Corrective Action Plans

Assistance Listings number and program name: 21.027 COVID-19 Corona Virus State and Local Fiscal Recovery Fund Contact: Maryn Belling Anticipated completion date: June 30, 2024 Corrective Action Plan: The County will develop, implement, and maintain procedures requiring both the performance & documentation of independent review and approval of all federal program reports prior to submitting them to the federal agency to ensure the reports are accurate, agree to County records, and contain only allowable expenditures. Program expenditures will be reconciled to the County’s accounting records. The County’s previous corrective action plan stated “Errors identified will be reported to the federal agency in adjusted or resubmitted reports” however the Federal Reporting interface lacks capacity for resubmitted reports. The adjusted reports resulted in the understatement and overstatement amounts noted in Federal Award Finding 2023-101. Departmental training will be provided for staff responsible for preparing and reviewing reports for both data management, compliance with Uniform Guidance, 2 Code of Federal Regulations (CFR) §200.510, and adherence to County’s policies and procedures.

The district Information Technology Services unit is currently working with Ellucian to configure and implement the Time and Effort reporting module within the BANNER timekeeping system. This will allow departments to monitor time and effort activity and ensure that allowable costs are tracked and charged to the appropriate programs and services. This should be completed by June 30, 2024.

Federal Agency Name: U.S. Department of Transportation, Federal Highway Administration Pass‐Through Entity: Nebraska Department of Transportation Assistance Listing Number: 20.205 Program Name: Highway Planning and Construction Finding Summary MAPA is the pass-through entity for several subrecipients. MAPA does not appear to have a formal policy to evaluate each subrecipient’s risk of noncompliance for appropriate subrecipient monitoring. Further, MAPA does not have a formal policy to monitor the activities of the subrecipients to the extent deemed necessary by the federal government, including the verification that subrecipients are audited when they reach Uniform Guidance spending levels and evaluation of those audits. However, the current procedures require a review of the subrecipients’ invoices, including all detailed costs by an appropriate individual at MAPA prior to payment. This process helps reduce risk of inappropriate funding to subrecipients. Corrective Action Plan MAPA will establish written internal procedures and complete a compliance risk determination for every federal subaward to evaluate subrecipient risk of noncompliance in accordance with the guidance provided in 2 CFR 200.332: Requirements for pass-through entities. In particular with regard to this finding, MAPA will verify whether every subrecipient is audited as required by the conditions cited in 2 CFR 200.332(f), and MAPA will evaluate such audits for compliance risk as part of its internal procedures. Responsible Individual Matthew Eash, Director of Finance Anticipated Completion Date June 30, 2024

Reference Number: 2023-001 Audit Finding: Other Compliance Corrective Action: The Public Utilities Department has re-evaluated the internal procedures and practices of maintaining compliance documentation. Third party vendors will no longer serve as an archive for notification documentation. All notification receipts and various forms of verification will be saved in house, on the City of San Diego’s network. This corrective action was set in place as of March 28, 2023, based on findings from the water arrearages program audit. The sewer arrearages program was also completed prior to the original corrective action plan date of March 28, 2023. This was the same finding for both the water and sewer arrearage program audits. Moving forward with this action on a continual basis, once email notifications are sent to customers using an external service provider, notification confirmations will be immediately archived at the City of San Diego. The acknowledgement must state that the credited amount is being provided through funding from the State Water Resources Control Board using federal American Rescue Plan Act (ARPA) funds. This affords the City full control and oversight of the verification process for all future noticing. All available notification verifications from the third-party vendor will be downloaded and saved to the City network for future inquiries. Furthermore, internal controls will be enhanced to ensure notification verification compliance. Upon notification to customers, the Billing and Financial Analytics Program Coordinator will oversee the immediate archiving of all confirmations of emails sent to customers using an external service provider. Once complete, the Billing and Financial Analytics Program Coordinator will notify the Program Manager, who will in turn, perform a secondary review of all notifications against the verification documentation to ensure accuracy. At this point, a third level of approval will be added, as the Public Utilities Customer Support Deputy Director will provide a final level review. Once complete, these documents will be saved for a minimum of five years, per the City of San Diego’s retention policy. Implementation Date: 03/28/2023 Contact: Tracy Morales Interim Deputy Director

Views of Responsible Officials and Planned Corrective Actions: The Organization made every effort to register subawards in excess of $30,000 with the Federal Funding Accountability and Transparency Act Subaward Reporting System. However, due to the change from DUNS to UEI by the federal government and the requirement to use an organization’s UEI to find sub-awardees in FSRS.gov, the Organization was not able to register the subawards meeting the requirements. The Organization is still working with our sub-awardees to establish and collect UEI’s for each so this reporting can be completed this year.

