Corrective Action Plans

The Organization will contact the affected federal agency for guidance on resolution of the billing errors. Additionally, the Organization will train management and staff working on the program to ensure an understanding of the program and its allowable costs. Furthermore, staff will be trained to review expenses throughout the year to ensure only allowable expenses are charged to the program. The review of expenses charged to the program will be performed by someone independent from the staff responsible for coding the expenses. The contact person for this corrective action is Annette Kovamees, VP of Revenue and Financial Operations.

April 13, 2023 Roslund, Prestage & Company, P.C. 525 W. Warwick Drive, Suite A Alma, MI 48801 Finding: 2022-001: Significant deficiency in internal control / immaterial non-compliance Federal Program: Block Grants for Prevention and Treatment of Substance Abuse ? Treatment and Women?s Specialty Services Condition: During testing of amounts charged to the grants, it was noted that provider stabilization payments were charged to the Treatment and Women?s Specialty Services grants but were not authorized by the grants. Corrective Action Plan: Mid-State Health Network will review grant documents when implementing new funding initiatives and will seek guidance from the awarding agency as needed. Responsible Party: Amy Keinath, Finance Manager Anticipated Completion Date: October 1, 2022

The Independent External Audit for the fiscal year ended June 30, 2022 included finding #2022-004 in which the District was cited as recording expenditures to the incorrect federal program. Allowable expenditures under the ECF program had not been adjusted to the limits set forth on FCC Form 471, which resulted in an overstatement of expenditures under the ECF program and an understatement of expenditures on the COVID-19 American Rescue Plan Elementary and Secondary Emergency Relief - 3 program. This finding is new to the District as of the 2021-22 Audit and is not a repeat finding. The cause for this finding is the need to reclassify expenditures, amounting to $65,260. The District has recorded these expenditures, of "local share" in the Emergency Connectivity Fund (ECF) budget line. These expenditures should have been expended from the COVID-19 American Rescue Plan Elementary and Secondary Emergency Relief - 3 budget line, as that is where the "local share" was expended. During the 2021-22 Fiscal Year, the School District worked with eRate Central to complete an application totaling $746,356, all of which were approved and committed by the FCC. While the District received this substantial commitment of funds to purchase earmarked technology equipment, the District was also responsible for a local share of some, but not all, devices. These local funds were being paid out of the ARP ESSER 3 Grant, out of a section earmarked for technology purchases. To mitigate findings, such as #2022-004 in the subsequent years, the District will record expenditures properly, using the appropriate budget codes. The District will review its expenditure budget lines and will monitor its usage of Federal Funds more closely. Anticipated Completion Date for Finding 2022-004: October 21, 2022 Person{s) Responsible for Corrective Action: Ryan Palmer & Marianne Romito

Need Analysis Planned Corrective Action: PowerFAIDS utilizes the ?Year in School? reported by the student on the ISIR to calculate Federal Direct Loan eligibility during packaging. If misreported by the student, advisors did not always catch these errors in their review. Executive Director of Financial Aid will provide in-house training to all advising staff to ensure proper understanding of awarding and implication of not appropriately updating fields used to calculate aid eligibility. WBU has funded a Financial Aid Compliance Specialist position in the Office of Financial Aid. Once filled, this position with be devoted to internal audit and federal/state regulation compliance. Person Responsible for Corrective Action Plan: Christy Miller, Executive Director of Financial Aid Anticipated Date of Completion: November 2022

FINDING 2022-002 Contact Person Responsible for Corrective Action: Shawn Spindler, Business Manager/Treasurer Contact Phone Number: 812.926.2090 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The appropriate personnel will prepare some sort of time and effort documentation which will then be approved by the Board of Trustees to have split personnel costs. Anticipated Completion Date: June 2023

Views of Responsible Officials and Planned Corrective Action ? The Purchasing Director will update policies and procedures to specifically address procurement for federal awards. The University will also ensure that Purchasing Department and Business Office staff participate in annual federal compliance training. Timeline and Estimated Completion Date: December 2022 Responsible Party: Aaron Flure, Purchasing Director and Stephanie Gonzales, Comptroller

