Corrective Action Plans

2023-001 Significant Deficiency: Internal Controls over Allowable Costs Status: In progress Planned Corrective Action: Management will design, implement, and monitor controls for the retention of employee benefit election forms to adequately document costs charged to federal programs. Anticipated Completion Date: March 31, 2024 Responsible Party: Alec Lundberg, Chief Financial Officer

FINDING 2023-003 Information on the federal program: Subject: Special Education Cluster (IDEA) - Earmarking Federal Agency: Department of Education Federal Program: Special Education Grants to States Assistance Listings Number: 84.027 Federal Award Numbers and Years (or Other Identifying Numbers): 19611-022-PN01, 20611-022-PN01, 21611-022-PN01, 22611-022-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking Audit Findings: Significant Deficiency Condition: 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. Context: The School Corporation is a member of the Greene Sullivan Special Education Cooperative (Cooperative). During fiscal year 2021-2022 and 2022-2023, the Cooperative operated the special education programs and spent the federal money on behalf of all its members.  As the grant agreements were between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. However, there was inadequate oversight performed by the School Corporation in order to ensure compliance with the Matching, Level of Effort, Earmarking compliance requirement. Although the Cooperative has a separate object code to identify expenditures for the purpose of proportionate share, there is no identifier or separate way to track which member school the funding was expended for. As such, the Non-Public Proportionate Share expenditures for the 19611-022-PN01, 20611-022-PN01, 21611-022-PN01, and 22611-022-PN01 grant awards could not be verified for the individual member schools. Additionally, the Cooperative did not obtain a waiver from the Indiana Department of Education for the amount unspent for the requirement on the 19611-022-PN01 and 20611-022-PN01 grant awards. For the 21611-022-PN01 grant award, a waiver was obtained from the IDOE which was used to cover a portion of the member school's required proportionate share amount; however, the remaining amount, which the Cooperative claimed to have expended, could not be traced to documentation that indicated which member school the expenditure was applied to. For the 22611-022-PN01 grant award, no waiver was obtained, and the amounts spent could not be traced to documentation that indicated which member school the expenditure was applied to. Also, the total amount expended for proportionate share was less than the total amount required when all member school proportionate share requirements were totaled. The lack of internal controls and noncompliance were isolated to the 19611-022-PN01, 20611-022-PN01, 21611-022-PN01, and 22611-022-PN01 grant awards. The minimum earmarking requirement for the 19611-022-PN01, 20611-022-PN01, 21611-022-PN01, and 22611-022-PN01 grant awards were $1,931, $3,486, $6,832, and $1,794, respectively. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and will take the following corrective action: 1 – Southwest School Corporation will establish a system of internal controls and procedures to ensure non-public proportionate share funds are appropriately allocated to the member school based on expenses charged directly on behalf of the member school. Supporting documentation for these expenses should be retailed for audit. 2 – Greene Sullivan Special Education Cooperative will require all staff to complete the appropriate google form following the completion of each session with Non-Public students. An example of this documentation is the Proportionate Share Service Log. This document will allow for ease of tracking funds per provider/school district. This will allow for successful usage of funds. In the event that funds are not successfully used, a waiver will be requested barring board approval. Responsible party and timeline for completion: Chris Stitzle, Superintendent, April 1, 2024

FINDING 2023-004 Finding Subject: Child Nutrition Cluster – Allowable Activities & Allowable Costs / Cost Principals Summary of Finding: Internal controls were not in place to ensure compliance with requirements related to the grant agreement, specifically the requirement: Allowable Activities & Allowable Costs / Cost Principals. Contact Person Responsible for Corrective Action: Scott Weltz, Amanda Brackett Contact Phone Number and Email Address: 765-654-5585, weltzs@frankfort.k12.in.us, bracketa@frankfort.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Internal controls will be established and followed to ensure compliance with requirements related to the grant agreement. The Deputy Treasurer or designee will provide payroll distribution reports to the Director for review of payroll claims against the grant. Anticipated Completion Date: Effective immediately and ongoing

