Corrective Action Plans

2022-036 Department of Human Services Ensure performance data reports are complete and accurate Federal Awarding Agency: U.S. Department of Health and Human Services Assistance Listing Number and Name: 93.558 Temporary Assistance for Needy Families Federal Award Numbers and Years: 2021G996115, 2021; 2022G996115, 2022 Compliance Requirement: Reporting Type of Finding: Material Weakness; Material Noncompliance Prior Year Finding: 2021-009, 2020-013, 2019-008 Questioned Costs: N/A Criteria: 45 CFR 265.7(a) and (b) and (f) Federal regulations require the department to collect monthly and report quarterly certain financial and non-financial data elements for services paid with Temporary Assistance for Needy Families (TANF) federal funding in the ACF-199 TANF data report. Federal regulations also require the department to report data quarterly for TANF eligible clients whose benefits are paid with designated state funds called maintenance of effort (MOE) in the ACF-209 SSP-MOE data report. Both data reports should be supported by applicable performance records. During fiscal year 2021, the department transitioned key aspects of the TANF program to Oregon Eligibility (ONE) for case management, while TANF child welfare payments continued to be recorded in OR-Kids the child welfare system. The department contracts with a service provider to extract data from ONE and OR-Kids to populate the data reports. Program staff currently work with the service provider to obtain comprehensible data reports prior to submission to review them for errors and when found, each issue is logged as a defect for the service provider to correct. The department and the U.S. Administration for Children and Families identified data reports submitted for state fiscal year 2022 were incorrect. The federal quarterly report ended September 30, 2021, was revised and resubmitted but still had likely errors according to program staff. Quarterly reports ended December 31, 2021 (Q1), March 31, 2022 (Q2), and June 30, 2022 (Q3), were corrected and resubmitted in February 2023. Data reports are comprised of individual component reports identified by ?T? for ACF-199 TANF and ?M? for ACF-209 MOE. We reviewed the resubmitted Q1, Q2, and Q3 reports and found: The Q1 TANF T2 and MOE M2 reports corrected a prior known defect. The fields identifying work participation have populated associated fields with job type and hours. The Q3 T6 report showing number of applications, number and types of families, and amount of assistance, reported $4.5 million more than supported by accounting records. The April 2022 T1 report contained 4,035 case numbers not found in the underlying system records, and 1,081 from system records not reported in the T1 report. OR-Kids cases in the Q1, Q2, and Q3 T1 24 of 45 fields left blank. In 10 of 21,171 cases recorded as having surpassed the federal funding limit of 60 months in the Q1, Q2, and Q3 T2 reports, we found three where the T2 reports did not agree to support in ONE. As the performance data reports are known to be incomplete and inaccurate, we are unable to test them for compliance with federal reporting requirements. To date, the implementation of ONE has not resolved findings related to performance data reporting, which have been ongoing since fiscal year 2010. Though the department has yet to receive a Service Organization Control (SOC) report from the service organization administering ONE and compiling data reports the department is in the process of contracting for a SOC report. Without an annual SOC report, the department does not have assurance controls are functioning as intended at the service organization for the TANF program. We recommend department management continue to review ACF-199 and ACF-209 reports prior to submission and monitor known compilation defects to ensure performance data reports submitted are complete and accurate. We also recommend department management obtain an annual SOC report over the service organization?s internal controls for the ONE application. MANAGEMENT RESPONSE: We agree with this recommendation. The Department continues to review ACF-199 and ACF-209 reports prior to submission to identify and resolve defects. The Department continues to monitor defects, sync up reports design with federal instructions, and progress towards complete and accurate reporting. The ACF 199 report issue regarding OR-Kids cases with 24 of 45 fields left blank is currently under development; mapping has been identified to rectify the missing data and once fixed, the future submissions will be corrected. The reports will be resubmitted to ACF at the end of the current fiscal year (for months October 2022 ? Sept 2023) to correct previous data. The issue regarding discrepant case counts between ACF 199 report and OR Kids data extract is under analysis. Child Welfare, TANF, and our technical team will develop a plan for rectifying and reconciling case numbers. The Department?s, Oregon Eligibility Partnership, has contracted for a SOC Type 2 audit, through contract 178884. The first audit review will be utilized to make sure all the reporting requirements and functional areas are in place. This means, the first formal audit finding, based on recommendation from the vendors, will occur in FFY25. Additional internal and external audits are happening on the system. Anticipated Completion Date: December 31, 2023 Contact: Annette Palmer, TANF Program Manager

