Corrective Action Plans

When or if the District enters into another project funded with federal dollars, the District will create a spreadsheet to track the submittals of weekly certified payrolls. This tracking document will include the following data: Project Description/Subcontractor Vendor/Date SAM verified/Date Intent Filed and Project Number/Date Affidavit Filed/Position & Dates/Verified Prevailing Wage (State or Federal, whichever is higher). Federal purchasing requirements will be shared with all staff tasked to manage the project.

Finding 2022-003 Federal Agency Name: Department of Agriculture Department of Health and Human Services Program Name: Community Facilities Loans and Grants Cluster Federal Financial Assistance Listing #10.766 Rural Health Research Centers Federal Financial Assistance Listing #93.155 Finding Summary: Eide Bailly LLP prepared our schedule of expenditures of federal awards (Schedule) and accompanying notes to the Schedule. Responsible Individuals: Pete Antonson, CFO Corrective Action Plan: Having auditors assist with preparing the schedule of expenditures of federal awards (SEFA) is not unusual. We will continue to be aware of the financial reporting requirements relating to the Health Center?s schedule of expenditures of federal awards and internal control that impact financial reporting. Anticipated Completion Date: Ongoing

Views of Responsible Officials: Connect Our Kids acknowledges the findings of the audit and will take immediate corrective action. Planned Corrective Action: All accounts will be reconciled in a timely manner for the following fiscal year. The federal grant revenue and expenditure cutoff will be maintained for the end of the fiscal year with any adjustments for accrual purposes no later than January 31st of the following year. Responsible Official: Cara Dobbins, CFO Anticipated Completion Date: 9/30/2023

The Chamberlain School District Business Manager, Michelle Willrodt, is the contact person responsible for the corrective action plan for this finding. Finding Number 2022-001 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 enough personnel to provide an ideal environment for internal controls. The district is aware of the continued weakness in internal controls and will continue to develop policies and procedures and provide on-going controls to reduce the risk.

Renelle Uthe, Business Manager for the Lyman School District, is the contact person for this corrective action finding. Due to the size of the Lyman School District 42-1, we cannot staff at a level sufficient to provide an ideal environment for internal controls. We are aware of this problem and have developed an Internal Control Policy to reduce the risk to an acceptable level.

FINDING 2022-003 Contact Person Responsible for Corrective Action: Darla Cain Contact Person Number: 260-982-7518 Views of Responsible Official: We concur with the findings. COVID-19 Education Stabilization Fund: Manchester Community Schools has established new controls for the mentioned above finding. The assistant business manager will prepare and print the reports. The treasurer will review the financial reports for accuracy. The treasurer will sign off on accurate documents and will file the paperwork for future reference. Anticipated Completion Date: The new internal controls will begin February 2023 and continue according to the grant schedule.

Finding 2022-004 Special Tests and Provisions Material Weakness in Internal Control over Compliance and Material Noncompliance Finding Summary: In our testing of special tests and provisions for Prevailing Wage Requirements, it was identified that the District did not satisfy the requirements of 2 CFR 656.40 through 2 CFR 656.41. The district did not ensure proper inclusion of prevailing wage rate clauses were included in a construction contract and also did not obtain proper support to ensure required certified payrolls were submitted. Responsible Individuals: Brian Korf, Superintendent. Corrective Action Plan: The District will establish controls to follow all applicable requirements under Uniform Guidance and applicable CFR sections. Anticipated Completion Date: June 30, 2023

Finding 2022-002 Department of Agriculture Federal Financial Assistance Listing/CFDA #10.766 Communities Facilities Loans and Grants Cluster Finding Summary: The Center does not have an internal control system designed to provide for the preparation of the schedule of expenditures of federal awards. As auditors, we were requested to assist with the preparation of the schedule of expenditures of federal awards. Responsible Individual: Bill Slater, 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. Anticipated Completion Date: Ongoing

