Corrective Action Plans

FINDING 2024-004 Finding Subject: Special Education Cluster (IDEA) - Procurement Contact Person Responsible for Corrective Action: Robert Glover Jr. Contact Phone Number: (219) 945-0250 Contact Email Address: rglover@hobart.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: As a member of the Northwest Indiana Special Education Cooperative (NISEC), School City of Hobart usually expends contracted services out of our general education fund. For the fiscal year 2023-2024, we included our contracted speech services into our federal grant funds. During the audit, Hobart was notified that we didn’t follow the procurement procedures when expending out of the federal grant. This finding was due to Hobart not going out and receiving multiple bids for contracted companies that provide services to our students. Hobart 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 explained why we use the three contracted vendors instead of going out for bids. Finding Speech Pathologists and Speech Language Assistants is very difficult in the school setting, and they have created great working relationships with these three contracted companies. Within the memo, we listed all the contracted vendors that they use and why they work directly with them instead of going out for bids. If any contracted services are not bid, at the beginning of each school year, they will create a new memo with any contracted companies that they will be using during that school year and the memo will be approved by the School Board. Anticipated Completion Date: 4/30/2025

Condition: Four vendors were awarded a contract without a competitive procurement process. Corrective Action Planned: We acknowledge the finding and will ensure to attempt to secure three quotes for such services going forward. It is extremely difficult, however, as operating on Nantucket presents unique challenges. We will ensure going forward to obtain quotes for every professional services contract we apply to federal grants and will follow the federal office guidelines closely going forward. Anticipated Completion Date: July 1, 2025 Contact: Martin Anguelov, Chief Financial Officer for Nantucket Public Schools and Deb Gately, Director of Special Education for Nantucket Public Schools

Condition: One vendor was awarded a contract without a competitive procurement process. Corrective Action Planned: Accounting will review the Federal procurement requirements and put together a Federal procurement guide that will assist in making sure this does not continue to happen. Anticipated Completion Date: By March 28, 2025 Contact: Caroline Burke, Town Accountant

FINDING 2024-003 Finding Subject: Childhood Nutrition Cluster – Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Ralph Shrader, Superintendent Contact Phone Number and Email Address: (765) 762-3364 / rshrader@msdwarco.k12.in.us Views of Responsible Officials: Option 1: We concur with the finding Description of Corrective Action Plan: We will obtain quotes for any purchases that qualify under the small purchases requirement Any director responsible for corporation contracts, will be responsible for checking Sam.gov to ensure the vendor is not on the suspension and disbarment list. A secondary individual will verify the findings. In addition, the micropurchase threshold will be raised to $50,000. Anticipated Completion Date: Effective Immediately

FINDING 2024-005 Finding Subject: Child Nutrition Cluster-Procurement and Suspension and Debarment Summary of Finding: The school corporation made purchases from vendors without using the procurement method and verifying that the vendor was not suspended or debarred. The School corporation did not properly implement a process to identify and assess internal and external risks, or monitor internal control activities to ensure they were operating effectively. Contact Person Responsible for Corrective Action: Melissa Embry Contact Phone Number and Email Address: 812-547-2637 melissa.embry@cannelton.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We will follow all correct procurement plans set forth in the future. We will also verify with each vendor and have a form filled out stating that they are not suspended or debarred. Cannelton management will establish a proper system of internal controls including policies and procedures related to risk assessment and monitoring activities within the federal program. Anticipated Completion Date: The School will ensure proper procurement methods are followed and that vendors are properly checked for suspension and debarment by December 2025. The additional controls will be implemented by August 2025.

Views of Responsible Officials:  The Organization will update its procurement policy to be in conformance with Federal cost principles for approval at the next Board Meeting on February 24, 2025.  Supporting operating procedures will be reviewed and adjusted accordingly to ensure compliance with the policy by February 28, 2025.  The situation resulting in this finding was for the procurement of support services for a new electronic health records system which was successfully implemented using the services purchased at a reasonable cost; however, the procedures followed by previous staff did not fully comply with the Organization's policies and procedures nor the Federal cost principles. The Organization has since implemented additional procedures to ensure documentation for competitive bids and justification for all purchases to comply with Federal requirements enhancing the Organization's internal procedures. The Organization will do a full review of the Federal cost principles and suggested procedures to ensure full compliance and implement new policies and additional procedures, as necessary, by February 28. 2025.

