Corrective Action Plans

The District immediately took corrective action by adding the items to the equipment subsidiary ledger. The District acknowledges the need to further strengthen the internal control process to prevent similar failures in the future. In addition to strengthening internal controls, the District has sought ancillary services to improve the management of equipment and the recording of items to the equipment subsidiary ledger.

Finding Number: 2024-001 Planned Corrective Action: The Board of Directors has a Fixed Asset and Inventory Policy in place which requires all acquisitions of property purchased with federal funds to be placed in the Board’s inventory and appropriately tagged with identifying information, including the specific grant funds used for the acquisition. In addition, the Policy requires the Education Management Organization (“EMO”) to maintain data records and an accurate inventory of all Board-owned property. The EMO is responsible for performing an annual physical inventory of all property owned by the School and non-Board assets located at the School. The inventory process includes confirming and validating asset records and confirming compliance with legal, auditing/reporting and insurance requirements regarding all Board-owned assets. The EMO is also required to compare the actual inventory on hand to property records and the Board reviews a copy of the comparison report on an annual basis. Skyway has recently purchased an inventory tracking system that will provide information on all tangible inventory in the building with necessary information to include funding source of the item purchased. The inventory hardware is currently getting the software installed. Once this is complete (April 2025) a full inventory process will be taking place for all tangible items in the building. The process of inputting all information and tagging each item will be completed before the beginning of August 2025. The new inventory system will replace any inventory systems or processes used in the past and all previous tags will be removed and replaced. Anticipated Completion Date: August 1, 2025 Responsible Contact Person: Stephanie Ataya, Treasurer and Noreen Brown, Director of Federal Programs

2024-008 Research and Development Cluster & Higher Education Institutional Aid– Federal Assistance Listing Nos. Various and 84.031 – Physical Inventory on Property & Equipment Recommendation: We recommend the University review its policies and procedures related to PPE purchased with federal funds and include the necessary information to be compliant. Explanation of disagreement with audit finding: There is no disagreement to the audit finding. Action taken in response to finding: Restricted Fund Accounting (RFA) will work with the Assistant Controller to ensure access to information about the PPE purchased with federal funds are readily available. RFA & Assistant Controller will have quarterly reviews of PPE listing related to federal funds. Name(s) of the contact person(s) responsible for corrective action: Director of Accounting, Tonya A. Cardwell & Assistant Controller, Clifton Smith, II. Planned completion date for corrective action plan: October 2025

Contact Person: Business Manager Planned Corrective Action: The Business Manager currently maintains a file which includes documentation in support of all amounts submitted on federal quarterly SF-425 reports. Planned Completion Date: Throughout the fiscal year ending June 30, 2025 and ongoing 2024 – 007 Contact Person: Business Manager Planned Corrective Action: The District will perform a physical inventory of all equipment purchased with federal dollars. Planned Completion Date: June 30, 2025

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 Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Equipment and Real Property Management Audit Finding: 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 was not able to provide a complete capital asset listing with the required information to support that the equipment purchases of $46,727 and $12,408 with COVID-19 – Education Stabilization Fund ESSER II and ESSER III funds had been added to the capital asset listing. Additionally, the School Corporation was not able to provide support that an inventory of capital assets had taken place at least once in the last 2 year. Corrective Action Plan: The School Corporation will implement a system of internal controls to ensure the capital asset listing is updated at least annually to include all equipment and real property acquisitions as well as dispositions that took place. The School Corporation will ensure the capital asset listing includes all required information. Person responsible for implementation and projected implementation date: The Business Manager will be responsible for overseeing the implementation of the corrective action plan, which will go into effect immediately.

2024-004 Contact Person: Duane Poitra, Business Manager Corrective Action Plan: The purchasing agent acquired verification that American Rescue Plan – Elementary and Secondary School Emergency Relief (ESSER III) may be used for IDEA B allowable special education purchases. Moving forward, prior approval will be acquired by District purchasing agents on the ND DPI Capital Expenditure Prior Approval For Use of Federal Funding form before capital purchase is made using federal funding. Anticipated Completion Date: Fiscal Year 2024-2025

Personnel Responsible for Corrective Action: Julie McGovern, Chief Financial Officer Anticipated Completion Date: September 30, 2025 Corrective Action Plan: Due to turnover in the Business Office, the corrective plan identified with the FY23 audit was not completed. The corrective action remains the same. The Business Office will implement a systematic process to properly track fixed assets that will include a description of the property, a serial / identification number, the source of the funding for the property including the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any disposition information should the asset be sold, retired or disposed. A key resource has been obtained that will enable this project to be completed in the timeframe noted.

