Corrective Action Plans

Finding Reference: 2025-001 – Activities Allowed or Unallowed Costs/Cost Principles — Food Distribution Cluster (TEFAP/CCC/CSFP) — Questioned Costs: 188,459 Responsible Person: Todd Frease, CFO Planned Actions & Timelines: 1. Allocation Methodology Correction (by 30 days from report issuance): We will redesign our administrative cost allocation model to remove the CCC double-counting and ensure each program’s share is based on documented, reasonable measures of benefit, consistent with 2 CFR §200.405. The revised workbook will include locked formulas and version control. 2. Secondary Review Control (effective next monthly close): We will implement a two-step review: preparer signs off on the allocation workbook, and an independent reviewer validates sources, bases, and formula ranges before posting entries or submitting claims. Evidence of review will be retained in monthly share drive by indicating approval through email. Anticipated Completion Date: Within 60 days of report issuance

FINDING 2025-003 Finding Subject: Special Education Cluster (IDEA) - Earmarking Contact Person Responsible for Corrective Action: Amy Silva Contact Phone Number and Email Address: 812-753-4230 amy.silva@sgibson.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The School Corporation has designated the Director of Special Education as the primary monitor responsible for overseeing nonpublic proportionate share expenditures. The Corporation Treasurer will provide the Director of Special Education and the Assistant Superintendent with a monthly budget-to-actual expenditure report for all active grants with nonpublic proportionate share requirements. This report will track the remaining unspent balance. The Director of Special Education will meet monthly with nonpublic school administrators to review the remaining fund balances, ensure services are being rendered, and project future expenditures. A final reconciliation will be performed within 30 days of each grant's end date to confirm all required funds were spent or a waiver was successfully obtained. Anticipated Completion Date: March 1, 2026

FINDING 2025-004 Finding Subject: Child Nutrition Cluster - Allowable Costs/Cost Principles Federal Agency: Department of Agriculture Federal Program(s): School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children Assistance Listing Numbers: 10.553, 10.555, 10.559 Federal Award Numbers and Years: FY2024, FY2025 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Allowable Costs/Cost Principals Audit Finding: Material Weakness, Modified Opinion Condition and Context An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Allowable Costs/Costs Principles compliance requirement. The School Corporation entered into a Fixed Price meal Contract with a food service management company (FSMC). For each meal type, a fixed price was established and billed by the FSMC based on meal counts served. The School Corporation failed to compare the invoices received from the FSMC to the School Corporations software reports to ensure the number of meals invoiced agreed to the meals served. Two invoices with the FSMC were selected for testing totaling $213,048.96. . Contact Person Responsible for Corrective Action: Erin Roach Contact Phone Number and Email Address: 765-653-3119 eroach@sputnam.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The food service director will compare the invoices received from the FSMC to the School Corporations software reports prior to submission for payment. Anticipated Completion Date: February, 2026

FINDING 2025-03 Finding Subject: Special Education Cluster (IDEA) - Earmarking Contact Person Responsible for Corrective Action: Dr. Emily Dykstra Contact Phone Number and Email Address: 812-849-4481 / dykstrae@mitchell.k12.in.us Views of Responsible Officials: “We concur with the finding.” Description of Corrective Action Plan: Mitchell Community Schools will utilize time and effort logs to track time that personnel spend working with non-public students. These logs will be turned into the Director of Special Education at the end of each school year, so that they will be available for future audits. A time and effort log template will be created by March 6, 2026 to be utilized with personnel for future IDEA grants. Anticipated Completion Date: March 6, 2026

The purpose of the Goods Receipt (GR) is to record receipt of goods or services as soon as they are delivered and verified to be in acceptable condition. A Goods receipt must be posted in SAP for all items actually received. Vendors submit invoice(s) referencing the purchase order (PO) directly to Accounts Payable after delivery, indicating that the goods or services have been provided and requesting payment. Accounts Payable then reviews the vendor invoice, purchase order, and goods receipt in SAP to perform the required three-way match (PO, GR, and vendor invoice) before processing payment. 1. The Accounts Payable team will collaborate with the Procurement Services Division to establish and implement a process that ensures the timely review and reconciliation of Goods Receipt (GR) entries. This will include the development of clear guidance / training materials for schools and offices to periodically review their GR balances. Training will be conducted via Virtual Office Hours on a quarterly basis for sites to make necessary adjustments when the goods or services received differ from the original Purchase Order (PO) or the corresponding invoice. 2. The Accounts Payable team will collaborate with the Procurement Services Division to develop supplemental documentation and guidance regarding proof of delivery for goods and services received. 3. Accounts Payable staff will receive ongoing training throughout the year on documentation and reconciliation requirements, particularly when new internal controls, procedures, and processes are created. Training will be incorporated into regular team meetings, procedural updates, and onboarding for new team members to maintain alignment and accuracy across the department. The implementation target date for the above corrective action plan is June 30, 2026. Name: Rocio Saucedo Title: Director of Accounts Payable Contact Information: Rocio.Saucedo@lausd.net

