Corrective Action Plans

FINDING 2023-001 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Reporting Summary of Finding: The Deputy Auditor prepared the quarterly reports and the Auditor reviewed the reports; however, the control was not effective and did not detect and allow correction of material misstatements prior to submission. Two of the four quarterly reports submitted during the audit period were selected for testing. For the two reports tested, all activity for the reporting period was not included, information submitted was not supported by the County's records, and the reports were not fairly presented Contact Person Responsible for Corrective Action: Jessica Secrease Contact Phone Number and Email Address: 765-456-2804 Jessica.secrease@howardcountyin.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The County will follow the internal controls established, including policies and procedures to ensure that the County provides the Treasury with complete and accurate information for the P&E Report in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The Chief Deputy will continue to work with the Projects Manager to ensure the reporting is accurate and all obligations and expenditures are reported correctly before sending the information to a third-party vendor. The Auditor will review and approve any reporting prior to submission. Initialed reports will be kept within the grant file. Anticipated Completion Date: September 2024

FINDING 2023-003 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds – Procurement and Suspension and Debarment Summary of Finding: The City did not obtain price or rate quotes for the one vendor tested that was less than the simplified acquisition threshold of $150,000 but exceeded the $10,000 micro-purchase threshold. The micro-purchase threshold may be increased, but the City did not provide documentation that the threshold had been increased. Documentation detailing the history of procurement, which must include the reason for the procurement method used, was not available for audit. A population of 9 covered transactions for goods or services were paid from Coronavirus State and Local Fiscal Recovery Fund funds during the audit period. A sample of 3 transactions were selected for testing. Of the 3 transactions tested, 1 vendor was not verified to not suspended nor debarred, or otherwise excluded or disqualified from participating in federal assistance programs or activities. Contact Person Responsible for Corrective Action: Craig Wright - Controller Contact Phone Number and Email Address: 765-747-4828 cwright@muncie.in.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Correcting the audit findings is ongoing. The city has implemented monitoring procedures to review and prevent reoccurring errors. Anticipated Completion Date: The internal control monitoring and checks and balances will be implemented immediately and continue going forward.

FINDING 2023-04 Finding Subject: COVID-19 Coronavirus State and Local Fiscal Recovery Funds – Reporting Summary of Finding: Reports were incorrectly completed, excluded amounts for the report period. Contact Person Responsible for Corrective Action: Amy L. Glackman Contact Phone Number: 317-392-6310 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Control procedures will be put into place effective immediately. The Auditor will have the Deputy Auditor start signing off on all reports to verify the dates are correct for the reporting period. Anticipated Completion Date: August 30, 2024

The Board of County Commissioners will take measures to ensure future compliance with all requirements of federal grants.

FINDING 2023-005 Finding Subject: COVID 19 Reporting Summary of Finding: We were required to submit quarterly P & E reports, ours were submitted in error Contact Person Responsible for Corrective Action: Amy Roberts Contact Phone Number and Email Address: ARoberts@dalevilleindiana.org 765-378-6288 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We will create controls so reports will be submitted in accurate manner in the future Anticipated Completion Date: March 1, 2025

FINDING 2023-005 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds – Reporting Summary of Finding: Finding 2023-005 found that the County did not have an effective system of internal controls in place to ensure accurate and complete reporting of Project and Expenditure (P&E) reports for the Coronavirus State and Local Fiscal Recovery Funds (SLFRF). The County was unable to provide supporting documentation for current period and cumulative obligations, resulting in reporting errors. This issue was isolated to the one annual P&E report submitted during the audit period. Contact Person Responsible for Corrective Action: Chad Shireman Contact Phone Number and Email Address: 812-738-8241; cshireman@harrisoncounty.in.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The County Auditor's office acknowledges the need for strengthened internal controls and improved processes to ensure compliance with reporting requirements for federal awards. A system of internal controls will be designed and implemented to ensure segregation of duties in the preparation, review, and submission of federal reports. This will involve designating different personnel for the preparation and review of P&E reports to ensure accuracy and thorough oversight before submission. Staff involved in federal reporting will receive training on SLFRF compliance and reporting requirements, including proper procedures for documenting obligations and reporting them accurately. The County will review its procedures to ensure compliance with federal reporting requirements periodically. This will help identify any potential issues in a timely manner and allow for immediate corrective action if needed. In addition, regular reviews will verify that corrective actions from prior audits are fully implemented and maintained. Anticipated Completion Date: December 31, 2024

