Corrective Action Plans

Corrective Action Plan: The Ohio Department of Job and Family Services (ODJFS), in coordination with the Ohio Department of Medicaid (ODM), the Department of Administrative Services (DAS), and our vendor teams will continue to work to address system design weaknesses by identifying and prioritizing system changes and updates that impact eligibility determinations and benefit amounts as well as alert volume and processing improvements. Weekly problem review meetings will continue to be held to identify reported system issues and track any needed updates through the normal prioritization and slotting process. These changes will be delivered according to the agreed upon release cadence based on business priority and impact. Upon delivery of such system changes, the team will monitor production to determine if the desired outcome was achieved. ODM and ODJFS continue to meet to analyze the alerts in Ohio Benefits and the group presents recommendations to our vendor team for overall system alert improvements; these recommendations were prioritized and corrected in our normal release cadence through calendar year 2022, with the most recent release occurring in February 2022. The next alert centered release is scheduled for April 2023. Comprehensive alert reduction efforts thus far have reduced the overall ~29 million backlog alerts and drove a ~22 million annual reduction in new arrival of alerts. A system release specific to IEVSs enhancements is planned for R4.6.1 (April 2023) which will streamline the process for county staff to process IEVS matches from the IRS Unearned Income interface. There will be both E-Verify enhancements and a change in the match logic which will result in a reduction in the volume of IRS records that are flagged as IEVS matches. Caseworker time spent on processing IRS IEVS matches is expected to reduce; remaining time spent on IRS IEVS matches is expected to have more value by allowing caseworkers to focus time on matches with an eligibility impact or potential for benefit recovery. Periodic and timely review of IEVS will be completed as follows: ? Each state Fraud Control Specialist is assigned designated county agencies to provide technical assistance and training, as well as to monitor certain reports to ensure compliance with state and federal regulations. The counties will be monitored monthly and those not showing improvement will be offered training and technical assistance as appropriate. When a Fraud Control Specialist notices a county agency falling short of a required threshold, contact is made with county officials and the offer of assistance will be made. Once the number of alerts becomes manageable by the county agency, a Continuous Improvement Plan (CIP) may be required of the county agency if the issue continues over a four-month period of continuous contact and assistance. This type of CIP may be initiated outside the scope of Fraud Control Triad Review. ? The Fraud Control Section will conduct follow-up on Continuous Improvement Plans (CIPs) as part of the Triad Review process. When the county agency responds with a CIP, it is reviewed for clarity, action, and desired outcomes. Once approved, the Fraud Control Section will issue a closure letter for the Triad Review; however, a CIP may remain open for a longer period of time if warranted. We are in the process of creating a procedure and a closure letter for CIPs alone. This procedure will be implemented by June 30, 2023. ? Supervisory Reviews are monitored as part of the Triad Review process. Currently, the question is posed to the county supervisor about conducting random supervisory reviews. We are in the process of creating a procedure within the Triad Review process to be provided a list of IEVS matches that were reviewed by the supervisor. This procedure will be communicated statewide through the Fraud Control Training Program and enforced and verified during the Triad Review process.To continue to support the county caseworker staff, the Ohio Benefits Program provides training materials and promotes ongoing learning about related business processes without requiring in-person training. For each major system release or system enhancement that impacts the end user, updated training materials are produced and disseminated. These materials may take the form of job aids that are posted to the project website, train-the-trainer sessions, and video conferences where system users can ask live questions about the system. In addition to system support and training, the Ohio Department of Job and Family Services (ODJFS) in coordination with the Ohio Department of Medicaid (ODM) continue to provide the following methods by which training and system guidance is provided to CDJFS employees: 1. New Worker Training (NWT): A 12-week, comprehensive Policy and Systems training for new users (or refresher training for existing users) in the Ohio Benefits Worker Portal (OBWP) has been developed. The courses cover Policy and Systems overview, TANF, SNAP, Cash and Case Maintenance, along with the primary Medicaid programs (MAGI & ABD). The training is comprised of multiple, self-guided, Web Based Training (WBT) modules and virtual Instructor Led Training (vILT) sessions that provides `hands on? instruction. 2. Monthly Statewide County Conference: Monthly statewide webinars to cover general OFA updates for SNAP and Cash. These meetings include OFA?s Policy and TA staff, Outcomes and Analysis, Data Reporting, Quality Control, Automated Systems Training and the OB-IMS Help Desk. All areas share information on both refresher topics and emerging policy as well as systems issues where additional training is needed. The meetings are facilitated by the Program & Policy Services area within the Policy section of OFA and provides input on issues needing additional training and guidance. AST provides copies of job aids and other training documents during these support meetings. Recording of statewide training sessions are made available for counties to access on demand. 3. Operational Support Webinars: Bi-weekly webinars are delivered jointly by ODJFS and ODM, to counties for systems-based information and instruction on emerging topics and training related issues. Topics for the webinar are identified through a coordinated effort with the OB-IMS Help Desk, the weekly PBI/Defect Closure meetings and On Demand System Inquiries (received via email), to review any issues or concerns discovered by the Help Desk during the previous week. Counties are also able to submit questions and request topics in advance of the webinars to be reviewed and covered as part of the webinar agenda. 4. Ohio Benefits System Release Webinars: These are delivered jointly by ODJFS and ODM to inform counties about updates and enhancements made in each Ohio Benefits system release. During these webinars, counties are provided information regarding proper systems operation based on the items included in the release and target items that no longer require a workaround by the county worker. 5. Job Aids Available on the Innerweb: Automated Systems Training (AST) routinely provides systems-related job aids for county use that target specific topics and pain points for the counties. On the average, one to two new job aids are either created or updated each week and the Innerweb training pages are routinely referenced during New Worker Training, Operational Support, and Ohio Benefits system release webinars. 6. Quarterly Regional County Operational Support Meetings: Both the Automated Systems Training (AST) and the OB-IMS Help Desk participate in these regionally based, quarterly meetings, along with ODM Operations, Systems, and Policy staff. They provide guidance and system instruction on emerging systems issues and/or where additional training is needed. The meetings are facilitated by the Program & Policy Services area within the Policy section of OFA and provides input on issues needing additional training and guidance. AST provides copies of job aids and other training documents during these support meetings. 7. Quarterly Work Activity Round Table Meetings: Automated Systems Training (AST) and the OB-IMS Help Desk participate in these regionally based, quarterly meetings to provide guidance and system instruction related to TANF Work Activities. The meetings are facilitated by the Outcomes & Analysis area within the Policy section of OFA and provides input on issues needing additional training and guidance. 8. On Demand Systems Inquiries: Automated Systems Training (AST) maintains an email box where counties can submit inquiries about correct data entry and system functionality within the OBWP. Timely responses are provided to these inquiries frequently providing Help Desk confirmed instructions in a timely manner. Many of these inquiries are shared at the meetings and communications channels listed above. 9. System Support for Targeted Policy Training: Automated Systems Training (AST) provides system related content to support targeted Policy training topics to provide a holistic view of the application of policies within OBWP. The targeted training is delivered via virtual meetings and/or WBT modules. Some topic examples include `Expedited SNAP,? `Delayed Processing? and `Early Denial.? Recording of statewide trainings are made available for counties to access later.Interagency Agreement An Interagency Agreement is entered into by the Ohio Department of Job and Family Services (ODJFS) and the Ohio Department of Administrative Services (DAS). This Agreement is entered into for the purpose of setting forth the roles and responsibilities, budget methodology and payment terms, data sharing restrictions, security protocols, and compliance requirements for the Ohio Benefits Program. DAS and ODJFS has completed extensive policy, program, and legal reviews and the final Agreement is in circulation to secure DAS and ODJFS Director?s signatures.

