Corrective Action Plans

Finding Number: 2023-003 Planned Corrective Action: The accounts payable clerk will double check all claims submitted to the state for accuracy. Anticipated Completion Date: 08/30/2024 Responsible Contact Person: Stacy Bolden

FINDING 2023-001 Finding Subject: Coronavirus State and Local Fiscal Recovery Funds – Reporting Summary of Finding: The Kosciusko County Sheriff's Office applied for the Indiana Local Body Camera Grant (ILBC). The sheriff’s office was awarded this grant on January 1, 2023, with a grant cost amount of up to $31,920. This grant is a reimbursable grant through the Indiana Department of Homeland Security. The period of performance was from January 1, 2023, to December 31, 2023. The Kosciusko County Sheriff's Office ordered body-worn cameras and equipment on April 26, 2023. The invoice for the cameras and the camera equipment was paid on July 14, 2023. The Kosciusko County Sheriff's Office then submitted a Reimbursement Claim Form on September 11, 2023. The Reimbursement Claim Form shows the Sheriff's Office incorrectly requested the full $31,920. They received $31,920 from the Indiana Department of Homeland Security on September 27, 2023. However, the county had only spent $9,581 of the grant money towards the body camera purchase. Therefore, there is a remaining balance in the fund of $22,339 as of December 31, 2023. Due to the period of performance, the county should have reimbursed the Indiana Department of Homeland Security $22,339. On May 9, 2023, the Sheriff's Office grant administrator submitted a Program Report for the ILBC grant. This report was filed without an implemented internal control or evidence of a review. The report was completed and submitted by the Sheriff's Office grant administrator. The report incorrectly indicated that all expenditures had been completed. As of the date of the submission, the county had not purchased the bodyworn cameras and all federal funds had not been expended. Contact Person Responsible for Corrective Action: Alyssa Schmucker Contact Phone Number and Email Address: 574-372-2325 aschmucker@kosciusko.in.gov View of Responsible Officials: We concur with the findings identified. Description of Corrective Action Plan: The Kosciusko Sheriff’s Office, grant coordinator will contact IDHS for instruction on how to return the $22,339.00 and prepare a claim to be processed by the Kosciusko County Auditor’s office. The grant balances are submitted each month by departments these are checked and confirmed by the Auditor’s Office this one was overlooked in the review process. The person who applied for the grant no longer works for the county. It is believed the new person handling the grants was not aware that this grant even existed. The Grant Administrator(s) will have someone sign off on the grant report submissions and forward all reports to the Auditor’s Office. Anticipated Completion Date: It is anticipated that this will be completed as soon as the information to return the funds is received from the state and the claim is submitted to the Auditor for payment. This claim will be paid as soon as it is received. On or before 12/31/2024.

U.S. DEPARTMENT OF THE TREASURY COVID-19 – Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) – Federal Assistance Listing Number 20.027 Corrective Action Plan – Internal Control over Compliance Finding Condition: The County has inadequate controls over approving and disbursing funds for the Coronavirus State and Local Fiscal Recovery Funds program. Plan: The County will assess why the established controls over approving claims and signing checks were not followed in the approval and disbursement of Coronavirus State and Local Fiscal Recovery Fund program funds. Anticipated Date of Completion: 11/30/2024 Management Response: Management will follow its established controls over approving and disbursing Coronavirus State and Local Fiscal Recovery Fund program funds.

Will review all salary charges for ESSA

ALN: 10.542, 10.551, 10.561, Corrective Action Plan: Inadequate Accounting Records - SNAP - P-EBT - DPHHS - The Montana Department of Public Health and Human Services conditionally concurs with this recommendation. Expenditures were tracked separately by program and records were adequate to trace funds in accordance with federal regulations. The department will continue to improve its processes related to ensuring new federal program activity is not co-mingled with other programs, especially when closely related. Person(s) Responsible for Corrective Measures: Corinne Kyler, Administrator, Montana Department of Public Health and Human Services, Target Date: Completed

