Corrective Action Plans

Federal program title: Home Partnership Investment Program, and Local Assistance and Tribal Consistency Fund program CFDA 14.239, 21.032 Recommendation: We recommend that management establish and maintain a formal process for the retention and organization of all grant-related documentation. This process should ensure that key documents are securely stored, easily accessible, and periodically reviewed to support ongoing compliance with grant requirements. Additionally, the County should work with granting agencies to obtain copies of any missing agreements and perform a comprehensive review to identify and address any outstanding compliance requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County will not be applying for any CDBG grants in the future unless there is adequate administrative cost allocation in the grant. The County will continue to make every effort to adequately close out CDBG grants and provide reports to the granting organization as staff and priorities allow. Name(s) of the contact person(s) responsible for corrective action: Under direction of the County Administrative Officer, the Senior Financial Analyst Suzie Hawkins. Planned completion date for correcting action plan: Completed and on-going.

2024-007 Missing Supporting Documentation for Federal Reimbursement Claims Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding. A process for retaining claims and supporting documentation has been implemented.

Tuerk House, Inc. recognizes the importance of maintaining compliance with federal grant requirements related to allowable costs and documentation standards. The Organization acknowledges the deficiencies identified in the areas of time and effort reporting and supporting documentation for expenditures charged to grant programs. To address this finding, Tuerk House is taking the following corrective actions: ·Implementing a formal time and effort certification process that requires employees to certify actual time worked on federal grant activities on a regular basis, rather than relying on budgeted allocations. ·Developing a standardized cost allocation methodology that aligns with actual grant activity and is supported by verifiable documentation. ·Requiring that all expenditures charged to federal awards be supported by complete and accurate source documentation, including vendor invoices, timesheets, and approvals. ·Establishing a document retention policy consistent with 2 CFR § 200.334 to ensure all supporting records are retained for the required period and readily accessible for audit or review. Training sessions for program and finance staff will be conducted to ensure consistent understanding and application of these updated policies and procedures. Organization Contact Person Responsible for Corrective Action – Joseph Koehler, Director of Finance Anticipated Completion Date – June 30, 2025

Solvista Health management agrees with the auditor’s finding. In conjunction with the shared services agreement, the Group will work with management to strengthen its document retention policies and processes and implement internal controls to ensure that all required grant reports are consistently reviewed, approved, submitted, retained and retrievable for the required retention period. This includes quarterly reports, expense reimbursement packets submitted to the grantors, project expenditure reports, or other grant-related records necessary to demonstrate compliance with federal reporting and record retention standards under the federal programs.

Title: Missing Required Moving to Work (MTW) Demonstration Program Documentation Program Name: Moving to Work Program ALN: 14.881 Description: During our review of the Authority's administration of the MTW Program, the Authority was unable to provide several critical documents required to support its eligibility and compliance under the MTW framework: 1. The Authority did not provide a copy of its Annual Contributions Contract (ACC), which serves as the foundational agreement between the Authority and HUD for the receipt and use of federal funds. 2. The Authority failed to provide a signed MTW Certification of Compliance for the most recent fiscal year, which affirms board approval of the MTW Plan and Report and verifies the Authority's adherence to MTW statutory objectives and HUD program requirements. 3. The Authority did not provide the required supplement to the annual MTW Plan, which outlines planned uses of MTW funds and activities for the fiscal year. 4. The Authority also failed to provide the HUD-issued approval letter for the supplement to the annual MTW Plan, which is necessary to validate HU D's acceptance of the Authority's proposed activities.Planned Corrective Action: Fiscal Year 2024 was a year marked by personnel turnover in key administrative, accounting, and human resources positions. The Authority will work to locate and archive the ACC, required supplement to the annual MTW Plan, the HUD issued approval letter for the supplement to the annual MTW Plan, and to complete the MTW Certification of Compliance.

Title: Missing Required Moving to Work (MTW) Demonstration Program Documentation Program Name: Moving to Work Demonstration Program ALN: 14.881 Description: During our review of the Authority's administration of the MTW Program, the Authority was unable to provide two critical documents required to support its eligibility and compliance under the MTW framework: he Authority did not provide a copy of its Annual Contributions Contract (ACC), which serves as the foundational agreement between the Authority and HUD for the receipt and use of federal funds. 2. The Authority also failed to provide a signed MTW Certification of Compliance for the most recent fiscal year, which affirms board approval of the MTW Plan and Report and verifies the Authority's adherence to MTW statutory objectives and HUD program requirements.Planned Corrective Action: Fiscal Year 2024 was a year marked by personnel turnover in key administrative, accounting, and human resources positions. The Authority will work to locate and archive the ACC and to complete an MTW Certification of Compliance.