Corrective Action Plan: Each state Fraud Control Specialist is assigned designated county agencies to provide technical assistance and training, as well as to monitor certain reports to ensure compliance with state and federal regulations. The counties will be monitored monthly and those not showing improvement will be offered training and technical assistance as appropriate. When a Fraud Control Specialist notices a county agency falling short of a required threshold, contact is made with county officials and the offer of assistance will be made. Once the number of alerts becomes manageable by the county agency, a Continuous Improvement Plan (CIP) may be required of the county agency if the issue continues over a four-month period of continuous contact and assistance. This type of CIP may be initiated outside the scope of Fraud Control Triad Review. The Fraud Control Section will conduct follow-up on CIPs as part of the Triad Review process. When the county agency responds with a CIP, it is reviewed for clarity, action, and desired outcomes. Once approved, the Fraud Control Section will issue a closure letter for the Triad Review; however, a CIP may remain open for a longer period of time if warranted. We are in the process of creating a procedure and a closure letter for CIPs alone. This procedure will be implemented by June 30, 2023. Supervisory Reviews are monitored as part of the Triad Review process. Currently, the question is posed to the county supervisor about conducting random supervisory reviews. We are in the process of creating a procedure within the Triad Review process to be provided a list of IEVS matches that were reviewed by the supervisor. This procedure will be communicated statewide through the Fraud Control Training Program and enforced and verified during the Triad Review process. Anticipated Completion Date for Corrective Action: ? The Ohio Benefits system improvement work and IEVS alert training ? Completed and continuing in fiscal year 2023 ? IEVS enhancement system release - April 2023 ? Triad Review closure letter procedures ? June 2023 Contact Person Responsible for Corrective Action Chris Dickens, Fraud Control Section Chief, Ohio Department of Job and Family Services 30 E. Broad Street, 37th Floor, Columbus, OH 43215 Phone Number: 614-387-5499, E-Mail Address: Chris.Dickens@jfs.ohio.gov

