Corrective Action Plans

Finding Number: 2023-004 Finding Title: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Program: 93.778 Medical Assistance Program Name of Contact Person Responsible for Corrective Action: Shelly Staebler Corrective Action Planned: Traverse County Social Services Fiscal department will work on identifying allowable and unallowable expenditures that are submitted on these reports, so only allowable expenditures are submitted going forward. Anticipated Completion Date: Completed, September 7, 2024

Finding no.: 2023-002 Contact person(s) responsible: Sally Alworth Corrective action planned: As of April 1, 2023, MPD has adopted a new written policy for administrative cost allocation. Costs that are not allowable for federal grants are flagged both on timecards and on purchasing transactions with a subaccount code that segregates them from overhead allocations. Costs related to facilities – rent, equipment leases, office insurance, shared supplies, depreciation, etc. – are now allocated to departments based on the square footage occupancy of each department, calculated using the guidance referenced in 2 CFR 200. Administrative costs that serve the entire organization such as Human Resources, Accounting, outsourced IT support, etc., are allocated to each department based on headcount, as we consider the number of personnel per department to be the best estimate of supporting services required by each team. The Payroll Specialist generates a current employee roster by department at the end of each month, which is used to update the administrative allocation. Once all costs have been allocated to the department level, both facilities and administrative costs are allocated down to individual grants based on the proportion of total wage costs assigned to each grant within the department for that month. Anticipated completion date: April 1, 2023

Finding no.: 2023-001 Contact person(s) responsible: Sally Alworth Corrective action planned: As of April 15, 2023, a new timecard system was implemented and charges to grants are supported by actual timecard entries. Timecards are approved by the employee and reviewed by a supervisor prior to payroll processing. Anticipated completion date: April 15, 2023

Corrective Action Plan 2023-002: EnterpriseKC has conducted the suspension and debarment checks and has included those checks in the contract files for all covered transactions and has also updated its procedures to ensure those checks are conducted and added to the contract file at or before the contract effective date. Completion Date: August 2024 Contact Person: Jay Konomos, Pillar Leader

Corrective Action Plan 2023-001: Management will implement a comprehensive time tracking review process that also extends to reviewing time for employees that choose to work remotely and will ensure that time not allocated to the grant is not included in the costs allocated to the grant. Management will revise the fringe benefit rate that gets charged to the hourly rates to ensure that none of the costs included in the fringe benefits are also direct expenses billed to the grant. The unallowable costs will be redirected to other allowable grant costs in 2024. Anticipated Completion Date: September 2024 Contact Person: Jay Konomos, Pillar Leader

Finding Number: 2023-001 Compliance Requirement: Activities Allowed or Unallowed; Allowable Costs/Cost Principles Programs: United States Department of the Treasury ALN Number: 21.019 ALN Name: Coronavirus Relief Fund Contract Periods: August 9, 2022 – December 31, 2024 (County of Cook, Illinois); June 16, 2023 – June 16, 2024 (City of New Orleans, Louisiana) Planned Corrective Action: In order to ensure that retroactive personnel costs are allocated to grants appropriately, the following measures are being implemented: 1. Effective October 1, 2024, Medical Debt Resolution, Inc. (the Organization) is transitioning to a common-date annual review including a common annual salary adjustment date for all personnel. This will ensure a timely administration of personnel compensation adjustments, thus eliminating the need for retroactive pay. 2. In the unlikely event of a retrospective pay need in the future, the Organization will develop and implement a new standard operating procedure for Allocation of Retrospective Pay which will provide guidelines for how to appropriately allocate the cost across funds if multiple periods are involved. 3. The Organization is thoroughly reviewing all retrospective payments made in 2023 and 2024 YTD and will be issuing an adjustment to all grants, as applicable, by October 31, 2024. Person Responsible: Vice President, Finance & Administration Expected Completion Date: October 31, 2024

Management’s response and corrective action is as follows: To improve the accuracy of ITA tracking, a revised ITA tracking system will be implemented. This will include data entry fields to capture all necessary information for each ITA payment, minimizing errors and omissions. Reconciliation with MUNIS on a monthly basis to identify any discrepancies. Additionally, mandatory training on the revised ITA Tracking system will be conducted for relevant staff members to ensure continuity. Expected Implementation Date: July 202 Contact person: Amanda Stanley, Chief WIOA Administrator, EmployBR

