Corrective Action Plans

FINDING 2025-002 Finding Subject: Child Nutrition Cluster - Procurement and Suspension Debarment Contact Person Responsible for Corrective Action: Andrea Miller Contact Phone Number and Email Address: 765-564-2100 ext 1002, millera@delphi.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The School Corporation will implement a standardized procurement checklist documenting the method of procurement, vendor selection, quote comparison, and basis for contract price. The checklist will also have language that requires written justification and approval for any single-source procurement, as well as the date for the required check for suspension and debarment. The documentation for the suspension and debarment will be filed with the procurement checklist. Anticipated Completion Date: June 2026

2025-004-Procurcmcnt Suspension and Debarment We have developed an internal form that each employee knows they must fill out when obtaining any kind of service or supply. We have educated staff on the dollar limits and thresholds required as well as any backup documentation needed to be obtained for each purchase of goods or services. Moving forward the finance department will be responsible for running sam.gov checks to make sure all vendors that the district does business with are clear of suspension and debarment at either the start of the fiscal year or whenever procuring new services and goods throughout the year.

Date: February 9, 2026 FINDING 2025-002 Finding Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Paula Powers, Food Service Coordinator Contact Phone Number and Email Address: 812-347-3905 ppowers@nhcs.k12.in.us Views or Responsible Official: We concur with the findings. Description of Corrective Active Plan: The Food Service Coordinator will verify Sam.gov to confirm a contractor is not suspended or disbarred before awarding a contract every 12 months. For small purchases, quotes will be obtained and retained with the claims for that payment. Anticipated Completion Date: March 2026

Information on the federal program: Subject: Child Nutrition Cluster, Procurement and Suspension and Debarment Federal Agency: Department of Agriculture Federal Programs: Child Nutrition Cluster Assistance Listings Numbers: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY2024, FY2025 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Procurement and Suspension and Debarment Audit Finding: Material Weakness, Qualified Opinion Condition: The School Corporation did not have internal controls in place to ensure compliance with the procurement and suspension and debarment requirements. The School Corporation 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: 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. 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. Micropurchases 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. The School Corporation did not review procurements done by the food service management company to ensure that proper procurement policies were followed. The School Corporation did not ensure that the food service management company did not use suspended or debarred vendors. During the audit period, we noted two small purchases for which the School Corporation did not have evidence of obtaining multiple quotes or documented rationale for selecting the vendor. Only the final invoice, purchase order, and quote from the selected vendor were available. During fiscal year 2024, we noted that for one of the three vendors tested, the correct procurement method was not followed. Purchases from the vendor were in excess of $150,000 during the fiscal year, requiring the simplified acquisition procurement process; however, the School Corporation applied the small purchase procurement process. The purchase was for equipment at two different buildings. The School Corporation issued two requests for quotes, one for each school, and treated them as separate procurements. However, as the purchases were similar in nature, the requests for quotes were dated the same day and sent to the same vendor, this should have been treated as one procurement in aggregate. The School Corporation did not have support for public advertisement, requests for formal sealed bids, or formal documentation for the basis of award. 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. During the audit period, we noted two vendors out of three that were sampled, over the $25,000 suspension and debarment threshold for which the School Corporation did not have evidence of a suspension and debarment check. Views of Responsible Officials: Management agrees with the finding and has prepared a corrective action plan. Description of Corrective Action Plan: Management will review procurements done by the food service management company. Management will also ensure that appropriate procurement processes are followed for all future purchases and suspension and debarment checks are completed for purchases over $25,000. Responsible Party and Timeline for Completion: The Treasurer will be responsible for implementing the corrective action plan, which will go into effect immediately.

Procurement policies and procedures were being updated to include clearer direction for documenting purchases, including a strengthened retention policy for procurement documentation. This was implemented at year end but was not present for the transactions during the year.

FINDING 2025-004 Finding Subject: Special Education Cluster (IDEA) – Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Jamesi Lemon Contact Phone Number and Email Address: jlemon@lakelandlakers.net 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) INDIANA STATE BOARD OF ACCOUNTS 36 Lakeland School Corporation 0825 E 075 N, LaGrange IN 46761 Phone: (260) 499 - 2400 Fax: (260) 463 - 4800 ______________________________________________________________________________________________ Educating and preparing ALL students for career & life success! 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: The projected date of completion is March 31, 2026.

