Corrective Action Plans

FINDING 2023-005 Finding Subject: Special Education Cluster (IDEA) – Period of Performance Summary of Finding: The School Corporation was a member of the Clark County Joint Services Program (Cooperative) during fiscal year 2021-2022. The School Corporation had not properly designed or implemented a system of internal controls to ensure transactions made from Special Education funds occurred within the appropriate period of performance. Claims for the Special Education programs were paid without an appropriate level of review or oversight to ensure the expenditures charged to each grant were within the allowed time frame. Although the reimbursement requests submitted to the Indiana Department of Education were prepared by the Corporation Treasurer and approved by the Special Education Director, the School was unable to provide tangible audit evidence of this review and approval process, which may have included a review of the costs included on each request to verify they were within the correct period of performance. Contact Person Responsible for Corrective Action: Ashley Compton, Director of Special Education and Allison Vanover, Corporation Treasurer Contact Phone Number and Email Address: 812-246-3375 alcompton@scsc.school avanover@scsc.school Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Silver Creek School Corporation is no longer part of the Special Education Cooperative. The Special Education Director and the Corporation Treasurer have a standing meeting once per month to review expenditures and receipts to prepare a reimbursement. At that time, the period of performance is also checked for accuracy. The Special education director will code initial expenditures to grant appropriation lines and submit to accounts payable specialist. Accounts payable specialist then confirms that the expenditure can be taken from that line in the working grant document for the corresponding grant. Oversight and review of grant allocations and approved totals with grant budgets are reviewed monthly at the time reimbursements are completed. Anticipated Completion Date: March 2024

FINDING 2023-002 Finding Subject: Child Nutrition Cluster - Eligibility, Special Tests and Provisions - Verification of Free and Reduced Price Applications (NSLP) Summary of Finding: Eligibility The School Corporation had not properly designed or implemented a system of internal controls, which would include segregation of duties, that would prevent or detect and correct noncompliance relating to the eligibility determination of a child receiving meals. There was no oversight or review to ensure the eligibility determination was correct. Special Tests and Provisions - Verification of Free and Reduced Price Applications (NSLP) The Account Specialist performed the verification of free and reduced price applications. There was no documentation that an oversight, review, or approval process, or other compensating control, had been established to ensure the proper number of applications were verified for accuracy. Contact Person Responsible for Corrective Action: Josh Sinclair, Food Service Director and Allison Vanover, Corporation Treasurer. Contact Phone Number and Email Address: 812-246-3375 jsinclair@scsc.school avanover@scsc.school Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We will use the proposed USDA form that has two signatures required. Mr. Sinclair will ensure that all signatures are collected for proof of verification. Mr. Sinclair and Ms. Susan Westfall will be a second check on the eligibility determination. One will do paper applications and the other will do online applications. Then, they will check each other for accuracy. Anticipated Completion Date: March 2024

Audit Finding Reference: 2023-002 Management’s Views and Planned Corrective Action: Food Service Balance – We will ensure that we spend the surplus food balance funds in 23-24 and not make a transfer of the funds from the district unless needed to ensure we don’t have an excess fund balance beyond the limit allowed. Name of Contact Person and Completion Date: Name – Bridget Cross Anticipated Completion Date – will be corrected for the 23-24 Audit

Finding #2023-003 – Material Adjustments (Prior year finding #2022-004) Condition: Johnson Block and Company, Inc., proposed numerous adjusting journal entries. We deem these entries to be significant in relation to the financial statements. Since the District did not make these adjustments in its accounting system prior to the audit, a material weakness exists in the District’s internal controls. Effect: This means that the proper recording and reporting of financial information may not occur within a timely manner. Cause: Financial information was not recorded in a timely manner and material adjustments were required in order to correct various transactions. Criteria: Material adjusting journal entries not prepared by the District before the audit are considered an internal control weakness. Recommendation: Policies and procedures should be implemented to ensure account balances are properly recorded in a timely manner. Response: The District will work to establish policies and procedures to reduce the number of adjusting journal entries proposed by the auditors. In addition, new finance accounting staff are receiving training to assist with correcting this finding. Contact Person: Gary Syftestad Anticipated Completion: Ongoing

