive sealed bidding is either not practicable or not advantageous to the governmental body, the purchasing agent may award a contract using this procedure instead of competitive sealed bidding. This provides a formal process for the procurement of goods and/or services for which price is not the sole factor in the selection of a vendor or vendors. Proper advertisement and procedures must be followed per IC 5-22 and corresponding documentation must be presented to the LEA prior to any final approval or purchases being made. Noncompetitive (Sole Source) All sole source procurements require adequate written justification and must be attached to the corresponding purchase order or payment. Anticipated Completion Date: All expenditures initiated after March 12, 2025

FINDING 2024-004 Finding Subject: Child Nutrition Cluster--Eligibility Contact Person Responsible for Corrective Action: Deb Rodriguez, Food Service Director Contact Phone Number and Email Address: 260.894.3191 and rodriguezd@westnoble.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Food Service Director will review the directly certified student list from the state and verify that is correctly entered into the school’s software. The Chief Financial Officer will review the list from the state and review the list that is inputted into the school’s software to ensure accuracy. Anticipated Completion Date: September 30, 2025

Action taken in response to finding: Program managers will continue working to ensure that all FAFTA forms are appropriately reported in SAM.gov Name(s) of the contact person(s) responsible for corrective action: Sharon Cullins, Community Development Planner, and Lara Kritzer, Director of Housing and Community Development. Planned completion date for corrective action plan: This will be implemented immediately.

FINDING 2024-003 Finding Subject: Title I Grants to Local Education Agencies - Special Tests and Provisions - Assessment System Contact Person Responsible for Corrective Action: Caleb Logan, Corporation Testing Coordinator Contact Phone Number and Email Address: (260) 367-3677 caleb.logan@whitko.org . Views of Responsible Official: We concur with this finding. Summary of Finding: School Corporation is required to obtain and store the completed Indiana Testing Security and Integrity Agreements for the entire staff. The School Corporation Testing Coordinator is responsible to gather all completed forms from each building for all staff and to store them. The Corporation Testing Coordinator during this audit period was a former employee of the School Corporation. The files of the Indiana Testing Security and Integrity Agreements were unable to be located from the former Testing Coordinator’s files (electronic or printed). The School Corporation had a process with the distribution, completion, and storage of the Indiana Testing Security and Integrity Agreements. However, there was ineffective internal controls and additional oversight in place to prevent these files from being recovered. Description of Corrective Action Plan: At the Beginning of each school year, the Testing Coordinator will distribute the Indiana Testing Security and Integrity Agreements to all staff through each Building Administrator. Employee completed agreements will be returned to the Building Administrator. Each Building Administrator will store these agreements for their building, and in turn will provide a copy to the School Corporation Testing Coordinator. The Testing Coordinator will verify that all staff have completed the agreement with a staff check sheet. The Corporation Testing Coordinator will follow up with any employee who has not completed an agreement. Staff hired during the school year are required to complete the agreement as well. The Testing Coordinator has both a hard paper copy as well as a scanned pdf file saved for all the completed agreements. At the end of the school year, the hard copy of all employees along with the check sheet will be stored in the central office secured storage room. Anticipated Completion Date: Immediately

Finding 2024-006 – Allowable Costs/Cost Principles Name of Contact Person: Darla Hawkins, City Treasurer, City of Sheridan, Wyoming Corrective Action Plan: With recent personnel changes, project managers with adequate knowledge of allowable costs are responsible for tracking all costs. In collaboration with the Treasury Department, new internal controls have been implemented, ensuring clear and effective tracking methods are maintained and practiced regularly. Proposed Completion Date: June 30, 2025

Name of Contact Person: Darla Hawkins, City Treasurer, City of Sheridan, Wyoming Corrective Action Plan: Due to personnel changes, obtaining authorization to access the reporting site proved to be a challenging and time-consuming process. To prevent similar issues in the future, a cross-training program and centralized task list are being developed to ensure multiple staff members are familiar with all tasks and have backup access to logins when available. Proposed Completion Date: June 30, 2025

