Corrective Action Plans

Views of responsible officials and planned corrective actions: The District will implement procedures in the 22-23 fiscal year to correct this compliance issue. District staff will follow procedures to verify that the District is not using vendors who are either suspended or debarred by the federal government, using the SAM.gov website. The following language has been communicated to CUSD staff and added to the District?s Business Users Guidelines Document. To process a requisition using Federal Monies (resource codes 3000-5999), staff shall perform the following procedures: Non-federal entities are subject to the non-procurement debarment and suspension regulations. These regulations restrict awards, sub-awards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities (2 CFR 200.213). To check if a vendor is disbarred or suspended: a. Go to the website at www.sam.gov (you do not need to register). b. Verify the status of the vendor by performing the following: ? Click on the search records icon on the top left. ? Use the "quick search" box and enter the vendor's name (leave remaining classifications blank) c. Click search at the bottom of the web page. d. Print a copy of the search results including if results were not found. e. If the vendor is not debarred, note on the requisition and / or contract if applicable, that the vendor has been checked in the SAM system and is not debarred. Include a copy of the printed page with the requisition. f. If a vendor search produces no results, print the page and attach as supporting documentation to the requisition. Note on the requisition and / or contract is applicable that the vendor has been checked in the SAM system. ? The District is prohibited from doing business with a vendor or individual that is debarred or suspended.

2022-003 Payroll Rates Approval Documentation Federal Program ? Emergency Solutions Grants Program Assistance Listing # 14.231 Significant Deficiency Category of Finding ? Allowable Costs/Cost Principles Name of contact person ? Laura Straw, Director of Finance Corrective action ? Management has reviewed the current practice for approval of raises and are implementing a new payroll system that will have authorizations built into the software which will correct this issue. Completion date ? Management and the Board of Directors implemented the above as of December 25, 2022.

Finding 2022-002 ? Allocation of Costs Based on Estimates Federal Program ? Emergency Solutions Grants Program Assistance Listing # 14.231 Significant Deficiency Category of Finding ? Allowable Costs/Cost Principles Name of contact person ? Laura Straw, Director of Finance Corrective action ? Agate is aware of the Uniform guidance regulations and will follow them in the future. The Director of Finance has implemented changes to allow for adjustments to actual periodically throughout the fiscal year and at year end to accurately account for the distribution of allocations based on actual costs. Additionally, a new accounting system that includes a module to allocate indirect costs was implemented in fiscal year 2023. Completion date ? Management and the Board of Directors implemented the above as of December 2022.

Auditor Description of Condition and Effect: The District was unable to provide evidence of allowable costs/cost principles and internal controls compliance as follows: Of the 21 payroll transactions selected for testing, the District was unable to provide documentation for eight of those charges. Of the 21 payroll transactions selected for testing, the District identified that one individual had been charged to the grant in excess of their actual payroll for the year. As a result of this condition, the District does not have appropriate payroll support for nine of the transactions charged to the grant. Auditor Recommendation: We recommend the District limit payroll charged to federal programs to costs that are supported by documentation that is allowable under federal cost principles and its own policies and procedures. Corrective Action: The District will work with its auditors to ensure that future charges to grants are for allowable costs and supported by documentation as prescribed under Uniform Guidance. Responsible Person: Lawrence Miller (Director of Finance and Business Operations) Anticipated Completion Date: June 30, 2023

Auditor Description of Condition and Effect: The District was unable to provide evidence of allowable costs/cost principles and internal controls compliance as follows: Evidence of an independent review was not documented for 16 out of 40 disbursements selected for testing. The District could not provide any supporting documentation for costs charged on 3 out of 40 disbursements selected for testing. The District is at increased risk of unallowable costs being charged to federal programs without being detected by its internal controls. Auditor Recommendation: We recommend the District follow its internal control policies and procedures that require independent review of all disbursement transactions. Corrective Action: The District will work with its auditors to ensure that future charges to grants are for allowable costs and supported by documentation as prescribed under Uniform Guidance. Responsible Person: Lawrence Miller (Director of Finance and Business Operations) Anticipated Completion Date: June 30, 2023

