Corrective Action Plans

Corrective Action: The Agency has implemented additional review procedures to ensure all grant-related liabilities are reconciled prior to financial statement preparation. This includes working with the grant administrator to incorporate structured reconciliations of the WIFIA loan liability as part of our monthly and year-end closing processes.

FINDING 2024-006 Subject: COVID‐19 ‐ Education Stabilization Fund ‐ Reporting Federal Agency: Department of Education Federal Program: COVID‐19 ‐ Education Stabilization Fund Assistance Listing Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S425U210013 Pass‐Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Chad Yencer, Superintendent Contact Phone Number: 765-348-7550 Views of Responsible Official: We concur with this finding Description of Corrective Action Plan: Internal Control 1. For state reporting related to ESSER grants, the Grants/Data Specialist will compile all required information and maintain thorough supporting documentation. The Corporation Treasurer will then review the compiled financial data for the reporting period, verifying its accuracy before presenting it to the Superintendent. Finally, the Superintendent will review the information and supporting documentation, confirming its accuracy prior to submission to the Indiana Department of Education (IDOE). All workpapers and calculations will be recorded and kept for verification Anticipated Completion Date: August 2025

Corrective action plan: TxDOT Aviation has modified the procedures for the SF-425 report preparation to require the subrecipient share of the expenditures to be properly reported when the match is from a local source. A Checklist will be created to include this amount when the document is reviewed by the Grant & Admin Section Director. TxDOT AVN will explore the consideration of including the local share in its accounting system which would allow identification of the local amount. Implementation dates: February 15, 2025 Responsible persons: Michelle Burcham, AVN Grant & Admin Section Director, Allison Martin, Grant Manager Lead

Corrective action plan: Federal Reporting will seek direction from the awarding agency if corrections are found to be needed after a report is submitted. If directed to, Federal Reporting will submit a revised report. If directed to wait until the next cumulative report to make the correction, Federal Reporting will save this documentation from the awarding agency. Implementation dates: February 12, 2025 (Implemented) Responsible persons: Alan Flynn, Manager, Federal Reporting

Future reporting of ESSR information will be noted wherever possible either in written notation or email format to document who worked on and reviewed reporting information and submissions. We will attempt to take screenshots of any forms that are not available for printing

FINDING 2024-006 - Education Stabilization Fund (ESSER) – Reporting Context: The School Corporation was required to submit two Annual Data Reports to the Indiana Department of Education (IDOE) during the audit period to meet federal reporting requirements for ESSER grant awards. We noted that the ESSER II, and ESSER III amounts reported for the reports covering the FY22 time period ($99,969 and $251,848, respectively) did not agree to the underlying expenditure records ($105,319 and $369,743, respectively, for the period of July 1, 2021 through June 30, 2022). Additionally, we noted that the ESSER II, and ESSER III amounts reported for the reports covering the FY23 time period ($168,087 and $266,122, respectively) did not agree to the underlying expenditure records ($169,046 and $241,329, respectively, for the period of July 1, 2022 through June 30, 2023). We also noted there was no documented, secondary review of the information in the annual data reports by someone other than the preparer. Contact Person Responsible for Corrective Action: Michelle L. Keene Contact Phone Number: (812) 384-4386 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We will ensure all ESSER reports include accurate information that agree to the underlying disbursement records. Anticipated Completion Date: Next report due to IDOE.

