Corrective Action Plans

Finding 2023-005 Lack of Internal Control / Noncompliance over Subrecipient Monitoring Name of Contact Person: Elena Begojevic, Business Manager Corrective Action Plan: HCSD established a Subrecipient Monitoring Checklist as a monitoring tool to ensure that subrecipients are successful and compliant and the subawards are used in accordance with federal statutes, regulations, and the terms and conditions of the federal and state awards. Proposed Completion Date: Fiscal Year 2024

Federal Award Findings and Questioned Costs Finding 2023-004 Lack of Internal Control / Noncompliance over Activities Allowed or Unallowed and Allowable Costs/Cost Principles Name of Contact Person: Elena Begojevic, Business Manager Corrective Action Plan: Management will ensure that the system of internal controls over cash disbursements is designed appropriately and operates effectively to ensure all transactions are coded, reviewed, and approved before payment is made. The Business manager and the Superintendent will conduct a review of claims to determine whether they are proper and valid charges. Once reviewed, all transactions will be authorized. DocuSign will be used for electronic signature approval. Accounts payable clerk will ensure that all transactions include copies of receipts for the goods or services purchased. Finally, the Finance department will work with the program directors to ensure that expenses are coded accurately and within reasonable timeframe to allow for timely submission of grant reports. Proposed Completion Date: Fiscal Year 2024

2023-024 Oregon Department of Human Services/Oregon Health Authority Strengthen review over direct costs charged to the program MANAGEMENT RESPONSE: We agree with this recommendation. The ODHS Office of Facilities Management coordinates care of a 168-building portfolio. Part of this work is coordination of furniture reconfiguration, minor and major remodels of office spaces and other building maintenance work. For these projects we rely on program staff with understanding of their funding sources to provide us with accurate coding to support the project related costs. Our office does not work directly with funding source management only coding and billing. To better track who is providing us the coding and maintain a record of payment approval we have revised our workorder form to include who from the program is providing the coding and what authority they have to provide the coding. This will allow us to assure that important details are captured regarding funding application and coding for billing and protect from funds being drawn from sources that do not support and/or are not appropriate for a given project. The questioned costs of $3,849 were corrected and refunded to CMS using document BTCL1485 with a April 17, 2024 effective date. The refund will be reported on the Q3 FFY 2024 CMS 64 which will be submitted by June 30, 2024. Anticipated Completion Date: June 30, 2024 Contact person: Karuna Thompson, Construction and Facilities Maintenance Manager; Travis Labrum, Grant Accounting Manager

Ref. No. Compliance and Internal Control over Compliance Findings 2023-006 Allowable Costs – Significant Deficiency Recommendation We recommend the County follow their internal control process to ensure that adequate documentation supports the accumulation of costs charged to the Program as required by 2 CFR §200 Subpart E. View of Responsible Officials and Planned Corrective Action Management agrees with this finding. The Department of the Prosecuting Attorney’s office has reviewed and agreed a detailed line item report and Payment Request/Approval form did not accompany the respective RFF. The Department has already corrected these deficiencies to ensure each expense has an Expense Approval form with justification and that each RFF is accompanied with a detailed line item report and backup documentation for each expense being requested for reimbursement. Each payroll and non-payroll monthly invoices submitted clearly shows the breakdown. With each invoice submitted, it will state, as an example, “VOCA-SNAP 21-V2-01 Report & Attachments MM/YY”. A sample of this was submitted on March 25, 2024 with response. In short, the necessary back-up requested going forward is and will be available to submit for future audits or reviews. Anticipated Completion Date: 3/27/2024 Responding Person(s): Robert Nadal Grant Management Specialist Phone No. 808-270-7608

