Corrective Action Plans

Planned Corrective Actions: We will ask vendors to provide invoices in a timely manner; review invoices more carefully; inform Accounting Dept of vendor activity in December for which an invoice has not been received during the month of December.

Single Audit Finding 2022-003 Material Weakness and Nonmaterial Noncompliance ? Allowable Costs and Eligibility See Corrective Action Plan for chart / table.

Assistance Listings number: 17.258 WIOA Adult Program; Assistance Listings number: 17.259 WIOA Youth Activities; and Assistance Listings number: 17.258 WIOA Dislocated Worker Formula Grants Contact Person(s): Jeremy Flowers, WIOA Executive Director and Lisa Grannis, WIOA Board Clerk and Compliance Specialist Anticipated completion date: June 30, 2023 Concur. To help ensure the County meets the WIOA Cluster?s earmarking requirement to spend no less than 20 percent of WIOA Youth Activities funds allocated to the County to provide in-school and out-of-school youth with paid and unpaid work experiences (WEX), the County has revised its process for tracking work experience expenditures. The County will utilize the revised process and provide technical assistance to the sub-recipient, Chicanos Por La Causa (CPLC) to implement procedures that will lead to an increase in Youth enrollments and placement into WEX to ensure at least 20 percent of the WIOA Youth Activities funds allocated to the County are used to provide in-school and out-of-school youth with paid and unpaid WEX. County staff is currently working with CPLC staff to implement a different approach to attaining the WEX requirements. The recommended solutions include improved tracking and monitoring of the WIOA Youth WEX activities to include both paid and unpaid work experiences, increasing all youth outreach, partnering with other local youth programs, and enrolling youth with barriers pursuant to current policy. The County will be tracking Youth progress and will be revising strategies as needed. The County?s goal is to see a significant increase in Youth WEX program activities by the end of fiscal year 22-23.

Assistance Listings number: 17.258 WIOA Adult Program; Assistance Listings number: 17.259 WIOA Youth Activities; and Assistance Listings number: 17.258 WIOA Dislocated Worker Formula Grants Contact Person(s): Jeremy Flowers, WIOA Executive Director and Lisa Grannis, WIOA Board Clerk and Compliance Specialist Anticipated completion date: June 30, 2023 Concur. The nonprofit organization was created in part to serve as the administrative arm of the Local Board and to provide a location for a resource center where WIOA services would be provided. The County did not distinguish fiscal responsibilities between parties and therefore assumed that certain expenditures of the Local Board and nonprofit would be allowable and could be paid directly by the County. The County considered the expenditures of the nonprofit to be program related, even though they were not directly incurred by the County. The County will improve its accounts payable policies and procedures for processing invoices using established process within the Finance Department, including ensuring all invoices are addressed to the County prior to payment. In addition, the County will establish clear contractual agreements that establish fiscal responsibilities that follow the program?s requirements. Finally, the County will coordinate with the pass-through grantor for the repayment of the unallowable costs identified in the finding.

Management concurs that the subscription period was from June 28, 2022 through June 27, 2023 and the benefits of the subscription service purchased under the award were received outside the grant?s period of performance. However, benefits were in support of Year 3 of the Coronavirus Recovery Project, which was granted by MBDA in January 2022 to start July 1, 2022. In order to have coverage from the start of the project, the subscription was purchased to ensure no break in service during to MBE during Year 3. In the future, as a part of our grant financial process, we will seek written approval from our program manager. Name of the contact person responsible for corrective action: Sharon Pinder, President, (301)593-5860. Planned completion date for corrective action plan: December 31, 2023.

