Corrective Action Plans

Finding 2022-004 ? Education Stabilization Fund - Reporting Contact Person Responsible for Corrective Action: Scott Miller, Heather Lawson Contact Phone Number: 765-659-1339 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Finding 2022-004 ESSER - we do not have GEER grants - We have reviewed all files of previous Treasurer and Superintendent and did not find documentation. We will make sure going forward that documentation stays with the Grant file at all times in case of staffing changes. Anticipated Completion Date: June 30, 2023

Finding 2022-04 ? Fiscal Management System (Material Weakness) Criteria: CFR Part 200.302.b Auditee Responsibilities includes the requirement that the financial management system of each non-Federal entity provide the following. Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. Accurate, current, and complete disclosure of the financial results of each Federal award or program. Condition: During the audit of Umpqua Public Transportation District for Fiscal Year 2021-2022, the district provided auditor with Separate and Identifiable General Ledger reports that showed a clear division between Federal, State and Local expenditures and revenues. However, the separation was done retroactivity and was not been completed for the entire fiscal year or life of grants. This deficiency was instrumental in causing the general ledger to be inadequate for financial and Federal Award Reporting. Cause: The District had originally relied on unskilled individuals for structuring and recording activities in their general ledger. District management did not have sufficient staff or monitoring policies to recognize and correct the deficiency. While trained staff have been hired at Umpqua Public Transportation District, and improvements made to the general ledger and recording of Federal grants, improvements are still necessary to meet the full requirements of CFR Part 200.302.b Auditee Responsibilities. Effect or Potential Effect: Potential for incorrect financial reporting, and untimely results, with the inability to rely on the general ledger for correct and timely information. Questioned Cost: No Context: While federal grant revenues and expenditures are now tracked using the general ledger ?jobs? indicators, additional recording is needed to track the matching portions of the costs and revenues of those federal grants. The lack of completed effort at separating revenues or expenditures by grant may lead to errors in reporting expenditures for Federal Awards. Repeat of a Prior-Year Finding: Yes, Findings and Questioned Costs 2021-11 Recommendation: We recommend that Umpqua Public Transportation District improve their general ledger structure to meet the requirement for separate accounts for Federal awards for program revenues and program expenditures. We also recommend that the district establish policies and procedures to ensure that all program revenues and expenditures are reported in the correct fiscal year. In addition, we recommend that the district establish a training program and policies and procedures for staff and management to receive appropriate training for administering and recording Federal Grant revenues and expenditures. District's Response: The District concurs with the recommendation. General ledger accounts separating Federal, State, and Local revenues and related expenditures will be designed and implemented. Corrective Action Plan: The District has hired a Finance Manager to oversee the day-to-day financial operations of the district. The Finance Manager has developed an accounting system for separating Federal, State, and Local revenues and related expenditures. This will allow the activities of the district to be recorded in a manner that allows for reporting in compliance with federal requirements. Planned Implementation Date: July 1, 2022 Responsible Person: General Manager, Umpqua Public Transit District

Finding 2022-03 - Source Documentation (Significant Deficiency) CFDA Title and Number: 20.513 (5310) Enhanced Mobility of Seniors and Individuals with Disabilities. Grant Agreement 33573 (City of Reedsport). Name of Federal Agency: Transit Services Program Cluster Internal Control over Compliance: Cash Management CFDA Title and Number: 20.509 (5311) CARES 5311 Operating Assistance. Formula Grants for Rural Areas and Tribal Transit Program. Grant Agreement 34196. Name of Federal Agency: Transit Services Program Cluster Internal Control over Compliance: Cash Management Criteria: 2 CFR Part 200.302(b)(1) The financial management system of each non-federal entity must provide for the following: Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. 200.302(b)(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 200.328 and 200.329. Condition: The District prepared drawdown calculations according to an internal reconciliation spreadsheet tool outside of the General Ledger rather than utilizing proper General Ledger expenditure and supporting backup information. Cause: General ledger reconciling procedures were not enforced or completed. Effect or Potential Effect: Activities or costs that are allowed or allowable could potentially be overpaid or underpaid. Questioned Cost: No Context: During our testing of expenditures, we found no Federal drawdown reimbursement requests selected for testing that did not reconcile to their corresponding expenditures. Repeat of a Prior-Year Finding: Yes, Findings and Questioned Costs 2021-8 Recommendation: The District should establish policies and procedures to ensure that each drawdown is reconciled with supporting expenditure documents and general ledger postings prior to reimbursement being requested. District's Response: The District had relied on inadequately skilled or trained individuals for recording activity in the general ledger. General ledger activity was not available timely, or in sufficient quality such that the General Manager could rely upon the general ledger to gather information for reporting to grantors. Consequently, the General Manager developed and relied upon their own spreadsheet records for grant reimbursement requests. Corrective Action Plan: The District has hired a Finance Manager to oversee the day-to-day financial operations of the District. The Finance Manager has made improvements in the general ledger recording and reporting for federal award requirements, but had not yet been able to eliminate the reliance upon the General Manager?s spreadsheet tool for grant management. The Finance Manager will continue to develop the general ledger procedures such that all necessary federal and state grant reporting requirements will be met within the general ledger. This will allow the activities of the district to be recorded and managed on a timely basis. Planned Implementation Date: July 1, 2022 Responsible Person: General Manager, Umpqua Public Transit District

