Corrective Action Plans

Information on the federal program: Subject: Special Education Cluster (IDEA) – Period of Performance Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Numbers: 84.027, 84.027X, 84.173, 84.173X Federal Award Numbers and Years (or Other Identifying Numbers): 22611-047-PN01, 22611-047-ARP, 22619-047-PN01, 22619-047-ARP Pass-Through Entity: Indiana Department of Education Compliance Requirement: Period of Performance Audit Finding: Material Weakness Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the Special Education Cluster program and Period of Performance compliance requirements. Context: During fiscal year 2023-24, the School Corporation was a member of Cooperative School Services (Cooperative). The Cooperative operated the special education programs and spent the federal money on behalf of its member schools. As the grant agreement was between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. For Special Education Cluster awards, funds must be obligated during the 27 months, extending from July 1 of the fiscal year for which the funds were appropriated through September 30 of the second following fiscal year. When testing transactions occurred in the liquidation period for the 22611-047-PN01, 22611-047-ARP, 22619-047-PN01 and 22619-047-ARP grant awards, two exceptions were identified in the sample of five transactions. For the above listed awards, costs must be obligated by September 30, 2023. For the two identified exceptions, an initial purchase order was made in September, but the ultimate transaction was paid to a separate vendor than the original purchase order, and this obligation was incurred in November 2023. This issue was isolated to fiscal year 2024. No costs incurred outside of the period of performance were identified in fiscal year 2025. Views of Responsible Officials and Corrective Action Plan: Management disagrees with part of the finding. The term “obligate” can be interpreted in various ways within our context. While we have a purchase order that was completed by September 30, we do agree that we changed vendors after September 30 and paid the non-public school directly. We agree with the finding that direct payment to a non-public school is not allowable. The purchase order is an internal written commitment to acquire the items/supplies, but it is not a binding written agreement to acquire “property” when we are purchasing supplies until it is provided to the vendor. The purchase order is authorization and approval to purchase the items/supplies. Once the purchase order is provided to the vendor, it is committed and is the binding written agreement. The invoice is an order to pay the obligation. Responsible Party and Timeline for Completion: Corrective action plan has been implemented as this finding impacted fiscal year 2024 but did not recur in fiscal year 2025. Sarah Claton, Cooperative School Services director, and Tracy Albertson, Director of Finance, will oversee the corrective action plan to monitor the cooperative on an ongoing basis.

Information on the federal program: Subject: Special Education Cluster (IDEA) – Activities Allowed or Unallowed, Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Numbers: 84.027, 84.027X, 84.173, 84.173X Federal Award Numbers and Years (or Other Identifying Numbers): 22611-047-PN01, 22611-047-ARP, 22619-047-ARP, 24611-047-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Finding: Material Weakness Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the Special Education Cluster program and Activities Allowed or Unallowed and Allowable Costs compliance requirements. Context: During fiscal year 2023-2024, the School Corporation was a member of Cooperative School Services (Cooperative). The Cooperative operated the special education programs and spent the federal money on behalf of its member schools. As the grant agreement was between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. For costs related to non-public schools, the practice of the Cooperative was to separate out the required amount for each member school from the Cooperative budget, and the member schools would work with the non-public schools to determine how to spend their proportionate share amount. Each member school would then request reimbursement from the Cooperative for non-public school expenditures incurred. This allowed both the Cooperative and member schools to maintain control of all Special Education funds, property, equipment and supplies. In the initial sample of 25 expenditures, there was no noncompliance identified. However, while performing a review of separate transactions for the Period of Performance compliance requirement, it was noted that non-public schools received direct reimbursements from the Cooperative for their proportionate share expenditures, which is not allowable under the grant award. The audit team reviewed the expenditure population in entirety and identified a total of 5 expenditures, totaling $17,857, that were made from Special Education funds directly to non-public schools by the cooperative during the audit period. The lack of controls and noncompliance was an isolated to the 22611-047-PN01, 22611-047-ARP, 22619-047-ARP and 24611-047-PN01 grant awards. This issue was isolated to fiscal year 2024. No direct payments to non-public schools were identified during fiscal year 2025. Views of Responsible Officials and Corrective Action Plan: Management concurs with the finding. During the required consultation meeting involving the Local Educational Agency (LEA), representatives from private schools, and the parents or legal guardians of nonpublic students with disabilities, the agenda will cover both allowable and un-allowed costs. The meeting agenda will clearly outline that all purchased items are the responsibility of the LEA, that gift cards are prohibited, and that all acquisitions must provide direct benefit to students with disabilities. Responsible Party and Timeline for Completion: Corrective action plan has been implemented as this finding impacted fiscal year 2024 but did not recur in fiscal year 2025. Sarah Claton, Cooperative School Services Director, and Tracy Albertson, Director of Finance, will oversee the corrective action plan to monitor the cooperative on an ongoing basis.