FA 2022-001 Improve/Strengthen Controls over Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principle Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency 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 COVID-19 - 84.425W - American Rescue Plan Elementary and Secondary School Emergency Relief Fund - Homless Children and Youth Federal Award Number: S425D200012 (Year: 2020), S425U2120012 (Year: 2021) S425W210011 (Year: 2021) Questioner Costs: $30,180 Prior Year Finding: None Description: The polices and procedures of the School District were insufficient to provide and adequate internal controls over expenditures as it relates to the Elementary and Secondary School Emergency Relief Fund program. Corrective Action Plans: Revise Federal Programs Handbook to enhance internal controls in the area of contracts. Provide addendums to contracted services to provide for retention bonuses to contracted staff. Estimated Completion Date: June 30, 2023 Contact Person: Seth Taylor, Chief Financial Officer Telephone: 229-723-4337 Email: staylor@early.k12.ga.us

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Elma School District No. 68 September 1, 2021 through August 31, 2022 This schedule presents the corrective action the District is planning to take for findings included in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Finding ref number: 2022-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with allowable activities and costs, procurement, and restricted purpose requirements Name, address, and telephone of District contact person: Lisa Arnold 1235 Montesano Elma Road Elma, WA, 98541 (360) 482-2822 Corrective action the auditee plans to take in response to the finding: The district concurs with the auditor. The district will ensure that processes are followed by all purchases going through the district office for approval before purchase. Purchases are now through an online system InformedK12 to help ensure procedures are followed. The district would like to note that this finding is because the district did not go out to bid for the student Chromebooks. The bid step was overlooked due to the quick turnaround to purchase devices to make sure all students had Chromebooks for the pandemic. Anticipated date to complete the corrective action: 01/2023

Purpose: To document Pomona College's Corrective Action Plan relating to finding 2022-001 in its June 30, 2022 Single Audit report. Finding 2022-001 Allowable Costs Criteria: The 2022 OMB Compliance Supplement notes the excerpt below as one of the Allowable Cost criteria: c. Costs did not consist of improper payments, including (1) payments that should not have been made or that were made in incorrect amounts (including overpayments and underpayments) under statutory, contractual, administrative, or other legally applicable requirements; (2) payments that do not account for credit for applicable discounts; (3) duplicate payments; (4) payments that were made to an ineligible party or for an ineligible good or service; and (5) payments for goods or services not received (except for such payments where authorized by law). Statement of Condition: Management charged nonpayroll expenses that had not been incurred as of year-end to a federal grant. Stipends for an 8-week summer program relating to Grant 6117 (Pomona Research in Mathematics Experience), CFDA/ALN: 47.049, that ran from June 9, 2022 to August 6, 2022 were partially incurred by year-end (June 30, 2022), but charged entirely to the grant in FY22. Per the contract with the hired Research Assistants, stipends were to be made in two installments, whereby the second installment relates to the portion of expenditure incurred after year-end. The second installment was charged to the grant in FY22, before the Research Assistants completed their grant-related work. Corrective Action Planned: Finance staff are working with the Director of Sponsored Research to better align stipend payment schedules with our fiscal year-end. Appropriate schedules for the variety of grant- funded summer research will be communicated to the Primary Investigators and academic department staff. Accounts Payable staff will be instructed to reject any participant payment requests that are not in accordance with the approved schedules. Additionally, reviews of each grant payment will be performed at the time of the ?payment request and in July, as part of our year-end close process, to identify any grant expen?es that may have been charged to the incorrect fiscal year and reclassify them accordingly. Name of contact Person responsible for corrective action plan: Associate Treasurer and Controller Mary Lou Woods, and Director of Finance Victoria Roberts Anticipated Completion Date: April 2023

Board of Education Independent School District No. 191 respectfully submits the following corrective action plan for the year ended June 30, 2022. Audit period: July 1, 2021 to June 30, 2022 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FINANCIAL STATEMENT FINDINGS None noted FINDINGS?FEDERAL AWARD PROGRAMS AUDITS Significant Deficiency in Internal in Internal Control over Procurement Recommendation: We recommend that the District ensures it retains documentation of its controls over all procurements going forward. We also recommend that the district keep documentation of price analysis and final determination for procurement items over the micro purchase threshold of $10,000. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The District will immediately implement the recommendation. Names of the contact persons responsible for corrective action: Tyler Dehne, Director of Finance Planned Completion date for corrective action plan: 6/30/2023