Management’s response and corrective action is as follows: To improve the accuracy and timeliness of payroll processing, a revised payroll procedures manual will be developed and disseminated to all staff responsible for time approval. Additionally, mandatory training on the ExecuTime system will be conducted for these staff members to ensure they have the necessary skills for proper and timely time sheet approvals. Expected Implementation Date: June 2024 Contact person: Amanda Stanley, Chief WIOA Administrator, EmployBR

Management’s response and corrective action is as follows: Architect certification is not required by the Department of Housing and Urban Development nor our policies and procedures. It is listed in our contracts as one of the many different types of reimbursement documentation our office will accept. For many projects, an architect certification for each draw would be financially prohibitive and would likely reduce the financial viability of affordable housing developments. Our office does conduct intermittent on-site or desktop monitoring throughout the course of the project to ensure evidence activities. Additionally, all construction projects must complete permit requirements to ensure housing quality. Evidence of monitoring or activity was provided to the auditors. Expected Implementation Date: October 2024 Contact person: Marlee Pittman Miller, Director, Mayor-President’s Office of Community Development

Management’s response and corrective action is as follows: After reviewing the condition, cause, and effect of the presented Finding, the City-Parish finds it important to clarify that the duplicative charges were initially identified and documented as a self-reported finding. This discrepancy was discovered during the subrecipient monitoring component of this award and was promptly reported and reconciled prior to being presented as an audit finding. Upon identification of the duplicative charges, totaling approximately $22,000, immediate corrective action was taken to address the non-compliance. Dated January 5, 2024, a memorandum was filed disclosing the duplicative reimbursements, documenting the actions taken to rectify these charges, and recommending further steps to enhance the internal controls of the non-profit organization. The following information summarizes the East Baton Rouge City-Parish American Rescue Plan Act (ARPA): Duplication of Benefits - Findings and Corrective Action Memorandum: This memorandum documents the incidental reimbursement of multiple duplicative items associated with the subrecipient’s grant agreement and the corrective actions undertaken to resolve these findings, ensuring compliance with the terms of this award. During the routine subrecipient monitoring reviews, it was discovered that duplicate reimbursements occurred for 12 items between separate federal awards (American Rescue Plan Act SLFRF and CARES Act). In accordance with 2 CFR 200.522(c), a corrective action plan was provided to resolve the non-compliance. To address this, the following actions were taken: 1) Reconciliation of Duplicate Reimbursements: The non-profit entity has since reconciled the total value of $22,222.98 in duplicate reimbursements with an equivalent value of eligible expenses, including all necessary backup documentation to satisfy existing procurement and reimbursement requirements. 2) Development of a Duplication of Benefits Policy: It was recommended that the non-profit entity develop a comprehensive duplication of benefits policy to strengthen their internal controls further. These additional safeguards are considered best practices and are intended to minimize the risk of future non-compliance. Additionally, a comprehensive, grant specific, financial management policy template was provided to support the non-profits action to adopt and implement an appropriate standard of internal controls. The City-Parish is committed to maintaining robust internal controls and ensuring compliance with federal regulations. Immediate corrective measures were proactively taken to address these duplicative charges. Additionally, the City-Parish's third-party grants manager has established recurring weekly monitoring meetings with the non-profit entity to support the development and implementation of an adequate system of internal controls. Continuous efforts are being made to improve these processes to prevent such issues in the future. Expected Implementation Date: January 2024 Contact person: Courtney Scott, Assistant Chief Administrative Officer, Mayor-President’s Office

Management’s response and corrective action is as follows: The volume, complexity, and rapid pace needed to provide benefits inherently results in higher risk of fraud. The City-Parish's policies and procedures detected the fraud as required by program guidance. Additional restrictions were implemented to further protect the program from fraud including no longer allowing any exceptions to homestead, not allowing any single-room rentals, and requiring a landlord provide documentation of 3 months of rental payments/deposits—no handwritten receipts accepted. The City-Parish also sent an email blast out to applicants to ensure they understood the additional documentation requirements. Consultants for the City-Parish provided a fraud detection tip sheet to case managers, consolidating previously given guidance, to assist them in determining potential incidents of fraud. There have been no instances of suspected fraud since July 2023 due to these measures. Expected Implementation Date: June 2024 Contact person: Dante Bidwell, Chief Administrative Officer, Office of the Mayor-President

