Corrective Action Plans

2020-01: Segregation of Duties Name of contact person: Katie Sponberger, Executive Director Corrective Action: Duties and functions will be reviewed to determine where segregation needs to occur. The duties will be separated as much as possible and alternative controls will be implemented to compensate for lack of segregation. The costs of segregating certain duties exceeds the benefit and therefore, nonfinancial employees will be trained to provide some assistance in these areas. Proposed completion date: The Board will implement the above procedure immediately.

Finding 2022-001 PROGRAM INCOME ? CFD #93.224 (Significant Deficiency in Internal Control over Compliance) Response: Corrective Action Plan The Operation Department will conduct a verification of the sliding fee scale. In their internal monthly Sliding Fee Discount audit process, the Site Manager is to review and verify each patient application, to the current Federal Poverty Level, to ensure patient is receiving the correct discount. Attached is a copy of policy and procedure for this corrective action plan.

Recommendation: Training of staff should be performed to bring the staff up to date with the implementation of all residual receipts compliance requirements. Action Taken: The Organization will request approval from HUD to pay back the excess residual receipt balance.

Findings Related to the Financial Statements Reported in Accordance with Government Auditing Standards Finding Number: 2022-001 ? Internal Control over Financial Close and Reporting Responsible Persons: Business Manager, Angelita Clitso Anticipated Completion Date: July 2023 Planned Corrective Action: The school has had turnover in the Business Office and in administrative positions. The business office will correct and reconcile all accounts timely.

Finding: 2022-5 Name of contact person: Renae Alston Corrective Action: Employees will be provided a refresher training on documentation of time sheets. Supervisors will be provided training on the review and reconciliation of data between the timesheet and the daysheet. Proposed Completion Date: March 31, 2023

2022-101 ? Reporting (Significant Deficiency, Compliance Finding) Federal Funding Agency: U.S. Department of Housing and Urban Development; U.S. Department of Treasury Pass Through Agency: Arizona Department of Economic Security and Central Arizona Shelter Services; Maricopa County, Arizona Title: Emergency Solutions Grant Program; Coronavirus State and Local Fiscal Recovery Funds. Assistance Listing #: 14.231; 21.027 Award Year: July 1, 2021 through June 30, 2022 Questioned Costs: N/A Person Responsible: Petrona Zickgraf, Controller, St Joseph the Worker Estimated Completion Date: 05/31/2023 Planned Corrective Action: We have established policies and procedures by which expenses being charged to each federal award are now summarized on an ongoing basis, to general ledger accounts in our accounting system so that at all costs that were charged to each award can be easily determined.

Finding 2022-002 Late Reporting and Noncompliance with Reporting Requirements Name of Contact Person: Leslie Young Corrective Action Plan: The district business office has had significant staffing transitions within the last year and was without a business manager for six months, despite a continual search for qualified applicants. It was identified that the district did not provide one quarterly reimbursement request to the State of Alaska in a timely manner during this period. The district business office is now fully staffed, with new staff hired in August, and is currently addressing this matter. Staff are being trained to support timely submission of quarterly reporting. Proposed Completion Date: 6/30/2023

