Corrective Action Plans

Reporting views of responsible officials and planned corrective actions Management will put in place controls and procedures to annually evaluate the percentage of time staff dedicate to the organization to determine the correct allocation for payroll.

Reporting views of responsible officials and planned corrective actions Management will ensure that moving forward there are controls in place to ensure expenses are captured in the correct fiscal period and that at year end there is a final review of the transactions to ensure that everything is not only properly entered, but properly classified as well.

Finding No. 2022-002 Program: U.S. DEPARTMENT OF EDUCATION Passed through the Commonwealth of Massachusetts?Department of Elementary and Secondary Education Material Weakness 2022-002: Special Education Cluster ? SPED Grants to States, IDEA, Part B (Assistance Listing #84.027) Pass-through program number: 0240-577419-2022-0645; Fiscal year ending June 30, 2022 Auditor?s Recommendation: The District should review currently established policies and procedures for maintenance of time and effort certifications as established within adopted grants manual. Personnel should review established policies and procedures on a routine basis to ensure the District?s compliance with all aspects of the District?s established policies and procedures as well as individual requirements pursuant to OMB. Established policies and procedures should be reviewed on an annual basis to ensure continued compliance with ever changing federal compliance and other financial reporting requirements. Action Taken: As indicated by the auditor, the budgeting for the 240 SPED allocation grant in fiscal year 2023 has been changed to exclude personnel costs (salaries & wages) subject to the ?time & effort? certifications. Therefore, ?time & effort? requirements will no longer be associated with this program. District personnel will continue to review established grants policies and procedures manual with current federal awards administration.

2022-003 Procurement Policy We will adopt a revised procurement policy that includes procedures to comply with the requirements outlined by Part 200.320 of the Uniform Guidance. We completed the adoption 0f the compliant policy in February 2023.

For future disasters, the City will discuss with all vendors exactly what documentation will be required before work begins.

This lapse was a result of delay in submission and approval of time charged by a consultant (operated outside of our automated time sheet controls). We will ensure the allocation is done after the actual time charge is made. We will monitor more closely and train the finance staff in our subsidiary for charging depreciation to the projects.

The District will ensure that all employees not on a formal allocation plan or entirely allocated to a single source complete daily activity reports.

Finding Summary: 36 out of 60 expenditures tested lacked timely approval of employees? actual time spent on the program. 5 out of 60 expenditures tested lacked employee signatures for certification of actual time spent on the program. 6 out of 60 expenditures tested were based on estimated fringe benefits. When compared to actual fringe benefits incurred, the amounts allocated to the program exceeded actual costs incurred Responsible Individuals: Program Directors, Director of Management Reporting Corrective Action Plan: Procedures will be established to ensure employee time charged to federal grants is documented, signed by employees, and reviewed and signed by program directors before each drawdown. Only actual fringe benefits will be charged to federal grants. Anticipated Completion Date: June 30, 2023

All employees paid by Cost Allocation will be charged to the programs based on time sheets, this was fully implemented June 15, 2022

