Lake Ridge Schools

FINDING 2025-005 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, COVID-19 - Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.027X, 84.173X Federal Award Numbers and Years (or Other Identifying Numbers): 22611-043-PN01, 22611-043-ARP, 22619-043-ARP Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking Audit Findings: Significant Deficiency, Other Matters Condition and Context The School Corporation is a member of the Northwest Indiana Special Education Cooperative (Cooperative). During fiscal year 2022-2023, the Cooperative operated the special education program and spent the federal money on behalf of all its members. As the grant agreement was between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the earmarking requirements. The Cooperative did not have adequate procedures in place to ensure that the required level of expenditures for 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. Due to the timing of the Cooperative's corrective action, the nonpublic expenditures spent did not meet the earmarking requirements for grant award numbers 22611-043-PN01, 22611-043-ARP, and 22619-043-ARP. From the beginning of the grant awards until September 2022, total grant expenditures were posted as expended. The nonpublic proportionate share expenditures were determined by applying a percentage to the nonpublic school budgeted expenditures. Beginning in September 2022, the Cooperative began tracking expenditures by member school for the nonpublic services. As such, we were unable to identify if the minimum amount per the grant award was expended and properly reported to the IDOE from the beginning of the grant awards through September 2022, as required. The lack of internal controls and noncompliance were isolated to 22611-043-PN01, 22611-043-ARP, and 22619-043-ARP grant awards. INDIANA STATE BOARD OF ACCOUNTS 26 LAKE RIDGE 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 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 Through inquiry of management, they were unaware of the requirements to track nonpublic proportionate share expenditures directly for each member school. While the Cooperative did implement new processes and procedures to ensure expenditures were tracked by member schools starting in September 2022, most of the grant awards had been allocated to the member schools based on a percentage of the budget. Effect Without the proper implementation of an effectively designed system of internal controls, the School Corporation was unable to ensure Cooperative compliance with earmarking requirements and the Cooperative was unable to track expenditures for nonpublic services for each member school. Consequently, the amounts requested for reimbursement were not supported by actual expenditures, but rather a percentage based on the budget per member school. Because of this, expenditures were not accurately reported to the oversight agency. Questioned Costs There were no questioned costs identified. INDIANA STATE BOARD OF ACCOUNTS 27 LAKE RIDGE SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Recommendation We recommended School Corporation's management develop written policies and procedures which would require tracking of actual nonpublic proportionate share expenditures by member school by the Cooperative. 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 2025-005 Finding Subject: Special Education Cluster (IDEA) - Earmarking Contact Person Responsible for Corrective Action: Adrian Wilkerson, Chief Financial Officer Chris Akers, Treasurer Contact Phone Number and Email Address: awilkerson@chsnewtech.com cakers@chsnewtech.com 219-838-1819 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The school corporation will request an update to the Cooperative Agreement requiring the cooperative to provide school specific expenditure reports for non-public services on a quarterly basis. The school corporation will require detail level data from the cooperative for earmarking compliance. During SEFA and AFR preparation, the treasurer will reconcile the cooperatives year-end report to the proportionate share requirement listed in the IDOE grant award letter. Anticipated Completion Date: This will be completed by the next SEFA submission date of August 29, 2026.