2022-026 Oregon Housing and Community Services Department Implement program monitoring over client assistance payments to ensure compliance Federal Awarding Agency: U.S. Department of the Treasury Assistance Listing Number and Name: 21.023 Emergency Rental Assistance Program (COVID-19) Federal Award Numbers and Years: ERA 1, 2021; ERA 2, 2021 (COVID-19) Compliance Requirement: Activities Allowed or Unallowed; Eligibility Type of Finding: Material Weakness; Material Noncompliance Prior Year Finding: N/A Questioned Costs: $21,624 (known); $11,067,350 (likely) (COVID-19) Criteria: 2 CFR 200.332(d); 2 CFR 200.501(g) Department management is responsible for monitoring the activities of subrecipients to ensure subawards are used for authorized purposes and are compliant with federal requirements. Additionally, department management is responsible for ensuring compliance when a contractor is responsible for program compliance or the contractor?s records must be reviewed to determine program compliance. The department provided $140 million and $46 million of phase one program funds to community action agencies (subrecipients) and a third-party vendor (contractor) to provide program delivery, respectively; and $132 million phase two program funds to only the contractor. Program delivery included determining client eligibility and making payments for direct client assistance for rent, utilities, internet, and other housing related costs. During implementation of the program, the department provided program manuals to the subrecipients and contractor. Due to the department?s limited staff, they focused on updating policies and procedures to address systemic issues identified; however, if a particularly challenging application required the department?s review, they were available to provide direct assistance. The department did not implement any predefined, systemic program monitoring of the subrecipients or contractor to ensure direct client assistance payments were paid to only eligible clients for only allowable and supported amounts. Therefore, auditors performed additional procedures at the subrecipient and contractor level to determine whether direct client assistance payments were paid to eligible clients for allowable activities. We tested a total of 62 randomly selected direct client assistance payments at 16 subrecipients totaling $183,515, and found the following: One subrecipient did not respond to audit requests for documentation, resulting in an inability to test one transaction in the amount of $360. One subrecipient did not obtain documentation to support that there was a lease agreement in place, resulting in questioned costs of $5,775. When extrapolated to the total population, these errors result in over $2.3 million in likely questioned costs. We tested 61 randomly selected contractor direct client assistance payments totaling $374,274, and found the following: One payment where an incorrect landlord was paid in the amount of $2,700. Attempts to recover the funds have been unsuccessful as of the date of the finding. Two payments where the rental amount was doubled, resulting in overpayments totaling $5,910. Seven payments where amounts already paid were not accurately reflected in the calculation of assistance provided, resulting in overpayments totaling $4,191. Three payments where amounts did not agree to supporting documentation, resulting in overpayments of $2,181. Three payments where there was insufficient documentation for amounts paid, resulting in overpayments of $432. One payment where costs were paid for the same household on alternate applications, resulting in an overpayment of $73. When extrapolated to the total population, these errors result in over $8.7 million in likely questioned costs. We recommend department management implement predefined, systemic program monitoring to ensure the subrecipients and contractor are administering program funds in accordance with program requirements. MANAGEMENT RESPONSE: We agree with this recommendation. OHCS agrees and had we not been operating during a global health pandemic and had we had adequate time and staffing, we would have addressed this issue more carefully as we have in previous years. However, given that this was a new program that lacked sufficient time and resources to design, launch and operate to meet the pressing needs of Oregonians facing eviction and homelessness, the work required unprecedented action that sometimes fell short of our usual standards for client assistance payment compliance. OHCS will use these lessons moving forward should we operate future emergency programs to move towards best practices. Corrective action plan: Lack of staff significantly limited our ability to perform the necessary monitoring. An additional contractor was brought on to monitor the work of our vendor in February of 2022. The contractor continued to provide program compliance support to OHCS through the end of January 2023. This contractor was also engaged in other projects and activities as needed during their contract term. The largest workload was investigating payments or cases that were identified as potentially non-compliant. All these cases were researched extensively, and findings were identified, and corrective action and collection activities were started if needed. Out of concern for the lack of administrative dollars associated with ERA staff knew an internal compliance effort would also be required. Since the summer of 2022 OHCS staff have been conducting internal random samples of applications and payments in addition to the work of our hired contractor. Additionally, this spring the program compliance team has engaged in a formalized review process focused on specific agencies administering ERA funds. Anticipated Completion Date: December 31, 2023 Contact: Jill Smith, Director of Housing Stabilization Division