􀀃 Finding􀀃2023􀍲005􀀃 􀀃 Finding􀀃Subject:􀀃Child􀀃Nutrition􀀃Cluster􀀃–􀀃Eligibility􀀃–􀀃Internal􀀃Controls􀀃 Summary􀀃of􀀃Finding:􀀃Internal􀀃Controls􀀃were􀀃not􀀃in􀀃place􀀃over􀀃direct􀀃certification􀀃of􀀃 students.􀀃 Contact􀀃Person􀀃Responsible􀀃for􀀃Corrective􀀃Action:􀀃Director􀀃of􀀃Food􀀃Service􀀃 Contact􀀃Phone􀀃Number􀀃and􀀃Email􀀃Address:􀀃(260)431􀍲2030,􀀃msnyder@sacs.k12.in.us􀀃 􀀃 Views􀀃of􀀃Responsible􀀃Official:􀀃We􀀃concur􀀃with􀀃the􀀃finding.􀀃 Description􀀃of􀀃Corrective􀀃Action􀀃Plan:􀀃 All􀀃direct􀀃certification􀀃information􀀃shall􀀃be􀀃initiated􀀃by􀀃the􀀃Director􀀃of􀀃Food􀀃Service:􀀃Pulling􀀃the􀀃 information􀀃monthly􀀃from􀀃CNP􀀃Web.􀀃The􀀃list􀀃of􀀃students􀀃to􀀃be􀀃directly􀀃certified􀀃will􀀃be􀀃printed,􀀃 signed􀀃and􀀃dated􀀃by􀀃the􀀃Director􀀃of􀀃Food􀀃Service.􀀃Once􀀃information􀀃is􀀃imported􀀃into􀀃the􀀃student􀀃 management􀀃system,􀀃the􀀃Assistant􀀃Food􀀃Service􀀃Director􀀃would􀀃then􀀃cross􀀃reference􀀃the􀀃printed􀀃list􀀃 of􀀃information􀀃to􀀃benefits􀀃assigned􀀃in􀀃the􀀃student􀀃management􀀃system􀀃to􀀃ensure􀀃accuracy.􀀃The􀀃 Assistant􀀃Food􀀃Service􀀃Director􀀃will􀀃initial􀀃next􀀃to􀀃the􀀃students􀀃they􀀃spot􀀃check􀀃on􀀃the􀀃list.􀀃The􀀃 printed􀀃document􀀃with􀀃signatures􀀃of􀀃both􀀃parties􀀃will􀀃be􀀃retained􀀃with􀀃the􀀃school􀀃years􀀃 applications.􀀃􀀃 Anticipated􀀃Completion􀀃Date:􀀃3/18/24􀀃

􀀃 Finding􀀃2023􀍲003􀀃 􀀃 Finding􀀃Subject:􀀃COVID􀍲19􀀃􀍲􀀃Education􀀃Stabilization􀀃Fund􀀃–􀀃Special􀀃Tests􀀃and􀀃Provisions􀀃–􀀃 Participation􀀃of􀀃Private􀀃School􀀃Children􀀃 Summary􀀃of􀀃Finding:􀀃Internal􀀃Controls􀀃were􀀃not􀀃effective.􀀃􀀃As􀀃a􀀃result,􀀃the􀀃school􀀃 corporation􀀃did􀀃not􀀃consult􀀃with􀀃the􀀃non􀍲public􀀃schools􀀃within􀀃its􀀃boundaries.􀀃 Contact􀀃Person􀀃Responsible􀀃for􀀃Corrective􀀃Action:􀀃Director􀀃of􀀃Business􀀃 Contact􀀃Phone􀀃Number􀀃and􀀃Email􀀃Address:􀀃(260)431􀍲2030,􀀃msnyder@sacs.k12.in.us􀀃 􀀃 Views􀀃of􀀃Responsible􀀃Official:􀀃We􀀃concur􀀃with􀀃the􀀃finding.􀀃 Description􀀃of􀀃Corrective􀀃Action􀀃Plan:􀀃 If􀀃we􀀃enter􀀃into􀀃a􀀃grant􀀃where􀀃another􀀃district􀀃serves􀀃as􀀃the􀀃LEA,􀀃we􀀃will􀀃ensure􀀃all􀀃non􀍲 public􀀃schools􀀃within􀀃our􀀃district􀀃boundaries􀀃are􀀃notified􀀃and􀀃given􀀃the􀀃opportunity􀀃for􀀃 participation.􀀃􀀃The􀀃Director􀀃of􀀃Business􀀃will􀀃document􀀃that􀀃the􀀃public􀀃schools􀀃were􀀃 contacted􀀃and􀀃document􀀃the􀀃meeting/conversation.􀀃􀀃The􀀃Deputy􀀃Treasurer􀀃or􀀃Asst.􀀃Director􀀃 of􀀃Business􀀃will􀀃review􀀃the􀀃documented􀀃meeting􀀃and􀀃sign􀀃stating􀀃it􀀃occurred.􀀃 Anticipated􀀃Completion􀀃Date:􀀃3/18/24􀀃

