Corrective Action Plans

During our current year audit, we noted that capital outlay expenditure codes were not reviewed with an appropriate level of precision to ensure all fixed asset purchases worthy of capitalization were added to the District’s fixed asset register. We recommend a reconciliation be prepared between the capital outlay expenditure codes and the fixed asset register to ensure that all items requiring capitalization as per District policy are captured, as well as a review of capital projects expenditures to date to determine if they are complete. We acknowledge that the District has made the necessary edits to the fixed asset register for the purposes of appropriate financial statement presentation. The District has reviewed the process for tracking fixed assets with the necessary staff members to ensure that paperwork is received timely from the various departments. Written protocols will be established and maintained in the Business Office Reference Guide. This will ensure that all assets are recorded in the fixed asset software in a timely manner. Status: In process Implementation Date: December 2024

Context: For 1 of 3 sample items tested, we noted the School Corporation expended $1,114,159 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. Contact Person Responsible for Corrective Action: David Rowe, Business Manager Contact Phone Number: 765-298-6505 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Qualifying building renovations will be added to the capital asset listing going forward. Anticipated Completion Date: Begin immediately, ongoing

MATERIAL WEAKNESS IN INTERNAL CONTROL OVER COMPLIANCE AND MATERIAL NONCOMPLIANCE – U.S. DEPARTMENT OF EDUCATION – PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, COVID-19 – EDUCATION STABILIZATION FUND – FEDERAL ALN 84.425 2024-003 Material Weakness in Internal Control Over Compliance and Material Noncompliance With Equipment and Real Property Management Requirements Finding Summary 2 CFR § 200.313 requires the District to designate fixed assets purchased under federal programs and to maintain related property records, including a description of the property, a serial number or other unique identification number, the source of funding for the property (including the federal ALN), 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 sale price of the property. A physical inventory of the property must be taken and the results reconciled with the property records at least every two years. During our audit, we noted that the District did not have sufficient controls in place within the COVID-19 – Education Stabilization Fund federal program to specifically identify federally funded fixed assets and maintain the required records as noted above to assure compliance with federal equipment and real property management requirements. The District does not have a process or procedure in place for a physical inventory of property acquired with federal funds. Two fixed assets purchased with federal awards were not maintained in accordance with federal equipment and real property management requirements. Corrective Action Plan Actions Planned – The District plans to review its internal control procedures to ensure future compliance with the federal compliance requirements specific to equipment and real property management requirements for the COVID-19 – Education Stabilization Fund federal program. Official Responsible – Kathleen Heider, Finance Director. Planned Completion Date – June 30, 2025. Disagreement With or Explanation of Finding – The District is in agreement with this finding. Plan to Monitor – Kathleen Heider, Finance Director, will ensure that federally funded fixed assets are distinguishable within the District’s finance system. The District also intends to review its control procedures relating to equipment and real property management requirements to ensure compliance for future federal awards expenditures.

Recommendation: We recommend the University ensure that a physical inventory over equipment is completed at least every two years. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Questioned Costs: N/A Action taken in response to finding: This is a repeat finding that was first presented to the University in conjunction with the release of the 2023 audit report in May 2024. The 2023 audit was completed after substantially all of Fiscal Year 2024 had elapsed, so there was not adequate time for the University to fully implement corrective action. While Langston has a plan for biennial equipment verification, the University commits to strengthening its physical inventory processes for tracking fixed assets. Name(s) of the contact person(s) responsible for the corrective action: Mr. Chris Kuwitzky, Vice President for Fiscal and Administrative Affairs. Planned completion date for corrective action plan: March 2025

Finding 2024-001 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, 84.425U Federal Award Numbers: S425D210013, S425U200013 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 $944,437 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. The School Corporation had also not performed a complete physical inventory of capital assets during the audit period. Views of Responsible Official: Management agrees with the finding and will take the following corrective action. Description of Corrective Action Plan: Stephanie Pittman, Treasurer will add the value of the building renovations to the capital asset listing as of June 30, 2024 and amend the annual financial report for the 2023- 2024 school year. Stephanie Pittman, Treasurer will also perform a complete physical inventory at the end of the 2024-2025 school year and develop a schedule for regular inventories at least every other year. Anticipated Completion Date: The amendment to the capital asset listing and annual financial report will be completed by February 15, 2025. The physical inventory will be completed by August 31, 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: S425U200013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Equipment and Real Property Management Audit Findings: Material Weakness Context: For 1 of 2 sample items tested, we noted the School Corporation expended $1,079,166 on roof 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. Contact Person Responsible for Corrective Action: Dawn Ray Contact Phone Number: 812.988.6601 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We will have someone other than the preparer of the capital asset invoices perform a documented review prior to submission to the Capital Asset company to validate the accuracy and completeness of the items to be submitted. Anticipated Completion Date: Immediately upon the completion of the audit.