Corrective Action Plan February 16, 2023 Cognizant or Oversight Agency for Audit Independence Community College respectfully submits the following corrective action plan for the year ended June 30, 2022. Name and address of independent public accounting firm: Jarred, Gilmore & Phillips, PA, P.O. Box 779, 1815 S Santa Fe, Chanute, Kansas 66720. Audit period: Year ended June 30, 2022. The findings from the February 16, 2023 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Finding: 2022-001 ? Improper Classification of Transactions Condition: Reconciliations of most balance sheet accounts found transactions that were improperly classified and/or not recorded at all. These balance sheet account reconciliations resulted in material amounts of general ledger adjustments posted after year end and through the date of the audit report. Recommendation: Additional training for staff is needed in the area of financial statement preparation and use of the general ledger software. Views of responsible officials: We are in agreement and the proper training will be added. Policies will also be updated to include additional detail & steps to assure that misclassifications can be traced and reclassified in a timely manner, along with assuring reconciliation of all balance sheet accounts can properly occur monthly. Finding: 2022-002 ? Reporting Condition: During our testing of financial reports to the grantor, it was determined a breakdown in internal controls occurred, because staff did not keep support for amounts reported to grantors from the accounting system. Staff tried to re-create the reports withthe accounting system and amounts were materially different than originally reported to the grantor. Recommendation: Additional training for staff is needed in the area of internal control over reporting. All reports filed should be thoroughly reviewed and approved before issuance. This review would include tying amounts reported to attached support from the accounting system. Views of responsible officials: We are in agreement and policies will be updated to include the proper internal controls are in place. It will also be required that all supporting GL documentation be included for all reporting aspects for Grants from the draws to annual reports. If the Oversight Agency for Audit has questions regarding this plan, please call Jonathan Sadhoo, Vice President for Administration & Finance, at (620) 332-5412. Sincerely, Independence Community College Independence Community College -

CORRECTIVE ACTION PLAN YEAR ENDED JUNE 30, 2022 (Unaudited) CORRECTIVE ACTION ? FINDING 2022-005 ? TIMELY DRAW DOWN GRANT REIMBURSEMENTS Anticipated Date of Completion: April 1, 2023 Name of Contact Person: Robin Vail, Business Manager Corrective Action Plan: Expenditure reports and cash requests are being processed to catch up. Provide more training for central office staff so they can take on more tasks.

May 31, 2023 Finding 2022-001: Cash Management ? Disbursement U.S. Department of Education ? Education Stabilization Fund ALN 84.425F COVID-19 Institutional Portion Criteria: Non-federal entities must minimize the time elapsing between the transfer of funds from the US Treasury or pass-through entity and disbursement by the non-federal entity for direct program or project costs and the proportionate share of allowable indirect costs, whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means (2 CFR section 200.305(b)). Condition: Management implemented a financial management system that meets the specified standards for fund control and accountability, but the system failed to ensure disbursement of funds within the required timeframe. Questioned Costs: None noted. Repeat Finding: This is not a repeat finding. Cause: Management did not accurately identify the required timeframe of disbursement for funds received under the Institutional Portion subprogram. A mitigating factor is the uniqueness of the Institutional Portion subprogram. Effect: Institutional Portion funds used to defray expenses associated with coronavirus was not disbursed within the required 3 calendar days of the drawdown from ED?s G5 grants system. Planned Corrective Action Management concurs with the finding. Since the program is not applicable to the organization after the issuance date of the financial statements, no corrective action is necessary. Responsible person: Sholom Goldstein, Executive Director Completed date: May 31, 2023

Finding ref number: 2022-002 Finding caption: The District did not have adequate internal controls for ensuring compliance with allowable activities and costs, and restricted purpose 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: The District does not concur with the finding or questioned costs. The district had every intention to provide these iPads to the preschool students who were not in the district technology plan. However, the pandemic caused many distribution delays. The decision was made to provide these students with older surplus iPads. Since the iPads shipment was expected after the students returned to school. The District will work with the FCC to resolve this finding. District does not have any other Emergency Connectivity Grants. Anticipated date to complete the corrective action: 11/1/2023

Finding Number: 2022-005 ? Approval Of Expense Reimbursement Submittals Corrective Action Plan: All expense reimbursements should have approval in writing. The findings were at a time when Academica NV was shorthanded, and since all open positions have been filled. Grant managers send a request for approval of a reimbursement request to schools, once ready. Approvals are now received in writing, via email, prior to any reimbursements being submitted. Personnel Responsible for Corrective Action: Nachum Golodner, Academica Director of Accounting Anticipated Completion Date: June 30, 2023

