Findings Citing § 200.303

FINDING 2025-001 Subject: Child Nutrition Cluster - Eligibility Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program Assistance Listings Numbers: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY24, FY25, FY24-FY25, FY24/25 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Findings: Material Weakness, Other Matters INDIANA STATE BOARD OF ACCOUNTS 13 NINEVEH-HENSLEY-JACKSON UNITED SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Condition and Context The School Corporation had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties, that was effective in preventing, or detecting and correcting, noncompliance related to the eligibility determination of a child receiving meals. Any child enrolled in a participating school who meets the applicable program's definition of "child," may receive meals under the applicable program. In the case of the School Breakfast Program and the National School Lunch Program, children belonging to households meeting nationwide income eligibility requirements may receive meals at no charge or at a reduced price. Children who have been determined ineligible for free or reduced-price school meals pay the full price, set by the School Food Authority, for their meals. As a general rule, a child's eligibility for free or reduced-price meals under a Child Nutrition Cluster program may be established by the submission of an annual application or statement which furnishes such information as family income and family size. Local educational agencies, institutions, and sponsors then determine eligibility by comparing the data reported by the child's household to published income eligibility guidelines. Additionally, a child may be direct certified. For a direct certification, annual eligibility determinations are based on the child's household receiving benefits under the Supplemental Nutrition Assistance Program (SNAP), the Food Distribution Program on Indian Reservations (FDPIR), the Head Start Program (ALN 93.600), or, under most circumstances, the TANF program (ALN 93.558). A household may furnish documentation of its participation in one of these programs, or the school, institution, or sponsor may obtain the information directly from the state or local agency that administers these programs. Certain foster, runaway, homeless, and migrant children are categorically eligible for free school lunches and breakfasts. Direct certified households do not need to complete an application. The Food Service Director was responsible for generating and reviewing the direct certification reports. Eligibility is then manually checked by the Food Service Director or Food Service Manager, then it is cross-referenced with the Child Nutrition Program web database to ensure eligibility was uploaded correctly. For two students tested who received free or reduced priced lunches, the eligibility determination was incorrect. The students were classified as free; however, the students should have been regular paying students. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." INDIANA STATE BOARD OF ACCOUNTS 14 NINEVEH-HENSLEY-JACKSON UNITED SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 7 CFR 245.6 states in part: ". . . (b) Direct certification. In lieu of requiring a household to complete the free and reduced price meal or free milk application, as specified in paragraph (a) of this section, the local educational agency must certify children as eligible for free meals or free milk in accordance with paragraph (b)(1)(i) of this section or may certify children as eligible for free meals or free milk in accordance with paragraph (b)(2) of this section. If a household also submits an application for directly certified children, the direct certification eligibility determination will take precedence. . . . (5) Direct certification documentation. (i) The required documentation for direct certification is provided in paragraph (2) of the definition of Documentation in § 245.2. (ii) (A) Beginning in School Year 2012-2013, direct certification with SNAP shall be conducted using a data matching technique only. Letters to households for direct certification may be used only as an additional means to notify households of children's eligibility based on receipt of SNAP benefits. The last period that letters to households may be used as the primary method for direct certification is School Year 2011-2012. While such notices cannot be the primary method used by a state to document receipt of SNAP, the local educational agency shall accept such a letter if presented by a household. (B) Letters or other documents may be used as the primary method for direct certification to document receipt of FDPIR or TANF benefits. (iii) Individual notices from officials of eligible programs for a Foster child, a Homeless child, a Migrant child, a Runaway child, or a Head Start child, as defined in § 245.2, may continue to be used. These notices are provided to school officials who must certify these children as eligible for free meals or free milk, as applicable, without further application, upon receipt of such notice. . . ." Cause For one student, the School Corporation erroneously accepted a possible match for a student on the direct certification report without confirming the match. The other student was incorrectly entered into the School Corporation's information system as "free." Effect Providing ineligible students free lunches would cause the School Corporation to receive too much federal funding from the program as amounts received are based on free and reduced meals served. Questioned Costs There were no questioned costs identified. INDIANA STATE BOARD OF ACCOUNTS 15 NINEVEH-HENSLEY-JACKSON UNITED SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure student eligibility for free or reduced-price lunches is accurately determined. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

Allowable Costs Federal Agency: United States Department of Education Federal Program Name: Special Education Cluster (IDEA) Assistance Listing Number: 84.027 / 84.173 Federal Award Identification Number and Year: HO27A230021 - 2023 (84.027) HO27A240021 - 2024 (84.027) H173A240024 - 2024 (84.173) H173A230024 - 2023 (84.173) Pass-Through Agency: Connecticut State Department of Education Pass-Through Number(s): 12060-SDE64370-20977-2024 12060-SDE64370-20983-2024 12060-SDE64370-20977-2025 12060-SDE64370-20983-2025 Award Period: 7/1/2023-6/30/2025 (2024 Grant) 7/1/2024-6/30/2026 (2025 Grant) Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matter Criteria or Specific Requirement: Under 2 CFR 200.303, the Board of Education must establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Out of a statistically valid sample of 60 payroll disbursements to individual employees, the Board of Education did not update the employee’s pay rate to reflect the amount approved in the new salary letter / union agreement for 2 payroll disbursements (both pertaining to the same employee). Questioned Costs: None noted. Context: The Town is required to make payroll disbursements in accordance with each employees approved salary letter / union agreement. Cause: 1 employee's pay rate was not updated to reflect the new fiscal year 2025 collective bargaining agreement for their specific union after its implementation in December 2024. Although retroactive pay for hours worked prior to ratification was correctly calculated and paid, the payroll system continued using the prior contract’s rate for all subsequent pay periods through the end of the school year. This occurred due to a failure in the payroll update process following contract implementation. Effect: The employee was underpaid for the remainder of the school year, resulting in non-compliance with the collective bargaining agreement. The absence of adequate internal controls increases the risk of payroll errors and potential fraud. Repeat Finding: No Recommendation: We recommend that the Board of Education implement additional controls over payroll updates and establish a documented process for updating pay rates immediately after contract ratification. Additionally, review and verification of rate changes, along with periodic reconciliation against approved salary schedules or union agreements, should be performed to ensure accuracy and compliance. Views of Responsible Officials and Planned Corrective Action: Management agrees with this finding. The Board of Education will implement additional controls over payroll updates and establish a documented process for updating pay rates immediately after contract ratification. Additionally, review and verification of rate changes, along with periodic reconciliation against approved salary schedules or union agreements, should be performed to ensure accuracy and compliance.

Assistance Listing, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Pell Grant Program ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - N/A Finding Type - Material weakness Repeat Finding - No Criteria - Per 2 CFR 200.303, School Districts are required to establish and maintain effective internal controls over compliance with federal statutes, regulations, and the terms and conditions of federal awards. This includes oversight of third party service providers that manage key systems used in the administration of Title IV programs. Controls over the third party service providers should include access to systems and data, change management, data backup and recovery, and system operations and monitoring. Condition - The School District relies on two third party vendors to manage key financial aid systems, including student information, eligibility determinations, disbursement calculations, and reporting. During the audit period, the institution did not perform any oversight activities or testing to verify the integrity, accuracy, or compliance of the systems managed by the vendor. There were no documented controls, service level agreements, or monitoring procedures in place. Questioned Costs - None If questioned costs are not determinable, description of why known questioned costs were undetermined or otherwise could not be reported - No questioned costs Identification of How Questioned Costs Were Computed - N/A Context - The School District utilizes two third party vendors to manage key financial aid systems. The School District relies on the controls embedded into the systems by the third party vendors; however, the School District does not perform any internal control reviews over one of the systems. Cause and Effect - The School District did not have a formal process for evaluating or monitoring third party service providers. Roles and responsibilities for oversight were not clearly defined, and there was a lack of awareness regarding federal requirements for vendor accountability. The absence of oversight and testing over third party systems increases the risk of undetected errors, data integrity issues, and noncompliance with Title IV requirements. This represents a material weakness in internal control over compliance. Recommendation - We recommend the institution establish formal oversight procedures for third party service providers managing Title IV systems. This should include documented agreements, regular performance reviews, system access controls, and periodic testing of data accuracy and compliance. Responsibilities should be clearly assigned to ensure ongoing monitoring. Views of Responsible Officials and Planned Corrective Actions - The School District agrees with the finding. The School District is implementing oversight practices for its third-party service providers, including maintaining written agreements and setting expectations for regular check-ins and performance reviews. Responsibilities for monitoring will be assigned to ensure ongoing attention to system accuracy and support needs.

2025-001 Reporting – Inaccurate Meal Counts Reported for Reimbursement. Federal Program: Child Nutrition Cluster (10.553, 10.555). Finding Type: Significant deficiency in internal control over compliance, and noncompliance with laws and regulations. Condition: The District did not maintain effective internal controls over the Child Nutrition Cluster to ensure the accuracy of meals served, as reported on monthly Claim Status Reports for reimbursement. Criteria: 2 CFR § 200.303 requires that non-federal entities establish and maintain effective internal control over federal awards that provides reasonable assurance that the entity is managing federal awards in compliance with federal statues, regulations, and the terms and conditions of the federal award. Additionally, 7 CFR § 210.8(a) requires that school food authorities establish internal controls which ensure the accuracy of meals served prior to the submission of monthly Claim Status Reports. At a minimum, these internal controls shall include on-site reviews of the meal counting and claiming system employed by each school in the District, comparisons of daily meal counts against data which will assist in the identification of inaccurate meal counts, and a system for appropriate corrective action when differences or deficiencies are identified. Cause: The District’s oversight of monthly reporting for reimbursement was ineffective in ensuring accuracy in the total number of meals served reported. Effect: The District received reimbursements in excess of meals served. Context: We evaluated meals served for all buildings in the District for three months during the audit period, comparing totals reported per the monthly Claim Status Reports to supporting point-of-sale reports and hard copy count sheets. For the months reviewed, the District served 159,265 total meals and requested reimbursement for 159,419. Questioned Costs: $1,782 Recommendation: The District should establish and maintain effective procedures and internal controls that would identify and correct errors and ensure accuracy prior to submitting monthly Claim Status Reports for reimbursement. View of Responsible Officials: The District agrees with the finding and will implement corrective action to address the condition.

