Corrective Action Plans

Title of result and comment:: Frankton FINDING 2023‐005 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:: Same as before CAP ‐ Any contract we establish we are goign to make sure they are now excluded or disquali ed by: (a) Checking SAM Exclusions; or (b) Collecting a certi cation from that person; or (c) Adding a clause or condition to the covered transaction with that person" We will also have a clause in our contracts that state they will Buy America Preference material. Anticipated Completion Date: Year: 2024 Month: 6 Day: 1 If applicable: Document reason issue will NOT be corrected within 6 months:: INDIANA STATE BOARD OF ACCOUNTS 34 Unit Name: Town of Frankton County: Madison Report period beginning date: Year: 2023 Month: 1 Day: 1 Report period ending date: Year: 2023 Month: 12 Day: 31

FINDING 2023-06 Finding Subject: Child Support Enforcement - Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Cash Management, Period of Performance Summary of Finding: No documented oversight Contact Person Responsible for Corrective Action: Amy L. Glackman Contact Phone Number: 317-392-6310 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Control procedures will be put into place effective immediately. The Auditor will meet with every department that has state grants and make sure that all invoices are double check for proper expenditures and have both employees sign off on the claim. Anticipated Completion Date: August 30, 2024

FINDING 2023-04 Finding Subject: COVID-19 Coronavirus State and Local Fiscal Recovery Funds – Reporting Summary of Finding: Reports were incorrectly completed, excluded amounts for the report period. Contact Person Responsible for Corrective Action: Amy L. Glackman Contact Phone Number: 317-392-6310 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Control procedures will be put into place effective immediately. The Auditor will have the Deputy Auditor start signing off on all reports to verify the dates are correct for the reporting period. Anticipated Completion Date: August 30, 2024

The Board of County Commissioners will work with all County Officials to go over all grants and federal monies that Comanche County receives to ensure that proper internal controls are implemented.

The Board of County Commissioners will work toward assessing and identifying risks to design written county-wide controls.

To address the identified weaknesses and strengthen internal controls over the preparation of the SEFA, management has initiated the following actions: 1. Establishment of Formal Policies and Procedures: We have developed and implemented a formal, written policy for the preparation and review of the SEFA. This policy outlines clear roles, responsibilities, and timelines for all departments involved in the process. 2. Centralization of Data Collection: We are centralizing the process of collecting expenditure data, which will be overseen by a designated team within the fiscal department. This will ensure consistency and accuracy in reporting across all departments. 3. Staff Training and Development: Key personnel involved in SEFA preparation are undergoing specialized training on federal, state, and city compliance requirements. This includes training on the proper classification of awards and expenditures. 4. Internal Review and Monitoring: A second layer of review has been introduced to verify the accuracy and completeness of the SEFA before it is submitted. A senior financial officer will perform this review, ensuring that any discrepancies are identified and corrected before submission. Management will implement ongoing monitoring to ensure adherence to the new policies and procedures. Quarterly reviews will be conducted to assess the accuracy of the data and the efficiency of the control measures. Management is committed to maintaining robust internal controls over the preparation of the SEFA to ensure the timely and accurate reporting of federal, state, and city awards. The actions outlined above are designed to prevent the recurrence of this deficiency and ensure full compliance with regulatory requirements.

Contact Person - Pattie Solberg, Auditor; Corrective Action Plan - The City should contact the Contractor to determine if the amount that was overpaid will be refunded or adjusted on the next "Pay Estimate." The City will also need to contact the Grantor to determine if the reimbursed dollars should be returned or adjusted on the next draw. To mitigate the risk of overpayment in the future, the City should reconcile construction payments to the "Pay Estimates." Completion Date - December 1, 2024

