Corrective Action Plans

Information on the federal program: Subject: Education Stabilization Fund (ESSER) – Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness 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 Reporting compliance requirements. Context: The School Corporation was required to submit Annual Data Reports to the Indiana Department of Education (IDOE) during the audit period to meet federal reporting requirements for ESSER grant awards. We noted that the ESSER II and ESSER III amounts reported on the Year 3 report ($288,565 and $115,716, respectively) did not agree to the underlying expenditure records ($139,081 and $88,437, respectively) for the period of July 1, 2022 through June 30, 2023. Corrective Action Plan: The School Corporation will implement a system of internal controls to ensure the amounts reported on the annual data reports agree to the underlying expenditure detail in the accounting system. Person responsible for implementation and projected implementation date: The Treasurer and the Superintendent will be responsible for implementing the corrective action plan, which will start with the next submission of the annual data report.

Information on the federal program: Subject: Education Stabilization Fund (ESSER) – Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Context: The School Corporation was required to submit two Annual Data Reports to the Indiana Department of Education (IDOE) during the audit period to meet federal reporting requirements for ESSER grant awards. We noted that the ESSER I and ESSER III amounts reported for the reports covering the FY22 time period ($22,163 and $409,347, respectively) did not agree to the underlying expenditure records ($3,796 and $404,347 respectively) for the period of July 1, 2021 through June 30, 2022. Additionally, we noted that the ESSER II amount reported for the reports covering the FY23 time period ($131,439) did not agree to the underlying expenditure records ($153,216) for the period of July 1, 2022 through June 30, 2023). We also noted there was no documented, secondary review of the information in the FY23 annual data reports by someone other than the preparer. Contact Person Responsible for Corrective Action: Dr. David Stashevsky Contact Phone Number: 765-378-3329 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The assistant superintendent will manage the grant with the superintendent providing oversight. The assistant superintendent will coordinate the receipts and expenditures of funds with the corporation treasurer. The superintendent will review all financial reports and approve in writing with notification sent to the assistant superintendent and treasurer. Anticipated Completion Date: The correction will be on the next annual report when it is due.

FINDING 2024-001 Information on the federal program: Subject: Education Stabilization Fund (ESSER) – Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Context: The School Corporation was required to submit two Annual Data Reports to the Indiana Department of Education (IDOE) to meet federal reporting requirements for ESSER grant awards. The Annual Data Reports were prepared by School Corporation management and reviewed by someone other than the preparer, however, the review process in place did not prevent, or detect and correct, errors. During testing of the accuracy of the annual data reports, the following errors were noted: • The Year 2 Annual Data Report for the ESSER III (84.425U) grant award reported total disbursements of $2,219,321 for the period of July 1, 2021 through June 30, 2022 compared to underlying disbursement detail of $2,715,940. • The Year 3 Annual Data Report for the ESSER III (84.425U) grant award reported total disbursements of $224,309 for the period of July 1, 2022 through June 30, 2023 compared to underlying disbursement detail of $306,194. Contact Person Responsible for Corrective Action: Kasey Clark Contact Phone Number: 574-772-1604 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: There will be two people who look over the ESSER reports before submitting to the state to make sure they agree with the reports. Anticipated Completion Date: When next report is due.

Information on the federal program : Subject: Education Stabilization Fund (ESSER) – Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Context : The School Corporation was required to submit two Annual Data Reports to the Indiana Department of Education (IDOE) during the audit period to meet federal reporting requirements for ESSER grant awards. We noted that the ESSER II amount reported for the reports covering the FY22 time period ($230,281) did not agree to the underlying expenditure records ($4,290 for the period of July 1, 2021 through June 30, 2022). We also noted there was no documented, secondary review of the information in the annual data reports by someone other than the preparer. Contact Person Responsible for Corrective Action: Candace McDonald Contact Phone Number: 765-734-1261 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Director of Finance will review financial statements and ensure they agree to amounts reported on the annual data reports. Reviews will be documented with a signature. FTE documentation will be retained. Anticipated Completion Date: When the next report is due