Information on the federal program: Subject: Education Stabilization Fund (ESSER) – Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013, S425U210013 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 four Annual Data Reports to the Indiana Department of Education (IDOE) each year during the audit period to meet federal reporting requirements for ESSER grant awards. We noted that the ESSER I, ESSER III and CrossAct amounts reported on the Year 3 report ($3,070, $745,718 and 119 employees respectively) did not agree to the underlying expenditure and employee records ($7,062, $754,729 and 207 employees respectively). Additionally, we noted that the ESSER II, ESSER III and CrossAct amounts reported on the Year 4 report ($452,658, $117,344 and 117 employees respectively) did not agree to the underlying expenditure and employee records ($62,794, $459,556 and 207 employees respectively). Of the eight reports the School Corporation was required to submit during the audit period, auditable evidence of review and approval of these reports was only provided for two. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.The Treasurer will work with the Grants Administrator to ensure that submissions are checked by both positions. Files will be kept with all documentation relating to the grant. A better understanding of the grant will result from regular meetings with the Treasurer and Grants Administrator to ensure accuracy. Both positions will sign off prior to submission. Responsible party and timeline for completion: The Corporation Treasurer will be responsible effective immediately.

Program: AL 21.027 – COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Reporting Corrective Action Plan: As of the reporting period ended September 30, 2024, changes requested by agencies to obligations or expenditures have been updated. DAS will obtain the written justification for capital expenditures for the projects identified. Contact: Philip Olsen Anticipated Completion Date: January 31, 2025

Program: AL 21.023 – COVID-19 Emergency Rental Assistance – Reporting Corrective Action Plan: On February 3, 2025, the vendor system report was corrected. A review of summary AMI data will be reconciled to detailed data to ensure subsequent reports are correct. Contact: Philip Olsen – DAS Accounting Administrator Anticipated Completion Date: February 2, 2025

Program: AL 17.225 – Unemployment Insurance (UI) – State – Reporting Corrective Action Plan: NDOL has reviewed the federal directions associated with the report in question and has an increased understanding of the report requirements. NDOL has developed a better understanding of reports related to benefits paid, reissued, cancelled, and recouped. NDOL can reconcile the timing of benefits drawn, benefits paid, benefits failed, benefits reissued to that activity in bank statements. NDOL is developing a reconciliation process for the timing of recouped benefits, and that activity on bank statements. NDOL will be able to accurately report benefits paid by relevant source, netted for any cancelled or recouped amounts in accordance with reporting guidelines, and directly traceable to supporting documentation. Contact: Rea Easton Anticipated Completion Date: September 2025

Program: AL 84.126 – Rehabilitation Services Vocational Rehabilitation Grants to States – Reporting Corrective Action Plan: Instructions for completing the RSA-17 report have been updated to ensure unliquidated obligations for indirect costs are correctly reported, and the correct payroll periods are included with the appropriate supporting documentation. Unliquidated obligations will not include contract amounts unless the contracts have been completed. As noted above, administrative costs will be reported using the sub ledgers/subsidiaries already set up in E1. Contact: Cathy Callaway Anticipated Completion Date: Done

Program: AL 12.401 – National Guard Military Operations and Maintenance (O&M) Projects – Cash Management & Reporting Corrective Action Plan: The Agency is meeting with State Budget Office to discuss and review options for better separating future federal funding by fiscal year. This will allow for better tracking and transparency of drawdown times. Further, the Agency is aware of the finding for Award W91243-22-2-1001 (SAG 132) and currently reconciling all line items in the Award Program and year to determine and action on return of appropriate federal funding. Contact: Lauren Hargreaves Anticipated Completion Date: Ongoing

Program: AL 93.558 – Temporary Assistance for Needy Families; AL 93.563 – Child Support Services; AL 93.566 – Refugee and Entrant Assistance; AL 93.568 – Low Income Home Energy Assistance (LIHEAP); AL 93.575 – Child Care and Development Block Grant; AL 93.658 – Foster Care Title IV-E; AL 93.659 – Adoption Assistance; AL 93.667 – Social Services Block Grant; AL 93.767 – Children’s Health Insurance Program; AL 93.778 – Medical Assistance Program; AL 10.561 – State Administrative Matching Grants for the Supplemental Nutrition Assistance Program – Allowable Costs/Cost Principles Corrective Action Plan: Time and Effort: Agency has submitted retroactive PACAP amendment (complete). For the IST Fiscal Projects Admin cost center, a time study will no longer be utilized, and the hours will be treated as General IST Administration without direct grant allocations. RMTS Allocations: Agency has clarified with staff what the “Non-DHHS Activities” selection pertains to (complete). Labor Hours Statistics: This was the first audit cycle of the new Cost Allocation system. DHHS will create a checklist of items for the new system that will be reviewed prior to completion of the quarterly cost allocation compilation. This checklist will address specific issues presented during this audit cycle. Recipient Counts: This was the first audit cycle of the new Cost Allocation system. DHHS will create a checklist of items for the new system that will be reviewed prior to completion of the quarterly cost allocation compilation. This checklist will address specific issues presented during this audit cycle. Contact: Patrick Werner Anticipated Completion Date: 6/30/2025