2022-053 Oregon Health Authority Improve financial reporting accuracy Federal Awarding Agency: U.S. Department of Health and Human Services Assistance Listing Number and Name: 93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (COVID-19) Federal Award Numbers and Years: 6 NU50CK000541, 2020 (COVID-19); 6 NU50CK000541, 2021 (COVID-19) Compliance Requirements: Reporting Type of Finding: Significant Deficiency, Noncompliance Prior Year Finding: 2021-022 Questioned Costs: N/A Criteria: 2 CFR 200.328 In response to the COVID-19 pandemic, the Centers for Disease Control (CDC) awarded states substantial funds for the purpose of addressing the pandemic at the state level. Among other requirements, states are required to submit monthly financial reports to the CDC providing totals spent on travel, payroll, equipment, and other categories. During the fiscal year 2021 audit, we reported a material weakness relating to the accuracy of the amounts reported to the CDC. The same issue persisted throughout fiscal year 2022. As of June 30, 2022, the department had not taken the necessary actions to implement the prior recommendations and had not fully corrected the reports submitted in fiscal years 2021 and 2022. However, as of March 2023, the department had implemented the appropriate corrective actions and the previously inaccurate reports have been updated, including the reports for fiscal year 2022. Audit standards require that we report on the status as of June 30, 2022. We recommend department management maintain the necessary internal controls to ensure the monthly financial reports are accurate and agree to the accounting records. MANAGEMENT RESPONSE: We agree with this recommendation. As you note in your audit letter, our financial reporting accuracy had been remedied for all historical and current reports by March 2023. Unfortunately, these improvements were not in place by June 30, 2022 and, for that reason, a finding was noted. Corrective action plan: ? All monthly financial reporting has been assigned to our Fiscal Analyst ? The Fiscal Analyst submits monthly financial reports and the query used to generate the reports to the Office of Financial Services (OFS) for review and approval ? The Fiscal Analyst revises monthly financial reports based on OFS feedback ? Following OFS approval, monthly financial reports are entered into CAMP by an ELC administrative staff member and verified by a second team member Anticipated Completion Date: March 31, 2023 Contact: Merry Carlson, ELC Contracts Manager

FINDING 2022-003 (Auditor Assigned Reference Number) Contact Person Responsible for Corrective Action: Philip McKelvey Contact Phone Number: 219-759-2531 Views of Responsible Official: we concur with the finding. Description of Corrective Action Plan: Reimbursement reports and claims will be signed off on between the submitter and the Food Service Consultant or Kitchen Manager(s) in order to ensure accuracy. Anticipated Completion Date: January 23, 2023.

FINDING:2022-004 Contact Person Responsible for Corrective Action: Brenda Layne, Food Service Director Contact Phone Number: 765-289-7323 Views of Responsible Official: We concur with the findings Description of Corrective Action Plan: The Corporation Treasure and I discussed this matter and we will be more mindful in the future to get the reimbursement claims receipted in a timely manner. Anticipated Completion Date: February 2023

