Corrective Action Plans

Finding 2023‐002 Finding Subject: COVID‐19 ‐ Education Stabilization Fund ‐ Reporting Summary of Finding: The School Corporation was required to submit an annual data report to the Indiana Department of Education (IDOE) via JotForm, a form/report builder. Data to be submitted included, but was not limited to, current period expenditures, prior period expenditures, and expenditures per activity. The School Corporation submitted two reports during the audit period; however, a single employee prepared and submitted the reports without evidence of a review or oversight process in place to prevent or detect and correct errors for the first report submission. Additionally, for the ESSER I Year 2 reporting, the ‘Total Mandatory Subgrant Amount Expended in Current Reporting Period’ was not supported by the School Corporation's records. Actual expenditures from a provided report did not agree to the amount submitted for the Annual Performance Reporting. The key line item ‘Total Mandatory Subgrant Amount Expended in Current Reporting Period’ for the ESSER I Year 2 report was determined to be overstated by $80,342. Contact Person Responsible for Corrective Action: Whitney Kuszmaul, District Treasurer & Tiffany Grant, Grant Coordinator Contact Phone Number and Email Address: (765) 342‐6641 Whitney.Kuszmaul@msdmartinsville.org & Tiffany.Grant@msdmartinsville.org Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Grant Coordinator works to collect the data from a couple different sources. The staff report information comes from our Payroll/HR department, the CE information comes from our Reporting Specialist and the financial data comes from District Treasurer. The Grant Coordinator requests a detailed report for the appropriate period and break down the detailed report by project/report categories. All of this information is then recorded in the DOE data sheet and is reviewed and tied back to the detailed reports provided by the District Treasurer. After review, the Grant Coordinator and the District Treasurer initial/sign off on the DOE data sheets. The Jot Form confirmation is retained with the DOE data sheets and supporting reports/documentation. Anticipated Completion Date: February 2024

The City agrees with the finding. The Treasury Portal automatically fills in the amounts for revenue loss for 2022 with amounts reported in 2020. The Treasury portal has many flaws that would cause errors in reporting. In addition, the portal has changed every quarter, which makes it challenging to report accurately. The City will implement controls to ensure that a second review is completed prior to certification of the report. Additionally, the Grant Administrator will work with department staff responsible for reporting and ensure that each report's supporting documentation is complete and ties to underlying subrecipient reports, the general ledger and grantor reports. All supporting documentation, along with a copy of the submitted report, will be stored in a central location to ensure that they are available for subsequent reviews and audits. This will be completed by June 30, 2024.

REPORTING Department of Environmental Protection (DEP) Assistance Listing Number 15.252 Effective March 2024, DEP will implement the following steps to correct the finding: 1. Review the Office of Surface Mining Federal Assistance Manual for information and instructions in regard to preparing the required financial reports for periodic and annual submissions. The information obtained from the Federal Assistance Manual will be compared to 2 CFR 200.328 and 329 to ensure all required information is included in the financial reports. 2. Review the Federal Notice of Grant Award documents to ensure that reporting period dates and the submitted reports reconcile and are in agreement. 3. Create and implement written narrative that agrees with the requirements set forth in the Federal Assistance Manual. 4. Develop and implement standard operating procedures to ensure timely, accurate reporting that involves a review and approval process prior to submission. 5. Create a checklist of required items, and signature lines to show that reviews/approvals have taken place.

FINDING 2023-006 Subject: COVID-19 – Education Stabilization Fund – Reporting Summary of Finding: The School Corporation did not submit annual reports in a timely manner during the first year of the audit period. Reimbursement requests included invoices which had been reimbursed previously and some request did not agree with supporting documentation. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure reports are submitted timely and supporting documentation is used and retained for reimbursement requests. Contact Person Responsible for Corrective Action: Casey Howard Contact Phone Number: 574-842-3364 x806 Views of the Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Reporting – The Treasurer and Deputy Treasurer will review and approve all grant reporting with Komputrol reports and grant approval. All deadlines will be submitted prior to due dates. The Superintendent, Treasurer, Deputy-Treasurer and/or Grant Writer will review all grant reimbursement requests prior to submission for accuracy. Anticipated Completion Date: Completed March 2023 – February 2024 INDIANA STATE

FINDING 2023-002 Finding Subject: Subject: COVID-19 - Education Stabilization Fund - Reporting Summary of Finding: Reports submitted were not substantiated by the ledgers. Contact Person Responsible for Corrective Action: Kellie Romer (Corporation Treasurer/Finance Director) Contact Phone Number and Email Address: 765-653-9771 Ext. 1010, kromer@greencastle.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: The school corporation will establish a proper system for internal controls and develop procedures to ensure reports are supported by the financial records. Anticipated Completion Date: Immediately 2/8/2024

