Corrective Action Plans

2022-028 Improve Controls over Eligibility Determinations Federal Agency: U.S. Department of Labor State Entity: Department of Labor (GDOL) Corrective Action Plans: (1) Identity verification was not performed appropriately in eight instances. GDOL Response: The Georgia Department of Labor disagrees with these findings as it relates to identity verification. The auditors did not identify the type of identity verification procedures not performed or any identity verification procedures that GDOL was required to perform. There was not a mandatory requirement to complete identity verification at the time most of these applications were submitted as the majority of these claims were employer-filed claims (EFC). Identity requirements for EFCs were implemented at a later date. At the start of the pandemic, the identity proofing processes available were Social Security Administration (SSA) verification, Department of Driver Services (DDS) crossmatch and for non-citizens, Department of Homeland Security Systematic Alien Verification for Entitlement (SAVE). As applicable, these processes were performed on all initial regular and EFCs, which includes the eight instances. (2) Non-monetary determination was not performed in two instances. GDOL Response: Instance 1: A disqualifying non-monetary determination was released and disqualification was entered into the system. The system erroneously released a payment for the week in question. An overpayment was established in January 2023. Instance 2: Claim was processed but issue did not get added to the claim to address separation reasons. A non-monetary determination was released in November 2022 to allow benefits. All payable weeks have been processed. There was no detriment to the claimant as they were determined eligible nor was there any monetary loss to the State. (3) Proof of employment or self-employment or a valid offer to begin employment and proof of wages was not submitted by two Pandemic Unemployment Assistance (PUA) claimants. GDOL Response: The GDOL disagrees with the findings related to proof of employment or self-employment or a valid offer to begin employment and proof of wages was not submitted by two PUA claimants. Under the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), claimants did not have to provide proof of employment or self-employment. It was not until Continued Assistance Act (CAA) was enacted December 27, 2020 that such proof was required. The disqualification could not be applied retroactively, as outlined in Unemployment Insurance Program Letter (UIPL) No. 16-20, Change 4. Instance 1: Claimants who established PUA entitlement at the minimum weekly benefit amount were instructed to submit their proof of wages by email. Under the CARES Act, if claimants did not submit proof, federal requirements only allowed for payment of the minimum weekly benefit amount and no disqualification of benefits. The claim cited was originally established and remains established for the minimum weekly benefit amount. In accordance with CAA rules, the claimant was notified to provide proof of employment and wages for weeks paid on or after 12/27/20. To date, no proof has been provided by the claimant. The claimant has been disqualified effective 12/27/20 and an overpayment was established in January 2023. Instance 2: Claimants who established PUA entitlement with a weekly benefit amount greater than the minimum was based on wages entered by the claimant and/or wages reported by the employer. CARES Act only required proof of wages to be submitted. If claimants did not submit proof, federal requirements only allowed for payment of the minimum weekly benefit amount and no disqualification of benefits. Claims established at a higher weekly benefit amount had to be reduced to the minimum amount if no proof was provided. To date, no proof has been provided by the claimant cited. The claim was established above the minimum amount; therefore, benefits were reduced to the minimum amount. In accordance with CAA rules, claimants were notified to provide proof of employment and wages for weeks paid on or after 12/27/20. The claimant has been disqualified effective 12/27/20 and an overpayment was established in November 2022 for weeks paid over the minimum amount under CARES and weeks paid after 12/27/20 under CAA/American Rescue Plan Act (ARPA). (4) Claimants did not self-certify for benefits in 18 instances. GDOL Response: The GDOL disagrees with the findings Claimants did not self-certify for benefits in 18 instances. Employer-Filed Claims (EFC) are submitted by employers on behalf of the claimant. The employer is responsible for attesting to the employment status and weekly earnings of the claimant for the EFC submitted. An affidavit certifying that the employer has obtained earnings from other employment as well as other requirements must be completed before EFCs can be entered or uploaded. Claimants for which EFCs are submitted are considered to be still attached to the employer and are exempt from the requirement to register for employment services per Georgia Employment Security Law Rule 300-2-4-.02. Such individuals are not required to be nor certify on a weekly basis to be able, available and actively seeking work. Additionally, USDOL encouraged states to waive work search requirements for all claimants during the pandemic. (5) Claimant and payment information did not exist in the system of record in one instance. GDOL Response: The identifying information the auditors provided for this claim does not match any claims in our system. Therefore, we are unable to validate the auditor?s finding. Summary The information above is provided for your consideration in dispelling some of the audit findings. GDOL took immediate action to establish the federal UI programs and comply with federal guidance and regulations. There was not a mandatory requirement to complete identity verification at the time most of these applications were submitted. At the start of the pandemic, the identity proofing processes available were Social Security Administration (SSA) verification, Department of Driver Services (DDS) crossmatch and for non-citizens, Department of Homeland Security Systematic Alien Verification for Entitlement (SAVE). As applicable, these processes were performed on all initial regular and employer-filed claims (EFC). Beginning January 2021, PUA applicants were required to complete additional identity verification processes. Beginning in December 2021, all applicants were required to complete identity verification prior to filing a claim for UI benefits. Effective December 6, 2021, the EFC process was revised to require individuals (employees) to complete an EFC profile to include a real-time identity verification before payments can be made. Employers are responsible for submitting the request for the payment to certify to the individual?s employment status, but the individuals must certify their identity and personal information for the claim to be processed. Employees are notified when a claim is filed on their behalf and provided instructions for their portion of completing the EFC process. Additionally, as system deficiencies were identified, changes were made as quickly as possible to mitigate risks of improper payments. Automation of PUA claims was suspended and reviews were handled manually by staff before a determination was released. GDOL established task forces to develop and implement strategies to address the ramped fraud attempts to bypass system and procedural safeguards. We regularly attended fraud meetings with various federal agencies and unemployment agencies from other states to share best practices for combatting fraud. As resources permitted, we did our best to implement these best practices and strategies. Prioritizing system changes was challenging with the time constraints, necessity to build a program based on an established program that operated manually in our state and the demands of all other federal UI programs; but GDOL made every attempt to maximize our system capacity to accommodate the guidelines of each program requirements. Georgia greatly appreciates your time and consideration of our response to the findings and welcome you to contact us if you have any questions. Estimated Completion Date: December 16, 2021 Contact Person: Crystal Singleton, Policy and Procedure Manager Telephone: 404-232-3183; E-mail: Crystal.Singleton@gdol.ga.gov

