Corrective Action Plans

Public Health agrees with the recommendation. Public Health will develop a process for conducting risk assessments of subrecipient funding, develop and implement procedures for obtaining single audit reports from subrecipients, as well as a system to monitor and track compliance with the single audit mandate among subrecipients. Public Health will ensure each subaward includes all requirements imposed on the subrecipient so that the federal award is used in accordance with Federal Statutes, regulations, and terms of conditions of the federal award. Estimated Implementation Date: May 2025 Contact: Melissa Relles, Assistant Deputy Director Division of Operations, Center for Preparedness and Response California Department of Public Health

California Department of Transportation (Caltrans) has determined that federal award information is not always disseminated to the project managers. Caltrans will review current policies and procedures of each division and revise, if necessary, so that best practices are followed. Caltrans Internal Audits Office will be working with Local Assistance’s single audit report monitoring process and take on the responsibility to monitor for all Caltrans divisions. Estimated Implementation Date: June 2025 Contact: Ben Shelton, Chief – Caltrans Internal Audits Office Division of Risk and Strategic Management

Finding #2023-015 Title of Finding Reporting Contact Person Kimberly Benson Anticipated Completion Date 6/30/2025 Corrective Action planned to be taken: We will ensure that all expenditures of COVID-19 funds are reported in the proper period.

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

Views of Responsible Officials and Planned Corrective Actions 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. 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 was expected to allow the Deputy Finance Director and staff to improve year-end closing procedures and 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. Management expects this finding to be fully corrected for fiscal year ended September 30, 2024.

All management will be educated on the procurement policy as well as the information noted from the CFR sections indicated in the findings by the Director of Finance. The Director of Finance will research and provide education to the Executive Leadership related to this finding during the Executive Leadership meeting. All Grants and cooperative agreements must be filed with the fiscal department. All expenditures must be approved prior to purchase / payment with sign off from Executive Director or Director of Finance.

The Agency agrees with the finding. When granting funds as a subaward to a pass-through entity, the Agency will update its master templates for subawards to include the required information. In addition, when the sub agreements are routed for signature and reviewed by the Chief Financial Officer, they will be double-checked to ensure compliance with this requirement.

The Agency agrees with the finding. When granting funds as a subaward to a pass-through entity, the Agency will update its master templates for subawards to include the required information. In addition, when the sub agreements are routed for signature and reviewed by the Chief Financial Officer, they will be double-checked to ensure compliance with this requirement.

The Agency agrees with the finding. When granting funds as a subaward to a pass-through entity, the Agency will update its master templates for subawards to include the required information. In addition, when the sub agreements are routed for signature and reviewed by the Chief Financial Officer, they will be double-checked to ensure compliance with this requirement.

FINDING 2023-004 Finding Subject: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Procurement and Suspension and Debarment Summary of Finding: Suspension and Debarment – Allen County did not have documentation that vendors’ suspension and debarment status were verified through either a) checking the Excluded Parties List System (EPLS), b) collecting a certification, or c) adding a clause or condition to the covered transaction agreement. Procurement – Allen County did not ensure purchases between $10,000 and $150,000 had received the adequate number of quotes or documented why an adequate number of quotes was not received. Contact Person Responsible for Corrective Action: Chris Cloud, Chief of Staff Contact Phone Number and Email Address: 260-449-4752 / chris.cloud@allencounty.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: To correct Finding 2023-004 for Suspension and Debarment, the Chief of Staff to the Board of Commissioners will check the EPLS on SAM.gov every time a contract is placed before the Board of Commissioners for signature not containing the appropriate suspension and debarment language or a county department starts a project with a vendor using State and Local Fiscal Recovery Funds (SLFRF). If a vendor is not found in EPLS, a certification will be solicited from the vendor prior to contract signing or purchase of goods or services verifying that they have not been suspended or disbarred. A new verification must be sought for every contract or purchase. Documentation will be kept on file by the Controller to the Board of Commissioners who is responsible for reviewing claims submitted for payment utilizing SLFRF. To correct Finding 2023-004 for Procurement, the Chief of Staff to the Board of Commissioners will instruct departments who may be spending between $10,000-$150,000 of SLFRF that price or rate quotations must be obtained from an adequate number of qualified sources. When departments submit a claim to the Controller of the Board of Commissioners for payment, they must also provide a cover sheet outlining a) rationale for the method of procurement, b) copies of quotes received, and c) a justification for the selected vendor. This information will be reviewed and if everything is in order, the cover sheet will be uploaded, along with the accompanying invoices, in the Workflow payment system as part of the record. Anticipated Completion Date: This CAP will be completed by December 31, 2024