The University initiated a thorough inventory process, including a requirement to tag and photograph all assets, during the fiscal year ended June 30, 2024. The inventory process was started on schedule in May 2024, and departments were asked to complete their inventory procedures and sign off on the inventory reports by June 2024. Despite the additional complications created by the University’s campus relocation project necessitated by the closure of the Hawai‘i Loa campus and the construction of the science laboratories, 91% of the departments completed their inventories prior to June 30, 2024. The remaining 9% of departments completed their inventories after requesting an extension and/or providing additional details on the requested inventory items in the meantime, and these inventories were completed during the fiscal year ending June 30, 2025. These results demonstrate improvement and progress compared to the prior year’s finding in this area and illustrate the University’s commitment to adhering to tits fixed asset inventory processes and procedures. The University is committed to addressing these issues promptly and effectively to ensure compliance with federal regulations. Accordingly, the University will complete the following tasks to correct this repeat finding: 1) Assess the allocation of resources. Assess the resources required to complete physical inventories and reconciliations timely. Allocate personnel, temporary assistance, and/or reassign staff duties as needed to support compliance with policy and regulation. 2) Review the inventory timeline and monitoring process. Assess, and if necessary, adjust the timeline for conducting and reconciling physical inventories of all department assets within the required two-year cycle. Consider modifying the time of the inventory to enable reconciliation prior to fiscal year-end. Evaluate whether shifting to a staggered inventory process to spread the workload throughout the year would assist with achieving compliance. 3) Leverage technology for inventory management. Identify ways to leverage the University’s existing ERP software alongside reporting technologies and techniques to aid in the inventory management and property reconciliation process. Use these tools to improve the efficiency and accuracy of inventory management. 4) Ensure the proper tagging of equipment. Conduct a review of all equipment items to ensure they are appropriately tagged or assigned unique identifiers in accordance with the Fixed Asset Policy and related regulations. 5) Train and guide staff and faculty who are responsible for asset management. Develop and provide training sessions for responsible staff and faculty on the inventory process, reconciliation procedures, and tagging requirements, to include individuals within the Business Office and located within the departments. Reinforce accountability and ensure consistent application of policies. 6) Monitor and report on the progress of the action plan by providing regular updates to Management. Person(s) Responsible: Controller & Associate Vice President. Targeted Correction Date: December 31, 2025. Fiscal Year in which Finding Initially Occurred: 2023 (Finding Number 2023-003).

Prior to June 30, 2025, the University will conduct a full physical inventory of equipment purchased using federal funds that have a net book value greater than zero on the University’s books as of June 30, 2024. For new purchases of equipment using federal funds, the University will tag these assets on a monthly basis. In addition, a physical inventory of equipment purchased using federal funds will be conducted every two years going forward. The inventory process will be reviewed by management to ensure timely and accurate completion.

Significant Deficiency 2024-001. Equipment and Real Property Management United States Department of Education, Passed Through New York State, Department of Education: Education Stabilization Funds COVID-19: Elementary and Secondary School Emergency Relief Fund ALN: 84.425D COVID-19: American Rescue Plan - Elementary and Secondary School Emergency Relief Fund ALN: 84.425U Condition: The District did not include capital expenditures paid with federal awards in its capital assets inventory records. Planned Corrective Action: The Deputy Superintendent will put procedures in place to ensure that equipment and capital spending of federal funds are included in the District’s fixed assets inventory. The federally-funded project noted in this report will also be added to the fixed assets inventory records for financial reporting purposes. Responsible Contact Person: Ms. Diane Castonguay, CPA Deputy Superintendent East Williston Union Free School District 11 Bacon Road Old Westbury, New York 11568 Anticipated Completion Date: August 15, 2025.

