Corrective Action Plans

FINDING 2023-003 Finding Subject: Education Stabilization Reporting Summary of Finding: During the audit period the School Corporation submitted two ESSER I reports, two ESSERI II reports and two ESSER III reports for a total of six reports. The reports were prepared and submitted by the Director of Finance without a documented oversight or review process. In addition, four of the six annual data reports were not supported by the School Corporation’s records. The financial information provided did not agree to the data submitted; therefore, we could not determine the accuracy of the annual data reports. Contact Person Responsible for Corrective Action: Camden Parkhurst Contact Person Phone Number and Email Address: 765-457-8101 camden.parkhurst@nwsc.k12.in.us View of Responsible Official: We concur with the finding. The submissions referenced without proper documentation were submitted by the previous CFO. The current finance staff is unable to locate any supporting documentation regarding those submissions. There is a reimbursement request internal controls document that was signed by both the CFO and Superintendent, but here is no supporting documentation to accompany it. Description of Corrective Action Plan: The current Director of Finance and finance team have attached all supporting documentation from the financial software to their submissions along with an internal controls document signed by the Director of Finance and Superintendent. The corporation is actively working with the Department of Education to amend when it believes to be some errors in the prior submissions as well. Anticipated Completion Date: August 2024

FINDING 2023-005 Finding Subject: COVID-19 - Education Stabilization Fund - Reporting Summary of Finding: Condition and Context The School Corporation had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance. The School Corporation was required to submit an annual data report to the Indiana Department of Education (IDOE) via JotForm, a form/report builder. Data to be submitted included, but was not limited to, current period expenditures, prior period expenditures, and expenditures per activity. During the audit period the School Corporation submitted two ESSER I reports, two ESSER II reports and two ESSER III reports, for a total of six reports. The annual data reports were to be prepared and submitted by the School Principal and reviewed by the Executive Business Director; however, no evidence of this review or oversight process could be provided. As such the annual data reports were prepared and submitted to IDOE without an oversight or review process to prevent or detect and correct errors. In addition, five of the six reports submitted during the audit period were not supported by the School Corporation’s records. The following errors were identified:  The ESSER I, Year 2 report, which had an applicable reporting period of October 1, 2020 through June 30, 201, reported $534,761 in expenditures. However, actual expenditures for the applicable reporting period totaled $478,883.  The ESSER 1, Year 3 report which had an applicable reporting period of July 1, 2021 to June 30, 2022, reported $0 in expenditures. However, actual expenditures for the applicable reporting period totaled $243,814.67.  The ESSER II, Year 1 report, which had an applicable reporting period of July 1, 2020 to June 30, 2021, reported $733 in expenditures. However, actual expenditures for the applicable reporting period totaled $322,539.  The ESSER II, Year 2 report, which had an applicable reporting period of July 1, 2021 to June 30, 2022, reported $0 in expenditures. However, actual expenditures for the applicable reporting period totaled $276,642.  The ESSER III, Year 2 report, which had an applicable reporting period of July 1, 2021 to June 30, 2022, reported $0 in expenditures. However, actual expenditures for the applicable reporting period totaled $1,315,208. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The school corporation will revise job descriptions to clearly identify segregation of duties for Federal Fund Coordinators, employees responsible for calculating accurate disbursement reports and reimbursement requests. Detailed expenditure reports will be generated for end of year reporting with the Accounting Specialist, Accounts Payable Coordinator and the Executive Director of Business Services completing a final review process providing signatures indicating review and accuracy before filing. Anticipated Completion Date: March 1, 2024.

Finding 2023 - 002 Reporting - Native Hawaiian Education – Assistance Listing 84.362A KA concurs with the Recommendation. In conjunction with the search and seating of a permanent School Director (in progress), the Reconstituted Governing Board (“RGB”) as a whole, intends to prioritize the: A) Updating and/or creation of policies (that either don’t exist or aren’t documented); B) Cascading policies to related processes and procedures; and C) Training appropriate staff; and D) Monitoring the practices, to ensure the day to day practices are consistent with and aligned to the policies, processes and procedures. Policy Focus: Grant Management (e.g., accounting, reporting, budgeting, compliance, authorized procurement, inventory, federal draws, federal progress report, communication with federal program office, utilization of curriculum, supplies, equipment in compliance with the specific grant). Any questions regarding this response may be directed to Aumoana Kanakaole-Lato, Reconstituted Governing Board Chair at aumoana.kanakaole@kamalaniacademy.org.