Finding 2022-02 ? Fiscal Management System, Ensure Compliance with Federal Regulations Over Accounting Systems (Material Weakness) Criteria: Management is responsible for establishing and maintaining effective internal control over financial reporting. Internal controls should allow management or employees in the normal course of performing their assigned functions to prevent or detect material misstatements in the financial reporting of all district funds. The Internal Control ? Integrated Framework, published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) and the U.S. Government Accountability Office Standards for Internal Control in the Federal Government specify that a satisfactory control environment is only effective when there are adequate control activities in place. Effective control activities dictate that a review is performed to verify the accuracy and completeness of financial information reported. The Federal Grant Activity Schedule captures amounts that must be accurate and complete in order to ensure the accuracy of the financial and federal information reported on such schedule to verify the accuracy and completeness of financial information reported. CFR Part 200.302.b Auditee Responsibilities includes the requirement that the financial management system of each non-Federal entity provide the following. Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. Accurate, current, and complete disclosure of the financial results of each Federal award or program. Condition: During the audit of Umpqua Public Transportation District for Fiscal Year 2021-2022, the district provided auditor with Separate and Identifiable General Ledger reports using QuickBooks Jobs feature, that showed identification between individual grant expenditures and revenues. Entries were prepared or recorded using the jobs feature, but not on a timely basis throughout the year, as portions were completed retroactively, and general ledger restated for the entire fiscal year. This deficiency was instrumental in causing the general ledger to be inadequate for financial and Federal Award Reporting for a large portion of the year. Cause: The District had relied on inadequately trained individuals to record activities and setup of their general ledger. The accounting records were retroactively constructed to meet Federal award reporting purposes, but late in the fiscal year. District management did not have sufficient training or monitoring policies to recognize and correct the deficiency. Effect or Potential Effect: Failure to record transactions timely into the general ledger for Umpqua Public Transportation District, and lack of proper accounting structure separating revenues and expenditures into each Federal and State or Local grant may result in transactions not being properly included in the district?s financial statements. The potential for incorrect financial reporting, and untimely results, with the inability to rely on the general ledger for correct and timely information, may also cause misstatement of financial statements, and inappropriate reporting of federal awards. Questioned Cost: No Context: Restatement of the general ledger was necessary for proper reporting of grants for the Schedule of Federal Awards. Tracking of matching local and state grants remains ineffective. Repeat of a Prior-Year Finding: Yes, Financial Statement Findings 2021-4 Recommendation: We recommend that Umpqua Public Transportation District improve their general ledger structure to meet the requirement for separate accounts for Federal awards for program revenues and program expenditures. In addition, we recommend that the district establish policies and procedures to ensure that all required matching of grant expenditures be recorded in sufficient detail tracking to ensure that all matching program revenues and expenditures are reported correctly in the fiscal year. We also recommend that the district continue training program, policies and procedures for staff and management for administering and recording Federal Grant revenues and expenditures. District's Response: The District concurs with the recommendation. General ledger accounts separating Federal, State, and Local revenues and related expenditures will be adhered to and further training implemented. Corrective Action Plan: The District hired a Finance Manager to oversee the day-to-day financial operations of the district. The Finance Manager retroactively created accounting records to separate grant revenues and related expenditures, for both Federal grant records as well as State grant records. The Finance Manager will improve the general ledger to allow the recording of the matching identification for each federal grant. This will allow the activities of the district to be recorded in a manner that allows for reporting in compliance with federal requirements. Planned Implementation Date: July 1, 2022 Responsible Person: General Manager, Umpqua Public Transit District

Planned Corrective Action: In the event of future receipts of Federal Awards, management and the board of directors will work towards developing a Federal Award Policy and Procedure manual. Person Responsible for Corrective Action Plan: Tim Stephens, Executive Director Anticipated Date of Completion: Prior to receipt of additional federal awards.

