Corrective Action Plans

FINDING 2022-004 Finding Subject: Title I Grants to Local Educational Agencies - Reporting Summary of Finding: Finding: Detail data on the Form 9 and Reimbursement Request was not provided to knowledgeable individuals for review. Recommendation: Design control that provides sufficient data to knowledgeable individuals for review. Contact Person Responsible for Corrective Action: Kareemah Fowler, Assistant Superintendent of Business and Finance Contact Phone Number and Email Address: (574) 393-6088; kfowler@sbcsc.k12.in.us Views of Responsible Officials: We concur with the findings. Description of Corrective Action Plan: Form 9 Data The Human Resources Department has added a second review to verify all employee distribution codes are correct when recording/updating employee requisitions. Additionally, detailed expense reports and payroll distribution reports that support each reimbursement request are being provided to knowledgeable employees to review. Anticipated Completion Date: Completed December 8, 2023, and May 2023 Reimbursement Requests Summary level payroll data is no longer being used to support reimbursement requests. Detailed expense reports and payroll distribution reports that support each reimbursement request are being provided to knowledgeable employees to review. Anticipated Completion Date: Completed May 2023.

Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Public and Indian Housing Program to ensure that established internal control policies are being followed on a timely basis. Melody Johnson-Williams, Executive Director, is responsible for implementing this corrective action by December 31, 2023.

Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Section 8 Housing Choice Vouchers Program to ensure that established internal control policies are being followed on a timely basis. Melody Johnson-Williams, Executive Director, is responsible for implementing this corrective action by December 31, 2023.

The Aha Macav Housing Entity will adhere, and practice set forth in the Financial Management Policy and Procedures, 8. Finance Reporting (a) Reports to Grant Agencies. Estimated Completion Date: The TDHE shall complete and submit all reports to Federal, State, and local grant agencies in accordance with, and in the format and timelines required by the agency. In this case, submitted to the Federal Audit Clearinghouse within 30 calendar days after receipt of the auditor’s report, or 9 months after the end of the audit period, whichever comes first.

(B) The Department revised its training model which is on track and will be fully rolled out to all eligibility sites by July 2022. (D) The Department disagrees with the auditor?s findings and questioned costs related to capitation payments under the Eligibility Issues Identified through Data Analyses section. These costs are related to cases that were ?not eligible? in CBMS but were showing as ?eligible? in Colorado interChange that were already identified by the Department. The Department was actively working to resolve these cases with CMS prior to the Public Health Emergency (PHE). The Department developed and implemented a reconciliation report that is used to research and resolve CBMS and Colorado interChange interface mismatches. Members identified on the reconciliation reports were being manually updated until March 2020. CMS instructed the Department to cease work on these cases when the PHE was implemented. During the PHE the Department was not allowed to terminate benefits for anyone receiving benefits prior to March 2020, even if eligibility was determined incorrectly prior to the PHE. During this unprecedented time, the authority and operations regarding these cases was not immediately available. The auditors? retrospective review fails to address the uncertainty that occurred during this period of the PHE. The Department agrees to resume work on the manual reconciliation process when authorized by CMS.

(A) Caseworker errors can be caused by an array of issues, including, training material retention; a lack of adequate funding to balance caseload inventory versus available work hours and staffing levels; a lack of quality review and performance reinforcement; and an assortment of local issues that lead to employee turnover. The Department will continue to work with eligibility sites regarding caseworker errors identified through this audit. The Department?s caseworker training resources, or Staff Development Center (SDC), is in the process of revamping all of their foundational training materials into a "Process-Based Training" model to be more effective and efficient based on training industry best practice. In addition, the SDC is converting all training materials into several different training modalities (instructor led courses, eLearning courses, desk aids, process manuals, infographics, workbooks, etc.) to be more engaging, effective, and accessible to adult learners with varying needs and preferences across large geographical areas. The revised training model is on track to be completed by July 31, 2021 and fully rolled out to all counties by Fiscal year end 2022. (C) The Department has thoroughly researched the issues identified in this audit and has made changes to CBMS to ensure that it is using the correct income information, income thresholds in determining eligibility, and buy-in premiums are assessed. These issues were fixed May 2019, February 2020, and March 2020, and in June 2021 the income information system issue will be corrected. The Department disagrees with the auditor?s questioned costs and projection of those questions costs. The Department disagrees with the auditor?s sampling, stratification, and costs used to generate the projected questioned costs. The costs incorrectly include members who remain eligible once the identified error had been resolved, payments that will be recovered by the Department through an existing process to recover capitation payments from deceased members, a Social Security Administration (SSA) interface error outside the control of the Department, and costs related to an already identified issue regarding reconciling eligibility between CBMS and Colorado interChange. Some of these costs are related to cases that were ?not eligible? in CBMS but were showing as ?eligible? in Colorado interChange that were already identified by the Department and should have been excluded from the questioned costs and the resulting projections. The Department will resume the reconciliation process between CBMS and Colorado interChange when authorized by CMS. Regarding the SSA interfaces, SSA posted results that are valid conditions for Medicaid eligibility, so those costs should have been excluded from the resulting projections. The Department agrees to bring interface issues to the attention of SSA. The Department has heard that other individuals have been notified on an SSA incarceration status which was incorrect. We have reached out to SSA concerning interface issues and will reach out again. In the meantime we will work with our eligibility workers to attempt to update these cases when they occur.

