Corrective Action Plans

CONDITION: The Western Beaver Area School District contracted with a third-party vendor – Snider Recreation for the purchase and installation of playground equipment. The contract was procured through a cooperative purchasing group. The District 1) was unable to provide documentation from the cooperative purchasing group to verify that the playground procurement contract was competitively procured, such as a bid evaluation and public solicitation and 2) did not obtain the adequate number of price or rate quotations. This is a continuing finding from the 2022-2023 fiscal year. CRITERIA: As specified in 2 CFR 200. 318(i) of the Uniform Guidance, the District must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. In addition, small purchase procedures per 2 CFR 200.320(a)(2)(i) for acquisitions between the micro-purchase threshold (currently $10,000) and the simplified acquisition threshold (current $250,000), price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate. Per 24 PS 8.807.1, there should be three quotes that are either written or well documented. MANAGEMENT’S CORRECTIVE ACTION PLAN: Management will review and update as necessary, it’s current procurement policies and procedures to ensure compliance with all applicable sections of the Uniform Guidance, in specific, Sections 2 CFR 200.318(i) and 200.320(a)(2)(i) of the Uniform Guidance, as well as 24 PS 8.807.1. In specific, these procedures will include 1) obtaining all relevant information pertaining to procurements involving federal assistance from any cooperative purchasing group and 2) obtaining quotations from three qualified providers where applicable and documenting those results. These two (2) updated procedures will be implemented during the remaining months of the 2024-2025 fiscal year, and all subsequent years, for future purchases where applicable.

2024-011 Higher Education – Institutional Aid – Federal Assistance Listing 84.031 – Procurement Recommendation: We recommend the University establish a policy to ensure that supporting documentation is maintained for procured goods and services. Explanation of disagreement with audit finding: There is no disagreement to the audit finding. Action taken in response to finding: The Title III Grant Management Department will ensure compliance with all federal and state requirements by maintaining procurement documents in accordance with the record retention policy. Additionally, the University’s Purchasing Department will retain electronic copies of submitted documents in BDMS or other relevant electronic record-keeping systems. Name(s) of the contact person(s) responsible for corrective action: Title III Associate Director, Jessica Wilson, & Title III Program Director, Carlene Jackson. Planned completion date for corrective action plan: June 2025

The Service Center will be sure to follow the federal procurement requirements pursuant to Policy 6325 and verify that appropriate controls and compliance with federal requirements are maintained with documentation supporting the procurement types.

Information on the federal program: Subject: Special Education Cluster (IDEA) – Procurement Federal Agency: Department of Education Federal Program: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Number: 84.027 Federal Award Numbers and Years (or Other Identifying Numbers): H027A220084, H027A230084 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Significant Deficiency Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirement. 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. However, Indiana Code 5-22-8 has a more restrictive threshold of $150,000 or less for when small purchase procedures may be used. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds. Micro purchases, typically for those purchases $10,000 or under, and small purchase procedures for those purchases above the micro purchase threshold, but below the simplified acquisition threshold. Micro purchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. Context: The School Corporation did not obtain price or rate quotes for one out of four vendors tested that were less than the simplified acquisition threshold of $150,000 but exceeded the $10,000 micro-purchase threshold. Documentation of vendor contract, bids or the School Corporation's process and rationale for the chosen vendor was not available for audit. Further, the School Corporation could not provide evidence that a suspension and debarment check had been performed on the vendor prior to entering into contract. Corrective Action Plan: The Special Education Director will obtain pricing quotes from the appropriate amount of qualified sources, when cumulative costs are projected to exceed the micro purchase threshold. The Special Education Director will document and communicate the results of this process with the Business Manager and Superintendent. Person responsible for implementation and projected implementation date: The Special Education Director, the Business Manager, and the Superintendent will be responsible for overseeing the implementation of the corrective action plan, which will go into effect immediately.

