Corrective Action Plans

FINDING 2022-004 Contact Person Responsible for Corrective Action: Christopher Dixon, Director of Nutrition and Sheryl Graves, Purchasing Specialist Contact Phone Number: 574-533-8631 Views of Responsible Official: We concur with the finding. Micro-Purchases The School Corporation will document the review/oversight of disbursements from program funds prior to payment. Claims will be prepared and reviewed by Christopher Dixon, Director of Nutrition, or designee, and submitted to the Accounts Payable Specialist for payment. Claims will be initialed or signed demonstrating approval of disbursements. Accounts Payable Specialist will enter claims into the financial software and pays claims after approval by the Chief Financial Officer and School Board. Documentation for claims will be kept in the business office. Small Purchases For Small Purchases, the School Corporation will obtain 3 quotes. Documentation of the 3 quotes are kept within the financial software system or electronically. For purchases about $50,000, GCS will enter into a contract with the vendor, after verifying that the vendor is not suspended or disbarred on SAM.gov. The contract will be electronically maintained by the Purchasing Specialist and uploaded to Gateway. Exceeds Simplified Acquisitions Signed and approved contracts will be maintained and filed electronically by the Purchasing Specialist. Suspension and Debarment All contracts will include documentation from SAM.gov that the vendor has not been suspended or disbarred. Anticipated Completion Date: April 2023

FINDING 2022-006 Contact Person Responsible for Corrective Action: Commissioners: Thomas Helmer, David Berry and Ricky Woodall Contact Phone Number: T. Helmer 765-795-4035, D. Berry 765-522-1775, R. Woodall 765-653-3757 Views of Responsible Officials: Concur with audit finding. Description of Corrective Action Plan: this was the first (for current officers) time getting this large of funds and jumping through all the necessary hoops and the county did not have anything in place prior to go off on how to proceed from start to finish. The county hired Barnes & Thornburg with the impression they would be walking us through the entire process and helping with all the reports. Commissioner Woodall had volunteered to be the county?s designee on handling all the reports necessary to do with the ARPA funds. He did them with the help he would receive from telephone calls with Barnes & Thornburg and the State. The county is going to hire someone (or an accounting firm) to start doing the reports and to make sure the county is complying with what needs to be done. Then, two county employees will have a review process to make sure the proper steps are being followed and the figures being turned in match what the county is showing has been receipted in and disbursed for each quarter and annually. Anticipated Completion Date: March 1, 2024

Finding: 2022-004 Contact Person Responsible for Corrective Action: Heather N Perry, Greene County Auditor Contact Phone Number: 812-384-8658 Views of Responsible Official: We concur with the finding. Description of Correction Action Plan: The Greene County Auditor?s office will establish and maintain effective internal controls over the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Lori Dawn Dickinson will review the P&E Report to verify that all entries are accurate and true, and I (Heather Perry) will submit the report. Heather Perry Greene County Auditor Anticipated Completion Date: April 30, 2024

Finding 2022-002 The Corrective Action Plan (CAP) is designed to address audit recommendations related to revenue recognition, timely grant claims submission, and monthly expenditure reconciliation. To enhance revenue recognition, the Finance Department will review and update existing accounting procedures, provide clearer guidelines, and conduct staff training. The timely submission of grant claims will be ensured through a monitoring mechanism, reporting structure, and an escalation process. Monthly reconciliation of revenue to expenditures will be established, with management reviewing and taking corrective actions as needed. Progress will be closely monitored and reported, with the goal of implementing these improvements immediately, involving the Finance Department, Grants Management Team, and relevant management personnel.

2022-004 ? Allowable Costs/Activities Allowed or Unallowed: Indirect Cost Name of Responsible Individual(s): Pamela Aguilera, Chief Financial Officer. Corrective Action: Safe & Sound?s Finance team implemented policies and procedures to ensure the indirect cost rate is calculated based on modified total direct costs, which excludes amounts over $25,000 for subawards. We updated our formulas to ensure that we properly calculated indirect costs on a monthly basis, ensuring the exclusion of subawards over $25,000. Date Completed: 7/31/2023