State of Missouri Single Audit Corrective Action Plan Year Ended June 30, 2023 State Agency: Department of Social Services (DSS) – MO HealthNet Division (MHD) and Family Support Division (FSD) Audit Finding Number: 2023-006 Medicaid and CHIP Participant Eligibility Terminations Name of the contact person responsible for corrective action: Heather Atkins Anticipated completion date for corrective action: June 30, 2024 Recommendations: The DSS through the MHD and the FSD review, strengthen, and enforce internal controls to ensure ineligible participant cases are closed when necessary and resume the DHSS vital records death match in the MEDES. DSS Response: The DSS partially agrees with this finding. Although, at this time, a death match with Department of Health and Senior Services (DHSS) vital records is not functional in MEDES, the death match is functional in the Family Assistance Management Information System (FAMIS) eligibility system currently used for SNAP, TANF, and MO HealthNet for Aged, Blind, and Disabled individuals. When the match is received into FAMIS from DHSS, that information is included on the eligibility file submitted to MMIS to ensure that the death date is captured in MMIS to prohibit any payments after the death of the individual. This control ensures that no improper payments are made on a beneficiary’s behalf after the date of death. DSS has processes in place to close eligibility when death information is received from family members and providers during the certification period. Additionally, DSS administers an electronic verification match with the federal hub during the annual review process to inquire about death. DSS also intends to resume use of the DHSS vital statistics match in MEDES in the future, but does not have an expected resumption date at this time. During the audit period, the FSD Call Center had processes in place to accept calls for applications, renewals, change in circumstance, and inquiries. However, contracted staff are unable to authorize any action that results in a case closing and that authorization must be completed by a DSS employee. There were procedures in place to transfer a call that will result in a case closing to a DSS employee. However, the participant cited in the finding failed to remain on the line during the transfer process, resulting in DSS staff not receiving the request to voluntarily close the case. Although call center staff noted in the electronic case file the purpose of the call, there are not systematic controls in place to take action or create tasks for DSS employees from the case notes. The DSS is strengthening internal controls by developing technology to receive changes from participants using technology that will populate the changes reported into MEDES and will create a task for DSS staff to review and authorize the change in the case. Additionally, participants can also report changes, including voluntary case closure on the FSD Portal at https://mydss.mo.gov/. Changes reported through the FSD Portal are uploaded and tasks are generated for DSS staff to review and complete the determination. Corrective action planned is as follows: Technology updates to receive changes from participants will be implemented in June 2024.

State of Missouri Single Audit Corrective Action Plan Year Ended June 30, 2023 State Agency: Department of Social Services (DSS) – MO HealthNet Division (MHD) and Family Support Division (FSD) Audit Finding Number: 2023-005 Medicaid and CHIP MAGI-Based Participant Eligibility Redeterminations Name of the contact person responsible for corrective action: Heather Atkins Anticipated completion date for corrective action: N/A Recommendations: The DSS through the MHD and the FSD review and correct cases for participants with manual overrides in the MEDES, ensure redeterminations are completed for these participants as required, and close the cases of any ineligible participants. In addition, the DSS should ensure system controls are functioning as designed for these participants. DSS Response: The DSS disagrees with this finding. The DSS disagrees there is a significant deficiency in internal controls. As noted in the finding, from the 60 participants selected, the SAO did not identify any participants with previously-established overrides; therefore, no incorrect payments were cited. Section 6008 of the Families First Coronavirus Response Act (FFCRA) required states to provide continuous coverage, through the end of the month in which the PHE period ends, to all Medicaid beneficiaries who were enrolled in Medicaid on or after March 18, 2020, regardless of any changes in eligibility unless the individual voluntarily terminated eligibility, is deceased, or moved out of state. As required by the Centers for Medicaid and Medicare Services (CMS) during the PHE, the DSS had processes in place to terminate eligibility for individuals who were deceased, voluntarily requested closure, or reported they have moved out of state when a current change was reported. The Consolidated Appropriations Act, 2023, signed on December 29, 2022, amended section 6008 of the FFCRA such that the continuous enrollment condition ended on March 31, 2023. During the PHE, the DSS did not conduct reviews of cases that did not report current changes. The DSS developed a report identifying all individuals with manual overrides and their certification dates to complete annual reviews on them. The DSS is actively working the report and have initiated annual reviews on all individuals that have had MO HealthNet eligibility for at least twelve consecutive months. The DSS anticipates completing the review of all individuals by August 31, 2024, to account for the required 90 day reconsideration period as required in 42 CFR 435.916.

