Corrective Action Plans

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.

Context: For the I sample item tested, we noted the School Corporation expended $500,000 on septic tank upgrades in the prior audit period which was charged to the ESSER III (84.425U) grant award. It was noted only $311,614 of these capital asset acquisitions were reported on the capital asset listing for the School Corporation as of June 30, 2024. Contact Per on Responsible for Corrective Action: Michele Harrison/ Corporation treasurer Brian Byrum / Superintendent Contact Phone Number: M. Harrison:765-492-5101 B. Byrum: 765-492-5102 Vie" s of Responsible Official: We concur with the finding. Description of Correcti e Action Plan: Our capital asset inventory is contracted out through Brett Lewis from Adtech. The management team contacted Mr. Lewis with the finding. The correct amount will be added to the next capitol asset inventory. Anticipated Completion Date: 3/7/2025

Context: For testing of Equipment and Real Property Management, 1 of 2 sample items tested, we noted the School Corporation expended $348,030 on roof renovations which was charged to the ESSER II (84.425D) 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 federal funding for the property, outlined in the criteria above. Contact Person Responsible for Corrective Action: Brittany Treesh Contact Phone Number: 260-357-3185 Views of Responsible Official: The school corporation concurs with the finding. Description of Corrective Action Plan: The school corporation will implement additional internal controls. Business Manager and Deputy Treasurer will expand object codes on the monthly expenditure report to keep track of project progress. Once project is completed both Business Manager and Deputy Treasurer will ensure the project has been updated and entered in the capital asset software. Anticipated Completion Date: The Business Manager will implement this procedure March 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. Contact Person Responsible for Corrective Action: Brittany Treesh Contact Phone Number: 260-357-3185 Views of Responsible Official: The school corporation concurs with the finding. Description of Corrective Action Plan: Garrett-Keyser-Butler’s Business Manager will work closely with the Special Education Cooperative Treasurer and DeKalb Eastern Business Manager during the grant process and make sure all required documents are collected. Anticipated Completion Date: The Business Manager will implement this procedure March 2025.

Finding 2023-002: Inventory Report: This is a repeat finding from the previous audit report, identified as finding number 2023-002. The school does not have internal controls and procedures to ensure a physical inventory is conducted at least every two years. • Response: Response: we will work with Jim Miller and Chris Ashmore to complete a physical inventory of all capital assets by September 30, 2025. Responsible Person/Position: Rod Iberg/ COO

This finding was brought to Management January 16, 2025. It involves significant cross-functional work including, but not limited to, Grants, Procure-to-Pay, Information Technology, Warehouse Operations, and Fine Arts. A group will come together in February 2025 representing these areas to develop a comprehensive action plan. That plan will be shared with the Internal Audit Committee and Board. It will include timelines and responsible parties, which Internal Audit staff will monitor.

Context: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Contact Person Responsible for Corrective Action: Lisa Baker, Business Manager/Treasurer Contact Phone Number: 765-664-0624 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The School Corporation is in the process of manually extracting and transferring fixed assets data from a database to a spreadsheet to allow the deputy treasurer access to the fixed assets data. This will allow the deputy treasurer to enter all assets as described in our board-approved policy into the updated fixed assets system. At least every six months, the business manager will generate a report from the financial software that will include object codes for purchases over $10,000 and for construction and verity that all assets have been added to the fixed assets spreadsheet. Currently, the business manager maintains the fixed assets database because it is not accessible to the deputy treasurer. It is the intent of the School Corporation to segregate these duties. The current fixed assets databased has been updated to include all flooring purchases that were previously missed. Anticipated Completion Date: We anticipate that the new fixed assets spreadsheet will be created and the data will be entered by December 31, 2025.

