Corrective Action Plans

Action taken in response to finding: The Organization agrees with the finding. The Organization will adopt a formal procurement policy in accordance with federal requirements. Name(s) of the contact person(s) responsible for corrective action: Paula Culp, Chief Administrative Officer Planned completion date for corrective action plan: March 2024

FINDING 2023-002 Finding Subject: Child Nutrition Cluster – Procurement and Suspension and Debarment Summary of Finding: We did not use the formal bid process for a vendor purchase over the simplified acquisition threshold. We did not ensure that all vendors over the $25,000 threshold were not suspended or debarred from conducting business with us. Contact Person Responsible for Corrective Action: Leeanne Koeneman Contact Phone Number and Email Address: Leeanne.Koeneman@nacs.k12.in.us; 260-637-8768 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Food Service Director will track cumulative expenditures for Vendor by Fiscal Year to ensure that compliance requirements related to procurement thresholds are met. Simultaneously, the Treasurer’s Office will provide reports to the Food Service Department on a monthly basis detailing the cumulative expenditures by vendor paid from the Food Service Fund. With thresholds being actively monitored, the Food Service Director will request quotes or bids, as applicable by individual and cumulative thresholds. Utilizing the procedures outlined above, individual and cumulative expenditures over $25,000 will be verified to ensure that the potential vendor(s) has not been suspended or debarred. Upon checking the status of vendor(s) at the Food Service Department, the results will be sent to the Treasurer’s office for review. Anticipated Completion Date: June 30, 2024

FINDING 2023-002 Finding Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Summary of Finding: Procurement The School Corporation failed to award contracts to four vendors totaling $314,783, which were considered small purchases. For small purchases of over $10,000 but less than $150,000, an informal process allows securing rate quotations from an adequate number of sources; however, the process still requires a written contract between the vendor and the school corporation. Suspension and Debarment The School Corporation failed, due to the lack of effective internal controls, to provide adequate oversight of the suspension/debarment process to ensure compliance to the process prior to paying vendors that were expected to be paid an amount equal to or exceeding $25,000. Contact Person Responsible for Corrective Action: Carla Gambill Contact Phone Number and Email Address: 812-847-6020 ext. 1004 cgambill@lssc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Procurement When quotes for small purchases are received, the Director of School Finance will acknowledge a quote provided by a vendor that will be accepted by the corporation by written letter acknowledging the school corporation’s acceptance of the quote. The contract as well as the quote will be retained by the Director of School Finance and the Director of Food Services for comparison to invoices. INDIANA STATE BOARD OF ACCOUNTS 30 Suspension and Debarment On an annual basis, all vendors that are expected to be paid in excess of $25,000 will be searched by the Director of School Finance for suspension or debarment or the vendor will provide certification, either as a separate document, or as part of a written contract, that the vendor is not excluded or disqualified to receive federal funds. Those searches or other documentation will be reviewed by the Superintendent and acknowledged by signature. Anticipated Completion Date: This Corrective Action Plan will be put in effect March 2024.

FINDING 2023-007 Finding Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Summary of Finding: An effective internal control system, which would include segregation of duties, was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Procurement The School Corporation did not complete or submit the fiscal year 2023 Procurement Plan as required to the Indiana Department of Education. Suspension and Debarment The School Corporation was a member of the East Central Educational Service Center (ECESC) during fiscal years 2021-2022 and 2022-2023. ECESC verified that vendors were not suspended or debarred when securing bids for food, dairy, and bread products on behalf of the member schools. However, for purchases of goods and services exceeding $25,000 handled by the School Corporation, 3 of the 5 vendors selected for testing were not verified for suspension and debarment to ensure vendors were not suspended or debarred from participation in federal programs. Contact Person Responsible for Corrective Action: Julie Cramer Contact Phone Number and Email Address: 765-932-4186 cramej@rushville.k12.in.us Views of Responsible Officials: We concur with the finding. Explanation and Reasons for Disagreement: N/A Description of Corrective Action Plan: Due to turnover in the Superintendent position and Food Service Director, position there was no access to SAM to verify vendor. This has been now been corrected and the Superintendent and Assistant Superintendent have access to SAM. They will verify for the Food Service Director any company will wish to deal with over $25,000. Future purchases will meet the school corporation’s procurement policy. All vendors in which expenditure exceed $25,000 will reviewed by the Food Service Director and either the Superintendent or Assistant Superintendent. Procurement – A 2023 procurement plan has been developed and will be sent to the Indiana Department of Education. Anticipated Completion Date: April 2024

