Corrective Action Plans

The Platte-Geddes School District Business Official, Kathleen A. Holter, is the contact person responsible for the corrective action plan for this finding. This finding is due to the limited number of staff employed in the district's business office. Staffing the office at an efficient and financially feasible level precludes the hiring of adequate personnel to provide an ideal environment for the internal controls. Platte-Geddes School District adopted an Internal Controls and Procedures policy in August 2017. 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.

Corrective Action Plan: The District has pursued education on the federal requirements regarding prevailing wage, and will make steps moving forward to ensure compliance with the federal standards relating to prevailing wage of federally financed contracts.

Corrective Action Plan and Views of Responsible Officials The District will review its records and verify alignment with reports submitted to the Los Angeles COE.

Finding 2022-002 Harvest Regional Food Bank, Inc. agrees with Finding 2022-002. Corrective Action Plan: All USDA/CSFP food received and entered into the SMF QuickBooks system by the Operations Manager will be verified by a secondary employee. All USDA/CSFP food distributed and invoiced in the SMF QuickBooks system by the Operations Manager will be verified by a secondary employee. All USDA/CSFP food receipt submissions to Arkansas Department of Human Services (DHS) will be verified by a Harvest employee to ensure Arkansas DHS files are updated with Harvest USDA/CSFP receipts. Any discrepancies will be discussed and corrected as necessary. Harvest will perform an inventory count quarterly and adjust inventory amounts as needed in the SMF QuickBooks system. Management Contact: Camille Wrinkle Phone Number: 870-774-1398 Completion by Date: 8/31/2023

FINDING 2022-007 Subject: COVID-19 ? Education Stabilization Fund ? Reporting Federal Agency: Department of Education Federal Program: COVID-19 ? Education Stabilization Fund Assistance Listing Number: 84.425D Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425U200013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirements. Context: The School Corporation was required to submit two Annual Data Reports to the Indiana Department of Education (IDOE) to meet federal reporting requirements for ESSER grant awards. The first report was for the period of March 13, 2020 to September 30, 2020 and was due by January 21, 2021. The second report was for the period of October 1, 2020 to June 30, 2021 and was due by May 13, 2022. The amounts reported as expended on the second report did not agree to the underlying expenditure records of the School Corporation. Per discussion with the Treasurer, the amounts reported on the second report were the appropriated amounts, not the actual amounts expended during the period. Therefore, the amounts on the report were overstated by approximately 25% for ESSER I and 280% for ESSER II compared to the correct amounts on the School Corporation?s records. Additionally, for both reports that were submitted, there was no documented review by someone other than the preparer of the report to ensure the information submitted was complete and accurate. Views of Responsible Officials and Planned Corrective Actions: We concur with the finding. Description of Corrective Action Plan: The NJ-SP School Corporation will implement effective internal controls to oversee that the federal grant information prepared and submitted is accurate and reviewed. This will be done in order to detect and correct errors that may be entered prior to submission. This will be done by having an employee prepare the Annual Data Report information while another employee reviews and approves the information before submitting. These controls will be implemented by July 1, 2023. Responsible Party and Timeline for Completion: Dalton C. Tunis ? Corporation Business Manager/Treasurer Anticipated Completion Date: July 1, 2023

FINDING 2022-003 Information on the federal program: Subject: Education Stabilization Fund - Annual Data Report Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Number: 84.425C, 84.425D, 84.425U Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Condition: The School Corporation did not have a documented review control in place to ensure the annual data report was reviewed by someone other than the preparer and that the report was submitted timely. Context: The Annual Data Report for the period of October 1, 2020 to June 30, 2021 was due to the Indiana Department of Education (IDOE) by May 13, 2022. The School Corporation submitted the report on May 16, 2022. In addition, there was no documented review by someone other than the preparer of the report to ensure the information submitted was complete and accurate. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and will take the following corrective action. Dr. Barry Stone, Director of Curriculum will prepare the Annual Data Report in a timely matter and the reports will be reviewed by Mrs. Berry, Superintendent and then signed off before submitting the report. Responsible party and timeline for completion: Federal regulation requires name and title of person overseeing corrective action plan and anticipated completion date. Dr. Barry Stone, Director of Curriculum will compile the report and Mrs. Berry, Superintendent will approve and sign off when the report is due.