Since the late submissions in November 2022, DRNY has ensured that the SF425s were submitted in accordance with the due dates per the Grant Award notices (GANs). Further DRNY has now calendared within outlook all the grant reporting required for awards for the next year and created an excel tracking sheet of all the remaining reporting required for current grants. Both the Executive Director and the CFO have access to this excel tracking and the calendar invites. As new GANs are received, the CFO will calendar in the tracking document all reporting requirements and within outlook send out invites each calendar year and copy the Executive Director on those calendar invites. CFO will confirm to Executive Director as these reports are complete and document in the excel tracker. Danielle Myers, CFO, is responsible for the resolution of this corrective action plan by 3/1/2024.

Condition: For the annual report covering January 1, 2022 through December 31, 2022, the indirect cost recovery/facility and administrative costs charged on the grants of the section (a)(1) institutional portion were incorrect based on supporting documentation provided by the University. In addition, for the fourth quarter 2022 (quarter ending December 31, 2022) and the first quarter 2023 (quarter ending March 31, 2023) institutional portion reports, the University reported the full amount of section (a)(1) student portion of HEERF awarded to the University on the section (a)(3) line instead of the section (a)(1) student funds awarded line, when the amount on the section (a)(3) line should have been the total Fund for the Improvement of Postsecondary Education (FIPSE) funding awarded to the University. Also, the first quarter 2023 (quarter ending March 31, 2023) institutional portion report was submitted to the Department of Education and uploaded to the University's website more than 10 days after the end of the quarter. Corrective Action: The University has updated their procedure for preparing and reviewing the required reports and has established a team from the finance department to discuss issues that arise. The team will handle the identified discrepancies through their resolution. The team will meet at least monthly, and as requested by the Senior Accountant of Grants or the Director of Finance and Accounting (DFA). The team is receiving training on procedures, guidelines, and terminology to ensure accuracy on completed reports to ensure compliance. The updated procedure is that the Senior Accountant of Grants will prepare the quarterly and annual reports based on data provided in the accounting system and from the Office of Financial Aid and assure that the reported data ties to the University’s records. The completed reports will be reviewed by the Director of Finance and Accounting. When needed, the finance team will meet to handle apparent discrepancies. Approved reports will be returned by the DFA to the Senior Accountant who will then post the reports for public viewing and submit a copy to the funder. Person Responsible For Corrective Action: Cedric Lewis, Director of Finance & Accounting Anticipated Completion Date: March 31, 2024

FINDING 2023-005 Finding Subject: Education Stabilization Fund - Reporting Summary of Finding: The School Corporation had not properly designed or implemented a system of internal controls that would likely be effective in preventing, or detecting and correcting, noncompliance. The School Corporation was required to submit annual data reports to the Indiana Department of Education (IDOE) via JotForm, a form/report builder. Data to be submitted included, but was not limited to, current period expenditures, prior period expenditures, and expenditures per activity. During the audit period the School Corporation submitted two ESSER I reports, two ESSER II reports and two ESSER III reports, for a total of six reports. The annual data reports were complied, prepared and submitted by the Assistant Superintendent and reviewed by the Treasurer prior to submission. However, this review process was not effective and did not detect and allow correction of errors prior to submission. All six of the submitted reports were selected for testing. Four of the reports were not supported by the unit's records. The financial information provided did not agree to the data submitted in the reports; therefore, we could not determine the accuracy of the reports. The lack of controls was systematic throughout the audit period. The noncompliance was isolated to the four reports identified above. The auditors recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure reports are supported by the ledgers or reports used to complete the report Contact Person Responsible for Corrective Action: Rolland Abraham Contact Phone Number and Email Address: 765-584-1401, rabraham@randolphcentral.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The School Corporation is required to submit annual data reports to the Indiana Department of Education (IDOE) via JotForm, a form/report builder. Data to be submitted includes, but is not limited to, current period expenditures, prior period expenditures, and expenditures per activity. The annual data reports will be complied/prepared by the Treasurer and the Assistant Superintendent to ensure the reports are supported by the corporation’s financial data. The JotForm will be reviewed by the Superintendent prior to submission. Anticipated Completion Date: 2/21/2024

Finding 2023-002 - Reporting Transitions in operations positions over the course of the first years of ESSER distributions and reimbursements, combined with the first round of data collection resulted in discrepancies between state reports and internal records. A thorough review of past reports and data will be completed to identify errors by the School Principal (Jennica Adkins) and future reports will be completed in conjunction with Bookkeeping Plus (Tina Spencer) to ensure accuracy. This will be completed before the next round of ESSER reports due April 2024.

