Corrective Action Plans

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 2022-006 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 2022-011 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

FINDINGS - FEDERAL AWARD PROGRAMS AUDIT SIGNFICANT DEFICIENCY/COMPLIANCE 2022-01 Procurement Policies and Procedures Recommendation: Quotes should be obtained whenever possible when purchases are expected to be between $10,000 and $250,000. If purchases are to equal or exceed $250,000, the proper bidding procedures should be followed. Bidding procedures, quotes, and efforts to give preference to minority or women-owned businesses should be documented, including documenting if bids or quotes could not be obtained. A procurement policy should be established as soon as possible and an individual should be assigned to monitor the implementation of the policy. Action Taken: The Organization has begun the process of establishing a procurement policy and have it completed by March 16, 2023. The Organization will also go back to purchases starting July 1, 2022, that exceeded the micro purchase threshold of $10,000 and prepare the required documentation as listed in the recommendation. This will be completed by April 30, 2023. Any purchases exceeding the micro purchase threshold of $10,000 going forward will be supported by the required documentation.

Program: AL 21.023 ? COVID-19 Emergency Rental Assistance ? Reporting Corrective Action Plan: N/A Contact: Philip Olsen Anticipated Completion Date: N/A

Program: AL 20.933 ? National Infrastructure Investments ? Reporting Corrective Action Plan: NDOT will finalize in coordination with FHWA a standard operating procedure for the quarterly SF-425 reporting process as well as generate a standard operating procedure for FFATA reporting. Contact: Khalil Jaber Anticipated Completion Date: June 2023

Program: AL 12.401 ? National Guard Military Operations and Maintenance (O&M) Projects ? Cash Management & Reporting Corrective Action Plan: The USPFO Grants Officer Representative (GOR) will continue to work closely with the Cooperative Agreement Program Mangers (CAPMs) to track projected invoices so they are paid out in a timely fashion (per Federal Cash Management requirements) from the Cooperative Agreement advance funds (as required by the State). Also upon implementation of the recommendation to change the data in the SF270 (contained in the Exit Conference), the SF270 submission will track the availability of advance funds ? thereby preventing excessive advance funds requested ? and fully expending current available advance funds to the federal requirements. Contact: Matt Zeigler, Grants Officer Representative Anticipated Completion Date: Implementation will occur at the start of the new State Fiscal Year 01-Jul-2023.

Contact Person Responsible for Corrective Action: Jessica Espinoza Contact Phone Number: (219) 836-9111 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: There has been turnover in the finance department and the past employees who would have been responsible for this are no longer here. There are already internal controls in place to ensure that the monthly sponsor claims submitted match the school?s meal count reports. The Treasurer will continue to ensure that everything is correctly entered before submission. Anticipated Completion Date: March 2023

Findings: Major Federal Program Audit, Significant Deficiency 2022-001 Written Uniform Guidance Policies and Procedures Recommendation: We recommend The Arc of the Ozarks draft and adopt written procedures in accordance with Uniform Guidance requirements. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and are in process of developing and implementing the appropriate policies and procedures.

FINDING 2022-003 Contact Person Responsible for Corrective Action: Gerri Ford Contact Phone Number: 812-937-2400 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Corporation Treasurer will prepare the annual reports and ensure the amounts agree to the accounting records. The annual reports prepared by the Corporation Treasurer will be provided to the Director of Learning who oversees the Elementary and Secondary School Emergency Relief (ESSER) grant to review and approve the amounts reported are accurate. After review and approval from the Director of Learning, the annual reports will be submitted by the Corporation Treasurer. Anticipated Completion Date: May 2023

