Corrective Action Plans

2022-003 Performance Reporting Microloan Program ? Assistance Listing No. 59.046 Recommendation: We recommend management develop procedures to ensure the required reporting is completed within the timeline allowed by the granting agency. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: New staff has been trained and the reporting calendar updated. CFO/COO to monitor and submit in a timely manner. Name(s) of the contact person(s) responsible for corrective action: Nasibu Sareva (CEO) and Felicia Ravelomanantsoa (CFO/COO) Planned completion date for corrective action plan: 12/31/2023

FINDING 2022-004 Contact Person Responsible for Corrective Action: Wendy Marples, County Auditor Contact Phone Number: 812-338-2142 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: All future reporting of the Coronavirus State and Local Fiscal Recovery Funds will be reviewed for accuracy by a second staff member of the Auditor?s office prior to submission. The report will be signed and dated by both the preparer and reviewer. All documentation will be maintained to help prevent any future inconsistencies. Anticipated Completion Date: April 2024

The Financial Aid Office and the Registrar's Office will work closely together to resolve the NSLDS reporting discrepancies. We are currently in the process of hiring a Compliance Coordinator that will serve as a bridge between the Financial Aid Office and the Registrar's office that will monitor and audit the reporting process for errors and discrepancies monthly. From here, if there are any discrepancies or inconsistencies, the Financial Aid Office and the Registrar's Office will work together to understand any patterns that exist so that our processes can be reevaluated and tightened to ensure ongoing compliance. Based on the review of information from last year's similar finding (2021), it was determined after the fact that Webster University had both reported the enrollment information correctly and in a timely manner to the Clearinghouse, however, the Clearinghouse frequently reported glitches and outages that prevented reporting to NSLDS in a timely manner. Going forward the Compliance Coordinator will monitor enrollment reporting, as well as the timing of the Clearinghouse's enrollment reporting to NSLDS. If it is determined that enrollment reporting via the Clearinghouse continues to be discrepant, Webster University will explore other methods of reporting that are more conducive to timely and accurate enrolment reporting to NSLDS.

CFDA# 21.027 ? COVID-19 Coronavirus State and Local Recovery Funds Finding 2022-015 The Annual Project Expenditure Report required as a Tier 5 reporter under the American Recovery Plan (ARP) State and Local Fiscal Recovery Funds (SLFRF) was not submitted. City?s Response: City personnel thought they had successfully submitted the required report in a timely fashion. Views of Responsible Officials and Corrective Action: The City Clerk thought that the report had been submitted in a timely fashion, ut could not produce documentation to verify the submission. Since the City?s expenditures are not included on the download of annual reporting data, the City assumes that the report was not properly submitted. Future report submissions will be made on a timely basis with documentation retained to demonstrate compliance with those reporting requirements. Name of Responsible Person: Frankie Roberts, City Clerk Name of City Contact: Frankie Roberts, City Clerk Projected Implementation Date: April 30, 2023

View of Responsible Officials and Corrective Action Plan ? The Academies have procedures in place requiring review and approval. Management believes that it was a limited number of items that may not have had written approval from a school administrator or the controller. Management will ensure that review and approval is properly documented by signature or an electronic approval.

2022-024 Improve Controls over Period of Performance Federal Agency: U.S. Department of Health and Human Services State Entity: Department of Behavioral Health and Developmental Disabilities (DBHDD) Corrective Action Plans: The Department will continue to improve the internal controls to ensure that expenditures are liquidated within 90 days of the end of the period of performance as required. The Department will update processes and procedures associated with period of performance requirements and provide training that outlines close-out processes associated with the specific grant awards. DBHDD will update the internal controls related to period of performance no later than June 30, 2023. Estimated Completion Date: June 30, 2023 Contact Person: Kenneth Ward, Director of Internal Audit Telephone: 404-884-5486; E-mail: kenneth.ward@dbhdd.ga.gov

