Corrective Action Plans

FINDING 2022-005Contact Person Responsible for Corrective Action: Lynn Leininger, Business ManagerContact Phone Number: (260) 367-3677Whitko Community Schools concurs with the finding and will implement internal controls for all grantrequirements and reporting compliances of the Education Stabilization Funds. All reporting will be a jointeffort between the Business Manager preparing the reports with the assistance of the business officepersonnel. Supporting paperwork and calculations will be maintained to support all report informationsubmitted. Prior to submission of Education Stabilization Funds, all information will be reviewed andsigned by the Deputy Treasurer to insure reporting compliance.The completion date for this corrective action will be May1, 2023.INDIANA STATE

Finding Number: 2022-002Planned Corrective Action: Cleveland Play House had extensive turnover during the 2022 fiscal yearwhich resulted in several vacancies, including the Director of Finance position, for a significant portion ofthe year. As a result, many of the reports that are standard practice in our organization were not beingcompleted. In addition, the filing of certain documentation to support expenditures was not being doneconsistently. The Director of Finance position was filled in the fall of 2022. As a result, documentationof allowable expenditures is being addressed for the fiscal 2023 audit.In addition to turnover, the organization transitioned to a new general ledger system with a new chartof accounts in fiscal year 2022. As a result of this transition and the vacancies mentioned above, certaindata pertaining to the federal programs was not being captured. Management has informed all staff ofthe requirements to track federal programs within the general ledger accounts.Anticipated Completion Date: June 30, 2023Responsible Contact Person: Erica Tkachyk, Director of Finance

FINDING 2022-005Contact Person Responsible for Corrective Action: William LutherContact Phone Number: (812) 330-7700Views of Responsible Official: We concur with this finding. This finding has been remediated as of the completion dateshown below.Description of Corrective Action Plan:All Education Stabilization Funds applicable to the reporting in this finding have been expended as of the completion datebelow. We will continue to submit all future Education Stabilization Funds annual reports with evidence to support thesubmission.Completion Date: September 30, 2022

FINDING 2022-010Subject: COVID -19 - Education Stabilization Funding - ReportingFederal Agency: Department of EducationFederal Program: Education Stabilization FundAssistance Listings Numbers: 84.425D, 84.425UFederal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013,S425U200013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: ReportingAudit Findings: Material Weakness, Modified OpinionContact Person Responsible for Corrective Action: Chad Yencer, SuperintendentContact Phone Number: 76+5-348-7550Views of Responsible Official: We concur with this findingDescription of Corrective Action Plan:Internal Control:1. The grants specialist/data specialist will compile the information for state reporting in the ESSER grants.The grants specialist will maintain documentation to support the data being presented.2. The corporation treasure will review all compiled financial data for the reporting period and verify it foraccuracy prior to submitting to the superintendent.3. The Superintendent will review the information, supporting documentation and verify accuracy prior tosubmitting to the IDOE reporting.Anticipated Completion Date: July 2023

FINDING 2022-002Contact Person Responsible for Corrective Action: Allison Pund and Melissa BoeglinContact Phone Number: 812-683-3971Views of Responsible Official: We concur to the finding.Description of Corrective Action Plan: Southwest Dubois will develop a system of internal controls that will ensurereporting compliance requirements are met. The corporation will assure one individual is completing the reports andanother is verify the reports.Anticipated Date of Completion: March 2023

Finding Number: 2022-001Prior Year Finding: NoFederal Agency: U.S. Department of TreasuryU.S. Department of EducationFederal Program: COVID-19 -Coronavirus State and Local Fiscal Recovery FundsCOVID-19 - Education Stabilization FundSupporting Effective Instruction State Grants (formerlyImproving Teacher Quality State Grants)Assistance Listing: 21.019, 84.425C and DPass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211838-01 (3/3/21 ? 12/31/24) 211815-01 (3/3/21 ? 12/31/24)211875-01 (3/3/21 ? 12/31/24) 201873-01 (3/13/20 ? 9/30/22)201787-01 (3/13/20 ? 9/30/22) 202233-01 (3/13/20 ? 9/30/22)191360-01 (7/1/18 ? 9/30/21) 201067-01 (7/1/19 ? 9/30/21)210781-01 (7/1/20 ? 6/30/22) 221052-01 (7/1/21 ? 6/30/23)Compliance Requirement: ReportingType of Finding Significant Deficiency in Internal Control over Compliance, OtherMattersRecommendation:We recommend that the Board review its policies and procedures to ensure that ReimbursementRequests and the detail & accompanying reconciliations used to prepare it are retained for auditpurposes.Explanation of disagreement with audit finding: There is no disagreement with the auditfinding. Action taken in response to finding: Procedures to ensure that the documentation to supportthe monthly submission of the Financial Status Report have been modified accordingly.Name(s) of the contact person(s) responsible for corrective action: BCPS grant accountants;Accounting Manager.Planned completion date for corrective action plan: For immediate implementation andongoing.

