Corrective Action Plans

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

FINDING 2022-004 Contact Person Responsible for Corrective Action: Stephanie Haynes- Clifford, Food Service Director Contact Phone Number: 260 665 2854 Extension 1202 Views of Responsible Official: 1. Procurement: The School Corporation did not obtain price or rate quotes for milk, bread, or food exceeding $10,000.00 from an adequate number of sources, as required under the small purchase procedures. 2. Suspension and Debarment: The School Corporation did not verify that vendors with contracts over $25,000.00 were not excluded or disqualified from participation in federal award programs. Description of Corrective Action Plan: 1. Food Service will maintain additional prices for like items and/or services. Documentation will be maintained regarding why each vendor is being utilized. Said documentation will be reviewed, initialed and dated by the Food Service Director and an additional staff member. 2. Food Service will maintain annual vendor certificates to ensure that they were not suspended or debarred from participation in federal programs. Anticipated Completion Date: February 10, 2023

Department: Labor Administrative and Financial Services Title: Internal control over CSLFRF expenditures needs improvement Questioned Costs: Known: $51,482,644 Likely: $51,482,644 Status: Management?s opinion is that corrective action is not required Corrective Action: We disagree with this finding. Likewise, we are unable to determine why the auditor has identified a questioned cost or includes a recommendation that only allowable costs are funded by CSLFRF. The transfer of $80 million to the Unemployment Trust Fund is completely allowable, with a portion categorized under the Public Health and Economic Impacts use category and a portion under the Revenue Loss - Provision of Government Services use category. All documentation to support the allowability of this transfer was provided to the auditor for review. There were errors in the original calculation of the total amount eligible under the Public Health and Economic Impacts category; however, we provided documentation to support that the total amount was eligible under the Revenue Loss - Provision of Government Services use category. Although we have identified a weakness in internal control over compliance, there was no actual noncompliance. Consequently, there is no cost that is considered unallowable; therefore, there should be no questioned cost. Completion Date: N/A Agency Contact: DOL Contact: Kimberly Smith, Deputy Commissioner, Department of Labor, 207-621-5096 DAFS Contact: Frank Wiltuck, Director of Internal Audit, OSC, 207-626-8420

FINDING 2022-003 (Auditor Assigned Reference Number) Contact Person Responsible for Corrective Action: Micah Williams/Amanda Myers Contact Phone Number: 765-832-2426 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The school corporation was under the assumption that the state procurement had secured the bidding/quote information for the vendor in question. Emails were given to document the ?go ahead? from our cooperative to order from the vendor. The corporation now understands that we are responsible for obtaining quotes outside of the cooperative. Anticipated Completion Date: Implemented immediately.

Finding 2022-004 Contact Person: Peter Gray Contact Phone: 765-775-5150 Views of Responsible Official: 1. There were no material cost issues in the overall report. There was a categorization error. This was discussed in Finding 2022-003. 2. The Revenue Loss expenditures were all valid personnel costs. Over 80% of the costs are police & fire. Other various city departments comprise the balance of the expenditure. We concur with the finding. Corrective Action: A. An additional layer of review has been initiated. The Director of Development is familiar with the requirements of the SLFRF guidance and will review and sign off on future reports. Anticipated Completion Date: 30 June 2022

Management concurs with the finding. The year-end closing process has improved significantly over the past years and we will continue to strengthen controls over financial reporting to reduce the time required to perform year-end analyses and the closing process. Specifically, analyses and adjustments to contract obligations and purchase orders will be performed on a quarterly basis to complete the reconciliation of year-end balances and transactions in July, within the time constraint. In addition, the Municipality immediately implemented a three-step quality control to the quarterly report?s submission (Preparer / Reviewer / Approval) to ensure that the amounts reported are in accordance with the accounting records. IMPLEMENTATION DATE Ongoing Process RESPONSIBLE PERSON Finance Department

