Corrective Action Plans

FINDING 2022-003 Contact Person Responsible for Corrective Action: Kyle Zahn Contact Phone Number: 765-883-5576 ext. 5112 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Director of Finance will conduct an internal audit of capital assets purchased and sold from 6/30/2022 to the current date in order to update the corporation?s capital assets records. New staff will also be trained on tracking capital assets transactions and completing the necessary documentation for future capital assets transactions. It is noted, a number of construction projects are scheduled in the near future which will result in capital assets being added. As such, after the completion of these projects, leadership will consider having the school?s contracted third-party capital assets consultant conduct an onsite inquiry visit to ensure the school?s records are accurate. Anticipated Completion Date: April 2023

Views of Responsible Officials, Corrective Action Plans, and Contact Information Pupil Services and Attendance will continue to provide policy guidance: 1. Provide ongoing reminders every other month through the Schoology communication platform regarding accurate enrollment, withdrawal codes and the MYPLN Essential Tips training to support with the withdrawal process, codes, and documentation. 2. Pupil Services and Attendance will continue to post resource tools such as the Certify Rules (this automated data validation tool allows users to efficiently identify data errors or omissions to improve the quality of student data in MiSiS) to support accurate enrollment and withdrawal procedures. 3. Pupil Services and Attendance will communicate with Local District Administration on disseminating information to school-site designees with audit findings to participate in the MYPLN training on accurate enrollment and withdrawal codes during school year 2023-24. 4. Pupil Services and Attendance will communicate with Office of Organizational Excellence to support in messaging the availability of the MYPLN training to support with the withdrawal process, codes, and documentation. 5. Will obtain written acknowledgement for completion of the MYPLN Essential Tips training to support with the withdrawal process, codes, and documentation from the schools identified with audit findings. Name: Elsy Rosado Title: Director, Pupil Services and Attendance Telephone: (213) 241-3844

Views of Responsible Officials, Planned Corrective Actions, and Contact Information Division of Adult and Career Education (DACE) will review the current process and implement the following: 1. Directive will be provided to DACE principals to stop enrolling 16?17-year-old students. 2. Instructions will be given to DACE Accelerated College and Career Transitions (ACCT) Advisors not to enroll students between ages 16-17 moving forward. 3. The District will utilize unrestricted funds for students under the age of 18 that are enrolled in the Workforce Innovation and Opportunity Act (WIOA) program. 4. DACE will continue to serve the existing 16?17-year-old ACCT student population through the end of the school year 2022-23 and use unrestricted funding sources other than WIOA. 5. During school year 2022-23 and henceforth, DACE will not report or claim any student outcomes other than those earned by students who are of 18 years of age and older. 6. DACE will amend the ACCT intake and enrollment policies and procedures in the DACE Counseling Handbook. Name: Megan Carroll Title: Program and Policy Development Coordinator Contact Information: mmc78271@lausd.net or (213) 241-3781 Name: Alejandra Salcedo Title: Federal Grants Specialist Contact Information: axs60041@lausd.net or (213) 241-3812

Finding ref number: 2022-002 Finding caption: The District did not have adequate internal controls for ensuring compliance with allowable activities and costs, equipment, and restricted purpose requirements. Name, address, and telephone of District contact person: Joe Vetter, 2320 Borst Avenue Centralia Washington 98531 ? (360)-330-7600 Corrective action the auditee plans to take in response to the finding: Going forward, the District will update Departments on procurement requirements to ensure that prevailing wage is included in contracts for public works projects that use Federal dollars. We will also ensure that Vendors who are completing public works projects for the District are sending their certified payroll into the District for projects over $2,000. Anticipated date to complete the corrective action: 5/24/2023

Corrective Action Plan Finding 2022-01 Federal Agency Name: U.S. Department of Education Program Name: COVID-19 Elementary and Secondary School Emergency Relief (ESSER) Assistance Listing Number: 84.425D, 84.425U Finding Summary: The Davis-Bacon and Related Acts apply to contractor and subcontractors performing on federally funded or assisted contracts in excess of $2,000 for the construction, alteration, or repair (including painting and decorating) of public buildings or public works. Davis- Bacon Act and Related Act contractors and subcontractors must pay their laborers and mechanics employed under the contract no less than the locally prevailing wages and fringe benefits for the corresponding work on similar projects in the area. The District entered into an HVAC replacement project and roof repair project with federal funds, but did not monitor contractor and subcontractor payroll to ensure prevailing wage rates were paid. Responsible Individuals: Jenny Smith Corrective Action Plan: Prior to finalizing any construction, alteration, or repair projects utilizing federal funds with a planned expenditure in excess of $2,000, PISD will research the latest local wage determination rates. PISD will share these wage determination rates with the contractor/subcontractor, and will be ensured through the contract that the contractor/subcontractor will comply with the Davis-Bacon and Related Acts. PISD will notify the contractor/subcontractor of the necessity of receiving certified payrolls as needed, so that PISD may monitor requirements throughout the project. Anticipated Completion Date: December 1, 2022