Corrective Action Plan: The Department will update its manual to include a process for performing and documenting a supervisory review and a reconciliation of subaward information entered into the FSRS website to USASpending.gov. In addition, the Department will reconcile all subaward reporting from June 2022 through February 2023 to ensure proper reporting during this timeframe. This reconciliation will include a supervisory review to help ensure accuracy. Anticipated Completion Date for Corrective Action: June 2023 Contact Person Responsible for Corrective Action: Corey Fronk, Director of Audits and Risk Management, Ohio Department of Education 25 South Front Street, 7th floor, Columbus, Ohio, 43215 Phone Number: 614-644-7812, E-Mail Address: Corey.Fronk@education.ohio.gov

Corrective Action Plan: 1. For one of 60 (1.7%) regular Unemployment benefit payments selected for testing, the claimant was paid FPUC benefits of $300 a week for several weeks of benefits which were already paid in state fiscal year 2021. As a result, we will question all duplicate FPUC payments made to this claimant during the audit period, totaling $4,800. a. A defect has been documented and an application development project will be created to remedy the concern. It will be prioritized amongst all of the other efforts currently in progress or planned for OJI. Timelines associated to the remediation is currently unknown. We currently don?t understand the root cause problem and what it will take to resolve it. 2. For eight of nine (88.9%) regular Unemployment benefit claims identified in an OJI system data match as potentially exceeding the maximum allowable amount per week, the claimants were paid $300 in FPUC benefits twice during the same benefit week. As a result, we will question costs for all FPUC payments over the allowable amount to these claimants during the audit period, totaling $17,640. a. A defect has been documented and an application development project will be created to remedy the concern. It will be prioritized amongst all of the other efforts currently in progress or planned for OJI. Timelines associated to the remediation is currently unknown. We currently don?t understand the root cause problem and what it will take to resolve it. 3. Two of two (100%) PUA claims identified in a uFACTS system data match exceeded the maximum allowable number of weeks (79): one by four weeks and the other by two weeks. As a result, we will question the PUA payments exceeding the maximum allowable number of weeks, totaling $1,656. a. A process adjustment has been made to ensure that when adjusting claim for proper payment, that we overpay the appropriate weeks as well. In some cases, that didn?t take place. This was a problem that was quickly identified, and a new process was created to deter this from happening again. We missed the correction on claim, and we have adjusted it. From a system perspective, if previous weeks are subsequently reversed back to paid, causing weeks to be over 79, a process will be identified to potentially mitigate the adjustment. 4. For eight of 60 (13.3%) PUA / FPUC payments selected for testing, the claimant was not eligible to receive benefits for the weeks claimed, was overpaid, or was underpaid, as follows: a. The finding for overpaid or underpaid claims was due to the tsunami of claims/workload the agency faced during the Pandemic as well as unknowledgeable new hires brought on to assist with the massive workload. At this time initial benefits adjudication is timely in its workload however we are still facing a high backlog of cases which have alleged fraud. Benefits adjudication will process claims after a thorough fraud review has been completed. Due to the backlog all of these cases will be late and have a possible under or overpayment. The benefits adjudication team will have any cases/determinations made within 21 days of receipt from BPC fraud dept. Anticipated Completion Date for Corrective Action: June 2024 Contact Person Responsible for Corrective Action: Valerie Shuster, Field Operations District Coordinator, Ohio Department of Job and Family Services 209 West 4th Street, Lorain, OH 44052 Phone Number: 440-244-7802, E-Mail Address: Valerie.Shuster@jfs.ohio.gov