Dear Mr. Waguespack: The Department of Children and Family Services has reviewed the finding “Noncompliance and Control Weakness Related to Cost Allocation”. The Department concurs with the finding and recommendation. When processing the July 2022 cost allocation statistics, we inadvertently selected the wrong report date for one statistic, which resulted in incorrect percentages being charged to various cost pools. The Cost Allocation Unit has implemented a review process to ensure that supporting data is accurate prior to processing monthly statistics. The Program Consultant will run all reports used by the Cost Allocation Unit each month and submit the reports to the Program Manager for approval. The Program Manager will verify the accuracy of the report dates and supporting documentation, sign the reports, and return them to the Program Consultant for processing monthly stats. The Cost Allocation Unit is updating the Cost Allocation Plan to include the missing cost pool and will submit future amendments promptly when major changes occur. Plan updates will continue to be submitted semi-annually. If you have any questions, please contact Tonja Hayes, Cost Allocation Unit Program Manager. Ms. Hayes can be reached at (225) 342-4859 or Tonja.Hayes.DCFS@LA.GOV

Views of Responsible Officials and Planned Corrective Action: Department of Human Services Response DHS concurs with the finding. The Division of Childcare and Early Childhood Education (DCCECE) utilized a custom software platform to provide payment files to the State’s accounting software, AASIS, to issue payments to recipients. Within this software, the AASIS coding for Sponsor Administrative costs is coded to CNP Block Consolidated (ALN 10.555) instead of CNP CACFP Sponsor Administrative (ALN 10.558) for the questioned costs of $98,474.00. Expense error corrections were not received timely by managerial accounting staff prior to the close out of SFY2023. Effective August 1, 2023, the division formerly known as DCCECE at DHS transitioned to the Arkansas Department of Education (ADE). DHS alerted financial staff with ADE in February 2024 to review the custom software platform to ensure grant expenses are being properly coded now. Due to depleted grant funds in CNP CACFP Cash in Lieu (ALN 10.558), the questioned costs of $38,341.68 in grants funds were manually moved by DHS Managerial Accounting staff into the CNP Block Consolidated grant. Managerial accounting staff have been retrained to ensure adequate federal funds are available prior to drawing. If manual adjustments are required, the division’s CFO, or their designee, must review and approve manual adjustments prior to the managerial accounting staff executing manual adjustments. DHS Office of Finance is developing an internal control documenting the prior approval process. DHS will continue to work in cooperation and coordination with ADE to provide all relevant financial information, documentation, or other items necessary for the administrative functions of DCCECE so as not to disrupt any services. Arkansas Department of Education Response The Arkansas Department of Education, Finance unit monitors federal grant awards by using separate cost centers for each program and award year within. This process provides transparent delineation of expenses and revenues within the State’s accounting system, AASIS. Additionally, ADE Finance owns an established procedure to reconcile federal grant awards for each month, within 90 days of the month’s end. The reconciliation procedure accounts for all activity within the grants and ensures data is aligned from the federal drawdown system to the State’s accounting system, AASIS. Anticipated Completion Date: Department of Human Services Response 3/31/2024 Arkansas Department of Education Response The itemized CNP programs are reconciled using ADE procedures as of August 1,2023. ADE ensures the accuracy of data from August 1, 2023, through January 31, 2024. Contact Person: Name: Misty Eubanks Title: Deputy Secretary for Operations and Budget and Interim Chief Financial Officer Agency: Department of Human Services Address: P.O. Box 1437, Slot S201 City, State, Zip: Little Rock, AR, 72203-1437 Phone Number: 501-320-6327 Email Address: misty.eubanks@dhs.arkansas.gov Name: Amy Thomas Title: Accounting Operations Manager Agency: Arkansas Department of Education Address: Four Capitol Mall, Room 204 City, State, Zip: Little Rock, AR, 72201 Phone Number: 501-682-3636 Email Address: Amy.Thomas@ade.arkansas.gov