Information on the federal program: Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY2024 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 to ensure compliance with requirements related to the Child Nutrition Program and Procurement compliance requirements. Context: The School Corporation is a member of a purchasing cooperative, who handles the procurement process and establishes competitively awarded contracts for the majority of food service purchases. For one-time purchases such as food service equipment, the School Corporation is responsible for handling the procurement process. For one of the two small purchase method procurements sampled for testing, the school disbursed $67,000 for food service equipment maintenance in fiscal year 2024. The procurement for this item was handled at the school level. We noted the School Corporation did not obtain quotes from an adequate number of qualified sources. The School Corporation also did not properly perform a suspension and debarment check on the vendor. This finding is isolated to fiscal year 2024. There were no purchases in 2025 that required a simplified acquisition or small purchase procurement other than those procured by the food service cooperative. Views of Responsible Officials and Corrective Action Plan: Moving forward, we will implement a standardized procurement checklist to ensure that quotes are obtained from the required number of vendors in accordance with the small purchase method regulations. Child Nutrition Department will also review micropurchase vendors’ cumulative annual spending on a routine basis to determine whether purchases may exceed the micropurchase threshold and require use of the small purchase method. Documentation of all quotes received will be maintained for audit verification. In addition, staff responsible for procurement have received IDOE/USDA refresher training on federal procurement requirements, including thresholds and documentation standards, to ensure full compliance. Suspension and debarment checks will continue to be conducted and documented for all applicable vendors. Responsible Party and Timeline for Completion: Corrective action plan has been implemented as this finding impacted fiscal year 2024 but did not recur in fiscal year 2025. Missy Corns, Food Service Director, and Tracy Albertson, Director of Finance, will oversee the corrective action plan to monitor the procurement and suspension and debarment requirements on an ongoing basis.

Information on the federal program: Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY23-24 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Finding: 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 eligibility compliance requirement. Context: During the testing of internal controls and compliance over eligibility determinations for free and reduced meals, we selected a sample of 15 applications and 45 direct certifications for testing. For 3 of the 15 applications, the School Corporation was not able to provide any documentation to support the eligibility determination due to turnover in the food service director position. Therefore, we were unable to determine whether the School Corporation complied with the eligibility requirements. The internal control and noncompliance was isolated to fiscal year 2024. Views of Responsible Officials and Corrective Action Plan: School Corporation has implemented procedures to ensure a complete record is maintained for every free and reduced-price meal application and any subsequent eligibility status change. All applications, supporting documentation, and determination records are retained as hard copy files. An electronic Benefit Issuance Document will also be retained during the year and printed as a hard copy record. Any change in eligibility status is documented with the effective date and supporting rationale to provide a clear audit trail. These procedures are now part of the School Corporation’s standard operating practices in school food service to ensure ongoing compliance and continuity moving forward. Responsible Party and Timeline for Completion: Corrective action plan has been implemented as this finding impacted fiscal year 2024 but did not recur in fiscal year 2025. Missy Corns, Food Service Director, and Tracy Albertson, Director of Finance, will oversee the corrective action plan to monitor the eligibility requirements on an ongoing basis.

The City will review the requirements for written policies and will adopt policies, as needed, or will revise its current policies as needed to comply with Uniform Guidance.