March 2, 2023 Shenandoah Area Agency on Aging respectfully submits the following corrective action plan for the year ended September 30, 2022. Name and address of independent public accounting firm: Brown, Edwards & Company, L.L.P. 1909 Financial Drive Harrisonburg, Virginia 22801 Audit period: September 30, 2022 The findings from the September 30, 2022 Schedule of Findings and Questioned Costs (the "Schedule") are discussed below. The findings are numbered consistently with the number assigned in the Schedule. FINDINGS - FINANCIAL STATEMENT AUDIT 2022-004: Authorized Signer for Bank Accounts Condition: Four bank confirmations signed by the executive director were sent to financial institutions holding SAAA assets as part of our audit were denied due to being signed by an unauthorized individual. Criteria: As part of management's responsibility to safeguard assets, the authorized signer for bank accounts should be documented. Cause: Management was unaware the listing of authorized check signers had not been updated by the bank as requested. Effect: It is critical for an entity to be able to access its cash deposits held by financial institutions. When a listing of authorized signers is not updated, the entity opens itself to opportunities for loss. Terminated employees may still have access to organizational assets or the organization may be prohibited from accessing their accounts at financial institutions if there is no perceived authority to access the funds. FINDINGS-FINANCIAL STATEMENT AUDIT (Continued) 2022-004: Authorized Signer for Bank Accounts (Continued) Recommendation: Management or governance should determine who has access to bank accounts and ensure only the appropriate parties maintain ongoing access for the safekeeping of the organization's assets. Planned Corrective Action: This finding was caused by the bank not updating its signature cards as requested by the Agency. This finding was immediately corrected once identified by the auditors. 2022-005: Material Audit Adjustments Condition: During the audit, we detected one material misstatement in the trial balance presented to us to begin our audit that was considered a material audit correction. Criteria: Generally accepted auditing standards dictates that detection of errors in an audit is a strong indicator of a significant deficiency or material weakness. Accordingly, we are required to communicate this finding as such. Cause: Financial information was missing or inaccurate. Effect: Assets and liabilities were overstated. Recommendation: We recommend that management implement a process to ensure accuracy of balance sheet and statement of activity accounts. Planned Corrective Action: Management agrees with the finding. During the last quarter of the fiscal year, the finance department experienced a vacancy. As a result, we were short-handed. There was one account that was not reconciled in a timely manner. After the year end, the position has since been filled. All significant balance sheets will be reconciled in a timely manner as in previous years. FINDINGS AND QUESTIONED COSTS- MAJOR FEDERAL AWARD PROGRAM AUDIT 2022-001: Cost Sharing Fees, ALN 93.045 Special Programs for the Aging - Title III, Part Cl - Nutrition services and Special Programs for the Aging-Title III, Part C2 - Nutrition services, Program income Condition: Individuals receiving Title III-C funded services for home delivered meals were charged cost sharing fees. Criteria: Agencies providing services funded under the Title III-C programs may not charge cost sharing fees for the Title 111-C services under Title III-C per 42 U.S. Code? 3030 c-2(a)(2). Cause: No controls or processes were in place to prevent cost sharing fees being charged to individuals receiving services provided under Title III-C programs. Effect: The cost sharing fees for Title III-C services are not allowed under federal guidelines and therefore these fees are considered a questioned cost. Questioned Cost Amount: $4,400 Perspective Information: Noted two fees were charged for Title 111-C services out of a sample of twenty-five cost sharing fees. Recommendation: Cost sharing fees are not allowed to be charged for Title III-C services provided to individuals. Only voluntary contributions may be made for these services. Management should implement procedures to ensure these fees do not continue to be charged. Planned Corrective Action: Management agrees with the finding. As noted in finding 2022-005, the vacant position, which has now been filled, was responsible for compliance review. Additional procedural reviews and corrected report formatting have been implemented to prohibit cost-sharing fees from being charged to the program. FINDINGS AND QUESTIONED COSTS - MAJOR FEDERAL AWARD PROGRAM AUDIT (Continued) 2022-002: Unallowable Costs, ALN 93.053 Nutrition Services Incentive Program, Allowable Costs Condition: Administrative expenditures were improperly classified as expenditures funded by the Nutrition Services Incentive Program (NSIP). Criteria: NSIP funds may only be used to purchase domestic foods as outlined under Title 7 U.S. Code of Federal Regulations Part 250.68, Nutrition Services Incentive Program. Grant funding received through NSIP may not be used to pay for administration or other services. Cause: Unallowable costs were improperly classified to the financial records supporting NSIP expenditures and allowable costs were improperly allocated to other projects. Effect: Financial records supporting costs expensed under the NSIP award do not reflect the nature of the expenditures requested for reimbursement. Expenditures were misclassified within the financial records to improper programs and thus are considered a questioned cost. Questioned Cost Amount: $98,327 Perspective Information: Noted in one out of a sample of twenty-five expenditures charged to the Aging Cluster. Two of the items in the sample were expenditures charged to NSIP. We reviewed the list of the remaining expenditures charged to NSIP and confirmed the sample was representative of the entire population. Recommendation: It is critical for the underlying financial records to support an organization's claims for costs reimbursements under federal award programs with adequate documentation. Staff must allocate costs appropriately for allowable costs under each federal program and ensure expenditures charged to the federal programs are for appropriate purposes and are properly classified in the records to avoid noncompliance with federal regulations and program requirements. Planned Corrective Action: Management partially agrees with the finding. We agree that certain amounts were misapplied to the NSIP account. However, the funds did purchase food as required by the grant. We believe this to be a reporting error and not a misuse of grant funds. With the vacant position recently filled, we have added additional review procedures to prevent any reoccurrence of misapplication. FINDINGS AND QUESTIONED COSTS- MAJOR FEDERAL AWARD PROGRAM AUDIT (Continued) 2022-003: Annual Reporting to VDARS, ALN 93.044 Special Programs for the Aging- Title III, Part B- Grants for Supporting Services and Senior Centers, ALN 93.045 Special Programs for the Aging - Title III, Part Cl - Nutrition Services, ALN 93.053 Nutrition Services Incentive Program, Reporting Condition: The 13th Aging Monthly Report required by the pass through agency, Virginia Department of Aging and Rehabilitative Services (VDARS) was not submitted timely and contained inaccurate revenue and expenditure data. Criteria: VDARS requires the annual I3th Month Aging Monthly Report to be submitted by November 15t?h The report must contain complete and accurate information as a restating of the monthly reporting for the fiscal year. Cause: The 131 Aging Monthly Report was not reconciled to underlying financial records, resulting in unexplained differences between the report and trial balance provided as part of the audit. Additionally, the report was not submitted by November 15, 2022. Effect: The submission of the 13th AMR was not performed timely and included data that did not agree to underlying financial records. This should have been caught during the course of a review process before submission. Therefore, it is considered a significant deficiency of internal controls over compliance. Recommendation: Ensure reporting is submitted timely by the deadline stated by VDARS. Implement a review process for each monthly submission, including documentation of the review. Reconcile the federal, state and local totals reported in the Aging Monthly Report to the underlying financial records as stated in the financial system to ensure accuracy before submission to VDARS. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. The AMR report was not filed in a timely manner. As noted in finding 2022-0005, the vacated position during the last quarter of the year was responsible for submittals. We note that the report has since been filed. With the position being filled, we believe the 13th AMR will be filed in a timely and accurate manner as in previous years. If the Federal Audit Clearinghouse has questions regarding this plan, please call Cindy Donaldson, Director of Finance at 540-635-7141. Sincerely yours,