FINDING 2025-002 Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Federal Agency: Department of Education Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children Assistance Listings Numbers: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY 2023-2024, FY 2024-2025 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Condition and Context 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 Procurement and Suspension and Debarment compliance requirement. INDIANA STATE BOARD OF ACCOUNTS 17 PIKE COUNTY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Procurement - Small Purchases Federal regulations allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisition threshold, which is set at $250,000 unless a lower, more restrictive threshold is set by a nonfederal entity. As Indiana Code has set a more restrictive threshold of $150,000, the informal procurement method is permitted when the value of the procurement does not exceed $150,000. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds. Micro-purchases, typically for those purchases $10,000 or under, and small purchase procedures for those purchases above the micro-purchase threshold, but below the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. A total of six claims were determined to require small purchase procedures. Of the six claims, totaling $334,605, four were selected for testing. For two of the four claims selected, the School Corporation did not obtain an adequate number of price or rate quotations. Additionally, documentation detailing the history of procurement, which must include the reason for the procurement method used, was absent for these two vendors. Suspension and Debarment Prior to entering into subawards and covered transactions with federal award funds, recipients are required to verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded. "Covered transactions" include, but are not limited to, contracts for goods and services awarded under a nonprocurement transaction (i.e., grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the SAM exclusions, collecting a certification from that person, or adding a clause or condition to the covered transaction with that person. Upon inquiry, the School Corporation indicated that all service contracts contain a provision regarding suspension and debarment and that the contracts were reviewed and signed by a knowledgeable member of the School Corporation. A population of four covered transactions for goods or services totaling $306,482, all of which equaled or exceeded the $25,000 threshold paid from the Child Nutrition funds during the audit period, was identified and selected for testing. For two of the four selected transactions, the School Corporation did not verify that the vendor was not suspended, debarred, or otherwise excluded from or eligible for participation in federal assistance programs or activities prior to issuing payment. The lack of effective internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: INDIANA STATE BOARD OF ACCOUNTS 18 PIKE COUNTY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.318 states in part: "(a) The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.317 through 200.327. . . . (i) The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. . . ." 2 CFR 200.320 states in part: "The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. (a) Informal procurement methods. When the value of the procurement for property or services under a Federal award does not exceed the simplified acquisition threshold (SAT), as defined in § 200.1, or a lower threshold established by a non-Federal entity, formal procurement methods are not required. The non-Federal entity may use informal procurement methods to expedite the completion of its transactions and minimize the associated administrative burden and cost. The informal methods used for procurement of property or services at or below the SAT include: (2) Small purchases — (i) Small purchase procedures. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity." 2 CFR 180.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or INDIANA STATE BOARD OF ACCOUNTS 19 PIKE COUNTY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (c) Adding a clause or condition to the covered transaction with that person." Cause The School Corporation did not have adequate internal controls to ensure compliance with procurement and suspension and debarment requirements. The Food Service Director was unaware of specific federal requirements regarding procurement thresholds for small purchases and the mandatory verification of vendor suspension and debarment status for transactions exceeding $25,000. The Director relied solely on the Food Service Center to ensure compliance. In addition, the School Corporation utilized additional vendors outside of the center's management scope without independently verifying their compliance status. Effect The lack of an effective internal control system enabled material noncompliance to occur and remain undetected. Noncompliance with the Procurement and Suspension and Debarment compliance requirement could enable small purchases made by the School Corporation to be uncompetitive and could lead to contracting with vendors who are suspended or debarred from receiving federal grant funding. Noncompliance with the grant agreement and the compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure there are appropriate procurement procedures for goods and services and contractors and subrecipients, as appropriate, are verified to not be suspended, debarred, or otherwise excluded prior to entering into any contracts or subawards. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2025-001 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 Number and Year (or Other Identifying Number): 24611-009-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking Audit Findings: Material Weakness, Other Matters INDIANA STATE BOARD OF ACCOUNTS 15 PIKE COUNTY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2023-004. Condition and Context The School Corporation did not have an effective internal control system in place to ensure compliance with the earmarking requirements and to ensure that the required level of expenditures for nonpublic school students with disabilities was met. Specifically, internal controls were not designed to ensure expenditures for nonpublic school students with disabilities were appropriately identified, tracked in the accounting records, and accurately reported. The School Corporation did not meet the earmarking requirements for grant award number 24611-009-PN01. The required expenditures for nonpublic proportionate share was $4,330; however, the School Corporation could only provide documentation of expenditures totaling $2,250. This resulted in an underexpenditure of $2,080 relative to the required set-aside amount for the grant. In addition, the School Corporation did not track the expenditures in a separate line item within the ledger to specifically identify services provided for nonpublic school students. The lack of internal controls and noncompliance was isolated to 24611-009-PN01 grant award. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: . . . (g) Be adequately documented. . . ." 2 CFR 200.208(b) states in part: "The Federal awarding agency or pass-through entity may adjust specific Federal award conditions as needed, . . ." 511 IAC 7-34-7(b) states: "The public agency, in providing special education and related services to students in nonpublic schools must expend at least an amount that is the same proportion of the public agency total subgrant under 20 U.S.C. 1411(f) as the number of nonpublic school students with disabilities, who are enrolled by their parents in nonpublic schools within its boundaries, is to the total number of students with disabilities of the same age range." INDIANA STATE BOARD OF ACCOUNTS 16 PIKE COUNTY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Cause The School Corporation had a lack of documented internal controls and oversight regarding specific grant compliance requirements. The School Corporation Treasurer was unaware of the mandate to separately track and ensure full expenditure of nonpublic proportionate share funds. This lack of knowledge led to an unverified assumption that the Special Education Cooperative was performing this tracking function on the School Corporation's behalf, which was not the case. Effect The School Corporation's lack of internal controls resulted in noncompliance with federal earmarking requirements and the terms of the grant award. The outcome was an underexpenditure of $2,080, representing funds intended for eligible nonpublic students. This amount constitutes questioned costs and may be subject to repayment to the granting agency. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the School Corporation. Questioned Costs We identified $2,080 in known questioned costs as noted above in the Condition and Context. Recommendation Management of the School Corporation should develop written policies and procedures which would require tracking of actual nonpublic proportionate share expenditures. Documentation should be maintained to show how these expenditures are being tracked to ensure compliance with the earmarking requirements. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

Finding 2025-001 – Allowable Costs/Cost Principles Identification of the federal program: Health Resources and Services Administration HIV Emergency Relief Project Grants Assistance Listing No. 93.914 Pass Through Numbers Pass Through Entity Grant Period 11987 PREV King County Public Health 3/1/2024–2/28/2025 13548 PREV King County Public Health 3/1/2025–2/28/2026 Location: Virginia Mason Medical Center, Bailey-Boushay House (Bailey-Boushay House) Criteria or specific requirement (including statutory, regulatory, or other citation): 2 CFR 200.303 (a) requires that a non-federal entity must “(a) establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” 2 CFR 200.430 (i) states “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflected the work performed. These records must: (i) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) be incorporated into the official records of the non-Federal entity; (iii) reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) encompass both federal assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) comply with the established accounting policies and practices of the non-Federal entity.” Condition: Bailey-Boushay House did not have effective internal controls addressing the requirements of 2 CFR 200.303(a) and 2 CFR 200.430, including consistent approval of employees’ timecards. Cause: Bailey-Boushay House’s management did not execute their intended corrective action to implement internal controls in response to the prior year finding. Effect or potential effect: Unallowable and/or inaccurate payroll expenditures could be charged to the federal program. Questioned costs: None. Context: For 2 of 8 payroll expenditures selected for testing, Bailey-Boushay House’s management did not properly approve the employee timecard for time charged to the grant. Total payroll expenditures, including fringe benefits, for Bailey-Boushay House were approximately $1.1 million and represent 29% of the total HIV Emergency Relief Project Grants expenditures of approximately $3.8 million. Identification of a repeat finding: This is a repeat finding – Findings 2024-001, 2023-003, 2022-007, and 2021-008. Recommendation: We recommend management at Bailey-Boushay House execute its processes to properly approve all time charged to federal grants in accordance with 2 CFR 200.430. Views of responsible officials: Management agrees with the finding. Corrective action over timecard approval will be implemented in January 2026.

Finding 2025-002 – Eligibility Identification of the federal program: Health Resources and Services Administration HIV Emergency Relief Project Grants Assistance Listing No. 93.914 Pass Through Number Pass Through Entity Grant Period 11987 PREV King County Public Health 3/1/2024–2/28/2025 13548 PREV King County Public Health 3/1/2025–2/28/2026 Location: Virginia Mason Medical Center, Bailey-Boushay House (Bailey-Boushay House) Criteria or specific requirement (including statutory, regulatory, or other citation): 2 CFR 200.303 (a) requires that a non-federal entity must “(a) establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: Bailey-Boushay House has processes in place to verify whether participants are eligible; however, documentation to evidence the execution of the controls was not retained. Cause: Bailey-Boushay House management did not retain evidence of the execution of controls due to lack of understanding of the need to retain the documentation. Effect or potential effect: Ineligible individuals may be provided services. Questioned costs: None. Context: We issued a material weakness for Bailey-Boushay House related to internal controls in the prior year. Based upon the implementation date of February 2025 for the corrective action provided by management, the finding related to this internal control had not been remediated for the full period under audit. As such, we did not test the operating effectiveness of this control and are issuing a material weakness consistent with the prior year finding. Total expenditures for Bailey-Boushay House were approximately $1.1 million and represent 29.8% of the total HIV program expenditures of approximately $3.8 million. However, expenditures are not based upon serving eligible patients. Identification of a repeat finding: This is a repeat finding – Finding 2024-004. Recommendation: We recommend management maintain evidence of the execution of internal controls related to documentation that individuals served are eligible to participate in the program. Views of responsible officials: Management agrees with the finding and implemented corrective action in February 2025.

Criteria: Under Uniform Guidance (2 CFR §200.302, §200.303, §200.305, §200.318–§200.326, and §200.430), a non-federal entity must establish, document, and maintain written policies and procedures for the management of federal awards. Effective internal control over federal awards provides reasonable assurance that the entity is managing the award in compliance with federal statutes, regulations, and the terms and conditions of the awards. Condition: The Town did not have written policies and procedures required by Uniform Guidance (2 CFR 200) for the administration of its federal programs. Specifically, the Town has not formally documented policies and procedures addressing key areas required under the Uniform Guidance, including but not limited to allowable and unallowable costs and cost principles, procurement standards, suspension and debarment, conflicts of interest, cash management, and reporting and record retention requirements. While informal processes exist, they are not sufficiently documented to ensure consistent application or compliance with federal requirements. Cause: The Town has not developed or formally adopted written federal grant management policies and procedures. Effect: Without formal written policies and procedures, there is an increased risk of noncompliance with federal program requirements. This condition exposes the Town to potential noncompliance with federal regulations, increases the risk of unallowable costs being charged to federal awards, and may affect the Town’s ability to properly administer, monitor, and report federal program activity. Additionally, the lack of documentation may impair continuity of compliance in the event of change in key personnel. Recommendation: The Town should develop, formally adopt, and implement written policies and procedures to comply with Uniform Guidance (2 CFR 200). The policies should address all major compliance areas, including but not limited to allowable and unallowable costs and cost principles, procurement standards, suspension and debarment, conflicts of interest, cash management, and reporting and record retention requirements. The Town should ensure that staff responsible for federal grant administration are properly trained to ensure adherence to these policies and that the policies are reviewed periodically and updated as needed. Views of responsible officials: See management’s responses to findings on Page 78.

Department of Agriculture Federal Financial Assistance Listing #10.766 Community Facilities Loans and Grants Special Tests and Provisions Significant Deficiency in Internal Control over Compliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal awards. Condition: During our testing, there was no formal review separate from the preparer over the reserve fund reconciliations for the federal program. Cause: The Authority did not have an adequate internal control policy in place to ensure review and approval over the reserve fund reconciliations. Effect: The lack of adequate policies governing review increases the risk that employees participating in the federal award administration may not be able to detect and correct noncompliance in a timely manner. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of three months out of twelve months were selected for testing. A lack of documented review was noted for all three months tested. Repeat Finding from Prior Years: No Recommendation: We recommend that the Authority enhance internal control policies to ensure that formal documentation of reviews is present. Views of Responsible Officials: Management agrees with the finding.

