Corrective Action Plans

Type of Finding: Material weakness in internal control over compliance relating to inadequate documentation and controls in place to ensure costs are reasonable and intended for the program charged. Views of Responsible Officials: Management accepts the finding. Effective internal control over the documentation of secondary review of financial reports, timely filing, and disclosed demographics contained within the reports, which can be attributed to a lack of documentation of review and controls in place for submission of a report when responsible employee is out of office during the due date. Authorized personnel review was not documented, and a performance report was not filed timely and was filed with incorrect demographics. More thorough training of staff, along with careful supervisory review and documentation of review of report submissions prior to filing would likely have prevented these errors. Corrective action: A process for secondary review of all financial and programmatic reports will be developed in each region.

We agree with the auditor’s comments, and the following actions will be taken to ensure all records are maintained for reporting purposes: 1. Implement a point-of-sale system 2. Use the point-of-sale system to track all meals served by student eligibility 3. Reconcile records against claim forms on a monthly basis as reimbursement claims are submitted to the California Department of Education The above steps have been completed and implemented since January of 2023 and the District maintains that it will continue the actions above to follow Child and Adult Care Food Program, Child Nutrition Cluster guidelines.

For the Year Ended June 30, 2023 Finding 2023-002 Condition #2: The University withdrew the current year budget amount for one grant for $176,615 before incurring allowable expenses and did not disburse the funds within three days. The University kept the funds in an insured account and used the funds on eligible expenses by June 30, 2023. The internal controls over cash management were not operating effectively. Corrective Action Planned: A desk review of ALN 47.076 National Science foundation (NSF) occurred in August 2023 and identified 17.76%, the current year annual budgeted amount, had been drawn down in advance of expenditures incurred and not fully utilized as indicated in 2 CFR 200.305 Federal Payments. MMU has discontinued the practice of drawing down funds in advance based on the budgeted amount for each year of the project (as prior grants allowed). Instead, MMU will draw down funds based on immediate cash requirements each month of the project after expenditures are incurred, reflected in the general ledger system and reviewed by the Principal Investigator (PI)/Co Principal Investigator (Co-PI) and Senior Accountant. The Business Office has implemented a cash management control as follows: Review financial requirements upon grant submission and again when awarded, adjust accounting controls according to grantor requirements, actively participate in monthly review of financial reporting to grantor and document all financial activities as required Name(s) of Contact Person(s) Responsible for Corrective Action: Cheryl Bailey (PI), and Kathleen Glancey (Co-PI) and Nicole Biddle, Senior Director of Finance. Anticipated Completion Date: Grants Manager, Kathleen Glancey, has experience with grant reporting and management systems. Cheryl Bailey (PI) and Kathy Glancey met during the month of September 2023 to create an updated grants management manual that contains policies and procedures to encompass all federal sponsored programs. MMU shared the grants manual with NSF by September 30th, 2023. Immediately upon completion of manual and submission to NSF, monthly meetings commenced to implement financial review of incurred expenses prior to cash draws. The complete action plan was implemented upon the desk review which was 4 months prior to the Single Audit.

FINDING 2023-005 Information on the federal program: Subject: Special Education Cluster (IDEA) - Reporting Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.027X, 84.173, 84.173X Federal Award Numbers and Years (or Other Identifying Numbers): 19611-022-PN01, 20611-022-PN01, 21611-022-PN01, 22611-022-PN01, 22611-022-ARP, 23611-022-PN01, 20619-022-PN01, 21619-022-PN01, 22619-022-PN01, 22619-022-ARP, 23619-022-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Qualified Opinion Condition: The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the reporting requirements. The Cooperative had not designed or implemented adequate policies or procedures to determine that requests for reimbursement were submitted accurately and agreed to supporting documentation. There was a documented oversight, review, and approval process in place; however, the Cooperative did not adequately ensure that proper procedures were followed. Context: The School Corporation is a member of the Greene-Sullivan Special Education Cooperative (Cooperative). During fiscal year 2021-2022, the Cooperative operated the special education programs and spent the federal money on behalf of all its members.  As the grant agreements were between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. However, there was inadequate oversight performed by the School Corporation in order to ensure compliance with the Reporting compliance requirement. The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the reporting requirements. The Cooperative had not designed or implemented adequate policies or procedures to determine that requests for reimbursement were submitted accurately and agreed to supporting documentation. There was a documented oversight, review, and approval process in place; however, the Cooperative did not adequately ensure that proper procedures were followed. For fiscal year 2022, 51 Reimbursement Reports were tested. 14 Reimbursement Reports could not be traced to unit ledgers for expenditures, and 21 Reports did not have appropriate supporting documentation. For fiscal year 2023, 23 Reimbursement Reports were tested. Three Reimbursements Report did not agree to supporting documentation, and key line items could not be verified. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and will take the following corrective action: 1 – Greene Sullivan Special Education Cooperative will implement a procedure that includes the requirement of proper documentation for all reimbursement requests, such as the detailed history report for each request submitted. The Director will then review each request prior to submission. Responsible party and timeline for completion: Chris Stitzle, Superintendent – April 1, 2024