FINDING 2023-003 Finding Subject: Drinking Water State Revolving Fund (DWSRF) Cluster -Procurement Summary of Finding: The Town did not obtain price or rate quotes for the two vendors tested that were less than the simplified acquisition threshold of $150,000 but exceeded the $10,000 micro-purchase threshold. The micro-purchase threshold may be increased, but the Town did not provide documentation that the threshold had been increased. Documentation detailing the history of procurement, which must include the reason for the procurement method used, was not available for audit. Contact Person Responsible for Corrective Action: Sherry Ervin Contact Phone Number and Email Address: 765-478-3522 cctownclerk@comcast.net Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Town will document in the minutes when there is only one (1) vendor available for the purchase of equipment Anticipated Completion Date: By year end 12/31/2024

FINDING 2023-001 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Reporting Summary of Finding: The City submitted four P&E reports during the audit period; however, the controls in place were not effective to prevent, or detect and correct, errors. As a result, errors in reporting were identified. The current period and cumulative expenditures reported consisted of the amounts expended by the beneficiaries who were awarded funds from the City, rather than total amounts expended to the beneficiaries, resulting in current period expenditures and cumulative expenditures being incorrectly reported on all four reports as follows:  Quarterly Report: October 1, 2022 to December 31, 2022 Current period expenditures were overstated by $40,350. Cumulative expenditures were understated by $262,057.  Quarterly Report: January 1, 2023 to March 31, 2023 Current period expenditures were understated by $2,338,864. Cumulative expenditures were understated by $2,499,656.  Quarterly Report: April 1, 2023 to June 30, 2023 Current period expenditures were understated by $1,200,000. Cumulative expenditures were understated by $3,699,656.  Quarterly Report: July 1, 2023 to September 30, 2023 Current period expenditures were overstated by $2,126,306. Cumulative expenditures were understated by $1,573,349. Contact Person Responsible for Corrective Action: Linda Moeller Contact Phone Number and Email Address: 812-948-5333 and lmoeller@cityofnewalbany.com Views of Responsible Officials and Explanation and Reasons for Disagreement:  We concur with the finding.  However, the issue and non-compliance deals with the interpretation of the federal rules regarding the appropriate amounts to report and when to report them by subrecipients of the monies. INDIANA STATE BOARD OF ACCOUNTS 19 Office of the Controller  New Albany City Hall  142 E Main Street, Suite 314  New Albany, Indiana 47150 Telephone: 812-948-5333  www.cityofnewalbany.com City of New Albany, Indiana Linda Moeller City Controller  The non-compliance is not related to policies or controls not being effective to prevent, detect or correct errors. In fact, the reporting system initially implemented by the City and put in the federal reports provided the actual expenditures for those periods by recipients of the grants.  However, the City does agree that after full examination and review of the federal rules the initial full amount of funds provided to the subrecipients should have been reported in full versus the actual expenditures during the periods. Description of Corrective Action Plan:  Current period and cumulative expenditures reported will consist of the amounts advanced to subrecipients. Anticipated Completion Date:  The City has already made this correction in its most recent Quarterly Report April 1, 2024 to June 30, 2024.