Assistance Listing Number, Federal Agency, and Program Name - ALN 14.239, Department of Housing and Urban Development (HUD), Home Investment Partnerships Program Federal Award Identification Number and Year - M18MC260202 2018; M19MC260202 2019; M20MC260202 2020; M21MC260202 2021 Pass through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2024 004 Criteria - Per 2 CFR 200.303, the recipient must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). The City is required to complete inspections of HOME-assisted units to ensure they meet the HUD housing standards outlined in 24 CFR 92.251(b)(viii). During the period of affordability (i.e., the period for which the nonfederal entity must maintain subsided housing) for HOME-assisted rental housing, the participating jurisdiction must perform on-site inspections to determine compliance with property standards and verify the information submitted by the owners no less than (a) every three years for projects containing 1 to 4 units, (b) every two years for projects containing 5 to 25 units, and (c) every year for projects containing 26 or more units. The participating jurisdiction must perform on-site inspections of rental housing occupied by tenants receiving HOME/HOME-ARP-assisted tenant-based rental assistance to determine compliance with housing quality standards (24 CFR sections 92.209(i), 92.251(f), and 92.504(d)). Per 24 CFR 92.504(d) (Sept. 30, 2024), once a housing quality standards inspection is completed, the results must be communicated to the property owner, and any deficiencies identified must be remedied immediately after notification if they are life-threatening and an additional inspection completed within 12 months for all other deficiencies. Condition - The requirements mandate that units be inspected, deficiencies communicated, and corrective actions taken promptly. However, controls over housing quality standards are not effectively designed, reflecting a persistent lack of segregation of duties necessary to ensure compliance. Furthermore, existing controls were insufficient to guarantee that HQS inspection requirements were met and that identified deficiencies were addressed in a timely manner. Questioned Costs - None If Questioned Costs are Not Determinable, Description of Why Known Questioned Costs Were Undetermined or Otherwise Could Not be Reported - N/A Identification of How Questioned Costs Were Computed - N/A Context - During our walkthrough of the City’s processes and controls, we observed that the inspector responsible for conducting inspections of HOME-assisted projects also prepares and signs the certification of completion, with no secondary review in place. In addition, sample testing revealed that 8 of 13 HOME-assisted projects were not inspected according to the established schedule. Finally, 4 of 13 projects did not have deficiencies identified during inspection resolved in a timely manner. Cause and Effect - The absence of effectively designed controls over inspection resulted in material noncompliance with program requirements, as described above. Recommendation - We recommend that the City establish and implement effective internal controls over inspections. These controls should include segregation of duties, independent review of inspection results, and documented approval processes. Strengthening these measures will help prevent errors or omissions from going undetected and reduce the risk of material noncompliance with program requirements. Views of Responsible Officials and Corrective Action Plan - During the fiscal year, the City reviewed and enhanced its internal controls over HQS inspections to strengthen oversight and segregation of duties. Process changes were implemented to ensure that inspections, documentation of deficiencies, follow-up actions, and certifications of completion have independent review and approval. In addition, management implemented monitoring procedures to track inspection schedules to help ensure HQS requirements are met in a timely manner. While corrective actions were initiated during the fiscal year, they were not fully implemented throughout the entire period. By year end, the controls were in place. The City will continue to monitor these controls to ensure ongoing compliance and to prevent similar issues from recurring.

Assistance Listing Number, Federal Agency, and Program Name - ALN 14.239, Department of Housing and Urban Development, Home Investment Partnerships Program Federal Award Identification Number and Year - M18MC260202 2018; M19MC260202 2019; M20MC260202 2020; M21MC260202 2021 Pass through Entity - N/A Finding Type - Material weakness Repeat Finding - Yes 2024 006 Criteria - Per 2 CFR 200.303, the recipient must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission. The HOME program has income targeting requirements such that only low-income or very low-income persons can receive housing assistance, as prescribed by 24 CFR 92.216, which covers income targeting for tenant-based rental assistance and rental units. The City maintains Asset Management Policies and Procedures to comply with these standards, which state that an annual review will be performed on each asset. Condition - The City lacked adequate controls to ensure annual reviews were conducted in accordance with its policy, limiting its ability to exercise proper oversight of eligibility determinations performed by the program’s contractor. If Questioned Costs are Not Determinable, Description of Why Known Questioned Costs Were Undetermined or Otherwise Could Not be Reported - N/A Identification of How Questioned Costs Were Computed - N/A Context - The City engaged a contractor to review developers’ income-eligibility determinations for HOME-assisted housing units. While the contractor performs these reviews, the City retains full responsibility for compliance with eligibility requirements. Our testing showed that the contractor reviewed 62 determinations during the fiscal period; however, the City conducted annual reviews for only 50 of these projects. Additionally, for 5 of 9 projects selected for testing, there was no evidence that the City reviewed the contractor’s certification of the developers’ income-eligibility determinations. As part of our procedures, we reviewed evidence that the contractor performed the required number of reviews and that individuals assessed were income-eligible to receive program benefits. Cause and Effect - The City did not implement controls to ensure eligibility reviews performed by the contractor were in compliance with the terms and conditions of the award. Without oversight of the contractor’s procedures for assessing participant eligibility, there is an increased risk that ineligible participants could receive program benefits, potentially resulting in material noncompliance and repayment obligations to the funder. Recommendation - We recommend that the City continue to implement oversight procedures to conduct and document reviews of contractor work related to compliance requirements and programmatic decisions, specifically, eligibility determinations. Views of Responsible Officials and Planned Corrective Actions - This finding is timing related and was resolved by the City during the fiscal year. The City reviewed and updated its policies and procedures to help ensure proper segregation of duties and proper oversight of eligibility determination. Additional processes now have independent review of inspections after the program’s contractor to further support program compliance. Review responsibilities were put in place to help ensure determinations receive an independent secondary review by city staff. These changes were in place by year end. The City will continue to monitor the program and review procedures to ensure continued compliance and to prevent the recurrence of similar timing-related issues.

Assistance Listing Number, Federal Agency, and Program Name - ALN 93.914, Department of Health and Human Services (HHS), HIV Relief Project Grants Federal Award Identification Number and Year - 6 H89HA00021 32 01 2024 Pass through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.303, the recipient must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission. Per 2 CFR 200.305(b)(3), when the reimbursement method is used, the federal agency or pass-through entity must make payment within 30 calendar days after receipt of the payment request, unless the federal agency or pass-through entity reasonably believes the request to be improper. Condition - A lack of effective controls resulted in noncompliance with federal payment requirements, specifically for payments made to subrecipients. Questioned Costs - None If Questioned Costs are Not Determinable, Description of Why Known Questioned Costs Were Undetermined or Otherwise Could Not be Reported - N/A Identification of How Questioned Costs Were Computed - N/A Context - During testing over a sample of 40 payments to subrecipients, we noted 3 payments that were made more than the required 30 days after the City received a reimbursement request from the subrecipient. Cause and Effect - A lack of effectively operating controls could result in the untimely disbursement of funds to subrecipients and material noncompliance with federal payment requirements. Recommendation - We recommend that the City design and implement controls to ensure compliance with federal payment requirements, including establishing timelines for processing subrecipient payments and review to ensure adherence to federal payment requirements. Views of Responsible Officials and Planned Corrective Actions - The three payments made were paid 1 to 2 days after the 30 day reimbursement requirement. The City will review its subrecipient payment terms and implement additional processes to help ensure compliance with federal payment requirements.

Assistance Listing Number, Federal Agency, and Program Name - ALN 10.557, United States Department of Agriculture, WIC Special Supplemental Nutrition Program for Women, Infants, and Children (WIC) Federal Award Identification Number and Year - E20240675 00 and E20241960 00 2024 Pass through Entity - Michigan Department of Health and Human Services (MDHHS) Finding Type - Material weakness Repeat Finding - No Criteria - 2 CFR 200 Appendix V.4 requires that each central service cost allocation plan be accompanied by a certification, which includes the period to which the accumulated costs under the plan are allocated. 2 CFR 200.303(a) requires nonfederal entities to establish and maintain effective internal controls over federal awards, providing reasonable assurance of compliance with federal statutes, regulations, and award terms. These controls should align with the "Standards for Internal Control in the Federal Government" or the COSO framework. Condition - The City applied indirect costs to the programs in a manner that did not align with the allocation methodology outlined in the 2022-2023 cost allocation plan submitted to MDHHS. Furthermore, the plan lacked explicit certification and contained minor errors and omissions. Questioned Costs - None If Questioned Costs are Not Determinable, Description of Why Known Questioned Costs Were Undetermined or Otherwise Could Not be Reported - N/A Identification of How Questioned Costs Were Computed - N/A Context - The City prepares an annual cost allocation plan as required by 2 CFR 200, Appendix V. During testing, we noted that the City charged indirect costs to ensure the amount did not exceed the budgeted indirect cost amount. However, under the methodology submitted with the plan, indirect costs should have been allocated based on the program’s total direct costs. Although total direct costs were below the budgeted amount, indirect costs were applied without consideration of this methodology. Additionally, the plan lacked evidence of certification and did not accurately specify the allocation period. Following identification of these matters, the City obtained approval from MDHHS permitting indirect costs to be charged without regard to total direct costs and acknowledging oversights in the plan, including the failure to clearly identify the applicable allocation period. Based on MDHHS’ approval, the additional indirect costs charged, though not proportional to total direct costs, did not result in questioned costs. Cause and Effect - The City’s internal controls were not sufficient to ensure that the required certification was performed or to detect the inconsistent application of the indirect cost allocation methodology. This control weakness increases the risk of noncompliance and may result in excessive indirect costs being charged to the program. Recommendation - We recommend that the City conduct a comprehensive review of its indirect cost allocation methodology, incorporating feedback provided by the funder, to ensure consistency between the cost allocation plan and its application. Additionally, the City should design and implement internal controls to verify that indirect costs are applied in accordance with the approved methodology and allocation period. We further recommend that all personnel involved in the preparation, submission, and application of indirect costs receive training on the revised methodology and related controls to prevent future inconsistencies and reduce the risk of noncompliance. Views of Responsible Officials and Planned Corrective Actions - Upon identification, the City worked with the Michigan Department of Health and Human Services and obtained approval and acceptance of the indirect cost calculation. The City will continue to work with MDHHS to ensure full compliance. The City has initiated a review of its indirect cost allocation methodology to ensure compliance. Management is updating the cost allocation calculation to document the approved allocation method and ensure the method is in accordance with the approved plan. The City will also provide training to staff involved in the preparation, submission, and calculation of the indirect costs to ensure understanding requirements.

Federal agency: U.S. Department of Agriculture Federal program name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.556, 10.559 Federal Award Identification Number and Year: 202121N109942, 2025 Pass-Through Agency: Minnesota Department of Agriculture Pass-Through Number: 202121N109942 Award Period: Year ended June 30, 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Non-federal entities other than states must follow the procurement standards set out at CFR sections 200.318 through 200.326. This includes utilizing one of the five allowable procurement methods, including small purchase guidelines for items over the micro-purchase threshold and sealed bids, competitive proposals, or noncompetitive proposals when items exceed the simplified acquisition threshold. In addition, the Uniform Guidance requires that the entity maintain records sufficient to detail the history of the procurement. 2 CFR 200.303 requires that the entity have sufficient controls over compliance related to federal awards. Condition: During our testing of the District’s procurements within the Child Nutrition program, it was noted that not all procurements followed the appropriate method and history of the transaction was not sufficiently documented. Questioned Costs: ALN 10.553 and 10.555 - $220,560.64 Context: Out of thirteen procurement which were tested, we noted one of them for which the District did not retain documentation detailing the history of the procurement, including the rationale for choosing the particular vendor. This was a statistically valid sample. Cause: Controls were insufficient to ensure this process occurred. Effect: The District was not in compliance with Uniform Guidance requirements for the proper documentation of all procurement transactions. Repeat Finding: No Recommendation: We recommend the District reviews its procedures and controls over procurement to ensure that all procurements are documented such that a third party can clearly see and understand the detailed history of the procurement. Views of responsible officials: There is no disagreement with the audit finding.