FINDING 2023-002 Finding Subject: Child Nutrition Cluster -Procurement and Suspension and Debarment Summary of Finding: The School Corporation had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance with Procurement, Suspension and Debarment. The School Corporation entered into more than $50,000 of like/kind transactions with a single vendor during FY2022 and FY2023 without entering into a contract or properly verifying that the vendor was not suspended or debarred. Contact Person Responsible for Corrective Action: Tracy Troesch Contact Phone Number and Email Address: 812-817-0900; tracy.troesch@sedubois.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Business Manager will review the vendors related to covered transactions and determine if like/kind transactions with any vendor are approaching or are expected to exceed $50,000. For vendors that meet the criteria of requiring a contract, the Business manager will obtain a contract, which will be reviewed and approved by the school board. The Business Manager will upload the purchase order and quote or other documentation of any purchase over $50,000 on Indiana Gateway for Government Units (Gateway) after board approval. Southeast Dubois County School Corporation followed the corrective action that was issued during the prior audit for Suspension and Debarment. During the current audit, the State Board of Accounts indicated that the corrective action and steps that were taken to verify compliance that the School Corporation was instructed to do were not adequate. Going forward, the Business Manager will run monthly vendor reports to determine if any vendors are close to the $25,000 to get a Certification Regarding Debarment, Suspension, Ineligibility, and Voluntary Exclusion form from the IN Department of Education needs to be issued to a vendor. If a vendor is close to the $25,000 mark, the Business Manager will send the Certification to be returned prior to future payment. Anticipated Completion Date: September 2024

Corrective Action: On November 23, 2023 MHC updated its Procurement Policy to require formal documentation of all rate quotes related to federal funding in accordance with federal procurement standards. This updated policy was then shared with MHC personnel responsible for contracting for services and has been implemented for transactions after this date. Name of Contact Person: Jennifer A. Pulse , CFO; Telephone number: 860-856-7963; Email address: JPulse@mhconn.org. Projected Completion Date: Completed 11/23/2023 If the Office of Management and Budget requires any additional information or has questions regarding this Plan, please call Jennifer A. Pulse at 860-856-7963.

FINDING 2023-004 Finding Subject:􀀃Child􀀃Nutrition􀀃Cluster􀀃􀍲􀀃Procurement􀀃and􀀃Suspension􀀃and􀀃Debarment Summary of Finding: An􀀃effective􀀃internal􀀃control􀀃system􀀃was􀀃not􀀃in􀀃place􀀃at􀀃the􀀃School􀀃Corporation􀀃to􀀃ensure􀀃compliance􀀃with􀀃 requirements􀀃related􀀃to􀀃the􀀃grant􀀃agreement􀀃and􀀃the􀀃Procurement􀀃and􀀃Suspension􀀃and􀀃Debarment􀀃compliance􀀃 requirement.􀀃 Contact Person Responsible for Corrective Action: Lela Simmons Contact Phone Number and Email Address: (219) 391- 4100, lesimmons@ecps.org Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: All􀀃purchases􀀃will􀀃require􀀃three􀀃quotes􀀃to􀀃ensure􀀃the􀀃Vendor􀀃is􀀃compliance􀀃with􀀃purchase􀀃of􀀃$150,000􀀃or􀀃exceed􀀃 micro􀍲purchase􀀃threshold􀀃of􀀃$10,000􀀃all􀀃quotes􀀃will􀀃be􀀃attached􀀃to􀀃the􀀃APV.􀀃This􀀃will􀀃ensure􀀃all􀀃documents􀀃are􀀃 available􀀃upon􀀃request.􀀃The􀀃School􀀃Corporation􀀃will􀀃work􀀃with􀀃State􀀃to􀀃receive􀀃approval􀀃of􀀃Food􀀃Service􀀃 Management􀀃Company.􀀃􀀃 Anticipated Completion Date: We anticipate having the above corrective action plan in place by September 30, 2024.