Corrective action plan: HHSC completed the correction of the rate prior to year-end close on August 25, 2023. General Ledger Cost Allocation Team will work with CFO Operations Support to develop a query to identify journal transactions that post in the CAPPS Financials general ledger module before the project start date. This query will be run monthly and any exceptions will be corrected. An additional review of the new fiscal year payroll projects will be performed by both Budget and the General Ledger Chartfield teams as part of annual fiscal year close coordination. Implementation date: August 31, 2024 Responsible person: Heather Nevill, Director, Fund Management

FINDING 2023-008 Information on the federal program: Subject: Special Education Cluster (IDEA) - Earmarking Federal Agency: Department of Education Federal Program: Special Education Grants to States Assistance Listings Number: 84.027 Federal Award Numbers: 22611-022-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking Audit Findings: Significant Deficiency Condition: 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. Context: The School Corporation is a member of the Greene Sullivan Special Education Cooperative (Cooperative). During fiscal year 2022-2023, the Cooperative operated the special education programs and spent the federal money on behalf of all its members. As the grant agreements were between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. However, there was inadequate oversight performed by the School Corporation in order to ensure compliance with the Matching, Level of Effort, Earmarking compliance requirement. Although the Cooperative has a separate object code to identify expenditures for the purpose of proportionate share, there is no identifier or separate way to track which member school the funding was expended for. As such, the Non-Public Proportionate Share expenditures for the 22611-022-PN01 grant award could not be verified for the individual member schools. Additionally, the Cooperative did not obtain a waiver from the Indiana Department of Education for the 22611-022-PN01 grant award, no waiver was obtained, and the amounts spent could not be traced to documentation that indicated which member school the expenditure was applied to. Also, the total amount expended for proportionate share was less than the total amount required when all member school proportionate share requirements were totaled. The lack of internal controls and noncompliance were isolated to the 22611-022-PN01 grant award. The minimum earmarking requirement for the 22611-022-PN01 grant award was $1,620. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and will take the following corrective action: 1 – Northeast School Corporation will establish a system of internal controls and procedures to ensure non-public proportionate share funds are appropriately allocated to the member school based on expenses charged directly on behalf of the member school. Supporting documentation for these expenses should be retailed for audit. 2 – Greene Sullivan Special Education Cooperative will require all staff to complete the appropriate google form following the completion of each session with Non-Public students. An example of this documentation is the Proportionate Share Service Log. This document will allow for ease of tracking funds per provider/school district. This will allow for successful usage of funds. In the event that funds are not successfully used, a waiver will be requested barring board approval. Responsible party and timeline for completion: Mark A Baker, Superintendent Effective April 2024

FINDING 2023-006 Finding Subject: COVID-19 Education Stabilization Fund – Allowable Costs/Cost Principles Summary of Finding: The School Corporation did not have effective internal controls over the ESSER funds and there was noncompliance in regards to the ESSER funds. Employee pay did not equal what transferred and supporting documentation for substitute pay and payment of sick days when school was closed. Contact Person Responsible for Corrective Action: Jamesi Lemon and Melanie Summers Contact Phone Number and Email Address: (260) 499-2400; jlemon@lakelandlakers.net/msummers@lakelandlakers.net Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: INDIANA STATE BOARD OF ACCOUNTS 30 A spreadsheet has been created to track the substitutes and the classes they are covering. Pay scales are also now included in the employee handbooks, so pay can be calculated correctly and tracked. Any transfers of payroll expenses are now completed monthly to ensure the correct amounts are being charged to the ESSER funds. Anticipated Completion Date: Immediately

Finding 2023-003 – Special Education Cluster – Earmarking Contact Person Responsible for Corrective Action: Quinnlyn Van Rys Contact Phone Number: 219-850-1914 - qvanrypces.k12.in.us Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Provider/Employee will submit payroll records by student services monthly/bi-monthly to the bookkeeper. Once payroll records are received, the CFO will prepare a spreadsheet that calculates the time 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. This documentation will be reviewed and signed off by the Director of Special Education of Portage Township Schools. Anticipated Completion Date: March 2024

