Corrective Action Plans

Finding ref number: 2022-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with allowable activities and costs, equipment, and restricted purpose requirements. Name, address, and telephone of District contact person: Joe Vetter, 2320 Borst Avenue Centralia Washington 98531 ? (360)-330-7600 Corrective action the auditee plans to take in response to the finding: Response to the Finding The District does not concur with the audit finding or the questioned costs. When the District applied for the ECF funding in 2020, we were in compliance with the requirements that were set forth by the FCC. It is only when the requirements were altered in 2021 and written in a more unclear manner that the District potentially did not comply with FCC guidelines. The District does agree that there is always room for improvement with internal controls and processes, however this was during the pandemic and we believe the appropriate level of reporting would be a management letter because all costs were allowable and devices were only provided to those with unmet need. The audit?s condition states that our internal controls were ineffective for ensuring we requested reimbursement only for students and staff with a documented unmet need and that some inventory elements for 10% of the equipment purchased with ECF funds were missing. Based on the guidance below, we have spent all funds for allowable costs, that those costs were reasonable and necessary and for students with unmet needs. Districts were able to determine whether students had unmet needs, and for our district this meant addressing instances where students may share a home device with others, the device was too old or slow to function properly, student owned devices did not have the appropriate security in place to protect students during remote learning, and operationally the district could not access personally owned devices to provide the thousands of Prioritizing Students ? Upholding High Expectations ? Championing Hope ? Cultivating Collaboration technical, problem solve technical questions, keep students safe and issues students faced during remote learning. Based on these experiences, unmet need was defined broadly, but within allowed parameters and inventory records were kept. Devices for remote learning could also be used at school. During the pandemic in Washington State we experienced times when classrooms, schools and or districts were closed by health department and state regulations because of outbreaks. Districts had to be prepared to support remote learning each day with constantly changing guidance on who was allowed to be in person. The following guidance from the Federal Communications Commission, titled ?Emergency Connectivity Fund Common Misconceptions?, ?Misconception #2: If schools have returned to inclass instruction for the upcoming school year, they are not eligible to participate. Answer: This is false. Equipment and services provided to students or school staff who would otherwise lack sufficient access to connected devices, and/or broadband internet access connection while off campus are eligible for Emergency Connectivity Fund Support.? From the Federal Communications Commission Order FCC-CIRC21-93-043021, question 77: ?We think schools are in the best position to determine whether their students and staff have devices and broadband services sufficient to meet their remote learning needs, and we recognize that they are making such decisions in the midst of a pandemic. We, therefore, will not impose any specific metrics or process requirements on those determinations.? And from question 53: ??we are sensitive to the need to provide some flexibility during this uncertain time. If those connected devices were purchased for the purpose of providing students?with devices for off-campus use consistent with the rules we adopt today, we will not prohibit such on-campus use.? SAO did not apply any reasonable measure to reduce questioned costs but did state they know some of the costs are reasonable, while still choosing to question all costs. A unmet needs survey was shown to the auditor?s, originally applied to reduce questioned cost, and then it was considered unsatisfactory. Receiving a 100% response rate for any survey to reduce questioned costs is not reasonable to expect in any setting, let alone among a student population of 3,200 students during a pandemic. That is clearly out of alignment with the FCC guidance. Corrective action the auditee plans to take in response to the findings: The District does not concur with the finding or questioned costs. SAO reviewed various types of documentation and chose not to accept any documentation presented by the District to even consider reducing questioned costs. The standard of documentation required by SAO to satisfy ?unmet? need in would have been hard to meet even if the District hadn?t been in the midst of a pandemic. The District has internal controls over asset inventory and software that was provided to the auditors to see the current inventory and the District only provided equipment only to students and staff with unmet needs, and all costs were allowable, reasonable and necessary. We look forward to working with the FCC to resolve this finding and we appreciate the guidance that was provided by the FCC, as noted below. Guidance from the FCC Devices for remote learning could also be used at school. During the pandemic in Washington State we experienced times when classrooms, schools and or districts were closed by health department and state regulations because of outbreaks. Districts had to be prepared to support remote learning each day with constantly changing guidance on who was allowed to be in person. The following guidance from the Federal Communications Commission, titled ?Emergency Connectivity Fund Common Misconceptions?, ?Misconception #2: If schools have returned to inclass instruction for the upcoming school year, they are not eligible to participate. Answer: This is false. Equipment and services provided to students or school staff who would otherwise lack sufficient access to connected devices, and/or broadband internet access connection while off campus are eligible for Emergency Connectivity Fund Support.? From the Federal Communications Commission Order FCC-CIRC21-93-043021, question 77: ?We think schools are in the best position to determine whether their students and staff have devices and broadband services sufficient to meet their remote learning needs, and we recognize that they are making such decisions in the midst of a pandemic. We, therefore, will not impose any specific metrics or process requirements on those determinations.? And from question 53: ??we are sensitive to the need to provide some flexibility during this uncertain time. If those connected devices were purchased for the purpose of providing students?with devices for off-campus use consistent with the rules we adopt today, we will not prohibit such on-campus use.? Anticipated date to complete the corrective action: 5/24/2023