FINDING 2025-006 Subject: Special Education Cluster (IDEA) - Level of Effort Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 23611-043-PN01, 24611-043-PN01, 23619-043-PN01, 24619-043-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking Audit Findings: Material Weakness, Modified Opinion Condition and Context Level of Effort - Maintenance of Effort (MOE) is a district-level test that determines whether the School Corporation is providing a consistent level of financial support to public schools from year to year. This rule ensures that the School Corporation does not use special education funds to shore up reductions in state and local support for public education. The Indiana Department of Education (IDOE) performs the maintenance of effort calculation utilizing the MOE Calculator workbook that is part of the grant application and Form 9 Financial Report information provided by the School Corporation from the prior year. As such, the amounts submitted to the IDOE in the prior year to be used in the computation are tested to ensure they were recorded properly in the School Corporation's records as to the account or object code. The School Corporation prepares the MOE Calculator workbook as part of the application process to the IDOE. The School Corporation is to report on the special education expenditure descriptions, budget codes, and expenditures for the prior year. The MOE Calculator workbooks for the audit period were based on fiscal years ending June 30, 2023 and 2024 ledgers. However, the School Corporation was unable to provide documentation to support the expenditures reported for maintenance of effort included in the MOE Calculator workbook. The MOE Calculator Workbooks reported expenditures were greater than the School Corporation's ledger by $550,469 and $759,837 for the fiscal years ending June 30, 2023 and 2024, respectively. Due to the material variance, we could not determine the detailed expenditures reported in the MOE Calculator to test. The MOE Calculator workbook variances were isolated to the 23611-043-PN01, 24611-043-PN01, 23619-043-PN01, and 24619-043-PN01 grants. INDIANA STATE BOARD OF ACCOUNTS 28 LAKE RIDGE 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 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 the 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 Management had not developed a system of internal controls that would have ensured the proper documentation was maintained to support the School Corporation's maintenance of effort as related to the Matching, Level of Effort, Earmarking compliance requirement. Effect Without the proper implementation of an effectively designed system of internal controls, the School Corporation cannot ensure compliance with the level of effort - maintenance of effort requirements. As a result, amounts reported as part of the grant application could not be audited. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a proper system of internal controls to ensure the proper recordkeeping is maintained to ensure compliance with the Matching, Level of Effort, Earmarking compliance requirement. INDIANA STATE BOARD OF ACCOUNTS 29 LAKE RIDGE SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2025-006 Finding Subject: Special Education Cluster (IDEA) – Level of Effort Contact Person Responsible for Corrective Action: Adrian Wilkerson, Chief Financial Officer Chris Akers, Treasurer Contact Phone Number and Email Address: awilkerson@chsnewtech.com cakers@chsnewtech.com 219-838-1819 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The school corporation will use the Form 9 to reconcile the MOE. The treasurer will prepare a report providing the total monthly expenditures to the cooperative, along with the wage and benefit report provided by the cooperative. Transportation expenses will be divided and recorded in the ledger clearly delineating which expenses are special education. When reporting MOE, the school corporation will reconcile the ledger with invoices. The business manager will review these costs prior to the MOE Workbook submission as part of the Special Education grant application. Anticipated Completion Date: This will be completed by the next SEFA submission date of August 29, 2026.

FINDING 2025-009 Subject: Title I Grants to Local Educational Agencies - Eligibility 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): S010A230014, S010A240014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Findings: Material Weakness, Other Matters Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2023-005. Condition and Context Eligibility for Title I is determined on the Eligible School Summary of the Title I application. Data from the School Corporation's student software system (Real Time data reports) was uploaded to the Indiana Department of Education's (IDOE) Data Exchange System. Enrollment and poverty information for the School Corporation was then abstracted by the IDOE from the Data Exchange System and prepopulated into the Title I application for the School Corporation. These counts are based upon the School Corporation's records as of October of the prior fiscal year. The enrollment and the poverty status of each student included in the summary data should have been supported by school records. INDIANA STATE BOARD OF ACCOUNTS 33 LAKE RIDGE SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) The October 2022 and 2023 real time data reports, which were used to prepopulate the School Corporation's enrollment numbers for the 2023-2024 and 2024-2025 Title I applications, were tested for accuracy. Of the 25 students tested, 6 students' socioeconomic status were incorrectly reported when compared with support provided by the School Corporation. The support provided for 5 of the students was insufficient as a socioeconomic status determination had not been documented in the record. Upon computation of the status from the record information, it was determined that the status had been incorrectly reported in the real time data report. The sixth student did not have documentation to support the status for the year tested; the documentation provided was for the prior year. 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). . . ." 34 CFR 200.78(a)(1) states: "After reserving funds, as applicable, under § 200.77, including funds for equitable services for private school students, their teachers, and their families, an LEA must allocate funds under this subpart to school attendance areas and schools, identified as eligible and selected to participate under section 1113(a) or (b) of the ESEA, in rank order on the basis of the total number of public school children from low-income families in each area or school." Cause The School Corporation had not designed or implemented an oversight or review process to ensure that the poverty data prepopulated into the Title I application was accurately reported. Effect Noncompliance with the grant agreement and the compliance requirement listed above 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 establish a system of internal controls over the Title I application poverty information, and that appropriate reviews are taking place to ensure compliance. INDIANA STATE BOARD OF ACCOUNTS 34 LAKE RIDGE SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2025-009 Finding Subject: Title I Grants to Local Educational Agencies - Eligibility Contact Person Responsible for Corrective Action: Regin Johnson, Title 1 Director Rae Lopez, Student Services Director Contact Phone Number and Email Address: rjohnson@chsnewtech.com rlopez@chsnewtech.com 219-838-1819 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The error causing this finding is within part of the annual student registration process. If a parent did not provide the socio-economic status (SES) data necessary to determine Title I eligibility, the student information system defaulted their SES to a former value. To correct this error, the collection of the SES data will be reviewed by the data manager to identify missing information. School registrars will request the parent/guardian provide any missing information. Students that have no current SES data by student count day will be automatically flagged as ineligible for the Title I count. This verified data will be what is submitted to the IDOE Data Exchange. Anticipated Completion Date: This revised process will be implemented for the 2026-2027 school year enrollment registration process. 58 INDIANA STATE BOARD OF ACCOUNTS 60

