Corrective Action Plans

FINDING 2025-006 Finding Subject: COVID-19 Education Stabilization Fund - Equipment and Real Property Management Contact Person Responsible for Corrective Action: Andrea Miller Contact Phone Number and Email Address: 765-564-2100 ext 1002, millera@delphi.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The School Corporation will amend the capital asset listing to include the full $802,314 improvement project, and accurately account for the $344,829 federal portion and calculate the percentage of federal participation. The Corporation Treasurer will prepare a spreadsheet to track all future construction progress and share with the Superintendent and Maintenance Director. This document will then be shared with the capital asset consultant annually for reporting purposes. A column will be added to the capital asset ledger to mark if federal funds were used. Anticipated Completion Date: June 2026

FINDING 2025-003 Finding Subject: Head Start Cluster – Equipment and Real Property Management Contact Person Responsible for Corrective Action: Tina Smith Contact Phone Number and Email Address: (765) 825-2178 tlsmith@fayette.k12.in.us Views of Responsible Officials: We concur with this finding. Description of Corrective Action Plan: The Treasurer will work closely with Ad-Tech to ensure that all required information is reported accurately. Anticipated Completion Date: The capital assets inventory list will be updated to include the above required information beginning with the 2025-2026 Inventory Report.

The KCS Special Education Department will undertake a new physical inventory of all IDEA equipment, updating any inaccurate asset numbers, serial numbers, and locations in the Incident IQ asset management system. Additionally, effective for FY 2027, the District will restructure the department by moving a Special Education IT Asset Management position under the supervision of the District Property Manager to ensure IDEA asset management is consistent with all district property management.

Finding 2025-005 Information on the federal program: Subject: Education Stabilization Fund – Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425U Federal Award Numbers: S425U210013 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 previous 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 in the prior audit period. During the testing of equipment acquisitions, it was noted the School Corporation had not updated the capital asset ledger as of June 30, 2025 for federal equipment acquisitions made in the current and prior period and had not fully implemented the corrective action plan from the previous audit related to this finding. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: 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: Treasurer and Building/Maintenance Director will work together after the school year to ensure the capital asset inventory is current.

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 2025-007 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. Fixed assets purchased with federal awards have not been 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 – Kathleen Heider, Finance Director. Planned Completion Date – June 30, 2026. Disagreement With or Explanation of Finding – The District is in agreement with this finding. Plan to Monitor – Kathleen Heider, Finance Director, 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.

PTS will update the capital asset listing to include all of the required information, including the source of funding the property. The Assistant Director of Finance will prepare the listing annually, and the CFO will review for completeness and accuracy before finalizing the list.

FINDING 2025-005 Finding Subject: COVID-19 - Education Stabilization Fund - Equipment and Real Property Management Contact Person Responsible for Corrective Action: Jamesi Lemon Contact Phone Number and Email Address: jlemon@lakelandlakers.net Views of Responsible Officials: We concur with the finding. 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 School Corporation department heads. Anticipated Completion Date: The projected date of completion is August 31, 2026.

Management is currently in the process of conducting a full physical inventory of equipment purchased using federal funds that have a net book value greater than zero in accordance with 2 CFR sections 200.313(c) through (e). The inventory process will be reviewed by management to ensure timely, accurate completion. Going forward, the University will tag all new assets acquired using federal funds. In addition, a revised policy has been established relating to an annual physical inventory of federally purchased equipment to facilitate compliance and increase related inventory controls. The revised policy includes, among other details, standard requirements for inventory tagging and related monitoring.

Information on the federal program: Subject: Education Stabilization Fund – Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425U Federal Award Numbers: S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Equipment and Real Property Management Audit Findings: Material Weakness Context: For the 2 sample items tested, the acquisitions were not reported on the capital asset listing for the School Corporation as of June 30, 2025. For one of the sample items, the School Corporation expended $333,000 on building renovations which was charged to the ESSER III (84.425U) grant award. For the other sample item, the School Corporation expended $71,000 for locker room upgrades that was charged to the ESSER III grant. Additionally, we noted the School Corporation’s capital asset listing did not contain all the required information, including the source of funding for the property, outlined in the criteria above. Contact Person Responsible for Corrective Action: Eric Speicher Contact Phone Number: 574-598-2768 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The school management will work with the company it hired for asset management to ensure that all items are properly listed on the asset list. The school management will conduct a thorough secondary review of the company’s final asset list.