Condition: Nine (9) employee payroll expenditures were claimed at an hourly rate greater than that approved by ISBE. Corrective Action Plan: Management will review its policies and procedures and implement changes to strengthen internal control over federal reporting. In addition, budgets will be monitored and amended accordingly within the period performance of the grant. Responsible Person: Janiesa Owens, Chief School Business Official Anticipated Completion Date: June 30, 2026

Finding 2025 – 002- Allowable Costs & Period of Performance (Significant Deficiency and Noncompliance) Management’s Response: Management concurs with the above finding, and the Fiscal Service Office will implement corrective action before September 2026. Management acknowledges the process gap as indicated and noted in the above findings. To strengthen policies and procedures surrounding grant disbursements and ensure expenses are properly approved and allowable under the specific grant budget, the Fiscal Service Office along with the Human Resources Department will implement a process to properly document, review, and approve all allowable grant pay rates and salaries.

FINDING 2025-002 Finding Subject: COVID-19 - Education Stabilization Fund - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Summary of Finding: The School Corporation was unable to provide proper documentation for 5 out of the 25 claims selected for control testing. The School Corporation was unable to provide proper documentation to support the determination of the amount of the teachers total salary that was allocated to the federal award. Contact Person Responsible for Corrective Action: Melissa Raaf Contact Phone Number and Email Address: (812) 649-2591 / missy.raaf@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 that all proper documentation is saved in a binder or electronically. Anticipated Completion Date: Effective FY 2025/2026

FINDING 2025-002 Finding Subject: Special Education Cluster (IDEA)- Earmarking Summary of Finding: The School Corporation is a member of the Greater Lafayette Area Special Services Cooperative (Cooperative). During fiscal years 2023-2024, the Cooperative operated the special education programs and spent the federal money on behalf of all of 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 Matching, Level of Effort, Earmarking compliance requirement. The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the earmarking requirements. The Cooperative did not have adequate procedures in place to ensure that the required level of expenditures for nonpublic school students with disabilities was met for each member school. The Cooperative did not have effective internal controls to ensure nonpublic school expenditures were appropriately identified and reported. The Non-Public Proportionate Share expenditures for the 22611-021-PN01, 22611-021-ARP, 22619-021-ARP, 23611-021-PN01, and 23619-021-PN01 grant awards could not be verified for the individual member schools. Total grant expenditures were posted as expended. The nonpublic proportionate share expenditures were determined by applying a percentage to the nonpublic school budgeted expenditures. As such, we were unable to identify if the minimum amount per the grant awards was expended and properly reported to the IDOE as required. The lack of internal controls and noncompliance were isolated to the 22611-021-PN01, 22611-021-ARP, 22619-021-ARP, 23611-021-PN01, and 23619-021-PN01 grant awards. Contact Person Responsible for Corrective Action: Lissa Stranahan Contact Phone Number and Email Address: (Phone) 765-771-6013 (Email) lstranahan@lsc.k12.in.us Views of Responsible Officials: We concur with the finding. The Greater Lafayette Area Special Services (GLASS)and Local Education Agency, Lafayette School Corporation, concur with the audit finding for Earmarking. GLASS did not have adequate procedures in place to ensure that the required level of expenditures for non-public school students with disabilities was met for each member school. The Cooperative did not have effective internal controls to ensure non-public school expenditures were appropriately identified and reported. The methodology used by the Cooperative to monitor non-public proportionate share expenditures was based upon a percentage for each school corporation that comprises the Cooperative rather than basing the expenditures off of the grant award for each non-public school within the geographical boundaries of the school corporations. While all proportionate share funds were expended, it was problematic in determining if the minimum amount per the grant awards was expended and properly reported prior to July 1, 2024. INDIANA STATE BOARD OF ACCOUNTS 28 Description of Corrective Action Plan: The former Director of GLASS retired June 30, 2023. Upon hire on July 1, 2023, the new director immediately implemented measures to correct the previous methodology used at GLASS. Non-public proportionate share funds are identified and reported based upon the grant award for each school corporation. The expenditures are based upon the geographical location of the non-public school and the corresponding public school corporation, not based upon the “home” school corporation of the student. This process was implemented and descriptions were included on the ledgers to identify non-public school proportionate share for grants that were initiated during the FY 2024-2025 school year. Anticipated Completion Date: The corrective action was already put into place on July 1, 2023 and implemented with FY 2024-2025. The audit finding reflects the previous grant cycle for 2022 grants and 2023 grants, which is prior to this action taken.