FINDING 2024-003 Finding Subject: Summary of Finding: Subject: Special Education Cluster (IDEA) - Procurement and Suspension and Debarment Federal Agency: Department of Education Federal Programs: Special Education Grants to States; COVID-19 - Special Education Grants to States; Special Education Preschool Grants; COVID-19 - Special Education Preschool Grants Assistance Listings Numbers: 84.027; 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 22611-042-ARP; 22619-042-ARP Pass-Through Entity: Indiana Department of Education Compliance Requirement(s): Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Dawn Mason, Business Manager, DeKalb Co. Eastern CSD Contact Phone Number and Email Address: 260-868-2125 Views of Responsible Officials: We concur with the findings. Description of Corrective Action Plan: The expenditures referenced in the finding were expended from the American Rescue Plan Special Education grant funds which were fully expended during the audit period. All future expenditures triggering procurement and suspension and debarment requirements will include implementing the following procurement policies. Reference Procurement Standards 2 CFR 200.318 Districts may not enter into contracts with entities that have been suspended or debarred from participating in contracts with federal funds. For contracts over $25,000, districts must verify a contractor is not excluded or disqualified. Contractors must be verified in one of three ways: 1. Checking the System for Award Management (SAM) (www.SAM.gov) 2. Collecting a certificate from that contractor. 3. Adding a clause or condition to the covered transaction with that contractor. (Recommended) **Proper verification and documentation must be sent to the LEA for audit purposes. INDIANA STATE BOARD OF ACCOUNTS 32 3326 CR 427, Waterloo, IN 46793 p 260-920-1011 f 260-837-7767 Steven E. Teders, Ed.S., Superintendent Loraine K. Vaughn, Ed.S., Assistant Superintendent Mark W. Rohm, Chief Financial and Operations Officer Personalized Pathways for Success Methods of Procurement Where specific EDGAR/UG thresholds apply, Districts must meet baseline requirements for procurement. If State or local rules have more restrictive thresholds, the most restrictive rule must be followed. Informal Procurement Procedures 1. Micro-purchase (0-$50,000) Dekalb County Eastern CSD has self-certified micro-purchases for up to $50,000 Micro-purchases may be awarded without soliciting competitive quotes if the district considers the price to be reasonable. Quotes must be attached to the invoice/checks for proper documentation and retained by the LEA. 2. Small Purchase ($50,000 – $150,000) Three quotes are required prior to purchase unless the purchase comes from a “Sole Source” vendor. Small purchases are required to be ordered under a purchase order unless in an emergency. Additional quotes must be presented along with the purchase order prior to being approved by the LEA. Formal Procurement Procedures 1. Sealed Bids (above $150,000) Bids must be solicited from an adequate number of suppliers, providing them with sufficient response time prior to the opening of the bids. Proper advertisement and procedures must be followed per IC 5-22 and corresponding documentation must be presented to the LEA prior to any final approval or purchases being made. 2. Competitive Proposals (above $150,000) The Request for Proposal method is used for procurements in which factors other than cost play a significant role. Per IC 5-22-9, when a purchasing agent makes a written determination that the use of competitive sealed bidding is either not practicable or not advantageous to the governmental body, the purchasing agent may award a contract using this procedure instead of competitive sealed bidding. This provides a formal process for the procurement of goods and/or services for which price is not the sole factor in the selection of a vendor or vendors. Proper advertisement and procedures must be followed per IC 5-22 and corresponding documentation must be presented to the LEA prior to any final approval or purchases being made. Noncompetitive (Sole Source) All sole source procurements require adequate written justification and must be attached to the corresponding purchase order or payment. Anticipated Completion Date: All expenditures initiated after March 12, 2025