FINDING 2023-003 Finding Subject: Special Education Cluster (IDEA) – Procurement, Suspension and Debarment Summary of Finding: Insufficient documentation provided for proof of Procurement and Suspension and Debarment verifications Contact Person Responsible for Corrective Action: Ghirmay Alazar (Procurement) Phyllis Ritenour (Suspension & Debarment) Contact Phone Number and Email Address: 317-845-9400 galazar@msdwt.k12.in.us pritenour@msdwt.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: Procurement - At our educational institution, we prioritize the unique leaning needs of our students by actively seeking vendors who can effectively meet our expectations. To ensure transparency and fairness in the vendor selection process, we examine total costs estimates from each vendor and analyze their reputations, experience, customer feedback, and ability to provide innovative solutions. We use this information to make informed decisions and the rationale behind our vendor selection process. When searching for vendors we will keep documentation that displays the cost from each vendor and the rational for selecting a specific vendor. Suspension and Debarment – Beginning July 2024 the Assistant Accounting Manager will run reports annually in July from sam.gov and from FMS and compare the 2 files to make sure that we don’t have vendors in our system that are on the debarment list. The files will then be forwarded to the Accounting Manager via email for review and approval. The approval email and the 2 reports will be saved in our shared drive as proof of file review. All new vendors will be checked in sam.gov before allowing purchases to be placed. The review sheets will be emailed to the Accounting Manager for review and approval, these will also be saved in our shared drive. Anticipated Completion Date: Procurement – December 2024 Suspension & Debarment – July 2024

We agree with the auditor’s comments, and the following actions will be taken to ensure all procurement procedures are within compliance: 1. Review current Board policies on small purchase and micro-purchase thresholds 2. Receive multiple quotes/bids for contracts that will qualify as small purchases. 3. Maintain documentation of the above for records purposes The above steps will be completed and implemented by December of 2024 to follow Child and Adult Care Food Program, Child Nutrition Cluster guidelines.

FINDING 2023-004 Information on the federal program: Subject: Special Education Cluster (IDEA) – Procurement and Suspension and Debarment Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.027X, 84.173, 84.173X Federal Award Numbers and Years (or Other Identifying Numbers): 19611-022-PN01, 20611-022-PN01, 21611-022-PN01, 22611-022-PN01, 22611-022-ARP, 23611-022-PN01, 20619-022-PN01, 21619-022-PN01, 22619-022-PN01, 22619-022-ARP, 23619-022-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Qualified Opinion Condition: The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the procurement and suspension an debarment requirements. The Cooperative had not designed or implemented adequate policies or procedures to ensure that proper procurement procedures for micro or small purchases were followed. There was no oversight, review, or approval process in place and documented at the Cooperative to ensure proper procedures were followed and price or rate quotations were obtained, if required, or documentation to support limited procurement procedures. Context: The School Corporation is a member of the Greene-Sullivan Special Education Cooperative (Cooperative). During fiscal year 2021-2022 and 2022-2023, the Cooperative operated the special education programs and spent the federal money on behalf of all its members.  As the grant agreements were between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. However, there was inadequate oversight performed by the School Corporation in order to ensure compliance with the Procurement and Suspension and Debarment compliance requirement. Procurement Federal regulations allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisition threshold, which is set at $250,000 unless a lower, more restrictive threshold is set by a non-Federal entity. As Indiana Code has set a more restrictive threshold of $150,000, informal procurement methods are permitted when the value of the procurement does not exceed $150,000. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds. Micro-purchases, typically for those purchases $10,000 or under, and small purchase procedures for those purchases above the micro-purchase threshold, but below the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. For fiscal year 2022, three vendors, totaling $88,772, were identified as being less than the simplified acquisition threshold of $150,000, but exceeding the $10,000 micro-purchase threshold. One of the three vendors was a bankcard used to pay several different vendors; however, individual determinations of amount spent by vendor could not be determined, and thus it was considered under this threshold. All three vendors were tested. For all three, the Cooperative did not obtain price or rate quotes nor was there documentation detailing the history of procurement, which must include the reason for the procurement method used. For fiscal year 2023, six vendors, totaling $264,106, were identified as being less than the simplified acquisition threshold of $150,000, but exceeding the $10,000 micro-purchase threshold. One of the six vendors was a bankcard used to pay several different vendors; however, individual determinations of amount spent by vendor could not be determined, and thus it was considered under this threshold. All six vendors were tested. For five of the six, totaling $252,906, the Cooperative did not obtain price or rate quotes nor was there documentation detailing the history of procurement, which must include the reason for the procurement method used. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Suspension and Debarment Prior to entering into subawards and covered transactions with federal award funds, recipients are required to verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded. “Covered transactions” include but are not limited to contracts for goods and services awarded under a non-procurement transaction (i.e., grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the SAMs exclusions, collecting a certification from that vendor, or adding a clause or condition to the covered transaction with that vendor. Upon inquiry of the School Corporation in order to review the procedures in place for verifying that a vendor with which it plans to enter into a covered transaction is not suspended, debarred, or otherwise excluded, the Cooperative disclosed they relied on a clause to be included in the vendor contracts to ensure compliance. Two covered transactions that equaled or exceeded $25,000 were identified. Both transactions, totaling $192,218, were selected for testing. One of the two transactions, totaling $44,883, included the appropriate clause. For the other vendor, the Cooperative did not verify the vendor’s suspension and debarment status prior to payment. The lack of internal controls and noncompliance regarding suspension and debarment were isolated to fiscal year 2023. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and will take the following corrective action: 1 – Southwest School Corporation will ensure a system of internal control and procedures are in place and appropriate procurement procedures for goods and services are followed. 2 – The Cooperative will post any openings that exceed the small purchase threshold in the local newspapers, within the office, and on the cooperative website. Any and all proposals will be presented to the Cooperative Board of Directors for approval. Responsible party and timeline for completion: Chris Stitzle, Superintendent – April 1, 2024

