Corrective Action Plans

FINDING 2023-001 Finding Subject: COVID-19 - Education Stabilization Fund - Reporting Summary of Finding: The annual reports provided for audit did not tie back to supporting records. One annual report, ESSER III Year 2, was not filed. Contact Person Responsible for Corrective Action: Superintendent Contact Phone Number and Email Address: (812) 649-2591 / brad.schneider@sspencer.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: In the future, the School Corporation will ensure all required annual reports for grant reporting are submitted and supported by school records. The required annual reports will be completed by the Corporation Treasurer and reviewed and approved by another knowledgeable employee for accuracy and completeness. Anticipated Completion Date: June 2024

FINDING 2023-010 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. Additionally, the ESSER I, Year 2, ESSER I, Year 3, ESSER II, Year 1, ESSER III, Year 1, and ESSER III, Year 2 reports were not supported by the School Corporation's records. Contact Person Responsible for Corrective Action: Todd Balmer, Assistant Superintendent/CFO and Allison Vanover, Corporation Treasurer Contact Phone Number and Email Address: 812-246-3375 tbalmer@scsc.school avanover@scsc.school Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We are currently meeting with a Grants Management Consultant that will be working with us on how to properly complete the ESSER reports to ensure submission moving forward is accurate. Prior to submission, the grants person will review to ensure the report is complete and the information is correct. We will also send the reports to the consultant for review. Anticipated Completion Date: April 2024

FINDING 2023-009 Finding Subject: COVID -19 - Education Stabilization Fund – Cash Management Summary of Finding: The School Corporation had not properly designed or implemented a system of internal control, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting noncompliance related to the Cash Management compliance requirement. Reimbursement requests for the programs were prepared by an employee and reviewed by another employee. While the School Corporation did have a process in place to review and approve reimbursement requests, not all reimbursement requests were traceable to the fund ledger and no audit evidence was provided to indicate the reviewer verified disbursements to the School Corporation records. Three of five reimbursement requests filed during the audit period were not traceable to the Schools Corporation’s fund ledger. Due to the lack of supporting documentation it was not possible to determine if grant payments were reimbursements of expenditures or advance payment of grant funds. The lack of internal controls and noncompliance were systemic issues throughout the audit period. The noncompliance was isolated to three of the five reimbursement requests filed during the audit period. Contact Person Responsible for Corrective Action: Todd Balmer, Assistant Superintendent/CFO and Allison Vanover, Corporation Treasurer Contact Phone Number and Email Address: 812-246-3375 tbalmer@scsc.school avanover@scsc.school Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The same process will be in place to review and approve grant reimbursements. The Deputy Treasurer will verify with the person preparing the reimbursement that the proper accounting information is on the receipt and that it is then receipted into the correct account in the FMS System and sign off. The Corporation Treasurer will review all receipts and be the second signature. Each month the accounts will be checked for accuracy by the grants person and the Corporation Treasurer will again be the second check for accuracy. The grant person will verify that the reimbursements of expenditures or advance payments are clearly marked and accounted for in the FMS System and sign off. The Corporation Treasurer will be the second signature. When reimbursements are prepared, these entries will also be reviewed. Anticipated Completion Date: March 2024