The District will become more thoroughly aware of applicable compliance requirements and seek guidance in writing when necessary from the appropriate granting agencies. Anticipated Completion: January 1, 2026 Responsible Party: Lynette Thrasher, lthrasher@mcusd1.net 815-472-6477

FINDING 2025-001 Finding Subject: Special Education Cluster (IDEA)-Earmarking Contact Person Responsible for Corrective Action: Chelsea Yon Contact Phone Number and Email Address: 812-354-8731 cyon@pcsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Treasurer of Pike County School Corporation will work with Exceptional Children’s Co-op on proportionate share expenditures. PCSC will also track those expenditures in a separate line along with revenue received for the proportionate share. Anticipated Completion Date: This method was implemented in the 2025-2026 school year and will continue with each school year as needed.

Grant Cash Management – Community Development Block Grants Condition: 2 CFR 200.403 of the Uniform Guidance mandates that only necessary, and allowable costs be drawn down off of federal grants. During the audit, we found that the Water Plant Construction project had construction invoices being drawn down from two grant sources, resulting in total draw request exceeding total expenses. Corrective Action: The City understands what happened and will work on developing and implementing procedures to ensure that all invoices are not drawn beyond the amount expended. Contact Person Responsible for Corrective Action: John Dantzer, City Manager Anticipated Completion Date: This issue will be corrected moving forward.

2025-001 Costs Incurred Beyond the Period of Performance Criteria: According to 2 CFR §§200.1, 200.308, 200.309, 200.344, and 200.403(h), a non-Federal entity may only charge allowable costs incurred during the approved budget period of the Federal award’s period of performance, and any costs incurred before the Federal award was made that were authorized by the Federal awarding agency or pass-through entity. All financial obligations incurred under the Federal award must be liquidated within the required time period. Costs incurred outside the approved period of performance are unallowable and constitute questioned costs. Client’s Response: During the grant cycle, the Organization submitted for an extension but did not receive confirmation of said extension. During the current fiscal year, the Organization has implemented additional controls to ensure that all grant funding is expended within the timeframe allotted. Proposed Implementation Date – 12/31/2025 Name of Contact Person – John Edwards, Sr. Email: jledwards@umadaop.org Phone: 419-255-4444

The Authority immediately implemented enhanced financial control measures to strengthen oversite of not only the accounts payable process, but the financial operations. These measures include the adoption of dual control for all ACH transactions, ensuring that no single individual has unilateral authority to initiate and approve electronic payments or to issue paper checks. Prior to any payments being processed, the Chief Executive Officer (CEO) receives a preliminary invoice listing for review and approval. New vendor requests (typically provided by procurement) are processed by the finance department; and, in addition to the required W-9, their standing on Sunbiz.org is reviewed and documented in their vendor file. All documents provided by the new vendor are saved electronically and attached to their vendor file in the Authority's software. Additionally, new financial control policies were adopted by the Palatka Housing Authority's Board of Commissioners at their December 16, 2025 meeting. The new policy follows HUD's financial management training resource suggestions and the finance staff will meet monthly with the CEO to review current financials. All staff will be trained on the new policies by January 31, 2026 providing everyone with the updated requirements. The Authority has also hired an Interim Chief Financial Officer with over 20 years of public housing accounting experience and is actively searching for a permanent staff accountant and CFO, thus ending the fee accountant contract. This brings all accountability back to the in-house team. If the Department of Housing and Urban Development has questions regarding this plan, please contact Oche Bridgeford, Executive Director at (386) 329-0132.

