Corrective Action Plans

Department of Education 2023-018 Education Stabilization Fund – Assistance Listing No. 84.425C Condition: Property records did not contain accurate information related to certain equipment purchases. Recommendation: We recommend the institutions strengthen its controls and processes related to capturing information relating to equipment purchases and ensure that property records properly reflect the required information. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Property Management department has and will continue to double-check the information being entered into the University’s inventory system as it relates to equipment purchases and University property. The Property Management department will also ensure university departments are completing quarterly self-audits, verifying the information of all assets added to their inventory reports. To ensure this the Property Manager will increase communication reminding departments to check for any discrepancies of newly added assets. Name(s) of the contact person(s) responsible for corrective action: Tanya Donnell, Property Manager; Vance Siggers, Interim Vice President of Campus Operations; and Howard Brown, Vice President of Business and Finance. Planned completion date for corrective action plan: September 01, 2024. If the Department of Education has questions regarding this plan, please call Tanya Donnell, Property Control Manager at (601)979-6354.

Finding 2023-002 – Head Start Cluster – Equipment Contact Person Responsible for Corrective Action: Brenda Overton Contact Phone Number: 574.393.5866 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We will add the equipment to our capital asset listing and ensure inventories are performed at least every two years. Anticipated Completion Date: April 2024

The District accepts the findings as reported. The School Business Official along with the District's Purchasing Agent will review the applicable policy(ies) and procedures and make recommendations for the same, where needed. Until such updates are made, the School Business Official will ensure all that needs to be aware of teh capitalization policy and procedures are made aware.

Significant Deficiency 2023-001. Equipment and Real Property Management United States Department of Education, passed through New York State Department of Education: Education Stabilization Fund (ESF) COVID-19: Governor’s Emergency Education Relief Fund ALN: 84.425C COVID-19: Elementary and Secondary School Emergency Relief Fund ALN: 84.425D COVID-19: American Rescue Plan – Elementary and Secondary School Emergency Relief ALN: 84.425U COVID-19: American Rescue Plan – Elementary and Secondary School Emergency Relief – Homeless Children and Youth ALN: 84.425W Condition: The District did not include equipment purchased using federal grant awards with its current year additions in the District’s capital assets inventory records. Planned Corrective Action: The District will adopt procedures to ensure that equipment purchased with federal funds is included and differentiated in the District’s capital assets inventory records. Responsible Contact Person: Robert Hauser Assistant Superintendent for Business and Operations Connetquot Central School District 700 Ocean Avenue Bohemia, New York 11716 Anticipated Completion Date: June 30, 2024.

We will give instructions to the Head Start program staff to prepare a capital assets subsidiary record which include a full description of the capital assets, the source of the property, who holds title, the acquisition date, cost of the property, percentage of Federal participation in the cost of the property, use and condition of the property, and any ultimate disposition data including the date of disposal, among others.

U.S. Department of Education – Passed-through the NYS Education Department COVID-19 Elementary and Secondary School Emergency Relief Fund; Assistance Listing Number 84.425D; Grant Period – Fiscal Year Ended June 30, 2023 Non-Compliance Criteria: According to 2 CFR section 200.313(d)(1), detailed property records must be maintained for equipment acquired under a federal grant award. Records should include a description of the property, a serial number or identification number, the source of funding (including the federal award identification number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and ultimate disposition data. Condition: During our audit, we noted the District’s fixed asset records were incomplete for some of the assets acquired with federal grant funding during the fiscal year. Cause: The District did not appropriately review and reconcile its expenditure records in order to identify equipment additions purchased with federal funds for the purposes of updating their fixed asset records. Effect: If the District’s fixed asset records are incomplete, they may not be properly safeguarded, and the District may not comply with the aforementioned federal regulations. Recommendation: We recommend that the District update their fixed asset records to include required information for assets purchased with federal awards and that a system of communication and a review process be implemented to ensure completeness and timing of fixed asset addition records. District’s Response: The District reviewed the federal guidelines with the grant administrator, requisitioner, and newly hired purchasing agent/fixed asset keeper on capital asset acquisitions through grants. The District has placed new internal controls to identify capital asset acquisitions through grants; those internal controls include but are not limited to review of minor remodeling, supplies and materials and equipment account codes, identification upon requisition, approval from grant administrator, and review by grant administrator. Before finalizing capital assets reports, the purchasing agent, fixed asset keeper, and current accounting consultant will review the purchase orders for anything above the District's capitalization policy. These controls will ensure the District is compliant and within requirements for capital asset acquisitions through grants. Individual Responsible for Implementing Corrective Action Plan: Brigid Siena, Assistant Superintendent for Business and Operations Implementation Date: March 26, 2024

