Corrective Action Plans

GDOL acknowledges this is a repeated finding from previous years, therefore the Department concurs with this finding and offers the following response preceded by the auditor’s findings: Auditor’s Findings: The Georgia Department of Labor did not have effective internal controls in place to ensure unemployment benefit payments were made correctly and only to eligible claimants. 1) Claimants did not self-certify for benefits in eighteen instances GDOL Response: Employer Filed Partial Claims (EFC) are submitted by employers on behalf of the claimant. The employer is responsible for attesting to the employment status and weekly earnings of the claimant for the EFC submitted. An affidavit certifying that the employer has obtained earnings from other employment as well as other requirements must be completed before EFCs can be entered or uploaded. Claimants for which EFCs are submitted are considered to be still attached to the employer and are exempt from the requirement to register for employment services per Georgia Employment Security Law Rule 300-2-4-.02. Such individuals are not required to be nor certify on a weekly basis to be able, available and actively seeking work. We recognize the state auditor's recommendations to add the self-certification. However, the current unemployment system is obsolete, having been put into production in 1982. This finding will persist until our new modernized unemployment insurance (UI) system is implemented in 2026. 2) Fraudulent employer-filed claims were filed for thirteen claimants GDOL Response: When we identify employer fraud schemes, we follow the guidance issued by the United States Department of Labor (USDOL) and collaborate with the United States Department of Labor Office of Inspector General (OIG) to investigate these cases. Additionally, we have taken the following measures to safeguard the system against fictitious employers: • Effective December 6, 2021, the Employer Filed Partial Claims (EFC) process was revised to require individuals (employees) to complete an EFC profile to include a real-time identity verification before payments can be made. Employers are responsible for submitting the request for the payment to certify to the individual’s employment status, but the individuals must certify their identity and personal information for the claim to be processed. Employees are notified when a claim is filed on their behalf and provided instructions for their portion of completing the EFC process. The MyUI Customer Portal dashboard provides all the EFC correspondence sent to the individual as well as the status of the profile setup and identify verification. • Before the implementation of the EFC profile requirement, GDOL utilized the Social Security Administration (SSA) crossmatch and Systematic Alien Verification for Entitlement (SAVE) verification processes to verify the identity of claimants where employers submit claims on their behalf. • Effective June 29, 2023, GDOL implemented additional employer filed claims safeguards and security measures to reflect amended Georgia Employment Security Rule 300-2-4-.09. Employers must now meet the following conditions to submit Employer Filed Partial Claims on behalf of their employees: o Employer accounts must have been registered with GDOL for more than 5 years. o Employers must be current on all quarterly tax and wage reports. o Employers must be current on all quarterly contribution taxes, assessments, penalties, and interest. o The week ending date on employer filed claims cannot be older than 30 days. The amended Georgia Employment Security Rule also clarifies that part-time employees are not eligible for Employer Filed Partial Claims. BPC and Integrity merit staff continue to establish pseudo claims when fraud is confirmed to relieve victims of liability and the fraudster is unknown. Otherwise, the payments are moved to the fraudsters claim account, if identified. GDOL has procured a vendor to build and implement a modernized UI system. We are also pursuing data analytics tools to expedite the identification and detection of fraudulent activities. These tools will also be incorporated into the modernized solution. 3) Proof of employment or self-employment or a valid offer to begin employment and proof of wages was not submitted by five Pandemic Unemployment Assistance (PUA) claimants. One of these claimants was not eligible to claim benefits in Georgia. GDOL Response: The claimants who established PUA entitlement with a weekly benefit amount greater than the minimum or later determined to not be eligible were based on wages entered by the claimant and/or wages reported by the employer. The Coronavirus Aid, Relief, and Economic Security (CARES) Act only required proof of wages to be submitted. If claimants did not submit proof, federal requirements only allowed for payment of the minimum weekly benefit amount and no disqualification of benefits. Claims established at a higher weekly benefit amount had to be reduced to the minimum amount if no proof was provided. To date, no proof has been provided by the claimants cited. The claims were reduced as appropriate. An overpayment has been established on all five claims identified for the difference in weekly benefit amount for weeks paid over the minimum amount under CARES and for the entire amount for weeks paid under Consolidated Appropriations Act (CAA)/American Rescue Plan Act (ARPA). GDOL’s current UI Information Technology (IT) system was developed in 1982 using mainframe “legacy’ technology. Due to the system’s age and other limitations, many automated processes and corrections cannot be fixed and/or easily implemented. As such, many processes must be handled manually by staff. This includes reviewing all the PUA proof documents submitted to determine the validity and eligibility for each PUA claim. Based on the volume of workload and staff limitations, GDOL has been unable to quickly complete this manual review to correct the finding. It is anticipated this manual review will continue throughout the FY24 audit review period. Summary: GDOL’s limited technology resources will hinder our ability to update our current system to satisfy the state audit’s recommendation. Therefore, we acknowledge that this finding will persist until a system-wide resolution is implemented in the new modernized UI system. The new solution will include a self-certification and dual certification process for employer filed claims and include controls over eligibility determinations for current and future UI programs. GDOL greatly appreciates the feedback and recommendations and will consider this information in our endeavors to modernize our UI system and business processes.

