Corrective Action Plans

Context: The School Corporation expended $732,738 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: Patrick Biggerstaff, Assistant Superintendent Contact Phone Number: (317) 831-0950 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Business Office personnel will ensure that federally funded capital assets are included in the capital asset listing for MCSC. Further, the capital asset list will clearly identify any equipment or projects that were supported by federal funding. Anticipated Completion Date: June 1, 2025

FINDING 2024-005 Finding Subject: COVID-19 - Education Stabilization Fund - Equipment and Real Property Management, Equipment and Real Property Management, Material Weakness, Modified Opinion Summary of Finding: The corporation is not maintaining a detailed capital asset listing. Contact Person Responsible for Corrective Action: Jami Parks, Business Manager Contact Phone Number and Email Address: 812-794-9630, jami.parks@scsd1.com Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The corporation will revise their capital asset listing to include what capital assets are purchased with federal grant funds, and for how much those assets were purchased for. Anticipated Completion Date: The anticipated completion date will be by the submission of the Gateway APR, 08/31/2025

FINDING 2024-002 Finding Subject: Special Education Cluster (IDEA) – Equipment and Real Property Management Contact Person Responsible for Corrective Action: Andrea Phillips, Director of Finance Contact Phone Number and Email Address: (812) 663-4774 aphillips@greensburg.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: A spreadsheet will be created containing all of the required information. This will be reviewed annually when completing the Gateway Annual Financial Report. It will be prepared by the Director of Finance and signed off by the Superintendent. Anticipated Completion Date: March 31, 2025

FINDING 2024-001 Finding Subject: Education Stabilization Fund – Equipment and Real Property Management Contact Person Responsible for Corrective Action: Andrea Phillips, Director of Finance Contact Phone Number and Email Address: (812) 663-4774 aphillips@greensburg.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: A spreadsheet will be created containing all of the required information. This will be reviewed annually when completing the Gateway Annual Financial Report. It will be prepared by the Director of Finance and signed off by the Superintendent. Anticipated Completion Date: March 31, 2025

•The Board developed a policy on October 15, 2024, with guidelines detailing proper inventory of real property and equipment. This policy includes maintaining inventory of items purchased with federal funds. The policy will be followed. •A detailed inventory listing for all real property and equipment, including those acquired under the COVID-19 American Rescue Plan ESSER program has been developed. •The listing will be updated through annual physical inventory

FINDING 2024-002 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: The School Corporation paid $2,135,000 for HVAC and flooring improvements and $92,301 in concrete work at various locations using COVID-19 - Education Stabilization Funds grant funds. These capital improvements were added to the detailed listing of capital improvements; however, did not include a detailed 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 the title, and percentage of federal participation in the project costs for the federal award under which the property was acquired. Contact Person Responsible for Corrective Action: Kasey Clark Contact Phone Number: 574-772-1604 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: AdTec does the inventory listing every two years and it will be placed on the Capital improvement listing. Anticipated Completion Date: Fall of 2025 during next inventory

Significant Deficiency 2024-001. Equipment and Real Property Management United States Department of Education, Passed Through New York State, Department of Education: Education Stabilization Fund COVID-19: Elementary and Secondary School Emergency Relief Fund ALN: 84.425D COVID-19: American Rescue Plan – Elementary and Secondary School Emergency Relief ALN: 84.425U COVID-19: American Rescue Plan – Elementary and Secondary School Emergency Relief – Homeless Children and Youth ALN: 84.425W Condition: The District did not include equipment purchased with federal awards with its current year additions in the District’s capital assets inventory records. Planned Corrective Action: The District will adopt procedures to ensure that equipment purchased with federal funds is included and differentiated in the District’s capital assets inventory records. The District will include this year’s equipment purchased with federal awards in its recent capital assets inventory records. Responsible Contact Person: Ms. Sharon Donnelly, Assistant Superintendent for Business Harborfields Central School District 2 Oldfield Road Greenlawn, New York 11740 Anticipated Completion Date: June 30, 2025.