FINDING 2024-005 Subject: Child Nutrition Cluster –Reporting Audit Finding: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Linda Zaborowski, CFO Contact Phone Number and Email Address: (219) 881-5536 lzaborowski@garycsc.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: Gary Community School Corporation (GCSC) is taking immediate action to strengthen internal controls over meal count reporting. The district will fully utilize the Skyward Student Information System to track all meals, including those processed through the Point of Sale (POS) system and a la carte items, ensuring a standardized process across all schools. To improve accuracy and prevent over-claiming, GCSC is implementing a unique student ID system where each student will either scan their ID card or manually enter their assigned ID number when receiving a meal. The CFO/Food Service Director will conduct daily reconciliations of meal counts with the Food Service Management Company (FSMC) and verify all claims against source records to prevent errors. Monthly claims will be reviewed for accuracy, ensuring that second student meals and staff meals are excluded. Additionally, GCSC will establish clear policies and procedures requiring the FSMC to provide complete and accurate data for all claim submissions. Regular internal audits and staff training will be conducted to enforce compliance, and an oversight process will be implemented to detect and correct discrepancies before submission. Anticipated Completion Date: Gary Community School Corporation will implement this procedure by March 2025.

Context: The School Corporation was required to submit two Annual Data Reports to the Indiana Department of Education (IDOE) during the audit period to meet federal reporting requirements for ESSER grant awards. We noted that the ESSER II and ESSER III amounts reported for the reports covering the FY22 time period ($0 and $0, respectively) did not agree to the underlying expenditure records ($79,112 and $99,245 respectively, for the period of July 1, 2021 through June 30, 2022). Additionally, we noted that the ESSER II, and ESSER III amounts reported for the reports covering the FY23 time period ($178,829 and $874,154, respectively) did not agree to the underlying expenditure records ($159,450 and $789,489), respectively, for the period of July 1, 2022 through June 30, 2023). We also noted there was no documented, secondary review of the information in the annual data reports by someone other than the preparer. Contact Person Responsible for Corrective Action: Abigail Lindsey Contact Phone Number: 765-853-5464 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Corporation will make sure all expenditures match annual data reports. Anticipated Completion Date: 05/01/2025

Condition: The District did not comply with the reporting requirements with respect to filing accurate quarterly reports with the ISBE. Plan: The District will submit accurate expenditure reports in the future regardless of the project end date. Anticipated Date of Completion: July 1, 2024. Name of Contact Person: Dr. Beau Fretueg, Superintendent. Management Response: We will review grant expenditures on a quarterly basis and submit accurate expenditure reports to the ISBE as required.

Condition: As of the March 31, 2024 reporting date, the Town’s Project and Expenditure Reports overstated expenditures by $821,704. Corrective Action Planned: We, the Town of Charlton, plan to correct our overstated expenditures by correcting the reporting that we submit to the U.S. Treasury and updating to reconcile to what was actually paid and processed by the Town out of ARPA funds. Anticipated Completion Date: April 30, 2025 Contact: Ashley Obrzut, Finance Director, Town of Charlton

Views of Responsible Officials: The delay in submitting the report was primarily due to oversight. To ensure that similar delays do not occur in the future, we are implementing the following measures: 1. Improved Project Management: We will review our internal processes and set clearer timelines for report preparation. We will assign specific personnel responsible for ensuring that all required reports are submitted on time. 2. Enhanced Communication: We will improve communication with all departments involved in the report preparation process to ensure that necessary information is gathered and validated promptly. 3. Monitoring Progress: We will establish a more robust internal monitoring process to track the progress of report preparation and ensure timely submission.