Sharon Armijo Clerk ? PO Box 197 (575) 533-6400 Joyce Laney Treasurer ? PO Box 407 (575) 533-6384 Lillie Laney Assessor ? PO Box 416 (575) 533-6577 Keith Hughes Sheriff ? PO Box 467 (575) 533-6222 Lucinda Howell Probate Judge 100 Main St. Reserve, New Mexico 87830 Buster F. Green Commissioner District No. 1 Audrey H. McQueen Commissioner District No. 2 Haydn Forward Commissioner District No. 3 Commission Office PO Box 507 ? (575) 533-6423 FAX (575) 533-6433 Loren Cushman County Manager 2022-001 (2018-003) Procurement of Goods and Services (Significant Deficiency) Condition ? During our test work of a sample of 35 transactions we noted the following: County not following disbursements policy and procedures: ? No PO, PO not attached (6 of 35) P cards (6 of 20) ? 1 month ? no documentation of commission review of monthly check register ? Invoice referenced but not attached ? Taxes paid on goods (6 instances) ? 2 instances with no supporting documents Procurement ? (under $20,000) ? 1 No PO ? 1 No supporting documents Procurement ? (> $20,000 & <$60,000) ? 3 instances of only 1 quote ? 2 No supporting documents The County continues to have documentation retention or application issues, no progress from prior year. Corrective Action Plan ? Staff has been proactive in ensuring that purchase orders and invoices are attached to checks and has created a filing system for processed checks. Staff has been proactive in confirming receipts of goods/services, requesting receipts from purchasers, and generally following the NM Procurement Code and County Procurement Policy. Checks are currently being backed up electronically along with purchase orders and other supporting documentation of purchase receipt and justification. Staff has been proactive in obtaining NTTC forms for businesses and utilizing vendors with current state contracts. Staff has created a binder for documenting monthly review of purchases by Commission including maintain original signatures of Commission members. In instances where procurement has found it impossible to obtain three quotations, staff has maintained adequate documentation of best efforts made to obtain said quotes and has conversed with legal to determine that best efforts is adequate in these instances. Responsible Position: Chief Procurement Officer/Accounts Payable Timeline for Correction: Completed Catron County Corrective Action Plan (continued) 2022-002 (2018-006) Local Government Budget Management System (LGBMS) Reporting Incomplete (Other Non-Compliance Repeated with modification. Condition ? The County did not include all budget expenditures in the LGBMS system. The County reported total budgeted expenditures for their original budget in LGBMS of $10,965,065. The actual budget amounts that should have been reported were $11,239,091. The County did not present a revenue budget to the Commission for approval when the Commission approved the expenditure budget. In addition the County did not enter the revenue budget into the budget to actual reporting system to aid in budget monitoring. The County continued to have budget compliance, monitoring and reporting issues in the current year, and therefore no progress has been made regarding budget in the current year. Corrective Action Plan ? We did hire a Finance Director and then almost immediately put him to work as Interim County Manager. A full time County Manager finally started March 22, 2023. The Finance Director?s goal is to have the County?s reporting to the DFA a routine matter ? accurate and on time. Responsible Position: Finance Director Timeline for Correction: June 30, 2024 2022-003 (2018-002) Maintenance of Capital Assets (Material Weakness) Repeated. Condition ? ? Construction In Process is not maintained and lacks a consistent process for adding to the depreciation schedule. ? Depreciation schedule was not updated or calculated for the entire fiscal year. The County digressed in its maintenance of capital asset records and documentation. Corrective Action Plan ? One of the goals of the new Finance Director is a complete review of Catron County?s capital asset records. Responsible Position: Finance Director Timeline for Correction: June 30, 2024 Catron County Corrective Action Plan (continued) 2022-004 