University System Response/Corrective Action Plan Agree. UND Asset Management adequately informs UND departments that the department is required to secure the tag to the asset. The requirement is also clearly listed in UND’s Capital Asset policy. UND Asset Management will work closely with departments to stress that they are required to secure tags to all major equipment assets. Contact Person: Sharon Loiland, Controller Anticipated Completion Date: March 31, 2025

Information on the federal program: Subject: Education Stabilization Fund (ESSER) – 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 Context: During the grant period, the School Corporation expended a total of $5,803,458 in Economic Stabilization Funds (ESSER) for a building project. Although this project was included in the School Corporation's capital asset records, it was recorded at the estimated total project cost of $6,256,000 in a prior audit period prior to these costs being expended. In addition, the School Corporation did not designate the amount of the project that was paid with federal grant funds, complete an inventory in the two-year audit period, or record expenditures and report budgeted amounts in the proper object code. Contact Person Responsible for Corrective Action: Heidi Sprunger Contact Phone Number: 260-589-3133 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The School Corporation will reach out to Asset Controls to have them fix the expended amount of $5,803,458 to reflect on our reports. The School Corporation will also have Asset Controls itemize which project was paid for with federal grant funds to reflect our reports. The School Corporation will put into place the following schedule to update our inventory to stay in compliance with state and federal requirements. The School Corporation will have Asset Controls or the Director of Operations physically count the inventory of capital assets on even year audits. During the odd year audits, the School Corporation will have Asset Controls or the Director of Operations perform a perpetual count. Anticipated Completion Date: 06/30/2025

Finding 2024-003 Reporting – Material Noncompliance and Material Weakness in Internal Control Over Compliance Corrective Action Plan The District acknowledges the finding regarding failure to retain source check documentation supporting student count certification for the Impact Aid program. In response to this issue, which pertained to source check forms from FY22 that were subject to review when payment was made in FY24, we have already implemented corrective measures. Under the oversight of our Director of Federal Programs, the District established and implemented comprehensive records retention procedures compliant with 2 CFR 200.303, including clear documentation requirements for federally connected children, a centralized digital repository for all Impact Aid records, a verification checklist system, and staff training on proper documentation protocols. This implementation was completed in June 2024, ensuring all records are now maintained in accordance with federal uniform guidance requirements. Expected Completion Date 07/01/2024

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 School Corporation expended $205,068 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: Candace McDonald Contact Phone Number: 765-734-1261 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We will request that funding sources be updated on our capital asset ledger. Personnel will ensure that all improvements are listed on the capital asset ledger. Anticipated Completion Date: November 2025

Context: For the 2 sample items tested, the School Corporation expended $396,100 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: Serena Francis, Business Manager Contact Phone Number: 765-985-3891 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: NMCS is in the process of updating our capital asset plan. As we move forward we will report all capital improvements and large purchases to this schedule as they occur. Anticipated Completion Date: 11/1/2025

4.1 Haiti Country Program to ensure the physical counts of property are conducted, that evidence of a count is formally documented, and an authorized individual formally approves the result of the count, and the related reconciliation of property records, in order to adhere to Federal regulations related to equipment management and its related maintenance. Responsible Official: Head of Operations, Supply Chain Managers, DRD Operations, SCM RTA, Completion Date: September 30, 2025

FINDING 2024-009 Subject: COVID-19 - Education Stabilization Fund - Equipment and Real Property Management Audit Finding: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Linda Zaborowski, CFO Contact Phone Number and Email Address: (219) 881-5536 lzaborowski@garycsc.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: Gary Community School Corporation (GCSC) is taking immediate action Gary and implementing an internal control system to ensure compliance with federal equipment and real property management requirements. The Business Office Coordinator is now responsible for tagging all equipment purchased for the district and entering all relevant information, including the source of funding and location, into the Follett Software system. When equipment is purchased, a copy of the purchase order will be provided to the Business Office Coordinator to ensure proper tracking and tagging of equipment purchased upon arrival. Inventory will be properly tracked based on GCSC policy # 7455 guidelines. In addition, all building personnel who receive equipment will be properly trained on procedures to ensure accurate tracking of assets. The Business Office Coordinator, with assistance from the Chief Financial Officer (CFO), will oversee all inventory of equipment and buildings. A physical inventory of all assets will be conducted at least once every two years to comply with federal regulations. These measures will ensure that all property is properly recorded, safeguarded, and maintained to prevent future findings. Anticipated Completion Date: Gary Community School Corporation will implement this procedure by July 2025.

