Corrective Action Plans

Finding Summary: The Town did not have written policies, procedures, and standards of conduct relative to federal awards as required by the Uniform Guidance. Responsible Individual: Kathryn Lynch, Town Administrator Corrective Action Plan: The Town will be updating the Town?s procedures and policies to incorporate the requirements of Part 200 of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. Anticipated Completion Date: June 30, 2023

Management agrees with the recommendation and has incorporated policy updates within the September 2023 updated policies and procedures to ensure compliance with required regulations. AALV will continue to update its policies to meet regulatory requirements.

OSF is currently redesigning key components of its accounting system to clearly identify federal expenditures with minimal adjustments. Anticipated Completing Date October 31, 2023

FINDING 2022-002 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. Context: There was no documented review by someone other than the preparer of the Annual Data Report to ensure the information submitted was complete and accurate. Additionally, the ESSER II Year 1 Annual Data Report submitted to the Indiana Department of Education did not disclose any expenditures and was therefore, understated by approximately $394,000. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and will take the following corrective action. The Annual Data Report will be reviewed, approved and signed by the Superintendent before it is submitted. Responsible party and timeline for completion: The Corporation Treasurer will be responsible effective immediately.

Finding 2022-003 ? Education Stabilization Fund - Reporting Contact Person Responsible for Corrective Action: David Stashevsky Contact Phone Number: 765-378-3329 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The assistant superintendent will manage the grant with the superintendent providing oversight. The assistant superintendent will coordinate the receipts and expenditures of funds with the corporation treasurer. The superintendent will review all financial reports and approve them in writing with notification sent to the assistant superintendent and treasurer. Anticipated Completion Date: The corrections will be made on the next annual report whenever that is due.

FINDING 2022-004 Contact Person Responsible for Corrective Action: John Szabo, Director of Business Affairs Contact Phone Number: 812-443-4461 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Director of Business Affairs (currently John Szabo) will compile information and complete the Annual Reports, which will be reviewed and signed-off on by Assistant Superintendent (currently Tim Rayle) to ensure accuracy of information being submitted. Anticipated Completion Date: Immediately, as of the next required report submission.

FINDINGS AND QUESTIONED COSTS - MAJOR FEDERAL AWARD PROGRAMS AUDIT 2022-002 U.S. Department of Environment Protection ? Assistance Listing # 66.468 Capitalization Grants for Drinking Water State Revolving Fund (Drinking Water State Revolving Fund Cluster) Lack of Required Written Policies & Procedures ? Compliance Condition & Criteria: The Authority does not currently have all the written policies and procedures in place as required by the Uniform Guidance as it relates to financial management and determining allowability of costs for the federal program (Title 2 U.S. Code of Federal Regulations (CFR) 200.302 & 200.305). In addition CFR sections 200.318, 200.319, and 200.320 require there to be written policies and procedures regarding procurement and conflicts of interest. Planned Corrective Action: This is the Authority?s first time subject to the requirements of the Uniform Guidance as we have not had any significant grant funding since 2004. The Authority does have a set of informal policies and procedures that are followed as it relates to financial management, allowability of costs, procurement, and conflicts of interest, and have been very careful to carry out all federal program activities in accordance with established regulations; however, the Authority was simply not aware of the requirement that these polices and procedures be documented in writing. The Authority will begin immediately to get these policies and procedures as they relate to federal programs documented in writing. The Authority is currently working with their consultants to have the written polices established and plan to have this completed within the next fiscal year. If the U.S. Department of Environmental Protection has questions regarding this plan, please contact: Mr. Kenneth Bost, Authority Chairman Alexandria Borough Water Authority PO Box 336 Alexandria, PA 16611 Phone: 814-669-4441

Finding 2022-003 ? Education Stabilization Fund - Reporting Contact Person Responsible for Corrective Action: Christopher deBruyn Contact Phone Number: (219) 785-2239 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The ESSER and GEER Grant Awards Annual Report was correctly completed, but did not have a verified review. Moving forward the review will be conducted by forwarding the completed to another member of the corporation team and a response email be sent back, only after the Annual Report has been understood and independently reviewed. Anticipated Completion Date: The next ESSER and GEER Grant Awards Annual Report

U.S. Department of Housing and Urban Development Susanne Corporation respectfully submits the following corrective action plan for the year ended June 30, 2022. Name and address of independent public accounting firm: KPM CPAs, PC 1445 E Republic Road Springfield, Missouri 65804 Audit period: July 1, 2021 through June 30, 2022 The findings from the June 30, 2022 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Findings ? Financial Statement Audit Significant Deficiency 2022-001 Financial Reporting Recommendation: Management should review and update monthly and year-end closing procedures to ensure controls over financial reporting are sufficient for financial statements to be prepared in accordance with accounting principles generally accepted in the United States of America. Action Taken: Management agrees with the finding and year end closing procedures will be changed to reflect appropriate accounting principles. Findings ? Major Federal Award Program Audit Significant Deficiency 2022-002 Written Uniform Guidance Policies and Procedures Recommendation: We recommend Susanne Corporation draft and adopt written procedures in accordance with Uniform Guidance requirements. Action Taken: Management agrees with the finding and is in the process of drafting and implementing written procedures for cash management and determining the allowability of costs in accordance with Subpart E ? Cost Principals. If the U.S. Department of Housing and Urban Development has questions regarding this plan, please call Joey Wilke at 417-366-3440.