2022-032 Improve Controls over Employer-Filed Claims Federal Agency: Various Federal Agencies: U.S. Department of Homeland Security U.S. Department of Labor State Entity: Department of Labor (GDOL) Corrective Action Plans: The Georgia Department of Labor disagrees with this finding. The Employer Filed (Partial) Claims (EFC) program originated in the late 1960?s and was designed to allow employers with short term, temporary periods of lack of work for their employees to retain their workforce when work resumes. This is a program that many large manufacturers in Georgia rely on when they have temporary plant shutdowns and have for decades. When GDOL has attempted in the past to limit this program, we have met strong resistance from Georgia?s manufacturers. This program optimizes our ability to process and pay mass numbers of claims more quickly, such as what occurred at the beginning of the pandemic. EFCs may be filed by an employer with respect to any complete pay-period week during which an otherwise full-time employee works less than full-time, due to lack of work only, and earns an amount not exceeding his/her unemployment insurance weekly benefit amount. Such claims shall not be submitted or allowed for vacation days regardless of whether such vacation days were requested by the employee or established by the employer. Effective March 19, 2020, a temporary, Emergency Rule 300-2-4-05(1), containing Rule 300-2-4-.09(1) was signed which required employers to electronically submit EFCs on behalf of their employees whenever it is necessary to temporarily reduce work hours or there was no work available for a short period of time. Employers were allowed to file such claims for full and part time employees whose earnings had been reduced. In July 2020, the Rule was sunset and employers were no longer required to file EFCs. EFCs may be filed online by single entry or upload or paper. An employer may submit EFCs for regular state unemployment insurance programs including available extended benefits programs with the same eligibility requirements as regular UI, such as Pandemic Emergency Unemployment Compensation (PEUC) and State Extended Benefits (SEB), given all regular UI entitlement is exhausted. By electing to submit EFCs on behalf of the individuals, the employer is responsible for attesting to the employment status and weekly earnings of the individual for the EFC submitted. An affidavit certifying that the employer has obtained earnings from other employment as well as other requirements must be completed before EFCs can be entered or uploaded. Individuals for which EFCs are submitted are considered to be still attached to the employer and are exempt from the requirement to register for employment services per Georgia Employment Security Law Rules 300-2-4-.02. Such individuals are not required to be nor certify on a weekly basis to be able, available and actively seeking work. The GDOL disagrees that we would not provide the requested information to the auditors. The data requested relates to an ongoing federal criminal investigation. GDOL did not provide the data with concerns that dissemination of the data to a third party could jeopardize the ongoing criminal investigation and create legal risk for GDOL. GDOL stated that the auditors should obtain permission from the United States Department of Justice as a condition to dissemination of the data. GDOL did not receive any confirmation that the auditors had discussed the matter or coordinated with the US Department of Justice. Even though there have been some publicized indictments, the US Department of Justice has confirmed to GDOL that the investigation is ongoing and future indictments are anticipated. Notwithstanding, GDOL reiterates it would be happy to share the relevant data in its possession with assurances that the auditors will not publicize or disseminate any of the audit data without first consulting with the US Department of Justice. GDOL is also happy to cooperate with the auditors and provide information relating to how GDOL discovered the methods and schemes used by the fraudsters; however, GDOL has serious concerns about any publication of such information or of any other specific vulnerabilities in GDOL?s systems that would serve to encourage or perpetuate additional unemployment insurance fraud. Summary When we identified employer fraud schemes, we followed the guidance issued by United States Department of Labor (USDOL) and collaborated with the United States Department of Labor Office of Inspector General (OIG) to investigate these cases. Effective December 6, 2021, the EFC process was revised to require individuals (employees) to complete an EFC profile to include a real-time identity verification before payments can be made. Employers are responsible for submitting the request for the payment to certify to the individual?s employment status, but the individuals must certify their identity and personal information for the claim to be processed. Employees are notified when a claim is filed on their behalf and provided instructions for their portion of completing the EFC process. The MyUI Customer Portal dashboard provides all the EFC correspondence sent to the individual as well as a status of the profile set up and identify verification. Prior to the implementation of the EFC profile requirement, GDOL utilized the Social Security Administration (SSA) crossmatch and Systematic Alien Verification for Entitlement (SAVE) verification processes to verify the identity of claimants where employers submit claims on their behalf. GDOL has no plans to stop utilizing the EFC program as it is an effective and popular program among employers with a successful 60-year track record. GDOL greatly appreciates the feedback and recommendations and will consider this information in future endeavors to modernize and update system and business processes. Estimated Completion Date: December 6, 2021 Contact Person: Crystal Singleton, Policy and Procedure Manager Telephone: 404-232-3183; E-mail: Crystal.Singleton@gdol.ga.gov