The College agrees with this finding. Management is in the process of remediating this policy omission and will implement and document the periodic inventory of customer data, including where it’s collected, stored or transmitted. The College expects to have this completed by June 30, 2024. Going forward the Information Technology department will periodically review the inventory of customer data and update as necessary.

Condition: We identified one instance where a student’s program enrollment effective date did not match the institution’s records. Recommendation: We recommend that the College enhance its policies and procedures regarding enrollment reporting including additional monitoring over the third-party service provider to ensure that reporting is completed accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: The College will review enrollment reporting procedures to determine where additional review of data and monitoring of third-party servicer data can be implemented to ensure accurate reporting. Name(s) of the contract person(s) responsible for corrective action: Chris Peterson – Director of Student Financial Aid, Stacy Sharp – Director of Registration and Records, and Laura Beyers – Director of Registration and Records Planned completion date for corrective action plan: June 30, 2024

We recommend that the City develop and maintain policies and procedures regarding loan monitoring and ensure that all documentation of loan monitoring be maintained on an annual basis. Management's Response: The City concurs with the finding. Responsible Individual: Marti Brown, City Manager. Corrective Action Plan: Given the strain on resource available among City staff, the City is working to hire an outside consulting firm to assure a consisten loan monitoring program is in place. Anticipated Completion Date: June 2024

We recommend that the City develop procedures to ensure that the CDBG Annual Performance Report is filed by the required due date. Management's Response: The City concurs with the finding. Responsible Individual: Marti Brown, City Manager. Corrective Action Plan: The City has recently brought on staff to complete the periodic reports required by HCD. It is the intent of the City to have this finding resolved by the end of FY 2023-24. Anticipated Completion Date: June 2024.

Recommendation: We recommend that the University strengthen its internal controls over monitoring the academic engagement for students that are enrolled in distance education courses at the University. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action in Response to Finding: The University had already identified this weakness prior to the Single Audit. To address this weakness, Portland State University has implemented a robust Initiation of Attendance protocol that is required of every instructor. Faculty were informed of: 1) Federal regulations related to initiation of attendance. 2) The standards used for documenting academic engagement in an online environment. 3) The method by which the instructor positively indicates that an online student has academically engaged in the course. The University has provided written policies on its website and engaged in a vigorous communication plan with both faculty and students. Compliance with the new policy is monitored through weekly reporting, and instructors who have not documented the initiation of attendance are referred to their dean, chair or department head. Prior to any reduction in Title IV aid, students are notified of any missing documentation and encouraged to speak with their instructors immediately. Last, reconciliation reports are monitored by the financial aid office for discrepancies and any conflicting information is resolved by contacting the instructor. Name of the contact person responsible for corrective action: Elijah Herr, Director of Student Financial Aid, Cindy Baccar, Associate Vice Provost & University Registrar and Karenna Wait, Director of Enterprise Applications. Planned completion date for corrective action plan: September 2023

Individual Responsible for Corrective Action: Everett Jeter, Director of Compliance Corrective Action: The error falls into the category of human oversight rather than fundamental misunderstanding of the regulation or timing of processes. A transfer monitoring record was originated for this student approximately six weeks prior to the spring 2023 semester. We did not receive a transfer monitoring response from NSLDS and therefore student was awarded aid as a non-transfer student. We recognized the oversight and the student’s award amount was updated to maintain appropriate annual limit during the spring 2023 semester. We will develop and implement additional controls to effectively capture transfer students for monitoring when a response from NSLDS is not received to ensure award accuracy. Anticipated Completion Date: August 15, 2024

Beginning immediately the District will develop internal controls to meet the requirements of the Davis-Bacon Act that ensure any time federal awards are used on construction that compliance with contracts, including inserting the prevailing wage clauses and ensuring that federal wage rates and fringes are met by an effective monitoring process which includes collecting and reviewing weekly certified payroll reports from the contractor or subcontractor. The District will also ensure that all items are posted at the work site to ensure compliance.

