Corrective Action Plans

Finding 2025-004 Title I Grants to Local Educational Agencies – Eligibility Contact Person Responsible for Corrective Action: Superintendent and Title I Program Director Mr. Todd Tanksley Contact Phone Number and Email Address: 812-849-4481 – tanksleyto@mitchell.k12.in.us Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan The School Corporation has established and implemented written internal control procedures to ensure that enrollment and poverty data reported in the October Real Time Reports are reviewed for accuracy and compared to the Title I application prior to submission. Beginning with the current grant cycle, the School Corporation will: 1. Obtain and retain copies of the October Real Time Report data used for each Title I application year. 2. Perform and document a detailed review of enrollment and poverty counts by school utilizing a worksheet that itemizes total enrollment at each school within the district, compares the low-income count according to the Real Time report, the utilized lunch software, and the counts indicated on the Title I application, and indicates a match (or variance in the event of data discrepancy) of the data among those three data sources. INDIANA STATE BOARD OF ACCOUNTS 32 3. Compare the poverty and enrollment data from the October Real Time Reports to the Eligible School Summary within the Title I application. 4. Verify poverty data using source documentation from the school lunch software system. 5. Investigate and resolve any discrepancies identified prior to submission. 6. Maintain documentation supporting the review, comparison, and verification process in accordance with federal record retention requirements under 2 CFR 200.334. Planned Evidence of Correction The School Corporation will maintain the following documentation as evidence of corrective action: ● October Real Time Reports ● Poverty and enrollment comparison worksheets ● School lunch software reports ● Signed and dated review checklists ● Copies of submitted Title I application Anticipated Completion Date Implemented and ongoing beginning with the 2026 Title I application.

Planned Corrective Action: The district will implement controls for monitoring reporting grant requirements and grant expenditures to ensure compliance with reporting and period of performance requirements for federal grants. Anticipated Completion Date: 6/30/26 Responsible Contact Person: Hiwot Abraha

Material Weakness Item 2025-003 - Period of Performance - U.S. Department of Health and Human Services, Health Center Program Cluster (Assistance Listing Number 93.224/93.527) Notice of Award Number 6 HB0CS00505-23-04, 6 H2ECS45602-02-04, 1 H8LCS50772-01-00 and 6 H8/-ICS46163-03-01 During our audit, we noted that LBUCC drew down $190,688 of federal grant funds under the Section 330 program for the budget period beginning June 1, 2024 to reimburse salary expenses incurred in May 2024. Recommendation: We recommend that LBUCC implement procedures to ensure that all drawdowns are supported by expenses incurred strictly within the grant's approved period of performance and train staff on grant compliance requirements. Action Taken: A change in the process to draw down funds has been implemented to determine that the funds were incurred in the proper funding period rather than the period it was paid. Effectivity Date: Process change was implemented 12/1/2025.

FINDING 2024-013 Finding Subject: Title I Grants to Local Educational Agencies - Eligibility Contact Person Responsible for Corrective Action: Tricia Hudson, Curriculum Director & Federal Grants Administrator Contact Phone Number and Email Address: 812.279.3521, ext. 16242; hudsont@nlcs.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The school district will maintain documentation of the nonpublic schools’ rosters with supporting poverty documentation in the form of free and reduced meal applications saved on file with the Title I application annually. Anticipated Completion Date: The school district began the practice above for the 2023-24 school year. The school district has supporting documentation of free and reduced lunch status for nonpublic school students for the 2023-24 school year and moving forward. This corrective action will be fully completed by June 30, 2026.

FINDING 2024-012 Finding Subject: Title I Grants to Local Educational Agencies - Level of Effort – Maintenance of Effort, Earmarking Contact Person Responsible for Corrective Action: Tricia Hudson, Curriculum Director & Federal Grants Administrator Contact Phone Number and Email Address: 812.279.3521, ext. 16242; hudsont@nlcs.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The school district will document all parent involvement expenditures with the object code 661 and all homeless set-aside funds with the object code 660 to ensure that Matching, Level of Effort, and Earmarking compliance requirements are consistently met. Any funds not expended will be carried over under the same Earmarking for the following grant period. The school corporation will properly document all Title I grant expenditures from accounts payable vouchers to payroll and fringe benefits. This documentation will ensure that we can calculate and substantiate that we met earmarking requirements for the grant prior to the closing of the allowable period. Anticipated Completion Date: The school district will comply with this plan for the FY25 Title I grant and for all Title grants moving forward. This corrective action will be fully completed by June 30, 2026.

