Corrective Action Plans

Community Consolidated School District 21 05-016-0210-04 CORRECTIVE ACTION PLAN FOR CURRENT YEAR AUDIT FINDINGS Year Ending June 30, 2022 Corrective Action Plan Finding No.: 2022- 003 Condition: During our audit testing we noted that the District submitted a claim through SPI invoicing for 2,200 laptops ($858,814 in equipment) that exceeded the allowable amount of equipment for reimbursement through the Emergency Connectivity Fund to satisfy the District's unmet need. Plan: Management will develop a process with the Information Services Department to determine that the District is meeting all grant requirements, including measuring unmet need, in order to fully comply with the terms and conditions of a funding vehicle. Anticipated Date of Completion: 6/30/2023 Assistant Superintendent of Finance & Operations/CSBO Management Response: See above

Corrective Action Plan (Prepared by the Charter Holder) Finding 2022 ? 001 Allowable Costs and Cost Principles Management will ensure that all employees involved in the procurement cycle attend appropriate training to further assist in their understanding of federal allowable cost principles. Responsible Party: Marian Hamlett, CFO Implementation Date: February 2023

Statement of Condition 2022-001 (Assistance Listing 14.157 and 14.195): The Corporation did not make all of the HUD required reserve for replacement deposits for the year ended November 30, 2022. Recommendation: Management should transfer $1,423 from the operating cash account to the reserve for replacements fund. Management Response: Agree. On December 16, 2022, management transferred $1,423 from the operating account to the reserve for replacements fund.

Management will deposit $4,198 into the Project?s Reserve for Replacement account by December 31, 2022.

Southern Huntingdon County School District 10339 Pogue Road ? Three Springs, PA 17264-9730 (814) 447-5529 ? FAX (8 14) 447-3967 CORRECTIVE ACTION PLAN YEAR ENDED JUNE 30, 2022 Southern Huntingdon County School District submits the following corrective action plan in response to the finding listed in Section III of the Schedule or Findings and Questioned Costs for Federal Awards for the year ended June 30, 2022: Significant Deficiency in Internal Control and Compliance Finding: Finding 2022-001-Allowable Costs/Cost Principles Condition: Lack of time and effort distribution records for payroll expense charged to ESSER Views of Responsible Officials: Hillary Lambert, Business Manager is the Responsible Official for the ESSER grants. She was unaware of the required time and effort documentation that was needed to support the employee's payroll allocation. Planned corrective action: A biannual time and effort certification has been completed for the first half of the 22?23 school year for the ESSER grants. Procedures have been put into place to ensure time and effort certifications are part of the grant paperwork that is completed at the beginning of every fiscal year. Person Responsible for Corrective Action Plan: Hillary Lambert, Business Manager Anticipated Completion Date: December 20, 2022

For the 2021-22 school year, the District failed to correctly allocate expenditures to the CACFP accounts. In order to correct this action for the 2022-23 School Year, the Director of Fiscal Services will work with the Director of Child Nutrition to reconcile each program and complete the Cost Allocation Worksheet. The District utilizes a direct cost vending agreement, which will allocate costs in an allowable manner. The Director of Fiscal services will be responsible for making the transfer of expenditures from the NSLP accounts to the CACFP accounts. The Director of Child Nutrition will verify the transfers have been completed correctly befor the books are closed. Contacts: Kevin Olson, Lori Toms(Director of Fiscal Services), and Suzanne Stamp(Director of Child Nutrition).

Bonnie Baerwald, MPA, CPA, President CORRECTIVE ACTION PLAN YEAR ENDED JUNE 30, 2022 United States Department of Education Moraine Park Technical College District respectfully submits the following corrective action plan for the year ended June 30, 2022. Audit period: July 1, 2021 ? June 30, 2022 The finding from the schedule of findings and questioned costs are discussed below. The finding is numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAMS AUDITS United States Department of Education 2022-002 COVID-19: Higher Education Emergency Relief Fund ? Assistance Listing No. 84.425 Recommendation: The auditors recommended the District design and implement controls to ensure adequate documentation of controls over verification of vendors status as not suspended or debarred under the requirements of 2 CFR Park 200 Section 200.214 are properly retained. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Moraine Park Technical College will take or has already taken the following actions: 1. Reviewed and updated policies and procedures related to suspension and debarment. 2. Communicated requirement reminders to purchasing agents under federal grants. 3. Training will be conducted for purchasing agents on verifying vendors and retention of documentation prior to procurement. 4. Reviewed documentation of verification retention requirements. Name(s) of the contact person(s) responsible for corrective action: Timothy Keenan, Tara Wendt If the United States Department of Education has questions regarding this plan, please call Timothy Keenan, Purchasing Manager at (920)924-3240.