Recommendation: The Authority should designate an individual to review tenant files to determine if a rent reasonableness has been performed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The HACMB currently has a Quality Control Coordinator who is designated to review samples of tenant files to ensure compliance. The HACMB has reviewed its Quality Control process for areas of improvement; (1) The Quality Control Coordinator will increase the number of file samples that are undergoing the Quality Control process. (2) The Quality Control Coordinator will hold bimonthly reviews with the specialists to ensure the same standard processes are being followed and to focus on retaining the supporting document in the files. The Section 8 staff will be notified of the appropriate action to take regarding any finding in the files. Name(s) of the contact person(s) responsible for corrective action: Suzie Millien Director of Section 8-HCV Planned completion date for corrective action plan: 3/31/2024.

Recommendation: The Authority should designate an individual to review tenant files to ensure that the income reported on the HUD-50058 is supported with proper calculations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The HACMB currently has a Quality Control Coordinator who is designated to review samples of tenant files to ensure compliance. The HACMB has reviewed its Quality Control process for areas of improvement; (1) The Quality Control Coordinator will increase the number of file samples that are undergoing the Quality Control process. (2) The Quality Control Coordinator will hold bimonthly reviews with the specialists to ensure the same standard processes are being followed and to focus on each targeted area that needs assistance the most. The Section 8 staff will be notified of the appropriate action to take regarding any finding in the files. Name(s) of the contact person(s) responsible for corrective action: Suzie Millien, Director of Section 8-HCV. Planned completion date for corrective action plan: 3/31/2024.

The party that was making sure of signatures and signatures of changes ended up in a backlog and lost time cards. If time cards are sent back for signatures a copy of the original will be kept until the signed ones come back, and follow up will be made on a timely basis.

With the implementation of the new software, Yardi Voyager 7s, a plan is in place to develop Standard Operating Procedures that are consistent with the City of Pittsburg’s Standard Operating Procedures. The Housing Authority Staff is updating the Administrative Plan to address operational procedures and the Finance Department Staff are developing procedures for internal control and transactional review. The Housing Authority has and will continue to provide resources for training and education. The budget for Fiscal Year 2023-2024 includes an increased allocation for Staff Training. Source documents have been collected and data is under review. We have engaged our former Accountant II to assist with corrections for December 2021-June 2022. The current Accountant II is finalizing an open ticket with Yardi to correct errors to the software-generated VMS report for July 2022-November 2022. The reporting errors have been identified as originating from an improper account set up during initial implementation. We have opened a ticket with the software vendor and the Yardi Development team is reviewing our findings.

Findings and Questioned Costs Related to Federal Awards Finding Number: 2023‐001 Program Name/Assistance Listing Title: Education Stabilization Fund Assistance Listing Number: 84.425 Contact Person: Arlene Laughter, Business Supervisor Anticipated Completion Date: December 31, 2024 Planned Corrective Action: The District has created an assistant manager position that will oversee all mandatory and required reports as requested by the Department of Education and Grants management. The District has also reached out to Jon Chase with Grants management to determine the required status of the report. In the future, the District will create a calendar to determine all timelines are met.

The Finance Department and Grants Management will train additional staff to mitigate the effect of staff turnover.

2023-002 Material Weakness: Gramm-Leach-Bliley Act (GLBA) (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268) Name of Contact Person Casey Reagan, Registrar, and Chris Summey, Head of our IT Department, are the Designated Employees in charge of overseeing the GLBA policy. Corrective Action Planned During the audit, it was noted that Tusculum did not fully address all of the requirements as described by 16 CFR 314.4. In addition, the application of the comprehensive information security program was not effectively administered by the University for the 2023 year. In fall 2023, IT, the Registrar, and the Director of Financial Aid met to discuss making sure that all of the new pieces of the GLBA policy were being implemented properly. In December of 2023, IT began the latest vulnerability scan and risk assessment to be in compliance with the risk assessment requirements of the GLBA Policy. This assessment should be completed by the end of spring 2024. The University is also working on updating its GLBA policies and procedures to align with the GLBA Policy. Anticipated Completion Date This process is currently ongoing and it is the University's goal to have ongoing GLBA policies updated and the risk assessment completed before the end of the 2023-2024 academic year.