2022-028 Improve Controls over Eligibility Determinations Federal Agency: U.S. Department of Labor State Entity: Department of Labor (GDOL) Corrective Action Plans: (1) Identity verification was not performed appropriately in eight instances. GDOL Response: The Georgia Department of Labor disagrees with these findings as it relates to identity verification. The auditors did not identify the type of identity verification procedures not performed or any identity verification procedures that GDOL was required to perform. There was not a mandatory requirement to complete identity verification at the time most of these applications were submitted as the majority of these claims were employer-filed claims (EFC). Identity requirements for EFCs were implemented at a later date. At the start of the pandemic, the identity proofing processes available were Social Security Administration (SSA) verification, Department of Driver Services (DDS) crossmatch and for non-citizens, Department of Homeland Security Systematic Alien Verification for Entitlement (SAVE). As applicable, these processes were performed on all initial regular and EFCs, which includes the eight instances. (2) Non-monetary determination was not performed in two instances. GDOL Response: Instance 1: A disqualifying non-monetary determination was released and disqualification was entered into the system. The system erroneously released a payment for the week in question. An overpayment was established in January 2023. Instance 2: Claim was processed but issue did not get added to the claim to address separation reasons. A non-monetary determination was released in November 2022 to allow benefits. All payable weeks have been processed. There was no detriment to the claimant as they were determined eligible nor was there any monetary loss to the State. (3) Proof of employment or self-employment or a valid offer to begin employment and proof of wages was not submitted by two Pandemic Unemployment Assistance (PUA) claimants. GDOL Response: The GDOL disagrees with the findings related to proof of employment or self-employment or a valid offer to begin employment and proof of wages was not submitted by two PUA claimants. Under the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), claimants did not have to provide proof of employment or self-employment. It was not until Continued Assistance Act (CAA) was enacted December 27, 2020 that such proof was required. The disqualification could not be applied retroactively, as outlined in Unemployment Insurance Program Letter (UIPL) No. 16-20, Change 4. Instance 1: Claimants who established PUA entitlement at the minimum weekly benefit amount were instructed to submit their proof of wages by email. Under the CARES Act, if claimants did not submit proof, federal requirements only allowed for payment of the minimum weekly benefit amount and no disqualification of benefits. The claim cited was originally established and remains established for the minimum weekly benefit amount. In accordance with CAA rules, the claimant was notified to provide proof of employment and wages for weeks paid on or after 12/27/20. To date, no proof has been provided by the claimant. The claimant has been disqualified effective 12/27/20 and an overpayment was established in January 2023. Instance 2: Claimants who established PUA entitlement with a weekly benefit amount greater than the minimum was based on wages entered by the claimant and/or wages reported by the employer. CARES Act only required proof of wages to be submitted. If claimants did not submit proof, federal requirements only allowed for payment of the minimum weekly benefit amount and no disqualification of benefits. Claims established at a higher weekly benefit amount had to be reduced to the minimum amount if no proof was provided. To date, no proof has been provided by the claimant cited. The claim was established above the minimum amount; therefore, benefits were reduced to the minimum amount. In accordance with CAA rules, claimants were notified to provide proof of employment and wages for weeks paid on or after 12/27/20. The claimant has been disqualified effective 12/27/20 and an overpayment was established in November 