Corrective Action Plans

The Treasurer, Town Manager and Select Board has taken the following actions to address finding 2022-007: The current Town Manager was appointed by the Select Board on August 14, 2023, and had no knowledge of this material weakness. She is an experienced Manager and has drafted a new Procurement Policy that addresses this deficiency. This policy was approved and implemented by the Select Board on January 23, 2024.

FINDING 2022-003 Finding Subject: COVID-19 - Education Stabilization Fund - Reporting Summary of Finding: An effective internal control system was not designed, nor implemented at the School Corporation to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirements. The annual Elementary and Secondary School Emergency Relief (ESSER) Data Collection reports were complied, prepared and submitted by three different staff members; however, this process was not properly designed or implemented to prevent, or detect and correct, errors. The School Corporation completed and submitted three annual Data Collection reports (Reports) for the ESSER grants. For two of the three reports tested, the report was 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 their accuracy. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Contact Person Responsible for Corrective Action: Matthew Miles, CFO Contact Phone Number and Email Address: 317-423-8380 mattmiles@msdlt.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The School District will work to ensure the ESSER report amounts tie to the accounting records and will improved record keeping of supporting documentation. If the amounts do not match, District will document support for all claims. Anticipated Completion Date: The School District will implement changes described in the Corrective Action Plan in February 2024.

Agree with the finding. We will implement the segregation of duties matrix as part of SOPs. We will ensure that authorization and review of cash draws of fedral funds are done by some one other than the individual who initiates and records the transaction . We have implemented the same and Dr EIli (pi) is reviewing and approving the report before each withdrawal. The Finance Head ( Nafih) is withdrawing the fund .Anticipated Completion Date : 12/31/2022 Actual date of implementation :01/24/2023

FINDING 2022-007 Finding Subject: COVID-19 - Education Stabilization Fund - Reporting Summary of Finding: Finding: No oversight of reports and supporting documentation did not agrees to report submitted Recommendation: Provide oversight of reports submitted and retain supporting documentation that agrees to reports submitted Contact Person Responsible for Corrective Action: Kareemah Fowler, Assistant Superintendent of Business and Finance Deb Martin, Director of Student Learning & Title I Contact Phone Number and Email Address: Kareemah Fowler (574) 393-6088; kfowler@sbcsc.k12.in.us Deb Martin (574) 393-6053; dmartin@sbcsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: All reports and supporting documentation, which supports each report submitted, will be reviewed/approved by the program director. All supporting documentation will be retained for future audits. Anticipated Completion Date: December 8, 2024

FINDING 2022-004 Finding Subject: Title I Grants to Local Educational Agencies - Reporting Summary of Finding: Finding: Detail data on the Form 9 and Reimbursement Request was not provided to knowledgeable individuals for review. Recommendation: Design control that provides sufficient data to knowledgeable individuals for review. Contact Person Responsible for Corrective Action: Kareemah Fowler, Assistant Superintendent of Business and Finance Contact Phone Number and Email Address: (574) 393-6088; kfowler@sbcsc.k12.in.us Views of Responsible Officials: We concur with the findings. Description of Corrective Action Plan: Form 9 Data The Human Resources Department has added a second review to verify all employee distribution codes are correct when recording/updating employee requisitions. Additionally, detailed expense reports and payroll distribution reports that support each reimbursement request are being provided to knowledgeable employees to review. Anticipated Completion Date: Completed December 8, 2023, and May 2023 Reimbursement Requests Summary level payroll data is no longer being used to support reimbursement requests. Detailed expense reports and payroll distribution reports that support each reimbursement request are being provided to knowledgeable employees to review. Anticipated Completion Date: Completed May 2023.

2022-005 Significant Deficiency in Controls over Compliance: Administrative Requirements of Uniform Guidance-Administrative Policies The schools have documented their administrative policies effective 3/1/2023.