Corrective Action Planned: Community Action Center of Northfield (CAC) is working with our food sourcing partners to investigate better accounting practices from their end to more accurately facilitate USDA food inventory before the food stuffs are delivered to CAC. Additionally, CAC will investigate cost-efficient models of physical inventory for in-kind donated (free) food. Name(s) of Contact Person(s) Responsible for Corrective Action: Scott Wopata, Executive Director, will be responsible for leading correct actions Anticipated Completion Date: While CAC is hopeful to receive more accurate inventory records from our food sources, this is outside of our control. Additionally, initial research into inventory management systems have proven extremely cost prohibitive as they relate to technology and/or labor, especially related to in-kind donated (free) food. We will pilot manual weekly inventory counts in the 2024/25 fiscal year with full corrective actions to reflect the outcome of those pilot studies.

Federal Agency Name: U.S. Department of Housing and Urban Development Program Name: Mortgage Insurance Rental Housing Federal Financial Assistance Listing: #14.134 Finding Summary: Testing performed by the auditors relating to testing of property, operations, and distributions detected one instance where a disbursement of Project funds was not supported with a detailed receipt. Responsible Individuals: Sue Lund, Administrator Corrective Action Plan: The Project will implement new form for invoice approval completion which includes ensuring proper documentation is obtained and retained before disbursement of funds occurs. Anticipated Completion Date: May 31, 2024

Finding: 2023-002 Reporting – Internal Control and Compliance over Reporting City’s Corrective Action Plan: As a direct outcome of the FY23 single audit findings, it was determined that we were not in compliance with filing the annual reports. Consequently, we did not file by the deadline of 12/31/2023 in anticipation of the SEFA for FY24. We acknowledge the non-compliance and are committed to rectifying the situation by submitting the annual reports by April 4, 2024. The Airport has addressed this finding by implementing stricter internal deadlines and enhancing oversight procedures. The Airport hired a dedicated Accountant in February 2024 to enhance the airport’s capacity to manage grant-related tasks effectively, ensuring timely submissions moving forward. Responsible Person: Executive Director of Aviation Expected Implementation: April 4, 2024 Finding: 2023-002 Reporting – Internal Control and Compliance over Reporting City’s Corrective Action Plan: The City has implemented new policies and procedures verifying timely submissions, including verification provided by the City’s Consultant to City Staff of the timely submissions. Responsible Person: Director of Housing & Community Development Expected Implementation: July 1, 2024

