Corrective Action Plans

Views of Responsible Officials: The transition to the accounting system has been completed by the Accountant.

On May 3, 2021, the Grantee inform the Municipality about the determination to temporarily submit to a partial protective intervention the programmatic and administrative function of the delegated agency of Pe?uelas. As a direct consequence of such a determination, since May 3, 2021, up to July 31, 2022 (grant termination date), two employees of the Grantee had interference in all fiscal and programmatic transactions of the delegated agency, requiring their authorization for fiscal or programmatic transactions to be carried out. During this timeframe, key personnel of the delegated agency, such as the Program Director, the Program Accountant, the Property Manager, among others, resigned or were required to be replaced by the Grantee?s representatives, altering the programmatic and fiscal operations of the delegated agency. About the program year 2021-2022 closing, the Municipality of Pe?uelas return the funds surplus after the end of the period of liquidation of obligations, including the $3,288,516 related to Head Start Disaster Recovery program retained in the Program restricted cash account as instructed by a Grantee?s representative. Related to the program year prematurely terminated by the Grantee (program year 2022-2023), the Municipality?s Finance Department staff reconciled the program fiscal transactions registered in the Municipality?s computerized accounting system, with the grant awards, as amended, and prepare a liquidation report of each grant award. Such reports will be submitted to the Grantee to discuss the steps for liquidation of obligations with third parties, and the reimbursement of payroll and other expenditures financed by the Municipality?s General Fund. Implementation Date: August 31, 2023 Responsible Person: Mrs. Yadixa Ramos Finance Department Director

We gave instructions to the finance department accounting staff to strengthening internal procedures and controls to ensure accurate preparation and submission of financial reports. Implementation Date: August 31, 2023 Responsible Person: Mrs. Yadixa Ramos Finance Department Director

Finding 2022-003 Information on the federal program: Subject: Education Stabilization Fund ? Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 ? Education Stabilization Fund Assistance Listing Number: 84.425C, 84.425D, 84.425U Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Significant Deficiency 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 and the GEER grant award. 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. We noted 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. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding. Crawford County Community School Corporation will continue submission of required data to the IDOE on federal spending with at least two people completing the curation. However, final drafts will be reviewed and then final reports will be signed by the at least two people who reviewed the final draft. This signed copy, if not required to be submitting to the IDOE, will be kept locally. Responsible party and timeline for completion: 1) Amy Belcher, Program Administrator, will ensure all final reports have been reviewed and signed by at least two people before submission to the IDOE immediately.

Response: Management notes that, as this is their first single audit and this was one-time emergency funding rather than an ongoing award, they do not have these procedures in writing. However, they followed SBA/SVOG guidelines for allowability of costs, which were researched early in the grant process, and assigned costs in accordance with those guidelines. The budget, which included all assigned costs and was approved by the Lakewood Board of Directors, was also submitted and cleared by the SVOG Compliance Team and they inquired about the allowability of any items over which the guidelines were unclear. Action to be taken: Management notes that, as this was one-time emergency funding rather than an ongoing award, they do not anticipate receiving federal funding in the future. As such, they do not intend to document these procedures in writing at this point. However, if they apply for federal funding again in the future, they will develop written procedures at that point. Responsible Person: Andrew Edwards, Executive Director

Finding 2022-003 ? Education Stabilization Fund - Reporting Contact Person Responsible for Corrective Action: Vicki Jones, Corporation Treasurer Contact Phone Number: 765-793-4877 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Education Stabilization Fund Reporting will be completed and submitted in a timely manner. The Education Stabilization Fund Reporting will be verified with a sign-off by the Superintendent. Anticipated Completion Date: Upon Request

FINDING 2022-004 Contact Person Responsible for Corrective Action: George ann Ewald, Director of Finance & HR Contact Phone Number: (574) 277-4452 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Director of Finance & HR will expand Fund 8700 to include adding line items for all allowable reimbursement costs associated with each firefighter position covered by the 2019 Staffing for Adequate Fire and Emergency Response (SAFER) federal grant. The Director of Finance & HR will ensure that all funds used to compensate each covered firefighter position will be paid entirely out of Fund 8700, only. This action will result in a negative value for Fund 8700 until which time the fund is reimbursed the allowable costs under the provisions of the federal grant. The Director of Finance & HR will generate a report for each reimbursement request, which will be limited to include only the payroll dates of the period for which the request is being submitted. The Fire Chief will review and confirm that all associated costs have been withdrawn from Fund 8700. The Fire Chief will then direct the Assistant Fire Chief to complete the reimbursement request via the FEMA GO website. Once the reimbursement request has been submitted, the Assistant Fire Chief will print the completed reimbursement request documents and obtain signatures from each of the following individuals: 1. Prepared By: (NAME), Director of Finance & HR 2. Reviewed & Approved By: (NAME), Fire Chief 3. Submitted By: (NAME), Assistant Fire Chief Anticipated Completion Date: ? Implementation: June 2023

FINDING 2022-004 Contact Person Responsible for Corrective Action Plan: Alva Sibbitt, Jr., Superintendent, Melissa Embry, Corporation Treasurer, Brehan Leinenbach, Grant Writer Contact Phone Number: 812-547-2637 Views of the Responsible Official: We concur with the findings. Description of the Corrective Action Plan: All reports will be done by the Corporation Treasurer and/or Grant Writer and checked over by the Superintendent. Anticipated Completion Date: February 2023

The Finance team are currently working on the year-end close FY22 and preparation for the audit. Fieldwork will take plan in July 2023 and we are confident that material will be ready to permit completion of the audit ahead of the deadline for FY22. Responsible Officials: Richard Callaghan, CFO Anticipated Completion Date: May 2023

Audit Finding #2022-002 Allowability of Costs Name of Contact Person: Maryland Hutchinson, Fiscal Manager. Corrective Action: UCAP has set up written procedures and descriptions of costs which was submitted to all executive and program staff to be used prior to submission of program expenditures. This was provided to program managers in order to ensure that the cost allocations are followed according to procedures. We have also implemented an internal policy in our financial reporting department to ensure that unallowable costs are not charged to expenditures in error through a thorough two-party review of all expenditures charged to grants. With the several layers of review, it will ensure that no unallowable costs are charged to federal grants. Proposed Completion Date: This was completed as of 3/31/2023.

FINDING 2022-003 Contact Person Responsible for Corrective Action: Nicole Wolverton, CFO Contact Phone Number: 219-881-5536 Views of Responsible Official: We concur with the audit finding. Description of Corrective Action Plan: As it relates to reporting of meal claims, a policy and procedure will be created and implemented to ensure that accurate meal counts are recorded and entered CNP web by Sodexo based off reports from Skyward recording daily meal counts, documentation and entry then reviewed by the GCSC Food Service Manager for accuracy prior to submission of claims and then reviewed by the CFO for completeness. Anticipated Completion Date: Gary Community School Corporation will implement this procedure by September 2023. INDIANA STATE

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

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

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

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

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

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

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

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

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

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

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

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

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

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