FEDERAL AWARDS FINDINGS AND QUESTIONED COSTS 2022-001: Material weakness in compliance and internal control over compliance: Allowable Costs/Cost Principles: AL 09.610090 Legal Services Corporation Recommendation: We recommend that the Organization assess the current level of staff needed by the Finance Department to ensure grant activity is recorded properly and in compliance with the grant requirements. The allocation of indirect expenses should be reviewed on a regular basis to determine the appropriateness of the allocations throughout the year. As a result of the audit process, management has altered the manner in which indirect costs are allocated, and, if applied properly and consistently, this revised method should resolve the issues associated with indirect cost allocations for 2023. Action Taken: CCLA Management agrees that the timeliness of information is imperative to the preparation and completion of the year-end audit. The staffing levels are being evaluated including the analysis of the appropriate staff categories. Management of the Organization is working on developing a more effective methodology to track grants and the allocation of indirect costs. The new fiscal year budget will include the recruitment of an experienced Contracts & Grant Manager to provide the department with accurate reporting of grant funding. As indicated below, the project to restructure the financial and administrative operations of CCLA is well under way. CCLA?s plan is to complete the implementation of key components of the plan in 2023, in time to completely resolve the issues raised in the 2022 audit and complete the 2023 audit with no material weaknesses or questioned costs. Major Milestones Planned Completion Status Project Start 2/1/23 Done Interim Project Review #1 to CCLA Board 2/15/23 Done Begin Stakeholder Interviews 3/1/23 Done Complete Stakeholder Interviews 4/1/23 Done Interim Project Update #2 to CCLA Board 4/19/23 Done Update Mayuris Pimentel: LSC 4/25/23 Done Completion of Project Assessment Process 5/31/23 Complete First Draft of Plan 6/7/23 Project Presentation to CCLA Board 6/14/23 Written Final Report Delivered to CCLA 6/21/23 Final Report Forwarded to Legal Services Corp. 7/1/23

