Corrective Action Plans

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.

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

Healthy Start Communities – Assistance Listing No. 93.926 Recommendation: We recommend the organization follow its newly established procurement policy related to the maintaining of necessary documentation to support the method of procurement utilized. The Organization may also consider qualifying multiple vendors for particular goods/service and then utilizing an approved vendors list. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The organization put a procurement policy in place effective November 30, 2024. Since then, the policy has been followed and will continue to be as new vendors are brought on. Name(s) of the contact person(s) responsible for corrective action: Danielle Martin, Vice President & Chief Financial Officer Planned completion date for corrective action plan: November 30, 2024

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

Management Response/Corrective Action Plan: The School Department reviewed both the federal and local procurement policies with the administrative team in December of 2024. A memo was also sent to all administrators specifically discussing the suspension and debarment procedures regarding the use of federal funds. Since then, the School Board has since reviewed both policies and has revised threshold amounts and other language per the advice of legal counsel and MSMA. Now adopted, the policies have been shared with administration to ensure that purchasing procedures are followed and will be reviewed regularly. If there is any chance of federal funds being used for a purchase, the Department will follow the federal procurement requirements. Municipal staff attempted to follow Treasury guidance to administer the State and Local Fiscal Recover Fund (SLFRF) grant and interpreted the “Revenue Replacement” category of expenditure to be exempt from nearly all of the usual federal grant requirements, including the Suspension and Debarment verification step. More recently, the interpretation of the rule changed, but not before certain projects had been initiated, in which the verification step had been missed. Going forward, this will not be an issue as all SLFRF monies have been expended.

Auditor Description of Condition and Effect. During our review of procurement transactions, we identified one instance of sole-source procurement for which the College did not properly document a procurement decision in accordance with 2 CFR 200.320 related to justifying the use of a noncompetitive procurement method. Specifically, the procurement files lacked written justification demonstrating why competition was not feasible and did not include evidence of required approvals in accordance with the College’s procurement policies even though the arrangement was allowable under the circumstances. As a result of this condition, the College could not document a procurement decision for one vendor in accordance with federal regulations. Auditor Recommendation. We recommend the College strengthen controls over sole-source procurements by requiring documented justification and formal approval prior to executing noncompetitive procurement arrangements. Management should also provide additional training to procurement and program staff to ensure consistent compliance with federal procurement requirements and internal policies. Corrective Action. The entity will strengthen procurement controls by requiring written justification and documented approval for all sole-source procurements in accordance with Uniform Guidance and the entity’s procurement policies. A standardized sole-source justification form will be implemented and required prior to execution of any noncompetitive procurement funded with federal awards. Responsible Persons. Tom Zeidel, Vice President of Finance and Facilities and Troy Slater, Director of Business Office. Anticipated Completion Date. 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

2025-006 Procurement, Suspension & Debarment – Special Education Cluster (IDEA) Recommendation: Our auditors recommend the District review their policies and procedures related to Uniform Guidance and the District's Purchasing Policy. Our auditors also recommends the District evaluate current procedures and controls to ensure that policies are consistently followed and properly documented in accordance with District policies. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: In response to audit findings regarding procurement, suspension, and debarment practices within the Special Education Cluster (IDEA), the District has initiated and is implementing a comprehensive enhancement of policies and procedures to ensure full compliance with Uniform Guidance (2 CFR Part 200) and the District's Purchasing Policy. We are conducting thorough evaluation of all procurement procedures specific to IDEA-funded purchases and have developed enhanced documentation protocols ensuring all procurement transactions are properly documented and maintained in accordance with federal and district requirements. Recent procurements reflect significantly improved documentation practices. We have created standardized procurement checklists and templates to promote consistency across all IDEA-related purchases, and staff now utilize these tools routinely. Regarding suspension and debarment verification, we have established a formal verification process requiring designated staff to check the System for Award Management (SAM.gov) database prior to executing contracts or purchase orders with vendors using IDEA funds, and compliance is now being consistently achieved. Documentation of these verification checks is maintained in procurement files as evidence of compliance. We have implemented training for all staff involved in IDEA procurement, and staff report increased awareness and confidence in performing these checks. Additionally, we have designated the Director of Business Services and Special Education Director as dual reviewers for all IDEA procurement transactions exceeding established thresholds, creating additional oversight that has already prevented potential compliance issues. Regular quarterly internal audits are being conducted, and initial audits indicate substantial improvement in both procurement documentation and suspension and debarment verification practices. These measures are strengthening our procurement framework for the Special Education Cluster and ensuring consistent compliance with federal regulations. Name of the contact person responsible for correction action: Lavesa Glover-Verhagen Planned completion date for corrective action: June 30, 2026

2025-005 Procurement – Child Nutrition Cluster Recommendation: Our auditors recommend the District review their policies and procedures related to Uniform Guidance and the District's Purchasing Policy. Our auditors also recommend the District evaluate current procedures and controls to ensure that policies are consistently followed and properly documented in accordance with District policies. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: In response to strengthening procurement practices within the Child Nutrition Cluster, the District has undertaken and is implementing a comprehensive review and enhancement of policies and procedures to ensure full alignment with Uniform Guidance (2 CFR Part 200) and the District's Purchasing Policy. Following detailed analysis of current procurement practices, we have implemented key enhancements including standardized procurement documentation templates, enhanced vendor selection procedures ensuring competitive procurement methods are consistently applied, and improved record-keeping systems. We have strengthened procedures for obtaining and documenting price quotes, formal bids, and proposals in accordance with established thresholds, with additional controls ensuring all procurement transactions receive appropriate supervisory review and approval. Since implementing these improvements, we have observed more consistent adherence to procurement thresholds, better documentation of competitive selection processes, and increased transparency in vendor selection decisions. We have provided targeted training to Child Nutrition staff and business office personnel on federal procurement requirements, and staff feedback indicates stronger understanding of compliance obligations. We have implemented quarterly internal reviews to monitor compliance, and initial reviews show marked improvement in documentation quality and policy adherence. These proactive measures are creating a robust and transparent procurement framework for the Child Nutrition Cluster, ensuring consistent compliance with federal regulatory requirements and district policies while promoting accountability and fiscal responsibility. Name of the contact person responsible for correction action: Lavesa Glover-Verhagen Planned completion date for corrective action: June 30, 2026