As noted by Georgia Department of Audits & Accounts (DOAA) in this finding, the corrective action, although implemented for the last quarter of F/Y 2023, was effective in dealing with this issue as no additional exceptions were identified in the tests performed by DOAA after the date of the corrective action being put into place. GDOL will continue to ensure that all current and future business practices follow the established policies and procedures of the Uniform Guidance, the U.S. Department of Labor, and the State of Georgia. When necessary, GDOL will modify its policies and procedures to ensure that expenditures reflect appropriate evidence of review and approval.

GDOL concurs with this finding: Regarding the pandemic Grants noted that were all under #UI34710-20-55-A-13: • The unemployment insurance (UI) Regular Grant typically provides the amount of available grant funds in advance based on 1.) and estimated number of claims to be processed in the current year (based on the average of two years prior activity) and 2.) the average processing times (based on the average of two years prior processing times). • In contrast, many of the pandemic grants are based on actual claims activity with monies being awarded “after the fact” with no consideration given to the aforementioned criteria as no prior- year basis exists. • GDOL experienced delays in some pandemic allocations due to delays in programing and the submission of the new reports for pandemic activities (Federal Pandemic Unemployment Compensation (FPUC), Pandemic Emergency Unemployment Compensation (PEUC) and Pandemic Unemployment Assistance (PUA)). All late reports have been submitted and we are reconciling grants as deemed appropriate. • With reimbursement based on pandemic claims activity, there was no clear mechanism for GDOL to be able to “forecast” the amount of time and effort needed to process the cyclical and unpredictable number of pandemic claims. As such, best efforts were made to estimate in this regard. • The 3073 FPUC grant is the only grant for which we have been reimbursed at 100%. However, due to the most recent implementation of stop/gain loss, we are no longer being reimbursed at the full amount. • Regarding the Employment Service/ Wagner-Peyser Funded Grants noted, the program period of performance was July 1, 2022 thru September 30, 2025. GDOL received instructions from USDOL on January 19, 2023 requesting a final ETA-9130 report be submitted by February 15th for grants that were being transferred to TCSG and offered technical assistance in completing the reports. The National office was designated to de-obligate the funds remaining and issue new grant numbers to obligate these funds at TCSG; however, several things occurred that caused the process to be delayed: o The required action was to check box 6 as yes (for the final 9130 reports) and 10g (Federal Share of Unliquidated Obligation) had to be zero although there were Unliquidated Obligations in the system. o Although the Wagner Peyer program was transferred to TCSG in January 2023, eligible costs continued. o The need for expenditure reconciliations was discussed with USDOL Regional Office and anticipated funds were drawn in lieu of billing TCSG. o Associated eligible costs were reconciled to the Wagner Peyser Ledger via manual journal entries in lieu of billing TCSG. o In addition, USDOL implemented a new GrantSolutions to replace its legacy grant processing system, E-Grants. USDOL replaced its legacy E-Grants Grantee Reporting System (GRS) by transitioning to PMS for grant recipients submission of the quarterly ETA-9130 financial reports on February 6,2023. o Although training was taken for this process, the overall reconciliation process was delayed, all reconciling items were resolved by the 9/30/23 reporting period.

We concur with this finding. Although the Wagner-Peyser Program transitioned to TCSG in December of 2022, related activities also continued at GDOL. Staff at the career centers continued to serve Georgia taxpayers in need of employment services rather than turning them away. As a result, staff continued to charge the Wagner-Peyser grant, and there were Wagner Peyser grant funds still remaining at GDOL. Journal vouchers were entered to allocate indirect costs to the Wagner-Peyser grant pursuant to GDOL's federally approved cost allocation plan. Journal vouchers were also used to correct other expenditures that should have been charged directly to Wagner Peyser. GDOL will ensure that all journal vouchers are properly supported by documentation, either attached directly to the journal voucher or the journal voucher will reference the supporting documentation which can be retrieved either electronically or manually.