Finding ref number: 2022-001 Finding caption: The District did not have adequate internal controls in place to ensure accurate reporting of its Schedule of Expenditures of Federal Awards Name, address, and telephone of District contact person: Leslie Oliver, ESD Business Manager, PO Box 367, Keller WA 99140 (509) 725-1481 Corrective action the auditee plans to take in response to the finding: The District recognizes and acknowledges deficiencies and errors by the District and its financial management contractor in collecting and reporting data pursuant to its Impact Aid application to the Federal Department of Education. While it has not been possible to identify how these originated, they appear to have been in place for a number of years, perhaps more than a decade, related to Washington State?s broad school choice policies and, not identified in previous audits by either Federal or State agencies. Regardless, the District has satisfactorily resolved outstanding data collection and reporting issues with the Department and has put in place administrative controls via training and oversight to comply with requirements. In the past ten months since the deficiencies were identified, the District has taken the following steps to address those and to come into compliance. The District Superintendent, District Secretary and Chair of the School Board were tasked with communicating and negotiating with Department officials. In a series of Zoom meetings, trainings and phone calls, the District team was made aware of the deficiencies, provided with guidance of strategies to correct those and with guidance on addressing the effects of Washington State?s school choice policies on Impact Aid. As a result of that guidance, the District corrected its data collection and validation methodology, proposed and negotiated tuition agreements with three adjoining Districts, proposed and negotiated repayment agreements with those Districts and the Department. Future data collection and validation will be reviewed by the District?s financial management contractor, Education Service District 101. District administration and Board will send representatives to attend the annual conference of the National Association of Federally Impacted Schools in Washington, DC, and to meet with Department staff to review the application and its data. The District will take part in any relevant training opportunities offered by the Department or by the Office of the Superintendent of Public Instruction. Anticipated date to complete the corrective action: immediate action in 2023

2022-002 ? Student Financial Aid Cluster ? (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work Study Program (c) Federal Perkins Loan Program ? Federal Capital Contributions (d) Federal Pell Grant Program (e) Federal Direct Student Loans (f) Teacher Education Assistance for College and Higher Education (TEACH), Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.038 (d) 84.063 (e) 84.268 (f) 84.379 ? Year Ended June 30, 2022 Condition: The University did not properly return loan funds subsequent to the R2T4 calculation for no passing grades withdrawal students for 1 out of the 12 students tested (8.3%) due to failing to return the required PLUS loans based on the calculation. Further, the amount of direct student loan funds returned was later disbursed to the student again due to lack of documentation in the University?s system of the unofficial withdrawal. We consider this to be an instance of noncompliance in relation to Special Tests and Provisions. Statistical sampling was not used. Management Response: The error identified above was made on a student?s record who did not officially withdraw from the University. As required by federal regulation, an ?all F?s? report is pulled at the end of each term and a determination is made for all students included on the report whether or not they attended classes until the end of the term. The student identified by the auditors was determined to have not attended the full Fall term. A return of title IV calculation was promptly processed by the Associate Director on the Department of Education?s website. The R2T4 calculation could not be processed via the SIS since the student did not have an official withdrawal date entered. The student loans were returned timely, however, the parent PLUS loan was missed in returning the funds. Subsequently the student contacted our office to challenge the withdrawal date and claimed he had attended classes all term and earned all of the loan funds that were disbursed for the term. There was no documentation in our SIS so the loans were reinstated in error. Corrective Action Plan: R2T4 procedures were updated to include a secondary confirmation of the return of loan funds according to the calculation. This secondary review will be scheduled at the time the R2T4 calculation is processed. Further, the procedure was updated to include entry of notes on the student?s electronic record to avoid reversal if challenged by the student. Responsible Person: Chilwana Thompson, Associate Director Implementation Date: August 1, 2022

2022 ? 001 Federal Agency: U.S. Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: SLFRP2619 - 2022 Pass-Through Agency: Minnesota Department of Education Pass-Through Number(s): Unknown Award Period: July 1, 2021 through June 30, 2022 ? Type of Finding: Significant Deficiency in Internal Control over Compliance Recommendation: We recommend the District implement procedures and controls in relation to the required Coronavirus State and Local Fiscal Recovery Funds, to ensure they are completed accurately and timely going forward. Views of Responsible Officials: There is no disagreement with the audit finding. Action Taken in Response to Finding: The District will implement procedures and controls over federal funds to ensure all requirements have been met. Name of the Contact Person Responsible for Corrective Action Plan: Amanda Heilman, Director of Finance and Operations Planned Completion Date for Corrective Action Plan: June 30, 2023