Condition: The University did not complete a physical inventory of the property within the last two years. Planned Corrective Action: During the 3rd calendar quarter each year, create a report of externally funded equipment purchases. Sometime within the nine months ending June 30th and using the report created, perform a physical inventory of all equipment purchased with federal awards. Save physical inventory records with images and locations with company records. Contact person responsible for corrective action: Amy Smitchols, Senior Director of Finance and Accounting Anticipated Completion Date: 02/07/2025

Name of Contact Person: Renee Orange, Assistant Controller Corrective Action: Owensboro Health, Inc. will implement an updated policy for the recipient of the CFDA #93.965 grant (i.e., the Coal Miners’ Clinic) which will ensure that (1) the clinic performs a physical inventory of property purchased with federal funds on an annual basis, (2) the results of the inventory are reconciled with the property records, and (3) this asset reconciliation is monitored and directed by the Authorized Official. Proposed Completion Date: February 28, 2024

Auditor recommendation: The auditor recommends the City enhance the design of its control activities and create a tool to assist in tracking and maintaining equipment purchased with federal funds. Additionally, the employees responsible for the inventory should be trained to ensure understanding of the Uniform Guidance requirements relevant to equipment and real property management. Periodic review should also be designed to evaluate compliance with relevant requirements. Views of Responsible Officials and Planned Correc􀀁ve Ac􀀁on: The City agrees with this finding. During FY24 the Airport Manager hired a Heavy Equipment Mechanic. This posi􀀁on is responsible for tracking, maintaining, and repairing Airport equipment. Logbooks are now being kept for all equipment. In CY25 the Finance Director, the Accoun􀀁ng Officer, and the Grants team will work with the Airport team to improve internal controls over equipment purchased with federal funds. Policies and procedures will be developed to ensure that an accurate physical inventory that contains the informa􀀁on required by the Uniform Guidance is conducted at year-end. The City is in the process of contrac􀀁ng with a vendor to assist the Airport with federal compliance and provide training for Airport staff on relevant Uniform Guidance requirements. The vendor’s scope of work will include helping with developing and documen􀀁ng policies and standard opera􀀁ng procedures related to equipment management. Tools will be developed to facilitate tracking and maintaining equipment purchased with federal funds. Addi􀀁onally, the Airport Department plans to create a Grant Accountant posi􀀁on which will be responsible for reconciling grant expenditures monthly. The Grant Accountant will also work with the Airport Heavy Equipment Mechanic to ensure that the inventory lis􀀁ng includes the funding source used for the purchase (i.e. federal or non-federal). In CY25 the City plans to provide Uniform Guidance to staff which will include capital assets and equipment informa􀀁on, and the specific requirements for the year-end inventory. Responsible Official: Emily Oster, Finance Director, James Harris, Airport Manager, Airport Heavy Equipment Mechanic, Matthew Bonifer, Accounting Officer, Erika Lujan, Grants Manager Timeline and Es􀀁mated Comple􀀁on Date: June 30, 2025

FINDING 2024-002 Finding Subject: Education Stabilization Fund – Equipment and Real Property Management Summary of Finding: The School Corporation failed to add improvements paid for out of ESSER monies to the capital asset listing and complete physical inventories were not completed. Contact Person Responsible for Corrective Action: Jessica Espinoza Contact Phone Number and Email Address: (219)836-9111 jbespinoza@munster.us Views of Responsible Officials: We concur with the finding. The School Corporation plans to complete a physical inventory of assets this year and every two years, thereafter. Description of Corrective Action Plan: The Director of Operations will share inventory listings with each building. An STM employee will conduct the inventory and it will be reviewed by a supervisor and signed off on. The sources of funding will also be added to the School Corporation’s inventory listing to easily identify equipment paid for out of Federal dollars. Anticipated Completion Date: Fall 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 Findings: Material Weakness Context: The School Corporation expended $1,367,798 on building renovations during the period under audit 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. Contact Person Responsible for Corrective Action: Andrew J Nicodemus, Business Manager Contact Phone Number: 765-362-2342 x6 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Crawfordsville Community School Corporation plans to review all internal control procedures, including the controls over Equipment and Real Property Management for the Education Stabilization Fund. After this review, we will implement a system to ensure that the proper procedures are completed and fully integrated into our internal control structure. We will implement additional training for all staff involved and will have a designated place where this support is kept. Anticipated Completion Date: We expect this Corrective Action to be implemented as of the current date due to this grant being completed and the School Corporation is not expected to have these grant funds in the future.