2022-025 Oregon Housing and Community Services Perform fiscal monitoring for subrecipients administrative expenditures to ensure compliance Federal Awarding Agency: U.S. Department of the Treasury Assistance Listing Number and Name: 21.023 Emergency Rental Assistance Program (COVID-19) Federal Award Numbers and Years: ERA 1, 2021 (COVID-19) Compliance Requirement: Activities Allowed or Unallowed; Allowable Costs/Cost Principles Type of Finding: Material Weakness; Material Noncompliance Prior Year Finding: N/A Questioned Costs: $121,463 (known) (COVID-19) Criteria: 2 CFR 200.332(a)(5) and (d) Department management is responsible for monitoring the activities of subrecipients to ensure subawards are used for authorized purposes and in compliance with federal requirements. Additionally, department management is responsible for communicating to subrecipients that they are required to permit the department and auditors access to their records as necessary to ensure the department is in compliance with program requirements. The department passed through program funds to community action agencies (subrecipients) to provide program delivery, including administrative costs. The department performed fiscal monitoring for only five of their 18 subrecipients during the audit period due to staff turnover. Fiscal monitoring includes procedures to address compliance with activities allowed and allowable cost requirements for administrative costs. Due to the limited fiscal monitoring performed, auditors performed additional procedures at the subrecipient level to determine whether the department was compliant with program requirements. We tested a total of 82 transactions, 70 randomly selected and 12 judgmentally selected from the 13 subrecipients that did not receive subrecipient monitoring during the fiscal year. We noted the following: One subrecipient did not respond to audit requests for documentation, resulting in an inability to test four transactions totaling $4,114. One subrecipient did not provide sufficiently detailed documentation to determine whether 7 transactions were for accurate amounts totaling $117,349. Of those seven transactions, we were unable to determine whether two transactions were for allowable activities or appropriately categorized as administrative expenditures. Without adequate monitoring of subrecipients, the department?s ability to ensure compliance with program requirements is diminished. We recommend department management perform fiscal monitoring to ensure subrecipients are expending administrative funds in accordance with program requirements. MANAGEMENT RESPONSE: We agree with this recommendation. Corrective action plan: OHCS had significant compliance monitoring staff turnover in FY22 which led to a lack of monitoring. OHCS has subsequently hired a contractor to perform fiscal monitoring of all ESG funded grantees. OHCS also hired staff to pre-FY22 levels, fully trained all staff and began developing internal working relationships with program staff to assure operational efficiencies. This includes an annual workshop with all grantees, internal training, and standardizations of monitoring processes. Anticipated Completion Date: June 30, 2023 Contact: Dean Criscola, Controller