2022-001 - U.S. Department of Health and Human Services - Nebraska Department of Labor ? Temporary Assistance for Needy Families ? 93.558 Criteria or Specific Requirement ? Management is responsible for implementing and effectively operating internal controls over compliance to mitigate the risk of misuse of the Organization?s federal funds and ensure participating students are eligible based on financial need. The Temporary Assistance for Needy Families (TANF) funds may be used for expenses related to Job?s for America?s Graduates (JAG) Program, which helps low-income students with additional resources in middle and/or high school to help the students graduate. To be eligible for the JAG Program, which is funded by the TANF funds, the students must be low-income, evidenced by qualification for free or reduced lunch. Planned Corrective Actions (Management's Response) - United Way of the Midlands (UWM) has reviewed and updated its policies, procedures and training within the JAG Program to improve retention of eligibility documentation and, in the event such documentation is no longer available, document the validation of eligibility requirements used to support Management?s decision on the applicant?s eligibility. This is fully documented in our Quality Assurance SOP (Standard Operating Procedures). UWM also implemented an additional detective internal control in our JAG Nebraska Invoicing SOP that requires a UWM Finance member independent of the eligibility onboarding process to audit monthly a small sampling of students for proper documentation and eligibility related to TANF invoicing. Management will monitor this regularly throughout the year to ensure procedures are being followed as documented. All changes have been implemented. Anticipated Completion Date - October 15th, 2022

Finding Reference 2022-009 Contact Person: Gerald Moench, Interim CFO (or Emily Buckley, VP of Advancement) Views of Responsible Officials and Planned Corrective Action: In including the questioned indirect cost as a HEERF expense, management only considered the per unit cost threshold, rather than both the per unit cost and the expected life of the items. The audit clarified the regulations and Donnelly promptly notified our program officer, posted a corrected quarterly report and refunded the funds to the Department of Education. Anticipated Completion Date: October 2022

Finding Reference 2022-008 Contact Person: Emily Matis Views of Responsible Officials and Planned Corrective Action: Adjustments have been made to drawdowns in April and June of 2022 in order to correct for these overdraws. However, even after these corrections, $694.47 was still overdrawn from FY22. This amount will be corrected in a future Title V draw for this amount. Salary drawdowns will be required to have backup payroll documentation for each draw in the future. Anticipated Completion Date: January 2023

2022-008: ALN 93.568 LIHEAP/COVID-19 LIHEAP - Activities Allowed or Unallowed, Passthrough from Massachusetts Department of Housing and Community Development Condition: Receipts of LIHEAP grant funds exceeded LIHEAP grant expenses during the fiscal year, and LIHEAP restricted cash was deficient by $1,849,775 when comparing the June 30, 2022 LIHEAP restricted cash balance of $1,965,909 to the LIHEAP deferred revenue of $3,815,684, indicating unallowable use of LIHEAP program funds. The Activities Allowed or Unallowed compliance requirement is identified as not being subject to audit in the Compliance Supplement and auditors are not expected to test requirements. However, we became aware of the material cash deficiency and determined non-compliance with the general requirements of the Activities Allowed or Unallowed compliance requirement clearly exists. Cause: LIHEAP program funds, including those identified in Finding 2022-007, were not immediately transferred to and held in the LIHEAP program checking account. Because the funds were not transferred they were utilized for non-LIHEAP programs resulting in unallowable activities related to the LIHEAP funds. Criteria: LIHEAP grant funds should only be utilized for allowable LIHEAP program activities. Effect of Potential Effect: Management did not comply with allowable activities compliance requirements for the LIHEAP program and has a LIHEAP cash deficiency of $1,849,775 at June 30, 2022. Recommendation: We recommend that management follow the compliance requirements for the LIHEAP program and only utilize LIHEAP program cash for allowable program activities. Additionally, we recommend that management correct the cash deficiency. Views of Responsible Officials: Management agrees with the finding, see Corrective Action Plan. Corrective Action Planned: June 27, 2023. NEFWC entered into a repayment agreement with the Commonwealth of MA on June 27, 2023. Anticipated Completion Date: September 30, 2023.