Reconciliations and Material Adjustments Corrective Action Plan Umatilla Morrow Head Start, Inc. (UMHS, Inc.) partnered with an independent accounting firm to streamline processes and develop templates for year-end closure. The agency used this opportunity to increase knowledge and understanding of needs associated with this task. As the fiscal department moves forward, systems and tools have been implemented to ensure timely closing and accurate tracking of this process. UMHS will continue to utilize the checklists put in place last fiscal year to guide month-end processes and reconciliations. Fiscal Management will review, monthly, the completion of said duties and will address any issues with staff immediately. Ongoing training will be done to ensure all fiscal staff members understand their role and duties within the agency. Bank reconciliations will continue to be completed monthly. The Executive Director, Director of Finance, Treasurer of the Board of Directors, or Other Designee will review the information and approval will be documented. UMHS will focus on segregation of duties within the fiscal department and ensure proper documentation is maintained. Person(s) Responsible: Executive Director, Director of Finance, Treasurer of the Board of Directors, or Other Designee Timing for Implementation: Immediately and Ongoing Reconciliations and Material Adjustments Corrective Action Plan Umatilla Morrow Head Start, Inc. (UMHS, Inc.) partnered with an independent accounting firm to streamline processes and develop templates for year-end closure. The agency used this opportunity to increase knowledge and understanding of needs associated with this task. As the fiscal department moves forward, systems and tools have been implemented to ensure timely closing and accurate tracking of this process. UMHS will continue to utilize the checklists put in place last fiscal year to guide month-end processes and reconciliations. Fiscal Management will review, monthly, the completion of said duties and will address any issues with staff immediately. Ongoing training will be done to ensure all fiscal staff members understand their role and duties within the agency. Bank reconciliations will continue to be completed monthly. The Executive Director, Director of Finance, Treasurer of the Board of Directors, or Other Designee will review the information and approval will be documented. UMHS will focus on segregation of duties within the fiscal department and ensure proper documentation is maintained. Person(s) Responsible: Executive Director, Director of Finance, Treasurer of the Board of Directors, or Other Designee Timing for Implementation: Immediately and Ongoing Reconciliations and Material Adjustments Corrective Action Plan Umatilla Morrow Head Start, Inc. (UMHS, Inc.) partnered with an independent accounting firm to streamline processes and develop templates for year-end closure. The agency used this opportunity to increase knowledge and understanding of needs associated with this task. As the fiscal department moves forward, systems and tools have been implemented to ensure timely closing and accurate tracking of this process. UMHS will continue to utilize the checklists put in place last fiscal year to guide month-end processes and reconciliations. Fiscal Management will review, monthly, the completion of said duties and will address any issues with staff immediately. Ongoing training will be done to ensure all fiscal staff members understand their role and duties within the agency. Bank reconciliations will continue to be completed monthly. The Executive Director, Director of Finance, Treasurer of the Board of Directors, or Other Designee will review the information and approval will be documented. UMHS will focus on segregation of duties within the fiscal department and ensure proper documentation is maintained. Person(s) Responsible: Executive Director, Director of Finance, Treasurer of the Board of Directors, or Other Designee Timing for Implementation: Immediately and Ongoing

FINDING 2023-002 Finding Subject: COVID-19 – Education Stabilization Fund - Reporting Summary of Finding: The School Corporation had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance. The School Corporation was required to submit annual data reports to the Indiana Department of Education (IDOE) via JotForm, a form/report builder. Data to be submitted included, but was not limited to, current period expenditures, prior period expenditures, and expenditures per activity. During the audit period the School Corporation submitted two ESSER I reports, two ESSER II reports and two ESSER III reports, for a total of six reports. The annual data reports were complied, prepared and submitted by the Assistant Superintendent without an oversight or review process in place to prevent, or detect and correct, errors. Furthermore, the reported data on two of the reports could not be traced back to records that accumulate or summarize the data; therefore, the accuracy and completeness of the reports could not be verified. Contact Person Responsible for Corrective Action: Jim Diagostino, Superintendent, and Lori Bennett, Treasurer Contact Phone Number: 317-539-9200 Views of Responsible Officials: We agree with the finding. Description of Corrective Action Plan: The Superintendent, or designee, will prepare the annual data reports to be reported to the IDOE by using records that accumulate or summarize the data. Prior to the submission of the reports, the Treasurer will review the records and annual data report. The Treasurer will initial and date a hard copy of the report to ensure accuracy and completeness. Anticipated Completion Date: March 31, 2024