VIEWS OF RESPONSIBLE OFFICIALS The PRDE acknowledges and accepts the finding. Management recognizes the importance of ensuring that all obligations and expenditures are properly incurred within the authorized period of performance established for each grant in compliance with federal regulations under 2 CFR §200.77 and §200.309. The PRDE has initiated a comprehensive review of the purchase orders (POs) identified in the finding that were obligated after the grant award end date of September 30, 2023. Each program—Adult Education (84.002), Special Education (IDEA, 84.027), and Career and Technical Education (Perkins V, 84.048A)—will evaluate these transactions to determine whether they correspond to allowable and valid obligations incurred during the active grant period. Where applicable and supported by documentation, PRDE will adjust or reclassify the expenses to the appropriate and current grant period. In instances where reassignment to an active grant is not possible, PRDE will identify available state funds to absorb these costs and will process the corresponding reimbursements or journal entries to ensure full compliance with federal requirements. Furthermore, PRDE’s Budget Office, in coordination with the Federal Affairs Office and Finance Office, is in the process of strengthening internal control procedures to prevent the creation of POs after the period of performance. This includes: (i)Automating system controls within the SIFDE accounting system to restrict the creation of POs for grants whose period of performance has expired; (ii)Implement an internal monitoring checklist at the program and budget level to validate the effective date of POs prior to approval; (iii)Establishing a communication between the Budget Office and program offices to ensure that any pending obligations are reviewed and processed before the closeout of the grant period. These corrective actions aim to ensure compliance with federal regulations, strengthen accountability, and enhance the overall effectiveness of the internal control environment related to the management of federal funds. IMPLEMENTATION DATE December 30, 2025 RESPONSIBLE PERSON María de los A. Lizardí Valdés Director Office of Federal Affairs Evelyn Rodríguez Cardé Director of Finance Dr. Jorge L. Acosta Irizarry Auxiliary Secretary of Occupational and Technical Education Dr. Yarilis Santiago Ramos Auxiliary Secretary of Adult Education Enid Díaz Nieves Associate Secretary of Special Education Executive Director

Federal Fund Source liquidation is monitored monthly via the Fund Source Reconciliation Report and the Provider Utilization Report. Requests to close purchase orders associated with expiring federal fund sources are submitted to OPC accordingly. The Federal Financial Reporting Group will now have the right to close purchase orders with federal fund sources to expedite this process. Also, the Provider Utilization Report has been updated with Key Performance Indicators (KPIs), Contract End Date Exceeds Period of Performance and Payments Exceed Period of Performance, that specifically address the period of performance as of December 2024.

FINDING 2024-001 Finding Subject: Title I Grants to Local Educational Agencies - Eligibility Contact Person Responsible for Corrective Action: Carolyn Wallace Contact Phone Number and Email Address: 812-738-2168, extension 102 and WallaceC@shcsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The following internal control procedures will be developed and implemented to assure that enrollment and poverty numbers of non-public schools is correctly entered into the grant application:  The Director for Elementary Curriculum, Instruction and Assessment/Title I Coordinator will utilize the “Guidelines for Title Services to Non-Public Schools” checklist (provided by the Indiana Department of Education during a recent Title I Directors meeting) to assure that all required non-public school related documentation is obtained and documented.  Someone other than the person preparing the Title I grant application will review the application prior to submission to assure that data is entered into the application correctly.  Documentation concerning the collaboration with and information obtained relating to the non-public school eligibility will be retained with the grant files to assure availability during audits. Anticipated Completion Date: April 1, 2025