Finding 2022-001 - Schedule of Expenditures of Federal Awards United States Department of Education Pass Through Entity: Texas Education Agency Federal Program: American Rescue Plan ? Elementary and Secondary School Emergency Relief (ARP ESSER) Assistance Listing Number: 84.425U Federal Award Number: S425U210042 Federal Award Year 2022 Repeat Comment: No Type of Finding: Material Weakness Condition: When reviewing the net assets released from restriction in the draft financial statements presented to the board, management determined and brought to the attention of the auditors the net assets restricted for pre-award costs for the ESSER federal program ($1,976,911) should have been released from restrictions during fiscal year ending June 30, 2022. The auditor, when tying the draft schedule of expenditures of federal awards to the updated schedules, determined the Organization had not included the pre-award federal expenditures related to the ESSER federal program. As a result, the initial testing of the ESSER major program did not include $1,976,991 in ESSER expenditures. When this was brought to management?s attention, the schedule of expenditures of federal awards was updated and the additional expenditures provided for testing. Cause: The additional $1,976,991 was related to ?pre-award? dollars awarded during fiscal year ended June 30, 2022, where allowable expenditures incurred in the previous year were permitted by the grant to be used for the ESSER funds awarded in the current year. Management was not aware of the requirement to include these amounts on the schedule of expenditures of federal awards. Recommendation: We recommend management of the Organization strengthen their internal controls to ensure all federal awards are included on the schedule of expenditures of federal awards. Corrective Action Plan: Prior to June 30, 2023, management will prepare an administrative procedure that requires the auditor to provide a draft financial and compliance report at least one (1) week prior to the meeting of the Board. In the procedure, management will require staff to reconcile the Schedule of Expenditures of Federal Awards to the Statement of Activities and other relevant accounting information to ensure the accuracy and completeness of the amounts disclosed. Person Responsible: Kevin Byrne, Vice President of Finance Anticipated Completion Date: June 30, 2023

We agree with this finding that certifications of direct assistance provided to individuals were not obtained. We have taken steps to correct the issues identified and during June 2023 we modified our procedures for certification of direct assistance received by clients. We will review our process and procedures for obtaining signatures from clients receiving gift cards and other forms of direct assistance, including non-financial assistance as well as rent and utility assistance, to ensure that amounts received, and dates received are attested by clients via signature or via an acceptable alternative electronic attestation.

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE ? ALL FEDERAL PROGRAMS AWARDED UNDER THE UNIFORM GUIDANCE 2022-001 Internal Controls Over Compliance With Cash Management, Allowable Costs, Standards for Financial Management, and Procurement Finding Summary During our audit, we noted that Universal Academy?s (the Academy) written internal control policies over compliance with the U.S. Office of Management and Budget?s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) did not include adequate written controls over compliance with cash management, allowable costs, financial management standards, and procurement. Corrective Action Plan Actions Planned ? The Academy has implemented an updated version of its written policies and procedures relating to cash management, allowable costs, financial management standards, and procurement for its federal programs to ensure compliance with the Uniform Guidance effective for fiscal year 2023. Official Responsible ? The Academy?s Executive Director, Farhiya Einte. Planned Completion Date ? June 30, 2023. Disagreement With or Explanation of Finding ? The Academy agrees with this finding. Plan to Monitor ? The Academy?s Executive Director, Farhiya Einte, will ensure appropriate written internal controls and procedures are updated and in place for future federal grants.