FINDING 2025-001 Information on the federal program: Subject: Child Nutrition Cluster - Internal Controls over Eligibility Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY2024, FY2025 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Finding: Material Weakness Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 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 the eligibility compliance requirement. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with eligibility requirements. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There were no questioned costs identified. Context: During the testing of internal controls over eligibility determinations for free and reduced meals, we noted there was no formal, documented review control in place. There is no documented, secondary review for the applications entered in the food service software which determines eligibility. Additionally, there was no documented review by School Corporation personnel of the Income Eligibility Guidelines used by the food service software which are updated on annual basis. Identification as a repeat finding, if applicable: No. Section III – Federal Award Findings and Questioned Costs (Continued) FINDING 2025-001 (Continued) Recommendation: We recommend that the School Corporation's management establish an internal control process to review the updates to the annual adjustments to the Income Eligibility Guidelines made to the food service software to determine eligibility to ensure updated guidelines are accurate and complete. This review should be documented on annual basis to confirm management’s oversight and monitoring of eligibility determinations. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.

Federal Agency: U.S. Department of Transportation Federal Program Name: Highway Planning and Construction Assistance Listing Number: 20.205 Federal Award Identification Number and Year: STP-5419 (613) - 2021 Pass-Through Agency: Missouri Department of Transportation Pass-Through Number(s): STP-5419 (613) Award Period: 2025 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Per Uniform Guidance 2 CFR 180.300 nonfederal entities entering into covered transactions must verify the party is not suspended or debarred from conducting business by the federal government. This can be performed by: Checking SAM exclusions, collecting a certification from the party, or adding a clause or condition to the covered transaction. Condition: The City did not maintain documentation indicating the date the SAM check was completed prior to entering into a covered transaction. Questioned costs: None Context: No process exists to review SAM exclusions list comparing the listing of vendors with expenditures exceeding $25,000 and documenting date this check was performed. Cause: The City does not have a control in place to ensure the SAM exclusion check is performed before entering into a covered transaction. Effect: The City could enter into a covered transaction with an entity that is suspended or disbarred. Repeat Finding: No Recommendation: We recommend that the City evaluate its procedures and implement an additional control to ensure verifications checks are occurring prior to entering into contracts with a vendor. Views of responsible officials: There is no disagreement the audit finding.

FINDING 2025-001 Subject: Title I Grants to Local Educational Agencies - Special Tests and Provisions - Annual Report Card, High School Graduation Rate Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listings Number: 84.010 Federal Award Numbers and Years (or Other Identifying Numbers): S010A220014, S010A230014, S010A240014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Annual Report Card, High School Graduation Rate Audit Findings: Material Weakness, Other Matters Condition and Context The internal controls in place at the School Corporation were not effective in order to ensure compliance with requirements related to the grant agreement and the Special Tests and Provisions - Annual Report Card, High School Graduation Rate compliance requirement. The School Corporation must report graduation rate data for all public high schools within the School Corporation using the four-year adjusted cohort rate. To remove a student from the cohort, the School Corporation must confirm the reason for removal in writing. Additionally, required documentation for each removal type must be retained by the School Corporation. Of the 25 students selected for testing, 2 students did not have any supporting documentation. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 20 USC 7801(23)(B) states: "To remove a student from a cohort, a school or local educational agency shall require documentation, or obtain documentation from the State educational agency, to confirm that the student has transferred out, emigrated to another country, or transferred to a prison or juvenile facility, or is deceased." INDIANA STATE BOARD OF ACCOUNTS 16 SCHOOL CITY OF HAMMOND SCHEDULE OF FINDINGS AND QUESTIONED COSTS Cause The 2 students' cumulative files could not be located by the School Corporations, thus, resulting in supporting documentation not to be retained. Effect Noncompliance with the grant agreement and the compliance requirement could result in the repayment of federal funds. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management evaluate the internal control policies and procedures to ensure the proper documentation is maintained for students that are removed from the cohort. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

Type of Findings: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Per 2 CFR 200.303, requires that non-federal entities receiving federal awards establish and maintain internal control designed to reasonably ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award. Effective internal controls should include procedures in place to ensure the required certifications for covered contracts and subawards are received, documented, and contracts are not made with a debarred or suspended party. Condition: During our review we noted that the district followed procurement guidelines and policies established in the DJB Federal Procurement guide, but the District does not have an established suspension and debarment policy that they follow. Effective internal controls should include procedures in place to ensure the required certifications for covered contracts and subawards are received, documented, and contracts are not made with a debarred or suspended party. Questioned costs: None Context: The sole vendor engaged under the IDEA grant was found to have no evidence of verification that the vendor was not suspended or debarred by the District. We did later verify that the vendor was not suspended or debarred per verification on SAM.gov. Cause: The District engaged with the vendor in a contract effective from 07/01/2023, but did not conduct a suspension and debarment check prior to engagement. Effect: The District could not be in compliance with suspension and debarment requirements for its federal programs. Repeat Finding: No Recommendation: We recommend that the District implement policies for verifying suspension and debarment compliance for all transactions with vendors that are paid with Federal Funds. View of Responsible Officials: There is no disagreement with the audit finding. Corrective action plan - management response: The District will formally adopt a Suspension and Debarment Verification Procedure that outlines the required process for verifying all vendors and subrecipients before entering into any contract funded by federal awards. Staff will verify suspension and debarment status by checking the System for Award Management (SAM.gov) prior to contract execution and will maintain documentation of verification in the procurement file. The Business Services Department will complete training on the new procedure and documentation requirements. Responsible Party: Business Manager Completion Date: Procedure adoption and staff training by December 31, 2025

2025-001- Unaccompanied Children Program - ALN 93.676- Reporting - Internal Control (Significant Deficiency) Grant No. 90ZU0620 Passed through from Board of Child Care of the United Methodist Church Grant Period: January 1, 2024 - December 31, 2026 Criteria: 2 CFR 200.303(a) requires non-Federal entities to establish and maintain effective internal controls over compliance with Federal statutes, regulations, and terms and conditions of Federal awards. Quarterly Federal Financial Reporting (FFR) report is required to be submitted by the 15th of the following month. Condition: The quarterly FFR due April 15, 2025 and July 15, 2025 were both filed on September 11, 2025. Questioned Costs: None noted. Effect: Failure to file reports timely could result in noncompliance with regulations and withdrawal of funding. Cause: The late filings were a result of inexperience regarding the filing requirements of the federal grant award. Recommendation: We recommend implementing controls to ensure all reports are filed timely and properly documented. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding. The Home promptly filed the FFRs on September 11, 2025 when made aware of the late filings. The Home designated the controller with responsibility for grant reporting including quarterly Federal Financial Reporting (FFR) and will implement policies and procedures to ensure timely filing going forward starting with the October 15, 2025 filing deadline.

Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.556, 10.559 Federal Award Identification Number and Year: 252MN061N1199 – 2025 Pass-Through Agency: Minnesota Department of Education Pass-Through Number(s): 1-2859-000 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Related to reporting requirements of the Child Nutrition Cluster, there should be a documented control in place to ensure all reports have proper documented review and approval prior to submission. Title 2 U.S. Code of Federal Regulations § 200.303 states that the auditee must establish and maintain effective internal control over the federal award that provides reasonable assurance that the auditee is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: During our testing it was noted that, for 1 of 4 reports tested, the District was not able to provide any documentation of the review performed to ensure they are meeting federal requirements surrounding reporting. Questioned costs: None Context: 1 of 4 reports selected for testing were missing documentation of the review and approval. Cause: The District has a procedure in place to address this finding. However, due to turnover, this procedure was missed on one of the reports tested. Effect: It is possible that if there were errors on the report they would not be caught by the internal control. Repeat finding: No Recommendation: The District ensures their key controls are operating effectively and documents the review and approval of all the reports. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Treasury Federal Program Name: Community Development Financial Institutions Equitable Recovery Program Assistance Listing Number: 21.033 Federal Award Identification Number and Year: 22ERP061061 – 2022 Award Period: April 10, 2023 through December 31, 2028 Type of Finding: - Material Weakness in Internal Control over Compliance - Other Matter Criteria or specific requirement: Per 2 CFR §200.303 and Government Auditing Standards (GAS), recipients of federal awards must establish and maintain effective internal control over federal programs. This includes maintaining documentation that supports the allowability of expenditures in accordance with the terms and conditions of the federal award. Condition: The original Schedule of Expenditures of Federal Awards (SEFA) submitted by the Credit Union included $2,331,150 in expenditures that appeared consistent with allowable uses under the grant agreement. However, the Credit Union did not maintain transaction-level tracking or retain detailed supporting documentation to substantiate the allowability of these expenditures. This lack of contemporaneous documentation prevented the audit team from obtaining sufficient appropriate audit evidence to confirm compliance with CDFI Fund requirements. Questioned costs: None Context: The deficiency was identified during the audit of the SEFA and reconciliation of unearned grant revenue. The original SEFA lacked sufficient documentation, and the audit team had to expand procedures to validate the revised expenditure amounts. Following this, Management performed a detailed analysis and reconciliation of grant-related transactions, which resulted in an updated SEFA. This revised schedule included properly supported expenditure details, ensuring alignment with grant requirements and correcting prior documentation gaps. Cause: The Credit Union did not implement adequate internal controls to ensure contemporaneous tracking and documentation of grant expenditures. This may have been due to limited staffing, lack of formal procedures, or insufficient training on federal grant compliance requirements. Effect: The absence of transaction-level tracking and supporting documentation created a risk of material misstatement in the SEFA and noncompliance with federal grant requirements. Although management later provided an updated SEFA with supported expenditures totaling $2,354,606, the initial lack of documentation could have led to disallowed costs or questioned costs if not corrected. The $23,456 difference between the updated SEFA and recorded grant revenue was not considered material to the financial statements. Repeat finding: Not a repeat finding. Recommendation: We recommend that the Credit Union implement procedures for transaction-level tracking of all federal grant expenditures to ensure accurate and complete records. The organization should maintain contemporaneous documentation that clearly supports the allowability of each expenditure in accordance with federal requirements. Additionally, staff should receive training on federal grant documentation and compliance requirements to strengthen understanding and adherence to applicable regulations. Finally, the Credit Union should perform periodic internal reviews to verify that documentation standards are consistently met and that internal controls remain effective. Views of responsible officials and planned corrective actions: Management agrees with the finding and acknowledges the need to strengthen internal controls over grant expenditure documentation. They have committed to implementing the recommended procedures.

