Corrective Action Plans

Regional School Unit 1 34 Wing Farm Parkway Bath, ME 04530 Telephone: (207) 443-6601 Facsimile: (207) 443-8295 Patrick M. Manuel, Superintendent of Schools pmanuel@rsu1.org ?Think ~ Care ~ Act? CORRECTIVE ACTION PLAN (Concerning Finding 2022-002) Contact Person Responsible for Corrective Action: Debra Clark, Business Manager Corrective Action: Regional School Unit 1 offers the following response to finding 2022-002 Regional School Unit 1 acknowledges that a discussion took place regarding this finding with two of the representatives from RHR Smith. Federal procurement procedure policies were discussed and the RSU agrees that the current policies in place could be strengthened in the future with regards to federal funds. RSU 1 requested that specific examples of the language be shared by the auditing firm to ensure stronger controls moving forward. There is a procurement policy in RSU 1 and it was shared with the auditing firm. RSU 1 disagrees with the statements in this deficiency that purchase orders and invoices were missing or incomplete and the unit is not following a consistent approval process over allowable expenses. All invoices and purchase orders that were requested were provided. The RSU 1 does not require a purchase order for services and in those situations a purchase order was not provided, but a signature was provided. There were invoices for tents in response to the pandemic that were emailed to the Facilities Director and then forwarded to the finance office that were not always signed before processing, but the approval was in the grant application and the expense was approved by the Superintendent on the accounts payable warrant. Based upon these actions, the RSU 1 disagrees with this finding.

Finding 2022-003 Significant Deficiency in Internal Controls over Compliance for Allowable Costs Corrective Action Planned: The Agency has completed time studies for personnel who are allocated across multiple programs and will review documentation to ensure the time study data is applied consistently or updated when necessary to support the allocation. Documentation will be maintained to support the allocation methods. Anticipated Completion Date: June 30, 2023 Responsible Parties: The Agency?s Management and staff.

This schedule presents the corrective action planned by the District for findings reported in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Finding ref number: 2022-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with federal wage rate requirements. Name, address, and telephone of District contact person: Joanne Klein 516 176th Street E. Spanaway, WA 98387-8399 Corrective action the auditee plans to take in response to the finding: District will include federal prevailing wage rate clauses in all federal contracts. We will also obtain the weekly certified payroll reports. Anticipated date to complete the corrective action: 9/1/2023

Views of Responsible Officials: America's Poison Centers has shifted its outsourced HR service provider effective September 15, 2023. The new firm has clearly been directed to proportionately allocate time based on the time sheet. The allocations will be reviewed by the outsourced accounting team to ensure that this has been executed upon. The CEO is responsible for overseeing both the new HR service provider and the outsourced accounting team and will ensure that this does not recur.

Name of Contact Person: Marsha Keene-Frye, Chief Executive Officer Recommendation: All disbursements of the organization should have proper approval and support before the disbursement is made. Corrective Action: All disbursements will be reviewed and initial for approval before the disbursement. Invoices, timesheet or other supporting documentation will be included in the review process to decrease the likelihood of reoccurring. Proposed Completion Date: Immediately

Pleasant View Home, Inc. Year Ended December 31, 2022 Corrective Action Plan Criteria or Specific Requirement ? During the testing of compliance for Federal Assistance Listing No. 93.498, U.S. Department of Health and Human Services Direct Program: COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution, it was determined that the Corporation had incorrectly re-reported $249,380 in Period 2 expenses in the Period 4 submission, which resulted in overstating expenses claimed against PRF funds of $249,380. This resulted in a total of $249,380 of COVID-19 expenses that were charged and reported which were duplicative and/or unsupported (Reference number 2022-002) Views of Responsible Officials and Corrective Action Plan ? The Corporation continues to improve its understanding of the nuances within the guidance as it relates to charging and reporting direct expenses. Additionally, the Corporation continues to implement additional controls over future reporting periods to help ensure guidance is followed, which is being achieved through educational sessions and additional layers of review over future reporting periods to help ensure guidance is properly followed. It should be noted that while certain expenses were erroneously double counted, the Corporation had sufficient unused Lost Revenues to cover the use of these funds. Personnel Responsible ? Tod Ritcha, CFO Anticipated Completion Date ? Change is in process and full adoption is anticipated by September 30, 2023

Finding 2022-002 Significant Deficiency in Internal Controls Over Compliance Condition: The District has not formalized written policies and procedures related to federal awards. Corrective Action Planned: The District has historically not received federal grant funds and had no previous requirements to implement this compliance item. Additionally, at this time, the District does not anticipate receiving any federal grant funds in the foreseeable future. In the future, if the District were to pursue requesting more federal grant funds, it will look to establish formalized, written policies relative to grant management. Anticipated Completion Date: November 1, 2028 Contact: Derek Knerr, Treasurer, Leino Park Water District

2022-001 FINDING Contact Person ? Kalen Wiseth, Finance Director Corrective Action Plan ? The Organization will implement procedures to ensure that all expenses are approved and this approval documentation is maintained. Completion Date - Immediately

Allowable Costs The District understands the need to properly document internal control procedures for allowable costs in accordance with Uniform Guidance and State Single Audit Guidelines. In the future, the District will retain their documentation to support their allowable cost approval for federal and state grants.

