Corrective Action Plans

Recommendations: Notification of the residual deposit amount will be sent to the property accountant, the executive officer, and the supervising manager in the future. A reminder to make the residual receipts deposit will be added to the project accountant?s calendar. Management Comments: The Management agrees with the finding. The reminder will be added to the calendar. Management agrees that a notification will be sent to the project accountant, the executive officer, and the supervising manager. Resolution: The project accountant issued a check for $17,227 for the residual receipts deposit upon notification of the finding. Corrective Action Completed.

Finding 2022-001 ? A. Activities Allowed or Unallowed, B. Allowable Costs / Cost Principles, E. Eligibility, and N. Special Tests and Provisions ? Material Weakness in Internal Controls Over Compliance Federal Program: COVID-19 Claims Reimbursement to Health Care Providers and Facilities for Testing Treatment, and Vaccine Administration for the Uninsured, Assistance Listing No. 93.461 (COVID-19 Uninsured Program) Federal Agency: U.S. Department of Health and Human Services, Health Resources and Services Administration (HRSA) Pass-Through Award Period: January 1, 2022 through December 31, 2022 Views of responsible officials and planned corrective actions: Management agrees with the finding as reported. It is noteworthy that the COVID-19 Uninsured Program (the Program) ceases to accept claims for testing and treatment effective March 22, 2022. Claims for vaccinations were no longer accepted after April 5, 2022. Should HRSA funding be re-instated, the Network is committed to ensure proper internal controls over compliance are established to fully comply with the Program?s set terms and conditions.

The excess Food Service fund balance was due to the additional funding received while the school operated the SFSP, SSO and CACFP programs, along with an excess fund balance from the prior year. Our prior year spend down plan included equipment replacement for the High School cafeteria and food service areas. Due to delays with shipping and manufacturing, the equipment wasn?t delivered and paid for until July 2022, after our fiscal year end. Had the equipment been delivered and paid for prior to year-end, the District would not have incurred an excess fund balance.

Finding Number 2022-001 Reporting - Deficiency Agency Name U.S. Department of Health and Human Services (American Rescue Plan Act) (ARPA) Pass-through Pennsylvania Commission on Crime and Delinquency Program ALN 21.027 - Coronavirus State and Local Fiscal Recovery Fund Criteria The Comprehensive Response to Violence (CRV) Program Reports are due within twenty (20) days after each quarterly reporting period. Condition/Context Temple University Health System (TUHS) received ARPA funding from the U.S Department of Health and Human Services, passed-through from the Pennsylvania Commission on Crime and Delinquency (PCCD) for the CRV Program. TUHS was required to submit quarterly CRV Program Reports to the PCCD. All Program Reports were submitted. However, we noted that two (2) reports were submitted after the due dates prescribed by PCCD. Questioned Costs None. Recommendation We recommend TUHS submit the required reports within the time frame prescribed. Corrective Action Plan Management acknowledges the finding and notes that two (2) of the CRV Program Reports were not submitted timely. Going forward, the program?s manager will submit the reports according to the time frame prescribed. Action Date June 30, 2023 Final Implementation June 30, 2023 Name And Phone Number Of Person Responsible For Implementation Scott Charles, Trauma Outreach Manager (215)868-4658

Identifying Number: 2022-002: Invoice Submitted in Duplication Criteria: Management was responsible for submitting accurate monthly reimbursement requests to the grantor for allowable costs incurred under the grant agreement. Condition: During compliance testing, it was determined that one invoice totaling $6,300 was submitted for reimbursement under the grant twice, in error. Context: An invoice totaling $6,300 was incorrectly submitted for reimbursement under the grant. Cause: The process to prepare monthly reimbursement requests is manual and the invoice was submitted for reimbursement during the month of July 2021 and again in August 2021 in error. Effect: As a result, the System received $6,300 from the grantor for costs that were not supported. Recommendation: Management should notify and refund the grantor for the funds received in duplication. Management should also implement controls to ensure this error does not reoccur. Contact: Michael Turilli, Chief Financial Officer Corrective Actions Taken or Planned: Management acknowledges the finding and will ensure appropriate review of supporting expenses submitted to the grantor. Management agrees to utilize their ERP system, which eliminates duplicate invoices, when sending future billings to the grantor. An amended report will be filed with the awarding agency, as applicable.