FINDING 2020-002 Contact Person Responsible for Corrective Action: Shelly Harrison, Corporation Treasurer Contact Phone Number: 765-492-5102 Views of Responsible Official: We concur to the findings; however, while completing the ESSER Reports, some formatting errors of the provided spreadsheet created some questions by the North Vermillion officials prompting a clarification email to the DOE. Since the formatting errors were not addressed and all completed boxes on the North Vermillion ESSER Report spreadsheet turned green (indicating the correct amounts on the spreadsheet), the North Vermillion officials felt the ESSER report submitted was correct. Description of Corrective Action Plan: To correct the internal control issue, the Superintendent and Corporation Treasurer will work independently as well as collaboratively on the ESSER Reports. Prior to submitting any future report, the corporation officials will document their work by signing off and dating the report prior to submission to the DOE. To rectify the incorrect dollar amount on the Yearly ESSER Report Spreadsheet, the corporation treasurer and superintendent will work collaboratively to correct the amounts on either the ESSER I Year End Report and the ESSER II Year 2 and/or Year End Report. Anticipated Completion Date: Both the Internal Control and ESSER I corrective actions have been corrected, with the ESSER I Final Expenditure Report being completed and signed off on. The ESSER II corrective actions will be completed on the upcoming ESSER III Year End Report when that report is due.

FINDING 2022-003 Contact Person Responsible for Corrective Action: Jeff Gambill, Superintendent; Jennifer Barcus, Corporation Treasurer. Contact Phone Number: 812-665-3550 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Corporation Treasurer will begin reviewing all annual data reports completed by the Superintendent, prior to submission of the reports, to verify that all expenditures are reported in the correct reporting period. Anticipated Completion Date: Immediate review will begin of all annual data reports.

Finding 2022-004 Contact Person Responsible for Corrective Action: Rhonda Morgan, FSD Contact Phone Number: 765-240-2386 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Frontier School Corporation will have the Elementary and Jr/Sr High Kitchen Managers pull the monthly reports from eTrition for breakfast and lunch meals served for their respective schools. A blank Monthly Worksheet will be provided to each Kitchen Manager to be filled out using the data report from eTrition, the foodservice software. The reports and worksheets from each school will be given to the Food Service Director. The FSD will have independently prepared a complete report using data pulled from eTrition including both schools. The FSD will then compare the elementary Kitchen Manager?s report with the Master Report. The FSD will then compare the Jr/Sr High Kitchen Manager?s report with the Master Report. The Master Report will then be presented to each Kitchen Manager for their approval after checking to see that the data matches, initialing and dating the Master Report. The Food Service Director will then submit the Monthly Claims Report to CNPweb. The Corporation Treasurer will also have access to all data collected to ensure proper reportig. All data and internal checks will be filed in the Food Service Director?s office.. Anticipated Completion Date: The CAP will be in place by March 24, 2023 in preparation for the Monthly Claim of March 2023 to be the first month these internal controls will be implemented.

