Corrective Action Plans

Finding 2024-002 – The Organization provided humanitarian assistance to migrants and asylum seekers turned over by Customs and Border Protection (CBP), including meals, transportation and shelter at hotels and the Organizations Respite Center. The Organization has intake procedures in place with respect to hotel shelter expenditures. However, the intake process was not consistently applied to all participants. The Organization was not able to provide supporting documentation for 5% of the requested sample of individuals who received shelter. Management's view: Management acknowledges this finding, and awareness has been brought to this area. The errors identified in this finding were made due to a lack of implementation of proper agency financial procedures by a former employee and occurred during a period of substantial influx in the number of non-citizen migrants being assisted. Authorization of credit card use was provided to one hotel vendor which led to unverified charges. This was identified and corrected by senior staff within three weeks. Proposed Corrective Action: The following measures were already taken to correct this finding: The organization has provided proper training to its program staff and accounting bookkeepers to improve the internal payment review process on all payment requests and has prohibited the use of credit cards to cover hotel stays for clients. All hotel payments are to be paid by check after reviewing the proper documentation submitted by the vendor, which includes an invoice with the non-citizen migrant's name as spelled in the Notice to Appear documentation provided by U.S. Customs and Border Protection. This documentation is then compared to the registration database maintained by the organization which includes name and A-number for all non-citizen migrants served. Any unauthorized payment will be immediately investigated and disputed on a timely basis. This policy has already been implemented successfully. An internal sample verification process was completed successfully with supporting evidence for all clients served after the previous unauthorized charges were identified within the period of three weeks. Anticipated Correction Date: These measures have been implemented.

Management agrees with the finding and recommendations, but also has determined that this finding will not be repeated in future years, as the arrearages program has come to a close.

Description of Corrective Action Plan: Shoals Community School Corporation will implement a secondary review of all reports submitted in the future regarding any federal funding. Kindra Hovis, Superintendent will share the reports with Kendra Wright, Treasurer and Kendra Wright, Treasurer, will share with Kindra Hovis, Superintendent all future federal awards’ expenditures and revenue reports to ensure accurate reviews and submissions. Responsible Party and Timeline for Completion: Kendra Wright, Treasurer and Kindra Hovis, Superintendent-this will be implemented monthly to review any federal funding moving forward.

FINDING 2024-004 Information on the federal program: Subject: COVID-19 – Education Stabilization Fund – Reporting 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 following exceptions in data reporting submissions:  ESSER I Year 4, ESSER II Year 3, and ESSER III Year 3 expenditures for the period of July 1, 2021 through June 30, 2022 ($0, $360,404, and $12,974, respectively) did not agree to underlying expenditure records ($60,937, $477,914, and $0, respectively).  ESSER II Year 4 and ESSER III Year 4 expenditures for the period of July 1, 2022 through June 30, 2023 ($57,667 and $363,486, respectively) did not agree to underlying expenditure records ($361 and $400,473, respectively). Description of Corrective Action Plan: Management will implement control processes surrounding federal data reporting to ensure that expenditures reported to granting agencies are in agreement with underlying records maintained by the School. Responsible Party and Timeline for Completion: Gretchen Berger, Corp Treasurer - 6-1-2025

Contact Person Responsible for Corrective Action: Dalton C. Tunis Contact Phone Number: 574-896-2155 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: An internal controls procedure will be put into place that ensures annual data reports are both reviewed and signed off on before submitting. The procedure will be that the Business Manager prepares the report and then reviews the report with the Superintendent. Once the Superintendent approves of the report he or she will sign of on the report and the report can be submitted. Documentation will be recorded to ensure the School Corporation stays in compliance with the requirements related to grant agreements and reporting requirements. Anticipated Completion Date: June 30, 2025

Finding 2024-001, Expense Allocations - Financial Management (Assistance Listing 16.575) Persons Responsible: Irene Math, Chief Financial Officer, Jessica Schneibolk, Controller Comment: Per 2 CFR § 200.302(a) (Financial Management), all recipient and subrecipient financial management systems must be sufficient to track expenditures and establish that funds have been used in accordance with federal statutes, regulations, and the terms and conditions of the federal award. Response: WJCS acknowledges the audit finding regarding the misallocation of occupancy expense. We are committed to strengthening our internal controls by implementing a more structured review process for expense allocations and will provide staff training on accurate cost classification. In addition, we will formalize documentation procedures to support updated automated expense allocations. Estimated Completion Date: The additional review procedures will be implemented by March 31, 2025, and will work to update financial system expense allocations by June 1, 2025