FINDING 2022-001 Contact Person Responsible for Corrective Action: Dawn Mason and Dana Hedges Contact Phone Number: 260-868-2125 Views of Responsible Official: We agree with the finding. Description of Corrective Action Plan: The Food Service Director will obtain price or rate quotes for vendors exceeding $10,000 from three sources. These will be reviewed and initialed by the Business Manager. For vendors with total disbursements expected to be between $50,000 and $150,000, the Food Service Director will obtain contracts from the vendors and these contracts will be stored at our Central Office. DeKalb Eastern will confirm with the Education Service Center via email or letter that the Service Center is correctly certified with the state for procurement requirements. 1f the Education Service Center remains uncertified, the Food Service Director will obtain price or rate quotes for milk from three sources. These quotes will be reviewed and initialed by the Business Manager. The Food Service Director will request a certification from vendors with contracts over $25,000 to show they are not excluded from participation in federal award programs. In the event the vendor is unable to provide a certification, DeKalb Eastern will utilize the SAM website to view the exclusions list of vendors . Anticipated Completion Date: Ongoing - The Food Service Director will obtain the necessary price and rate quotes, as well as contracts and certifications and the Business Manager will review and initial the quotes.

FINDING 2022-004 Contact Person Responsible for Corrective Action: Cheryl Alcorn, County Auditor Contact Phone Number: 574-753-7700 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Auditor and Commissioner will work together to ensure Project and Expenditure Amounts are properly reported to the Department of Treasury. The corrective plan of action will include the guidance of financial advisors to ensure reporting to be complete and accurate. Anticipated Completion Date: Corrective action plan will start immediately.

FINDING 2022-001 (Auditor Assigned Reference Number) Contact Person Responsible for Corrective Action: Todd Pritchett Contact Phone Number: 317-889-4060 Views of Responsible Official: The finding is not disputed. The corporation experienced turnover during the audit period in the cafeteria manager's positon which may have contributed to inability to provide documentation of three quotes for the specified purchase. Description of Corrective Action Plan: On-going training and additional and more experience will continue to address proper documentation procedures. Anticipated Completion Date: Immediate

FINDING 2022-003 Contact Person Responsible for Corrective Action: Chad Shireman Contact Phone Number: 812-738-8241 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The county will ensure that internal controls that are currently in place will be modified in order to be effective in preventing, detecting and correcting errors. This will include making sure the county auditor and designated county commissioner are aware of all reporting deadlines and reporting periods covered. Once the county auditor enters expenditure and obligation information, the designated county commissioner will review the data and submit the necessary report(s). Anticipated Completion Date: This will be completed by September 30, 2023, allowing the county auditor to update the designated county commissioner in the Department of the Treasury?s system and inform him of all upcoming report deadlines. This will ensure the effectiveness of existing internal controls.

FINDING 2022-005 Contact Person: Donald Lopp, Director of Operations and Planning Contact Phone Number: (812) 948.4110 Views of Responsible Official: Corrective Action As Director of Operations and Planning, the American Rescue Plan quarterly reports are submitted through the office. During the audit, it appears eight of the ten audit items had the correct cumulative expenditure but those figures were not also applied to the current quarter expenditures. The US Treasury portal will not allow for the submission of the quarterly report unless the cumulative obligations and expenditures match. Description of Corrective Action Plan: Prior to submission, quarterly reports will be printed and reviewed by secondary staff in Office to review submission correctness. Anticipated Completion Date: This method will be instituted at the July 2023 quarterly report submission.