The following corrective actions are being taken by Criminal Justice Coordinating Council (CJCC), effective for all federal reporting for the performance and financial period ending March 31, 2024: Federal Financial Report (FFR) Processes are updated as follows: • Federal Financial Report responsibilities are distributed on a per grant basis to the members of the CJCC Budget Team. • Because the US DOJ Just Grants system does not allow for review or secondary viewers in the financial reporting items the FFRs are to be printed digitally by the completing analysts/director. • FFR’s will be reviewed with written certification of review by a budget team member that was not responsible for primary submission of the report for each grant. • Any corrections will be made within the period of correction for the report to prevent a misstated report from becoming a permanent record. Prepared Federal Funding Accountability and Transparency Act (FFATA) and Performance Measures Tool (PMT) reports processes are updated as follows: • All PMTs and FFATA data will be routed for review through the Victims Assistance Division – Director of Operations for certification of completeness and accuracy.

Commodity Supplemental Food Program (CSFP) and The Emergency Food Assistance Program (TEFAP) have developed a tentative 2024 inventory schedule to ensure continued compliance with the annual USDA Food and Nutrition Services (FNS) requirements. The schedule was submitted to FNS as part of the state’s Management Evaluation (ME) findings response. The State received notification from FNS on January 26, 2024, noting the successful completion and close-out of the FFY 2022 Management Evaluation and its findings.

Commodity Supplemental Food Program (CSFP) and The Emergency Food Assistance Program (TEFAP) have developed a tentative 2024 agency review schedule to ensure continued compliance with the annual USDA Food and Nutrition Services (FNS) requirements. The schedule was submitted to FNS as part of the state’s FFY 2022 Management Evaluation (ME) findings response. The State received notification from FNS on January 26, 2024, noting the successful completion and close-out of the FFY 2022 Management Evaluation and its findings.

We will continuously monitor the compliance supplements for updates in order to meet all requirements. We have added additional staff to complete FFATA reporting to ensure the reports are submitted timely and accurately moving forward.

Finding 2023-001 – Title I Grants to Local Education Agencies – Activities Allowed or Unallowed, Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Amy Phillips Contact Phone Number: (765) 662-2546 ext 8070 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Marion Community Schools will establish an internal control system that will require review of all timesheets and payroll registers by the Chief Financial Officer (CFO) or the Assistant Chief Financial Officer (Asst CFO). Timesheets/payroll registers will be reviewed for any new or updated wage amounts and provide a second sign off documenting that these were reviewed and approved. The payroll employee should bring these forward for initial review, however, the CFO/Asst CFO will still review registers as a double check and to prevent errors. Payroll changes should be kept together for easy reference, as well as with the payroll file for the period in which the change was made. Anticipated Completion Date: Immediately

Finding Number: 2023-001 – Period of Performance Planned Corrective Action: The item in question was a deposit for an event that took place in August 2023. It was made in June 2023. While the $24k payment was a valid payment within the grant terms, it was inadvertently recorded as an expense item in our 2023 schedule of expenditures of federal awards instead of as a prepaid asset. Upon discovery we implemented new procedures whereby payments made at year end will be subjected to an additional review to ensure they are recorded in the proper period. Person Responsible: Stephen Mack, Chief Financial Officer Expected Completion Date: Immediately

Fiscal year ended June 30, 2023, represents a transition year for the Academy as it is the first fiscal year in which Academy staff has been in charge of processing all accounting and business transactions in‐house. Previously the Academy utilized a back‐office provider. In making the transition to in‐house processing, the Academy has sought to build up the capabilities of its business department, including the full implementation of a new financial software system as well as augmenting the capabilities of staff both in number and in capabilities. In addition, the Academy has made extensive use of expert outside consultants to strengthen its system of internal controls and accounting procedures to ensure that a robust system for processing accounting and business transactions is in place. The Academy will continue to both procure the services of outside experts and augment the capabilities of the business department as deemed necessary. In addition, the departments in charge of maintaining files and records pertinent to financial transactions will strengthen their procedures to ensure that all such files and records are properly maintained, and the business department will audit such on a quarterly basis. The business department will continue to ensure that all accounts receivable, accounts payable, and refundable advances will be reconciled quarterly. As well, at the end of each fiscal year, all areas will be reconciled and adjusted as needed. At the beginning of each fiscal year, all areas will be verified for accuracy and any necessary corrections will be made accordingly.