FINDING 2023-003 Finding Subject: Special Education Cluster (IDEA) - Earmarking Summary of Finding: We recommend that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure non-public proportionate share funds are appropriately allocated to the member school based on expenditures charged directly on behalf of the member school. Supporting documentation for these expenditures should be retained for audit. Contact Person Responsible for Corrective Action: Carolyn Wallace Contact Phone Number and Email Address: (812) 738-2168, extension 1012 - WallaceC@shcsc.k12.in.us

Program: AL 21.027 – COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Allowability & Subrecipient Monitoring Corrective Action Plan: Payments to Developmental Disability Providers, Assisted-Living Facilities, and Nursing Facilities for Employee Retention and Recruitment: DHHS is in the process of obtaining affidavits from all Developmental Disability Providers, Assisted-Living Facilities, and Nursing Facilities who received payments under LB1014 stating that funds were used for allowable purposes. Premium Pay: We do not believe any corrective action is warranted as our files were corrected with the Auditor’s guidance and assistance in accordance with all CSLFRF eligibility requirements. Assistance to Nonprofits: For Shovel-Ready awards that have already been granted, DED will confirm prior to close-out of the grant that there is sufficient supporting documentation showing the awardee suffered a harm related and reasonably proportional to the award. Sufficient supporting documents must prove that the nonprofits suffered an economic harm, such as a decrease in revenue or an increase in expenses due to COVID-19. The evidence may include but is not limited to: • Profit and loss statements showing a decrease in revenue or an increase in expenses • Audited financial statements showing a decrease in review or an increase in expenses • Change in a line of credit • Increase in costs for projects related to COVID-19, such as construction cost data, • Decrease in written pledges related to COVID-19 • Decrease in donations related to COVID-19 • Historical fundraising comparisons University of Nebraska: The University project is ongoing. In the next six months, Military/NEMA will initiate monitoring activities to include the review and validation of expenditures for allowability as required under 2 C.F.R. part 200. Nursing Scholarships: DHHS’ current internal controls for the Nursing Scholarship program have minimized the risk of fraud as they correctly identified this case of fraud and have identified others prior to any payment being made. DHHS will continue to review payments for the Nursing Scholarship program, which uncovered the $5,000 identified in the finding. Contact: Payments to Developmental Disability Providers, Assisted-Living Facilities, and Nursing Facilities for Employee Retention and Recruitment: Heather Arnold, CPA, CFE DHHS Deputy Director of Financial Services Premium Pay: Nicole Zimmerman, Finance Director Assistance to Nonprofits: Audrey Sautter, DED Compliance Team Manager University of Nebraska: Erv Portis, Assistant Director-Nebraska Emergency Management Agency (NEMA) Nursing Scholarships: Heather Arnold, CPA, CFE DHHS Deputy Director of Financial Services Anticipated Completion Date: Payments to Developmental Disability Providers, Assisted-Living Facilities, and Nursing Facilities for Employee Retention and Recruitment: June 2025 Premium Pay: N/A Assistance to Nonprofits: DED will draft a policy to place the above into effect within the next 7 days. University of Nebraska: July 2024 Nursing Scholarships: June 2025

Program: AL 21.026 – COVID-19 Homeowner Assistance Fund – Allowability Corrective Action Plan: The Agency will continue to work with NIFA and monitor process improvement. Findings will be reviewed with management and work to eliminate errors. Contact: Erv Portis Anticipated Completion Date: ongoing

Program: AL 21.023 – COVID-19 Emergency Rental Assistance – Allowability & Eligibility & Period of Performance Corrective Action Plan: Continue process improvement to identify and correct assistance payments that are in accordance with the approved timelines and federal regulations. Contact: Erv Portis Anticipated Completion Date: Ongoing