Corrective Action Plan: The following actions will be taken: ? Work with the Ohio Department of Rehabilitation and Correction to obtain more accurate incarceration dates. Currently we are not receiving the dates the claimant is incarcerated in a facility. We are currently receiving their expected release date which does not meet the needs of the office. ? We do not believe there is a need to work with the Department of Health as there has been no discrepancy with the accuracy of the data provided. ? We will create a process to create a weekly review file and save those results for review and evaluation purposes for both death and incarceration records. ? We will create a procedure to investigate the results of the death and incarceration files consistent with our existing procedures to investigate similar situations. Anticipated Completion Date for Corrective Action: January 2024 Contact Person Responsible for Corrective Action: Carl Prideau, Section Chief-BPC, Ohio Department of Job and Family Services 30 East Broad Street, 38th floor, Columbus OH 43215 Phone Number: 614-644-5164, E-Mail Address: Carl.Prideau@jfs.ohio.gov

Corrective Action Plan: The Office of Community Development (OCD) is in the process of implementing a new timeline for ESGP funding to be compliant with federal regulations. The following steps of the corrective action have already been completed. 1. Since the OHTF account balance is now in the position to allow OCD to commit funds earlier within the program year, the HCRP timelines can be adjusted to meet HUD?s 60-day requirement. 2. OCD must handle this change cautiously as HCRP serves Ohio?s most vulnerable population, the homeless, and our most vulnerable grantees, non-profit organizations. Interruptions in services and operating support would be detrimental to both. Both are dependent upon the continuity of OCD?s programs? timing. Therefore, a series of meetings have been scheduled with grantees to strategize about the most seamless way to implement this change with the least disruption in services and support. The first meeting was held on February 24, 2023. The second one is scheduled for March 31, 2023. 3. OCD will discuss this topic with the Supportive Housing Advisory Group in the fall of 2023. This meeting is part of Ohio?s Consolidated Planning Process to gather stakeholders input to create Ohio?s Annual Action Plan to submit to HUD for approval. A public comment period is built into the process as well, so additional feedback may be gathered to consider. Finally, the new timeline will be approved by HUD within the Annual Action Plan. 4. While OCD is having meetings and gathering feedback, staff will be working on the internal impact this change may create. System requirement changes and delays they may cause; report deadline shifts and alignment with other homeless reporting systems; and staff workload balance in coordination with other programs are a few we are aware of at this point. Also, the program planning begins far in advance to the grantee application submission. Therefore, timelines get set and approved early on. There are times when our allocation amounts are released from HUD late which delays our application process. There are times when HUD issues our grant agreement late which will require OCD to hold all grantees? agreements until ours is executed. Either one will cause a disruption in services after the program period is changed to an earlier start date. All these factors must be carefully considered prior to making this transition, so that surprises and delays are kept to a minimum. In some cases, a back-up plan will be required. Anticipated Completion Date for Corrective Action: September 2024 Contact Person Responsible for Corrective Action: Talia D. Givens-Gore, Program Operations Manager, Ohio Department of Development 77 South High Street, 26th floor, Columbus, Ohio 43215 Phone Number: 614-728-8140, E-Mail Address: Talia.Givens-Gore@development.ohio.gov