CORRECTIVE ACTION PLAN SEPTEMBER 4, 2024 The POISE Foundation respectfully submits the following corrective action plan for the year ended December 31, 2023. Name and address of independent public accounting firm: Maher Duessel, CPAs 503 Martindale Street, Suite 600 Pittsburgh, PA 15212 Audit period: January 1, 2023 to December 31, 2023 The findings from the December 31, 2023 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.Finding 2023-001 - Internal Control over Financial Reporting - Allowable Costs U.S. Department of Health and Human Services, Passed through the Pennsylvania Department of Health Immunization Cooperative Agreements, ALN 93.268 Allowable Costs Condition: The Foundation did not have adequate procedures in place to ensure that all costs submitted to the Pennsylvania Department of Health (DOH) were allowable. Close monitoring of invoices was performed by DOH, resulting in repeated requests to adjust invoicing of grant costs to remove unallowable costs. This cycle of submission and rejection went on for many months, elongating the reimbursement process. During our compliance testing, we noted three of twenty-five expenditures charged to the federal grant and selected for detailed testing that were determined to be unallowable costs. These unallowable costs were also identified by the DOH during their invoice review.Total federal expenditures between 2021 and 2023 were $2,549,344. Of this amount, expenditures totaling $1,049,850 have been reviewed in totality and ultimately approved by the DOH as allowable costs, after corrections were made by the Foundation. Remaining federal expenditures incurred in 2023 of $1,499,494 are pending DOH approval. Based on previously identified unallowable costs, we acknowledge there could be additional unallowable costs as the DOH reviews and approves invoices relating to the remaining 2023 federal expenditures. The amount of potential unallowable costs cannot be quantified. As was understood by the Foundation to be the case from grant inception, the DOH intends to review each monthly invoice to ensure 100% of costs are allowable, and will not move forward to the next month until the month under review is corrected by the Foundation and approved by DOH for reimbursement. Criteria: The Foundation administered the federal 93.268 grant passed through from the Pennsylvania Department of Health and therefore committed to following the internal control and compliance regulations set forth in Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance).Cause: The Foundation does not have internal controls in place to ensure adequate review of allowable costs for the DOH grant. Effect: The Foundation was not in compliance with allowable costs. As described above, significant effort was required on the part of the Foundation to invoice and make corrections and re-submit and significant effort was required on the part of DOH to monitor the grant submissions. This resulted in significant delays in the receipt of additional grant reimbursements by the Foundation and negatively impacted the Foundation's cash flows. Questioned costs: Unknown.Context: 100% testing by DOH to date has indicated systemic issues. Our sampling resulted in similar findings. DOH intends to do a 100% test of all transactions.Repeat Finding from Prior Year: No. Recommendation: We recommend that management establish procedures to ensure that all costs charged to the grant are appropriately reviewed and determined allowable per the grant agreement, ideally before even being incurred but certainly before being invoiced to the DOH. POISE Foundation Response: Management acknowledges several costs included in the initial invoice were deemed to be unallowable costs. It was communicated to management that it could not submit the initial invoice until all expenses had occurred for the initial payment. The initial invoice included a span of 19 months and many of the unallowable costs were reoccurring costs that were deemed unallowable. Management has hired a new Managing Director who has oversight of the invoicing process. The Managing Director has reviewed all unsubmitted invoices to ensure past costs that were deemed unallowable will not be charged in subsequent invoices and will review any new costs to ensure they comply with allowable costs. This is currently being done as of the date of this letter. Finding 2023-002: Internal Control over Financial Reporting and Account Adjustments Condition: During the audit process, several adjustments involving contribution revenue and related contributions receivable were proposed by the auditors in order for the financial statements to be prepared in accordance with accounting principles generally accepted in the United States of America (GAAP). Then, using the information provided by management, the auditors prepared the GAAP financial statements, which were subsequently reviewed by management. These adjustments were necessary to properly reflect current year operations and account balances as of year-end. Criteria: Auditing standards continue to place emphasis on determining an entity's ability to fully prepare their own external financial statements, including the posting of all adjustments necessary to present financial statements in accordance with GAAP and evaluating the need for all necessary financial statement disclosures.Cause: Internal controls were not in place to ensure that the Foundation follow appropriate contribution revenue recognition standards for conditional and unconditional grant awards and the Foundation did not post necessary adjustments for contribution revenue to be recorded in accordance with GAAP. Effect: Adjustments were required to be recorded in order for the financial statements to be prepared in accordance with GAAP. Recommendation: We recommend that management evaluate the internal controls over the financial reporting process to ensure that an individual is assigned to review contributions received for proper revenue recognition and to ensure the financial statements are prepared in accordance with GAAP. POISE Foundation Response: POISE Foundation has put in place a process whereby revenue will be classified as conditional or unconditional and booked accordingly based on a review of funding agreements and contracts by the development, program and finance department staff to ensure there is agreement on the nature of the revenue to ensure proper accounting in a timely manner.This is currently being done as of the date of this letter. If the Pennsylvania Department of Health has questions regarding this plan, please contact Mark S. Lewis at 412-281-4967