FINDING 2023-007 Information on the federal program: Subject: COVID-19 - Education Stabilization Fund – Activities Allowed or Unallowed, Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Number: 84.425D Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Findings: Material Weakness, Modified Opinion Contact Persons Responsible for Corrective Action: Regin Johnson, Title I Director Chris Akers, Treasurer Adrian Wilkerson, Chief Financial Officer Contact Phone Number and Email Address: (219) 838-1819 rjohnson@lakeridgeschools.net cakers@lakeridgeschools.net awilkerson@lakeridgeschools.net Condition: 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 Activities Allowed or Unallowed and Allowable Costs/Cost Principles compliance requirements. Context: A number of transfer adjustments were made during the audit period from Corporation fund 7923 (ESSER III) to fund 7941 (CARES Ed Stabilization). These transfers were made move payroll disbursement activity for reimbursement. Support for these adjustments was traced to School Corporation’s records to verify the Gross Payroll activity moved for all but one transaction, which totaled $27,824. The supporting documentation for this transaction exceeded the amount of the transaction. Inquiry with School Corporation officials and review of the documentation determined that the amount transferred in this transaction was based on the remaining grant budget amounts in the grant fund 7941. The transaction was not based on actual payroll disbursements as all other transfer adjustments were. The $27,824 without supporting documentation is considered questioned costs. Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: For future transfers of payroll disbursements, both the Treasurer and Grant Director will ensure that the amount transferred corresponds to actual, documented payroll expenses and not an aggregate salary and/or benefit expenditure. The Chief Financial Officer shall review and approve these transfers to ensure compliance. Anticipated Completion Date: Immediate

Re: Single Audit Corrective Action Plan for the Fiscal Year Ended June 30, 2023 AUDIT FINDINGS Finding Reference Number: 2023-001 Description of Finding: No Written Policies, Procedures, or Standards of Conduct Relative to Federal Awards. Statement of Concurrence or Nonconcurrence: Mental Health America, Northern Kentucky and Southwest Ohio agrees with the audit finding. Corrective Action: Mental Health America, Northern Kentucky and Southwest Ohio will prepare written procedures governing the expenditures of Federal Funds. Name of Contact Person:Elizabeth Atwell, Executive Director eatwell@mhankyswoh.org (513)721-2910 Projected Completion Date: On or before June 30, 2024

February 14, 2024 City of Bellevue, Kentucky Single Audit Corrective Action Plan for the Fiscal Year Ended June 30, 2023 Audit Findings Finding Reference Number: 2023-01 Description of Finding: No Written Policies, Procedures, or Standards of Conduct Relative to Federal Awards. Statement of Concurrence or Nonconcurrence: The City of Bellevue, Kentucky agrees with the audit finding. Corrective Action: The City of Bellevue, Kentucky will prepare written procedures governing the expenditures of Federal Funds. : Name of Contact Person Lindy Jenkins City Clerk / Treasurer (859) 431-8888 Projected Completion Date: On or before June 30, 2024

Re: State Single Audit Corrective Action Plan for the Fiscal Year Ended June 30, 2023 AUDIT FINDINGS Finding Reference Number: 2023-01 Description of Finding: No Written Policies, Procedures, or Standards of Conduct Relative to Federal Awards. Statement of Concurrence or Nonconcurrence: Sanitation District No.1 agrees with the audit finding. Corrective Action: Sanitation District No.1 will prepare written procedures governing the expenditures of Federal Funds. Name of Contact Person:Debbie Vinson, Accounting Manager dvinsonsd1.orq (859) 578-7462 Projected Completion Date: On or before June 30, 2024

Finding 2023-003 – Allowable Costs and Activities, Eligibility – Compliance Federal Award. No. 21.026 Homeowner Assistance Fund – COVID 19 Corrective Action Plan: The Commission was made aware of the sophisticated fraudulent entity through its contacts with the National Council of State Housing Agencies (NCSHA). Staff remains active in those groups, participating in weekly and monthly calls and will adopt further preventative measures that have been shown to be effective in other states. Staff has implemented a more rigorous servicer onboarding process, whereby questionable items or documentation deemed to be suspicious or potentially altered will be presented to the program director, finance staff, compliance staff, or other internal staff for further investigation. Staff does not anticipate further issues with falsified information with the enhanced onboarding procedures implemented. In addition, balances owed are verified by loan servicers, and funds are paid directly to the servicer and never to individual homeowners. Completion Date: The Commission implemented additional compliance review procedures during fiscal year 2023 and completed its investigation of the identified case. Contact Person: Steve Whitson, Director of Community Programs