Corrective Action Plan: The Ohio Department of Job and Family Services (ODJFS), in coordination with the Ohio Department of Medicaid (ODM), the Department of Administrative Services (DAS), and our vendor teams will continue to work to address system design weaknesses by identifying and prioritizing system changes and updates that impact eligibility determinations and benefit amounts as well as alert volume and processing improvements. Weekly problem review meetings will continue to be held to identify reported system issues and track any needed updates through the normal prioritization and slotting process. These changes will be delivered according to the agreed upon release cadence based on business priority and impact. Upon delivery of such system changes, the team will monitor production to determine if the desired outcome was achieved. ODM and ODJFS continue to meet to analyze the alerts in Ohio Benefits and the group presents recommendations to our vendor team for overall system alert improvements; these recommendations were prioritized and corrected in our normal release cadence through calendar year 2022, with the most recent release occurring in February 2022. The next alert centered release is scheduled for April 2023. Comprehensive alert reduction efforts thus far have reduced the overall ~29 million backlog alerts and drove a ~22 million annual reduction in new arrival of alerts. A system release specific to IEVSs enhancements is planned for R4.6.1 (April 2023) which will streamline the process for county staff to process IEVS matches from the IRS Unearned Income interface. There will be both E-Verify enhancements and a change in the match logic which will result in a reduction in the volume of IRS records that are flagged as IEVS matches. Caseworker time spent on processing IRS IEVS matches is expected to reduce; remaining time spent on IRS IEVS matches is expected to have more value by allowing caseworkers to focus time on matches with an eligibility impact or potential for benefit recovery. Periodic and timely review of IEVS will be completed as follows: ? Each state Fraud Control Specialist is assigned designated county agencies to provide technical assistance and training, as well as to monitor certain reports to ensure compliance with state and federal regulations. The counties will be monitored monthly and those not showing improvement will be offered training and technical assistance as appropriate. When a Fraud Control Specialist notices a county agency falling short of a required threshold, contact is made with county officials and the offer of assistance will be made. Once the number of alerts becomes manageable by the county agency, a Continuous Improvement Plan (CIP) may be required of the county agency if the issue continues over a four-month period of continuous contact and assistance. This type of CIP may be initiated outside the scope of Fraud Control Triad Review. ? The Fraud Control Section will conduct follow-up on Continuous Improvement Plans (CIPs) as part of the Triad Review process. When the county agency responds with a CIP, it is reviewed for clarity, action, and desired outcomes. Once approved, the Fraud Control Section will issue a closure letter for the Triad Review; however, a CIP may remain open for a longer period of time if warranted. We are in the process of creating a procedure and a closure letter for CIPs alone. This procedure will be implemented by June 30, 2023. ? Supervisory Reviews are monitored as part of the Triad Review process. Currently, the question is posed to the county supervisor about conducting random supervisory reviews. We are in the process of creating a procedure within the Triad Review process to be provided a list of IEVS matches that were reviewed by the supervisor. This procedure will be communicated statewide through the Fraud Control Training Program and enforced and verified during the Triad Review process.To continue to support the county caseworker staff, the Ohio Benefits Program provides training materials and promotes ongoing learning about related business processes without requiring in-person training. For each major system release or system enhancement that impacts the end user, updated training materials are produced and disseminated. These materials may take the form of job aids that are posted to the project website, train-the-trainer sessions, and video conferences where system users can ask live questions about the system. In addition to system support and training, the Ohio Department of Job and Family Services (ODJFS) in coordination with the Ohio Department of Medicaid (ODM) continue to provide the following methods by which training and system guidance is provided to CDJFS employees: 1. New Worker Training (NWT): A 12-week, comprehensive Policy and Systems training for new users (or refresher training for existing users) in the Ohio Benefits Worker Portal (OBWP) has been developed. The courses cover Policy and Systems overview, TANF, SNAP, Cash and Case Maintenance, along with the primary Medicaid programs (MAGI & ABD). The training is comprised of multiple, self-guided, Web Based Training (WBT) modules and virtual Instructor Led Training (vILT) sessions that provides `hands on? instruction. 