CORRECTIVE ACTION PLAN JUNE 30, 2022 REFERENCE: 2022-101 CFDA NUMBER 84.425D ? COVID 19 ? EDUCATION STABILIZATION FUND CFDA NUMBER 84.425U ? COVID 19 ? EDUCATION STABILIZATION FUND U.S. DEPARTMENT OF EDUCATION ? 2021 PASSED THROUGH ARIZONA STATE DEPARTMENT OF EDUCATION GRANT NUMBER: S425D210038 & S425U210038 CLIENT RESPONSE AND CORRECTIVE ACTION PLAN We concur with the condition. 1. Name of the contact person responsible for corrective action: Wendi Allardice - Superintendent Karen Hancock - Title I/ESSER Grants Manager 2. Corrective action planned: A. Protocols developed to obtain at least 3 vendor quotes for any items over 10,000 with an analysis and justification of vendor chosen. B. Protocol in place for checking for vendor suspensions or debarment prior to purchase approval. C. Monthly meeting for comparison of proposed and estimated purchases and actual purchases and charges to the Grant. 3. Anticipated completion date: Anticipated completion date for above listed plan: 08/31/2022

DPH agrees with the finding and recommendations. DPH will notify its subrecipients about their subawards and include any changes in subsequent subaward modifications. DHSP will strengthen its review processes to complete and include the Notice of Federal Subaward Information form as part of the contract copy at the time of the contract execution.

FINDING 2022-002 (Auditor Assigned Reference Number) Contact Person Responsible for Corrective Action: Greg Elkins, CFO Contact Phone Number: 317-485-3100 Views of Responsible Official : We concur with the finding Description of Corrective Action Plan: The Food Service Director (FSD), with assistance from the CFO, will develop a plan to secure a third vendor for kitchen equipment repairs, both for emergencies or regular maintenance repairs. The FSD and CFO will also develop a plan to solicit service plan proposals from qualified providers. The FSD and CFO will utilize approved service agreements through purchasing cooperatives, if available or, solicit responses through the public works bidding process. If a responsive responsible bidder can be secured, the service contract will be approved by the school board of trustees. Anticipated Completion Date: 7/1/2023

FINDING 2022-004 Contact Person Responsible for Corrective Action: Wendy Marples, County Auditor Contact Phone Number: 812-338-2142 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: All future reporting of the Coronavirus State and Local Fiscal Recovery Funds will be reviewed for accuracy by a second staff member of the Auditor?s office prior to submission. The report will be signed and dated by both the preparer and reviewer. All documentation will be maintained to help prevent any future inconsistencies. Anticipated Completion Date: April 2024

FINDING 2022-002 Contact Person Responsible for Corrective Action: Jim Evans Contact Phone Number: (574) 875-5161 Views of Responsible Official: We concur with the finding Description of Corrective Action Plan: This finding has been corrected by discontinuing purchases from the vendor in question for the remainder of the 2022-2023 school year. In future years, future purchases from this vendor will be limited to $9,000.00 per fiscal year. The purchases will be monitored by the Food Service Director and the Food Service Managers in each building. Anticipated Completion Date: This finding has been corrected.

The County agrees with the finding and recommendation. On September 12, 2022, the County issued the ?Notice of Federal Subaward Information Template and Subrecipient Monitoring? memo, which provided departments with a template to communicate the 14 subrecipient reporting requirements from 2 CFR ?200.332(a) to their subrecipients at the time of the subaward. The memo also reminded departments to provide all the required elements from 2 CFR ?200.332(a) to existing CRF subrecipients that were not initially provided all the requirements. In addition, the memo reminded departments that subrecipient agreements must include detailed expectations for periodic reporting and timing of reporting submission. On January 12, 2023, the County issued the ?CARES and ARP Act Funds Subrecipient Monitoring? memo, which reminded departments that subrecipient agreements must include data encryption requirements. The memo also reminded departments that existing subrecipient agreements without data encryption requirements will need to be amended by departments. In May 2023, during the Single Audit Kick-off annual meeting, the County will include the issued ?Notice of Federal Subaward Information Template? on the presentation slides and remind departments that the template should be used to communicate the 14 subrecipient reporting requirements. The County will also reiterate that departments need to maintain documentation that the template was provided to subrecipients at the time of the subaward and existing subrecipients that were not initially provided all the subaward requirements.