The District will develop and implement documented procedures for recording and communicating information regarding grants. Oversight and any necessary training will be made available on an as-needed basis, in an effort to eliminate audit adjustments and ensure compliance with grant requirements. In addition, the District will develop procedures to ensure that grant draw requests are prepared, reviewed, and submitted on a timely basis in accordance with the grant agreements.

On a monthly basis, the grant department will review the payroll register to verify the payroll is being charged correctly to the federal awards. The grant department staff will notify the Director of Grants and Federal Programs of any employees that are incorrectly charged to a grant. When an error is discovered, an adjusting journal entry will be prepared soon thereafter and reviewed by the Director of Grants and Federal Programs.

This letter is in reference to the City of Rochester, New Hampshire's major federal programs monitoring procedure as part of City's single audit for the year ended on June 30, 2022. Included please find the Corrective Action Plan for the finding related to Time and Effort Documentation. CORRECTIVE ACTION PLAN Audit Finding Reference: 2022-001 Improve Time and Effort Documentation Federal Agency: U.S. Department of Education Program: Title I Grants to Local Educational Agencies AL Number: 84.010 Award Year: 2020, 2021, and 2022 Compliance Requirement: Allowable Costs/Costs Principles Planned Corrective Action: The Rochester School Department developed a procedure to ensure that semi-annual certifications are completed by employees funded under federal funding sources, including Title I, no later than July 30th for the period from January 1 - June 30, and no later than January 30th for the period from July 1 - December 31 annually after the finding 2021-001. This procedure is currently being implemented and has been disseminated to all grant managers and the Federal Grants Manager. The forms are already being utilized and completed by the appropriate employees. Attached please find our semi-annual certification template. This repeat finding is due to the prior year single audit report not being issued until September 2022, which is in the fiscal year 2023, so this change was not able to impact the year ending in June 2022, since that year was already over.

2022-002: Internal Control over Compliance and Compliance with Activities Allowed or Unallowed and Allowable Costs/Cost Principles Contact: Karina F. Alvarez Title: Senior Director of Total Rewards Anticipated Completion Date: September 2023 Corrective Action: The Center?s is committed to ensuring the appropriate documentation is in place in order to adhere to federal regulations regarding activities allowed or unallowed and allowable costs. In response to the audit finding, the Center is taking the following corrective actions to address the audit recommendations: ? Management will review and update policies as needed to ensure employee compensation changes are documented sufficiently and verified through a quality control review; ? Implement additional functionality and security to minimize the potential for data entry error; and ? Design, develop, and implement a new Human Resource Information System (HRIS) that will provide a digital and modern platform to manage review and approval workflows surrounding compensation adjustments. Status as of February 2023: Management has informed the impacted employee and has updated their compensation documentation accordingly.

FA 2022-002 Improve Controls over Indirect Costs Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principle Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: COVID-19 - 84.425D - Elementary and Secondary School Emergency Relief Fund COVID-19 - 84.425U - American Rescue Plan Elementary and Secondary School Emergency Relief Fund Federal Award Number: S425D210012 (Year: 2021), S425U2120012 (Year: 2021) Questioner Costs: $559,442.53 Description: The School District charged indirect cost expenditures to the Elementary and Secondary School Emergency Relief Fund program in excess to the maximum amount allowed. Corrective Action Plans: We concur with this finding. The District is developing corrective actions to strengthen internal controls, policies, and procedures and ensure adherence through improved monitoring. Estimated Completion Date: Fiscal Year 2024 Contact Person: Dr. Myisha Warren, Executive Director of Federal Programs Telephone: 678-676-1200 Email: Myisha_Warren@dekalbschoolsga.org

FA 2022-001 Improve Budgetary Controls over Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principle Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: COVID-19 - 84.425D - Elementary and Secondary School Emergency Relief Fund Federal Award Number: S425D200012 (Year: 2020), S425D210012 (Year: 2021) Questioner Costs: $62,747.69 Description: A review of expenditures charged to the Elementary and Secondary School Emergency Relief Fund program revealed instances in which expenditures had not been properly approved by the pass-through entity. Corrective Action Plans: We concur with this finding. The District is developing correction actions to strengthen internal controls, policies, and procedures and ensure adherence through improved monitoring. Estimated Completion Date: Fiscal Year 2024 Contact Person: Dr. Myisha Warren, Executive Director of Federal Programs Telephone: 678-676-1200 Email: Myisha_Warren@dekalbschoolsga.org

The allocation of costs between our two federal programs and other programs are made by the Program Director or after discussion between the Program Director and the Federal Grant Manager; then communicated to the accountant. In addition, our accountant has the program knowledge and ability to question cost allocations. Beginning mid-September, 2023, the basis for allocations will be documented on an invoice or other supporting documents. Effective June 2023, weekly payroll time records allocating hours to projects and programs are prepared by each employee. Those time records are approved by the Program Director or the Treasurer, as appropriate. The allocations are then reviewed by the Federal Grant Manager and entered bi-weekly into the accounting records.