Program: AL 20.509 – Formula Grants for Rural Areas – Allowability & Subrecipient Monitoring Corrective Action Plan: NDOT recently updated the Invoicing Reimbursement Acceptable Documentation Requirement Guidelines. These guidelines offer comprehensive instruction, best practices, and a clearer definition of allowable expenses for subrecipients. The updated guide was distributed to subrecipients in February 2024. Over the next six months, NDOT plans to conduct additional training sessions through opportunities such as the monthly Transit Manager meetings, on-site visits, or webinars with subrecipients. The objective is to ensure a thorough understanding of required documentation and the identification of eligible federal reimbursement expenses. To assist with transit subrecipient monitoring, NDOT management has designated an internal auditor within the Transit Section. The auditor’s focus will be assessing reimbursement documentation, reviewing time studies, evaluating cost allocation plans, developing risk assessment, and helping to intensify monitoring efforts over all subrecipients. NDOT is also in the process of improving and updating the invoice review process to provide consistency for reviewing and approving invoices to enhance accuracy within the Transit Section. Additionally, NDOT has established a dedicated unit “Financial Oversight” within the Transit Section solely focusing on Subrecipient reimbursements. The four staff members in this unit will report directly to Financial Aid Administrator III, this oversight will enhance the quality checks and consistency among subrecipient reimbursements. The Financial Oversight unit will continue to evaluate and refine the operations to ensure federal regulation and required documentation is in place prior to any subrecipient reimbursement. Contact: Jodi Gibson Anticipated Completion Date: On-going

Program: Various, including AL 93.778 – Medical Assistance Program (Medicaid), and AL 93.563 – Child Support Enforcement – Allowable Costs/Cost Principles Corrective Action Plan: The OCIO is currently setting rates for the fiscal year 2026 - 2027 biennium. We are developing standard operating procedures for each rate that is set and charged to customer agencies. In addition, more in-depth documentation will be maintained to justify costs to be recovered and stored in an accessible location for future review. The Print Shop is utilizing a rate setting methodology to develop and substantiate rates at the individual service line level for the fiscal year 2026 – 2027 biennium. Contact: Philip Olsen/Ann Martinez/Noah Finlan Anticipated Completion Date: June 30, 2025

Program: Various, including AL 84.027 – Special Education Grants to States; AL 84.173 – COVID-19 Special Education Preschool Grants; AL 84.425D – COVID-19 Education Stabilization Fund – Elementary and Secondary School Emergency Relief Fund (ESSER I and ESSER II); AL 84.425U – COVID-19 Education Stabilization Fund – American Rescue Plan – Elementary and Secondary School Emergency Relief Fund (ARP ESSER) – Subrecipient Monitoring Corrective Action Plan: First SPED subrecipient – As education subrecipients have had a significant influx of subawards to mitigate post-COVID supports for Nebraska education with limited staff capacity, the Department has remained mindful of these conditions and is on schedule to complete its annual fiscal monitoring efforts within the normal timelines afforded each year. Second SPED subrecipient – Because the UNL utilizes PVS as allowed by 2 CFR 200.430 in regard to salary and wage benefit costs for employees working on a project under a contractual grant agreement, the NDE going forward will require PVS supporting documentation be submitted as a minimum semi-annually for each contract to verify the salary and benefit costs being requested for reimbursement as recommended by the U.S. Department of Education beginning with any payments occurring after March 1, 2023. Third SPED subrecipient – The documentation to support the review of purchased services and supplies during fiscal monitoring was provided to the APA on March 4, 2024. Single Audits – The Director of Grants Management and Director of Grants Compliance will work collaboratively to ensure all subrecipient audits are reviewed and applicable management decision letters are issued within the requested timeframe. Contact: Jen Utemark, Administrator, Office of Budget & Grants Management Anticipated Completion Date: July 1, 2024

Program: AL 93.658 – Foster Care Title IV-E; AL 10.561 – State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; AL 93.659 – Adoption Assistance – Allowable Costs/Cost Principles Corrective Action Plan: DHHS will assign RMTS Administrator rolls to Program staff to better monitor the RMTS process. Contact: Patrick Werner Anticipated Completion Date: 6/30/2024

Program: AL 93.558 – Temporary Assistance for Needy Families; AL 93.563 – Child Support Enforcement; AL 93.568 – Low Income Home Energy Assistance (LIHEAP); AL 93.575 – Child Care and Development Block Grant; AL 93.658 – Foster Care Title IV-E; AL 93.778 – Medical Assistance Program; AL 10.561 – State Administrative Matching Grants for the Supplemental Nutrition Assistance Program – Allowable Costs/Cost Principles Corrective Action Plan: Training will be completed that highlights the importance of complete and accurate Journal Entries and how they may affect Federal Funding. Contact: Patrick Werner Anticipated Completion Date: 6/30/2024