Context: The School Corporation is a member of the Northeast Indiana Special Education Cooperative (Cooperative). During fiscal years 2022-2023 and 2023-2024, the Cooperative operated the special education program and spent the federal money on behalf of all its members. As the grant agreement was between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. Description of Corrective Action Plan: School Corporation will reach out to the Cooperative to discuss internal controls over procurement, and suspension and debarment and request annual listing of vendors exceeding federal and state procurement thresholds to ensure Cooperative adheres to regulations and established procurement policy and request that procurement policies are written, and all procurements are fully documented based upon the applicable federal and state standards Anticipated Completion Date: The School Corporation will implement the actions noted above quarterly to ensure proper internal controls are in place. The treasurer will request this information starting in April of 2025 for the first quarter of the calendar year.

Context: The School Corporation expended $720,784 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: Abigail Lindsey Contact Phone Number: 765-853-5464 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Corporation will ensure that building renovations will be added to the capital asset list. Anticipated Completion Date: 07/30/2025

FINDING 2024-004 Contact Person Responsible for Corrective Action: Rachel Dutoi Contact Phone Number: 574-254-4503 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: As our Purchasing Specialist is leaving the corporation, we are taking the opportunity to revise who and how the inventory and capital asset listings are tracked and maintained. These duties will be assigned to an individual who will coordinate the purchases from the various buildings and departments. We will be looking to designate an individual at each building and department who will track and account for purchases over $5,000 and then submit the information to the person coordinating the information for the corporation. This information will be available to the Business Department to review and use while completing the submission of the Annual Financial Report at the end of the Fiscal Year. Anticipated Completion Date: This new process should be in place by July 1, 2025.

FINDING 2024-001 Finding Subject: COVID-19 - Education Stabilization Fund - Equipment and Real Property Management Contact Person Responsible for Corrective Action: Sarah Gizzi, Business Manager Contact Phone Number and Email Address: (317) 861-4463 x1014, sgizzi@newpal.k12.in.us Condition and Context: A property record or capital asset listing would include the following for each asset: 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, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property. The property record or capital asset listing should be maintained for assets purchased that exceed the School Corporation’s capitalization threshold. The School Corporation maintained a detailed listing of capital assets; however the capital asset listing provided did not identify which assets were purchased with federal dollars, the FAIN, or the percentage of federal participation in the project costs for the federal award under which the property was acquired. Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The asset management procedures and internal controls of New Palestine Community Schools have been improved to include the necessary details regarding assets purchased with federal awards by creating and maintaining a separate listing of federally purchased assets that qualify for capitalization. The listing includes the FAIN and the percentage of federal participation in the project costs for the federal award under which the property was acquired, in addition to the detailed information already on file for each asset. The listing will be reviewed regularly by grant administrators and management to ensure compliance. Anticipated Completion Date: These procedures have been implemented effective immediately, March 3, 2025.

FINDING 2024‐006 Finding Subject: COVID‐19 ‐ Education Stabilization Fund ‐ Equipment and Real Property Management Summary of Finding: The School Corporations capital asset listing did not include all the required asset information for assets purchased with federal awards. The following information for each asset was not included in the School Corporations capital asset listing: the source of funding for the property (including the federal award identification number (FAIN)), and percentage of federal participation in the project costs for the federal award under which the property was acquired. In addition, assets were not properly safeguarded and maintained. During the audit period, the School Corporation purchased assets and completed improvement projects totaling $1,794,965 with ESSER funds. These assets were not included on the asset listing or physical inventory prepared by the consultant. Additionally, the School Corporation was unable to provide a listing of capital asset deletions during the audit period. Therefore, we could not determine if the disposition of any equipment or real property acquired under federal awards were properly reflected in the property records. Contact Person Responsible for Corrective Action: Tim Scott Contact Phone Number and Email Address: 574‐654‐7273 tscott@npusc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The corporation will meet with its asset listing consultant and have the HVAC project added to its assets listing. The corporation will also continue to fill out Form 369 for tracking both the acquisition and deletion of capital assets. In addition, the Grants Manager will work with our technology department to ensure proper inventory lists are kept of future equipment purchased through grants. Anticipated Completion Date: June 2026