Condition: Costs charged to ALN 97.036 – Disaster Grants: Public Assistance were also charged to ALN 84.425 - Education Stabilization Fund (Elementary and Secondary School Emergency Relief - "ESSER") in prior fiscal years, indicating potential duplication of expenditures across federal programs. Planned Corrective Action: The District applied for reimbursement of potentially eligible COVID expenditures in 2022. Per an April 5, 2022 FEMA memo “FEMA Continues Funding to Support the Safe Operations of Schools”, school districts could apply for reimbursement for ESSER funded expenditures, and then upon approval of application shift the funds to general fund. “Schools and school districts may utilize FEMA Public Assistance to receive full reimbursement for costs for the purposes above. Schools and districts may also use Elementary and Secondary School Emergency Relief (ESSER) funding from the U.S. Department of Education as a way to provide the up-front cost for the above health and safety measures, and later seek reimbursement through the FEMA Public Assistance process. For example, a local education agency (LEA) may use ESSER funds for costs that may ultimately be covered by FEMA; however, once it receives funds from FEMA for those costs, it must reimburse the ESSER grant account.” FEMA provided District award notification for COVID testing in December 2024 and January 2025, by this time the ESSER grant had closed on September 30, 2024 and the final expenditure reports for ESSER had been submitted to MDE in November 2024. Therefore the District could not complete the allowable general fund swaps. The District notified Michigan Department of Education and Michigan State Police of the timing issue. Upon request from MI State Police, the District provided documentation that available general funds were available to conduct the swaps if the FEMA approval had been received in a timely manner. Contact person responsible for corrective action: Jeremy Vidito, CFO Anticipated Completion Date: Requested documentation was submitted to Michigan State Police on November 7, 2025

FINDING 2025-001 Information on the federal program: Subject: Special Education Cluster (IDEA) – Internal Controls Federal Agency: Department of Education Federal Program: Special Education Grants to States, Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.027X, 84.173X Federal Award Numbers and Years (or Other Identifying Numbers): 22611-046-PN01, 22611-046-ARP, 22619-046-ARP Pass-Through Entity: Indiana Department of Education Compliance Requirement: Earmarking Audit Findings: Significant Deficiency Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and earmarking compliance requirement. Context: The School Corporation is a member of the Porter County Education Services (Cooperative). During fiscal year 2023-2024, the Cooperative operated the special education program and spent the federal money on behalf of all its members. As the grant agreement was between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the earmarking requirements. The Cooperative did not have adequate procedures in place to ensure that the required level of expenditures for non-public school students with disabilities was met for each member school. The Cooperative did not have effective internal controls to ensure non-public school expenditures were appropriately identified and reported. The Non-Public Proportionate Share expenditures for the 22611-046-PN01, 22611-046-ARP, and 22619-046-ARP grant awards could not be verified for the individual member schools. Total grant expenditures were posted as expended. The non-public proportionate share expenditures were determined by applying a percentage to the non-public school budgeted expenditures. As such, we were unable to identify if the minimum amount per each applicable member schools’ grant award was expended and properly reported to IDOE, as required. The lack of internal controls was isolated to the 22611-046-PN01, 22611-046-ARP, and 22619-046-ARP grant awards which were fully expended during fiscal year 2024. These three grant awards had minimum earmarking requirements for the Non-Public Proportionate Share of $39,016, $9,471, and $533, respectively. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. The Cooperative has implemented additional internal controls which includes the following: Provider/Employee will submit payroll records/invoices by student services monthly/bi-monthly to the bookkeeper. Once payroll records or invoices are received, the CFO will prepare a spreadsheet that calculates the time/amounts serviced by the non-public school and member school. Once the total hours are calculated, a percentage based on total hours worked for each member school will be used to allocate the provider/employee time for each member school. This documentation will be attached to each reimbursement request. Management of the School Corporation will also implement an internal control to monitor the School Corporation’s non-public proportionate share requirements and request supporting documentation from the Cooperative to verify the minimum earmarking requirements are being met. Responsible Party and Timeline for Completion: Corrective action plan has been implemented as this finding impacted fiscal year 2024 but did not recur in fiscal year 2025. Jim Holifield, Chief Financial Officer, will oversee the corrective action plan to monitor the Cooperative on an ongoing basis.

We are reinforcing our invoice verification procedures which include specific instructions on how to enter invoices including invoices without unique numbers so that the accounting system will flag and prevent any future duplicate payments. The accounts payable staff will also receive a refresher training.