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

FINDING 2023-003 Information on the federal program: Subject: Child Nutrition Cluster - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children, Fresh Fruit and Vegetable Program Assistance Listings Numbers: 10.553, 10.555, 10.559, 10.582 Federal Award Number and Year (or Other Identifying Numbers): FY2021-2022, FY2022-2023 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Adrian Wilkerson, Chief Financial Officer Contact Phone Number and Email Address: (219) 838-1819 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 the Allowable Costs/Cost Principles. Context: The School Corporation had not designed or implemented a system of internal control to ensure that program costs incurred by the Food Service Management Company were supported by proper documentation and were allowable. The School Corporation entered into a cost reimbursement contract with a food service management company (FSMC). The FSMC incurred costs and invoiced the School Corporation for reimbursement of the costs. Due to the lack of effective internal controls, the following errors were noted: In a test of 44 items, 22 items (50%) totaling $6,641 did not have proper documentation to support that the expenses were allowable and for the benefit of food service. Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: In addition to the monthly review of the FSMC invoice and budget, the Chief Financial Officer will review and approve the supporting documentation (invoices, payroll records) provided by the FSMC to ensure that expenses are allowable and for the benefit of food service. Anticipated Completion Date: Immediate

FINDING 2023-003 Subject: Child Nutrition Cluster (CNC) – Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Allowable Costs Audit Findings: Material Weakness Condition: The School Corporation did not have adequate internal controls in place to ensure that the School Corporation complied with the allowable cost requirements. Context: During our testing of the School Corporation’s compliance with the allowable costs requirements for CNC, we noted the following exceptions in our testing of 120 disbursements (60 vendor and 60 payroll): 1. The School Corporation paid $233 of sales tax across three vendor food purchases. 2. For two employee payroll selections, we were unable to trace their rate of pay to a Board approved wage rate ordinance or contract. The total amount paid out to the two employees was $2,635. FINDING 2023-003 (Continued) 3. We identified one employee that the School Corporation incorrectly paid one hour more than what the timecard stated, resulting in an overpayment of $14. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Food Service Director will review and signature all fund 800 expenditures prior to disbursement. All Food Service employee wages will align with the board approved rates. Payroll will be signed as reviewed by direct supervisors and the Business Office prior to remittance. Responsible Party and Timeline for Completion: Implement immediately

FINDING 2023-002 Subject: Child Nutrition Cluster (CNC) – Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Allowable Costs Audit Findings: Material Weakness Condition: The School Corporation did not have adequate internal controls in place to ensure that the School Corporation complied with the allowable cost requirements. Context: During testing of vendor disbursements for the CNC program, we identified 9 disbursements in a sample of 60, for which there was no evidence of a formal documented review of the disbursement taking place prior to the disbursement. Additionally, during testing of CNC payroll disbursements, we selected 8 pay periods for controls testing and noted that none of the 8 pay periods had proof of a formal review of the payroll distribution prior to remittance. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Food Service Director will review and signature all fund 800 expenditures prior to disbursement. Payroll will be signed as reviewed by direct supervisors and the Business Office prior to remittance. Responsible Party and Timeline for Completion: Implement immediately