Federal Agency Name: Department of Labor Assistance Listing Number: 17.270 Program Name: Reentry Employment Opportunities Finding Summary: Our auditors identified that the 9130 financial reports were completed on the cash basis of accounting and were completed as of the date of the report was submitted and not based on the specified quarterly reporting period. Additionally, documentation was not retained to support the numbers reported and there was no documented review or approval over the 9130 quarterly reports. Corrective Action Plan: The first two 9130 quarterly reports were submitted, and the cumulative federal expenditures were misstated. Once the 9130 reports are submitted and approved by the funder, we are unable to correct it. The amounts were corrected and accurate by the fiscal year ending 2024. This final quarterly 9130 was submitted accurately to reflect the full year of expenditures. Effective immediately, the General Ledger detail will be saved for each monthly report as well as the quarterly reports. This will ensure that if something does get changed after the submission of the 9130 reports, we are able to review the detail to see what was changed in order to reconcile. Responsible Individual: Mindy Baylor, Director of Finance Anticipated Completion Date: January 2025

FINDING 2024-003 Finding Subject: COVID-19 - Education Stabilization Fund - Reporting Summary of Finding: Annual Report for ESSER grants were all submitted but there was no supporting documentation showing internal controls of another person reviewing the information that was submitted was accurate. Contact Person Responsible for Corrective Action: Ginger Schenks Contact Phone Number and Email Address: 812-749-4755 ext 1143; gschenks@corp.egsc.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: The Treasurer will work with the Superintendent and/or Grant Administrator ensuring that annual financial reporting for federal grants is completed on time with review by the Superintendent. The Treasurer will supply the financial data for the time period of reporting to the Grant Administrator and/or Superintendent for their approval and submission of the annual financial report. The Superintendent and/or Grant Administrator will ensure that expenses align with the grant application prior to submission. The report and supporting documentation will be downloaded and the Treasurer and Superintendent will sign and date that report. This document will be in the grant folder in the Treasurer’s Office. Anticipated Completion Date: This process will begin with the next annual financial report due date.

Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and will take the following corrective action. The ESSER annual Data Collection reports will need to be reviewed more closely to ensure that they are matching to the disbursement detail in the accounting software. Once the superintendent has entered numbers into the report, there should be a second review of those numbers to the accounting software numbers by the corporation treasurer. In addition, detail of full-time equivalent employees needs to be documented by the deputy treasurer and retained with each report going forward. Responsible party and timeline for completion: Responsible party is Theresa Robbins, Corporation Treasurer. The timeline for completion is spring of 2025.

Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: This is isolated to FY23 reporting. Internal controls over ESSER reporting were not implemented by previous business office personnel. Corrective action involves the Treasurer preparing the reporting, reviewing the reports with the Superintendent, and confirming accuracy before submitting to the Department of Education. The approval is documented. This was implemented for Year 4 reporting submitted April 23, 2024. Completion Date: 4/23/2024

Context: The School Corporation was required to submit two Annual Data Reports to the Indiana Department of Education (IDOE) during the audit period to meet federal reporting requirements for ESSER grant awards. We noted that the ESSER I and ESSER II amounts reported for the reports covering the FY22 time period ($90,217 and $238,439, respectively) did not agree to the underlying expenditure records ($81,958 and $400,439 respectively, for the period of July 1, 2021 through June 30, 2022). Contact Person Responsible for Corrective Action: Michele Harrison/ Corporation treasurer Brian Byrum I Superintendent Contact Phone Number: M. Harrison:765-492-5101 B. Byrum: 765-492-5102 Views of Responsible Official: We concur with the finding. De cription of Corrective Acti0n Pl an: Our management team noted that the ESSER 1 and ESSR II spreadsheet submitted to the state was incorrect; however, the actual expenditures were correct every month. The spreadsheet was corrected in the following annual submission to the DOE (which is outside this audit window). The next Audit will show the corrected spreadsheet for ESSER I and ESSER II. It is also noted that the management team will implement more internal controls with regard to the preparer and reviewer being different personnel. For year 5 collection, the corporation treasurer will provide the expenditure reports, an outside consultant will prepare the spreadsheet, and have the current superintendent review before submitting. Anticipated Completion Date: 3/7/2025