2022 for weeks paid over the minimum amount under CARES and weeks paid after 12/27/20 under CAA/American Rescue Plan Act (ARPA). (4) Claimants did not self-certify for benefits in 18 instances. GDOL Response: The GDOL disagrees with the findings Claimants did not self-certify for benefits in 18 instances. Employer-Filed Claims (EFC) are submitted by employers on behalf of the claimant. The employer is responsible for attesting to the employment status and weekly earnings of the claimant for the EFC submitted. An affidavit certifying that the employer has obtained earnings from other employment as well as other requirements must be completed before EFCs can be entered or uploaded. Claimants for which EFCs are submitted are considered to be still attached to the employer and are exempt from the requirement to register for employment services per Georgia Employment Security Law Rule 300-2-4-.02. Such individuals are not required to be nor certify on a weekly basis to be able, available and actively seeking work. Additionally, USDOL encouraged states to waive work search requirements for all claimants during the pandemic. (5) Claimant and payment information did not exist in the system of record in one instance. GDOL Response: The identifying information the auditors provided for this claim does not match any claims in our system. Therefore, we are unable to validate the auditor?s finding. Summary The information above is provided for your consideration in dispelling some of the audit findings. GDOL took immediate action to establish the federal UI programs and comply with federal guidance and regulations. There was not a mandatory requirement to complete identity verification at the time most of these applications were submitted. At the start of the pandemic, the identity proofing processes available were Social Security Administration (SSA) verification, Department of Driver Services (DDS) crossmatch and for non-citizens, Department of Homeland Security Systematic Alien Verification for Entitlement (SAVE). As applicable, these processes were performed on all initial regular and employer-filed claims (EFC). Beginning January 2021, PUA applicants were required to complete additional identity verification processes. Beginning in December 2021, all applicants were required to complete identity verification prior to filing a claim for UI benefits. Effective December 6, 2021, the EFC process was revised to require individuals (employees) to complete an EFC profile to include a real-time identity verification before payments can be made. Employers are responsible for submitting the request for the payment to certify to the individual?s employment status, but the individuals must certify their identity and personal information for the claim to be processed. Employees are notified when a claim is filed on their behalf and provided instructions for their portion of completing the EFC process. Additionally, as system deficiencies were identified, changes were made as quickly as possible to mitigate risks of improper payments. Automation of PUA claims was suspended and reviews were handled manually by staff before a determination was released. GDOL established task forces to develop and implement strategies to address the ramped fraud attempts to bypass system and procedural safeguards. We regularly attended fraud meetings with various federal agencies and unemployment agencies from other states to share best practices for combatting fraud. As resources permitted, we did our best to implement these best practices and strategies. Prioritizing system changes was challenging with the time constraints, necessity to build a program based on an established program that operated manually in our state and the demands of all other federal UI programs; but GDOL made every attempt to maximize our system capacity to accommodate the guidelines of each program requirements. Georgia greatly appreciates your time and consideration of our response to the findings and welcome you to contact us if you have any questions. Estimated Completion Date: December 16, 2021 Contact Person: Crystal Singleton, Policy and Procedure Manager Telephone: 404-232-3183; E-mail: Crystal.Singleton@gdol.ga.gov