Information on the federal program: Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Material Weakness Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the Child Nutrition Program and Procurement compliance requirements. Context: The School Corporation is a member of a purchasing cooperative, who handles the procurement process and establishes competitively awarded contracts for the majority of food service purchases. For one-time purchases such as food service equipment, the School Corporation is responsible for handling the procurement process. For one of the two small purchase method procurements sampled for testing, the school disbursed $67,000 for food service equipment maintenance in fiscal year 2024. The procurement for this item was handled at the school level. We noted the School Corporation did not obtain quotes from an adequate number of qualified sources. The School Corporation also did not properly perform a suspension and debarment check on the vendor. This finding is isolated to fiscal year 2024. There were no purchases in 2025 that required a simplified acquisition or small purchase procurement other than those procured by the food service cooperative. Views of Responsible Officials and Corrective Action Plan: Moving forward, we will implement a standardized procurement checklist to ensure that quotes are obtained from the required number of vendors in accordance with the small purchase method regulations. Child Nutrition Department will also review micropurchase vendors’ cumulative annual spending on a routine basis to determine whether purchases may exceed the micropurchase threshold and require use of the small purchase method. Documentation of all quotes received will be maintained for audit verification. In addition, staff responsible for procurement have received IDOE/USDA refresher training on federal procurement requirements, including thresholds and documentation standards, to ensure full compliance. Suspension and debarment checks will continue to be conducted and documented for all applicable vendors. Responsible Party and Timeline for Completion: Corrective action plan has been implemented as this finding impacted fiscal year 2024 but did not recur in fiscal year 2025. Missy Corns, Food Service Director, and Tracy Albertson, Director of Finance, will oversee the corrective action plan to monitor the procurement and suspension and debarment requirements on an ongoing basis.

Finding 2025-002 - Procurement - Noncompliance with Formal Competitive Requirements Noncompliance & Significant Deficiency Moving to Work Demonstration - ALN #14.881 Corrective Action Plan: SCRHA3 will review operating practices to ensure alignment with Federal Regulations and its procurement policy. This will include assigning a Procurement Officer to oversee the procurement process and verify all procedures are followed for procurements based on the policy, defining staff roles and providing necessary training to personnel involved in procurement. The Housing Authority will develop a process that a procurement requester must complete & submit the procurement to the Procurement Officer for review and approval. Person Responsible: Richard Brockington (Director of Development) Anticipated Completion Date: No later than end of first quarter of 2026 - March 31, 2026.

Material Weakness in Internal Control over Compliance and Compliance 2025-001 Procurement, Suspension, and Debarment. Criteria The District is required to maintain and use documented procurement procedures for procurement transactions under federal awards. Noncompetitive procurement (sole source) may be used if specific circumstances in the Uniform Guidance are met. Statement of Condition The District procured IDEA services through the LIU using a noncompetitive (sole source) approach. The District did not retain documentation in the procurement file to support the basis for noncompetitive procurement. Statement of Cause The District did not consistently follow documented procurement procedures for the IDEA program and the procedures. Possible Asserted Effect Without documentation supporting the noncompetitive procurement method, the District is not able to demonstrate compliance with federal procurement requirements applicable to IDEA. Questioned Costs None noted. Context One vendor was utilized and there was not appropriate documentation maintained of procurement regarding the services. Repeat Finding This is not a repeat finding. Recommendation We recommend that a process be implemented to review the services provided under the IDEA program to ensure procurement documentation is appropriately maintained. Views of responsible officials and planned corrective action To ensure compliance with this standard in the future, the Assistant to the Chief Financial and Operations Officer will provide the Director of Special Education and the Superintendent with the Sole Source Justification form by July 1st of each year. The Director of Special Education and the Superintendent will be responsible for completing the Sole Source Justification form and submitting a copy of the signed document to the Business Office. The Special Education Financial Secretary will attach the Sole Source Justification form to the purchase requisition for services from the Franklin Learning Center for the IDEA-qualified students.