State of Missouri Single Audit Corrective Action Plan Year Ended June 30, 2023 State Agency: Department of Social Services (DSS) – MO HealthNet Division (MHD) and Missouri Medicaid Audit and Compliance (MMAC) Audit Finding Number: 2023-003 - Medicaid and CHIP New Provider Eligibility Name of the contact person responsible for corrective action: Dale Carr Anticipated completion date for corrective action: June 30, 2024 Recommendation: The DSS through the MHD and the MMAC review, strengthen, and enforce internal controls to ensure complete new provider enrollment application checklists are prepared and retained documenting that new Medicaid and CHIP provider applications were reviewed and screened as required. DSS Response: DSS agrees with the auditor's recommendation. The Corrective Action Plan includes the department’s planned actions to address the finding. Corrective action planned is as follows: 1. The MMAC Provider Enrollment Unit (PEU) will add a new final check box at the bottom of the provider enrollment verification form where the PEU clerk will verify each required step to enroll a new provider was completed. 2. The MMAC PEU will increase the number of quality control reviews of completed provider enrollment verification checklists by supervisors and managers. 3. MMAC PEU will train the staff that are scanning the completed enrollment files into FileNet to look at the verification checklist and make sure it has all required initials and checks. If they determine it does not, it will be returned to the PEU staff member that processed the enrollment. 4. All PEU staff working new enrollments will be retrained on the importance of checking each step on the verification checklist to indicate whether each step was completed or “not applicable”.

State of Missouri Single Audit Corrective Action Plan Year Ended June 30, 2023 State Agency: Department of Elementary and Secondary Education (DESE) Audit Finding Number: 2023-016 Child Care Payments Name of the contact person responsible for corrective action: Shelley Woods Anticipated completion date for corrective action: 12/31/2024 Corrective action planned is as follows: DESE agrees with the auditor’s finding. It has been challenging to have adequate internal controls over the child care program with two separate state agencies trying to administer different aspects of the program. The Department of Social Services (DSS) has been implementing eligibility and authorizations for families, while DESE has been administering rates, rules, licensure, and provider agreements. Effective July 1, 2024, eligibility and authorizations for families transfers under DESE’s authority to ensure all facets of program implementation are within one state agency for better internal controls. In addition, DESE transitioned to a new Child Care Data System (CCDS) for provider payments in the beginning of January 2024. Access, interfaces, and updates within the older systems has created multiple barriers and payments issues for the program. This single system, CCDS, allows parents to have a streamlined process for eligibility determinations, report changes in address or income, find or change providers, while also giving providers one place to apply for a contract, view authorizations, update contact information, view payment remittances, and make payment adjustments. By December 31, 2024, the CCDS will have combined all functions of FAMIS, FACES, and CCBIS attendance system into CCDS. DESE users can easily and efficiently make family and rate changes as necessary and view all information in the system, which will also strengthen internal controls. DESE also continues to revise and clarify internal procedures to ensure consistent and accurate eligibility determinations and claims processing. CCDF regulations specifically state pursuant to 45 CFR 98.21(a)(1) that because a child meeting eligibility requirements at the most recent eligibility determination or redetermination is considered eligible between redeterminations, any payment for such a child shall not be considered an error or improper payment due to a change in the family's circumstances. Based on this regulation, DESE will work with the Administration for Children and Families to repay any claims considered questioned costs.