Information on the federal program: Subject: Education Stabilization Fund – Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U, 84.425W Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S425U210013, S425W210015 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Equipment and Real Property Management Audit Findings: Material Weakness Context: For the 2 sample items tested, the acquisitions were not reported on the capital asset listing for the School Corporation as of June 30, 2025. For 1 sample item, the School Corporation expended $810,047 on building renovations which was charged to the ESSER III (84.425U) and ESSER II (84.425D) grant awards. For the other item, the School Corporation expended $9,182 on a vehicle which was charged to the ESSER HCY (84.425W) grant award. Additionally, we noted that the School Corporation’s capital asset listing did not contain all required information, including the source of funding for the property, as outlined in the criteria above. 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: I will work with our Capital Asset Inventory vendor to identify and document correctly equipment purchases.

Finding 2025-006 e. Program Name: Head Start and Early Head Start f. Criteria or Specific Requirement: Physical Inventory Observation: Under 2 CFR 200 200.313(4)(2), a physical inventory of property must be taken at least once every two years. The results should be reconciled with the general ledger. g. Condition: The Organization has not performed a physical inventory in the last two years. h. Response: Physical inventory is currently underway, at about 50% completion across multiple locations. We estimate this will be completed by the end of the fiscal year.

FINDING 2025-001 Information on the federal program: Subject: Education Stabilization Fund – Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425U Federal Award Numbers: S425U210013 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: For 1 of 2 sample items tested, we noted the School Corporation expended $88,727 on bus garage additions which was charged to the ESSER III (84.425U) grant award. It was noted this capital asset acquisition was not reported on the capital asset listing for the School Corporation as of June 30, 2025. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. Our current protocol puts the sole responsibility for updating the capital asset listing on the Corporation Treasurer. Our policy will be revised to include at least 2 people who review the listing on an annual basis. Responsible Party and Timeline for Completion: Sarah Briggeman, Treasurer. Anticipated completion date: 5/31/26.

FINDING 2025-002 Finding Subject: COVID-19 – Education Stabilization Fund – Equipment and Real Property Management Contact Person Responsible for Corrective Action: Eric Rosebrough, Director of Facilities Contact Phone Number and Email Address: 317-244-0236 erosebrough@speedwayschools.net Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: 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. There have been no new ESSER purchases since 2023. Anticipated Completion Date: This is currently being corrected as of 02/17/2026.

FINDING 2025-001 Finding Subject: COVID-19-Education Stabilization Fund-Equipment and Real Property Management Contact Person Responsible for Corrective Action: Monica Young, Treasurer Contact Phone Number and Email Address: 812-482-1801 myoung@gjcs.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action: An Excel spreadsheet has been developed for the Exceptional Children’s Co-op, the Patoka Valley Vocational Co-op and the Greater Jasper School Corporation to complete for all equipment bought over the $5,000 threshold. Also, they will denote which purchases are made with federal funds. The entities will give their information to Greater Jasper when they have an item that needs to be added to the fixed asset list so the company can add it to the report. The information given to Greater Jasper from the Exceptional Children's Co-op will be signed off by the director and bookkeeper. The list from Patoka Valley will be signed by the director. Anticipated Completion Date: Immediately

Finding 2025-003 – Education Stabilization – Equipment and Real Property Management Context: For 1 of the 3 sample items tested, the acquisitions were not reported on the capital asset listing for the School Corporation as of June 30, 2025. For 1 sample item, the School Corporation expended $38,840 on building renovations which was charged to the ESSER III (84.425U) grant award. Contact Person Responsible for Corrective Action: Kimberly Nieves Contact Phone Number: 219-766-2214 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: As an internal control, the Director of Business Affairs and Human Resources has reviewed the requirements for Equipment and Real Property Management. We will review our Capital Asset Listing and ensure that we are including these items. Anticipated Completion Date: August 2026

Finding 2025-001: Equipment and Real Property Management – Compliance and Internal Control (Significant Deficiency) Research and Development Cluster View of Responsible Officials and Planned Corrective Action: The University concurs with the auditor’s finding. Management is conducting a comprehensive review of the matter to confirm full compliance with the requirements of 2 CFR 200.313(d)(2). As part of this process, the University is strengthening its internal controls and procedures related to federally funded equipment. Going forward, the University will ensure that all equipment acquired with federal grant funds is tagged, recorded, and supported by complete and applicable documentation. Additionally, procedures will be reinforced to ensure ongoing inventory verification and monitoring to maintain continued compliance with federal regulations. Name of Contact Person(s) Responsible for the Plan: Benjamin Durant, SVP/COO Finance & Administration durantb@montclair.edu Anticipated Completion Date: June 30, 2026

