Corrective Action Plans

Finding: The Department of Health did not have adequate internal controls over and did not comply with requirements to ensure payments to providers were allowable, met cost principles, and were within the period of performance for the Immunization Cooperative Agreements program. Questioned Costs: Assistance Listing # 93.268 93.268 COVID-19 Status: Corrective action in progress Corrective Action: The Department partially agrees with the finding. The Department agrees that internal controls can be strengthened over provider payments to ensure funds are allowable and spent within the period of performance. The following actions were taken: ? Required payments to providers contain adequate support in line with the A19 matrix and subrecipients? risk assessments. ? Provided additional training to staff in the immunization unit responsible for reviewing invoices. ? Developed tracking sheets which enable staff to record details from backup documentation reviews and payment approvals. The Department will review the control weaknesses identified in the audit related to the consolidated contract payment process and will determine if changes need to be made. The Department disagrees with the audit exceptions and questioned costs identified in the finding. The Department will work with the federal grantor to resolve any questioned costs. Completion Date: Estimated December 2023 Agency Contact: Jeff Arbuckle External Audit Manager PO Box 47890 Olympia, WA 98504-7890 (360) 701-0798 Jeff.Arbuckle@doh.wa.gov

We determined this understatement was a unique occurrence that made it through our existing controls due to the site?s program and finance leads submitting an estimated benefit amount rather than the actual amount recorded in the general ledger. The Program Manager conducted training with the program and finance leads for the Fort Lauderdale site to reinforce their understanding of the grant program?s local site control policies. At the Corporation?s System Office, we have enacted a policy requiring that all Health Ministries provide a cost center or a general ledger report to support payroll costs that are accounted for separately from a time and effort report. This will allow us to independently validate these types of expenses in the future and not rely on local site validation as we have in the past.

FINDING 2022-004 Contact Person Responsible for Corrective Action: Sue Pitts Contact Phone Number: 812-268-6077 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We will implement a system of internal controls related to the preparation and submission of the Project and Expenditure (P&E) Reports. The Clerk-Treasurer will prepare the reports to be reviewed by the Deputy Clerk-Treasurer, prior to submission, to ensure that all projects, sections, and key line items are complete and supported by the ledger. Starting in 2024, the reports will be submitted by the April 30th deadline. Anticipated Completion Date: January 2024

FINDING 2022-002 Contact Person Responsible for Corrective Action: Valeriano F. Gomez / City Controller Contact Phone Number: 219-391-8300 Views of Responsible Official: We concur with the finding Description of Corrective Action Plan: Additional Internal controls to address Finding 2022-002: A.- 1. East Chicago SLFRF reporting personnel, will be expanded to include a review of Quarterly Project and Expenditure Reports by a city senior accountant. 2. All personnel will jointly review Quarterly Project & Expenditure Report when completed, before proceeding to submission in portal. 3. Review by city personnel of previous Quarterly Reports to include the initial Interim Report (SLT-4798, 8-31-21) to address issues. 4. To address possible error in reporting tier will e-mail Treasury (SLFRF@treasury.qov.) for guidance and direction. Per Project and Expenditure Report User Guide April 1, 2023. B.- 2. East Chicago SLFRF reporting personnel will include the project ledger to future SLFRF Compliance Quarter Reports to ensure accurate reporting within the proper timeline / period. Note: In addition, with further discussion, we will continue to work on finding other proposals to improve internal controls issues related to Finding 2022-002. Anticipated Completion Date: Corrective actions should be in place for next SLFRF Quarterly Report (2nd Qtr. 2023).

FINDING 2022-004 Julia Reeves Auditor Contact Person 812-988-5485 Contact Phone Number: Views of Responsible Official: I agree with the findings as they are listed. Description of Corrective Action Plan: Auditor?s office will Generate a report with a date range and keep the report on file for verification to confirm report. The Auditor?s office will verify report before submission. Anticipated Completion Date: December 31, 2023

Following the Auditor's recommendations and as a corrective action, the staff or department in charge locate and document all required reports that were filed according to the requirements of the grant agreement, including the reconciliation thereof with the official Municipality’s accounting subsidiaries. In addition, the Municipality will design, document, establish and provide the necessary and required training, including guidelines and procedures, to all personnel who work directly or indirectly with the management of these federal funds.