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

FINDING 2024-007 Subject: Title I Grants to Local Educational Agencies - Eligibility Audit Finding: Material Weakness, Other Matters Contact Person Responsible for Corrective Action: Linda Zaborowski, CFO Contact Phone Number and Email Address: (219) 881-5536 lzaborowski@garycsc.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: The Gary Community School Corporation has implemented a corrective action plan to strengthen internal controls over Direct Certification data related to food service eligibility and to ensure the accuracy of enrollment and poverty data used in the Title I application process. The Business Services Coordinator will oversee a structured monthly verification process to confirm that student eligibility for free or reduced‐price meals is accurately reflected in Skyward, the district’s student management system. Every month, Direct Certification data will be retrieved from the Indiana Department of Education (IDOE) and cross‐checked against Skyward records. Additionally, Real Time reports, which are used to prepopulate enrollment numbers for reporting and compliance purposes, will be reviewed to ensure consistency with the verified Direct Certification data. Any discrepancies found between these data sources will be promptly investigated, corrected, and documented to maintain compliance with federal and state food service regulations. To enhance accountability, staff responsible for managing student eligibility data will receive training on the verification and reconciliation process. This training will ensure that they understand how to properly retrieve Direct Certification data, compare it to Skyward records and Real Time reports, and document necessary corrections. Anticipated Completion Date: Gary Community School Corporation will implement this procedure by July 2025.

FINDING 2024-002 Finding Subject: Title I Grants to Local Educational Agencies - Earmarking Summary of Finding: The school corporation was unable to provide documentation showing that it met the Earmarking requirements for its Homelessness Reservation. Additionally, the school corporation did not carry over the funds to provide Title I, Part A services to students experiencing homelessness in the subsequent school year and reserve funds from the next year’s grant award for this purpose as required. No expenditures related to the homelessness earmarking requirement were identified. It is recommended that the School Corporation’s management strengthen its system of internal controls to ensure Homelessness Reservation and Parental set-aside expenditures are monitored throughout the period of performance to ensure Earmarking requirements are met before expiration of the grant. Contact Person Responsible for Corrective Action: John Szabo, Director of Business Affairs Contact Phone Number and Email Address: (812) 443-4461 / szaboj@clay.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Director of Business Affairs and the Title I Grant Coordinator (currently John Szabo and Dr. Brady Scott, respectively) will review initial Title I budget to verify amount of Homelessness reservation and Parental set-aside. They will create a plan of expenditure for both reservations, and will work with corporation homeless student liaison (currently Rachel Kiefer) to execute the plan. Director of Business Affairs will periodically monitor reimbursements to ensure that spending plan is being completed and that funds are expended appropriately, and will report this to Title I Grant Coordinator upon review. Anticipated Completion Date: July 2025

MENT OF HEALTH AND HUMAN SERVICES 2024-002 Period of Performance Block Grants for Community Mental Health Services – ALN 93.958 Condition: Expenses incurred in fiscal year 2023 were included as expenses to the federal program in fiscal year 2024. Recommendation: We recommend the organization enhance its internal controls to ensure expenses for the correct grant period are charged to the federal program. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will enhance its internal controls to ensure expenses for the correct grant are charged to the federal program properly. Name of the contact person responsible for corrective action: Michelle Glines, Chief Financial Officer Planned completion date for corrective action plan: 6/30/2025

Condition: During the audit, it was identified that $247,000 in federal funds were expended outside of the authorized period of performance for the Emergency Shelter Grant Program under the CARES Act. These expenditures were deemed unallowable by HUD and required repayment. The issue resulted from the lack of an effective monitoring system to track grant performance periods and ensure compliance with federal requirements. Planned Corrective Action: 1. Implement a Grant Period Monitoring System: The organization will establish a formal process for tracking the start and end dates of each grant’s period of performance, including automated alerts and internal checklists. 2. Strengthen Internal Controls: Develop procedures to ensure all expenses are reviewed and approved based on the grant’s performance period before payment or reimbursement/ 3. Staff Training: Provide mandatory annual training for fiscal and program staff on Uniform Guidance cost principles, compliance requirements, and federal reporting standards. 4. Pre-Audit Reconciliation: Conduct quarterly reconciliations of grant expenses to verify compliance with the authorized periods and allowable cost principles. 5. Documentation Submitted to HUD: The organization has submitted supporting documentation and justifications to HUD to validate the expenditures incurred outside the contractual performance period. These expenditures were related to payroll and operational costs within the same program operation. The entity awaits HUD’s determination and will comply with any final resolution or additional corrective guidance provided.

The County agrees with the recommendation and will work with the Grant Administrator to implement policies and procedures to ensure all pre-award payments occur within the grant timelines.