Recommendation: One City Schools, Inc. should design and implement appropriate internal controls for retaining support for claims in accordance with federal requireents. Action Taken: One City Schools has developed a new process to document meal counts per month, attendance and enrollment numbers per month, submission of claims, and the signature of a designated second approver, the COO. As each claim is made, the associated backup documentation will be presented to the second approver for their review and signature. Once approved, the entire packet of information will be retained. This process was initiated in December 2023.OCS completed the second designated approver review retroactively for all claims in the months of July, September, October, and November 2023.

Recommendation: Additional training should be provided to individuals responsible for the development of written policies and procedures in accordance with the Uniform Guidance. Action Taken: One City Schools is in the process of identifying a required training program for all staff members involved in the submission, review and/or approval of the schedule of expenditures of federal awards. This includes One City’s Executive Chef, Executive Director of K-8, COO and VP of Government Relations (who oversees compliance). Designated staff will take advantage of all DPI-provided training seminars and resources available, and we will track attendance of relevant staff members. This process will be in place by June, 2024.

Finding Number: 2023‐008 Federal Program, Assistance Listing Number and Name: ALN 14.241, Department of Department of Housing and Urban Development, Housing Opportunities for Persons with AIDS (HOPWA) and COVID‐19 HOPWA Condition: Original Finding Description: The controls in place were not adequate to ensure that amounts reported within the CAPER were accurate and complete in relation to activity reported in the general ledger and underlying records of the City. Contact Person Responsible for Corrective Action: Regina Greear (ODFS), Cynthia Saxton (OGA) and Julie Schneider (HRD) Anticipated Completion Date: June 2023 Planned Corrective Action: The City will review during the AFCAP process and implement additional reporting controls that includes verification of expenditures, retention of supporting documentation and a timely final reconciliation of the CAPER Report to the general ledger.

Condition: During compliance testing of the District's accounting records to the expenditure report filed with the Illinois State Board of Education, we noted the District overclaimed $4,000 of expenditures at 6/30/23. Plan: The District will review its policies and procedures and implement changes to strengthen internal control over federal reporting. Furthermore, the District will adequately document claimed expenditures that are consistent with the terms and conditions of each grant agreement. Anticipated Date of Completion: 6/30/2024. Name of Contact Person: Dr. Anita Rice, Superintendent. Management Response: The District is currently strengthening internal control procedures over grant reporting and monitoring.

Condition: During compliance testing of the District's accounting records to the expenditure report filed with the Illinois State Board of Education, we noted the District overclaimed $516 of expenditures at 6/30/23. Plan: The District will review its policies and procedures and implement changes to strengthen internal control over federal reporting. Furthermore, the District will adequately document claimed expenditures that are consistent with the terms and conditions of each grant agreement. Anticipated Date of Completion: 6/30/2024. Name of Contact Person: Dr. Anita Rice, Superintendent. Management Response: The District is currently strengthening internal control procedures over grant reporting and monitoring.

Finding Number: 2023-001 Planned Corrective Action: The Dayton Early College Academy will comply with all federal grant compliance requirements – including reporting requirements and deadlines. Anticipated Completion Date: 07/01/2023 Responsible Contact Person: Steven Hinshaw, Treasurer

Contact: Reginald Gregory Title: Executive Director/Controller Phone Number: 202-772-4300 Estimated completion date: June 30, 2024 Corrective Action: Management will continue to stress the importance of following the detailed procedures for preparation and review of the SEFA. Responsibility for compiling the SEFA was assigned to a Senior Program Accounting Manager who is tasked with assuring the SEFA and all support reconciliation are complete and accurate. Both the Director of Program Accounting and the Executive Director of Finance/Controller will review the SEFA for completeness, accuracy, and compliance with CFR Section §200.510(b).

FINDINGS – FEDERAL AWARD PROGRAMS AUDIT U.S. Department of Education Passed Through Kansas State Department of Education Program Name: Education Stabilization Fund Cluster Federal Assistance Listing Numbers: 84.425W, 84.425U, 84.425D Finding 2023-001 Recommendations: The District should have an employee compare the Board Clerk’s supporting documentation and the Education Stabilization Fund spreadsheet report before its submission to the State of Kansas for its accuracy. After the approval by the secondary review employee, the report submitted should be printed, initialed by the secondary reviewer, stapled with the information used to compile the report and combined with all financial records for the fiscal year. Action Taken: We agree with the recommendation. Our targeted implementation date is March 2024. If the Kansas State Department of Education and/or Kansas State Department of Administration has questions regarding this plan, please call Rex Richardson at 620-675-2277.

