Corrective Action Plans

Finding 2022-004 – Special Education Cluster – AL No.’s 84.027 & 84.173 Department of Education Massachusetts Department of Elementary and Secondary Education and the Massachusetts Department of Early Education and Care Noncompliance and Significant Deficiency Related to Internal Control over Compliance of the Major Programs Criteria: The Period of Availability for the SPED PL 94-142 Grant was September 29, 2021 through September 30, 2023. Condition: During our test of controls over compliance it was noted that there are expenditures charged to the SPED PL 94-142 Grant (September 29, 2021 through September 30, 2023) for services outside of the period of performance as set forth by the Massachusetts Department of Elementary and Secondary Education. Context: During our test of expenditures and review of the general ledger against the SPED PL 94-142 Grant as it is related to compliance it was noted that the first payroll charged to the grant were for services prior to the grant start date of September 29, 2021 and thus would be outside the period of performance and thus would not be allowable costs. Effect: The School Department was not in compliance with the period of performance requirement as set forth by the Massachusetts Department of Elementary and Secondary Education. Questioned Costs: Questioned costs for the first payroll charged to the grant whose service period was prior to the grant start date of September 29, 2021 was $7,249.98. Cause: Staffing turnover in the financial department lead to weakened standard procedures/protocols by inexperienced (temporary) staffing. Recommendation: We recommend the School Department follow procedures to ensure that expenditures charged to the grant are within the period of performance as set forth by the Massachusetts Department of Elementary and Secondary Education. Managements Response: Management agrees with the auditors’ findings and will put in procedures and policies to correct the action going forward. Responsible for Corrective Plan: Patrick McIntyre, School Business Manager Estimated Completion Date: Fiscal Year 2023 Action Taken: The School Department ensures that expenditures charged to the grant only once approved and within the period of performance as set forth by the Massachusetts Department of Elementary and Secondary Education (DESE). Accounting codes are not set up for individual grants until final approval from DESE.

Invoices that are received will be scanned to “invoices”. This will direct them to our electronic software, Docuware. The item will then be forwarded to the appropriate Program Director for approval, and they will indicate the appropriate cost centers / allocations. Bookers will then review the approved coding and entered fiscal software. If there is a question or concern about approved coding by the bookkeeper they will speak with Director of Finance, Ethan Terrio. Once invoices are entered into fiscal software, checks will be printed. The check stub and invoice will be attached to each other and filed in the fiscal department. Paper documents will continue to be maintained in fiscal until we go 100% paperless, then all documents will be stored in Docuware.

1. Processes related to the program stating roles of each individual involved in the process were documented and implemented in September 2022. 2. Regular risk assessment and monitoring functions are performed by management and grant awarders.

Following the completion of the 2021 Single Audit, we adjusted the Organization's Accounting Policies & Procedure Manual to include detailed information outlined in HUD's electronic Line of Credit Control System (eLOCCS) inclusive of the roles and responsibilities of the system's Users and Approving Official. Specifically, Accounting Department Leadership (i.e., the Chief Financial Officer), designated accounting personnel (i.e., Accountants), and/or agency Executive Leadership (i.e., CEO/Executive Director), must be cognizant of a grant's period of performance.

97.036 - Noncompliance with Period of Performance Requirement – Disaster Grants - Public Assistance (Presidentially Declared Disasters) Oklahoma County will design and implement internal control procedures to ensure that all period of performance requirements are met. Anticipated Completion Date: Completed and approved at BOCC on 3/27/2024 Responsible Contact Person: Brian Maughan, BOCC Chairman