FINDING 2023-004 Finding Subject: Title I Grants to Local Educational Agencies - Eligibility Summary of Finding: One person was primarily responsible for compiling and uploading student data, including poverty status for Real Time reports. There was no additional review or verification being done to ensure that the numbers being pre-populated on the grant applications were correct. There was no internal control in place, such as an oversight, review or approval process to ensure eligibility was properly determined. There was no October 1 Real Time report presented for audit for either fiscal year 2020-2021 or 2021- 2022, which would have been used to pull in enrollment and poverty information for the 2021-2022 and 2022-2023 grants, respectively. Therefore, we were unable to verify if the amounts reported in the grant application were correct. Additionally, we were unable to verify if the correct socioeconomic status was properly reported for any of the students. Contact Person Responsible for Corrective Action: Terry Richey and Chrystal Street Contact Phone Number and Email Address: 812.793.2061 trichey@crothersville.k12.in.us cstreet@crothersville.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The corporation treasurer and superintendent will review current internal controls policies especially segregation of duties and the areas in which we are lacking. We will consider rotation of duties in which employees will learn different roles when possible. We will also consider using technological solutions to enhance the reliability and integrity of processes. Superintendent will retain the Real Time reports and other supporting documentation. Superintendent will also start verifying the numbers pre-populated on the grant application to ensure correct reporting. Another person will start reviewing the application prior to submission to IDOE. Anticipated Completion Date: April 1, 2024

The Department has instituted additional internal controls to ensure that expenditures are liquidated within 90 days of the end of the period of performance as required. This includes a monthly reconciliation of all federal sources performed by the Grants Manager and reviewed by the respective Budget Manager and Finance Director to address any identified issues before the liquidation date. As a redundancy measure, the Budget Manager reviews AP contract activity associated with federal fund sources via the Provider Utilization Report to monitor the liquidation rate in correlation with the liquidation date to ensure all expenditures are captured within the period of performance. Post-liquidation date journal activity is mainly aligned with transactional code cleanup, not necessarily new expense posting outside the period of performance. As such, it doesn’t include or constitute changes to previously submitted federal reporting. To mitigate transactional errors, the Budget Manager, in coordination with the Grants Manager, thoroughly reviews the coding of procurement requests that utilize federal funds for the appropriateness of use and accuracy. This includes deactivating federal fund sources in the statewide accounting system to prevent transactions posting outside of the period of performance. These additional internal controls related to the period of performance were implemented in July 2023. The Office of Internal Audit will perform a review of the updated processes to ensure they are effective in correcting the above findings no later than March 31, 2024.

The Department has instituted additional internal controls to ensure that expenditures are liquidated within 90 days of the end of the period of performance as required. This includes a monthly reconciliation of all federal sources performed by the Grants Manager and reviewed by the respective Budget Manager and Finance Director to address any identified issues before the liquidation date. As a redundancy measure, the Budget Manager reviews AP contract activity associated with federal fund sources via the Provider Utilization Report to monitor the liquidation rate in correlation with the liquidation date to ensure all expenditures are captured within the period of performance. Post-liquidation date journal activity is mainly aligned with transactional code cleanup, not necessarily new expense posting outside the period of performance. As such, it doesn’t include or constitute changes to previously submitted federal reporting. To mitigate transactional errors, the Budget Manager, in coordination with the Grants Manager, thoroughly reviews the coding of procurement requests that utilize federal funds for the appropriateness of use and accuracy. This includes deactivating federal fund sources in the statewide accounting system to prevent transactions posting outside of the period of performance. These additional internal controls related to the period of performance were implemented in July 2023. The Office of Internal Audit will perform a review of the updated processes to ensure they are effective in correcting the above findings no later than March 31, 2024.

FINDING 2023-007 Finding Subject: Title I Grants to Local Educational Agencies - Eligibility Summary of Finding: There was a material weakness, in that the School Corporation had not properly designed or implemented a system of internal controls, including appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance. During the audit period, the School Corporation submitted two Title I Applications using the prior year’s Real Time Report data. The October 2021 Real Time Report used for the 2022-2023 Title I Application was not available for review to ensure compliance with the grant’s eligibility requirement. Contact Person Responsible for Corrective Action: Amanda Knipper Contact Phone Number and Email Address: 574-457-3188 x 1376, aknipper@wawasee.k12.in.us Views of Responsible Officials: Management concurs with the finding. Description of Corrective Action Plan: The Real Time Report data is pulled by Data Exchange directly from the School Corporation’s student management software system. The School Corporation will put a system in place to ensure that all student data within the student software system is accurate to ensure correct reporting of the Real Time data. The Grant Coordinator will review the Real Time report before submission with the information housed in the student management software and a second person will review the data for accuracy. An internal sign-off form will be created and implemented to document the secondary review of the report data. The Superintendent and the Treasurer will both sign off on the data digitally during the certification period as determined by IDOE. Anticipated Completion Date: The projected date of completion is August 2024.

