Corrective Action Plans

FINDING 2025-001 Finding Subject: Child Nutrition Cluster - Procurement Suspension and Debarment Contact Person Responsible for Corrective Action: Carrie Alford Contact Phone Number and Email Address: 812-254-5536 calford@wcs.k12.in.us Views of Responsible Officials: “We concur with the finding.” Description of Corrective Action Plan: To address this repeat finding, the Business Manager will now review all federal purchase requests before any funds are committed. We will ensure the correct procurement method is used by requiring and filing at least three competitive quotes for any small purchase between $10,000 and $150,000. For any transaction $25,000 or greater, the Business Manager will verify the vendor’s eligibility on SAM.gov and keep a date-stamped screenshot in the file as proof of the search. This centralized oversight and mandatory documentation process will ensure we maintain a proper history of procurement and prevent further noncompliance. Anticipated Completion Date: 02/01/2026

FINDING 2025-003 Finding Subject: Special Education Cluster (IDEA) – Procurement and Suspension and Debarment Summary of Finding: 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. The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the procurement and the suspension and debarment requirements. The Cooperative did not have adequate procedures in place to ensure that the requirements for the simplified acquisition threshold and for small purchases were met for each applicable procured good or service or to ensure that vendors were not suspended or debarred prior to entering a covered transaction. 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 NEISEC we will need to take action to secure bids and quotes and keep copies and make we are within compliance Suspension and Debarment: We will be sure to complete our own verifications and not rely on NEISEC to check on suspension and debarment Anticipated Completion Date: Immediately

FINDING 2025-003 Finding Subject: Special Education Cluster (IDEA) - Procurement Contact Person Responsible for Corrective Action: Meghan Damron Contact Phone Number and Email Address: 219-650-5300, mdamron@mvsc.k12.in.us Views of Responsible Officials: We concur with the finding. We have taken the audit finding, conclusions and recommendations and created a corrective action plan to correct our procurement for the future. Description of Corrective Action Plan: Although Merrillville Community School Corporation left Northwest Indiana Special Education Cooperative (NISEC) as of July 1, 2024 we continue to use our procurement process following our school board policies. NISEC has reported that for the 2023-2024 school year the corrective action plan was initiated by the below process. As a member of the Northwest Indiana Special Education Cooperative (NISEC), the School Corporation usually expends contracted services out of our general education fund. For the fiscal year of 2023-2024 we included our contracted speech services into our federal grant funds. During the audit the School Corporation was notified that we didn’t following the procurement procedures when expending out of the federal grant. This finding was due to the School Corporation not going out and receiving multiple bids for contracted companies that provide services to our students. The School Corporation uses three contracted companies to provide Speech Pathologist and Speech Language Assistants. We have used these three companies for many years and have built great working relationships with these providers. After receiving the finding and discussing with the auditor we created a memo that we took to our board. In the memo we explain why we use the three contracted vendors instead of going out for bids. Finding Speech pathologist and Assistant are very difficult in the school setting and we have created great working relationships with these three contracted companies. Within the memo we list all of the contracted vendors we use and why we work directly with them instead of going out for bids. At the beginning of each school year we will take a new memo with any contracted companies that we will be using during the school year. Dexter Suggs, Ph.D. Superintendent of Schools "Once a Pirate, Always a Pirate" BOARD OF SCHOOL TRUSTEES Judy C. Dunlap James Donohue DeLena N. Thomas Alex Dunlap III Robert J. Krause President Vice-President Secretary Member Member INDIANA STATE BOARD OF ACCOUNTS 31 MERRILLVILLE COMMUNITY SCHOOL CORPORATION 6701 Delaware Street, Merrillville, IN 46410 (219) 650-5300 FAX (219) 650-5320 www.mvsc.k12.in.us Anticipated Completion Date: The Northwest Indiana Special Education Cooperative created the memo as soon as we received the finding and took the memo to the board. We have procedures in place now that any vendor that will exceed the simplified acquisition threshold, we will obtain bids or create a memo if bids are not an option. We took the memo to our October 9,2024 board. This was completed fully as of July 1, 2024. Dexter Suggs, Ph.D. Superintendent of Schools "Once a Pirate, Always a Pirate"