FINDING 2024-003 Finding Subject: Education Stabilization Fund- Equipment and Real Property Management Contact Person Responsible for Corrective Action: Todd Slagle Contact Phone Number and Email Address: 812-874-2243 tslagle@northposey.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The School Corporation will develop and implement a formal internal control system to ensure proper segregation of duties and compliance with federal regulations. Missing assets, such as the ironworker purchased with ESSER 3E funds, will be added to the listing immediately. The School Corporation will conduct periodic reviews and reconciliations to verify that all assets, including those purchased with federal funds, are accurately reflected in the capital asset ledger. Anticipated Completion Date: We anticipate completing the Corrective Action by July 1, 2025

Finding 2024-004 – Equipment Management (Significant Deficiency and Noncompliance) Planned Corrective Action: The University is currently conducting an inventory and will ensure that it occurs at least every two years. Anticipated Date of Completion: June 2025 Person Responsible for Corrective Action: Director of Financial Services & Cost Management and AVP/Controller

Contact Person Responsible for Corrective Action: Dalton C. Tunis Contact Phone Number: 574-896-2155 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: For future projects and purchased equipment, NJ-SP will make sure proper documentation will be recorded for any equipment and real property purchased. An internal control system will be put into place that ensures the Business Manager receives proper documentation and records the capital assets into a spreadsheet in order for the equipment can be traced and the School Corporation stays in compliance. Anticipated Completion Date: June 30, 2025

CORRECTIVE ACTION PLAN - Recognizing the need/requirement to maintain property records appropriately, the district is working to schedule/complete a comprehensive physical inventory that should assist in identifying the location of equipment funded by the Education Stabilization Fund (ESF), resulting in questioned costs of $2,186,066 per this finding (in addition to all other equipment carried by the district regardless of funding source). The district plans are to continue to work with NEFEC to enact property records within Skyward to capture accurate information and a base starting point per completion of a physical inventory. All property records will then be maintained in Skyward to capture all information required under Federal funding provisions and a reconciliation to physical inventory counts will be prepared no less than every 2 years. Anticipated Completion Date: June 30, 2025 Responsible Contact Person: Walter Copeland, Interim CFO

FINDING 2024-002 Finding Subject: COVID-19 - Education Stabilization Fund - Equipment and Real Property Management Summary of Finding: The district did not have proper internal controls in place and documentation to track property or capital assets that were purchased with federal grant funds. Contact Person Responsible for Corrective Action: Dawn Mason, Business Manager, DeKalb Co. Eastern CSD Contact Phone Number and Email Address: 260-868-2125; dmason@dkeschools.com Views of Responsible Officials: We concur with the findings. Description of Corrective Action Plan: As federal funds are used and expended, property and capital assets that meet or exceed the threshold will be entered on a spreadsheet by the Business Manager or Grant Administrator which will contain 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, and use and condition of the property Anticipated Completion Date: All expenditures initiated after March 12, 2025

Management concurs. The City will update the fiscal policies and procedures manual to ensure a physical inventory of all city-wide departments will be performed every two years for all capital assets.

Department: Education Title: Internal control over ESF subrecipient monitoring procedures needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Department will work with the GEMS software developer to create the collection tool that will be integrated into the FY24 and FY25 ESSER performance report. The School Administrative Unit reports will be due on May 5, 2025 and reviewed by the individuals who continue to support the work of the Emergency Relief Funds. The equipment inventories and real property lists will be maintained in the Department files. Completion Date: April 15, 2025, May 5, 2025, and July 1, 2025, respectively Agency Contact: Shelly Chasse-Johndro, Director, ESEA, DOE, 207-458- 3180

FINDING 2024-005 (Section III-Federal Award Findings and Questioned Costs) Finding Subject: COVID-19 Education Stabilization Fund- Equipment and Real Property Management Audit Finding: Material Weakness, Other Matters Contact Person Responsible for Corrective Action: Brian Leitch and Holly Singleton Contact Phone Number and Email Address: 260-347-2502 bleitch@eastnoble.net, hsingleton@eastnoble.net Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: If Federal funds are used to purchase Capital Assets, the Deputy Treasurer will ensure that the percentage of federal participation and the use and condition of the property will be included in the capital asset listing. The listing will then be reviewed and approved by the CFOO. Anticipated Completion Date: Immediately

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 Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, 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 $2,799,607 on building renovations which was charged to the ESSER II (84.425D) and ESSER III (84.425U) grant awards. It was noted these capital asset acquisitions were not reported on the capital asset listing for the School Corporation as of June 30, 2024. 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: Dawn Cook, Corporation Treasurer; Joel Mahaffey, Superintendent Contact Phone Number: (260) 692-6193 Description of Corrective Action Plan: Business Office personnel will ensure that federally funded capital assets are included in the capital asset listing for ACCS. Further, the capital asset list will clearly identify any equipment or projects that were supported by federal funding. Anticipated Completion Date: Implementation is immediately.