Other Matters 2023-001. Equipment and Real Property Management United States Department of Education, passed through New York State Department of Education Education Stabilization Fund (ESF) COVID-19: Elementary and Secondary School Emergency Relief Fund ALN: 84.425D COVID-19: American Rescue Plan – Elementary and Secondary School Emergency Relief Fund (ARP ESSER) ALN: 84.425U Condition: The District did not include equipment purchased using Federal grant funds in its current year additions in its capital assets inventory Planned Corrective Action: Management agrees with the finding and will ensure that the temperature control project purchased with federal funds is captured, reconciled, and included in the District’s capital assets inventory records. Responsible Contact Person: Charles Scheid, CPA Assistant Superintendent for Business Southold Union Free School District 420 Oaklawn Avenue P.O. Box 470 Southold, New York, 11971-0470 Anticipated Completion Date: June 30, 2024

Finding 2023-003 – Education Stabilization Fund – Equipment Contact Person Responsible for Corrective Action: Amy Phillips Contact Phone Number: (765) 662-2546 ext 8070 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Marion Community Schools will establish internal controls to ensure that all capital assets are tracked properly. All capital expenditures will be reviewed by the Director of Operations, the Chief Financial Officer or Assistant Chief Financial Officer, and the accounts payable business office specialist. Although we utilize an outside source for maintaining our capital assets ledger, we need to ensure that they receive the necessary information to ensure the accuracy of the ledger. By establishing a regular review of capital assets, we can ensure that everything is accounted for. All new capital assets will be properly reported to our capital assets inventory vendor in a timely manner. The accounts payable department will also be properly trained on coding capital expenditures in the accounting system as another layer of protection. Anticipated Completion Date: Apr 30, 2024

The large purchase of equipment has been resolved with the items added to the inventory system. The grant guidelines classified the purchases as supplies due to the item cost which is how they were originally missed being reported. A large purchase of this type is an anomaly for the District. However, we have added reviewing federal supply purchases to our year end inventory checklist.

FINDING 2023-004 Finding Subject: COVID-19 – Education Stabilization Fund – Equipment and Real Property Management Summary of Finding: Equipment purchased with ESF grant awards, although accounted for in the capital asset listing, were not properly identified with the source of the funding, who holds title, percentage of federal participation in the project costs, etc. Contact Person Responsible for Corrective Action: Debra Elder, Treasurer and John Scioldo, Superintendent Contact Phone Number and Email Address: 812-547-3300; debbie.elder@tellcity.k12.in.us and john.scioldo@tellcity.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We will reach out to AdTec, the company the school corporation works with on the updating of the capital asset records, to request that they add the missing information to the capital asset listing for said purchased equipment as described in greater detail in the audit finding. It is our goal to have this completed by the end of the July 2023 – June 2025 audit cycle. Anticipated Completion Date: No later than June 30, 2025