􀀃 Finding􀀃2023􀍲002􀀃 􀀃 Finding􀀃Subject:􀀃COVID􀍲19􀀃–􀀃Education􀀃Stabilization􀀃Fund􀀃􀍲􀀃Reporting􀀃 Summary􀀃of􀀃Finding:􀀃Internal􀀃Controls􀀃were􀀃not􀀃effective􀀃and􀀃did􀀃not􀀃prevent,􀀃nor􀀃allow􀀃for􀀃 detection􀀃and􀀃correction􀀃of􀀃errors􀀃prior􀀃to􀀃submission.􀀃 Contact􀀃Person􀀃Responsible􀀃for􀀃Corrective􀀃Action:􀀃Director􀀃of􀀃Business􀀃 Contact􀀃Phone􀀃Number􀀃and􀀃Email􀀃Address:􀀃(260)431􀍲2030,􀀃msnyder@sacs.k12.in.us􀀃 􀀃 Views􀀃of􀀃Responsible􀀃Official:􀀃We􀀃concur􀀃with􀀃the􀀃finding.􀀃 Description􀀃of􀀃Corrective􀀃Action􀀃Plan:􀀃 Once􀀃the􀀃Deputy􀀃Treasurer􀀃completes􀀃the􀀃report,􀀃they􀀃will􀀃give􀀃the􀀃report􀀃and􀀃all􀀃 supporting􀀃documentation􀀃to􀀃the􀀃Asst.􀀃Director􀀃of􀀃Business􀀃for􀀃review.􀀃􀀃After􀀃thorough􀀃 review,􀀃the􀀃report􀀃and􀀃supporting􀀃documentation􀀃will􀀃be􀀃signed􀀃by􀀃both􀀃the􀀃Asst.􀀃Director􀀃 of􀀃Business􀀃and􀀃the􀀃Deputy􀀃Treasurer.􀀃􀀃Once􀀃reviewed,􀀃the􀀃report􀀃and􀀃supporting􀀃 documentation􀀃will􀀃be􀀃given􀀃to􀀃the􀀃Director􀀃of􀀃Business􀀃for􀀃final􀀃approval􀀃and􀀃signature.􀀃􀀃􀀃 Anticipated􀀃Completion􀀃Date:􀀃3/18/24􀀃

The Department has instituted additional internal controls to ensure that expenditures are liquidated within 90 days of the end of the period of performance as required. This includes a monthly reconciliation of all federal sources performed by the Grants Manager and reviewed by the respective Budget Manager and Finance Director to address any identified issues before the liquidation date. As a redundancy measure, the Budget Manager reviews AP contract activity associated with federal fund sources via the Provider Utilization Report to monitor the liquidation rate in correlation with the liquidation date to ensure all expenditures are captured within the period of performance. Post-liquidation date journal activity is mainly aligned with transactional code cleanup, not necessarily new expense posting outside the period of performance. As such, it doesn’t include or constitute changes to previously submitted federal reporting. To mitigate transactional errors, the Budget Manager, in coordination with the Grants Manager, thoroughly reviews the coding of procurement requests that utilize federal funds for the appropriateness of use and accuracy. This includes deactivating federal fund sources in the statewide accounting system to prevent transactions posting outside of the period of performance. These additional internal controls related to the period of performance were implemented in July 2023. The Office of Internal Audit will perform a review of the updated processes to ensure they are effective in correcting the above findings no later than March 31, 2024.