FINDING 2025-005 Finding Subject: Special Education – Procurement Suspension & Debarment Contact Person Responsible for Corrective Action: Dr. Wendy Skibinski Contact Phone Number and Email Address: 317-205-3332 x 77230 wskibinski@msdwt.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Special Education will ensure that all procurement procedures are followed for both the simplified acquisition method and the small purchase method. Documentation will be retained to verify that required procedures were followed. Anticipated Completion Date: September 30, 2026

FINDING 2025-001 Finding Subject: Child Nutrition Cluster – Procurement Suspension & Debarment Contact Person Responsible for Corrective Action: Annette Guenther Contact Phone Number and Email Address: 317-205-3332 x 77209 aguenther@msdwt.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: Child Nutrition will ensure that all procurement procedures are followed for both the simplified acquisition method and the small purchase method. Documentation will be retained to verify that required procedures were followed. Anticipated Completion Date: September 30, 2026

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

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE AND REPORTABLE INSTANCE OF NONCOMPLIANCE – U.S. DEPARTMENT OF AGRICULTURE, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, CHILD NUTRITION CLUSTER – FEDERAL ALN 10.553, 10.555, AND 10.582 2025-002 Internal Control Over Compliance and Reportable Noncompliance With Federal Procurement Requirements Finding Summary 2 CFR § 200.320 requires Independent School District No. 280 (the District) to establish and maintain effective internal control over compliance with requirements applicable to its federal program expenditures, including applicable procurement requirements. The District did not have sufficient controls in place within the child nutrition cluster federal programs to ensure compliance with federal procurement requirements related to methods of procurement, which resulted in reportable a instance of noncompliance. Corrective Action Plan Actions Planned – The District will review policies and procedures relating to procurement for its child nutrition cluster federal programs to ensure that multiple quotations are obtained when required and that adequate documentation is retained. The District solicited quotes and retained the necessary documentation for the noncompliant contract in fiscal year 2026. Official Responsible – The District’s Director of Finance, Heidi Savatdy. Planned Completion Date – June 30, 2026. Disagreement With or Explanation of Finding – The District agrees with this finding. Plan to Monitor – The District’s Chief Administrative Officer, Craig Holje, will monitor the implementation of these corrective actions as implemented by the Director of Finance to ensure appropriate controls over federal procurement requirements are in place and being consistently applied to ensure multiple quotations are solicited and retained for contracts awarded for goods or services in excess of the District’s micro-purchase threshold, as required by the Uniform Guidance.

2025-018 PROCUREMENT HIGHER EDUCATION POLICY COMMISSION (HEPC), BLUEFIELD STATE UNIVERSITY (BSU) Assistance Listing Number: Various – Research & Development Cluster Higher Education Policy Commission (HEPC) response: HEPC maintains procurement policies consistent with state law, which is one of the three allowable criteria recognized in 2 CFR §200.320(a)(1)(iv) for establishing a micro purchase threshold of up to $50,000. A Self-Certification letter will be developed and maintained by April 30, 2026, while formally defining micro-purchase thresholds applied to federal awards. This selfcertification letter will be retained as part of our procurement documentation and will provide how the micro-purchase threshold was determined and applied in accordance with 2 CFR §200.320(a)(1)(iv). Bluefield State University (BSU) response: Beginning in FY 2026, the BSU Controller and Director of Purchasing will review the criteria recognized in 2 CFR §200.320(a)(1)(iv) for establishing a micro purchase threshold of up to $50,000. These requirements will be presented to the Board of Governors before June 30, 2026.

Material Weakness in Internal Control over Compliance: • Provide grants management training to all its financial staff and management covering the Uniform Guidance/OMB Guidance for Federal Financial Assistance, as well as the Financial Policies and Procedures Manual. • Develop and implement policies and procedures that include monitoring of procurements to ensure policies and procedures are being followed. • Include in policies and procedures that a member of the finance department or management will review the SF-425 for correctness before submission.

CONDITION: During my review of the District’s compliance with the requirements for noncompetitive procurement, I noted the District did not document its rationale for purchases made from ‘Western PA Psych Care’ totaling $40,000. This is a repeat finding from the previous fiscal year 2024-001 CRITERIA: In accordance with Section 2 CFR 200.318(i) of the Uniform Guidance, the District must maintain records sufficient to detail the history of procurement. These records include but are not limited to the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore, Section 2 CFR 200.320(c’) of the Uniform Guidance details five (5) circumstances in which noncompetitive procurement can be used. RECOMMENDATION: I recommend that for all future purchases involving noncompetitive procurement, the District adheres to the requirements of 1) the District’s Procurement Policy for Federal Programs (#626), and 2) Section 2 CFR 200.320(c) of the Uniform Guidance.MANAGEMENT’S PLANNED CORRECTIVE ACTION: For noncompetitive procurement, the District will maintain records sufficient to detail the history of procurement. These records will include but are not limited to the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. The District’s timeframe for implementation is effective immediately. The District has a formal procurement policy for federal programs (#626) in place. The District hired a Business Manager effective with the 2024-2025 fiscal year who, in conjunction with the District’s Federal Program Coordinator, will be responsible for following the District’s existing procurement policy for federal programs, in particular related to this finding, the implementation of noncompetitive procurement procedures to ensure that they are followed appropriately. The implementation of this procedure took place after the questioned cost noted this fiscal year and will be effective for all future District procurements.