Finding 2023-002 – Allowable Costs and Activities, Eligibility – Compliance and Control Finding Federal Award No. 21.023 Emergency Rental Assistance Program – COVID 19 Corrective Action Plan: The Commission administered direct assistance according to the program rules and regulations. The Commission collected the required information and documentation to review and approve applications. Applicants submitted certified applications meeting the requirements of the program. However, the Commission staff discovered through its noncompliance review and identification processes that some program applicants provided false information and fraudulent documentation that continues to be investigated and reported to the proper authorities. Internal controls have been enhanced to mitigate and help prevent further exposure to noncompliance. Past and ongoing measures implemented to ensure eligibility of all funds disbursed include: the adoption of a formal fraud, waste, and abuse policy in July 2021 as well as providing additional training to employees and third parties that were responsible for reviewing and approving applications in order to better detect invalid applicants to prevent funding these applicants. In May 2021, the Commission hired an Internal Compliance Manager and created an Internal Compliance Department who has engaged a third party law firm and a consulting group to provide consultative assistance to improve processes and to assist in investigating applications deemed to be questionable. Further, internal staffing capacity was expanded with the creation of the Community Programs Processes Department in fall 2021 and the Data and Analytics Department in early 2022. Additional investigative techniques such as “mass denial metrics” and tiered level reviews were implemented into weekly application processing. Commission staff set regular internal coordination meetings to improve communication and aid in the identification of new indicators. Internal compliance staff actively participates in national groups administering similar programs, and explores and adopts new preventative or other review measures demonstrated to be effective in other states. As program funds for direct rental and utility assistance have been expended and direct assistance applications no longer accepted, additional internal metrics and compliance review processes are being developed to apply a consistent process for examining any outstanding questioned costs and to make a final determination regarding the eligibility of disbursed funds. Completion Date: The Commission implemented additional compliance review procedures during fiscal years 2021 and 2022 and expects to conclude its investigation of the fiscal year identified cases during calendar year 2024. Contact Person: Steve Whitson, Director of Community Programs

Finding 2023-001 – Allowable Costs and Activities – Compliance and Control Finding Federal Award No. 14.231 Emergency Solutions Grant Program – COVID 19 Corrective Action Plan: The Commission administered direct assistance according to the program rules and regulations. The Commission collected the required information and documentation to review and approve applications. Applicants submitted certified applications meeting the requirements of the program. However, the Commission staff discovered through its noncompliance review and identification processes that some program applicants provided false information and fraudulent documentation that continues to be investigated and reported to the proper authorities. Internal controls have been enhanced to mitigate and identify instances of potential noncompliance. The use of program funds for direct rental assistance under this program was concluded and the final disbursements made in early May 2021. Past and ongoing measures implemented to ensure eligibility of all funds disbursed include: The Commission hiring an Internal Compliance Manager and establishing an internal compliance department in May 2021 who engaged a third party law firm and a consulting group to provide consultative assistance to improve processes and to assist in investigating applications deemed to be questionable. A formal fraud, waste and abuse policy was adopted in July 2021. During fiscal year 2022, the Commission undertook extensive efforts to detect instances of ineligible applicants and documentation irregularities, which resulted in identification of these instances of applicant noncompliance. As program funds for direct rental assistance have been expended, additional internal metrics and compliance review processes are being developed to apply a consistent process for examining any outstanding questioned costs and to make a final determination regarding the eligibility of disbursed funds. Completion Date: The Commission implemented additional compliance review procedures during fiscal years 2021 and 2022, reviewed applications to identify potentially fraudulent applications during fiscal years 2022 and 2023 and expects to conclude its investigation of identified cases during fiscal year 2024. Contact Person: Steve Whitson, Director of Community Programs