2022-060 Higher Education Coordinating Commission Strenthen controls to ensure expenditures are not obligated beyond the period of performance Federal Awarding Agency: U.S. Department of Labor Assistance Listing Number and Name: 17.258 WIOA Adult Program 17.259 WIOA Youth Activities 17.278 WIOA Dislocated Workers Formula Grant Federal Award Numbers and Years: AA32218F30; 2018, AA32218G10; 2018 AA32218G30; 2018, AA32218G70; 2018 AA32218H90; 2018, AA32218F31; 2018 Compliance Requirement: Period of Performance Type of Finding: Significant Deficiency; Noncompliance Prior Year Finding: N/A Questioned Costs: $47,523 (known) Criteria: 20 CFR 683.110; 2 CFR 200.343 (2018) WIOA grants are available for expenditure by the State during the grant program year and the two succeeding program years. In addition, the State must liquidate all financial obligations incurred no later than 90 calendar days after the end date of the period of performance. We judgmentally selected for review expenditures recorded in fiscal year 2022 related to 2018 grant award whose period of performance ended June 30, 2021. Our review of the supporting documentation found there were 3 out of 13 items with expenditures that were outside the period of performance. Total question cost for these expenditures were $47,523. Per management, these errors were due to a change in personnel and trying to balance out the 2018 grant after the fact. We recommend department management review and revise controls to ensure expenditures are only obligated during the period of performance federally mandated dates. MANAGEMENT RESPONSE: We agree with this recommendation. The three errors pertaining to those expenditures that were outside the period of performance, were due to a change in personnel and trying to balance out the 2018 grant, after the fact. The HECC have addressed these issues by ensuring that all new accountants are fully trained in a timely manner. Also, HECC has implemented training for all current accounting staff in identifying what is an allowable cost within the period of performance. This training also included a review of proper close-out procedures for all grants. Anticipated Completion Date: June 30, 2023 Contact: Christopher Bui, Budget and Fiscal Manager

2022-018 Oregon Housing and Community Services Controls are needed to ensure program expenditures are allowable Federal Awarding Agency: U.S. Department of Housing and Urban Development Assistance Listing Number and Name: 14.231 Emergency Solutions Grants Program (COVID-19) Federal Award Numbers and Years: E-20-DW-41-0001, 2020 (COVID-19) Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Type of Finding: Material Weakness; Material Noncompliance Prior Year Finding: N/A Questioned Costs: $245,362 (known) (COVID-19) Criteria: 24 CFR 576.100; CPD-21-08 III.E.3 Emergency Solutions Grants-Cares Act (ESG-CV) funds may be used for the five regular Emergency Solutions Grants (ESG) program components, as well as administrative activities: street outreach, emergency shelter, homelessness prevention, rapid re-housing, and homeless management information systems (HMIS). They may also be used for additional activities including, but not limited to, temporary emergency shelter, hazard pay, handwashing stations, cell phones and internet, personal protective equipment, and laundry. The funds are disbursed to the subrecipients after reimbursement requests are submitted. Federal funds totaling $31,894,565 were distributed to 44 subrecipients during fiscal year 2022. We randomly selected 61 individual distributions made by the department to subrecipients. Subsequently, we randomly selected an expenditure from each disbursement request and then judgmentally selected additional expenditures from select disbursements. While gaining an understanding of the department?s internal control process, we learned the review process for subrecipient disbursement requests did not include a detailed verification that underlying expenditures were for allowable activities and costs. Given the department?s incomplete review process, we were unable to verify compliance by testing those reviews. The department requested supporting documentation from the subrecipients, documentation that should have been reviewed and retained by the department, for the required audit procedures to be performed. Our audit procedures were performed in three stages. First, we randomly selected 61 individual distributions made by the department to subrecipients, totaling $5,580,560. These disbursements generally consisted of reimbursement for multiple expenditures made by a subrecipient. Next, we asked the department to request a listing of expenditures from the subrecipients related to those disbursements. Finally, if provided, we agreed the listings to the disbursement and randomly and judgmentally selected individual expenditures from the listings for testing. We were unable to perform any review of 20 disbursements either because we did not receive a listing of the subrecipient?s expenditures, or the listing did not agree to the disbursement selected for testing. These disbursements related to 10 of the 44 subrecipients receiving funds in fiscal year 2022 and $1,475,345 of the $5,580,560 in disbursements selected for testing noted above. From the expenditure listings we did receive, we randomly and judgmentally selected individual expenditures to determine whether the supporting documentation agreed to the amount requested for reimbursement by the subrecipient. Of those 41 individual transactions selected for testing, there was inadequate or no supporting documentation provided for 29 items, and one instance where the request exceeded the support. These exceptions resulted in total questioned costs of $245,362. If requests for funds are not supported by documented expenditures, the department could be unknowingly reimbursing subrecipients for unallowable costs and activities. We recommend management implement internal controls to ensure subrecipient reimbursements are for allowable expendiures. MANAGEMENT RESPONSE: We agree with this recommendation. OHCS had significant staff turnover in FY22, and that coupled with the substantively increased number of subrecipients, lead to a lack of monitoring. OHCS has subsequently hired staff and established vendor relationships to perform fiscal monitoring as a backup for when staff vacancies exist. Additionally, OHCS is on track to complete fiscal and program monitoring for all subrecipients of ESG funds in FY23. Anticipated Completion Date: June 30, 2023 Contact: Dean Criscola, Controller