FINDING 2022-004 Subject: COVID-19 ? Education Stabilization Fund ? Reporting, Equipment and Real Property Management Federal Agency: Department of Education Federal Program: COVID-19 ? Education Stabilization Fund Assistance Listing Number: 84.425D Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting, Equipment and Real Property Management Audit Finding: Material Weakness Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Reporting and Equipment and Real Property Management compliance requirements. Context: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirements. Reporting The School Corporation was required to submit two Annual Data Reports to the Indiana Department of Education (IDOE) to meet federal reporting requirements for ESSER grant awards. The first report was for the period of March 13, 2020 to September 30, 2020 and was due by January 21, 2021. The second report was for the period of October 1, 2020 to June 30, 2021 and was due by May 13, 2022. For both reports that were submitted, there was segregation of duties between the preparation of the report and the review and submission of the report by someone other than the preparer. However, the review was not sufficient to prevent the following error: ? In the second report, the amounts reported as expended did not agree to the underlying expenditure records of the School Corporation for ESSER I and ESSER II awards. Per discussion with the Treasurer, the amount in the report included expenditures through the report due date of May 13, 2022 rather than through the reporting period end date of June 30, 2021. This resulted in an overstatement of expenditures of $83,000 for ESSER I and $184,000 for ESSER II. Equipment and Real Property Management During our testing of equipment and real property management, it was noted that the School Corporation had not conducted a physical inventory during the last two years as required. Views of Responsible Officials and Planned Corrective Actions: We concur with the finding. Description of Corrective Action Plan: For the upcoming year 3 ESSER report that is due by April 7th, the corporation treasure will ensure that the data provided for the completion of this report only includes the correct time period information for July 1, 2021 through June 30, 2022. Southwestern superintendent, Josh Edwards, will verify the correct dates and amounts for the requested time period before submitting the report. Both the treasurer and the superintendent will review the form and sign a printed copy to be kept on file at the administration building. Inventory has in the past only been taken within certain departments. A more complete inventory will be scheduled. Southwestern superintendent, Josh Edwards, and treasurer Bonnie Thopy will research the required criteria to become compliant. Once these parameters have been established they will work within the guidelines to ensure an inventory will be completed before the next audit period. Responsible Party and Timeline for Completion: Treasurer, Bonnie Thopy, and Superintendent, Josh Edwards ? these changes will be implemented for FY2023.

Federal Program Name: ? Block Grants for Community Mental Health Services ? ALN 93.243 ? Substance Abuse and Mental Health Services Projects of Regional and National Significance ? ALN 93.829 ? Section 223 Demonstration Programs to Improve Community Mental Health Services ? ALN 93.958 Recommendation: Our auditors recommended the Organization revise their Financial and Control Policy to encompass the requirements defined within ? 2 CFR 200.305. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management concurs with the audit finding. While the policy has been updated previously, it was not updated such that it complied with the requirements of 2 CFR 200.305. The Controller and CFO have updated the policy so that it fully complies with all of the requirements defined within 2 CFR 200.305. Name(s) of the contact person(s) responsible for corrective action: CFO and Controller. Planned completion date for corrective action plan: Will implement in fiscal year 2023.

FINDING 2022-016 Contact Person Responsible for Corrective Action: Casey Brewster Contact Phone Number: 812-752-8935 Views of Responsible Official: We concur with the finding Description of Corrective Action Plan: The approved grant budgets for all federal grants will be input into the financial management system and with all expenditures reported monthly from the Treasurer to the Director overseeing the federal grant for review and final approval. The Director shall be one of the approvers within the approval chain of federal grant funds the Director oversees. The Director shall be responsible for reviewing and utilizing actual expenditure reports to complete the annual reports, or any other reports, prior to another documented review by the Treasurer or CFO. All documentation related to the reports shall be maintained for future audit purposes. Anticipated Completion Date: April 2023.