January 12, 2023To Whom It May Concern:Finding 2022-001Finding 2022-001 addresses the use of CRF funding and the purchase made that covered period 8/25/21-8/24/22. The District moved forward with this expenditure in good faith based on their understanding of expenditure allowances and reporting. However, because the contract was for yearlong services and extended beyond the close of the reporting window on 10/06/21, CRF funding should not have been utilized.The District has contacted and shared the finding with CDE for additional guidance of how they want us to correct this matter. The District will also implement moving forward a check and balance system of working with the grantee to clarify any concerns about deadlines or allowable expenditures. If further assistance is needed we will work with our auditors to make the adjustments needed.Respectfully,Jorge MartinezDirector, Fiscal ServicesBellflower Unified School District562-866-9011 x 2161

FINDING # 2022-024No finding in prior yearThe New Jersey Department of Labor and Workforce Development (DLWD) has a policy in place for processing tuition reimbursements that are performed by the Department?s Accounts Payable unit. The policy was reviewed by the Office of Finance & Accounting (F&A) and internal control procedures were enhanced to ensure that fiscal cutoff measures were appropriately addressed. Tuition reimbursement procedures include having the requests forwarded to the responsible Supervising Analyst in the Appropriations/Accounting unit for final review and approval to ensure the proper fiscal period is charged. The correcting transactions were completed during the Single Audit timeframe to remediate the findings by charging and reimbursing the proper fiscal year accounts. The DLWD will continue its efforts to ensure compliance and that all charges applied to Federal awards are within the specified period of performance going forward.COMPLETION DATE/CONTACT PERSON December 31, 2023Ruslana Nagorniak(609) 984-7678Ruslana.Nagorniak@dol.nj.gov

FINDING # 2022-021No finding in prior yearThe Department of Children and Families (DCF) will review and enhance its procedures and controls to ensure that expenditures charged to the program are incurred within each grant award?s specified period of performance.Further, as the federal SSBG grant award cited has a period of performance that remains open through September 2023, DCF has adjusted the four transactions that were posted incorrectly to another available funding source and ensured that all transactions presently recorded are now in compliance and within the specified period of performance.COMPLETION DATE/CONTACT PERSON Fiscal Year 2024Steven M. Dodson(609) 888-7555Steven.Dodson@dcf.nj.gov

September 14, 2023This is a corrective action plan in response to the audit finding on our FY2022 Single Audit (2022-001) provided to the Town of Rutland on 8/29/2023.Planned Corrective ActionDuring FY2022 and FY2023 there were significant changes to staffing in the Town Administrator and Town Accountants offices. The project to create formalized written policies and procedures that are required under the Uniform Guidance was not completed. The Town has draft policy and procedures established that will be adopted by the Board of Selectmen and will be implemented for fiscal year 2024.Contact person and Completion dateThe Town Administrators office will be facilitating the implementation of the new policy and procedures that will bring us into compliance with the Uniform Guidance for FY2024. The contact information for his office is as follows:Austin Cyganiewicz, Town Admin. ? acyganiewicz@townofrutland.org 508-886-4100 ext. 1000Tomeca Murphy, Executive Asst to TA & BOS ? tmurphy@townofrutland.org 508-886-4100 ext. 2001

Finding 2022-005 ReportingThe Corporation management agreed with the finding. As of August 15, 2023, the Corporation will remove any individual submissions from the general submission and reconcile the general submission to the supporting documentation less these individual submissions. The Corporation does not expect to receive any further funding from the ARP or PRF and has no further reporting requirements under this grant.Responsible Personnel include Harley McCoige, Controller, Cortney Couture, Director of Accounting, and Samantha Pratt, Director of Internal audit.