US Department of Health and Human Services HIV CARE Formula Grants Passed-through State of Hawaii Department of Health 1250 Punchbowl Street Honolulu, HI 96813 Hawaii Health & Harm Reduction Center (HHHRC) respectfully submits the following corrective action plan for the year ended June 30, 2022 for the finding identified in the schedule of findings and questioned costs as identified by our auditors, KKDLY LLC, who are located at Topa Financial Center, 745 Fort Street, Suite 2100, Honolulu HI 96813 FEDERAL AWARD FINDINGS AND QUESTIONED COSTS Material Weakness Finding 2022-001 Eligibility U.S. Department of Health and Human Services HIV CARE Formula Grants CFDA No. 93.917 Condition During the in-take and re-assessment process for the Ryan White HIV/AIDS Part B (RWB) program, case managers are responsible for (1) ensuring that all required forms and documents are received from clients, (2) reviewing those forms and documents for completeness and accuracy to verify that RWB program eligibility requirements are met; and (3) inputting the client?s information into e2 Hawaii, HHHRC?s system to monitor and track all RWB program clients. Effective April 1, 2022, HHHRC updated their policies and procedures, requiring a manager or knowledgeable employee other than the case manager to sign off on the certification forms to document their review of eligibility determinations for completeness and accuracy. We selected a sample of 60 clients receiving assistance under the RWB program as part of our eligibility testing. Within the 60 files, we examined 61 annual or semi-annual certification forms dated prior to April 1, 2022, and 32 annual or semi-annual certification forms dated April 1, 2022 or later. Of the 61 certification forms dated prior to April 1, 2022, we noted 59 certification forms did not contain evidence of a review performed by a manager or a knowledgeable employee other than the case manager. Of the 32 certification forms dated April 1, 2022 or later, we noted 6 certification forms were not signed off by a manager or knowledgeable employee other than the case manager. Criteria The Uniform Guidance, as prescribed in 2 CFR section 200.305, requires that non-federal entities receiving federal awards establish and maintain internal control over federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Internal controls over compliance with RWB eligibility requirements should include formal policies and procedures to ensure that data used to determine eligibility are complete and accurate in compliance with RWB program requirements. Eligibility determination procedures should be performed by case managers and reviewed by a manager or knowledgeable employee. Cause HHHRC implemented a formal policy requiring a manager or knowledgeable employee other than the case manager to sign off on the annual and semi-annual certification forms for each client. This formal policy was implemented on April 1, 2022. As such, the certification forms that were prepared prior to this date were not reviewed in accordance with this policy. Effect Without appropriate internal controls, noncompliance with RWB eligibility requirements may occur. Refer to Finding 2022-002 for instances of noncompliance identified in the current year. Identification of a Repeat Finding This finding was reported as a federal award finding in the immediate previous audit as Finding 2021-001. Recommendation We again recommend that HHHRC adhere to established policies and procedures to ensure that eligibility determinations performed by case managers during the in-take and re-assessment process are reviewed by a manager or knowledgeable employee other than the case manager for completeness and accuracy. Views of Responsible Officials and Planned Corrective Action HHHRC has implemented a formal policy and review process by a manager or higher level within the organization for every certification form within 1 week of completing the form. As noted earlier in the audit, HHHRC has made significant progress on this compliance measure with certifications dated after April 1, 2022 having significantly higher review rates (26/32 had review compared to 2/60 prior to April 1, 2022). Additionally, HHHRC has added an additional policy of the HIV Director or Clinical Deputy Director will review twice annually a random selection of at least 20 certification forms to ensure there was manager review documentation and this internal control will hopefully identify any deficiencies in this practice.