The Agency of Human Services receives funding under ALN 93.568 and is responsible for reporting the federal interest liability for this program to the Department of Finance and Management. The Agency of Human Services previously relied on the Department of Finance and Management for notification of the annual interest rate. Going forward, the Agency of Human Services will obtain the annual interest rate directly from the CMIA website: Cash Management Improvement Act - Annual Interest Rates (treasury.gov). The Department of Finance and Management will also verify the Agency of Human Services’ submission prior to submitting the CMIA Annual Report to the US Department of the Treasury. Position Responsible for Implementation of Corrective Action Candace Elmquist Financial Director Candace.Elmquist@vermont.gov Peter Moino Director of Internal Audit Peter.Moino@vermont.gov Date of Implementation of Corrective Action: Completed: 2/6/2024

AOE will do review training to ensure all positions processing reimbursement requests fully understand what is required for backup on payment requests. This training will be conducted jointly by the business office and our compliance team and will be completed by the end of FY24 and will include the following key points. 1. Verity the entity on the backup. 2. The period of reimbursement matches the reimbursement request period. 3. The amount on the backup must be the same and cannot be higher (or lower) than the request. Position Responsible for Implementation of Corrective Action Name: Sean Cousino Position: Deputy CFO Email: sean.couisno@vermont.gov Phone Number: 802 595-3693 Date of Implementation of Corrective Action: 7/01/2024

AOE will do review training to ensure all positions processing reimbursement requests fully understand what is required for backup on payment requests. This training will be conducted jointly by the business office and our compliance team and will be completed by the end of FY24 and will include the following key points. 1. Verity the entity on the backup. 2. The period of reimbursement matches the reimbursement request period. 3. The amount on the backup must be the same and cannot be higher (or lower) than the request. Position Responsible for Implementation of Corrective Action Name: Sean Cousino Position: Deputy CFO Email: sean.couisno@vermont.gov Phone Number: 802 595-3693 Date of Implementation of Corrective Action: 7/01/2024

The Department will review its procedures and internal controls and update as necessary to ensure that expenditures are incurred within the allowable period of performance for respective awards. It should be noted that during the period of performance for which this audit was conducted there were a large number of personnel changes and shifts. The position that was responsible for the majority of these duties retired in January 2024. We proactively hired for her replacement a year before she retired. Over the course of the year our replacement took over more and more duties. In the process of this replacement, we have completed a tremendous amount of evaluation of our assigned duties, processes, workflow, training, and documentation. Not only in this role, but we are also undergoing a division and business unit wide analysis of our internal controls and workflow. It should also be noted that the UI admin funds are considered ‘formula funds’ from the US DOL. We are expected to run this program year-round with no gaps in service or performance. The funding that we receive from US DOL is based on an antiquated formula that breaks down the amount that is budgeted by Congress between 52 state and territories. We generally do not receive enough funding for the entire year. Also, with the recent trend of Congress to utilize the tool of the Continuing Resolution our funding is often ambiguous until most of the program year is over. We have at times seen our funding cut once a budget had been passed by Congress even though there was only about 3 months left in the program year. We are still expected to run this program and ‘find other sources of funding’. This does make the adherence to the period of performance challenging. However, as we evaluate our internal controls and procedures over the coming months, we will make note of every opportunity to strengthen this function to ensure that all charges applied to program funds are relevant, within the period of performance of the award, and are correctly reviewed and signed. Cameron Wood, UI Director, Cameron.Wood@vermont.gov Scheduled Completion Date of Corrective Action Plan: August 31, 2024

The Department will review its procedures and internal controls and update as necessary to ensure that expenditures are adequately reviewed and signed off on. It should be noted that during the period of performance for which this audit was conducted there were a large number of personnel changes and shifts. The position that was responsible for the majority of these duties retired in January 2024. We proactively hired for her replacement a year before she retired. Over the course of the year our replacement took over more and more duties. In the process of this replacement, we have completed a tremendous amount of evaluation of our assigned duties, processes, workflow, training, and documentation. Not only in this role, but we are also undergoing a division and business unit wide analysis of our internal controls and workflow. Cameron Wood, UI Director, Cameron.Wood@vermont.gov Scheduled Completion Date of Corrective Action Plan: August 31, 2024

WAID management will consider documenting its policies and procedures in the event duties need to be transitioned.

Corrective Action Plan: Management agrees with the recommendation. Regarding the repeat condition of the total number of undergraduate and graduate students, it was partially corrected as the presentation of 1,219 was correct for undergraduate and the total number of enrolled undergraduate and graduate was 1,818, however the supporting data was not. The Financial Aid Office and the Business Service Office have documented the process and data source to obtain accurate data for reporting purposes. This will be corrected moving forward and reflected in the revised reporting of FISAP on December 15, 2023. Regarding the repeat condition of the tuition and fees reporting, the Business Service Office has documented the reconciling process and data source to ensure accurate reporting. The corrected undergraduate and graduate student’s tuition and fees should be $69,898,134. This will be corrected moving forward and reflected in the revised reporting of FISAP on December 15, 2023.