Coronavirus State and Local Recovery Funds Reporting Planned Corrective Action: The City has adjusted the procedures to develop and submit the annual report to include segregation of duties. Anticipated Completion Date: March 1, 2026 Responsible Contact Person: Gretchen Hoskins, Finance Director

Coronavirus State and Local Fiscal Recovery Funds Procurement, Suspension, and Debarment Planned Corrective Action: The City implemented a Vendor’s Doing Business Policy in FY 2025-26 requiring all new vendors be searched on SAM.gov and California Secretary of State prior to executing a contract, with emphasis on federal awards. Anticipated Completion Date: March 9, 2026 Responsible Contact Person: Gretchen Hoskins, Finance Director

Finding Reference: 2025-001 – Reporting Condition: During testing of reporting compliance for major federal programs, we selected three of twelve monthly OAF reports submitted during the fiscal year. For each month tested, reported amounts did not reconcile to MOFC’s internal Poundage Distribution reports and Product Code – Agencies by County reports. Specifically, we identified material variances between the OAF reports and internal distribution records, including: October 2024: ACP distributions were omitted from the OAF report, resulting in a variance of approximately 821,528 pounds (projected dollar impact of $262,889). January 2025: VA/Holiday Purchase distributions were omitted from the OAF report, resulting in a variance of approximately 310,898 pounds (projected dollar impact of $155,449). June 2025: Donated distributions, primarily Direct Retail Pickup (DRP) quantities, were omitted from the OAF report, resulting in a variance of approximately 933,505 pounds (projected dollar impact of $1,764,324). Additional differences were noted in purchased distributions of 40,399 pounds (projected dollar impact of $16,968). Although management provided explanations indicating that certain distributions were omitted in error or excluded due to differences in reporting scope, MOFC did not maintain documented reconciliations supporting the reported amounts. Evidence of review and approval demonstrating that differences were identified, investigated, and resolved prior to report submission was not provided. Views of Responsible Officials Items 1 & 2 are both failures of a report in our former ERP to include exception components and needed to be added manually when reporting. This is a result of human error. Item 3 is a result of a WIP component currently being installed into the new ERP to add in programmatic data for agency pickups. This is currently added manually for reporting purposes – also human error. Planned Corrective Action: Implementation of the Direct Retail Pickup poundage integrations into the current ERP will negate the necessity to manually enter the numbers. While this install is occurring, we will continue to manually update. Anticipated Completion Date: Initial discussions have occurred with an anticipated solution provided, tested and approved before the end of FY26 timeframe.

Management is aware and understands the importance of compliance with the federal requirements and will ensure the meal counts will be properly reported in the future.

Reporting Responses UNR – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; Management staff, independent of the preparer, will review and sign off on each report. This review process will include verifying that all information is correctly entered. ● How compliance and performance will be measured and documented for future audit, management and performance review. Compliance and performance will be measured through the independent review process, where management will verify and sign off on each report to ensure accuracy. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. Associate Director of Post Award Official Contact: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu

Reporting Responses UNR – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; Management staff, independent of preparer, will review and sign off on each report. This review process will include verifying that all information is correctly entered. ● How compliance and performance will be measured and documented for future audit, management and performance review. Compliance and performance will be measured through the independent review process, where management will verify and sign off on each report to ensure accuracy. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. Associate Director of Post Award Official Contact: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu

Reporting Responses CSN – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; CSN Office of Grants and Contracts Post-Award Management has advised the grant’s principal investigator (PI) that underlying documentations must match the data reported on the Annual Performance Reports submitted to the award sponsor. The CSN GEAR UP PI and GEAR UP First Year College Advisor have refined the reporting and record keeping process to ensure accurate reporting and supporting documentation is kept in compliance with the grant. The Senior Accountant of Grants and Contracts also reviews the data before each report is submitted to the sponsor. ● How compliance and performance will be measured and documented for future audit, management and performance review. CSN GEAR UP PI and GEAR UP First Year College Advisor will continue to ensure accurate reporting and supporting documentation is kept in compliance. CSN Office of Grants and Contracts Post-Award Management will continue to communicate with PIs to ensure all reports have been reviewed for adequate and accurate supporting documentation prior to submission to the sponsor. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. CSN Program Director, who is the Gaining Early Awareness and Readiness for Undergraduate Programs (GEAR UP) Principal Investigator (PI), is accountable for exercising oversight and responsibility. GBC – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; o Establishment of a formal review and approval workflow requiring secondary review by the Grants Office of participants numbers prior to submission of any financial or performance report. This will require: (1) Identification of the reporting period; (2) Review of all source documents supporting reported totals; and, (3) Mathematical reconciliation of reported figures o Training provided to grant program staff and administrative personnel on documentation standards and reporting accuracy expectations. o All corrective actions were implemented immediately upon identification of the finding and will be fully in place within 30 days of notification. The revised procedures are now standard practice for all grants reporting participant numbers. ● How compliance and performance will be measured and documented for future audit, management and performance review. o Reports may not be submitted to the pass-through entity without documented secondary review and written approval from the Grants Director or the Grant and Asset Coordinator. o Interim and final program reports will be reviewed to ensure: (1) Participant totals match underlying documentation; (2) Source documentation is retained and accessible; and, (3) Approval signatures are present prior to submission. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. o The Grants Director and the Director of Business Operations are responsible for oversight of grant compliance. NSU – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; NSU has reviewed the finding and has put additional measures in place to ensure compliance. Staff responsible for preparing reports were retrained and multi-layered quality checks have been implemented to safeguard integrity of data entered in shared databases. NSU’s multi-layered quality checks include written confirmations from staff involved in service activities and backup of documentation within NSU’s local storage to support the numbers being reported. The latter represents a move away from using a database that is accessible to multiple institutions to a centrally controlled location within NSU. This process outlined herein was implemented in August 2025 and ensures that the source documentation reconciles with reports and is available for auditing purposes. ● How compliance and performance will be measured and documented for future audit, management and performance review. To ensure compliance, NSU staff who are responsible for the program and technical reporting have reviewed and updated internal policies and procedures relating to reporting. Performance targets and benchmarks have been reestablished and will be measured at set intervals. Any errors detected will be documented and remedied. Additionally, errors will serve as the basis for continuous improvement processes and retraining as needed. These will be documented in performance reviews. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The NSU GEAR UP Principal Investigator and First-Year College Advisor Supervisor are responsible and accountable for ensuring reporting is supported by underlying records. TMCC – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; TMCC reports on the number of participants for all services rendered under the GEAR UP grant through both the Interim Progress Report (IPR) and the Final Progress Report (FPR). The identified issue concerns a discrepancy between the reported participant count on the IPR and the underlying supporting records. To ensure data accuracy going forward, TMCC will implement an additional review of participant reporting. Prior to the submission of progress reports, a second technical reviewer within the GEAR UP team would verify the participant counts entered into GEARS (GEAR UP’s designated data-reporting platform) against the supporting documentation (the attendance sheet). Should a discrepancy be identified, the GEAR UP team will follow up with the individual responsible for the data entry on GEARS to reconcile the difference. This may include requesting correction of data entry errors or obtaining additional documentation to support the reported participant count, as appropriate. Additionally, attendance sign-in sheets will be collected and retained by TMCC staff to allow for direct verification prior to reporting. ● How compliance and performance will be measured and documented for future audit, management and performance review. Compliance and performance will be measured by the implementation of a second reviewer for the participant data reported through GEARS and included in the progress reporting. This review can be documented through an internal checklist, internal communication, or other appropriate records demonstrating that the participant data was reviewed and validated prior to the submission of progress reports. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. Primary responsibility for accurate participant reporting will remain with the TMCC First Year College Advisor (FYCA) or other designated staff responsible for preparing grant performance reports. Responsibility for completing the secondary verification review will be assigned to a designated GEAR UP technical reviewer or program staff member who is independent of the initial data entry and report preparation. If repeat or similar observations occur, program leadership will evaluate adherence to established procedures and implement additional corrective actions, which may include staff retraining, revision of internal procedures, or reassignment of reporting responsibilities, as appropriate. UNLV agrees with this finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; The UNLV OSP will continue to work with PIs to ensure there is a documented review of progress reports. PIs will be expected to demonstrate review of progress reports and provide supporting documentation for data. Additionally, if reports require financial expenditures, the Office of Sponsored Programs will require validation before submission. Communication dissemination will occur twice within the academic year. ● How compliance and performance will be measured and documented for future audit, management and performance review. UNLV OSP will continue communications through Research Weekly (an internal communication newsletter) to remind PIs to ensure timely submission of progress reports and retention of records such as, lab notes, testing, populations served, activities performed, etc. to demonstrate activities supported by the grant. UNLV OSP will maintain communications with PIs to perform monitoring throughout the life of the award. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The UNLV OSP Executive Director is accountable for exercising oversight and responsibility along with the applicable Deans. UNR – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; All participant counts reported in Interim Progress Reports will be supported by retained underlying source documentation that directly reconcile to the reported totals. Standard documentation expectations and retention requirements will be communicated to program staff. ● How compliance and performance will be measured and documented for future audit, management and performance review. Compliance will be measured through pre-submission review of reported participant data against underlying records and through post-submission spot checks conducted by Program Director. Documentation supporting reported counts will be retained in the official project file and made available for future audit, management review, and internal monitoring. Evidence of reconciliation will be documented via checklists or certifications retained with the report. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. Program Director WNC – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; Sponsors have determined grant practices and required reporting documentation, which have not been consistently required or expected of subrecipients. WNC will maintain its own sign-in sheets and documentation for all grant-sponsored activities to ensure compliance with overall grant requirements. The corrective action was implemented in July 2025. ● How compliance and performance will be measured and documented for future audit, management and performance review. The GEAR Up coordinator will create and maintain sign-in sheets or other documentation for every grant-sponsored activity. The coordinator will maintain records in accordance with federal and state guidance and will ensure that supporting documentation is sufficient to support the reported figures. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. Final responsibility and accountability fall on the GEAR Up coordinator and grant administrator. Official Contact: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu

Cash Management Responses WNC – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; Western Nevada College implemented the practice of invoice review (proper segregation of duties) in October 2024, in which all invoices are reviewed from an individual separate from the preparer. This practice has been in place since our October 2024 grant billing period and has continued ever since. This audit finding resulted from the auditor selecting a transaction prior to WNC implementing the new procedure. All other transactions selected by the auditor were in compliance. ● How compliance and performance will be measured and documented for future audit, management and performance review. All grant invoices going forward will have a second level of review prior to drawing down or requesting reimbursement of funds. Documentation will be compiled for each grant invoice that will indicate that a second level of review has been obtained. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The Vice President of Finance & Administration may be held accountable in the future if repeat or similar observations are noted. Official Contact: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu

Allowable Costs/Cost Principles Responses GBC accepts the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; o GBC maintains evidence of review and approval of the payroll expenses in question. GBC is very willing to enhance internal controls to provide for documented review and approval for terminated employees charged to the grant program. o GBC has strengthened internal controls over payroll expenditures charged to federal grants to ensure documented review and segregation of duties, particularly for terminated employees. o Documented evidence of review and approval will be retained within the payroll/grants file to ensure a clear audit trail. o Human Resources and Grants Accounting staff have been reminded of federal documentation requirements specific to grant-funded payroll expenditures. ● How compliance and performance will be measured and documented for future audit, management and performance review. o Quarterly internal reviews of payroll expenditures charged to federal grants, with specific review of terminated employees. o Retention of documented approval evidence in electronic grant files. o Review during annual fiscal year-end grant reconciliations. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. o The Grants Director and Director of Business Operations are responsible for oversight of grant compliance. Official Contact: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu

Reporting Responses UNLV agrees with this finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; The UNLV OSP will continue to work with PIs to ensure there is a documented review of progress reports. PIs will be expected to demonstrate review of progress reports and provide supporting documentation for data. Additionally, if reports require financial expenditures, OSP will require validation before submission. Communication dissemination will occur twice within the academic year. ● How compliance and performance will be measured and documented for future audit, management and performance review. UNLV OSP will maintain communications with PIs to perform monitoring throughout the life of the award. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The UNLV OSP Executive Director is accountable for exercising oversight and responsibility along with the applicable Deans. UNR – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; Management staff, independent of preparer, will review and sign off on each report. This review process will include verifying that all information is correctly entered. ● How compliance and performance will be measured and documented for future audit, management and performance review. Compliance and performance will be measured through the independent review process, where management will verify and sign off on each report to ensure accuracy. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. Associate Director of Post Award Official Contact: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu

Reporting Responses UNR – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; Management Staff, independent of preparer, will review each subaward report required. The review process will include verifying that all subaward information required by FFATA is correctly entered. ● How compliance and performance will be measured and documented for future audit, management and performance review. Compliance and performance will be measured through the independent review process, where management will verify the information in each report is accurate. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. Associate Director of Pre Award Official Contact: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu

Reporting Responses TMCC – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; Two additional layers of review have been added to ensure that every RFR/Invoice is reviewed. On 4/14/25 an extra invoice review was added to Workday ensuring that they have to go through a review by someone other than the creator. During this step, the attachments including RFR and the approval email by the controller is also reviewed for accuracy. The Grant Accountant also established a log in August of 2025 that includes the Due Date, Date sent to the Controller for Approval, the Approval date and the submission date. ● How compliance and performance will be measured and documented for future audit, management and performance review. Emails documenting the review of the RFRs are kept as proof of review and saved in our files as well as Workday. The tracking document will also be made available for future review. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The Grant Accountants will be responsible for ensuring that we are in compliance with the corrective actions UNLV agrees with this finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; UNLV OSP does have separation of duties from the originator of the subaward to the review of the subaward agreement in entering all of the data points into Sam.gov for FFATA reporting; however, UNLV OSP will create a process document that explicitly notes this for future documentation. ● How compliance and performance will be measured and documented for future audit, management and performance review. Cross checking of the issued subaward (originator) is reviewed and entered into the federal portal by the submitter. As the federal portal requires one party to enter and submit, OSP management perceives this to be very low risk but will ensure reviews occur. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The UNLV OSP Executive Director is accountable for exercising oversight and responsibility. WNC – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; Western Nevada College implemented the practice of invoice review (proper segregation of duties) in October 2024, in which all invoices are reviewed from an individual separate from the preparer. This practice has been in place since our October 2024 grant billing period and has continued ever since. This audit finding resulted from the auditor selecting a transaction prior to WNC implementing the new procedure. All other transactions selected by the auditor were in compliance. ● How compliance and performance will be measured and documented for future audit, management and performance review. All grant invoices going forward will have a second level of review prior to drawing down or requesting reimbursement of funds. Documentation will be compiled for each grant invoice that will indicate that a second level of review has been obtained. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The Vice President of Finance & Administration may be held accountable in the future if repeat or similar observations are noted. Official Contact: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu

Cash Management Responses DRI – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; Controls were implemented beginning on April 14, 2025, to require secondary approvals on all sponsored invoice transactions. NSHE’s accounting system was reconfigured to require a review step for all invoice business processes. An individual other than the preparer must now review and approve all transactions. ● How compliance and performance will be measured and documented for future audit, management and performance review. Documentation for all sponsor invoice transactions occurs through the business process history in the accounting system. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The Chief Financial Officer may be held accountable in the future if repeat or similar observations are noted. UNLV agrees with this finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; UNLV Office of Sponsored Programs (OSP) has an internal control that requires a reconciliation form to be completed with each invoice submission. With any manual control, human error may occur, as in this case; however, the reconciliation form is used every time and is reviewed by the originator and approving authority. ● How compliance and performance will be measured and documented for future audit, management, and performance review. Reinforcement of cross-checking of the reconciliation form is enforced and will be used as documentation for review. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The UNLV OSP Executive Director is accountable for exercising oversight and responsibility. Official Contact: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu

Finding 2025-005 Errors in Verification Reporting Condition: Northern Illinois University (University) did not properly code the verification status in the Common Origination and Disbursement (COD) System for students who were disbursed Pell Grant funds and later selected for verification and the internal controls in place did not prevent and detect the exceptions. Corrective Action Plan: University has taken the following corrective actions that will eliminate all material exceptions: 1) University procedures have been updated to ensure verification status updates are properly transmitted to the Common Origination and Disbursement (COD) system upon completion of verification. Relevant staff have been trained on the revised procedures. 2) University has implemented a process to periodically review records and confirm that verification statuses are accurately reflected in COD. All affected student records have been reviewed and corrected. It has been confirmed in the National Student Loan Data System (NSLDS) that none of the mis-reported statuses resulted in an overpayment. Individual(s) Responsible for Corrective Action: Registration and Records Staff Anticipated Completion Date: June 30, 2026