Program: AL 93.558 – Temporary Assistance for Needy Families; AL 93.566 – Refugee and Entrant Assistance; AL 93.568 – Low Income Home Energy Assistance (LIHEAP); AL 93.575 – Child Care and Development Block Grant; AL 93.658 – Foster Care Title IV-E; AL 93.659 – Adoption Assistance; AL 93.667 – Social Services Block Grant; AL 93.778 – Medical Assistance Program; AL 10.561 – State Administrative Matching Grants for the Supplemental Nutrition Assistance Program – Allowable Costs/Cost Principles Corrective Action Plan: This was the first audit cycle of the new Cost Allocation system. DHHS will create a checklist of items for the new system that will be reviewed prior to completion of the quarterly cost allocation compilation. This checklist will address specific issues presented during this audit cycle. Contact: Patrick Werner Anticipated Completion Date: 6/30/2025

COMMONWEALTH OF PUERTO RICO CORRECTIVE ACTION PLAN MUNICIPALITY OF NARANJITO FOR THE FISCAL YEAR ENDED JUNE 30, 2024 Audit Report: Reports on Compliance and Internal Control in Accordance with Government Auditing Standards and 2 CFR 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards Audit Period: July 1, 2023 – June 30, 2024 Fiscal Year: 2023-2024 Principal Executive: Hon. Orlando Ortíz Chevres - Mayor Contact Person: Mrs. Carmen López, Interim Finance Director Phone: (787) 869 – 2200 Original Finding Number: 2024-005 Statement of Concurrence or Nonconcurrence: We concur with the finding. Corrective Action : We understand that only two (2) reports did not agree with the accounting records. We have consultants that are responsible for the preparation of these reports. Instructions were given to the consultants in order to correct the reports that do not agree with the accounting records. There was a misunderstanding with the reports, in which the past-through entity instructed that purchase orders and expenditures incurred should be reported. As subsequently clarified, only the expenditures incurred should be reported. Implementation Date: June 30, 2025 Responsible Person: Carmen I. López – Interim Finance Director

Internal Controls over Grant Management (Significant Deficiency and Noncompliance) Recommendation: We recommend the City develop a grants manual or additional written policies that comply with the requirements of 2 CFR 200 and ensure compliance. Response to 2024-005: Internal Controls over Grant Management (Significant Deficiency and Non-Compliance) In response to the Deficiency in the City of Wetumpka’s previous corrective action plan, the City was in the process of establishing a written financial management system in accordance with 2 CFR 200.302 to include written procedures to implement requirements for payment methods and determine allowability of costs in accordance with subpart E. The City of Wetumpka has financial management internal controls in place. All of the City’s grant activities (Federal and State) are tracked in a separate fund from the general operating funds under unique assigned general ledger numbers for each grant awarded to the City. All grant funds are deposited into a dedicated bank account and are not co-mingled with other funds of any kind.