2022-059 Department of Human Services Ensure issued benefits are accurate Federal Awarding Agency: U.S. Department of Agriculture Assistance Listing Number and Name: 10.542 Pandemic EBT Food Benefits (COVID-19) Federal Award Numbers and Years: Not available (COVID-19) Compliance Requirement: Activities Allowed or Unallowed Type of Finding: Significant Deficiency; Noncompliance Prior Year Finding: N/A Questioned Costs: $3,692,215 (known); $13,554,666 (likely) (COVID-19) Criteria: Public Law 116-127; 2 CFR 200.303 The federal requirements for the Pandemic EBT (P-EBT) program require state agencies follow their approved state plan. Part of Oregon?s simplifying assumptions in their state plan was that the benefit amount was determined at the school level, not the individual level, based on the school?s operating status, for October 2020 ? May 2021. As part of Oregon?s Ready Schools, Safe Learners program, schools were required to weekly report their operating status/instructional model to the Oregon Department of Education (ODE). In fiscal year 2022, the Department of Human Services (department) paid retroactive P-EBT benefits for children related to the 2020-2021 school year. This sample population consisted of institutions (schools and other educational facilities) and months in which children at the institutions received benefits, totaling $391 million. We selected a random sample of 40 institutions and a random month to determine if the benefits provided to the children, based on the status reported by the institution, were accurate. We identified 4 institutions, for April/May, where the benefit paid status of the institution was not the same as reported by the institution to ODE. In all 4 cases, the benefits paid were at a higher level resulting in questioned costs of $38,931 and likely questioned costs of $9.2 million. One of the simplifying assumptions for the P-EBT program, approved in Oregon?s state plan, was ?Oregon will have a limited reconsideration process to revisit benefit allotments at a school level.? However, the department allowed institutions to update their status without additional review, explanation, or documentation. The department could not provide the auditors any support for the changes made by the institutions. Furthermore, the Oregon Governor issued a directive to schools, on March 5, 2021, to begin a phased approach to require all public schools to provide in-person instruction through either a fully on-site or hybrid model on or before the week of April 19, 2021, for all schools. Although benefits issued continued to decrease as the school year end approached, in May 2021, 26% of the institution?s benefits paid were for fully virtual totaling $17 million. We judgmentally selected 36 institutions classified as fully virtual in May with benefits totaling $7.9 million. For 25 institutions, the benefit paid status did not agree to the status reported by the institution to ODE resulting in questioned costs of $3,653,284 and likely questioned costs of $4.4 million. We recommend DHS perform review to identify any additional discrepancies between benefits paid and the institutions reported status, to determine if payments were appropriate, and communicate with the federal awarding agency to determine if repayment is necessary. MANAGEMENT RESPONSE: We respectfully disagree with the findings that schools were not able to directly update their learning mode according to the guidance provided in the P-EBT state plan. The department has included emails and documents that support the actions/decisions taken in the delivery of the Oregon P-EBT school year 2020-2021 state plan was in accordance with federal approval from Food and Nutrition Service (FNS). According to the USDA FNS approval letter received on May 7, 2021, and posted to the FNS website, FNS confirms that Oregon will ?develop(ed) a centralized database to collect student eligibility information and school status? to determine the monthly benefit level for each school (6th bullet on page 2). This information is also confirmed in email correspondence with FNS on April 29, 2021, and May 3, 2021. Within the email the Department details that Oregon will develop a database to collect school status, this is then confirmed by FNS. As part of Oregon?s federally approved simplified assumptions, the state plan allows the school points of contact to update their predominate learning model for each month of the 2020-2021 school year, which may be different than the Ready Schools, Safe Learners (RSSL) Weekly Status Report. An email communication was shared with all identified school points of contact on June 28, 2021. This email requested that school points of contact update their schools predominate learning mode into the Oregon School Meals Benefit (OSMB) system used by the Oregon Department of Human Services to issue P-EBT benefits no later than July 13, 2021. Information reported through the RSSL weekly status report was used to determine the predominate learning mode only in the event that the school point of contract did not update a learning mode manually within OSMB prior to July 13, 2021. On May 9, 2023, the P-EBT policy team confirmed school operating status during the selected months with 5 schools for SOS audit. Email responses from the schools are summarized below: ?See Corrective Action Plan for Table? At the recommendation of the auditors the Department has reached out to FNS Child Nutrition Program about the finding and we are waiting for a response. Anticipated completion date: N/A Contact: Heather Miles, SNAP, CSFP, and TEFAP Program Manager