FINDING 2023-003 Finding Subject: Special Education Cluster (IDEA) - Procurement Summary of Finding: The School Corporation’s management had not developed a system of internal controls that would ensure compliance with procurement and suspension and debarment compliance requirement. Contact Person Responsible for Corrective Action: Tracey Haas, Deputy Treasurer Contact Phone Number and Email Address: thaas@mcas.k12.in.us (219)873-2000 ext. 8346 Views of Responsible Officials: We concur with this finding. We are working on establishing a proper system of internal controls and develop policies and procedures to ensure there are appropriate procurement procedures for goods and services. Description of Corrective Action Plan: We are working on establishing a proper system of internal control and developing policies and procedures to ensure there are appropriate procurement procedures for goods and services. We are working on a checklist for procurement for all federal grants. Moving forward we will ensure required bids and quotes are attached to the claim for payment. Anticipated Completion Date: The Anticipated date of completion for this correction is January 1, 2025.

FINDING 2023-004 Subject: Child Nutrition Cluster – Procurement and Suspension and Debarment Summary of Finding: The School Corporation had not designed or implemented internal controls, policies, or procedures to ensure that proper procurement procedures for small purchases were followed. Due to the lack of oversight or implemented controls small purchases paid to eight vendors totaling $180,015 were made without obtaining price or rate quotes. The School Corporation had not designed or implemented internal controls, policies, or procedures to ensure that vendors were not suspended or debarred prior to entering into a covered transaction. One covered transaction that equaled or exceeded $25,000 was identified and selected for testing. Transactions to the vendor totaled $81,295; the School Corporation did not verify the vendor’s suspension and debarment status prior to payment. Contact Person Responsible for Corrective Action: Juli Windsor Contact Phone Number:765-689-9131 Views of Responsible Official: We concur with the finding Description of Corrective Action Plan: The corporation will have adequate internal control in place and the corporation will develop a procedure to ensure rate or priced quotes are obtained for small purchases and ensure contractors are not suspended, debarred, or otherwise excluded prior to entering into any contracts or subawards. Anticipated Completion Date: April 2024

Finding 2023-005 Accuracy of Federal Reports POF's initial and current exposure a few months later to Single Audit compliance requirements have sharpened its focus on the need to purposefully identify and maintain corroborating evidence regarding its timely submission and acceptance by each of the respective funding sources. While POF believes that all these reporting requirements were timely met and accepted by all funding sources, It did not consistently maintain either the report itself, or the related documentation such as copies of the emails sent or the associated read-receipts as evidence of these reports. Effective July 1, POF routinely and consistently accumulated and organized these documents as well as ancillary evidence of their transmission to, receipt by, and acknowledgement of acceptance by the federal agency. POF will be more diligent in its transmissions to funders. POF noted that the 2022 Closeout Report was inexplicably re-submitted instead of the correct 2023 Closeout Report. This is unacceptable, and POF will add a second set of reviews by a second person to improve quality control in this area. As necessary, POF will seek professional education and advice in implementing policies, practices, and procedures in addition to those already described herein.