Personnel File Maintenance (Significant Deficiency) Statement of Condition ? We tested a sample of 10 Payroll transactions and noted the following: ? Three instances (3 of 10) where the current payrate was not substantiated by a personnel action form. ? One personnel file did not include any current documents ? all documents were for 2017 and prior. ? One personnel file lacked a PERA membership application. Corrective Action Plan ? The County has made available training through NM EDGE where we can learn to improve procedures, and best practices to develop strategies on completing internal controls. Auditors did provide valuable feedback on what was necessary to complete Personnel files and those suggestions will be implemented form there on. Responsible Position: HR/Payroll Clerk Timeline: June 30, 2023 2022-005 Solid Waste Receipts Audit Trail (Significant Deficiency) Statement of Condition ? The Solid Waste department?s receipting system lacks a clear audit trail. ? No schedule indicating receipts by customer, only a total page of deposit amount (5 deposits for dump fees totaling $9,696) ? Cash deposits were co-mingled with other cash deposits for the day and therefore not traceable specifically to solid waste cash receipts (all solid waste receipts ? 10 receipts tested totaling $19,392) ? No receipts are issued for each customer (receipts only issued upon customer request) No copies or records of receipts that were issued were maintained (all solid waste receipts ? 10 receipts tested totaling $19,392) Corrective Action Plan ? 1. Solid Waste Clerk will attach a corresponding customer receipt to all spreadsheets. 2. Treasurer?s Office has reconciled the second issue listed above. 3. Convenience Center Attendants will immediately receipt all customers. Responsible Position: Solid Waste Clerk/Coordinator Timeline: April 30, 2023 2022-006 Travel and Perdiem Procedures and Regulations Not Properly Followed (Other Non-Compliance) Statement of Condition ? We tested a sample of 10 travel transactions and noted the following: ? 5 instances where no travel form (per policy) was attached to approve travel $2730.64. ? 1 instance where mileage rate reimbursed was $.46 per mile rather that $.45 per mile ? total over allowable reimbursement was $1.25. Corrective Action Plan ? New travel forms have been created pursuant to DFA Per Diem rates from Memo dated April 12, 2022. New staff has been proactive in ensuring that travel requests are handled timely and properly. Responsible Position: Accounts Payable Timeline: Completed Catron County Corrective Action Plan (continued) 2022-007 Lack of Maintenance of Grant Documentation (Material Weakness) Statement of Condition ? During our test work of federal award reimbursements and expenditures and New Mexico capital Outlay Appropriations, documentation and supporting invoices and reimbursement requests as well as grant award agreements were not available or present in County records. Reimbursement requests are not timely. County is not following award guidelines to maintain the accounting of grant activity for reimbursement requests, expenditures and supporting documentation. The County has numerous awards that are not managed and status of awards is not current. Corrective Action Plan ? The County hired a Finance Director. Even though he spent most of his first eight months as Interim county Manager, he was able to assemble grant documents and collect grant funds that had been waiting for years to be claimed. As we now also have a full time County Manager, this part of the Finance Director?s job should improve even more. Responsible Position: Financial Director Timeline: June 30, 2023 2022-008 (2020-007) Late Audit Report ? (Other Non-Compliance) Repeated with modification Statement of Condition ? The audit report was submitted to the State Auditor?s Office after the county due date of December 1, 2021. This finding remains essentially the same as prior year. Corrective Action Plan ? We are glad the auditor is taking part of the responsibility here. However, if the County can keep a consistent staff in the Commission Office following proper procedures, the audit will definitely go smoother and quicker. Responsible Position: Finance Director Timeline: June 30, 2024