Finding 2024-002 Bridges Interface Controls Management Views DTMB disagrees with the condition and the effect of the OAG’s finding. The OAG sampled 85 total files across eight interfaces. Of these, seven appeared to present issues. For five of the sampled files, detailed exception results no longer existed. DTMB maintains summary tables for 10 years and purges detailed exception records at the beginning of each calendar year for anything older than 12 months. This purge process was communicated to the OAG during the fiscal year 2022 audit, and sampling was performed prior to purging for the fiscal year 2023 audit. When informed that the sample included files for which the detailed exception records had been purged, the OAG requested DTMB run a simulation processing of the original interface file in a testing environment to recreate detailed exception records. DTMB’s technical teams informed the OAG that rerunning in the current test environment would likely differ from the original results due to code changes that occurred in the test environment subsequent to when the original interface files were run in production. The OAG requested DTMB to proceed with rerunning the files in the current test environment. As a result, the OAG identified five instances where the detailed exception records from the simulation in the test environment did not exactly match the summary table from the original production interface results. For the 2 remaining files out of 85 (2.4 percent) that were cited, it should be clarified that the reconciliation being discussed is not data that was lost or misplaced between systems, but reconciliation of two exceptions correctly logged and correctly not counted in a summary report because they were alerts during processing, not errors that would be forwarded for review. These results do not present a significant deficiency in the ability of MDHHS to review the detailed exceptions. Also, these 2 records are insignificant when compared to the 11.6 million records processed in the 85 sampled files (0.000001 percent). Therefore, the current controls are reasonable to ensure that data processed from the source system to the receiving system is processed accurately, completely, and timely. Planned Corrective Action DTMB disagrees with the finding and does not intend to take further action. Anticipated Completion Date Not applicable Responsible Individual(s) Nathan Buckwalter, DTMB

As a corrective measure, BGCPR will take the following actions and will anticipate completing on June 30, 2025: a. Establish clear guidelines for the creation, storage, access, updating, and disposal of records. b. Define retention periods in accordance with legal requirements. c. Develop periodic monitoring procedures to verify record completeness and compliance. d. Implement scheduled internal reviews and standardized checklists. e. Assign specific responsibilities to Human Resources personnel for policy enforcement.