2023-005

FINDING 2025-010 Subject: Title I Grants to Local Educational Agencies - Special Tests and Provisions - Assessment System Security 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): S010A230014, S010A240014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Assessment System Security Audit Findings: Material Weakness, Other Matters Condition and Context State Educational Agencies (SEA), in consultation with Local Educational Agencies (LEA), are required to establish and maintain an assessment security system that is valid, reliable, and consistent with relevant professional and technical standards. Within their assessment system, SEAs must have policies and procedures to maintain test security measures and ensure that LEAs implement those policies and procedures. As such, the Indiana Department of Education created and published the Indiana Assessments Policy Manual. As a part of the assessment security, any individual who administers, handles, or has access to secure test materials at the school or School Corporation shall complete assessment training and sign a testing security and integrity statement that remains on file in the appropriate building-level office by September 30 each year. The School Corporation provided online assessment system security training. The School Corporation electronically captures the completion of the training, which includes the form signoff, in an electronic document. The School Corporation had not established effective internal controls to ensure all applicable personnel received the training prior to September 30. Of the 25 individuals tested, 2 were determined not to have taken the training for the 2024-2025 school year. Another 2 individuals who were employed when the school year started did not take the required training until February 2025, which was after the September 2024 deadline. All 4 instances of noncompliance occurred in the 2024-2025 school year. The lack of internal controls was a systemic issue throughout the audit period, and the noncompliance was limited to the 2024-2025 school year. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: INDIANA STATE BOARD OF ACCOUNTS 35 LAKE RIDGE SCHOOLS 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). . . ." 20 USC 6311(b)(2)(A) states: "Each State plan shall demonstrate that the State educational agency, in consultation with local educational agencies, has implemented a set of high-quality student academic assessments in mathematics, reading or language arts, and science. The State retains the right to implement such assessments in any other subject chosen by the State." 511 IAC 5-5-5 states in part: ". . . (b) Any individual who administers, handles, or has access to secure test materials at the school or school corporation shall complete assessment training and sign a testing security and integrity agreement to remain on file in the appropriate building-level office each year. (c) Each individual required to sign the testing integrity agreement under this rule shall sign the form by the date established and included on the testing integrity agreement. . . ." Indiana Assessments Policy Manual states: "Ensure all staff (including, but not limited to, TAs, proctors, principals, teachers in tested as well as non-tested grade levels, front office staff, teacher aides, cafeteria employees, custodians, etc.) complete IDOE's required test security and integrity training by September 30 annually. Locally maintain documentation (attendance sign-in sheets, training agendas, and other training materials) reflecting completion of all required training." Cause The School Corporation did not have effective internal control procedures in place over assessment security training. Effect Not all required employees received the Indiana Testing Security and Integrity training in a timely manner. Noncompliance with the grant agreement and the compliance requirement listed above could result in the repayment of federal funds. Questioned Costs There were no questioned costs identified. Recommendation We recommended that School Corporation's management establish a proper system of internal controls including policies and procedures to ensure that all individuals required to take the assessment system security do so, and in a timely manner. INDIANA STATE BOARD OF ACCOUNTS 36 LAKE RIDGE SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2025-010 Finding Subject: Title I Grants to Local Educational Agencies - Special Tests and Provisions - Assessment System Security Contact Person Responsible for Corrective Action: Adrian Wilkerson, Chief Financial Officer Chris Akers, Treasurer Cynthia Mose-Trevino, Assistant Superintendent Corporation Test Coordinator Contact Phone Number and Email Address: awilkerson@chsnewtech.com cakers@chsnewtech.com cynthia.mose-trevino@chsnewtech.com 219-838-1819 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: A two layer verification of completion will be implemented by each building level STC ensuring completion of test security training at their site, and the CTC verifying this completion data for all required district personnel. Anticipated Completion Date: This revised process will be fully implemented by the beginning of the 2027 calendar year.