Corrective action plan: For the annual UI access review, TWC will monitor the annual CAPPS Systems Access Privileges Certification in CAPPS to ensure timely completion. For the code developer/promoter system roles, IT will implement a new quarterly review of developer roles to ensure no staff member has both roles assigned to ensure separation of duties in the system roles. We are also looking at potential technical solutions that would automate and prevent staff being assigned certain roles based on separation of duties. Implementation date(s): February 28,2023 Responsible Persons: Heather Hall, CIO

Corrective action plan: The OOG?s Public Safety Office (PSO) Performance and Records Coordinator staff position, which is the position responsible for submitting the FFATA reports into the federal reporting system, was vacant at the time the May 2022 report was due. This position is now filled and PSO updated the written policy and procedure to include additional staff positions that will prepare the FFATA report in the event the Coordinator is unavailable. In addition, the FFATA policy has been updated to include dates by which certain steps in the process should be met. See excerpt from revised PSO Policy 5.40 FFATA: ?FFATA Reports are prepared by the Grants Administration Performance and Records Coordinator and will be reviewed by the appropriate Program Manager(s). The Grants Administration Director will review and approve reports prior to submission in the FFATA Subaward Reporting System (FSRS). In the event the Performance and Records Coordinator is not available to prepare the FFATA reports, either the Grants Administration Business Operations Specialist or the Grants Administration Compliance and Operations Administrator will prepare and route the reports for review. On or about the 5th day of the month in which the report is due, the Performance and Records Coordinator, or backup, will pull new award data and grant adjustment data from eGrants. On or about the 10th day of the month in which the report is due, the Records and Performance Coordinator, or backup, will route the report to the appropriate Program Manager(s) for review. On or about the 15th day of the month the report will be routed to the Grants Administration Director for review and approval. Monthly reports will be prepared and submitted at https://www.fsrs.gov/ no later than the last day of the current month for awards made during the prior month.? Implementation date(s): The vacant Performance and Records Coordinator position was filled in July 2022. The FFATA policy was updated February 3, 2023. Responsible persons: Zach Lohbauer, Performance and Records Coordinator Angie Martin, Director of Grants Administration

Corrective action plan: Texas Integrated Eligibility Redesign System (TIERS) - In order to bring password settings into compliance with the HHSC Information Security (IS) Security Policy, the TIERS Operations team released tool/method (113.0) successfully into production without any adverse impact. This release was completed on 09/24/2022 and contained the security requirements to restrict minimum allowed password changes from zero (unlimited) to one meaning users are allowed "only" one password change a day. This was verified by CliftonLarsonAllen LLP (CLA) auditors on 12/21/22. Screenshots were also provided to CLA auditors. Implementation date(s): September 24, 2022 Responsible Persons: Director, Information Technology (IT) Infrastructure Services

Finding 2022-002 - Eligibility - Significant Deficiency in Internal Control Over Compliance - Recommendation: We recommend the University amend procedures so in the event that packaging is done manually, there are added reviews over the student's aid awarded. - Corrective Action Plan: We accept Moss Adams' recommendation and if a situation arises where we must manually package a student, the procedure will include an additional review by another individual, either the Director or a Counselor, to review the package for accuracy. An internal review of FY22 indicated this was an isolated incident. - Anticipated Completion Date: Management will complete the Corrective Action Plan by June 30, 2023. - Individual Responsible: Oscar Jones, Director of Financial Aid.

The following are management responses to the internal control findings: 2022-001 Single Audit major Program - Material Weakness MCR Health has established a policy and procedures to review the contract and 0MB Compliance Supplement requirements for all Federal or state awards to gain an understanding of the compliance requirements and will have in place internal controls to ensure compliance. The review will be completed by the Finance and Budget Manager, (Tracy Brown), during the application process for each grant. This was put into place March 1, 2023. If anything needs to be addressed, please do not hesitate to give me a call at 941-776- 4008 x306.

Finding 2022-002: Significant deficiency in internal control over reporting. Summary: Although total award expenditures for the year agreed to the amount reported, quarterly reporting and annual reporting submitted for grant tracking did not match quarterly information as per accounting records. Corrective Action Planned: Written policies and procedures over the review and approval of Federal Award reporting will be updated to ensure complete and accurate reporting of award expenditures. Anticipated Completion Date: By Sept 30, 2023. Name of Contact Person Responsible for Corrective Action: Tammy Rash, Administrative Services Director

Finding 2022-001: Significant deficiency in internal control over procurement. Summary: There was no documented evidence that a contractor was required to comply with the prevailing wage requirement of the Federal Award agreement in one contract under the Federal Award. Corrective Action Planned: Written policies and procedures regarding procurement and grant compliance will be updated and implemented to ensure compliance with procurement terms and conditions of Federal Awards. Anticipated Completion Date: By Sept 30, 2023. Name of Contact Person Responsible for Corrective Action: Tammy Rash, Administrative Services Director