Auditor’s Recommendations: We recommend the District establish a policy and implement procedures regarding large purchases related to Federal grants to insure that no vendors who are suspended, debarred, or otherwise excluded from participating in transactions funded through Federal grants are used. As identified above, there are several methods in which the District can verify vendors who are not suspended or debarred. The District may have the vendor provide an annual certification that is s not currently suspended, debarred, or otherwise prevented from receiving Federal dollars. In other occasions in which a single purchase is going to be made, the purchasing procedures should include looking up the vendor on the GSA website, printing a copy of the verification, and placing it in the file with the purchase order. The District has options, and it should establish what method is the least intrusive, but also effective, in complying with the requirements of the Uniform Grant Guidance. Responsible Official’s Plan: • Specific corrective action plan for funding: The procurement Officer of SJSWCD has updated the procurement process on 12/7/23 that all contractors who will be receiving Federal monies must provide an annual certification that they are not suspended, debarred, inactive, or otherwise excluded from participating in transaction funded through Federal grants. The policy change will be approved at the next board meeting. • Timeline for completion of corrective action plan: December 7, 2023 • Employee position(s) responsible for meeting the timeline: Oralia Bridge, District Manager

FINDING 2023-006 Information on the federal program: Subject: Special Education Cluster (IDEA) – Procurement and Suspension and Debarment Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.027X, 84.173, 84.173X Federal Award Numbers: 19611-022-PN01, 20611-022-PN01, 21611-022-PN01, 22611-022-PN01, 22611-022-ARP, 23611-022-PN01, 20619-022-PN01, 21619-022-PN01, 22619-022-PN01, 22619-022-ARP, 23619-022-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Qualified Opinion Condition: The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the procurement and suspension an debarment requirements. The Cooperative had not designed or implemented adequate policies or procedures to ensure that proper procurement procedures for micro or small purchases were followed. There was no oversight, review, or approval process in place and documented at the Cooperative to ensure proper procedures were followed and price or rate quotations were obtained, if required, or documentation to support limited procurement procedures. Context: The School Corporation is a member of the Greene-Sullivan Special Education Cooperative (Cooperative). During fiscal year 2021-2022 and 2022-2023, the Cooperative operated the special education programs and spent the federal money on behalf of all its members. As the grant agreements were between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. However, there was inadequate oversight performed by the School Corporation in order to ensure compliance with the Procurement and Suspension and Debarment compliance requirement. Procurement Federal regulations allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisition threshold, which is set at $250,000 unless a lower, more restrictive threshold is set by a non-Federal entity. As Indiana Code has set a more restrictive threshold of $150,000, informal procurement methods are permitted when the value of the procurement does not exceed $150,000. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds. Micro-purchases, typically for those purchases $10,000 or under, and small purchase procedures for those purchases above the micro-purchase threshold, but below the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. For fiscal year 2022, three vendors, totaling $88,772, were identified as being less than the simplified acquisition threshold of $150,000, but exceeding the $10,000 micro-purchase threshold. One of the three vendors was a bankcard used to pay several different vendors; however, individual determinations of amount spent by vendor could not be determined, and thus it was considered under this threshold. All three vendors were tested. For all three, the Cooperative did not obtain price or rate quotes nor was there documentation detailing the history of procurement, which must include the reason for the procurement method used. For fiscal year 2023, six vendors, totaling $264,106, were identified as being less than the simplified acquisition threshold of $150,000, but exceeding the $10,000 micro-purchase threshold. One of the six vendors was a bankcard used to pay several different vendors; however, individual determinations of amount spent by vendor could not be determined, and thus it was considered under this threshold. All six vendors were tested. For five of the six, totaling $252,906, the Cooperative did not obtain price or rate quotes nor was there documentation detailing the history of procurement, which must include the reason for the procurement method used. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Suspension and Debarment Prior to entering into subawards and covered transactions with federal award funds, recipients are required to verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded. “Covered transactions” include but are not limited to contracts for goods and services awarded under a non-procurement transaction (i.e., grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the SAMs exclusions, collecting a certification from that vendor, or adding a clause or condition to the covered transaction with that vendor. Upon inquiry of the School Corporation in order to review the procedures in place for verifying that a vendor with which it plans to enter into a covered transaction is not suspended, debarred, or otherwise excluded, the Cooperative disclosed they relied on a clause to be included in the vendor contracts to ensure compliance. Two covered transactions that equaled or exceeded $25,000 were identified. Both transactions, totaling $192,218, were selected for testing. One of the two transactions, totaling $44,883, included the appropriate clause. For the other vendor, the Cooperative did not verify the vendor’s suspension and debarment status prior to payment. The lack of internal controls and noncompliance regarding suspension and debarment were isolated to fiscal year 2023. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and will take the following corrective action: 1 – Northeast School Corporation will ensure a system of internal control and procedures are in place and appropriate procurement procedures for goods and services are followed. 2 – The Cooperative will post any openings that exceed the small purchase threshold in the local newspapers, within the office, and on the cooperative website. Any and all proposals will be presented to the Cooperative Board of Directors for approval. Responsible party and timeline for completion: Mark A Baker, Superintendent Effective April 2024