Finding Number 2023-002 • Significant deficiency in internal controls over compliance related to allowable costs and period of performance. Criteria • 2 U.S. CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards require that costs must be necessary and reasonable for the performance of the Federal Award, that costs be determined in accordance with GAAP, and that costs be adequately documented including the allocation of those costs. Condition/Context for Evaluation • IPHC’s internal controls over non-payroll charges to the Federal Award did not include review for allowability, accrual in the proper period, or that adequate documentation existed to support the amounts charged or allocated. Three out of 25 nonpayroll disbursements tested did not include evidence supporting one or more of these controls. Questioned Costs • $2,674 Cause • IPHC’s operation of internal controls were not sufficient to ensure allowable costs were charged in accordance with 2 U.S. CFR 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. Effect or Potential Effect • As a result, charges were made to Federal awards that were not allowable. Repeat Finding • Not applicable. Recommendation • We recommend that IPHC ensure internal controls include reviewing costs charged to the Federal Award for conformity with 2 U.S. CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards for allowability, allocability, and reasonableness. o Allowability 200.403, 200.404, 200.405 o Allowable budget period – 200.403 (h) Contact Person(s): • Executive Director: David Wilson (david.wilson@iphc.int); • Assistant Director: Andrea Keikkala (andrea.keikkala@iphc.int) Explanation and specific reasons for disagreement with the audit finding or that corrective action is not required (if applicable): Not applicable. Corrective action planned: We acknowledge that the deficiencies identified, while minor in dollar value to the grant, represent areas for improvement. The specific issues identified were: 1. Field office rental: A field office rental statement was partially charged to the incorrect fiscal year. Reason: The landlord submitted the invoice for payment after the year-end close (FY2022) and was subsequently fully charged to FY2023, instead of being split across fiscal years. 2. Postage (2 elements): The IPHC loads postage stamps on a stamps.com account to process missing logbook notices to vessel owners, a function that pertains to a grant. Clear delineation of the cost of the stamps allocated to the grant and the stamps allocated to activities that do not qualify under the grant were not enumerated. The employee that requested the stamps in the procurement software did so because the lead team member was not available. When procuring the stamps the face-value of a stamp was used at $0.60 instead of $0.57, a discount the organization receives due to bulk purchase and stamp.com membership. The cost of this error was $9.96. At the start of FY2023, we used a single operating Fund (Fund 30 – Statistics) to record income and expenses for data related activities that included some grant funds. During the course of the year, we commenced the development of the new 5-year grant application with NOAA Fisheries to cover IPHC’s Directed Commercial Catch Sampling of Pacific halibut in Alaska (IPHC Grant 802) (Grant Number: NOAA-NMFS-AK-2023-2007663) from FY2022-FY2026. During this grant renewal/development process, a decision was taken to split Fund 30 – Statistics into two, with Fund 35 AK Cost-Recovery being created. This new Fund 35 was developed to contain only those expenses and income that were deemed as eligible under the grant rules. Over the course of the year, the Secretariat categorized income and expenses between the two Funds, which involved recoding some transactions coded to Fund 30 at the start of the fiscal year, to Fund 35 later in the year. For FY2024, we will continue to undertake monthly reconciliation and month-end close processes to ensure charges are appropriately coded and attributed. In addition, the year-end reconciliation and close processes will support the attestation of funds spent under the grant within one month of the fiscal year ending. This proactive approach aims to ensure timely completion for the single audit, allowing for comprehensive scrutiny of costs assigned to the grant before incorporating financial statements for review during the single audit process. Further, we will ensure preliminary scrutiny and month-end close of financial reports pertaining to grant funds before loading them to the auditors for review. Finally, our procedures have already been improved to ensure that costs charged to the federal awards are charged to the appropriate activity code and are allowable under federal cost principles. Anticipated completion date: Completed - 1 December 2023, and annually by year-end closeout.

FINDING 2023-004 Finding Subject: Special Education Cluster (IDEA) - Earmarking Summary of Finding: The School Corporation had not properly designed or implemented internal controls over Earmarking to ensure non-public school expenditures were appropriately identified and reported. Contact Person Responsible for Corrective Action Plan: Sara Harpenau Contact Phone Number and email Address: harpenaus@dspcoop.org, 812 482-6661 Views of Responsible Officials: We agree with the finding. Description of Corrective Action: The Finance Manager of the Exceptional Children’s Co-op has developed an Excel spreadsheet and workbook for each of the employees who are providing services to homeschooled children and the private school special education children. This spreadsheet enables them to document the children to whom they provide services, the dates of the services, the purpose of the encounter, and the duration of the visit. Each employee has a calculated goal of the time that is required of them throughout the school year to provide these services. Anticipated Completion Date: This method was implemented in the 2022/2023 school year and will continue with each school year as needed.