Views of Responsible Officials and Planned Corrective Actions The timesheets did not reflect the correct hours charged to the program. After discussions with program management, it was discovered that correct communication to staff had not been completed regarding proper program and grant payroll coding for work done on the program. This has been corrected. The Foundation?s contract administrative staff is working more closely with program staff to ensure for each payroll that the time worked on programs is properly reflected on timesheets that are approved by employees and managers. Necessary changes are communicated between program and contract administrative staff to ensure that timesheets reflect work hours properly. Personnel responsible for implementation: Steven Hartman Position of responsible personnel: Associate Director, Contract Accounting Date of Implementation: August 31, 2023

Action item - Title 2022-002 - Time Elapsing Between Transfer of Funds and Disbursements Date Identified: March 2023 Status: (Open; In-process) In-process Description Time elapsed between the transfer of funds from the US Department of Education and UPPR disbursement, instances where found in which the time elapsed exceeds a reasonable time. Grantee Required Action: PUPR should identify a time control method to assist the University in reducing the time elapsing between the transfer of funds from the Federal awarding agency and its disbursements. Identified Root Cause: Lack of controls over the cash management requirement to maintain the advance method. Grantee resolution plan: Transfers and Disbursement process will be reviewed to minimize the time between drawdown and disbursement and comply with Federal regulations. Funds are regularly monitored to ensure that only needed funds for immediate use are drawdown. Drawdowns are initiated when accounting department send the Grant monthly reconciliation to Federal and State Funds Administration Office, Compliance officer reviews the reconciliation and Director of Federal Funds Administration determine needed funds to be requested. A new Enterprise Resource Planning (ERP) software it?s under implementation and will address this issue as part of the implementation process. Anticipated completion date: September 2023 Name and Title of contact person responsible for corrective action: Pablo Salom Portela- Director, Federal and State Funds Administration Office Phone: 787-622-8000 ext. 683 Email: psalom@pupr.edu

Finding Number: 2022-001 Condition: The College drew down an estimated amount for student and institutional portion prior to the funds being disbursed to students or used for allowable expenditures. Planned Corrective Action: The College will review its cash management policies and in the future follow U.S. GAAP and the uniform guidance. Contact person responsible for corrective action: Tom Reynolds, Associate Vice President of Business Services and Deputy Treasurer Lakeland Community College Anticipated Completion Date: As soon as possible moving forward starting 12/19/2022

Finding Reference Number: 2022-002 Concur or Do Not Concur: Concur Agree or Disagree with Auditor Recommendations: Agree Actions Taken or Planned on the Finding: Management agrees with the finding. The residual receipts account deficiency was funded on March 8, 2022 in the amount of $12,428. Management will ensure that the residual receipts account is properly funded in the future. Completion Date: March 8, 2022

Finding Reference Number: 2022-001 Concur or Do Not Concur: Concur Agree or Disagree with Auditor Recommendations: Agree Actions Taken or Planned on the Finding: Management agrees with the finding. The residual receipts account deficiency was funded on February 25, 2022 in the amount of $15,254. Management will ensure that the residual receipts account is properly funded in the future. Completion Date: August 1, 2022

Response and Corrective Action Plan: The District will implement a process to review and retain meal claim reporting documentation as outlined by the Iowa Department of Education and Office of Management and Budget. Kevin Posekany, June 30, 2023.

2022-001: Reporting Corrective Action: Due to ever-evolving processes, LCCC did not fully comprehend all reporting nuances for the HEER program. The Comptroller and Director of Sponsored Awards will continue to perform in-depth reviews of all reporting guidance and requirements to ensure accurate reporting. Anticipated Completion Date: June 30, 2023 Contact Persons: Nola Rocha, Comptroller and Jennifer McCartney, Director of Sponsored Awards and Compliance

2022-002 Condition and Criteria: The U.S. Department of Agriculture regulation located at 7 CFR Part 210, Subpart C, Section 210.14(b) states that the food service fund is to limit its net cash resources to an amount that does not exceed 3 months average expenditures. The cash and due from other funds balances in the Academy's food service fund exceeded the allowable amount at June 30, 2022. Cause: While the appropriate Academy employees were aware of the applicable compliance requirements, the Academy did not spend the necessary amount to reduce fund balance to the allowable limit. Effect: Noncompliance with the requirements of the Code of Federal Regulations. Recommendation: The Academy should develop and implement a plan to reduce its net cash resources to the allowable limit. Management Response: The The Academy through its management company has developed processes to ensure all costs related to the operation of the food service fund are properly recorded. Additionally, the Academy subsequent to year, made significant purchases to upgrade the kitchen equipment further spending the necessary amount to reduce the fund balance to the allowable limit.