Department: Defense, Veterans and Emergency Management Title: Internal control over DG – PA program financial reporting needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Maine Emergency Management Agency (MEMA) Management Analyst participated in training on use of Public Assistance Federal grant management system, the Payment Management System. MEMA received ongoing feedback from Federal reviewers of submitted SF-425 reports. MEMA will revise the existing SOP for Federal Financial Reporting. MEMA will incorporate detailed review tabs to SF-425 Workbooks. MEMA staff involved in preparation and review of SF-425 reports will participate in further training on the process. Completion Date: June 11, 2025, first item, July 31, 2025, second item, April 30, 2025, third and fourth items, and June 30, 2025, fifth item Agency Contact: Sunny Cyr, MEMA Business Office Director, DVEM, 207-707-2507

Department: Health and Human Services Administrative and Financial Services Title: Internal control over WIC cash balances needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Department will contact the Federal Awarding Agency to identify steps needed to resolve the cash discrepancy. Completion Date: September 30, 2025 Agency Contact: Sarah Gove, Director, DHHS Service Center, DAFS, 207-458-6626

Department: Education Administrative and Financial Services Title: Internal control over CNC cash management needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Department has developed and implemented new procedures to confirm that batch payments are paid on time. Completion Date: March 15, 2025 Agency Contact: Jane McLucas, Director of Child Nutrition, DOE, 207-624-6880

Finding Number: 2024-002 Planned Corrective Action: Meals on Wheels of the Monterey Peninsula (MOWMP) will address the finding by taking the steps outlined below: 1. Expenditure of Federal Funds: Controller and/or bookkeeper will develop a process and procedures that will identify the amount, source, and expenditure of Federal funds for all Federal awards; that track and verify expenditures and income. Yearly reviews of the identification and tracking process will be conducted to ensure accuracy and relevance. 2. Federal Award Compliance: Controller and/or bookkeeper will develop a process and procedures to verify compliance with Federal statues, regulations, and the terms and conditions of each Federal award. Yearly reviews of the verification process will be conducted to ensure accuracy and relevance. Person Responsible for Corrective Action Plan: Leadership Oversight – Christine Winge, Executive Director Operational Oversight – Kay Smith, Controller Anticipated Date of Completion: MOWMP will complete the Corrective Action Plan by February 28, 2025 and these procedures will be in full effect for the fiscal year 2025.

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 II amounts reported for the reports covering the FY22 time period ($0 and $459,915 respectively) did not agree to the underlying expenditure records ($27,092 and $455,658 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 ($459,616 and $22,273 respectively) did not agree to the underlying expenditure records ($107,610 and $1,274,716 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. Additionally, the School Corporation was unable to provide the supporting reports containing the FTEs reported as of 9/30/22 and 9/30/23. Contact Person Responsible for Corrective Action: Jennifer Graves Contact Phone Number: 812-659-1424 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Federal reporting will be completed by the due date assigned and approved by the Superintendent prior to submission. After submission, the reports will be maintained. Anticipated Completion Date: Immediate

FINDING 2024-003 Finding Subject: COVID-19 - Education Stabilization Fund – Reporting Contact Person Responsible for Corrective Action: Carolyn Wallace Contact Phone Number and Email Address: 812-738-2168, extension 102 and WallaceC@shcsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The following internal controls will be implemented related to the required reporting of information:  Supporting details of reported information will be retained within the grant files for audit purposes.  Documentation of the collaboration between personnel submitting the report will be retained for audit purposes.  Documentation from the Indiana Department of Education to assure that the submitted data was correctly uploaded will be requested and retained for audit purposes. Anticipated Completion Date: June 30, 2025

FINDING 2022-004 Contact Person Responsible for Corrective Action: Jeff Gambill, Superintendent; Jennifer Barcus, Corporation Treasurer; Jeri Morin, Data Coordinator Contact Phone Number: 812-665-3550 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Superintendent will prepare all annual data reports and have a documented formal review from the Corporation Treasurer and the Data Coordinator, prior to submission, to validate the accuracy and completeness of the data submitted. Anticipated Completion Date: Immediate review will begin of all annual data reports.

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