Corrective Action Plan: Ohio EMA continues to work with the vendor (Civix/EMGrants) to modify the FFATA reporting functionality within the grant management system. Controls independent of the grant management system are in place and continue to be refined as new situations surrounding the FFATA process continue to present themselves. These controls include the monthly running of obligation reports out of the EMGrants system followed by the timely reporting of any applicable items in FSRS. Recipient-Sub-Recipient Grant Agreements have been revised to require applicants to supply us with executive compensation information required by FFATA. This information is also required in SAM.gov. However, we?ve discovered various flaws in the SAM.gov system that makes it unreliable. Lastly, we have implemented processes for documenting all known, and future unknown, flaws within the FFATA process. This will assist us with clearly showing in future audits what is and is not in our control with FFATA. It?s worth noting the majority of the timeliness errors found in the auditor?s sampling occurred prior to Ohio EMA?s implementation of its corrective action plan in SFY 2022. The items sampled after the corrective action plan implementation date did not return any timeliness errors. Anticipated Completion Date for Corrective Action: Completed Contact Person Responsible for Corrective Action: Laura Adcock, Disaster Recovery Branch Chief, Ohio Department of Public Safety 2855 West Dublin Granville Road, Columbus, Ohio 43235 Phone: 614-230-7696, E-mail Address: ladcock@dps.ohio.gov

Corrective Action Plan For the Year Ended June 30, 2022 Reference Number: 2022-001 Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Head Start Cluster Assistance Listing Number: 93.600 Federal Award Numbers: 09CH010862-04-02 and 09HE000903-01-00 Category of Finding: Reporting Type of Finding: Material Weakness in Internal Control over Compliance and Instance of Noncompliance The Employment and Human Services Department will comply with Appendix A (I)(a) of 2 CFR Part 170 to report each obligating action greater than or equal to $30,000 in Federal funds for a subaward to a non-Federal entity no later than the end of the month following the month in which the obligation was made. When applicable, the Employment and Human Services Department will require that its subrecipient provide their executive total compensation. The Employment and Human Services Department will report the information per 2 CFR 170 Appendix A, and the grant award instructions. The Employment and Human Services Department?s fiscal management will work with fiscal staff to develop a FFATA tracking tool for designated fiscal staff to use to meet the reporting requirement of Head Start. EHSD designated fiscal staff will be trained on the tracking tool and reporting requirement for completeness, accuracy and timeliness in accordance with 2 CFR 170 Appendix A, and the grant award instructions. Contact person responsible for corrective action plan: Marla Stuart, Director Contra Costa County Employment and Human Services Department Emilia Gabriele, Chief Deputy Director Contra Costa County Employment and Human Services Department Erik Brown, Chief Financial Officer Contra Costa County Employment and Human Services Department

Current year audit findings: 2022-001 Special Tests and Provisions Corrective action planned: The Organization is working directly with IHS to develop policies that will include all the necessary background investigation steps to ensure its pre-employment checks are in compliance with the contractual requirements. The Organization will formally update its policies after it has determined, with the help of IHS, that the policies are sufficient. We will work with IHS to get a final determination for contract compliance. After receiving a definite answer and technical assistance and guidance from IHS, NATIVE could begin the fingerprint background process for identified staff and volunteers. Anticipated completion date: December 2023 Contact person responsible for corrective action: Joe Dressler, HR Director; Toni Lodge, CEO

See Corrective Action Plan for chart/table.

Finding 2022-001 Finding Summary: C.S. Lewis Academy is required to submit annual financial statements and the proposed budget to the USDA. These items were not provided to the USDA by June 30, 2022. Responsible Individuals: Diane Nelson, Executive Director and Nate Adams, Business Manager Corrective Action Plan: Management will provide a copy of the audited financial statements and copy of the proposed budget to USDA annually. Anticipated Completion Date: Ongoing Anticipated Completion Date: Management will ensure all necessary corrective action plan items are in place by the end of 2022.

Finding Number: 2022-001 Program Name/Assistance Listing Title: Education Stabilization Fund Assistance Listing Number: 84.425D Contact Person: Sarah Manobe, Payroll Specialist Anticipated Completion Date: January 9, 2023 Planned Corrective Action: Separation of duties has been established. We hired a payroll person that will be fully dedicated to conducting the duties of processing payroll from start to end. We also hired a full-time Human Resource Manager that will be responsible for conducting all other functions of the Human Resource department, this will ensure to have better internal controls.

The District will ensure compliance with wage rate requirements going forward. The District will ensure that contracts have the language in it going forward.

