Corrective Action Plans

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.

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: S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Equipment and Real Property Management Audit Findings: Material Weakness Condition and Context: 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. For four sample items tested, we noted the School Corporation expended approximately $86,300 on a 72-passenger bus, $670,600 on roof renovations, $19,000 on an intercom package for the high school, and $21,000 on admin building improvements, which were charged to the ESSER II (84.425D) and ESSER III (84.425U) grant awards. For three of the four sample items (all except the bus purchase), it was noted the capital asset acquisitions could not be traced to the capital asset listing for the School Corporation as of June 30, 2024. We noted the acquisitions were properly approved by IDOE in the grant application, management completed a physical inventory in the 2-year audit period, and the assets were properly maintained and safeguarded. Contact Person Responsible for Corrective Action: Bonnie Thopy Contact Phone Number: 317-729-5746 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: In the past, items were added to the fixed asset report by the deputy treasurer. Since that position had been dissolved, the responsibility for adding items will now be moved to the administrative assistant, Jordan Bledsoe. Anticipated Completion Date: A complete fixed asset inventory will be completed during the summer of 2025 by Asset Control Solutions at that time all items will be current. Going forward the business manager will provide the administrative assistant the information to be added to the fixed asset report. The business manager will insure the AFR matches the amount on the fixed asset report, and the AFR will be reviewed by the superintendent before submitting to verify the amounts.

Management will ensure that a physical inventory of assets is completed on a regular basis. Keely Linton, Executive Director, is the person responsible for the corrective action. The completion date of the corrective action is March 12, 2025.

Corrective Action Plan: The University has developed a project plan to identify all assets that require inventory to meet Uniform Guidance requirements. Tasks, milestones, and deliverables will drive completion of the project, with the imperative to meet federal regulations and alignment with operational procedures taking priority. Contemporaneous reporting will be enhanced to include aged inventory dates and allow for setting of inventory tasks across a continuum. Meeting Uniform Guidance requirements will take precedence when completing inventory of all federally sponsored equipment, and if in conflict with internal operations and/or processes. UT Southwestern Medical Center’s Asset Management procedure manual(s) will be revised to include the new process, controls, and reports established to consistently and repeatedly meet Uniform Guidance requirements. Further, UT Southwestern’s Sponsored Program Administration and Internal Audit teams will coordinate to perform ad hoc internal reviews to assure the respective project plan has been completed and new process continues to meet the requirements of Uniform Guidance respective asset management inventory requirements. Implementation of this plan will commence February 1, 2025, with asset inventory being fully compliant with Uniform Guidance prior to July 31, 2025. Internal reviews will continue for a minimum period of two fiscal years, through FY27. Implementation Date: February 1, 2025 Responsible Person: Megan G. Marks, PhD, Associate Vice President, Sponsored Programs Administration Sharonda Lawson, Director, Sourcing and Contract Management Timothy Martin, Director, Purchasing

Corrective Action Plan: UTMB will conduct a review of asset property records to ensure the serial numbers and locations are correct. UTMB Finance will coordinate with UTMB Supply Chain to evaluate and strengthen controls related to assets in Surplus warehouse. Implementation Date: November 1, 2025 Responsible Person: Mike Linton, Sr. Finance Manager

Corrective Action Plan: UT Health-San Antonio’s Property Control group will continue to stress the importance of updating equipment locations in a timely manner. The University’s Property Control practices will be enhanced to emphasized compliance with our property policies. The Property Control Office will continue to perform more rigorous spot audit reviews subsequent to the annual inventory process for respective departments with federally funded assets. Implementation Date: February 2025 Responsible Person: Yvette Martinez, Senior Director of Financial Affairs

Corrective Action Plan: The University has taken steps to identify and correct the deficiencies in Inventory’s processes and external knowledge base. Inventory Services has reviewed their website and made the necessary updates to their inventory trainings and guides. In the near future, Inventory Services will create a web-based training module that will be required for departmental inventory contacts. Inventory will still offer individual training sessions to departmental inventory contacts. Implementation Date: August 2025 Responsible Person: Christopher Ochoa, Inventory Manager

Corrective Action Plan: TEES Property Management will continue working with departments to increase their awareness regarding the updating of location information in a timely manner. Departments will also be reminded regularly to notify property management of missing and/or stolen property when discovered and to submit the appropriate forms. Property Management will increase communication to departments regarding the replacement of asset tags that have been damaged and/or are missing. A listserv has been established by TEES to effectively and efficiently communicate this information to the departments. Implementation Date: February 2025 Responsible Person: Jennifer Caddel, Inventory & Property Control Coordinator