Corrective Action to be taken: We will develop internal procedures to improve controls and documentation concerning the disbursements of federal grants. Expected Completion Date: We anticipate that the procedures will be completed by July 01, 2023. Contact Person: Steven Greenberg, Assistant Superintendent of Operations.

Finding Reference Number: 2022-001 Concur or Do Not Concur: Concur Agree or Disagree with Auditor Recommendations: Agree Actions Taken or Planned on the Finding: Management agrees with the finding. The related project will reimburse the Project for the costs in the amount of $6,570. Completion Date: August 11, 2022

Compliance: Finding: 2022-006 Condition: During the course of the audit, it was noted that the District charged expenses to the grant that had not actually been incurred. Therefore, the reimbursement basis method was not followed and expenses that were not incurred were claimed in June 2022 resulting in the District receiving revenue before expenses were paid. Plan: The District will first spend the money to claim it for reimbursement. Anticipated Date of Completion: 6/30/2023 Name of Contact Person: Kristina Gardner, Superintendent Management's Response: The District will be sure to spend the money before claiming the expense for reimbursement.

Compliance: Finding: 2022-005 Condition: During the course of the audit, it was noted that the District charged an expense that was incurred after fiscal year end on the cumulative expenditure report through June 30, 2022. Therefore, the reimbursement basis method was not followed and an expense paid in August 2022 was claimed in June 2022 before actually being paid. Plan: The District will first spend the money to claim it for reimbursement. Anticipated Date of Completion: 6/30/2023 Name of Contact Person: Kristina Gardner, Superintendent Management's Response: The District will be sure to spend the money before claiming the expense for reimbursement.

Views of Responsible Officials, Corrective Action Plans, and Contact Information 1) Accounting Controls team will continue to coordinate with Central Office/program coordinators to: a) communicate the impact of questioned cost resulting from current year?s audit findings b) follow through on the sample testing performed on payroll documentations as a secondary control twice a year; and c) provide feedback and training to the schools based on the result of sample testing 2) Accounting Controls team will coordinate with the MyPLN team regarding the implementation of the annual Mandatory Time & Effort Training. This is a required 30-minute training of administrators, timekeepers, and supervisors with review questions at the end of the course, and requires a 100% correct answers before a certificate of completion will be issued. Name: Timothy Rosnick Title: Deputy Controller Telephone: (213) 241 -7989

Views of Responsible Officials, Planned Corrective Actions, and Contact Information Division of Adult and Career Education (DACE) will review the current process and implement the following: 1. Directive will be provided to DACE principals to stop enrolling 16?17-year-old students. 2. Instructions will be given to DACE Accelerated College and Career Transitions (ACCT) Advisors not to enroll students between ages 16-17 moving forward. 3. The District will utilize unrestricted funds for students under the age of 18 that are enrolled in the Workforce Innovation and Opportunity Act (WIOA) program. 4. DACE will continue to serve the existing 16?17-year-old ACCT student population through the end of the school year 2022-23 and use unrestricted funding sources other than WIOA. 5. During school year 2022-23 and henceforth, DACE will not report or claim any student outcomes other than those earned by students who are of 18 years of age and older. 6. DACE will amend the ACCT intake and enrollment policies and procedures in the DACE Counseling Handbook. Name: Megan Carroll Title: Program and Policy Development Coordinator Contact Information: mmc78271@lausd.net or (213) 241-3781 Name: Alejandra Salcedo Title: Federal Grants Specialist Contact Information: axs60041@lausd.net or (213) 241-3812