Finding 2022-003 Federal Agency Name: Department of Agriculture Program Name: Communities Facilities and Loans Grants Cluster Federal Financial Assistance Listing #10.766 Finding Summary: The Hospital does not have an internal control system designed to provide for a complete and accurate schedule of federal expenditures of federal awards being audited. As auditors, we were requested to assist with the preparation of the schedule. Responsible Individuals: Renae Karst, Chief Financial Officer Corrective Action Plan: It is not cost effective to have an internal control system designed to prepare the schedule of expenditures of federal awards. We requested that our auditors, Eide Bailly LLP, to assist with the preparation of the schedule of expenditures of federal awards. We have designated a member of management to review the drafted schedule of expenditures of federal awards, and we have reviewed with and agree with the final Schedule of Expenditures of Federal Awards. We will begin developing a Grant Award Policy and Procedure Manual around tracking and reporting of awards to ensure accurate and up-to-date communication of award requirements. This communication will include implementing additional processes to improve our internal controls over identifying and reporting of expenditures in compliance with the Schedule of Expenditures of Federal Awards (SEFA) if applicable. We will provide staff training annually for any updates or adjustments to the policy. Anticipated Completion Date: Ongoing

Finding 2022-004 Federal Agency Name: Department of Agriculture Program Name: Communities Facilities and Loans Grants Cluster Federal Financial Assistance Listing #10.766 Finding Summary: Management maintained the reserve amount in the cash sweep general fund account which was not established as a separate bookkeeping account or as a separate bank account. The Hospital had excess cash available to cover the required reserve amount. Responsible Individuals: Renae Karst, Chief Financial Officer Corrective Action Plan: Management will establish a separate bookkeeping account in the general ledger to establish the correct reserve amount of cash within its general operating bank account. The reserve account will be part of total cash in the bank to maximize interest earned on the reserve balance. Anticipated Completion Date: June 30, 2023

2022-006 SPECIAL PROVISIONS ? STATE ADMINISTRATIVE MATCHING GRANTS FOR SUPPLEMENTAL NUTRITION ASSISTANCE PROGRAM (SNAP CLUSTER) Recommendation: We recommend that income verification be reviewed for each eligible case files. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County will continue to work on training new staff on requirements, and continue to perform case file reviews. Name of the contact person responsible for corrective action plan: Deborah Erickson, Administrative Services Director Planned completion date for corrective action plan: December 31, 2023

2022-005 ALLOWABLE COSTS AND ALLOWABLE ACTIVITIES ? STATE ADMINISTRATIVE MATCHING GRANTS FOR SUPPLEMENTAL NUTRITION ASSISTANCE PROGRAM (SNAP CLUSTER) Recommendation: We recommend the county ensures that all employees included on the random moment study listing are included on the proper line for reimbursement requests. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County will review their procedures to ensure the random moments studies are periodically reviewed against payroll and updated appropriately. Name of the contact person responsible for corrective action plan: Deborah Erickson, Administrative Services Director Planned completion date for corrective action plan: December 31, 2023

FINDING 2022-008 Contact Person Responsible for Corrective Action: Carrie McGuire Contact Phone Number: (574) 875 -5161 Views of Responsible Official: We concur with the finding Description of Corrective Action Plan: Prior to the submission of the Title I application annually, the federal grants coordinator with consult with all non-public schools within our district boundaries as listed by the IDOE in the grant application portal. The signed consultation forms will be uploaded to the IDOE?s Title I Programs Application Center as attachments. The corporation treasurer will verify that all consultation forms are signed and uploaded in the Application Center before the initial grant application budget can be submitted for review. Anticipated Completion Date: December 31, 2022

FINDING 2022-007 Contact Person Responsible for Corrective Action: Contact Phone Number: (574) 875-5161 Views of Responsible Official: We concur with the finding Description of Corrective Action Plan: When required annual federal grant reports are completed for submission, they will be reviewed by the treasurer for accuracy. Both the treasurer and the grants coordinator will sign off on the reports. Anticipated Completion Date: June 30, 2022