Name of contact person: Rita Huck Corrective Action: The 21st Century Community Learning Centers grant director was told by the Office of Public Instruction that the District could pay for expenditures that were incurred in July, 2022 for a summer program that was held until the middle of July, 2022. These payments were made from the FY 2022 grant that was scheduled to end June 30, 2022. We have discussed how and when obligations and expenditures will be handled going forward. Proposed Completion Date: Immediately.

FINDING 2023-005 Information on the federal program: Subject: Title I Grants to Local Educational Agencies - Eligibility Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies CFDA Number: 84.010 Federal Award Numbers and Years or Other Identifying Numbers: S010A210014, SA10A20014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Finding: Material Weakness, Other Matters Contact Person Responsible for Corrective Action: Regin Johnson, Title I Director Contact Phone Number and Email Address: (219) 838-1819 rjohnson@lakeridgeschools.net Condition: This finding addresses two issues. First, 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 Eligibility compliance requirement. Second, The School Corporation has established a process of receiving and reviewing the listing of students from the Private Schools in order to be entered into the Title I application. However, the internal controls were determined not effective since the School Corporation only requested to receive eligible students listing and not enrolled students. Context: The School Corporation has not established a process of review of the Eligibility Summary in the Title I application for the student enrollment and poverty. Real time report October 1 count is used for the eligibility summary in the Title I application. Additionally, the examiner could not determine if the enrolled private school number was correct because the School Corporation did not request the information. Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Title I Director will review and sign off on the Real Time October 1 report to ensure that the student enrollment and poverty numbers reconcile with what is submitted in the Eligibility Summary. Additionally, the Title I Director will solicit both eligible and total enrollment figures from private schools that wish to participate in Title I. Anticipated Completion Date: The Corrective Action will be implemented immediately and completed upon the filing of the next Real Time report and Eligibility Summary.

(A) Colorado School of Mines will ensure appropriate reviews of expenditures occur to ensure they are within the period of performance for the federal award, and ensure that staff have an appropriate understanding of the related period of performance requirements or obtain clarification from the federal grantor, as appropriate. (B) Mines did not update published Procurement Policies specific to approval limits by position to accurately reflect the delegated approval authority. Mines will update the published policies to accurately reflect delegated approval limits and review the procurement approval process.

COSA has already strengthened year-end and grant period ending procedures by conducting monthly reviews to identify any expenses and unpaid expenses that should be captured and submitted for reimbursement. These reviews are being conducted by the Finance Director and Executive Director.

FINDING 2022-007 Contact Person Responsible for Corrective Action: Kristin Nass Contact Phone Number: 812-752-8935 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: In addition to on-going training and support of the Director of Grants/Programs who oversees Title I, a comprehensive checklist which includes required documentation and actions (including the verified data from non-pub school) is being developed and will be implemented in the spring of 2023. Checklist completion and reviewed data will be signed off by the CFO. Anticipated Completion Date: May 2023

FINDING 2022-010 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: Instead of utilizing journal entries for corrections or adjustments in generic form, corrections to large or for multiple disbursements or receipts should be completed by reversing the action within the financial software and then correctly processing the disbursements or receipts. The on-going training and the related corrective actions which ensure more frequent and more in-depth reviews of reports on a monthly basis will also reduce the need for corrections in general. However, in the event there must be journal entries for corrections, documentation supporting and related to any journal entry will be input into the financial management software, as will any related notes, and any journal entry will have documented approval contained in that software, all completed by separate people ? the Treasurer and CFO. Additional, related training will also be sought to ensure related processes and controls are understood and followed. Anticipated Completion Date: June 2023

Views of Responsible Officials and Planned Corrective Actions: The County agrees with the recommendation and has discussed additional review procedures with the subrecipients. In addition, the County created a Grants Division with increased staffing that can help provide monitoring throughout the year.