State of Missouri Single Audit Corrective Action Plan Year Ended June 30, 2023 State Agency: Department of Social Services (DSS) – Division of Finance and Administrative Services (DFAS) and Children’s Division Audit Finding Number: 2023–008 – Department of Social Services Cost Allocation Name of the contact person responsible for corrective action: Arlene Damron Anticipated completion date for corrective action: April 2024 Recommendation: The DSS continue to strengthen internal controls and procedures over the PACAP, the AlloCAP system, the RMTS process, and the RMTS allocation to ensure costs are properly allocated to federal programs. In addition, the DSS should revise the PACAP to reflect updates to the RMTS process. DSS Response: The department partially agrees with the recommendation. DSS does not agree internal controls need to be strengthened for the PACAP and the AlloCAP. This part of the process functioned as intended. The issues identified by the auditor occurred based upon the way the RMTS universe was defined after revisions were made in the HR data that was being entered into SAM II HR. Staff that were not eligible were selected for the RMTS due to these changes. Corrective action planned is as follows: The RMTS universe has been corrected to exclude staff that do not fall into the specific criteria of eligible staff. An RMTS response report will be pulled monthly to review the results to make sure invalid responses are removed prior to allocating administrative costs.

State of Missouri Single Audit Corrective Action Plan Year Ended June 30, 2023 State Agency: Department of Health and Senior Services Audit Finding Number: 2023-012 CACFP Subrecipient Reimbursements Name of the contact person responsible for corrective action: Sarah Walker, Bureau Chief Anticipated completion date for corrective action: The agency does not agree with the audit findings or believes that corrective action is not required. Explanation and specific reasons are as follows: CACFP Subrecipient Reimbursements DHSS disagrees. The DHSS through BCFNA maintains a strong system of internal controls over meal reimbursements to CACFP facilities/sponsors to ensure costs are allowable and supported. The system is in compliance with Uniform Guidance and USDA program requirements. The system includes subrecipient monitoring based on risk assessments per the substance and spirit of Uniform Guidance, initial and ongoing training and technical assistance opportunities, and reviews of invoices. Throughout the SAO’s finding they repeatedly acknowledge that the BCFNA monitoring process is in compliance with Nutritionist Manual which is based on USDA requirements, but is somehow not in compliance with broader federal requirements. This goes against the accepted hierarchy of federal compliance guidance which says that 2 CFR 200 Uniform Grant Guidance is broader and less specific than the higher ranking requirements set forth by specific federal grant funders and awards. The SAO has not noted any specific noncompliance with federal requirements regarding subrecipient monitoring. The SAO’s finding noted the DHSS could enhance or improve its process but not that it is out of compliance with federal requirements for subrecipient monitoring. The SAO is trying to hold DHSS to a higher standard than what is federally required. The DHSS’ strong system of internal controls which is documented in the Nutritionist Manual is in compliance with federal regulations and is used as a best practice by the USDA for other states. The report from the most recent USDA Management Evaluation Report for Fiscal Year 2023 issued November 2023 stated “The FNS determined that the SA Monitoring of Sponsors and SA Oversight of Sponsor Monitoring’s has adequate management controls in place for administering the CACFP in accordance with Federal regulations. The FNS staff reviewed SA practices that included detailed SA review forms, spreadsheets that provided extra oversight, and written procedures detailing the monitoring process. The SA provides online CACFP trainings along with a handbook to institutions that detail policies and procedures governed by the SA. The SA developed an extensive tracking system in addition to a very thorough review tool that contains meal component and