Views of Responsible Officials, Corrective Action Plans, and Contact Information For the 2021-22 school year, the Food Services Division used federal waivers to support students and families by providing meals under multiple programs. Starting August 2021, COVID concerns resulted in the district discontinuing breakfast in the classroom. USDA waivers permitted the distribution of breakfast and supper meals to students as they left campus for consumption at home. As the school year progressed, the after-school supper program was reinstated for a small group of students at some schools, and this group of students was given a breakfast to take home. Additionally, we distributed weekend meals comprising of supper and snacks. Lastly, the district requested Food Services to serve a morning snack (at the District?s expense) for hungry students. The snacks were tracked manually for reimbursement from ESSER funds by the district. Each meal service required a different form to count meals and multiple sheets for the same meal period depending on how the meal bags were distributed (exit gate vs. classroom). The managers had many forms that had to be put together and summed up to come up with the reimbursable counts. Manually compiling and uploading the information is the reason for the variances. Each time there was a change in the operation, the Food Service team had to create a new training module for the change in operation, which created additional forms leading to the errors seen in the audit review. We want to state respectfully that our error rate for meal counts was 0.4% which, given the multiple food distribution channels to support students, is understandable. To address the audit findings, Food Services will review and modify our procedures and be stringent in monitoring our existing systems and procedures: 1. Food Services Division will add steps to our current meal claiming procedures to ensure accuracy of claims. a. Food Service Manager will utilize the Meal Count Consolidation Form for meal periods that have more than one meal count sheet. b. Food Service Manager will input meal counts into CMS based on information from the Consolidation Form. c. Food Service Manager will run a weekly Meal Counts Report generated from CMS. d. Food Service Manager will compare daily meal count documents to the five-day Meal Count Report for accuracy. e. Area Food Services Supervisors (AFSS) will randomly check meal counts entered in CMS and compare them with the numbers entered in daily meal count sheets. Each school will have a random review every 2-3 months, and where errors are found there will be additional follow up. 2. Food Services will follow the review steps as indicated in Corrective Action Response #1 and confirm the claim for accuracy prior to submission to CNIPS. a. Food Services Central Office Staff will provide a daily meal count report to all Supervisors for review to identify any inputting errors. b. Food Service Managers will review and adjust meal counts prior to the CNIPS claim submission, based on AFSS feedback. The target date for the implementation of the above corrective action plan is by the end of February 2023. Name: Manish Singh Title: Director, Food Services Division Telephone: (213) 241-2993

Views of Responsible Officials and Planned Corrective Action Corrected. As the HRSA program stopped receiving claims as of March 22, 2022 due to lack of sufficient funds, QHS will evaluate lab requisitions submitted by the urgent care subsidiary to determine total amount of claims to be remitted back to HRSA as a result of error when filing the claim. Urgent care personnel have also been retrained on the lab requisition process and additional monitoring controls are being considered to assist in detecting errors made during this process.

The District will review each cell entry before submission of expenditure reports. The District's total expenditures exceeded the ESSER II allotment to cover the error on the cell entry. See the full Corrective Action Plan included with the reporting package.

Criteria: The federal drawdowns should be documented with support for the calculation of the amount and with indication of a review by a second individual to ensure the propriety of the amount. Condition/Cause: The District?s process for requesting funds did not have evidence of a review by a second individual prior to drawing the funds down from the grantor. Effect: The District did not have a strong control environment to ensure federal drawdowns were properly supported and calculated for the amounts requested. Recommendation: We recommend the District implement processes to have a second person review and approve the support and the drawdown amount from federal grants prior to requesting those funds from the grantor. Response from Responsible Officials and Corrective Actions: Action: Written procedures will be developed to address the protocols of records retention and management.

Findings and Questioned Costs Related to Federal Awards Finding Number: 2022-001 Program Name/Assistance Listing Title: MBDA Business Center Assistance Listing Number: 11.805 Contact Person: Carlos Valdivia, VP of Administration and Finance Anticipated Completion Date: October 31, 2022 Planned Corrective Action: The 2 CFR Part 200, Appendix XI ?Compliance Supplement? released in July 2021, did not provide guidance on which of the twelve compliances apply to the grant in question. Therefore, the AZHCC Foundation did not have the proper procurement procedures in place during the calendar year ended December 31, 2021. AZHCC received the 2021 final single audit report, which included the noncompliance with the ?Procurement and Suspension and Debarment? finding, on August 9, 2022. AZHCC implemented and put into action the proper policies on October 1, 2022. It is the AZHCC Foundation?s policy that minority and women owned businesses whose expertise match the needs of the contract get preference over other contractors. While we have worked with our vendors for many years, by virtue of the government grant source, we are constantly vetting minority business enterprises for new and diverse contractors. The following was implemented on October 1, 2022: ? The AZHCC Foundation developed policies and procedures for: o purchases that exceed the micro-purchase threshold of $10,000 but are less than the simplified acquisition threshold of $250,000. o Verification that selected vendors are not suspended or debarred. ? The AZHCC Foundation distributed policies and procedures to staff. ? The AZHCC Foundation trained staff on the new policies and procedures. It is the AZHCC position that the correction action was implemented within a timely manner, within 60 days, from the day of receiving the 2021 final audit report. None of the transactions in question for the 2022 audit finding took place after the correction action was applied.