FINDING 2022-014 Contact Person Responsible for Corrective Action: Casey Brewster Contact Phone Number: 812-752-8935 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The approved grant budgets for all federal grants will be input into the financial management system and with all expenditures reported monthly from the Treasurer to the Director overseeing the federal grant for review and final approval. The monthly reports will then be used by the Director to generate a reimbursement request for actual expenditures. The reimbursement request must then be reviewed and signed by the Treasurer or the CFO prior to submission to the State by the Director. Anticipated Completion Date: April 2023

FINDING 2022-006 Contact Person Responsible for Corrective Action: Casey Brewster Contact Phone Number: 812-752-8935 Views of Responsible Official: We concur with the finding. INDIANA STATE BOARD OF ACCOUNTS 67 Description of Corrective Action Plan: Additional training related to grant budgets entered into and monitored within the financial software will occur, as will the new practice of having the program directors initiating monthly reimbursement requests informed by the accurate reports from the software (ledger), with documented review by the Treasurer or CFO. Additional training over the reporting requirements is taking place with the Treasurer, CFO and Directors overseeing federal funds provide accurate reporting. Anticipated Completion Date: June 2023

FINDING 2022-011 Contact Person Responsible for Corrective Action: Casey Brewster Contact Phone Number: 812-752-8935 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Additional training related to grant budgets entered into and monitored within the financial software will occur, as will the new practice of having the program directors initiating monthly reimbursement requests informed by the accurate reports from the software (ledger), with documented review by the Treasurer or CFO. Additional training over the reporting requirements is taking place with the Treasurer, CFO and Directors overseeing federal funds provide accurate reporting. Anticipated Completion Date: June 2023

FINDINGS - FEDERAL AWARD PROGRAMS AUDIT SIGNFICANT DEFICIENCY/COMPLIANCE 2022-01 Procurement Policies and Procedures Recommendation: Quotes should be obtained whenever possible when purchases are expected to be between $10,000 and $250,000. If purchases are to equal or exceed $250,000, the proper bidding procedures should be followed. Bidding procedures, quotes, and efforts to give preference to minority or women-owned businesses should be documented, including documenting if bids or quotes could not be obtained. A procurement policy should be established as soon as possible and an individual should be assigned to monitor the implementation of the policy. Action Taken: The Organization has begun the process of establishing a procurement policy and have it completed by March 16, 2023. The Organization will also go back to purchases starting July 1, 2022, that exceeded the micro purchase threshold of $10,000 and prepare the required documentation as listed in the recommendation. This will be completed by April 30, 2023. Any purchases exceeding the micro purchase threshold of $10,000 going forward will be supported by the required documentation.

Program: AL 21.023 ? COVID-19 Emergency Rental Assistance ? Reporting Corrective Action Plan: N/A Contact: Philip Olsen Anticipated Completion Date: N/A

Program: AL 20.933 ? National Infrastructure Investments ? Reporting Corrective Action Plan: NDOT will finalize in coordination with FHWA a standard operating procedure for the quarterly SF-425 reporting process as well as generate a standard operating procedure for FFATA reporting. Contact: Khalil Jaber Anticipated Completion Date: June 2023

Program: AL 12.401 ? National Guard Military Operations and Maintenance (O&M) Projects ? Cash Management & Reporting Corrective Action Plan: The USPFO Grants Officer Representative (GOR) will continue to work closely with the Cooperative Agreement Program Mangers (CAPMs) to track projected invoices so they are paid out in a timely fashion (per Federal Cash Management requirements) from the Cooperative Agreement advance funds (as required by the State). Also upon implementation of the recommendation to change the data in the SF270 (contained in the Exit Conference), the SF270 submission will track the availability of advance funds ? thereby preventing excessive advance funds requested ? and fully expending current available advance funds to the federal requirements. Contact: Matt Zeigler, Grants Officer Representative Anticipated Completion Date: Implementation will occur at the start of the new State Fiscal Year 01-Jul-2023.

Contact Person Responsible for Corrective Action: Jessica Espinoza Contact Phone Number: (219) 836-9111 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: There has been turnover in the finance department and the past employees who would have been responsible for this are no longer here. There are already internal controls in place to ensure that the monthly sponsor claims submitted match the school?s meal count reports. The Treasurer will continue to ensure that everything is correctly entered before submission. Anticipated Completion Date: March 2023

Findings: Major Federal Program Audit, Significant Deficiency 2022-001 Written Uniform Guidance Policies and Procedures Recommendation: We recommend The Arc of the Ozarks draft and adopt written procedures in accordance with Uniform Guidance requirements. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and are in process of developing and implementing the appropriate policies and procedures.

