Corrective Action Plans

Audit Report: Reports on Compliance and Internal Control in Accordance with Government Auditing Standards and OMB Super Circular Uniform Guidance Audit Period: July 1, 2022 – June 30, 2023 Fiscal Year: 2022-2023 Principal Executive: Hon. Marcos Cruz Molina, Mayor Contact Person: Mr. Edgardo Pérez, Department of Management, Administration and Budget Director Phone: (787)855-2500 Original Finding Number: 2023-003 Statement of Concurrence or Non concurrence: We concur with the finding. Corrective Action: The QPR Reports for the months from January to March 2023, were completed by the previous POC Recovery Office. We understand that expenses were reported in the QPR on the date when the certification with the contractor´s invoice was received at the Secretary of Engineering and Conservation of Infrastructure and not on the date of payment or disbursement of the invoice. For example, if the invoice was received in the month of February, the expense was recorded in the QPR from January to March even though it was not paid until the month of April. We are verifying each project reported in the QPR against the amount reported at the SIMA System. We expect to have updated and correct information for all the Quarterly Progress Reports for the period from January to March 2024. Implementation Date: Fiscal Year 2023-2024. Responsible Person: Dafne L. Claudio Sánchez Accountant

Criteria: 2 CFR Section 200.302 of the Uniform Guidance requires that a non-federal entity provide for accurate, Current, and complete disclosure of the financial results of each Federal award or program. Additionally, 2 CFR Section 200.303 of the Uniform Guidance requires the non-Federal entity to establish and maintain effective internal controls over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations and the terms and conditions of the Federal award. Condition: Issues identified during our audit procedures over the SEFA and federal grant expenditure reports (SEFA project rollout). Cause: Lack of timely review and oversight of federal project expenditures, including the SEFA rollout report. In addition, the preliminary SEFA and underlying support was not timely reviewed by management after it was prepared by accounting staff. Agency Response: On a monthly basis there will be review on the expenditures to ensure that contractual expenses will be accrued. On a quarterly basis the SEFA rollout report will required to be created by the Financial Data Analyst or designee by the CFO. This report will be created by the 25th of the month after the quarter end. Once the report is created the analysis and review of expenditures to revenues will also occur. Based on the analysis, any discrepancies that are noted will be communicated with the Director of Finance. Those discrepancies will be corrected within 48 hours by the program accountants with the direction of the Director of Finance. In the event that the staff fails to make the corrections there will be disciplinary action. By the 30th of the month the report will be given to the CFO for review and approval. Responsible staff will be Lisette DeLeon, CFO, Cynthia Timm, Director of Finance, various staff, Program accountants, and Boubacar Traore, Financial Analyst. This process will begin January 2024 and be fully implemented by February 2024.

2023-003 Internal Control Over Financial Reporting Management Response: Management concurs with the recommendation above. Management will ensure policies and procedures over financial reporting which capture all required adjustments necessary to fairly present consolidated financial statements. Since their inception, the Academies had outsourced its accounting function to an outside company. Management has now moved that function in-house and hired a full-time finance director to oversee all accounting functions. The finance director will be responsible for monitoring all financial policies and procedures. Responsible Person: Preston Castille, Jr., Helix Community Schools, President Anticipated Remediation Date: Fiscal year ended June 30, 2024

Finding 2023-006 – Education Stabilization Fund – Reporting Contact Person Responsible for Corrective Action: Laura Hubinger, CFO-Greater Clark County Schools lhubinger@gccschools.com Jennifer Cato, Deputy Treasurer-Greater Clark County Schools jcato@gccschools.com Kimberly Hartlage, Deputy Superintendent and Grant Administration khartlage@gccschools.com Contact Phone Number: 812-288-4802 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The reimbursement request was submitted by grant department without a second review. New procedures now in place requires the grant department to submit data to business office. The business office reviews the data and prepares the reimbursement request. The request is then submitted back to grant office and the request is verified by grant administrative team, then verified by the deputy treasurer and finally the CFO. This control will assist in preventing errors in submissions. Anticipated Completion Date: Immediately

Management agrees with this finding and will write policies and procedures for Federal awards.

The newly hired CFO will update the policies and procedures and oversee the Finance Department and will develop procedures to ensure there are proper segregation of duties over key cycles, taking into consideration the size and complexity of the Organization. These procedures will strengthen the expense and accounts payable processes to ensure compliance with the provisions of 2 CFR § 200.302.