Condition: During compliance testing of the District's accounting records to the expenditure report filed with the Illinois State Board of Education, we noted the District overclaimed $134,309 of expenditures at 6/30/23. Plan: The District will review its policies and procedures and implement changes to strengthen internal control over federal reporting. Furthermore, the District will adequately document claimed expenditures that are consistent with the terms and conditions of each grant agreement. Anticipated Date of Completion: 6/30/2024 Name of Contact Person: Dr. Dwayne E. Evans, Superintendent of Schools Management Response: The District is currently strengthening internal control procedures over grant reporting and monitoring.

1. Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. 2. Action Planned in Response to Finding The Academy will adopt the referenced policies to achieve compliance with Uniform Guidance. 3. Official Responsible Samuel Yigzaw, Executive Director, is the official responsible for ensuring corrective action. 4. Planned Completion Date June 30, 2024 5. Plan to Monitor Completion The Board of Education will be monitoring this Corrective Plan.

This finding is a result of a) staff changes that occurred throughout the year without an adequate training and transition strategy, b) a lack of sufficiently detailed written procedures, and c) a lack of resources to adequately review staff work and provide feedback. Status/timeline: This is amongst the first areas that will be addressed by our fee accountant. Enhanced policies and procedures to be written within 30 days of fee accountant start date. The Directof Finance and Accounting along with the fee accountant will help ensure procedures are being followed with proper supporting documentation provided for each draw.

2023-002 Compliance and Internal Controls over Allowable Costs (Significant Deficiency) Assistance Listing Number 21.027 COVID-19 Coronavirus State and Local Fiscal Recovery Funds 2022-2023 Funding U.S. Department of Treasury Recommendation: The Agency should update its payroll allocation spreadsheets to agree with the approved timesheets per payroll period to ensure only allowable payroll costs are charged to grants. Corrective Action: The Agency had a turnover of finance staff in 2022-23 that created an inconsistent review of the allocation spreadsheet. The Agency did not receive reimbursements from any grantor due to an error in the allocation calculations. The allocation spreadsheet and timesheets will be reconciled as part of the monthly close. Responsible Party: Senior Accountant and Director of Human Resources Date Expected to be Corrected: Immediately If the U.S. Department of Treasury and U.S. Department of Veteran Affairs have any questions regarding this plan, please contact Nkechi “Nikki” Agwuenu, new CEO, at 713.754.7083

2023-002 Compliance and Internal Controls over Allowable Costs (Significant Deficiency) Assistance Listing Number 64.033 VA Supportive Services for Veteran Families, VA Supportive Services for Veteran Families – Shallow Subsidy, and VA Supportive Services for Veteran Families – Legal Services 2021-2022 and 2022-2023 Funding U.S. Department of Veteran Affairs Recommendation: The Agency should update its payroll allocation spreadsheets to agree with the approved timesheets per payroll period to ensure only allowable payroll costs are charged to grants. Corrective Action: The Agency had a turnover of finance staff in 2022-23 that created an inconsistent review of the allocation spreadsheet. CRR did not receive reimbursements from any grantor due to an error in the allocation calculations. The allocation spreadsheet and timesheets will be reconciled as part of the monthly close. Responsible Party: Senior Accountant and Director of Human Resources Date Expected to be Corrected: Immediately If the U.S. Department of Treasury and U.S. Department of Veteran Affairs have any questions regarding this plan, please contact Nkechi “Nikki” Agwuenu, new CEO, at 713.754.7083

Recommendation: We recommend that the Authority implements a control to ensure that the preliminary SEFA is mostly accurate so that the correct programs are tested. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: In order to facilitate timely and accurate preparation of the SEFA for the Harris County Housing Authority (HCHA) March 31 fiscal year end, a reconciliation of pass-thru revenues in the general ledger will be performed. In addition, HCHA will make sure to include grant-specific coding in the charts of accounts in order to identify specific and eligible items. The HCHA will also review grants included in the previous year’s SEFA to determine if they should be included in the current year SEFA. In situations where expenditures reported in the SEFA are not the same as the expenditures reported in the general ledger (due to outstanding loan balances, timing of grant awards, expenditures incurred in a prior period, etc.), a reconciliation will be provided to the as notes to the SEFA. Name(s) of the contact person(s) responsible for corrective action: Melissa Quijano, Executive Director Planned completion date for corrective action plan: March 31, 2024