FINDING 2024-004 Finding Subject: Special Education Cluster (IDEA) - Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Dawn Mason, Business Manager, DeKalb Co. Eastern CSD Contact Phone Number and Email Address: 260-868-2125 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The expenditures referenced in the finding were expended from the American Rescue Plan Special Education grant funds which were fully expended during the audit period. All future expenditures triggering procurement and suspension and debarment requirements will include implementing the following procurement policies. Reference Procurement Standards 2 CFR 200.318 Districts may not enter into contracts with entities that have been suspended or debarred from participating in contracts with federal funds. For contracts over $25,000, districts must verify a contractor is not excluded or disqualified. Contractors must be verified in one of three ways: 1. Checking the System for Award Management (SAM) (www.SAM.gov) 2. Collecting a certificate from that contractor. 3. Adding a clause or condition to the covered transaction with that contractor. (Recommended) **Proper verification and documentation must be sent to the LEA for audit purposes. Methods of Procurement Where specific EDGAR/UG thresholds apply, Districts must meet baseline requirements for procurement. If State or local rules have more restrictive thresholds, the most restrictive rule must be followed. Informal Procurement Procedures 1. Micro-purchase (0-$50,000) Dekalb County Eastern CSD has self-certified micro-purchases for up to $50,000 Micro-purchases may be awarded without soliciting competitive quotes if the district considers the price to be reasonable. Quotes must be attached to the invoice/checks for proper documentation and retained by the LEA. 2. Small Purchase ($50,000 – $150,000) Three quotes are required prior to purchase unless the purchase comes from a “Sole Source” vendor. Small purchases are required to be ordered under a purchase order unless in an emergency. Additional quotes must be presented along with the purchase order prior to being approved by the LEA. Formal Procurement Procedures 1. Sealed Bids (above $150,000) Bids must be solicited from an adequate number of suppliers, providing them with sufficient response time prior to the opening of the bids. Proper advertisement and procedures must be followed per IC 5-22 and corresponding documentation must be presented to the LEA prior to any final approval or purchases being made. 2. Competitive Proposals (above $150,000) The Request for Proposal method is used for procurements in which factors other than cost play a significant role. Per IC 5-22-9, when a purchasing agent makes a written determination that the use of competitive sealed bidding is either not practicable or not advantageous to the governmental body, the purchasing agent may award a contract using this procedure instead of competitive sealed bidding. This provides a formal process for the procurement of goods and/or services for which price is not the sole factor in the selection of a vendor or vendors. Proper advertisement and procedures must be followed per IC 5-22 and corresponding documentation must be presented to the LEA prior to any final approval or purchases being made. Noncompetitive (Sole Source) All sole source procurements require adequate written justification and must be attached to the corresponding purchase order or payment. Anticipated Completion Date: All expenditures initiated after March 12, 2025

Context: The School Corporation is a member of the Northeast Indiana Special Education Cooperative (Cooperative). During fiscal years 2022-2023 and 2023-2024, the Cooperative operated the special education program and spent the federal money on behalf of all its members. As the grant agreement was between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. Description of Corrective Action Plan: School Corporation will reach out to the Cooperative to discuss internal controls over procurement, and suspension and debarment and request annual listing of vendors exceeding federal and state procurement thresholds to ensure Cooperative adheres to regulations and established procurement policy and request that procurement policies are written, and all procurements are fully documented based upon the applicable federal and state standards Anticipated Completion Date: The School Corporation will implement the actions noted above quarterly to ensure proper internal controls are in place. The treasurer will request this information starting in April of 2025 for the first quarter of the calendar year.