Finding 2022-003:COVID-19 Education Stabilization Fund, CFDA 84.425U U.S. Department of Education Passed through the Colorado Department of Education Compliance Requirements: Activities Allowed and Unallowed, Allowable Costs/Cost Principles Grant No.: 4414 Type of Finding: Internal Control Over Compliance (material weakness) and Compliance (material noncompliance) Recommendation: The District should strengthen its internal controls with adopted policies and procedures to include a review of reimbursement requests to ensure indirect costs are allowable and adequate source documentation is maintained for federally-funded activities. Action Taken: Adequate documentation will be maintained to support the calculations of the indirect costs and any other costs associated with ESSER funding. If the U.S. Department of Education has questions regarding this plan, please call the responsible party listed below. Sincerely yours, Jeff Bollinger Superintendent Mountain Valley School District RE-1 Lisa DuPont Co-Business Manager Mountain Valley School District RE-1 Rebecca Quintana Co-Business Manager Mountain Valley School District RE-1

Finding 2022-03: Allowed and unallowed costs. District Response: A. Federal budgets will be reviewed on a monthly basis and revised as needed. B. Kim Hamm: Federal Programs Director and Julie Clark: Special Services Director C. July 1, 2023

Contact Person Responsible for Corrective Action: Michelle Keene Contact Phone Number: (812) 384-4386 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Schedule of Expenditures of Federal Awards will include all Federal Awards. The SEFA will be verified with a sign-off by the Superintendent and compared to the supporting funds ledger. Anticipated Completion Date: FY23 SEFA

FINDING 2022-003 Contact Person Responsible for Corrective Action: Jason R. Watson, Assistant Superintendent Contact Phone Number: O?ce 812-866-6244 Cell: 812-599-0627 Contact Email: jwatson@swjcs.us Views of Responsible O?cial: We concur with this audit finding. Description of Corrective Action Plan: Action taken in an e?ort to remedy finding 2022-003 includes, but is not limited to, the following: ? Beginning December 27, 2022, an e?ective internal control system was implemented related to grant agreement and the reporting compliance requirements. ? The Assistant Superintendent prepares and formats the data for required reporting. ? The prepared and formatted data, and supporting documentation is shared via a DocuSign Envelope to be reviewed for accuracy. ? The DocuSign Envelope is routed to the Treasurer for the initial review. His/her eSignature indicates its completion. ? It is then routed to the Deputy Treasurer for a second review. His/her eSignature indicates its completion. ? The DocuSign envelope is then routed back to the Assistant Superintendent for submission, barring any required corrections. ? In the event that corrections to the report are required, the Assistant Superintendent?s eSignature in the appropriate location indicates that corrections are needed prior to submission. ? A second DocuSign Envelope, with the needed corrections, is then generated and proceeds through the process again. ? When the report is o?cially submitted, the Assistant Superintendent indicates its completion by eSignature in the appropriate location. ? The Superintendent monitors the internal controls by confirming that both the Treasurer and Deputy Treasurer have completed their review and indicates as such via eSignatures. ? The Chief Financial O?cer receives a carbon copy of the completed DocuSign Envelope. Anticipated Completion Date: December?27,?2022?

FINDING 2022-009 Contact Person Responsible for Corrective Action: Kasey Clark Contact Phone Number: 574-772-1604 Views of Responsible Official: We concur with the findings Description of Corrective Action Plan: Internal controls will be in place for ESSER funds so that Treasurer and Superintendent or Title I specialist will sign off on annual reports to ensure accuracy of ESSER dollars spent. Anticipated Completion Date: March 2023

FINDING 2022-006 Contact Person Responsible for Corrective Action: Kasey Clark Contact Phone Number: 574-772-1604 Views of Responsible Official: We concur with the findings Description of Corrective Action Plan: We will take the set aside amount and make a specific line in the financial software and report the amount that is needed as needed to be reported. The Treasurer will prepare the final expenditure report and the Title I Specialist will review the report to ensure the set asides are accurately reported. Anticipated Completion Date: March 2023