2. Monthly Statewide County Conference: Monthly statewide webinars to cover general OFA updates for SNAP and Cash. These meetings include OFA?s Policy and TA staff, Outcomes and Analysis, Data Reporting, Quality Control, Automated Systems Training and the OB-IMS Help Desk. All areas share information on both refresher topics and emerging policy as well as systems issues where additional training is needed. The meetings are facilitated by the Program & Policy Services area within the Policy section of OFA and provides input on issues needing additional training and guidance. AST provides copies of job aids and other training documents during these support meetings. Recording of statewide training sessions are made available for counties to access on demand. 3. Operational Support Webinars: Bi-weekly webinars are delivered jointly by ODJFS and ODM, to counties for systems-based information and instruction on emerging topics and training related issues. Topics for the webinar are identified through a coordinated effort with the OB-IMS Help Desk, the weekly PBI/Defect Closure meetings and On Demand System Inquiries (received via email), to review any issues or concerns discovered by the Help Desk during the previous week. Counties are also able to submit questions and request topics in advance of the webinars to be reviewed and covered as part of the webinar agenda. 4. Ohio Benefits System Release Webinars: These are delivered jointly by ODJFS and ODM to inform counties about updates and enhancements made in each Ohio Benefits system release. During these webinars, counties are provided information regarding proper systems operation based on the items included in the release and target items that no longer require a workaround by the county worker. 5. Job Aids Available on the Innerweb: Automated Systems Training (AST) routinely provides systems-related job aids for county use that target specific topics and pain points for the counties. On the average, one to two new job aids are either created or updated each week and the Innerweb training pages are routinely referenced during New Worker Training, Operational Support, and Ohio Benefits system release webinars. 6. Quarterly Regional County Operational Support Meetings: Both the Automated Systems Training (AST) and the OB-IMS Help Desk participate in these regionally based, quarterly meetings, along with ODM Operations, Systems, and Policy staff. They provide guidance and system instruction on emerging systems issues and/or where additional training is needed. The meetings are facilitated by the Program & Policy Services area within the Policy section of OFA and provides input on issues needing additional training and guidance. AST provides copies of job aids and other training documents during these support meetings. 7. Quarterly Work Activity Round Table Meetings: Automated Systems Training (AST) and the OB-IMS Help Desk participate in these regionally based, quarterly meetings to provide guidance and system instruction related to TANF Work Activities. The meetings are facilitated by the Outcomes & Analysis area within the Policy section of OFA and provides input on issues needing additional training and guidance. 8. On Demand Systems Inquiries: Automated Systems Training (AST) maintains an email box where counties can submit inquiries about correct data entry and system functionality within the OBWP. Timely responses are provided to these inquiries frequently providing Help Desk confirmed instructions in a timely manner. Many of these inquiries are shared at the meetings and communications channels listed above. 9. System Support for Targeted Policy Training: Automated Systems Training (AST) provides system related content to support targeted Policy training topics to provide a holistic view of the application of policies within OBWP. The targeted training is delivered via virtual meetings and/or WBT modules. Some topic examples include `Expedited SNAP,? `Delayed Processing? and `Early Denial.? Recording of statewide trainings are made available for counties to access later.Interagency Agreement An Interagency Agreement is entered into by the Ohio Department of Job and Family Services (ODJFS) and the Ohio Department of Administrative Services (DAS). This Agreement is entered into for the purpose of setting forth the roles and responsibilities, budget methodology and payment terms, data sharing restrictions, security protocols, and compliance requirements for the Ohio Benefits Program. DAS and ODJFS has completed extensive policy, program, and legal reviews and the final Agreement is in circulation to secure DAS and ODJFS Director?s signatures.