The finding from Section III — Federal Awards Findings and Questioned Costs Finding 2023-002 — Cash Management and Reporting Condition: The District did not file the required quarterly reports for June 2023 for grant #223-210073 and #225-210073 in a timely manner within the 10-day requirement. The District did not file the required quarterly report for June 2023 for grant #200-210073. Also, the District did not file the required final expenditure report for grant #200-200073 timely. Views of Responsible Officials and Planned Corrective Actions: The District Business Manager will work with all involved in the process of the Federal Grants filing the expenditure reports quarterly and filing of the final expenditure reports. Procedures will include creating a calendar with the due dates, reporting the expenditures in the accounting software and creating a report with the expenses listed for the month and quarterly. Account numbers have been created according to the PDE accounting manual for the recording of all expenses and revenue for each federal grant. All expenditures will be recorded correctly and in a timely manner. The person responsible for the corrective action plan will be the Business Manager and the anticipated completion date will be June 30, 2024.

FINDING 2023-003 Information on the federal program: Subject: Education Stabilization Fund – Advance Draws Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs- Cost Principles Audit Finding: Material Weakness, Qualified Opinion Condition: The School Corporation requested reimbursement prior to incurring expenditures under federal grant awards. An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Activities Allowed or Unallowed, Allowable Costs- Cost Principles compliance requirements. Context: During testing disbursements charged to ESF grants, we noted advance payments were received during the audit period prior to allowable costs being incurred by the School Corporation impacting the following Education Stabilization Fund grant awards: ● The School Corporation submitted a claim for reimbursement for $43,864 from the ESSER I grant award (84.425D) which was receipted on August 24, 2021. As of August 24, 2021, the School Corporation had incurred $41,674 of grant expenditures. The remaining $2,190 was disbursed on April 12, 2022. ● The School Corporation submitted a claim for reimbursement for $148,822 from the ESSER II grant award (84.425D) which was receipted on July 28, 2021. There were no expenditures incurred as of the date of the reimbursement request. The School Corporation began incurring expenditures after the advance payment, however, as of June 30, 2022, the School Corporation had an unspent cash balance of $24,613 in the ESSER II fund because of the advance payment. The School Corporation did not request any reimbursements for the period of July 1, 2022 through June 30, 2023 and continued to incur expenditures. As of June 30, 2023, the School Corporation had an unspent cash balance of $16,145. FINDING 2023-003 (Continued) ● The School Corporation submitted two claims for reimbursements from the ESSER III grant award (84.425U) during fiscal year 2022. The first claim reimbursement was receipted on November 24, 2021, in the amount of $52,210. The second claim reimbursement request was receipted on June 22, 2022, in the amount of $144,649. The School Corporation had incurred expenditures as of the date of each claim reimbursement requests, however, the amount claimed for reimbursement exceeded expenditures incurred resulting in advance payments being received. As of June 30, 2022, the School Corporation had an unspent cash balance of $88,348 in the ESSER III fund as a result of the advance payment. The School Corporation did not request any claims for reimbursements for the period of July 1, 2022 through June 30, 2023 and continued to incur expenditures. As of June 30, 2023, the School Corporation had an unspent cash balance of $21,842 in the ESSER III fund because of the advance payments. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. Going forward the reimbursement will be prepared by the Assistant Superintendent once the funds have been spent and the Corporation Treasurer will review the reimbursement before it is submitted. Responsible Party and Timeline for Completion: The Assistant Superintendent, David Hobaugh, and the Corporation Treasurer, Kristina James, will oversee the corrective action plan and will be implemented immediately.