Finding 2022-003 Department of Agriculture Federal Financial Assistance Listing/CFDA #10.766 Communities Facilities Loans and Grants Cluster Finding Summary: The Center?s fiscal year 2023 operating budget was not submitted during the period under audit and prior year audited financial statements were not submitted to USDA until USDA requested them, which was subsequent to the submission timeframe. Responsible Individual: Bill Slater, Chief Financial Officer Corrective Action Plan: A copy of the budget will be sent to USDA as soon as it is approved by the board and has been added to the year end procedures checklist. The audited financial statements will be provided to USDA upon finalization and within the 150 days of year end. Anticipated Completion Date: December 31, 2022

Finding 2022-003 Federal Agency Name: Department of Agriculture Program Name: Community Facilities Loans and Grants Federal Assistance Listing #10.766 Federal Agency Name: Department of Health and Human Services Program Names: COVID-19 Provider Relief Fund and American Rescue Plan Rural Distribution; COVID-19 Coronavirus State Hospital Improvement Program Federal Assistance Listings #93.498 & 93.301 Finding Summary: Eide Bailly assisted in the preparation of our draft schedule of expenditures and federal awards and accompanying notes to the consolidated schedule of expenditures and federal awards. Responsible Individuals: Jody Nelson, CEO and Megan Peterson, CFO Corrective Action Plan: It is not cost effective to have an internal control system designed to provide for a complete and accurate schedule of expenditures and federal awards. We requested that our auditors, Eide Bailly LLP, assist in the preparation of the schedule of expenditures. We have designated a member of management to review the drafted schedule of expenditures. Anticipated Completion Date: Ongoing

Finding 2022-001 Corrective Action Plan: Arden Theatre Company will review supporting documentation for costs applied to grant awards to ensure they are recorded in the proper periods in the accounting software and grant award submissions. In regards to this finding, Arden Theatre Company reviewed costs applied to the SVOG grant to ensure only those that were incurred during the SVOG period of March 1, 2020 to June 30, 2022 were included. Any identified costs that occurred outside of the period were replaced with allowable costs that were incurred during the SVOG period. Anticipated Completion Date: Arden Theatre Company has implemented this corrective action as of December 13, 2022. Name of Contact Person Responsible for Corrective Action: Amy Murphy, Managing Director

Persons responsible for corrective action plan: Resty Rios, Staff Accountant Resty.rios@crihb.org Adrianna Davisson, Grants Manager Adrianna.davisson@crihb.org It is the standard practice for all financial and programmatic reporting to be reviewed and approved prior to submission to the funding agency. The Clinic will ensure that all financial and programmatic reports will be clearly documented with the appopriate review and approval signatures prior to submission to the funding agency. The anticipated completion date is 6/30/2023.

Persons responsible for corrective action plan: Resty Rios, Staff Accountant Resty.rios@crihb.org Adrianna Davisson, Grants Manager Adrianna.davisson@crihb.org The Clinic will review all participant files to ensure all applicable documentation is located within each file. The Clinic will also implement an approval process for new participants to ensure participant eligibility is reviewed and approved prior to providing services. The anticipated completion date is 6/30/2023.

The District is working with Dant Clayton to calculate the difference between the amount paid under the contract and the applicable Davis Bacon prevailing wage rates. The difference will be captured in a change order, which will also incorporate any necessary contract provisions into the agreement with Dant Clayton. This change order will resolve any outstanding issues with the procurement and the use of ESSER funds.

FINDING 2022-001 Contact Person Responsible for Corrective Action: Teresa Hester ? Clerk/Treasurer Contact Phone Number: 765-738-6381 Views of Responsible Official: We concur with finding: As stated in the Finding 2022-001 this finding is also a finding in the 2021-002. All of the transactions were already complete when the 2021 finding was noted. Difficult to change what already was. Internal controls were in place overall with the Grant Writer, Engineering Firm and Clerk/Treasurer, but the town was not provided with direct access to copies of the semi-annual reports. These reports were not accessible because OCRA does not give all unit?s rights to view. (Not being able to have access is where Government Officials should take into consideration when requiring units to be compliant.) Screen shots of the activity were provided to auditor. Description of Corrective Action Plan: The semiannual and other reporting was the responsibility/authority of our grant management. (Town officials have no log-in rights for the records) For future endeavors moving forward we will be implementing a more efficient internal controls. Collaborating with the grant management in knowing when the reports are being filed and that the Clerk/Treasurer is sent a copy of the reports for review. Anticipated Completion Date: This particular project has been finalized, therefore there is no an anticipated completion date. For future endeavors we will implement a more detailed and diversified internal controls process.