ALN: Various R&D, Corrective Action Plan: Equipment Inventory Controls - MSU - Montana State University - Bozeman will enhance the internal controls surrounding the capital asset inventory and tagging process, including accessing research space to count and tag new assets. The university had a difficult time over the pandemic in retaining employees and hiring replacements. There were also difficulties accessing space on campus due to social distancing requirements. The university has been able to hire employees in Property Management and expects the pandemic-related challenges to be minimal moving forward. Person(s) Responsible for Corrective Measures: Aaron Mitchell, Associate Vice President for Financial Services, Montana State University, Target Date: 12/31/2024

ALN: Various R&D, Corrective Action Plan: Equipment Inventory Controls - UM - The University of Montana - Missoula has strengthened internal controls by hiring an Account Analyst to manage asset tagging and to conduct comprehensive reviews to ensure all assets are tagged and accounted. The Account Analyst will be assisted by an intern to conduct a thorough review to verify and update the status of all assets. Person(s) Responsible for Corrective Measures: Rachel Buswell, Controller, University of Montana - Missoula, Target Date: 09/30/2024

CONDITION: The District did not properly record its federal program expenditures for the ESSER and ARP ESER federal grant programs using the various funding source expenditure codes as prescribed by the Chart of Accounts for PA Local Educational Agencies maintained by the PA Office of the Budget, Office of Comptroller Operations and well as Section 2 CFR 200.302(a) of the Uniform Guidance. CRITERIA: The financial management system of the District must provide for 1) identification in it’s accounts, of all Federal awards received and expended and the Federal programs under which they were received, and 2) accurate, current and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in sections 200.328 and 200.329 of the Uniform Guidance. 74CORRECTIVE ACTION PLAN: The School District concurs with the above noted finding. The School District has employed a new Business Manager whose responsibilities include the oversight of the financial management system and the posting of all transactions into that system. Procedures will be put into place during the remaining months of the 2023-2024 fiscal year, and all subsequent years, for ensuring federal program expenditures are properly coded within the District’s financial management system so as allow for proper reporting related to those expenditures.

2023-007 – Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Finding Summary: Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Significant Deficiency in Internal Control and Instance of Non-Compliance Corrective Action Plan: The city is in the process of updating its Purchasing Policy and will include language on allowable costs and cost principles that are compliant with 2 C.F.R. 200. The Purchasing Policy requires updates at least every five years and will be taken to City Council before the end of 2024 for approval by Resolution. Responsible Individual(s): Lincoln Bogard, Administrative Services Director; A’ja Wallace, Deputy Finance Director; and Barbara Mason, Purchasing Manager Anticipated Completion Date: December 2024

2023-003 - REPORTING Recommendation: We recommend that the Council implement controls and policies and procedures over financial reporting to ensure compliance with federal reporting requirements. Action Taken: The Executive Director will review and approve all financial reporting documents before submission. Since identified in the report, the Fiscal Officer has provided the Executive Director all previous fiscal year 2023 and 2024 financial reports for review and approval, if needed.

CONDITION: The District did not properly record its federal program expenditures for the ESSER and ARP ESSER federal grant programs using the various federal funding source expenditure codes as prescribed by the Chart of Accounts for PA Local Educational Agencies maintained by the PA Office of the Budget, Office of Comptroller Operations. This is a repeat finding (2022-005) from the previous fiscal year. CRITERIA: The Pennsylvania Department of Education (PDE), through the PA Office of the Budget, Office of Comptroller Operations Chart of Accounts requires School Districts to utilize specific funding source codes for federal program expenditures. In addition, Section 2 CFR 200.302(a) and 302(b) of the Uniform Guidance requires non-federal organizations such as the School District to maintain financial records which account for federal funds in such a manner as to be able to properly track the identification and use of federal funds. RECOMMENDATION: I am recommending that the School District properly follow the guidance contained within the PA Office of the Budget, Office of Comptroller Operations Chart of Accounts for recording all expenditures of the School District, most specifically, federal program grant expenditures to 1) enhance internal controls for tracking and monitoring federal program expenditures and 2) comply with the recordkeeping requirements for federal funds as specified in Section 2 CFR Part 200.302(a) and 302(b) of the Uniform Guidance and PDE regulations. MANAGEMENT’S CORRECTIVE ACTION PLAN: District management is in the process of revising its chart of accounts in the general ledger to properly reflect the funding source codes for federal program expenditures, and other available funding source codes (state and local) as applicable to the District. It is anticipated that the updated chart of accounts will be utilized by the District starting with the 2024-2025 fiscal year to enable the District to enhance its internal controls for tracking and monitoring federal program expenditures and to comply with the recordkeeping requirements for federal funds as specified in Section 2 CFR Part 200.302(a) and 302(b) of the Uniform Guidance and PDE regulations.