FINDING 2025-012 Subject: COVID-19 - Education Stabilization Fund - Equipment and Real Property Management Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425U, 84.425W Federal Award Numbers and Years (or Other Identifying Numbers): S425U210013, S425W210015 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Equipment and Real Property Management Audit Findings: Material Weakness, Modified Opinion Condition and Context A property record or capital asset listing is required to be maintained for all equipment, property improvements, and property purchased with the COVID-19 - Education Stabilization Fund grant awards to ensure adequate safeguards are in place to prevent loss or damage of items. Equipment to be included in the listing is that which exceeds the School Corporation's capital asset threshold of $5,000. The School Corporation spent $1,696,964 on three improvements with the COVID-19 - Education Stabilization Funds which should have been recorded as capital assets purchased with federal grant funds as these projects exceeded the capitalization threshold. However, only two of the three improvements were added to the capital asset listing. The HVAC project which totaled $725,000 was not added to the asset listing as required. Additionally, the capital asset listing provided did not include all required information, the listing did not include the source of funding for the property (including the federal award identification number), who holds the title, the percentage of federal participation in the project costs for the federal award under which the property was acquired, or the use and condition of the property. The lack of internal controls and noncompliance were systemic throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: INDIANA STATE BOARD OF ACCOUNTS 39 LAKE RIDGE SCHOOLS 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 200.313(d) states in part: "Management requirements. Procedures for managing equipment (including replacement equipment), whether acquired in whole or in part under a Federal award, until disposition takes place will, as a minimum, meet the following requirements: (1) Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the FAIN), who holds title, the acquisition date, and cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. . . . (2) A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years. (3) A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated. (4) Adequate maintenance procedures must be developed to keep the property in good condition. . . ." Cause Effective internal controls were not in place to ensure that all assets purchased with federal funds were added to the School Corporation's capital asset listing. The School Corporation uses a consultant to prepare the capital asset listing, which did not include all required information. 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 design and implement a proper system of internal controls that would ensure compliance with the equipment and real property management requirements. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2025-012 Finding Subject: COVID-19 Education Stabilization Fund – Equipment and Real Property Management Contact Person Responsible for Corrective Action: Adrian Wilkerson, Chief Financial Officer Chris Akers, Treasurer Regin Johnson, Title I Grant Director Contact Phone Number and Email Address: awilkerson@chsnewtech.com cakers@chsnewtech.com rjohnson@chsnewtech.com 219-838-1819 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The corporation will create a binder with any expenditure qualifying as a capital asset expenditure. This binder will be provided to the capital asset consultant, currently AdTec. Anticipated Completion Date: This will be implemented immediately.

FINDING 2023-005 Subject: Title I Grants to Local Educational Agencies - Eligibility 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): S010A210014, SA10A200014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Findings: Material Weakness, Other Matters INDIANA STATE BOARD OF ACCOUNTS 23 LAKE RIDGE SCHOOLS 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 would likely be effective in preventing, or detecting and correcting, noncompliance related to the enrollment and poverty data as reported by the Indiana Department of Education (IDOE) and the School Corporation in the Title I application. Public School (Local Educational Agency) Eligibility for Title I is determined on the Eligible School Summary of the Title I application. Enrollment and Poverty numbers for the public school district are automatically pulled from the IDOE's Official Pupil Enrollment (PE) count for each school into the Eligible School Summary page of the Title I application. These counts are based upon the School Corporation's records as of October of the prior fiscal year. The School Corporation had not established a process of review of the Eligibility Summary in the Title I application for the student enrollment and poverty counts. There was no documentation of the School Corporation verifying the enrollment and poverty counts in the Title I application. Nonpublic Schools Enrollment and poverty numbers for any non-public schools are manually entered into the application by the School Corporation. The School Corporation established a process to receive and review the listing of students from the nonpublic schools for enrollment and poverty counts to be entered into the Title I application. However, the internal controls were ineffective as the School Corporation requested to receive a listing of poverty student counts only; the list of enrolled students was not provided by the nonpublic schools. Therefore, we were unable to determine if the enrolled student count in the application was accurate. 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). . . ." 34 CFR 200.78(a)(1) states: "After reserving funds, as applicable, under § 200.77, including funds for equitable services for private school students, their teachers, and their families, an LEA must allocate funds under this subpart to school attendance areas and schools, identified as eligible and selected to participate under section 1113(a) or (b) of the ESEA, in rank order on the basis of the total number of public school children from low-income families in each area or school." INDIANA STATE BOARD OF ACCOUNTS 24 LAKE RIDGE SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Cause A proper system of internal controls was not designed by management of the School Corporation, which would include segregation of key functions. 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 design or implementation of the components of a system of internal controls, including policies and procedures that provide segregation of duties and additional oversight as needed, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, documentation was not available to determine if the enrolled and poverty counts for the public and non-public data in the Title I application was accurate. 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 documentation is retained to support information in the Title I application. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