FINDING 2023-003 Finding Subject: Child Nutrition Cluster – Procurement and Suspension and Debarment Summary of Finding: Procurement: For one of the two vendors tested for small purchases an adequate number of price or rate quotes were not obtained. Suspension and Debarment: The School Corporation purchased bread, dairy produce and commodities through Region 8 Education Service Center (Region 8) However, Region 8 had not received the SFA – only Cooperative classification from IDOE for fiscal years 2021-2022 and 2022-2023. As such, the School Corporation could not rely on Region 8’s verification of suspension and debarment and was required to complete their own verification. One covered transaction was identified and tested that equaled or exceeded $25,000. For the noted transaction, the School Corporation did not verify that the vendor was not excluded or disqualified from participation in federal award programs. Contact Person Responsible for Corrective Action: Susan Loftain Contact Phone Number and Email Address: (260) 693-2007 loftains@sgcs.k12.in.us Views of Responsible Officials: Option 1: “We concur with the finding.” Description of Corrective Action Plan: Procurement: All vendors procured through Region 8 we will need to take action to secure bids and quotes and keeps copies and make we are within compliance Suspension and Debarment: We will be sure to complete our own verifications and not rely on Region 8 to check on suspension and debarment Anticipated Completion Date: Today 2/28/24

Finding 2023-004 Finding Subject: Child Nutrition Cluster-Procurement and Suspension and Debarment Summary of Finding: The School Corporation had not properly designed or implemented internal controls over procurement and suspension and debarment Contact Person Responsible for Corrective Action: Dr. Tracy Lorey, Monica Young, April Hopf Contact Phone Number and Email Address: tlorey@gjcs.k12.in.us myoung@gjcs.k12.in.us ahopf@gjcs.k12.in.us 812-482-1801 Views of Responsible Officials: We agree with the finding. Description of Corrective Action Plan: The school corporation will follow our Procurement policy in the future. Anticipation Completion Date: August 2024—Beginning of New School Year