FINDING 2022-003 CONTACT PERSON RESPONSIBLE FOR CORRECTIVE ACTION: Lacey Sturgeon/Melissa Bell CONTACT PHONE NUMBER: 765-762-2500 VIEWS OF RESPONSIBLE OFFICIAL: We concur with the finding. DESCRIPTION OF CORRECTIVE ACTION PLAN: The Director of Food Service and Assistant Director of Food Service will review the SAM Exclusions prior to entering a financial agreement with the vendor. The Child Nutrition Secretary will review all claims to ensure no contractors are subject to non-procurement debarment suspension are used. The acquisition threshold will be monitored for all vendors by the Director of Food Service and Assistant Director. Formal bid process and awarding of contracts will be followed as federal regulations required. ANTICIPATED COMPLETION DATE: March 2023

FINDING 2022-001 Contact Person Responsible for Corrective Action: Brian Leitch, Chief Finance & Operations Officer / Treasurer 260-347-2502 ext.: 10017 Roger Urick, Interim Food Service Director 260-347-2502 ext.: 10011 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Procurement: East Noble School Corporation will attempt to solicit (3) quotes for purchases between $10,000 and $150,000. In the event we are unable to acquire the (3) quotes we will document our attempt and state the reason for which vendor we select. Suspension and Debarment: For any contract in excess of $25,000 we will solicit information from said vendor stating, ?They are not suspended or debarred from receiving Federal Funds?. This will be included in the contract or requested to be with the quote. Anticipated Completion Date: April 2023

FINDING 2022-003 Contact Person Responsible for Corrective Action: John Szabo, Director of Business Affairs Contact Phone Number: 812-443-4461 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: When appropriate, the Food Services Director will employ a minimum three vendor rotation for Micro Purchases, and use effective reasoning when applicable. Director of Human Resource will review the use of these vendors on an ongoing basis. For intermediate purchases between $10,000 and $150,000, the Asst. Food Services Director will solicit at least three quotes. Once a vendor is selected, a contract will be executed and signed by the Asst. Food Services Director and the Director of Human Resources or another designated Director. For purchases over $150,000, formal bidding procedures including proper advertising and formal Board of Trustees approval. Once a vendor is selected by the Board of Trustees a contract will be executed and signed by the Asst. Food Services Director and the Director of Human Resources or another designated Director. Anticipated Completion Date: August 1, 2023

DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION 2022-004 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. The identified sponsors with missing permanent agreements for the time period selected now have signed permanent agreements via the web-based form. FNP will add the applicable FAIN numbers to the Financial Management portion of FNP?s public website. FNP will review and update these numbers annually as applicable. FNP, in conjunction with DESE?s Federal Accounting Unit, have embarked on a process to provide all Child Nutrition sponsors instructions and collect information related to UEIs. FNP will continue the process and outreach until all UEIs have been collected. Name of the contact person responsible for corrective action: Robert Leshin, Director of Nutrition, Jeffrey Benbenek, Director of Audit & Compliance Planned completion date for corrective action plan: July 1, 2023

FINDING 2022-003 Contact Person Responsible for Corrective Action: Karen Scalf, Chief Financial Officer Contact Phone Number: (765)973-3406 Views of Responsible Official: Richmond Community Schools agrees with this finding as this information was unknown and the purchases made were at separate times throughout the year, were cumulative totals, and were due to unexpected equipment breakages. Suspension and Debarment and appropriate contractual controls are important to RCS and routine internal controls are in place. The one sample noted was verified in INBiz at the Indiana Secretary of State?s office as we were unaware that only Sam.gov was permissible as the verification tool. It is routine practice for RCS to verify both areas, however documentation did not exist for the Sam.gov check on this particular sample during the audit period. Description of Corrective Action Plan: The Chief Financial Officer will review with the Business Office and RCS Administrators the necessity for Suspension and Debarment compliance as well as the appropriate processes. Vendors will be checked in Sam.gov prior to any new acceptance of vendors and any new receipt of W-9 Forms. Verifications of this check will be screen prints of the Sam.gov page, dates, and initials of the employee who verified Sam.gov. Vendors who are not in good standing and are not active in Sam.gov will not be accepted for transaction in any federal fund. RCS will also try our best to coordinate contracts with vendors on purchases between $50,000 and $150,000 during the budget year. These contracts may be approved after the purchase as purchases such as this occur due to unexpected breakages or emergencies. Anticipated Completion Date: April 7, 2023