(A) The state implemented the first phase of the monitoring dashboard in June 2020 with Project 13889 that identifies members that are active with no SSN without exemptions. The second phase of the monitoring dashboard implementation was pushed back to July 2023 due to competing legislative mandates.

(A) The Department completed the system enhancement, allowing on-going data feeds from DORA into the interChange. The enhancement included implementation of a front-end claim edit, to prevent claim payments to providers with an expired license. The edit will be functional once the impact to providers has been determined. The project was completed mid July 2022 with courtesy notices to our provider network, to update license information as applicable. Policies and procedures were updated to address this finding on May 17, 2022. The policy and procedure is effective July 1, 2022. (B) The Department has updated its policies and procedure for reviewing license actions, effective July 1, 2022. (C) Licensure continues to be a quality monitoring criterion for the Department and the Fiscal Agent. The Department completed the system enhancement, allowing on-going data feeds from DORA into the interChange. The enhancement included implementation of a front-end claim edit, to prevent claim payments to providers with an expired license. The edit will be functional once the impact to providers has been determined. The project was completed mid July 2022 with courtesy notices to our provider network, to update license information as applicable.

(A) The Department agrees with the audit recommendation to develop and implement formal written policies and procedures. Prior to this audit, the Department began creating formal written policies and procedures for site case reviews, maintenance of supporting documentation, timely training for failed workers, and performance of timely re-certification of presumptive eligibility sites (PE site). This finding had no known questionable cost associated with it. (B) The Department agrees with the audit recommendation to develop an effective tracking mechanism to identify and monitor PE sites that are due for re-certification every two years and ensuring that the recertifications are performed. Prior to this audit, the Department began developing a tracking mechanism for PE site re-certifications. This finding had no known questionable cost associated with it. (C) The Department fixed enrollment information for Fiscal Year 2020 and 2021 in CBMS for beneficiaries who were no longer eligible for presumptive eligibility and have either had their benefits terminated or were moved to the regular Medicaid and Children?s Basic Health Plan programs. The Department is currently performing regular reviews to appropriately terminate applicants? presumptive eligibility in CBMS when appropriate. However, the Department has not addressed the programming and system issues in CBMS. The Department plans to fully implement this recommendation by December 2022.

(A) The Department will create written procedures documenting system and monitoring processes used to prevent claims from paying after a beneficiary?s date-of-death is verified. In addition, the procedures will document the processes used to recover payments made between a beneficiary?s verified date-of-death and the date the Colorado interChange system is updated with the date-of-death. (B) The system issues described in this audit were resolved as of April 2020 for fee-for-service claims and November 2020 for capitation payments. Once a beneficiary's date-of-death is verified, payments that were made after to the date-of-death will be recovered through the Department's existing processes. As noted in the Department?s response to Recommendation (A), the Department will create written procedures documenting system and monitoring processes used to prevent claims from paying after a beneficiary?s date-of-death is verified. In addition, the procedures will document the processes used to recover payments made between a beneficiary?s verified date-of-death and the date the Colorado interChange system is updated with the date-of-death. (C) The review for FFS claims is complete and all Notices of Adverse Action have been sent to providers. At this time we are waiting on any requests for informal reconsiderations, appeals, and/or payments to process.

(A) The Department continues to work with the Fiscal Agent to ensure that the required database matches occur and the interChange properly displays the results of Social Security Number and Federal Employer Identification Number verifications for all providers. The project was completed mid July 2022.

