Corrective Action Plans

Finding 2022-003: Information on the Federal Program: 84.42SF - Higher Education Emergency Relief Fund - institutional Portion, 84.42SE- Higher Education Emergency Relief Fund - Student Portion Compliance Requirement: Cash Management Type of Finding: Material Weakness Criteria: Under 2 CFR Section 200.303(a), non-federal entities must establish and maintain effective internal controls to provide reasonable assurance that the entity is managing the federal awards in compliance with statutes, regulations, and the terms and conditions of the award. Additionally, under HEERF award, grantees are under an obligation to minimize the time between drawing down funds from GS and paying obligations incurred by the grantee (liquidation). If a HEERF grantee is using HEERF grant funds to make financial aid grants to students, the Department may evaluate for compliance with the rule grantees who have not drawn down the funds from GS and not paid the obligations (the financial aid grants to students) to the students within fifteen calendar days. The Supplemental Agreement published by the U.S. Depaitment of Education pe1tammg to Supplemental Grant Funds identifies that funds not disbursed within 3 days of being drawn down may be subject to heightened scrutiny by the U.S. Department of Education, the institution's auditors, and/or the Department's Office of the Inspector General. Internal controls over compliance with direct and material compliance requirements should be sufficient to prevent or detect and correct material noncompliance in a timely manner. Condition: During testing of cash management compliance requirements, it was noted that Jacksonville College had drawn down the entirety of the HEERF awards in 2021 and recorded $1,302,078. In 2022, the College had expended the majority of the funds but continues to report a deferred liability of $42,887 related to prematurely drawn-down HEERF funds. Context: Jacksonville College did not review compliance requirements related to drawing down of grant funds and over-drew funds related to the HEERF grant. Questioned Costs: $42,887 remaining in Deferred Income. Cause: A material weakness in internal control over compliance exists relating to cash management. Personnel responsible for maintaining compliance with cash management did not have sufficient education on the cash management requirements. In addition, there was no review over compliance with cash management requirements to monitor compliance. Effect or Potential Effect: The College was not in compliance with Federal requirements of the COVID-l 9 Education Stabilization Fund. 44 Repeat Finding: Not a repeat finding. Recommendation: We recommend that the College put into place controls that require review of grant requirements prior to drawing down funds. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The College regrets that this was the process that was used. The failure to review the requirements for the draw-down of HEERF funds was managed by a previous administration. When it was discovered that the proper process was not used by the previous administration, immediate controls and policy reviews were put into place to avoid any further issues of non-compliance. Specifically, Cabinet held weekly meetings where the Executive Vice President was responsible to update Executive Administration with the current status on the utilization of funds. Since that time, a new president has been put into place by the Board of Trustees. The president is committed to following whatever requirements are mandated for all federal programs. In collaboration with all Cabinet members, relevant departments on campus, and a financial consultant, the College will avoid any further issues of non-compliance.

Finding 2022-003 Federal Agency Name: Department of Education Program Name: Special Education-Grants for Infants and Families Federal Financial Assistance Listing #84.181 Compliance Requirement: Other Federal Agency Name: Department of Health and Human Services Program Name: HRSA COVID-19 Claims Reimbursement for the Uninsured Program and the COVID-19 Coverage Assistance Fund Federal Financial Assistance Listing #93.431 Compliance Requirement: Other Federal Agency Name: Department of Homeland Security Federal Emergency Management Agency Program Name: Disaster Grants - Public Assistance (Presidentially Declared Disasters) Federal Financial Assistance Listing #97.036 Compliance Requirement: Other Finding Summary: SRHC does not have an internal control system designed to provide for a complete and accurate schedule of expenditures of federal awards being audited. Therefore, significant federal programs were excluded from the schedule. Responsible Individuals: Kevin Hoffman, Controller Corrective Action Plan: Management will implement controls to ensure a complete and accurate schedule of expenditures of federal awards and that the schedule will be reviewed by an individual independent of the preparer. Anticipated Completion Date: 9/30/2023

The District will expend any excess funds as soon as administratively possible and monitor profitability (or lack thereof) of the food service program on a quarterly basis to ensure revenues do no exceed expenditures.

Purchase Needed Equipment

We agree with this finding. NWCH was successful in adding needed staff in 2023, but was unable to hire a degreed accountant or controller, or to contract with an accounting firm for oversight of the accounting function. Bookkeeper training was provided from Shelter Resources Financial Manager in February 2023. NWCH is researching CPA firms in order to contract a qualified controller with expertise in real estate holdings relevant to NWCH. NWCH has been actively searching for a qualified CPA to hire or contract with since 2021, however, due to capacity constraints and overwhelmed CPA firms, NWCH has been unsuccessful. Efforts to hire experienced accounting personnel continues.