FINDING 2025-001 Subject: Special Education Cluster (IDEA) - Procurement Federal Agency: Department of Education Federal Programs: Special Education Grants to States, COVID-19 - Special Education Grants to States Assistance Listings Numbers: 84.027, 84.027X Federal Award Numbers and Years (or Other Identifying Numbers): 22611-043-ARP, 23611-043-PN01, 24611-043-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion INDIANA STATE BOARD OF ACCOUNTS 15 RIVER FOREST COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Condition and Context The School Corporation is a member of the Northwest Indiana Special Education Cooperative (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 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 Procurement and Suspension and Debarment compliance requirement. When the value of the procurement for property or services exceeds the simplified acquisition threshold (SAT), or a lower threshold established by a nonfederal entity, formal procurement methods are required. The SAT is typically set at $250,000. However, Indiana Code 5-22-8 has a more restrictive threshold, and, therefore, the SAT threshold is set at $150,000. Formal procurement methods require adherence to documented procedures and formal methods such as sealed bids or proposals. The School Corporation did not have internal controls in place to ensure that the Cooperative complied with procurement requirements. The Cooperative did not have procedures in place to ensure compliance with procurements in excess of the SAT threshold. During 2023-2024, the Cooperative had three vendors which exceeded the SAT and all three vendors were tested. The Cooperative did not obtain sealed bids or competitive proposals, nor was a circumstance met that would have allowed for a noncompetitive procurement for the purchases. The total dollar amount spent with all three vendors was $1,417,349. The lack of internal controls and noncompliance were systemic issues limited to 2023-2024. Criteria 2 CFR 200.303 states in part: "The recipient and subrecipient must: (a) Establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control-Integrated Framework' issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.320 states in part: "The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. (a) Informal procurement methods. When the value of the procurement for property or services under a Federal award does not exceed the simplified acquisition threshold (SAT), as defined in § 200.1, or a lower threshold established by a non-Federal entity, formal procurement methods are not required. The non-Federal entity may use informal procurement methods to expedite the completion of its transactions and minimize the associated administrative burden and cost. The informal methods used for procurement of property or services at or below the SAT include: . . . INDIANA STATE BOARD OF ACCOUNTS 16 RIVER FOREST COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (b) Formal Procurement Methods. When the value of the procurement for property or services under a Federal financial assistance award exceeds the SAT, or a lower threshold established by a non-Federal entity, formal procurement methods are required. Formal procurement methods require following documented procedures. Formal procurement methods also require public advertising unless a non-competitive procurement can be used in accordance with § 200.319 or paragraph (c) of this section. The following formal methods of procurement are used for procurement of property or services above the simplified acquisition threshold or a value below the simplified acquisition threshold the non-Federal entity determines to be appropriate: (1) Sealed bids. A procurement method in which bids are publicly solicited and a firm fixed-price contract (lump sum or unit price) is awarded to the responsible bidder whose bid, conforming with all the material terms and conditions of the invitation for bids, is the lowest in price. The sealed bids method is the preferred method for procuring construction, if the conditions. . . . (2) Proposals. A procurement method in which either a fixed price or cost-reimbursement type contract is awarded. Proposals are generally used when conditions are not appropriate for the use of sealed bids. . . ." Cause The Cooperative noted they were unaware of the procurement requirements of expenditures exceeding the SAT. They stated they have used the same vendors to provide professional services for several years but only recently started using federal grant award funds for the services. Effect Without the proper implementation of an effectively designed system of internal controls, the School Corporation cannot ensure the vendors paid with federal award funds by the Cooperative are procured using the required methods. Without following the required methods for procurement, the Cooperative could be overpaying for services. Questioned Costs There were no questioned costs identified. Recommendation Management of the School Corporation should develop written policies and procedures which would require that appropriate procurement methods are used by the Cooperative for vendors that exceed the SAT. Appropriate documentation should be maintained to ensure the procurement methods are being followed and compliance with procurement methods are being followed. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2025-002 Subject: Special Education Cluster (IDEA) - Earmarking Federal Agency: Department of Education Federal Programs: Special Education Grants to States, COVID-19 - Special Education Grants to States, Special Education Preschool Grants, COVID-19 - Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.027X, 84.173, 84.173X Federal Award Numbers and Years (or Other Identifying Numbers): 22611-021-PN01, 22611-021-ARP, 22619-021-ARP, 23611-021-PN01, 23619-021-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking Audit Findings: Material Weakness, Modified Opinion Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2023-004. Condition and Context The School Corporation is a member of the Greater Lafayette Area Special Services (GLASS) Cooperative (Cooperative). During fiscal year 2023-2024, 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 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, 26311-021-PN01, and 23619-021-PN01 grant awards. INDIANA STATE BOARD OF ACCOUNTS 17 LAFAYETTE SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (g) Be adequately documented. . . ." 2 CFR 200.208(b) states in part: "The Federal awarding agency or pass-through entity may adjust specific Federal award conditions as needed . . ." 511 IAC 7-34-7(b) states: "The public agency, in providing special education and related services to students in nonpublic schools must expend at least an amount that is the same proportion of the public agency total subgrant under 20 U.S.C. 1411(f) as the number of nonpublic school students with disabilities, who are enrolled by their parents in nonpublic schools within its boundaries, is to the total number of students with disabilities of the same age range." Cause A proper system of internal controls was not designed by management of the School Corporation. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As such, the School Corporation's nonpublic proportionate share expenditures could not be determined, and it could not be determined if the School Corporation met its minimum nonpublic proportionate share as required by the grant agreement. INDIANA STATE BOARD OF ACCOUNTS 18 LAFAYETTE SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure nonpublic 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 retained for audit. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2025-001 Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment 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 Numbers and Years (or Other Identifying Numbers): FY 23/24, FY 24/25 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Other Matters This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2023-002. Condition and Context The School Corporation had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties, to ensure compliance with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Procurement Federal regulations allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisition threshold, which is set at $250,000 unless a lower, more restrictive threshold is set by a nonfederal entity. As Indiana Code has set a more restrictive threshold of $150,000, informal procurement methods are permitted when the value of the procurement does not exceed $150,000. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds: micro-purchases, typically for those purchases $10,000 or under, and small purchase procedures for those purchases above the micro-purchase threshold but below the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. During the audit period, a total of four vendors were determined to require small purchase procedures, and all four vendors were selected for testing. For two of the four vendors, the School Corporation could not provide the procurement history or the rationale for the method of procurement, selection of vendors, and basis for price. The total dollar amount spent with these two vendors was $165,131. Suspension and Debarment Prior to entering into subawards and covered transactions with federal award funds, recipients are required to verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded. "Covered transactions" include, but are not limited to, contracts for goods and services awarded under a nonprocurement transaction (i.e., grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the SAMs exclusions, collecting a certification from that vendor, or adding a clause or condition to the covered transaction with that vendor. INDIANA STATE BOARD OF ACCOUNTS 14 SOUTH SPENCER COUNTY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) During review of the School Corporation's procedures, officials stated that the Food Service Director verified that vendors were not suspended or debarred by including a clause in the vendor contract or by collecting a certification from the vendor prior to entering into a covered transaction. We identified ten transactions during the audit period that equaled or exceeded $25,000 and were therefore determined to be covered transactions. All ten transactions, totaling $767,259, were selected for testing. The School Corporation was unable to provide documentation that the vendor's suspension and debarment status was verified for four of these transactions, which comprised the same two vendors for both years of the audit period. The total dollar amount spent with these two vendors was $268,962. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.318 states in part: "(a) The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.317 through 200.327. . . . (i) The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. . . ." 2 CFR 200.320 states in part: "The non-Federal entity must have and use document procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. INDIANA STATE BOARD OF ACCOUNTS 15 SOUTH SPENCER COUNTY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (a) Informal procurement methods. When the value of the procurement for property or services under a Federal award does not exceed the simplified acquisition threshold (SAT), as defined in § 200.1, or a lower threshold established by a non-Federal entity, formal procurement methods are not required. The non-Federal entity may use informal procurement methods to expedite the completion of its transactions and minimize the associated administrative burden and cost. The informal methods used for procurement of property or services at or below the SAT include: . . . (2) Small purchases– (i) Small purchase procedures. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. . . ." 2 CFR 180.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person." Cause The School Corporation's corrective action plan from the prior audit stated that the Food Service Director was the individual responsible for implementing the corrective action measures and that those measures would be implemented in June 2024. The Food Service Director resigned, however, in May 2024. Therefore, the new Food Service Director was unaware of the compliance issues and the need to implement the corrective action measures during the current audit period. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of preventing, or detecting and correcting, noncompliance. As a result, the School Corporation did not comply with the small purchase procurement requirements or the suspension and debarment requirements of the federal award. By not properly completing the procurement process, the School Corporation could have overpaid for the goods or services that were procured. Additionally, the School Corporation could have made payment to a vendor that was suspended or debarred. Payments to such vendors are unallowable. Noncompliance with the grant agreement and the compliance requirement could result in the loss of future federal funds to the School Corporation. INDIANA STATE BOARD OF ACCOUNTS 16 SOUTH SPENCER COUNTY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a proper system of internal controls and develop policies and procedures to ensure expenditures made from federal awards are in compliance with the procurement and suspension and debarment compliance requirements. The School Corporation's system of internal controls should be designed to ensure that the appropriate procurement method is utilized and that documentation is retained to support the procurement methods used in order to ensure compliance with the terms and conditions of the federal award. Additionally, the system should be designed to ensure that vendors are not suspended or debarred, or otherwise excluded, prior to the School Corporation entering into a covered transaction. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2025-002 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 Numbers: 84.425U, 84.425D Federal Award Numbers and Years (or Other Identifying Numbers): S425U210013, S425D200013 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Findings: Material Weakness, Other Matters Condition and Context The School Corporation did not have an effective system of internal controls over federal award requirements that would have ensured that expenses charged to the grant were for activities and costs that were allowable under the federal award. The School Corporation designed a process for vendor claims in which all purchase orders were approved by either the Superintendent of Schools or a member of his staff who was knowledgeable of the requirements of the federal program, with the associated claim vouchers, then reviewed by another employee who was also knowledgeable of the requirements of the federal program prior to submission to the School Board for final approval for payment and inclusion on the reimbursement requests submitted for the program. Out of a sample of 25 claims selected for internal control testing, the School Corporation was unable to provide 5 claim vouchers to show the aforementioned review and approval. We were therefore unable to verify that the stated internal control was properly implemented and operated effectively for those claims to ensure the expenditures were for activities and costs allowed under the federal award. INDIANA STATE BOARD OF ACCOUNTS 17 SOUTH SPENCER COUNTY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) The School Corporation also designed a process for payroll claims where the Superintendent of Schools reviewed and approved the detailed payroll distribution reports which included employees with payroll expenses charged to the federal award. However, the internal control was not adequately designed and did not detect noncompliance with the allowable cost requirements of the award. During compliance testing of vendor and payroll claims, one payroll claim for a Certified Intervention Teacher was selected for testing. The School Corporation was unable to provide documentation to support the determination of the amount of the teacher's total salary that was allocated to the federal award. We then reviewed all payroll expenses associated with the Certified Intervention Teacher position paid out of the federal award during the audit period and determined that a total of $22,416 was charged to the federal award without proper documentation to support the amount of the teacher's salary allocated to the federal award. We consider the $22,416 to be questioned costs. The lack of effective vendor internal controls was systemic to both awards but was isolated to fiscal year 2023-2024 prior to the appointment of the current Treasurer. The lack of effective payroll internal controls was systemic to both awards, while the noncompliance was isolated to award number S425U210013. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following . . . (3) Records that identify adequately the source and application of funds for federally funded activities. These records must contain information pertaining to Federal awards, authorizations, financial obligations, unobligated balances, asses, expenditures, income and interest and be supported by source documentation. . . ." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. . . . INDIANA STATE BOARD OF ACCOUNTS 18 SOUTH SPENCER COUNTY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (g) Be adequately documented. . . ." Cause The School Corporation experienced turnover in a key position related to the internal controls over the federal award, resulting in issues with organization and retention of supporting documentation to verify the key internal control over vendor claims. In addition, the School Corporation's policies and procedures were not properly designed to show the determination of how employees' compensation would be allocated to multiple cost centers. As a result, the key internal control over payroll claims was unable to prevent, or detect and correct, noncompliance with the allowable costs requirement of the federal award. Effect Without proper implementation of an effectively designed system of internal controls, noncompliance that resulted in questioned costs remained undetected. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the School Corporation. Questioned Costs We identified $22,416 in known questioned costs as noted in the Condition and Context. Recommendation We recommended that the School Corporation's management establish a proper system of internal controls to ensure expenditures made from federal awards are for activities and costs allowed per the terms and conditions of the federal award and in compliance with the Activities Allowed or Unallowed and the Allowable Costs/Cost Principles compliance requirements. We also recommended that the School Corporation strengthen its policies and procedures to ensure that appropriate supporting documentation is retained and available for audit. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

2025-001 Documentation of Internal Controls over Federal Awards Year Finding Originated: 2025 Criteria: Per 2 CFR § 200.303(a), the non-Federal entity must establish, document, and maintain effective internal control over Federal awards that provides reasonable assurance that the entity is managing the award in compliance with Federal statutes, regulations, and the terms and conditions of the awards. Condition: Although the City maintains formal policies and procedures which document internal controls, the policies are not up to date with current Federal requirements and are not prescribed as required by the Uniform Guidance. Further, the policies do not cover all aspects of compliance pertaining to the federal programs the City facilitates. Cause: City management was not aware of all documentation requirements under Uniform Guidance for internal controls over federal programs. Effect: The City’s failure to document internal control procedures related to federal programs increases the risk of noncompliance with federal requirements, misstatement of financial reports, and potential misuse of federal funds. Recommendation: We recommend that the City enhance and document internal controls over federal awards in accordance with 2 CFR § 200.303(a). Views of responsible officials: See management’s response to finding on Page 72.