(B) The Department will review and revise, as necessary, its taxi claim billing requirements and rates to ensure that they are consistent. In addition, the Department will devise controls to ensure that taxi claims are paid in accordance with established requirements and rates and explore controls to ensure that only permitted providers bill as a taxi. The Department is working on reductions in the max fee and unit limits for taxi claim billing codes, which it will have completed by the end of October 2021. In addition, the Department is considering systematically pricing the code at each taxi provider?s specific Public Utilities Commission (PUC) rate. This change, if pursued, will require a system change request, which will take a year or more, which is why the Department has selected an implementation date of December 2022. If this proves infeasible, alternate controls will be implemented. HCPF has met with DORA PUC. The Department is trying to establish a process to decide if the PUC taxi rate still applies or an internal rate can be created. Because of these discussions and needed system changes the implementation date has been moved to December 2023. (D) The Department intends to define in rule the types of documentation that NEMT providers must keep on hand and make clear that they must furnish records to the Department upon request. The July 2022 date will allow for the completion of formal rulemaking. The Department further intends to develop and implement a process to perform regular risk-based provider file reviews with a focus on noncompliant providers. These reviews will ensure, at a minimum, that the providers? paid claims are supported with appropriate documentation and represent the least costly option appropriate to meet each recipient?s needs. The Department met with the RAC team on February 22, 2023 to come up with a process to perform small audits for claims from providers that are outside the Intelliride service area. New systems will be implemented which has pushed the anticipated completion date to December 2023. (E) The Department will amend its contract with its NEMT broker by adding a mandatory annual audit so that it can reconcile trip scheduling data with paid claims data. This will help ensure that the Department pays accurately, pays for NEMT services, and pays for the least costly transportation option appropriate for each recipient. The Department chose July 2022 to add the audit through its annual contract amendment and renewal processes. The contract amendment was completed and signed June 30, 2022 that included a clause for an annual audit of claims. (F) The Department will develop a data review process to reconcile interChange data on NEMT trip claims to interChange data on Medicaid medical claims. This process will entail periodic reviews of NEMT claims to see if members have corresponding medical claims on those dates. If they do not, the Department will follow up with the appropriate NEMT provider to investigate. The July 2022 implementation date reflects the potential need for system changes. This is implemented, the Department has been pulling claims data and where corresponding medical claims are not found HCPF is investigating on a case by case basis to find the cause. (G) Department staff will work with the Department?s Program Integrity (PI) staff on processes to investigate and recover, as appropriate, the overpayments and inappropriate payments that the audit identified as known or likely questioned costs, and repay the federal portion, as appropriate. The December 2022 implementation date reflects the time needed to investigate and when appropriate, recover any overpayments. This has been implemented and the federal portion has been returned to CMS. (H) The Department will develop a process to track staff time and productivity to ensure that it has sufficient staff assigned to oversee and administer NEMT. This process will include documenting time spent each week on various tasks to get a sense of where help is needed, and which tasks take up the most staff resources. Based on its findings, the Department will explore staffing options, as needed. The Department selected the July 2022 implementation date to allow for data collection through the end of State Fiscal Year 2021-22. This has been implemented. New NEMT staff was hired November 1, 2022 to act as the liaison to the counties and clients in the 55 counties outside of the Intelliride service area.

The Department did not have strong enough controls for the initial checks on the financial data reporting templates. This process has been updated and will be rectified in coming cycles. The Department has modified its templates in order to address the concerns provided by the auditors including signatures and supplemental reporting. Written policies and procedures for the validation and audit of the templates are being developed currently and will be in place and effective in December 2022. The Department will be correcting this error by posting the audit results along with other quality and audit reports on the following site: https:hcpf.colorado.gov/quality-and-healthimprovement-reports.

(A) The MLR report template has been updated and will now be reviewed at least yearly by the Department. In addition, new written policies and procedures are being developed and will be implemented before the submission of the next MLR for review. (B) The Department will add contract language and enforcement mechanisms in order to receive accurate information in a timely manner. This includes specific timelines for correcting incomplete or inaccurate information in order to submit the MLR report timely to the Centers for Medicare & Medicaid Services.