Finding Number: 2022-004 Condition: During testing of the grant, we noted the School District utilized funds from the Education Stabilization Funds ( ESF) for minor remodeling and renovations of the school buildings. Per the 2022 Compliance Supplement, recipients and subrecipients that use ESF for minor remodeling, renovation, or construction contracts that are over $ 2,000 and use laborers and mechanics, must meet Davis Bacon prevailing wage requirements. The School District expended approximately $ 360,000in ESSER funds that related to repairs and renovations for an indoor air purification system; however, the School District received the certified payroll reports from the contractor prior to being requested by the auditor. Planned Corrective Action: The School District will implement procedures such completing a review of contracts to make sure they include the Davis Bacon prevailing wage rate and review any certified payroll reports from the contractors. Annually for projects subject to Davis Bacon, the district will review certified payrolls of the contractors subject to the legislation. Contact person responsible for corrective action: Nikki Nash, Super intendent and Blair Brindley, Director of Business Operations. Anticipated Completion Date: 6/30/2023

Finding Number: 2022-003 Condition: During payroll expenditure testing of salaried employees, it was identified that, for employees who spend time in multiple cost objectives, appropriate controls were not in place to perform a timely reconciliation between the time charged to Title I based on budget estimates and the actual time expended on Title I activities. Ultimately a reconciliation was performed and approximately $ 99,000 was overcharged to Title I and subsequently reclassified as a non- grant expenditure. However, the School District requested and received reimbursement for this amount during the year- end June 30,2022. Planned Corrective Action: The School District will implement procedures to complete a review and reconciliation process to support the amount charged to Title I based on budget estimates is reasonable when compared to actual time expended on federal and state grants, specifically Title I Reconciliation will occur more than once a year to be able to align grant budgets, as needed. Contact person responsible for corrective action: Jennifer Graber, Director of Curriculum and Instruction and Blair Brindley, Director of Business Operations Anticipated Completion Date: 6/30/2023

FINDING 2022-001 Contact Person Responsible for Corrective Action: Linda Pruitt Contact Phone number: 765-342-1001 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Morgan County Commissioners adopted Ordinance No. 2023-10 which establishes internal control procedures related to the expenditure of ARPA funds. This ordinance also requires reports to be reviewed by the Auditor?s office prior to submission and a printed copy with the County Administrator?s signature and the County Auditor or Deputy Auditor?s signature shall be retained. This ordinance took effect upon passage on April 17, 2023. Anticipated Completion Date: Has already been corrected.

2022-001 Policies and Procedures for Federal Awards Corrective action planned: Create a written policy and procedure on the tracking and usage of federal awards and have it uploaded into our policy and procedure software. Anticipated completion date: February 28th, 2023 Contact person responsible for corrective action: Corey Furin, CFO

The county will review and update our procurement policies and provide additional training and education to all departments to ensure the minimum requirements of 2 CFR 200 and the procurement policies established by the Oconto County Board are being followed. Planned completion date for corrective action: December 31, 2023 Name of the contact person responsible for corrective action: Lisa Sherman, Finance Director

FINDING 2022-002 Contact Person Responsible for Corrective Action: Tamara L. Asdell Contact Phone Number: 812-726-4440 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan The food service director will prepare and sign the monthly reimbursement claim then have the claim reviewed by another cafeteria worker or the corporation treasurer who will then sign off on the claim to be submitted. Anticipated Completion Date. Immediately

CORRECTIVE ACTION PLAN FINDING 2022-007 Contact Person Responsible for Corrective Action: Heidi Sprunger Contact Phone Number: 260-589-3133 Views of Responsible Official: We concur with the finding. The district provided documentation of the email correspondence with the design build project manager. The project manager emailed the district once a month with two separate invoices showing what work had been completed on the project. Once the email was received we had an individual internally check the invoices line for line to confirm that all costs were included in both invoices. Verbal authorization was given to accounts payable to proceed with payment. The district did not have documentation of email verification attesting approval of the invoices. Description of Corrective Action Plan: We have spoken to PSI about a process. We have determined the following, PSI requires subcontractors to submit the certified payroll reports along with their billings. PSI accounting team collects and verifies dates of the CP reports. PSI does not fund the subcontractors? billings until receipt of reports. Once PSI had verified their process the billings will be sent to the district and approval from the Superintendent or Business Manager will be determined before bills will be submitted to the Business Office Manager for submission of payment for the School Board Approval. Anticipated Completion Date: Immediately

