Corrective Action Plans

ALN: 97.036, Corrective Action Plan: Deficient FFATA Controls - DMA - The Montana Department of Military Affairs, Disaster and Emergency Services Division, will update Federal Funding Accountability and Transparent Act (FFATA) reporting procedures to ensure proper controls are in place for timely and accurate submissions. FFATA procedures will be defined and updated to include saving a copy of each submitted FFATA report and annotating review. The department will reach out to federal partners for additional training and guidance on FFATA reporting to properly comply with federal requirements. Person(s) Responsible for Corrective Measures: Delila Bruno, Administrator, Montana Department of Military Affairs, Target Date: 12/01/2024

ALN: 93.575, 93.596, Corrective Action Plan: Expenditures Not Within Obligation Period - CCDF - PHHS - The Montana Department of Public Health and Human Services, Child Care and Development Fund programs will improve internal controls to ensure federal funds are used in the correct obligation period. Significant improvements were made in state fiscal year 2023. Additional controls were developed to ensure inactivation of cost centers to prevent payroll or other expenses to post beyond the first year of the grant. Guidelines were created to provide additional time and review of the ACF-696 reports prior to submission. The department has identified set-aside costs for grant funds that are allowable and will offset portions of the questioned costs. Person(s) Responsible for Corrective Measures: Tracy Moseman, Administrator, Montana Department of Public Health and Human Services, Target Date: Completed

FINDING 2023-001 Finding Subject: COVID19- Coronavirus State and Local Fiscal Recovery Funds – Internal Controls Summary of Finding: The County had not properly designed or implemented a system of internal controls. A single employee received all accounts payable vouchers for expenditures from the SLFRF award. The employee was to review and approve the accounts payable voucher to ensure all expenditures were for allowable activities, allowable costs, and were within the period of performance prior to issuing payment from the SLFRF fund. Of the sixty accounts payable vouchers tested during the audit period, four were not properly reviewed or approved by the single employee responsible for implementing the control. Contact Person Responsible for Corrective Action: Lisa Clark/Benock Contact Phone Number and Email Address: 812-885-2502, lcbenock@knoxcounty.in.gov Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Auditors Office Accounts Payable Clerk will review the claim voucher to be sure it is properly itemized with fund number on which it is drawn and the appropriation account to be charged. The claim will be reviewed by another Auditor staff member. The claim approval will be filed with consideration by the board of County Commissioners. Anticipated Completion Date: Immediately

FINDING 2023-002 Finding Subject: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Reporting Summary of Finding: The County did not have procedures in place to prevent, or detect and correct, errors on Project and Expenditure (P&E) reports submitted to the U.S. Department of the Treasury. The report submitted during the audit period included projects with current period obligations and cumulative obligations totaling $3,319,955 that had not yet been obligated by the end of the reporting period. It was recommended that management of the County design and implement a proper system of internal controls, including policies and procedures that would provide segregation of duties to ensure appropriate reviews, approvals, and oversight of federal reports are taking place and to ensure the County provides the Treasury with complete and accurate information for the P&E report. Contact Person Responsible for Corrective Action: Amy Copeland Contact Phone Number and Email Address: acopeland@ripleycounty.com; 812-689-6311 INDIANA STATE BOARD OF ACCOUNTS 21 Ripley County Auditor Amy Copeland – Auditor 102 West 1st North Street, PO Box 235 Versailles, IN 47042 Ph: 812-689-6311 Fax: 812-689-3006 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: I, Amy Copeland, Auditor, plan to have the county attorney sit with me when I fill this report out from now on. I will also have one of my employees look over it before it is submitted. Anticipated Completion Date: April 30, 2025

Audit Finding Reference: 2023-001 – Document Policies and Procedures over Federal Awards Planned Corrective Action: The Town is in the process of reviewing Policies and Procedures as they relate to Federal Awards. Name of Contact Person and Completion Date: Derek Geser, Wilbraham Town Accountant & Nick Breault, Wilbraham Town Administrator - No estimated completion date as of now.

Organization submitted expenses outside of period of performance and was unable to provide proof of extension. Statement of Concurrence or Nonconcurrence: Concur Corrective Action: Although we did receive information via email and phone conversations intimating that extension for said grant was imminent, we will no longer continue to submit expenses without documented approval for extension in writing. We will also ensure that all expenses for said contracts will be posted to proper period so that we will comply Responsible Person to Oversee Corrective Action Plan: George Thomas Chief Financial Officer 845-452-2728 ext. 224 Date Corrective Plan will be put in Place: Starting today immediately June 13, 2024

Corrective Action Planned: The identified payments relate to postage expenditures recorded in the Child Support Enforcement Grant. Postage expenditures are controlled in the State's mailing system through mail codes. Agencies send approved postage budgets to the Department of Administrative Services (DAS), who then creates a new mail code or adds additional funding to existing codes in the system. All mail processed through the mailing system is charged to these individual mail codes. A monthly expenditure report from the mailing system is interfaced with NH First, and the DAS uploads a journal entry to the general ledger to record these expenditures. The review and approvals for these postage transactions occur upfront at the agency level, not through a NH First approval workflow. DHHS and DAS will work together to document adequate evidence of this upfront review and approval.