Recommendation: The final payables listing that is approved and matches the grant drawdown amount should be retained to document proper approval. Planned Corrective Action: Management agrees with the findings and will review personnel needs with the objective of being able to better support the office staff and perform monitoring activities

Finding 2022-004 Contact Person Responsible for Corrective Action: Rhonda Morgan, FSD Contact Phone Number: 765-240-2386 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Frontier School Corporation will have the Elementary and Jr/Sr High Kitchen Managers pull the monthly reports from eTrition for breakfast and lunch meals served for their respective schools. A blank Monthly Worksheet will be provided to each Kitchen Manager to be filled out using the data report from eTrition, the foodservice software. The reports and worksheets from each school will be given to the Food Service Director. The FSD will have independently prepared a complete report using data pulled from eTrition including both schools. The FSD will then compare the elementary Kitchen Manager?s report with the Master Report. The FSD will then compare the Jr/Sr High Kitchen Manager?s report with the Master Report. The Master Report will then be presented to each Kitchen Manager for their approval after checking to see that the data matches, initialing and dating the Master Report. The Food Service Director will then submit the Monthly Claims Report to CNPweb. The Corporation Treasurer will also have access to all data collected to ensure proper reportig. All data and internal checks will be filed in the Food Service Director?s office.. Anticipated Completion Date: The CAP will be in place by March 24, 2023 in preparation for the Monthly Claim of March 2023 to be the first month these internal controls will be implemented.

CORRECTIVE ACTION PLAN YEAR ENDED JUNE 30, 2022 Millersburg Area School District submits the following corrective action plan in response to the finding listed in Section III of the Schedule of Findings and Questioned Costs for Federal Awards for the year ended June 30, 2022: Significant Deficiency in Internal Control and Compliance Finding: Finding 2022-001 ? Cash Management and Reporting Condition: The District incorrectly filed its June 2021 quarterly report which in turn resulted in PDE halting payments and placing grant #013-210254 in dormant status. The District did not file any further quarterly returns in a timely manner within the 10-day requirement or the final expenditure report in a timely manner within the 30-day requirement. The District did not file the final expenditure report for grant #013-220254 in a timely manner within the 30-day requirement. The District did not file the final expenditure report for grant #200-200254 in a timely manner within the 30-day requirement. The District did not file the quarterly reports for grant #223-210254 and #225-210254 in a timely manner within the 10-day requirement. Views of Responsible Officials: The District will review and establish procedures to ensure that all required quarterly cash on hand and final expenditure reports are properly completed within the required time periods. Planned Corrective Action: A new federal programs coordinator has been hired and the district has consulted with an experienced federal programs coordinator to train that individual. Procedures are now in place to ensure that the District files all quarterly cash on hand reports within 10 days of quarter ending and final expenditure reports within 30 days after the funds are expended, but no later than 30 days after the ending date of the project. All existing compliance issues related to filing deadlines are being addressed and corrected. Person Responsible for Corrective Action Plan: Mr. Michael A. Lyter, Federal Programs Coordinator Anticipated Completion Date: June 30, 2023 Sincerely, Eric S. Petery, Business Manager

2022-004 Internal Control over Compliance and Compliance with Cash Management Requirements Contact: Chris Holmes Title: Controller Phone Number: 202-235-1938 Estimated Completion Date ? ongoing Corrective Action PSI is refining its method for calculating drawdowns on federal awards that are near the end of the period of performance dates. For such awards, the Accounts Receivable team in Washington will work with the Program Management Teams to obtain specific projections of trailing costs from country offices.