CORRECTIVE ACTON PLAN December 31, 2022 Finding No. 2022-001; Name of Responsible Official James Haislip, VP System Office Finance; Management?s Response to Findings - Management agrees with the finding. The issue results from BayCare tracking contract labor time in its timekeeping system and then submitting the hours worked to the contract labor firms to pay the individual. BayCare?s timekeeping system also included hourly rates for each contracted position. Due to fluctuating market conditions, pay rates for contract labor were changing frequently but not updated timely in our timekeeping system. Allowable costs submitted for Provider Relief Funds were based on information from our timekeeping system. Description of Corrective Action - Allowable cost submitted for Provider Relief Funds were based on information from our timekeeping system. The finding was first identified in Reporting Period 2 (RP2) and communicated to management after RP3 was prepared. RP3 included PRF expenses through Q2 of 2022. RP4 included PRF expenses through Q4 2022. Management implemented the prior year Corrective Action Plan (CAP) and as a result the error rate on contract labor incurred in Q3 of 2022 decreased compared to prior year with minimal errors identified. There were no errors identified for Q4 2022. Anticipated Completion Date - CAP was completed in RP5.

Finding 2022-002: Allowable Costs/Cost Principles - Federally Approved Indirect Cost Rate (Material Weakness) Name of Auditee?s Contact Person Responsible for Corrective Action: Gary Mendell Corrective Action Planned: Management is in the process of amending contracts in place and will elect to utilize the 10% de minimis indirect cost rate, or a lesser rate based upon the contract terms for future periods. In addition, management is amending indirect costs billed to current contracts to reduce the annual indirect costs charged to the contracts to ensure that the indirect costs do not exceed the 10% de minimis indirect cost rate on an annual basis. Anticipated completion date: December 2023

Corrective Action Plan: Finding 2022-001: Allowable Costs/Cost Principles - Time and Effort Reporting (Material Weakness) Name of Auditee?s Contact Person Responsible for Corrective Action: Gary Mendell Corrective Action Planned: Management has implemented additional time tracking on a weekly basis for all employees who work on federal contracts. Employees must track and allocate their time based on actual time spent. The timesheets are then reviewed and approved by the program director or a direct supervisor. Anticipated completion date: October 2023

Re: Government Auditing Standards Findings - Year Ending June 30, 2022 - This construction project was posted o the Bid4Michigan site. The bid posting is very specific outlining the components each bidder must follow, including prevailing wages. Unfortunately, the prevailing wage requirement was not checked as a requirement for this particular job. Requirements normally specific to public school districts carries forward to the specifications issued by our architects, which did not happen this time. We will not miss this requirement in the future, as it is very standard. Completion date: immediate

2022-001 Material Weakness in Internal Control Over Compliance and Compliance Finding Recommendation: We recommend the District reviews its procurement policies and procedures to ensure that the proper procurement methods as prescribed in the Uniform Guidance are utilized for all transactions which utilize federal funds. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The District will work to revise its procedures as necessary to ensure that all procurements which are charged to federal programs are fully documented, including support for noncompetitive proposals. Name(s) of the contact person(s) responsible for corrective action: Christopher Onyango-Robshaw, Coordinator of Finance. Planned completion date for corrective action plan: June 30, 2023

Comments on Findings and Recommendations. Finding 2022-001 Valor Christian College concurs with the finding and recommendations in the finding. Actions Taken or Planned: Finding 2022-001 - The Valor Christian College Finance Department and the Valor Christian College CFO will increase controls over the process to ensure that no recruitment advertising expenses are attributed to CARES ACT funds. The amount of originally attributed to advertising expenses has been reallocated to allowable items/expenses.

2022 ?1 Restricted Fund Usage Questioned Cost: $9,000 Condition: Management failed to utilize restricted funds for the purpose in which they were designated. Criteria: The management company expended $9,000 of funds restricted for use in furnishing tenant common areas and the management office, on daily operating expenses. Cause: Site managers did not expend funds for their intended use. Effect: Restricted funds were not spent appropriately and therefore, should be returned to donor. Recommendation: I recommend management comply with all donor restrictions. Management Response: - Initially the funds were not restricted. The funds were earned by the property because the property was used as a set for a movie. - The money did not come from the Board. The money was generated by the property and is considered to be other income. Given the financial needs of the property there was no way that funds could be set aside for the operations. The Debt owed to the Management Company as of 12/31/2022 was $59,401. Given the severe cash flow issues at the property all resources had to be directed to resolve the financial situation of Boyd Manor. The funds were used for the benefit of Boyd Manor. The management company was also owed $59,401.