Embry-Riddle Aeronautical University Corrective Action Plan Single Audit - Fiscal Year Ending 2024 Finding: 2024-001 Federal Program: Federal Direct Student Loans (ALN 84.268) Federal Pell Grant Program (ALN 84.063) Name(s) of the contact person(s) responsible for corrective action: • Julie Ferguson, University Registrar • Edward Trombley, Registrar, Worldwide Campus • Ria Woods White, Senior Associate Registrar, Residential Campuses • Scott Johnson, Associate Registrar, University Registrar Office View of Responsible Officials: Registrar leadership agree with the audit finding and will implement additional review procedures to ensure that enrollment and graduate records are submitted to the National Student Loan Data System (NSLDS) in a timely and accurate manner. Corrective Action Plan: Action Anticipated Completion Date Institute periodic internal reviews to ensure that the enrollment and graduation reporting process meet required standards. Ongoing Operationalize a duplicative review process for Worldwide enrollment and graduation report submissions. Ongoing

Condition During our reporting test, we detected reports that were submitted after the corresponding biweekly period. In addition, the expenditures in the reports contained errors of reporting related to the amounts for employee retentions for payroll taxes, which were included in the reports but are not expenditures incurred by the Organization. Views of Responsible Officials and Corrective Actions Justification: The organization acknowledges that four (4) out of twenty-four (24) bi-weekly reports for ALN 21.027 were submitted late. The report due September 1, 2023, was submitted on September 6, 2023. This delay was due to an unintentional error involving a mismatch of dates, as explained in an email to the grantor on the same day as the submission. The grantor acknowledged receipt of the report. Furthermore, the organization maintains continuous communication with the grantor to validate eligible expenses. The grantor has not verbalized any major discrepancies related to late submissions in the monthly stakeholder meetings due to our continuous communication with the grantor. While the organization recognizes the late submission, it asserts that the delay was minor and promptly addressed. Root Cause Analysis and Immediate Corrective Actions: • Objective: Identify underlying causes of late submissions and report errors. o Conduct interviews with staff involved in reporting processes. o Review workflow for report preparation, approval, and submission. o Analyze gaps in understanding compliance requirements (e.g., misclassification of FICA/Medicare retentions). Corrective Actions: The organization has taken steps to improve internal controls and prevent future late submissions. To address and prevent the issues identified in Finding No. 2024-001, the following corrective actions are the following: Establish Formalized Oversight and Monitoring: ● Implement a system of checks and balances for report preparation and submission. ● Designate specific personnel responsible for reviewing reports before submission to ensure accuracy and timeliness. ● Develop a tracking mechanism (e.g., a checklist or calendar) to monitor report deadlines and submission status. Enhance Internal Controls: ● Develop and document written policies and procedures for the bi-weekly reporting process. This documentation should clearly outline: ○ Report preparation guidelines, following 2 CFR 200.302. ○ Data sources and required supporting documentation, following 2 CFR 200.300. ○ Review and approval processes, following 2 CFR 200.303. ○ Submission deadlines and methods, following grantor requirements and 2 CFR 200.343. ● Provide training for staff responsible for preparing and submitting reports, emphasizing the importance of accuracy and adherence to deadlines, following 2 CFR 200.303. ● Implement a process for regular reconciliation of report data with underlying financial records to ensure accuracy, following 2 CFR 200.302. Improve Report Accuracy: ● Clearly define what constitutes an allowable expenditure for the federal program, in accordance with 2 CFR Part 200 Subpart E. ● Provide specific guidance and examples to staff to prevent the inclusion of non-expenditure items (like employee payroll tax retentions) in reports. ● Implement automated checks or validation rules in the reporting process to detect and prevent errors. ● Conduct pre-submission audits by a compliance officer to review expenditures against federal guidelines, including OMB Circular A-133. ● Develop a retroactive correction protocol to address past errors, including communication with the grantor if amendments are Timely Submission of Reports: ● Implement a system of reminders for report deadlines. ● Establish clear consequences for failing to submit reports on time. ● Evaluate the current reporting timeline and assess if adjustments are needed to ensure timely submission. Communication with Grantor: ● Proactively communicate with the grantor regarding the corrective actions being taken to address the findings. ● Provide the grantor with a timeline for implementation of these actions. By implementing these corrective actions, Sociedad para Asistencia Legal de Puerto Rico, Inc. can improve the accuracy and timeliness of its bi-weekly reporting, ensure compliance with federal requirements, and mitigate the risk of penalties or other adverse actions. Name(s) of the Contact Person(s) Responsible for Corrective Action Héctor A. Díaz Pomales - Director de Finanzas Anticipated Completion Date: March 26, 2025