Finding 2022-004 Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance, and Special Test and ProvisionsThe Corporation management agreed with the finding. Effective September 1, 2022, The Corporation has implemented the following changes, which we believe would address future internal control considerations.The below procedures were added to the grant checklist which is required on all grants applied for by the Corporation entities. Responsible parties are required to document all procedures and sign off on these procedures. The requirements formalize reporting and data management procedures, which include proper management approval and retention of these records. The grant checklist is additionally approved by the grant applicant and Vice President or Executive Director overseeing the grant.Determine required data requests in order to support this grant:? All data requests should list required data fields and constraints and must be reviewed and approved by management.? Detail sample review of the results must be performed to validate the accuracy and completeness of data and that report results meet the grant requirements.? Report access should be restricted to approved users or report results must be validated to approved constraints.Documentation of these procedures must be retained with management sign off and readily available upon request.Grants in excess of $187,500 require review by Finance or Internal Audit representative to verify that appropriate procedures are in place for documentation of controls on reporting and data management.Responsible Personnel beyond the specific Vice President or Executive director of the grant include Harley McCoige, Controller, Cortney Couture, Director of Accounting, and Samantha Pratt, Director of Internal audit.

Vendor invoice processing is performed by the Accounting Coordinator who inputs pertinent invoice data into the accounting software for payment. The UWGC Senior Director of Finance or in her absence the UWGC Chief Financial Officer will provide a secondary level of review to verify invoices are applied to the correct period for the correct amount after the Accounting Coordinator inputs the data to ensure that Federal funds are reimbursed accurately and in the appropriate period

Vendor invoice processing is performed by the Accounting Coordinator who inputs pertinent invoice data into the accounting software for payment. The UWGC Senior Director of Finance or in her absence the UWGC Chief Financial Officer will provide a secondary level of review to verify invoices are applied to the correct period for the correct amount after the Accounting Coordinator inputs the data to ensure that Federal funds are reimbursed accurately and in the appropriate period.

Management will ensure that accrued expenses are reviewed in detail at grant year end to ensure only costs incurred prior to year end are accrued and reported as grant expenditures.

Finding: 2022-048 - Auditors could not obtain sufficient and appropriate evidence to verify compliance with LIHEAP? s period of performance requirements.Questioned Costs: NoneAssistance Listing Number: 93.568Assistance Listing Title: LIHEAPViews of Responsible Officials (state whether your agency agrees or disagrees with the finding; if you disagree, briefly explain why): DOH agrees with the finding.Corrective Action (corrective action planned): The Division of Public Assistance plans to review all current LIHEAP compliance procedures to identify areas for improvement. Potential modification of accounting structures will be examined as well. Staff training will take place to ensure any new procedures are fully understood prior to official implementation of updated processes.Completion Date (list anticipated completion date): DOH anticipates the finding will be resolved in FY2024.Agency Contact (name of person responsible for corrective action): Josephine Stern, Assistant Commissioner

Finding: 2022-070 - Testing of five subawards subject to Federal Funding Accountability and Transparency Act (FFATA) requirements had obligated amounts incorrectly reported to the FFATA Subaward Reporting System, or not reported at all.Questioned Costs: NoneAssistance Listing Number: 66.202Assistance Listing Title: Congressionally Mandated ProjectsViews of Responsible Officials (state whether your agency agrees or disagrees with the finding; if you disagree, briefly explain why): AgreeCorrective Action (corrective action planned): FFATA Quality Compliance Plan:1. Develop and immediately implement Standard Operating Procedures to be incorporated into the staff instruction manual for FFATA reporting protocols.2. Develop, implement, and maintain a spreadsheet of all FFATA ? mandated subaward reporting, containing a comprehensive list, by federal grant funding source, including due dates and sign-off by responsible staff member when submitted into the FSRS system.3. Train all relevant staff on the procedure manual and FFATA Report Tracking spreadsheet.Completion Date (list anticipated completion date): May 30, 2023Agency Contact (name of person responsible for corrective action): Jenn Brown

Finding 2022-006Significant deficiency in compliance and internal controls over compliance and instance of noncompliance related to periodof performance.Contact Person(s):Nicholas Lee, Chief Financial OfficerCorrective action planned:Vacated billing staff position filled and additional support staff retraining underway to ensure incurred costs documentationis available for processing during the period of performance and subsequent cost reimbursements bills are submitted tofederal awards within appropriate period of performance timeframe.Anticipated completion date:June 30, 2023