CONDITION: During the PDE monitoring review of the ARP ESSER grant program, it was noted that the School District did not document in writing its rationale for the noncompetitive procurement of services provided by J. Martin & Associates. 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 School District adhere to Section 2 CFR 200.318(i) and Section 2CFR 200.320(c’) of the Uniform Guidance regarding the proper documentation required for noncompetitive procurement, as well as the District’s Procurement Policy for Federal Programs (#626.5). MANAGEMENT’S PLANNED CORRECTIVE ACTION: The School District’s will maintain procurement records, including why the noncompetitive procurement contract was necessary with appropriate documentation vetted by the District Solicitor. Additionally, the District will conduct an analysis to support that the price paid was reasonable. This analysis is needed to justify procurements that are not competitively bid. The timeframe for implementation is effective immediately.

FINDING 2024-002 Information on the federal program: Subject: Child Nutrition Cluster - Internal Controls over Procurement and Suspension and Debarment Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program, Supply Chain Assistance Program, Summer Food Service Program Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY 22-23, FY 23-24 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: Procurement The School Corporation participates in Unified Purchasing Cooperative of the Ohio River Valley (the “Cooperative”), which procures vendors for food purchases and other supplies on behalf of its members. During the audit period, the School Corporation also purchased food and supplies from vendors not procured by the Cooperative. One vendor with aggregate annual purchases of $38,261 for fiscal year 2024 exceeded the small purchase threshold ($10,000 - $150,000). The School Corporation could not provide documentation showing the bids received from other vendors that were used to compare pricing. Suspension and Debarment For the small purchase vendor noted above that was not procured by the Cooperative and had aggregate annual disbursements exceeding the federal suspension and debarment threshold of $25,000, the School Corporation did not provide documentation confirming that the vendor was not suspended or debarred before disbursing federal funds during fiscal year 2024. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Management will implement a procurement checklist that is reviewed after the purchasing process has been completed to ensure compliance with purchasing requirements for federal awards. Sam.gov will be checked for each vendor with aggregate purchases above $25,000. Responsible Party and Timeline for Completion: Ginny Shannon, FSD and Gretchen Berger, Corp Treasurer - 6-1-2025

Finding 2024-003 – Procurement and Suspension and Debarment (Significant Deficiency and Noncompliance) Planned Corrective Action: The University’s College of Agriculture, Environment, and Nutrition Sciences (CAENS) did not follow the three-quote procurement process. The two invoices, one dated November 2023 and one dated June 30, 2024, were cited for this exception. The University implemented internal controls enhancement by requiring the Office of Grants and Contracts to review and approve CAENS documents, including procurement, before they are submitted for processing in the University financial system, effective November 8, 2024. The University also established a new Procurement policy in Fiscal Year 2025, which includes an increase in quote limits and a preferred vendors list. Anticipated Date of Completion: Corrective action was implemented for CAENS on November 8, 2024. The new Procurement Policy will be effective for the fiscal year 2025. Person Responsible for Corrective Action: Assistant Vice President for Budgets and Procurement, and the Senior Associate Vice President for Business Affairs/Interim CFO

CONDITION: The Beaver County Career and Technical Center contracted with a third-party vendor – Huckstein Mechanical for the purchase of technology equipment. The contracts were procured through a cooperative purchasing group. The Center 1) was unable to provide documentation from the cooperative purchasing group to verify that the technology procurement contracts were competitively procured, such as a bid evaluation and public solicitation and 2) did not obtain the adequate number of price or rate quotations. CRITERIA: As specified in 2 CFR 200. 318(i) of the Uniform Guidance, the Center must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. In addition, small purchase procedures per 2 CFR 200.320(a)(2)(i) for acquisitions between the micro-purchase threshold (currently $10,000) and the simplified acquisition threshold (current $250,000), price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate. Per 24 PS 8.807.1, there should be three quotes that are either written or well documented.MANAGEMENT’S CORRECTIVE ACTION PLAN: Management will review and update as necessary, it’s current procurement policies and procedures to ensure compliance with all applicable sections of the Uniform Guidance, in specific, Sections 2 CFR 200.318(i) and 200.320(a)(2)(i) of the Uniform Guidance, as well as 24 PS 8.807.1. In specific, these procedures will include 1) obtaining all relevant information pertaining to procurements involving federal assistance from any cooperative purchasing group and 2) obtaining quotations from three qualified providers where applicable and documenting those results. These two (2) updated procedures will be implemented during the remaining months of the 2023-2024 fiscal year, and all subsequent years, for future purchases where applicable.