FINDING 2022-009 Contact Person Responsible for Corrective Action: Danica Houze, Chief Financial Officer Contact Phone Number: 812-274-8001 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: In the future when we have construction projects being paid from federal funds we will request the contractor to submit payroll logs weekly to the Director of Facilities. We will also require them to include weekly payroll reports in the pay applications. Anticipated Completion Date: 2/13/23

FINDING 2022-008 Contact Person Responsible for Corrective Action: Danica Houze, Chief Financial Officer Contact Phone Number: 812-274-8001 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Documentation will be kept to ensure evidence of preparation, review, and approval of the Grant Reporting. Two individuals will sign off on all future reports and documentation will be kept on file. Anticipated Completion Date: 2/13/2023

FINDING 2022-004 Contact Person Responsible for Corrective Action: Janet McCreary, Director of Curriculum, Instruction, & Assessments Contact Phone Number: 812-274-8001 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The high school will create procedures for tracking enrollments, removals, transfers, expulsion, and graduation numbers. Beginning in FY23, a cohort review is administered three times yearly (September, February, and June) by administration and school counselors. Student Services clerk reviews the withdrawal file for any student marked unknown or undetermined to obtain any necessary documentation and/or signatures. After review and confirmation of the appropriate mobility code and documentation, administration will work with the district technology team to correct errors in data exchange. Anticipated Completion Date: 2/13/2023

FINDING 2022-003 Contact Person Responsible for Corrective Action: Janet McCreary, Director of Curriculum, Instruction, & Assessments Contact Phone Number: 812-274-8001 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Data Management Specialist will save all reports submitted to the DOE. This will ensure that supporting documentation is kept that will be used determine Eligibility for Title I. The Title I Compliance Specialist/Grants & Compliance Specialist will verify the information for accuracy and keep documentation of the review. Anticipated Completion Date: 2/13/2023

FINDING 2022-005 Contact Person Responsible for Corrective Action: Vonessia Harmon, Business Manager Contact Phone Number: 765-569-4195 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Due to the unexpected COVID19 pandemic along with the addition of new ESSER & CARES grants & their various reporting requirements, the Business Manager failed to obtain review and signature from the Superintendent for the annual data collection reports. Effective immediately, in addition to the monthly reimbursement requests, the Superintendent will also properly review & sign off on all State & Federal grant reporting documents prepared & submitted by the Business Manager. Audit Evidence: Superintendent Signature & Date In the NCP Business Office Handbook; under Grants; the following has been added: ?The Superintendent will properly review and sign off on each reporting requirement to ensure accuracy.? Anticipated Completion Date: Effective immediately