FINDING 2024-001 Finding Subject: Child Nutrition Cluster - Reporting Summary of Finding: There were no controls in place to ensure that the School Corporation complied with the reporting requirements. The reimbursement request reports were prepared and submitted by the Food Service Director without any oversight, review or approval process to ensure accuracy of the reports. There was no oversight to make sure that the number of meals served matched the report filed. The lack of internal controls was systemic throughout the audit period. Contact Person Responsible for Corrective Action: Amanda Myers Contact Phone Number and Email Address: 765-832-3551/amyers@svcs.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Amanda Myers, Food Services Director, will continue to receive the information for the monthly meals served from the cafeteria managers at each school. Once she enters the information, the HS cafeteria manager will review the numbers to ensure that the information was entered correctly. The reimbursement forms and information that was entered will be submitted to the finance department to ensure the reimbursement process is correctly receipted. Anticipated Completion Date: Immediate.

Context: The School Corporation was required to submit two Annual Data Reports to the Indiana Department of Education (IDOE) during the audit period to meet federal reporting requirements for ESSER grant awards. We noted that the ESSER I, ESSER II, and ESSER III amounts reported for the reports covering the FY22 time period ($3,000, $0 and $0, respectively) did not agree to the underlying expenditure records ($0, $207,168, and $104,885, respectively, for the period of July 1, 2021 through June 30, 2022). Additionally, we noted that the ESSER II, and ESSER III amounts reported for the reports covering the FY23 time period ($328,359 and $334,119, respectively) did not agree to the underlying expenditure records ($121,193 and $229,234, respectively, for the period of July 1, 2022 through June 30, 2023). Contact Person Responsible for Corrective Action: Melissa Dempsey Contact Phone Number: 812-546-2000 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Business Manager and Assistant will jointly review all expenditures or fedral grant awards with in the fiscal year that are to be reported to ensure accuracy of reporting. Anticipated Completion Date: July 2025

Official Responsible for Ensuring CAP Dani Haman, Head Start business manager, will be responsible to ensure that the appropriate measures are taken. Correcting Plan The District will provide Dani Haman, Head Start business manager, necessary training. The Planned Completion Date of CAP Immediately

The Organization will review the terms and conditions of all federal awards to determine if program income is applicable to the federal program. For such federal programs, the Organization will ascertain the requirements for determining or assessing the amount of program income, and the requirements for recording and using program income. If required in accordance with the program, the Organization will implement a process for tracking and reporting the program income generated and used during the fiscal year. Further, the Organization will add another level of review of financial reports to ensure that program income is properly reported in accordance with the terms and conditions of the award. Anticipated Completion Date: 3/31/2025 Responsible Contact Person: Jeffery McNeal, Chief Financial Officer

The Municipality established internal control to maintain schedule of the due date reports in order to avoid this situation.

FINDING 2024-003 Finding Subject: Education Stabilization - Reporting Summary of Finding: The School Corporation had not designed, nor implemented, a system of internal controls to ensure that the annual Elementary and Secondary School Emergency Relief (ESSER) Data Collection reports (Reports) were complete and accurately submitted. The Reports were prepared by one employee without a documented oversight, review, or approval process in place to prevent, or detect and correct, errors. Contact Person Responsible for Corrective Action: Trina Huff Contact Phone Number and Email Address: (812) 689-4114, thuff@jaccendel.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: Moving forward treasurer will provide even more information to the reviewer specifically pertaining to the findings and any other pertinent information for that person to have a better idea of what they are looking for and will keep documentation of the review being done and signed off on. Anticipated Completion Date: This will be corrected with the next round of ESSER reporting due January 2025.

