Corrective Action Plans

Finding 2023-004 – Education Stabilization Fund – Equipment 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 engage a third-party vendor to complete a Capital Asset Inventory every fiscal year. Anticipated Completion Date: 6-30-2024

DEA Asset Forfeitures – Assistance Listing No. 16.922 Recommendation: Procedures should be updated to ensure all assets purchased with federal funds go through a physical inventory count every 2 years. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Waltham Police Department Policy Chapter 17 – Fiscal Management – has been updated/amended adding a stand-alone paragraph mandating a physical annual audit of any assets purchased with federal funding. Name(s) of the contact person(s) responsible for corrective action: Deputy Police Chief Steven R. Champeon Planned completion date for corrective action plan: On or about April 5, 2024, the policy should be finalized and distributed department wide.

CORRECTIVE ACTION PLAN: For the findings and questioned costs relating to federal awards of fiscal year ended June 30, 2023, Finding No. 2023-001 - Equipment and Real Property Management: Criteria: 2 CFR section 200.313(d), Equipment Management Requirements, states that: Procedures for managing equipment (including replacement equipment), whether acquired in whole or in part under a Federal award, until disposition takes place will, as a minimum, meet the following requirements: (1) Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the FAIN), who holds title, the acquisition date, and 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. (2) A physical inventory of the property must be taken, and the results reconciled with the property records at least once every two years. (3) A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated. (4) Adequate maintenance procedures must be developed to keep the property in good condition. (5) If the non-Federal entity is authorized or required to sell the property, proper sales procedures must be established to ensure the highest possible return. Condition: The last physical inventory of the property was taken on July 13, 2021, with the property subsidiary as of August 2020. A physical inventory should have been performed on or before July 13, 2023. Cause: The Inventory would be done during fiscal 2022-2023, but the employee in-charge of fixed assets got a chronic condition diagnostic. After the diagnostic the employee is underperforming. The beginning of the inventory was postponed as stated in the corrective action section of this document. Effect: Conducting physical inventory ensures compliance with regulations and helps maintain accountability for the use of federal expenditures, prevents fraud and abuse, and helps identify surplus or underutilized equipment, leading to more efficient allocation of resources. In addition, the condition above resulted in assets that could not be found in the facilities due to disposal after the date of the inventory observation, items relocated to other areas and items purchased after the date of the last inventory observation. Questioned Cost: None. Corrective action: The Foundation duly complies with four of five requirements of 2 CFR section 200.313(d). Management is committed to fully complying with the regulations. A plan is being developed to begin a physical inventory by the end of the fiscal year ending Juen 30, 2024. Finance staff will perform the inventory, along with the staff of the Foundation departments. The inventory plan will include the following: • Establish time schedules. • Identify responsible parties. • Detail description of entire inventory process. • Send to research laboratories, clinical research, clinical laboratory and administrative offices, the subsidiary list of the inventory as per the subsidiary, along with instructions. • Establish a deadline to departments send to finance the certified list of inventories. • Upon receipt of department inventories the finance staff will schedule a visit to each department, to confirm the inventory certification received. • Reconcile the inventory with general ledger and make the necessary adjustments in general ledger and the subsidiary. • Prepare an inventory report, for record, and for audit purposes. The report’s total dollar amount will be reconciled with the general ledger, including all equipment certified in the inventory. Submitted on March 15, 2024, by: Alejandro Ramírez Chief Financial Officer

Finding 2023-009 Finding Subject: COVID-19 - Education Stabilization Fund - Equipment and Real Property Management Summary of Finding: The School Corporation made one purchase of equipment with grant funds, a school bus in the amount of $204,961. The school bus was acquired in June 2021, late in the prior audit period, and the expenditure was reimbursed under the ESSER II award in July 2021 in the current audit period. The lack of internal controls resulted in material noncompliance with the equipment requirements of the federal award. The School Corporation did not maintain a capital asset ledger during the audit period, so the equipment purchased was not maintained in the property records as required. Additionally, the School Corporation did not perform a physical inventory of equipment at least once every two years as required. The School Corporation did comply with the requirements to appropriately safeguard and maintain the equipment, but no key control was identified that would prevent, or detect and correct, noncompliance with these requirements if it were to occur. Contact Person Responsible for Corrective Action: Terry Richey and Chrystal Street Contact Phone Number and Email Address: 812.793.2061 trichey@crothersville.k12.in.us cstreet@crothersville.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The corporation treasurer and the superintendent will investigate a capital asset program that we will be able to maintain ourselves. This might include reaching out to districts similar in size to see what they utilize or to work with an agency that can get us started. Anticipated Completion Date: April 1, 2024

