Corrective Action Plans

FINDING 2023-004 Subject: COVID-19 – Education Stabilization Fund – Earmarking Summary of Finding: Only 9% of the required 20% minimum earmarking requirement was spent. The remaining set aside amount that was requested for reimbursement was spent on activities that were not a part of the earmarking requirement. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure required earmarking requirements are met. Contact Person Responsible for Corrective Action: Casey Howard Contact Phone Number: 574-842-3364 x806 Views of the Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Superintendent, Treasurer, Deputy-Treasurer and/or Grant Writer will review all grant reimbursements prior to submission for all earmarking. Earmarking will be reviewed for implementation of evidence-based learning loss and accelerated learning. A grant amendment has been requested in January 2024 to include additional allowable expenses. Anticipated Completion Date: February 2024

Finding 2023-004 – Special Education Cluster – Earmarking Contact Person Responsible for Corrective Action: Kimberly Nieves Contact Phone Number: 219-508-0504 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Director of Business Affairs & HR will work with the Special Education Coop to ensure compliance with the Earmarking requirement. Anticipated Completion Date: February 2024

2023-001: Special Education Cluster – Procurement Context/Condition - Of the four procurement transactions subjected to testing, there were two professional service contracts that the District did not have documentation supporting the sole source procurement method. Corrective Action Plan – Laramie County School District No. 1 (LCSD1) appreciates the thorough review conducted by the auditing team, identifying the lack of documentation for two sole source contracts for special education trainers hired in response to the Wyoming Department of Education’s monitoring review. In response, LCSD1 has undertaken a comprehensive corrective action plan to rectify the identified issues and prevent future occurrences. Immediate steps include a detailed review of the existing contract, identification of missing documentation, engagement with legal counsel to ensure compliance, and the development of clear procedures for documenting sole source justifications. To address potential gaps in staff understanding, LCSD1 has implemented additional training programs and reviews by procurement staff. LCSD1 will also evaluate federal, state and district procurement policies and initiate additional internal monitoring requirements for special education contracts. LCSD1 does not dispute the finding and will continue to improve processes and procedures with a focus on periodic reviews to enhance procurement practices. Contact Person – Jed Cicarelli, Chief Financial Officer Anticipated Completion Date – Immediately

The Morgan County Economic Development Office acknowledges status reports submitted by the required due date for the CDBG program.

ALN 21.023 – Lack of Internal Controls and Noncompliance with Subrecipient Monitoring – Emergency Rental Assistance Program (Repeat Finding 2021-013) Cleveland County takes the auditor's findings seriously and has already implemented several improvements in documentation, monitoring, and reporting practices. Cleveland County is working toward improvements for Fiscal Year 2025 and has reconciled billing to align with the contract scope of work. However, we recognize the need for documented internal controls and are committed to addressing all recommendations to ensure compliance and transparency in future programs. The County appreciates the constructive feedback and will continue to refine its processes to better serve its citizens.

The Municipality Administration is committed to identify the control of deficiency that allowed for the deficiency to happen. Additionally, the administration is committed to implementing the correct control structure to prevent the situation from happening in the future. The Municipality Management will continue the search of supporting documentation of the highlighted transactions. New proposed control structure to be evaluated by Municipality for adequacy.

Evidence of AAFAF Funds closeout report was provided, there is no issue.

21.023 - Lack of Internal Controls and Noncompliance with Subrecipient Monitoring Requirement – Emergency Rental Assistance Program (Repeat Finding – 2021-002) Oklahoma County will comply with federal laws and regulations and grant agreements by creating award agreements that are designed and implemented to ensure Subrecipient Monitoring is performed. Anticipated Completion Date: 6/21/2023 Responsible Contact Person: Brian Maughan, BOCC Chairman

21.019 - Lack of Internal Controls and Noncompliance with Subrecipient Monitoring Requirement – Coronavirus Relief Fund (Repeat Finding - 2021-001) Oklahoma County will comply with federal laws and regulations and grant agreements by creating award agreements that are designed and implemented to ensure Subrecipient Monitoring is performed. Anticipated Completion Date: 6/30/2024 Responsible Contact Person: Brian Maughan, BOCC Chairman

FINDING 2022-003Contact People Responsible for Corrective Action: Lynn Leininger, Business Manager and AllisonKellogg, Director of Special EducationContact Phone Number: (260) 367-3677Whitko Community Schools concurs with the finding and will implement a dual check system with theBusiness Manager and the Director of Special Education. All proportionate money earmarked fornonpublic school expenditures under the Special Education Cluster will be continually monitored from theapproval through the end of the grant to insure all compliance requirements are met.The completion date for this corrective action will be July 1, 2023.