FINDING 2023-004 Finding Subject: Child Nutrition Cluster – Procurement, Suspension, and Debarment Summary of Finding: Material Weakness, Other Matters The School Corporation had not properly designed or implemented an effective system of internal controls to prevent, or detect and correct, noncompliance. Procurement: A School Nutrition Cooperative (Co-ops, Education Service Center, Group Purchasing Organization, etc.) that would like to be classified as a School Food Authority (SFA) Cooperative must complete a questionnaire and submit it to the Indiana Department of Education (IDOE). Once a questionnaire is received IDOE will review the answers to determine a Cooperative’s classification. Only Cooperatives that submit the questionnaire and receive a SFA-only Cooperative classification from IDOE in writing will be considered a SFA only Cooperative for the purposes of the procurement process and procurement reviews. When the value of goods or services exceeds the simplified acquisition threshold, the proper purchasing method would be the bidding process, unless the purchase meets certain other qualifications. Federal regulations allow for informal procurement methods when the value of the procurement for goods or services does not exceed the simplified acquisition threshold, which is customarily set at $250,000. However, Indiana Code 5-22-8 has a more restrictive threshold of $150,000 or less for when small purchase procedures may be used. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds. Micro-purchases, typically for those purchases $10,000 or under, and small purchase procedures for those purchases above the micro-purchase threshold, but below the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. If it is determined a single source provider can be used for a small purchase, documentation must be retained supporting the determination. The School Corporation purchased milk through Region 8 Education Service Center (Region 8). However, Region 8 had not received the SFAonly Cooperative classification from IDOE for fiscal years 2021–2022 and 2022-2023. As such, the School Corporation could not rely on the procurement done by Region 8. Region 8 could be considered one quote for procurement; however, the School Corporation did not obtain any other quotes related to the purchase of milk, therefore, an adequate number of quotes from qualified sources was not obtained. Suspension and Debarment: Prior to entering into subawards and covered transactions with federal award funds, recipients are required to verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded. “Covered transactions” include, but are not limited to contracts for goods and services awarded under a non-procurement transaction (i.e. grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the SAMs exclusions, collecting a certification from that vendor, or adding a clause or condition to the covered transaction with that vendor. INDIANA STATE BOARD OF ACCOUNTS 47 MADISON-GRANT UNITED SCHOOL CORPORATION Steve Vore., Superintendent Ben Mann, Chief Financial Officer Kristy Drewitz, Transportation Allison McGuire, Payroll/Benefits Anna Richards, Corp Secretary/Deputy Treasurer Inspire, Cultivate, and Promote excellence in every Argyll. Upon inquiry of the School Corporation in order to review the procedures in place for verifying that a vendor with which it plans to enter into a covered transaction is not suspended, debarred, or otherwise excluded, the School Corporation noted that vendor’s were checked against Sam. Gove and verified to not be suspended or debarred. Four covered transactions that equaled or exceeded $25,000 were identified. All for transactions, totaling $213,795, were selected for testing. For three of the four vendors, the School Corporation did not verify the vendor’s suspension and debarment status prior to payment. The total amount spent with the three vendors was $162,733. Contact Person Responsible for Corrective Action: Kathy Bernaix Contact Phone Number and Email Address: 765-536-0008 kbernaix@mgusc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Procurement: Three quotes will be requested for “small purchases” and the process will be reviewed to ensure it is performed. Suspension and Debarment: Before purchasing goods that total $25,000 or more from a vendor, the Food Service Director will look up the vendor on SAM.gov for debarment activity. Anticipated Completion Date: February 2024

FINDING 2023-003 Finding Subject: Special Education Cluster (IDEA) – Procurement and Suspension and Debarment Summary of Finding: Procurement Federal regulations allow for informal procurement methods when the value of the procurement for goods or services does not exceed the simplified acquisition threshold, which is customarily set at $250,000. However, Indiana Code 5-22-8 has a more restrictive threshold of $150,000 or less for when small purchase procedures may be used. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds. Micropurchases, typically for those purchases $10,000 or under, and small purchase procedures for those purchases above the micro-purchase threshold, but below the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. If it is determined a single source provider can be used for a small purchase, documentation must be retained supporting the determination. The Cooperative did not adhere to the requirements necessary for them to be in compliance with the procurement of small purchases during the audit period. Suspension and Debarment The School Corporation did not have internal controls in place to ensure compliance with the suspension and debarment requirement. The Cooperative did not have adequate internal controls in place to ensure all applicable vendors were not suspended or debarred prior to entering into a covered transaction. As such, the Cooperative never entered into a contract, although their payments to the vendor exceeded $50,000. The INDIANA STATE BOARD OF ACCOUNTS 30 Cooperative did not perform procedures to ensure that the vendor was not suspended or debarred from participation in federal programs. Contact Person Responsible for Corrective Action: Lana M. Miller Contact Phone Number and Email Address: Phone Number-812-689-6282 Email- lmiller@sripley.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The ROD Special Education Cooperative will make notes in the Board Minutes regarding the fact that only one vendor can provide specific services prior to entering into a contract or purchasing said services. Each company providing services will be checked on the SAM.gov website to ensure that the vendor has not been suspended or debarred. This documentation will be provided to the ROD board for review, and our Superintendent is a member of that board. Anticipated Completion Date: February 1, 2024