MANAGEMENT?S CORRECTIVE ACTION PLAN: Once policies and procedures for individual procedures for the mentioned operations in 2022-01 above are implemented, the procedures for approval of payment should flow with more accuracy. These procedures will help to ensure proper internal controls over expense approval and help to avoid noncompliance. Detailed policies for expense approval relating to federal programs will be updated. Policies for the mentioned procedures should be completed during the fiscal year ending June 30, 2023.

Management agrees with the recommendation that drawdown requests be reconciled to the general ledger and will implement this in the current fiscal year.

Management is aware and understands the importance of compliance with the federal requirements and will ensure the meal counts will be properly reported in the future.

NORTHEASTERN ILLINOIS UNIVERSITY JUNE 30, 2022 Corrective Action Plan Finding Number: 2022-006 Condition: Northeastern Illinois University (University) charged unallowable expenditures to the Federal TRIO Program (TRIO) - Student Support Services grant. Planned Corrective Action: The Principal Investigator in coordination with Grants and Contracts Office will frequently review expenditures charged to the grant and ensure expenses are allowable within federal requirements and grant agreement. In addition, the University already removed the questioned costs incorrectly charged to the grant. Contact person responsible for corrective action: Amie Jatta, Director of TRIO Student Support Services Anticipated Completion Date: 6/30/2023

NORTHEASTERN ILLINOIS UNIVERSITY JUNE 30, 2022 Corrective Action Plan Finding Number: 2022-007 Condition: Northeastern Illinois University (University) did not pay an employee for the time worked on a grant for a 3-month period when the employee worked those hours. Planned Corrective Action: The MPI team will consult with relevant units to submit accurate timesheets while waiting for official communication from the funder. MPIs will call a meeting within seven (7) business days after the NIH PO/GMS initial review of the carry-forward request. Circumstances of the current finding will be put in writing and saved in the grant files of our office as well as in the offices of GA, ORSP and HR. Contact person responsible for corrective action: Christina Ciercierski, Principal Investigator of CHICAGO CHEC Anticipated Completion Date: 3/21/2023

Response to 2022-002 We agree there were errors in the calculation of lost revenue. The PRF guidance on reporting changed/updated several times over the course of 2 years and some requirements were missed right before the reporting was due. However, the organization?s eligibility did not change and the funded amount was fully supported by the actual loss of revenue calculation required by DHHS. Management will closely monitor future grant reporting. Contact person responsible for corrective action: Eden Ballatan, CFO Anticipated Completion Date: 3/31/2023

Response to 2022-003 Due to COVID-19, the completion of the capital project had been delayed several times beyond the original grant end date. The extension request was submitted before the end date of the grant ? December 31, 2021, however due to the year-end holiday season no response was received in a timely manner. Hence, the organization identified 100% of the grant expenditures and drew down the remaining funds. After receiving clear guidance from the HRSA program manager, some funds were returned as advised and drawn later upon completion of the project. Management will closely monitor cash management requirements specified by each grant. Contact person responsible for corrective action: Eden Ballatan, CFO Anticipated Completion Date: 6/30/2023

Finding Number: 2022-001 Condition: Controls in place did not identify an inaccurate calculation of assistance. Planned Corrective Action: The corrective action plan in response to Finding 2021-001 was implemented on September 22, 2022; and therefore the fiscal year ended June 30, 2022 was complete before implementation of the corrective action plan, which is as follows: Case Managers, Quality Review and Agency Managers can see supporting documentation and review cases in real time. All cases are processed by Case Managers, who consult with Agency Managers on questions, and 100 percent of cases are quality reviewed by a team from CLA (an outsourced professional services firm specializing in grants management) prior to processing payment. As Heart of West Michigan United Way receives MSHDA written guidance updates, we continue to hold twice-weekly meetings with CERA Agency Managers to discuss the frequent changes to the MSHDA guidance in order to gain a full understanding of the program requirements and regulations. Information is then disseminated to Case Managers. We will continue to hold regular trainings for CERA Case Managers to ensure consistency in approach and understanding of required documentation and proper assistance calculation. CLA continues to conduct a quality review check of 100 percent of applications to enhance internal controls and oversight. Additionally, the CERA Program Manager completes random checks of assistance calculations and payments. Contact person responsible for corrective action: Gail Montgomery, Vice President of Finance Anticipated Completion Date: September 23, 2022