During 2023, the newly elected County Auditor took on an active role in tracking the Coronavirus State and Local Fiscal Recovery Funds by preparing and maintaining spreadsheets so that the Commissioners have the most current information for making decisions. The County Auditor attends or watches/listens to the Commissioners’ meetings to make sure that she is updating the spreadsheets with all action taken by the Commissioners. Before submitting the Schedule of Expenditures of Federal Awards for the 2023 audit, we will consult with the Commissioners’ Office and the County Auditor to make sure that we are reporting the transactions correctly based on the spreadsheets prepared and maintained for such purposes.

The Corrective action plan will be to follow the period of performance going forward in order to not have this reoccur again in the future. The County management will review all grant documents to make sure they are in Compliance with the requirements. Van Wert County adopted the Standard Allowance for revenue loss up to $10 million for the ARPA funds. Lost revenue dates will be reviewed in the future to ensure supporting documents are also in Compliance with the grant requirements.

Assistance listing number and program name: 93.268 COVID-19 Immunization Cooperative Agreements 93.323 COVD-19 Epidemiology and Laboratory Capacity for Infectious Diseases Agency: Department of Health Services Name of contact person and title: Lora Andrikopoulous, Grants Administrator Anticipated completion date: March 31, 2024 Agency’s Response: Concur ADHS will work with the Financial Services Assurance Team, Procurement, Finance Managers, Other internal partners, and Grants to update the process of Federal Funding Accountability and Transparency Act (FFATA). The process moving forward will include a communication plan, updates to standard work, creation of new standard work, and additional training.

Condition: On the June 30, 2022 Project and Expenditure report the City reported $7,292,100 of obligations for expenditures that had yet to be specifically identified nor met the definition of an obligation. Corrective Action Planned: $7,292,100 was used to fund the FY 2023 operating budget. The funds were used to defray payroll expenses in the Police department, Fire Department, and School. For FY 2024 no ARPA funds were used to fund the operating expenses, so going forward no obligations will be incurred that aren’t specifically identified by the ARPA approval process. Anticipated Completion Date: Completed Contact: Robert Dickinson, City Auditor

The Deputy Finance Director and the Finance Department identified the transactions as potentially being incorrectly recorded; however, it was not identified timely and/or officially addressed, and was not detected by the Grants Administrator as being recorded in the incorrect period. At the moment the trial balances and year-end closing procedures were being completed, the City was operating without a Finance Director. The Deputy Finance Director and Finance Department were working diligently to review the accounting and handle various tasks, but were not able to timely address the issue with the specific transactions mentioned above. During June 2023, the City hired a Finance Director which will allow the Deputy Finance Director and staff to improve year-end closing procedures and will provide additional support to the Finance Department to ensure controls in place over financial reporting are sufficient. The Grants Administrator will be more involved in communicating with the Finance Department, at a minimum on a monthly basis, as related to reporting of expenditures that are being funded by federal, state, and local awards.

REFERENCE # 2022-002 EQUIPMENT AND REAL PROPERTY MANAGEMENT – SIGNIFICANT DEFICIENCY- NONCOMPLIANCE Program Name/ALN Emergency Solution Grant Program (ALN # 14.231) Compliance Requirements- Equipment Management -- Grants and Cooperative Agreements Equipment means tangible personal property, including information technology systems, having a useful life of more than one year and a per-unit acquisition cost which equals or exceeds the lesser of the capitalization level established by the non-federal entity for financial statement purposes or $5,000 (2 CFR section 200.1). Title to equipment acquired by a non-federal entity under grants and cooperative agreements vests in the non-federal entity subject to certain obligations and conditions (2 CFR section 200.313(a)). Non-federal entities other than states must follow 2 CFR sections 200.313(c) through (e) which require that: (b) Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the federal award identification number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property (2 CFR section 200.313(d)(1)). (c) A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years (2 CFR section 200.313(d)(2)). Condition/Context: Based on our review of the Equipment and Real Property Management compliance requirements, we noted that the Division has written policies regarding Equipment and Real property management. We noted that, Division’s property records did not include all required elements as required by (2 CFR section 200.313(d)(1)). We also noted that, physical inventory of the property was not performed and thus the results were not reconciled with the property records at least once every two years (2 CFR section 200.313(d)(2)). Questioned Costs: Cannot be determined Recommendation: We recommend that the Division must: • include a description of the property, a serial number or other identification number, the source of funding for the property (including the federal award identification number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property. • A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years. Corrective Action Plan: Divisional Headquarters and the local units will include all relevant information on the master vehicle list and take a physical inventory at leas once every two years. Step 1 Action Date: Ongoing Final Implementation Date: 12/31/2023 Name and Phone # Of Person Responsible for Implementation: Jeanne Stromberg, Major, Divisional Finance Secretary (916) 563-3710