Department: Education Title: Internal control over ESF subrecipient monitoring procedures needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: During the review of ESF applications, the Office of Federal Emergency Relief Programs (OFERP) team will confirm that equipment purchases are denoted in the equipment budget category of the application. Equipment inventories and real property lists will be collected during the subrecipient monitoring process from school administrative units (SAUs) and reviewed for compliance by the OFERP team. Completion Date: Ongoing and July 1, 2024 respectively Agency Contact: Shelly Chasse-Johndro, Director of OFERP, DOE, 207-458-3180

Significant Deficiency 2023-001. Equipment and Real Property Management Education Stabilization Fund (ESF) COVID-19: Elementary and Secondary 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 with Federal 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: Dr. Rubie R. Harris, Assistant Superintendent for Finance & Management Services Huntington Union Free School District 50 Tower Street Huntington Station, New York 11746 Anticipated Completion Date: June 30, 2024.

FINDING 2023-007 Finding Subject: Education Stabilization Fund - Equipment and Real Property Management Summary of Finding: Finding: Education Stabilization Funds may be used to purchase equipment. Capital expenditures for general and special purpose equipment purchases are subject to prior by ED or the pass-through entity. In addition, with prior approval by the ED or the passthrough entity, recipients and subrecipents may use ESF funds to purchase real property and perform construction or minor remodeling, and for improvements to land, buildings, or equipment that meet the overall purpose of the ESF program, which is "to prevent, prepare for, and respond to" the COVID-19 pandemic. The School Corporation had not established policies or procedures to ensure compliance with requirements related to the grant agreement and the Equipment and Real Property Management compliance requirements. The School Corporation purchased two servers and completed a HVAC project using ESF funds however those items were not included on property records that included all the required information (including a description, source of funding, percentage of federal participation, location, and use and condition of the property). In addition, a physical inventory was not completed after the equipment was purchased. Recommendation: We recommended that management of the School Corporation design and implement a proper system of internal control, including policies and procedures that would provide segregation of duties to ensure property records are maintained for equipment and real property purchased with federal funds and a physical inventory to be completed at least every two years. Contact Person Responsible for Corrective Action: Dr. Tim Garland Contact Phone Number and Email Address: 574-626-2525 / garlandt@lewiscass.net Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Lewis Cass does have an asset management documentation but it has not been updated since October 2020. Lewis Cass has been actively pursuing an asset management vendor to perform a thorough review and update our current property. The items listed on this finding have been add to the property records. Lewis Cass has the task of finding a new asset management firm and update property records. This task will be completed by fiscal year 2025. Anticipated Completion Date: 6/30/2024

Finding # 2023-023 Title of Finding Equipment and Real Property Management Contact Person Sarah Wills and Christine Miller Anticipated Completion Date FY 2024 Corrective Action planned to be taken: The Board will establish procedures that will ensure compliance with requirements of the United States Department of Education's equipment management requirements and the requirements applicable to the ESSER program.

Description of Corrective Action Plan: The Superintendent, Corporation Treasurer, Director of Grants and the Director of Facilities and / or Director of Technology will monitor equipment purchases larger than $5,000. Once the purchase is made, the Director of Facilities and / or Director of Technology will tag the equipment and notify the Director of Grants, Treasurer and Superintendent when the fixed asset inventory is completed and updated. Responsible Party and Timeline for Completion: Treasurer, Jill Wagoner, Director of Grants, Eric Knebel, Director of Technology Brandon Shafter, Director of Facilities Zac Moore, Superintendent, Dr. Angela Piazza. The corrective action will be implemented starting immediately.

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.