Significant Deficiency 2025-001. Equipment and Real Property Management United States Department of Education, Passed-through New York State, Department of Education: Special Education Cluster Special Education Grants to States: IDEA Part B ALN: 84.027 Special Education Preschool Grants: IDEA Preschool ALN: 84.173 Condition: The District did not include, as additions in the District’s capital assets inventory records, all equipment purchased with federal awards. 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: Sharon Donnelly, Assistant Superintendent for Business. Harborfields Central School District 2 Oldfield Road Greenlawn, New York 11740 donnellys@harborfieldscsd.org 631-754-5300 Anticipated Completion Date: June 30, 2026.

FINDING 2025-003 Finding Subject: Subject: COVID-19 - Education Stabilization Fund - Equipment and Real Property Management Audit Findings: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Ellen Prince and Chrystal Street Contact Phone Number and Email Address: ellenprince@crothersville.k12.in.us; cstreet@crothersville.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The district has established a comprehensive capital asset ledger that includes all equipment and real property. The previously omitted building has been added with full acquisition and cost information. We will implement procedures to conduct and document a physical inventory of capital assets at least once every two years. Responsibility for maintaining the ledger and overseeing inventory procedures will be assigned to designated administrative staff to ensure ongoing compliance and accurate reporting. Anticipated Completion Date: February 28, 2026

2025-020 EQUIPMENT AND REAL PROPERTY MANAGEMENT DEPARTMENT OF AGRICULTURE (DOA) Assistance Listing Number: 93.103 The property for which adequate records (tested against 2 CFR 200) were unavailable for the Department of Agriculture was purchased in 2010, before the implementation and 2 CFR 200. Federal financial assistance for State governments was governed by circular A-102 during time of purchase which did not have equivalent property management requirements as found in circular A-110 and subsequently 2 CFR 200. Adequate records were available for the two additional properties sampled purchased in 2017 and 2021, demonstrating the current property management system and processes are adequate to meet requirements of current federal financial assistance. Moving forward, DOA will be reviewing current property records to ensure compliance with 2 CFR 200.313.

U.S. DEPARTMENT OF EDUCATION AND INDIANA DEPARTMENT OF EDUCATION Charter Schools – AL #84.282 Education Stabilization Fund – AL #84.425C, 84.425D & 84.425U U.S. Department of Education Herron High School, Inc. d/b/a Herron Classical Schools and its Wholly-Owned Subsidiaries (the Organization) respectively submits the following corrective action plan for the year ended June 30, 2025. Name and address of independent public accounting firm: Donovan CPAs 9292 N. Meridian Street, Suite 150 Indianapolis, IN 46260 Audit period: Year ended June 30, 2025 The findings from the schedule of findings and questioned costs for the year ended June 30, 2025, are discussed below. The findings are numbered consistently with the numbers assigned in the Schedule. FEDERAL AWARD FINDINGS AND QUESTIONED COSTS U.S. DEPARTMENT OF EDUCATION AND INDIANA DEPARTMENT OF EDUCATION Education Stabilization Fund – AL #84.425C, 84.425D & 84.425U 2025-001 Equipment and Real Property Management (Repeat Finding 2024-002) Significant Deficiency Recommendation: The Auditor recommended the Organization develop a system of internal controls aligned with the applicable compliance requirements to properly track equipment acquisitions in the accounting records and to ensure a physical inventory is appropriately documented when completed. Planned Corrective Action: The Organization has begun to notate and identify equipment and property purchased with federal funds in accounting records by using appropriate coding methods. These items will be visible on the fixed asset register. Regular annual inventory measures will be conducted for compliance and reporting. Michelle Krauter, VP, Chief Financial Officer, will oversee the ongoing implementation of this process to ensure adherence to all compliance requirements and this process has already begun as of the finalization of this audit. Will be completed within fiscal year.

Corrective Action: I-CARE, Inc. will strengthen equipment and real property management practices to ensure alignment with UniformGuidance requirements. The Agency will update policies, enhance documentation, and reinforce internal oversight toensure accurate tracking, authorized use, and proper disposition of federally funded assets. Key Actions: Update property and equipment management policies. Strengthen asset tracking and documentation procedures. Reinforce staff training and internal oversight. Complete inventory reconciliation and documentation review. Responsible Officials: Director of Finance, in coordination with Program Leadership. Anticipated Completion Date: Within 120 days of audit acceptance. Status: In progress.