FINDING 2023-005 Finding Subject: Covid-19 Education Stabilization Fund- Equipment Summary of Finding: A property record or capital asset listing which would include the source of funding for the property (including the federal award identification number (FAIN)), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, and use and condition of the property is to be maintained for assets purchased that exceed the School Corporation's capitalization threshold. The School Corporation maintained a detailed listing of capital assets; however, the asset records provided for audit did not reflect all additions of equipment paid for with the School Corporation’s Education Stabilization Fund award. Twenty-three pieces of equipment, totaling $248,202, were purchased during the audit period, all of which were selected for testing. Sixteen of the pieces of equipment, totaling $133,353, were not added to the listing of capital assets. In addition, the seven pieces of equipment added to the listing did not include all the required information. The missing information included the source of funding for the property (including the federal award identification number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, and the use and condition of the property. Contact Person Responsible for Corrective Action: Andrew Schoff, Business Manager Contact Phone Number: 219-767-2263 Ext 1003 Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: Beginning June 2024 the School Corporation will have a detailed Capital Assets Ledger with any piece of equipment exceeding the amount of $5000.00. The School Corporation is working with an Asset’s Management company to ensure the Capital Assets Ledger is correct and up to date. We will ensure all items that exceed the threshold will be included, as well as, detailed information including the grant program number that items were purchased from. Anticipated Completion Date: These corrective actions will go into effect immediately and will be utilized with the June 30, 2024 to create a Capital Assets Ledger.

FINDING 2023‐003 Finding Subject: COVID‐19 Education Stabilization Fund – Equipment and Real Property Management Summary of Finding: Incomplete information on capital assets, especially when involving federal funding, where having additional internal controls would have prevented the omissions. Contact Person Responsible for Corrective Action: Jill C. Mires Contact Phone Number and Email Address: 812‐883‐4437, jmires@salemschools.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Assets will be better recorded, with separation of duties being the first step of internal controls. Capital assets will be added by the A/P clerk and reviewed by the treasurer. Entries will include previously missing information such as where the asset was purchased and if it was purchased with federal funds, what federal grants were used and the FAIN (Federal Award ID Number). The new treasurer will work on reimplementing the 2‐year inventory process for each building that composes the SCS. Anticipated Completion Date: Dec. 31, 2024

MATERIAL WEAKNESS IN INTERNAL CONTROL OVER COMPLIANCE AND MATERIAL NONCOMPLIANCE – U.S. DEPARTMENT OF EDUCATION – PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, COVID-19 – EDUCATION STABILIZATION FUND (FEDERAL ALN 84.425) 2023-003 Material Weakness in Internal Control Over Compliance and Material Noncompliance With Equipment and Real Property Management Requirements Finding Summary 2 CFR § 200.313(d)(1) requires the District to designate fixed assets purchased under federal programs and to maintain related property records, including a description of the property, a serial number or other unique identification number, the source of funding for the property (including the federal ALN), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use, and condition of the property, and any ultimate disposition data, including the date of disposal and sale price of the property. A physical inventory of the property must be taken and the results reconciled with the property records at least every two years. During our audit, we noted that the District did not have sufficient controls in place within the COVID-19 – Education Stabilization Fund federal program to specifically identify federally funded fixed assets and maintain the required records as noted above to assure compliance with federal equipment and real property management requirements. The District does not have a process or procedure in place for a physical inventory of property acquired with federal funds. One fixed asset purchased with federal awards was not maintained in accordance with federal equipment and real property management requirements. Actions Planned – The District plans to review its internal control procedures to ensure future compliance with the federal compliance requirements specific to equipment and real property management requirements for the COVID-19 – Education Stabilization Fund federal program. Official Responsible – Bryan Hennekens, Director of Finance and Operations. Planned Completion Date – June 30, 2024. Disagreement With or Explanation of Finding – The District agrees with this finding. Plan to Monitor – Bryan Hennekens, Director of Finance and Operations, will ensure that federally funded fixed assets are distinguishable within the District’s finance system. The District also intends to review its control procedures relating to equipment and real property management requirements to ensure compliance for future federal awards expenditures.