Responsible Individual: Matthew Zern, Financial Officer Corrective Action Plan: The Greater Johnstown Area Vocational Technical School currently has procedures in place for cash monitoring to ensure compliance with U.S. Department of Education Federal Student Aid guidelines which are similar to the requirements for the HEERF funds. Due to unfamiliarity with the HEERF guidelines during the COVID-19 pandemic, these funds were drawn down in the G5 system earlier than needed. In the future, GJCTC will follow existing procedures to ensure compliance with cash management. Anticipated Completion Date: June 30, 2023.

Kettle Falls School District has already taken action to correct the finding. We utilized a project management firm to oversee the elementary roof project that this finding was based on. We informed them that we were using Federal funds to support the project and asked them to make sure that all rules regarding Federal funds were being followed. However, we learned during this audit that they were not followed. As soon as we learned about a potential issue with our current audit, we made an immediate change to our practice. We no longer rely on the firm to ensure that Federal requirements are being met. We now oversee those requirements, and the district will be certifying the payroll for any project that is being funded through Federal dollars.

Finding 2022-003 Federal Agency Name: Department of Agriculture Program Name: Communities Facilities and Loans Grants Cluster Federal Financial Assistance Listing #10.766 Finding Summary: The Hospital does not have an internal control system designed to provide for a complete and accurate schedule of federal expenditures of federal awards being audited. As auditors, we were requested to assist with the preparation of the schedule. Responsible Individuals: Renae Karst, Chief Financial Officer Corrective Action Plan: It is not cost effective to have an internal control system designed to prepare the schedule of expenditures of federal awards. We requested that our auditors, Eide Bailly LLP, to assist with the preparation of the schedule of expenditures of federal awards. We have designated a member of management to review the drafted schedule of expenditures of federal awards, and we have reviewed with and agree with the final Schedule of Expenditures of Federal Awards. We will begin developing a Grant Award Policy and Procedure Manual around tracking and reporting of awards to ensure accurate and up-to-date communication of award requirements. This communication will include implementing additional processes to improve our internal controls over identifying and reporting of expenditures in compliance with the Schedule of Expenditures of Federal Awards (SEFA) if applicable. We will provide staff training annually for any updates or adjustments to the policy. Anticipated Completion Date: Ongoing