Finding Number: 2023‐002 Program Name/Assistance Listing Title: Education Stabilization Fund Assistance Listing Numbers: 84.425U Contact Person: Talise Berry Anticipated Completion Date: April 30, 2025 Planned Corrective Action: The Wilson School District has begun implementing internal procedures that require supporting documentation to be uploaded into the financial system for all transactions. Ongoing staff turnover will facilitate the enforcement of this process among all personnel handling transactions within the financial system. The district has also developed resources to ensure that staff understand the importance of maintaining accurate supporting documentation.

We concur with this finding and have implemented measures to mitigate the repetition or additional occurrences. In 2020, we implemented an electronic system to more efficiently collect and store expenditures and supporting documentation, eliminating a paper filing system. We updated our fiscal policies and procedures in 2022 to document a standardized process for documenting expenditures and retaining receipts. For instance, invoices cannot be processed without adequate documentation. Additionally, credit card holders are responsible for submitting electronic credit card receipts to the fiscal office monthly. In 2022, an updated credit card policy was provided to all employees. The adherence to the credit card policy is monitored by the Fiscal Office and CEO. Responsible person(s): Jemea Dorsey, CEO and Jeanetta Johnson, Fiscal Manager Anticipated Completion Date: FY 2022

2023-005 Allowable Costs/Cost Principles – Indirect Costs U.S. Department of Education Education Stabilization Fund – Assistance Listing No. 84.425 Pass-Through Agency: Arizona Department of Education Pass-Through Number(s): All Pass-Through Numbers Present in the SEFA Recommendation: We recommend management to incorporate a management review control to ensure the calculation is complete and accurate and all supporting documents including the general ledger used for the calculation is retained in accordance with UG. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The district will have a process in place to update all documentation related to indirect costs and the calculations from the general ledger. Name(s) of the contact person(s) responsible for corrective action: Clementina Carlyle, Chief Financial Officer.

Management Response The eight selections were for salaried employees who worked more than 80 hours in the pay period. When a salaried employee has uncompensated overtime, the Garden must charge the documented hourly rate, adjusting hours for the uncompensated time against non-contract funding. This results in the actual paid dollars being billed to the federal award, as appropriate for cost reimbursement. The outcome being total hours on the timecard may be more than the paid hours reflected in the register. This is in accordance with the Uniform Guidance. The calculation of this adjustment was performed but not documented. Corrective Action Plan: Documentation of the salary allocation process has been completed. Anticipated Completion Date: Completed. Contact person(s) responsible for the corrective action: Jaime Kuczkowski, CPA Jaime@balancefm.com, Diane Wondolowski, Director of Finance, dwondolowski@sbbotanicgarden.org.