􀀃 Finding􀀃2023􀍲002􀀃 􀀃 Finding􀀃Subject:􀀃COVID􀍲19􀀃–􀀃Education􀀃Stabilization􀀃Fund􀀃􀍲􀀃Reporting􀀃 Summary􀀃of􀀃Finding:􀀃Internal􀀃Controls􀀃were􀀃not􀀃effective􀀃and􀀃did􀀃not􀀃prevent,􀀃nor􀀃allow􀀃for􀀃 detection􀀃and􀀃correction􀀃of􀀃errors􀀃prior􀀃to􀀃submission.􀀃 Contact􀀃Person􀀃Responsible􀀃for􀀃Corrective􀀃Action:􀀃Director􀀃of􀀃Business􀀃 Contact􀀃Phone􀀃Number􀀃and􀀃Email􀀃Address:􀀃(260)431􀍲2030,􀀃msnyder@sacs.k12.in.us􀀃 􀀃 Views􀀃of􀀃Responsible􀀃Official:􀀃We􀀃concur􀀃with􀀃the􀀃finding.􀀃 Description􀀃of􀀃Corrective􀀃Action􀀃Plan:􀀃 Once􀀃the􀀃Deputy􀀃Treasurer􀀃completes􀀃the􀀃report,􀀃they􀀃will􀀃give􀀃the􀀃report􀀃and􀀃all􀀃 supporting􀀃documentation􀀃to􀀃the􀀃Asst.􀀃Director􀀃of􀀃Business􀀃for􀀃review.􀀃􀀃After􀀃thorough􀀃 review,􀀃the􀀃report􀀃and􀀃supporting􀀃documentation􀀃will􀀃be􀀃signed􀀃by􀀃both􀀃the􀀃Asst.􀀃Director􀀃 of􀀃Business􀀃and􀀃the􀀃Deputy􀀃Treasurer.􀀃􀀃Once􀀃reviewed,􀀃the􀀃report􀀃and􀀃supporting􀀃 documentation􀀃will􀀃be􀀃given􀀃to􀀃the􀀃Director􀀃of􀀃Business􀀃for􀀃final􀀃approval􀀃and􀀃signature.􀀃􀀃􀀃 Anticipated􀀃Completion􀀃Date:􀀃3/18/24􀀃

FINDING 2023-002 Finding Subject: COVID-19 – Education Stabilization Fund – Reporting Summary of Finding: ESSER III, Year 2 report contained material errors in the amounts reported Contact Person Responsible for Corrective Action: Tanya Pearson Contact Phone Number and Email Address: 765-522-6218 tpearson@nputnam.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We will have one person complete the ESSER report and one person review the ESSER report for accuracy. Anticipated Completion Date: Immediately with the next ESSER report submission

FINDING 2023-003 Finding Subject: Covid-19 Education Stabilization Fund- Reporting Summary of Finding: Annual Data Report 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. The School Corporation was required to submit six annual data reports during the audit period. None of the annual data reports were submitted. Upon inquiry of the School Corporation to determine why the reports were not submitted, the School Corporation explained they had interpreted the reports to be final reports submitted upon completion of the grant not annual reports of expenditures. Reimbursement Requests To gain an understanding of how the School Corporation spent their Education Stabilization Fund award, all reimbursement requests submitted to the Indiana Department of Education (IDOE) were requested. Five of the ten reimbursement requests submitted to IDOE could not be located. As such, we determined reimbursement requests for the audit period should be further tested. The School Corporation’s process was to complete reimbursement requests on a periodic basis to obtain reimbursement for expenditures paid. Although the reimbursement requests were prepared by the Treasurer utilizing various ledger reports and were reviewed by a second knowledgeable employee; the process did not prevent, or detect and correct, errors. Of the ten reimbursement requests received, as noted above, five could not be provided for audit. Therefore, we were unable to substantiate the expenses reimbursed by those requests or if the requests were mathematically accurate or fairly presented. The remaining five reimbursement requests were tested without issue. Contact Person Responsible for Corrective Action: Andrew Schoff, Business Manager Contact Phone Number: 219-767-2263 Ext 1003 SOUTH CENTRAL COMMUNITY SCHOOL CORPORATION 9808 S 600 W Union Mills, IN 46382 219-767-2263 or 219-733-2311 Fax 219-767-2260 INDIANA STATE BOARD OF ACCOUNTS 34 Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: Beginning March 2024 the Business Manager will submit Annual Data Reports for any Federal Grant issued when stated in the Grant contract. The Annual Data Report will be reviewed by the Superintendent for accuracy. Also, the Business Manager will request reimbursement timelier for Federal Grants collecting supporting documentation to ensure correct amounts are being requested. Documentation will be maintained with a copy of the submitted reimbursement requests to provide support for the amounts being requested. Anticipated Completion Date: These corrective actions will go into effect immediately and will be utilized with the March 31, 2024 for any Federal Grant reimbursement.