pattern calculation. The SA conducts oversight of the review process and tracks each step to confirm completion of any follow up required of institution. The SA CACFP training resources and online modules were reviewed and evaluated to ensure it contained the correct information and up to date policies and procedures. The FNS staff reviewed the SA policies and procedures and interviewed key SA staff regarding procedures for each respective area of this Section. All files reviewed are compliant with Program requirements. The FY 2023 CACFP ME review did not identify any significant reportable issues.” This entitlement program provides reimbursements for nutritious meals and snacks to organizations that serve eligible children and adults. CACFP processes an average of 700 claims per month and provided healthy meals in Missouri to over 31 million children and adults in 2023. The increased claim testing and recoupment suggested by the SAO would create a significant barrier to participation for sponsors/facilities (many of which are small child care centers, day care homes, emergency shelters and adult day care centers) which is prohibited by USDA. Reviewing supporting documentation with every individual reimbursement claim at the time of submission as suggested in the finding is not feasible given the number of reimbursement claims processed monthly by program staff already functioning at capacity. Neither is it required by Uniform Guidance, the USDA or standard subrecipient monitoring procedures. The BCFNA already requires claims to be paid on a reimbursement basis rather than in advance and performs various reviews of the claims in CNPWeb, so the additional step of requiring supporting documentation with every reimbursement claim at the time of submission is unnecessary and is intended as a specific condition to remedy high risk subrecipients per 2 CFR 200.208. Furthermore, BCFNA offers technical assistance training and reviews in addition to regular monitoring reviews. In addition to the edit checks within the CNPWeb system which validate such things as capacity limits and licensing, BCFNA staff has, and continues to perform, additional verification such as spot-checks for inconsistencies (i.e. a greater number of enrolled participants as compared to licensed or total capacity or suspicious claim irregularities or patterns). Each claim submitted also requires a certification of truthfulness, accuracy, completeness with potential criminal, civil or administrative penalties in accordance with U.S. Code Title 18, Section 1001 and Title 31, Sections 3729-3730 and 3801-3812. As noted by the SAO, the risk based monitoring approach implemented by BCFNA has been effective in identifying significant issues and claim errors in recent years. The USDA established an acceptable level of risk with respect to the CACFP program and provided approved risk management processes and requirements. DHSS disagrees with the methodology the SAO used in its calculations. Out of the SAO’s test sample of 60 monitoring reviews, only 9 of the overclaims were over the $600 threshold of acceptable risk set by the USDA. 7 CFR 226.8(f): In conducting management evaluations, reviews, or audits in a fiscal year, the State agency, FNS, or OIG may disregard an overpayment if the overpayment does not exceed $600. A State agency may establish, through State law, regulation or procedure, an alternate disregard threshold that does not exceed $600. The SAO left the inflated error percentage in the body of the finding despite repeated requests and only included the lower suggested rates in footnote 4. The SAO also did not explain how their test of monitoring reviews performed by BCFNA, instead of a sample of claims submitted, was representative of CACFP reimbursements that would lend to projecting to the total population. BCFNA monitors using a risk-based approach as required and in response to known erroneous claims and to proactively address issues. A sample of monitoring reviews is proportionally more likely to include a higher number of claims with discrepancies. For example, fifty five percent of the monitoring reviews completed during fiscal year 2023 were graded as a B or C and were give additional technical assistance and/or monitoring follow up as a result.