FINDING 2023-005 Finding Subject: Child Nutrition Cluster – Reporting; Special Tests and Provisions, Eligibility Summary of Finding: Internal controls were not in place to ensure compliance with requirements related to the grant agreement, specifically related to reporting and eligibility. Contact Person Responsible for Corrective Action: Scott Weltz, Amanda Brackett Contact Phone Number and Email Address: 765-654-5585, weltzs@frankfort.k12.in.us, bracketa@frankfort.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Internal controls will be established and followed to ensure compliance with requirements related to the grant agreement. The Director shall submit the report after the Treasurer reviews and verifies the information in the report. Such measures will prevent future misstatements and provide the proper internal controls. Anticipated Completion Date: Effective immediately and ongoing

2023-003 - #84.425U COVID-19 Elementary and Secondary School Emergency Relief Fund III Federal Grantor: U.S. Department of Education Pass-through Award Number: 2022-291673-DPI-ESSERFIII-165 Pass-through Entity: Wisconsin Department of Public Instruction Condition: There were Education Stabilization Fund construction projects performed by contractors. Grant expenditures for the projects paid by the Education Stabilization Fund totaled $556,368. There was not a prevailing wage clause in the contracts and certified payrolls were not received. Criteria: Wage rate requirements apply to the Education Stabilization Fund when laborers and mechanics employed by contractors or subcontractors work on construction contracts more than $2,000. Laborers must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL). Nonfederal entities shall include in their contracts, subject to wage rate requirements, a provision that the contractor or subcontractor comply with those requirements and the DOL regulations. This includes a requirement for the contractor or subcontractor to submit to the District weekly payrolls and a statement of compliance (certified payrolls). Cause: The District was not aware that wage rate requirements applied to the construction projects. Effect: A reimbursement request was made for expenditures that did not comply with wage rate requirements. Questioned Costs: $556,368 Auditor’s Recommendation: Establish controls to comply with wage rate requirements related to the Education Stabilization Fund. Grantee Response: The District has implemented additional procedures to ensure prevailing wage rate requirements are included in all contracts funded by federal programs. Contact Person: Mary Prielipp Anticipated Completion: June 30, 2024

In addition to changes made under Corrective Action Work Plan 2023-002, we are updating our drawdown procedures to include an additional step to reconcile expenditures to the accounting records at the time of submission. If there are any discrepancies, any reconciling items will be retained as part of the file maintained for that grant.

2023-020. Working Capital Reserves in Excess of Federal Guidelines State Agency: Department of Governmental Operations Federal Agency: Various Division of Purchasing and General Services Cooperative Contract Management Fund – Public entities in Utah rely on the Division of Purchasing and General Services (State Purchasing) to maintain the cooperative contract program to assist with public procurement in Utah. The usage of state cooperative contracts by public entities continues to increase yearly, resulting in a corresponding increase in the collection of administrative fees. State Purchasing continues to review contract administrative fees on state cooperative contracts as each contract expires and is resolicited. This is a slow process since State Purchasing has approximately 1,200 cooperative contracts that expire only every five years and are then resolicited. While State Purchasing is allowed under law to collect up to a 1.0% administrative fee on each cooperative contract, currently the average administrative fee is approximately 0.35%, a decrease of 18.6% from the average contract administrative fee in fiscal year 2022. The Division of Purchasing and General Services also continues to work with the Department of Government Operations executive leadership to request the Utah Legislature appropriate out a portion of the excess reserves in the Cooperative Contract Management Fund. The calculation of the federal portion of these transfers will be submitted to Cost Allocation Services for review and approval when these transfers are completed. Federal Surplus Property Fund- Surplus Property anticipated relocating by the end of fiscal year 2023 with the completion of the new Utah State Prison. Due to schedule changes, the new location for Surplus Property was not completed in time and the new anticipated relocation date is the end of fiscal year 2025. At the time of relocation, Surplus Property will use the excess reserve funds to move and furnish the new location, including replacing aged equipment. Contact Person: Windy Aphayrath, waphayrath@utah.gov, Director, Division of Purchasing and General Services Anticipated Correction Date: June 30, 2025 Division of Finance Purchasing Card Fund – State Finance is in the process of implementing a new travel and expense reporting system for all state agencies. This system will simplify travel approvals, travel reimbursements, and reduce the administrative burden for the purchasing card (P-Card) expense reports on state agency personnel. To cover system implementation costs, State Finance elected not to distribute the rebates received from U.S. Bank related to state agency P-Card spending for calendar years 2021, 2022, and 2023. Rebates were still sent to participating entities external to the primary government. The anticipated completion date for the new system is the end of the calendar year 2024. State Finance will then review annually the costs of the system, develop a cost allocation strategy between the travel and P-Card programs, and adjust travel rates to cover the travel program's ongoing costs. The P-Card program will then distribute any remaining P-Card rebates to state agencies respective to their spend. This effort should reduce and/or eliminate any excess federal reserves in the P-Card fund by the end of fiscal year 2025. Contact Person: Allyson Branch, abranch@utah.gov, Assistant Director, Division of Finance Anticipated Correction Date: June 30, 2025 Division of Risk Management Workers' Compensation Fund – The Division of Risk Management did not request an increase in rates for fiscal year 2024 for the Workers Compensation Fund. It is also anticipated that premiums for worker compensation insurance for fiscal year 2025 will increase. This increase will help bring this fund back into compliance. The Division of Risk Management will also reevaluate this program at the end of fiscal year 2024 to determine if a legislative request to transfer funds out and/or refund the federal portion of retained earnings is needed to reduce and/or eliminate the excess federal reserves remaining in this fund. Contact Person: Rachel Terry, rachelgterry@utah.gov, Director, Division of Risk Management Anticipated Correction Date: June 30, 2025 Division of Technology Services Communication Services – The fiscal year 2024 Communication Services rate was set to under recover the cost of providing this service by $276,000. The fiscal year 2025 rate was also set to under recover the cost of providing this service by an additional $398,000. DTS plans to annually review and adjust rates and issue mid-year rebates, if necessary, to bring DTS Communication Services into compliance with federal excess reserve guidelines by the end of fiscal year 2025. Mainframe Services – This service will be coming to an end by fiscal year 2024. As this service ends, DTS will issue rebates of any remaining Mainframe Services retained earnings to the state agencies who used the system. Contact Person: Dan Frei, dfrei@utah.gov, Finance Director, Division of Technology Services Anticipated Correction Date: June 30, 2025 Division of Human Resource Management Human Resources Field Services – During fiscal year 2023, the Division of Human Resource Management worked to better align expenses with the corresponding rate. A cost allocation plan was developed to accomplish this goal. As a result of that effort, the Human Resources Field Services rate was decreased, and the Payroll Services and Core Services rates were increased for fiscal year 2025. The Division anticipates that these rate adjustments will eliminate the excess reserves. Contact Person: John Barrand, jbarrand@utah.gov, Director, Division of Human Resource Management Anticipated Correction Date: June 30, 2025