FINDING 2022-007 Contact Person Responsible for Corrective Action: Mary K. Kaczka, Assistant Director, Community Development Contact Phone Number: 574-322-4472 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Financial Reporting: Management has developed the following process to correct for the lack of evidence for review or approval for reports that are submitted: Staff responsible for preparing the report in IDIS and management responsible for review for accuracy and completeness will both sign appropriate documentation detail (PR 5 and PR 7, draw spread sheets, draw vouchers) supporting the Cash on Hand Report and the IDIS report. CDBG staff has consulted with HUD CPD staff for additional training on how to complete the PR 26 report. The training assisted staff in filing two (2) past due reports and resulted in changes to the reporting process utilized by staff. Performance Reporting: Management will address the performance reporting weaknesses by taking the following steps: The assistant director of community development will document the segregation of duties for the completion and submittal of the CAPER before submission to HUD. Documentation will consist of a clear and understandable workflow on City workpapers, and final submissions, evidenced by signature (ink or digital stamp), email string other generally acceptable audit trail. Additionally, as part of continuing education, CDBG staff participated in a workshop organized by our CDBG consultant this past June, 2023 to better understand the Section 3 reporting requirements. Special Reporting for Federal Funding Accountability and Transparency Act (FFATA): Management will address the weaknesses identified in Special Reporting for Federal Funding Accountability and Transparency (FFATA) by taking the following actions: Management will review and strengthen the current process in place for identification and timely submission of projects that qualify for FFATA reporting. Completed reports will show evidence of segregation of duty for completion, and review and approval. Anticipated Completion Date: August 31, 2023

The City is in agreement with the finding noted and will consider formally documenting policies and procedures. Heather Shippey, City Clerk will be responsible for the corrective action and anticipated completion of corrective action will be taken before September 30, 2023.

FINDING 2022-005 Subject: COVID-19 ? Education Stabilization Fund ? Reporting Federal Agency: Department of Education Federal Program: COVID-19 ? Education Stabilization Fund Assistance Listing Number: 84.425D Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirements. Context: The School Corporation was required to submit two Annual Data Reports to the Indiana Department of Education (IDOE) to meet federal reporting requirements for ESSER grant awards. The first report was for the period of March 13, 2020 to September 30, 2020 and was due by January 21, 2021. The second report was for the period of October 1, 2020 to June 30, 2021 and was due by May 13, 2022. For the first report, the amounts reported as expended did not agree to underlying expenditure records of the School Corporation. Per discussion with the Treasurer, the amount in the report included expenditures from outside of the reporting period, resulting in an overstatement of expenditures of approximately $28,000. Additionally, for both reports that were submitted, there was no documented review by someone other than the preparer of the report to ensure the information submitted was complete and accurate. Description of Corrective Action Plan: The treasurer will prepare the grant reporting and have the deputy treasurer review and make any corrections to the information online prior to submission. Responsible Party and Timeline for Completion: Jennifer Blakely, Treasurer, and Debbie Blevins, Deputy Treasurer ? this corrective action will be implemented for all reporting requirements immediately following the audit in March 2023.

FINDING 2022-002 Information on the federal program: Subject: Education Stabilization Fund ? Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 ? Education Stabilization Fund Assistance Listing Number: 84.425C, 84.425D, 84.425U Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Significant Deficiency Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirements. Context: The School Corporation was required to submit two Annual Data Reports to the Indiana Department of Education (IDOE) to meet federal reporting requirements for ESSER grant awards and the GEER grant award. The first report was for the period of March 13, 2020 to September 30, 2020 and was due by January 21, 2021. The second report was for the period of October 1, 2020 to June 30, 2021 and was due by May 13, 2022. We noted for both reports that were submitted, there was no documented review by someone other than the preparer of the report to ensure the information submitted was complete and accurate. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding. The School Treasurer will complete the Annual ESSER data report. The Grant Director will verify the report(s) for accuracy and completion. The Grant director will sign off on each report and then confirm via email the report(s) is correct and ready for submission to the IDOE. Responsible party and timeline for completion: Contact person responsible for Corrective Action: Patti Kappes, Treasurer Contact phone number: (812)427-4215 Anticipated completion date: April 30, 2023

Finding 2022-003 ? Education Stabilization Fund - Reporting Contact Person Responsible for Corrective Action: Mr. Patrick Culp, Superintendent Contact Phone Number: 219-279-2418 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Tri-County School Corporation will ensure someone other that the preparer of the report perform a documented review prior to submission to validate the accuracy and completeness of the data submitted. Anticipated Completion Date: March 29, 2023