Department: Defense, Veterans and Emergency Management Title: Internal control over DG ? PA program cash management needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Maine Emergency Management Agency (MEMA) and the Security and Employment Service Center (SESC) will work jointly to develop and implement a cash management procedure that meets the Federal and State requirements. MEMA and SESC will seek technical assistance as appropriate. Completion Date: June 30, 2023 Agency Contact: Joe Legee, Deputy Director, MEMA, 207-624-4400

Department: Administrative and Financial Services Title: Internal control over Child Support Enforcement expenditures needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Division of Support Enforcement and Recovery and the Judicial Branch will revisit and modify the terms and language of the cooperative agreement to help clarify that all allowable costs subject to federal financial participation are adequately and timely documented. Completion Date: June 1, 2023 Agency Contact: Jerry Joy, Director, Division of Support Enforcement and Recovery, DHHS, 207- 624-6985

Department: Administrative and Financial Services Title: Internal control over TANF reporting needs improvement Questioned Costs: None Status: Corrective action is completed Corrective Action: Effective April 1, 2022, US Department of Health and Human Services grant recipients are no longer required to complete the quarterly Federal Cash Transaction Report "FCTR" (also referred to as the FFR-425 or SF-425) to report cumulative Federal cash disbursements. Procedures are currently in place to ensure Federal financial reporting is reviewed accurately. Completion Date: April 1, 2022 Agency Contact: Sarah Gove, Director, DHHS Service Center, DAFS, 207-458-6626

Department: Administrative and Financial Services Title: Internal control over ICA program cash management needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The DHHS Financial Service Center will reconcile daily files for the Immunization grants from 2021 to present. Completion Date: December 31, 2023 Agency Contact: Sarah Gove, Director, DHHS Service Center, DAFS, 207-458-6626

FINDING 2022-006 Contact Person Responsible for Corrective Action: Schauna Relue Contact Phone Number: 260-665-2854 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The ESSER reports requested by IDOE will follow the same procedures of all FER reports. The ?data collection? for the ESSER grants was not identified as a financial report, and thus did not follow these processes. Now that we know this is a financial report, the steps below will be followed. The grant was initially not set up correctly and expenses were expended to and then transferred to the correct accounts once the grants were set up correctly. These changes were in flux when the report was requested, so what was reported at the time of the report is no longer what is reflected in grants? ledgers. The corrective action will require that the program director gathers the initial data, the data will be reviewed by the administrative assistant to the grants? director, and then reviewed by the Treasurer. All three employees will sign/initial a printed copy of the report before it is submitted. Data regarding students served by programs and staff reports will be reviewed by the program director and the data specialist and signed off on by both parties to ensure accuracy. Anticipated Completion Date: Effective Immediately; Completion will occur when the next report is requested.

Department: Labor Administrative and Financial Services Title: Internal control over CSLFRF expenditures needs improvement Questioned Costs: Known: $51,482,644 Likely: $51,482,644 Status: Management?s opinion is that corrective action is not required Corrective Action: We disagree with this finding. Likewise, we are unable to determine why the auditor has identified a questioned cost or includes a recommendation that only allowable costs are funded by CSLFRF. The transfer of $80 million to the Unemployment Trust Fund is completely allowable, with a portion categorized under the Public Health and Economic Impacts use category and a portion under the Revenue Loss - Provision of Government Services use category. All documentation to support the allowability of this transfer was provided to the auditor for review. There were errors in the original calculation of the total amount eligible under the Public Health and Economic Impacts category; however, we provided documentation to support that the total amount was eligible under the Revenue Loss - Provision of Government Services use category. Although we have identified a weakness in internal control over compliance, there was no actual noncompliance. Consequently, there is no cost that is considered unallowable; therefore, there should be no questioned cost. Completion Date: N/A Agency Contact: DOL Contact: Kimberly Smith, Deputy Commissioner, Department of Labor, 207-621-5096 DAFS Contact: Frank Wiltuck, Director of Internal Audit, OSC, 207-626-8420

Department: Health and Human Services Administrative and Financial Services Title: Internal control over WIC cash balances needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Department will finalize the reconciliations and take the necessary steps to put the cash balances where they belong. Completion Date: December 31, 2023 Agency Contact: Sarah Gove, Director, DHHS Service Center, DAFS, 207-458-6626

CORRECTIVE ACTION PLAN FINDING 2022-002 Contact Person Responsible for Corrective Action: Tamara Swartzentruber, Treasurer Contact Phone Number: 812-486-3220 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Treasurer has worked with management and will implement better controls when preparing the Annual Data Report on the COVID-19 Education Stabilization Fund. We will work to get the report reviewed and submitted on the correct due date. Anticipated Completion Date: April 2023

We agree with the finding, This was due to the modification of assistance listing number for two awards. We will strengthen our controls for review of all grant documents before issuing the SEFA report.