Finding 2024-002 Finding Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Beverly Hindes Contact Phone Number: 219-996-4771 x128 Views of Responsible Officials: We agree with the finding. Description of Corrective Action Plan: The Treasurer will ensure compliance with the Procurement and Suspension and Debarment requirement. Anticipated Completion Date: March 3, 2025

Condition: One vendor was awarded a contract without a competitive procurement process. Corrective Action Planned: The Town will communicate to all relevant departments that State procurement exemptions do to not apply to Federal procurements. We believe this was an isolated incident based on a misinterpretation of the Federal requirements; however, we will endeavor to provide an additional level of scrutiny to the vetting of these contracts. Anticipated Completion Date: June 30, 2025 Contact: J. Michael Buckley, Town Accountant

FINDING 2024-002 Finding Subject: Child Nutrition Cluster - Procurement Contact Person Responsible for Corrective Action: Kyle Zahn & Jack Lazar Contact Phone Number and Email Address: (765) 883-5576 kzahn@western.k12.in.us jlazar@western.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: At a coming leadership meeting the Finance Director will review procurement rules and procedures with the leadership team. Additionally, the Director of Finance and Food Service Director will conduct an audit of the vendors used for the Child Nutrition Cluster and revise as necessary current systems for identifying vendors who exceed $50,000 during a school year. Anticipated Completion Date: March 31, 2025

Views of Responsible Officials: We have already taken several steps to address this issue and to ensure that similar situations do not occur in the future: 1. Policy Review and Reinforcement: We have conducted a detailed review of the procurement policy to ensure that all relevant employees know its requirements and the importance of compliance. We are also revising our internal communication to ensure everyone involved in procurement knows the steps and documentation required. 2. Training and Awareness: To prevent future non-compliance, we are scheduling mandatory training sessions for all personnel involved in procurement activities. This will help ensure that all team members fully understand the policy and know how to apply it correctly.

FINDING 2024‐005 Finding Subject: Special education Cluster (IDEA) ‐ Procurement and Suspension and Debarment Summary of Finding: When the value of the procurement for property or services are within the small purchase threshold, or a lower threshold established by a nonfederal entity, quotes and a contract are required. The small purchase threshold is between $10,000 and $150,000 however the threshold between $10,000 and $50,000 require quotes from an adequate number of qualified sources. Indiana Code 5‐22‐8 has more restrictive requirements for the small purchase threshold between $50,000 and $150,000, which require three quotes and a contract to be awarded. The Cooperative had five vendors which fell within the small purchase threshold and all five vendors were tested. The Cooperative did not obtain quotes or competitive proposals, nor was a circumstance met that would have allowed for a noncompetitive procurement for the purchases. Three vendors paid from the grant funds were identified as being covered transactions during the audit period. All three vendors, provided goods or services which equaled or exceeded $25,000 and were selected for testing. For all three vendors, the Cooperative did not verify the vendors’ suspension and debarment status prior to payment. Contact Person Responsible for Corrective Action: Tim Scott Contact Phone Number and Email Address: 574‐654‐7273 tscott@npusc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Due to several changes in personnel in the Special Education office, obtaining quotes and checking SAMS.gov was an oversight. The Special Ed Administrative Assistant and/or the Special Ed Director is now making sure these things are complete before a purchase order is entered or services are rendered. A copy of SAMS.gov and the quote are attached to the purchase order. Anticipated Completion Date: October 2024

FINDING 2024-003 Finding Subject: Child Nutrition Cluster – Procurement and Suspension and Debarment Summary of Finding: Documented evidence of the implementation of the control process was not maintained. Due to the lack of controls, it could not be determined that the school corporation ensured compliance with the grant agreement. Proper safeguards were not in place to ensure that documentation was properly maintained, causing the CFO and Food Service Director to be unable to locate the documentation for each procurement method. Contact Person Responsible for Corrective Action: Allison Pund and Margaret Leavitt Contact Phone Number and Email Address: 812-683-3971 x5002; punda1@swdubois.k12.in.us; leavittm@swdubois.k12.in.us Views of Responsible Officials: We concur with the finding. Explanation and Reasons for Disagreement: NA Description of Corrective Action Plan: The School Corporation will establish a proper system of internal control and develop policies and procedures to ensure all requirements are followed. Creation of these policies and procedures will be created by the CFO and Food Service Director. Internal controls will be put in place to ensure these policies and procedures are followed. In addition, the Food Service Director will maintain all bids, contracts, and other documentation to support the procurement methods used and will verify suspension and debarment prior to entering into covered transactions of $25,000 or more. Anticipated Completion Date: August 2025