Finding ref number: 2022-002 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: Kris Hagel (253) 530-3701 14015 62nd Avenue, Gig Harbor WA 98332 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 our inventory control system and reports which showed Kindergarten devices being checked out to the teachers instead of individual students. This was needed to ensure an additional level of accountability for devices for some of our youngest learners. In addition we did piggyback on a competitively bid contract to receive the most devices for the least cost. We are not in agreement that utilizing the contract for the devices did not meet the minimum federal requirements for procurement. The standard of documentation required by SAO to satisfy ?unmet? need 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 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 in-class 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: August 31, 2023

Management intends to maintain an adequate cash balance and use grant funds towards their intended purpose

2022-003 ? Internal Controls over Compliance ? (Significant Deficiency) Agency?s Response: The District?s payroll office will work more closely with Federal Programs to ensure proper compliance when additional compensation is requested. Amounts will be verified prior to processing payment and ensure amounts fall within compliance. Person responsible for corrective action: Jade Kittrell, Payroll Specialist, Valeryia Gauthier, Federal Programs Director. Timeframe: Immediate as of November 2022.

FINDING: Title 29, U.S. Code of Federal Regulations, Part 5, Sub-Part A Davis Bacon and Related Acts Provisions and Procedures (the "Davis-Bacon Act") requires that any construction contract in excess of $2,000 that is funded wholly or in part by federal funds include prevailing wage rate clauses. The laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for locality of project (prevailing wage rates) by the Department of Labor (DOL) and the contractor or subcontractor must submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls.) During fiscal year 2022, the Board entered into a construction project contract totaling $689,002.89 that did not include prevailing wage rate clauses. As of September 30, 2022, the Board had expended $431,105.95 of COVID-19 Education Stabilization Funds (Elementary and Secondary School Emergency Relief) on the project. The Board did not have controls in place to ensure the Davis-Bacon Act wage rate requirements were included in construction contracts, therefore, the construction project contract was awarded during the fiscal year that did not include prevailing wage rate clauses not did the contractors submit weekly certified payrolls to the Board. As a result, the Board is not in compliance with the Davis-Bacon Act as it pertains to wage rate requirements. RECOMMENDATION: The Board should comply with Title 29, U.S. Code of Federal Regulations, Part 5, Sub-Part A Davis Bacon and Related Acts Provisions and Procedures (the "Davis-Bacon Act") when using COVID-19 Education Stabilization Funds (ESSER) to fund construction contracts in excess of $2,000. RESPONSE/VIEWS: We agree to the finding. CORRECTIVE ACTION PLANNED: All contracts will be reviewed more carefully by the superintendent and CSFO. ANTICIPATED COMPLETION DATE: These contracts are in the process of being updated. CONTACT PERSON: Morgan Blankenship (morgansmothers@wcsclass.com) (205-489-5018).