Management will implement the necessary changes to WHCA's policies and procedures.

Moving to Work Demonstration Program – Assistance Listing No. 14.881 Recommendation: We recommend the Authority review their process and internal controls over HQS inspections to ensure compliance with HUD requirements and their administrative plan. Furthermore, management should ensure no HAP payments are issued for units that have not passed HQS housing inspections. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Housing Choice Voucher department is addressing inspection controls in multiple ways. The Department has added additional staffing and also has created new tracking that makes it easier to review and identify units that have not passed inspection and not been abated. The Department has also instituted an ongoing process that has the inspections manager conducting a monthly review of units moving through the abatement process to ensure timely processing and cessation of HAP payments as needed. As part of this review the Department is also conducting a comprehensive review of units that have prior failed inspections to ensure abatement occurred. Name of the contact person responsible for corrective action: Mark La Brayere Planned completion date for corrective action plan: Three elements are continuous with no final completion date. The singular comprehensive review is scheduled to be completed within three months.

Management agrees with the finding. Our current federal project is substantially completed, however, should the Township receive additional federal grants, the Township will adopt the required written procedures. The anticipated completion date is prior to receiving another federal award.

Responsible Party: JCCS PC & Sara Hudson Anticipated Completion Date: February 29, 2024 Corrective Action Plan: For the fiscal year ending June 30, 2023, the organization prepared a draft of the SEFA with the intent of finalizing it with the assistance of the auditor. We were unaware this would result in a finding in the audit. The organization will work with JCCS PC going forward to independently prepare the annual SEFA.

Additional preventive internal control procedures will be implemented, including an additional level of review of the reimbursement requests prior to submission. These procedures and internal controls have been implemented as of the date of this report.

Views of Responsible Officials: During our FY22 audit, GRF expressly noted that for an organization our size, tracking grant expenses outside of Quickbooks was understandable and acceptable. During this FY23 audit, GRF changed its stance and said we had to report grant expenses in Quickbooks. This should be removed as a finding, as District Bridges was following the advice of GRF from the FY22 audit. It is unconscionable to discredit an organization after they followed the firm's advice. Additionally, over the last few months, we have consulted several other nonprofit finance experts, as well as peer organizations that receive federal funds, to see tracking templates and procedures, and understand best practices. We are currently exploring more robust grant expense tracking softwares based on their recommendations, but they all noted that spreadsheet tracking was acceptable for an organization of our size.

MANAGEMENT WILL WORK WITH THEIR CONSULTANT AND DEVELOP WRITTEN POLICIES AND PROCEDURES OVER THEIR FEDERAL AWARDS IN ACCORDANCE WITH THE REQUIREMENTS OF THE UNIFORM GUIDANCE

Item 2023‐002 Written policies, procedures, and standards of conduct Recommendation: Grantees should have written policies, procedures, and standards of conduct as required by 2 CFR 200, Subparts D & E of the Uniform Guidance. 2 CFR 200, Subparts D & E requires the non‐Federal entity to establish and maintain written policies, procedures, and standards of conduct including internal controls over the Federal awards that provides reasonable assurance that the non‐Federal entity is managing the Federal statutes, regulations, and the terms and conditions of the Federal award. Specific requirements relate to the following: § 200.302 Financial management  § 200.305 Payment  § 200.319 Competition  § 200.320 Methods of procurement to be followed  § 200.430 Compensation—personal services  § 200.431 Compensation—fringe benefits We recommend that the City implement the required written policies and procedures. Action Taken: Management, namely Jan Boutwell, City Clerk, agrees with the finding and will implement the necessary written policies to comply with the UG. Management anticipates completion by September 30, 2024.