FUNDACION DE DESARROLLO COMUNAL DE PUERTO RICO, INC. (FUNDESCO) acknowledges the findings identified during the single audit regarding reporting requirements stemming from a lack of personnel. However, FUNDACION DE DESARROLLO COMUNAL DE PUERTO RICO, INC. (FUNDESCO) has already contracted capable personnel to assist in the finance department to comply with financial reports. FUNDACION DE DESARROLLO COMUNAL DE PUERTO RICO, INC. (FUNDESCO) will conduct a comprehensive assessment of the technical training needs of the identified personnel. Evaluate their current knowledge and skill levels related to reporting requirements, accounting principles, and compliance regulations. Also, FUNDACION DE DESARROLLO COMUNAL DE PUERTO RICO, INC. (FUNDESCO) will determine the most effective delivery method for the training program, considering the learning references and availability of personnel. Options may include: • In-person workshops or seminars led by subject matter experts. • Online courses or virtual training sessions accessible remotely. • Self-paced learning modules supplemented with instructional materials and resources. Implementing this corrective action plan focused on technical training for personnel responsible for reporting requirements, FUNDACION DE DESARROLLO COMUNAL DE PUERTO RICO, INC. (FUNDESCO) can enhance reporting accuracy, compliance, and overall effectiveness.

Context: The School Corporation was required to submit two Annual Data Reports to the Indiana Department of Education (IDOE) during the audit period to meet federal reporting requirements for ESSER grant awards. We noted that the ESSER II amount reported on the Year 3 report ($572,289) did not agree to the underlying expenditure records ($558,956) for the period of July 1, 2021 through June 30, 2022. Additionally, we noted that the ESSER I, ESSER II, and ESSER III amounts reported on the Year 4 report ($105,506, $510,158, and $1,156,254, respectively) did not agree to the underlying expenditure records ($138,662, $316,236, and $1,158,054, respectively) for the period of July 1, 2022 through June 30, 2023. Contact Person Responsible for Corrective Action: David Rowe, Business Manager Contact Phone Number: 765-298-6505 Views of Responsible Official: We concur with the finding, while noting that all expenditures and revenue from reimbursements balance within our system. Description of Corrective Action Plan: Verify that all expenditure account numbers match those utilized by AFR and Gateway reporting. Anticipated Completion Date: Begin immediately, ongoing.

Information on the federal program: Subject: Education Stabilization Fund (ESSER) – Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S425U200013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Context: The School Corporation was required to submit two Annual Data Reports to the Indiana Department of Education (IDOE) during the audit period to meet federal reporting requirements for ESSER grant awards. We noted that the ESSER II and ESSER III amounts reported on the Year 3 report ($397,392 and $294,138, respectively) did not agree to the underlying expenditure records ($498,259 and $1,509,413, respectively, for the period of July 1, 2021 through June 30, 2022). Additionally, we noted that the ESSER II and ESSER III amounts reported on the Year 4 report ($400,501 and $294,129, respectively) did not agree to the underlying expenditure records ($412,324 and $287,065, respectively, for the period of July 1, 2022 through June 30, 2023). We noted that the 195 number of Full-time equivalent (FTE) positions on September 30, 2023 on the second report did not agree to the underlying records supporting number of 274 Full-time equivalent (FTE) positions on September 30, 2023. Contact Person Responsible for Corrective Action: Dawn Ray Contact Phone Number: 812.988.6601 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We will have someone other than the preparer of the report perform a documented review prior to submission to validate the accuracy and completeness of the data submitted. Anticipated Completion Date: Immediately upon the completion of the audit.

The Corporation will have a secondary review process in place to assure the information and timeline are correct before submission.

Context: The School Corporation was required to submit two Annual Data Reports to the Indiana Department of Education (IDOE) during the audit period to meet federal reporting requirements for ESSER grant awards. We noted that the ESSER II and ESSER III amounts reported on the Year 3 report ($347,591 and $337,851 respectively) did not agree to the underlying expenditure records ($135,355 and $159,811 respectively). Additionally, we noted that the ESSER II amount reported on the Year 4 report ($233,093) did not agree to the underlying expenditure records ($267,310) of the School Corporation. Contact Person Responsible for Corrective Action: Vicki Jones Contact Phone Number: 765-793-4877 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Annual report data will be submitted with the requested information and will be verified with a sign-off by the Superintendent. Anticipated Completion Date: July 2025