Corrective Action: Before any expenditure is obligated, all revisions/amendments will be approved in MCAPS mst. The business Manager, Federal Programs Director, and Superintendentwill ensure MDE's approval is tangible before any obligations. We will implement a tool that allows this process to be measured daily. Responsible Parties: Avery Johnson, Business Manager Robert Sanders, Superintendent Corrective Action Start Date: February 14, 2025

Information on the federal program: Subject: Education Stabilization Fund (ESSER) - Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013, S425U200013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Condition and 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. The School Corporation was required to submit Annual Data Reports to the Indiana Department of Education (IDOE) during the audit period to meet federal reporting requirements for ESSER grant awards. We noted that the ESSER I amount reported on the Year 3 report ($86,004) did not agree to the underlying expenditure records ($196,436) for the period of July 1, 2021 through June 30, 2022. We also noted that the ESSER II and ESSER Ill amounts reported on the Year 3 report ($0 and $1,684,755, respectively) did not agree to the underlying expenditure records ($1,391,963 and $4,330,649, respectively), for the period of July 1, 2022 through June 30, 2023. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Vincennes School Corporation will include the Federal Programs Coordinator when preparing any annual reports to confirm accuracy of the reporting. Responsible Party for Corrective Action: Michele Fleck, Treasurer Timeline for Completion: Effective immediately.

FINDING 2024-008 Finding Subject: Covid-19-Education Stabilization Fund-Reporting Summary of Finding: Not all reports filed by the school corporation during the audit period were properly supported by the records of the school corporation. Additionally, the School corporation did not properly implement a process to identify and assess internal and external risks, or monitor internal control activities to ensure they were operating effectively. Contact Person Responsible for Corrective Action: Melissa Embry Contact Phone Number and Email Address: 812-547-2637 melissa.embry@cannelton.k12.in.us Views of Responsible Officials: We concur with the finding. However, these data collections reports are not user-friendly and we receive very little guidance on how to do them. One email that we received from the IDOE stated it was for the ESSER III year 3, however the attachment was named year 4 with the year 3 dates listed on the spreadsheet. The due date that it showed for this report was July 24, 2025 on the subject of the memo, but said July 24, 2024 within the body of the memo. Description of Corrective Action Plan: In the future all reports will be done by the Corporation Treasurer and the Grant Specialist and signed off on by the Superintendent. Anticipated Completion Date: The noncompliance will be addressed immediately. The additional controls will be implemented by August 2025.

FINDING 2024-007 Finding Subject: Covid-19-Education Stabilization Fund-Allowable Costs/Cost Principles Summary of Finding: This finding claims federal awards were not in compliance with the terms and conditions as well as the allowable cost compliance requirements. Additionally, the School corporation did not properly implement a process to identify and assess internal and external risks, or monitor internal control activities to ensure they were operating effectively. Contact Person Responsible for Corrective Action: Melissa Embry Contact Phone Number and Email Address: 812-547-2637 melissa.embry@cannelton.k12.in.us Views of Responsible Officials: We concur with the finding. The reason we spent the money the way we did is because the IDOE approved our budget. We spent exactly as it was approved not knowing that we could not spend it on items or services that were being paid for prior to the grant’s application. If it was not supposed to be spent this way, then IDOE should have never approved it. To prevent noncompliance going forward, the school’s grant administrator will review disbursements of the program to ensure they were not spent on items or services that were in place prior to the grant’s application. Description of Corrective Action Plan: To prevent noncompliance going forward, the school’s grant administrator will review disbursements of the program to ensure they were not spent on items or services that were in place prior to the grant’s application. Cannelton management will establish a proper system of internal controls including policies and procedures related to risk assessment and monitoring activities within the federal program. Anticipated Completion Date: The noncompliance will be addressed immediately. The additional controls will be implemented by August 2025.