Responsible Contact Person(s): Melinda Raines, Director of Human Resources Karen Holt, Human Resources Business Process Consultant Corrective Action Planned: In 2018, the Virginia Department of Social Services (DSS) implemented written procedures to administer the Conflict of Interests Act (COIA) as outlined in the Code of Virginia. While an SOEI policy was not created, the procedures were clear, documented, and administered. DSS continues to refine written procedures and correct identified deficiencies to meet compliance with the COIA. In January 2022, DSS began the process to have oversight responsibility for the COIA reassigned to another Human Resources (HR) unit. HR continues to evaluate and update the approach used to identify and track employees in a position of trust upon hire or change in responsibilities. Prior to the annual disclosure process the SOEI coordinator will review positions against Executive Order 18 (2022) to confirm positions within the agency that are designated as positions of trust. Division directors from various areas will be consulted to determine if any positions involving contracts, licenses, audits, budgets, policy, or grants should be designated in a position of trust. Team members from HR will review the designation list and any additions or removals from the prior year will be updated in the economic interest field in the human capital management system. To capture new hires and transfers in a position of trust throughout the year, the SOEI coordinator will review the new hire and transfer report for the agency twice per month. When a new hire or transfer is moving into a position of trust the employee’s information will be added into the Conflict of Interest Disclosure System. Notifications will be sent requesting the disclosure form is completed on or prior to the employee’s start date. The system will be monitored to track progress of completion. Should the employee not complete the financial disclosure, the employee’s supervisor will be notified. When new employees in a position of trust receive access to the Commonwealth of Virginia Learning Center (COVLC), they are enrolled into the conflict of interest (COI) training and provided a deadline for completing the course. The SOEI coordinator will monitor the COVLC system for completion. Should the employee not complete the orientation training, the employee’s supervisor will be notified. To improve monitoring and tracking of COI training every two years, a spreadsheet will be maintained listing training completion dates. The report will be monitored on the same schedule as the new hire and transfer report. The spreadsheet will flag a filer’s record when the most recent training date approaches the two year mark and needs to be retaken. HR will then enroll the employee in the COI training, notify the employee and the employee’s manager of the training requirement, and monitor for completion. Reassigning oversight of the COIA to another HR unit and following the updated written procedures should show considerable improvement and compliance with the agency’s monitoring of the COIA by April 1, 2024. Estimated Completion Date: 4/1/2024

Finding Reference Number: 2023-001 Description of Finding: Written Procurement Policy (significant deficiency) Statement of Concurrence: Management concurs with the finding and had implemented a written procurement policy that complies with the requirements of the Uniform Guidance. Corrective Action: Management has established a written procurement policy and implemented the documented procurement procedures as of August 13, 2022. Name of Contact Person: Steve Tyrell, Senior Vice President, CFO & COO, 518-366-1533, steve.tyrell@WCMO.edu Projected Completion Date: The College’s corrective action plan is completed and in effect at this time.

FINDING 2023-005 Finding Subject: Special Education Cluster (IDEA) – Procurement and Suspension and Debarment Summary of Finding: Procurement Federal regulations allow for informal procurement methods when the value of the procurement for goods or services does not exceed the simplified acquisition threshold, which is customarily set at $250,000. However, Indiana Code 5-22-8 has a more restrictive threshold of $150,000 or less for when small purchase procedures may be used. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds. Micro-purchases, typically for those purchases $10,000 or under, and small purchase procedures for those purchases above the micro-purchase threshold, but below the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. If it is determined a single source provider can be used for a small purchase, documentation must be retained supporting the determination. The Cooperative did not adhere to the requirements necessary for them to be in compliance with the procurement of small purchases during the audit period. Suspension and Debarment The School Corporation did not have internal controls in place to ensure compliance with the suspension and debarment requirement. The Cooperative did not have adequate internal controls in place to ensure all applicable vendors were not suspended or debarred prior to entering into a covered transaction. As such, the Cooperative never entered into a contract, although their payments to the vendor exceeded $50,000. The Cooperative did not perform procedures to ensure that the vendor was not suspended or debarred from participation in federal programs. Contact Person Responsible for Corrective Action: Julie Dudley Contact Phone Number and Email Address: 812.537.7205 jdudley@lburg.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The ROD Special Education Cooperative will make notes in the Board Minutes regarding the fact that only one vendor can provide specific services prior to entering into a contract or purchasing said services. Each company providing services will be checked on the SAM.gov website to ensure that the vendor has not been suspended or debarred. This documentation will be provided to the ROD board for review, and our Superintendent is a member of that board. Anticipated Completion Date: February 1, 2024