Finding Number: 2022-002 Condition: We noted during testing that the City had no procedure in place to verify contractors are not suspended, debarred, or otherwise excluded pursuant to 2 CFR Section 180.300 prior to entering into contracts with award funds. Planned Corrective Action: Procedures have already been put into place to ensure that each new contractor is not on the Federal list of suspended and/or debarred contractors. Furthermore, all vendors previously paid have been searched for in the Federal list and none were suspended and/or debarred. Contact person responsible for corrective action: Cynthia Cutright Anticipated Completion Date: 09/23/2022

Pursuant to federal regulations, Uniform Administrative Requirements Section 200.511, the following is the internal control finding, as noted in the Delta Area Transit Authority, Michigan?s (the ?Transit?) Single Audit report for the year ended September 30, 2022, and the corrective action to be completed: Finding: 2022-003 - Material weakness, internal controls over federal award (repeat finding) Auditor Description of Condition and Effect: Costs must meet certain general criteria to be allowable under federal awards. One criterion is that the costs be adequately documented. 9 of the 40 accounts payable expenses that were selected for testing included documentation showing that an individual with knowledge of the transaction reviewed the invoice to: verify that it was necessary and reasonable for the performance of the federal award, verify that it was accurate in amount, authorize the voucher for payment, or establish the appropriate general ledger code for posting. Further, none of the 45 payroll expenses that were selected for testing included employee timecards reviewed and authorized for payment by their immediate supervisor. Auditor Recommendation: We recommend that the Authority update its policies and procedures to provide documented proof of review and authorization by management of all expenses. These policies and procedures should be updated to conform with the Uniform Guidance as soon as practical. Corrective Action: We agree with the finding and will update and clarify our policies and implement new systematic review tools as protections against the payment of unsigned vouchers. Responsible Person: John Stapleton, Director Anticipated Completion Date: June 30, 2023

Dr. Chris Nold is the contact person responsible for the corrective action plan for this finding. This finding is due to the limited number (one) of employees 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. Kimball School District adopted an Internal Controls and Procedures policy in December 2017 and recently updated it in June 2021. 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.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Number: 14.871 & 14.879 Passed Through: Direct Award Pass Through Number: N/A Compliance Requirement Affected: Special Provisions Award Period: 2022 Type of Finding: Material Weakness in Internal Control over Compliance. Recommendation: We recommend that the Authority design and implement internal controls over special provisions. Other provisions, such as reasonable rent, housing quality standards inspections, and HQS enforcement, should be reviewed by someone independent of the initial preparation/inspection. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Authority will evaluate implementing reviews over tenant files, financial and performance reports, and other special provisions. Name of the contact person responsible for corrective action plan: Kim Wallace, Executive Director Planned completion date for corrective action plan: December 31, 2023

We are looking at options to increase the finance teams so that we have capacity to finish the audits on time in future years Anticipated Completion Date: September 1, 2023 Responsible Contact Person: David Maloney, Shelter House Controller

Multi-Family Housing Revitalization Demonstration Program - Assistance Listing No 10.447 Material Weaknesses: See Findings 2022-001, 2022-002, 2022-003

Rural Rental Housing Loans - Assistance Listing No 10.415 Material Weaknesses: See Findings 2022-001, 2022-002, 2022-003

Program: Emergency Rental Assistance Program Assistance Listing No.: 21.023 Federal Agency: U.S. Department of the Treasury Passed-through: Direct Award Award Year: 2021/2022 Compliance Requirement: Reporting Type of Finding: Material Weakness Views of Responsible Officials: We concur with the finding. Corrective Action Plan: The Emergency Rental Assistance Program (ERAP) was an emergency program that was implemented during the height of the COVID-19 pandemic. As ERAP is closed, the County cannot revise its processes to include this recommendation but will do so should any similar programs be administered by the County or a County subrecipient in future. Responsible Individual(s): Anne Putney, Principal Management Analyst Anticipated Completion Date: N/A

