Corrective Action Plans

Corrective Action Plan: The Department will continue its work to ensure the data provided to the USED and other entities is timely and accurate. This includes communication to subrecipients through CCIP notes, reminder emails, reporting dashboard information and guidance documents on the time period for reporting and expectations. Going forward, the Department will also include a training webinar and open office hours. In addition, the Department will revise its process for annual reporting ESSER expenditures to the USED to ensure the Department?s survey to collect ESSER expenditure data from subrecipients has a validation/error test against OAKS payments for a given reporting period. If the data does not align with the expenditure data in OAKS, the subrecipient will have to undergo data correction to ensure accurate reporting. Data correction will vary depending on the organization and any previous expenditures reported to USED. Anticipated Completion Date for Corrective Action: July 2023 Contact Person Responsible for Corrective Action: Corey Fronk, Director of Audits and Risk Management, Ohio Department of Education 25 South Front Street, 7th floor, Columbus, Ohio, 43215 Phone Number: 614-644-7812, E-Mail Address: Corey.Fronk@education.ohio.gov

Corrective Action Plan: The Department will update its manual to include a process for performing and documenting a supervisory review and a reconciliation of subaward information entered into the FSRS website to USASpending.gov. In addition, the Department will reconcile all subaward reporting from June 2022 through February 2023 to ensure proper reporting during this timeframe. This reconciliation will include a supervisory review to help ensure accuracy. Anticipated Completion Date for Corrective Action: June 2023 Contact Person Responsible for Corrective Action: Corey Fronk, Director of Audits and Risk Management, Ohio Department of Education 25 South Front Street, 7th floor, Columbus, Ohio, 43215 Phone Number: 614-644-7812, E-Mail Address: Corey.Fronk@education.ohio.gov

Corrective Action Plan: ? Foster Care CB-496 (quarter ending September 30, 2021) o The error on Line 10a was a result of keying errors in the worksheet which were transferred to the federal report. Line 10a was overstated by $2,183 ($1,091.50 ffp). We will make a prior period adjustment on the 3/31/23 CB-496 report to correct the error. ? The error on Line 16a was a result of keying errors in the worksheet which were transferred to the federal report. Line 16a was overstated by $63,449.75 ($31,749.88 ffp). We will make a prior period adjustment on the 3/31/23 CB-496 report to correct the error. ? A prior period amount was entered on the 9/30/21 Foster Care report in OLDC with an incorrect Funding Category. The Funding Category determines which line on the report captures the claim. The amount of $171 was claimed on Line 5 but should have been claimed on Line 6. The FFP for both lines is 50%, so there is no financial discrepancy. We will make a prior period adjustment on the 3/31/23 CB-496 report to correct the error. ? WIOA Cluster ETA-9130 (Statewide Rapid Response for quarter ending March 31, 2022): o The error on Line 10g was a result of a keying error. This error was corrected on the June 2022 Statewide Rapid Response ETA 9130 report. The unit supervisors will continue to review the supporting documentation of the analyst completing the report and check for keying errors before the report is submitted for review by the section chief. Anticipated Completion Date for Corrective Action ? CB-496 adjustments ? March 2023 ? WIOA error - Completed Contact Person Responsible for Corrective Action: Nahshon Moore, Financial Manager, Ohio Department of Job and Family Services 30 East Broad St., 37th floor, Columbus, Ohio 43215 Phone Number: 614-728-2898, E-Mail Address: Nahshon.Moore@jfs.ohio.gov

Corrective Action Plan: 1. For one of 60 (1.7%) regular Unemployment benefit payments selected for testing, the claimant was paid FPUC benefits of $300 a week for several weeks of benefits which were already paid in state fiscal year 2021. As a result, we will question all duplicate FPUC payments made to this claimant during the audit period, totaling $4,800. a. A defect has been documented and an application development project will be created to remedy the concern. It will be prioritized amongst all of the other efforts currently in progress or planned for OJI. Timelines associated to the remediation is currently unknown. We currently don?t understand the root cause problem and what it will take to resolve it. 2. For eight of nine (88.9%) regular Unemployment benefit claims identified in an OJI system data match as potentially exceeding the maximum allowable amount per week, the claimants were paid $300 in FPUC benefits twice during the same benefit week. As a result, we will question costs for all FPUC payments over the allowable amount to these claimants during the audit period, totaling $17,640. a. A defect has been documented and an application development project will be created to remedy the concern. It will be prioritized amongst all of the other efforts currently in progress or planned for OJI. Timelines associated to the remediation is currently unknown. We currently don?t understand the root cause problem and what it will take to resolve it. 3. Two of two (100%) PUA claims identified in a uFACTS system data match exceeded the maximum allowable number of weeks (79): one by four weeks and the other by two weeks. As a result, we will question the PUA payments exceeding the maximum allowable number of weeks, totaling $1,656. a. A process adjustment has been made to ensure that when adjusting claim for proper payment, that we overpay the appropriate weeks as well. In some cases, that didn?t take place. This was a problem that was quickly identified, and a new process was created to deter this from happening again. We missed the correction on claim, and we have adjusted it. From a system perspective, if previous weeks are subsequently reversed back to paid, causing weeks to be over 79, a process will be identified to potentially mitigate the adjustment. 4. For eight of 60 (13.3%) PUA / FPUC payments selected for testing, the claimant was not eligible to receive benefits for the weeks claimed, was overpaid, or was underpaid, as follows: a. The finding for overpaid or underpaid claims was due to the tsunami of claims/workload the agency faced during the Pandemic as well as unknowledgeable new hires brought on to assist with the massive workload. At this time initial benefits adjudication is timely in its workload however we are still facing a high backlog of cases which have alleged fraud. Benefits adjudication will process claims after a thorough fraud review has been completed. Due to the backlog all of these cases will be late and have a possible under or overpayment. The benefits adjudication team will have any cases/determinations made within 21 days of receipt from BPC fraud dept. Anticipated Completion Date for Corrective Action: June 2024 Contact Person Responsible for Corrective Action: Valerie Shuster, Field Operations District Coordinator, Ohio Department of Job and Family Services 209 West 4th Street, Lorain, OH 44052 Phone Number: 440-244-7802, E-Mail Address: Valerie.Shuster@jfs.ohio.gov