FINDING 2023-003 Finding Subject: COVID-19 Education Stabilization Fund - Equipment and Real Property Management Summary of Finding: The School Corporation maintained a detailed listing of capital assets; however, the asset records provided for audit did not include two capitalized expenditures in the amounts of $70,000 and $26,440 related to the replacement of rooftop air conditioning units. Additionally, the capital asset listing provided did not identify which assets were purchased with federal dollars nor did the assets have an assigned serial number or other identification number. Contact Person Responsible for Corrective Action: Tracy Troesch Contact Phone Number and Email Address: 812-817-0900; tracy.troesch@sedubois.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Business Manager has added the two assets referenced above to the asset records. Additionally, the Business Manager has reviewed the capital asset records and noted all capital assets that were purchased with federal funds. The School Corporation will determine a way to assign identification numbers to the assets listed on the record. Anticipated Completion Date: September 2024

The District will review the equipment and real property maintenance procedure with appropriate personnel. These employees will be required to review the policy at a minimum once a year and acknowledge through signature that they have been made aware of the procedure. These signature records will be maintained with their annual training records. Inventory updates and lists will be reviewed at least quarterly by administration to ensure compliance.

The District will review federal expenditures of OCAS object codes to 700s and 450s at year end to the federal inventory listing to ensure all equipment has been captured as required by federal regulations.

FINDING 2023-007 Finding Subject:􀀃COVID􀍲19􀀃􀍲􀀃Education􀀃Stabilization􀀃Fund􀀃􀍲􀀃Equipment􀀃and􀀃Real􀀃Property􀀃Management􀀃 Summary of Finding: The􀀃lack􀀃of􀀃internal􀀃controls􀀃and􀀃noncompliance􀀃were􀀃systemic􀀃issues􀀃throughout􀀃the􀀃audit􀀃 period.􀀃 Contact Person Responsible for Corrective Action: Lela Simmons Contact Phone Number and Email Address: (219) 391- 4100, lesimmons@ecps.org Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: School City of East Chicago will implement update policies to ensure all thresholds are in accordance to state and federal guidelines. Anticipated Completion Date:􀀃We􀀃anticipate􀀃having􀀃the􀀃above􀀃corrective􀀃action􀀃plan􀀃in􀀃place􀀃by􀀃September 30, 2024.

FINDING 2023-004 Finding Subject: COVID-19 Education Stabilization Fund Equipment and Real Property Management Summary of Finding: Inventory not included by Kroll (consultant) on Fixed Asset Ledger Contact Person Responsible for Corrective Action: Phyllis Ritenour Contact Phone Number and Email Address: 317-845-9400 pritenour@msdwt.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: Future Capital Asset Ledgers from Consultant will be reviewed by the Accounting and Assistant Accounting Manager. They will be compared not only to our spreadsheet of new and retired vehicles but also to all capitalized equipment, 734 & 735 object codes, listed in our financial system since the last capital asset review. Anticipated Completion Date: August 2025

COLD SPRING HARBOR CENTRAL SCHOOL DISTRICT Finding #2023-001from the 2022/23 Single Audit with Corrective Action Plan. CORRECTIVE ACTION PLAN Equipment/Real Property Management Condition: During our audit, we noted the District’s fixed asset records were incomplete for some of the assets acquired with federal grant funding during the fiscal year. District Corrective Action Plan o The District has developed a comprehensive standard operating procedure (SOP) that will ensure compliance with the District’s Capital Asset policy, including timely tagging of assets and ongoing safeguarding of assets. The SOP appoints a property control manager that will be responsible for tagging assets timely and in accordance with our policy. This person will also perform quarterly physical inventory testing to ensure assets are safeguarded. See attached detailed SOP. o Responsible Parties: ▪ Christine Costa, Assistant Superintendent for Business ▪ Christine Johnson, Treasurer ▪ Lisa Bifulco, Deputy Purchasing Agent ▪ Dawn Fox, Property Control Manager o Completion Date: December 2023