FINDING 2023-005 Finding Subject: Special Education Cluster (IDEA) - Earmarking Summary of Finding: The School Corporation had not properly designed or implemented internal controls over Earmarking. Contact Person Responsible for Corrective Action Plan: Sara Harpenau Contact Phone Number and email Address: harpenaus@dspcoop.org, 812 482-6661 Views of Responsible Officials: We agree with the finding. Description of Corrective Action: The Finance Manager of the Exceptional Children’s Co-op has developed an Excel spreadsheet and workbook for each of the employees who are providing services to the homeschooled children and the private school special education children. This spreadsheet enables them to document the children to whom they provide services, the dates of the services, the purpose of the encounter, and the duration of the visit. Each employee has a calculated goal of the time that is required of them throughout the school year to provide these services. Anticipated Completion Date: This method was implemented in the 2022/2023 school year and will continue with each school year as needed.

Finding 2023-001 Information on the federal program: Subject: Special Education Cluster - Earmarking Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.173 Federal Award Numbers: 20611-054-PN01, 20619-054-PN01, 21611-054-PN01, 21619-054-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking Audit Findings: Significant Deficiency Condition: 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. Context: The School Corporation is a member of the Wabash Miami Area Programs for Exceptional Children (Cooperative). During fiscal year 2021-2022 and 2022-2023, the Cooperative operated the special education programs and spent the federal money on behalf of all its members. As the grant agreements were between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. However, there was inadequate oversight performed by the School Corporation in order to ensure compliance with the Matching, Level of Effort, Earmarking compliance requirement. The Non-Public Proportionate Share expenditures for the 20611-054-PN01, 20619-054-PN01, 21611-054-PN01, and 21619-054-PN01 grant awards could not be verified for the individual member schools. The non-public school share funds for all member schools were comingled and the aggregate amount of expenditures was then allocated to the member schools on a percentage basis. These allocations were the amounts reported to IDOE. As such, we were unable to identify which expenditures were for each school in order to verify the minimum amount per the grant award was expended and properly reported to IDOE as required. The School Corporation’s minimum, nonpublic earmarking requirement for grant awards 20611-054-PN01 and 21611-054- PN01 was $1,643 and $7,941, respectively. The School Corporation did not have any minimum, nonpublic earmarking requirement for the 20619-054-PN01 and 21619-054-PN01 grant awards. The lack of internal controls and noncompliance were isolated to the 20611-054-PN01, 20619-054-PN01, 21611-054-PN01, and 21619-054-PN01 grant awards. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. 1. Meet with LEA Superintendent, Director of Special Education, and Office Manager on January 16th, 2024 at 2:00 pm to review current procedure and brainstorm ideas. 2. Meet with IDOE Finance Specialist for clarification. Responsible Party and Timeline for Completion: Ann Higgins, WMAP Special Education Director, will oversee the corrective action plan and timeline for completion. The anticipated completion date is March 1, 2024.

FINDING 2023-007 Finding Subject: Education Stabilization Fund – Allowable Costs/Cost Principles Summary of Finding: Material Weakness, Other Matters The Elementary and Secondary School Emergency Relief (ESSER) Fund provided funding to States and school districts to combat the effects of the coronavirus, help safely reopen and sustain the safe operation of schools, and to address the impact of the coronavirus pandemic on the nation’s students. States were required to subgrant a portion of their ESSER allocation to local educational agencies (LEA). Prior to LEAs receiving their respective subgrants, LEAs were required to complete an application for ARP ESSER funding, which was submitted to the Indiana Department of Education (IDOE), the pass-through entity for approval. The application included a district level budget identifying how the LEA intended to spend program funds. The School Corporation did not have internal controls in place over payroll disbursements charged to the ESSER grant funds. Payroll disbursements were paid without evidence that the detailed report of payroll disbursements was reviewed and approved by another person not involved in the original payroll process. Contact Person Responsible for Corrective Action: Bengamin Mann Contact Phone Number and Email Address: 765-536-0008 bmann@mgusc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Quarterly grant meetings will be held between the CFO, Deputy Treasurer, and Grant writer. This will ensure compliance requirements continue to be met. The CFO now reviews the Org Charge report and signs off before the payroll batch being released to the bank. This report is generated by Payroll and Benefits. Also, this entire report is now included with board claims for board approval rather than a final summary sheet. Anticipated Completion Date: February 2024