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

FINDING 2023-006 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): S010A210014, SA10A200014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Annual Report Card, High School Graduation Rate Audit Finding: Material Weakness Repeat Finding This is a repeat finding from the prior audit report. The prior audit finding number was 2021-003. INDIANA STATE BOARD OF ACCOUNTS 25 LAKE RIDGE SCHOOLS 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 would likely be effective in preventing, or detecting and correcting, noncompliance to ensure required documentation supporting the removal of a student from the high school graduation cohort for mobility reasons was prepared, reviewed, and retained. When a student is listed on the cohort report as having exited the cohort, the school should have documentation supporting the removal of those students. One individual was responsible for collecting and reviewing the documentation and then removing the student from the graduation cohort. There was no evidence of a second review by a knowledgeable individual to ensure all students removed from the cohort had the appropriate documentation. The lack of internal controls was a systemic issue 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). . . ." Cause A proper system of internal controls was not designed by management of the School Corporation which would include segregation of key functions. 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. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation design and implement a proper system of internal controls, including policies and procedures that would provide segregation of duties to ensure appropriate reviews, approvals, and oversight are taking place. INDIANA STATE BOARD OF ACCOUNTS 26 LAKE RIDGE SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2023-006 Information on the federal program: 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 CFDA Number: 84.010 Federal Award Numbers and Years (or Other Identifying Numbers): S010A210014, SA10A20014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Annual Report Card, High School Graduation Rate Audit Finding: Material Weakness Contact Persons Responsible for Corrective Action: Regin Johnson, Title I Director Chris Bajmakovich, Principal Calumet HS Contact Phone Number and Email Address: (219) 838-1819 rjohnson@lakeridgeschools.net cbajmakovich@lakeridgeschools.net Condition: An effective internal control system, which would include segregation of duties,was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Annual Report Card, High School Graduation compliance requirement. Context: One individual was involved in collecting the High School student documentation for withdrawal, reviewing the documentation, and removing the student from the cohort. Other review of knowledgeable individual was not documented to ensure all students that were removed from the graduation cohort, had the appropriate documentation to do so. Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The high school principal shall review and approve withdrawal documentation collected by the registrar prior to the removal of the student from the graduation cohort. Anticipated Completion Date: Immediate