FINDING 2022-004Contact Person Responsible for Corrective Action: Timothy LaGrangeContact Phone Number: 812-683-3971Views of Responsible Official: We concur to the finding.Description of Corrective Action Plan: Southwest Dubois and the DSP Exceptional Child?s Co-op have created a systemof internal controls that will ensure reporting compliance requirements are met. The Co-op has developed a shared file foreach of their staff that is participating gin the requirements for the proportionate share. This will be a detailed list of datesand duties that were applied to the proportionate share of each member school corporation. This list will be printed andattached to the grant records and can also be provided to each member corporation if requested.Anticipated Date of Completion: May 2023

FINDING 2022-014 Contact Person Responsible for Corrective Action: Casey Brewster Contact Phone Number: 812-752-8935 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The approved grant budgets for all federal grants will be input into the financial management system and with all expenditures reported monthly from the Treasurer to the Director overseeing the federal grant for review and final approval. The monthly reports will then be used by the Director to generate a reimbursement request for actual expenditures. The reimbursement request must then be reviewed and signed by the Treasurer or the CFO prior to submission to the State by the Director. Anticipated Completion Date: April 2023

FINDING 2022-008 Contact Person Responsible for Corrective Action: Casey Brewster Contact Phone Number: 812-752-8935 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Quarterly reviews of parental involvement will be included in the quarterly grant reviews with the Director of Grants/Programs and the CFO. The Director will also be in engaged in IDOE provided trainings such as TitleCon, and understands the parental involvement requirements needing to be met and will monitor accordingly. In addition, the monthly reports of all revenue and expenditures shall include tracking of specific spending requirements, such as parental involvement spending. Finally, the comprehensive checklist that will be implemented will include the earmarking requirements and status. Anticipated Completion Date: May 2023

FINDING 2022-006 Contact Person Responsible for Corrective Action: Casey Brewster Contact Phone Number: 812-752-8935 Views of Responsible Official: We concur with the finding. INDIANA STATE BOARD OF ACCOUNTS 67 Description of Corrective Action Plan: Additional training related to grant budgets entered into and monitored within the financial software will occur, as will the new practice of having the program directors initiating monthly reimbursement requests informed by the accurate reports from the software (ledger), with documented review by the Treasurer or CFO. Additional training over the reporting requirements is taking place with the Treasurer, CFO and Directors overseeing federal funds provide accurate reporting. Anticipated Completion Date: June 2023

FINDING 2022-012 Contact Person Responsible for Corrective Action: Casey Brewster Contact Phone Number: 812-752-8935 INDIANA STATE BOARD OF ACCOUNTS 69 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Refresher training will be completed by staff, including the Director of Special Education in the area of IDEA Matching, Level of Effort, and Earmarking/MOE requirements with follow-up collaboration with the CFO. Additional training and implementation of controls to verify compliance internally is being developed and will include a monthly and quarterly checklist that requires documentation at the time of the review and it shall also remain on file for inspection during a future audit. This comprehensive checklist includes items beyond those addressed in this written plan and has also been referenced within other actions of this plan. Anticipated Completion Date: June 2023

FINDING 2022-011 Contact Person Responsible for Corrective Action: Casey Brewster Contact Phone Number: 812-752-8935 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Additional training related to grant budgets entered into and monitored within the financial software will occur, as will the new practice of having the program directors initiating monthly reimbursement requests informed by the accurate reports from the software (ledger), with documented review by the Treasurer or CFO. Additional training over the reporting requirements is taking place with the Treasurer, CFO and Directors overseeing federal funds provide accurate reporting. Anticipated Completion Date: June 2023

Wabanaki Public Health and Wellness received our FY21 audit in April 2023, which did not allow for the changes to be made in time for FY22. The corrective action plan from FY21 continues to be our course of action and will be fully implementing the following to ensure compliance in FY23. Wabanaki Public Health & Wellness followed sections of the subrecipient monitoring for requirements of documentation and follow through, however there were areas in which the audit team brough forth to light that needed some enhancing for procedures. WPHW will follow through with full review of the OMB standards for the subrecipient monitoring and build a check list to determine that each required section/item is followed throughout the period of award. The WPHW team, which includes, the Director of Finance, Financial Quality and Compliance Manager, and the Contract Specialist will be working together to build the required list and procedure and reviewing the checklist for when the award is first presented to allow both parties, (sub awardee and WPHW) to understand the requirements for the award. Throughout the award period WPHW will maintain required documentation following the CFR 200.332 guidelines. The Financial Quality and Compliance Manager will review processes through the periodic review of all awards to verify that monitoring has been completed at the deemed timeframe and all parties involved are maintaining the set forth requirements of the award. Person(s) Responsible: Beth McLean Timing for Implementation: Summer 2023

FINDING 2022-004 Contact Person Responsible for Corrective Action: Amanda M. Brackett, Chief Financial Officer Contact Phone Number: (765) 269-8218 Views of Responsible Official: We agree with the findings identified. Description of Corrective Action Plan: In order to mitigate future findings regarding earmarking within the Greater Lafayette Area Special Services cooperative, the TSC will implement procedures to ensure better internal controls which includes monitoring. The Chief Financial Officer will monitor the progress of the Corrective Action Plan to ensure that we fulfill our requirements of the CAP. Anticipated Completion Date: Summer 2023.