Finding # 2022-001: Type: Federal award, Significant Deficiency over Schedule of Expenditures of Federal Awards (SEFA) Finding The Organization?s initial schedule of expenditures of federal awards (SEFA) presented for the audit did not identify all federal awards. The SEFA excluded a new award and required adjustments. Recommendation: The Organization should implement additional procedures to review the preparation of the SEFA presented for the audit to accurately capture all activity under federal awards. Corrective Action: We will instill additional levels of review prior to submitting draft schedules to the auditor. Anticipated Completion Date: 6/30/2023

AUDIT FINDING #2022-001 Condition: For 8 of 12 semi-annual Federal Financial Reports tested, the reported cash disbursements did not reconcile to the expenditures recorded in the general ledger. Unreconciled differences ranged from $30 to $104,174 and totaled approximately $199,000. CORRECTIVE ACTION Upon transmittal, revenue and total expenses matched the profit and loss reports for the 12 Federal Financial Reports referenced above. The 8 Federal Financial Reports noted above occurred in periods prior to the 2021-002 audit finding that was implemented in October 2022. The Council will continue to follow the 2021-002 corrective action finding. In addition, accruals for expenses paid in the current year for the previous year will be done on a monthly basis with the reversals being done on the first day of each following month. All entries and accruals will be completed prior to the filing of the Federal Financial Reports.

Views of Responsible Officials and Corrective Action: We are in the process of hiring a new bookkeeper/accountant to help manage these issues and develop policies to avoid future errors. We will also implement a process to make sure QuickBase and QuickBooks agree.

Material Weakness Reporting ? Major Programs, including COVID-19 funding Criteria and Condition: While the Organization has some written financial management procedures documentation, it does not meet all the recent specific requirements under 2 CFR 200.302 in the Uniform Grant Guidance. Context: The financial management requirements under 2 CFR 200.302 require each non-federal entity maintain effective control over, and accountability for all funds, property, and other assets, including having written procedures in place. Cause: The Organization did not comply with this requirement. Potential Effect: Errors could occur in financial reporting. Recommendation: We recommend the Organization update its existing policies to comply with the requirements under 2 CFR 200.302. Views of Responsible Officials and Planned Corrective Actions: Management understands the importance of defining and following the necessary policies and procedures to remain in compliance with the requirements under 2 CFR 200.302. Action Taken and Anticipated Completion: We will begin drafting the necessary policies in the 2023.

Views of Responsible Officials: The transition to the accounting system has been completed by the Accountant.

Views of Responsible Officials: The transition to the accounting system has been completed by the Accountant.

On May 3, 2021, the Grantee inform the Municipality about the determination to temporarily submit to a partial protective intervention the programmatic and administrative function of the delegated agency of Pe?uelas. As a direct consequence of such a determination, since May 3, 2021, up to July 31, 2022 (grant termination date), two employees of the Grantee had interference in all fiscal and programmatic transactions of the delegated agency, requiring their authorization for fiscal or programmatic transactions to be carried out. During this timeframe, key personnel of the delegated agency, such as the Program Director, the Program Accountant, the Property Manager, among others, resigned or were required to be replaced by the Grantee?s representatives, altering the programmatic and fiscal operations of the delegated agency. About the program year 2021-2022 closing, the Municipality of Pe?uelas return the funds surplus after the end of the period of liquidation of obligations, including the $3,288,516 related to Head Start Disaster Recovery program retained in the Program restricted cash account as instructed by a Grantee?s representative. Related to the program year prematurely terminated by the Grantee (program year 2022-2023), the Municipality?s Finance Department staff reconciled the program fiscal transactions registered in the Municipality?s computerized accounting system, with the grant awards, as amended, and prepare a liquidation report of each grant award. Such reports will be submitted to the Grantee to discuss the steps for liquidation of obligations with third parties, and the reimbursement of payroll and other expenditures financed by the Municipality?s General Fund. Implementation Date: August 31, 2023 Responsible Person: Mrs. Yadixa Ramos Finance Department Director

We gave instructions to the finance department accounting staff to strengthening internal procedures and controls to ensure accurate preparation and submission of financial reports. Implementation Date: August 31, 2023 Responsible Person: Mrs. Yadixa Ramos Finance Department Director

Finding 2022-003 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. Crawford County Community School Corporation will continue submission of required data to the IDOE on federal spending with at least two people completing the curation. However, final drafts will be reviewed and then final reports will be signed by the at least two people who reviewed the final draft. This signed copy, if not required to be submitting to the IDOE, will be kept locally. Responsible party and timeline for completion: 1) Amy Belcher, Program Administrator, will ensure all final reports have been reviewed and signed by at least two people before submission to the IDOE immediately.