INTERNAL CONTROLS OVER FINANCIAL STATEMENT PREPARATION, GRANT CLOSE OUT AND COMPLIANCE WITH RELATED PROVISIONS OF GRANTS AND CONTRACTS SHOULD BE IMPROVED HEAD START AND EARLY HEAD START PROGRAMS LOW-INCOME HOME ENERGY and WATER ASSISTANCE PROGRAM CFDA # 93.600, 93.568 and 93.499 (Questioned Costs - Undetermined) Management is in the process of assessing the organizational structure and capacity to provide adequate financial reporting. With Board review and approval of the agency?s financial funding sources, the agency will hire additional fiscal clerk to further support financial requirements and segregation of duties to ensure adequate internal controls are fully implemented. The CFO will have the overall responsibility of properly reconciling and closing out the accounting system and grant activity each month in an efficient and timely manner to eliminate the risk of significant errors occurring. Budget-to-actual schedules will be an integral part of the grant accountant analyst?s basic responsibilities. The fiscal policies and procedures will be updated with the enhancements implemented within the fiscal department. Staff will be trained on revised policies and procedures and uniform guidance regulations. The new automated financial system, will support financial reporting to meet GAAP requirements and to provide informative reports for Board and Management. All enhancements will be implemented by December 31, 2023.

Finding Number: 2022-002 Condition: The College did not retain underlying support related to the student emergency grants information reported by the College on the annual and quarterly basis. Planned Corrective Action: Support used for reporting will be retained for all future reports moving forward including the fourth quarter 2022 report and the 2022 annual report. Contact person responsible for corrective action: Tom Reynolds, Associate Vice President of Business Services and Deputy Treasurer Lakeland Community College Anticipated Completion Date: As soon as possible moving forward for future quarterly and annual reports starting 12/19/2022

FINDING 2022-003 Contact Person: Jo Ann Treon Phone Number (765)948-4632 Views of Responsible Official: We concur with the findings. Description of Corrective Action Plan: Forms RD 442-2 & RD Form 442-3 will be completed in August 2023. Anticipated Completion Date: Immediately

FINDING 2022-007 Subject: COVID-19 ? Education Stabilization Fund ? Reporting Federal Agency: Department of Education Federal Program: COVID-19 ? Education Stabilization Fund Assistance Listing Number: 84.425D Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425U200013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirements. Context: The School Corporation was required to submit two Annual Data Reports to the Indiana Department of Education (IDOE) to meet federal reporting requirements for ESSER grant awards. The first report was for the period of March 13, 2020 to September 30, 2020 and was due by January 21, 2021. The second report was for the period of October 1, 2020 to June 30, 2021 and was due by May 13, 2022. The amounts reported as expended on the second report did not agree to the underlying expenditure records of the School Corporation. Per discussion with the Treasurer, the amounts reported on the second report were the appropriated amounts, not the actual amounts expended during the period. Therefore, the amounts on the report were overstated by approximately 25% for ESSER I and 280% for ESSER II compared to the correct amounts on the School Corporation?s records. Additionally, for both reports that were submitted, there was no documented review by someone other than the preparer of the report to ensure the information submitted was complete and accurate. Views of Responsible Officials and Planned Corrective Actions: We concur with the finding. Description of Corrective Action Plan: The NJ-SP School Corporation will implement effective internal controls to oversee that the federal grant information prepared and submitted is accurate and reviewed. This will be done in order to detect and correct errors that may be entered prior to submission. This will be done by having an employee prepare the Annual Data Report information while another employee reviews and approves the information before submitting. These controls will be implemented by July 1, 2023. Responsible Party and Timeline for Completion: Dalton C. Tunis ? Corporation Business Manager/Treasurer Anticipated Completion Date: July 1, 2023

FINDING 2022-003 Information on the federal program: Subject: Education Stabilization Fund - Annual Data Report Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Number: 84.425C, 84.425D, 84.425U Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Condition: The School Corporation did not have a documented review control in place to ensure the annual data report was reviewed by someone other than the preparer and that the report was submitted timely. Context: The Annual Data Report for the period of October 1, 2020 to June 30, 2021 was due to the Indiana Department of Education (IDOE) by May 13, 2022. The School Corporation submitted the report on May 16, 2022. In addition, there was no documented review by someone other than the preparer of the report to ensure the information submitted was complete and accurate. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and will take the following corrective action. Dr. Barry Stone, Director of Curriculum will prepare the Annual Data Report in a timely matter and the reports will be reviewed by Mrs. Berry, Superintendent and then signed off before submitting the report. Responsible party and timeline for completion: Federal regulation requires name and title of person overseeing corrective action plan and anticipated completion date. Dr. Barry Stone, Director of Curriculum will compile the report and Mrs. Berry, Superintendent will approve and sign off when the report is due.