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.

Corrective Action Plan: After monthly reconciliations, financial statements will be delivered to AJAC Directors monthly. AJAC Accounting Department will hold monthly close calls to collaborate with AJAC Directors to ensure accuracy of financials. Anticipated Completion Date: Completed

Corrective Action Plan: After monthly reconciliations, AJAC Directors will review all appropriate reimbursable direct expenses related to each grant or contract agreement. After an expense has been included on a reimbursable request, the transaction will be marked appropriately in the accounting software to ensure that transactions are submitted for reimbursement correctly. All necessary reclasses will be performed in the accounting software to match the reimbursement request (invoice). Anticipated Completion Date: Completed

Corrective Action Plan: After monthly reconciliations, AJAC Directors will identify all appropriate indirect expenses specific to each grant or contract agreement and request reimbursement for actual indirect expenses up to the 10% de minimis rate. All items identified as being reimbursable to a specific grant or contract will be reclassed in the accounting software to match the reimbursement request (invoice). Anticipated Completion Date: 09/01/2024

Corrective Action Plan: AJAC Directors will develop and implement policies and procedures for appropriate methods of calculation that ensure benefit allocations are aligned with wage allocations at an employee level. Invoicing will reflect actual benefit expenses up to a predetermined amount or percentage that is unique to each individual grant or contract agreement. Anticipated Completion Date: Completed

Policies will be placed and adopted by the agency that meet the UG code. These policies will be placed in the fiscal manual. The fiscal manual will be created by using federal guidelines and by using the DDAP fiscal manual as guidance.

During 2022, there was a change in accounting staff which led to difficulty in tracking and preparing the SEFA. Once management became aware of the issues, changes have been made to internal processes to allow for proper SEFA tracking moving forward.

The County has identified federal grants subject to the Uniform Guidance and will develop written procedures for determining the allowability of costs in accordance with 2 CFR 200, Subpart E—Cost Principles and the terms and conditions of the Federal award.

The University concurs with the finding. As a result of this finding, the University created a new fund code within their general ledger chart of accounts for the purpose of classifying these funds as federal funds. The University performed the appropriate reclassifying journal entries within their general ledger utilizing the newly created fund code to recognize the $138,700 as federal revenue and expenditures.

Significant Deficiency in Internal Control over Compliance and Compliance Recommendation: CLA recommends that The Organization move away from using a cumulative profit and loss report and instead run monthly general ledger details by program as support for their monthly reimbursement requests. This will enhance clarity of costs attributable to each monthly period and reduces the chance that costs will be missed when requesting for reimbursement. Any reconciling transactions can be clearly tracked an Excel file of the general ledger detail by program. In addition, CLA recommends that The Organization emphasize to program management staff the importance of filing reimbursement requests each month and in a timely manner to reduce administrative and financial burden. There is no disagreement with the audit finding. Action taken in response to finding: The organization has modified our approach to making monthly reimbursement requests by including monthly general ledger details by program to ensure we have appropriate support and to increase clarity of costs attributable by month. Since fall/winter 2023, we have increased training to financial and program management staff around the importance of filing reimbursement request in a timely manner and we intend to increase the size of the financial support staff to further help minimize timely delays in reimbursement requests. Name(s) of the contact person(s) responsible for corrective action: Gary Slater Planned completion date for corrective action plan: 4/1/2024