Program: Temporary Assistance for Needy Families Program Assistance Listing No.: 93.558 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Social Services Award Year: 2021/2022 Compliance Requirement: Allowable Costs, Eligibility and Special Tests and Provisions Type of Finding: Material Weakness, Instances of Noncompliance Views of Responsible Officials: We concur with the finding. Corrective Action Plan: Finding Part 1: Two (2) out of 60 cases tested were missing the annual redetermination for the reevaluation of their benefits and eligibility requirements. Solano County has policies and procedures as well as systematic processes set up to ensure that redeterminations are processed annually. It is Solano County?s policy that the SAWS 2 Plus, Rights and Responsibilities and the Child Support Questionnaire and Notice and Agreements be processed which require workers to: ? Conduct a telephone interview with the recipient, print the forms, and document the County Use Section which requires worker?s signature and date. ? Mail the forms to the recipient for signature ? Upon return, review the SAWS 2 Plus and additional forms for completeness ? Initiate the required case action based upon information provided on the forms A redetermination of eligibility of the recipient shall be completed at least once every twelve (12) months. The annual CalWORKs Redetermination requires a face-to-face or telephone interview with the parent or person responsibility for the child or the person having responsibility for the care and control of the child. The Division Managers implemented a Quality Assurance Unit of lead workers to conduct 2-3 case reviews per month for all workers. Case reviews are a valuable tool in assessing case accuracy and recognizing quality casework. The case reviews are used to develop and strengthen worker and supervisory skills, provide structure for measuring results, identify, correct and prevent errors, and strengthen accountability to the programs and services we delivery as an agency. Specific corrective actions are outlined below to prevent these errors in the future: ? The CalWORKs Program Specialist will work with Hiring and Staff Development to strengthen the eligibility redetermination handbook with verbiage to emphasize the following: o The renewal be authorized only after required forms are received by the county and scanned into the document imaging system. o Ensure that redetermination dates are correct in the system at application and renewal. o Highlight these requirements when training this topic ? The CalWORKs Program Specialist will discuss the findings and redetermination requirements in the following ways: o Monthly Program Support Forum conducted with managers, supervisors, and lead workers o Issue a reminder memorandum to all staff o Written material will be published in the Monthly Program Support Newsletter to all staff Finding Part 2: In 31 out of 60 cases, we found that the review of the IEVS was not documented during the application or annual re-determination applicable to the fiscal year. However, we found that the related recipients/cases were eligible. It is Solano County?s policy to maintain program integrity. All CalWORKs (TANF) cases are required to be reviewed to assist with the eligibility determination using the Income and Eligibility Verification System (IEVS) at application and annual redetermination. ? IEVS is a computer cross match of State wage data, Unemployment Insurance Benefit data, wage data maintained by the Social Security Administration, and unearned income data maintained by the Internal Revenue Services and/or Franchise Tax Board. ? Staff is required to initiate the required case action and notices based on information received from the report, which includes generating adequate and timely notice. ? IEVS is system-generated at application. Effective February 2021, the CalWIN system auto-generates IEVS at least 15 days prior to the beginning of the redetermination due month. Specific corrective actions are outlined below to prevent these errors in the future: ? An ad-hoc report will be developed to generate monthly to help ensure the reports are reviewed and signed off by workers. A process will be put in place to ensure supervisors and lead workers follow up with the completion of these reports. ? The CalWORKs Program Specialist will work with Hiring and Staff Development to strengthen the eligibility handbook sections for Application, Annual Redetermination, and IEVS Interfaces. ? The CalWORKs Program Specialist will discuss the findings and IEVS requirements in the following ways: o Monthly Program Support Forum conducted with managers, supervisors, and lead workers o Issue a reminder memorandum to all staff o Written material will be published in the Monthly Program Support Newsletter to all staff Responsible Individual(s): Daniel Horel, Employment and Eligibility Services Manager Thomas West, Employment and Eligibility Services Manager Anticipated Completion Date: June 30, 2023