FINDING 2024‐002 Subject: Special Education Cluster (IDEA) – Procurement Summary of Finding: During the 2023-2024 fiscal year, federal grant funds were to pay for contracted speech services. The vendors used exceeded the Simplified Acquisition Threshold and sealed bids or competitive proposals were not obtained. Contact Person Responsible for Corrective Action: Adam C. Minth Contact Phone Number: 219-374-3504 Views of Responsible Official: The school corporation concurs with the finding and will be implementing corrective procedures by the end of this fiscal year. Description of Corrective Action Plan: As a member of the Northwest Indiana Special Education Cooperative (NISEC), Hanover Community School Corporation usually expends contracted services out of our general education fund. For the fiscal year 2023-2024, we included our contracted speech services into our federal grant funds. During the audit, Hanover was notified that we didn’t follow the procurement procedures when expending out of the federal grant. This finding was due to Hanover not going out and receiving multiple bids for contracted companies that provide services to our students. Hanover 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 explained why we use the three contracted vendors instead of going out for bids. Finding Speech Pathologists and Speech Language Assistants is very difficult in the school setting, and they have created great working relationships with these three contracted companies. Within the memo, we listed all the contracted vendors that they use and why they work directly with them instead of going out for bids. At the beginning of each school year, they will create a new memo with any contracted companies that they will be using during that school year. Anticipated Completion Date: 4/30/2025

FINDING 2024-004 Finding Subject: Special Education Cluster (IDEA) – Procurement and Suspension and Debarment Summary of Finding: Procurement- Small Purchase In fiscal year 2023, the Cooperative had five vendors which fell within the small purchase threshold (between $10,000 and $150,000). The Cooperative did not obtain quotes or competitive proposals, nor was a circumstance met that would have allowed for a noncompetitive procurement for the purchases. The total amount spent in was $292,806. Suspension and Debarment Verification to verify that contractors and subrecipients are not suspended, debarred, or otherwise under a nonprocurement transaction through SAM was not being completed. Three vendors each fiscal year provided goods or services which equaled or exceeded $25,000 were selected for testing. The total amount spent on covered transactions was $266,063 and $142,639 for fiscal years 2023 and 2024. For all six vendors, the Cooperative did not verify the vendors’ suspension and debarment status prior to payment. Contact Person Responsible for Corrective Action: Greg Hunt Contact Phone Number: (219) 362-7056 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Our Special Education Administrative Assistant has already begun checking on SAM for any federal purchases to verify suspension and debarment. She has also been provided with the LaPorte Community School Corporation’s Procurement Policy number po6325 and will adhere to those guidelines for any future purchases. Anticipated Completion Date: January 2025

Context: The School Corporation is a member of the Northeast Indiana Special Education Cooperative (Cooperative). During fiscal years 2022-2023 and 2023-2024, the Cooperative operated the special education program and spent the federal money on behalf of all its members. As the grant agreement was between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. Contact Person Responsible for Corrective Action: Brittany Treesh Contact Phone Number: 260-357-3185 Views of Responsible Official: The school corporation concurs with the finding. Description of Corrective Action Plan: Garrett-Keyser-Butler’s Business Manager will work closely with the Special Education Cooperative Treasurer and DeKalb Eastern Business Manager during the grant process and make sure all required documents are collected. Anticipated Completion Date: The Business Manager will implement this procedure March 2025.