Finding ref number:2022-001 Finding caption:bThe District did not have adequate internal controls for ensuring compliance with allowable activities and costs, procurement, and restricted purpose requirements. Name, address, and telephone of District contact person: Keith Ounsted, Business Manager 325 West Chenault Avenue, Hoquiam, WA 98550, (360) 538-8209 Corrective action the auditee plans to take in response to the finding: The District currently has policies in place regarding procurement. In this instance the policies weren?t followed. The district will review all policies around procurement to ensure they are up to date. The District will engage in a retraining of employees that are allowed to make purchases so that all personnel understand what is required. Anticipated date to complete the corrective action: 7/31/2023

Views of Responsible Officials of the Auditee: Management agrees with this finding and will take corrective action. Corrective Action Plan: The Institute will design and implement internal controls to ensure employees paid with Federal funds are paid in accordance with approved budgets. Anticipated Completion Date: September 30, 2023 Contact Person(s): Jonathan Sherbert, CFO

Reference number ? 2021-003 Contact person ? Celia Solomita, CFO Management agrees that protocols will be implemented to ensure that all invoices are formally approved prior to payment. This will be in place prior to December 31, 2023.

Reference number ? 2022-001 Contact person ? Celia Solomita, CFO Management agrees that protocols will be implemented to ensure that all invoices are formally approved prior to payment. This will be in place prior to December 31, 2023.

The City has implemented steps to be more proactive in subrecipient monitoring and will perform additional testing to meets these requirements.

The City used the initial guidance when filing required reports. The grant coordinator will receive additional training to better understand the Uniform Guidance for federal funding and receive continuing education on the Final Rules issued by the Department of Treasury.

2022-003 Significant Deficiency in Compliance and Internal Control over Compliance ? Allowable Costs/Cost Principles Name and Contact Person: Janelle Friday, Tribal Administrator Corrective Action: Klawock Cooperative Association will ensure that they implement policies and procedures to address internal control over payroll and redesign the timesheet. Proposed Completion Date: June 30, 2023

Corrective Action Planned: The annual on-site reviews required as part of the National School Lunch Program were not completed during the 2021-2022 fiscal year due to an oversight by the previous Director of Business Services. There were no questioned costs or unallowable expenditures. District staff have added this procedure to their work calendar to ensure the reviews will be completed in a timely manner in the future. Additionally, District staff will review all administrative policies issued by the State of Michigan related to the food service program. Anticipated Completion Date: February 1, 2023 ? The fiscal year 2022-2023 on-site reviews are required to be completed prior to February 1, 2023. District staff will complete the reviews prior to the due date.

Corrective Action Plan: FINDING NO. 2022-001 - Inadequate Controls over Grant Related Payroll Disbursements Condition: During control testing over payroll expenditures related to the Elementary and Secondary Emergency Relief (ESSER) III grant, it was noted that one of the employees charged to the grant was supposed to be paid by Kane County, on behalf of the Regional Office of Education, beginning with pay periods subsequent to November 30. Instead, a total of five pay periods continued to be charged to ESSER III after November 30 instead of the County. Each of these pay periods were requested for reimbursement with ESSER III funding. Regional Office of Education management did start properly recording the employee as a County expenditure beginning with the first payroll run in March 2022. Plan: When posting payroll in the Regional Office accounting system, net pay amounts for Kane County payroll and Regional Office payroll will be verified and any discrepancies will be discovered and corrected at that time. In addition, grant expenditure reports will be reviewed by the grant writer and finance director on a quarterly basis to ensure payroll costs posted to the grant are accurate. Anticipated Date of Completion: September 2022 Contact Person: Julie Hadjiev

Higher Education Emergency Relief Funding (HEERF) ? Assistance Listing No. 84.425 Recommendation: We recommend the colleges reevaluate their procedures surrounding allowable costs and costs being charged to the grant to ensure all are allowable costs. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Clarkson College has reevaluated their procedures surrounding allowable costs and costs being charged to the grant to ensure all are allowable costs. The employee responsible for this finding is no longer associated with the college.