Corrective Actions Taken or Planned: MARTA has grown substantially in the last several years. This progress includes identifying areas that need to be updated or developing new processes and documentation. MARTA has an Asset Inventory Policy and Procedures in which the purpose is to ensure that fixed assets are properly accounted for, identified, and tracked. MARTA also has Cash Handling Policy and Procedures which addresses safeguarding public funds and maximizing the available resources. This is designed to reduce the risks associated with the collection, receipts storage and reporting of cash transactions and to safeguard and maintain the security and integrity of MARTA's fiscal assets. MARTA will review and update these policies and/or create new policies to make sure that they are compliant with the Uniform Guidance. Personnel responsible: Sandy Benson, General Manager Anticipated completion date: October 2026

Finding 2025-002 – Education Stabilization – Equipment and Real Property Management Context: For the 3 sample items tested, the acquisitions were not reported on the capital asset listing for the School Corporation as of June 30, 2025. For 1 sample item, the School Corporation expended $5,528,730 on building renovations which was charged to the ESSER III (84.425U) grant award. The other 2 sample items were equipment purchases totaling $25,554 charged to the Homeless Children and Youth Grant (84.425W) grant award. Additionally, we noted the School Corporation’s capital asset listing did not contain all the required information, including the source of funding for the property, outlined in the criteria above. Contact Person Responsible for Corrective Action: Katy Dowling Contact Phone Number: 317-869-4364 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The township will implement a capital asset process that will identify roles and responsibilities and have appropriate internal controls to ensure accuracy. Anticipated Completion Date: June 30, 2026

Finding 2025-001: U.S. Department of Health and Human Service, National Institutes for Health Research and Development Cluster, Cancer Control, Assistance Listing #93.399; Lack of Required Written Policies Corrective Action: We agree with the recommendation. We do currently require complete supporting documentation for all expenditures. Montana Cancer Consortium (MCC) has updated the Financial Process Procedure to include language related to receipt management, allowable and disallowed grant expenses, and timing of payment requests. Timeline: This was implemented on December 1, 2025. Responsible Parties: MCC Director, Principal Investigators

2025-004: Equipment Management U.S. Department of Education Passed through Missouri Department of Elementary and Secondary Education Education Stabilization Fund, Assistance Listing No. 84.425D (COVID-19—Elementary and Secondary School Emergency Relief Fund), 84.425U (COVID-19—American Rescue Plan-Elementary and Secondary School Emergency Relief), 84.425W (COVID-19—American Rescue Plan-Elementary and Secondary School Emergency Relief-Homeless Children and Youth) Federal award years 2023-2025 Criteria: The Uniform Guidance (2CFR 200.303) requires nonfederal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Also, in accordance with 2 CFR section 200.313(d)(1), property records must be maintained that include a description of the property, a serial number of other identification number, 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, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property. In accordance with 2 CFR section 200.313(d)(2), a physical inventory of equipment and property must be taken, and the results reconciled with the property records at least once every two years. Condition: During the fiscal year 2024 audit, it was previously reported that the District’s controls were not operating effectively to reasonably ensure the District had maintained property records with the above required information, nor had it performed the required physical inventory of equipment within the two previous years. During fiscal year 2025, the District incorporated processes and controls over equipment management that met the property record requirements. The District also performed a physical inventory during fiscal year 2025 that included counting and reconciling approximately half of the District’s equipment and property within this grant program. Therefore, the District had not yet met the requirements of performing a physical inventory of all equipment and property within the previous two years. Cause: Given the timing of when the District incorporated its processes and controls, insufficient time remained to perform a physical inventory of all the District’s equipment and property within this grant program, and only approximately half of the items were subject to the physical inventory. Effect or potential effect: The District is not in compliance with federal grant requirements over the physical inventory of equipment. Improper equipment procedures could result in actions taken by oversight agencies which could impact future funding. Questioned costs: None Context: As noted above, the District updated its property records for all its property and equipment, and then approximately half of the District’s property and equipment was subject to a physical inventory. Identification as a repeat finding, if applicable: 2024-004 and 2024-006. Recommendation: We recommend the District continue to perform the processes and controls it added during fiscal year 2025, and complete the inventory count for the remaining items, to be compliance with the federal grant 2 year cycle. View of responsible officials: Management agrees with this finding. Corrective Action: Management plans to continue to keep detailed records and perform physical inventories in accordance with 2 CFR section 200.313(d)(2). Anticipated Completion Date: June 30, 2026 Contact Person: Dominic Accurso, Controller 816-321-5000 Dominic.accurso@nkcschools.org