The corrective action plan listed below is response to the San Bernardino Valley Municipal Water District’s single audit report for the fiscal year ending June 30, 2024, prepared by Rogers, Anderson, Malody and Scott, CPA’s 2024-001 - Lack of Internal Controls Over the Reporting Process Significant Deficiency Reclamation States Emergency Drought Relief Program, AL 15.514 Recommendation: We recommend that the District develop and implement formal policies and procedures to ensure that federal reports are reviewed for accuracy, completeness, and timeliness prior to submission. Management should assign responsibility for report preparation and review, implement checklists or reconciliation processes, and provide training to sta􀆯 involved in federal reporting. Corrective Action: To ensure compliance for future reporting, the District has implemented procedures that prior to submission of grant reporting, the accounting department will approve the report for all grant expenditures. In addition, the District has arranged for sta􀆯 training for employees involved with federal grants and reporting. Person Responsible for Corrective Action: Chief Financial O􀆯icer Senior Accountant Project Managers (Various Departments) Anticipated Completion Date for Corrective Action: Corrective Action is immediately implemented in response to the auditors’ recommendation.

Finding No. 2024-005 Failure to Notify Recipients of Federal Direct Loan and Federal Pell Grant Disbursements ALNs: 84.063, 84.268 Program: Student Financial Assistance Cluster Corrective Action: The University created an automated process to send financial aid notifications on a regular basis. Completed: January 31, 2024 Contact Person: Amanda Fijal

Finding No. 2024-004 Failure to Properly Complete Required Verification Procedures ALNs: 84.007, 84.033, 84.063, 84.268 Program: Student Financial Assistance Cluster Corrective Action: Additional training will be provided to staff. Implementation Date: June 30, 2025 Contact Person: Amanda Fijal

Finding No. 2024-003 Failure to Determine Eligibility in Accordance with SFA Regulations ALNs: 84.007, 84.033, 84.063, 84.268 Program: Student Financial Assistance Cluster Corrective Action: Additional training will be provided to staff. Implementation Date: June 30, 2025 Contact Person: Amanda Fijal

Finding No. 2024-002: Untimely Review of Subrecipient Single Audit Reports AL and Program Expenditures: Various ($539,084,567) Program Name: Research and Development (R&D) Cluster Corrective Action: Process Improvements: - The University began the annual review of Subrecipient Single Audit reports for FY25 and the review schedule is currently on time and up to date. - Implement scheduled calendar appointment reminders to ensure Single Audit Reports are reviewed and completed on time. (Completed 1/6/2025) - Train additional staff member on subrecipient monitoring review process to assist during heavy volume periods. Expected Implementation: April 2025 Contact: Jennifer A. Ponting (Associate Vice President, Research Administration)

Finding No. 2024-001: Inaccurate Property Management Records AL Numbers: Various Program Name: Research and Development Cluster Corrective Action: The Central Accounting team will conduct bi-annual equipment training with all departments of the University, scheduling virtual training with all equipment coordinators. Expected Implementation: June 30, 2025 and December 31, 2025 The University is researching equipment tagging software alternatives that will enhance tracking capabilities and enable asset tagging at a more granular level. The Central Accounting team will work with leadership to outline a timeline for a new tagging system. Expected Implementation: September 30, 2025 Contact: Kathy Conrad and Craig Elmore