Assistance Listings number and name: Award numbers and years: Assistance Listings number and name: Award numbers and years: Federal agency: 21.023 COVID-19 - Emergency Rental Assistance Program 1505-0270, May 5, 2021 through September 30, 2025 23*019, May 5, 2021 through September 30, 2025 23*056, May 5, 2021 through September 30, 2025 23*064, May 5, 2021 through September 30, 2025 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds 1505-0271, March 3, 2021 through December 31, 2024 19418, May 31, 2023 through September 30, 2023 U.S. Department of the Treasury Name of contact person: Ken Walker, Director (Interim), Grants Management & Innovation; Art Cuarón, Director, Finance and Risk Management Anticipated completion date: June 30, 2026 Response: Concur. The Pima County Department of Grants Management & Innovation (GMI) acknowledges the finding related to noncompliance with federal reporting requirements for the Emergency Rental Assistance (ERA) and Coronavirus State and Local Fiscal Recovery Funds (SLFRF) programs. We recognize the critical importance of maintaining accurate, complete, and well-documented reporting in accordance with federal regulations, and we are committed to addressing the deficiencies noted in this finding. GMI recently adjusted the scope and activities of one of its decisions to address this concern. The division’s new title is Monitoring, Analysis, and Performance (MAP) and its responsibility is to ensure that required reporting documentation is appropriately collected and retained and that related policies and procedures are up-to-date and followed. Corrective Actions Taken and Planned: 1. Documentation and Retention Procedures The Department has implemented a formalized process to ensure that all program reports are supported by comprehensive documentation. This includes: o Capturing and retaining system-generated reports, screenshots, and data queries used in the preparation of ERA and SLFRF quarterly submissions. Each grant specific folder contains subfolders for: • Relevant emails • Screenshots of uploaded information and portal submissions • A copy of the Departmental Approval Form (review form acknowledging the review and agreement to submit programmatic and financial reports into its respective portal.) • A downloaded PDF of the data submitted for the respective quarter. o Establishing a secure digital repository to store supporting documentation for each report, ensuring accessibility and retention in accordance with 2 CFR §200.334 and the County’s record retention policies. • Reporting Guidance • Compliance Supplements • Resources (programmatic and/or service codes, definitions, etc.) • Copies of raw data provided and coding scripts for applicable data sets. o Conducting periodic internal audits to verify documentation compliance. • The MAP Monitoring manager will oversee periodic internal audits for all federal grants. 2. Policy and Procedure Development The Department is finalizing written policies and procedures that establish clear internal controls over the federal reporting process. These policies will require: o A formal reconciliation process of reported expenditures against the County’s general ledger prior to submission. o An independent review and documented approval of all reports to ensure accuracy and compliance with federal guidelines. o Designated accountability roles within the reporting workflow, with approvals required at each stage. This includes electronic approvals within Amplifund and Workday. Amplifund is now the central repository of all grant documentation and Workday is the County’s system of financial records. 3. Training and Staff Development In response to staff turnover, which created institutional knowledge gaps, the Department has launched a training initiative to ensure all relevant personnel are familiar with ERA and SLFRF reporting requirements. Training covers: o Reporting timelines and content requirements, o Use of the U.S. Treasury’s reporting portals, and o Internal compliance expectations, including documentation standards and retention policies. The performance of staff assigned to these tasks will be monitored and corrective action, including re-training, will be taken to address any failures. 4. Reporting Calendar and Tracking Mechanism To improve timeliness and oversight, the Department has initiated a centralized reporting calendar and task-tracking system (Amplifund). This system: o Sends automated reminders of upcoming reporting deadlines, o Tracks task completion by staff, and o Tracks workflows 5. Coordination with Federal Grantor The Department is actively engaging with the U.S. Department of the Treasury to determine whether any corrections can be submitted for previously reported ERA and SLFRF data. U.S. Treasury staff has informed grantees that they are to correct mistakes made in a previous report in the current report. So, while federal guidance currently limits the ability to resubmit reports after the reporting deadline, the County is exploring whether exception-based resubmissions are permissible in cases of material reporting error. Conclusion The County is committed to enhancing and upholding best practice internal controls and fully aligning with federal grant requirements. Staff recognize the impact of these reporting deficiencies and are taking decisive steps to improve accountability and audit readiness across all federal programs. The corrective actions outlined above are designed to address the current finding and to mitigate similar risks for other grant programs administered by the County.

The Board has developed procedures to ensure that all purchase orders are approved before orders are placed, all expenditures are properly authorized by the respective program director and supporting documentation is adequately maintained. The Board is using a requisition form in Droplet to achieve this goal. All employees authorized to make or approve purchases have been trained on purchasing procedures outlined in the Purchasing Policies and Procedures Manual for Local Educational Agencies in the State of West Virginia by the WVDE Office of School Finance on 2/23/2024.

The Board will establish procedures that will ensure compliance with guidance set forth in Title 2 U.S. Code of Federal Regulations (CFR) Part 200 for Special Education.

The District is aware of the importance of maintaining documentation that demonstrates expenditures charged to a program are allocable and allowable. The District will review existing procedures related to the review of temporary workers to ensure that documentation is available to demonstrate charges to programs comply with federal guidelines and regulations. The District also recognizes the importance of timely approval of time and effort in compliance with federal regulations. While the District does perform regular reconciliations of expenses to ensure allowability, the District will review and update procedures, as necessary, to continue to improve and document timely supervisory approvals after each bi-weekly payroll is processed in relation to finding 2024-01 in the District’s Report on Internal Controls and Compliance.

FINDING 2024-002 Finding Subject: COVID-19 – Education Stabilization Fund - Reporting Contact Person Responsible for Corrective Action: Kelli Keith Contact Phone Number and Email Address: 812-438-2655, kkeith@risingsun.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: When the criteria for the reporting is changed forcing us to change our answers, we will keep better notes of what we changed, and why we changed it. Our final numbers were correct, and we spent the money out of the correct categories. Jennifer Mossburger, Title I coordinator, and I worked together on this reporting. We will continue to work together on the reporting for the federal grants. However, we will do a better job of documenting our work. Anticipated Completion Date: 3/3/2025