FINDING 2022-004 Contact Person Responsible for Corrective Action: Mike Schimpf, Superintendent Contact Phone Number: 765-569-4191 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The material weakness in graduation cohort supporting documentation was due to the performance of previous building administration at the High School. A new building Principal and Guidance counselor have replaced those individuals. It is the responsibility of the Superintendent to ensure that the new building administrators are following IC 20-26-13 for graduation Cohort rate determination. Effective immediately, the High School building Principal and HS Guidance counselor will be given a copy of the graduation Cohort compliance regulations. The Superintendent will monitor their compliance and supporting documentation as needed. Anticipated Completion Date: Effective immediately

Finding Ref. No. 2022-002 Finding: The Uniform Guidance, 2 CFR 200.303, requires non-Federal entities receiving Federal Awards (i.e., auditee management) to establish and maintain effective internal controls over the Federal Award that provide reasonable assurance that the non-Federal entity is managing the Federal Award in compliance with Federal statutes, regulations, and terms and conditions of the Federal Award. 20 CFR 604.3(a) requires a State to only pay an individual who is able to work and available for work for the week which Unemployment Compensation (UC) is claimed. Based on work performed on unemployment compensation payments at the Alabama Department of Labor, for the period of October 1, 2021, through September 30, 2022, we identified 243 payments, totaling $58,809.00, which were made to 22 deceased claimants. We also identified an additional 186 payments, totaling $42,276.00, which were made to 27 incarcerated claimants. The combined improper payments to deceased or incarcerated claimants total $101,085.00 for the Unemployment Insurance Program. The Alabama Department of Labor did not have internal controls in place which were adequately designed to identify deceased or incarcerated claimants in a timely manner, in order to help prevent and/or detect improper payments. The lack of a well-designed system of internal controls, to identify deceased or incarcerated claimants, could cause the Alabama Department of Labor to continue to pay benefits to claimants who are deceased or incarcerated. Recommendation: The Alabama Department of Labor should establish and maintain effective internal controls to help ensure payments are not made to deceased or incarcerated claimants. Response/Views: We agree with the finding. Corrective Action Planned: ADOL now utilizes IDV through the Integrity Data Hub (IDH) for death crossmatch, giving ADOL the capability to crossmatch all claimants through the IDV. However, the review process is manual at this time. ADOL continues to pursue a fully automated process with the system vendor. ADOL is also working with the Interstate Connection Network (ICON) through the National Association of State Workforce Agencies (NASWA) to implement a match of SSN?s with the Social Security Administration?s Prisoner Update Processing System (PUPS). This will allow records to be checked in a nationwide database not just the State of Alabama. Reason for the Recurrence: The cause of this was due to the workload of pandemic claims and the lack of requirements to provide proof of income and employment. Prior to the pandemic a person had to have wages in order to qualify for benefits, eliminating a deceased person of more than 2 years from being monetarily eligible for benefits. Any remaining claimants that had died would be reported by the employer or through returned mail or a surviving of family member. Any notice of deceased person would be reviewed. With no way to verify whether a person was deceased or not, some did pay benefits. Anticipated Completion Date: ADOL implemented checking claims through IDH June 2022. Netacent, the vendor who maintains ADOL?s unemployment system, anticipates the PUPs project to be fully functioning by December 31,2023. Contact Person(s): Brent Langley, Assistant Unemployment Administrator

FINDING 2022-008 (Auditor Assigned Reference Number) Contact Person Responsible for Corrective Action: Todd VanDerWeele Contact Phone Number: 574.223.2159 Views of Responsible Official: We concur with the finding. The Head Secretary at Rochester High School will document any student that is removed from the high school graduation cohort. The secretary will have the high school principal review and approve this documentation, and the secretary will place in the student?s permanent file. Anticipated Completion Date: May 31, 2023

