Corrective Action Plans

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

Management's Response: Management concurs with the above finding and all documentation for annual reports will be held and kept as required moving forward. This will be implemented with the 2025 annual report.

Finding Number: 2024-001 Planned Corrective Action: Towpath Trail High School will comply with all federal grant compliance requirements – including reporting requirements and deadlines. Anticipated Completion Date: 2/14/2025 Responsible Contact Person: Dave Massa, Treasurer

As part of the 2023-2024 FY audit, there was a finding of non-compliance on financial reporting for a late filing. The corrective action plan is to implement new policies to ensure timely financial compliance with all grant requirements. For questions, please contact Katie Harris, the Director of Finance. The board plans to enact these new policies as of June 30th, 2025.

2024-001 Investments for Public Works and Economic Development Facilities – Assistance Listing No. 11.300 Recommendation: The College should implement formal review procedures to document review and approvals over required reports in addition to procedures to ensure reports are being submitted timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Routine communication between program directors and accounting staff will include discussion of reporting timeline in order to ensure timely submission. The Finance Department will review and approve required reports that are prepared by grant program directors. Name(s) of the contact person(s) responsible for corrective action: Jacob Wheeler, Chief Financial Officer Planned completion date for corrective action plan: February 28, 2025.

Corrective Action: Management will continue to stress the importance of following the detailed procedures for preparation and review of the SEFA. The SEFA checklist is updated to include a thorough review of expenditure details to ensure no prior-year expenses are reported. Responsibility for compiling the SEFA was assigned to a Senior Program Accounting Manager who is tasked with assuring the schedule and all the support reconciliation are complete and accurate. Both the Director of Program Accounting and the Executive Director of Finance/Controller will review the SEFA for completeness, accuracy, and compliance with CFR Section §200.510(b). Estimated completion date: June 30, 2025 Individual Responsible for Corrective Action Plan: Contact: Reginald Gregory Title: Executive Director/Controller Phone Number: 202-772-4300

FINDING 2024-003 Subject: COVID-19 - Education Stabilization Fund - Reporting 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 Condition: An effective internal control system was not in place at the School District in order to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirements. Context: The School Corporation had not designed nor implemented a system of internal control to ensure that the annual Elementary and Secondary School Emergency Relief (ESSER) annual Data Collection reports (Reports) were complete and accurately submitted. The reports were prepared and submitted in JotForm, the online application used by the Indiana Department of Education to collect information, without an oversight or secondary review process in 2 place to prevent, or detect and correct, errors. During tie out of the Year 3 report, a variance between the underlying records and reported expenditures of $187,649 was noted due to the lack of effective controls surrounding annual data reporting. 84.425U expenditures submitted within the Year 3 report were overstated by $187,649. Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Management will implement a formal review process over data reporting to ensure compliance with reporting requirements for federal awards. A Grant Coordinator has been hired and is already in place. Both the Grant Coordinator and Treasurer will review and sign off of required reporting and ensure it is completed in a timely manner. Responsible Party and Timeline for Completion: Andrew Grismore - Grant Coordinator and Moriah Crane - Treasurer will be responsible. These corrective measures are already in place.

2024 – 003B – Reporting Grantor: Department of Health and Human Services Passthrough Agency: N/A Program Name: Community Project Funding/Congressionally Directed Spending - Construction Award Name: Congressional Directives Award Year: 2024 Award Number: 6 CE1HS47194-01-10 Assistance Listing Number: 93.493 The Alliance management acknowledges that the Federal Financial Report (FFR) for the Congressional Directives award reporting period ending August 31, 2023 was filed late. The form was filed four business days after the due date. Through the date of this FFR filing, the Alliance had not drawn down any funds on this grant and the FFR was a $0 filing. The Alliance is up to date and in compliance with all FFR filings under the grant.

Response: Management agrees with the finding and acknowledges that a significant deficiency was identified related to report submission delay. To prevent this issue from recurring, we are implementing several corrective actions. These include establishing a stricter communication schedule with Post Award Administrators to ensure timely submission of reports and strengthening of our internal monitoring procedures by tracking submission deadlines more closely. Contact person responsible for corrective action: Lynne Duong, Post Award & Compliance Manager Anticipated completion date: December 31, 2024

Reference Number: 2023-010 Finding: Improve Controls and Compliance with Reporting Name of Contact Person: Lorina Esposito Corrective Active Plan: In the past year, the City has fully staffed the division of housing and community development which has led to the successful submission of the 2024 CAPER. The staff worked diligently to find all required data for the report and participated in training courses to prepare for future CAPERs. Proposed Completion Date: 3/31/26

Reference Number: 2023-008 Finding: Improve Controls and Compliance with Reporting Name of Contact Person: Christine Chamberland Corrective Active Plan: The City will develop and implement formal written procedures for preparing, submitting, and retaining all required quarterly performance and evaluation reports in compliance with program requirements. Designated staff will be responsible for tracking reporting deadlines, ensuring timely submissions, and maintaining thorough documentation of all reports. Management will conduct regular reviews to monitor compliance and address any deficiencies promptly. Proposed Completion Date: 6/30/26

Finding Number: 2023-002 Planned Corrective Action: City Auditor has confirmed the ARPA 3/31/24 and 3/31/25 Project and Expenditure Reports submitted agree to City Accounting records. Anticipated Completion Date: July 3, 2025 Responsible Contact Person: City Auditor Sherri Hess