2022-001 Eligibility Housing Voucher Cluster Material Weakness in Internal Control Material Noncompliance Condition: Out of an approximate population of 1,436 tenants, 43 tenant files were tested and the following deficiencies were noted: ? 13 files had incorrect utility allowance calculations, ? 12 files had an incorrect income calculation, ? 2 files utilized incorrect payment standard, and ? 1 file was missing the 214 declaration for all tenants in household. Auditor Recommendations: The Authority should consider reevaluating their established procedures and controls in place to ensure full compliance in regards to eligibility. The Authority needs to consider the impact to the rest of the population of tenant files that were not selected as part of the auditor?s sample. Action Taken: This audit provides an opportunity for the Lakeland Housing Authority staff in correcting problems identified during the audit, we are implementing new procedures and increasing staff proficiency. The plan is as follows: ? The department under the supervision of Carlos Pizarro has hired an additional Quality Control and Compliance Specialist Courtney Mitchell, from now until done she will be leading with the assistance of the program's Assistant Manager Alondra Baez a full 100% file audit, ? The current staff will be re-trained on income calculation, file management, fair housing, occupancy, inspections, SEMAP, etc? ? The staff will continue to use a quality control sheet while processing all recertifications or changes, ? The HCV program issued a task order to one of the consultants to help us monitor the progress of our internal file audit.

2022-002 Eligibility Public and Indian Housing Program ? AL No. 14.850 Material Weakness in Internal Control Material Noncompliance Condition: Out of an approximate population of 257 tenants, 30 tenant files were tested and the following deficiencies were noted: ? 5 files had incorrect income calculations, and ? 1 file was completed but not entered into the system. Auditor Recommendations: The Authority should consider reevaluating their established procedures and controls in place to ensure full compliance in regards to eligibility. The Authority needs to consider the impact to the rest of the population of tenant files that were not selected as part of the auditor?s sample. Action Taken: This audit provides an opportunity for the Lakeland Housing Authority staff to correct problems identified during the audit, we are implementing new procedures and increasing staff proficiency. The plan is as follows: ? The department under the supervision of Carlos Pizarro has entered into a contract with a company named Preferred Compliance, we will be asking them to do a 100% review on all the public housing files, they are already reviewing all the files including admissions for the Low-Income Housing Tax Credits, ? The current staff will be re-trained on income calculation, file management, fair housing, occupancy, inspections, etc? ? The staff will continue to use a quality control sheet while processing all recertifications or changes,

Finding 2022-03 Federal Agency Name: Department of Health and Human Services Program Name: Community Facilities Loans and Grants CFDA #10.766 Finding Summary: Eide Bailly LLP prepared our draft of the schedule of expenditures of federal awards (SEF) Responsible Individuals: Mandy Robinson, Administrator and Carol Schoch, Business Office Manager Corrective Action Plan: Management will review the Health Center's internal financial reporting process to enable staff to draft as much of the Schedule as possible. Anticipated Completion Date: June 2023

Finding Number: 2022-001 Planned Corrective Action: The District acknowledges it did not obtain certified payroll information from Panzica Construction until December 2022 which was after the Auditor raised the issue with the District. The District will work to ensure compliance with grant terms, in this instance, by assigning compliance responsibility to the Cost Center Manager who negotiates, monitors, and receives invoices, and authorizes payments. Standard prevailing wage contract language will be developed in consultation with General Counsel?s Office with the language inserted into future contracts, as appropriate. Anticipated Completion Date: 06/30/23 Responsible Contact Person: Nathan J. Mortimer, Interim CFO

Parkston School District Business Manager, Craig Bruening, is the contact person responsible for the corrective action plan for this finding. This finding is due to the limited number of staff members employed in the district's business office. Staffing the office at an efficient and financially feasible level precludes the hiring of enough personnel to provide an ideal environment for the internal controls. Parkston School District adopted an Internal Controls and Procedures policy in January 2019 that we are following. We are aware of the weakness in internal controls and will adhere to policies and procedures we have in place while providing compensating controls to reduce the risk. This will be an ongoing process.

View of Responsible Officials and Corrective Actions: The following steps have been and are being taken regarding tenant certifications: 1. After contracting a third-party entity to review 10% of our files in Oct 2022, findings of said review led to the recommendation to retrain staff. 2. All Managers and assistant Managers received HCV & PH Rent Calculation Training In June 2023. 3. We are also currently working with our TA from HUD, Ms. Valerie Jackson. Ms. Jackson has identified, and is about to roll out training for our staff, to uniform and streamline our tenant files.