Assistance Listing Number, Federal Agency, and Program Name - 84.007, 84.063, 84.268; U.S. Department of Education; Federal Supplemental Educational Opportunity Grants, Federal Pell Grant Program, Federal Direct Student Loans Federal Award Identification Number and Year - P007A236053, P063P232857, P268K242857; 2024 2025 Pass through Entity - N/A Finding Type - Material weakness Repeat Finding - Yes 2024-002 Criteria - In accordance with 2 CFR 200.303, the College must establish and maintain effective internal control over its federal awards in order to provide reasonable assurance that it is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Specific to these Title IV programs, 34 CFR 668.22 outlines the requirements for institutions to follow when returns of Title IV funds are required, including identifying when calculations are necessary and the time frame in which they are required to be returned. Condition - There was a lack of internal controls in place related to the return of Title IV funds, which lead to two students with returns that were not issued timely and two students with error in return calculations. Questioned Costs - N/A Identification of How Questioned Costs Were Computed - N/A Context - Once return calculations were identified and calculated, there were no controls in place to ensure that the calculations were complete, accurate, or returned in a timely manner. Cause and Effect - A lack of review of the processes to identify students who required a calculation, review the completed calculations for accuracy, or ensure that that all calculated returns were completed could lead to incomplete calculations, inaccurate calculations, or untimely return of funds once they are identified. Recommendation - We recommend that the College implement a review control that would cover each stage of the return process outlined. Views of Responsible Officials and Corrective Action Plan - The College has implemented procedures to verify that academic dates are entered accurately in Banner and confirmed by personnel other than those responsible for calculating and reviewing returns of Title IV funds. This should ensure the related calculations are complete and accurate, and the funds are returned in a timely manner.

Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Center Program Assistance Listing Number: 93.224/93.527 Federal Award Number: H80CS24103-13-00; H80CS24103-14-04 Award Periods: May 1, 2024 – April 30, 2025; May 1, 2025 – April 30, 2026 Criteria: CFR § 200.303 Internal controls states that the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: The Organization filed a Standard Form 425 (SF-425) Federal Financial Report which included inaccurate information. Questioned Costs: None. Context: The SF-425 filed was for the project period beginning May 1, 2024 through April 30, 2025 and failed to include the correct amount for an unobligated balance. Cause: Oversight. Effect: Inaccurate report filed. Repeat Finding: No. Recommendation: We recommend the Organization closely review all SF-425 reports filed to ensure that the grant drawdowns reconcile to the amount reported as federal share of expenditures and any unobligated balances/carryover requests are done promptly. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program: Student Financial Aid Cluster ALN: 84.063, 84.268 Federal Award Identification Number: P063P241225 - 2025 ; P268K251553 - 2025 Award Period: July 1, 2024 – June 30, 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Internal Control – Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non- Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Compliance – The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Condition: During our testing of enrollment status reporting, we noted the change in enrollment status was not reported within 60 days. Questioned Costs: None Context: The change in enrollment data was not reported timely for 1 out of 40 students. Cause: Hagerstown Community College did not have a process in place to ensure the students who changed status were reported timely and accurately. Effect: Student enrollment status changes was not reported timely to NSLDS. Repeat Finding: No Recommendation: We recommend Hagerstown Community College reevaluate their procedures and review policies surrounding reporting status changes to NSLDS to ensure timely and accurate reporting. Views of responsible officials: Management agrees with the finding and has a plan to correct the finding

Assistance Listing Number, Federal Agency, and Program Name: Assistance Listing Number 21.027 Coronavirus State and Local Fiscal Recovery Funds Federal Award Identification Number and Year: SLFRP0127-FRF2969-774301 Pass-through Entity – Department of Environment, Great Lakes, and Energy Finding Type – Significant deficiency in internal control over compliance Repeat Finding - No Criteria - per 2 CFR § 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition – During our testing for reporting compliance, it was noted the client failed to submit monthly reports within the required time frame. 3 out of 4 samples selected for testing were not submitted on time. Identification of How Questioned Costs Were Computed – N/A Questioned Costs – None Cause – Current Management procedures and controls were not sufficient to ensure that report was completing in a timely manner, therefore required reports were not submitted on time. Effect – The City did not submit monthly report on time. Recommendation – We recommend management increase awareness of federal program compliance requirements and monitor compliance with the requirements on regular basis. In addition, we recommend that management review its procedures and controls in place to ensure that reports are completed and submitted by the required due dates. View of Responsible Officials and Corrective Action Plan – Management agrees with the finding. See corrective action plan.

Assistance Listing Number, Federal Agency, and Program Name: Assistance Listing Number 16.922 Equitable Sharing Federal Forfeitures Program Federal Award Identification Number and Year: MI8245300 Direct award – Department of Justice Finding Type – Significant deficiency in internal control over compliance Repeat Finding - No Criteria - Per 2 CFR § 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition – During our testing for Reporting compliance, it was noted the client failed to submit Equitable Sharing Agreement and Certification within the required time frame. The Equitable Sharing Agreement and Certification was submitted late. Identification of How Questioned Costs Were Computed – N/A Questioned Costs – None Cause – Current Management procedures and controls were not sufficient to ensure that report was completing in a timely manner, therefore required report was not submitted on time. Effect – The City did not submit monthly report on time. Recommendation – We recommend management increase awareness of federal program compliance requirements and monitor compliance with the requirements on regular basis. In addition, we recommend that management review its procedures and controls in place to ensure that reports are completed and submitted by the required due dates. View of Responsible Officials and Corrective Action Plan – Management agrees with the finding. See corrective action plan.

United States Department Agriculture Federal Financial Assistance Listing #10.766 Community Facilities Loans and Grant Special Tests and Provisions Significant Deficiency in Internal Control Over Compliance and Noncompliance Criteria – 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. Condition – During our testing, there was no formal review separate from the preparer over the reserve fund reconciliation for the federal program and there was no formal review of the balance in comparison to the required minimum reserve balance. Cause – The Health Center did not have an adequate internal control policy in place to ensure review and approval over the amount of the reserve fund. Effect – The lack of adequate policies governing review increases the risk that employees participating in the federal award administration may not be able to detect and correct noncompliance in a timely manner. Questioned Costs – None reported. Context – Sampling was not used. The Health Center has one reserve account, which includes the debt service and emergency and replacement reserve, that was tested. Due to there being no formal review of the balance in comparison to the required minimum reserve balances, the reserve balance was underfunded as of June 30, 2025, in the amount of $17,486. Repeat Finding from Prior Years – Yes, Finding 2024-003 Recommendation – While noncompliance was identified due to the minimum reserve balance being underfunded as of June 30, 2025, it is noted that Management has corrected the reserve balance to in compliance after year-end. We recommend that the Health Center enhance internal control policies to ensure that a formal review over the reserve fund reconciliation and a formal review of the balance in comparison to the required minimum reserve balances be completed by staff separate from the preparer. Views of Responsible Officials – Management agrees with the finding.

2025-003: Reporting Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555 Federal Award Identification Number and Year: 252IL058N1099-2024, 252IL058N1199-2024, 252IL058N1099-2025, 252IL058N1199-2025 Pass-Through Agency: Illinois State Board of Education Pass-Through Number(s): 25-4210-00, 25-4220-00, 24-4210-00, 24-4220-00 Award Period: July 1, 2024 – June 30, 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal Laws, regulations and program compliance requirements. Effective internal controls should include formal documentation of review and approval for reports submitted under the program. Condition: There is no formal documentation of review and approval of reports submitted by an individual other than the preparer. Questioned Costs: None Context: 5 of 5 financial reports tested. Cause: The District has not implemented adequate internal controls to ensure independent review and approval of submitted reports. Effect: Noncompliance with reporting requirements. Repeat Finding: No Recommendation: We recommend the District strengthen its internal control procedures by ensuring that all reports are reviewed and approved by someone other than the individual responsible for preparing and submitting them. This review should be formally documented. Views of Responsible Officials: There is no disagreement with the audit finding.

2025-004: Procurement Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555 Federal Award Identification Number and Year: 252IL058N1099-2024, 252IL058N1199-2024, 252IL058N1099-2025, 252IL058N1199-2025 Pass-Through Agency: Illinois State Board of Education Pass-Through Number(s): 25-4210-00, 25-4220-00, 24-4210-00, 24-4220-00 Award Period: July 1, 2024 – June 30, 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal Laws, regulations and program compliance requirements. Effective internal controls should include formal documentation of review and approval by the board for procurements over the small purchases threshold. Condition: Procurement methods for certain purchases made with federal award funds were not adequately documented or approved in accordance with the District’s procurement policy. Questioned Costs: None Context: 3 of the 4 procurements tested. Cause: The District did not follow its established internal control procedures for procurement. Effect: May result in a disallowed cost if grant requirements are not followed. Repeat Finding: No Recommendation: We recommend the District review federal procurement requirements to ensure proper documentation and authorization procedures are followed. The District should consider implementing a federal procurement checklist to support compliance. Views of Responsible Officials: There is no disagreement with the audit finding.

2025-005: Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555 Federal Award Identification Number and Year: 252IL058N1099-2024, 252IL058N1199-2024, 252IL058N1099-2025, 252IL058N1199-2025 Pass-Through Agency: Illinois State Board of Education Pass-Through Number(s): 25-4210-00, 25-4220-00, 24-4210-00, 24-4220-00 Award Period: July 1, 2024 – June 30, 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal Laws, regulations and program compliance requirements. Effective internal controls should include verification the vendor is not suspended or debarred through the SAMs exclusion list, collecting of certification from the entity, or by adding a clause or condition to the covered transaction with the entity. Condition: The District did not retain documentation verifying that vendors were not suspended or debarred prior to entering into the transactions. Questioned Costs: None Context: 2 of 3 vendors tested did not have supporting documentation retained. Cause: The District lacks an effective internal control system to verify and document suspension and debarment status of vendors prior to contract execution. Effect: May result in a disallowed cost if grant requirements are not followed. Repeat Finding: No Recommendation: We recommend the District review federal procurement requirements and implement procedures to ensure proper documentation of suspension and debarment checks of vendors, prior to contracts and purchases over the covered transaction threshold. The District should consider using a federal procurement checklist to support compliance. Views of Responsible Officials: There is no disagreement with the audit finding.

U.S. Department of Agriculture Passed Through the North Dakota Department of Public Instruction and the Minnesota Department of Human Services Federal Financial Assistance Listing # 10.565 All Awards Federal Financial Assistance Listing # 10.568 All Awards Food Distribution Cluster Activities Allowed/Unallowed and Allowable Costs/Cost Principles Significant Deficiency in Internal Control over Compliance Criteria – 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. Condition – As part of our audit, two payroll allocation errors were identified. It was determined that some errors resulted in overallocation of costs while others in underallocation of costs. Cause – No formal review of the allocations were completed before or after each payroll. This resulted in incorrect amounts being allocated to the programs. Effect – The failure to adequately review payroll allocations resulted in incorrect charges to the program. Questioned Costs – None Reported. Context/Sampling – A nonstatistical sample of 8 pay periods out of a population of 26 pay periods were selected for testing. 2 pay periods had an error. Repeat Finding from Prior Year(s) – Yes, Finding 2024-004. Recommendation – It is recommended that the Organization implement processes and controls to ensure that payroll allocations are reviewed and approved with each payroll processed. Views of Responsible Officials – Management agrees with the finding.