2024-003 Equipment and real Property Management Recommendation: The School should ensure proper policies and procedures are in place to monitor the physical inventory requirements and ensure the physical inventory is completed and documented. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A physical inventory of capital assets will be done in the spring/summer of 2025 and every other year after. Adjustments to financials will be recorded as necessary upon completion of physical inventory. A Capital (Fixed) Asset policy will be created and presented to Board for approval. Name(s) of the contact person(s) responsible for corrective action: Deborah S. Czmiel Planned completion date for corrective action plan: 06/30/2025

Finding 2024-007 Contact Person Responsible for Corrective Action: Cindy Skinner, Corporation Treasurer Contact Phone Number: 765-282-5615 View of Responsible Official: We Concur with the Findings Description of Corrective Action Plan: The Corporation Treasurer will review the Financial report more closely and make sure that internal controls are in place to ensure compliance. Anticipated Completion Date: March 2025

Finding 2024-006 Contact Person Responsible for Corrective Action: Cindy Skinner, Corporation Treasurer Contact Phone Number: 765-282-5615 View of Responsible Official: We Concur with the Findings Description of Corrective Action Plan: We will work with the Capital Assets reporting Firm more closely to assure that all listed property is properly marked and that it is still in our possession. Anticipated Completion Date: March 2025

Finding 2024-005 Contact Person Responsible for Corrective Action: Cindy Skinner, Corporation Treasurer Contact Phone Number: 765-282-5615 View of Responsible Official: We Concur with the Findings Description of Corrective Action Plan: We will implement internal controls that will correct the Allowable Activities and Costs procedures for Federal Grants. Anticipated Completion Date: March 2025

Finding 2024-004 Contact Person Responsible for Corrective Action: Brenda Layne, Food Service Director Contact Phone Number: 765-289-7323 We concur with the finding. Corrective Action plan: As of SY 24/25 when the High School Treasurer checks the 10% of the paper applications, she will make a list of the ones she checked and it will be located in the application binder. As of March 1st, 2025 The Food Service Director will run a copy of Direct Certs that Titan has in their file, she will then cross check it with the list that is send from IDOE. She will keep both list together in a file after initialing it. Anticipated completion Date: March 2025

Finding 2024-003 Contact Person Responsible for Corrective Action Plan: Brenda Layne, Food Service Director Contact Phone Number: 765-289-7323 We concur with the finding. Corrective Action plan: As of 3/1/25. Cindy will look the company up on Sam.gov. and the Food Service Director will look it over and both of us will initial and keep a copy on file. Anticipated Completion Date: March 2025