FINDING: 2023-002 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Reporting Summary of Finding: The P&E report was prepared by one employee without an oversight or review process in place to ensure accuracy. The report submitted was not mathematically accurate or complete. Per Resolution 2022-1028, approved on December 12, 2022, the City obligated funds for six separate projects totaling $2,257,927. However, the P&E report submitted on April 18, 2023 only included one project resulting in an understatement of total obligations of $1,807,927. Additionally for the one project submitted the key line items of “Current Period Expenditures”, “Total Cumulative Expenditures”, and “Current Period Obligations” as reported on the P&E report did not agree to the City’s financial ledger Contact Person Responsible for Corrective Action: Lynn M. Gorski, Clerk-Treasurer Contact Phone Number: 574-936-2124 Views of Responsible Official: We concur with the finding from SBOA. Description of Corrective Action Plan: There was very little training on how to enter information into the Treasury website for the 2022 year. When it was entered there was only one obligation in the amount of $68,609 even though Resolution No. 2022-1028 noted the intent on spend. Because of lack of training on entering the information it was understated. When the information was entered for the April 2024 report all obligations were entered. When the next report is processed, I will have another staff member verify what is entered prior to submission to the Treasury Department. Anticipated Completion Date: April 30, 2025 Lynn M. Gorski Title: Clerk-Treasurer Date: August 26, 2024

Finding 2023-004 Finding Subject: Covid-19 – Coronavirus State and Local Fiscal Recovery Funds – Procurement and Suspension and Debarment Summary of Findings: The County did not have a Board approved procurement policy that would reflect applicable state laws and regulations including procedures to avoid acquisition of unnecessary or duplicative items and procedures to ensure that all solicitations incorporate a clear and accurate description of the technical requirements for the material, product, or service to be procured. The County had five vendors that qualified for testing under small purchase procurement requirements (vendors paid $10,000-$150,000). Of the two chosen for testing, one was awarded a contract without the County obtaining quotes. The contract awarded was $31,000 for engineering services related to drain construction. Contact Person Responsible for Corrective Action: Debbie Morton-Crum, County Auditor Contact Phone Number: 765-482-2940 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The process was not clear to the Auditor’s Office or the departments submitting the claims for payment. We are more aware of the correct process and procedures that need to take place and will add those procedures to our Internal Control policy to ensure that the vendor is not suspended or debarred. Anticipated Completion Date: October 2024

Finding 2023-003 Finding Subject: Covid-19 – Coronavirus State and Local Fiscal Recovery Funds – Subrecipient Monitoring Summary of Finding: The County did not include all required information in the subrecipient agreements during the audit period. Contact Person Responsible for Corrective Action: Debbie Morton-Crum, County Auditor Contact Phone Number: 765-482-2940 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The County Commissioners are responsible for the American Rescue Plan project list along with that responsibility is to have a sub-recipient agreement in place with those outside entities that received American Rescue Plan grant monies from the County. An Internal Control is now in place that requires a sub-recipient agreement in place before a warrant can be paid to those outside entities. We will put procedures in place to ensure that money disbursed to sub-recipient is monitored. Anticipated Completion Date: December 2024

Finding 2023-002 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Reporting Summary of Finding: The County had not properly designated or implemented a system of internal controls, which would include appropriate segregation of duties that would likely be effective in preventing, or detecting and correcting, noncompliance. A single employee prepared and submitted reports without a documented review or oversight process in place to prevent or detect and correct errors. The County submitted three P&E reports during the audit period. No report was submitted for the period of October 1, 2022 to December 31, 2022 although there was activity during this time period. For the three reports submitted, all activity for the reporting period was not included and the reports were not fairly presented. Contact Person Responsible for Corrective Action: Debbie Morton-Crum, County Auditor Contact Phone Number: 765-482-2940 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We are putting Internal Controls in place specific to the Covid-19 Coronavirus State and Local Fiscal Recovery Funds grant. We will put a checklist together when it is submitted by other departments with a review and approval process for the disbursement by the governing body before the claim can be processed. Anticipated Completion Date: October 2024