Corrective Action Plan: Alerts - The Ohio Department of Administrative Services (DAS) in coordination with the Ohio Department of Medicaid (ODM), the Ohio Department Job and Family Services (ODJFS), and our vendor partners will continue to work to address system design weaknesses by identifying and prioritizing system changes and updates that impact eligibility determinations and benefit amounts as well as alert volume and processing improvements. Weekly problem review meetings will continue to be held to identify reported system issues and track any needed updates through the normal prioritization and slotting process. These changes will be delivered according to the agreed upon release cadence based on business priority and impact. Upon delivery of such system changes, the Ohio Benefits Program Team will monitor production to determine if the desired outcome was achieved. The Ohio Benefits Program Team continued to analyze system alerts during FY2021 and FY2022 and presented recommendations to the vendor partners for overall system alert improvements; these recommendations were prioritized, and strategic modifications were implemented in our normal release cadence through calendar year 2022, with the most recent release occurring in February 2022. Comprehensive alert reduction efforts thus far have reduced by approximately 29 million the overall number of backlog alerts and have resulted in approximately 22 million fewer new alert generations. The next alert-centered release, R4.6.1, is scheduled for April 2023. This release, specific to IRS IEVS enhancements will streamline the work for County Caseworkers to process IRS IEVS matches from the IRS Unearned Income interface. There will be both E-Verify enhancements and a change in the match logic which will result in a reduction in the volume of IRS records that are flagged as IRS IEVS matches. County Caseworker time spent processing IRS IEVS matches is expected to reduce; remaining time spent on IRS IEVS matches is expected to have more value by allowing County Caseworkers to focus time on matches with an eligibility impact or potential for benefit recovery. Interagency Agreements - An Interagency Agreement is entered into by the Ohio Department of Job and Family Services (ODJFS) and the Ohio Department of Administrative Services (DAS). A second Interagency Agreement is entered into by the Ohio Department of Medicaid (ODM) and the Ohio Department of Administrative Services (DAS). Each of these Agreements are entered into for the purpose of setting forth the roles and responsibilities, budget methodology and payment terms, data sharing restrictions, security protocols, and compliance requirements for the Ohio Benefits Program. DAS, ODM, and ODJFS have completed extensive policy, program, and legal reviews and the final Agreement is in circulation to secure DAS, ODM, and ODJFS Director?s signatures. Data Governance - A well-designed, mature, data governance program typically includes a governance team, a steering committee that acts as the governing body, and a group of data stewards. They work together to create the standards and policies for governing data, as well as implementation and enforcement procedures that are primarily carried out by the data stewards. The Ohio Benefits Program Data Governance Team meets monthly since September 2022. The team, led by ODJFS as one of the primary data owners, is working to complete its initial objectives which include: ? Address and Remediate Concerns about Reporting Cleanliness. o Develop an improved process for report intake, development, and delivery. ? Enhance Automatic Reporting and Monitoring. o Develop oversight reports to examine key areas of the business that are used to monitor for compliance. ? Evaluate EDMS? Audit Accessibility. o Understand the audit process and make recommendations on how to organize and display data to assist with future audits. ? Address Additional Priorities as determined by the data governance committee (in conjunction with the steering committee and other stakeholders). o The team will continue to establish key objectives to monitor and improve. DAS follows DAS Policy 2100-04 for Data Classification. The Ohio Benefits Program systems store data in a consistent manner, with shared data understanding for making program eligibility determinations based on quality data. As a collector and processor of the data, DAS acts as a DATA STEWARD for the agency DATA OWNERS. Per state data classification policy (2100-04, point 5.4), "? a data owner is responsible for establishing data use guidelines. An information owner shall not be a data or system administrator, but rather the head of a business or program area?? DAS customers are responsible for classifying their data and for informing DAS as to its levels of confidentiality and criticality." Since the DAS Ohio Benefits Program team has not been given data ownership and data classification information, the DAS Ohio Benefits Program team treats all data as "Confidential Personal Information". Some data may be further classified as Federal Tax Information (FTI) or Health Insurance Portability and Accountability Act (HIPAA) information, with the corresponding data access restrictions, monitoring and reporting requirements. As a Data Steward, the DAS Ohio Benefits Program team is responsible for carrying out data usage and security policies and meeting state and federal regulations for data contained on the Ohio Benefits Program systems and storage. Anticipated Completion Date for Corrective Action: ? Alerts ? April 2023 ? Interagency Agreements ? Completed ? Data Governance - Completed Contact Person Responsible for Corrective Action: Kristina Hagberg, Deputy State Chief Information Officer, Ohio Department of Administrative Services 30 East Broad Street, Columbus, Ohio 43215 Phone: 614-644-9245, E-mail Address: Kristina.Hagberg@das.ohio.gov