View of Responsible Officials and Corrective Actions: The following steps have been and are being taken regarding tenant certifications: 1. After contracting a third-party entity to review 10% of our files in Oct 2022, findings of said review led to the recommendation to retrain staff. 2. All Managers and assistant Managers received HCV & PH Rent Calculation Training In June 2023. 3. We are also currently working with our TA from HUD, Ms. Valerie Jackson. Ms. Jackson has identified, and is about to roll out training for our staff, to uniform and streamline our tenant files.

FINDING 2022-004 ? ELEMENTARY AND SECONDARY SCHOOL EMERGENCY RELIEF FUND DAVIS-BACON PREVAILING WAGE REQUIREMENTS Contact Person Responsible for Corrective Action: Lisa Baker, Business Manager Contact Person's Phone Number: 765-664-0624 Views of Responsible Official: There is no disagreement with the audit finding. Description of Correction Action Plan: When the school district is awarded federal funds that will be used for construction, alteration, or repair projects in excess of $2,000, the superintendent and/or business manager will notify the contractors that the project is being funded by federal funds and the requirements as outlined by the Davis-Bacon Act. In addition, the superintendent and/or the business manager will ensure that the contractors provide weekly payroll report certifications and will review the documents to ensure compliance with the wage rate requirements. Anticipated Completion Date: March 24, 2023

FINDING 2022-003 ? ELEMENTARY AND SECONDARY SCHOOL EMERGENCY RELIEF FUND REPORTING Contact Person Responsible for Corrective Action: Lisa Baker, Business Manager Contact Person's Phone Number: 765-664-0624 Views of Responsible Official: There is no disagreement with the audit finding. Description of Correction Action Plan: The recipients of the ESSER Data Reporting notice from the Indiana Department of Education, which include the director of curriculum and assessment and the business manager, will work together to ensure the data reports are properly completed, approved, and submitted by the due date. The director of curriculum and assessment will complete the reports and present them to the business manager who will review and approve the reports. The director of curriculum and assessment will submit the reports and make record of the date and time submitted. Anticipated Completion Date: March 24, 2023

Corrective Action Plan and Views of Responsible Officials The district did not remain aware of all of the reporting criteria related to the COVID testing audit requirements. These requirements have been noted, and our records relating to the safe return to school have been reviewed. The district fiscal team has been transitioned at the CBO and Director of Fiscal level. We will continue our work to maintain a thorough backup for all grant funds.

Program Name: Education Stabilization Fund ? Assistance Listing 84.425D & 84.425U Condition: All construction contracts in excess of $2,000 awarded by non-Federal entities must include a provision for compliance with the Davis-Bacon Act as supplemented by the Department of Labor regulations. This includes a requirement for the contractor to submit to the non-Federal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls). Corrective Action Plan: Management will work with contractors to get provisions included in construction contracts in progress and ensure new contracts have required provisions and obtain certified payrolls. Person Responsible for Corrective Action: David Jones, Business Manager Anticipated Completion Date ? FY2023

Finding #2022-003 ? Material Adjustments 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 needed 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

Condition: The Health Center?s Period 2 report to HHS included duplicate amounts for utilities expenses. Planned Corrective Action: Management will continue to refine processes to more diligently review expenses to ensure no duplicate expenses are included in the underlying supporting documentation. However, the Health Center included as eligible expenses in the Period 2 submission only those amounts up to the funding received, plus accrued interest. Had the noted questioned costs been identified prior to submission, the Health Center would have included additional amounts in the eligible expenses reported in the PRF reporting portal to demonstrate satisfactory use of the PRF funding received. The Health Center had $418,778 in additional eligible operating expenses which were not included in the Period 1 submission and $1,916,769 in additional eligible capital expenses not included in the Period 2 submission which would have been used to replace the identified questioned costs. Person Responsible: Wade Eschenbrenner, CFO Anticipated Completion Date: Ongoing