NHED concurs with the finding identified with the expenditures of $3605. The NHED will have the LEA’s submitting for indirect costs after September 30th upload an invoice and back up documentation into GMS. The NHED concurs with the findings identified with expenditures of $5,172. There were in fact some items that were charged outside the period of performance. This happened prior to us receiving the FY22 audit finding and putting in place new controls to prevent. We have since put into place DOE-OBM-33 to ensure payments are being reviewed closely to the period of performance at multiple times. We have also corrected any items charged to the wrong CAN. The NHED concurs with the findings identified with expenditures of $816. We will look into the district returning these funds or other enforcement actions. In addition to the DOE-OBM-033 process, the Division of Learner Support has created and implemented a transfer of funds procedure.

In regards to COVID-19 Coronavirus State and Local Fiscal Recovery Funds (SLFRF) - Assistance Listing No. 21.027; Grant period - Year ended December 31, 2023 the District will put measures in place to ensure that only costs compliant with the proper period of performance are charged to the grant. The anticipated completion date of these actions is April 18th, 2024 with Jeff Peeples the responsbile person for implementation

Maintain detailed documentation of the review process, including any findings or discrepancies identified during the review of drawdowns. Establish clear review procedures for the drawdowns prepared by the Assistant Controller. Continuously monitor the effectiveness of the review process and identify areas for improvement. Implement any necessary changes or enhancements to the review procedures to ensure thorough compliance with grant requirements.

To ensure compliance with grant regulations the school district will implement the following: ● Conduct a comprehensive assessment of existing procedures to identify gaps that led to non-compliance with grant regulations. ● Ensure timely submission of grant applications. ● Maintain detailed documentation of all award dates and expenditures to provide a clear compliance record. ● Ensure all documentation is easily accessible and systematically organized for audit purposes. ● Ensure pre-award costs are allowable only to the extent they would have been allowable if incurred after the effective date and ONLY with written approval from the Federal awarding agency (as per 2 CFR 200.458). ● Establish a process for obtaining and documenting written approval for pre-award costs. ● Provide comprehensive training on compliance with Uniform Grant Guidance to all relevant staff. ● Review and update policies and procedures related to grant expenditures regularly to ensure they are current and compliant with federal regulations. ● Assign accountability for monitoring and reporting compliance to specific roles within the organization. This implementation of this plan shall be the responsibility of the Russ Kaubris, Business Manager. Starting with the Fiscal Year 2025 grant cycle, procedures to comply will be implemented.

DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION 2023-005 Child and Adult Care Food Program – Assistance Listing No. 10.558 Action taken in response to the finding: The Office for Food and Nutrition Programs (FNP) has moved from a paper based permanent agreement to a web form that exists on the DESE Security Portal. All existing and new Child Nutrition Sponsors will continue to sign off on the document via the web-based portal allowing for a more efficient collection and document retention process. A change will be made in the portal to automatically apply a DESE signature upon submission of the permanent agreement to avoid a late DESE signature. Name of the contact person responsible for corrective action: Rob Leshin, Director of FNP Planned completion date for corrective action plan: July 1, 2024

DEPARTMENT OF ELEMENTARY PUBLIC HEALTH 2023-003 WIC Special Supplemental Nutrition Program for Women, Infants, and Children – Assistance Listing No. 10.557 Action taken in response to the finding: The Department and the WIC Nutrition Program will have all fiscal staff review the Operating Procedures to refresh themselves of the procedures surrounding Purchase Orders and Expenditures. (Excerpt from Operating Procedures) All Staff should complete a “Request for Purchase” form with all pertinent information such as quotes, renewal notices, conference registration, etc. and submit it to supervisor or Director for initial approval. Once the request is approved, the form is given to a fiscal staff to start the process of encumbering funds through MMARS and preparing a PURCHASE ORDER. At the very least, staff will identify that the service performed is correct and that funds are available and already encumbered to process the payment. All federal payments require a Program Code, and so the fiscal staff need to be sure the appropriate one is entered based on the dates of service or the date of the Purchase Order. Once all documents have been uploaded and submitted, then either the WIC State Director or the Fiscal Director will need to electronically approve the transaction in the Tracking System. The Fiscal Director and the State Director will more thoroughly review the assignment of Program Codes as they pertain to the Federal grant award dates before approving payment documents. This review will involve verifying: • The type of service • Date of service or receipt of item • Date of Purchase Order • Program Codes Name of the contact person responsible for corrective action: Beverly Andrew and Rachel Colchamiro Planned completion date for corrective action plan: April 30, 2024

Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. The Health System will review, modify, and implement policies and procedures over the program to ensure funds are disbursed for expenditures incurred prior to requesting reimbursement and that expenditures are incurred within the contract’s performance period.

Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. The Health System will review, modify, and implement policies and procedures over the program to ensure that costs incurred are appropriately charged based on the contracts’ performance periods.

Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. The Health System will review, modify, and implement policies and procedures over the program to ensure that costs incurred are appropriately charged based on the contracts’ performance periods.

Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. The Health System will review, modify, and implement policies and procedures over the program to ensure that costs incurred are appropriately charged based on the contracts’ performance periods.

2023-002 Finding: Allowable Costs and Allowable Activities Status: Corrective action in progress Criteria: According to 2 CFR Part 200.303 - The non-Federal entity must (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (b) Comply with the U.S. Constitution, Federal statutes, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity's compliance with statutes, regulations and the terms and conditions of Federal awards Condition: During testing, we noted that one transaction totaling $1,501,269 related to 2022 activities and was included as an expenditure on the fiscal year 2023 Schedule of Expenditures of Federal Awards. The period of performance for the project began in 2022 and extended through 2023. Corrective Action: To facilitate more accurate and timelier grant reporting the following improvements are proposed: 1. Increased grant training for all departments. The Engineering Department is bringing in CDOT to do this, last year Forvis Mazars provided countywide training and the Finance Department will provide additional training on an ad hoc basis. A full understanding of the requirements of the grants that are being applied for is crucial. 2. Departments receiving grants will provide monthly reconciliations of all grants and provide grant agreements to the Finance Department to ensure accurate reporting on the SEFA (Schedule of Expenditures of Federal Awards). 3. Effective communication is essential to successful reporting and the Finance Department will formalize meetings with departments to address issues that surface and reporting expectations. Person(s) Responsible for Implementation: Jill Janz – Accounting Manager, Christie Guthrie – Assistant Finance Director Implementation Date: 6/1/24 and ongoing

Capital Fund Program – CFDA 14.872 Recommendation: The Commission should review the obligation and expenditure of capital grants on an ongoing basis and implement policies and procedures to ensure all federal compliances are followed pertaining to obligation and expenditures verification. Action Taken: New Management has taken over as of March 2023 and will review and implement stronger policies and procedures pertaining to capital fund grants. Anticipated Completion Date of Action: December 31, 2024.

Finding 2023-001 U.S. Department of Education Condition: Tuition invoices and payroll costs were charged to a 2023 grant that were for services rendered prior to the grant start date. Corrective Action Planned: The School will implement procedures to review all manual journal entries for period of performance compliance before posting to the general ledger. Anticipated Completion Date: Immediately Contact: Gilbert Lefort III, Director of Finance, North Attleborough Public Schools

School District 12 Education Foundation (dba Five Star Education Foundation) agrees with the finding and recommendation.School District 12 Education Foundation (dba Five Star Education Foundation) will document approval, or other internal control, to prove transactions charged to grants are allowable, within the period of performance required by the grant and are meet procurement policies established by Uniform Guidance.

The City is developing a formal grants policy that will be implemented in 2024. As a part of this policy, City Departments will be required to demonstrate a detailed understanding of grant terms and conditions and specify to City Administration and the Finance Department how the grant will be administered and monitored prior to application. In addition, Departments will be required to send copies of all grant documents, including reports, to the Finance Department in a timely manner to allow the Finance Department to monitor grant activities

Views of Responsible Officials: The Organizations concur with the auditor's assessment and are in the process of implementing a pre-award risk assessment procedure.

Research and Development – Assistance Listing No. Various Recommendation: We recommend the University review its current close out procedures and implement additional procedures to monitor the timeliness of federal account close outs. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Langston is strengthening the close-out process of federal awards to halt expenditures thus reducing redistributions and cost-transfers. Name(s) of the contact person(s) responsible for corrective action: Mr. Robert Dixon, Director, Grants and Contracts Fiscal Administration at Oklahoma State University and Mr. Chris Kuwitzky, Vice President for Fiscal and Administrative Affairs. Planned completion date for corrective action plan: September 2024

We agree that the allocation being performed once annually does not create the most equitable allocation of costs between our individual programs. We will perform our indirect cost allocations more periodically during the course of the fiscal year to ensure that more appropriate times studies and applicable participant hours are being utilized to limit the potential of allocating unrelated indirect costs from the year to individual programs, including the federally funded programs.