Corrective Action Plans

8. Deficiency 2022-008 ? Instance of Noncompliance ? Meal County Tally a. An instance of noncompliance was identified over compliance requirement L from the 2022 Office of Management and Budget (OMB) Compliance Supplement. Recordkeeping of the daily supporting documentation for the monthly claims was found to not be in compliance with federal requirements. The District should develop and implement policies and procedures to ensure that all original daily meal counts and tallies used to support reimbursement reports are maintained for the appropriate amount of time. b. Plan of Action: The District will review, develop and implement procedures to provide the required reporting. c. Timeframe: Fiscal year 2023-24

5. Deficiency 2022-005 ? Material Weakness ? Evidence of Review Needed a. A material weakness in controls over compliance was identified for controls over compliance requirement L from the 2022 Office of Management and Budget (OMB) Compliance Supplement. Controls over reporting were found not to be implemented. The District should develop and implement policies and procedures to ensure that all monthly reimbursement reports are reviewed in a timely manner and documented appropriately. b. Plan of Action: The District will implement internal controls to address the need for additional oversight of monthly meal reimbursement reports. c. Timeframe: August 2023

Brookwood School District 167 07-106-1670-02 CORRECTIVE ACTION PLAN FOR CURRENT YEAR AUDIT FINDINGS Year Ending June 30, 2022 Corrective Action Plan Finding No.: 2022-002 Condition: The District's expenditure population was less than amounts claimed by $5,617. The District was unable to identify and support expenditures for this difference. Plan: The District will implement additional review procedures to ensure that expenditure claims submitted for reimbursement agree to supported transactions within the accounting system for allowable costs under the award. Anticipated Date of Completion: June 30, 2023 Name of Contact Person: Mr. Kevin Slattery, C.S.B.O. Business Manager

6. 2022-006 Cash Management - Early Head Start The District did not maintain supporting documentation for interim grant drawdowns made during the year. Grant revenues were not reconciled with general ledger grant expenditures until year end. When reconciled at year end, $3,505 was overdrawn and due back to the State of Michigan. District Corrective Action: Assistant Superintendent will approval all drawdowns and record documentation in grant notebook.

Condition: There was one Education Stabilization Fund construction project performed by a contractor. Grant expenditures for the project paid by the Education Stabilization Fund totaled $158,462. There was not a prevailing wage clause in the contract 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 project. Effect: A reimbursement request was made for expenditures that did not comply with wage rate requirements. Questioned Costs: $158,462 Auditor's Recommendation: Establish controls to comply with wage rate requirements related to the Education Stabilization Fund. Grantee Response: The District will comply with the wage rate requirements for the Education Stabilization Fund going forward. Contact Person: Morgan Preuss Anticipated Completion: 6/30/2023

FINDING 2022-005 Information on the federal program: Subject: COVID-19 ? Education Stabilization Fund ? Cash Management, Other Matters Federal Agency: Department of Education Federal Program: Elementary and Secondary School Emergency Relief (ESSER II) Fund Assistance Listing Number: 84.425D Pass-Through Entity: Indiana Department of Education Compliance Requirement: Cash Management Audit Finding: Material Weakness, Noncompliance, Other Matters Condition: 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 cash management compliance requirements for the COVID-19 ? Education Stabilization Fund. Context: During our audit procedures, we noted that in fiscal year 2021, the School Corporation had drawn down $108,445 more in ESSER II funds than what they had expended. The School Corporation received $297,500 of ESSER II funds during fiscal year 2021, but had only disbursed $189,055. The School Corporation spent $107,361 of the remaining funds during fiscal year 2022 and had an ending balance of $1,084 as of June 30, 2022. The ESSER II grant is a cost reimbursement grant and therefore, the School Corporation should not have drawn down these funds prior to the expenses being incurred. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Superintendent and/or the Superintendent?s designees will not request funds from reimbursable grants before expenditures have been made by the corporation. Responsible Party and Timeline for Completion: The responsible parties are the Superintendent and/or the Superintendent?s designees. The corrective action will take place immediately (3/15/2023).

FINDING 2022-004 Information on the federal program: Subject: Child Nutrition Cluster ? Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Condition: 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 reporting compliance requirement. Context: We noted that for two claims in a sample of four, there was no formal evidence of the sponsor claim reimbursement summary being reviewed by someone independent of who prepared the sponsor claim reimbursement summary prior to submission. We noted that for one claim in a sample of four, the meal counts were over/under claimed for the month. We noted that in October 2020 the School Corporation had overclaimed lunches by 175 meals and underclaimed breakfast by 156 meals. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Superintendent is now utilizing the personalized login on CNP Web to review claims before final submission. The superintendent will also email approval of claims to the FSMC Food Service Director upon submission and approval by the superintendent on CNP Web. Responsible Party and Timeline for Completion: The Superintendent and FSMC Food Service Director will be the responsible parties and the corrective action will take place immediately (3/15/2023).