GDOL acknowledges this is a repeated finding from previous years, therefore the Department concurs with this finding and offers the following response preceded by the auditor’s findings: Auditor’s Findings: The Georgia Department of Labor did not maintain adequate controls over the identification, recording, and reporting of benefit overpayments associated with the Unemployment Insurance programs. GDOL Response: GDOL now freezes the overpayment data at the end of every month so we can conduct periodic reconciliation of the overpayment records. This will allow discrepancies to be identified faster and resolved before the deadline to submit the report for the specified period. GDOL consults with USDOL’s national 227 reporting specialists on an ongoing basis to work towards a reconciliation of previously submitted reports. Federal regulations require an actual person to review and establish fraudulent overpayments. Due to the volume of claims and the number of cross matches to be performed on all state and federal pandemic programs, it requires multiple GDOL staffing levels to manually review all cross matches, requiring increased levels of state and federal funding. The crossmatch process is conducted using software which runs a systematic check against weeks in a quarter for which benefits are paid and wages are reported during the same quarter. Although the program may detect weeks paid and wages reported, this alone is not indicative of an overpayment. Therefore, the process involves verification correspondence being sent to both the claimant and the employer, as applicable, to verify the status of employment, the wages earned as well as the weeks in which an individual worked and earned the wages. Based on responses, an assessment is made to determine if an overpayment exists and subsequent actions are taken accordingly. We are prohibited from assuming a match is an overpayment. It is not an overpayment until we have completed a full investigation and provided due process to all parties. GDOL developed an aggressive plan to complete all crossmatches. We are running cross matches on all the state and federal programs. The Department has a significant number of pending and potential overpayment investigations that may result in either a non-fraud or fraud determination. We are utilizing non-overpayment staff to assist with overpayment investigations. Additionally, we are utilizing temporary agency staff to perform some clerical duties; however, federal regulations prohibit non-merit staff from adjudicating and releasing overpayment decisions. We are slated to run our last accelerated crossmatch in March 2024 and will resume our regular crossmatch schedule in June 2024. Additionally, GDOL has procured a vendor to build and implement a modernized unemployment insurance (UI) system slated to be launched in 2026. We will continue to utilize available resources to investigate and establish overpayments in the legacy system as quickly as possible and will continue to do so within the program parameters in the new system. Summary: The current unemployment system is obsolete and cannot be remediated at this time Therefore, we acknowledge that this finding will persist until a system-wide resolution is implemented in the new modernized UI system. GDOL greatly appreciates the feedback and recommendations and will consider this information in our endeavors to modernize our UI system and business processes.

GDOL acknowledges this is a repeated finding from previous years, therefore the Department concurs with this finding and offers the following response preceded by the auditor’s findings: Auditor’s Findings: The Department of Labor should improve internal controls over Employer Filed Unemployment Compensation claims. GDOL Response: GDOL submits the following information as an overview of the employer filed claims program and actions that have been taken and will continue to address the findings as well as incorporate additional safeguards and available technological system controls in the new system: 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 for 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 due to the pandemic. 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. By electing to submit EFCs on behalf of the individuals, the employer is responsible for attesting by an affidavit to the employment status and weekly earnings of the individual for the EFC submitted. The affidavit certifies that the employer has obtained earnings from other employment as well as other requirements must be completed before EFCs can be entered or uploaded for their employees. 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 actively seeking work. 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 the status of the profile setup and identify verification. Before 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. When we identify employer fraud schemes, we follow the guidance issued by the United States Department of Labor (USDOL) and collaborate with the United States Department of Labor Office of Inspector General (OIG) to investigate these cases. Effective June 29, 2023, GDOL implemented additional Employer Filed Claims safeguards and security measures to reflect amended Georgia Employment Security Rule 300-2-4-.09. Employers must now meet the following conditions to submit Employer-Filed Partial Claims on behalf of their employees: • Employer accounts must have been registered with GDOL for more than 5 years. • Employers must be current on all quarterly tax and wage reports. • Employers must be current on all quarterly contribution taxes, assessments, penalties, and interest. • The week ending date on employer filed claims cannot be older than 30 days. The amended Georgia Employment Security Rule also clarifies that part-time employees are not eligible for Employer Filed Partial Claims. Summary: This finding will persist until a system-wide resolution is implemented in the new modernized UI system. GDOL will include a self-certification and dual certification process for employer filed claims in the new solution.