FINDING 2023-005 Finding Subject: COVID 19 Reporting Summary of Finding: We were required to submit quarterly P & E reports, ours were submitted in error Contact Person Responsible for Corrective Action: Amy Roberts Contact Phone Number and Email Address: ARoberts@dalevilleindiana.org 765-378-6288 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We will create controls so reports will be submitted in accurate manner in the future Anticipated Completion Date: March 1, 2025

FINDING 2023-004 Finding Subject: COVID 19 Procurement Suspension and Debarment Summary of Finding: We did not have a policy for procurement and debarment for federal funds Contact Person Responsible for Corrective Action: Amy Roberts Contact Phone Number and Email Address: ARoberts@dalevilleindiana.org 765-378-6288 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We will create a policy for future federal fund expenditures Anticipated Completion Date: March 1, 2025

The City of Scottsboro will adopt and implement policies in regards to federal award compliance, including subrecipient monitoring compliance.

Planned Corrective Actions: MARR will retain a CPA consultant to implement a document retention policy that is consistent with federal document retention requirements.

Planned Corrective Actions: MARR will retain a CPA consultant to implement a full - range of controls relating to reporting, including federal program reporting. MARR will take such steps as necessary to ensure that reports are timely and accurately prepared, reviewed, and approved prior to filing. All controls, including review and approval will be documented in such documentation to be maintained. MARR will retain a CPA consultant to implement and adopt formal written policies relating to grants management ordered by Uniform Guidance.

Planned Corrective Actions: MARR will retain a CPA consultant to implement a full-range of control over costs charged to federal programs. MARR’s protocol shall ensure that such costs are the direct benefit to the program, are reviewed, approved, documented and ensure the accounting and reporting process be accurate. Further, controls over grant billings will be established to ensure expenditures represent actual costs incurred. All control activities, including independent review, should be documented and evidence of review and approval will be maintained.

Planned Corrective Action: MARR will retain a CPA consultant to recommend to management the establishment of procedures and controls to allocate costs between grants based on actual costs attributed to grant and the particular expenditure allowed by the grant. All such allocations will be supported by activity-level substantiation and be reviewed. Documentation of the allocation methodology, review and approval will be maintained in writing. MARR will retain a CPA consultant to implement a full-range of control over costs charged to federal programs. MARR's primary decision-making authority regarding such controls shall be placed with the MARR's president. MARR's protocol shall ensure that such costs are the direct benefit to the program, are reviewed, approved, documented and ensure the accounting and reporting process be accurate. Further , controls over grant billings will be established to ensure expenditures represent actual costs incurred. All control activities, including independent review, should be documented and evidence of review and approval will be maintained.

Planned Corrective Action: MARR will retain a CPA consultant to establish formal written policy documenting significant accounting procedures including but not limited to the independent review of the grant period of performance when recording transactions and preparing grant reimbursement requests. Evidence of the review to be documented and maintained according to the procedures to be implemented.

FINDING 2023-004 Finding Subject: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Suspension and Debarment Federal Agency: Department of the Treasury Summary of Finding: Prior to entering into subawards and covered transactions with SLFRF award funds, recipients are required to verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded. &”Covered transactions” include, but are not limited to, contracts for goods and services awarded under a non-procurement transaction (i.e., grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the Excluded Parties List System (EPLS), collecting a certification from that person, or adding a clause or condition to the covered transaction with that person. Due to the Treasury’s determination that the revenue loss eligible use category does not give rise to subawards, the County was only required to comply with suspension and debarment requirements related to covered transactions. Upon inquiry of the County determine its policies and procedures related to suspension and debarment requirements, the County stated that they did not have policies or procedures in place for verifying that an entity with which it plans to enter into a covered transaction is not suspended, debarred, or otherwise excluded or disqualified from participating in federal assistance programs or activities. The County entered into covered transactions with four vendors during the audit period for goods or services that equaled or exceeded $25,000 that were paid from SLFRF award funds. All four covered transactions, totaling $1,661,247, were selected for testing. The County did not verify the vendors’ suspension and debarment status prior to payment for any of the four vendors. Contact Person Responsible for Corrective Action: Paula Stewart Contact Phone Number and Email Address: 812-275-3111 pstewart@lawrencecounty.in.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The county will implement a policy to obtain a certification statement on all award payments exceeding $25,000 that the vendor is not suspended, debarred, or otherwise excluded from SLFRF award funds. The executed certification will be placed in the grant’s file. Anticipated Completion Date: Immediately.