FINDING 2022-005 Finding: Internal controls were not in place/effective in relation to the Title I Annual Expenditure Reports filed during the audit period. Subsequently, the 20-21 Title I Annual Expenditure Report did not agree with School Corporation?s ledgers. $578,452 of expenditures were reported the Annual Expenditure Report and $677,514 from Fund 4121 on the ledgers. Contact Person Responsible for Corrective Action: Carrie McGuire Contact Phone Number: (574) 875-5161 Views of Responsible Official: We concur with the finding Description of Corrective Action Plan: When required annual federal grant reports are completed for submission, they will be reviewed by the treasurer for accuracy. Both the treasurer and the grants coordinator will sign off on the reports. In order to address the issue related to earmarking and set-asides within Title I not be completed, Concord Community Schools created a Grants and Assessment Coordinator position in May 2022. A person was hired to fill this position starting on July 1, 2022. One of the essential functions of this position is maintaining current and accurate records related to federal and state grants. Starting in January 2023, in addition to the Grants and Assessment Coordinator, a member of the business department will be a second reviewer and sign the semi-annual certifications. Anticipated Completion Date: December 31, 2023

FINDING 2022-006 Finding: An effective internal control system, which would include segregation of duties, was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the following compliance requirements: Earmarking. Of the $7,139.98 set-aside for the SY 20 Grant it was determined that only $2,284.50 was spent on Parent Involvement. Of the $6,817.51 set-aside for the SY 21 Grant, only $95.78 was spent during the audit period. In addition, Homeless Reservation set-asides were not me SY 20 or 21. Of the $1,900 designated for SY20, only $32.89 was spent. No amount was determined to have spent for the SY 21. Contact Person Responsible for Corrective Action: Carrie McGuire Contact Phone Number: (574) 875-5161 Views of Responsible Official: We concur with the finding Description of Corrective Action Plan: In order to address the issue related to earmarking and set-asides within Title I not be completed, Concord Community Schools created a Grants and Assessment Coordinator position in May 2022. A person was hired to fill this position starting on July 1, 2022. One of the essential functions of this position is maintaining current and accurate records related to federal and state grants. Starting in January 2023, in addition to the Grants and Assessment Coordinator, a member of the business department will be a second reviewer and sign the semi-annual certifications. Anticipated Completion Date: September 30, 2023

FINDING 2022-004 Finding: Non-Public School: No documentation could be found to support non-public school students qualifying for Title I on the 2020-2021 and 2021-2022 Applications. These numbers determine equitable share distributions to these non-public schools. Contact Person Responsible for Corrective Action: Carrie McGuire Contact Phone Number: (574) 875-5161 Views of Responsible Official: We concur with the finding Description of Corrective Action Plan: Non public schools will be consulted prior to the initial Title I(a) application being submitted at the start of each grant cycle. Non-public school consultation forms and spreadsheet(s) for any equitable share calculations will be uploaded into the Title I application center as attachments. These will be verified by the corporation treasurer before the Title I application is submitted annually. Prior to the submission of the Title I application annually, the federal grants coordinator with consult with all non-public schools within our district boundaries as listed by the IDOE in the grant application portal. The signed consultation forms will be uploaded to the IDOE?s Title I Programs Application Center as attachments. The corporation treasurer will verify that all consultation forms are signed and uploaded in the Application Center before the initial grant application budget can be submitted for review. A form will be created so that when files are downloaded from the Child Nutrition Program (CNP) website and subsequently uploaded into Mealtime, there will be places for a signature of the person who downloaded the file, a signature for the person who uploaded the file, and a reviewer. Anticipated Completion Date: September 15, 2023

FINDING 2022-001 Contact Person Responsible for Corrective Action: Jim Evans Contact Phone Number: (574) 875-5161 Views of Responsible Official: We concur with the finding Description of Corrective Action Plan: This finding was corrected beginning July 1, 2022. Concord Community Schools hired an additional staff member and that staff member reviews the information used to prepare the Monthly Sponsored Claims for reimbursement to verify that the claims are accurate, complete and prepared in accordance with the grant requirements. Once the review is complete, the Monthly Sponsored Claims are printed and signed by both the Food Service official who prepared the claims and the food service official who reviewed the claims for accuracy, completeness and compliance with grant requirements. Anticipated Completion Date: This finding has been corrected.