The CEO shall strengthen the monitoring procedures and work more closely with the accounting staff to ensure that controls over the general ledger allow the proper recording and reporting of federal program transactions.

In Response to Findings and Questioned Costs ? Major Federal Award Program Audit for the Year Ended June 30, 2022 2022-001 Utilization of a Cost Plus a Percentage of Cost Contract Responsible Persons: ? Gwenn Wysling, Executive Director ? Darcy Justice, Executive Assistant Corrective Action Plan: 1. Bethlehem Inn will modify the organization?s procurement policy so that cost plus a percentage of construction cost methods of contracting are not allowed, unless first approved by the board. 2. Bethlehem Inn will provide Deschutes County with legitimacy of the fee in question ($41,208) as evidenced by an independent third party. 3. Reach an agreement with Deschutes County on the questioned cost. Anticipated Completion Date corresponding to the #1-3 above: 1. By February 22, 2023 2. By March 3, 2023 3. By March 31, 2023

FINDING 2022-014 Contact Person Responsible for Corrective Action: Casey Brewster Contact Phone Number: 812-752-8935 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The approved grant budgets for all federal grants will be input into the financial management system and with all expenditures reported monthly from the Treasurer to the Director overseeing the federal grant for review and final approval. The monthly reports will then be used by the Director to generate a reimbursement request for actual expenditures. The reimbursement request must then be reviewed and signed by the Treasurer or the CFO prior to submission to the State by the Director. Anticipated Completion Date: April 2023

FINDING 2022-006 Contact Person Responsible for Corrective Action: Casey Brewster Contact Phone Number: 812-752-8935 Views of Responsible Official: We concur with the finding. INDIANA STATE BOARD OF ACCOUNTS 67 Description of Corrective Action Plan: Additional training related to grant budgets entered into and monitored within the financial software will occur, as will the new practice of having the program directors initiating monthly reimbursement requests informed by the accurate reports from the software (ledger), with documented review by the Treasurer or CFO. Additional training over the reporting requirements is taking place with the Treasurer, CFO and Directors overseeing federal funds provide accurate reporting. Anticipated Completion Date: June 2023

2022-003 - Written Policies Required by the Uniform Grant Guidance Auditor Description of Condition and Effect. Although the Organization has processes in place to cover these areas, there are no formal written policies for payments and allowability of costs charged to federal programs. As a result of this condition, the Organization did not fully comply with the Uniform Grant Guidance applicable to its federal programs. Auditor Recommendation. Formal written policies should be prepared to comply with the Uniform Guidance. Corrective Action. Management concurs with the finding. The Organization will prepare formal written policies to fully comply with the Uniform Grant Guidance applicable to its federal programs. Responsible Person. Matt Morris, Chief Finance & Operations Officer Anticipated Completion Date: June 30, 2023

FINDING 2022-011 Contact Person Responsible for Corrective Action: Casey Brewster Contact Phone Number: 812-752-8935 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Additional training related to grant budgets entered into and monitored within the financial software will occur, as will the new practice of having the program directors initiating monthly reimbursement requests informed by the accurate reports from the software (ledger), with documented review by the Treasurer or CFO. Additional training over the reporting requirements is taking place with the Treasurer, CFO and Directors overseeing federal funds provide accurate reporting. Anticipated Completion Date: June 2023

Findings Required to Be Reported by the Uniform Guidance Department of Education Finding: 2022-001 CFDA #: 84.425 E & F Recommendation: We recommend the College adopt the reimbursement method of cash management for all federal funding. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Corrective Action Planned: Subsequent to June 30, 2022, we have disbursed all of the remaining Student Aid Portion and there are no remaining Higher Education Emergency Relief Funds subject to cash management compliance. The College already operates under the reimbursement method for all other federal funds. Name of Contact Responsible for Corrective Action: Mike Trochuck, Vice President for Finance, 708-239-4836. Anticipated Completion Date: Completed as of November 29, 2022.