FINDING 2024‐003 Finding Subject: Emergency Connectivity Fund ‐ Equipment and Real Property Management and Special Test and Provisions Summary of Finding: The School Corporation had not properly designed or implemented a system of internal controls that would likely be effective in preventing, or detecting and correcting, noncompliance. The School Corporation purchased iPads and Wi‐Fi hotspots during the audit period with Emergency Connectivity Fund grant monies. The School Corporation did not keep an inventory record of all hotspots distributed to students. Contact Person Responsible for Corrective Action: Jackie Conley Contact Phone Number and Email Address: 574‐654‐7273 jaclynconley@npusc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Grants Manager will work with our technology department to ensure proper inventory lists are kept of future equipment purchased through grants. Anticipated Completion Date: June 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: S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Equipment and Real Property Management Audit Finding: 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) A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years. (3) A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated. (4) Adequate maintenance procedures must be developed to keep the property in good condition.. . ." Context: We noted the School Corporation expended approximately $7.1 million on HVAC projects which was charged to the ESSER II and ESSER III (84.425D and 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. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding. Even though infrastructure items themselves are not to be listed separately on a capital asset detail, we will modify the value of the buildings themselves. Responsible party and timeline for completion: The Director of Business Services, Rob James, will modify the building values during the annual capital asset update done in July 2025.

FINDING 2024-005 Finding Subject: Education Stabilization Fund – Equipment and Real Property Management Summary of Finding: The School Corporation’s capital asset listing did not include all the required asset information for assets purchased with federal awards. The following information for each asset was not included in the School Corporations capital asset listing: the source of funding for the property (including the federal award identification number (FAIN)), percentage of federal participation in the project costs for the federal award under which the property was acquired, and the use and condition of the property. During the audit period, the School Corporation had improvement projects totaling $8,022,149 with Education Stabilization Funds (ESF). These assets were not included on the asset listing or physical inventory prepared by the consultant. The School Corporation did not maintain a capital asset listing with the equipment purchased with ESF and could not have conducted a complete physical inventory bi-annually as required and could not properly maintain and safeguard the equipment as required. Contact Person Responsible for Corrective Action: Greg Hunt Contact Phone Number: (219) 362-7056 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We have contacted our appraisal company and provided documentation to include the HVAC equipment into our next appraisal document update. We anticipate the next official appraisal listing will be in July 2025. Anticipated Completion Date: July 2025

Contact Person Responsible for Corrective Action: Brittany Taylor Contact Phone Number: 260-488-2513 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We are planning a physical inventory for spring/summer 2025 and will continue to repeat physical inventories every two years going forward. Additionally, we will track the project costs for all ongoing construction projects for inclusion on the capital asset listing. Anticipated Completion Date: 8/31/2025

Contact Person Responsible for Corrective Action: Donna Wilson, CFO Contact Phone Number: 812-462-4314 Views of Responsible Official: The School Corporation will appropriately update the capital asset listing to include all equipment and real property acquisitions and review for potential capital asset dispositions on an annual basis. Description of Corrective Action Plan: The Deputy Treasurer and/or Treasurer will monitor all expenditures in order to ensure compliance with requirements related to grant agreements and Equipment and Real Property Management Requirements set forth in grant agreements. Proper additions and dispositions of equipment and real property will be reflected in the capital asset records of the School Corporation. Anticipated Completion Date: Immediately.

Subject: Education Stabilization Fund – Equipment and Real Property Management 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 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 $94,444 on equipment/real property acquisitions during the period under audit which was charged to the ESSER II (84.425D) grant award. While the School Corporation did maintain a capital asset listing for the audit period, controls in place were not operating in an effective manner to properly track federal equipment acquisitions. The School Corporation failed to include the equipment/real property purchases on the capital asset listing. The School Corporation had also not performed a complete physical inventory of capital assets during the audit period as required by federal and state regulations. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Management will consult Board approved polices for capital asset management and ensure listings include and identify purchases made with federal funds and ensure a physical inventory is completed at least once every two years. Responsible Party and Timeline for Completion: Fairfield Community Schools has hired 3G Solutions to perform a complete inventory of assets.