FINDING 2023-006 Finding Subject: Education Stabilization Fund - Reporting Summary of Finding: Management had not developed or implemented a system of internal control that would have ensured compliance with the grant agreement and the Reporting compliance requirement. The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Reporting compliance requirement could result in the loss of future federal funds to the School Corporation. We recommended that the School Corporation's management establish internal controls to ensure compliance and comply with the grant agreement and the Reporting compliance requirement. Contact Person Responsible for Corrective Action: Andrea Miller Contact Phone Number and Email Address: 765-564-2100, millera@delphi.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The treasurer will prepare all required reports, and the grant administrator will verify the information on the reports. Reports will be signed and dated by both parties. Anticipated Completion Date: July 2024

Finding 2023‐002 Finding Subject: COVID‐19 ‐ Education Stabilization Fund ‐ Reporting Summary of Finding: The School Corporation was required to submit an annual data report to the Indiana Department of Education (IDOE) via JotForm, a form/report builder. Data to be submitted included, but was not limited to, current period expenditures, prior period expenditures, and expenditures per activity. The School Corporation submitted two reports during the audit period; however, a single employee prepared and submitted the reports without evidence of a review or oversight process in place to prevent or detect and correct errors for the first report submission. Additionally, for the ESSER I Year 2 reporting, the ‘Total Mandatory Subgrant Amount Expended in Current Reporting Period’ was not supported by the School Corporation's records. Actual expenditures from a provided report did not agree to the amount submitted for the Annual Performance Reporting. The key line item ‘Total Mandatory Subgrant Amount Expended in Current Reporting Period’ for the ESSER I Year 2 report was determined to be overstated by $80,342. Contact Person Responsible for Corrective Action: Whitney Kuszmaul, District Treasurer & Tiffany Grant, Grant Coordinator Contact Phone Number and Email Address: (765) 342‐6641 Whitney.Kuszmaul@msdmartinsville.org & Tiffany.Grant@msdmartinsville.org Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Grant Coordinator works to collect the data from a couple different sources. The staff report information comes from our Payroll/HR department, the CE information comes from our Reporting Specialist and the financial data comes from District Treasurer. The Grant Coordinator requests a detailed report for the appropriate period and break down the detailed report by project/report categories. All of this information is then recorded in the DOE data sheet and is reviewed and tied back to the detailed reports provided by the District Treasurer. After review, the Grant Coordinator and the District Treasurer initial/sign off on the DOE data sheets. The Jot Form confirmation is retained with the DOE data sheets and supporting reports/documentation. Anticipated Completion Date: February 2024

REPORTING Department of Environmental Protection (DEP) Assistance Listing Number 15.252 Effective March 2024, DEP will implement the following steps to correct the finding: 1. Review the Office of Surface Mining Federal Assistance Manual for information and instructions in regard to preparing the required financial reports for periodic and annual submissions. The information obtained from the Federal Assistance Manual will be compared to 2 CFR 200.328 and 329 to ensure all required information is included in the financial reports. 2. Review the Federal Notice of Grant Award documents to ensure that reporting period dates and the submitted reports reconcile and are in agreement. 3. Create and implement written narrative that agrees with the requirements set forth in the Federal Assistance Manual. 4. Develop and implement standard operating procedures to ensure timely, accurate reporting that involves a review and approval process prior to submission. 5. Create a checklist of required items, and signature lines to show that reviews/approvals have taken place.

FINDING 2023-006 Subject: COVID-19 – Education Stabilization Fund – Reporting Summary of Finding: The School Corporation did not submit annual reports in a timely manner during the first year of the audit period. Reimbursement requests included invoices which had been reimbursed previously and some request did not agree with supporting documentation. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure reports are submitted timely and supporting documentation is used and retained for reimbursement requests. Contact Person Responsible for Corrective Action: Casey Howard Contact Phone Number: 574-842-3364 x806 Views of the Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Reporting – The Treasurer and Deputy Treasurer will review and approve all grant reporting with Komputrol reports and grant approval. All deadlines will be submitted prior to due dates. The Superintendent, Treasurer, Deputy-Treasurer and/or Grant Writer will review all grant reimbursement requests prior to submission for accuracy. Anticipated Completion Date: Completed March 2023 – February 2024 INDIANA STATE

FINDING 2023-002 Finding Subject: Subject: COVID-19 - Education Stabilization Fund - Reporting Summary of Finding: Reports submitted were not substantiated by the ledgers. Contact Person Responsible for Corrective Action: Kellie Romer (Corporation Treasurer/Finance Director) Contact Phone Number and Email Address: 765-653-9771 Ext. 1010, kromer@greencastle.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: The school corporation will establish a proper system for internal controls and develop procedures to ensure reports are supported by the financial records. Anticipated Completion Date: Immediately 2/8/2024