FINDING 2023‐004 Finding Subject: COVID‐19 Education Stabilization Fund ‐ Reporting Summary of Finding: Federal reporting lacked internal controls, resulting in errors on federal reporting. Contact Person Responsible for Corrective Action: Jill C. Mires Contact Phone Number and Email Address: 812‐883‐4437, jmires@salemschools.us Views of Responsible Officials: We concur with the findings. Description of Corrective Action Plan: Internal controls will be added to each federal report that is submitted. They will be reviewed by a second staff member, indicated by a signature and date. Accounting expense reports and any other supporting documentation used to complete the reports will be kept internally with the reports and used by the reviewer to verify the accuracy of the reports. Anticipated Completion Date: March 2024

FINDING 2023-004 Finding Subject: COVID 19 - Education Stabilization Fund - Reporting Summary of Finding: The School Corporation failed, due to the lack of internal controls, to ensure that the ESSER annual data reports were complete and accurate prior to submission and that the reports had sufficient oversight to prevent, or detect and correct, errors. Contact Person Responsible for Corrective Action: Carla Gambill Contact Phone Number and Email Address: 812-847-6020 ext. 1004 cgambill@lssc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Director of School Finance 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 Superintendent, or his or her designee, will review the records and annual data report. The Director of School Finance and the Superintendent, or his or her designee, will initial and date a hard copy of the report to ensure accuracy and completeness. Anticipated Completion Date: This Corrective Action Plan will be put in effect April 2024 or when the next annual data reports are prepared.

FINDING 2023-006 Finding Subject: COVID-19 Education Stabilization Fund - Reporting Summary of Finding: 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. After the annual data reports were prepared, they were reviewed by a second knowledgeable individual; however, this process did not allow for the prevention, or detection and correction of errors prior to submission. Due to the lack of effective internal controls, two of the six annual data reports were not supported by the School Corporation’s records. Contact Person Responsible for Corrective Action: Nancy Schroeder Contact Phone Number and Email Address: 765-932-3901 schroedern@rushville.k12.in.us Views of Responsible Officials: We concur with the finding. Explanation and Reasons for Disagreement: N/A Description of Corrective Action Plan: Information in the ESSER III Year 1 and Year 2 reports were entered into incorrectly. The Superintendent or Corporation Treasurer will review all ESSER reports with the Grant Coordinator, Nancy Schroeder, to ensure accuracy. Anticipated Completion Date: April 2024

FINDING 2023-005 Finding Subject:􀀃Title􀀃I􀀃Grants􀀃to􀀃Local􀀃Educational􀀃Agencies􀀃–􀀃Reporting􀀃 Summary of Finding: An􀀃effective􀀃internal􀀃control􀀃system􀀃was􀀃not􀀃in􀀃place􀀃at􀀃the􀀃School􀀃Corporation􀀃to􀀃ensure􀀃compliance􀀃with􀀃 requirements􀀃related􀀃to􀀃the􀀃grant􀀃agreement􀀃and􀀃the􀀃Reporting􀀃requirement.􀀃The􀀃School􀀃Corporation􀀃did􀀃not􀀃have􀀃 effective􀀃internal􀀃controls􀀃to􀀃ensure􀀃that􀀃reimbursement􀀃requests􀀃or􀀃final􀀃expenditure􀀃reports􀀃were􀀃properly􀀃 supported􀀃with􀀃documentation.􀀃 Contact Person Responsible for Corrective Action: Lela Simmons Contact Phone Number and Email Address: (219) 391- 4100, lesimmons@ecps.org Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: Internal controls and policies will be put in place to ensure all Title cash request will have three approvals before submitting the request to the State. The Federal clerk will prepare the request, the federal director we do second approval. The CFO will do final approval after review all documentation associated with the cash request. All will sign document. All title state reporting and back up documentation will be reviewed by the CFO and signed. Anticipated Completion Date:􀀃We􀀃anticipate􀀃having􀀃the􀀃above􀀃corrective􀀃action􀀃plan􀀃in􀀃place􀀃by􀀃September 30, 2024.

Type of Finding: Material weakness in internal control over compliance relating to inadequate documentation and controls in place to ensure costs are reasonable and intended for the program charged. Views of Responsible Officials: Management accepts the finding. Effective internal control over the documentation of secondary review of financial reports, timely filing, and disclosed demographics contained within the reports, which can be attributed to a lack of documentation of review and controls in place for submission of a report when responsible employee is out of office during the due date. Authorized personnel review was not documented, and a performance report was not filed timely and was filed with incorrect demographics. More thorough training of staff, along with careful supervisory review and documentation of review of report submissions prior to filing would likely have prevented these errors. Corrective action: A process for secondary review of all financial and programmatic reports will be developed in each region.