Corrective Action Plan: ? Office of Unemployment Insurance Operations (OUIO) will develop a schedule of cross matches to ensure the matches are being performed timely and as intended. If the information necessary to complete the cross-matches is obtained from an outside party, the Department will work with the entity to ensure the information is obtained timely. Additionally, the Department will continue to prioritize issues based on the aging of issues created by the cross-matches, monitor the issue backlog, ensure issues are being addressed timely, and the Notices of Determination are issued in a timely manner. ? OUIO will develop quality reviews focusing on the timing of the fact-finding questionnaires generated by the OJI and/or uFACTS systems once an issue has been created. ? OUIO will develop periodic management reviews over the certification of OJI and uFACTS overpayments to the Ohio Attorney General and subsequent collections. ? OUIO will develop system enhancements within OJI to ensure the monetary fraud overpayment penalty amounts are being applied to each applicable overpayment. Management should monitor the system enhancements to ensure they are being captured, properly applied, and appropriately collected. Anticipated Completion Date for Corrective Action: June 2024 Contact Person Responsible for Corrective Action: Carl Prideau, Section Chief-BPC, Ohio Department of Job and Family Services 30 East Broad Street, 38th floor, Columbus OH 43215 Phone Number: 614-644-5164, E-Mail Address: Carl.Prideau@jfs.ohio.gov

Corrective Action Plan: The Office of Community Development (OCD) is in the process of implementing a new timeline for ESGP funding to be compliant with federal regulations. The following steps of the corrective action have already been completed. 1. Since the OHTF account balance is now in the position to allow OCD to commit funds earlier within the program year, the HCRP timelines can be adjusted to meet HUD?s 60-day requirement. 2. OCD must handle this change cautiously as HCRP serves Ohio?s most vulnerable population, the homeless, and our most vulnerable grantees, non-profit organizations. Interruptions in services and operating support would be detrimental to both. Both are dependent upon the continuity of OCD?s programs? timing. Therefore, a series of meetings have been scheduled with grantees to strategize about the most seamless way to implement this change with the least disruption in services and support. The first meeting was held on February 24, 2023. The second one is scheduled for March 31, 2023. 3. OCD will discuss this topic with the Supportive Housing Advisory Group in the fall of 2023. This meeting is part of Ohio?s Consolidated Planning Process to gather stakeholders input to create Ohio?s Annual Action Plan to submit to HUD for approval. A public comment period is built into the process as well, so additional feedback may be gathered to consider. Finally, the new timeline will be approved by HUD within the Annual Action Plan. 4. While OCD is having meetings and gathering feedback, staff will be working on the internal impact this change may create. System requirement changes and delays they may cause; report deadline shifts and alignment with other homeless reporting systems; and staff workload balance in coordination with other programs are a few we are aware of at this point. Also, the program planning begins far in advance to the grantee application submission. Therefore, timelines get set and approved early on. There are times when our allocation amounts are released from HUD late which delays our application process. There are times when HUD issues our grant agreement late which will require OCD to hold all grantees? agreements until ours is executed. Either one will cause a disruption in services after the program period is changed to an earlier start date. All these factors must be carefully considered prior to making this transition, so that surprises and delays are kept to a minimum. In some cases, a back-up plan will be required. Anticipated Completion Date for Corrective Action: September 2024 Contact Person Responsible for Corrective Action: Talia D. Givens-Gore, Program Operations Manager, Ohio Department of Development 77 South High Street, 26th floor, Columbus, Ohio 43215 Phone Number: 614-728-8140, E-Mail Address: Talia.Givens-Gore@development.ohio.gov