FINDING 2024-005 Subject: Child Nutrition Cluster – Internal Controls over Procurement and Suspension and Debarment 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): FY 22-23, FY 23-24 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: Procurement The School Corporation participates in K12’s Leading Indiana Cooperative (KLIC), which procures vendors for food purchases and other supplies on behalf of its members. During the audit period, the School Corporation also purchased food and supplies from vendors not procured by the Cooperative. One vendor with aggregate annual purchases of $62,545 and $49,614 for fiscal year 2023 and 2024, respectively, exceeded the small purchase threshold ($10,000 - $150,000). For the 2023 fiscal year, the School Corporation could not provide documentation showing the bids received from other vendors that were used to compare pricing. As it pertains to the 2024 fiscal year, the School Corporation could not provide any documentation surrounding the procurement of the small purchase vendor. Suspension and Debarment For the small purchase vendor noted above that was not procured by the Cooperative and had aggregate annual disbursements exceeding the federal suspension and debarment threshold of $25,000, the School Corporation did not provide documentation confirming that the vendor was not suspended or debarred before disbursing federal funds during fiscal year 2024. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Management will implement a procurement checklist that is reviewed management to ensure compliance with the School’s purchasing policy for federal awards. Responsible Party and Timeline for Completion: Jessica Defossett, Annually in June or as new vendor is needed.

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): FY2023, FY2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement Procurement Audit Finding: Material Weakness Condition and Context: 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 requirement. The School Corporation utilizes two vendors for the majority of food and supplies purchases for the food service program. One vendor is procured through a purchasing cooperative, Southwest Indiana Co-op, where the School Corporation is a member. The other vendor met the simplified acquisition threshold for fiscal year 2023 and the small purchase threshold for fiscal year 2024. The School Corporation was unable to provide any supporting documentation for the procurement process undertaken as required by the School Corporation's procurement policy. Management stated the items purchased were chosen based on a comparison of prices with two other vendors, however, management had no documented support for the rationale or process to determine which vendor would be selected for food and supplies purchases. The sample item amount disbursed was $151,511 for food purchases in FY23 and $129,583 for food purchases in FY24. The School Corporation did properly confirm the vendor was not debarred or suspended. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The treasurer will provide the food service director with quarterly vendor reports so the spending thresholds can be monitored. In the event it is known that expenditures will exceed the threshold, the food service director will work to provide rationale for the vendor choice and/or procure items using the bid/RFP process. Responsible Party for Corrective Action: Tamara L. Asdell, Treasurer Timeline for Completion: Immediately

FINDING 2024-001 Finding Subject: Special Education Cluster (IDEA) – Procurement and Suspension and Debarment Summary of Finding: Federal Agency: Department of Education Federal Programs: COVID-19 - Special Education Grants to States; 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; dmason@dkeschools.com 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. 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. E INDIANA STATE BOARD OF ACCOUNTS 25 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 2024-003 Finding Subject: Special Education Cluster (IDEA) – Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Bethany Cmar Contact Phone Number and Email Address: 765-641-2126 (Bcmar@acsc.net) Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: When it comes to procurements thresholds, ACS will prepare a policy to follow the necessary federal guidelines. For small purchases, three quotes or bids will be obtained to ensure compliance with the procurement guidelines. For all vendors expected to exceed over $25,000 in expenditures will be kept in a binder by the Special Ed Director to ensure that they are not suspended or debarred from federal awards. The CFO will then review and approve the documentation supporting this via signature. Anticipated Completion Date: June 30, 2025

Identifying Number: Finding No. 2024-003 – Procurement over Small Purchase Transactions (Mental and Behavioral Health Education and Training Grants) Finding: The College did not obtain price or rate quotations obtained from different qualified transactions for all small purchase transactions sampled under the Mental and Behavioral Health Education and Training Grants. Corrective Actions Taken or Planned: Responsible Official: Jaime Cacciola, Director of Grant and Tim Pollak, Director of Finance Anticipated Completion Date: April 30, 2025 View of Responsible Individuals: 1. A new procurement policy was created and put into effect in FY2025 that addresses all compliance requirements under Uniform Guidance sections §200.317 – §§00.326, which includes the following: Methods of Procurement to be Followed (§200.320) Small Purchase Method: Small purchase procedures are those relatively simple and informal procurement methods for securing services, supplies or other property that do not cost more than the defined Simplified Acquisition Threshold of $250,000. Price or rate quotations must be obtained from at least two suppliers. The PI is responsible for documenting suppliers reviewed, quotes received and reason for selection of supplier. Quotes can be obtained from suppliers or from public websites and included as backup documentation for the purchase.