2023-006. Lack of Controls over Food Benefit Payments State Agency: Department of Health and Human Services Federal Agency: Department of Health and Human Services The Division of Family Health (DFH) will continue efforts to ensure proper management of the WIC program. The department and DFH will consider possible improvements for managing third party food benefit redemptions. Contact Person: Mykio Saracino, Assistant Office Director, 385-228-4798 Anticipated Correction Date: December 31, 2024

2023-016. Underlying Accounting Data Does Not Support CRF Quarterly Reports State Agency: Governor’s Office of Planning and Budget Federal Agency: Department of the Treasury GOPB has reviewed its master CRF expenditure file and reconciled all reported CRF expenditures to FINET transactions. The reconciliation accounted for original expenditure transactions, CRF expenditures that were booked when agencies are reimbursed for eligible transactions, and FEMA reimbursements for expenditures charged to the CRF. GOPB made final updates to the September 31, 2023, CRF quarterly report that was submitted on October 10, 2023. Contact Person: Duncan Evans, Senior Managing Director of Budget and Operations, 801-538-1592 Anticipated Correction Date: Completed October 10, 2023

2023-015. Obligation of CRF Funds Not Completed Within Proper Timeframe State Agency: Governor’s Office of Planning and Budget Federal Agency: Department of the Treasury GOPB will save copies of the Treasury Department guidance documents and the September 2022 email from the Treasury Office of the Inspector General that it used to determine that it could update the December 31, 2022 quarterly CRF report to include additional benefit payments from the Unemployment Compensation Fund made between March 1, 2020 and December 31, 2021. GOPB will also save copies of financial reports and other documentation that demonstrates the total costs incurred from the Unemployment Compensation Fund during that time frame did not exceed total deposits into the fund from the CRF, SLFRF, or other sources. Contact Person: Duncan Evans, Senior Managing Director of Budget and Operations, 801-538-1592 Anticipated Correction Date: March 31, 2024

2023-013. Improper Reimbursement of Utility Expenditures Due to Lack of Effective Internal Controls State Agency: Department of Transportation Federal Agency: Department of Transportation UDOT will train employees to verify utility agreements are drafted and effective before UDOT works on projects with utility partners. UDOT will continue to coordinate with utility partners to align reimbursement practices with the applicable federal requirements. Responsible Party: Carmen Swanwick, Project Development Director, (801) 232-7802 Completion Date: June 2025