Response: Management notes that, as this is their first single audit and this was one-time emergency funding rather than an ongoing award, they do not have these procedures in writing. However, they followed SBA/SVOG guidelines for allowability of costs, which were researched early in the grant process, and assigned costs in accordance with those guidelines. The budget, which included all assigned costs and was approved by the Lakewood Board of Directors, was also submitted and cleared by the SVOG Compliance Team and they inquired about the allowability of any items over which the guidelines were unclear. Action to be taken: Management notes that, as this was one-time emergency funding rather than an ongoing award, they do not anticipate receiving federal funding in the future. As such, they do not intend to document these procedures in writing at this point. However, if they apply for federal funding again in the future, they will develop written procedures at that point. Responsible Person: Andrew Edwards, Executive Director

Finding 2022-003 ? Education Stabilization Fund - Reporting Contact Person Responsible for Corrective Action: Vicki Jones, Corporation Treasurer Contact Phone Number: 765-793-4877 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Education Stabilization Fund Reporting will be completed and submitted in a timely manner. The Education Stabilization Fund Reporting will be verified with a sign-off by the Superintendent. Anticipated Completion Date: Upon Request

FINDING 2022-004 Contact Person Responsible for Corrective Action: George ann Ewald, Director of Finance & HR Contact Phone Number: (574) 277-4452 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Director of Finance & HR will expand Fund 8700 to include adding line items for all allowable reimbursement costs associated with each firefighter position covered by the 2019 Staffing for Adequate Fire and Emergency Response (SAFER) federal grant. The Director of Finance & HR will ensure that all funds used to compensate each covered firefighter position will be paid entirely out of Fund 8700, only. This action will result in a negative value for Fund 8700 until which time the fund is reimbursed the allowable costs under the provisions of the federal grant. The Director of Finance & HR will generate a report for each reimbursement request, which will be limited to include only the payroll dates of the period for which the request is being submitted. The Fire Chief will review and confirm that all associated costs have been withdrawn from Fund 8700. The Fire Chief will then direct the Assistant Fire Chief to complete the reimbursement request via the FEMA GO website. Once the reimbursement request has been submitted, the Assistant Fire Chief will print the completed reimbursement request documents and obtain signatures from each of the following individuals: 1. Prepared By: (NAME), Director of Finance & HR 2. Reviewed & Approved By: (NAME), Fire Chief 3. Submitted By: (NAME), Assistant Fire Chief Anticipated Completion Date: ? Implementation: June 2023

FINDING 2022-004 Contact Person Responsible for Corrective Action Plan: Alva Sibbitt, Jr., Superintendent, Melissa Embry, Corporation Treasurer, Brehan Leinenbach, Grant Writer Contact Phone Number: 812-547-2637 Views of the Responsible Official: We concur with the findings. Description of the Corrective Action Plan: All reports will be done by the Corporation Treasurer and/or Grant Writer and checked over by the Superintendent. Anticipated Completion Date: February 2023

The Finance team are currently working on the year-end close FY22 and preparation for the audit. Fieldwork will take plan in July 2023 and we are confident that material will be ready to permit completion of the audit ahead of the deadline for FY22. Responsible Officials: Richard Callaghan, CFO Anticipated Completion Date: May 2023

Audit Finding #2022-002 Allowability of Costs Name of Contact Person: Maryland Hutchinson, Fiscal Manager. Corrective Action: UCAP has set up written procedures and descriptions of costs which was submitted to all executive and program staff to be used prior to submission of program expenditures. This was provided to program managers in order to ensure that the cost allocations are followed according to procedures. We have also implemented an internal policy in our financial reporting department to ensure that unallowable costs are not charged to expenditures in error through a thorough two-party review of all expenditures charged to grants. With the several layers of review, it will ensure that no unallowable costs are charged to federal grants. Proposed Completion Date: This was completed as of 3/31/2023.

FINDING 2022-003 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: As it relates to reporting of meal claims, a policy and procedure will be created and implemented to ensure that accurate meal counts are recorded and entered CNP web by Sodexo based off reports from Skyward recording daily meal counts, documentation and entry then reviewed by the GCSC Food Service Manager for accuracy prior to submission of claims and then reviewed by the CFO for completeness. Anticipated Completion Date: Gary Community School Corporation will implement this procedure by September 2023. INDIANA STATE