FINDING 2024-003 Subject: Special Education Cluster (IDEA) - Procurement and Suspension and Debarment Federal Agency: Department of Education Federal Programs: COVID-19 - Special Education Grants to States, COVID-19 - Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 22611-042-ARP, 22619-042-ARP Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion INDIANA STATE BOARD OF ACCOUNTS 20 METROPOLITAN SCHOOL DISTRICT OF STEUBEN COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Condition and Context The School Corporation is a member of the Northeast Indiana Special Education Cooperative (Cooperative). During fiscal years 2022-2023 and 2023-2024, the Cooperative operated the special education program and spent the federal money on behalf of all its members. As the grant agreement was between the Indiana Department of Education and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the procurement and the suspension and debarment requirements. The Cooperative did not have adequate procedures in place to ensure that the requirements for the simplified acquisition threshold and for small purchases were met for each applicable procured good or service or to ensure that vendors were not suspended or debarred prior to entering into a covered transaction. Procurement When the value of the procurement for property or services exceeds the simplified acquisition threshold (SAT), or a lower threshold established by a nonfederal entity, formal procurement methods are required. The SAT is typically set at $250,000. However, Indiana Code 5-22-8 has a more restrictive threshold. Therefore, the SAT threshold is set at $150,000. Formal procurement methods require adherence to documented procedures and formal methods such as sealed bids or proposals. When the purchase value exceeds the micro-purchase threshold but is less than the simplified acquisition threshold, a small purchase occurs. Small purchases require documented full and open competition or a documented rationale for limited competition. For 2022-2023, the Cooperative had one vendor, with disbursements, totaling $379,313, which exceeded the SAT threshold of $150,000. The Cooperative did not obtain sealed bids or competitive proposals nor was there documentation detailing the history of the procurement, which must include the reason for the procurement method used. For 2022-2023, the Cooperative had one vendor with disbursements in the amount of $55,374, which were less than the SAT threshold of $150,000, but exceeded the $50,000 micropurchase threshold and was selected for testing. The Cooperative did not obtain price or rate quotes nor was there documentation detailing the history of the procurement, which must include the reason for the procurement method used. For 2023-2024, three vendors with disbursements, totaling $175,125, were identified as being less than the simplified acquisition threshold of $150,000, but exceeding the $50,000 micropurchase threshold and were selected for testing. The Cooperative did not obtain price or rate quotes for two of the three vendors and there was no documentation detailing the history of the procurement, which must include the reason for the procurement method used. 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 nonprocurement transaction (i.e., grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the SAM exclusions, collecting a certification from that vendor, or adding a clause or condition to the covered transaction with that vendor. INDIANA STATE BOARD OF ACCOUNTS 21 METROPOLITAN SCHOOL DISTRICT OF STEUBEN COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Upon inquiry of the Cooperative 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 there were not any documented internal controls or procedures. Nine covered transactions were identified. The covered transactions, totaling $803,836, were selected for testing. The Cooperative did not verify the suspension and debarment status of the tested vendors prior to payment. The lack of internal controls and noncompliance were systemic throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.320 states in part: "The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. (a) Informal procurement methods. When the value of the procurement for property or services under a Federal award does not exceed the simplified acquisition threshold (SAT), as defined in § 200.1, or a lower threshold established by a non-Federal entity, formal procurement methods are not required. The non-Federal entity may use informal procurement methods to expedite the completion of its transactions and minimize the associated administrative burden and cost. The informal methods used for procurement of property or services at or below the SAT include: . . . (2) Small purchases– (i) Small purchase procedures. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. . . . INDIANA STATE BOARD OF ACCOUNTS 22 METROPOLITAN SCHOOL DISTRICT OF STEUBEN COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (b) Formal Procurement Methods. When the value of the procurement for property or services under a Federal financial assistance award exceeds the SAT, or a lower threshold established by a non-Federal entity, formal procurement methods are required. Formal procurement methods require following documented procedures. Formal procurement methods also require public advertising unless a non-competitive procurement can be used in accordance with § 200.319 or paragraph (c) of this section. The following formal methods of procurement are used for procurement of property or services above the simplified acquisition threshold or a value below the simplified acquisition threshold the non-Federal entity determines to be appropriate: . . . (1) Sealed bids. A procurement method in which bids are publicly solicited and a firm fixed-price contract (lump sum or unit price) is awarded to the responsible bidder whose bid, conforming with all the material terms and conditions of the invitation for bids, is the lowest in price. The sealed bids method is the preferred method for procuring construction, if the conditions. . . . (2) Proposals. A procurement method in which either a fixed price or cost-reimbursement type contract is awarded. Proposals are generally used when conditions are not appropriate for the use of sealed bids. . . ." 2 CFR 180.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking the SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person." Cause The Cooperative noted that the ARP portion of the Special Education grant was new for 2022-2023 and 2023-2024. The ARP funding gave opportunity for types of expenditures that do not typically get expensed using special education funding. The transactions noted within the Condition and Context were from the ARP portion of the grant, which provided property or services that exceeded the micro-purchase threshold. Management of the Cooperative was unaware of the procurement requirements when property or services exceed the micro-purchase threshold. In addition, management of the Cooperative was unaware of the suspension and debarment requirements when a covered transaction is expected to equal or exceed $25,000. Effect Without the proper implementation of an effectively designed system of internal controls, including policies and procedures that provide segregation of duties and additional oversight as needed, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. Without following the required methods for procurement, the Cooperative could be overpaying for services. Unverified vendors to whom payments equal to or in excess of $25,000 could be suspended, debarred, or otherwise excluded. INDIANA STATE BOARD OF ACCOUNTS 23 METROPOLITAN SCHOOL DISTRICT OF STEUBEN COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Noncompliance with the provisions of federal statutes, regulations, and terms and conditions of the federal award could result in the reduction of future federal funding to the Cooperative. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the Cooperative's management design and implement a system of internal controls related to procurement and suspension and debarment procedures to ensure procurement requirements are met and to ensure entities are neither suspended nor debarred or otherwise excluded or disqualified prior to entering into any covered transactions. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2024-002 Subject: Title I Grants to Local Educational Agencies - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listings Number: 84.010 Federal Award Number or Year (or Other Identifying Number): S010A210014 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Findings: Material Weakness, Modified Opinion Condition and Context Direct charges to a federal award are to be for allowable activities and allowable costs made in conformance with the applicable cost principles. The School Corporation did not have a process or internal controls in place to ensure expenditures for the 2021 Title I grant award were for allowable activities and costs and in conformance with the cost principles. The School Corporation was unable to provide supporting documentation for $43,141 worth of expenditures transferred out of the 2021 grant award fund 4121 from July 1, 2022 to December 1, 2022. These expenditures were originally expended from the Title I 2021 grant award fund 4121, requested for reimbursement and then the expenditures were moved to other funds. Because these expenditures were reappropriated, they were not an allowable activity or cost of the 2021 Title I grant award. In addition, the School Corporation was unable to provide supporting documentation for $6,646 worth of certified salary expenditures requested for reimbursement for the same grant award from February 17, 2022 to June 30, 2022. It was determined that this amount was double requested for reimbursement and was not an actual expenditure. The total amount of $49,787 was considered questioned costs. Subsequent to the 2021 Title I grant award, the School Corporation established and implemented a process and internal controls to ensure expenditures for the 2022 and 2023 awards from July 1, 2022 through December 31, 2023, were for allowable activities and costs and in conformance with the cost principles. The vendor expenditures are initiated by the Title I Director and the Title I Administrative Assistant. Payroll is reviewed each pay period by the Title I Administrative Assistant. The Business Manager/Treasurer prepares the reimbursement request using a detailed expenditure report from their accounting system. The Title I Administrative Assistant verifies the information entered into the reimbursement request by also comparing it to the detailed expenditure reports. The Title I Administrative Assistant also reconciles the Title I award to the expenditures. INDIANA STATE BOARD OF ACCOUNTS 18 METROPOLITAN SCHOOL DISTRICT OF STEUBEN COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) If the Title I Administrative Assistant identifies that a correction of errors needs to be made to a Title I fund, they fill out a Corrections Form. The Title I Director then reviews and signs the form and provides it to the Business Manager/Treasurer to make the correction in the accounting system prior to completing a request for reimbursement. After the corrections have been made, the Title I Administrative Assistant verifies the changes were correctly made. After all corrections are made, the reimbursement request is approved by the Title I Director and then submitted by the Business Manager/Treasurer. We tested 25 other non-journal entry expenditures from all three Title I grant awards during the audit period and did not identify any additional noncompliance with these expenditures. The lack of internal controls and supporting documentation was isolated to the 2021 Title I grant award number S010A21001 from February 17, 2022 to December 31, 2022. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. . . . (g) Be adequately documented. . . ." 2 CFR 200.302(b) states in part: "The recipient's and subrecipient's financial management system must provide for the following: . . . (7) Written procedures for determining the allowability of costs in accordance with subpart E of this part and the terms and conditions of the Federal award." INDIANA STATE BOARD OF ACCOUNTS 19 METROPOLITAN SCHOOL DISTRICT OF STEUBEN COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 2 CFR 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for the Federal awards that are renewed quarterly or annual, from the date of submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." Cause A proper system of internal controls was not designed by management of the School Corporation. The School Corporation segregated duties of knowledgeable staff that were involved in the process of purchasing, entering claim information, processing claim and payroll information, and using reliable financial data from the accounting system. However, it had not established a process or internal controls for the 2021 Title I award number S010A21001 to ensure that all accounting corrections were made prior to processing a request for reimbursement. Effect Without the proper implementation of an effectively designed system of internal controls, the School Corporation could not ensure that only expenditures for allowable activities and costs were made and requested for reimbursement. Any program funds the School Corporation reallocated to other funds or double requested for reimbursement would be unallowable, and the awarding agency could potentially recover them. Questioned Costs Questioned costs in the amount of $49,787 were identified as noted in the Condition and Context. Recommendation We recommended that Management of the School Corporation establish a proper system of internal controls and develop written policies and procedures to ensure that expenditures for all Title I grant awards are for allowable activities and costs in conformance with the cost principles and that support for all expenditures and journal entries is maintained for the date ranges of costs documented on the requests for reimbursement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2024-003 Finding Subject: Child Nutrition Cluster – Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Todd Fleetwood, Director of Business and Operations Contact Phone Number: 260-244-5771 fleetwoodta@wccsonline.com Views of Responsible Official: The School Corporation concurs with the finding Description of Corrective Action Plan: To ensure compliance with federal procurement regulations, prior to entering into a purchase agreement using federal funds exceeding $25,000, the Food Service Director or Assistant Food Service Director will take one of the following actions: 1. Verify Vendor Status: Check the System for Award Management (SAM) Exclusions List to confirm the vendor is not suspended or debarred. 2. Obtain Certification: Collect a written certification from the vendor affirming their eligibility to receive federal funds. 3. Include Contractual Safeguard: If applicable, incorporate a clause or condition in the purchase agreement requiring compliance with federal suspension and debarment regulations. These steps will be documented and retained for audit purposes to ensure full compliance with federal procurement requirements. INDIANA STATE BOARD OF ACCOUNTS 22 107 North Walnut Street  Columbia City, Indiana 46725 Phone (260) 244-5771  Fax (260) 244-4590  Website http://wccsonline.com Anticipated Completion Date: 07/01/2025