Corrective Action Plan: The University will remit annually any interest earned in excess of $500 to the Department of Health and Human Services. Implementation Date: 2/2024 Responsible Person: Andrea Wright, Executive Director of Accounting Services

Corrective Action Plan: The University is updating procedures to ensure unallowable charges are not paid using Title IV funds without proper authorization from the student or parent. The University will review and improve, as necessary, existing controls to ensure that Title IV aid in excess of the student’s institutional charges will not be held without written authorization from the student or parent. Implementation Date: May 2024 Responsible Persons: Beth Tolan, Associate Vice President of Financial Aid & Scholarships Christopher Foster, Associate Vice President of Student Accounting

Corrective Action Plan: There is a current initiative at the university to complete a comprehensive review of all of our current charge item types for Title IV allowable/non-allowable purposes. The Office of Scholarships and Financial Aid is working with Student Business Services (SBS) and each academic college to departmentalize the charges. Once this effort is complete, we will work with SBS and Accounting to begin setting up and testing the required changes. We are committed to making the necessary changes in order to be in compliance but want to make sure it is understood that this is a monumental undertaking that will require considerable effort. It will demand a massive commitment of resources and time. Due to the nature of PeopleSoft and the effects of effective dating, this update will need to be implemented prior to the beginning of an aid year. We will take precautions to prevent inadvertent errors and system glitches by implementing these changes in 2025-2026. The Office of Scholarships and Financial Aid in conjunction with Student Business Services are in the early stages of implementing functionality in PeopleSoft that will allow students to provide permission to apply financial aid for charges other than allowable charges. The implementation of this functionality will allow us to obtain written authorization from students or parents prior to crediting student ledger accounts for certain charges. Implementation Date: February 2025 Responsible Persons: Kevin Burns, Bursar Charita Hampton, Interim Executive Director, SFA Gretta McClain Gibbs, Director, Accounting Services Madiha Syeda, Financial Manager, General Accounting

Corrective Action Plan: The Office of Student Financial Success has worked with the Office of Information Technology to deliver student loan disbursement information via the student portal. A tab has been created that allows students to receive specific disbursement information related to their student loans. In addition, the disbursement notification process has been established to ensure all students receive a disbursement notification before disbursements are made to student accounts. Our policy now requires, before disbursement, the generation of disbursement notifications made by the Senior Systems Analyst. Implementation Date: January 2024 Responsible Person: Dr. Latisha Addison, Executive Director Student Financial Success Corrective Action Plan: The University has implemented significant process enhancements in this area. The University has updated the charges associated with the university installment plan in the ERP system to be designated as an unallowable charge. This update will ensure that Title IV aid will not pay towards those charges. Management will conduct a second level review to ensure that the University is in compliance with the requirements. Implementation Date: February 2024 Responsible Person: Mr. Errol Thomas, Executive Director of Student Accounting

The Authority will drawn down CFP funds on a reimbursement basis or can ensure subsequent disbursement with three business days to ensure compliance with 31 CFR Part 205

FINDING 2023-007 Information on the federal program: Subject: Special Education Cluster (IDEA) - Reporting Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.027X, 84.173, 84.173X Federal Award Numbers: 19611-022-PN01, 20611-022-PN01, 21611-022-PN01, 22611-022-PN01, 22611-022-ARP, 23611-022-PN01, 20619-022-PN01, 21619-022-PN01, 22619-022-PN01, 22619-022-ARP, 23619-022-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Qualified Opinion Condition: The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the reporting requirements. The Cooperative had not designed or implemented adequate policies or procedures to determine that requests for reimbursement were submitted accurately and agreed to supporting documentation. There was a documented oversight, review, and approval process in place; however, the Cooperative did not adequately ensure that proper procedures were followed. Context: The School Corporation is a member of the Greene-Sullivan Special Education Cooperative (Cooperative). During fiscal year 2021-2022, the Cooperative operated the special education programs and spent the federal money on behalf of all its members. As the grant agreements were between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. However, there was inadequate oversight performed by the School Corporation in order to ensure compliance with the Reporting compliance requirement. The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the reporting requirements. The Cooperative had not designed or implemented adequate policies or procedures to determine that requests for reimbursement were submitted accurately and agreed to supporting documentation. There was a documented oversight, review, and approval process in place; however, the Cooperative did not adequately ensure that proper procedures were followed. For fiscal year 2022, 51 Reimbursement Reports were tested. 14 Reimbursement Reports could not be traced to unit ledgers for expenditures, and 21 Reports did not have appropriate supporting documentation. For fiscal year 2023, 23 Reimbursement Reports were tested. Three Reimbursements Report did not agree to supporting documentation, and key line items could not be verified. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and will take the following corrective action: 1 – Greene Sullivan Special Education Cooperative will implement a procedure that includes the requirement of proper documentation for all reimbursement requests, such as the detailed history report for each request submitted. The Director will then review each request prior to submission. Responsible party and timeline for completion: Mark A Baker, Superintendent Effective April 2024