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

FINDING 2023-003 (Auditor Assigned Reference Number) Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds – Reporting Summary of Finding: The Town submitted one P&E report during the audit period timely; however, a single employee prepared and submitted the P&E report without a review or oversight process in place to prevent or detect and correct errors. Only one annual report was required to be submitted by the Town. For the report tested, all activity for the reporting period was not included, information submitted was not supported by the Town's records, and the reports were not fairly presented. Contact Person Responsible for Corrective Action: Matt Sumner Contact Phone Number and Email Address: 317-732-4532, msumner@whitestown.in.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: For applicable reports that are to be submitted for federal grants, we will implement a control/review and ensure the information being reported is correct prior to submission. Anticipated Completion Date: November 1, 2024

FINDING 2023-005 Finding Subject: COVID-19 Coronavirus State and Local Fiscal Recovery Funds- Reporting Summary of Finding: Material Weakness Contact Person Responsible for Corrective Action: Mary Fletcher Contact Phone Number and Email Address: (765) 998-7439, mfletcher@uplandindiana.com Views of Responsible Officials: We concur with the finding Explanation and Reasons for Disagreement: Description of Corrective Action Plan: The Town of Upland will implement an oversight system to review the P&E Report before submission to the Federal Government. Anticipated Completion Date: Upon the submission of our next report due April 30, 2025

FINDING 2023-004 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Reporting Contact Person Responsible for Corrective Action: Humphrey Nagila Contact Phone Number: 317-542-4554 Views of Responsible Official: We agree with this finding. The City will create a policy and procedure to ensure appropriate segregation of duties and reviews, approvals, and oversight are in place for reporting. This policy will require that two staff members from the Controller's Office prepare the quarterly Project and Expenditure report (P&E report). One staff member shall be responsible for preparing the report and the other will complete a review and submission of the report. Anticipated Completion Date: 12/31/2024

FINDING 2023-003 Finding Subject: COVID-19 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY - PROCUREMENT AND SUSPENSION AND DEBARMENT. Summary of Finding: There were deficiencies in the internal control system of the City resulting in noncompliance with the grant’s procurement and suspension and debarment requirements. Contact Person Responsible for Corrective Action: Ashley Huffman Contact Phone Number and Email Address: 765-521-6803 nccityclerk@gmail.com Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The City did not follow its policy for Federal Grant Disbursements. The Clerk Treasurer's office will ensure compliance with the Procurement requirement. The City has implemented maintaining contract files with the Deputy Clerk Treasurer reviewing to ensure they contain documentation of the history of the procurement, including the rationale for the method of procurement and selection of the vendor. Anticipated completion date: September 1, 2024

FINDING 2023-004 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Reporting Summary of Finding: The County submitted four P&E reports during the audit period; however, the errors as identified below were noted on all four reports.  Quarterly Report: October 1, 2022 to December 31, 2022 Current period expenditures reported 7 projects with errors totaling $77,234. Cumulative expenditures reported 22 projects with errors totaling $3,955,669.  Quarterly Report: January 1, 2023 to March 31, 2023 Current period expenditures reported 7 projects with errors totaling $173,169. Cumulative expenditures reported 25 projects with errors totaling $2,633,217.  Quarterly Report: April 1, 2023 to June 30, 2023 Current period expenditures reported 2 projects with errors totaling $0, since expenditures were posted to the incorrect project. Cumulative expenditures reported 24 projects with errors totaling $2,372,744.  Quarterly Report: July 1, 2023 to September 30, 2023 Current period expenditures reported 3 projects with errors totaling $13,412. Cumulative expenditures reported 26 projects with errors totaling $2,273,749. Contact Person Responsible for Corrective Action: Don Lopp, Director of Operations and County Planning Contact Phone Number and Email Address: 812-948-4110 and dlopp@floydcounty.in.gov Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: As Director of Operations and Planning, the American Rescue Plan quarterly reports are submitted through the office. During the last two audit, it appears data input errors have occurred with the reporting of total expenditures. The initial corrective action of review was not sufficient to correct the data input errors. During the recent July 2024 quarterly report, staff reviewed the items on line and believe that all reporting has been corrected. Starting with the September reporting, two staff members will review the data input Anticipated Completion Date: September 2024 – For the third quarter reporting period.