FINDING 2024-006 Subject: Title I Grants to Local Educational Agencies - Special Tests and Provisions - Annual Report Card Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listings Number: 84.010 Federal Award Numbers and Years (or Other Identifying Numbers): S010A210014, S010A220014, S010A230014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Annual Report Card Audit Findings: Material Weakness, Other Matters Contact Person Responsible for Corrective Action: Beth Husband/Alexandria Eckert Contact Phone Number 260-356-8312 Email Address: bhusband@hccsc.k12.in.us/aeckert@hccsc.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: All withdrawals will have the proper documentation (transcript request or withdrawal form) attached to the student record and the form will be dated within two weeks of the student enrollment end date. The forms must be signed by the parent and the principal. Title 1 Director will review for accuracy and completion of forms. Anticipated Completion Date: December 31, 2025

FINDING 2024-005 Finding Subject:. 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 was required to submit five annual data reports as outlined below. Fund Applicable Reporting Period ESSER I July 1, 2021 – June 30, 2022 ESSER II July 1, 2021 – June 30, 2022 ESSER III July 1, 2021 – June 30, 2022 ESSER II July 1, 2022 – June 30, 2023 ESSER III July 1, 2022 – June 30, 2023 All five annual data reports were selected for testing. Two of the five annual data reports did not include the correct expenditure information. Specifically the ESSER II and ESSER III annual data reports with an applicable reporting period of July 1, 2022, to June 30, 2023, did not include expenditure data for this period. Instead, the annual reports incorrectly reported expenditures from the previous period of July 1, 2021 to June 30, 2022. Contact Person Responsible for Corrective Action: Greg Elkins, CFO Contact Phone Number and Email Address: (317) 485-3100, greg.elkins@mvcsc.k12.in.us Views of Responsible Officials: We agree with the finding. Description of Corrective Action Plan: Since the conclusion of the 2020-2022 SBOA audit, the CFO and Corporation Treasurer have archived numerous email threads and other evidence of communication which documents the process for pulling ESSER financial data from the Skyward Finance system and submitting the required reports. This documentation shows the CFO and Treasurer regularly communicating, checking and rechecking the data, and verifying the timely submission of that data. The school received periodic requests from the Indiana Department of Education, Office of Federal Grants asking it to submit financial data for all ESSER funds. Originally, the data requests were submitted through JotForms which do not have the capability of notifying any individuals other than the recipient. The school was required to create its own documents for proof of submission and did so. In subsequent requests, IDOE provided Excel spreadsheets to be completed and returned electronically. Those emails and spreadsheets have been curated by the school. The school has documented unclear instructions provided by IDOE, the pass through agency. The school accepts responsibility to report grant activity for the federally required reporting periods regardless. The school will ask for explicit instructions from IDOE and reconfirm the reporting data required and time period(s) in question. This additional layer of internal controls will be added to the process currently utilized by the CFO and Corporation Treasurer. The school has not expended any dollars from any ESSER fund since 2023. Anticipated Completion Date: TBD based on when the next reporting submission is requested by IDOE (all ESSER grants activities have ceased and the funds have been closed out locally.)

Finding 2024-003 Contact Person Responsible for Corrective Action Plan: Brenda Layne, Food Service Director Contact Phone Number: 765-289-7323 We concur with the finding. Corrective Action plan: As of 3/1/25. Cindy will look the company up on Sam.gov. and the Food Service Director will look it over and both of us will initial and keep a copy on file. Anticipated Completion Date: March 2025