Planned Corrective Action(s): SIG-NAL will enhance internal controls by implementing formal review and approval processes for payroll, expenses, and financial reporting. The organization will require documented evidence (digital or written) of all reviews and approvals and will maintain these records in a standardized, centralized system. The Finance Team will ensure that all controls are performed and documented in accordance with 2 CFR Part 200 requirements. Updated internal control policies and procedures adopted in 2025 address these requirements and are being fully implemented. Anticipated Completion Date ● March 2026 Responsible Party ● Director of Operations, with support from the Finance Team and Executive Director

2022‐008 Grant Expenditures (Material Weakness) Recommendation: The Organization’s accounting system should be modified to accommodate expense tracking by individual grant and policies and procedures should be implemented to require direct expenses be assigned to specific grants. A method should be established to allocate indirect costs in accordance with federal regulations. Policies and procedures are also needed to provide appropriate oversight of all grant accounting including reporting. Action Taken (Unaudited): Management has updated its control procedures to include proper written policies for the internal control over financial reporting to ensure conformity with U.S. GAAP. Dan Watkins is responsible for this corrective action. A review process and coding within the accounting system was completed in January 2025. All invoices and staff time are evaluated for the level of effort towards each grant.

ALLOWABLE ACTIVITIES AND ALLOWABLE COSTS - SIGNIFICANT DEFICIENCY Federal Program Emergency Rental Assistance ALN 21.023; passed through the County of Berks Condition/Cause During 2022 payments of rental and utility assistance were entered as batches within the financial accounting software. A separate spreadsheet was utilized to track individual payments included within the batches. The original spreadsheet provided contained data entry errors. After revising for corrections, the detail provided by the Authority outlining individual payments was $472,226 lower than expenses reported in the financial reporting software and could not be reconciled by management. For 6 out of 60 cases tested, the amount paid for rent did not agree to a lease agreement or bills on file for the following reasons: (1) clerical errors, (2) duplicate payments due to multiple staff working on the same file, or (3) failure to request support before payment was made. The Authority did not have controls in place to detect the noncompliance prior to issuing payments. Recommendation We recommend the Authority revisit and strengthen internal controls over tracking individual payments for transactions entered as batches, particularly when related to federal awards. We encourage the Authority to continue working to identify the individual transactions making up the remainder of the federal expenditures under this program. We also recommend the Authority revisit and strengthen internal controls over allowable activities and allowable costs related to grant programs. Management Response The Authority launched the Emergency Rental Assistance Program (ERAP) with little administrative guidance from the U.S. Treasury. The Authority contracted with the Berks Coalition to End Homelessness (BCEH) to undertake various aspects of the Emergency Rental Assistance Program and in the late fall of 2021, the Authority began reviewing all case documentation provided by BCEH. This review eliminated the vast majority of the errors noted. The Authority also updated case documentation checklists as well as provided training for staff involved with ERAP.

Description of Finding: The allocation of payroll costs to programs are done manually instead of done based on entity-wide timesheets Statement of Concurrence or Nonconcurrence: The California Asian Pacific Chamber of Commerce (CalAsian) agrees with the finding. Corrective Action: CalAsian acknowledges the serious nature of this finding and the potential for damage to relationships with the grantors and Federal entities. The Interim Controller and Director of Finance are currently implementing an ERP system which will allow for better cost collection, reporting and reviews of the grant-related expenses for accuracy, reliability, and reconciliation. We also understand these findings are repetitive from the 2021 audit; however, due to catch-up of the prior year audits, we were unable to address these issues prior to completion of the 2022 audit. This delay was caused by a change in auditors as our previous auditor did not have the capacity to retain us as clients due to staff shortages related to COVID. A subcontractor has been retained to assist with providing information for the 2023 audit to bring the audits current. The ERP system includes electronic timesheets for daily charging to specific grants, as well as more visibility into the proper separation of direct, indirect, and unallowable costs per the CFR. Timesheet training has been performed and timesheet completion is required for all employees each day. This will begin on 1/1/2025 and will provide support for hours worked/billed, as well as document the certification and approvals that all time entered is accurate and in compliance with contract requirements. and provide proper support for all grant labor costs and indirect costs. An indirect cost pool allocation structure is being designed and implemented to properly allocate the allowable indirect costs to each work effort, including Fringe, Overhead and G&A. This proposed structure and rates will be submitted for approval in 2025 for use in billing the contracts properly. Monthly reviews by the Project Directors/Managers plus Accounting will be performed to identify any potential cost charging issues and corrective action(s) required. Name of Contact Person: Ryan Fong, Director of Finance, 916-446-7883, rfong@calasiancc.org Susan Wright, Controller, 256-689-7055, swright@calasiancc.org Pat Fong Kushida, President & CEO, 916-446-7883, patfongkushida@calasiancc.org Projected Completion Date: January 2025