Identifying Number: Finding No. 2024-002 – Procurement over Small Purchase Transactions (Research and Development Grants) Finding: The College did not obtain price or rate quotations obtained from different qualified transactions for all small purchase transactions sampled under the Research and Development Cluster Grants. Corrective Actions Taken or Planned: Responsible Official: Jaime Cacciola, Director of Grant and Tim Pollak, Director of Finance Anticipated Completion Date: April 30, 2025 View of Responsible Individuals: 1. A new procurement policy was created and put into effect in FY2025 that addresses all compliance requirements under Uniform Guidance sections §200.317 – §§00.326, which includes the following: Methods of Procurement to be Followed (§200.320) Small Purchase Method: Small purchase procedures are those relatively simple and informal procurement methods for securing services, supplies or other property that do not cost more than the defined Simplified Acquisition Threshold of $250,000. Price or rate quotations must be obtained from at least two suppliers. The PI is responsible for documenting suppliers reviewed, quotes received and reason for selection of supplier. Quotes can be obtained from suppliers or from public websites and included as backup documentation for the purchase.

FINDING 2024-007 (Section III-Federal Award Findings and Questioned Costs) 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; dmason@dkeschools.com 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. 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. Per Uniform Guidance: 2 CFR § 200.511(a) – “The auditee is responsible for follow-up and corrective action on all audit findings. . .The auditee must also prepare a corrective action plan for current year audit findings. . . The corrective action plan and summary schedule of prior audit findings must include findings relating to the financial statements which are required to be reported in accordance with GAGAS. ” 2 CFR § 200.511(c) – “At the completion of the audit, the auditee must prepare, in a document separate from the auditor's findings described in § 200.516, a corrective action plan to address each audit finding included in the current year auditor's reports. The corrective action plan must provide the name(s) of the contact person(s) responsible for corrective action, the corrective action planned, and the anticipated completion date. If the auditee does not agree with the audit findings or believes corrective action is not required, then the corrective action plan must include an explanation and specific reasons.” 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 2024-003 Finding Subject: Special Education Cluster – Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Marcia Fullenkamp, Treasurer Contact Phone Number and Email Address: (812) 623-2212; mfullenkamp@rodspecialed.org Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The ROD Special Education Cooperative will make notes in the Board Minutes regarding the fact that only one vendor can provide specific services prior to entering into a contract or purchasing said services. Each company providing services will be checked on the SAM.gov website to ensure that the vendor has not been suspended or debarred. Anticipated Completion Date: February 1, 2024

Management agrees with the finding and will review and revise its procurement polciies and procedures to provide clarity, provide additional training to employees and board members, and establish monitoring procedures to ensure policies and procedures are being followed.

Management agrees with the finding and will review and revise its procurement polciies and procedures to provide clarity, provide additional training to employees and board members, and establish monitoring procedures to ensure policies and procedures are being followed.

Finding 2024‐002 Finding Subject: Special Education Cluster (IDEA) ‐ Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Todd A. Armstrong, Assistant Superintendent Contact Phone Number and Email Address: (812) 897‐6036 tarmstrong@warrick.k12.in.us Views of the Responsible Official: We concur with the finding. Additional Explanation: Although the vendors selected provided specific services outlined in the federal grant, proper documentation of how those vendors were selected was not maintained. Moreover, the department believed by following the spending allotted in the grant, they were meeting necessary purchasing guidelines. Internal controls did not identify this misstep and allowed the services to be purchased. To avoid this in the future, guidelines will be prepared for all departments submitting purchase requests, and an additional control will be put in place to verify that procedures are followed. Description of Corrective Action Plan: 1) Create and write an administrative guideline that outlines expected purchasing procedures. 2) Distribute and make available the administrative guideline to employees. 3) Create an additional internal control in the business office to verify that those procedures were met with each requisition or request for purchase. 4) Provide necessary corrections to any request that does not follow guidelines. Mr. Armstrong will oversee, direct, and coordinate this process. He will work with the Corporation administrative team to develop and write the guidelines. The Business department will distribute the guidelines to all interested parties and have guidelines available upon request. Mr. Armstrong will outline expectations and determine when they have been met satisfactorily. Anticipated Completion Date: The remedy for this finding will be in place prior to June 30, 2025.