FINDING 2022-003 Subject: Child Nutrition Cluster ? Reporting Federal Agency: Department of Agriculture Federal Program: Summer Food Service Program for Children Assistance Listing Number: 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY2021, FY2022 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: 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 requirement. Context: For all four monthly claims selected for testing, there was no formal evidence of the sponsor claim reimbursement summary being reviewed by someone independent of who prepared the sponsor claim reimbursement summary prior to submission. Views of Responsible Officials and Planned Corrective Actions: We concur with the finding. Description of Corrective Action Plan: Tamara Florio, Director of School Nutrition, will prepare and submit the claims after they have been signed and reviewed by Kendra Wright, Treasurer. Kendra Wright, Treasurer, will also compare claims with reimbursements and will sign prepared monthly reimbursement claim reports. Responsible Party and Timeline for Completion: Tamara Florio, Director of School Nutrition, and Kendra Wright, Treasurer ? these changes will be implemented effective immediately.

Finding 2022-001 ? Material Weakness Contact Persons: Marcie Jeffries, Finance Officer, or Trudy Murray, Executive Director Corrective Action: The Finance Department and the Management Department has worked closely with Bank of America at the onset of fraudulent activities from Section 8 Housing Choice Voucher Program to safeguard the assets. Through this process ACH Positive Pay was established for all ECHSA, Inc., bank accounts. This system allows CashPro to block unauthorized ACH transactions from posting to an account and allows the Finance Department to establish ACH authorization online. Further, the system safeguards the accounts by contacting the assigned contact person by phone or by sending a secure message via email of any fraudulent looking ACH pull downs. These activities will not be allowed to pass through the accounts without approval from the Finance Officer. The plan is to continue utilizing the ACH Positive Pay CashPro process to prevent fraudulent activities. As with other issues, COVID-19 Pandemic, for one reason or another, caused a high turnover with staff including the Finance Officer, who left without any notice, which resulted in the Finance Department being without an Officer in charge and payments to vendors becoming the sole responsibility of the Finance Technicians. After advertising the Finance Officer?s position unsuccessfully through several avenues, including local CPA offices, a candidate, Marcie Jeffries, was interviewed and hired effective July 25, 2022. Hiring Ms. Jeffries has allowed the internal controls for the Finance Department to be reestablished and the implementation of the current Finance Manual carried out. The Management Department, with the supervision of the Board of Directors Finance Officer will continue to make every effort necessary to safeguard ALL accounts, in particular, the Section 8 account that experienced the fraudulent activities.

FINDING 2022-009 Contact Person Responsible for Corrective Action: Melissa Hinds, Director of Special Education Contact Phone Number: 812-279-3521 Views of Responsible Official: We concur with the audit finding. Description of Corrective Action Plan: As of July 2022, internal controls were put into place to ensure supporting documentation was attached to all reimbursements. Anticipated Completion Date: July 2022

FINDING 2022-017 Contact Person Responsible for Corrective Action: Tricia Malone Hudson, District Curriculum Specialist Contact Phone Number: 812-279-3521 Views of Responsible Official: We concur with the audit finding. Description of Corrective Action Plan: The school corporation will develop a protocol for ensuring that all documentation and records regarding Federal Grants will be maintained for a period of three years. Anticipated Completion Date: North Lawrence Community Schools implemented this procedure beginning in September 2022.

FINDING 2022-018 Contact Person Responsible for Corrective Action: Tricia Malone Hudson, District Curriculum Specialist Contact Phone Number: 812-279-3521 Views of Responsible Official: We concur with the audit finding. Description of Corrective Action Plan: The school corporation will develop a series of checkpoints for federal grants. This includes multiple staff reviews and approvals prior to purchases. In addition, the reimbursement process includes multiple reviews and approvals prior to submission. Anticipated Completion Date: North Lawrence Community Schools implemented this procedure beginning in January 2023. INDIANA STATE

FINDING 2022-015 Contact Person Responsible for Corrective Action: Tricia Malone Hudson, District Curriculum Specialist Contact Phone Number: 812-279-3521 Views of Responsible Official: We concur with the audit finding. Description of Corrective Action Plan: The school district will establish a process for monitoring the services provided to students in the nonpublic school. Anticipated Completion Date: North Lawrence Community Schools will implement this procedure by June 2023.