FINDING 2022-003 Contact Person Responsible for Corrective Action: Gerri Ford Contact Phone Number: 812-937-2400 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Corporation Treasurer will prepare the annual reports and ensure the amounts agree to the accounting records. The annual reports prepared by the Corporation Treasurer will be provided to the Director of Learning who oversees the Elementary and Secondary School Emergency Relief (ESSER) grant to review and approve the amounts reported are accurate. After review and approval from the Director of Learning, the annual reports will be submitted by the Corporation Treasurer. Anticipated Completion Date: May 2023

FINDING 2022-007 Contact Person Responsible for Corrective Action: Mary K. Kaczka, Assistant Director, Community Development Contact Phone Number: 574-322-4472 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Financial Reporting: Management has developed the following process to correct for the lack of evidence for review or approval for reports that are submitted: Staff responsible for preparing the report in IDIS and management responsible for review for accuracy and completeness will both sign appropriate documentation detail (PR 5 and PR 7, draw spread sheets, draw vouchers) supporting the Cash on Hand Report and the IDIS report. CDBG staff has consulted with HUD CPD staff for additional training on how to complete the PR 26 report. The training assisted staff in filing two (2) past due reports and resulted in changes to the reporting process utilized by staff. Performance Reporting: Management will address the performance reporting weaknesses by taking the following steps: The assistant director of community development will document the segregation of duties for the completion and submittal of the CAPER before submission to HUD. Documentation will consist of a clear and understandable workflow on City workpapers, and final submissions, evidenced by signature (ink or digital stamp), email string other generally acceptable audit trail. Additionally, as part of continuing education, CDBG staff participated in a workshop organized by our CDBG consultant this past June, 2023 to better understand the Section 3 reporting requirements. Special Reporting for Federal Funding Accountability and Transparency Act (FFATA): Management will address the weaknesses identified in Special Reporting for Federal Funding Accountability and Transparency (FFATA) by taking the following actions: Management will review and strengthen the current process in place for identification and timely submission of projects that qualify for FFATA reporting. Completed reports will show evidence of segregation of duty for completion, and review and approval. Anticipated Completion Date: August 31, 2023

The City is in agreement with the finding noted and will consider formally documenting policies and procedures. Heather Shippey, City Clerk will be responsible for the corrective action and anticipated completion of corrective action will be taken before September 30, 2023.

FINDING 2022-005 Subject: COVID-19 ? Education Stabilization Fund ? Reporting Federal Agency: Department of Education Federal Program: COVID-19 ? Education Stabilization Fund Assistance Listing Number: 84.425D Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirements. Context: The School Corporation was required to submit two Annual Data Reports to the Indiana Department of Education (IDOE) to meet federal reporting requirements for ESSER grant awards. The first report was for the period of March 13, 2020 to September 30, 2020 and was due by January 21, 2021. The second report was for the period of October 1, 2020 to June 30, 2021 and was due by May 13, 2022. For the first report, the amounts reported as expended did not agree to underlying expenditure records of the School Corporation. Per discussion with the Treasurer, the amount in the report included expenditures from outside of the reporting period, resulting in an overstatement of expenditures of approximately $28,000. Additionally, for both reports that were submitted, there was no documented review by someone other than the preparer of the report to ensure the information submitted was complete and accurate. Description of Corrective Action Plan: The treasurer will prepare the grant reporting and have the deputy treasurer review and make any corrections to the information online prior to submission. Responsible Party and Timeline for Completion: Jennifer Blakely, Treasurer, and Debbie Blevins, Deputy Treasurer ? this corrective action will be implemented for all reporting requirements immediately following the audit in March 2023.