Finding 2022-004 Federal Agency Name: Department of Agriculture Program Name: Communities Facilities and Loans Grants Cluster Federal Financial Assistance Listing #10.766 Finding Summary: Management maintained the reserve amount in the cash sweep general fund account which was not established as a separate bookkeeping account or as a separate bank account. The Hospital had excess cash available to cover the required reserve amount. Responsible Individuals: Renae Karst, Chief Financial Officer Corrective Action Plan: Management will establish a separate bookkeeping account in the general ledger to establish the correct reserve amount of cash within its general operating bank account. The reserve account will be part of total cash in the bank to maximize interest earned on the reserve balance. Anticipated Completion Date: June 30, 2023

2022-002 ALLOWABLE COSTS AND ALLOWABLE ACTIVITIES ? COVID-19 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS Recommendation: We recommend that the County include consideration of any expenditures that may be part of other federal programs as part of their review. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County will review their procedures to ensure expenditures coded to federal grants are not already claimed by other grant programs. Name of the contact person responsible for corrective action plan: Deborah Erickson, Administrative Services Director Planned completion date for corrective action plan: December 31, 2023

FINDING 2022-008 Contact Person Responsible for Corrective Action: Carrie McGuire Contact Phone Number: (574) 875 -5161 Views of Responsible Official: We concur with the finding Description of Corrective Action Plan: Prior to the submission of the Title I application annually, the federal grants coordinator with consult with all non-public schools within our district boundaries as listed by the IDOE in the grant application portal. The signed consultation forms will be uploaded to the IDOE?s Title I Programs Application Center as attachments. The corporation treasurer will verify that all consultation forms are signed and uploaded in the Application Center before the initial grant application budget can be submitted for review. Anticipated Completion Date: December 31, 2022

FINDING 2022-007 Contact Person Responsible for Corrective Action: Contact Phone Number: (574) 875-5161 Views of Responsible Official: We concur with the finding Description of Corrective Action Plan: When required annual federal grant reports are completed for submission, they will be reviewed by the treasurer for accuracy. Both the treasurer and the grants coordinator will sign off on the reports. Anticipated Completion Date: June 30, 2022

FINDING 2022-005 Finding: Internal controls were not in place/effective in relation to the Title I Annual Expenditure Reports filed during the audit period. Subsequently, the 20-21 Title I Annual Expenditure Report did not agree with School Corporation?s ledgers. $578,452 of expenditures were reported the Annual Expenditure Report and $677,514 from Fund 4121 on the ledgers. Contact Person Responsible for Corrective Action: Carrie McGuire Contact Phone Number: (574) 875-5161 Views of Responsible Official: We concur with the finding Description of Corrective Action Plan: When required annual federal grant reports are completed for submission, they will be reviewed by the treasurer for accuracy. Both the treasurer and the grants coordinator will sign off on the reports. In order to address the issue related to earmarking and set-asides within Title I not be completed, Concord Community Schools created a Grants and Assessment Coordinator position in May 2022. A person was hired to fill this position starting on July 1, 2022. One of the essential functions of this position is maintaining current and accurate records related to federal and state grants. Starting in January 2023, in addition to the Grants and Assessment Coordinator, a member of the business department will be a second reviewer and sign the semi-annual certifications. Anticipated Completion Date: December 31, 2023

FINDING 2022-004 Finding: Non-Public School: No documentation could be found to support non-public school students qualifying for Title I on the 2020-2021 and 2021-2022 Applications. These numbers determine equitable share distributions to these non-public schools. Contact Person Responsible for Corrective Action: Carrie McGuire Contact Phone Number: (574) 875-5161 Views of Responsible Official: We concur with the finding Description of Corrective Action Plan: Non public schools will be consulted prior to the initial Title I(a) application being submitted at the start of each grant cycle. Non-public school consultation forms and spreadsheet(s) for any equitable share calculations will be uploaded into the Title I application center as attachments. These will be verified by the corporation treasurer before the Title I application is submitted annually. Prior to the submission of the Title I application annually, the federal grants coordinator with consult with all non-public schools within our district boundaries as listed by the IDOE in the grant application portal. The signed consultation forms will be uploaded to the IDOE?s Title I Programs Application Center as attachments. The corporation treasurer will verify that all consultation forms are signed and uploaded in the Application Center before the initial grant application budget can be submitted for review. A form will be created so that when files are downloaded from the Child Nutrition Program (CNP) website and subsequently uploaded into Mealtime, there will be places for a signature of the person who downloaded the file, a signature for the person who uploaded the file, and a reviewer. Anticipated Completion Date: September 15, 2023