FINDING 2024-005 Finding Subject: COVID-19 – Education Stabilization Fund – Equipment and Real Property Management Contact Person Responsible for Corrective Action: Robert Glover Jr. Contact Phone Number: (219) 945-0250 Contact Email Address: rglover@hobart.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The corrective action plan for finding 2022-003 was effective in ensuring that equipment over the capitalization threshold was barcoded and documented in School City of Hobart’s internal asset tracking system which we began utilizing in 2024. The external consulting company we used to perform our asset inventory omitted the items in question from their report. The items in question will be added to the external consultant’s existing spreadsheet. School City of Hobart will examine other options for external asset inventory services in the future. Any future purchases will be catalogued and provided as a list to the party who conducts our next asset inventory. School City of Hobart will require written documentation from any future consultant that all new items were added into the inventory in the future. Anticipated Completion Date: 04/30/2025

RCS will update the current practice of formal updates to the Fixed Asset List from every other year, to every year effective the 2025 year

FINDING 2024-007 - Education Stabilization Fund (ESSER) – Equipment Context: The School Corporation expended $341,336 on building renovations which was charged to the ESSER III (84.425U) grant award. 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: Michelle L. Keene Contact Phone Number: (812) 384-4386 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We will ensure the capital asset ledger is updated to include all capital asset activity. Anticipated 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: 84.425U 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. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan. The Treasurer will prepare all necessary documentation and have it reviewed by the Grants Administrator to ensure that we are in compliance with the grant agreement. Both parties will sign as verification of agreement. Responsible party and timeline for completion: The Corporation Treasurer will be responsible effective immediately.

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 2 of 3 sample items tested, we noted the School Corporation expended approximately $22,000 and $67,000 on a new sign and servers, respectively. These assets were charged to the ESSER III (84.425U) grant award. 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. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan. Responsible party and timeline for completion: Kendra Sandquist, Director of Finance has assessed all ESSER grant award expenditures, notably the capital projects and equipment purchases. For the digital sign and network servers, local capital asset records have been updated and the asset management and appraisal company, Deyo/Stone, has been notified. Deyo/Stone has provided an updated asset management appraisal as of December 31, 2024 to include these Federally-funded assets. This Corrective Action was completed on February 10, 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 Federal Award Numbers: S425D210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Equipment and Real Property Management Audit Findings: Material Weakness Criteria: 2 CFR 200.313(d) states in part: "Management requirements. 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. (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. (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. (4) Adequate maintenance procedures must be developed to keep the property in good condition. . . ." 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 the one sample item tested in a population of two, we noted the School Corporation expended $175,000 on baseball bleacher renovations which was charged to the ESSER II (84.425D) grant award. The bleachers were not reported on the capital asset listing for the School Corporation as of June 30, 2024. Views of Responsible Official: Management agrees with the finding and will take the following corrective action. Description of Corrective Action Plan: Going forward, we will have multiple people verify the appropriation budget account assigned to any purchase of a single item over the material threshold of $5,000, to ensure accountability and accuracy in our process We have set up an on-site physical inventory with Asset Control Solutions, Inc. They are contracted to physically complete an update inventory of our assets biennially. Anticipated Completion Date: 6/30/2025

For the year ended June 30, 2024 Finding No. 2024-001 – Communication of Property Disposals Award Information Cluster: Research and Development Grantors: National Institutes of Health National Science Foundation Award Numbers: NIH 5R00CA158066-04, NIH 1R21-AI48561-01, NSF CHE-1362211 Award Years: 2013-2014, 2000-2001, 2014-2015 Assistance Listing Numbers: 93.396, 93.856, 47.049 Assistance Listing Titles: Cancer Biology Research, Microbiology and Infectious Diseases Research, Mathematical and Physical Sciences Management agrees with the recommendation to continue to provide training to individuals involved with the handling of assets purchased with federal funding. This training will be performed through various means and emphasize the necessity of timely disposal reporting to ensure the accuracy of the University's property records. We are in the process of implementing the following corrective actions and plan to have these completed by the start of the 2026 fiscal year: • We will issue an annual written guideline to property custodians, including clear procedures for the proper identification of capital assets and the timely completion of disposal documentation. • We will continue to conduct our biennial moveable equipment inventory with property custodians and reinforce the importance of maintaining accurate property records. • We will review the current application used by property custodians to process asset disposals and consider conversion to a Google Forms application to improve the workflow and efficiency for completing asset disposal requests. • We will reinforce, during quarterly business manager meetings, asset transfer and disposal communication protocols. The University is committed to maintaining accurate and timely records related to fixed asset disposal. We believe the corrective actions outlined above will effectively address the audit finding and strengthen the University’s internal controls. Appropriate Contact: Jeff Laderer Plant Fund Accounting Program Manager