Corrective Action Plan: To correct the issue of reporting in a timely manner, the following strategies will be employed: 1. Monthly encumbrance report - The Grant Strategy Manager will run an encumbrance report (PO-006 Open Purchase Order Encumbrance Report through Cognos BI reporting system) during the first week of each month to identify all new encumbrances for each federal grant, new awards and contracts made with federal grant funds. The Grant Strategy Manager will report all new subgrant awards that are made each month to the FSRS website, except for specific large grant programs that will be delegated to the program division as described below. 2. Delegate large reports to program divisions ? Some federal grants have multiple subgrantees who receive funds for numerous programs. The larger and more complex grants are managed by the Community Services Division (CSD). This includes grants for CDBG, CSBG, ESG, HEAP, HWAP, and HOME programs. Transparency reports for these programs will be assigned to staff members in CSD for data entry to the FSRS website. The Grant Strategy Manager will sort the encumbrance report by grant and assign the reporting task to CSD staff members for completion by the end of the month following the award. CSD staff members will notify the Grant Strategy Manager when data entry for the month is complete. The Grant Strategy Manager will then review the reports for accuracy and submit the reports in a timely manner before the end of the month after the subaward is made as required. 3. Training ? The Grant Strategy Manager will provide training for CSD staff members about Transparency Act reporting, how to use the FSRS website, how to enter data, and the schedule for reporting. To correct the issue of internal controls, the following strategies will be employed: 1. Monthly Review ? For Transparency reports prepared by the Grant Strategy Manager, the report will be sent to the Senior Financial Program Manager (or designee) for review and accuracy check prior to submission on the FSRS website. For Transparency reports completed by CSD staff, the reports will be reviewed by the Grant Strategy Manager for review and accuracy check. The accuracy check in both cases will include: ? Review the Encumbrance Report spreadsheet showing subgrantees and encumbrance amounts and compare to the Transparency Report for accuracy. ? Check a sample of data from the Transparency Report for accuracy with subgrant agreements and contracts as they appear in Salesforce or other programs. 2. Training - The Grant Strategy Manager will provide training for Finance Division and CSD staff about the Transparency reporting and review process and how to check reports for accuracy. Finance Department staff members will be cross-trained to complete the Transparency reporting function as well in cases where the Grant Strategy Manager is absent. Anticipated Completion Date for Corrective Action: April 2023 Contact Person Responsible for Corrective Action: Keith McCormish, Grants Strategy Manager, Ohio Department of Development 77 South High St., 27th floor, Columbus, Ohio 43215 Phone: 614-466-8396, Email Address: Keith.McCormish@development.ohio.gov

Corrective Action Plan: OCD anticipates utilizing the following protocol to resolve the finding: Step 1 and Future The Ohio Department of Development is under contract with a consultant to build OCD?s new grant management system and migrate out of OCEAN. Neither enhancing existing reports nor building new ones in OCEAN are feasible options at this point. The new system will allow OCD to have control in building custom reports to meet numerous needs. OCD also anticipates having increased automation features, enhanced validations, and data linkage on a broader spectrum. All these aspects will reduce the risk of error and will allow for reporting on precise information to assist in the new reconciliation process which will be structured as follows. A. New system reports will be pulled by Senior Financial Analysts and compared with the IDIS PR28 report and OAKS data once per quarter for each funding source. B1. If there are no discrepancies, the reconciliation will be logged in the system with the date and time it occurred. End. B2. If there are discrepancies, the Senior Financial Analyst will meet with the Operations Manager to present the discrepancies and determine if there is a quick explanation. C1. If so, the resolution will be logged. Adjustments will be made accordingly and documented. End. C2. If not, create a plan of action for a deeper dive. Continue to circle back and alter the plan of action until the source of the discrepancy is found, adjustments are made and actions are logged. End. Step 1 is complete in the sense that there is a contract in place for a new grant management system that will provide OCD with tools necessary to carry out reconciliation procedures accurately and efficiently on a regular basis. OCD will meet with the consultants to inquire about the system?s capability of storing historical data to access historical reports. The future of the resolution is outlined within A. through C2 after the system is built. It is too early in the program development to provide names for the new reports. Step 2 and Present In the meantime, while the system is being built, the Operations Manager and Staff will collectively utilize a more manual process that will include pulling the current PR28 report from IDIS to reconcile with OCEAN and OAKS data for the grants listed in this finding. Report options are limited in OCEAN, therefore, it may be necessary for staff to maneuver through layers throughout the projects? data. After the discrepancies are found, adjustments are made, and actions are logged. A follow-up response will be submitted along with necessary documentation to evidence the grants have been reconciled and all systems and reports match. Anticipated Completion Date for Corrective Action: December 2023 Contact Person Responsible for Corrective Action: Talia D. Givens-Gore, Program Operations Manager, Ohio Department of Development 77 South High Street, 26th floor, Columbus, Ohio 43215 Phone Number: 614-728-8140, E-Mail Address: Talia.Givens-Gore@development.ohio.gov

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.