Information on the federal program: Subject: Education Stabilization Fund (ESSER) – Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S425U210013 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 Annual Data Reports to the Indiana Department of Education (IDOE) during the audit period to meet federal reporting requirements for ESSER grant awards. We noted that the ESSER II and ESSER III amounts reported on the Year 3 report ($288,565 and $115,716, respectively) did not agree to the underlying expenditure records ($139,081 and $88,437, respectively) for the period of July 1, 2022 through June 30, 2023. Corrective Action Plan: The School Corporation will implement a system of internal controls to ensure the amounts reported on the annual data reports agree to the underlying expenditure detail in the accounting system. Person responsible for implementation and projected implementation date: The Treasurer and the Superintendent will be responsible for implementing the corrective action plan, which will start with the next submission of the annual data report.

Information on the federal program: Subject: Education Stabilization Fund (ESSER) – Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Context: The School Corporation was required to submit two Annual Data Reports to the Indiana Department of Education (IDOE) during the audit period to meet federal reporting requirements for ESSER grant awards. We noted that the ESSER I and ESSER III amounts reported for the reports covering the FY22 time period ($22,163 and $409,347, respectively) did not agree to the underlying expenditure records ($3,796 and $404,347 respectively) for the period of July 1, 2021 through June 30, 2022. Additionally, we noted that the ESSER II amount reported for the reports covering the FY23 time period ($131,439) did not agree to the underlying expenditure records ($153,216) for the period of July 1, 2022 through June 30, 2023). We also noted there was no documented, secondary review of the information in the FY23 annual data reports by someone other than the preparer. Contact Person Responsible for Corrective Action: Dr. David Stashevsky Contact Phone Number: 765-378-3329 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The assistant superintendent will manage the grant with the superintendent providing oversight. The assistant superintendent will coordinate the receipts and expenditures of funds with the corporation treasurer. The superintendent will review all financial reports and approve in writing with notification sent to the assistant superintendent and treasurer. Anticipated Completion Date: The correction will be on the next annual report when it is due.

FINDING 2024-001 Information on the federal program: Subject: Education Stabilization Fund (ESSER) – Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness 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 Annual Data Reports were prepared by School Corporation management and reviewed by someone other than the preparer, however, the review process in place did not prevent, or detect and correct, errors. During testing of the accuracy of the annual data reports, the following errors were noted: • The Year 2 Annual Data Report for the ESSER III (84.425U) grant award reported total disbursements of $2,219,321 for the period of July 1, 2021 through June 30, 2022 compared to underlying disbursement detail of $2,715,940. • The Year 3 Annual Data Report for the ESSER III (84.425U) grant award reported total disbursements of $224,309 for the period of July 1, 2022 through June 30, 2023 compared to underlying disbursement detail of $306,194. Contact Person Responsible for Corrective Action: Kasey Clark Contact Phone Number: 574-772-1604 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: There will be two people who look over the ESSER reports before submitting to the state to make sure they agree with the reports. Anticipated Completion Date: When next report is due.

Department of Health and Human Services Response/Corrective Action Plan The Department of Health and Human Services agrees with the recommendation. During review of audit found two overpayment errors as a result of outdated supporting documents. Refunds have been requested. HHS provides ongoing training with eligibility and supervisory staff regarding document and eligibility requirements with staff. HHS actively monitors application quality and provides ongoing quality control reviews ensuring consistent adherence to best practices. Contact Person: Jessica Thomasson, Executive Policy Director Anticipated Completion Date: October 2024

Information on the federal program : Subject: Education Stabilization Fund (ESSER) – Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Context : The School Corporation was required to submit two Annual Data Reports to the Indiana Department of Education (IDOE) during the audit period to meet federal reporting requirements for ESSER grant awards. We noted that the ESSER II amount reported for the reports covering the FY22 time period ($230,281) did not agree to the underlying expenditure records ($4,290 for the period of July 1, 2021 through June 30, 2022). We also noted there was no documented, secondary review of the information in the annual data reports by someone other than the preparer. Contact Person Responsible for Corrective Action: Candace McDonald Contact Phone Number: 765-734-1261 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Director of Finance will review financial statements and ensure they agree to amounts reported on the annual data reports. Reviews will be documented with a signature. FTE documentation will be retained. Anticipated Completion Date: When the next report is due