Comments on the finding and each recommendation: The Corporation's required deposit into the residual receipts account per the June 30, 2021 Computation of Surplus Cash, Distributions and Residual Receipts was not deposited within 90 days of the fiscal year end. Management should make all required residual receipts deposits per the annual Computation of Surplus Cash, Distributions and Residual Receipts within 90 days after the fiscal year end. Action(s) taken or planned on the finding: Agree. Management deposited $233 into the residual receipts fund on June 30, 2022.

Finding ref number: 2022-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with allowable activities and costs, equipment, and restricted purpose requirements. Name, address, and telephone of District contact person: Joe Vetter, 2320 Borst Avenue Centralia Washington 98531 ? (360)-330-7600 Corrective action the auditee plans to take in response to the finding: Response to the Finding The District does not concur with the audit finding or the questioned costs. When the District applied for the ECF funding in 2020, we were in compliance with the requirements that were set forth by the FCC. It is only when the requirements were altered in 2021 and written in a more unclear manner that the District potentially did not comply with FCC guidelines. The District does agree that there is always room for improvement with internal controls and processes, however this was during the pandemic and we believe the appropriate level of reporting would be a management letter because all costs were allowable and devices were only provided to those with unmet need. The audit?s condition states that our internal controls were ineffective for ensuring we requested reimbursement only for students and staff with a documented unmet need and that some inventory elements for 10% of the equipment purchased with ECF funds were missing. Based on the guidance below, we have spent all funds for allowable costs, that those costs were reasonable and necessary and for students with unmet needs. Districts were able to determine whether students had unmet needs, and for our district this meant addressing instances where students may share a home device with others, the device was too old or slow to function properly, student owned devices did not have the appropriate security in place to protect students during remote learning, and operationally the district could not access personally owned devices to provide the thousands of Prioritizing Students ? Upholding High Expectations ? Championing Hope ? Cultivating Collaboration technical, problem solve technical questions, keep students safe and issues students faced during remote learning. Based on these experiences, unmet need was defined broadly, but within allowed parameters and inventory records were kept. Devices for remote learning could also be used at school. During the pandemic in Washington State we experienced times when classrooms, schools and or districts were closed by health department and state regulations because of outbreaks. Districts had to be prepared to support remote learning each day with constantly changing guidance on who was allowed to be in person. The following guidance from the Federal Communications Commission, titled ?Emergency Connectivity Fund Common Misconceptions?, ?Misconception #2: If schools have returned to inclass instruction for the upcoming school year, they are not eligible to participate. Answer: This is false. Equipment and services provided to students or school staff who would otherwise lack sufficient access to connected devices, and/or broadband internet access connection while off campus are eligible for Emergency Connectivity Fund Support.? From the Federal Communications Commission Order FCC-CIRC21-93-043021, question 77: ?We think schools are in the best position to determine whether their students and staff have devices and broadband services sufficient to meet their remote learning needs, and we recognize that they are making such decisions in the midst of a pandemic. We, therefore, will not impose any specific metrics or process requirements on those determinations.? And from question 53: ??we are sensitive to the need to provide some flexibility during this uncertain time. If those connected devices were purchased for the purpose of providing students?with devices for off-campus use consistent with the rules we adopt today, we will not prohibit such on-campus use.? SAO did not apply any reasonable measure to reduce questioned costs but did state they know some of the costs are reasonable, while still choosing to question all costs. A unmet needs survey was shown to the auditor?s, originally applied to reduce questioned cost, and then it was considered unsatisfactory. Receiving a 100% response rate for any survey to reduce questioned costs is not reasonable to expect in any setting, let alone among a student population of 3,200 students during a pandemic. That is clearly out of alignment with the FCC guidance. Corrective action the auditee plans to take in response to the findings: The District does not concur with the finding or questioned costs. SAO reviewed various types of documentation and chose not to accept any documentation presented by the District to even consider reducing questioned costs. The standard of documentation required by SAO to satisfy ?unmet? need in would have been hard to meet even if the District hadn?t been in the midst of a pandemic. The District has internal controls over asset inventory and software that was provided to the auditors to see the current inventory and the District only provided equipment only to students and staff with unmet needs, and all costs were allowable, reasonable and necessary. We look forward to working with the FCC to resolve this finding and we appreciate the guidance that was provided by the FCC, as noted below. Guidance from the FCC Devices for remote learning could also be used at school. During the pandemic in Washington State we experienced times when classrooms, schools and or districts were closed by health department and state regulations because of outbreaks. Districts had to be prepared to support remote learning each day with constantly changing guidance on who was allowed to be in person. The following guidance from the Federal Communications Commission, titled ?Emergency Connectivity Fund Common Misconceptions?, ?Misconception #2: If schools have returned to inclass instruction for the upcoming school year, they are not eligible to participate. Answer: This is false. Equipment and services provided to students or school staff who would otherwise lack sufficient access to connected devices, and/or broadband internet access connection while off campus are eligible for Emergency Connectivity Fund Support.? From the Federal Communications Commission Order FCC-CIRC21-93-043021, question 77: ?We think schools are in the best position to determine whether their students and staff have devices and broadband services sufficient to meet their remote learning needs, and we recognize that they are making such decisions in the midst of a pandemic. We, therefore, will not impose any specific metrics or process requirements on those determinations.? And from question 53: ??we are sensitive to the need to provide some flexibility during this uncertain time. If those connected devices were purchased for the purpose of providing students?with devices for off-campus use consistent with the rules we adopt today, we will not prohibit such on-campus use.? Anticipated date to complete the corrective action: 5/24/2023