(B) The Department will continue our existing proactive approach to minimize this issue. The resolution of a SSN discrepancy is addressed through manual intervention by county eligibility technicians when identified through the system edit implemented in December 2020. The Department will continue the existing process to address duplicate SSNs. The Department has already made significant progress to monitor CBMS through the use of CBMS monitoring dashboards. These dashboards allow the Department to monitor and perform daily analysis. The Department meets bi-weekly to discuss findings and next steps to resolve any issues identified through the dashboard. These dashboards are being implemented over time as areas of improvements are identified. As part of the Department's continual improvement strategy, SSN discrepancy reports are included in the next implementation phase of the monitoring dashboards scheduled for June 2023. The Department will develop and implement policies and procedures outlining how the report will be used to effectively monitor and correct SSN and State ID discrepancies. Once that work is complete, the Department will send updated written guidance to our county and medical assistance sites on how to use system edits, reports, and dashboards to resolve duplicate SSNs. (C) The Department will continue our existing proactive approach to minimize this issue. The resolution of a SSN discrepancy is addressed through manual intervention by county eligibility technicians when identified through the system edit implemented in December 2020. The Department will continue the existing process to address duplicate SSNs. The Department has already made significant progress to monitor CBMS through the use of CBMS monitoring dashboards. These dashboards allow the Department to monitor and perform daily analysis. The Department meets bi-weekly to discuss findings and next steps to resolve any issues identified through the dashboard. These dashboards are being implemented over time as areas of improvements are identified. As part of the Department's continual improvement strategy, SSN discrepancy reports are included in the next implementation phase of the monitoring dashboards scheduled for June 2023. Once that work is complete, the Department will send updated written guidance to our county and medical assistance sites on how to use system edits, reports, and dashboards to resolve duplicate SSNs appropriately and in a timely manner.

(B) The Department agrees to develop and implement policies and procedures requiring Department staff to perform reconciliations of recipient agencies? and Regional Food Banks? physical inventories to the Web-based Supply Chain Management system to ensure inventory records are complete and accurate. Starting in January 2021 the Department began developing a position description for an Inventory Specialist with the focus of ensuring accurate and thorough accounting of all year-end inventory and reconciliations. The position was hired in April 2021. Due to the implementation of the inventory database and the timing of beginning and ending inventories, the Department anticipates being able to do a full reconciliation of inventories by December 2022. (C) The Department agrees to develop and implement a tracking system for food inventory at recipient agencies and Regional Food Banks using the Web Supply Chain Management system receipts as the basis of food received, including the maintenance of supporting documents. The Department is undertaking an inventory overhaul which includes implementing a new inventory database and creating and hiring an Inventory Specialist. The Department recognized the need for inventory software and started the process of obtaining it in June 2020. In May 2021, the Department received a signed licensing agreement for a new database which is expected to be implemented in six months per an OIT timeline. In addition to the database, the Department recently hired a new Inventory Specialist position. This position will lead the development of policies, procedures, inventory reconciliations, and monthly report management. Once the Inventory Specialist has a comprehensive understanding of federal and state policy and the new database software, the Department will develop policies and procedures, training for partner agencies, and roll out new requirements for the tracking and reconciliation of program inventories.

Project for Pride in Living, Inc. respectfully submits the following corrective action plan for the year ended December 31, 2022. Audit period: January 1, 2022 ? December 31, 2022 The findings from the December 31, 2022, schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Findings ? Financial Statements Audit Material Weakness 2022-001 ? Audit Adjustments Recommendation ? The Organization establish procedures to regularly review out-of-the-ordinary activities to ensure its accounting is complete and accurate. Auditee's comments ? During 2022, PPL experienced turnover in its Corporate Controller position. Transfer of knowledge regarding the acceptance of the donated property and communication regarding the timing of its recording were not properly executed during the transition. Additionally, the nature of the contribution (noncash/property) is unique to our organization and the omission of its recording was not identified within the established internal controls for cash transactions. As such, recording of the donated property was inadvertently overlooked. The Organization is actively working to update its financial policies, to include recording of unique transactions such as non-cash donations of property. When large non-cash donations are made, the Corporate Controller will work with the Chief Financial Officer and auditing firm on the best way to accurately record the transaction in accordance with GAAP. Generally, the transaction will be recorded in the period the donation is received to avoid a similar recording error in the future. Furthermore, PPL Financial Leadership, including the CFO and Corporate Controller, in collaboration with our external auditors, have established a mid-point check-in that will take place at the end of third quarter to reflect on previous year audit takeaways as well as year-to-date financial status. Name(s) and contact person(s) responsible for corrective action: Scott Cordes. Planned completion date for corrective action plan: New procedures have been established and are anticipated to be approved by the Board of Directors in October. A mid-point check-in with our auditing firm has also been scheduled to take place in October 2023. If there are any questions regarding this plan, please contact Scott Cordes at (612) 455-5149.