Finding Number: 2022-005 Finding Title: Allowable Costs/Cost Principles and Reporting Program: Medical Assistance Program 93.778 Name of Contact Person Responsible for Corrective Action: Nicole Hegge - Sr. Manager, Accounting - Finance and Central Services Corrective Action Planned: In order to appropriately report the revenue offset that may impact federal programs, we have updated our quarterly process ensuring that any federal revenue offsets are included in the appropriate fund and report. In some instances, this may still require the County to file amendments to federal reports; however, they will be completed no later than eight weeks following the end of the quarter. Anticipated Completion Date: December 31, 2023

Finding #2022-004 ? Services billed that were not identified in the student?s IEP. Medical Assistance Program (Medicaid; Title XIX) (93.778) Federal Grantor ? U.S. Department of Health and Human Services Pass-through Entity ? Wisconsin Department of Health Services Condition: Covered school based services billed to Medicaid must be identified within the child?s IEP. A child?s billing sampled during the audit included nursing and transportation services. These services were not listed in the child?s IEP. Questioned costs: $654.12 Criteria: Students with covered services billed to Medicaid must have the services listed within the child?s IEP. Effect: Potentially unallowable billings arise when services are not included within the IEP of students. Cause: Nursing and transportation services were omitted from the child?s IEP, yet were billed to Medicaid. The District did not review the child?s IEP against services billed to ensure compliance. Recommendation: The District should only bill Medicaid for covered services included in IEP. The IEP should be reviewed prior to services being provided and billed to Medicaid. Also, the District should be reviewing the files on a regular basis to ensure compliance with this requirement. Response: We will review the District?s requirements and procedures for billing Medicaid and make any necessary changes to ensure completeness and accuracy. Contact Person: Tracy Case Anticipated Completion: December 31, 2023

Finding #2022-003 ? Parental consent to bill Medicaid not present in student file Medical Assistance Program (Medicaid; Title XIX) (93.778) Federal Grantor ? U.S. Department of Health and Human Services Pass-through Entity ? Wisconsin Department of Health Services Condition: The Medicaid program requires parental consent to bill Medicaid for any billable services provided and to keep these consent forms on file at the District. A student file sampled during the audit did not have a signed parental consent form. Questioned costs: $334.66 Criteria: A signed parental consent form (M-5) must be received prior to billing Wisconsin Medicaid for school based services. All students with services billed to Medicaid should have the consent form (M-5) on file. Effect: Not having a signed form (M-5) would lead to potentially unallowable billings. Cause: The District either did not obtain parental consent to bill Medicaid or did not properly handle the consent form after it was received. The District did not review the student file to ensure compliance. Recommendation: The District should obtain parental consent to bill Medicaid for every student receiving and being billed for these services. The consent form should be obtained and filed prior to any billings being made to Medicaid. Also, the District should be reviewing the files on a regular basis to ensure compliance with this requirement. Response: We will review the District?s requirements and procedures for obtaining parental consent and make any necessary changes to ensure completeness and accuracy. Contact Person: Tracy Case Anticipated Completion: December 31, 2023

The District will create better meal claim tracking procedures and create a summary spreadsheet to more easily report meal claims on a monthly basis.