GDOL acknowledges this is a repeated finding from previous years, therefore the Department concurs with this finding and offers the following response preceded by the auditor’s findings: Auditor’s Findings: The Georgia Department of Labor did not have effective internal controls in place to ensure unemployment benefit payments were made correctly and only to eligible claimants. 1) Claimants did not self-certify for benefits in eighteen instances GDOL Response: Employer Filed Partial 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. We recognize the state auditor's recommendations to add the self-certification. However, the current unemployment system is obsolete, having been put into production in 1982. This finding will persist until our new modernized unemployment insurance (UI) system is implemented in 2026. 2) Fraudulent employer-filed claims were filed for thirteen claimants GDOL Response: When we identify employer fraud schemes, we follow the guidance issued by the United States Department of Labor (USDOL) and collaborate with the United States Department of Labor Office of Inspector General (OIG) to investigate these cases. Additionally, we have taken the following measures to safeguard the system against fictitious employers: • Effective December 6, 2021, the Employer Filed Partial Claims (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 the status of the profile setup and identify verification. • Before 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. • Effective June 29, 2023, GDOL implemented additional employer filed claims safeguards and security measures to reflect amended Georgia Employment Security Rule 300-2-4-.09. Employers must now meet the following conditions to submit Employer Filed Partial Claims on behalf of their employees: o Employer accounts must have been registered with GDOL for more than 5 years. o Employers must be current on all quarterly tax and wage reports. o Employers must be current on all quarterly contribution taxes, assessments, penalties, and interest. o The week ending date on employer filed claims cannot be older than 30 days. The amended Georgia Employment Security Rule also clarifies that part-time employees are not eligible for Employer Filed Partial Claims. BPC and Integrity merit staff continue to establish pseudo claims when fraud is confirmed to relieve victims of liability and the fraudster is unknown. Otherwise, the payments are moved to the fraudsters claim account, if identified. GDOL has procured a vendor to build and implement a modernized UI system. We are also pursuing data analytics tools to expedite the identification and detection of fraudulent activities. These tools will also be incorporated into the modernized solution. 3) Proof of employment or self-employment or a valid offer to begin employment and proof of wages was not submitted by five Pandemic Unemployment Assistance (PUA) claimants. One of these claimants was not eligible to claim benefits in Georgia. GDOL Response: The claimants who established PUA entitlement with a weekly benefit amount greater than the minimum or later determined to not be eligible were based on wages entered by the claimant and/or wages reported by the employer. The Coronavirus Aid, Relief, and Economic Security (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 claimants cited. The claims were reduced as appropriate. An overpayment has been established on all five claims identified for the difference in weekly benefit amount for weeks paid over the minimum amount under CARES and for the entire amount for weeks paid under Consolidated Appropriations Act (CAA)/American Rescue Plan Act (ARPA). GDOL’s current UI Information Technology (IT) system was developed in 1982 using mainframe “legacy’ technology. Due to the system’s age and other limitations, many automated processes and corrections cannot be fixed and/or easily implemented. As such, many processes must be handled manually by staff. This includes reviewing all the PUA proof documents submitted to determine the validity and eligibility for each PUA claim. Based on the volume of workload and staff limitations, GDOL has been unable to quickly complete this manual review to correct the finding. It is anticipated this manual review will continue throughout the FY24 audit review period. Summary: GDOL’s limited technology resources will hinder our ability to update our current system to satisfy the state audit’s recommendation. Therefore, we acknowledge that this finding will persist until a system-wide resolution is implemented in the new modernized UI system. The new solution will include a self-certification and dual certification process for employer filed claims and include controls over eligibility determinations for current and future UI programs. GDOL greatly appreciates the feedback and recommendations and will consider this information in our endeavors to modernize our UI system and business processes.

We will continuously monitor the compliance supplements for updates in order to meet all requirements. We have added additional staff to complete FFATA reporting to ensure the reports are submitted timely and accurately moving forward.

2023-004: Material Weakness and Material Noncompliance- Wage Rate Requirements The District will implement internal controls to ensure that all contractors working on federally funded projects for which wage rate requirements apply, are notified and the District will obtain necessary documentation to verify compliance. In addition, the District will implement internal controls to ensure the necessary language is included in all future solicitations for quotes or bids for which prevailing wage requirements apply. • Anticipated Completion Date: February 26, 2024 • Responsible Contact Person: Seth Cales Treasurer

There is no disagreement with the audit finding. There were previous receivables from the prior period that were not timely reviewed and overlooked due to an oversight and staff turnover. The Community Action Partnership of Mercer County does not foresee this happening again in the future now that the Programs are under the Community Action Partnership of Mercer County’s accounting software. Employee Responsible for Corrective Action: Michelle Clarke Completion Date: July 1, 2024