CORRECTIVE ACTION PLAN March 26, 2024 City of Roanoke, Virginia respectfully submits the following corrective action plan for the year ended June 30, 2023. Name and address of independent public accounting firm: Brown, Edwards & Company, L.L.P. 3906 Electric Road Roanoke, VA 24018 Audit period: June 30, 2023 The findings from the June 30, 2023 Schedule of Findings and Questioned Costs (the "Schedule") are discussed below. The findings are numbered consistently with the number assigned in the Schedule. FINDINGS AND QUESTIONED COSTS - MAJOR FEDERAL AWARD PROGRAM AUDIT 2023-001: Workforce Investment Opportunity Cluster - Assistance Listing #17.258117.259 / 17.277 / 17.278, Subrecipient Monitoring Condition: During our review of subrecipient monitoring, we noted that the City's monitoring was not being performed according to the formal written policy. While monitoring was performed and documented during the second half of fiscal year 2023, there was a lack of evidence of testing and suggestions to the subrecipient during the first half of fiscal year 2023. Criteria: According to 2CFR 200.33l(a) of the 0MB Compliance Supplement, the City should make subrecipients aware of award information. According to the City's Program Participant Monitoring Plan, the City is supposed to conduct subrecipient monitoring on a semi-annual basis which should include desk reviews of payroll, disbursements, and other financial items. Cause: Staff turnover, particularly for the role of grant accountant, caused these procedures to be overlooked. Management prioritized core operating activities with staffing vacancies in lieu of monitoring activities. Management asserts staff went onsite to review key documents, as documented by email activities, but did not document specific items subject to review. Effect: Noncompliance with federal grant requirements with regard to subrecipient monitoring as well as an increased risk of subrecip1ent misusing funds. Questioned Cost Amount: Not applicable. Perspective Information: One out of two awards Recommendation: We recommend performing subrecipient monitoring in accordance with the City's guidelines and following the procedures laid out in the Program Participant Monitoring Plan. Corrective Action: Management concurs with the recommendation and will ensure that follow-up occurs regarding information provided by business owners. Loss of staff in this accountability area resulted in inquiry and reviews conducted by varying personnel the past few fiscal years. The Accounting Supervisor and the Accounts Payable coordinator, in the absence of a Grant Accountant, conducted the first semi-annual visit for fiscal year 2023. A grant accountant was hired in Spring 2023 along with an Accounting Manager, who were able to conduct the second visit in June 2023. Revisions to the policies and procedures were made following the June visit along with developing formalized documentation templates that show what was subject to monito ring. Fiscal year 2024 monitoring in January 2024 has been completed with follow-up to occur in June 2024. 2023-002: Coronavirus State and Local Fiscal Recovery Funds -Assistance Listing #21.027, Disbursements Condition: During our review of the locality's disbursements related to the program, it was noted that procurement policies were not being followed. In 3 of 25 instances, credit card purchases were not properly approved. Criteria: CSLFRF funds may be used for eligible expenses subject to restrictions set forth in Treasury's Interim Final Rule and Final Rule at 31 CFR Part 35. Also, 2 CFR Part 200 section 303 requires effective control over, and accountability for, all funds. According to the City's procurement policy, department managers and directors are supposed to review and approve credit card purchases on a monthly basis. Review includes ensuring appropriate supporting documentation is included. Documentation should support that transactions are for allowable expenses. Cause: Though the City has controls that push compliance, monitoring and enforcement by Finance is lacking. Additionally, the volume of transactions make monitoring challenging. Some transaction support and approval are routed electronically through US Bank for automation, but there are thousands of monthly transactions. Effect: Noncompliance with federal grant requirements with regard to disbursements. Questioned Costs: Not applicable. Perspective Information: Three out twenty-five transactions Recommendation: We recommend disbursing funds in accordance with the City's procurement policy including a process that requires approval of all credit card purchases. Corrective Action: Management concurs with the recommendation and will ensure that procurement policies including those over credit card purchases will be adhered to. Starting in fiscal year 2023 communication to department directors occurred reinforcing that reviewing and approving financial transactions is necessary under City policy. The City's Department of Finance on a monthly basis is monitoring P-Card compliance and has enhanced communication of internal deadline dates for coding and approving transactions. Follow-up is performed by the Accounts Payable coordinator to address issues with individual users and departments who have unapproved transactions. This practice will continue moving forward with issues of continued non-compliance by users and directors potentially resulting in revoking privileges of using city purchasing cards. 2023-003: Coronavirus State and Local Fiscal Recovery Funds -Assistance Listing #21.027, Disbursements Condition: During our review of the locality's revenue loss calculation, it was noted that one revenue figure was not supported by the City's transmittal form causing the lost revenue available for the City to claim to be understated by approximately $4.8 million. Criteria: Under the Final Rule, recipients can elect a one-time "standard allowance" of $10 million (not to exceed the recipient's award amount) to spend on the "provision of government services" during the period of performance. Alternatively, recipients can calculate lost revenue for the years 2020, 2021, 2022, and 2023 based on the formula provided in the Final Rule to determine the amount of SLFRF funds that can be used for the "provision of government services." According to the 0MB Compliance Supplement section 4-21.027 section III B, recipients can choose whether to use calendar or fiscal year dates but must be consistent through the period of the performance and must provide auditors with evidence supporting their revenue loss calculation. Cause: The calculation of revenue loss was performed by staff who was new to their role with the City. All figures agreed with the Auditor of Public Accounts (APA) transmittal except for one section. Supervisory review was performed but did not detect the inconsistency in the calculation with reported figures on the APA transmittal form. Effect: Noncompliance with federal grant requirements with regard to lost revenue, understating the available revenue loss the City can utilize. Questioned Cost Amount: Not applicable. Perspective Information: Three out of twenty-five transactions Recommendation: We recommend that a process be put in place that ties out all amounts used on the lost revenue calculation to amounts on the transmittal form. Corrective Action: Management concurs with the recommendation and will ensure that the APA transmittal is used for future calculations as necessary. The calculation will be subject to multiple reviews. A final ARPA revenue loss calculation is planned for the spring that will incorporate the updated revenue loss figures from fiscal year 2023 ACFR and update the reporting figures in the fiscal year 2022 ACFR. The City's plan for ARPA spending currently does not plan to utilize the entire revenue loss funds but instead seeks to spend on specific projects that are ARPA eligible. If the Federal Audit Clearinghouse has questions regarding this plan, please call Andrea Trent, Financial Management Consultant at 540-853-5224. Sincerely yours, Andrea F. Trent Financial Management Consultant