The organization will revise and reinforce its procurement policies to ensure compliance with 2 CFR 200.318–200.320. Staff involved in procurement will receive training in federal procurement standards, including competitive bidding and documentation requirements. Internal controls will be strengthened to ensure consistent application of procedures and oversight. Anticipated Completion Date: 5/31/2026. Responsible Contact Person: Anthony Daniels-Halisi, CEO.

The organization will revise and reinforce its procurement policies to ensure compliance with 2 CFR 200.318–200.320. Staff involved in procurement will receive training in federal procurement standards, including competitive bidding and documentation requirements. Internal controls will be strengthened to ensure consistent application of procedures and oversight. Anticipated Completion Date: January 31, 2026. Responsible Contact Person: Alfred D. Ivy, Director of Business Affairs & Operations.

FINDING 2025-002 Finding Subject: Child Nutrition Cluster – Procurement and Suspension and Debarment Contact Person(s) Responsible for Corrective Action: Mendy Shrout & Billy Boyette Contact Phone Number and Email Address(es): (765) 795-4664 / mshrout@cloverdale.k12.in.us & bboyette@cloverdale.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Procurement We will be updating the Policy 6325 for Micro purchases from $10,000.00 to $50,000.00. We are in policy review now. Suspension and Debarment All new vendors entered into the system are checked by the Corporation Treasurer through the Office of Inspector General search, printed and kept on file in the Corporation office. Further, all vendors used by the Food Service department have been updated to be current. Anticipated Completion Date: March 1, 2026

FINDING 2025-002 Finding Subject: Teacher and School Leader Incentive Grants – Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Chris Gearlds, Assistant Superintendent Contact Phone Number and Email Address: (317) 856-5265; cgearlds@decaturproud.org Views of Responsible Official: We concur with Audit Finding Description of Corrective Action Plan: The Teacher and School Leader Incentive Grant was completed during the audit period and the school district does not plan on receiving this award in the future. Therefore, further corrective action is not required and district officials will utilize this information to ensure compliance in other federal awards. Anticipated Completion Date: February 1, 2026

Condition: The Village did not have written policies for cash management or procurement that adhered to the requirements of the Code of Federal Regulations. Planned Corrective Action: The Village is currently reviewing existing policies to determine the best course of action and updating them for compliance. Some updates may require voter approval as certain provisions are in the Village Charter. Contact person responsible for corrective action: Penny Ray Anticipated Completion Date: 12/31/2026

Criteria or Specific Requirement: Nonfederal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. Views from Responsible Officials: Management agrees with the finding. Management has established written policies and procedures for procurement. Management confirmed policies and procedures were followed and monitored during the construction of the project. Written policies and procedures were completed after year-end. Contact Person: John Jacques Date of Completion: November 14, 2025

Special Education Cluster (IDEA) – Assistance Listing No. 84.027/84.173/ Recommendation: We recommend the district add internal controls over monitoring vendor purchases throughout the fiscal year and comparing them to procurement policies to ensure proper procedures are followed in accordance with 2 CFR 200.319. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The District will continue to review its internal controls and modify policies and procedures, as necessary. Additional training will be attended by staff to rectify this matters for future years. Name(s) of the contact person(s) responsible for corrective action: Julie A. Stone, Director of Business Services Planned completion date for corrective action plan: The District plans to have the finding corrected by the reporting period ending June 30, 2026.