United States Department of Health and Human Services 2025-001 Procurement – Assistance Listing No. 93.279 Condition: The Organization did not maintain sufficient documentation to support the procurement method utilized prior to engaging a contracted service provider. Recommendation: We recommend the Organization consistently follow its established policies and procedures related to the maintaining of necessary documentation to support the method of procurement utilized. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Given the infrequency of spend in excess of the Simplified Acquisition Threshold, Chestnut will take a targeted approach in the corrective action. An initial first step in correction action has been taken and completed 2/18 including educating and informing Chestnut Health Systems Audit Committee and Chestnut Executive Leadership of lack of documentation supporting the procurement process. The Executive Leadership team and assigned grant leadership will be provided with the current Chestnut Procurement policy, reinforcing the requirements at each respective level of spend. For those programs with anticipated vendor spend in excess of the Simplified Acquisition Threshold, targeted working sessions will occur with respective program leadership and the Executive Leadership team to reinforce expectations, review template tools that can be leveraged during the process, and to remedy any gaps in understanding the policy and execution of the policy. Name(s) of the contact person(s) responsible for corrective action: Melissa Woodbury, CFO. Planned completion date for corrective action plan: By June 1, 2026 If there are any questions regarding this plan, please call Melissa Woodbury, CFO, at 309-820-3572.

Corrective Action: SHN will develop a comprehensive Federal Grants Management Policy Manual, including procurement-related procedures that fully align with the requirements of Uniform Guidance (2 CFR 200.320). The draft manual and related procedures will be reviewed by an external Federal Grants Management Specialist to ensure accuracy and compliance. As of January 2026, SHN is continuing to refine and update its procurement procedures to ensure full compliance with Uniform Guidance and alignment across all federal grant–related purchasing activities. This will be completed by June 30, 2026. Proposed completion date: Management will develop procedures for Board of Directors approval in June 2026.

Corrective Action: SHN will develop a comprehensive Federal Grants Management Policy Manual, including procurement-related procedures that fully align with the requirements of Uniform Guidance (2 CFR 200.320). The draft manual and related procedures will be reviewed by an external Federal Grants Management Specialist to ensure accuracy and compliance. As of January 2026, SHN is continuing to refine and update its procurement procedures to ensure full compliance with Uniform Guidance and alignment across all federal grant–related purchasing activities. This will be completed by June 30, 2026. Proposed completion date: Management will develop procedures for Board of Directors approval in June 2026.

Finding 2025-001 Material Weakness in Internal Control over Compliance and Other Matters, and Material Noncompliance Corrective Action Plan: The observed finding was the result of inadequate staff training on the proper School Nutrition Procurement (SNP) guidelines. Newly responsible staff have attended multiple training sessions and are now fully aware of proper SNP procurement procedures. Stricter internal controls are being implemented to prevent recurrence and regular planning and forecast meetings will be held with the school nutrition team. Moving forward, The Sr Director of Purchasing and Materials Management will ensure purchases will be forecast and an analysis completed yearly. For all estimated purchases of $50,000 or more in Child Nutrition Programs, new Requests for Proposals (RFPs) will be created, or purchases will be made through a USDA-approved purchasing cooperative RFP, as applicable. New RFPswill be developed after reviewing cost estimates, product requirements, and specifications, in accordance with the approved formal procurement guidelines found in 2 CFR 200.320(b), 7 CFR Part 210.19(e), and Section 17 of the NSLP Administrator’s Reference Manual (ARM). The resulting contract awards will be annual with optional renewals and contracts will be managed and records retained per Sections 16 and 30 of the NSLP ARM to ensure compliance. Responsible Officials: Leander ISD Management Anticipated Date of Completion: November 2025

The School District should be in compliance with the NJ DOE purchasing guidelines. The School District will make every attempt to follow the guidelines and protocols for every purchase. School Business Administrator. 2025-2026 fiscal year.

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.