Finding 2024-002 Condition: A vendor was awarded a contract without an appropriate procurement process. Corrective Action Planned: : Comply with federal procurement regulations and seek quotes from three vendors in anticipation spending of over $10,000. Anticipated Completion Date: Currently in place Contact: Marie Znamierowski

Finding 2024-001 Condition: Two vendors were awarded a contract without an appropriate procurement process. Corrective Action Planned: Comply with federal procurement regulations by setting up a quote system and seek quotes for anticipated spending of over $10,000. Anticipated Completion Date: May 1, 2025 Contact: Marie Znamierowski

FINDING 2024-002 Finding Subject: Child Nutrition - Procurement, Suspension, and Debarment Summary of Finding: There were no controls in place to ensure that the School Corporation complied with the small purchase requirements. The School Corporation obtained quotes for the two vendors that qualified for the small purchase threshold, but no oversight performed. There were no controls in place to ensure that the vendors included a suspension and debarment clause or check the Sam.gov website. Contact Person Responsible for Corrective Action: Micah Williams Contact Phone Number and Email Address: 765-832-2426/mwilliams@svcs.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The finance department will work in conjunction with the Food Services Director to ensure that quotes are obtained from vendors that are listed on Sam.gov or have a suspension and debarment clause before making in purchases. There will be an email thread detailing the request, the quotes, and the process for ensuring suspension and debarment. Anticipated Completion Date: Immediate.

Finding: While testing the procurement requirement, we noted that internal controls were not properly designed over the procurement requirement. Prior to receiving federal funding beginning in August 2022, the program conducted a request for proposal (RFP) process and began contracting with a vendor. When federal funding was obtained, the vendor was not reevaluated in accordance with the Uniform Guidance to ensure the procurement requirements were being met. In addition, we noted UW Health – Madison’s procurement policy documents do not include all of the information that is required by the Uniform Guidance. Correction actions taken or planned: Management became aware of the need to perform additional procedures to comply with Uniform Guidance part way through the year ended June 30, 2024 and completed the evaluation once it became known. However, by that time, the vendor was already charged to the grant prior to the completion of the vendor evaluation. UW Health has developed processes and procedures to ensure compliance with the Uniform Guidance and that evaluations are taking place prior to any vendors being charged to the grant. UW Health is also in the process of updating policy to comply with Uniform Guidance. Anticipated completion Date: June 2025 UW Health employees responsible for Corrective Action Plan: James Hood, Director of Procurement Services and Jamie Soyk, Program Director – Financial Reporting

2024-001 (Procurement and Suspension & Debarment) Management Comments and Corrective Action: Due to the growing need to adequately care for the minors at SWK’s shelters coupled with the limitations of access to vendors caused by COVID-19, SWK utilized existing vendor to minimize significant disruptions to operations. The Organization is aware they are operating under contracts that were procured in previous years that may not have all the records maintained. Reprocuring all of these contracts at once would potentially cause disruptions in operations due to the products/services related to those vendors playing an important role in the Organization’s dayto- day operations. In April 2021, the Organization hired new procurement leadership and invested in Full Time Employees (FTEs) to develop a robust procurement department. Due to this procurement revamp, Procurement adopted a hybrid model, and Desktop Protocols were established to provide universal procedures to fulfill policy. Protocols instruct staff on obtaining three quotes and provide tools for selecting the vendor. In addition, quality protocols and tools are currently in development to verify a random sample of procurement transactions and files. The Organization still has several active contracts procured under the old policies that they are working on reprocuring as these contracts’ renewal dates arise, if not earlier. Proposed Implementation Date of Corrective Action: In process and to be completed by December 31, 2025. Person Responsible for Corrective Action: Steven Beckman, CFO 45

The district will establish a system of internal controls with the Cooperative (NISEC) to ensure formal procurement methods are properly followed.

Type of Finding : Significant Deficiency Over Compliance with Procurement and Suspension Debarment Delta County Joint School District No. 50J had the following regarding internal controls in Nutritional Services: The District did not properly procure one vendor within the Child Nutritional Cluster that incurred questioned costs in excess of the $25,000 threshold, based on 2 CFR 200.516. Delta County Joint School District No. 50J concurs with finding 2024-001 and will implement the following corrective steps: Additional procedures have been put in place, and documentation will be maintained for purchases to satisfy Procurement and Debarment requirements.