FINDING 2022-007 (Auditor Assigned Reference Number) Contact Person Responsible for Corrective Action: Todd VanDerWeele Contact Phone Number: 574.223.2159 Views of Responsible Official: We concur with the finding. 1. The Curriculum Director will create a control at the beginning of the school year so that we can properly ensure all parties receive test security training. This will be a google document, separated by tabs at the bottom for each building, with the names of all staff members. The control will also contain columns that can be check marked when test security forms and training is completed. The control will also contain a box to show the date training was completed. 2. We will have this document for training on test security in each building in August and September. Each staff member will sign the document to show they received the training. 3. The Curriculum Director will create an agenda for each training to properly ensure all staff members are trained. 4. All staff members will also be required to sign the test security form provided by the IDOE at their respective training. 5. For all staff members who miss training at their building, a Google Form will be provided with all of the test security information. Staff members will be required to fill out the form and watch the training video. The form will be time and date stamped. 6. The Curriculum Director will update the control at least once a week until all staff members are trained. Anticipated Completion Date: February 2024

Finding Number: 2022-001 Planned Corrective Action: Mid-East's Adult Education Financial Coordinator retired at the end of Fiscal Year 2021. As any new position, there was a learning curve and the new Financial Aid Coordinator received limited training with the former Coordinator. Consultants were hired to help, but this specific reconciliation process was not discussed. There has been a recent change in the Adult Education Director's position, and it is the intention of the new Director to eventually cross-train positions. This will assist in the future for a smoother transition between employees leaving and new employees hired. Since the finding, the Adult Education Financial Coordinator has established a checklist of items that need to be completed for each drawdown. This checklist will be placed in each drawdown folder. The Monthly Drawdown Reconciliation plan will include beginning with verifying with Common Origination and Disbursement Center (COD) School Summery report prior to the disbursement. Once the disbursement information is entered into Ed-Express and transferred to COD for the month review of the School Summary report, it will be reviewed to verify that the "Cash>Net Accepted & Posted Disbursements" matches the Achademix Drawdown Batch. Then, again when the disbursement funds are disbursed, a review of the COD School Summary report will occur. At any time, if a variance occurs, it will be addressed immediately. This plan of action went into place with the February 17, 2023 disbursement process. All documentation of any reconciliations will be kept in each drawdown file. The variance of the $866.00 occurred during the final drawdown of Fiscal Year 2022. As the reconciliation process was not in place, the variance was not discovered. As a new Fisca Year started, it was a new batch of funds, and the $866 variance was not discovered until the audit process. The variance was researched and corrected. The correction was located and corrected in Ed Express and had no monetary effect. The School Summary report from COD Cash>Net Accepted & Posted Disbursements" is at zero for 2021-2022, and documentation has been kept on that. The newly implemented checklist and process for reconciliation will prevent variances from happening in the future. Anticipated Completion Date: Currently in place and will continue. Responsible Contact Person: Thasia Shilling, Adult Education Financial Aid Coordinator

Finding 2022-002 ? Reporting Type of Finding: Compliance and material weakness in internal control over compliance Corrective Action Plan: This process has already been corrected and the certification for ETA-9130 has been updated to an employee who can certify on behalf of the Organization. These reports are prepared by accounting and will be reviewed and certified by the program director.

Finding 2022-003 ? Approval of Invoices Type of Finding: Material Weakness in internal control over compliance Corrective Action Plan: The Organization is already in the process of reviewing its policy surrounding the review process for invoices. The Organization will be implementing an approval sheet for all expenses on credit cards and other federal charges. Accounting will only charge the expense to the grants once it has verified the expense has gone through the proper approval channels.

FINDING 2022-003 Finding Subject: COVID-19 ? Coronavirus State and Local Fiscal Recovery Funds ? Reporting Summary of Finding: Material weaknesses were found related to Reporting for the COVID-19 ? Coronavirus State and Local Fiscal Recovery Funds program. Contact Person Responsible for Corrective Action: Connie A Berger, Clerk-Treasurer Contact Phone Number and Email Address: 812-547-2349 clerk-treasurer@tellcity.in.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Corrective Action Plan will happen in 2024 when submitting information in the project and expenditure report due the US Department of the Treasury. I will have one of the Deputy Clerk-Treasurers review and check the information before I submit the information, and also have them watch when the information is submitted into the computer system. The City elected to claim all the SLFRF allocation as revenue loss. Anticipated Completion Date: The Completion Date for the Corrective Action Plan will be April 30, 2024. This is the date that the next yearly report will be due.