Finding Number: 2023-004 Planned Corrective Action: No further funds will be released from the Coronavirus State and Local Fiscal Recovery Funds without written verification that funds are allocated for and spent in accordance with allowable expenditures. Anticipated Completion Date: December 31, 2024 Responsible Contact Person: Jennifer Widmer, County Auditor

Views of Responsible Officials: Management concurs with the recommendation. See the corrective action plan.

Finding 2023-001 – Internal control deficiency over Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance, Reporting, and Special Tests and Provisions. Condition: Management did not design effective internal controls to retain documentation to evidence the operating effectiveness of the internal controls over the projects and related expenses submitted to FEMA for reimbursement. Current Status: In progress. Resolution: Management will develop and implement additional internal controls to ensure documentation is retained to evidence the operating effectiveness of the internal controls. These internal controls will ensure expenses included in FEMA grant applications are reported completely and accurately. The additional internal controls will include a reconciliation of application expense detail to final paid invoices along with a notation that each expense is allowed to be included in the FEMA submission. The reconciliation will be reviewed and approved by the Cottage Health Director of Finance prior to final FEMA submission and evidence of the review will be retained. Contact Person: Lawrence Thomas, Director of Corporate Finance Anticipated Completion Date: November 29, 2024

Finding ref number: 2023-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with allowable activities and costs, and restricted purpose requirements. Name, address, and telephone of District contact person: Caryn Metsker, Director of Financial Services 800 Eastmont Avenue East Wenatchee, WA 98802-4443 509-888-4686 Corrective action the auditee plans to take in response to the finding: The Eastmont School District respectfully does not concur with the finding regarding our internal controls for ensuring compliance with allowable activities, costs, and restricted purpose requirements in regard to the Emergency Connectivity Funds. The District has completed the necessary corrective actions by revising our board policies and procedures to ensure compliance with allowable activities, costs, and restricted purpose requirements. However, these changes were not implemented by the end of the 2022-2023 school year because the audit for the 2021-2022 school year had not been completed until the 2023-2024 school year. Consequently, the District was unable to implement the new process until the audit status for 2021-2022 was confirmed, ensuring that the corrected steps were compliant The District did not receive any specific guidance from the State Auditor's Office on how to properly document the unmet need identified in the audit. Despite our efforts to seek assistance and clarification, the lack of direction hindered our ability to address the finding promptly. The necessary changes to our policies and procedures required approval from the Board of Directors. This approval, governed by a strict process, was not obtained until December 2023. We began working on the changes immediately following the previous audit but were constrained by the formal approval process. The District is disappointed that despite our efforts to comply, the State Auditor's Office issued another finding for the 2022-2023 audit based on a differing opinion on the "unmet" need. This repetition of findings, despite our documented efforts and changes, suggests a misalignment in expectations and understanding. The audit for the 2022-2023 school year consumed significant resources and taxpayer dollars, which we believe could have been better utilized. The time spent reviewing our information, which was largely unchanged except for the updated policy and procedure, appears redundant. We had asked for documentation and guidance from the State Auditor's Office but did not receive the necessary support or compliance assistance. The District is committed to maintaining high standards of accountability and compliance. We regret that our efforts to address the audit findings were not deemed timely enough and that this has resulted in an additional finding. We will continue to enhance our processes and seek clearer communication and guidance from the State Auditor's Office to ensure that future audits are more aligned with our compliance efforts. We hope this response provides a clear understanding of our position and the steps we have taken. Anticipated date to complete the corrective action: The corrective action has already been implemented within the school district.

City staff will contact all Community Based Organizations (CBOs) that received Emergency Rental Assistance 2 funding to determine if they were required to complete a Single Audit per the Single Audit Act. This communication will include, if applicable, a request that they submit the organizations most recent audit for review by staff. Should a Single Audit identify any findings or other deficiencies, staff will ask the CBO to provide an update as to the status of the deficiency and if it has been appropriately addressed. Staff will document this communication in the electronic file of the CBO who was required to complete a Single Audit.

The Human Services Department The Human Services Department has acknowledged the issue identified regarding timesheet pre-approvals and will take immediate steps to address the issue. HSD will ensure that proxy timesheet approvers are properly assigned in cases where the primary supervisor is unavailable on the day payroll approval is due. HSD will maintain compliance with payroll policies and ensure the accuracy of timesheet approvals. Office of Housing The Office of Housing has acknowledged the finding regarding timesheet pre-approvals and will take immediate steps to address the issue. Office of Housing will ensure that proxy timesheet approvers are properly assigned in cases where the primary supervisor is unavailable on the day payroll approval is due. This adjustment will be incorporated into the previous improved practices, eliminating the need for pre-approving timesheets. By ensuring that proxy approvers are in place, the department will maintain compliance with payroll policies and ensure the accuracy of timesheet approvals. Parks and Recreation Department The Parks and Recreation Department acknowledges the finding regarding timesheet preapprovals and will ensure that proxy timesheet approvers are assigned moving forward as part of the department's ongoing commitment to improved practices. In addition, the department would like to clarify that the pre-approval noted occurred before the implementation of the current corrective action plan, which addressed the prior year's finding. The department reassures the State Auditor's Office (SAO) that the newly adopted practices, which prevent preapprovals, will continue to be strictly followed, ensuring compliance and accuracy in payroll processing, even during pay periods that coincide with holidays.

HSD acknowledges the identified weakness and implemented an updated Accounts Payable control procedure in 2024, that includes an additional standard monthly report and review process to ensure that reimbursements are processed with the required 30-day period.

Title of result and comment:: Frankton FINDING 2023‐006 Contact person Responsible for Corrective Action: First Name: Timothy Last Name: Detrick Contact’s Phone Number:: (765) 754‐7285 Contact’s Email Address:: tdetrickct@gmail.com Views of Responsible Official: We concur with the finding Description of Corrective Action Plan:: We have started a ledger that will keep track of all funds/grants that may not appear on our bank Rec. They will be check every month by the board to make sure they are accurate. Anticipated Completion Date: Year: 2024 Month: 6 Day: 14 If applicable: Document reason issue will NOT be corrected within 6 months::