FINDING 2023-002 Finding Subject: Internal Controls over COVID-19 – Coronavirus State and Local Fiscal Recovery Funds: American Rescue Plan Grant Summary of Finding: As part of sound management of the Federal award, the County was responsible for implementing a system of internal control that would ensure compliance with the applicable requirements. The County had not properly designed or implemented such a system. There was no evidence of segregation of duties, such as an oversight, review, or approval process, that would have ensured that expenditures of award funds were made only for activities and costs that were allowable under the Federal award and Federal regulations and that expenditures were made only for costs incurred within the period of performance. Additionally, the County Auditor prepared and submitted all required reports without an oversight, review, or approval process in place to ensure that the reports were accurate. Contact Person Responsible for Corrective Action: Paula Stewart, Auditor Contact Phone Number and Email Address: 812-275-3111 pstewart@lawrencecounty.in.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The County Commissioners oversee the COVID -19 – Coronavirus State and Local Fisal Recovery Fund: American Rescue Plan Grant. The county will obtain a signoff form for expenditures from this grant to indicate a review to determine the payment of award funds is only for activities and costs that are allowable under the Federal award and Federal regulations and only for costs incurred within the period of performance. The county will also implement a procedure to assign the preparation of the annual report to one individual in the office of the County Auditor. Upon completion, the individual will turn the completed report over to another individual to verify its accuracy and completeness. Both individuals will sign and date the completed report. Anticipated Completion Date: Immediately.

Corrective Action Plan: JFS has made two enhancements to its billing process to prevent errors related to cost reimbursable awards in the future: 1. JFS created a tracking mechanism within its accounting system for all federally funded programs, where accounting entries related to costs that should be billed (i.e. cash paid for reimbursable goods/services) are bifurcated from other accounting entries (i.e. accruals) which are not reimbursable. With this enhanced reporting capability, JFS can more accurately generate bills directly from its accounting system. 2. Secondly, JFS Finance was significantly understaffed in 2023, which increased the likelihood of human error. As a result, JFS has hired an Accounting Manager in 2024 and will strive for preparer and reviewer workflow on important accounting related tasks. Contact Person Responsible for Corrective Action: Lisa Brooks, CFO Anticipated Completion Date of Corrective Action: June 2024

Recommendation: We recommend that the Borough develop and implement comprehensive written procurement policies and conflict of interest policies that comply with the Uniform Guidance. Management’s Response: The Borough will research federal expenditure policies and determine the best way to move forward.

FINDING 2023-005 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds – Reporting Summary of Finding: Finding 2023-005 found that the County did not have an effective system of internal controls in place to ensure accurate and complete reporting of Project and Expenditure (P&E) reports for the Coronavirus State and Local Fiscal Recovery Funds (SLFRF). The County was unable to provide supporting documentation for current period and cumulative obligations, resulting in reporting errors. This issue was isolated to the one annual P&E report submitted during the audit period. Contact Person Responsible for Corrective Action: Chad Shireman Contact Phone Number and Email Address: 812-738-8241; cshireman@harrisoncounty.in.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The County Auditor's office acknowledges the need for strengthened internal controls and improved processes to ensure compliance with reporting requirements for federal awards. A system of internal controls will be designed and implemented to ensure segregation of duties in the preparation, review, and submission of federal reports. This will involve designating different personnel for the preparation and review of P&E reports to ensure accuracy and thorough oversight before submission. Staff involved in federal reporting will receive training on SLFRF compliance and reporting requirements, including proper procedures for documenting obligations and reporting them accurately. The County will review its procedures to ensure compliance with federal reporting requirements periodically. This will help identify any potential issues in a timely manner and allow for immediate corrective action if needed. In addition, regular reviews will verify that corrective actions from prior audits are fully implemented and maintained. Anticipated Completion Date: December 31, 2024