Finding: The Health Care Authority did not have adequate internal controls over and did not comply with requirements to report recoveries of fraudulent overpayments on the CMS-64 report. Questioned Costs: Assistance Listing # 93.775 93.777 93.777 COVID-19 93.778 93.778 Amount $977,612 Status: Corrective action in progress Corrective Action: The Authority partially concurs with the finding. The Authority has established a process to ensure information concerning the status of Medicaid Fraud Control Unit (MFCU) cases is communicated timely to the Authority from the Attorney General?s Office. The Authority has documented the process to ensure recoveries of fraudulent overpayments are reported on the CMS-64 report appropriately and any federal share is returned timely to the Centers for Medicaid & Medicare Services (CMS). The Authority agrees that $1,032 needs to be repaid to CMS and will initiate return of those funds. The Authority does not concur that the remaining $976,580 needs to be returned to CMS. The state pursued assets through its available means and the court. The provider in question has been out of business since 2017 and a final court ruling was made in June 2022. In April 2023, the Attorney General?s Office certified the defaulted corporation had no identifiable assets. In accordance with 42 CFR 433.318(d), the provider is out of business and the Authority is not required to return the overpayment to CMS. The Authority will provide the court documentation and Attorney General?s certification to CMS Audit Resolution. The conditions noted in this finding were previously reported in findings 2021-052 and 2020-050. Completion Date: Estimated September 2023 Agency Contact: Kari Summerour, CPA External Audit Compliance Manager PO Box 45502 Olympia, WA 98504-5502 (360) 725-9586 Kari.Summerour@hca.wa.gov

Finding: Washington State University did not ensure that returns of Title IV funds were accurate for the Student Financial Assistance programs. Questioned Costs: Assistance Listing # 84.007 84.033 84.038 84.063 84.268 84.379 Amount $2,582 Status: Corrective action complete Corrective Action: The University has improved processes for the return of Title IV funds. The University: ? Included a standard calculation in workbooks to quickly identify whether amounts to be returned for withdrawn students will exceed the amounts disbursed. ? Implemented a quality check to review these exceptions, and to investigate and correct as necessary. The University has returned all questioned costs to the sponsors. Completion Date: May 2023 Agency Contact: Heather Lopez Chief Audit Executive PO Box 641221 Pullman, WA 99164-1221 (509) 335-2001 hlopez@wsu.edu

FINDING 2022-002 Contact Person Responsible for Corrective Action: Debra G. Walker Contact Phone Number: 765-529-2800 Views of Responsible Official: We concur with the findings. Description of Corrective Action Plan: We have corrected and added the $47,363 to the expenditure report. Anticipated Completion Date: Corrected on the March 2023 expenditure report.

Finding: The Department of Commerce did not have adequate internal controls over and did not comply with requirements for monitoring subrecipients to ensure payments were allowable, properly supported, and met period of performance requirements for the Coronavirus State and Local Fiscal Recovery Funds. Questioned Costs: Assistance Listing # 21.027 COVID-19 Amount $28,886,606 Status: Corrective action in progress Corrective Action: The Department implemented procedures to strengthen internal controls to ensure program expenditures are allowable, properly supported, and in compliance with the subrecipient fiscal monitoring requirements. The Homelessness Assistance Unit managing director completed the following corrective actions in July 2022: ? Updated unit reimbursement procedures to include a requirement for specific supporting documentation to accompany payment requests from all subrecipients. ? Provided training to staff on reviewing supporting documentation to ensure expenditures reconcile with reimbursement requests and to verify expenditures are within the period of performance. ? Reviewed 2 CFR 200.332 and updated procedures to include additional requirements for pass-through entities. ? Worked with the Department?s internal control officer for review and feedback of the updated procedures. The managing director will perform a review of the reimbursement process during the next fiscal year which begins July 1, 2023, to ensure procedures are followed. The Department increased the number of client files reviewed during program monitoring. The client file review included verifying household assistance expenses were allowable and incurred within the period of performance. Since the Department received the Coronavirus State and Local Fiscal Recovery Funds through legislative appropriation, resolution of the questioned costs with the grantor will be managed by the Office of Financial Management. Completion Date: Estimated September 2023 Agency Contact: Gena Allen Internal Control Officer PO Box 42525 Olympia, WA 98504 (360) 480-5149 Gena.Allen@Commerce.wa.gov