The Office of the State Superintendent (OSSE) agrees with the conditions and recommendations of this finding. The OSSE corrective action plan includes the following: • The OCFO budget team will ensure that every budgeted federal award has a corresponding equivalent Federal Notice of Grant Award (NOGA). • Grant reconciliations done to determine carryover balances and subsequent budget modifications will incorporate cash as well as accrued expenditures. • Quarterly financial reviews will be conducted to properly review and support expenditures. • During the year-end close process, the accounting team will compare total awarded amount and total expenditures. Contact - Keith Fletcher, Agency Fiscal Officer, OSSE, Crosby Boyd, Controller, Education Cluster Estimated Completion Date - February 1, 2025 See Corrective Action Plan for chart/table

The Department of Human Services (DHS) OCFO concurs with the finding. Expenditures were inadvertently categorized to the incorrect fund. Moving forward, a meeting will be scheduled with the HSSC Comptroller, the Accounting Officer, the AFO and the Budget Staff for a detailed review and walk through of the SEFA to confirm the expenditures are correctly categorized by fund and grant, and expenditures reconcile to reports from the financial system. Contact - Barbara Roberson, Accounting Officer Estimated Completion Date - September 30, 2024 See Corrective Action Plan for chart/table

Federal Aid Policies Finding 2023-002 Auditor Description of Condition and Effect: The Authority’s management has completely turned over and been restructured. However, the Authority’s policies for federal aid approved in 2021 have not been revised to update for the current management structure. The policies have also not been updated for changes in the 2 CFR 200 that have occurred. As a result, the Authority is noncompliant with 2 CFR 200. Auditor Recommendation: We direct the Authority review and update all federal aid policies and implement procedures to ensure that they are being reviewed at least once a year for changes in the Authority’s management structure or changes that occur in the 2 CFR 200. Corrective Action Plan: The Authority will update their federal policies to comply with 2 CFR 200 and will review all policies on an annual basis going forward. Responsible Official: Contact person is Rufus Adams, Executive Director,275 East Wall Street, P.O. Box 837, Benton Harbor, Michigan 49023. Telephone (269) 927-2268. Due Date: September 30, 2024

2023-005 - Internal Control Over Compliance and Compliance – Reporting (Preparation of the Schedule of Expenditures of Federal Awards) Contact: Jordan Kramer Title: Chief Financial Officer Phone Number: 202-624-7787 Anticipated Completion Date: December 2024 Management’s Corrective Action Plan NGA has begun to produce quarterly versions of the Statement of Federal Awards (SEFA). This routine process has enabled staff to proactively identify new awards and lapsed agreements to keep the SEFA current. Given the importance of this schedule to NGA’s continued management of federal funds, we have emphasized and trained staff to follow all applicable federal requirements when managing funds on this schedule. We expect our action plan to continue until December 2024 as we have encountered several issues this fiscal year that required reconciliation of prior years.

Finding 2023-023 Pandemic EBT Food Benefits, ALN 10.542 - Accuracy of Financial Reports Management Views MDHHS agrees with the finding. Planned Corrective Action The Food and Nutrition Service has ended the P-EBT program and there will be no additional expenses after February 2024. However, for the last report submitted during May 2024, MDHHS implemented a report review process prior to certification to ensure the P-EBT financial report information is accurate. Anticipated Completion Date Completed Responsible Individual(s) Bethany Cabanaw, MDHHS

All Final Expenditure Reports will include the appropriate expenditure amounts associated with the grant year.