REPORTING Recommendation: We recommend the Department review the instructions for completion of the federal financial reports with training provided to the program staff preparing and reviewing the federal financial reports to ensure submitted reports are complete and timely. We recommend the Department implement effective processes and procedures to maintain the submitted reports and the documentation used to prepare the reports in the files of the Department. Corrective Action: The Department understands the issues and is taking corrective action to improve reporting. Due to the New Mexico emergent events that took place in FY22, the Department made the emergent events the Department?s priority and onboarding became a secondary focus for the Department. In FY23, the Department has shifted its priority to onboarding across the Department, and we have onboarded a Grants Unit Manager to oversee the reporting requirements of all federal grants. A procedural checklist will be implemented to ensure that: 1. the recipient share section is completed, 2. that financial reports are submitted to the Department timely, and 3. all Performance Progress Reports as submitted. Due Date of Completion: June 30, 2023 Responsible Person(s): Chief Financial Officer

CASH MANAGEMENT Recommendation: We realize the Department continues to have staff turnover. We recommend the Department review its process and implement effective policies, procedures, and controls to ensure the accounting records appropriately reflect the activity of the grant. The Department should consider efficiencies to make the process less cumbersome. While the Department has existing processes at the federal program level, there appears to be a need for higher level monitoring and reconciliation of federal program activity to ensure the completeness of federal program-level reconciliations and reimbursements. The Department should consider further contracting with an outside third party to aid in the process of performing reconciliations and billings. The deficit fund balance in the Federal Grants Fund (40280) should be reviewed and addressed. The Department should evaluate the need to obtain a deficiency appropriation or some other funding to cover this deficit. Corrective Action: The Department partially understands the issue. The Department will internally audit our expenditures to ensure that all transactions include an operating unit. The Department will also establish a checklist to include that all signatures are collected and that applicable documentation is received for reimbursement purposes. As part of our Sub Grant recipient review for Assistance Listings 97.036 and 97.067, we cannot reimburse the subrecipient until they submit applicable receipts for reimbursement and answer all requests for information as required by FEMA. Due Date of Completion: June 30, 2023 Responsible Person(s): Chief Financial Officer, Grants Unit Manager

Finding ref number: 2022-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with wage rate requirements. Name, address, and telephone of School District contact person: Heather C. Pinkerton 310 SW 16th St Chehalis, WA 98532 360-807-7207 Corrective action the auditee plans to take in response to the finding: It is highly unusual for the district to utilize federal funds for construction projects; the Covid-19 Education Stabilization Funds were an anomaly. The District?s Director of Business and Operations was unaware that prevailing wage clauses are required to be included in all public works contracts over $2,000 that are paid with federal funds. She was aware that prevailing wages need to be paid. The audit finding does not dispute that prevailing wages were paid appropriately, just that the clauses were not included in the contracts. To be very clear, this finding is for not having required language in contracts. The District is now aware that inclusion of the clauses is a compliance requirement. Going forward, it is unlikely that federal funds will be used for construction projects; however, when federal funds are utilized for construction projects, the District will either include the required prevailing wage rate clauses in its contracts or will obtain a separate signed clause with the required prevailing wage rate information. Anticipated date to complete the corrective action: Immediately