There is no disagreement with the audit finding. Prior leading into this audit, there were two sets of accounting records. The Programs had their own records separate from the Community Action Partnership of Mercer County. For the fiscal year 2023-2024, the Programs are now under the Community Action Partnership of Mercer County with one set of accounting records. The general ledger, balance sheet and expenditures are to be reviewed on a timely basis. Employee Responsible for Corrective Action: Michelle Clarke Completion Date: July 1, 2024

Finding Number: 2023-001 Condition: The Medical Center's controls for reporting submissions did not identify that it had a reporting requirement deadline, and the report was submitted late. Planned Corrective Action: The grant administrator and accountant will review the contract for reporting requirements and add submission dates to work calendars with reminders. Contact person responsible for corrective action: Keith Poniers, CFO Anticipated Completion Date: This has been corrected

FINDING 2023-002 Finding Subject: COVID-19 – Education Stabilization Fund – Reporting Summary of Finding: ESSER III, Year 2 report contained material errors in the amounts reported Contact Person Responsible for Corrective Action: Tanya Pearson Contact Phone Number and Email Address: 765-522-6218 tpearson@nputnam.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We will have one person complete the ESSER report and one person review the ESSER report for accuracy. Anticipated Completion Date: Immediately with the next ESSER report submission

Finding 2023-002 – Education Stabilization Fund – Special Tests and Provisions - Wage Rate Requirements Contact Person Responsible for Corrective Action: Amy Phillips Contact Phone Number: (765) 662-2546 ext 8070 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Marion Community Schools will develop and implement a formal internal controls system to ensure compliance with all federal grant requirements. A detailed checklist of requirements listed in the grant agreement will be provided by the Grants Manager and reviewed for accuracy by the Grants Team consisting of the Assistant Superintendent for Curriculum and Instruction, the Grants Manager, the Chief Financial Officer, and the Chief Technology Officer. Compliance requirements will be monitored during weekly grant team review meetings for the duration of the grant agreement. All vendor contracts for construction will include clauses for the federal wage requirements and any additional requirements that may be required in the future. Construction companies will be required to provide us with weekly payroll report certifications. When the reports are received, they will be reviewed and approved by the Grants Manager and the Chief Financial Officer. Anticipated Completion Date: April 30, 2024

Although we checked and double checked the information as shown in COD under the R2T4 section, there still appears to be an issue with regards to COD correctly showing Vacation time in COD. Going forward, we are actually printing out the R2T4's to ensure that the correct number of days are listed on the R2T4 sheet and maintaining hard copies in addition to saving online.

U.S. Department of Treasury Peoria Area Convention and Visitors Bureau, Inc. respectfully submits the following corrective action plan for the year ended June 30, 2023. Audit period: July 01, 2022- June 30, 2023 FINDINGS— MAJOR FEDERAL AWARD PROGRAMS U.S. Department of Treasury 2023-001 The American Rescue Plan Act/State Fiscal Recovery Fund Program – Assistance Listing Number: 21.027 Recommendation: We recommend that for all federally funded grants the Organization perform the required suspension and debarment verification when required, including implementing the necessary internal controls over this process. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: Management will update their procurement policy and implement the necessary controls to ensure the suspension and debarment verification is completed when required. Name(s) of the contact person(s) responsible for corrective action: CJ Goddard Planned completion date for corrective action plan: December 2023 If the U.S. Department of Treasury has questions regarding this plan, please call CJ Goddard at 309-224- 6881.

Reviewing all areas of this finding, the District needs to assist with extra help from the district office and ensure that all student records are updated timely based on the review of income eligibility forms or direct certification information, plus additional training.

Finding #2023-002 – Material Audit Adjustments Condition: The audit proposed numerous adjusting journal entries during the audit process to adjust District account balances. We deem these entries to be significant in relation to the financial statements. Since the District did not make these adjustments in its accounting system prior to the audit, a material weakness was determined to exist in the District’s internal controls. Effect: Financial reports generated by the accounting system may not provide an accurate reflection of the District’s financial position or activities. Cause: Financial information was not recorded in a timely manner and numerous adjustments were needed in order to correct account balances. Criteria: Material adjusting journal entries not prepared by the District before the audit are considered an internal control weakness. Recommendation: Policies and procedures should be implemented to ensure account balances are properly recorded in a timely manner. Response: The District will establish policies and procedures to reduce the number of adjusting journal entries proposed by the auditor in future years. Contact Person: Loras Winders Anticipated Completion: June 30, 2024