Finding ref number: 2022-001 Finding caption: The District did not have adequate internal controls for ensuring compli-ance with federal requirements for allowable activities and costs. Name, address, and telephone of District contact person: Katrin Williams, Business Manager PO Box 118 Adna, WA 98522 (360)748-0362 Corrective action the auditee plans to take in response to the finding: The District concurs and will review the current and future year?s indirect cost rates for ESSER re-imbursements. Anticipated date to complete the corrective action: Completed

Finding ref number: 2022-002 Finding caption: The District did not have adequate internal controls for ensuring compli-ance with allowable activities and costs and restricted purpose require-ments. Name, address, and telephone of District contact person: Katrin Williams, Business Manager PO Box 118 Adna, WA 98522 (360)748-0362 Corrective action the auditee plans to take in response to the finding: 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 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 Connec-tivity Fund Common Misconceptions?, ?Misconception #2: If schools have returned to in-class in-struction 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 eligi-ble 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 met-rics 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 pur-chased 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: Completed

Finding Summary: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Matching, Level of Effort and Earmarking, and Audit Requirements for Federal Awards (Uniform Guidance) provides that amounts for matching but be verifiable, allowed under general cost principles, determined in accordance with generally accepted accounting principles and reported on the grant reports. Amounts for match was not properly reported on the financial report, in addition supporting documentation was not retained for all match and certain match recorded in accordance with generally accepted accounting principles. Responsible Individuals: Erik Schoen, CEO; Amber Stanley, Business Manager Corrective Action Plan: We are in agreement with this finding. As part of our CAP, we have replaced our former business manager with a new employee, who is receives regular support and guidance from an independent accounting professional with decades of experience. Together, they are forming a point-by-point strategic approach so that this finding is corrected in the current FY. As of 11/1/22, we had already started changing the inkind contributions workbook to reflect a more detailed representation of what contribution was being applied to what grantor. This has resulted in an easier to understand form. We have also begun to keep more accurate records both digitally and in paper form. We will continue to improve on this process by completing match on a per quarter basis while instituting a better process. Anticipated Completion Date: June 30, 2023

RE: Finding 2022-002, Maintain Employees' Time and Effort Records To whom it may concern: Time and Effort Records have been maintained as of the start of the 2022-2023 fiscal year. The District is now in compliance and will be going forward. Tom Lafleur Director of Finance and Operations

The District Federal Programs Coordinator will: 1. Attend professional development activities provided by our Federal Programs Consultant, Dr. Cheryl Sattler with Ethica, LLC. These activities include monthly technical calls, annual Title 1 Bootcamp, and Spring Coordinator's Workshop. 2. Seek help and advice from Dr. Sattler as needed. 3. Attend FASFEPA Conferences, twice per year, to learn about updates and changes to federal laws regarding Title 1 funds. 4. Review the budget entered into the district's accounting system to ensure there are no discrepancies.

Audit Finding Reference: 2022-003 Improve Controls and Documentation over Payroll Process Planned Corrective Action: The Portland Public School District's payroll operations have been under strain since its conversion to a new software system (Munis) in January 2019. Certain modules and functionalities were not set up completely or correctly prior to launch, which necessitated workarounds, time-consuming manual processing, and error correction. These challenges were compounded by staff turnover, staffing shortages, and the heightened pressures across the district caused by the pandemic. As a result certain systems, processes, procedures, and documentation protocols have weakened over this time. PPS is aware of this and has been working toward a permanent solution to the root cause of the payroll challenges. In collaboration with outside consultants, PPS has entered into an agreement to transition to ADP as a third-party payroll provider for the district, with expected implementation in fall 2023. PPS has retained a project manager for the transition, whose focus will not only be the technical software transition but also ensuring that sound policies, procedures, and controls are in place alongside system capabilities that meet the needs of the district. Additionally, PPS intends to invest in additional HR staff in order to implement new workflow that ensures appropriate segregation of duties, review, and documentation of employee pay information. Name of Contact Person: Terry Young Ed.D Executive Director of Operations Portland Public Schools 353 Cumberland Avenue Portland, ME 04101 Direct: (207) 842-5333 Anticipated Completion Date: 11/1/2023