Finding 2022-003 Contact Person Responsible for Corrective Action: Jennifer Anderson, Student Services/Special Education Director. Contact Number: 812-876-6325 View of the Responsible Official: Richland-Bean Blossom C.S.C. concurs with finding 2022-003. Description of Corrective Action Plan: The School Corporation will develop Internal Control procedures over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statues, regulations, and the terms and conditions of the Federal award. The School Corporation will develop and maintain an effective internal control system, which would include segregation of duties and would ensure compliance with requirements related to the grant agreement as well as following compliance requirements for Procurement and Suspension and Debarment. The School Corporation will have a control in place to ensure that proper procurement requirements regarding the Small Purchases threshold are met. The School Corporation will retain the appropriate amount of quotes needed and document if there is a unique situation with a vendor where quotes cannot be received. This information will be reviewed and implemented by the Corporation Treasurer, Student Services/Special Education Director or another authorized staff member. Anticipated Complete Date: Implementation of Corrective Action Plan will be set in places as of March 2023.

DHS: The Office of Children, Youth, and Families (OCYF) is sending out a Restrictions and Requirements document with each tentative and final allocation letter. This document lists all OCYF?s grants, the federal agency granting the fund and where to find the rules and regulations guiding the usage of the funds. For the State fiscal year 2021-2022, Tentative Allocation Letters were sent out on April 1, 2021, with Federal Award Identification Numbers (FAIN) and funding amounts. Final Allocation Letters were sent out August 12, 2021, with the Amount, FAIN and Name. OCYF has a risk assessment process in place for Title IV-E and TANF awards. During the Quality Assurance reviews, which occur twice a year at a minimum, OCYF reviews a sample of Title IV-E eligible foster care cases, Title IV-E ineligible foster care cases, Title IV-E eligible adoption assistance cases, and TANF eligible cases. Depending on the number of eligibility and claiming errors identified during the review, OCYF schedules more frequent visits as the risk of repeated and continued errors in these County Children and Youth Agencies (CCYAs) is higher. Inaccurate eligibility determinations lead to inaccurate federal claiming, so basing the review schedule on a CCYA?s eligibility review outcome allows OCYF to target those CCYAs where inaccurate claiming is a higher risk. However, to further address this finding, the risk assessment now includes documentation. Anticipated Completion Date: Completed Contact Person and Title: TinaMarie Petrovitz, Director of County Support DOH: The Department plans to develop and implement a robust subrecipient monitoring program which includes establishing a new section within the Budget Office pending enacted budget funds and complement to support the creation of the section. Initiative goals/milestones include: - Assessment: Comprehensive assessment of all current federal grants and subawards and their processes. This assessment will document best practices and identify gaps within the agency?s processes. It will also provide an evaluation of current operational and technological resources that can be leveraged to facilitate compliance. Target start date: February 27, 2023. Target completion date: June 30, 2023. - Educate Department: Budget Office is developing a bulletin that will outline the subrecipient monitoring requirements with links to State and Federal Sources. The bulletin will be shared with all program office staff. The Budget Office will develop the following templates and provide to all program offices: - Determination of vendor status: Subrecipient or Contractor - Risk Assessment Form - Internal Control Self-Assessment for Subrecipient Template - Subrecipient Monitoring Template All materials will be updated with any additional information gained during the assessment. Start date: February 3, 2023. Target Completion Date: June 30, 2023 - Implementation of full compliance initiative: Recommendations provided in the assessment will be used to develop and implement comprehensive policies and procedures led by a new section in the Budget Office. Target start date July 1, 2023. Target fully operational date: June 30, 2024. Anticipated Completion Date: 06/30/2024 Contact Person and Title: Andrea Race, CFO

FINDING 2022-004 Contact Person Responsible for Corrective Action: Nicole Wolverton, CFO Contact Phone Number: 219-881-5536 Views of Responsible Official: We concur with the audit finding. Description of Corrective Action Plan: A policy and procedure will be created to ensure that all micro-purchases of $10,000 or less have the appropriate documentation and quotes required by Federal guidelines along with any purchases above the given thresholds based on procurement regulations. Documentation of quotes, bids, or contracts will be maintained by the GCSC Food Service manager and approved by the CFO for accuracy and completeness. A policy and procedure will be created to ensure that supporting documentation is received from the food service vendor that corresponds to any discounts or rebates received and are reflected appropriately in the billing reports. The GCSC Food Service manager will review documentation for billing accuracy prior to claims being paid and approved by the CFO. Anticipated Completion Date: Gary Community School Corporation will implement this procedure by September 2023.