FINDING 2022-002Contact Person Responsible for Corrective Action: Janetta C HardyContact Phone Number: 812-752-4343 X222Views of Responsible Official:I concur with the finding.Description of Corrective Action Plan:In April of 2022 the City of Scottsburg?s annual reporting of COVID 19 ? State and Local Fiscal RecoveryFunds for 2021 provided the Common Council?s allocated expenditures for the reporting period instead ofactual expenditures for the reporting period. This error was corrected in the 2023 reporting for April 1,2022 ? Mar 31, 2023 expenditures. However the cumulative obligations and the current periodobligations were again reported as the total grant award. This will be corrected in the April 2024reporting.In regards to this finding, as clerk treasurer I reviewed the report created by Tish Richey and submittedwith inaccurate numbers. I qualify this under human error, commonly known as a mistake. In the future, Iwill do my best to not make a mistake in reporting and retain the initialed documentation for what issubmitted. Lastly, this was the first year for federal reporting of these funds and the instructions wereambiguous at best.Anticipated Completion Date: April 2024

AUDIT FINDING REFERENCE: 2022-002FINDING SUMMARY:The District?s expenditures charged to grant award number 21-340-07000 occurred prior to the date of the sub-grantaward provided by the State of Nevada Department of Education.RESPONSIBLE PERSON:Dr. David Jensen, SuperintendentPLANNED CORRECTIVE ACTION:This finding was in relation to a pass-through grant of Supplemental Corona Virus Relief Funding provided to theDistrict in lieu of an error found in the PCFP funding formula for the bi-ennium. While the District?s expenditures forthe program are consistent with the March 1, 2020 through December 31, 2021 Period of Performance for thisfederal funding, the Period of Performance on the sub-grant Award was listed as December 10 through December 31,2021. Prior to acceptance, the District informed the pass-through entity that the funds would be used to reimbursecosts incurred during July through October, 2021, and the pass-through entity personnel verbally assured Districtmanagement that this would be acceptable. However, the pass-through entity did not amend the sub-grant awardperiod of performance, resulting in non-compliance with the sub-grant award.Humboldt County School District agrees with the audit finding that this was an isolated instance resulting from aunique situation that arose and was out of the District?s control, and is not the result of a systematic problem.However, the District will follow the recommendation and make every effort to obtain written documentation of anypromised revisions to sub-grant awards prior to expending funds from the pass-through entity in the future.ANTICIPATED COMPLETION DATE:January 31, 2023

Corrective Action Plan: After monthly reconciliations, financial statements will be delivered to AJAC Directors monthly. AJAC Accounting Department will hold monthly close calls to collaborate with AJAC Directors to ensure accuracy of financials. Anticipated Completion Date: Completed

Reporting was corrected in the 2024 report.

Federal Agency Name: Department of Homeland Security Program Name: COVID‐19 Disaster Grants – Public Assistance Federal Financial Assistance Listing #97.036 Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Costs Principles and Period of Performance Finding Summary: The review and approval of the expenditure listing was not retained. Responsible Individuals: David Meadows, Interim CFO Corrective Action Plan: Management agrees with the finding and has reviewed the operating procedures of Robert C. Byrd Clinic. Furthermore, we will implement procedures to retain expenditure listings and other support for federal awards as well as the related review. Anticipated Completion Date: Ongoing

Management agrees with the finding and has determined it was due to a grant specific issue that they should not have moving forward. They will continue to monitor grant expenditures to be sure they are only submitted within the period performance.