U.S. Department of Agriculture Passed Through the North Dakota Department of Public Instruction and the Minnesota Department of Human Services Federal Financial Assistance Listing # 10.568 All Awards Federal Financial Assistance Listing # 10.569 All Awards Food Distribution Cluster Eligibility Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria – 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. This includes a process to ensure proper completion of all tracking forms and documentation, including documented reviews in relation to eligibility. Condition – During our review of the eligibility determinations, it was identified that there were various instances where applications or other eligibility determinations and reviews were not completed timely or accurately. The files were missing the documented processes or were completed after the prior form’s expiration dates. Cause – Due to oversight by management, all forms were not completed and documented within participant files. This was largely due to differences in fiscal years, calendar years, and terms of the applications and certifications not being appropriately considered when completing and monitoring the various eligibility documents. Effect – The Organization’s internal control process was not appropriately enforced and monitored, resulting in lack of timely documentation of eligibility determination. However, it is noted that the agencies were subsequently determined to be eligible for the program. Questioned Costs – $29,692 Context/Sampling – A nonstatistical sample of 32 participating agencies within TEFAP who received $2,061,190 in food commodities, out of a population of 151 agencies receiving food commodities totaling $5,958,935, were selected for eligibility testing. 4 out of the 32 eligibility determinations tested had an error, with 4 of those resulting in questioned costs, as reported above. Repeat Finding from Prior Year(s) – Yes, Finding 2024-003. Recommendation – Management should review internal control procedures to ensure all eligibility determination reviews are documented and retained in the file and consideration is appropriately given to fiscal year, calendar year, and application terms. Views of Responsible Officials – Management agrees with the finding.

ELMWOOD PARK COMMUNITY UNIT SCHOOL DISTRICT 401 06-016-4010-26 SCHEDULE OF FINDINGS AND QUESTIONED COSTS Year Ending June 30, 2025 SECTION III - FEDERAL AWARD FINDINGS AND QUESTIONED COSTS Year originally reported? 3. Federal Program Name and Year: National School Lunch Program, School Breakfast Program 4. Project No.: 25-4210-00 & 25-4220-00 5. AL No.: 10.555 & 10.553 6. Passed Through: 7. Federal Agency: Illinois State Board of Education U.S. Department of Agriculture 8. Criteria or specific requirement (including statutory, regulatory, or other citation) Per 2 CFR §200.303, non-federal entities must establish and maintain effective internal control over federal awards to provide reasonable assurance of compliance with federal statutes, regulations, and the terms and conditions of the award. Additionally, 7 CFR §210.8(a) requires school food authorities to establish internal controls to ensure the accuracy of meal counts prior to submitting monthly claims for reimbursement. These controls must include a review process before submission to verify that claims are correct 9. Condition The District does not have an adequate review process in place for meal count claims prior to submission. Claims prepared by one individual are submitted without independent verification. As a result, the district reported an incorrect lunch count for January 2025. This error appears to be isolated to January; however, it would likely have been prevented if a review process were in place. 10. Questioned Costs No reportable questioned costs identified. 11. Context The District participates in the National School Lunch Program (ALN 10.555) and School Breakfast Program (ALN 10.553), which require accurate reporting of meal counts to determine reimbursement. Meal count claims are prepared monthly by a designated staff member and submitted to the state agency for reimbursement. Currently, the district does not have a formal process for independent review of these claims prior to submission. This lack of review contributed to an error in January 2025, when the district reported fewer lunches than were actually served. We reviewed a non-statistical sample of meal claims, and aside from the month of January 2025, noted no similar issues. 12. Effect The District claimed fewer meals than were actually served for January 2025, resulting in lower reimbursement than it was entitled to under the National School Lunch Program. While the error appears isolated to January, the lack of an independent review increases the risk of similar underclaims or overclaims in the future. 13. Cause The district did not implement a secondary review of meal count claims before submission. 14. Recommendation The District should implement a formal review process for all meal count claims prior to submission. This process should include independent verification by someone other than the preparer to ensure accuracy and compliance. 15. Management's response The District will implement a system in which meal count claims will have secondary approval by the CSBO.

Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program Assistance Listings Numbers: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY 2024, FY 2025 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Eligibility, Special Tests and Provisions - Non-Profit School Food Service Accounts Audit Finding: Material Weakness INDIANA STATE BOARD OF ACCOUNTS 14 CROWN POINT COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Condition and Context The School Corporation had not properly designed or implemented a system of internal controls that would likely be effective in preventing, or detecting and correcting, noncompliance related to the grant agreement and the Eligibility and the Special Tests and Provisions - Non-Profit School Food Service Accounts compliance requirements. Eligibility - Direct Certifications A child's eligibility for free or reduced-price meals under a Child Nutrition Cluster program may be established by the submission of an annual application or statement which furnishes such information as family income and family size. Local educational agencies, institutions, and sponsors then determine eligibility by comparing the data reported by the child's household to published income eligibility guidelines. Additionally, a child may be direct certified. For a direct certification, annual eligibility determinations are based on the child's household receiving benefits under SNAP, FDPIR, the Head Start Program (ALN 93.600), or, under most circumstances, the TANF program (ALN 93.558). A household may furnish documentation of its participation in one of these programs; or the school, institution, or sponsor may obtain the information directly from the state or local agency that administers these programs. Certain foster, runaway, homeless, and migrant children are categorically eligible for free school lunches and breakfasts. Direct certified households do not need to complete an application. The Direct Certification Report was downloaded from the State of Indiana database and uploaded to the School Corporation's lunch point-of-sale (POS) system at the beginning of the school year and then monthly throughout the school year. An oversight or review process to ensure the Direct Certification Report was downloaded monthly, the upload had imported correctly, and that students' statuses were updated accordingly was not designed or implemented. Special Tests and Provisions - Non-Profit School Food Service Accounts A School Food Authority (SFA) is required to account for all revenues and expenditures of its non-profit school food service in accordance with state and federal requirements. An SFA must operate its food services on a non-profit basis; all revenue generated by the school food service must be used to operate and improve its food services. Federal reimbursement receipts were posted to the School Lunch fund by one individual without a documented oversight or review process to ensure they were correctly credited to the school food service account. The lack of internal controls was systemic throughout the audit period. INDIANA STATE BOARD OF ACCOUNTS 15 CROWN POINT COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Criteria 2 CFR 200.303 states in part: "The recipient and subrecipient must: (a) Establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control-Integrated Framework' issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Cause Management had not developed or documented that an oversight or review process to ensure the direct certification report was properly processed or that reimbursements related to the Non-Profit Food Service Account were properly posted to the School Lunch fund. Effect The failure to design or implement a system of internal controls places the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management design and implement a proper system of internal controls that would ensure that the appropriate reviews, approvals, and oversight are completed and documented. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2025-003 Subject: Title I Grants to Local Educational Agencies - Special Tests and Provisions - Annual Report Card, High School Graduation Rate Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listings Number: 84.010 Federal Award Numbers and Years (or Other Identifying Numbers): S010A220014, S010A230014, S010A240014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Annual Report Card, High School Graduation Rate Audit Finding: Material Weakness INDIANA STATE BOARD OF ACCOUNTS 16 CROWN POINT COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Condition and Context The School Corporation had not properly designed or implemented a system of internal controls that would likely be effective in preventing, or detecting and correcting, noncompliance related to the grant agreement and the Special Tests and Provisions - Annual Report Card, High School Graduation Rate compliance requirement. The School Corporation must report graduation rate data for all public high schools within the School Corporation using the four-year adjusted cohort rate. To remove a student from the cohort, the School Corporation must confirm the reason for removal in writing. Additionally, required documentation for each removal type must be retained by the School Corporation. The School Corporation had a process in place to ensure that a student's removal from the high school graduation cohort for mobility reasons was properly documented and reviewed. However, for 5 of the 34 students tested, evidence of the review process was not documented. The lack of internal controls was systemic throughout the audit period. Criteria 2 CFR 200.303 states in part: "The recipient and subrecipient must: (a) Establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control-Integrated Framework' issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Cause Management had not ensured that the oversight or review process was consistently documented. Effect The failure to design or implement a system of internal controls places the School Corporation at risk of noncompliance with the grant agreement and the compliance requirement. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management design and implement a proper system of internal controls that would ensure that the appropriate reviews, approvals, and oversight are completed and documented consistently. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2025-002 Subject: Special Education Cluster (IDEA) - Suspension and Debarment Federal Agency: Department of Education Federal Programs: Special Education Grants to States, COVID-19 - Special Education Grants to States Assistance Listings Numbers: 84.027, 84.027X Federal Award Numbers and Years (or Other Identifying Numbers): 21611-010-PN01, 22611-010-PN01, 23611-010-PN01, 24611-010-PN01, 22611-010-ARP Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2023-004. Condition and Context Prior to entering into subawards and covered transactions with federal award funds, recipients are required to verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded. "Covered transactions" include, but are not limited to, contracts for goods and services awarded under a nonprocurement transaction (i.e., a grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the SAMs exclusions, collecting a certification from that person, or adding a clause or condition to the covered transaction with that person. Upon inquiry of the School Corporation in order to review the procedures in place for verifying that a person with which it plans to enter into a covered transaction is not suspended, debarred, or otherwise excluded, the School Corporation did provide documentation that suspension and debarment requirements were verified for one of the tested vendors. No documentation was provided for the remaining covered transactions, totaling $329,876. The lack of proper internal controls and noncompliance were systemic issues throughout the audit period. INDIANA STATE BOARD OF ACCOUNTS 18 EAST ALLEN COUNTY SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 180.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person." 2 CFR 200.214 states: "Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities." Cause A proper system of internal controls was not designed by management of the School Corporation to ensure all vendors to whom payments equal to or in excess of $25,000 were verified prior to entering into subawards and covered transactions. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, vendors to whom payments equal to or in excess of $25,000 were not all verified to be not suspended, debarred, or otherwise excluded. Noncompliance with the provision of federal statutes, regulations, and terms and conditions of the federal award could result in the reduction of future federal funding to the School Corporation. INDIANA STATE BOARD OF ACCOUNTS 19 EAST ALLEN COUNTY SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish and implement an effective system of internal controls to ensure all vendors to whom payments equal to or in excess of $25,000 are verified prior to entering into subawards and covered transactions. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

Finding 2025-002: Federal Program: Corporation for National and Community Service: Kentucky Cabinet for Health & Family Services AmeriCorps State & National, Assistance Listing No. 94.006 Criteria: The University must have internal controls in place for compliance as required by 2 CFR Part 200.303. The University requires that interviews be conducted and documented prior to onboarding AmeriCorps members. Condition: During our testing of eligibility for 25 program participants, we noted that four participants did not have evidence of being interviewed prior to being hired. Cause: Until the implementation of a new system and procedure, the University's documentation process for interviews during a portion of the audit period did not include formalized controls to centralize retention and documentation of interview evidence. Interview documentation was maintained through individual staff email accounts and calendar systems lacked standardized filing and retention protocols, resulting in the inability to locate evidence that interviews were conducted for four participants. Effect: The University's internal control was not followed and thus a total of four program participants did not have evidence of being properly interviewed prior to being hired. Questioned Costs: There are no questioned costs. Recommendation: We recommend the University review controls and implement a standardized process and refine its system to ensure ongoing compliance with established controls. Views of responsible officials and planned corrective actions: The University agrees with the auditors' finding and recommendations. The following corrective actions have been taken: During the 2023-2024 academic year, EngageKY implemented a new process for recordkeeping related to the recruitment and selection of Kentucky College Coaches. As part of the implementation, site supervisors and program staff began to use Salesforce to maintain notes from screening interviews and general interviews. The missing documentation referenced in this finding was for individuals hired prior to the new process. EngageKY will continue to use Salesforce to document the recruitment and selection of Kentucky College Coaches.