The HIDTA Financial Manager, in conjunction with the City's Finance Assistant, will request smaller dollar amounts with new advances in order to liquidate the prescribed HIDTA guideline of 21 days.

Management deposited $1,875 back into the Project?s Reserve for Replacement account on December 9, 2022.

The School Lunch fund has excess fund balance on hand due to the additional reimbursements provided during the COVID-19 pandemic. The District is currently reviewing the programs aging equipment and will create a plan to use these funds to support the program's infrastructure in addition to it facilitating minimal increases in school lunch prices.

COVID-19 Provider Relief Fund ? Assistance Listing No. 93.498 Recommendation: The Organization should review all expense amounts entered into the reporting portal submission to ensure the amounts are accurate and agree to internal supporting documentation. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management has implemented a process that should ensure all future reports are accurate and reviewed prior to submission. This includes a review and verification of expenses that are being reported to ensure they are accurately entered and supported by internal records. Further, management has identified additional infection control related costs which were not claimed during the reporting periods submitted. These costs have been isolated to ensure they are not available for use in future periods. Name of the contact person responsible for corrective action: Mark Sperka, CEO Planned completion date for corrective action plan: March 2023

2022-002 Significant Deficiency Name of contact person: Erin Benson, Executive Director Corrective Action: The Organization has been placed on high-risk status by Maine DOL and adopted new policies in conjunction with Maine DOL. The Organization is working with Maine DOL to develop a program to properly train and oversee staff and board members to ensure drawdowns are filed timely and accurately. Proposed implementation date: The corrective action plan has been implemented and is being followed at this time.

Finding 2022-001: Reporting ? Significant Deficiency/Non-Compliance Federal Program ? Airport Improvement Program Federal Agency ? U.S. Department of Transportation Pass-Through Entity ? Not Applicable Assistance Listing Number ? 20.106 Federal Award Year ? December 31, 2022 Criteria: The Uniform Guidance requires written policies/procedures in order to comply with certain requirements. These areas include allowability of costs, cash management, procurement, subrecipient monitoring and conflicts of interest. Condition: As part of our audit of the Authority's Airport Improvement Grant Program, it was noted that the Authority did not adopt written policies/procedures surrounding certain areas to comply with the requirements of the Uniform Guidance. Questioned Costs: Not applicable. Context: The Authority does not have in place a number of written policies/procedures surrounding their administration of federal awards. Cause: Authority management failed to adopt the required written policies/procedures. Effect: The Authority is not in compliance with the written policy/procedure requirements of the Uniform Guidance. Corrective Action Taken: Since the finding was identified during the audit, the Authority has initiated a plan to prepare and file the written policies/procedures required of the Uniform Guidance. Expected Completion Date: December 31, 2023 Designated member responsible for corrective action plan: James Meyer, Authority Director

Finding 2022-012 Personnel Responsible for Corrective Action: Assistant Comptroller - Brian Huggins Anticipated Completion Date: July 2022 Corrective Action Plan: The University has implemented a process to document all allowable costs prior to funds being draw down that will be prepared by a Senior Accountant, reviewed by the Assistant Comptroller and Comptroller for 2nd review, and sent to the CFO for final review and approval prior to requesting reimbursement/cash drawdowns from the Federal Government. Moreover, the University is implement a quarterly grant review process with the grant Principal Investigator to review grant expense allocations. G5 drawdowns will take the second Monday of each month.

Finding 2022-010 Personnel Responsible for Corrective Action: Assistant Comptroller ? Brian Huggins Anticipated Completion Date: June 2023 Corrective Action Plan: The University Finance Compliance Officer will create and publish an operational calendar listing name of report, department responsible for reporting, reporting deadlines, and governing agency. The Finance Compliance Officer will work with the respective departments to ensure accurate and timely completion of all reports.

Finding 2022-004 Personnel Responsible for Corrective Action: Assistant Comptroller ? Brian Huggins Anticipated Completion Date: July 2022 Corrective Action Plan: The University has implemented a process to document all allowable costs prior to funds being draw down that will be prepared by a Senior Accountant, reviewed by the Assistant Comptroller and approved by the Comptroller prior to requesting reimbursement/cash drawdowns from the Federal Government. Moreover, the University is implement a quarterly grant review process with the grant Principal Investigator to review grant expense allocations. G5 drawdowns will take the second Monday of each month.