Epidemiology and Laboratory Capacity for Infectious Diseases Cash Management Significant Deficiency in Internal Control over Compliance For the audited period and until August 2023, the procedure of the program and the Department of Health was "advanced" and was as follows: 1. The Epidemiology program worked with the validation of the voucher and recovered the director's signature for the punch of the "certificate". Once the validation and signature were in place, the cash request was processed. Once the cash request was remitted or the credit notice was registered, the receipt was delivered to the Tax Intervention area. 2. The Fiscal Intervention area works on the approval of the payment on the vouchers. Vouchers were worked on a first-come, first-served basis. This intervention process can take a week or more. The program had no control over the timing of payment approvals. This created a weakness when it came to cash management compliance. The program did confirm that the money was available at the time the payment was approved but had no control over the date the payment was approved. However, due to the nature of our funds and the volume of invoices, the Treasury Department asked us to change the modality for terms of cash requests from "advanced" to reimbursement. This began to be implemented as of September 2023. This method of reimbursement makes it easier for the program to have better control over cash management. With this method, the program requests the funds on the days that the Treasury Department makes the payment rolls. Once the petition is created on the same day of the print run and approved by the Program Director, it is submitted to the Office of Federal Affairs to prepare the request for funds to the federal government. The Office of Federal Affairs has the flexibility and agility to process such a request within two days. This helps us to meet the requirements of cash management.

Recommendation: We recommend Ozarks Regional YMCA draft and adopt written procedures in accordance with Uniform Guidance requirements. View of Responsible Officials and Planned Corrective Action: Management agrees with the finding and is in process of developing and implementing the appropriate policies and procedures. The board of directors will vote to approve the policies during the second quarter of 2024.

March 27, 2024 2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment) Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance not obtained. Corrective Action: We agree with the finding. The Consortium has carefully reviewed our policies and procedures and have made the necessary changes to ensure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium. We believe the updated procedures will result in the reduction over time and ultimately the complete elimination of this issue. Contact Person: Shamar Herron: Sherron@mwse.org Anticipated Completion Date: December 2024 Respectfully, Shamar Herron

Recommendation: We recommend the Agency draft and adopt written procedures in accordance with Uniform Guidance requirements. Action Taken: Management agrees with the finding and adopted the appropriate policies and procedures in December 2023.

The School System does not concur with the auditor’s findings and recommendations. The total expenditures for all federal programs recorded in the Schedule of Expenditures for Federal Awards are accurately presented and tie to the general ledger. The payroll sub-ledger is corrected before posting to the general ledger every two weeks. The resulting differences are most often immaterial, but can be traced to corrections made by the Accounting Office after payroll is reviewed by the grants Restricted Funds Supervisor to ensure payroll is not posted to expired grants. To ensure all employees are paid according to pay dates established in our various labor agreements and recorded correctly in the general ledger, we will continue the payroll transaction validation process that assures the payroll expenses recorded are allowable and accurately stated in the SEFA and balance to the general ledger. BDO Response – We have reviewed management’s response and our finding remains as indicated, since we could not validate the details of the differences.

FINDING 2023-004 (Auditor Assigned Reference Number) Finding Subject: 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 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. During the audit period the School Corporation was required to submit two ESSER I reports, two ESSER II reports and two ESSER III reports, for a total of six reports. However, the School Corporation failed to submit all six required reports. The lack of internal controls and noncompliance were systemic issues throughout the audit period. 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 accurately. Contact Person Responsible for Corrective Action: Stefanie Grandstaff, Director of Business Services Contact Phone Number and Email Address: (574)-946-4010 ext. 230, stefanie.grandstaff@epulaski.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: In the future when there is a multiyear federal grant given to Eastern Pulaski Community School Corporation, the final expenditure reporting will be completed on a yearly basis to ensure annual reporting is accurate. Determination of grant requirements for reporting will be determined and procedures put into place upon acquiring a new grant. When submitting grants for reimbursements each month, the Director of Business Services and Superintendent review the reports pulled from Skyward, sign the reimbursement form and then the Director of Business Services will submit it for reimbursement. The same internal controls will be put in place for final expenditure reporting for grants requesting this information. Anticipated Completion Date: June 30, 2024

Management agrees with the finding. The necessary written documentation to comply with the Uniform Guidance will be prepared by December 31, 2024.

2022-005 - Year Ended December 31, 2022 Department of Health and Human Services CFDA #93.829 Section 223 Demonstration Programs to Improve Community Health Services (CCBHC) Procurement, Suspension and Debarment Material Weakness in Internal Control over Compliance Finding Summa,y: - Rimrock Foundation does not have formally documented written internal control procedures over compliance with federal award programs to meet the requirements regarding compliance with federal regulations for procurement, suspension and debarment. Responsible Individuals Jeffrey Keller, CEO and Shirley Ehlang, Lead Financial Accountant Corrective Action Plan: Rimrock Foundation will adopt written internal control procedures over compliance with federal award programs regarding compliance with federal regulations for procurement, suspension and debarment. Anticipated Completion Date: Ongoing

Management agrees with the finding and is in process of developing and implementing the appropriate policies and procedures.