MW 2022-004 Review of Reimbursement Requests and Expenses Recommendation: Review of reimbursement requests and monthly expense submissions should be documented and ensure the completeness and accuracy of the submission. Review of individual payroll and non-payroll expense allowability should be documented. Management Response: Since the prior audit, we implemented several changes which affect the repeated findings. We have already implemented the recommended process for the review of reimbursement requests and monthly expense submissions. These are documented to ensure the completeness and accuracy of the submission. We also implemented the documentation of the review of individual payroll and non-payroll expense allowability. The fiscal year 20-21 audit report was issued on June 30, 2022. The change in the fiscal year resulted in a 12-hour turnaround making it difficult to clear the findings and implement the recommended changes from last year's audit. RESPONSIBLE PARTY - AMBER CARROLL

Finding #2022-005 ? Child Nutrition Cluster ? Unclaimed Meals (#10.553 and #10.555) Federal Grantor ? U.S. Department of Agriculture Pass-through Award Numbers ? 2022-304627-DPI-SB-546 and 2022-3046247-DPI-NSL-547 Pass-through Entity ? Wisconsin Department of Public Instruction Condition: Food service claims were not prepared by the District within the 60-day window for November 2021 breakfast meals and December 2021 lunch meals served. The auditor brought to the District?s attention during August 2022 fieldwork. Based on meals served, the November 2021 breakfast claim was calculated to be for $9,665 and the December 2021 lunch claim was calculated as $23,751. Effect: District did not receive reimbursement for meals served during November 2021 for breakfast meals served and December 2021 lunch meals served. Cause: The District did not have proper procedures in place for submitting monthly claims. The District began contracting with a Food Service Management Company starting in 2021-2022. Criteria: Monthly breakfast and lunch reimbursement claims should be made within the 60-day time frame. Procedures should be in place to ensure accurate claims are made timely. Recommendation: Policies and procedures should be implemented to ensure meals are claimed in compliance with federal requirements and within the 60-day time frame. Response: On January 30, 2023, the District requested a one-time waiver requests with DPI to claim the meals that were previously missed. The November 2021 breakfast claim was for $9,665 and the December 2021 lunch claim was for $23,751. DPI approved payment on the one-time exceptions in February 2023 and payments were made to the District in March 2023. The District will establish policies and procedures to ensure meals are claimed in a timely manner and in compliance with requirements. Contact Person: Robert Antholine, Phone number: 262-537-2211, Email: rantholine@randall.k12.wi.us Anticipated Completion: June 30, 2023

Condition: There were three Education Stabilization Fund construction projects performed by a contractor. Grant expenditures for the projects totaled $770,436. (ESSER II - $401,545 and ESSER III $368,891). There was not a prevailing wage clause in the contracts and certified payrolls were not received. Questioned Costs: $770,436. 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 of 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 the wage requirement applied to these construction projects. Effect: Potential reimbursement for costs that did not follow the wage rate requirements. Context: The PA, HVAC, and water heater construction projects began in May, June, and September 2021, respectively, before the District was aware of wage rate requirements. After becoming aware of the requirement, there were no further construction projects. Recommendation: Establish controls to comply with wage rate requirements related to the Education Stabilization Fund. Response: The District became aware of wage rate requirements after finishing the project. Before bidding any future construction projects more than $2,000, the request for bid and contract will include a prevailing wage rate clause. Certified payrolls will be received for any such contracts. Contact Person: Tim Zacharias Anticipated Completion: June 30, 2023

2022-003 Cash Management ? Internal Control and Compliance over Reimbursement Requests and Close Outs City?s Corrective Action Plan: City will follow its grant management policies to ensure close outs are submitted and prepared in a timely manner and monitor all grant agreements to ensure the grant is received or performance requirement is met. Responsible Person: Ray Beeman, Director of Administrative Services Expected Implementation Date: July 1, 2023

2022-002 Cash Management ? Internal Control and Compliance over Drawdown Requests City?s Corrective Action Plan: City will follow its grant management policies and procedures to ensure drawdown requests are submitted and prepared in a timely manner. Responsible Person: Ray Beeman, Director of Administrative Services Expected Implementation Date: July 1, 2023

Finding 2022-003: Cash Management Contact Information of Responsible Party: Tonya Pierre, General Manager Corrective Action Plans: The District will review and monitor debt compliance requirements throughout the year to ensure that timely decisions can be made to ensure compliance. the District will discuss increase the water and wastewater rates again to insure they are producing sufficient revenue to pay the district expenses. Start Date: April 2023 Target End Date: July 2024 Status: 50% Completed