Allowable Costs ? COVID 19 Federal Emergency Management Agency Disaster Grants ? Public Assistance, Assistance Listing Number 97.036, Department of Homeland Security Condition A cost item was submitted twice within the applications of FEMA funds and funded by FEMA. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding. FEMA was notified about the cost item and provided the College with instruction related to the return of funds. In addition, all future applications will be reviewed by a second staff member to prevent submission of a duplicate item. Responsible Official: Kathleen McGuire, Vice President for Financial Services Expected Completion Date: December 1, 2022 Summary Schedule of Prior Audit Findings None noted.

FINDING 2022-005 Contact Person Responsible for Corrective Action: Danica Houze, Chief Financial Officer Contact Phone Number: 812-274-8001 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Starting in FY 2021 Time and Effort logs were kept by employees working with non-public students. Logs are submitted to the Director of Student Services and the payroll department, then accounts are distributed to match time actually spent with the non-public time spent per the time and effort logs. Anticipated Completion Date: 2/13/2023

Finding Number: 2022-003 Finding. The district purchased and requested reimbursement totaling $7,415 for devices purchased for the sole purpose of anticipated loss or breakage which did not meet the definition of eligible equipment. Corrective Action Plan: The district will seek guidance from the Federal Communications Commission on how the remaining devices should be used and implement proper controls over the program. Anticipated Completion Date: June 30, 2023

Finding Number: 2022-002 Finding. Unallowable costs totaling $2,800 for seven devices that were provided to school board members, who do not provide educational services to students. Response Corrective Action Plan: The district will seek guidance from the Federal Communications Commission on how the devices should be used and will implement proper controls over the program. Anticipated Completion Date: June 30, 2023

FINDING 2022-001 Contact Person Responsible for Corrective Action: Tammy Breedlove, Food Service Director Contact Phone Number: 765-569-4308 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The following internal control process has been added to the Business Office Handbook Effective February 1, 2023. The Food Service Director will follow all guidelines as contained in the Child Nutrition Procurement Plan and retain all documentation in compliance with Child Nutrition regulations and State Law. Furthermore, the Food Service Director will ensure that the following procedures are in place: 1. Each School year, the Food Service Director will prepare 5 binders- 1 for each Cafeteria, 1 for the Food Service Director, and 1 for the Business Manager. These binders will contain all approved bids and price changes/vendor correspondence. It is the responsibility of the Food Service Director & Cafeteria Site Managers to update these binders as price changes occur. Audit Evidence will be the contents in each binder for each school year. 2. When invoices for goods are received, the Food Service Director is responsible for ensuring that the invoices are reviewed and crosschecked to the original order/ approved pricing by the Cafeteria Site Manager. Furthermore, the Food Service Director will also review the invoices/pricing and sign off on the claim voucher sheet as approval for the Business Manager to pay the invoice. Audit Evidence: The Cafeteria Site Manager?s signature on the invoices & the Food Service Director?s signature on the claim voucher sheet. Anticipated Completion Date: Effective February 1, 2023

Finding Ref. No. 2022-003 Finding: The Uniform Guidance, 2 CFR Part 200 provides for state public agencies to submit a cost allocation plan to cognizant agent for review, negotiation, and approval. Charges to federal awards should be in accordance with the approved public assistance cost allocation plan. The Department of Human Resource's Public Assistance Cost Allocation Plan provides a summary of the allocation methodologies utilized by the Department to allocate allowable administrative costs to benefiting state and federal programs. Based on allocation methodologies, the Department prepares quarterly allocation schedules to set up cost allocation step percentages and codes for the allocation process. The Department did not provide allocation schedules for the second, third, and fourth quarters; therefore, we could not verify that costs were allocated in accordance with the approved Cost Allocation Plan. This is a significant deficiency in internal controls. Recommendation: The Department should establish and maintain effective internal controls to provide reasonable assurance that allocations to federal award programs are in accordance with the approved Public Assistance Cost Allocation Plan. Response/Views: We agree with the finding that the document was not available to the Examiners of Public Accounts. OHR provides statistics to the Comptroller's Office each quarter which are loaded into the Cost Allocation system. The resulting allocation schedules should have been retained but were not. Corrective Action Planned: The Cost Allocation Manager has written the step into the instructions to save the allocation schedule each quarter when provided to OHR by the Comptroller's Office. Anticipated Completion Date: August 8, 2023. Contact Person(s): Nancy L. Schlich