2021-003

FINDING 2023-008 Subject: COVID-19 - Education Stabilization Fund - Special Tests and Provisions - Wage Rate Requirements Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Number: 84.425D Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Wage Rate Requirements Audit Findings: Material Weakness, Modified Opinion 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 would likely be effective in preventing, or detecting and correcting, noncompliance to ensure that construction contracts in excess of $2,000 paid from federal grant funds included a prevailing wage rate clause and that certified payrolls were obtained. Construction contracts in excess of $2,000 financed by federal assistance funds must pay wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) to their laborers and mechanics. Nonfederal entities are to include in their construction contracts subject to the Wage Rate Requirements a provision that the contractor or subcontractor comply with these requirements and the DOL regulations. This would include a requirement to submit a copy of the payroll and statement of compliance to the entity for each week in which contract work was performed. One construction contract, totaling $4,000,000 was paid from the COVID-19 - Education Stabilization Fund grant funds during the audit period. The one construction contract was selected for testing. Upon review of the construction contract, it was determined the required prevailing wage rate clause was not properly included. Additionally, certified payrolls were not obtained until after the School Corporation was issued an ESSER Construction Monitoring Report in late 2023. The School Corporation only obtained a "sample" of certified payrolls and did not obtain all of the certified payrolls for the work performed within the grant period. The lack of internal controls and noncompliance was isolated to the contract noted above. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: INDIANA STATE BOARD OF ACCOUNTS 29 LAKE RIDGE SCHOOLS 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). . . ." 29 FR 5.5 states in part: "(a) The Agency head shall cause or require the contracting officer to insert in full in any contract in excess of $2,000 which is entered into for the actual construction, alteration and/or repair, including painting and decorating, of a public building or public work, or building or work financed in whole or in part from Federal funds or in accordance with guarantees of a Federal agency or financed from funds obtained by pledge of any contract of a Federal agency to make a loan, grant or annual contribution (except where a different meaning is expressly indicated), and which is subject to the labor standards provisions of any of the acts listed in § 5.1, the following clauses . . . (1) Minimum wages. (i) All laborers and mechanics employed or working upon the site of the work (or under the United States Housing Act of 1937 or under the Housing Act of 1949 in the construction or development of the project), will be paid unconditionally and not less often than once a week, and without subsequent deduction or rebate on any account (except such payroll deductions as are permitted by regulations issued by the Secretary of Labor under the Copeland Act (29 CFR part 3)), the full amount of wages and bona fide fringe benefits (or cash equivalents thereof) due at time of payment computed at rates not less than those contained in the wage determination of the Secretary of Labor which is attached hereto and made a part hereof, regardless of any contractual relationship which may be alleged to exist between the contractor and such laborers and mechanics. . . . (3) Payrolls and basic records. . . . (ii) (A) The contractor shall submit weekly for each week in which any contract work is performed a copy of all payrolls to the (write in name of appropriate federal agency) if the agency is a party to the contract, but if the agency is not such a party, the contractor will submit the payrolls to the applicant, sponsor, or owner, as the case may be, for transmission to the (write in name of agency). . . ." 2 CFR 200 Appendix II states in part: "In addition to other provisions required by the Federal agency or non-Federal entity; all contracts made by the non-Federal entity under the Federal award must contain provisions covering the following, as applicable. . . . INDIANA STATE BOARD OF ACCOUNTS 30 LAKE RIDGE SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (D) Davis-Bacon Act, as amended (40 U.S.C. 3141-3148). When required by Federal program legislation, all prime construction contracts in excess of $2,000 awarded by non- Federal entities must include a provision for compliance with the Davis-Bacon Act (40 U.S.C. 3141-3144, and 3146-3148) as supplemented by Department of Labor regulations (29 CFR Part 5, "Labor Standards Provisions Applicable to Contracts Covering Federally Financed and Assisted Construction"). In accordance with the statute, contractors must be required to pay wages to laborers and mechanics at a rate not less than the prevailing wages specified in a wage determination made by the Secretary of Labor. In addition, contractors must be required to pay wages not less than once a week. . . ." Cause A proper system of internal controls was not designed by management of the School Corporation, which would include segregation of key functions. 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 a result, construction contracts entered into did not contain the required wage rate requirements clauses nor were certified payrolls timely obtained by the School Corporation. 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 the School Corporation's management establish a system of internal controls and include the wage rate requirement clause in construction contracts. In addition, certified payrolls should be obtained as required. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2023-008 Information on the federal program: Subject: COVID-19 - Education Stabilization Fund - Special Tests and Provisions - Wage Rate Requirements Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Number: 84.425D Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Wage Rate Requirements Audit Findings: Material Weakness, Modified Opinion Contact Persons Responsible for Corrective Action: Regin Johnson, Title I Director Adrian Wilkerson, Chief Financial Officer Contact Phone Number and Email Address: (219) 838-1819 rjohnson@lakeridgeschools.net awilkerson@lakeridgeschools.net Condition: Construction contracts in excess of $2,000 financed by federal assistance funds must pay wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) to their laborers and mechanics. Nonfederal entities are to include in their construction contracts subject to the Wage Rate Requirements a provision that the contractor or subcontractor comply with these requirements and the DOL regulations. This would include a requirement to submit a copy of the payroll and statement of compliance to the entity for each week in which contract work was performed. Context: The School Corporation had not designed, nor implemented a system of internal control to ensure that construction contracts in excess of $2,000 paid from federal grant funds included a prevailing wage rate clause. One construction contract, totaling $4,000,000 was paid from the Education Stabilization Fund grant funds during the audit period. The single contract was tested and it did not contain the required prevailing wage rate clause. Additionally, certified payrolls were not obtained until after the School Corporation was issued an ESSER Construction Monitoring Report in late 2023. The School Corporation only obtained "sample" of certified payrolls and did not obtain all of the certified payrolls for the work performed within the grant period. Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Chief Financial Officer and Grant Director will ensure that all future construction contracts contain the prevailing wage rate clause required by the program. Additionally, the Chief Financial Officer will review and approve all certified payrolls and compliance statements submitted by contractors and subcontractors in order to ensure compliance with the program. Anticipated Completion Date: Immediate