FINDING 2023-002 Finding Subject: COVID-19 – Education Stabilization Fund – Equipment and Real Property Management Summary of Finding: Internal controls were not in place to ensure compliance with requirements related to the Equipment and Real Property Management requirement. Contact Person Responsible for Corrective Action: Scott Weltz, Michelle Wolfe Contact Phone Number and Email Address: 765-654-5585, weltzs@frankfort.k12.in.us, wolfem@frankfort.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Internal controls will be established and followed to ensure compliance with requirements related to the grant agreement. This will ensure that an asset inventory is completed for the school corporation Anticipated Completion Date: Effective immediately and ongoing

The Superintendent, Corporation Treasurer and Director of Facilities will monitor equipment purchases larger than $5,000. Once the purchase is made, the Director of Facilities will tag the equipment and notify the company when the Fixed Asset Inventory is completed. Responsible party and timeline for completion: Superintendent, Corporation Treasurer and Director of Facilities. Fixed Asset Inventory is completed once every 2 years. Next inventory will be completed in June, 2025 and the equipment not listed will be added at that time.

Finding 2023-005 Information on the federal program: Subject: Education Stabilization Fund – Internal Controls over Equipment Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Equipment and Real Property Management Audit Findings: Material Weakness Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Equipment and Real Property Management Requirements compliance requirements. Context: The School Corporation expended $2,354,885 during the audit period on equipment acquisitions for a new HVAC system and chiller at the North White Middle-High School building. Equipment acquisitions were charged to the ESSER II (84.425D) and ESSER III (84.425U) grant awards. During the testing of equipment acquisitions, it was noted the School Corporation had not update the capital asset ledger as of June 30, 2023 for equipment acquisitions made during the period under audit. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. When the capital asset inventory is completed, the Corporation Treasurer and the Building/Maintenance Director will verify the inventory is up to date and accurate. Responsible Party and Timeline for Completion: The Corporation Treasurer, Emma Conwell, and Building/Maintenance Director, Dean Cook, will oversee the corrective action plan which will be implemented by June 30, 2024.

MATERIAL WEAKNESS IN INTERNAL CONTROL OVER COMPLIANCE AND MATERIAL NONCOMPLIANCE – U.S. DEPARTMENT OF EDUCATION – PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, COVID-19 – EDUCATION STABILIZATION FUND – FEDERAL ALN 84.425 2023-005 Material Weakness in Internal Control Over Compliance and Material Noncompliance With Equipment and Real Property Management Requirements Finding Summary 2 CFR § 200.313 requires the District to designate fixed assets purchased under federal programs and to maintain related property records, including a description of the property, a serial number or other unique identification number, the source of funding for the property (including the federal ALN), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use, and condition of the property, and any ultimate disposition data, including the date of disposal and sale price of the property. A physical inventory of the property must be taken and the results reconciled with the property records at least every two years. During our audit, we noted that the District did not have sufficient controls in place within the COVID-19 – Education Stabilization Fund federal program to specifically identify federally funded fixed assets and maintain the required records as noted above to assure compliance with federal equipment and real property management requirements. The District does not have a process or procedure in place for a physical inventory of property acquired with federal funds. Two fixed assets purchased with federal awards were not maintained in accordance with federal equipment and real property management requirements. Corrective Action Plan Actions Planned – The District plans to review its internal control procedures to ensure future compliance with the federal compliance requirements specific to equipment and real property management requirements for the COVID-19 – Education Stabilization Fund federal program. Official Responsible – Sara Bratsch, Director of Finance. Planned Completion Date – June 30, 2024. Disagreement With or Explanation of Finding – The District is in agreement with this finding. Plan to Monitor – Sara Bratsch, Director of Finance, will ensure that federally funded fixed assets are distinguishable within the District’s finance system. The District also intends to review its control procedures relating to equipment and real property management requirements to ensure compliance for future federal awards expenditures.

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

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