Finding 2022-001 Contact Person: Shari Reese Completion Date: March 13, 2023 Managements Response: Reporting Period 1: During Reporting Period 1, several subsidiaries of CaroMont Health, Inc. (?Parent?) received general distributions from the CARES Act Provider Relief Fund (?PRF?). Management reported all the general distributions received by the subsidiaries under the Parent entity in the portal, including the general distributions received by CaroMont Regional Medical Center (?Hospital?). Management listed the TINS of the subsidiaries, including the Hospital, in the Subsidiary Data section in the Parent?s portal. Management reported lost revenues utilizing option i, 2019 Actual Revenues, for the subsidiaries in the Parent?s portal. Reporting Period 2: During Reporting Period 2, the Hospital received both general and a targeted distributions (High Impact Area) from the CARES Act PRF. Management was unsure how to report so it contacted the HRSA Provider Support Line. HRSA opened case #00025470 and on January 18, 2022, Management had a phone conference with a representative of HRSA to discuss Period 2 reporting. HRSA advised management to report as follows: ? Hospital ? report the targeted distribution. Only report revenue, expenses, and data for the Hospital. ? Parent ? report general distributions. Don?t change any numbers from Period 1. Report revenue, expenses, and data for all subsidiary TINS listed in the portal. Management specifically remembers explaining to the HRSA representative that this approach would result in double counting of Total Unused Lost Revenues because Hospital revenues would be reported in both portals. The HRSA representative said that would be okay because Management answered YES to ?Is the parent entity reporting on your General Distribution payments?? in the Hospital portal, because the Hospital?s TIN is listed in the Subsidiary Information section in the Parent?s portal, and because the Parent?s TIN is listed in the Subsidiary Questionnaire section in the Hospital?s portal. Management documented these instructions in their notes made during the call. Management also specifically remembers asking the HRSA representative if the Hospital revenue should be removed from the prior quarters in the Parent portal when reporting Period 2 to which the representative replied, ?don?t change any numbers?. Management documented these instructions in their notes made during the call. Management filed the Period 2 reports for the Parent and the Hospital in accordance with HRSA?s instructions received during this phone conference. Management reported lost revenues under option i, 2019 Actual Revenues, for the listed subsidiaries in the Parent portal and for the Hospital in the Hospital portal. However, since Management was concerned this approach would result in double counting of unused lost revenues, they created a reconciliation spreadsheet on February 1, 2022. This spreadsheet documented unused lost revenues from the PRF Financial Reporting Summary Reporting pages in the Parent and Hospital portals for Period 1 and Period 2 and calculated the correct total unused lost revenues when the reports were combined and the double counting was eliminated. Management?s intent was to update this reconciliation during Period 4 reporting to ensure the remaining unused lost revenues in both the Parent and Hospital portals exceeded the combined reconciled lost revenue ? thereby ensuring there would be no double counting of lost revenues after all PRF reporting was completed. Reporting Period 4: During Report Period 4, several subsidiaries of the Parent received general distributions from the CARES Act PRF and targeted distributions from the American Rescue Plan (?ARP?). By the time the Portal Reporting opened for Period 4, CaroMont?s auditors were conducting the Single Audit for the year ended June 30, 2022, and reached out to Management to discuss their concerns about potential double counting of lost revenues in the Period 2 portal reporting. Management explained their process for reporting Period 2 and shared with the auditors their reconciliation spreadsheet that was created on February 1, 2022. The auditors had also performed a reconciliation that resulted in the same outcome. The auditors and management subsequently had several discussions on the different alternatives available to correct the Period 2 overstatement. Management evaluated the alternatives and ultimately decided to change its calculation of Lost Revenues in the Parent portal for Period 4 from option i, 2019 Actual Revenue, to option iii, Alternative Method of Calculating Lost Revenues Attributable to COVID-19. However, management continued to report lost revenues in the Hospital portal for Period 4 utilizing option i, 2019 Actual Revenue, as it had in Period 2. Management created another reconciliation spreadsheet on February 23, 2023 that demonstrated the Hospital revenue was excluded from the Parent?s lost revenue calculations in Period 4. This spreadsheet was uploaded as supporting documentation for option iii in the Parent?s portal. By changing from option i to option iii for lost revenues in the Parent portal for Period 4, management corrected the overstatement of lost revenues identified in the Audit of Federal Awards Performed in Accordance with U.S. Office of Management and Budget Uniform Guidance for the year ended June 30, 2022.

The District concurs and will review current year?s indirect rates for ESSER reimbursements.

Finding 2022-001 ? EXCESS FUND BALANCE IN FOOD SERVICE FUND Type: Material Weakness in Internal Control / Noncompliance ? Special Tests and Provisions Program: Child Nutrition Cluster (ALN 10.553, 10.555 and 10.559) Condition: As of year-end the District had a fund balance in the non-profit food service fund in excess of three months' operating expenses by approximately $165,196. Criteria: The USDA requires that the District limit its net cash resources to an amount that does not exceed 3 months average expenditures of the nan-profit food service fund per requirements in 7 CFR Part 210. 14(b). Cause: This condition was caused by the meal claims increasing and having more reimbursements come in than anticipated. Effect: The District will be required to develop a spending plan for reducing the balance to an acceptable level during the following school year. The plan must be submitted to MDE, Office of School Support Services, for prior approval. Recommendation: We recommend that the District develop a spending plan as required by MDE, and submit the plan at their earliest convenience. Corrective Action Plan: Shepherd Public Schools will work with MDE to create a spenddown plan to address the excess fund balance in the food service fund. This plan will include allowable equipment upgrades and replacements to be crafted in collaboration with the food service director, district business manager and superintendent, as well as any other members deemed appropriate by superintendent. The process of creating the plan is expected to begin immediately, with compliance of 7CFR Part 210.14(b) to be met no later than June 30, 2023.