FINDING 2021-003 Information on the federal program: Subject: Title I Grants to Local Educational Agencies - Internal Controls Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listing Number: 84.010 Federal Award Numbers and Years (or Other Identifying Numbers): S010A180014, S010A190014 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Special Tests and Provisions ? Annual Report Card, High School Graduation Rate Audit Finding: Significant Deficiency 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). . . ." 34 CFR 200.19(b) states in part: "High schools? (1) Graduation rate. Consistent with paragraphs (b)(4) and (b)(5) of this section regarding reporting and determining AYP, respectively, each State must calculate a graduation rate, defined as follows, for all public high schools in the State: (i) (A) A State must calculate a 'four-year adjusted cohort graduation rate,' defined as the number of students who graduate in four years with a regular high school diploma divided by the number of students who form the adjusted cohort for that graduating class. . . . (ii) The term 'adjusted cohort' means the students who enter grade 9 (or the earliest high school grade) and any students who transfer into the cohort in grades 9 through 12 minus any students removed from the cohort. (A) The term "students who transfer into the cohort" means the students who enroll after the beginning of the entering cohort's first year in high school, up to and including in grade 12. (B) To remove a student from the cohort, a school or LEA must confirm in writing that the student transferred out, emigrated to another country, or is deceased. (1) To confirm that a student transferred out, the school or LEA must have official written documentation that the student enrolled in another school or in an educational program that culminates in the award of a regular high school diploma. . . . (2) Transitional graduation rate. (i) Prior to the deadline in paragraph (b)(4)(ii)(A) of this section, a State must calculate graduation rate as defined in paragraph (b)(1) of this section or use, on a transitional basis? (A) A graduation rate that measures the percentage of students from the beginning of high school who graduate with a regular high school diploma in the standard number or years; or . . . (ii) For a transitional graduation rate calculated under paragraph (b)(2)(i) of this section? (A) 'Regular high school diploma' has the same meaning as in paragraph (b)(1)(iv) of this section; (B) 'Standard number of years' means four years unless a high school begins after ninth grade, in which case the standard number of years is the number of grades in the school; and (C) A dropout may not be counted as a transfer. . . ." 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 Special Tests and Provisions - Annual Report Card, High School Graduation Rate compliance requirement. Cause: The School Corporation had not developed a system of internal control to ensure compliance with the Special Tests and Provisions - Annual Report Card, High School Graduation Rate compliance requirement. Effect: The School Corporation had not developed a system of internal control to ensure compliance with the Special Tests and Provisions - Annual Report Card, High School Graduation Rate compliance requirement. Questioned Costs: There were no questioned costs identified. Context: The School Corporation did not comply with the Special Tests and Provisions - Annual Report Card, High School Graduation Rate requirement, which necessitated that for the students removed from the High School cohort graduation rate for mobility reasons there was written documentation that the student was enrolled in another school or in an educational program that culminated in the award of a high school diploma, or emigrated to another country, or was deceased. Of the 5 students tested, 1 did not have the required supporting documentation to substantiate removal from the cohort for mobility reasons. Identification as a repeat finding: Yes. Identified as Finding 2019-004 in the prior audit report. Recommendation: We recommended that the School Corporation's management establish controls to ensure compliance and comply with the Special Tests and Provisions - Annual Report Card, High School Graduation Rate compliance requirement. Views of Responsible Officials and Planned Corrective Actions: For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2021-003 Information on the federal program: Subject: Title I Grants to Local Educational Agencies - Internal Controls Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listing Number: 84.010 Federal Award Numbers and Years (or Other Identifying Numbers): S010A180014, S010A190014 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Special Tests and Provisions ? Annual Report Card, High School Graduation Rate Audit Finding: Significant Deficiency Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Special Tests and Provisions - Annual Report Card, High School Graduation Rate compliance requirement. Context: The School Corporation failed to comply with the Special Tests and Provisions - Annual Report Card, High School Graduation Rate requirement, which necessitated that for the students removed from the High School cohort graduation rate for mobility reasons there was written documentation that the student was enrolled in another school or in an educational program that culminated in the award of a high school diploma, or emigrated to another country, or was deceased. Of the 5 students tested, 1 did not have the required supporting documentation to substantiate removal from the cohort for mobility reasons. Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Title I Director will meet with the District Data Specialist to ensure the buildings are coding student withdrawals correctly and are obtaining the proper documentation. The District Data Specialist will review with registrars the proper documentation that must be kept on hand; continued training will occur to meet the internal control requirement. Responsible Party and Timeline for Completion: The responsible parties are listed above and the timeline for completion will be immediately.