FINDING 2022-003 (Auditor Assigned Reference Number) Contact Person Responsible for Corrective Action: Tina Gross Contact Phone Number: 317-346-8749 Views of Responsible Official: We concur with this finding. Description of Corrective Action Plan: The district will implement an additional review of reports submitted for federal grants, and document that review of any final submission. Anticipated Completion Date: 2-23-23

FINDING 2022-002 Contact Person Responsible for Corrective Action: Andrew Nicodemus Contact Phone Number: 765-362-2342 Views of the Responsible Official: We agree with the finding. Description of Corrective Action Plan: Crawfordsville Community School Corporation plans to review all internal control procedures, including the control procedures over Program Income for the Child Nutrition Cluster. After this review, we will implement a system to ensure that compliance with the federal program income requirements is met. Anticipated Completion Date: We expect this Corrective Action to be implement by the end of April 2023 to allow for a full review of all internal control processes and procedures.

FINDING 2022-003 (Auditor Assigned Reference Number) Contact Person Responsible for Corrective Action: Monica Kegerreis, Assistant Superintendent Contact Phone Number: 574-831-2188 Views of Responsible Official: We concur with the finding Description of Corrective Action Plan: The ESSER reports requested by IDOE will follow the same procedures of all FER reports. The ?data collection? for the ESSER grants was not identified as a financial report, and thus did not follow these processes. Now that we know this is a financial report, the steps below will be followed. The grant was initially not set up correctly and expenses were expended to and then transferred to the correct accounts once the grants were set up correctly. These changes were in flux when the report was requested, so what was reported at the time of the report is no longer what is reflected in grants? ledgers. The corrective action will require that the program director gathers the initial data, the data will be reviewed by the administrative assistant to the grants? director, and then reviewed by the Treasurer. All three employees will sign/initial a printed copy of the report before it is submitted. Data regarding students served by programs and staff reports will be reviewed by the program director and the data specialist and signed off on by both parties to ensure accuracy. Anticipated Completion Date: March 24, 2023

Finding: 2022-001 Federal Agency Name: Department of Health and Human Services Program Name: COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution, COVID-19 HRSA Claims Reimbursement for the Uninsured Program and the COVID-19 Coverage Assistance Fund Federal Financial Assistance Listing #: #93.498, 93.461 Finding Summary: Management prepared the schedule of expenditures of federal awards for the year ended June 30, 2022. During testing, the auditors decreased the amount reported for the COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution program (PRF) to the amounts reported within the Department of Health and Human Services (HHS) for Period 2 and Period 3 Special Report. In addition, adjustments were made to decrease the amount reported for the COVID-19 HRSA Claims Reimbursement for the Uninsured Program and the COVID-19 Coverage Assistance Fund (Uninsured Program) to total receipt of monies received from the federal agency during the year ended June 30, 2022. Finding 2022-001 relates solely to which period expenditures are included in the schedule of expenditures of federal awards as compared to periods deposited from the Uninsured Program and to periods in which they are included in Period 2 and Period 3 reports. Responsible Individuals: Austin Willuweit, Vice President of Finance Jen Schmaltz, Corporate Controller Corrective Action Plan: Monument Health will review future schedules of expenditures of federal awards to ensure period reporting consistent with agency filings and deposit periods. Anticipated Completion Date: June 30, 2023