FINDING 2024-002 Subject: Title I Grants to Local Educational Agencies - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listings Number: 84.010 Federal Award Number or Year (or Other Identifying Number): S010A210014 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Findings: Material Weakness, Modified Opinion Condition and Context Direct charges to a federal award are to be for allowable activities and allowable costs made in conformance with the applicable cost principles. The School Corporation did not have a process or internal controls in place to ensure expenditures for the 2021 Title I grant award were for allowable activities and costs and in conformance with the cost principles. The School Corporation was unable to provide supporting documentation for $43,141 worth of expenditures transferred out of the 2021 grant award fund 4121 from July 1, 2022 to December 1, 2022. These expenditures were originally expended from the Title I 2021 grant award fund 4121, requested for reimbursement and then the expenditures were moved to other funds. Because these expenditures were reappropriated, they were not an allowable activity or cost of the 2021 Title I grant award. In addition, the School Corporation was unable to provide supporting documentation for $6,646 worth of certified salary expenditures requested for reimbursement for the same grant award from February 17, 2022 to June 30, 2022. It was determined that this amount was double requested for reimbursement and was not an actual expenditure. The total amount of $49,787 was considered questioned costs. Subsequent to the 2021 Title I grant award, the School Corporation established and implemented a process and internal controls to ensure expenditures for the 2022 and 2023 awards from July 1, 2022 through December 31, 2023, were for allowable activities and costs and in conformance with the cost principles. The vendor expenditures are initiated by the Title I Director and the Title I Administrative Assistant. Payroll is reviewed each pay period by the Title I Administrative Assistant. The Business Manager/Treasurer prepares the reimbursement request using a detailed expenditure report from their accounting system. The Title I Administrative Assistant verifies the information entered into the reimbursement request by also comparing it to the detailed expenditure reports. The Title I Administrative Assistant also reconciles the Title I award to the expenditures. INDIANA STATE BOARD OF ACCOUNTS 18 METROPOLITAN SCHOOL DISTRICT OF STEUBEN COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) If the Title I Administrative Assistant identifies that a correction of errors needs to be made to a Title I fund, they fill out a Corrections Form. The Title I Director then reviews and signs the form and provides it to the Business Manager/Treasurer to make the correction in the accounting system prior to completing a request for reimbursement. After the corrections have been made, the Title I Administrative Assistant verifies the changes were correctly made. After all corrections are made, the reimbursement request is approved by the Title I Director and then submitted by the Business Manager/Treasurer. We tested 25 other non-journal entry expenditures from all three Title I grant awards during the audit period and did not identify any additional noncompliance with these expenditures. The lack of internal controls and supporting documentation was isolated to the 2021 Title I grant award number S010A21001 from February 17, 2022 to December 31, 2022. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. . . . (g) Be adequately documented. . . ." 2 CFR 200.302(b) states in part: "The recipient's and subrecipient's financial management system must provide for the following: . . . (7) Written procedures for determining the allowability of costs in accordance with subpart E of this part and the terms and conditions of the Federal award." INDIANA STATE BOARD OF ACCOUNTS 19 METROPOLITAN SCHOOL DISTRICT OF STEUBEN COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 2 CFR 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for the Federal awards that are renewed quarterly or annual, from the date of submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." Cause A proper system of internal controls was not designed by management of the School Corporation. The School Corporation segregated duties of knowledgeable staff that were involved in the process of purchasing, entering claim information, processing claim and payroll information, and using reliable financial data from the accounting system. However, it had not established a process or internal controls for the 2021 Title I award number S010A21001 to ensure that all accounting corrections were made prior to processing a request for reimbursement. Effect Without the proper implementation of an effectively designed system of internal controls, the School Corporation could not ensure that only expenditures for allowable activities and costs were made and requested for reimbursement. Any program funds the School Corporation reallocated to other funds or double requested for reimbursement would be unallowable, and the awarding agency could potentially recover them. Questioned Costs Questioned costs in the amount of $49,787 were identified as noted in the Condition and Context. Recommendation We recommended that Management of the School Corporation establish a proper system of internal controls and develop written policies and procedures to ensure that expenditures for all Title I grant awards are for allowable activities and costs in conformance with the cost principles and that support for all expenditures and journal entries is maintained for the date ranges of costs documented on the requests for reimbursement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

Finding Number: 2024 – 001 – Allowable costs/cost principles - Cost Transfers Grantor: Department of Health and Human Services, National Institute of Health Program Name: Research and Development Cluster Award Name: various Award Numbers: various Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research Assistance Listing Numbers: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855 Award Year: Fiscal Year 2024 Passthrough Entity: various Corrective Action Plan: Weill Cornell Medicine (WCM) acknowledges that it was unable to readily produce supporting documentation and justifications for certain cost transfers. The university will review its cost transfer policies and procedures by September 30, 2025. Updates to the policy and procedures will be communicated to the respective campuses and incorporated into ongoing training by December 31, 2025. In addition, the need to maintain comprehensive documentation for cost transfers in a readily accessible repository will be considered as future systems are implemented. Responsible individual: Melissa Paray, Director, Grants and Contract Accounting, Weill Cornell Medicine

FINDING 2024-006 Subject: COVID‐19 ‐ Education Stabilization Fund ‐ Reporting Federal Agency: Department of Education Federal Program: COVID‐19 ‐ Education Stabilization Fund Assistance Listing Numbers: 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 Findings: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Chad Yencer, Superintendent Contact Phone Number: 765-348-7550 Views of Responsible Official: We concur with this finding Description of Corrective Action Plan: Internal Control 1. For state reporting related to ESSER grants, the Grants/Data Specialist will compile all required information and maintain thorough supporting documentation. The Corporation Treasurer will then review the compiled financial data for the reporting period, verifying its accuracy before presenting it to the Superintendent. Finally, the Superintendent will review the information and supporting documentation, confirming its accuracy prior to submission to the Indiana Department of Education (IDOE). All workpapers and calculations will be recorded and kept for verification Anticipated Completion Date: August 2025