FINDING 2021-007 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Reporting Summary of Finding: Material Weakness, Other Matters The County did not have an effective internal control system to ensure compliance with the Reporting compliance requirement. Recipients were required to submit a one-time Interim report to the U.S. Department of the Treasury (Treasury). The County submitted the required interim report during the audit period. The County's process for the completion and submission of the Interim Report was that the County Auditor prepared the Interim Report based on the County's records, without a proper oversight or review process in place prior to submission. The Interim Report was determined to be materially misstated. The County understated the December 31, 2019, Base Year Revenues by $660,302. Contact Person Responsible for Corrective Action: Timothy Stabosz Contact Phone Number and Email Address: 219-326-6808 x2226 tstabosz@laporteco.in.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: To correct this finding, we will require one person to complete the report and another to review the report prior to submission. The preparer and reviewer will sign/initial to document the review process. Anticipated Completion Date: We will begin requirement a review prior to submission as of November 21, 2024.

Invoices that are received will be scanned to “invoices”. This will direct them to our electronic software, Docuware. The item will then be forwarded to the appropriate Program Director for approval, and they will indicate the appropriate cost centers / allocations. Bookers will then review the approved coding and entered fiscal software. If there is a question or concern about approved coding by the bookkeeper they will speak with Director of Finance, Ethan Terrio. Once invoices are entered into fiscal software, checks will be printed. The check stub and invoice will be attached to each other and filed in the fiscal department.Paper documents will continue to be maintained in fiscal until we go 100% paperless, then all documents will be stored in Docuware.

Finding: 2021-002 - Earmarking, Reporting (Performance Progress Reporting) – Material Weakness in Internal Controls Over Compliance and Instance of Noncompliance (Scope Limitation) Recommendation: We recommend that the Coalition develop policies and procedures for tracking actual expenditures related to earmarking requirements and maintain all supporting documentation for the calculation of the earmarking percentages that are reported in the semi-annual performance progress reports. Corrective Action Plan: The Coalition’s staff has developed policies and procedures for tracking actual expenditures related to these requirements, and maintaining all supporting documentation for the calculation of the earmarking percentages that are reported in the semi-annual progress reports. The Coalition has developed an internal control process for reviewing and approving calculations required by Section 50 of the grant agreement and has strengthened its reporting management review controls to ensure that the review is effective to ensure the completeness and accuracy of reports, and that all elements are appropriately supported, prior to submission the federal agency. Anticipated Completion: Late Summer and Fall of 2023 Responsible Party: WCADVSA Co-Directors, Tiffany Eskelson-Maestas and Susie Markus

Finding: 2020-003 - Period of Performance Significant Deficiency in Internal Controls Over Compliance and Instances of Noncompliance Recommendation: The Organization should implement controls to ensure all expenditures allocated to grants are for costs incurred during the specified period of performance. Corrective Action Plan: In January 2021 the WWBC engaged with HighPoint CPA, a non-profit fiscal management firm that processes our accounting, payroll and/or tax needs. HighPoint CPA has implemented a new fiscal management system DEXT, that increases our grant management efficiency and tracking. The Executive Director meets the Monday before the monthly board meeting with the Board Chair and Treasurer to review financial statements and grant reporting documents in order to verify that they are free from material misstatement. In addition, the Finance and Audit committee meets the 2nd Tuesday of every month to ensure compliance. Anticipated Completion: January 2021 Responsible Party: Board of Directors and Executive Director

Finding: 2020-002 - Allowable Costs & Period of Performance Material Weakness in Internal Controls Over Compliance and Instances of Noncompliance Recommendation: The Organization should implement controls to ensure accurate recordkeeping and document retention to substantiate expenditures allocated to grants. Corrective Action Plan: In working with HighPoint CPA, the WWBC has implemented the online accounting system DEXT: all invoices, receipts, bank statements and deposits are loaded in the program and the Executive Director is responsible for categorizing the data, ensuring proper fiscal grant management and is reviewed by the HighPoint CPA team and is reconciled with QuickBooks. The finance committee, which meets the 2nd Tuesday of every month reviews the past month’s financials to ensure compliance. Paper copies are also printed out and filed. Anticipated Completion: January 2021 Responsible Party: Executive Director