Management Response and Corrective Action Plan CRRUA has not previously required a single audit under Uniform Guidance, CRRUA will work with DAC Grant and Accounting team, who assist in oversight per contract agreement, to develop written procedures and policies per Uniform Guidance requirements. In addition, CRRUA will enlist external assistance for additional review and recommendations regarding the drafted policies and procedures. Finding resolved timeline: Implemented by June 30, 2024. In the next 3 months CRRUA will implement policies and procedures required to conform with Uniform Guidance. Designation of employee position responsible for meeting this deadline: Juan Carlos Crosby, (Interim) Executive Director and Mary DeAvila, Office Manager

Action taken in response to finding: • Staff will verify that costs were incurred within the grant period. • Staff will verify that payroll costs are charged according to the period end date and not the pay date.

Action taken in response to finding: • All costs charged to grants will be reviewed and verified. • Indirect costs will be checked and verified for all grants

CORRECTIVE ACTION PLAN JUNE 30, 2023 REFERENCE: 2023-101 CFDA NUMBER 84.425D – COVID 19 – EDUCATION STABILIZATION FUND U.S. DEPARTMENT OF EDUCATION – 2023 PASSED THROUGH ARIZONA STATE DEPARTMENT OF EDUCATION GRANT NUMBER: S425D210038 CLIENT RESPONSE AND CORRECTIVE ACTION PLAN We concur with the condition. 1. Name of the contact person responsible for corrective action: Michelle Borja, Finance Director 2. Corrective action planned: Time and Effort documentation for employees who work solely on a single cost objective is prepared semi-annually and signed by the employee and/or a supervisor having firsthand knowledge of the work performed by the employee. Time and Effort documentation is collected semi-annually by the Accounting Office. The Finance Director will review forms to ensure the form is completed appropriately. Forms will be reviewed to ensure the period of performance is recorded accurately and signatures obtained from employees and/or supervisors are dated appropriately. 3. Anticipated completion date: Implemented immediately and completed by June 30, 2024

CORRECTIVE ACTION PLAN JUNE 30, 2023 REFERENCE: 2023-101 CFDA NUMBER 84.425D – COVID 19 – EDUCATION STABILIZATION FUND U.S. DEPARTMENT OF EDUCATION – 2023 PASSED THROUGH ARIZONA STATE DEPARTMENT OF EDUCATION GRANT NUMBER: S425D210038 CLIENT RESPONSE AND CORRECTIVE ACTION PLAN We concur with the condition. 1. Name of the contact person responsible for corrective action: Michelle Borja, Finance Director 2. Corrective action planned: Time and Effort documentation for employees who work solely on a single cost objective is prepared semi-annually and signed by the employee and/or a supervisor having firsthand knowledge of the work performed by the employee. Time and Effort documentation is collected semi-annually by the Accounting Office. The Finance Director will review forms to ensure the form is completed appropriately. Forms will be reviewed to ensure the period of performance is recorded accurately and signatures obtained from employees and/or supervisors are dated appropriately. 3. Anticipated completion date: Implemented immediately and completed by June 30, 2024

Corrective Action Plan: A process was put in place in May 2023 to ensure all principal approvals are documented in writing or electronic approval in the system, which can be date stamped by the system. Payroll will not be run, nor grants submitted, until proper approval is received. Personnel Responsible for Corrective Action: Nachum Golodner, Academica Director of Accounting Anticipated Completion Date: June 30, 2024

FINDING 2023-006 Finding Subject: Title I Grants to Local Educational Agencies – Internal Controls Summary of Finding: There was a material weakness, in that the School Corporation had not properly designed or implemented a system of internal controls, including appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance. Vendor claims were prepared by the Deputy Treasurer or Grant Coordinator and reviewed by the Corporation Treasurer to ensure compliance with allowable costs / cost principles compliance requirement. However, this review was not documented for 11 out of the 40 vendor claims tested. Contact Person Responsible for Corrective Action: Rachel Moore Contact Phone Number and Email Address: 574-457-3188 x 1369, rmoore@wawasee.k12.in.us Views of Responsible Officials: Management concurs with the finding. Description of Corrective Action Plan: The School Corporation will put a system in place to ensure that all vendor disbursement claims are reviewed by a secondary person and to ensure that the secondary reviewer signs off on all vendor disbursement claims. Anticipated Completion Date: The projected date of completion is April 2024.