Finding 2025-003: Federal Program: U.S. National Science Foundation: Research and Development Cluster Office of Integrated Activities, Assistance Listing No. 47.083 Criteria: The University must have internal controls in place for compliance as required by 2 CFR Part 200.303. The University requires review by grant department before disbursement. Condition: During our testing of awarded scholarships for eight students, we noted that two student applications did not have evidence of being reviewed prior to disbursement of the scholarship. Cause: The University does not have a procedure in place to properly review scholarship applications prior to disbursement. Effect: Two students received scholarships that were not properly reviewed prior to disbursement. Questioned Costs: There are no questioned costs. Recommendation: We recommend that the University review and revise their policies and procedures related to reviewing and approving Research & Development grant scholarships prior to disbursement. Specifically, the University should:  Implement a review process to verify scholarships are reviewed and approved by Grant Administration prior to disbursement.  Provide training to relevant staff on proper documentation procedures to forward to Grant Administration to enhance compliance and accuracy. Views of responsible officials and planned corrective actions: The University agrees with the auditors' finding and recommendations. The following corrective action will be taken: The University will review and revise policies and procedures related to reviewing and approving Research & Development grant scholarships prior to disbursement. The University will do the following:  Implement a review process to verify scholarships are reviewed and approved by Grant Administration prior to disbursement.  Provide training to relevant staff on proper documentation procedures to forward to Grant Administration to enhance compliance and accuracy.

8. Criteria or specific requirement: Per Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR Part 200) Subpart D, Post Federal Award Requirements Section 200.303, Internal controls, the recipient must establish, document and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient is managing the Federal award in compliance with Federal statutes, regulations and the terms and conditions of the Federal award. Per 7 CFR Section 210.8(a), the school food authority shall establish internal controls which ensure the accuracy of meal counts prior to the submission of the monthly claim for reimbursement. '9. Condition: Three (3) monthly claims for reimbursement reported meal counts in excess of those supported by records of the District. 10. Cause: The District's internal controls over compliance were not functioning effectively to ensure claims for reimbursement were accurately prepared. '11. Effect: The District was not in compliance with the reporting compliance requirement. '12. Questioned Costs: The following questioned costs were computed based on the excess meals claimed for reimbursement times the applicable reimbursement rate: $37 (Project No. 25-4220-00) $2,074 (Project No. 25-4210-00) '13. Context: From the population of eleven (11) monthly claims for reimbursement, a sample of four (4) claims were selected for testing. We noted three (3) months in which the claims for reimbursement reported meal counts in excess of those supported by records of the District as follows: October 2024: Actual breakfast meals served: 10,313; Breakfast meals claimed for reimbursement: 10,326. March 2025: Actual lunch meals served: 12,901; Lunch meals claimed for reimbursement: 12,911 April 2025: Actual lunch meals served: 10,087; Lunch meals claimed for reimbursement: 10,190 In addition, the District was unable to locate supporting documentation of the snack claim counts of 765 for October 2024 and 525 for April 2025, which contributed to the questioned cost total for program 25-4210-00. A statistically valid sample was not utilized. 14. Recommendation: We recommend that management review its policies and procedures and implement changes to strengthen internal control over compliance. 15. Management's response: The District agrees with the auditor's finding and recommendation.

SIGNIFICANT DEFICENCY Internal Controls and Compliance Criteria: Pursuant to the Code of Federal Regulations (CFR), Title 2 Grants and Agreements, Subpart D Post Federal Award Requirements, Section 200.303 “the non-federal entity must establish and maintain effective internal control over the Federal aware that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.” Condition: When investigating the controls related to equipment management, we became aware that the District has implemented new procedures to track and maintain an inventory list adequately. However, the infrastructure items bought were not inventoried. Only non-infrastructure items were being inventoried and tracked. Cause: The internal control-related infrastructure items for the Education Stabilization Fund are nonexistent. Effect: There is noncompliance and a lack of internal control regarding the infrastructure items for the Education Stabilization Fund. Recommendations: The District should include infrastructure items in the current inventory system. Views of Responsible Officials and Planned Corrective Actions: The District agrees with the finding. See the separate document for planned corrective actions.

2025-001: Enrollment Reporting Controls– Student Financial Aid Special Test Material Weakness Federal Program: Student Financial Assistance Cluster Federal Agency: Department of Education Federal Award Year: July 1, 2024 - June 30, 2025 Assistance Listing Number(s): Student Financial Assistance Cluster • 84.007 • 84.033 • 84.038 • 84.063 • 84.268 • 84.379 • 93.925 Criteria: To comply with enrollment reporting requirements, institutions must accurately and timely report student enrollment status changes to the National Student Loan Data System (NSLDS) within 60 days of determining the change, as outlined in Federal Regulations 34 CFR 682.610 and 685.309. Auditee requirements contained in Title 2 U.S. Code of Federal Regulations (2 CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D – Post Federal Award Requirements, Section 200.303 – Internal Controls, requires the auditee to establish and maintain effective internal control over the Federal award that provides reasonable assurance that the nonfederal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with a framework such as the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: There is no control in place by the College to review information submitted to the NSLDS for student enrollment status changes. The individual performing the submission is able to complete and transmit the data without an independent review or verification by another person, increasing the risk of inaccurate or incomplete information being reported. Cause: Lack of control in place over enrollment status changes reported to the NSLDS. Effect or Potential Effect: Lack of controls in place could result in instances of noncompliance with Department of Education and Federal regulations. Questioned Costs: None Context: While the College ensures accurate status change data is sent to the National Student Clearinghouse (third party who submits enrollment status changes to the NSLDS), the College does not have controls in place to ensure information was submitted to the NSLDS accurately and timely. Repeat Finding: Yes Recommendation: We recommend the College implement controls where there is an independent review of the submissions received by NSLDS to ensure enrollment status changes are reported accurately and timely. Views of Responsible Officials: Management agrees with the finding. See corrective action plan.

2025-002: Return of Title IV Funds Controls Significant Deficiency Federal Program: Student Financial Assistance Cluster Federal Agency: Department of Education Federal Award Year: July 1, 2024 - June 30, 2025 Assistance Listing Number(s): Student Financial Assistance Cluster • 84.007 • 84.033 • 84.038 • 84.063 • 84.268 • 84.379 • 93.925 Criteria: When a student withdraws, institutions must comply with the "Return of Title IV Funds" requirements outlined in 34 CFR 668.22, ensuring any unearned funds are returned to the Department of Education within 45 days of determining the student's withdrawal. Auditee requirements contained in Title 2 U.S. Code of Federal Regulations (2 CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D – Post Federal Award Requirements, Section 200.303 – Internal Controls, requires the auditee to establish and maintain effective internal control over the Federal award that provides reasonable assurance that the nonfederal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with a framework such as the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: There is no evidence of a control in place by the College to review Return of Title IV Fund calculations. Cause: Lack of control in place over returns of Title IV funding. Effect or Potential Effect: Returns of Title IV Funds may not be refunded within the 45-day requirement and result in instances of noncompliance with the Department of Education. Questioned Costs: None Context: The College claims to review these calculations; however, there is no evidence that such reviews were conducted or effective. Additionally, there is no retention of documentation demonstrating that an approval or review occurred, making it impossible to verify that the process was properly performed. Repeat Finding: Yes Recommendation: We recommend the College review its process and controls in place for calculating refunds from Title IV and include an independent review and sufficient documentation to support the application of the control. Views of Responsible Officials: Management agrees with the finding. See corrective action plan.

Finding 2025.002: Cash Management - Significant Deficiency Grantor: U.S. Department of Health and Human Services Federal Program Name: Block Grants for Community Mental Health Services Federal Assistance Listing Number: 93.958 Federal Award Identification Number and Year: 24MHA2102 Criteria In accordance with §200.305, Federal Payment, grantees and subgrantees that receive grant funds are responsible for maintaining controls regarding the management of federal program funds under the Uniform Guidance in 2 CFR 200.302 and 200.303. Condition The Organization's drawdowns did not illustrate review and approval by management. Cause The Organization did not have adequate controls to ensure drawdowns were properly approved and such approval is documented. Effect or Potential Effect The condition may lead to inaccurate or improper drawdowns. Questioned Costs None Context We selected three drawdowns for testing of cash management procedures. We noted that for all three drawdowns, there was no formal approval or evidence of review. Identification of Repeat Finding No Recommendation The Organization should develop written procedures to review all drawdowns that occur in order to ensure accuracy. Views of Responsible Officials and Planned Corrective Actions Management and the Board of Directors agree with the finding and will implement additional controls to ensure there is formal evidence of review being performed.

Assistance Listing, Federal Agency, and Program Name - 21.027, U.S. Department of Treasury, COVID 19 Coronavirus State and Local Fiscal Recovery Funds Federal Award Identification Number and Year - H4HRGP33345 Pass-through Entity - State of Colorado, Department of Local Affairs, for the benefit of the Division of Housing Finding Type - Material weakness Repeat Finding - No Criteria - Per 2 CFR 200.303, the recipient must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States, or the “Internal Control Integrated Framework," issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - Management did not have controls in place to ensure documentation was maintained evidencing the organization's verfication that contractors are not suspended or debarred from participating in a federally funded activity. Questioned Costs - N/A If questioned costs are not determinable, description of why known questioned costs were undetermined or otherwise could not be reported - N/A Identification of How Questioned Costs Were Computed - N/A Context - While gaining an understanding of the organization's internal controls, we noted management was unable to provide documentation to support that checks for suspension and debarment occurred before the organization entered into a covered transaction. We were able to verify in our sample testing that management did not enter into contracts with individuals or organizations suspended or debarred from participating in federal programs. Cause and Effect - A lack of controls could result in material noncompliance with federal procurement standards. Recommendation - We recommend management retain documented evidence that checks for suspension and debarment have occurred before entering into a covered transaction with outside contractors. Views of Responsible Officials and Corrective Action Plan - Management concurs with the finding. We acknowledge that, for one federal program under the Coronavirus State and Local Fiscal Recovery Funds program (Assistance Listing 21.027), the required suspension and debarment verification was performed; however, the supporting documentation evidencing this verification was not retained in the contract file. This represents a documentation lapse rather than a control deficiency. Volunteers of America Colorado (VOAC) routinely performs suspension and debarment verifications for all applicable vendors, contractors, and subrecipients receiving federal funds in accordance with 2 CFR 200.214. This requirement applies to entities and individuals awarded federally funded contracts or subawards exceeding the micro purchase threshold and excludes routine commercial vendors for indirect administrative costs or purchases under $10,000. To strengthen compliance documentation and ensure consistent audit support, VOAC has implemented the following corrective actions: 1.Policy Enhancement: The procurement procedure has been updated to explicitly require saving and retaining a time stamped screenshot or PDF confirmation of each SAM.gov verification showing the verification date and results. Where applicable, contractors subject to 2 CFR 200.214 must also provide a self certification statement within the executed agreement. 2.Centralized Recordkeeping: Verification evidence will be maintained in both the individual contract file and the centralized grant management system. 3.Annual Training and Refresher: Procurement and grants management staff will participate in annual training to reinforce 2 CFR 200.214 requirements and best practices for documentation and record retention. Management believes this was an isolated documentation lapse prior to the current audit period when the contractor was selected, and that the actions taken since have resolved the issue and will ensure continued compliance.