Finding 2022-003 ? Special Education Cluster ? Cash Management Contact Person Responsible for Corrective Action: Abigail Lindsey Contact Phone Number: 765-853-5464 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Upon receiving invoices from K12 for programs funded through reimbursement grants, Union will issue payment immediately upon receiving reimbursement. Anticipated Completion Date: 06/30/2023

Finding: During a review by the external auditors of the tally sheets utilized by the clubs for meals served and submitted to the finance department for input into the billing system used by the Department of Education (DOE) for reimbursement, it was discovered that an incorrect number of meals was keyed into the system for one club. The number of meals submitted was higher than what the club had originally reported and resulted in an overpayment received from DOE. Corrective Actions Taken or Planned: The organization, with oversight from Kay Ridgard, Controller, immediately contacted DOE and let them know of the error. DOE made the corrective adjustment in their system and recovered the overpayment by reducing the upcoming September 2022 payment due to the organization by the amount of the overpayment received. There was a complete review of the internal process used in the billing of DOE for meals for each location. The process for submission for reimbursement is outlined below with changes highlighted: 1. Tally sheets sent from the clubs are reviewed by the Accounts Payable Associate (Procurement Coordinator when hired) to ensure that there are no addition errors. 2. Numbers from the tally sheets are entered into an Excel file to give summary totals for the organization and this is used by the Accounts Payable Associate to input data into the DOE system. 3. The Controller (or Manager) reviews the excel file before the data is input into the DOE system to ensure it accurately reflects the tally sheets. 4. Data is input in the DOE system and reports are generated showing the accepted submission that will be reimbursed. 5. The Controller (or Manager) performs a second review to ensure the submitted data match the previously reviewed Excel file.

Finding 2022-002 ? Federal and State Findings and Questioned Costs Corrective Action Plan: Edit check reports from the district?s student information syste, Infinite Campus, will be provided on a monthly basis, no later than the 5th of the month for the preceding month. Any errors listed on the reports will be researched and corrected by the Food Service Director or Assisitant Food Service Director. After all meal sales errors are corrected the final reports will be provided to the Director of Business Services no later than the 10th of the month. These reports will be used to make the monthly federal (USDA) food service claims and retained as documentation for the claims. Person(s) Responsible: Director of Business Services and Food Service Director. Timing for Implementation: August 2022.

CORRECTIVE ACTION PLAN - JUNE 30, 2022 Finding 2022-002: Immaterial Compliance Federal Award Finding This finding is caused by the District?s Food Service Fund?s fund balance being over the USDA?s threshold of 3 months average expenditures. The District is fully aware of this situation and has a spend down plan in place to help alleviate the excess fund balance down to a reasonable level and anticipates the completion date for the corrective action plan be before the end of the 2022-23 fiscal year. The persons responsible for the corrective action are Cathy Kierczynski, the food service director and Katy Xenakis-Makowski, Superintendent. The plan for monitoring adherence is the food service director and business manager will work together to assess where the fund balance is after all of the projects from the spend down plan are completed. Condition: This finding is caused by the District?s Food Service Fund?s fund balance being over the USDA?s threshold of 3 months average expenditures. The USDA requires that the ending balance of the non-profit school food service fund does not exceed three months? average of operating expenses [7 CFR Part 210.14(b)]. Corrective Steps Taken: At this time, the District has a spend down plan in place with the State of Michigan to help alleviate the excess fund balance down to a reasonable level. Anticipated Completion Date: At the end of the 2022-23 Fiscal Year. Monitoring: The plan for monitoring adherence is the food service director and superintendent will work together to assess where the fund balance is after all of the projects from the spend down plan are completed. Name of Responsible Person for Further Information: Cathy Kierczynski, Food Service Director and Katy Xenakis-Makowski, Superintendent. Questioned Costs Related to this Finding: None.