2019-004

FINDING 2019-004 Subject: Title I Grants to Local Educational Agencies - Special Tests and Provision - Annual Report Card, High School Graduation Rate Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies CFDA Number: 84.010 Federal Award Numbers and Years (or Other Identifying Numbers): 17-4650, 18-4650, 19-4650 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 Repeat Finding This is a repeat finding from the immediately prior audit. The prior audit finding number was 2017-009. Condition and Context An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Special Tests and Provisions - Annual Report Card, High School Graduation Rate compliance requirement. The School Corporation failed to comply with the Special Tests and Provisions - Annual Report Card, High School Graduation Rate requirement, which necessitated that for the students removed from the High School cohort graduation rate for mobility reasons there was written documentation that the student was enrolled in another school or in an educational program that culminated in the award of a high school diploma, or emigrated to another country, or was deceased. Of the 14 students tested, 4 did not have the required supporting documentation to substantiate removal from the cohort for mobility reasons. The lack of 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). . . ." 34 CFR 200.19(b) states in part: "High schools? (1) Graduation rate. Consistent with paragraphs (b)(4) and (b)(5) of this section regarding reporting and determining AYP, respectively, each State must calculate a graduation rate, defined as follows, for all public high schools in the State: (i) (A) A State must calculate a 'four-year adjusted cohort graduation rate,' defined as the number of students who graduate in four years with a regular high school diploma divided by the number of students who form the adjusted cohort for that graduating class. . . . (ii) The term 'adjusted cohort' means the students who enter grade 9 (or the earliest high school grade) and any students who transfer into the cohort in grades 9 through 12 minus any students removed from the cohort. (A) The term "students who transfer into the cohort" means the students who enroll after the beginning of the entering cohort's first year in high school, up to and including in grade 12. (B) To remove a student from the cohort, a school or LEA must confirm in writing that the student transferred out, emigrated to another country, or is deceased. (1) To confirm that a student transferred out, the school or LEA must have official written documentation that the student enrolled in another school or in an educational program that culminates in the award of a regular high school diploma. . . . (2) Transitional graduation rate. (i) Prior to the deadline in paragraph (b)(4)(ii)(A) of this section, a State must calculate graduation rate as defined in paragraph (b)(1) of this section or use, on a transitional basis? (A) A graduation rate that measures the percentage of students from the beginning of high school who graduate with a regular high school diploma in the standard number or years; or . . . (ii) For a transitional graduation rate calculated under paragraph (b)(2)(i) of this section? (A) 'Regular high school diploma' has the same meaning as in paragraph (b)(1)(iv) of this section; (B) 'Standard number of years' means four years unless a high school begins after ninth grade, in which case the standard number of years is the number of grades in the school; and (C) A dropout may not be counted as a transfer. . . ." Cause The School Corporation had not developed a system of internal control to ensure compliance with the Special Tests and Provisions - Annual Report Card, High School Graduation Rate compliance requirement. Effect The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement or the compliance requirement listed above could have resulted in the loss of federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish controls to ensure compliance and comply with the Special Tests and Provisions - Annual Report Card, High School Graduation Rate compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2019-004 Contact Person Responsible for Corrective Action: Kathy Martin, Title I Director Contact Phone Number: (219) 838-1819 Views of Responsible Official: The district concurs with the internal control finding, the review tested that there were weaknesses with a portion of the documents reviewed from the school building registrar. Description of Corrective Action Plan: The Title I Director will meet with the District Data Specialist to ensure the buildings are coding student withdrawals correctly and are obtaining the proper documentation. The District Data Specialist will review with registrars the proper documentation that must be kept on hand; continued training will occur to meet the internal control requirement. Anticipated Completion Date: Review and training will occur on or before March 31, 2020.

2017-009

GSA_MIGRATION

GSA_MIGRATION

2015-003

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

2015-006, 2015-007

GSA_MIGRATION

GSA_MIGRATION