Finding Number: 2022-001 Condition: In order to comply with program rules, nonfederal entities must establish and maintain effective internal controls over the federal award, as prescribed by 2 CFR 200.303(a). For Provider Relief Funds, the terms and conditions of the grant, according to U.S. Department of Health and Human Services (HHS), require that the System report certain information accurately into the HHS PRF Reporting Portal in order to attest to the utilization of the funding received. Specifically, the HHS June 11, 2021, post-payment reporting notice provides specific guidance on the calculation of lost revenue and amounts to be reported in the portal. Planned Corrective Action: Chief Financial Officer will insure that all guidance available for PRF reporting (FAQ's etc.) is reviewed prior to making any further submissions to the portal and that the Chief Financial Officer will review the filings with the preparer prior to submissions. Contact person responsible for corrective action: Chief Financial Officer Anticipated Completion Date: August 1, 2023

Finding: 2022-004 Contact Person Responsible for Corrective Action: Heather N Perry, Greene County Auditor Contact Phone Number: 812-384-8658 Views of Responsible Official: We concur with the finding. Description of Correction Action Plan: The Greene County Auditor?s office will establish and maintain effective internal controls over the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Lori Dawn Dickinson will review the P&E Report to verify that all entries are accurate and true, and I (Heather Perry) will submit the report. Heather Perry Greene County Auditor Anticipated Completion Date: April 30, 2024

INTRODUCTION: The last three years have been challenging to the FRHA on many fronts. There were vacancies in several key executive management positions, the Executive Director abruptly retired, and particularly the Director of Finance position had seen three people serve in that role. There was also the COVID-19 pandemic, where key staff people were absent, or working remotely as labor laws were relaxed. Emergency Contracts were issued with many of the formal bidding policies and procedures being forgiven, making it more difficult on internal controls over financial reporting. REMEDY: Stability has been restored with the hiring of a new Executive Director and Deputy Executive Director along with the Director of Finance position. The FRHA is working closely with HUD and DHCD officials, in setting up automated reminders of all Financial Reporting Deliverables to all key personnel. The Executive Director is also meeting bi-monthly with all FRHA Financial team members to review monthly financial requirements. The Executive Director is further forging a stronger professional relationship with the FRHA Fee Accountants and Auditors to establish better communication on all Financial Controls.

Finding 2022-007 Federal Agency Name: Department of Education Program Name: Education Stabilization Fund ALN 84.425 Finding Summary: During our testing of cash management, we noted instances where the Student Aid Portion was not disbursed within 15 calendar days of the drawdown and instances where the Institutional Portion was not disbursed within 3 calendar days of the drawdown. Responsible Individuals: Lorelle Davies, Chief Financial Office Corrective Action Plan: As the deadline neared for the end of the award period, The College initially drew the funds with a plan to make an expedited disbursement of the funds. Other Oregon Community Colleges shared with the College success in receiving extensions for the grants. The HEERF team then determined it would be more impactful to our community if we altered course and requested an extension to implement a more strategic plan. Upon the guidance of the Department of Education Grant Administrator, we promptly returned the funds to G5. Columbia Gorge Community College experience turnover in a large number of key positions and was not aware of the 15-day requirement. The grant agreement was on record, but was missing the terms of the withdrawal document. The Chief Financial Officer contacted the Department of Education by email to acknowledge error and provided an action plan with confirmation that funds were returned. We reviewed and assured that no interest was earned on the funds. Updated our G5 award to remove the previous CFO and reissue all grant terms. The grant team reviewed and assured that no interest was earned on the funds and continued compliance going forward. Since the return of the funds we have continued to communicate, implement, and rectify any and all grant issues. We will continue to seek out grant administrator guidance to prevent these issues in the future. Confirmation of account flag removed and resolution received March 28, 2022 Anticipated Completion Date: March 28, 2022