CORRECTIVE ACTION PLAN March 26, 2024 City of Roanoke, Virginia respectfully submits the following corrective action plan for the year ended June 30, 2023. Name and address of independent public accounting firm: Brown, Edwards & Company, L.L.P. 3906 Electric Road Roanoke, VA 24018 Audit period: June 30, 2023 The findings from the June 30, 2023 Schedule of Findings and Questioned Costs (the "Schedule") are discussed below. The findings are numbered consistently with the number assigned in the Schedule. FINDINGS AND QUESTIONED COSTS - MAJOR FEDERAL AWARD PROGRAM AUDIT 2023-001: Workforce Investment Opportunity Cluster - Assistance Listing #17.258117.259 / 17.277 / 17.278, Subrecipient Monitoring Condition: During our review of subrecipient monitoring, we noted that the City's monitoring was not being performed according to the formal written policy. While monitoring was performed and documented during the second half of fiscal year 2023, there was a lack of evidence of testing and suggestions to the subrecipient during the first half of fiscal year 2023. Criteria: According to 2CFR 200.33l(a) of the 0MB Compliance Supplement, the City should make subrecipients aware of award information. According to the City's Program Participant Monitoring Plan, the City is supposed to conduct subrecipient monitoring on a semi-annual basis which should include desk reviews of payroll, disbursements, and other financial items. Cause: Staff turnover, particularly for the role of grant accountant, caused these procedures to be overlooked. Management prioritized core operating activities with staffing vacancies in lieu of monitoring activities. Management asserts staff went onsite to review key documents, as documented by email activities, but did not document specific items subject to review. Effect: Noncompliance with federal grant requirements with regard to subrecipient monitoring as well as an increased risk of subrecip1ent misusing funds. Questioned Cost Amount: Not applicable. Perspective Information: One out of two awards Recommendation: We recommend performing subrecipient monitoring in accordance with the City's guidelines and following the procedures laid out in the Program Participant Monitoring Plan. Corrective Action: Management concurs with the recommendation and will ensure that follow-up occurs regarding information provided by business owners. Loss of staff in this accountability area resulted in inquiry and reviews conducted by varying personnel the past few fiscal years. The Accounting Supervisor and the Accounts Payable coordinator, in the absence of a Grant Accountant, conducted the first semi-annual visit for fiscal year 2023. A grant accountant was hired in Spring 2023 along with an Accounting Manager, who were able to conduct the second visit in June 2023. Revisions to the policies and procedures were made following the June visit along with developing formalized documentation templates that show what was subject to monito ring. Fiscal year 2024 monitoring in January 2024 has been completed with follow-up to occur in June 2024. 2023-002: Coronavirus State and Local Fiscal Recovery Funds -Assistance Listing #21.027, Disbursements Condition: During our review of the locality's disbursements related to the program, it was noted that procurement policies were not being followed. In 3 of 25 instances, credit card purchases were not properly approved. Criteria: CSLFRF funds may be used for eligible expenses subject to restrictions set forth in Treasury's Interim Final Rule and Final Rule at 31 CFR Part 35. Also, 2 CFR Part 200 section 303 requires effective control over, and accountability for, all funds. According to the City's procurement policy, department managers and directors are supposed to review and approve credit card purchases on a monthly basis. Review includes ensuring appropriate supporting documentation is included. Documentation should support that transactions are for allowable expenses. Cause: Though the City has controls that push compliance, monitoring and enforcement by Finance is lacking. Additionally, the volume of transactions make monitoring challenging. Some transaction support and approval are routed electronically through US Bank for automation, but there are thousands of monthly transactions. Effect: Noncompliance with federal grant requirements with regard to disbursements. Questioned Costs: Not applicable. Perspective Information: Three out twenty-five transactions Recommendation: We recommend