CORRECTIVE ACTION PLAN OF CURRENT AUDIT FINDINGS June 30, 2022 Finding 2022-001 ? Child Nutrition Cluster ? Reporting Contact Person Responsible for Corrective Action: Thomas McFarland Contact Phone Number: 574-342-2255 Views of Responsible Official: We do not concur with the finding. Description of Corrective Action Plan: While the claim does not have a second signature indicating review before submission, the procedures that Triton follows, which include segregation of duties, justify that someone else reviewed the data, before submission. The data is compiled by the building secretary and submitted to the Business Manager. The Business Manager reviews the claim and logs into the online submission website with a secure user name and password to enter the data. While we believe that the secure user name and password is just as much proof as a signature that the data has been reviewed, we will begin having the document signed by a second person in order to satisfy this requirement Anticipated Completion Date: 3/15/23

Oversight Agency for Audit, Piazza Apartments respectfully submits the following corrective action plan for the year ended September 30, 2022. Name and address of independent public accounting firm: Bellows Associates, P.A., 5401 N University Drive, Suite 201, Coral Springs, Florida 33067 Audit period: October 1, 2021 through September 30, 2022 The findings from the September 30, 2022 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. SECTION III ? FINDINGS AND QUESTIONED COSTS ? MAJOR FEDERAL AWARD PROGRAMS AUDIT FINDING No. 2022-001: Section 202 Supportive Housing for Elderly, CFDA 14.157 Recommendation: The Project should return the excess withdrawals to the replacement reserve account. Action Taken: Management has incorporated 9250 training into both the new hire training and the annual managers conference training. If the Oversight Agency for Audit has questions regarding these plans, please call Christine Harris at 954-835-9200. Sincerely yours, Christine Harris Accounting Manager

Contact Person Responsible for Corrective Action: Michelle Keene Contact Phone Number: (812) 384-4386 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The School Corporation will implement a formal review of the Education Stabilization Annual Report and ensure the amounts reported agree to the underlying records. Anticipated Completion Date: Effective for the next Annual Report due

Single Audit Finding 2022-002 Non-Material Non-Compliance ? Allowable Costs See Corrective Action Plan for chart / table.

Oversight Agency for Audit, Partnership for Seniors, Inc., respectfully submits the following corrective action plan for the year ended September 30, 2022. Name and address of independent public accounting firm: Bellows Associates, P.A., 5401 N University Drive, Suite 201, Coral Springs, Florida 33067. Audit period: October 1, 2021 through September 30, 2022. The finding from the September 30, 2022 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. SECTION III ? FINDINGS AND QUESTIONED COSTS ? MAJOR FEDERAL AWARD PROGRAMS AUDIT FINDING NO. 2022-001: Section 202 Supportive Housing for the Elderly, CFDA 14.157 Recommendation: The Project should implement procedures to appropriately and timely identify surplus cash at each fiscal year-end and deposit those funds in the residual receipts account within 90 days after the Project?s fiscal year-end. Action Taken: The former accountant did not request a timely transfer of the surplus. All current accountants have been trained on the proper surplus cash procedures. If the Oversight Agency for Audit has questions regarding these plans, please call Christine Harris at 954-835-9200. Sincerely yours, Christine Harris Accounting Manager

Purchase needed equipment.