Views of Responsible Officials The Organization agrees with this finding. Corrective Action Plan The Organization will update its property records to include all required information. Additionally, the Organization plans to document its performance of a physical inventory count and related reconciliation on an annual basis. Name(s) of Responsible Individuals Lacy Kimes, Board President Anticipated Completion Date June 30, 2025

CORRECTIVE ACTION PLAN FINDING 2024-002 Contact Person Responsible for Corrective Action: Tamara Swartzentruber, Treasurer Contact Phone Number: 812-486-3220 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Treasurer will schedule the inventory of the property and equipment owned by the school corporation to be completed during the audit period. Anticipated Completion Date: July 2024

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, 84.425U Federal Award Numbers: S425D200013, 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 $419,545 on equipment acquisitions during the period under audit which was charged to the ESSER II (84.425D) and ESSER III (84.425U) grant awards. The School Corporation did not maintain a capital asset listing for the audit period to properly track federal equipment acquisitions. 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 prepare a detailed asset listing and ensure a physical inventory is completed at least once every two years. Responsible Party and Timeline for Completion: David Wolford, Director of Operations and Technology, will create a draft capital asset listing by July 1, 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: S425U200013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Equipment and Real Property Management Audit Findings: Material Weakness Context: The School Corporation expended $82,286 on building renovations during the period under audit 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. Contact Person Responsible for Corrective Action: Vicki Jones Contact Phone Number: 765-793-4877 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: All capital assets will be included in the AFR each year and verified with a sign-off by the Superintendent. Anticipated Completion Date: July 2025

Management's Response: Management concurs with the above finding and notes that an annual physical inventory is done. Moving forward all federal equipment housed in a separate inventory system will be included in the annual physical inventory process. In addition, the tracking and monitoring of these assets will be brought to the asset manager within the fiscal services office. Action will be taken immediately and completed by June 2025.

FINDING #2024-002: EDUCATION STABILIZATION FUNDS – EQUIPMENT AND OTHER CAPITAL EXPENDITURES (5000) Corrective Action Plan: Compton USD will act with diligence and care. Under the new Director of Fiscal Services, a pre-approval checklist for all grant expenditures, including mandatory CDE approval for equipment and capital expenditures, has been implemented.

Equipment Management Management agrees with the finding and the auditor's recommendation. Mass General Brigham (MGB) will develop supplemental training materials focusing on the policies and procedures around federal equipment management. The training materials will emphasize the importance of accuracy in the disposal request forms including identification of assets purchased with federal funding. In addition, updates to equipment disposals that are already complete will no longer be held for processing once all other disposals associated with a transfer or sale are complete_ Management believes these are isolated incidents that will be avoided going forward through enhanced training and escalation when delays occur. Training materials will be developed by Research Space Management Directors for implementation April 2025 to coincide with annual Asset Certification.

The District will re-implement bi-annual physical inventory of inventoriable items by an independent third-party vendor, as required under the provisions of 2 CFR 200.313. This process will be under the direction of the Purchasing Services Department and will begin in Fiscal Year 2024-2025.

Elementary and Secondary School Emergency Relief – Assistance Listing No. 84.425D, 84.425U Recommendation: Auditor recommends that the District establish and implement procedures to ensure that a physical inventory of equipment is conducted at least once every two years. This should include assigning responsibility for the inventory process, setting a schedule for inventory counts, and ensuring that the results are reconciled with the equipment records. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We will work with the Building and Grounds Director to create a schedule for the inventory process. Name(s) of the contact person(s) responsible for corrective action: Frank Neve Planned completion date for corrective action plan: 06/30/2025. U.S. Department of Agriculture

Management agrees with the recommendation and has already contracted with an asset appraiser to physically inventory the research funded assets. We are also planning to do a full physical inventory of all property in the Spring of 2026 as part of our Facilities and Administrative Rate proposal base year activities.This is expected to be completed prior to the close of FY2025.

Town management concurs with the finding, and while audit staff were still onsite for field work, Town staff implemented and added tracking and documentation information for all federally funded capital assets, to include unique descriptors, Catalog of Federal Domestic Assistance grant number, funding source and amount. In addition, inventory counts for federally funded assets will be conducted and recorded at least once every two years.

Corrective Action Plan: The District has developed and implemented a Federal Funds Manual. Anticipated Corrective Action Plan Completion Date: November 18, 2024 Contact Information: For additional information regarding this finding please contact Blaise Paul, Chief Business & Finance Officer, at 414-768-6140.