Management?s Response and Planned Corrective Actions: 1. The name of the contact person(s) responsible for the corrective action a. Kathleen Broadhurst, Finance Director/ShelterCare 2. The corrective action planned: a. Pinehurst Management is the management agent overseeing property through 4/30/2023. A new management agent will be identified to take over the property after 4/30/2023. b. Ensure that the new managing agent employs an onsite manager with HUD compliance experience. c. Currently prioritizing recertifications by oldest first. d. Monthly review of TRACS reports to ensure recertifications are being completed in a timely manner. 3. The anticipated completion date: a. New processes will be implemented by 5/1/2023.

Morrow County School District #1 respectfully submits the following corrective action plan in response to deficiencies reported in our audit of fiscal year ended June 30, 2022. The audit was completed by the independent auditing firm Dickey and Tremper, LLP and reported the deficiencies listed below. US DEPARTMENT Of EDUCATION Education Stabilization Fund (ESF)- Elementary and Secondary School Emergency Relief (ESSER) Fund CFDA# 84.425D Material Weakness #2022-003 Auditor Discussion and Recommendation: Condition and criteria: The District should have control processes in place to ensure that allowable projects subject to prevailing wage requirements are performed under those requirements. There was one project that was subject to Federal prevailing wage requirements but did not get performed or documented for those requirements. Cause: The District did not have policies and procedures set up to monitor the prevailing wage requirements. Context and effect: The District has few capital projects funded by grant dollars, but there was one project for security improvements that fell under Federal prevailing wage guidelines. The proposal from the contractor said it included prevailing wage rates, but there was not an official contract found that would detail the prevailing wage requirements and we were unable to locate copies of certified payrolls indicating the District was not monitoring this requirement. The total cost of the project was $133,878 and included costs for the equipment and installation of the security enhancements. Auditor?s recommendation: We recommend the District update their policies and procedures to identify and monitor projects with Federal prevailing wage requirements. We also recommend contracts containing language applicable to Federal programs be prepared for all large projects. Management?s Plan of Action: Individuals Involved: Matt Combe, Superintendent/Management Gabriel Hansen, Chief Financial Officer/Business Manager Brandi Sweeney, Maintenance Coordinator Plan: The district will include in contracts language requesting the proper documentation of compliance with prevailing wage on contract using Federal programs. To monitor this requirement the district will request from contractors prevailing wage certifications if they are not received timely. Time Frame: Implement in contracts language stating request for documentation of compliance with prevailing wage laws completed by January 3, 2023 Implement review of certified payroll documents and request from contractors when not received completed by January 3, 2023.

Finding 2022-06 Federal Agency Name: Department of Health and Human Services Program Name: COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution CFDA # 93.498 Finding Summary: The Medical Center tracked eligible expenses internally within a spreadsheet. The spreadsheet included errors in the calculation of allowable expenditures, which were included on the Period 1 report to the Health Resources and Services Administration (HRSA). Responsible Individuals: Tim Hall, HORNE Corrective Action Plan: Ensure that all of the spreadsheets used to track expenses are free of errors. Anticipated Completion Date: 3/31/2023

Finding 2022-05 Federal Agency Name: Department of Health and Human Services Program Name: COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution CFDA # 93.498 Finding Summary: The Medical Center tracked eligible patient care revenues internally within a spreadsheet. The revenues included in the spreadsheet and on the Period 1 report to HRSA, which were utilized to calculate lost revenues, contained an error. Responsible Individuals: Tim Hall, HORNE Corrective Action Plan: Ensure that all of the spreadsheets used to track revenue are free of errors. Anticipated Completion Date: 3/31/2023