Finding 2025-004 Internal Controls Over Procurement Condition: Northern Illinois University (University) included incorrect documentation within purchase requisition forms for small purchases and simplified acquisition procurement transactions at the time of approval of the purchase which did not allow a reviewer to determine the appropriateness of the procurement method. Corrective Action Plan: University has taken the following corrective actions that will eliminate all material exceptions: 1. The University implemented revised procedures and targeted training beginning in April 2025 to strengthen compliance with 2 CFR 200 procurement requirements. The transactions identified in the condition occurred prior to full implementation of this corrective action. 2. The University will continue to monitor procurement processes to ensure accurate and complete documentation of the procurement method selected. Individual(s) Responsible for Corrective Action: Sponsored Programs & Procurement Services & Contract Management Staff Anticipated Completion Date: June 30, 2026

Finding 2025-003 Errors in Reporting for NSLDS Condition: Northern Illinois University (University) did not properly report enrollment changes for certain students who received federal student aid to the National Student Loan Data System (NSLDS) and the internal controls in place did not prevent and detect errors. Corrective Action Plan: University has taken the following corrective actions that will eliminate all material exceptions: 1. The University will review and strengthen its current enrollment reporting procedures to ensure Program-Level updates are completed consistently, particularly in cases involving unofficial withdrawals. 2. The University will develop a batch reporting process for unofficial withdrawals to facilitate accurate enrollment reporting at both the program and campus level. Additional verification steps will be implemented prior to submission to confirm that both campus-level and program-level enrollment statuses are properly updated. 3. The University will also reinforce staff training related to NSLDS reporting requirements and enhance supervisory review procedures to reduce the risk of similar errors occurring in the future. Individual(s) Responsible for Corrective Action: Registration and Records Staff Anticipated Completion Date: June 30, 2026

Information on the federal program: Subject: Education Stabilization Fund – Special Tests and Provisions - Wage Rate Requirements Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Number: 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Wage Rate Requirements Audit Findings: Material Weakness, Material Noncompliance, Qualified Opinion Context: The School Corporation did not obtain the weekly payroll reports certifications from a company that performed renovations to replace HVAC equipment and install windows in the building. Therefore, no review was performed to ensure that pay rates complied with the federal wage rate requirements. The amount disbursed and reported on the SEFA during the audit period is $696,118 and the labor portion was not determinable by the School Corporation. Contact Person Responsible for Corrective Action: Nathaniel Day Contact Phone Number: 317-462-4434 . Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We will comply with Bacon Davis on future projects using federal funds.

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 Listing Number: 84.010A Federal Award Numbers and Years (or Other Identifying Numbers): S010A220014, S010A230014, S010A240014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Finding: Material Weakness Context: We noted that for 13 of the 40 payroll samples selected, the School Corporation did not have employees fill out semi-annual certifications to support the percentage of their payroll charged to the Title I grants. Contact Person Responsible for Corrective Action: Nathaniel Day Contact Phone Number: 317-462-4434 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We will continue the plan instituted in the 2021-23 Audit. This finding was identified after the first period of the 2023-25 audit and was corrected at that time moving forward.

Information on the federal program: Subject: Special Education Cluster (IDEA) – Internal Controls Federal Agency: Department of Education Federal Program: Special Education Grants to States, Special Education Preschool Grants Assistance Listings Numbers: 84.027 Federal Award Numbers and Years (or Other Identifying Numbers): 22611-131-PN01, 23611- 131-PN01, Contract 78674 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs- Cost Principles Audit Finding: Material Weakness, Other Matters Context: We noted that for 11 of the 40 payroll samples selected, the School Corporation did not have employees fill out semi-annual certifications to support the percentage of their payroll charged to the Special Education Cluster funds. Additionally, for one payroll sample, we noted that the employee was incorrectly paid $1,250 using Special Education Cluster funds prior to the employee performing work related to the Special Education Cluster. Contact Person Responsible for Corrective Action: Nathaniel Day Contact Phone Number: 317-462-4434 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We will continue the plan instituted in the 2021-23 Audit. This finding was identified after the first period of the 2023-25 audit and was corrected at that time moving forward.

Program: AL 21.027 – COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Allowability Corrective Action Plan: DHHS will work with Federal Partners on reviewing allowability of methodology used. Contact: Patrick Werner Anticipated Completion Date: June 30, 2026