FINDING 2022-003 Finding Subject: Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance Summary of Finding: Noncompliance regarding the above compliance requirements Contact Person Responsible for Corrective Action: Koren Gray Contact Phone Number: 765-436-2205 Views of Responsible Official: No corrective action is required. The Town?s use of funds was appropriate under the law effective at the time of their actions. While the FAQs and fact sheets seem fairly clear that ARPA funds cannot be used to pay for any debt, including, specifically, BANs and tax anticipation warrants, the language in the actual Interim Final Rule seems to allow ARPA funds to be used for new debt. The Interim Final Rule, issued in May 2021, states: ?Contributions to rainy day funds and similar financial reserves would not address these needs or respond to the COVID?19 public health emergency but would rather constitute savings for future spending needs. Similarly, this eligible use category would not include payment of interest or principal INDIANA STATE BOARD OF ACCOUNTS 27 Per Uniform Guidance: 2 CFR ? 200.511(a) ? ?The auditee is responsible for follow-up and corrective action on all audit findings. . .The auditee must also prepare a corrective action plan for current year audit findings. . . The corrective action plan and summary schedule of prior audit findings must include findings relating to the financial statements which are required to be reported in accordance with GAGAS. ? 2 CFR ? 200.511(c) ? ?At the completion of the audit, the auditee must prepare, in a document separate from the auditor's findings described in ? 200.516, a corrective action plan to address each audit finding included in the current year auditor's reports. The corrective action plan must provide the name(s) of the contact person(s) responsible for corrective action, the corrective action planned, and the anticipated completion date. If the auditee does not agree with the audit findings or believes corrective action is not required, then the corrective action plan must include an explanation and specific reasons.? on outstanding debt instruments, including, for example, short-term revenue or tax anticipation notes, or other debt service costs. As discussed below, payments from the Fiscal Recovery Funds are intended to be used prospectively and the interim final rule precludes use of these funds to cover the costs of debt incurred prior to March 3, 2021. Fees or issuance costs associated with the issuance of new debt would also not be covered using payments from the Fiscal Recovery Funds because such costs would not themselves have been incurred to address the needs of pandemic response or its negative economic impacts.? The Final Rule, issued in 2022, summarizes the Interim Final Rule, including that the Interim Final Rule did not allow for ?payment of interest or principal on outstanding debt instruments; ? [or] fees or issuance costs associated with the issuance of new debt?? The issue date of these bond anticipation notes is the same as the actual date of delivery, which is after March 3, 2021. Under all federal laws, debt does not exist until it is actually issued ? that is to say, debt does not exist at the time of approval of the PER, the time of adoption of the authorizing documents, or at any point before it is actually issued. The Thorntown BANs were issued after March 3, 2021, making them ?new debt,? not ?outstanding debt? for the purposes of the Rules. The Interim Rule does not allow for debt service payments on outstanding debt as it is not a prospective use of the funds. It does, however, seem to allow for debt service payments on ?new debt,? just not for issuance costs, which were covered by the SRF. The Final Rule also includes this statement: ?Specifically, use of funds for debt service, to replenish financial reserves, or to satisfy an obligation arising from a judicial settlement or judgment were ineligible uses of funds under the eligible use categories for public health and negative economic impacts and revenue loss. These restrictions apply to all recipients. Recipients should note that restrictions on use of funds for debt service, to replenish financial reserves, or to satisfy an obligation arising from a judicial settlement or judgment apply to all eligible use categories, not just the eligible use categories in which they were discussed in the interim final rule.? The Final Rule clarifies several times that all debt service, including short term debt issued after the beginning of the pandemic in response to the lack of revenue, was intended to be an ineligible use. However, because the Final Rule seems to make it clear that the Interim Final Rule was unclear on this point, the Town can make a strong argument based on the points above that this BAN was an eligible use under their interpretation of the Interim Final Rule and should be allowed under the Treasury?s Statement Regarding Compliance with the Coronavirus State and Local Fiscal Recovery Funds Interim Final Rule and Final Rule. Description of Corrective Action Plan: Not Applicable. However, as final guidance and the final rule are now available, the Town would not use ARPA funds to pay for any new debts moving forward. INDIANA STATE BOARD OF ACCOUNTS 28 Per Uniform Guidance: 2 CFR ? 200.511(a) ? ?The auditee is responsible for follow-up and corrective action on all audit findings. . .The auditee must also prepare a corrective action plan for current year audit findings. . . The corrective action plan and summary schedule of prior audit findings must include findings relating to the financial statements which are required to be reported in accordance with GAGAS. ? 2 CFR ? 200.511(c) ? ?At the completion of the audit, the auditee must prepare, in a document separate from the auditor's findings described in ? 200.516, a corrective action plan to address each audit finding included in the current year auditor's reports. The corrective action plan must provide the name(s) of the contact person(s) responsible for corrective action, the corrective action planned, and the anticipated completion date. If the auditee does not agree with the audit findings or believes corrective action is not required, then the corrective action plan must include an explanation and specific reasons.? Anticipated Completion Date: Not Applicable.