FINDING 2023-002 Finding Subject: COVID-19 – Education Stabilization Fund - Reporting Summary of Finding: The School Corporation had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance. The School Corporation was required to submit annual data reports to the Indiana Department of Education (IDOE) via JotForm, a form/report builder. Data to be submitted included, but was not limited to, current period expenditures, prior period expenditures, and expenditures per activity. During the audit period the School Corporation submitted two ESSER I reports, two ESSER II reports and two ESSER III reports, for a total of six reports. The annual data reports were complied, prepared and submitted by the Assistant Superintendent without an oversight or review process in place to prevent, or detect and correct, errors. Furthermore, the reported data on two of the reports could not be traced back to records that accumulate or summarize the data; therefore, the accuracy and completeness of the reports could not be verified. Contact Person Responsible for Corrective Action: Jim Diagostino, Superintendent, and Lori Bennett, Treasurer Contact Phone Number: 317-539-9200 Views of Responsible Officials: We agree with the finding. Description of Corrective Action Plan: The Superintendent, or designee, will prepare the annual data reports to be reported to the IDOE by using records that accumulate or summarize the data. Prior to the submission of the reports, the Treasurer will review the records and annual data report. The Treasurer will initial and date a hard copy of the report to ensure accuracy and completeness. Anticipated Completion Date: March 31, 2024

The University filed four quarterly HEERF reports for the year that accurately reflected the spending and accounting of federal funds. The report in question is the annual report, which, by its design (it cannot be saved prior to submission, and the only way to print it is to print a screen shot of each of the 48 pages) makes review before submission extremely difficult. There were literally hundreds of entries in this report, and there were three errors, each of which reflected information that was reported accurately in the quarterly reports posted on the University’s website. Despite the unfortunate design constraints, the University will endeavor to identify a practical way to conduct a review of the annual report before submission next spring. Anticipated Completion Date: Continuing Responsible Contact Person: Eugene L. Munin

Corrective Action Planned: This was first brought to the Authority’s attention in the current year. The Authority is working towards submitting appropriate reports. Anticipated Completion Date: Ongoing Contact Person Responsible: Jennie Weary, Treasurer/Secretary

Identifying Number: 2023-002 Finding: For 2 out of the 8 reports selected for the COVID-19 Coronavirus State and Local Fiscal Recovery Funds program, the reports were not submitted within the required timeframe. For 3 out of the 8 reports selected, there was no evidence of submission. For 2 out of the 5 reports selected for the Transitional Living for Homeless Youth program, the reports were not submitted within the required timeframe. For 2 out of the 5 reports selected for the Basic Grant program, the reports were not submitted within the required timeframe. Corrective Action Plan for Audit Finding 2023-002: Calendar reminders will be created for both financial and performance reports. Director Finance & Business will follow up with the program for the status of performance report submissions. Chief of Staff, The Relatives will maintain a PDF of performance report submission emails. Responsible for Corrective Action Plan: Julie Pool, Director of Finance & Business, Program Director, Youth Focus and Chief of Staff, The Relatives

2023-006 – Reporting – Material Weakness in Internal Controls over Compliance and Material Noncompliance Recommendation: The auditors recommend the University create an internal control to obtain reporting requirements for each award received by the University. The auditors recommend a standard process be implemented for each award to track the due dates to ensure they are completed timely. Planned corrective actions: The university will create an internal control policy to ensure that it has the necessary paperwork for each award it receives. This will be the routine procedure followed for every award in order to keep track of the deadlines and finish on time. Name of Responsible Party: 1. Grant P.I’s 2. Terri Slack, Fiscal Officer 3. Yolanda Maltos, Grant Accountant 4. Melissa Hill, Provost 5. Alysia Stevens, Controller 6. VP of Administration, CFO 7. Dr. Andrew Sund, President Anticipated completion date: 6/30/2024