FINDING 2022-004 Contact Person Responsible for Corrective Action: Mary Brown Contact Phone Number: 765-472-3901 Ext. 1240 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: During the 2022, we were notified the reporting of the cumulative expenditures for ARPA Funding was inaccurately reported. We have already contacted US Department of Treasury to correct the prior and current year reporting and awaiting a response. We will change the process for reporting to attempt to correct the prior years reporting to ensure we are providing complete transparency for the expenditure of funds. In addition, we will implement the internal control to require the reviewing individual sign the report. Anticipated Completion Date: January 2024

2022-002 ? CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS ? NONCOMPLIANCE WITH SUBRECIPIENT GRANT AGREEMENT REQUIREMENTS ? ALN 21.027 ? OTHER NONCOMPLIANCE Condition: Burleigh County did not communicate and document all of the elements as outlined in 2 CFR 200.332(a) for the subrecipients of the Coronavirus State and Local Fiscal Recovery Funds program. During testing, we noted the following elements were not included: ? subrecipient's unique entity identifier ? federal award identification number ? federal award date (see definition of Federal award date ? 200.1) of award to the recipient by the Federal agency ? subaward period of performance start and end date ? name of Federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity ? Assistance Listings number and Title ? identification of whether the award is Research and Development ? indirect cost rate for the Federal award (including if the de minimis rate is charged) per ?200.414 ? a requirement that the subrecipient permit the pass-through entity and auditors to have access to the subrecipient's records and financial statements as necessary for the pass-through entity to meet the requirements of this part, and appropriate terms and conditions concerning closeout of the subaward Corrective Action Plan: We agree with the recommendation. Burleigh County has implemented new policies and procedures in 2023 regarding subrecipient monitoring. Anticipated Completion Date: FY 2023

Finding 2022-005 Contact Person Responsible for Corrective Action: Debbie Morton-Crum, County Auditor Contact Phone Number: 765-482-2940 View of Responsible Official: 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: October 1, 2023

Finding 2022-004 Contact Person Responsible for Corrective Action: Debbie Morton-Crum, County Auditor Contact Phone Number: 765-482-2940 View of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The American Rescue Plan was completely new in 2022 and the reporting was not documented correctly per the State and Federal guidelines. We have since received some instruction on the proper filing procedures and will put those guidelines into our Internal Control Policy. Anticipated Completion Date: October 1, 2023

Finding # 2022-005 Title of Finding Reporting Contact Person Jewell Aguilar Anticipated Completion Date 06/30/2023 Corrective Action planned to be taken: The report to the U.S. Treasury was submitted late due to several circumstances, including this was the first report filed on a new federal funding portal that was not user friendly and the deadline was also very close to Primary election deadlines of the County Clerk's office, which filed the report. We will make every effort to ensure that future deadlines are met and expenditures and commitments are filed separately and as accurately as possible.

FINDING 2022-007 Contact Person Responsible for Corrective Action: Katie King, Director of Child Nutrition Contact Phone Number: 812-866-6254 Contact Email: kking@swjcs.us Views of Responsible O?cial: We concur with this audit finding. Description of Corrective Action Plan: Action taken in an e?ort to remedy finding 2022-007 includes, but is not limited to, the following: ? Informal procurement methods (small purchase procedures) will be followed for any purchases made by, or on behalf of, the Nutrition Services Department exceeding $10,000.00 up to $150,000.00. Quotes from at least three qualified vendors/contractors will be required. Any purchases made on behalf of the Nutrition Services Department (for example, Maintenance contracting work for kitchen appliance repairs) will need prior approval from the Director of Child Nutrition. ? Wilson Education Center was not an approved co-op for school year, 2020-2021, but was retroactively approved to be a co-op for school year 2021-2022. Therefore, the correction has been made. Anticipated Completion Date: February 1, 2023