Specific corrective action plan for finding: Christi Walter, Coordinator Purchasing Department along with the Dom Atcitty, Grants Specialist, will review vendors that are issued requisitions at each approval level to assist in catching $25K or more for Suspension and Debarment. A printed document from SAM.GOV verifying eligibility to Requisitions over $25K should be attached. At the initial setup of new vendors, the Purchasing Department will review vendors in SAM.GOV. A printed document from SAM.GOV verifying eligibility of vendor will be attached to the vendor file. Timeline for completion of corrective action plan: July 1, 2023 Employee position(s) responsible for meeting the timeline: Dom Atcitty, Grants Specialists; Christi Walter, CPO; Lisa Smith, Purchasing Specialist; Bellamie DeHerrera-Presley, Federal Grants Coordinator and Erica Benally, Federal Grants Specialist

FINDING 2023-005 Finding Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Summary of Finding: Management had not developed a system of internal controls that would have ensured compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. The failure to establish an effective internal controls system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement could result in the loss of future federal funds to the School Corporation. We recommended that the School Corporation's management establish a system of internal controls to ensure compliance with the Procurement and Suspension and Debarment compliance requirement. Contact Person Responsible for Corrective Action: Andrea Miller Contact Phone Number and Email Address: 765-564-2100, millera@delphi.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Food Service Director will obtain 3 quotes for any purchase over $10,000 from different vendors, in addition if the purchase is over $50,000 a contract will be awarded. Vendors will be verified by SAM.gov for suspension and disbarment, a record of these searches will be printed and kept in the vendor file. In addition, a vendor list will be provided annually to the school board for approval. Anticipated Completion Date: July 2024

This document serves as the response to the 2022-2023 Financial Audit on behalf of BELIEVE Schools, Inc. We’ve identified and reviewed the finding outlined below: The results of our auditing procedures disclosed one instance of noncompliance which is required to be reported in accordance with Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (“Uniform Guidance”) and which is described in the accompanying schedule of findings and questioned costs as Finding No. 2023- 001. Our opinion on the major federal programs is not modified with respect to these matters. In an effort to address the finding and to ensure the school's alignment with federal compliance standards, the following corrective action plan has been implemented for all purchases made with federal and state program funds: 1. For any procurement or contract ranging from $10,000-$250,000, The Principal, Angel Jackson-Anderson, should seek to acquire as many quotes as possible, aiming for up to five. Prior to finalizing any purchase order, invoice, or commencement of production, the school is mandated to receive and assess three price comparisons from different businesses or organizations. These price comparisons must be logged in the BCCHS Quote Comparison Template and reviewed by the following parties: a. The individual conducting the price comparison b. Building Level Operations Leader c. Executive Director for purchases or contracts exceeding $20,000 2. For any purchase or contract exceeding $250,000, a formal bidding process is required. BELIEVE Schools has adopted resources provided by the Indiana Department of Education: a. Procurement Checklist b. Procurement Plan Template (accessible through DOE) This protocol has been incorporated into the Standard Operating Procedures and School Handbooks, with all relevant stakeholders duly informed on February 16th, 2024.

FINDING 2023-003 Finding Subject: Subject: Child Nutrition Cluster - Procurement Summary of Finding: An adequate number of quotes were not obtained for small purchases. Contact Person Responsible for Corrective Action: Kellie Romer (Corporation Treasurer/Finance Director), Shelley Gardner (Corporation School Food Authority) Contact Phone Number and Email Address: 765-653-9771 Ext. 1010, kromer@greencastle.k12.in.us, 765-653-9771 Ext. 1011, sgardner@greencastle.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: The procurement (small and micro purchases) will be verified by a two-person internal control; the food services director and food services assistant, finance director or deputy treasurer. We will also establish a process to address small and micro purchases. This would include acquiring bids for any combined expenditure(s) over a $150,000, acquiring quotes for any small purchase(s) between $10,000 and $150,000, and documenting equitable distribution among vendors concerning any micro purchases under $10,000. All vendor contracts will be approved yearly. All quotes and purchases will be verified by two-person internal control. Anticipated Completion Date: Immediately 2/8/2024

Recommendation: We recommend that the Organization establish and maintain effective internal controls over procurement requirements. Action Taken: All purchases at One City Schools already require a second approver before invoices are paid. At the November 2023 Board meeting, One City Schools adopted new procurement policies that meet the federal requirements including effective internal controls.

Correctice action plan: The procurement policy will be evaluated and followed with reference to the appropriate Federal, State, and local laws, regulations, and standards. All staff charged with initiating and approving purchases under federal grant programs will use the documented policy. Individual(s) responsible: Allison Hayes, Debbie Pinnock, Yolana Adams Completion Date: Plan to be implemented as soon as possible.