Finding 2022-06 Report Preparation and Submission Condition: It was discovered that the Organization demonstrated deficiencies in reporting accuracy and completeness, as well as a failure to comply with state law by not filing a required annual report. Upon review of the Organization?s reporting practices, it was observed that three out of the five reports selected for testing contained discrepancies, inaccuracies, or incomplete reporting metrics. These discrepancies raise concerns about the reliability of the organization's reported data, which can impact decision-making, program effectiveness, and the organization's ability to fulfill its fiduciary responsibilities. Furthermore, the Organization failed to file the mandatory annual report as required by Indiana Code 5-11-1-4, further indicating a deficiency in compliance with local regulations. Corrective Actions Taken or Planned: The Organization?s Board and Executive Team consisting of the CEO and COO acknowledge the finding related to reporting deficiencies. The Organization has adopted internal policies to address this to include a grants management tracking system that records reporting requirements and a checks and balance system. The required annual report process has been initiated and a 2023 report will be filed in the month of October 2023.

Finding 2022-01 Financial Close Process Condition: The auditors noted a lack of a strong financial close process which led to several material audit adjustments that were proposed during the audit and recorded by the client to properly reflect various financial statement accounts. Corrective Actions Taken or Planned: The Organization?s Board and Executive Team consisting of the Chief Executive Officer (?CEO?) and the Chief Operating Officer (?COO?) recognize the existence of gaps in the financial accounting practices at the organization during the year ending 2022. A transition occurred between independent bookkeepers during this year causing these discrepancies. The Executive Team recognized the need to hire staff and put new policies and processes in place. The Organization began this process in October of 2022 with the hiring of a Finance Manager. Additionally, a transition occurred in the first quarter of 2023 to a new independent bookkeeper with strong training in nonprofit accounting. The Organization will adopt all GAAP nonprofit accounting practices in 2023. New processes have been adopted to reconcile the financial statements weekly. The Finance Manager and Bookkeeper meet weekly for additional oversight. Balance sheet accounts are reconciled monthly and presented to the COO and Board Treasurer.

2022-004 Material Weakness in Controls over Compliance: Activities Allowed or Unallowed We agree with the recommendations and have made improvements to our procedures. The schools were not prepared for the rapid expansion of the food program, not only at our two high schools, but our partner schools' which requested contracted breakfast/lunch food services for their students as well. This unprecedented growth coupled with supply chain issues from food wholesalers, and shortage of employees in the hiring pool, only exacerbated our issues. The audit sample showed a large error rate for one of the schools. We have gone through the entire year for the school(s) individual count sheets. In the event the Michigan Department of Education determines that the identified discrepancies warrant a repayment we have recorded an allowance in the financial statements for the year ended June 30, 2021. Staff were not properly trained in how to complete the count sheets; however, supervisors did not take the time once they saw there was a problem due to everyone trying to simply get the meals served to the children. In addition, there was a lack of oversight of the Food Service Manager by her direct supervisor. At the time of the 2021 audit, when the issue was brought to our attention, we developed new procedures. School staff performing counts have been trained in how to properly complete the count sheets. The Business Manager now reviews all count sheets and ties counts to the summary report used to submit claims prior to submittal for reimbursement. Given that training and implementation of procedures did not fully occur until January 2022, there are errors in counts prior to implementation of the procedures and repeat findings in fiscal year 2021-22. In addition, with the end of the pandemic, beginning with the 2022-23 school year, the schools were able to resume using electronic software to accurately capture the meal counts.

Finding Number: 2022-017 ? SEFA Preparation Corrective Action Plan: In 2022, the office had downsized due to turnover in staff. While a process was in place for reconciling, a secondary review was not performed to verify accuracy of the residual value calculations. To strengthen the oversight of financial management in the School, Academica Nevada, the School?s management company, has filled all the open positions and realigned staff responsibilities to reduce individual workloads and provide additional oversight and review. The grant manager will reconcile all grants to ensure proper cutoff, with a secondary review performed by a member of management. Responsible Individuals: Nachum Golodner, Director of Accounting Anticipated Completion Date: June 30, 2023