FINDING 2022-001 Contact Person Responsible for Corrective Action: Jim Evans Contact Phone Number: (574) 875-5161 Views of Responsible Official: We concur with the finding Description of Corrective Action Plan: This finding was corrected beginning July 1, 2022. Concord Community Schools hired an additional staff member and that staff member reviews the information used to prepare the Monthly Sponsored Claims for reimbursement to verify that the claims are accurate, complete and prepared in accordance with the grant requirements. Once the review is complete, the Monthly Sponsored Claims are printed and signed by both the Food Service official who prepared the claims and the food service official who reviewed the claims for accuracy, completeness and compliance with grant requirements. Anticipated Completion Date: This finding has been corrected.

Management is aware and understands the importance of compliance with the federal requirements and will ensure the wage requirements are met in the future.

View of Responsible Officials and Planned Corrective Action: CVFiber is keeping track of the award period for each grant award and comparing records monthly to ensure expenditures are within the period of performance. Should terms be changed at the state level or in any regard, this will be reflected in writing so that the dates align at all times. Planned Implementation Date of Corrective Action: Implemented Person Responsible for Corrective Action: Jennille Smith, Executive Director.

View of Responsible Officials and Planned Corrective Action: Beginning in November 2022, corrections were made on all reporting to ensure they agreed with the accounting on a monthly and year to date basis. After reporting was completed, CVFiber chose to reclass a large expense, and those reports were resubmitted. CVFiber internally identified account classifications of all expenditures and has a current process of double checking the classifications as they are being reconciled. Planned Implementation Date of Corrective Action: Implemented Person Responsible for Corrective Action: Jennille Smith, Executive Director.

Department of Health and Human Services 2022-003 Immunization Research, Demonstration, Public Information and Education, Training and Clinical Skills Improvement Projects - Assistance Listing No. 93.185 Recommendation: We recommend the Foundation attend training, review federal requirements, and fully understand the requirements over indirect costs Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: CFGF will engage with external firm to assist with fully understanding requirements related to indirect costs and federal requirements. CFGF will also work with external firm to assist in the identification and selection of additional training opportunities for staff who work on federal programs. Name(s) of the contact person(s) responsible for corrective action: Brett Hunkins Planned completion date for corrective action plan: December 31, 2023 If the Department of Health and Human Services has questions regarding this plan, please call Brett Hunkins at 810-767-8270.

Department of Health and Human Services 2022-002 Immunization Research, Demonstration, Public Information and Education, Training and Clinical Skills Improvement Projects - Assistance Listing No. 93.185 Recommendation: We recommend the Foundation attend training, review federal requirements, and fully understand the requirements over indirect costs Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: CFGF will engage with external firm to assist with fully understanding requirements related to indirect costs and federal requirements. CFGF will also work with external firm to assist in the identification and selection of additional training opportunities for staff who work on federal programs. Name(s) of the contact person(s) responsible for corrective action: Brett Hunkins Planned completion date for corrective action plan: December 31, 2023

Grant expenditures that specify a period of coverage and/or performance will be amortized based on the service contract terms. Amortization costs that go beyond a grant?s expiration date will not be recorded against the expired grant.

The Town will continue to rely on its auditors to perform non-attest services to prepare the financial statements. Management will continue to approve and take full responsibility for any non-attest services provided. As noted above, it is not feasible for many small towns, including the town of Fairfield, Vermont, to invest the time and money in training for the preparation of the financial statements in-house. The local emphasis is placed instead on ensuring that the entries into the local accounting system are accurate and timely, therefor providing good information for the accurate preparation of the financial statements.