FINDING 2025-001 Finding Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Summary of Finding: Procurement: For two vendors, the School Corporation did not obtain price or rate quotes as required. The School Corporation did not maintain documentation to support the rationale and justification to limit competition, and there was no documentation of the history of the Procurement which would include the rationale for the method of procurement, the selection of the vendor, and the basis for price. Suspension and Debarment: Two vendors were identified for which the School Corporation was required to verify the suspension and debarment status, however no such verification could be provided for audit. Contact Person Responsible for Corrective Action: Food Service Director, Joshua Deck Contact Phone Number and Email Address: (812) 649-2591 / josh.deck@sspencer.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Procurement: The Food Service Director will maintain a binder/Google Drive folder with documentation of price and/or rate quotes and documentation of the attempts made from at least three vendors that fall within the small purchase threshold. If price and/or rate quotes cannot be obtained from at least three vendors, documentation of the reasoning will be maintained. Suspension and Debarment: The Food Service Director will ensure that all vendors are not suspended or debarred by either ensuring the suspension and debarment verbiage is included in the contracts, providing a clause to the vendor to sign that they are not suspended or debarred, or checking the SAM.gov website. Documentation of these records will be maintained for audit. Anticipated Completion Date: Effective FY 2025/2026

FINDING 2025-001 Finding Subject: Special Education Cluster (IDEA) - Procurement Contact Person Responsible for Corrective Action: Samantha Berrier Contact Phone Number and Email Address: 219-962-2909, sberrier@rfcsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The offices of the Northwest Indiana Special Education Cooperative (NISEC), on behalf of River Forest Community School Corporation, its member school, has implemented a corrective action plan to ensure that the proper methodology for procurement is followed. Additionally, a system of internal controls has been established to ensure that vendors are procured using the required methods. The Northwest Indiana Special Education Cooperative created a corrective action plan to develop procedures to obtain bids when any vendor will exceed the simplified acquisition threshold. As part of this corrective action plan they have included procedures to follow if a noncompetitive procurement would be applicable. These procedures include documenting the rationale for using this alternative method and requesting approval from the Board of School Trustees when doing so. Anticipated Completion Date: October 9th, 2024

Condition: The University supported full and open competition when testing Research and Development procurement contracts but did not support rationale for utilizing the selected contractor for 12 of the 23 samples tested. The University supported full and open competition when testing Coronavirus State and Local Fiscal Recovery Funds procurement contracts but did not support rationale for utilizing the selected contractor for 5 of the 5 samples tested. Planned Corrective Action: Management will reinforce its existing procurement procedures to ensure that competitive selections are not only conducted appropriately but also consistently documented. Management will implement a standardized documentation protocol that captures the rationale, evaluation criteria, and selection process for each procurement decision. The Procurement Policy will be revised, training will be provided to relevant staff, and periodic reviews will be conducted to ensure compliance. Contact person responsible for corrective action: Luba Kagan Anticipated Completion Date: June 30, 2026

FINDING 2025-002 Finding Subject: Child Nutrition Cluster-Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Missy Schultheis Contact Phone Number and Email Address: 812-354-8478 mschultheis@pcsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The School Corporation will review and update the existing procurement policy to ensure it clearly outlines the procedures for different purchasing methods including the specific thresholds. We will establish a procedure requiring the retention of all documentation supporting procurement decisions. We will develop a process to verify that vendors/contractors are not suspended or debarred by any federal or state agency prior to entering into a "covered transaction" or contract. Anticipated Completion Date: This be implemented in the 2025-2026 school year and will continue for future years.

The District Cafeteria Manager, Melanie Pardini, corrected this procedure for fiscal year 2025-26 and has the process in place going forward for each fiscal year.

We agree with auditor's comments, and the following actions have or will be taken to ensure the procurement of goods and services for the nutrition services department follows all applicable steps according to Title 2, Code of Federal Regulations (2 CFR) sections 200.317 -200.327; Title 7, Code of Federal Regulations (7 CFR), parts 210 and 220; and all applicable state and local rules: 1. During the school year 2024/2025, changes were made to staff to allow for additional oversight. A Procurement Specialist reporting directly to the Director of Purchasing was added to staff in lieu of a Buyer that had previously reported to the Director of Nutrition Services. This move allowed for an additional step to ensure proper procurement is happening. 2. All purchasing methods, including Micropurchase, Simplified Acquisition, and Formal, will be followed in accordance with all applicable regulations, in line with RUSD's written procurement procedures. 3. Any noncompetitive procurement will only occur if the conditions outlined in applicable regulations are met and sufficient evidence and documentation is received and retained, including participating in performing due diligence to ascertain whether a single source document is accurate from any given vendor. 4. In addition documented annual training will take place for all staff involved in the procurement process. This procedure includes a review and annual update of procurement procedures, if applicable, and an acknowledgement of the nutrition services code of conduct in regards to purchasing. Please reach out to us with any questions.