Bishop Museum Corrective Action Plan Fiscal Year Ended June 30, 2022 The following finding was cited in the single audit for the Bishop Museum for the period ending June 30, 2022: Finding 2022-001: Criteria - 2 CFR 200.302{b)(l) of the Uniform Guidance states that a nonfederal entity must identify in its accounts all federal awards received and expended, as well as the federal programs under which they are received, and those amounts must be accurately and completely reported on the SEFA. Condition - During the audit, for the year ended June 30, 2022, expenditures of federal awards for certain programs was not included in the SEFA provided by the Museum. The SEFA was subsequently corrected and one of the federal programs was identified to be a major federal award program. Cause - The funds received and the federal expenditures for the programs were not recorded in the Museum's general ledger in the same manner as the other federal programs, and therefore, the funds expended were not identified and reported on the SEFA. Effect or Potential Effect -A federal program that should have been identified as a major program would not have been included on the SEFA and not subjected to the required audit procedures. Recommendation - All expenditures of federal awards should be recorded in the general ledger in a consistent manner such that the expenditures can be readily identified in preparing the SEFA. Action Plan: Bishop Museum will revise its Budget Center Account form to incorporate and identify all federal funded activities, This revision will eliminate human error of omission. This Budget Center Account form is used to create new distribution codes within the MIP accounting system. Currently this form does not have a line item to specifically address certain critical information that is included in the Schedule of Expenditures of Federal Awards {SEFA). The revision will entail the following additional information to be added in the form and in MIP accounting software. ? Assistance Listing Number {ALN) or Catalog of Federal Domestic Assistance {CFDA) ? Federal Award Identification Number (FAIN) ? Dates of Project ? List of Fiscal Years impacted by the Dates of Project ? Total award amount Following the revisions, current personnel involved in creating the new distribution codes should ensure that the additional information mentioned above is included. These five new, critical line items will aid in the development of the SEFA list each fiscal year, and eliminate human error of omission. Responsible Party: Tracie Mackenzie, Research and Collections Grants and Office Manager tracie@bishopmuseum.org (808) 262-3325 Bernajet Salvanera, Director of Accounting Bernajet.salvanera@bishopmuseum.org (808) 847-8274 Implementation: The use of the revised form and adding the additional information in MIP will be implemented starting July 1, 2023 and it will be an ongoing procedure.

2022-002 - The corrective action plan was documented in our response to the auditor's comment. See the Schedule of Findings and Questioned Costs. Mark Vasina Director of Finance 402-878-3341 June 30, 2023

Item 2022-001 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 Board implement the required written policies and procedures. Action Taken: The Board?s management, namely Stacey Parker, CFO and General Manager, acknowledges the finding and will implement the necessary written policies to comply with the UG. Management anticipates completion by September 30, 2023. Audit finding 2022-001 relates to prior year 2021-001 finding. Updated reference number to current audit year 2022.

FINDING 2022-002 (Auditor Assigned Reference Number) Contact Person Responsible for Corrective Action: Micah Williams Contact Phone Number: 765-832-2426 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Director of Finance and Facilities and Payroll Personnel Director will work together to confirm the information to be submitted in regards to the ESSER/GEER Funds. Both will sign off on the information. The information will then be reviewed by the Director of Curriculum and Superintendent to ensure that the reporting is accurate. Additionally, one of those individuals will sign off on the reporting. Anticipated Completion Date: Implemented Immediately

Finding 2022-002 ? Education Stabilization Fund ? Reporting Contact Person Responsible for Corrective Action: Kylie Enochs Contact Phone Number: (812) 659-1424 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Moving forward with the corporation?s ESF reporting, all data will be reviewed and have a formal sign-off, either by the superintendent or the other co-treasurer to ensure all data being reported is accurate. NOTE: The treasurer was in her first month in her position and was not a part of this filing. Moving forward, we are adjusting personnel to put the treasurer into the internal controls loop of the Title 1 program (which was responsible for filing the first ESF report. Anticipated Completion Date: Effective Immediately