Finding 22-07 Name of Contact Person: Jay Toland, Associate Superintendent of Business Operations Corrective Action Plan: The finding resulted from significant turnover within the Finance Department. Management will establish procedures to ensure that all bank account and other required reconciliations are prepared on a timely basis going forward. The Finance department will also strive to keep key positions filled at all times and ensure that staff receives appropriate training regarding reconciliations. Proposed Completion Date: Immediately

Finding 2022-002: Special Education Cluster (IDEA), CFDA 84.027 and 84.173 U.S. Department of Education Passed through the Colorado Department of Education Compliance Requirements: Reporting Grant No.: 4027, 6027, 4173, and 6173 Type of finding: Internal Control (material weakness) and noncompliance (material noncompliance) Material Weakness: The material weakness at Finding 2022-001 also applies to this grant. Action Taken: The SLV BOCES will continue to evaluate duties and responsibilities of staff responsible for financial close and grant reconciliation. As of September 2022, Special Education Coordinators have been given grant oversight responsibilities and will monitor grants closely to assure that expenditures are made in a timely manner. Although the BOCES does not currently have a Budget Manager, we are working closely with an accounting agency to perform budgeting and accounting tasks with the assistance of the SLV BOCES HR/Payroll Manager. If the U.S. Department of Education have questions regarding this plan, please call the responsible party listed below. Sincerely yours, Stacy Holland Interim Executive Director San Luis Valley Board of Cooperative Educational Services Cindy Squires Human Resources/Payroll Manager San Luis Valley Board of Cooperative Educational Services

CORRECTIVE ACTION PLAN - FINDING 2022-002 We have prepared the accompanying corrective action plan as required by the standards applicable to financial audit contained in Government Auditing Standards and by the audit requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Federal Assistance # 84.041, 84.425, 84.027 Program Titles Impact Aid, Covid-19 Education Stabilization Fund, Special Education ? Grants to States Federal Agency U.S. Department of Education Condition The District did not submit their audit for the fiscal year ending June 30, 2022 timely. The audit was submitted April 24, 2023, which was 24 days past the March 31, 2023 deadline. Corrective Action Plan The District will coordinate with the audit firm under contract to ensure that the audit report for the fiscal year ending June 30, 2023 will be submitted in a timely manner. District Contact Arlene Laughter, Business Manager Completion Date June 30, 2023

Finding 2022-002: Late Residual Receipt Payment Auditee?s Response: Shalom II Housing, Inc. (the Organization) is in agreement with the finding and the recommendation. During 2021, the Organization did on review their surplus cash calculation on a regular basis, resulting in a late deposit. Subsequently, the Organization deposited $13,939 to their residual receipts account. Planned Corrective Action Plan: The Organization will deposit $13,939 to their residual receipts account. Name of Responsible Person: Renee St. John, Chief Financial Officer Name of Department Contact: Renee St. John, Chief Financial Officer Current Status: In Progress. Management is working on depositing the necessary funds into their residual receipts account. In addition, management is working on developing a procedure to calculate surplus cash on a monthly basis to ensure surplus cash is properly calculated. This is expected to be completed during fiscal year 2023.

Finding 2022-002 Material Weakness in Internal Control over Compliance, Noncompliance ? Reporting Corrective Action Plan Weakness referenced Uniform Guidance Reporting that is not applicable going forward due to federal program discontinuing. Expected Completion Date Please see above.

Special Tests and Provisions ? Wage Rate Requirements There is no disagreement with the finding. Management immediately began to review policies and procedures. District Contacts: Mark Boehlke, Assistant Superintendent, Business and Operational Services Wendy Baackes, Coordinator of Financial Services Finding 2022-002 expected to be corrected during the 2022-23 fiscal year.

Responsible Individuals: Marth Pena, Coordinator of Afterschool Programs Corrective Action Plan: OUSD has implemented a new Expanded Learning Attendance improved tracking system and provided training to service providers. This new database allows for accurate and prompt attendance taking. 1. OUSD transitioned to a new attendance tracking system. Due to the multiple errors and consistent changes in attendance, OUSD began using Aeries Supplemental Attendance tracking instead of CitySpan in fall 2021. This transition has allowed the Expanded Learning Office to support struggling sites with real-time accurate attendance data. 2. On July 29, OUSD held a mandatory Aeries training for all after-school staff and reviewed all CDE (ASES, 21st CCLC, and ASSETS) attendance requirements. Over 100 after-school staff attended. 3. All Attendance documents were revised to include Aeries attendance protocols. 4. OUSD Designed dashboards with real-time student and attendance data for all after-school providers The CDE has accepted the District's CAP as of 8/29/2022, and we expect improved outcomes during the fiscal year 2023. Anticipated Completion Date: June 30, 2023