FINDING 2022-003􀯗 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Reporting􀯗 Summary of Finding:􀯗􀯗 Recipients are required to submit quarterly or annually Project and Expenditure (P&E) reports to the Department of the Treasury (Treasury). The reporting periods, as well as the respective due dates, are based upon type of recipient and its population, as well as the recipient's allocation amount. Information to be reported includes projects funded, expenditures, and contracts for the appropriate reporting period. The County was classified as a metropolitan county with a population below 250,000 residents that received an allocation of more than $10 million in Coronavirus State and Local Fiscal Recovery Funds (CSLFRF). Therefore, quarterly P&E Reports were due by January 31, 2022, and the last day of the month after the end of each quarter thereafter. The County submitted four quarterly P&E Reports during the audit period. The County’s process for the completion and submission of the P&E Reports was the Grant Administrator prepared the P&E Reports and the County Auditor reviewed them prior to submission; however, the control was not effective in detecting and preventing noncompliance. Two of the four quarterly reports submitted during the audit period were selected for testing. The County utilized the current period obligations field to document total obligations less current period expenditures. For the reports tested, the current period obligations, per the County’s interpretation of the field, were not supported by the County’s records. The following errors were noted: Quarter 2 P&E Report (April 1, 2022 - June 30, 2022) 􀄁 The Current Period Obligations for the Revenue Replacement project were overstated by $399,097. Quarter 3 P&E Report (July 1, 2022 - September 30, 2022) 􀄁 The Current Period Obligations for the Prairie Creek Water Run Water Line project were overstated by $67,773. 􀄁 The Current Period Obligations for the Parks Department - Latrine project were overstated by $25,758. 􀄁 The Current Period Obligations for the Foraker/Southwest project were overstated by $230,338. The lack of effective internal controls and noncompliance was a systemic issue during the audit period. Contact Person Responsible for Corrective Action: Patricia Pickens Contact Phone Number and Email Address: 574.535.6719 ppickens@elkhartcounty.com􀯗 􀯗 􀯗 INDIANA STATE BOARD OF ACCOUNTS 36 117 N. 2ND St Rm 203 Goshen, IN 46526 - 574-535-6719 􀀃 Views of Responsible Officials:􀯗􀯗 We disagree with the finding.􀯗􀯗 􀯗 Explanation and Reasons for Disagreement:􀯗􀯗 The finding does not accurately reflect the administration of the SLFRF program and fails to correctly identify key challenges that impacted the difference in data. There is a rigorous system of diligent records keeping, auditing expenditures, and internal controls including multiple points of review and approval for reporting ARPA funds. All expenditures are accounted for and maintained with supporting documentation. The auditing team can clearly demonstrate attention to detail in the tracking and reporting of all expenditures. They also have extensive record of on-going issues with the reporting portal including tickets and communications with Treasury support. They have identified issues with the portal that prevented the submission of reports or caused erroneous calculations/data.

Finding 2022-002, ALN 21.027 Coronavirus State and Local Fiscal Recovery Funds Following the comprehensive audit conducted on the CWWAPP 1.0 disbursement Year Ended June 30, 2022, the following exceptions have been identified that require immediate attention. Below is a summary of the exceptions observed: Summary of Exceptions: 1.Credits applied for electric and secondary water disbursements exceeded the prescribed 60-day timeframe. 2.Recalculation of eligible credits for three out of sixty samples resulted in awarded amounts surpassing the calculated eligibility, leading to questioned costs (i.e., over award). Corrective Action Plan: 1.In order to ensure adherence to the stipulated 60-day window for credit applications, for the upcoming CWWAPP arrearage funding we have initiated immediate testing of bill notices upon receipt of the CWWAPP 2.0 disbursement check. Simultaneously, a secondary query has been implemented to validate consistency between the initial query and the present data. Should any discrepancies or technical issues arise, we will promptly seek extension from the State Water Resources Control Board (SWRCB) to facilitate timely funding. 2.To mitigate the risk of over awarding eligible customers, a final query will be conducted prior to disbursement to confirm the accuracy of awarded amounts for each eligible account. We are committed to implementing these corrective measures swiftly and effectively to uphold compliance standards and improve efficiency within the framework of the SWRCB and CWWAPP. Responsible Official: Jeff Sparks Assistant Customer Service Manager Corrective Action Plan Implementation Date: May 17th, 2024