FINDING 2022-001 Contact Person Responsible for Corrective Action: Colby Shank Contact Phone Number: 317-921-4765 Views of Responsible Official: Ivy Tech Community College disputes this audit finding. The College has an effective internal control system to ensure compliance with requirements related to the Special Tests and Provisions ? Return of Title IV Funds compliance requirement. The College previously determined that the Return of Title IV Funds (R2T4) is high-risk due to the large number of transactions, the College?s modular term-based system, and the manual nature of R2T4 calculations. Therefore, a robust quality control review process was implemented. College personnel regularly monitor the error rates and nature of errors discovered through the quality control review to identify, correct, and eliminate calculation errors. The claimed errors outlined in Finding 2022-001 relate to the interpretation of how a correction recalculation is determined. In correction calculations, aid previously returned as a result of the initial calculation in the 2021-2022 academic year was considered no longer disbursed and was included in the correction calculation as ?aid that could have been disbursed.? In certain scenarios, this can result in different return amounts than if the aid had been included in the calculation as ?aid disbursed.? In the absence of explicit guidance on how to handle these scenarios within the Federal Student Aid Handbook, College interpretation and precedent has been to treat aid previously returned under the original calculation as aid that could have been disbursed. Volume 5, Chapter 2 of the 2021-2022 Federal Student Aid Handbook states that ?any undisbursed Title IV aid for the period that the school uses as the basis for the R2T4 calculation is counted as aid that could have been disbursed.? Ivy Tech confirmed this interpretation as valid via a third-party financial aid expert who facilitated a discussion with a representative of the USDOE. This USDOE representative confirmed the accuracy of the calculation and the alignment with the Federal Student Aid Policy Implementation and Oversight Directorate. During this discussion, the representative stated that the results of the original calculation could not be ignored, and that including aid that is no longer disbursed as ?aid that could have been disbursed? is the proper way to perform a correction calculation. The auditors state the College should have performed the following actions: ?The College should have considered the original amount of aid to be returned that had already been posted to each student?s account. The College should have posted the additional amount of aid to be returned to the students? accounts based upon the net difference between the original calculation and the corrective calculation performed for each student.? This methodology would have produced inaccurate return amounts under the interpretation of guidance from Federal Student Aid from which the College was operating during the review period. Only posting the ?net difference? between the original calculation and the correction calculation would have resulted in too few funds being returned to Federal Student Aid for many calculations during the review period. Specifically, a difference in return amounts occurred when the amount of unearned charges (institutional charges for the period multiplied by the percentage of unearned Title IV aid) was less than the calculated amount of Title IV aid to be returned. Under the R2T4 calculation formula, the amount of unearned charges can effectively create a ?cap? on the amount of Title IV aid to be returned by the school. At Ivy Tech Community College, this cap is most often reached when students receive disbursements of federal student loans prior to withdrawing. Because a relatively small percentage of Ivy Tech students receive federal student loans, most correction calculations performed during the review period by Ivy Tech under our interpretation of the guidance resulted in accurate return amounts. This issue only impacted a subset of students who received a correction calculation during the review period. Description of Corrective Action Plan: Upon receiving new guidance from the Chicago/Denver regional office of Federal Student Aid, Ivy Tech has modified the way in which it performs R2T4 correction calculations. Aid returned as a result of the original calculation will remain in the correction calculation as ?aid disbursed? instead of ?aid that could have been disbursed.? The College is no longer following prior guidance received by an expert consultant, a representative of Federal Student Aid that advised the College to include aid that has already been returned as ?aid that could have been disbursed.? The calculation change will be monitored for correctness through the College?s previously established internal controls and quality assurance process for the R2T4 process. Financial aid staff have been trained on the calculation change. Ivy Tech will review all students during the review period who received a correction calculation and will cover with institutional aid any federal grant aid that otherwise would not have been returned under the new guidance from Federal Student Aid. Anticipated Completion Date: 3/31/2023

Corrective Action Plan For the year ended June 30, 2022 Section II - Financial Statement Findings Section III - Federal Award Findings and Questioned Costs Finding 2022-001 Name of Contact Person: Tarsha Dudley, Executive Director Corrective Action: We will prepare the Actual Modernization Cost Certificates for all grant years that have been completed. Proposed Completion Date: Immediately