FINDING 2023-005 Finding Subject: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Procurement and Suspension and Debarment Summary of Finding: Procurement - Policy The County had not established a purchasing policy that would reflect applicable state laws and regulations including procedures to avoid acquisition of unnecessary or duplicative items, 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 and did not maintain written standards of conduct covering conflicts of interest and governing actions of its employees engaged in the selection, award, and administration of contracts. Procurement – Small Purchases The County had one vendor that was identified as being less than the simplified acquisition threshold of $150,000 but exceeding the $50,000 micro-purchase threshold. The one vendor was selected for testing. For the one vendor, the County did not obtain price or rate quotes nor was there documentation detailing the history of procurement, which must include the reason for the procurement method used. Suspension and Debarment One covered transaction paid with SLFRF grant funds was identified during the audit period. The covered transaction totaled $66,000 with $46,752 paid in the audit period. Upon review, the County had not performed procedures to ensure the vendor was not suspended or debarred, or otherwise excluded or disqualified, from participation in federal assistance programs or activities at any time during the audit period Contact Person Responsible for Corrective Action: Bryan Lewis Contact Phone Number and Email Address: 574-223-4764 and blewis@co.fulton.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The County will work on establishing a purchasing policy which will address federal procurement requirements. Before entering into contracts we will ensure the procurement procedures in the policy are followed and obtain quotes for vendors that meet the small purchase threshold as well as verify the suspension and debarment status. The Commissioners and Auditor’s office will work together to ensure requirements are met before payment is processed. Anticipated Completion Date: No later than December 31, 2024

FINDING 2023-004 Finding Subject : COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Reporting Summary of Finding: The County submitted the P&E report on June 16, 2023, which was 47 days after the due date. Additionally, the report was not mathematically accurate and complete. The key line items of "Total Cumulative Expenditures" and "Current Period Expenditures" as reported on the P&E report did not agree to the County's ledger. Contact Person Responsible for Corrective Action: Christina Sriver Contact Phone Number and Email Address: 574-223-2912 and auditor@co.fulton.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Upon initial discussion of the Coronavirus State and Local Fiscal Recovery Funds report with State Board of Accounts a deputy auditor began to review the files and financial tracking. This employee will work to update all expenditures of the CSLFR funds to ensure accuracy on the upcoming report and submit timely. Anticipated Completion Date: No later than December 31, 2024

FINDING 2023-002 Finding Subject: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds - Reporting Summary of Finding: The SLRF report did not include project information or amounts. Contact Person Responsible for Corrective Action: Auditor Contact Phone Number and Email Address: 765-653-5513, auditor@putnam.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: We have reached out to Baker Tilly, who does the reports for the County, regarding our audit finding so they know the reporting requirements that will need to be done for the next project and expenditure report which is due to be filed by April 30, 2025. Once we receive the report from Baker Tilly we will have a county employee review for accuracy of the report. Anticipated Completion Date: April 30, 2025

FINDING 2023-004 Subject: COVID 19 - Coronavirus State and Local Fiscal Recovery Fund - Reporting Federal Summary of Finding: Perry County did not properly report period expenditures. The County submitted one P&E report during the audit period. Although the Deputy Auditor compiled the information for the report and the County Auditor reviewed and submitted the report, the internal controls were not effective in preventing, or detecting and correcting, errors. As a result, the P&E report contained errors. Contact Person Responsible for Corrective Action: Kristinia L. Hammack, Perry County Auditor Contact Phone Number: (812) 547-6427 Views of Responsible Officials: We concur with the audit finding. Description of Corrective Action Plan: The Auditor is now aware that the P&E Reporting Period is not calendar. All internal control will stay in place and this information will be noted for further SLFRF Reporting. The Auditor will review the reports prior to submission to ensure that the reporting period is not on a calendar year when reporting. Completion Date: March 1, 2025 INDIANA STATE