Finding 2025-001: Procurement Finding: The College's procurement policy does not reflect all applicable state and local laws and federal regulations. For two out of three (67%) small purchase procurements, there was not sufficient evidence to support that documentation of the noncompetitive procurement method selected was provided at the time of purchase. Cause: The College does not have a procurement policy that follows the procurement standards set out at 2 CFR sections 200.318 through 200.327. Corrective Actions Taken or Planned: The Business Office will review all applicable state and local laws and federal regulations and enhance the College’s procurement policy. As part of the review and enhancement, the policy on the website will be updated, and additional training will be held with PI’s currently with grants and those receiving grants in the future. A more robust procurement process will be implemented which will involve multiple departments. By October 31, 2025, the Business Office will communicate with all current PI’s an interim policy including the need for competitive bids, vendor screening, and more detailed descriptions. Contact Person Responsible: Doug MacKay, Controller Lake Forest College Completion Date: January 31, 2026

FINDING: 2025-005 Name of contact person: Lynn Gierke, Township Supervisor, 906-523-4000 Description of Finding: In accordance with 2 CFR Section 200.319(d), non-federal entities must have their own written policies for procurement transactions. The policy should incorporate all requirements within 2 CFR section 200.318 through 200.326 of the Uniform Guidance. Corrective Action Plan: We will create a procurement policy that meets all the requirements of 2 CFR section 200.318 through 200. Proposed Completion Date: March 31, 2026

Finding #SA2024-003: Procurement Documentation Assistance Listing Number: 21.027 Assistance Listing Title: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of the Treasury Pass Through Entity: County of San Mateo Federal Award Identification Number: SFLRP0201 • Name(s) of the contact person: Kenneth Stiles, Finance Manager • Corrective Action Plan: The City will strengthen procurement documentation to comply with 2 C.F.R. §§ 200.317–200.327. Specifically, the City will: 1. Implement a standardized procurement checklist for all federally funded contracts. 2. Document the procurement method and basis for selection. 3. Perform and retain cost/price analysis where required. 4. Maintain solicitation and evaluation documentation in contract files. 5. Provide staff training on federal procurement requirements. • Anticipated Completion Date: July 2026

The Village will establish formal UG policies and procedures.

Management acknowledges that procurement documentation was not consistently maintained during the audit period. Since that time, improvements have been made; however, additional work is ongoing to fully standardize documentation practices across the Organization. Staffing stability since September 2024 has improved consistency and accountability. A Vice President of Programs has been hired to strengthen compliance oversight, and a Compliance & Risk Management Committee will be established in FY2026 to support organization-wide monitoring. The Organization is also implementing targeted training on 2 CFR Part 200 for fiscal, program, and contracts staff to reinforce procurement requirements. In addition, enhancements to procurement procedures and documentation standards are underway. The implementation of Blackbaud Financial Edge in FY2027 will further strengthen internal controls through improved workflows, tracking, and documentation retention. Management is committed to achieving full compliance with Uniform Guidance procurement requirements. Actions Taken - Reinforced procurement documentation expectations with program and administrative staff - Increased supervisory review of procurement transactions - Hired a Vice President of Programs to strengthen compliance oversight - Established plans to launch a Compliance & Risk Management Committee in FY2026 - Initiated cross-functional training on 2 CFR Part 200 for fiscal, program, and contracts staff - Began enhancing procurement policies, procedures, and documentation standards - Initiated implementation of Blackbaud Financial Edge to support procurement tracking and internal controls.