Finding No. 2022-002 ? Cash Management View of Responsible Officials: The University maintains that it has policies and procedures in place to ensure expenditures are paid in accordance with 2 CFR Part 200.305(b) which requires non-federal entities to ??minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity??. The University states in Note 1 to the Schedule of Expenditures of Federal Awards that it reports expenditures on an accrual basis of accounting unless otherwise directed by the terms and conditions of the underlying awards. These accrued expenditures are paid on a timely basis in accordance with the University?s existing processes, thereby ensuring compliance with the requirements in 2 CFR Part 200.305(b). This finding is based on the results of testing for Audit Objective No. 4 in Part 3, Section C. Cash Management, in the Office of Management and Budget (?OMB?) Compliance Supplement issued April 2022 which states ?For grants and cooperative agreements to non-federal entities that are paid on a reimbursement basis, supporting documentation shows that the costs for which reimbursement was requested were paid prior to the date of the reimbursement request.? However, as noted above, 2 CFR Part 200.305(b) requires only that non-federal entities minimize the time elapsing between the receipt of funds and the ultimate disbursement for the expenditures, and does not otherwise state that expenditures must be paid prior to the date of the reimbursement request. In October 2017, on behalf of its member institutions, the Council on Governmental Relations (?COGR?) issued a letter to the OMB Office of Federal Financial Management requesting that the Compliance Supplement be amended, followed by an update to 2 CFR Part 200.305, to address these inconsistencies. This request has not been addressed to date. The University will continue to monitor the OMB interpretation and responses to COGR?s request, and reevaluate its existing policies and procedures as necessary. Anticipated Completion Date: N/A

FINDING 2022-002 Contact Person Responsible for Corrective Action: Dan Scherry Contact Phone Number: (812) 937-2400 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: At each Co-Op Board Meeting, the Superintendent will request a copy of the reimbursement requests submitted indicating the amount in North Spencer?s non-public expenditures along with the supporting documentation (timesheets showing time spent with non-public students). Superintendent will make sure the two (requests and timesheets) agree in order to ensure a percentage is not used for the reimbursement requests. Anticipated Completion Date: March 15, 2023

FINDING 2022-0003 Contact Person Responsible for Corrective Action: Chris Richie Contact Phone Number: 219-987-4711 ext. 1113 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: 1) At the beginning of each school year, Cooperative School Services (CSS) will issue step by step instructions regarding documentation of services to any school personnel providing services for non-public school students with Service Plans for Special Education. The instructions will include but not be limited to a list of current nonpublic school students on his/her caseload, Time and Effort (T&E) logs with examples, etc. The building principal will be asked to review and co-sign the completed T&E logs. (If there are additional students identified over the course of the school year, CSS will provide the appropriate information to any new service providers.) 2) During each school year, CSS will obtain the hourly rate (salary, benefits and other appropriate expenditures) for school personnel providing Special Education or Related Services to non-public school students from the school corporation Treasurer. 3) On monthly basis, the signed T&E logs will be submitted to the CSS office. The amount of federal Proportionate Share funds that can be claimed for each participating school corporation will be calculated by CSS and the school corporation Treasurer. 4) The school corporation will submit a claim to CSS for reimbursement for the funds expended to provide services for non-public school students at least twice per school year. CSS will submit the claim to the Fiscal Agent school corporation for reimbursement. The reimbursement claim will be paid through the Fiscal Agent school corporation?s school board procedures from the IDEA Proportionate Share funds. Anticipated Completion Date: March 31, 2023

FINDING 2022-003 Contact Person Responsible for Corrective Action: Tim Scott Contact Phone Number: 574-654-7273 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Corporation Treasurer will meet with representative/s from the South LaPorte County Special Education Cooperative to ensure compliance with the matching, level of effort, and earmarking requirements for federal grants. He will pay particular attention to acquire proof that the required level of expenditures for non-public school students with disabilities is met. Anticipated Completion Date: August 2024