FINDING 2024-002 Finding Subject: COVID-19 Education Stabilization Fund – Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Findings: Material Weakness Contact Person Responsible for Corrective Action: Todd Fleetwood, Director of Business and Operations Contact Phone Number: 260-244-5771 fleetwoodta@wccsonline.com Views of Responsible Official: Whitley County Consolidated Schools Todd Fleetwood Director of Business and Operations INDIANA STATE BOARD OF ACCOUNTS 21 107 North Walnut Street  Columbia City, Indiana 46725 Phone (260) 244-5771  Fax (260) 244-4590  Website http://wccsonline.com The School Corporation concurs with the finding. Description of Corrective Action Plan: The business office inadvertently omitted the reviewer’s sign-off on one of the grant reimbursement forms. This oversight will be promptly corrected. Anticipated Completion Date: 04/01/2025

Prior Year Finding: No Federal Agency: U.S. Department of Treasury Federal Program: Coronavirus State and Local Fiscal Recovery Assistance Listing: 21.027 Pass-Through Entity: Maryland State Department of Education Pass-Through Award Number and Period: 211851 (3/3/2021 -12/31/2024) Compliance Requirement: Suspension and Debarment Type of Finding: Material Weakness in Internal Control over Compliance Recommendation We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. However, WCPS did adjust our practices during fiscal year 2024 based on guidance from our previous audit firm to add the suspension and debarment affidavit to all new vendor registrations and service contracts. Action taken in response to finding: Effective immediately, the Purchasing Department will review all requisitions that are going against Fund 02 (Restricted Fund) and ensure that the vendor has been checked for suspension/debarment. New vendors are required to sign an affidavit that they have not been suspended or debarred. This check will ensure that old vendors that were in place prior to the FY 2023 finding have been validated against SAM.GOV or have a signed affidavit to ensure they have not been suspended or debarred. We will also be sending emails to our current vendors to ensure that we have a signed affidavit on file. Name(s) of the contact person(s) responsible for corrective action: Adam Pelc, Supervisor of Accounting and Scott Bachtell, Supervisor of Purchasing Planned completion date for corrective action plan: For immediate implementation and ongoing.