FINDING 2023-002 Finding Subject: COVID-19 - Education Stabilization Fund - Reporting Summary of Finding: There was not an effective oversight or review process in place to prevent, or detect and correct, errors regarding the annual data report submissions. The School Corporation’s records did not support the amounts reported for expenditures in either ESSER II annual data report. It was recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure all reports submitted on behalf of the Education Stabilization Fund program funds are supported by the School Corporation’s underlying accounting records. Contact Person Responsible for Corrective Action: Tim Armstrong Contact Phone Number and Email Address: 812.753.4230: tim.armstrong@sgibson.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Beginning with the annual data report submissions for these funds due in April 2024, the Assistant Superintendent will audit the reports as prepared by the Treasurer in order to ensure the spreadsheets are correct and reflect the financial statements’ of the school corporation. Anticipated Completion Date: 5 March 2024

FINDING 2023-005 Information on the federal program: Subject: Special Education Cluster (IDEA) - Reporting Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.027X, 84.173, 84.173X Federal Award Numbers and Years (or Other Identifying Numbers): 19611-022-PN01, 20611-022-PN01, 21611-022-PN01, 22611-022-PN01, 22611-022-ARP, 23611-022-PN01, 20619-022-PN01, 21619-022-PN01, 22619-022-PN01, 22619-022-ARP, 23619-022-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Qualified Opinion Condition: The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the reporting requirements. The Cooperative had not designed or implemented adequate policies or procedures to determine that requests for reimbursement were submitted accurately and agreed to supporting documentation. There was a documented oversight, review, and approval process in place; however, the Cooperative did not adequately ensure that proper procedures were followed. Context: The School Corporation is a member of the Greene-Sullivan Special Education Cooperative (Cooperative). During fiscal year 2021-2022, the Cooperative operated the special education programs and spent the federal money on behalf of all its members.  As the grant agreements were between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. However, there was inadequate oversight performed by the School Corporation in order to ensure compliance with the Reporting compliance requirement. The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the reporting requirements. The Cooperative had not designed or implemented adequate policies or procedures to determine that requests for reimbursement were submitted accurately and agreed to supporting documentation. There was a documented oversight, review, and approval process in place; however, the Cooperative did not adequately ensure that proper procedures were followed. For fiscal year 2022, 51 Reimbursement Reports were tested. 14 Reimbursement Reports could not be traced to unit ledgers for expenditures, and 21 Reports did not have appropriate supporting documentation. For fiscal year 2023, 23 Reimbursement Reports were tested. Three Reimbursements Report did not agree to supporting documentation, and key line items could not be verified. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and will take the following corrective action: 1 – Greene Sullivan Special Education Cooperative will implement a procedure that includes the requirement of proper documentation for all reimbursement requests, such as the detailed history report for each request submitted. The Director will then review each request prior to submission. Responsible party and timeline for completion: Chris Stitzle, Superintendent – April 1, 2024

FINDING 2023-007 Information on the federal program: Subject: Special Education Cluster (IDEA) - Reporting Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.027X, 84.173, 84.173X Federal Award Numbers: 19611-022-PN01, 20611-022-PN01, 21611-022-PN01, 22611-022-PN01, 22611-022-ARP, 23611-022-PN01, 20619-022-PN01, 21619-022-PN01, 22619-022-PN01, 22619-022-ARP, 23619-022-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Qualified Opinion Condition: The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the reporting requirements. The Cooperative had not designed or implemented adequate policies or procedures to determine that requests for reimbursement were submitted accurately and agreed to supporting documentation. There was a documented oversight, review, and approval process in place; however, the Cooperative did not adequately ensure that proper procedures were followed. Context: The School Corporation is a member of the Greene-Sullivan Special Education Cooperative (Cooperative). During fiscal year 2021-2022, the Cooperative operated the special education programs and spent the federal money on behalf of all its members. As the grant agreements were between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. However, there was inadequate oversight performed by the School Corporation in order to ensure compliance with the Reporting compliance requirement. The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the reporting requirements. The Cooperative had not designed or implemented adequate policies or procedures to determine that requests for reimbursement were submitted accurately and agreed to supporting documentation. There was a documented oversight, review, and approval process in place; however, the Cooperative did not adequately ensure that proper procedures were followed. For fiscal year 2022, 51 Reimbursement Reports were tested. 14 Reimbursement Reports could not be traced to unit ledgers for expenditures, and 21 Reports did not have appropriate supporting documentation. For fiscal year 2023, 23 Reimbursement Reports were tested. Three Reimbursements Report did not agree to supporting documentation, and key line items could not be verified. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and will take the following corrective action: 1 – Greene Sullivan Special Education Cooperative will implement a procedure that includes the requirement of proper documentation for all reimbursement requests, such as the detailed history report for each request submitted. The Director will then review each request prior to submission. Responsible party and timeline for completion: Mark A Baker, Superintendent Effective April 2024