Current applicable financial personnel, district staff, and school board personnel, including the school board attorney, have been apprised of the Davis-Bacon Act and its application to various projects. The requirements of the act will be addressed annually to ensure all parties (i.e. new employees and new board members) are aware of requirements resulting from the act. All Federally funded facility contracts will include the required prevailing wage rate language and that those wage rates paid by contractors and/or subcontractors for projects are consistent with prevailing wages established by U.S. Department of Labor.

On a monthly basis, the grant department will review the payroll register to verify the payroll is being charged correctly to the federal awards. The grant department staff will notify the Director of Grants and Federal Programs of any employees that are incorrectly charged to a grant. When an error is discovered, an adjusting journal entry will be prepared soon thereafter and reviewed by the Director of Grants and Federal Programs.

This letter is in reference to the City of Rochester, New Hampshire's major federal programs monitoring procedure as part of City's single audit for the year ended on June 30, 2022. Included please find the Corrective Action Plan for the finding related to Time and Effort Documentation. CORRECTIVE ACTION PLAN Audit Finding Reference: 2022-001 Improve Time and Effort Documentation Federal Agency: U.S. Department of Education Program: Title I Grants to Local Educational Agencies AL Number: 84.010 Award Year: 2020, 2021, and 2022 Compliance Requirement: Allowable Costs/Costs Principles Planned Corrective Action: The Rochester School Department developed a procedure to ensure that semi-annual certifications are completed by employees funded under federal funding sources, including Title I, no later than July 30th for the period from January 1 - June 30, and no later than January 30th for the period from July 1 - December 31 annually after the finding 2021-001. This procedure is currently being implemented and has been disseminated to all grant managers and the Federal Grants Manager. The forms are already being utilized and completed by the appropriate employees. Attached please find our semi-annual certification template. This repeat finding is due to the prior year single audit report not being issued until September 2022, which is in the fiscal year 2023, so this change was not able to impact the year ending in June 2022, since that year was already over.

2022-002: Internal Control over Compliance and Compliance with Activities Allowed or Unallowed and Allowable Costs/Cost Principles Contact: Karina F. Alvarez Title: Senior Director of Total Rewards Anticipated Completion Date: September 2023 Corrective Action: The Center?s is committed to ensuring the appropriate documentation is in place in order to adhere to federal regulations regarding activities allowed or unallowed and allowable costs. In response to the audit finding, the Center is taking the following corrective actions to address the audit recommendations: ? Management will review and update policies as needed to ensure employee compensation changes are documented sufficiently and verified through a quality control review; ? Implement additional functionality and security to minimize the potential for data entry error; and ? Design, develop, and implement a new Human Resource Information System (HRIS) that will provide a digital and modern platform to manage review and approval workflows surrounding compensation adjustments. Status as of February 2023: Management has informed the impacted employee and has updated their compensation documentation accordingly.

FA 2022-002 Improve Controls over Indirect Costs Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principle Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: COVID-19 - 84.425D - Elementary and Secondary School Emergency Relief Fund COVID-19 - 84.425U - American Rescue Plan Elementary and Secondary School Emergency Relief Fund Federal Award Number: S425D210012 (Year: 2021), S425U2120012 (Year: 2021) Questioner Costs: $559,442.53 Description: The School District charged indirect cost expenditures to the Elementary and Secondary School Emergency Relief Fund program in excess to the maximum amount allowed. Corrective Action Plans: We concur with this finding. The District is developing corrective actions to strengthen internal controls, policies, and procedures and ensure adherence through improved monitoring. Estimated Completion Date: Fiscal Year 2024 Contact Person: Dr. Myisha Warren, Executive Director of Federal Programs Telephone: 678-676-1200 Email: Myisha_Warren@dekalbschoolsga.org