Federal Audit Clearinghouse RE: Prairie State College Corrective Action Plan Fiscal Year Ended June 30, 2022 Finding 2022-001 ? Controls Over Preparation of the Schedule of Expenditures of Federal Awards Criteria Uniform Guidance (2CFR?200) dictates that management is responsible for identifying and reporting federal expenditures on the Schedule of Expenditures of Federal Awards (SEFA) for all federal grants received. Condition The initial SEFA provided by the College omitted $67,225 of Higher Education Emergency Relief Funds. Planned Corrective Action The College continues to invest in hiring qualified compliance and accounting staff members. A new Manager of Accounting Services has been hired and the grant accountant position has been posted and candidates are being reviewed. The College will continue to focus on compliance and accurate reporting for all grants and processes, establishing best practices for the institution. Contact person (s) responsible for corrective action: Cheri Taylor-Lawton, Controller and Director of Business Services Anticipated completion date: December 31, 2023 Finding 2022-002 ? Financial Reporting Criteria Financial reporting is the responsibility of management and includes the preparation of footnote disclosures, financial statement preparation, and overall maintenance of the general ledger. The inability of an organization to demonstrate proficiency in financial reporting is considered to be a control deficiency that would be considered to be a material weakness. Condition While the College demonstrated its responsibility for preparing financial statements and footnote disclosures, the following errors/control weaknesses were noted: ? Approximately $4.4 million of capital expenditures incurred from 2019 through 2021 for which restricted cash was to have been utilized was not transferred from restricted to unrestricted accounts until 2022. ? The initial lease schedules that we received appeared to have been rolled over from the prior year and did not reflect the implementation of Governmental Accounting Standards Board (?GASB?) Statement No. 87 ? Leases. However, the College was able to ultimately implement the standard. ? An audit adjustment was needed to increase the personal property replacement tax revenue and receivable by $120,369. ? Net investment in capital assets reported on the draft statement of net position was understated and unrestricted net position overstated by $4.8 million of unspent bond proceeds held in the Community Development Board escrow accounts. ? On the Uniform Financial Statements, $3.6 million of the Higher Education Emergency Relief Fund grant that was used for revenue replacement was misclassified. Planned Corrective Action As noted above, the College is investing in hiring qualified financial staff members to fill current, vacant positions. The finance team will continue to exercise diligence in this area by allowing added time for the review process. Contact person responsible for corrective action: Cheri Taylor-Lawton, Controller and Director of Business Services Anticipated completion date: December 31, 2023 Finding 2022-003 ? Inadequate Controls Over and Compliance with Reporting Requirements Assistance Listing: 84.425 Program Title: Education Stabilization Fund Subprograms: Higher Education Emergency Relief Fund (?HEERF?) Governor?s Emergency Education Relief (?GEER) Federal Agency: Department of Education Criteria There are three components to reporting for HEERF: 1) public reporting on the (a)(1) Student Aid Portion; (2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. The CARES, CRRSAA, and ARP institutional quarterly portion reporting requirements involve publicly posting completed forms on the institution?s website. The forms must be conspicuously posted on the institution?s primary website on the same page the reports of the IHE?s activities as to the emergency financial aid grants to students (Student Aid Portion) are posted. The GEER grant agreement requires quarterly reporting of expenditures to be submitted no later than 30 calendar days following the three-month period covered by the report. Condition The HEERF Q2 2022 Institutional Portion report was not posted to the College?s website by the due date of July 10, 2022. The report was posted only after the College was informed by the auditors that it had not been posted. In addition, when comparing the College?s drawdowns and expenditures to the amount reported on the Q2 2022 Student Aid Portion report, a $2,437,286 variance, with drawdowns exceeding the amount reported on the quarterly report, was noted. The drawdowns were accurate with the report amount in error. Quarterly reporting for GEER was submitted late as follows: quarter ending 9/30/21 submitted 100 days late, quarter ending 12/31/21 submitted 101 days late, quarter ending 3/31/22 not submitted. No expenditures were incurred and no report was submitted for the quarter ending 6/30/22. For GEER II, no expenditures were reported for the quarters ending 9/30/21 and 12/31/21 and one report was submitted for both quarters on 2/18/22. In addition, $6,219.49 was reported as expended on the GEER?s 3/31/22 quarterly report and in the general ledger but the amount was never requested for reimbursement. Finally, total expenditures on the two GEER II quarterly reports were $12,069.44 less than total expenditures per the general ledger detail and the schedule of expenditures of federal awards but was ?trued up? in the next reporting period according to College staff. Planned Corrective Action The College did not have a single, dedicated grant manager for CARES funding allocations as with other institutional grants. Since receiving the initial allocation, the continued personnel challenges have plagued the financial team. Corrective action will be taken at the institution to implement best practices, ensuring processes are identified and appropriate training and backup are in place to avoid future errors. Contact person responsible for corrective action: Cheri Taylor-Lawton, Controller and Director of Business Services Anticipated completion date: December 31, 2023 Dr. Judy Mitchell, Interim Chief Financial Officer

2022-005 Schedule of Expenditures of Federal Awards Recommendation: Reimbursement grant revenue accounts should be reconciled to the underlying grant expenditures on the grant request and other reports on a timely basis. Corrective Action: We concur. Prior to July 1, 2019, Organization staff did not adequately set up or maintain the accounting software being used. During the year new staff added multiple accounts to ensure that the data in the system matched data showing on government reports. Frequent reconciliations and implementation of policies and procedures will allow data to be accurate in the system and match data that has been submitted to the government from worksheets done in the past.

2022-004 Grant Expenditures Recommendation: The coding of expenditures in the general ledger accounting system should reflect the amounts requested under each grant. Additionally, reconciliations should be performed regularly to ensure expenditures are not duplicated or eligible expenditures are not omitted from grant reimbursement requests. Corrective Action: We concur. Processes have been put into place to make sure that variances do not occur. Any questions with allowable costs have been referenced in 2 CFR 200 subpart E used for a common procedure for all expenses. The executive director and office manager will review expenditures prior to the distribution of office expenses from among the funds, which will ensure accuracy before the request is made. This will also eliminate the number of correcting entries which need to be adjusted in the expenses.