Corrective Action Plan - FEDERAL AWARD FINDINGS AND QUESTIONED COSTS FA 2022-001 Improve Controls over Federal Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principles 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) S45U210012 (Year: 2021) Questioned Costs: $26,460 Repeat of Prior Year Finding: None Description: A review of expenditures charged to the Emergency Connectivity Fund and Elementary and Secondary School Emergency Relief Fund programs revealed that the School District?s internal control procedures were not operating appropriately to ensure that expenditures were allowable. Corrective Action Plan: The District will contact each Federal Program to determine the appropriate action to take to ensure the funds are appropriately allocated. Moving forward, Finance will review all reimbursements as well as work with other Departments to ensure that expenses are being allocated to the correct program. Estimated Completion Date: April 28, 2023 Contact Person: Samantha Jenkins Telephone: 478-456-3362 Email: Samantha.jenkins@baldwin.k12.ga.us

FINDING 2022-007 Contact Person Responsible for Corrective Action: Kasey Clark Contact Phone Number: 574-772-1604 Views of Responsible Official: We concur with the findings Description of Corrective Action Plan: The time and effort for the stipends was not documented. The time and effort for all stipends will be documented for any stipend. All stipends will be reviewed and approved by the Treasurer. Anticipated Completion Date: March 2023

FINDING 2022-004 Contact Person Responsible for Corrective Action: Kasey Clark Contact Phone Number: 574-772-1604 Views of Responsible Official: We concur with the findings. Description of Corrective Action Plan: The bus rates will have in every weekly pay attached the rates for each route and submitted with their timecards. The bus rates will be prepared by the Transportation Director and will be reviewed by the Deputy Treasurer and then the Treasurer. Anticipated Completion Date: March 2023

Recommendation: The Organization should perform its own calculation of surplus cash and remit required deposits to the residual receipts account within 60 days after year-end as required by HUD. Views of Responsible Officials and Planned Corrective Actions: Corrected. The Organization remitted the required amount of surplus cash to the residual receipts account. In the future, management will try to remit deposits in a timely manner, within 60 days after yearend.

Recommendation: Management personnel should monitor cash flows on a monthly basis in line with budget and monthly required deposits in order to appropriately meet the current and future cash flow needs of the property. Views of Responsible Officials and Planned Corrective Actions: Management acknowledges the lack of cash flow management. The onsite and regional manager plan to work together to perform better monthly review of expenses compared to budget and work to fund the delinquent and current deposits as soon as cash is available

Department: Administrative and Financial Services Title: Internal control over expenditure processing needs improvement Questioned Costs: Known: 59,759 Likely: Undeterminable Status: Corrective action complete Corrective Action: The Department will reverse the unallowable charge to the HSGP grant. The Department will provide additional training for data entry and invoice approval processes. Completion Date: March 1, 2023 and March 31, 2023 respectively Agency Contact: Marilyn Leimbach, Director, Service and Employment Service Center, DFPS, DAFS, 207-248-2556

Item 2022-001 ? Eligibility Contact person: Jeanne Garrett Management?s Response ? Management has provided an additional group training for County Coordinators, Assistants, and Contractors for determining eligibility criteria and calculating the awards for the LW-010-CONS grant on June 30, 2023. County Coordinators and Assistants will take more time and verify that the preset awards are correct prior to sending them to the central office for processing. Contractors will verify award accuracy when received from the counties and initial these awards. The Service Manager will also double check applications during the batching process.

Department: Health and Human Services Title: Internal control over cost of care assessments needs improvement Questioned Costs: Undeterminable Status: Management?s opinion is that corrective action is not required Corrective Action: The Department agrees with the two exceptions found by the Office of the State Auditor. However, we believe that the Department has reasonable assurance with the controls in place that results in a 97% compliance rate with the COC calculations, which is a 2% increase from last year. In the prior year's finding the Department committed to continuing to achieve a 95% compliance rate and CMS agreed with the Department and closed the prior finding. No corrective action is necessary as a result of an error rate of only 3%. The Department will continue to actively manage and monitor the Cost of Care system in compliance with federal regulations. Completion Date: N/A Agency Contact: Anthony Pelotte, Director, Office for Family Independence, DHHS, 207-624-4104