Gramm-Leach-Bliley Act (GLBA) Compliance Planned Corrective Action: The school’s IT firm has taken the following steps to address GLBA Compliance in the following manner. Element 1: ADB Network Consultants LLC and its Delegated Partners will serve as the Morris Brown College Managed Cybersecurity Service Provider. ADB is responsible for overseeing and implementing and enforcing the institution’s information security program. Element 2: The risk assessment for MBC’s Cyber Security program is covered within the MBC Cyber-Security -Incident-Response document on pages 8 through 12 which includes Appendix B (Incident Categorization), Appendix C (Incident Impact Definitions and IRT Incident Severity & Response Classification Matrix), and Appendix D (IRT Incident Record Form). The system is designed to provide ongoing and updated Reporting. Element 3: Access to MBC’s network, data, and email system is permitted only to authorized users. Access is granted by MBC Authorized Personnel and/or IT service providers through the administrative console of the respective environment (Active Directory Domain Controller for network and data access, Microsoft 365 Admin Center for Outlook email access, and MBC Authorized Personnel and/or Security Guards for physical facilities access). Element 4: MBC Authorized Personnel and IT service providers will test the Cyber Security Incident Response Plan periodically, but at least annually to monitor the effectiveness of the safeguards it has implemented. Element 5: MBC’s IT service provider created a Cyber Security Incident Response Plan, which documents who and how MBC Authorized Personnel and IT service providers will respond to Cyber Security incidents. Element 6: MBC has a 2-year contract with its IT service provider, ADB Network Consultants LLC. The service contract lists and governs the services that the IT service provider and its partners will perform monthly. Element 7: Provides for the evaluation and adjustment of its information security program in light of the results of the required testing and monitoring; any material changes to its operations or business arrangements; the results of the required risk assessments; or any other circumstances that it knows or has reason to know may have a material impact the information security program (16 C.F.R. 314.4(g)). ADB Network Consultants LLC implemented a system that will log the activity of authorized users and prevent unauthorized network access. Email Threat Protection has also been setup. Person Responsible for Corrective Action Plan: Shermanetta Carter, CFO Anticipated Date of Completion: June 30, 2024

FINDING 2023-001 Finding Subject: Student Financial Assistance Cluster - Special Tests and Provisions - Enrollment Reporting Summary of Finding: Although the University had policies and procedures in place over Enrollment Reporting, a process to ensure that system defects did not impact reporting requirements was not implemented. As such, for students who had a reduction or increase in enrollment status during the Spring 2023 term, errors in reporting campus level and program level data went undetected. Students with a status of withdrawn or with no changes during the period were accurately reported. It was recommended that the University's management establish a system of internal controls that includes a review of Banner job processes to verify source data is correctly populated so as to ensure that all data elements required to be submitted to NSLDS are accurate. Contact Person Responsible for Corrective Action: Angel Nelson, Associate Registrar Contact Phone Number and Email Address: (812) 465-1626; angel.nelson@usi.edu Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: While the University of Southern Indiana had internal controls in place to verify the accuracy of our enrollment reporting data, these controls were not effective in discovering system errors. In order to correct this deficiency, the following corrective actions have been implemented: 1. The system defect within our student information system has been corrected by our vendor. 2. All student records affected by the system defect have been corrected in the National Student Loan Clearinghouse database. 3. Beginning in January 2024, the University increased the number of records selected for review from the enrollment file, making sure to review some students who had a reduction or increase in enrollment status, as well as some who had withdrawn. 4. Associate Registrar has subscribed to the e-community for our software vendor to monitor for future system errors. Anticipated Completion Date: The system defect was corrected with the installation of a system patch that was installed on June 4, 2023. All other steps in the corrective action plan have been completed as of January 26, 2024.

Planned Corrective Action: The Director of Financial Aid will document the review of students that change academic status (full time vs part time) and determine if any adjustments need to be made to the students Cost of Attendance as a result of the change. The Director of Financial Aid will document this review and note any changes that were made as a result. If no changes are necessary, this will be documented as well Person Responsible for Corrective Action Plan: Sandra Mitchell Holder, Director of Financial Aid Anticipated Completion Date June 2024