Corrective action plan: Management is implementing a job/cost time and labor system as part of the current Paylocity system currently in place. This new time tracking system will allow individuals working directly on contracts to record time spent on grants on their individual weekly timecards. This system will allow management to report time spent by person by contract within our current payroll and financial system. This enhancement will not be in place until January 2023. In the meantime, management has formalized a quarterly manual review process to document actual time spent per employee per contract along with any needed adjustments to allocation percentages. Personnel responsible for corrective action: Stephanie Cawby, Senior Accountant and Alex Laprade-Velasco, Financial Analyst Estimated corrective action completion date: December 2022 ? Manual quarterly review of contract time spent and adjustments. January 2023 ? Implementation of Paylocity Job Cost Time tracking and roll out to employees

Contact Person - Jeremy Tammi, Superintendent. Corrective Action Plan - The District will obtain approvals prior to incurring expenditures. The District will also report all expenditures to the correct finance and object codes at the time the expenditure is incurred. Completion Date - December 31, 2022.

See Corrective Action Plan for chart/table

Finding 2022-001 Federal Agency Name: Department of Homeland Security, State of Idaho Office of Emergency Management Program Name: Disaster Grants ? Public Assistance CFDA # 97.036 Finding Summary: Administrative labor costs were claimed for reimbursement that fell outside the period of performance of the federal award in two instances. In addition, one instance in which the Cooperative submitted a material cost for reimbursement that was not used in the project. Responsible Individuals: Reed Christensen Corrective Action Plan: Management revised its procedures to ensure a review of labor hours submitted in the future for FEMA-reimbursed projects in order to ensure the labor hours submitted fall more precisely within the Federally specified timeframe of the disaster declaration. As it concerns material cost reimbursements, in the future the work order will be reviewed and reconciled to the ?pick list? quantities. This has also been added to our FEMA-related work procedure. Anticipated Completion Date: March 30, 2023

FINDING 2022-004 (Auditor Assigned Reference Number) Contact Person Responsible for Corrective Action: Todd VanDerWeele Contact Phone Number: 574.223.2159 Views of Responsible Official: We concur with the finding. We have adjusted our retention practices to keep all employee records according to statute. After employees listed on the personnel report for hiring or reclassification are approved, the HR Director will provide the approved personnel report, salary schedule or CBA salary schedule, employee contract, and screen shot of the entries into the school?s financial software to the Business Manager to review and approve. Anticipated Completion Date: March 31, 2023

FINDING 2022-003 (Auditor Assigned Reference Number) Contact Person Responsible for Corrective Action: Todd VanDerWeele Contact Phone Number: 574.223.2159 Views of Responsible Official: We concur with the finding. We have adjusted our retention practices to keep all employee records according to statute. After employees listed on the personnel report for hiring or reclassification are approved, the HR Director will provide the approved personnel report, salary schedule or CBA salary schedule, and screen shot of the entries into the school?s financial software to the Business Manager to review and approve. Anticipated Completion Date: March 31, 2023

Corrective Action Plan Contact Name: Maggie Menefee Corrective Action: ALIVE is seeking an individual with appropriate nonprofit and federal award experience to provide additional oversight Expected Completion Date: December 31, 2022.

State Agency: Department of Health Single Audit Contact: Melissa Fiore Title: Audit Services Director Telephone: 518-473-0525 E-mail Address: Melissa.Fiore@health.ny.gov Federal Program(s) (ALN # [s]): Medicaid Assistance (93.775, 93.777, 93.778) Audit Report Reference: 2022-016 Anticipated Completion Date: 12/1/2022 Corrective Action Planned: The Corrective Action was implemented. The Department will continue to follow its revised policies and procedures including internal controls to ensure any service organization with access to NCCI data maintain a confidentiality agreement to be compliant with CMS NCCI Technical Guidance manual, sections 7.1.1 and 7.1.2.