FINDING 2022-004 Information on the federal program: Subject: Special Education Cluster - Earmarking Federal Agency: Department of Education Federal Program: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Number: 84.027, 84.173 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking Audit Finding: Significant Deficiency Condition and Context: The School Corporation is a member of the Daviess-Martin Special Education Cooperative (Cooperative). During fiscal year 2020-2021, the Cooperative operated the special education programs and spent the federal money on behalf of all its member schools. As the grant agreements were between the Indiana Department of Education (!DOE) and each member school, the school corporation was responsible for ensuring and providing oversight of the Cooperative. However, there was inadequate oversight performed by the School Corporation in order to ensure compliance with the Matching, Level of Effort, Earmarking compliance requirement. The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the earmarking requirements. The Cooperative did not have adequate procedures in place to ensure that the required level of expenditures for non-public school students with disabilities was met for each member school. The Cooperative did not have effective internal controls to ensure non-public school expenditures were appropriately identified and reported. The Non-Public Proportionate Share expenditures for the 19611-007-PN01 and 19619-007-PN01 grant awards could not be verified for the individual member schools. Total grant expenditures were posted as expended. The non-public proportionate share expenditures were then determined by applying the budgeted percentage for non-public school expenditures to the total expenditures. These were the amounts reported to !DOE. As such, we were unable to identify if the minimum amount per the grant awards was expended and properly reported to !DOE as required. The lack of internal controls and noncompliance was isolated to the 19611-007-PN01 and 19619-007-PN01 grant awards. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and will take the following corrective action. The School Corporation will set internal controls in place to ensure that the required level of expenditures for non-public school students with disabilities was met for our school corporation. Earmarking requirements for the Matching, Level of Effort will be reviewed and reported. We have consulted with Daviess-Martin Special Education Co-Op and they have assured us additional Komputrol training has been completed on their part to ensure that we are all monitoring internal controls. Responsible party and timeline for completion: Federal regulation requires name and title of person overseeing corrective action plan and anticipated completion date. Mrs. Berry, Superintendent will work with the Daviess-Martin Special Education Co-Op to ensure our School Corporation is in compliance each school year.

FINDING 2022-005 Contact Person Responsible for Corrective Action: Danica Houze, Chief Financial Officer Contact Phone Number: 812-274-8001 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Starting in FY 2021 Time and Effort logs were kept by employees working with non-public students. Logs are submitted to the Director of Student Services and the payroll department, then accounts are distributed to match time actually spent with the non-public time spent per the time and effort logs. Anticipated Completion Date: 2/13/2023

FINDING 2022-002 Information on the federal program: Subject: Special Education Cluster (IDEA) - Earmarking Federal Agency: Department of Education Federal Program: Special Education Grants to States Assistance Listing Number: 84.027 Federal Award Number: 20611-001-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking Audit Findings: Significant Deficiency Condition: The School Corporation is a member of the Adams Wells Special Services Cooperative (Cooperative). During fiscal year 2021-2022, the Cooperative operated the special education programs and spent the federal money on behalf of all its member schools. As the grant agreements were between the Indiana Department of Education (IDOE) and each member school, the school corporation was responsible for ensuring and providing oversight of the Cooperative. There was inadequate oversight performed by the School Corporation in order to ensure compliance with the Matching, Level of Effort, Earmarking compliance requirement. The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the earmarking requirements. The Cooperative did not have adequate procedures in place to ensure that the required level of expenditures for non-public school students with disabilities was met for each member school. The Cooperative did not have effective internal controls to ensure non-public school expenditures were appropriately identified and reported. Context: The Non-Public Proportionate Share expenditures for the 20611-001-PN01 grant award could not be verified for the individual member schools. Total non-public expenditures were posted as expended. The member school proportionate share expenditures were then determined by applying a budgeted percentage to the total non-public expenditures. These were the amounts reported to IDOE. As such, we were unable to identify if the minimum amount per member school was expended and properly reported to IDOE as required. The School Corporation?s Non-Public Proportionate Share for the 20611-001- PN01 grant application was $5,368. Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Our corrective action plan is following the AWSSC plan of: Co-ops cannot combine proportionate share funds. Funds must be spent within each LEA?s geographic boundary. We will not receive a repeat finding for FY21. We will correct for FY22 and forward. Time & Effort Logs are being completed to show how many hours personnel are servicing Non-Pub school students with a service plan. If Materials and Equipment are purchased for a specific student?s need, per the service plan, then those expenditures are 100% school specific. Per the DOE, Materials used by our Speech Language Pathologist for Speech Therapy for all six school corporations, those expenditures are split evenly across all school corporations with a non-pub proportionate share allocation. Responsible Party and Timeline for Completion: The Superintendent and Corporation Treasurer will work with the Adams Wells Special Services Cooperative to monitor and verify those expenditures are allocated appropriately across all school corporations with a non-pub proportionate share allocation.