Action taken: The district is hiring an additional account clerk (N: Tonn) and the deputy treasurer (R. Heimer) will begin working with the treasurer (C. Meher) so that the treasurer can focus more closely on reporting and more of the duties of the business manager. Review of the final cost reports is ongoing and the Comptroller's Office and/or Office of Grants Finance will be contacted once the internal audit is complete to make any necessary adjustments. This will be done by the treasurer, C. Meher. Anticipated completion date: will begin January 5, 2026 and continue throughout the school year

Finding 2025.004 – Period of Performance Federal Program Name: Continuum of Care Federal Assisted Listing Number:: 14.267 Recommendation We recommend that management implement additional controls and policies over period of performance. Staff who purchase items with grant funds should have additional training on period of performance requirements. Planned Corrective Action: TVCCA is strengthening its period of performance controls through the following actions: 1. Training – All employees with purchasing power will be trained on the deadlines of the grants they are responsible for. This training includes what the definition of obligation truly is, as well as allowable spend down period of their grants. Finance staff will also be trained on the timing and definitions of obligations. 2. Revised internal controls and workflow – Cutoff testing will be performed and added to the month close checklist on a quarterly basis to align with grant closing schedules. 3. Monitoring – Cutoff testing will be monitored on a quarterly basis in association with quarter ending checklist. Name of Contact Person: Max Logan, CFO, 860-425-6506, mlogan@tvcca.org Anticipated Completion Date: March 31, 2026

Duplicate Title I Draw Condition: 2 CFR 200.403 of the Uniform Guidance mandates that only necessary, and allowable costs be drawn down off of federal grants. During the audit, we found that the prior fiscal year's accrued payroll, which was drawn off of the grant In the previous fiscal year, was drawn off of the grant a second time in the current fiscal year, creating questioned costs of $53,509. We recommend that management implement procedures to ensure that all accruals charged to federal grants are properly reversed in the subsequent fiscal year to ensure that duplicate draws on those same expenses are not made. Corrective Action: The District understands what happened and will work on developing procedures to prevent such duplicate draws do not occur in the future. Contact Person Responsible for Corrective Action: Chanda Cleaves, Executive Director of Finance Completion Date: This issue will be corrected moving forward.

Reference Number: 2025-001 Description: Finding 2025-001 - Federal ALN 93.778 Medicaid Cluster Corrective Action Plan: The District will update the setup for Medicaid reporting in Skyward Qmlativ to back out expenditures coded to federal grants, specifically project numbers 341 and 347. Anticipated Corrective Action Plan Completion Date: Corrective action was implemented on July 23, 2025. The district has reviewed reports generated after this date and verified the accuracy of reporting. Contact Information: For additional information regarding this finding please contact Beth Sheridan, Assistant Superintendent of Finance and Operations, at 262-560-2119. Beth Sheridan Assistant Superintendent of Finance and Operations

Research and Development Cluster— Assistance Listing Nos. Various Recommendation: We recommend that the University review its procedures around review and approval of R&D expenditures to ensure that only valid expenditures are reported. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University does have existing internal control processes over its federal grants. The principal investigators code, approve, and submit expenditures for payment. In addition, principal investigators receive periodic grant reports which include the detail of all transactions charged to their grants for review. The University will add an additional control step to review coding of research and development payment requests in the ERP system prior to payment. Names of the contact persons responsible for corrective action: Gerri Stepanek and Carole Kampf Planned completion date for corrective action plan: September 1, 2025

2025-003 Period of Performance (repeat of finding 2024-005) Corrective action planned: Beginning April 1, 2025, when the organization was made aware of this finding in last year’s audit, OMC took immediate corrective actions. The CFO/Designee will monitor expenses, and a separate prepaid schedule has been developed to track future period expenses. OMC’s current CFO/Designee has a basic understanding of GAAP. All coding will be reviewed and approved by an authorized, knowledgeable CFO/Designee. Anticipated completion date: Corrective Action taken on April 1, 2025. Contact person responsible for corrective action: Allen Boyd, Director of Fiscal Operations

Management has enhanced controls over FEMA grant compliance by strengthening the formal review process to verify that costs claimed are eligible, adequately supported, and consistent with FEMA program requirements prior to submission, including the removal of any duplicates.

Planned Corrective Action: All purchase orders will be approved by an Administrator and the Business Administrator. The current software allows for and audit path of approval, changes will be made to include the above practice in accordance with City and School District policy. Name of Contact Person: Dawn Cilley, Business Administrator dcilley@laconiaschools.org Anticipated completion date: September 30, 2026 Example of Planned Corrective Action: School ERP Pro software will be adjusted for an approval path including an Administrator and The Business Administrator.