Finding: The Department of Commerce did not have adequate internal controls over and did not comply with requirements to ensure payments to subrecipients of the Emergency Rental Assistance program were allowable and properly supported. Questioned Costs: Assistance Listing # 21.023 COVID-19 Amount $255,642,551 Status: Corrective action in progress Corrective Action: The Department implemented procedures to strengthen internal controls to ensure Emergency Rental Assistance program expenditures are allowable, properly supported, and in compliance with the subrecipient fiscal monitoring requirements. The Homelessness Assistance Unit managing director completed the following corrective actions in September 2022: ? Updated unit reimbursement procedures to include a requirement for specific supporting documentation to accompany payment requests from all subrecipients. ? Provided training to staff on reviewing supporting documentation to ensure expenditures reconcile with reimbursement requests and to verify expenditures are within the period of performance. ? Reviewed 2 CFR 200.332 and updated procedures to include additional requirements for pass-through entities. ? Worked with the Department?s internal control officer for review and feedback of the updated procedures. The managing director will perform a review of the reimbursement process during the next fiscal year, which begins July 1, 2023, to ensure procedures are followed. The Department will consult with the federal grantor to discuss the audit results. Completion Date: Estimated September 2023 Agency Contact: Gena Allen Internal Control Officer PO Box 42525 Olympia, WA 98504-2525 (360) 480-5149 Gena.Allen@Commerce.wa.gov

Finding: The Department of Social and Health Services improperly charged $390 to the Coronavirus Relief Fund. Questioned Costs: Assistance Listing # 21.019 COVID-19 Amount $390 Status: Corrective action in progress Corrective Action: The Department concurs with the finding. Since the Department received CRF funding through legislative appropriation, resolution of the questioned costs with the grantor will be managed by the Office of Financial Management. Completion Date: Estimated October 2023 Agency Contact: Richard Meyer External Audit Compliance Manager PO Box 45804 Olympia, WA 98504-5804 (360) 664-6027 Richard.Meyer@dshs.wa.gov

Finding: The Department of Corrections improperly charged $37,392 to the Coronavirus Relief Fund. Questioned Costs: Assistance Listing # 21.019 COVID-19 Amount $37,392 Status: Corrective action complete Corrective Action: The Department concurs that the questioned costs identified by the auditors resulted from an employee?s overpayment inappropriately charged to the Coronavirus Relief Fund (CRF). The Department is committed to ensuring compliance with federal grant requirements. In response to this audit finding, the Department: ? Reviewed controls around payroll overpayments and developed a process to ensure they are not included in any future federal funding transfers. ? Reviewed and identified allowable costs that were not initially charged to the grant which would compensate for the questioned costs identified. The identified costs have been filed with the original transfer journal voucher and will be provided to the Office of Financial Management (OFM). Since the Department received CRF funding through legislative appropriation, resolution of the questioned costs with the grantor will be managed by the OFM. Completion Date: June 2023 Agency Contact: Anita Kendall Senior Director, Business Services PO Box 41106 Olympia, WA 98504-1106 (360) 480-7915 Anita.kendall@doc1.wa.gov

Finding: The University of Washington did not have adequate internal controls to ensure key personnel commitments specified in grant proposals or awards were met. Questioned Costs: Assistance Listing # Various Amount $0 Status: Corrective action in progress Corrective Action: The University has established internal controls to ensure compliance with key personnel program requirement through time and effort certifications, project reporting processes, and budget reconciliation requirements. Additionally, the University offers multiple training courses to research administrators and principal investigators (PI) on management of sponsored awards. The University agrees there are areas for improvement over staff and PI training, and resources available to monitor contribution and documentation of committed levels of time and effort. The University will implement the following improvements: ? Update training materials and provide additional training to PIs and key personnel on: o Documentation of time and effort. o Prior approval requirements for reductions in time and effort. ? Update guidance and instructions for time and effort certifications to ensure all personnel involvement in various grant programs is properly accounted for during the certification process. ? Develop exception reports to provide additional oversight to monitor deviations from committed time and effort for PIs and key personnel. Completion Date: Estimated February 2024 Agency Contact: Erick Winger Controller 4300 Roosevelt Way NE Seattle, WA 98195 (206) 543-5322 erickw@uw.edu