Corrective Action Steps Taken - As of August 3, 2022, the school management company Distinctive Schools, has engaged with EdOps to provide additional Financial Operations Support to Plymouth Educational Center. Future Steps to be implemented ? EdOps and Distinctive Schools have begun holding monthly review meetings with various members of the Plymouth Educational Center team to provide stronger review and greater visibility into potential budget related impacts. Based on information obtained during these meetings, annual forecasts are created and if any amendments are deemed necessary during the process, they will be presented to the board of directors. Monitoring Plan ? The CFO and Manager of Financial Strategy and Budgeting will monitor monthly the budget to actual variance and present forecasted information monthly. Additionally, an amended budget will be presented to the board for approval if necessary. Date of Completion - Nov 1, 2022 People Responsible ? Elizabeth Winke, Controller & Interim CFO & Nadine Blanco, Manager of Financial Strategy and Budgeting Finding 2022-002 Corrective Action Steps Taken ? The management company, on behalf of Plymouth Educational Center, is working with the equipment vendor to rectify the shipping issue. Future Steps to be implemented ? The technology team will include receipt dates within the equipment tracking system and will follow up on any discrepancies identified from purchasing, to receipt of goods, to payment of goods. Additionally, those governed with approval of invoices will verify receipt of equipment prior to invoice approval and payment. Monitoring Plan ? Equipment inventory will be verified quarterly for new inventory purchases versus grant reimbursements to confirm all inventory has been received and is accounted for against the grant, including appropriate tagging of equipment. Date of Completion ? November 1, 2022 Person Responsible ? Roberto Vargas, Director of IT, and Karey Henderson, Managing Director of Operations PLYMOUTH

Finding Number: 2022-001 Anticipated Completion Date: 07/19/2022 Responsible Contact Person: Katherine Miranda, University Registrar Kelly Burt, Assistant Registrar Records Management and Reporting Planned Corrective Action: Ensure all graduation dates are reported on enrollment reporting within 30 days of the status change Due to new procedures, reporting processes and new staff, a group of our Spring 2022 graduates were not reported in a timely manner. Once we were made aware of this issue, we went into immediate action to correct the error. We worked with Clearinghouse to confirm our own misconceptions and ways to remedy the error. We updated all records individually through the Clearinghouse system. After all records were corrected, we updated our staff manual to ensure this does not occur in the future. Staff will continue to review all records to ensure accurate and timely reporting.

Finding Number: 2022-001 Condition: The Hospital?s controls in place for reporting submissions did not identify that the lost revenue amounts reported in the period 3 portal submission did not consistently follow the Hospital's Option iii methodology. Planned Corrective Action: The Hospital reviewed its process surrounding the reporting of lost revenue, implemented additional levels of review, and corrected the issue with its period 4 portal submission. Contact person responsible for corrective action: Jenee Seibert, CFO Anticipated Completion Date: 5/12/2023

Finding 2022-001 - Schedule of Expenditures of Federal Awards United States Department of Education Pass Through Entity: Texas Education Agency Federal Program: American Rescue Plan ? Elementary and Secondary School Emergency Relief (ARP ESSER) Assistance Listing Number: 84.425U Federal Award Number: S425U210042 Federal Award Year 2022 Repeat Comment: No Type of Finding: Material Weakness Condition: When reviewing the net assets released from restriction in the draft financial statements presented to the board, management determined and brought to the attention of the auditors the net assets restricted for pre-award costs for the ESSER federal program ($1,976,911) should have been released from restrictions during fiscal year ending June 30, 2022. The auditor, when tying the draft schedule of expenditures of federal awards to the updated schedules, determined the Organization had not included the pre-award federal expenditures related to the ESSER federal program. As a result, the initial testing of the ESSER major program did not include $1,976,991 in ESSER expenditures. When this was brought to management?s attention, the schedule of expenditures of federal awards was updated and the additional expenditures provided for testing. Cause: The additional $1,976,991 was related to ?pre-award? dollars awarded during fiscal year ended June 30, 2022, where allowable expenditures incurred in the previous year were permitted by the grant to be used for the ESSER funds awarded in the current year. Management was not aware of the requirement to include these amounts on the schedule of expenditures of federal awards. Recommendation: We recommend management of the Organization strengthen their internal controls to ensure all federal awards are included on the schedule of expenditures of federal awards. Corrective Action Plan: Prior to June 30, 2023, management will prepare an administrative procedure that requires the auditor to provide a draft financial and compliance report at least one (1) week prior to the meeting of the Board. In the procedure, management will require staff to reconcile the Schedule of Expenditures of Federal Awards to the Statement of Activities and other relevant accounting information to ensure the accuracy and completeness of the amounts disclosed. Person Responsible: Kevin Byrne, Vice President of Finance Anticipated Completion Date: June 30, 2023