FINDING 2022-006 Contact Person Responsible for Corrective Action: Mindy Byers Contact Phone Number: 765-364-6401 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: ALN changed during middle of audit period. Will inquire mid-year with departments managing grants to see if any ALN changes. If so, new grant fund will be created. Anticipated Completion Date: 08/2023

2022-007 Special Education Cluster (IDEA) and COVID-19 Education Stabilization Fund Recommendation: The School Corporation should implement procedures and controls to ensure all disbursements have proper support and proper approval documented. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: The school corporation will strengthen controls to ensure all federal grant expenditures have documentation of review and approval by a person knowledgeable of the grant requirements. Name of the contact person responsible for corrective action: Cheryl Harvey, Business Manager Planned completion date for corrective action plan: Begin immediately

Mountain Park identified replacement COVID related costs to evidence the spend down of period three Provider Relief funds. These funds are not subject to repayment as the Organization was able to attest and comply with the terms and conditions of the funding, including demonstrating that the distributions received were used for qualifying expenses or lost revenue attributable to COVID-19. Expected completion date: Completed Owner: Sandra Curtice, CFO

The Organization will contact the affected federal agency for guidance on resolution of the billing error. Additionally, the Organization will train management and staff working on the program to ensure an understanding of the program and its allowable costs. Furthermore, management and staff will be trained to review expenses throughout the year to ensure only allowable expenses are charged to the program. The review will include confirming that costs charged to the program are in conformity with any allowable cost elections. The contact person for this corrective action is Annette Kovamees, VP of Revenue and Financial Operations

The Organization will contact the affected federal agency for guidance on resolution of the billing errors. Additionally, the Organization will train management and staff working on the program to ensure an understanding of the program and its allowable costs. Furthermore, staff will be trained to review expenses throughout the year to ensure only allowable expenses are charged to the program. The review of expenses charged to the program will be performed by someone independent from the staff responsible for coding the expenses. The contact person for this corrective action is Annette Kovamees, VP of Revenue and Financial Operations.

April 13, 2023 Roslund, Prestage & Company, P.C. 525 W. Warwick Drive, Suite A Alma, MI 48801 Finding: 2022-001: Significant deficiency in internal control / immaterial non-compliance Federal Program: Block Grants for Prevention and Treatment of Substance Abuse ? Treatment and Women?s Specialty Services Condition: During testing of amounts charged to the grants, it was noted that provider stabilization payments were charged to the Treatment and Women?s Specialty Services grants but were not authorized by the grants. Corrective Action Plan: Mid-State Health Network will review grant documents when implementing new funding initiatives and will seek guidance from the awarding agency as needed. Responsible Party: Amy Keinath, Finance Manager Anticipated Completion Date: October 1, 2022

The Independent External Audit for the fiscal year ended June 30, 2022 included finding #2022-004 in which the District was cited as recording expenditures to the incorrect federal program. Allowable expenditures under the ECF program had not been adjusted to the limits set forth on FCC Form 471, which resulted in an overstatement of expenditures under the ECF program and an understatement of expenditures on the COVID-19 American Rescue Plan Elementary and Secondary Emergency Relief - 3 program. This finding is new to the District as of the 2021-22 Audit and is not a repeat finding. The cause for this finding is the need to reclassify expenditures, amounting to $65,260. The District has recorded these expenditures, of "local share" in the Emergency Connectivity Fund (ECF) budget line. These expenditures should have been expended from the COVID-19 American Rescue Plan Elementary and Secondary Emergency Relief - 3 budget line, as that is where the "local share" was expended. During the 2021-22 Fiscal Year, the School District worked with eRate Central to complete an application totaling $746,356, all of which were approved and committed by the FCC. While the District received this substantial commitment of funds to purchase earmarked technology equipment, the District was also responsible for a local share of some, but not all, devices. These local funds were being paid out of the ARP ESSER 3 Grant, out of a section earmarked for technology purchases. To mitigate findings, such as #2022-004 in the subsequent years, the District will record expenditures properly, using the appropriate budget codes. The District will review its expenditure budget lines and will monitor its usage of Federal Funds more closely. Anticipated Completion Date for Finding 2022-004: October 21, 2022 Person{s) Responsible for Corrective Action: Ryan Palmer & Marianne Romito