This appears to be an isolated incident. Management plans to submit corrections for that specific month.

VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTIONS: Management acknowledges the finding, but believes it was the result of unfortunate timing surrounding an unusual situation. Accordingly, management concludes that corrective action is not necessary and does not expect this situation to arise again in the future.

Management response/corrective action plan: Maine school districts are required to pay the MEPERS Unfunded Actuarial Liability (UAL) contribution plus a health insurance fee for wages paid from federal funds to Teachers and Educational Technicians. In the rush to quickly hire and onboard dozens of new employees who were hired in response to the pandemic, many newly hired teachers and educational technicians were not correctly coded as federally funded employees in the payroll system. The result was the requisite employer UAL contributions and health insurance fees were not paid until the error was discovered later. Procedures have been revised and the Director of Business Services now assigns payroll codes for all new hires to prevent a recurrence.

The Accounting Manager will work in conjunction with the Junior Staff Accountant and/or Grant Assistant to ensure monthly, quarterly, and semi-annual reconciliations have appropriate supporting documentation to reconcile to internal statistics and the reports include evidence of a preparer and reviewer. Procedures will be revised as necessary and documented.

Written policy will be adopted to reflect the process being undertaken to minimize the time elapsing between the transfer of funds from the US Treasury. Current process of carrying out detailed analysis of anticipated expenses for the quarter will be reflected in the policy.

Finding 2022-001 - Significant Deficiency Internal Control Over Compliance: Concur or Do Not Concur with this Finding - Concur; Agree or Disagree with auditor recommendations - Agree; Completion Date or Proposed Completion Date - September 30, 2022; Actions Taken or Planned on the Finding - Management has strengthened and improved internal control over compliance with respect to required residual receipts deposit.; Contact Person First Name - Dawn; Contact Person Last Name - Cole;

Finding #2022-002 ? Grant Program: Department of Transportation Airport Improvement Program ? Assistance Listing #20.106 The Great Falls International Airport Authority agrees with the audit recommendations. This was a unique program that unlike other grants allowed us to be reimbursed for operating expenses and likely will never be seen again. The Authority normally receives grants for capital projects each year through the Airport Improvement Program (?AIP?). The Airport employee?s professional construction managers for these projects, such that the normal process is that a contractor invoice is submitted, reviewed and recommended for payment by our construction manager and then submitted for reimbursement from AIP. The COVID relief grants used to reimburse operating costs did not follow this normal process and controls. We will correct the issue identified by re-structuring the process of handling and reconciliation of the grant funds. Airport Accountant, Chayleen Person, will be the one handling the federal funding reimbursement requests. Actions, responsible individuals, and anticipated completion date: - Airport Accountant, Chayleen Person, will handle the reimbursement requests and the review of the federal funding. - Airport Accountant, Chayleen Person, will reconcile these funds monthly to ensure the federal account matches our GL account.

2. Finding 2022-002 a. Comments on the Finding and Each Recommendation We recommend that Management should establish internal controls and procedures to ensure that required residual receipts reserve deposits are made timely. b. Action(s) Taken or Planned on the Finding The management agent will perform and review the surplus cash calculation and deposit any surplus cash in the residual receipts account within the 90 day requirement.

Finding 2022-002 - (Supportive Housing for the Elderly 14.157); Concur or Do Not Concur with this Finding - Concur; Agree or Disagree with auditor recommendations - Agree; Completion Date or Proposed Completion Date -September 26, 2022; Actions Taken or Planned on the Finding - Management has strengthened and improved internal control over compliance with respect to required residual receipts deposit.; Contact Person First Name - Dawn; Contact Person Last Name - Cole.

Finding 2022-001 - (Supportive Housing for the Elderly 14.157); Concur or Do Not Concur with this Finding - Concur; Agree or Disagree with auditor recommendations - Agree; Completion Date or Proposed Completion Date -September 16, 2022; Actions Taken or Planned on the Finding - Management has made the required deposit into the residual receipts account.; Contact Person First Name - Dawn; Contact Person Last Name - Cole.

Corrective Action The current School Business Administrator started mid-way through the audited year. Corrective action has already been implemented to ensure that reimbursement claims are submitted timely. The claimed meals will be addressed with the Food Service Company that submits the claims. Person(s) Responsible Kristina Edgar, School Business Administrator Planned Completion Date June 30, 2023