FA 2024-001 Improve Controls over Procurement, Suspension and Debarment Compliance Requirement: Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: 84.027 - Special Education Grants to States 84.173 - Special Education Preschool Grants Federal Award Number: H027A220073 (Year: 2023), H027A230073 (Year: 2024), H173A220081 (Year: 2023), H173A230081 (Year: 2024), Questioned Costs: None Identified Description: A review of expenditures charged to the Special Education Cluster revealed that the School District's internal control procedures were not operating appropriately to ensure that the School District's procurement and suspension and debarment procedures were followed. Corrective Action Plans: To improve controls over procurement and suspension and debarment within our federal programs, we will: 1. Conduct an audit review training session in which we will review the audit findings, the corrective action plan, and the proper procedures for procurement and suspension and debarment. Attendance will be mandatory for all employees involved in the purchasing process for federal programs. A sign-in sheet will be used to document attendance. 2. Require all employees who are involved in the purchasing process for federal programs to review the Federal Programs Handbook annually and sign an attestation that they have done so. 3. Create a checklist that must be completed as part of the purchasing process for federal programs requisitions. This checklist will include steps found in the procurement and suspension and debarment policies set forth in the Federal Programs Handbook. Completed checklists will be maintained with voucher packets for each requisition. Estimated Completion Date: 6/30/2025 Contact Person: Nicole Price, Finance Director Telephone: 229-649-2234 Email: price.nicole@marion.k12.ga.us

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

FA 2024-001 Improve Controls over Procurement and Suspension and Debarment Compliance Requirement: Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: 84.027 - Special Education Grants to States 84.173 - Special Education Preschool Grants Federal Award Number: H027A220073 (Year: 2022), H027A230073 (Year: 2023), H173A230081 (Year: 2023) Questioned Costs: $44,955 Description: A review of expenditures charged to the Special Education Cluster revealed that the School District's internal control procedures were not operating appropriately to ensure that the School District's procurement and suspension and debarment procedures were followed. Corrective Action Plans: We are implementing a more structured approach to larger purchases, which should help improve oversight and accountability. A new purchasing policy was implemented to ensure that significant expenditures are carefully reviewed and align with the district's financial strategy. Having the new CFO involved in reviewing and overseeing large purchases, as they'll be able to bring financial oversight to the process. Offering training to staff members who need help understanding the new policy will also ensure smooth adoption and compliance across the board. Estimated Completion Date: June 30, 2025 Contact Person: Shannon White, Business Services Director Telephone: 229-671-6045 Email: swhite@goats.org

Finding 2024-004 Internal Controls over Procurement Plan: University will work with information technology to enhance the eprocurement system to ensure appropriate documentation support is captured when a user selects the method for a non-competitive procurement. Expected Implementation Date: December 2025 Contact: Aaron Rosenthal, Assistant Vice Chancellor Purchasing and Contract Management University of Illinois Chicago Aaronr1@uillinois.edu 312-996-8074 Bradley Henson, Director of Purchasing Purchasing and Contract Management University of Illinois Urbana-Champaign Bhenson4@uillinois.edu 217-300-2459

Context: For the three small purchase method procurements sampled for testing, we noted that the School Corporation, did not obtain quotes from an adequate number of qualified sources. The total amount disbursed for the sample items was $114,123 in FY23 and $13,404 in FY24 for contracted rehabilitation therapy and speech pathology services. The School Corporation did properly perform a suspension and debarment checks on the sample vendors. Contact Person Responsible for Corrective Action: Patrick Biggerstaff, Assistant Superintendent Contact Phone Number: (317) 831-0950 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Three quotes will be obtained, according to local policy (po6320) as well as state and federal guidance, when relevant purchasing and cost thresholds are reached. Anticipated Completion Date: April 1, 2025

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