disbursing funds in accordance with the City's procurement policy including a process that requires approval of all credit card purchases. Corrective Action: Management concurs with the recommendation and will ensure that procurement policies including those over credit card purchases will be adhered to. Starting in fiscal year 2023 communication to department directors occurred reinforcing that reviewing and approving financial transactions is necessary under City policy. The City's Department of Finance on a monthly basis is monitoring P-Card compliance and has enhanced communication of internal deadline dates for coding and approving transactions. Follow-up is performed by the Accounts Payable coordinator to address issues with individual users and departments who have unapproved transactions. This practice will continue moving forward with issues of continued non-compliance by users and directors potentially resulting in revoking privileges of using city purchasing cards. 2023-003: Coronavirus State and Local Fiscal Recovery Funds -Assistance Listing #21.027, Disbursements Condition: During our review of the locality's revenue loss calculation, it was noted that one revenue figure was not supported by the City's transmittal form causing the lost revenue available for the City to claim to be understated by approximately $4.8 million. Criteria: Under the Final Rule, recipients can elect a one-time "standard allowance" of $10 million (not to exceed the recipient's award amount) to spend on the "provision of government services" during the period of performance. Alternatively, recipients can calculate lost revenue for the years 2020, 2021, 2022, and 2023 based on the formula provided in the Final Rule to determine the amount of SLFRF funds that can be used for the "provision of government services." According to the 0MB Compliance Supplement section 4-21.027 section III B, recipients can choose whether to use calendar or fiscal year dates but must be consistent through the period of the performance and must provide auditors with evidence supporting their revenue loss calculation. Cause: The calculation of revenue loss was performed by staff who was new to their role with the City. All figures agreed with the Auditor of Public Accounts (APA) transmittal except for one section. Supervisory review was performed but did not detect the inconsistency in the calculation with reported figures on the APA transmittal form. Effect: Noncompliance with federal grant requirements with regard to lost revenue, understating the available revenue loss the City can utilize. Questioned Cost Amount: Not applicable. Perspective Information: Three out of twenty-five transactions Recommendation: We recommend that a process be put in place that ties out all amounts used on the lost revenue calculation to amounts on the transmittal form. Corrective Action: Management concurs with the recommendation and will ensure that the APA transmittal is used for future calculations as necessary. The calculation will be subject to multiple reviews. A final ARPA revenue loss calculation is planned for the spring that will incorporate the updated revenue loss figures from fiscal year 2023 ACFR and update the reporting figures in the fiscal year 2022 ACFR. The City's plan for ARPA spending currently does not plan to utilize the entire revenue loss funds but instead seeks to spend on specific projects that are ARPA eligible. If the Federal Audit Clearinghouse has questions regarding this plan, please call Andrea Trent, Financial Management Consultant at 540-853-5224. Sincerely yours, Andrea F. Trent Financial Management Consultant

AUDITEE’S CORRECTIVE ACTION PLAN As required by Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost principles, and Audit Requirements for Federal Awards (UG), the Jackson Public School District has prepared and hereby submits the following corrective action plan for the findings included in the Schedule of Findings and Questioned Cost for the year ended June 30, 2023: Finding 2023-001 Corrective Action Plan Details A.    Contact person responsible for corrective action: Name: Marc Rowe Title: Executive Director B.    Description of corrective action planned: The district will implement and strengthen its internal control systems over reporting and submitting its monthly claims for reimbursement to ensure claims are submitted within established reporting deadlines. C.    Anticipated completion date of corrective action: 6/30/2024