Finding 2022-005 Federal Agency Name: Department of Health and Human Services Program Name: COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution FFAL #93.498 Finding Summary: The review process for the Period 4 HHS report submitted did not detect the error reported regarding the actual reported revenues for 2019 that were incorrectly keyed into the portal submission. Additionally, the revenues for 2022 were reported based upon actual revenue billed and reported within the electronic medical records (EMR) system which does not include monthly or quarterly adjustments posted to the general ledger. Responsible Individuals: Amanda Soesbe, Chief Finance Officer Corrective Action Plan: There are no further PRF Portal submissions. The control aspect implemented to involve review of the portal submission will be expanded if further submissions are warranted. An expanded control would require the CFO to review in detail with the reviewer how the numbers were obtained and provide all supporting documentation for cross reference against the requirements. This may require extra time to educate and inform the reviewer of the PRF program and requirements. Anticipated Completion Date: 12-31-2023

Finding 2022-006 Federal Agency Name: Department of Agriculture Program Name: Community Facilities Loans and Grants FFAL #10.766 Finding Summary: We elected to make a withdrawal and subsequent replenishment on the reserve account. There was no documented secondary review of the monthly reserve fund account reconciliations as compared to the required minimum balance. Responsible Individuals: Amanda Soesbe, Chief Finance Officer Corrective Action Plan: An automatic transfer to fund the debt reserve account was established in January 2023 and repeats each month until the fund has been properly funded. Additionally the finance packets presented to the governing board will include monthly oversight of debt reserve balances and whether or not the facility is in compliance. Anticipated Completion Date: 9-30-2023

FINDING 2022-003: COVID-19 ? Coronavirus State and Local Fiscal Recovery Funds ? Internal Controls Contact Person Responsible for Corrective Action: Clerk-Treasurer Richard Aguirre Contact Phone Number: (574) 533-8623 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: To enhance internal controls, the City of Goshen Clerk-Treasurer?s Office has identified and segregated duties related to the preparation of the Schedule of Federal Awards (SEFA). Using the checklist from the SBOA as a reference, an internal checklist has been created to use for annual review of the policies and procedures. For this year in particular, a revisiting of the policies and procedures is necessary to address and clarify segregation of duties, both for internal and external purposes. The design, including segregation of duties, exists between the Clerk-Treasurer, Deputy Clerk-Treasurer, and the Grants Manager. However, the reporting procedures can be improved, specifically in how implementation generates verifiable proof and documentation. What is cited below is more of a ?retroactive finding? from 2021, since SBOA did not audit these funds previously. There also had been a series of difficulties with the Treasury portal; by the time the system was corrected, the reports were submitted. Regarding the procedures, the City of Goshen undertook data entry, review, and submission using three different individuals, and there is evidence of this review that has not been acknowledged by the SBOA. The review and oversight process, however, is being improved in light of this new finding. The revision of policies will more effectively articulate the steps that effect internal control and ensure consistent implementation. To ensure the accuracy of Project and Expenditure Reports prior to submission to the U.S. Department of Treasury, the preparer will email the reviewer when a report is ready for review. The reviewer will respond to the email when the information is reviewed and include any errors noted that need to be corrected. This email correspondence will be kept and provided to state auditors. The City also will maintain an approval sheet indicating that the review of the report has been completed and the reviewer will sign and date the approval sheet and note any errors found during the review. Anticipated Completion Date: This process should be reviewed and ready by the next SEFA preparation, in January 2024. ? Completed and submitted to the State Board of Accounts, Aug. 29, 2023

FINDING 2022-005 Contact Person Responsible for Corrective Action: Brenda Layne, Food Service Director Contact Phone Number: 765-289-7323 Views of Responsible Official: We concur with the findings Description Qf Corrective Action Plan: The prompts have been fixed on the Distribution Report, so it will include all Cafeteria employees. The F.S.D. will also initial each time card and Distribution Report. In the future ALL Claims will be initialed by the F.S.D. And as additional control the Superintendent will also initial all claims prior to the School Board meeting. Anticipated Completion Date: February 2023

Corrective Action Plan Section III. Findings and Questioned Costs for Federal Awards Material Weakness in Internal Control Over Compliance ? Medicaid Cluster Finding 2022-001 and 2022-002 "See Corrective Action Plan for Chart/Table"

OPEN FOR CLIENT.