FINDING 2023-003 Finding Subject: COVID-19 Coronavirus State and Local Fiscal Recovery Funds - Reporting Summary of Finding: Significant Deficiency Contact Person Responsible for Corrective Action: Ann Hathaway Contact Phone Number and Email Address: 317-852-1126 ahathaway@brownsburg.org Views of Responsible Officials: We concur with the finding that there was not a review in place prior to submitting the report for 3/31/2023. The rules, dates and requirements were quickly changing for the reporting of the Coronavirus State and Local Fiscal Recovery Funds. With there being only one project and a relatively small amount spent, the report was filed with no errors. Description of Corrective Action Plan: The 3/31/2024 report was reviewed and further reports will be going forward. Anticipated Completion Date: Immediately

ALN: 84.425, 84.425F, Corrective Action Plan: Controls and Compliance - HEERF - MSU - The Montana State University - Bozeman will enhance internal controls to comply with federal regulations surrounding cash management and reporting requirements for new Federal programs, including those through the Higher Education Emergency Relief Fund (HEERF), and intends to use existing resources and controls within the university to strengthen the review and reporting requirements for new programs. The university is corresponding with the United States Department of Education to resolve the use of outstanding HEERF monies. Person(s) Responsible for Corrective Measures: Aaron Mitchell, Associate Vice President for Financial Services, Montana State University - Bozeman, Target Date: 12/31/2024

Corrective Action Plan: The Institute implemented the recommendations in the fourth quarter of fiscal year 2024.

FINDING 2023-002 Finding Subject: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Reporting Summary of Finding: The County did not have procedures in place to prevent, or detect and correct, errors on Project and Expenditure (P&E) reports submitted to the U.S. Department of the Treasury. The report submitted during the audit period included projects with current period obligations and cumulative obligations totaling $3,319,955 that had not yet been obligated by the end of the reporting period. It was recommended that management of the County design and implement a proper system of internal controls, including policies and procedures that would provide segregation of duties to ensure appropriate reviews, approvals, and oversight of federal reports are taking place and to ensure the County provides the Treasury with complete and accurate information for the P&E report. Contact Person Responsible for Corrective Action: Amy Copeland Contact Phone Number and Email Address: acopeland@ripleycounty.com; 812-689-6311 INDIANA STATE BOARD OF ACCOUNTS 21 Ripley County Auditor Amy Copeland – Auditor 102 West 1st North Street, PO Box 235 Versailles, IN 47042 Ph: 812-689-6311 Fax: 812-689-3006 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: I, Amy Copeland, Auditor, plan to have the county attorney sit with me when I fill this report out from now on. I will also have one of my employees look over it before it is submitted. Anticipated Completion Date: April 30, 2025

Finding 2023-002 Late Reporting and Noncompliance with Reporting Requirements Name of Contact Person: Anita Fuller, Finance Director Corrective Action Plan: Proposed Completion Date: Immediately

DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION 2023-005 Child and Adult Care Food Program – Assistance Listing No. 10.558 Action taken in response to the finding: The Office for Food and Nutrition Programs (FNP) has moved from a paper based permanent agreement to a web form that exists on the DESE Security Portal. All existing and new Child Nutrition Sponsors will continue to sign off on the document via the web-based portal allowing for a more efficient collection and document retention process. A change will be made in the portal to automatically apply a DESE signature upon submission of the permanent agreement to avoid a late DESE signature. Name of the contact person responsible for corrective action: Rob Leshin, Director of FNP Planned completion date for corrective action plan: July 1, 2024

Condition: Obligations were overstated by approximately $650,000 on the March 31, 2023 Project and Expenditure report. Corrective Action Planned: The Town of Pepperell mis-stated $650,000 as obligated based on intended uses. $300,000 of those funds have been re-directed to real obligations and the Select Board will be authorizing additional spending in the next 10 weeks. Anticipated Completion Date: October 31, 2024 Contact: Andrew MacLean, Town Administrator, Pepperell amaclean@town.pepperell.ma.us, 978-650-1621

The City will use the contract start date (7/1) as the Obligation date, and will submit the FFATA report accordingly.

All Final Expenditure Reports will include the appropriate expenditure amounts associated with the grant year.