FINDING 2023-003 Finding Subject: Education Stabilization Fund – Reporting Summary of Finding: An effective internal control system, which would include segregation of duties, was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the following compliance requirements: Reporting 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 by one employee without an oversight or review process in place to prevent, or detect and correct, errors. Additionally, for ESSER II, Year 1, annual report tested the School Corporation could provide supporting documentation that did not agree with the ESSER II, Year 1, annual report. The lack of internal controls was a systemic issue throughout the audit period. The noncompliance was isolated from ESSER 1I, Year 1 report. Contact Person Responsible for Corrective Action: Amber Rushton Contact Phone Number and Email Address: Phone Number: (765) 489-4543 Email: arushton@nettlecreek.k12.in.us Views of Responsible Officials: “We concur with the finding.” Description of Corrective Action Plan: The Business Manager will prepare annual reports for grants and the Director of Learning and/or Superintendent will review and sign-off reports before submission. Anticipated Completion Date: June 30, 2024

Audit Report: Reports on Compliance and Internal Control in Accordance with Government Auditing Standards and OMB Super Circular Uniform Guidance Audit Period: July 1, 2022 – June 30, 2023 Fiscal Year: 2022-2023 Principal Executive: Hon. Marcos Cruz Molina, Mayor Contact Person: Mr. Edgardo Pérez, Department of Management, Administration and Budget Director Phone: (787)855-2500 Original Finding Number: 2023-003 Statement of Concurrence or Non concurrence: We concur with the finding. Corrective Action: The QPR Reports for the months from January to March 2023, were completed by the previous POC Recovery Office. We understand that expenses were reported in the QPR on the date when the certification with the contractor´s invoice was received at the Secretary of Engineering and Conservation of Infrastructure and not on the date of payment or disbursement of the invoice. For example, if the invoice was received in the month of February, the expense was recorded in the QPR from January to March even though it was not paid until the month of April. We are verifying each project reported in the QPR against the amount reported at the SIMA System. We expect to have updated and correct information for all the Quarterly Progress Reports for the period from January to March 2024. Implementation Date: Fiscal Year 2023-2024. Responsible Person: Dafne L. Claudio Sánchez Accountant

We concur. Procedures will be put in place and reporting will be modified and improved to ensure deadlines are met.

FINDING 2023-009 Finding Subject: Education Stabilization Fund - Reporting Summary of Finding: Material Weakness, Other Matters, Qualified Opinion 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 prepared by the Chief Financial Officer and reviewed by a second knowledgeable individual; however, this process did not allow for the prevention, or detection and correction of errors prior to submission. Due to the lack of effective internal controls, one of the six annual data reports was not supported by the School Corporation’s records. For the ESSER 1, Year 2 report, which covered the period of October 1, 2020 to June 30, 2021, the School Corporation’s records did not support the data in the report. The lack of controls and noncompliance were isolated to the ESSER I, Year 2 report. Contact Person Responsible for Corrective Action: Bengamin Mann Contact Phone Number and Email Address: 765-536-0008 bmann@mgusc.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: Supporting documentation of data reported will be retained with each report filed. Anticipated Completion Date: February 2024

Corrective Actions Taken or Planned: Management will make necessary revisions to previous reporting. Management will complete and file all past due quarterly and annual reports accurately and in compliance with all HEERF reporting requirements. The fiscal year 2024 annual report will be filed in a timely manner. Anticipated Completion Date: March 31, 2024 Responsible Contact Person: Jacalyn Kovach, AVP Finance/Controller

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