Corrective Action Plans

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

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

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.

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.

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

The District will enhance its procedures to ensure that Title I schoolwide program resources are properly allocated to schools. The Director of Federal Programs will consult with the Florida Department of Education about the allowability of the questioned costs.

FINDING 2022-002 Contact Person Responsible for Corrective Action: Teresa Stuckey, Director of Elementary Education and Title I Contact Phone Number: 812-462-4228 Views of Responsible Official: The School Corporation will work with non-public schools to make sure that their enrollment is properly reported. Description of Corrective Action Plan: School Corporation personnel will work with non-public school representatives to secure accurate enrollment information and maintain the proper documentation for audit purposes. Additionally, enrollment data entered on the Title I application portal will be reviewed prior to submission to ensure that data entered agrees with supporting documentation. Anticipated Completion Date: During submission of the 23-24 Title I application.

FINDING 2022-013 Contact Person Responsible for Corrective Action: Tricia Malone Hudson, District Curriculum Specialist Contact Phone Number: 812-279-3521 Views of Responsible Official: We concur with the audit finding. Description of Corrective Action Plan: The district will develop a system for reviewing the Real Time report to ensure accuracy. In addition, the district will maintain a copy of the participating nonpublic school?s summary data related to enrollment and poverty status. Anticipated Completion Date: North Lawrence Community Schools will implement this procedure by June 2023.

FINDING 2022-008 Contact Person Responsible for Corrective Action: Nicole Wolverton, CFO Contact Phone Number: 219-881-5536 Views of Responsible Official: We concur with the audit finding. Description of Corrective Action Plan: A policy and procedure will be created and implemented to ensure that the documentation required to support a student?s socioeconomic status is reviewed and retained for Eligibility compliance. This information will be reviewed and entered by the Testing department with a final review by the Federal Programs Administrator. Anticipated Completion Date: Gary Community School Corporation will implement this procedure by September 2023.