FINDING 2020-002 Contact Person Responsible for Corrective Action: Shelly Harrison, Corporation Treasurer Contact Phone Number: 765-492-5102 Views of Responsible Official: We concur to the findings; however, while completing the ESSER Reports, some formatting errors of the provided spreadsheet created some questions by the North Vermillion officials prompting a clarification email to the DOE. Since the formatting errors were not addressed and all completed boxes on the North Vermillion ESSER Report spreadsheet turned green (indicating the correct amounts on the spreadsheet), the North Vermillion officials felt the ESSER report submitted was correct. Description of Corrective Action Plan: To correct the internal control issue, the Superintendent and Corporation Treasurer will work independently as well as collaboratively on the ESSER Reports. Prior to submitting any future report, the corporation officials will document their work by signing off and dating the report prior to submission to the DOE. To rectify the incorrect dollar amount on the Yearly ESSER Report Spreadsheet, the corporation treasurer and superintendent will work collaboratively to correct the amounts on either the ESSER I Year End Report and the ESSER II Year 2 and/or Year End Report. Anticipated Completion Date: Both the Internal Control and ESSER I corrective actions have been corrected, with the ESSER I Final Expenditure Report being completed and signed off on. The ESSER II corrective actions will be completed on the upcoming ESSER III Year End Report when that report is due.

FINDING 2022-003 Contact Person Responsible for Corrective Action: Jeff Gambill, Superintendent; Jennifer Barcus, Corporation Treasurer. Contact Phone Number: 812-665-3550 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Corporation Treasurer will begin reviewing all annual data reports completed by the Superintendent, prior to submission of the reports, to verify that all expenditures are reported in the correct reporting period. Anticipated Completion Date: Immediate review will begin of all annual data reports.

COVID-19 Provider Relief Fund ? AL No. 93.498 Recommendation: Our auditors recommended the Organization evaluate its financial reporting processes and controls to determine whether additional controls over the preparation of any Provider Relief Fund reports are needed to ensure the reports are prepared in line with the Provider Relief Fund guidelines. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Management?s response: The Organization missed reducing the costs claimed against PRF by the amounts reimbursed through the Medicare cost report. The Organization did have additional lost revenues though that would offset these costs claimed and wouldn?t result in a repayment of the funds. We would look to HRSA for guidance on how you would like us to update our Phase 1 PRF report or how you would like to see this corrected. Also, the CFO will listen to webinars to receive education for Phase IV funds that were received by the Organization to ensure compliance with the reporting requirements. COVID-19 Provider Relief Fund ? AL No. 93.498 (Continued) Name(s) of the contact person(s) responsible for corrective action: Connie Prewitt, Interim CFO Planned completion date for corrective action plan: Will implement in fiscal year 2023.

Rural Health Care Services Outreach, Rural health Network Development and Small Health Care Provider Quality Improvement ? AL No. 93.912 Recommendation: Our auditors had the following recommendation related to FFATA reporting: ? They recommended the Organization review the instructions for completion of the federal financial reports with training provided to the program staff preparing and reviewing the federal financial reports to ensure submitted reports are complete and timely. ? Specific to special reports for FFATA, they recommended the Organization provide training on the requirements to those employees responsible for reporting the action in FSRS. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Management?s response: The Organization was unaware of the FFATA reporting requirement. The Organization will register and submit the FFATA. Also, the Organization failed to report the indirect costs on the FFR. The Organization has notified the responsible parties to avoid future occurrences. The FFR?s have been completed to report indirect costs separately in fiscal year 2023. The FFATA was submitted in fiscal year 2023 and will be updated yearly. Name(s) of the contact person(s) responsible for corrective action: Connie Prewitt, Interim CFO Planned completion date for corrective action plan: Will implement in fiscal year 2023.

FINDING 2022-008 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: Documentation will be kept to ensure evidence of preparation, review, and approval of the Grant Reporting. Two individuals will sign off on all future reports and documentation will be kept on file. Anticipated Completion Date: 2/13/2023