Corrective Action Plans

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

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