Lakewood Public Schools respectfully submits the following corrective action plan for the year ended June 30, 2022. Auditor: Maner Costerisan 2425 E. Grand River Avenue, Suite 1 Lansing, MI 48912 Audit Period: Year ended June 30, 2022 District Contact Person: Pam Behling, Director of Finance The finding from the June 30, 2022 schedule of findings and responses are discussed below. The findings are numbered consistently with the number assigned in the schedule. Finding - Federal Award Findings and Question Costs Finding 2022-001 Considered a significant deficiency Recommendation: The District should implement a budget, as well as the required corrective action plan, for the 2022-2023 school year that will adequately reduce the food service fund balance. Action to be taken: Management agrees with the finding and we are in the process of developing a plan to spend down the food service fund balance. Items being considered is improving outdated equipment and enhancing/expanding health food options. Date of Completion: The District?s spend down plan is anticipated to be completed by June 30, 2024. Kitchen equipment availability is severely limited due to national supply chain delays. The installation of this equipment is also limited based on times when school is not in session. These are the two primary factors why the District anticipates it will take multiple years in-order to complete its spend down plan.

FINANCIAL STATEMENT & FEDERAL AWARD FINDINGS 2022-001 Recommend continued evaluation and enhancements to limited segregation of duties over financial reporting Auditor?s recommendations: While the implementation of these additional procedures is of significant importance and an improvement, we would continue to recommend management evaluate additional enhancements and review of established policies and procedures to ensure risks are minimized as best possible (cost benefit) and to levels acceptable by the Board of Trustees. We would recommend management and the Board?s continued evaluation include, but not be limited to the following: ? Organizational and operational structure of the Foundation and the in relationship to the School. (Business Manager lack of segregation of duties). ? Evaluate more formalized budget and actual reporting directly from the computerized financial management system; limiting the use of decentralized creation of summaries and reports, which will allow for more streamlined reporting of activity. ? Recommend posting of payroll activity processed through the third-party payroll provider to the financial management system on a weekly basis, rather than monthly basis. We recommend further streamlining the documentation for each posting thereof into one source document. Additionally, we recommend payroll activity between the third-party payroll provider and the ledger be reconciled and reviewed on a routine basis. ? We recommend evaluation of check signing authority and adopted thresholds for dual signatures ($5,000). Based upon the current year audit, excluding the renovation project costs, the majority of the School?s non-salary expenditures are below the dual signature threshold. ? We recommend evaluation of use of debit card linked to School?s account. While utilized to a limited extent, management should evaluate risks/benefits (debit card direct access to account funds) against other methodologies (i.e., credit card). Management should evaluate with financial institution. ? We recommend procedures addressing reimbursement of expenditures to individuals for credit card purchases (require additional proof of actual payment (i.e., of statement) and be made only after the transaction/event has taken place and proof of attendance). ? We recommend management review adopted policies and procedures surrounding federal award programs and compliance thereto, be enhanced by additional review to OMB Uniform Guidance and the Compliance Supplement to further delineate procedures directly with OMB guidance and the applicable requirements associated with each federal award program the School receives annually. Based upon our conversation with the Business Manager during the current audit, the Board of Trustees is continuing the process of evaluating additional procedure enhancements, and assessments of overall financial operations, inclusive of those involving the Foundation. It is important that this continue as an annual process and be documented accordingly. Management should refer to the federal ?Green Book? and Internal control- Integrated Framework published by COSO in updating and assessments of established internal controls over financial reporting and compliance. Action Taken: The Global Learning Charter Public School Administration and Board of Trustees acknowledge that the limitations present with the segregation of financial duties are the direct result of the size of the school?s financial operation. We have worked diligently to create responsible oversight measures, and while the Board of Trustees remains confident in the increased oversight that was implemented in the previous fiscal year, we will continue to seek ways to enhance our procedures. To this end, GLCPS has already put into place many of the recommendations outlined in the finding including source document reports from Infinite Visions provided to the Board of Trustees, weekly payroll posting, and an enhanced process for reimbursement documentation. Moving forward, GLCPS will also be revising its policies and procedures guide for both federal awards and general operations to review areas where additional checks and balances can be implemented. The Global Learning Charter Public School Foundation will also be reviewing the composition of its Board of Directors with the goal of creating a clear separation in oversight between the School and Foundation.

Views of Responsible Officials and Planned Corrective Actions: Claims will be reviewed for accuracy by a second individual before they are submitted in the future. Also, the District reimbursed $37,145.07 to NDE in October 2022.