CORRECTIVE ACTION PLAN 2022-001 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 will create and submit 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 Kristy Donner, the food service director and Nicole Darby, the business manager. The anticipated completion date of the corrective action plan is before the end of the 2023 fiscal year. The District anticipates certain projects may require lead time for getting new equipment or renovation projects completed and therefore will plan accordingly to make sure projects get completed prior to the end of the fiscal year. 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.

The City agrees with this finding and will work with Grant Administrators to ensure that reports are submitted in accordance with the guidelines set by state and federal agencies. The City will continue to work with Grant Administrators to ensure that reporting requirements are submitted and provide supporting documentation to prove the timing of submissions.

The City agrees with this finding and will work with Grant Administrators to ensure that reimbursement requests are in compliance with the guidelines set by state and federal agencies. Due to the City?s limited budget and restrictions set by Grant Agencies, the City and the Grant Administrators agreed to wait to submit invoices or group invoices to meet the required threshold for reimbursements. The Grant Agencies have not delayed or rejected payment of any invoices due to the delay in submissions.

Name of Responsible Individual: Aaron Carlson, Executive Director of Financial Aid Corrective Action: Corrective action was taken. The University has since transitioned to a new Financial Aid processing system, Jenzabar Financial Aid (JFA), that automatically sends updates daily, making regular uploads of files to COD much simpler. Completion Date: Completed

Name of Contact Person: Jennifer Phillip Corrective Action Plan: Records will be reviewed monthly by two individuals to insure they are complete. Back up documentation shall be kept in a secure location where at least two other budget supervisors are aware and have access to same. Proposed Completion Date: January 31, 2023

Corrective Action Plan Responsible Party: Barbara Staggs, Chief Financial Officer Finding 2022-001 The required annual deposit to the residual receipts account was not made. This deposit is required to be made within 60 days following year-end. Comments on the Finding and Recommendation Management is in agreement with this finding and the related recommendation. Action(s) Taken or Planned on the Finding Surplus cash is calculated on a monthly basis. All residual receipts are required to be deposited in a separate federally insured account within 60 days of the fiscal year-end. Written instructions are included on the surplus cash calculation spreadsheet to ensure compliance.

Finding: 2022-005 Federal Agency name: Department of Agriculture Program Name: Communities Facilities Loans and Grants Cluster Federal Financial Assistance Listing: #10.766 Compliance Requirement: Special Tests and Provisions Finding summary: Management maintained the reserve amount in the pooled investment fund account which was not established as a separate bookkeeping account nor as a separate bank account. Although the pooled investment funds includes marketable securities backed by the full faith and credit of the United States, based on the portfolio mix of the investment pool, additional cash balances on hand need to supplement the investment pool to adequately fund the reserve. The Organization has excess cash available. Further, there is no secondary level of review being performed over the monthly reconciliation of the reserve account. Responsible Individuals: Carmen Weber, Administrator and Joyce Schwingler, CFO Corrective Action Plan: The reserve amount was withdrawn from the pooled investment fund and deposited into an account at the First State Bank of Roscoe, Eureka Branch, which is FDIC insured. Administrator will review, sign and date all bank statements received for the reserve account at the First State Bank of Roscoe, Eureka Branch. Anticipated Completion Date: December 2022

Finding 2022-004: Cash Disbursements (Significant Deficiency) Name of Auditee?s Contact Person Responsible for Corrective Action: Gary Mendell Corrective Action Planned: Management is in the process of implementing Bill.com, which will require review and approval by a direct supervisor or higher, to ensure proper segregation of duties for approval of expenditures. Management will also reinforce the importance of employees providing the appropriate invoices or supporting documentation for all expenditures submitted for payment. Expenditures will not be paid without the appropriate supporting documentation. All approvals will be tracked through an online system. In addition, management will reinforce the importance of reviewing the timing of when expenditures are incurred, to ensure they are recorded in the appropriate fiscal year. Anticipated completion date: November 2023

Finding 2022-003: Cash Management - Cash Requisitions (Material Weakness) Name of Auditee?s Contact Person Responsible for Corrective Action: Gary Mendell Corrective Action Planned: Prior to any cost reimbursement invoices submitted, the invoices will be reviewed and approved by the State Manager or a Director of State Engagement to ensure amounts requested for reimbursement were incurred prior to the reimbursement request and are related to costs that were properly allocated to the federal program. Anticipated completion date: October 2023