FINDING 2023-003 Information on the federal program: Subject: Education Stabilization Fund – Advance Draws Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs- Cost Principles Audit Finding: Material Weakness, Other Matters Condition: The School Corporation requested reimbursement prior to incurring expenditures under federal grant awards. An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Activities Allowed or Unallowed, Allowable Costs- Cost Principles compliance requirements. Context: During testing disbursements charged to ESF grants, we noted the ESSER I grant award, tracked in Fund 7940, and the ESSER III grant award, tracked in Fund 7932, had a positive cash balance of $2,718 and $35,661, respectively, at June 30, 2023 as a result of advance payments received during fiscal year 2023. The School Corporation submitted a request for reimbursement on November 15, 2022 for $21,745 from the ESSER I grant award and $565,876 from the ESSER III grant award, respectively. These requests for reimbursements were partially supported by disbursements incurred as of the date of the request, however, partially include requests for advance payments that were still not fully expended as of June 30, 2023. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. If there are any posting corrections after a reimbursement has been made and received, the Corporation Treasurer will contact IDOE (Indiana Department of Education) asking whether they would like the difference between the reimbursement and the new disbursement amount paid back to DOE or spent down within a specific time period. Responsible Party and Timeline for Completion: The Corporation Treasurer, Emma Conwell, will oversee the corrective action plan which will be implemented by June 30, 2024.

Noncompliance with HCM 1 Monitoring Planned Corrective Action: SDCC currently operates under HCM2 status which requires that the College proves that sufficient compliance has been met prior to the reimbursement of all Title IV funds. As SDCC continues its efforts to move to HCM1 status, processes and procedures have been identified and will be implemented when authorization to operate under HCM1 status is received. Person Responsible for Corrective Action Plan: Kayleigh Reyes, Director of Financial Services Anticipated Date of Completion: Policies and procedures for HCM1 was provided during the audit.

FINDING 2023-003 Finding Subject: Child Nutrition Cluster-Reporting Summary of Finding: The School Corporation did not have effective internal controls over the Child Nutrition Cluster (CNC) reporting. The Claims for Reimbursement were prepared by one employee and not reviewed by a second employee to ensure compliance. Contact Person Responsible for Corrective Action: Jamesi Lemon Contact Phone Number and Email Address: (260) 499-2400; jlemon@lakelandlakers.net Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Claims for Reimbursement will be prepared by the Food Service Director and the Director of Business Operations will review the claims for compliance. The claims will then be initialed signaling they have been reviewed. Anticipated Completion Date: Immediately

The Authority has performed a review of all patients who have had indications of additional health insurance on an account with a HRSA payment, and made appropriate refunds.

Finding 2023-001 & 2023-002 Internal Control over Compliance and Compliance with Cash Management Responsible Official’s Response and Corrective Action Plan Pursuant to s. 216.181(16)(b), F.S., 2 CFR § 200.305(8) and (9), Federal payment, and DEL Program Guidance 240.01 – Cash Management Procedures, the Early Learning Coalition of Southwest Florida will invest the funds it receives under the Florida Department of Education’s Division of Early Learning (DEL) Grant Agreement in secure, interest-bearing accounts, unless DEL otherwise authorizes. The ELC shall return to DEL all interest income earned on VPK funds and interest earned on CCDF funds in excess of $500 for the program year. The ELC shall notify DEL if there are no interest payments due to be returned. The target date for completion is on or before September 1, 2024. The immediate goal is to comply prior to the new contract year beginning July 1, 2024. However, if meeting compliance requirements precipitates a change in banking institutions, this change would require implementing a procurement process in compliance with s. 287.057, F.S., and 2 CFR Parts 200.318-320. Anticipated Completion Date: September 1, 2024 Responsible Party: Melanie Stefanowicz, Chief Executive Officer