Context: The School Corporation expended $1,313,973 on building renovations which was charged to the ESSER III (84.425U) grant award. The School Corporation was unable to provide the capital asset listing as of June 30, 2024, for testing to ensure the building renovations were properly included on the listing. Contact Person Responsible for Corrective Action: Jennifer Graves Contact Phone Number: 812-659-1424 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: A fixed asset inventory will be secured prior to the next audit. Anticipated Completion Date: December 31, 2025

FINDING 2024-002 Finding Subject: COVID-19 - Education Stabilization Fund – Equipment and Real Property Management Contact Person Responsible for Corrective Action: Carolyn Wallace Contact Phone Number and Email Address: 812-738-2168, extension 102 and WallaceC@shcsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: South Harrison Community School Corporation personnel in conjunction with the services of a qualified outside agency will compile an initial capital asset listing and will begin to conduct periodic inventory reviews as required. Anticipated Completion Date: August 15, 2025

FINDING 2024-002 Finding Subject: Special Education (IDEA)-Equipment The school corporation did not maintain sufficient property records of equipment purchased with Special Education funds. All equipment was not properly added to records systems and information was entered incorrectly in the records system. Contact Person Responsible for Corrective Action: Robert McIntire Contact Phone Number and Email Address: 765-455-8000 rmcintire@kokomo.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The school corporation will retrain grant directors and review all requirements related to Equipment and Property Management. Anticipated Completion Date: Retraining of grant directors and all employees related to property management related to grant purchases will be completed by September 1, 2025.

Corrective action The Foundation duly complies with four out of five requirements of 2 CFR section 200.313(d). Management is committed to fully complying with the regulations. A plan was developed to begin a physical inventory by the end of the fiscal year ending June 30, 2024. The execution of this plan is approximately 80% completed as of the date of this letter. The Foundation plans to complete the inventory by June 30, 2025. Finance staff has been performing the inventory, along with the staff of the Foundation’s various departments. The inventory plan includes the following: • Time schedules. • Identification of responsible parties. • Detailed description of entire inventory process. • Submission to research laboratories, clinical research, clinical laboratory and administrative offices of the list of inventory assets, according to books, along with instructions for the identification of the assets. • Deadline for departments to submit to finance the certified list of inventories. • Upon receipt of department inventories, the finance staff has scheduled visits to each department, to confirm the inventory certification received. • Reconciliation of the inventory with general ledger, and booking of any necessary adjustments in general ledger and the subsidiary ledger. • Preparation of an inventory report 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 25, 2025, by:

District will review federal claims for equipment purchases items greater than $5,000 and life longer than a year and capture equipment items into the property records as they are received.

FINDING 2022-003 Contact Person Responsible for Corrective Action: Jeff Gambill, Superintendent; Brian Rehmel, Maintenance Supervisor Contact Phone Number: 812-665-3550 Views of Responsible Official: We concur with the finding, Description of Corrective Action Plan: The Superintendent and Maintenance Supervisor will begin reviewing all capital asset inventories. These inventories are completed every two years, by an independent company. The Superintendent and Maintenance Supervisor will also maintain a corporation capital asset listing, updating any additions between inventories, to verify that the assets are properly accounted for on the capital asset inventory. The Superintendent and Maintenance Supervisor will add to the corporation capital asset listing, the assets that were omitted from the most recent capital asset inventory, and ensure that those assets are listed in the next capital asset inventory. Anticipated Completion Date: The Superintendent and Maintenance Supervisor will immediately begin maintaining a capital asset listing, updating any additions between inventories, as well as adding the assets that were omitted on the previous capital asset inventory.