Description of Finding: Expenditure detail does not support the amounts billed Statement of Concurrence or Nonconcurrence: The California Asian Pacific Chamber of Commerce (CalAsian) agrees with the finding. Corrective Action: CalAsian acknowledges the serious nature of this finding and the potential for damage to relationships with the grantors and Federal entities. The Interim Controller and Director of Finance are working to secure an ERP system which will allow for better cost collection, reporting and reviews of the grant-related expenses for accuracy, reliability, and reconciliation. We also understand these findings are repetitive from the 2021 audit; however, due to catch-up of the prior year audits, we were unable to address these issues prior to completion of the 2022 audit. This delay was caused by a change in auditors as our previous auditor did not have the capacity to retain us as clients due to staff shortages related to COVID. A subcontractor has been retained to assist with providing information for the 2023 audit to bring the audits current. The auditors tested 84% of the total 2021 total direct grant expenditures and this issue was isolated to one payroll entry for $2,500.00, which is a result of a one-time, non-recurring clerical error. No issues were noted in the 2022 audit work related to this finding. We are currently analyzing and ensuring revenue and expenses for grants in 2023 and 2024 have proper recognition and billing of accurate and complete costs. This issue will be further mitigated with the implementation of the new accounting system on 1/1/2025. The ERP system includes electronic timesheets for daily charging to specific grants, as well as more visibility into the proper separation of direct, indirect, and unallowable costs per the CFR. Timesheet training has been performed and timesheet completion is required for all employees beginning on 1/1/2025. This will provide support for hours worked/billed, as well as document the certification and approvals that all time entered is accurate and in compliance with contract requirements. and provide proper support for all grant and indirect labor costs. An indirect cost pool allocation structure is being designed and implemented to properly allocate the allowable indirect costs to each work effort. This proposed structure and rates will be submitted for approval in 2025. Monthly reviews by the Project Directors/Managers plus Accounting will be performed to identify any potential cost charging issues and corrective action(s) required. Name of Contact Person: Ryan Fong, Director of Finance, 916-446-7883, rfong@calasiancc.org Pat Fong Kushida, President & CEO, 916-446-7883, patfongkushida@calasiancc.org Projected Completion Date: January 2025

1. All related administrative and program operational costs have been appropriately classified and documented in QuickBooks beginning in March 2022. 2. Monthly review of administrative and program operational costs is performed by management and grant awarders.