2023-004 – Reporting – Material Weakness in Internal Controls over Compliance and Material Noncompliance Recommendation: The auditors recommend the University update previously posted reports to accurately reflect the actual expenditures during the time period covered by the report. The auditors recommend each report be posted to the University’s website on separate documents by quarter and should not be cumulative. The auditors also recommend the University implement a process to ensure the submission dates and publication dates are maintained to ensure compliance with the reporting due dates and that the data submitted in the reports is properly supported by institutional records. Lastly, the auditors recommend each report be properly reviewed by someone other than the preparer and that the review be documented with a signature and date. Planned corrective actions: Heritage University will update the previously posted reports to accurately reflect the actual expenditures during FY21, FY22 & FY23 on the University’s website by quarter. Going further it will be the Grant accountant’s practice that the submission dates and publication dates are maintained and documented with reporting due dates. All documents will be reviewed and approved by the VP of Administration/CFO with dated signatures. Name of Responsible Party: 1. Yolanda Maltos, Grant Accountant 2. Alysia Stevens, Controller 3. VP of Administration/CFO 4. Dr. Andrew Sund, President Anticipated completion date: 6/30/2024

Planned Corrective Action: We agree with the auditor’s comments, and the following action will be taken to improve the condition. Director Will Triplett and Manager Clarissa Lostaunau will implement a written policy included in the HSP Policy and Procedure Manual outlining accurate process and completion of the HSP 14 monthly reporting. The manual will include written steps on obtaining, verifying and storing all backup documentation for all data on the HSP 14. The team will also include a verification process before the submission of the report where two employees approve the monthly report as an internal control, one being from management. This will be completed by December 31, 2023 and led by Director of Transformational Services, Will Triplett.

Donovan CPAs 9292 N. Meridian St, Ste 150 Indianapolis, IN. 46260 Attn: Jacob Stephenson Re: Response to Audit - 7/1/22 - 6/30/23 Single Audit December 21, 2023 Regarding Finding 2023-001 Reporting Significant Deficiency occurred as a result of inadequate controls to ensure accurate reporting to eh DOE. Correct 1.Regarding Finding 2023-001 Reporting Significant Deficiency occurred as a result of inadequate controls to ensure accurate reporting to the DOE. Corrective Action Plan as Follows: a. Deborah Czmiel (CFO) will request grant reports which include total expenses for each federal grant from BPI for the reporting period. b. Deborah Czmiel (CFO), Deborah Snedden (Superintendent) and Jeff Wood (Asst Superintendent) will compare grant reports from BPI to financial statements. Any discrepancies will be addressed and resolved by Deborah Czmiel (CFO) prior to submission of final report. c. Deborah Czmiel (CFO) will complete and submit the final reports, after the expense totals have been confirmed and reconciled. With collaboration of the administrative team and the proper checks and balances as identified above any future inaccurate submissions will not occur. Respectfully, Deborah s. Czmiel CFO/Business Manager

Failure to Properly Track Grant Expenditures Recommendation: We recommend that the Clinic maintains an effort to track federal and state funding and expenditures separate from regular program expenditures, inquiring of granting agencies if needed. Action Taken: Management is now properly tracking grant expenditures and can accurately state quantities of grant expenditures.

Finding 2023-002 Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing: 21.027 Federal Agency: U.S. Department of the Treasury Passed-through: N/A Award Year: 2022-2023 Compliance Requirement: Reporting Grant Award Number: Applies to all awards with findings and no specific grant award. Type of Finding: Material Instance of Noncompliance, Material Weakness in Internal Controls over Compliance Management’s Response: We concur. Views of Responsible Officials and Corrective Action: Management agrees with the finding and understands the importance of properly reporting federal and will institute a multi-step review system before such reporting is finalized and submitted. Name of Responsible Person: Terri Willoughby, CFO Name of Department Contact: Finance Projected Implementation Date: January 1, 2024

Finding #2023-003 - Major Federal Award Finding - Reporting Significant Deficiency-in Internal Controls over Compliance Corrective Action Plan: Procedure(s) were drafted covering data collection, storage, and reporting of HEERF data, including setting alerts to comply with the reporting due dates, however, the VP of Finance did not adhere to them. The VP of Finance will meet with the Executive Vice President to set up an accountability structure to ensure that quarterly reports are reviewed and filed on or before the due date. A revised annual report for calendar 2022 will be submitted to the Department of Education.

The University filed four quarterly HEERF reports for the year that accurately reflected the spending and accounting of federal funds. The report in question is the annual report, which, by its design (it cannot be saved prior to submission, and the only way to print it is to print a screen shot of each of the 48 pages) makes review before submission extremely difficult. There were literally hundreds of entries in this report, and there were three errors, each of which reflected information that was reported accurately in the quarterly reports posted on the University’s website. Despite the unfortunate design constraints, the University will endeavor to identify a practical way to conduct a review of the annual report before submission next spring. Anticipated Completion Date: Continuing Responsible Contact Person: Eugene L. Munin

The College did not report total expenditures on the quarterly reports for the ALN 84.425M (SIP). The College will revise procedures to ensure amounts reported on the reports are accurate.