DEPARTMENT OF EDUCATION 2021-003 Supporting Effective Education Development ? CFDA No. 84.423a Recommendation: We recommend the Center design controls to put in place an adequate review process to ensure all required documentation is obtained/retained from subrecipients prior to entering into a contract. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We are now using a Subrecipient Commitment Form to be completed by existing and future sub recipients. Name(s) of the contact person(s) responsible for corrective action: Mike English Planned completion date for corrective action plan: December 1, 2022

FINDING 2022-002 ? ELEMENTARY AND SECONDARY SCHOOL EMERGENCY RELIEF FUND ACTIVITIES ALLOWED OR UNALLOWED AND ALLOWABLE COSTS/COST PRINCIPLES Contact Person Responsible for Corrective Action: Lisa Baker, Business Manager Contact Person's Phone Number: 765-664-0624 Views of Responsible Official: There is no disagreement with the audit finding. Description of Correction Action Plan: The following phrase will be added to payroll time cards and bus trip sheets when ESSER funds will be used to pay wages and payroll-related expenses: "I hereby certify that this is a true and accurate representation of all hours worked on behalf of ESSER-funded Summer Academy (or ESSER-funded After-School Tutoring) and that duties performed were only for Summer Academy (or After-School Tutoring)." Contract addendums will include the phrase "ESSER-funded Summer Academy" as well. Anticipated Completion Date: March 24, 2023

For 2022, quarterly reviews were being performed; however, due to the transition in personnel in the Accounting and Finance areas, the annual review was not done. The College has updated its procedures to include a review of the annual submission similar to the current practice of reviewing the quarterly submission.

Corrective Action Plan McAlister Institute for Treatment & Education, Inc. Ling & Bouman, LLP Corrective Action Plan prepared by Steve Hubbard, Chief Financial Officer, (619) 442-0277 2022-01 ? Payroll Recommendation We recommend Management require additional training to Human Resources staff and supervisors regarding meal, rest and recovery period compliance and update their policies and procedures to ensure compliant breaks. In the event of a meal break premium that occurs as the direct result of patient care, appropriate documentation should be maintained by the organization. Meal Break premiums should be automatically coded as a non-reimbursable expense and any exceptions should be manually transferred to program expenses once appropriate supporting documentation is obtained. Actions Taken or Planned on the Finding We concur with the recommendation, and it was implemented effective March 23, 2022.

Condition: The Health Center?s Period 2 report to HHS included duplicate amounts for utilities expenses. Planned Corrective Action: Management will continue to refine processes to more diligently review expenses to ensure no duplicate expenses are included in the underlying supporting documentation. However, the Health Center included as eligible expenses in the Period 2 submission only those amounts up to the funding received, plus accrued interest. Had the noted questioned costs been identified prior to submission, the Health Center would have included additional amounts in the eligible expenses reported in the PRF reporting portal to demonstrate satisfactory use of the PRF funding received. The Health Center had $418,778 in additional eligible operating expenses which were not included in the Period 1 submission and $1,916,769 in additional eligible capital expenses not included in the Period 2 submission which would have been used to replace the identified questioned costs. Person Responsible: Wade Eschenbrenner, CFO Anticipated Completion Date: Ongoing

FINDINGS?FEDERAL AWARD PROGRAMS AUDITS U.S. Department of Housing and Urban Development 2022-004 Community Development Block Grant ? Assistance Listing number: 14.218 Recommendation: We recommend the City establish cutoff procedures for the accrual of grant related reimbursements to ensure expenditures are invoiced within the appropriate contract dates as specified by the agreements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will ensure that grant expenditures processed after the end of the fiscal year are thoroughly reviewed to ensure they are recorded in the correct fiscal year. Name(s) of the contact person(s) responsible for corrective action: Mark C. Mason, CPA, Financial Services Director; Juan G. Guerra, ICMA-CM, CPA, Controller Planned completion date for corrective action plan: December 31, 2023

FINDINGS?FEDERAL AWARD PROGRAMS AUDITS U.S. Department of Housing and Urban Development 2022-003 Community Development Block Grant ? Assistance Listing Number: 14.218 Recommendation: We recommend that the City design processes and procedures to ensure that all reports are submitted timely as required by grant agreements. We recommend the City develop an internal compliance checklist that includes required reports and due dates to be maintained for tracking and record keeping purposes to assist in monitoring compliance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: City could not log into the federal system, we have since fixed this problem. Finance will keep a calendar of all reporting requirements and check in prior to the due date to ensure reports are submitted on time. Name(s) of the contact person(s) responsible for corrective action: Mark C. Mason, CPA, Financial Services Director; Juan G. Guerra, ICMA-CM, CPA, Controller Planned completion date for corrective action plan: April 30, 2023