FINDING 2023-002 Subject: Coronavirus State and Local Fiscal Recovery Funds - Reporting Federal Agency: U.S. Department of Treasury Assistance Listing Number: 21.027 Federal Award Number: FY 2022 Pass-Through Entity: N/A Compliance Requirements: Reporting Audit Findings: Material Weakness, Modified Opinion Condition: The City had not properly designed 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. Recipients are required to submit quarterly or annually Project and Expenditure (P&E) reports to the Department of Treasury (Treasury). The reporting periods, as well as the respective due dates, are based upon type of recipient and its population, as well as the recipient's allocation amount. Information to be reported includes projects funded, expenditures, and contracts for the appropriate reporting period. The City was classified as a metropolitan city with a population below 250,000 residents that received an allocation of less than $10 million in Coronavirus State and Local Fiscal Recovery Funds (CSLFRF). As, annual reports are to cover one calendar year and must be submitted to the Treasury by April 30 each year. Context: The City submitted one P&E report during the audit period; however, a single employee prepared and submitted the P&E report without a review or oversight process in place to prevent, or detect and correct errors. In addition, the P&E report was not properly supported by the City’s records. All but $100,000 of the expenditures were reported under the Eligible Use Category of “Administrative Expenses.” However, the City’s expenditures during the audit period consisted of assistance to business and households, sewer infrastructure, and tourism support, none of which qualified as Administrative Expenses. Furthermore, the City reported that it was electing to take the Revenue Loss Standard Allowance, but the amount reported as Revenue Loss was $0. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The City of Crawfordsville management will follow the following process. 1. Before processing request from designated organizations the Clerk Treasurer and Mayor or a designated person, will review documentation and approve for payment/claim processing. 2. After approval a claim will be submitted to the Clerk Treasurer office for payment. 3. Clerk Treasurer will prepare and submit monthly expenditure report to the Mayor or designated person. 4. Annually before the Clerk Treasurer, reports to the U.S. Treasury expenditures the Clerk Treasurer and Mayor, or designated person, will review and confirm expenditures. 5. Clerk Treasurer will submit report to U.S. Treasury following prompts. 6. Clerk Treasurer will notify Mayor of the annual report submission. Responsible Party and Timeline for Completion: Clerk Treasurer and the submission that takes place in 2024 (2023 report).

FINDING 2023-003 Finding Subject: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds - Reporting Summary of Finding: Recipients are required to submit quarterly or annually Project and Expenditure (P&E) reports to the U.S. Department of the Treasury (Treasury). The reporting periods, as well as the respective due dates, are based on the type of recipient and the recipient’s population, as well as the recipient’s allocation amount. Information to be reported includes projects funded, expenditures, and contracts for the appropriate reporting period. The County was classified as a metropolitan county with a population below 250,000 residents that received an allocation of less than $10 million in State and Local Fiscal Recovery Funds. As such, the initial P&E report, covering the period from March 3, 2021 to March 31, 2022, was required to be submitted to the Treasury by April 30, 2022. The subsequent annual reports are to cover one calendar year and must be submitted to the Treasury by April 30 each year. The County submitted one P&E report during the audit period, which was obtained from the Treasury's website. Although one employee prepared the P&E report and another reviewed the entries, the system of internal controls was not effective in preventing, detecting, or correcting errors. The data submitted included amounts which should not have been included and amounts which were not supported by the County’s records. Errors identified included the following: • Total Cumulative Obligations were overstated by $907,630. • Total Cumulative Expenditures were overstated by $4,332,524. The lack of effective internal controls and noncompliance were isolated to the P&E Report submitted during the audit period. Contact Person Responsible for Corrective Action: Britt Ostler Contact Phone Number and Email Address: (765) 659-6330 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: INDIANA STATE BOARD OF ACCOUNTS 29 The County received guidance from a consultant in regards to reporting the SLFRF. The consultant had advised “if the County planned to spend $5M, then the total cumulative “obligations” would be $5M. Per review of the SBOA, two figures in the 2023 P&E Report were miscalculated: Cumulative Obligations and Cumulative Expenditures. The Cumulative Obligations reported should be the amount contracted for the project plus any change orders. The Cumulative Expenditures should be the amount expended in prior years, if any, plus the amount expended until March 31st of the year the P&E Report is dated. The current period for the 2023 P&E Report covered April 1, 2022 to March 31, 2023. Future P&E Reports submitted for this grant will use this understanding of Cumulative Obligations and Cumulative Expenditures and will be prepared by the County Auditor and reviewed by a second individual prior to submission. Anticipated Completion Date: April 1, 2025