Finding 2023-002 Contact Person: Lily Rakness Parra, County Clerk Corrective Action Planned: Washakie County agrees with the finding of 2023-002. Washakie County is currently working on implementing a more thorough tracking procedure in order to document all of the significant processes for our federal awards. Also, in order to further track funds disbursed, a sams.gov account has been set up and is currently utilized in order to determine if an entity is eligible for disbursement of federal funds. An amendment to implement sams.gov utilization will be produced in order to add it to our current Procurement Policy.

FINDING 2023-009 Finding Subject: Education Stabilization Fund - Reporting Summary of Finding: Material Weakness, Other Matters, Qualified Opinion 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 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 prepared by the Chief Financial Officer and reviewed by a second knowledgeable individual; however, this process did not allow for the prevention, or detection and correction of errors prior to submission. Due to the lack of effective internal controls, one of the six annual data reports was not supported by the School Corporation’s records. For the ESSER 1, Year 2 report, which covered the period of October 1, 2020 to June 30, 2021, the School Corporation’s records did not support the data in the report. The lack of controls and noncompliance were isolated to the ESSER I, Year 2 report. Contact Person Responsible for Corrective Action: Bengamin Mann Contact Phone Number and Email Address: 765-536-0008 bmann@mgusc.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: Supporting documentation of data reported will be retained with each report filed. Anticipated Completion Date: February 2024

Program:Various, including AL 20.509 – Formula Grants for Rural Areas and Tribal Transit Program – Reporting Corrective Action Planned: The transit will continue to provide training to all the personnel who handles the information needed to properly calculate the SEFA amounts for future audits. Anticipated Completion Date: June 30, 2024 Responsible Party: Christy Warner, Transit Administrator

FINDING 2023-003 Finding Subject: Education Stabilization Reporting Summary of Finding: During the audit period the School Corporation submitted two ESSER I reports, two ESSERI II reports and two ESSER III reports for a total of six reports. The reports were prepared and submitted by the Director of Finance without a documented oversight or review process. In addition, four of the six annual data reports were not supported by the School Corporation’s records. The financial information provided did not agree to the data submitted; therefore, we could not determine the accuracy of the annual data reports. Contact Person Responsible for Corrective Action: Camden Parkhurst Contact Person Phone Number and Email Address: 765-457-8101 camden.parkhurst@nwsc.k12.in.us View of Responsible Official: We concur with the finding. The submissions referenced without proper documentation were submitted by the previous CFO. The current finance staff is unable to locate any supporting documentation regarding those submissions. There is a reimbursement request internal controls document that was signed by both the CFO and Superintendent, but here is no supporting documentation to accompany it. Description of Corrective Action Plan: The current Director of Finance and finance team have attached all supporting documentation from the financial software to their submissions along with an internal controls document signed by the Director of Finance and Superintendent. The corporation is actively working with the Department of Education to amend when it believes to be some errors in the prior submissions as well. Anticipated Completion Date: August 2024

FINDING 2023-005 Finding Subject: COVID-19 - Education Stabilization Fund - Reporting Summary of Finding: Condition and Context 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 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 to be prepared and submitted by the School Principal and reviewed by the Executive Business Director; however, no evidence of this review or oversight process could be provided. As such the annual data reports were prepared and submitted to IDOE without an oversight or review process to prevent or detect and correct errors. In addition, five of the six reports submitted during the audit period were not supported by the School Corporation’s records. The following errors were identified:  The ESSER I, Year 2 report, which had an applicable reporting period of October 1, 2020 through June 30, 201, reported $534,761 in expenditures. However, actual expenditures for the applicable reporting period totaled $478,883.  The ESSER 1, Year 3 report which had an applicable reporting period of July 1, 2021 to June 30, 2022, reported $0 in expenditures. However, actual expenditures for the applicable reporting period totaled $243,814.67.  The ESSER II, Year 1 report, which had an applicable reporting period of July 1, 2020 to June 30, 2021, reported $733 in expenditures. However, actual expenditures for the applicable reporting period totaled $322,539.  The ESSER II, Year 2 report, which had an applicable reporting period of July 1, 2021 to June 30, 2022, reported $0 in expenditures. However, actual expenditures for the applicable reporting period totaled $276,642.  The ESSER III, Year 2 report, which had an applicable reporting period of July 1, 2021 to June 30, 2022, reported $0 in expenditures. However, actual expenditures for the applicable reporting period totaled $1,315,208. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The school corporation will revise job descriptions to clearly identify segregation of duties for Federal Fund Coordinators, employees responsible for calculating accurate disbursement reports and reimbursement requests. Detailed expenditure reports will be generated for end of year reporting with the Accounting Specialist, Accounts Payable Coordinator and the Executive Director of Business Services completing a final review process providing signatures indicating review and accuracy before filing. Anticipated Completion Date: March 1, 2024.