FINDING 2022-007Subject: Title I Grants to Local Education Agencies ? EarmarkingFederal Agency: Department of EducationFederal Program: Title I Grants to Local Educational AgenciesAssistance Listing Number: 84.010Federal Award Numbers and Years: FY18, FY19, FY 20, FY 21Pass-Through Entity: Indiana Department of EducationCompliance Requirements: Matching, Level of Effort, EarmarkingAudit Finding: Material Weakness, Other MattersContact Person Responsible for Corrective Action: David Parker, Assistant SuperintendentContact Phone Number: 765-348-7550Views of Responsible Official: We concur with the findingDescription of Corrective Action Plan:Title I Procedures and Internal Controls for Homeless Student Set-AsidesYearly district Title I Homeless Student Set-Asides (?off-the-top? mandatory allocations as described in theyearly Title I grant basic application), shall be monitored and controlled on a semi-annual basis using thefollowing protocols:1. The BCS Assistant Superintendent, in collaboration with the designated district McKinney-Vento liaison,school principals, and school guidance personnel, will review and update the corporation homeless studentlist at the start of each new semester (fall/spring). This list will be maintained by the district McKinney-Vento liaison.2. The BCS Assistant Superintendent or district McKinney-Vento liaison will communicate the amount ofTitle I set-aside funds available to assist homeless students to school principals, and school guidancepersonnel. The LEA understands that services for homeless students attending non-Title I schools shouldfirst provide services similar to those given to students in Title I schools.3. School principals and/or school guidance personnel will work to identify specific needs of homelessstudents.4. Title I homeless student set-aside funds will be used to assist identified needs of specific students, as allowedoutlined by Title I - services may include, but are not limited to: See Corrective Action Plan for chart/table

Finding 2022-005: Activities Allowed, Allowable Costs, and Period of Performance – Material Weakness. Management Response: We are reviewing our internal controls (SOPs, Operational Manuals and Handbooks), including the document retention policy to assure retrieval. Interdepartmental review of the program contract and the Operations Manual will be held to assure understanding of allowable expenses. 1. Managerial training will be administered to assure Program expenditures are allowable. 2. Operations Manual is being updated to have a process that insures approval workflows for allowable costs. 3. Accounting Policies & Procedures Manual is being updated to improve internal controls & show clear process of compliance over expenditures.

2022-005 Significant Deficiency in Controls over Compliance: Administrative Requirements of Uniform Guidance-Administrative Policies The schools have documented their administrative policies effective 3/1/2023.

FINDING 2022-008 Contact Person Responsible for Corrective Action: Casey Brewster Contact Phone Number: 812-752-8935 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Quarterly reviews of parental involvement will be included in the quarterly grant reviews with the Director of Grants/Programs and the CFO. The Director will also be in engaged in IDOE provided trainings such as TitleCon, and understands the parental involvement requirements needing to be met and will monitor accordingly. In addition, the monthly reports of all revenue and expenditures shall include tracking of specific spending requirements, such as parental involvement spending. Finally, the comprehensive checklist that will be implemented will include the earmarking requirements and status. Anticipated Completion Date: May 2023

Finding 2022-008 Lack of Internal Control over Activities Allowed or Unallowed and Allowable Costs/Cost Principles Name of Contact Person: Bart Mwarey, Superintendent, and Yodean Armour, Business Manager Corrective Action Plan: District will adhere to internal control policies to ensure that the regulations contained in 2 CFR 200 are followed. Proposed Completion Date: June 30, 2023

FINDING 2022-0003 Contact Person Responsible for Corrective Action: Chris Richie Contact Phone Number: 219-987-4711 ext. 1113 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: 1) At the beginning of each school year, Cooperative School Services (CSS) will issue step by step instructions regarding documentation of services to any school personnel providing services for non-public school students with Service Plans for Special Education. The instructions will include but not be limited to a list of current nonpublic school students on his/her caseload, Time and Effort (T&E) logs with examples, etc. The building principal will be asked to review and co-sign the completed T&E logs. (If there are additional students identified over the course of the school year, CSS will provide the appropriate information to any new service providers.) 2) During each school year, CSS will obtain the hourly rate (salary, benefits and other appropriate expenditures) for school personnel providing Special Education or Related Services to non-public school students from the school corporation Treasurer. 3) On monthly basis, the signed T&E logs will be submitted to the CSS office. The amount of federal Proportionate Share funds that can be claimed for each participating school corporation will be calculated by CSS and the school corporation Treasurer. 4) The school corporation will submit a claim to CSS for reimbursement for the funds expended to provide services for non-public school students at least twice per school year. CSS will submit the claim to the Fiscal Agent school corporation for reimbursement. The reimbursement claim will be paid through the Fiscal Agent school corporation?s school board procedures from the IDEA Proportionate Share funds. Anticipated Completion Date: March 31, 2023