Condition: The District recorded a duplicate deposit of $133,868 in federal funds to the general ledger. Corrective Action Planned: The Central Office will ensure that the general ledger transactions are reconciled to the final financial reports before submission to DESE. Anticipated Completion Date: June 30, 2025 Contact: William Plunkett, Director of Finance

Finding 2023-002 – Preparation and Maintenance of Equipment Population The single audit report included the following recommendation: To address the Condition identified above, we recommend Amtrak to continue integration of the systems in such a way that appropriate funding source would be tagged to each asset automatically and that required property records would automatically be consolidated into one system of record and updated in that system. Ensure that adequate IT interface and business process application controls over the completeness, accuracy, validity, confidentiality, and availability of transactions and data during application processing (input, processing, output, etc.) are in place. Additionally, management should consider breaking out large purchase orders containing multiple items of equipment and tools under one purchase request, by creating separate level 2 WBSE codes in order to distinguish between different types of items being acquired, in order to be able to provide more appropriate classification. Identification as a repeat finding: Not a repeat finding Management Response/Status of Action Plans: Amtrak will implement the following to mitigate the finding related to the equipment population. 1. To prevent errors regarding the mapping of grant funding to equipment, the Capital Accounting Department will be implementing additional procedures and validations in the preparation and approval of the equipment review population file. This will include additional cross checks to validate mappings from fund sources to equipment and an additional review by EAMDT. The additional review and approval steps will be formalized with documented steps before September 2024. 2. To prevent errors related to missing asset numbers, the Capital Accounting Department, in coordination with EAMDT, has implemented an additional review of the single audit eligible indicator and inclusion of an asset unit number at the time the equipment asset is recorded in the fixed asset ledger. Additionally, EAMDT and Capital Accounting are now utilizing automated reporting that allows real time review of single audit equipment additions and data fields from the Company’s systems. This reporting allows for a timely view of key data fields from the related systems including Asset Equipment Description, Asset Unit Number, Single Audit Flag, Last Audit Date and Conditions. All equipment with missing asset unit numbers will be investigated and corrected. If any equipment marked as single audit eligible appears as not being eligible, Capital Accounting will investigate and resolve. The contacts for this item are Carol Hanna, VP Controller and Michele Millsaps, Assistant Controller, Capital and Inventory Accounting. Amtrak anticipates that changes above will remediate this finding in the fiscal year ending September 30, 2024 and beyond.

Finding 2023-002 Condition: The Town reported its entire award on the March 31, 2023 Project and Expenditure report as fully obligated and expended in error. Corrective Action Planned: Accounting will review all expenditures and amend the Project and Expenditure report to reflect the trial balance as of March 31, 2023. We will also ensure that reporting due April 30, 2024 is completed accurately based on the guidance of the Treasury. Anticipated Completion Date: By April 30, 2024 Contact: Caroline Burke, Town Accountant

Finding: The Office of Superintendent of Public Instruction improperly charged $42,265 to the Special Education Cluster. Questioned Costs: Assistance Listing # 84.027 84.027 COVID-19 84.173 84.173 COVID-19 Amount $42,265 Status: Corrective action complete Corrective Action: As stated in the finding, the Office has adequate internal controls to comply with period of performance requirements. To address the allowable periods for journal vouchers (corrections), the Office will ensure the correction cycle will align with federally established liquidation periods. In response to the finding, the Office has updated procedures to strengthen internal controls, as follows: • Monitor monthly expenditures to ensure the Office stays within the allowable pre-determined threshold and grant award limit. • Complete expenditure corrections within the grant liquidation period. • Liquidate obligations charged to the grant on the last business day of January (or 120 days after the budget period ends). • Request prior approval of late liquidations from the federal grantor as needed. The Office will communicate the corrective action plan with internal stakeholders to ensure compliance with updated process/procedures. The Office will consult with the federal grantor to discuss whether the questioned costs identified in the audit should be repaid. Completion Date: January 2024 Agency Contact: Amy Kollar Director of Agency Financial Services PO Box 47200 Olympia, WA 98504-7200 (360) 725-6283 Amy.kollar@k12.wa.us