The University of New Hampshire respectfully submits the following corrective action plan for the year ended June 30, 2022. Audit period: July 01, 2021 to June 30, 2022 The finding from the schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the numbers assigned in the schedule. FINDINGS?FINANCIAL STATEMENT AUDIT There were no financial statement findings in the current year. FINDINGS?FEDERAL AWARD PROGRAMS AUDITS U.S. Department of Education 2022-001 Education Stabilization Fund ? Assistance Listing Numbers 84.425E and 84.425F Recommendation: We recommend the Universities and Colleges maintain the documentation used during the reporting process to support the numbers included in the public reporting on their website as well as maintain the formal documentation of the review and approval process that the reports go through during preparation. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University of New Hampshire (UNH) will work to resolve the reporting finding for fiscal year 2022 reporting. UNH will develop a process to ensure that the information reported is accurate and supporting documentation used to prepare the reports and review and approval of the reports is retained. Name(s) of the contact person(s) responsible for corrective action: Liz Stevens, Director of Student Financial Services (Student Reporting) Susan Zipkin, Director Accounting and Financial Compliance (Institutional Reporting) Planned completion date for corrective action plan: March 31, 2023 If the U.S. Department of Education has questions regarding this plan, please contact the individuals noted above. Plymouth State University respectfully submits the following corrective action plan for the year ended June 30, 2022. Audit period: July 01, 2021 to June 30, 2022 The finding from the schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the numbers assigned in the schedule. FINDINGS?FINANCIAL STATEMENT AUDIT There were no financial statement findings in the current year. FINDINGS?FEDERAL AWARD PROGRAMS AUDITS U.S. Department of Education 2022-001 Education Stabilization Fund ? Assistance Listing Numbers 84.425E and 84.425F Recommendation: We recommend the Universities and Colleges maintain the documentation used during the reporting process to support the numbers included in the public reporting on their website as well as maintain the formal documentation of the review and approval process that the reports go through during preparation. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Plymouth State University (PSU) will work to resolve the reporting finding for fiscal year 2022 reporting. PSU will develop a process to ensure that future information is reported timely, and the review and approval of the reports is documented and retained. The FY21 Uniform Guidance Single Audit was not finalized until June 2022, which contributed to the recurring issues noted in this finding. Name(s) of the contact person(s) responsible for corrective action: Mary Batch, Director of Finance (Institutional Reporting) Mac Broderick, Director of Student Financial Services (Student Reporting) Planned completion date for corrective action plan: July 31, 2022 If the U.S. Department of Education has questions regarding this plan, please contact the individuals noted above. Keene State College respectfully submits the following corrective action plan for the year ended June 30, 2022. Audit period: July 01, 2021 to June 30, 2022 The finding from the schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the numbers assigned in the schedule. FINDINGS?FINANCIAL STATEMENT AUDIT There were no financial statement findings in the current year. FINDINGS?FEDERAL AWARD PROGRAMS AUDITS U.S. Department of Education 2022-001 Education Stabilization Fund ? Assistance Listing Numbers 84.425E and 84.425F Recommendation: We recommend the Universities and Colleges maintain the documentation used during the reporting process to support the numbers included in the public reporting on their website as well as maintain the formal documentation of the review and approval process that the reports go through during preparation. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Keene State College (KSC) will work to resolve the reporting finding for fiscal year 2022 reporting. KSC developed a process to ensure that the information is reporting timely, accurately, and supporting documentation used to prepare the reports and review and approval of the reports is retained. The FY21 Uniform Guidance Single Audit was not finalized until June 2022, which contributed to the recurring issues noted in this finding. Name(s) of the contact person(s) responsible for corrective action: Catherine Mullins Planned completion date for corrective action plan: July 1, 2022 If the U.S. Department of Education has questions regarding this plan, please contact the individuals noted above. Granite State College respectfully submits the following corrective action plan for the year ended June 30, 2022. Audit period: July 01, 2021 to June 30, 2022 The finding from the schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the numbers assigned in the schedule. FINDINGS?FINANCIAL STATEMENT AUDIT There were no financial statement findings in the current year. FINDINGS?FEDERAL AWARD PROGRAMS AUDITS U.S. Department of Education 2022-001 Education Stabilization Fund ? Assistance Listing Numbers 84.425E and 84.425F Recommendation: We recommend the Universities and Colleges maintain the documentation used during the reporting process to support the numbers included in the public reporting on their website as well as maintain the formal documentation of the review and approval process that the reports go through during preparation. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Granite State College (GSC) will work to resolve the reporting finding for fiscal year 2022 reporting. GSC and the University of New Hampshire (UNH) are in the process of merging as part of a new college within UNH, which resulted in a transition of reporting responsibilities and processes. GSC and UNH will develop a process to ensure that the information reported is accurate and supporting documentation for the review and approval of reports is retained. The FY21 Uniform Guidance Single Audit was not finalized until June 2022, which contributed to the recurring issues noted in this finding. Name(s) of the contact person(s) responsible for corrective action: Andrea Nepveu, Acting Director of Financial Aid (Student Reporting) Susan Zipkin, Director, Accounting and Financial Compliance (Institutional Reporting) Planned completion date for corrective action plan: March 31, 2023 If the U.S. Department of Education has questions regarding this plan, please contact the individuals noted above.