The City will develop written policies and procedures which include the relevant provisions required by 2 CFR § 200.318 through 2 CFR § 200.327 Contract provisions.

2024-003 Material weakness in internal control over compliance Federal Agency: U.S. Department of the Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Compliance requirement: Procurement, suspension and debarment Recommendation: We recommend management enhance procedures and controls to ensure documentation is maintained to support all suspension and debarment verifications related to expenditures from federal award programs. Such documentation should be consolidated and maintained in a secure, accessible location. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: In 2026 the Borough responded with an SOP to outline the procedures implemented in response to the material weakness finding for internal controls. The SOP outlines, the process for verifying suspension and debarment verification through SAM.gov or another third party resource before federal award payments are made. All vendors are required to be verified prior to payment and annually, with record keeping maintained in a secure location by the finance team. Name(s) of the contact person(s) responsible for corrective action: Layla Richard-Rau, Director of Finance Planned completion date for corrective action plan: Implementation to take place on or before April 27, 2026.

Information on the federal program: Federal Agency: Department of the Treasury Pass-Through Entity: N/A – Direct Grant Federal Program: Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) Assistance Listing Number: 21.027 Compliance Requirement: Procurement – Suspension and Debarment Audit Findings: Material Weakness, Noncompliance Condition: The City did not have internal controls in place to ensure compliance with the procurement and suspension and debarment requirements. The City had not designed or implemented adequate policies or procedures to ensure that proper procurement procedures for small purchase and simplified acquisition procurement thresholds were followed. Context: For one out of three samples selected for the small purchase procurement threshold, three quotes and rationale for selecting the vendor were not documented. Small purchase procurements require three competing quotes and rationale for selection of the vendor. The procurement was for park improvement design services. The City was unaware that professional services are required to follow the federal procurement process. Per grant requirements, all grant funded expenditures require appropriate procurement, regardless of whether it is a good or service. For two out of three samples selected for suspension and debarment testing, the City did not have support that vendors procured under CSLFRF funding were not suspended or debarred. Views of Responsible Officials and Planned Corrective Actions: The City had already been checking and documenting the check for suspension and disbarment of all vendors – however, the check was being performed at the time of vendor onboarding, which may have been in a previous period. Management agrees with the finding and has already started taking the steps to implement a procedure for checking procurement and suspension and debarment for each contract that expends American Rescue Plan Act Coronavirus State and Local Fiscal Recovery Funds or any other Federal funds at the time of award. Responsible party and timeline for completion: The Controller is responsible for overseeing the implementation of the corrective action plan and will ensure the appropriate personnel are involved in the procurement and suspension and debarment process. The corrective action plan is in effect immediately. Further, the Controller will conduct an internal audit on or around June 30, 2026, to ensure that the new procedures have been implemented correctly.

Finding 2024-016 Material Weakness in Internal Control and Material Noncompliance – Procurement and Suspension and Debarment Condition: The DPS Grant Administration did not adhere to the Danbury Public Schools “Bids and Purchases Competitive” procurement policies, that were compliant with Federal Part 3 compliance guidelines. DPS had a procurement policy in place that was consistent with the standards of the aforementioned compliance sections; however, DPS did not follow their own procurement policy in certain instances which consists of obtaining three quotes for a small purchase procurements and advertising for bids publicly for large >$5,000 purchase procurements. They only obtained one quote for small purchases, and they did not use a public bid process for expenditures over $5,000. Additionally, DPS did not have internal controls in place to ensure vendor eligibility was verified prior to entering into a covered transaction with them. Contact Person: Michael Weaver, CFO, Danbury Public Schools Corrective Actions Planned: We agree with the finding. The policy was revised at the end of the 2025 Fiscal Year. Additionally, a new and additional review process was put into place prior toentering a requisition for approval. This process requires all necessary documentation be furnished to the finance office prior to the requisition being approved. Completion Date: 7/16/2025