Finding 2023-001 Federal Agency Name: US Department of Health & Human Services, California Department of Social Services Program Name: Child Care and Development Fund Cluster CFDA #93.575 Finding Summary: The Commission has not established written procedures for determining allowability of costs in accordance with Subpart E- Cost principles or the conditions of the Federal award. Responsible Individuals: Debora Dickerson-Sims, Chief Financial Officer Corrective Action Plan: Review current policies and procedures to revise or develop new procedures for determining allowability of costs in accordance with Subpart E – Cost principles or the conditions of the Federal award. Anticipated Completion Date: June 30, 2024

The Hannibal School District received millions of one-time federal grant monies to assist with expenditures incurred as a result of the effects of the coronavirus pandemic. Although these funds were hugely helpful, minimal guidance was available. This is not a finding that has been presented to us in the past. The school district has received federal and state grants annually that are reconciled to the appropriate project codes and this process will be diligently followed as in prior years. For example, the district was awarded the Immediate Responses Services grant in Fall 2023. The expenditure project codes for this grant have been provided by grant guidance and any and all expenditures will be coded using these expenditures codes. This should prevent any need for future journal entries moving forward. This process is an example of the systematic process that will be followed for all grants.

This following is submitted as our management response to the audit finding regarding Allowable Costs Reporting in the District’s FY23 Audit. At the close of Fiscal Year 2023, the District submitted a payment request for federal ESSER reimbursement, encompassing eligible employee expenses spanning multiple years in accordance with ESSER guidelines. However, an administrative oversight became apparent, as the expense codes and ASBRs for the relevant years had not been amended to align with the represented expenditures. To address this, the District is undertaking a meticulous correction process through adjusting journal entries. This corrective action will ensure that the expense codes accurately reflect the corresponding project codes and Fiscal Year expenditures. Simultaneously, the ASBRs for the affected years will be resubmitted, aligning with the requisite financial standards. Looking ahead, the District is instituting a proactive measure to prevent recurrence. The superintendent, or a designated district representative, will verify that the District's accounting software records, as compiled by the District Bookkeeper, impeccably mirror the accurate totals for expense codes, incorporating the requisite accounting codes, including project codes. This validation will be a prerequisite before any future reimbursement request for federal funds is submitted, ensuring a heightened level of precision and compliance in financial reporting. These measures underscore the District's commitment to fiscal accountability, rectifying oversights, and fortifying internal controls to uphold the integrity of financial processes. The district will begin immediately implementing the revised proactive measures and is in the process of rectifying the noted issues with corrective journal entries. This process will be updated prior to January 15, 2024. Should you need anything further from the district, please do not hesitate to contact me.

Background: One repeat finding from the 2022 fiscal year audit was identified on the Schedule of Expenditures and Federal Awards during 2023 fiscal year end audit conducted by Aldrich CPAs + Advisors LLP (Aldrich). For fiscal year 2022, Aldrich performed an audit on the major program Disaster Grants – Public Assistance (Presidentially Declared Disasters) for the monies received from the Department of Homeland Security passed through the Oregon Office of Emergency Management awarded to the City for the February 2021 Ice Storm. Management recognizes the importance of adequate procedures and internal control oversight and has rectified this finding. Management’s response and corrective plan of action for the finding follows. Finding 2023-001: 21.027 Coronavirus State and Local Fiscal Recovery Funds Criteria: 2 CFR Part 200.302(b)(7) requires the financial management system to include written procedures for determining the allowability of costs. Condition: City of Oregon City has not developed written procedures for determining the allowability of costs. Cause: Administration did not have written procedures for determining the allowability of costs. Effect: Unallowable costs could be charged to the program. Questioned Costs: None   Perspective: Written procedures for determining the allowability of costs is integral to the proper design of internal controls. However, the results of audit procedures did not detect any costs which are not allowable charged to the program. Recommendations: Management should develop written procedures as required by 2 CFR Part 200.302(b)(7). Responsible Official: Matt Zook, Finance Director Views of Responsible Officials: Management understands the requirement for written procedures for determining the allowability of costs. A formal policy and procedure was approved and adopted August 22, 2023. The opportunity to identify this finding arose due to new management staff and a new audit firm engage with the June 30, 2022 audit, and we appreciate the opportunity to improve compliance.