FINDING 2022-003 The City will transfer all ineligible administrative and indirect cost from the 97.024 ? Emergency Food and Shelter program no later than September 1, 2023. In addition, when administrative costs are allowed on a grant, delegate agencies will be required to maintain and provide adequate supporting documentation justifying the direct administrative cost charged to the program, which must be submitted through the City?s invoicing system. Assistant Budget Director Belczak at the Office of Budget and Management will be responsible for ensuring that this corrective action plan is implemented by the beginning of the fourth quarter in October 2023.

FINDING 2022-002 As a result of the 2022 Single Audit, the Department of Housing (DOH) received an audit finding with respect to potential unallowable rental assistance payments made because of an internal control failure in the case management workflow that did not adequately segregate reviewer and approver duties. As a corrective action, DOH terminated its contractual agreement with its program administrator effective May 12, 2023. To disburse the remaining emergency rental assistance dollars, DOH has entered into a contractual agreement with the Illinois Housing Development Authority to be its new program administrator effective June 30, 2023. DOH is actively investigating questionable cases to quantify the total population and dollar amount of ineligible payments made. In addition, DOH is reviewing its case management workflow procedures to ensure clear segregation of duties in any future rental assistance program. Daniel Kay Hertz, DOH Director of Policy, will be responsible for ensuring that this corrective action plan is fully implemented by January 1, 2024.

2022-001 Crime Victim Services - Assistance Listing No. 16.575 Recommendation: The Organization should implement internal controls to ensure that time and effort is reviewed on a timely basis. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Women's Advocates has systematized time and effort within the payroll system whereby employees and their supervisors approval timecards with the appropriate grant coding. Name(s) of the contact person(s) responsible for corrective action: Yulanda Williams Planned completion date for corrective action plan: 1/23/2023

Finding No. 2022-004 Criteria: The terms and conditions of the CARES Act Provider Relief Fund (PRF) distributions state that funds are to only be used to prevent, prepare for, and respond to coronavirus, and that funds may only be used for healthcare related expenses or lost revenue that is attributable to the coronavirus. The Health Resources and Services Administration (HRSA) provided guidance on how an organization was to report usage of PRF distributions received. Period 1 and Period 2 reporting required an organization to illustrate how PRF funds received were used. An organization was allowed to include eligible expenditures from January 1, 2020 through December 31, 2021 depending on the period reporting. Condition: During the process of identifying expenses that were incurred to prevent, prepare for, or respond to the coronavirus pandemic, management included expenses incurred in January 2020 and February 2020 which were not supported by management in relation to prepare, prevent, or respond to coronavirus as these were incurred prior to when the Hospital began to prepare for coronavirus. Planned Corrective Action: Management will continue to refine processes to review reporting requirements and the accumulation of eligible expenditures per the terms and conditions of the PRF and reporting guidance provided by HRSA. However, the Hospital also incurred and reported sufficient unreimbursed expenditures attributable to coronavirus in the PRF reporting portal that if the noted item were not to be reported, the Hospital would have satisfactorily incurred eligible expenses in excess of PRF funds received, including interest earned on such funds. Planned Completion Date: Ongoing Person Responsible: Crystal Wyatt, CFO

Planned Corrective Action: Management has initiated a review of the payroll process and procedures and will make necessary adjustments to include verification and review of payroll servicer calculations. Anticipated completion date: January 2023. Responsible contact person: Angela Gleason, Director of Finance.

Management agrees with this finding. Management believes that the cost of additional staff time and training to prepare these items outweighs the benefits to be received. Management will continue to review the schedules of expenditures of federal and state awards and other information.

2022-004 U.S. Department of Treasury Passed through State of Minnesota Child Nutrition Cluster 10.555/10.559 Activities Allowed or Unallowed and Allowable Costs/Cost Principles Deficiency in Internal Control over Compliance CORRECTIVE ACTION PLAN (CAP): Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Actions Planned in Response to Finding: The Business Manager continues training dealing with governmental financial/accounting practices. Official Responsible for Ensuring CAP: Bill Strom, Superintendent, is the official responsible for ensuring corrective action. Planned Completion Date for CAP: June 30, 2023. Plan to Monitor Completion of CAP: The Board of Education will be monitoring this corrective action plan.