Finding 2023-002: Section 202 Supportive Housing for the Elderly, Capital Advance and Project Rental Assistance Contract, ALN 14.157 Anticipated Completion Date: September 30, 2024 Recommendation: It was recommended management of Sessions Village 202 review their internal controls over the cash disbursement process with the necessary individuals involved in the process to ensure the implementation of general ledger account coding on cash disbursements is consistently performed going forward. Action Taken: The Executive Director and A/P Clerk agreed upon using certain general ledger account codes consistently for similar purchases from the same vendor. In Sessions Village 202’s accounting system, these agreed upon general ledger account codes have been pre-set as a default for certain vendors. When invoices are received that should be appropriately coded to this default general ledger account code, errors of not documenting the general ledger account code on the invoice are periodically made. Sessions Village 202 will consistently perform the general ledger account coding internal control procedures on invoices going forward.

Finding 2023-002: Section 232 Loan – Mortgage Insurance Nursing Homes, Intermediate Care Facilities, Board and Care Homes and Assisted Living Facilities Loan, ALN 14.129 Anticipated Completion Date: September 30, 2024 Recommendation: It was recommended management of Cheney Care Community review their internal controls over the cash disbursement process with the necessary individuals involved in the process to ensure the implementation of general ledger account coding on cash disbursements is consistently performed going forward. Action Taken: The Executive Director and A/P Clerk agreed upon using certain general ledger account codes consistently for similar purchases from the same vendor. In Cheney Care Community’s accounting system, these agreed upon general ledger account codes have been pre-set as a default for certain vendors. When invoices are received that should be appropriately coded to this default general ledger account code, errors of not documenting the general ledger account code on the invoice are periodically made. Cheney Care Community will consistently perform the general ledger account coding internal control procedures on invoices going forward.

FINDING 2023-005 Finding Subject: Education Stabilization Fund - Reporting Summary of Finding: The School Corporation had not properly designed or implemented a system of internal controls 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 and reviewed by the Treasurer prior to submission. However, this review process was not effective and did not detect and allow correction of errors prior to submission. All six of the submitted reports were selected for testing. Four of the reports were not supported by the unit's records. The financial information provided did not agree to the data submitted in the reports; therefore, we could not determine the accuracy of the reports. The lack of controls was systematic throughout the audit period. The noncompliance was isolated to the four reports identified above. The auditors recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure reports are supported by the ledgers or reports used to complete the report Contact Person Responsible for Corrective Action: Rolland Abraham Contact Phone Number and Email Address: 765-584-1401, rabraham@randolphcentral.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The School Corporation is required to submit annual data reports to the Indiana Department of Education (IDOE) via JotForm, a form/report builder. Data to be submitted includes, but is not limited to, current period expenditures, prior period expenditures, and expenditures per activity. The annual data reports will be complied/prepared by the Treasurer and the Assistant Superintendent to ensure the reports are supported by the corporation’s financial data. The JotForm will be reviewed by the Superintendent prior to submission. Anticipated Completion Date: 2/21/2024

Update grant spreadsheet monthly

Adopt suggested policies as outlined by auditor

FINDING 2023-006 Finding Subject: Education Stabilization Fund - Reporting Summary of Finding: Management had not developed or implemented a system of internal control that would have ensured compliance with the grant agreement and the Reporting compliance requirement. The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Reporting compliance requirement could result in the loss of future federal funds to the School Corporation. We recommended that the School Corporation's management establish internal controls to ensure compliance and comply with the grant agreement and the Reporting compliance requirement. Contact Person Responsible for Corrective Action: Andrea Miller Contact Phone Number and Email Address: 765-564-2100, millera@delphi.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The treasurer will prepare all required reports, and the grant administrator will verify the information on the reports. Reports will be signed and dated by both parties. Anticipated Completion Date: July 2024

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.