FINDING 2024-005 Subject: COVID-19 - Education Stabilization Fund - Allowable Costs/Cost Principles and Allowable Activities Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425C, 84.425U Federal Award Numbers and Year (or Other Identifying Numbers): S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Allowable Costs/Cost Principles Audit Findings: Material Weakness, Modified Opinion Person Responsible for Corrective Action: Chad Yencer - Superintendent Contact Phone Number: 765-348-7550 Views of Responsible Official: Agree Description of Corrective Action Plan: This was a singular occurrence where the rate for a remedial program was not approved by the BCS school board, and where the payments did not tie back to an allowable cost. This program and fund are no longer active. Anticipated Completion Date: Completed

FINDING 2024-003 Finding Subject: Title I Grants to Local Educational Agencies-Eligibility Contact Person Responsible for Corrective Action: Dr. Eric Goggins, Superintendent Contact Phone Number and Email Address: 812-385-4851; egoggins@ngsc.k12..in.us Views of Responsible Officials: We concur with the finding. Explanation and Reasons for Disagreement: Not applicable Description of Corrective Action Plan: The food service director will do monthly eligibility reporting through the food service software to determine any free, reduced, paid, or direct certification eligibility changes. Change reports will be generated and provided to each building secretary on a monthly basis. Copies of each school’s eligibility changes will be provided to Marissa Breidenbaugh (HR Coordinator/Administrative Secretary) in the district office. Marissa will provide a deadline for all schools to update eligibility. On the deadline date, she will review each students Harmony demographics to ensure that the changes in eligibility have been recorded. The assistant superintendent will continue to develop the Title I application collaboratively with non-public schools. This development will include continued review of eligibility and enrollment data to ensure that it agrees with all supporting documentation. Anticipated Completion Date: This corrective action plan was implemented on March 3, 2025 and will continue to be implemented with the next Title I grant application process beginning approximately May 2025. INDIANA STATE

Corrective Action: Child Nutrition will provide proof of documentation on all vendors illustration that they are not suspended or debarred. Also, invoices will be a part of the procurement packet. lt will be uploaded to the financial software system for primary filing and filed physically as a secondary method. Avery Johnson, Business Manager Robert Sanders, Superintendent Linda Little, Child Nutrition Director Corrective Action Start Date: February 18, 2025

FINDING 2024-004 Finding Subject: Child Nutrition Cluster-Activities Allowed or Unallowed, Allowable Costs/Cost Principles Summary of Finding: Payments made based on statements or no supporting documentation. The School corporation did not properly implement a process to identify and assess internal and external risks, or monitor internal control activities to ensure they were operating effectively. Contact Person Responsible for Corrective Action: Melissa Embry Contact Phone Number and Email Address: 812-547-2637 melissa.embry@cannelton.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Invoices are already being given to the Corporation Treasurer monthly and are being attached to each Accounts Payable Voucher to show exactly what is being paid for. Cannelton management will establish a proper system of internal controls including policies and procedures related to risk assessment and monitoring activities within the federal program. Anticipated Completion Date: The noncompliance was corrected as of January 2025. The additional controls will be implemented by August 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.

Contact Person Responsible for Corrective Action: Dr. Tammy Rowshandel, Chief Accountability Officer Contact Phone Number: 812-462-4224 Views of Responsible Official: The School Corporation's management will establish an effective system of internal control to ensure compliance and comply with the grant agreement and the Special Tests and Provisions - Annual Report Card, High School Graduation Rate compliance requirement. Description of Corrective Action Plan: A system will be put in place that ensures compliance with the Special Tests and Provisions-Annual Report Card, High School Graduation Rate requirements. Records will be retained for audit so that appropriate documentation is available to substantiate all future reporting. Building registrars will enter state exit codes for students and upload documentation to substantiate the exit codes that are chosen. Once the documents are uploaded, the registrars will place the word “AUDIT” in the withdrawal comments. This indicates the exit is now audit ready. Schools will conduct regular internal cohort audits. Comparisons of IDOE cohort data and withdrawal information in Skyward will be done. The registrar, assistant principal, and data counselor in each building will work together to check the original uploads of documentation done by the registrar and keep record of this work. One final internal audit will take place at the school level by head counselors and assistant principals to indicate all graduates are correctly identified and all exits have proper documentation on file. The CFO and superintendent will digitally sign off on these records during IDOE July certification. Anticipated Completion Date: March 1, 2025