Identifying Number: 2024-004 Equipment Management—Material Weakness U.S. Department of Education Passed through Missouri Department of Elementary and Secondary Education Education Stabilization Fund, Assistance Listing No. 84.425C (COVID-19—Governor’s Emergency Education Relief Fund), 84.425D (COVID-19—Elementary and Secondary School Emergency Relief Fund), 84.425U (COVID-19—American Rescue Plan-Elementary and Secondary School Emergency Relief), 84.425W (COVID-19—American Rescue Plan-Elementary and Secondary School Emergency Relief-Homeless Children and Youth) Federal award year 2023-2024 Summary of Finding: Criteria: The Uniform Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance retirements. Also, in accordance with 2 CFR section 200.313(d)(1), property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the federal award identification number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property. In accordance with 2 CFR section 200.313(d)(2), a physical inventory of equipment and property must be taken, and the results reconciled with the property records at least once every two years. Condition: The District’s controls were not operating effectively to reasonably ensure the District had maintained property records with the above required information, and performed the required physical inventory of equipment within the two previous years. As a result, the District did not comply with the compliance requirements for equipment and property. Cause: The District does not have processes and procedures in place related to equipment management, tracking and required physical inventories. Effect or potential effect: The District is not in compliance with federal grant requirements over the tracking and physical inventory of equipment. Improper equipment procedures could result in actions taken by oversight agencies which could impact future funding. Questioned costs: None Context: For all sample selections tested in the major program, there was no process of tagging and tracking equipment purchased with federal funding, nor evidence that any physical inventories had been performed. Identification as a repeat finding, if applicable: Not applicable.   Corrective Action: District personnel do not normally make capital purchases from federal grants. ESSER III was unusual in this regard. Management has prepared a spreadsheet that will be used to track the capital purchases made from ESSER dollars. We will send this spreadsheet to Operations and Academic Services personnel so that they can populate the data. Once this is complete, we will schedule an inventory of these items. Anticipated Completion Date: June 2025 (for the year ending June 30, 2025). Contact Person: Steve Marriott, Controller 816-321-5000 Steve.marriott@nkcschools.org

CORRECTIVE ACTION PLAN Nov 6, 2024 Higher Institute for Arts and Technology (the School) provides its Corrective Action Plan for the fiscal year ended June 30, 2024. FINDING 2024-001 – RECONCILIATION OF PHYSICAL INVENOTRY – Significant Deficiency Planned corrective action: The School through the educational service provider agreement with Entrepreneurial Ventures in Education (EVE) will implement procedures and provide additional training to school staff that are responsible for taking physical inventory to ensure results are reconciled with fixed asset property records maintained by EVE. Responsible officers: Jeffrey Larkins, Director of Finance and Accounting; Javier Dimas, Vice-President of Operations Estimated completion date: May 15, 2025 22

As of October 8, 2024, the Executive Director of Business & Human Resources, Kevin J. Polunci has reached out to Questar III BOCES to ensure the equipment purchased with federal funds is clearly denoted in the report ending June 30, 2025.

Implementation plan of action: The Business Manager will review these requirements with the Account Clerk responsible for tracking fixed assets to ensure that purchases made with federal dollars are recorded in the database with all the necessary information to meet the compliance requirements. In addition, we will establish a process to perform a physical inventory as required every two years. Person Responsible for Implementation: Jodi Birch, Business Manager and Kristie Smith, Account Clerk Anticipated Completion Date: June 30, 2025

Reference Number: 2023-009 Finding: Improve Controls and Compliance with Equipment and Real Property Management Name of Contact Person: Lorina Esposito Corrective Active Plan: Over the past year staff has ensured that the inventory is up-to-date and accurate. Inventories were performed in 2024 in preparation for the single audit. Now that the division of housing and community development is fully staffed, the inventory can be shared amongst staff as well as uploaded to the shared drive to ensure it can be accessed in the event of staff turnover. Proposed Completion Date: 3/31/26

Name of Contact Person Responsible for Corrective Action Plan: Marcee Pool, Interim Superintendent Corrective Action Plan: Dublin City Schools concur with the finding and are working to implement appropriate internal controls to alleviate the finding. Anticipated Completion Date: December 31, 2026

2023 – 007: Equipment and Real Property Management (Compliance; Internal Controls Over Compliance) Material Weakness Condition: During our review of the Organization’s internal controls over compliance related to the Title V major program, we noted that the Organization did not obtain prior written approval from the funding agency for the purchase of land and a building with Title V funds, with the purchase exceeding the $20,000 threshold included in the Title V contract. Additionally, the Organization did not have an approved budget that included these capital expenditures. The Organization also does not have an adequate system of controls established to identify, mark, record, or maintain equipment and real property purchased with federal funds, and no periodic physical inventory of such assets is being performed. Corrective Action Plan: Management will review internal control policies and procedures to ensure that prior written approval is obtained for all capital expenditures with federal funds. A procedure will be set up for maintaining property records, conducting periodic physical inventories, and ensuring all staff are trained on these requirements.