FINDING 2022-014 Contact Person Responsible for Corrective Action: Tricia Malone Hudson, District Curriculum Specialist Contact Phone Number: 812-279-3521 Views of Responsible Official: We concur with the audit finding. Description of Corrective Action Plan: The school district has established a process for reviewing reimbursements and district expense records to ensure alignment. Anticipated Completion Date: North Lawrence Community Schools implemented this procedure beginning in January 2023.

FINDING 2022-013 Contact Person Responsible for Corrective Action: Tricia Malone Hudson, District Curriculum Specialist Contact Phone Number: 812-279-3521 Views of Responsible Official: We concur with the audit finding. Description of Corrective Action Plan: The district will develop a system for reviewing the Real Time report to ensure accuracy. In addition, the district will maintain a copy of the participating nonpublic school?s summary data related to enrollment and poverty status. Anticipated Completion Date: North Lawrence Community Schools will implement this procedure by June 2023.

FINDING 2022-012 Contact Person Responsible for Corrective Action: Tricia Malone Hudson, District Curriculum Specialist Contact Phone Number: 812-279-3521 Views of Responsible Official: We concur with the audit finding. Description of Corrective Action Plan: The district will scan and save all testing security agreements for all staff. The test coordinator will be responsible for ensuring that all relative staff complete training and sign testing agreements. Anticipated Completion Date: North Lawrence Community Schools implemented this procedure beginning in September 2022.

FINDING 2022-007 Contact Person Responsible for Corrective Action: Melissa Hinds, Director of Special Education Contact Phone Number: 812-279-3521 Views of Responsible Official: We concur with the audit finding. Description of Corrective Action Plan: As it relates to cash management for the Special Education Cluster (IDEA), the District?s Treasurer and Special Education Director will review all cash balances quarterly to verify compliance with the grant agreement. As of July 2022, internal controls were put into place to ensure supporting documentation was attached to all reimbursements. Anticipated Completion Date: March 2023

FINDING 2022-004 Contact Person Responsible for Corrective Action: Robyn Muder, Director of Business Contact Phone Number: 812-279-3521 Views of Responsible Official: We concur with the audit finding. Description of Corrective Action Plan: Supporting documentation for all transfers out of the Food Service account are kept in a labeled folder. Anticipated Completion Date: North Lawrence Community Schools implemented this procedure in 2022.

FINDING 2022-003 Education Stabilization Fund-Internal Controls Contact Person Responsible for Corrective Action: Michele Fleck, Treasurer Contact Phone Number: 812-882-4844 Description of Corrective Action Plan: Effectively immediately, the Vincennes Community School Corporation will include the Federal Programs Coordinator when preparing any annual reports to confirm accuracy of the reporting. This will provide more internal controls. Anticipated Completion Date: 07/01/2023.

FINDING 2022-002 Education Stabilization Fund-Special Tests and Provisions - Wage Rate Requirements Contact Person Responsible for Corrective Action: Michele Fleck, Treasurer Contact Phone Number: 812-882-4844 Description of Corrective Action Plan: Effectively immediately, the Vincennes Community School Corporation will obtain wage reports from construction vendors. We will make sure to follow the Davis Bacon Act requirements as it pertains to paying construction costs using ESSER funds. Anticipated Completion Date: 07/01/2023

Action planned in response to finding: Management will implement procedures to ensure that all audit documentation, including documentation from third-party service providers, is available for the audit in a timely manner and the audit report is completed and submitted within the appropriate timeframe.