Corrective Action Plans

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

Finding 2025-001 - Head Start Cluster – Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Equipment and Real Property Context: During testing, we noted the Unit spent $160,847 on flooring upgrades which exceeded the $5,000 federal equipment and real property threshold. However, the Unit did not perform any of the required federal compliance steps related to the flooring purchase (getting approval before making the purchase, adding the flooring purchase to the capital asset listing, and performing an inventory of the flooring). The Unit believed the flooring purchase did not require approval because it does not meet the criteria of a major renovation under Head Start guidelines. However, as noted in the criteria above, the flooring still qualifies as an equipment and real property purchase. Contact Person Responsible for Corrective Action: Brenda Overton Contact Phone Number: 574.393.5866 Views of Responsible Official: The Consortium management disagrees with the finding. Description of Corrective Action Plan: The Consortium plans to discuss this matter with ACF/HHS to determine if the finding is out of compliance. Anticipated Completion Date: June 30, 2026

FINDING 2025-004 Finding Subject: Education Stabilization Fund – Equipment and Real Property Management Contact Person Responsible for Corrective Action: Mendy Shrout Contact Phone Number and Email Address): (765) 795-4664 / mshrout@cloverdale.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We have contacted our Capital Assets vendor to add columns to the report to identify federal purchases. Anticipated Completion Date: July 1, 2027

FINDING 2025-004 Finding Subject: COVID-19 – Education Stabilization Fund – Equipment and Real Property Management Contact Person Responsible for Corrective Action: Kirk Farmer, Chief Financial Officer Contact Phone Number and Email Address: (317) 856-5265; kfarmer@decaturproud.org Views of Responsible Official: We concur with Audit Finding Description of Corrective Action Plan: The Education Stabilization Fund grant was completed during the audit period and the school district does not plan on receiving this award in the future. Therefore, further corrective action is not required and district officials will utilize this information to ensure compliance in other federal awards. Anticipated Completion Date: February 1, 2026

Auditor Description of Condition and Effect. The College does not have a formal process or system in place to track fixed assets acquired with federal award funds. As a result, there is no centralized or consistent documentation of asset details, location, or usage for assets purchased with federal funds. Without proper tracking, the entity is at risk of noncompliance with federal regulations, potential loss or misuse of federally funded assets, and challenges in conducting accurate inventories or audits. This could lead to questioned costs or disallowed expenditures during federal reviews. Auditor Recommendation. That the College implement a formal fixed asset tracking system that complies with 2 CFR §200.313. This system should include procedures for recording asset details, conducting periodic inventories, and reconciling records. Staff responsible for asset management should be trained on federal requirements to ensure ongoing compliance. Corrective Action. In its Jenzabar accounting system software, the College will code fixed assets that were, and will be, acquired with federal award funds. The College will also set reminders in May 2026, and at least once every two years thereafter, to conduct an inventory and reconcile this with the accounting records. Responsible Persons. Tom Zeidel, Vice President of Finance and Facilities and Troy Slater, Director of Business Office. Anticipated Completion Date. October 31, 2025.

Finding 2025-003 - Internal Control over Major Federal Program Compliance Program : Education Stabilization Fund (CFDA 84.425) Condition: Lack of policies and procedures for asset inventory management. Repeat Finding and Material Weakness Corrective Action Plan: The District will implement procedures to ensure asset physical inventories are completed and inventory records are completed and updated in accordance with the requirements of 2 CFR 200.318 of the Uniform Guidance. The district will provide training to responsible personnel. Planned Completion Date: March 31, 2026 Responsible Contact Person: Dr Marty Spence, Superintendent (417) 469-3260

Condition: The University did not complete a physical inventory of the property within the last two years. Planned Corrective Action: Management will establish a formal inventory schedule that mandates physical inventory and reconciliation at least once every two years. Designated personnel will be assigned responsibility for executing and documenting the inventory process. Additionally, internal controls will be enhanced through periodic monitoring and reminders to ensure timely completion and proper recordkeeping. Contact person responsible for corrective action: David Dettloff, Staff Accountant Anticipated Completion Date: February 26, 2026

2025-003 – Significant Deficiency and Noncompliance – Federal Equipment Corrective Action Plan: The City will implement a centralized Federal Equipment Register capturing all required data elements under 2 CFR §200.313(d) and assign responsibility to the Logistics Officers of the Fire Department, Police Department, and Department of Public Works, with oversight by Finance. A full physical inventory of federally funded equipment will be completed and reconciled by March 31, 2026, and biennial inventory procedures will be established. Staff will be trained on equipment management requirements, and documentation will be retained to ensure compliance. Anticipated Completion Date: March 31, 2026

Conditions 1-5 Repeat Finding, same response for Finding Nos. 2024-007, 2024-012, and 2024-019

Conditions 1-5 Repeat Finding - same response for Finding No. 2027-007, 2024-012, and 2024-025

The MOF recruited a dedicated asset management officer and began a government-wide asset inventory in April 2026. Upon completion, the FMIS asset module will be fully implemented in FY2027 to improve the classification, recording, reporting, and monitoring of capital assets. The MOF also continues to coordinate with Ministries and Agencies to update and reconcile asset records. Repeated finding: same response on Finding Nos. 2024-007, 2024-019, and 2024-25

Finding Number 2024-026 Subject Heading (Financial) or AL no. and program name (Federal) AL #84.425 – EDUCATION STABILIZATION FUND (ESF - AL #84.425D; 84.425U) Planned Corrective Action The Office of Title Services (OTS) staff will ensure that at a minimum a district’s inventory procedures meet the following requirements. • For materials and supply items, the Office of Title Services (OTS) staff will review the district’s inventory procedures for compliance with 2 C.F.R. 200.302(b)(4). • For equipment items ($10,000 or greater unit cost) OTS staff will review the district’s inventory procedures for compliance with the requirements of 2 C.F. R. 200.313 (d)(1) • Additionally, training will be provided to staff during our annual internal training. Anticipated Completion Date Aug-25 Responsible Contact Person Tammy Smith

Finding2024-007:Equipment and Real Property Management (Title V, CFDA 93.U01) Material Weakness (Repeat Finding: 2023-007) Condition: The Organization lacked a system to identify, mark, record, or maintain equipment and real property purchased with federalfunds; no periodic physical inventory was performed; and there was no process to obtain prior written approval for capital expenditures of $10,000 or more, as required by 2 CFR §200.310 through §200.314 and §200.407. Corrective Action: • Establish a property/equipment ledger recording description, acquisition cost, funding source, acquisition date, location, and disposition for all federally funded equipment and real property. • Implement a physical inventory at least once every two years, reconciled to the property ledger, per 2 CFR §200.313(d). • Implement a prior-written-approvalworkflow requiring awarding agency/pass-through approval before purchasing or leasing equipment ($10,000+ per unit), land, or buildings with federal funds. • Apply the GLrestructuring from Finding 2024-003 so capital purchases under Title V are individually identifiable. Responsible Party: Chief Financial Officer Anticipated Completion Date: Property ledger established concurrent with the Blackbaud implementation, kickoff August 13, 2026; complete by March 31, 2027; first physical inventory completed by June 30, 2027