Corrective Action Plans

Condition: During compliance testing of the District's accounting records to the expenditure report filed with the Illinois State Board of Education, we noted the District overclaimed $5,331 of expenditures at 6/30/24. Upon review of the general ledger and quarterly expenditure report, it was determined that the District erroneously overstated their claim amount on one function object code by a cumulative amount of $5,331. Under 2530-500, total expenditures were $1,084,669 but District claimed $1,090,000, resulting in an overclaim of $5,331. Plan: Management will review its policies and procedures to ensure that potential expenditures are deemed to be allowable before spending federal funds. In addition, the District will consider implementing a monitoring process to ensure that control procedures are being followed. Anticipated Date of Completion: 6/30/2025. Name of Contact Person: Dr. Dwayne E. Evans, Superintendent of Schools. Management Response: Management is currently strengthening internal control procedures over grant reporting and monitoring.

Condition: During compliance testing of the District's accounting records to the expenditure report filed with the Illinois State Board of Education, we noted the District claimed $80,199 of expenditures at 6/30/24. Upon review of the general ledger and quarterly expenditure report, it was determined that the District paid the expenditures in FY25 and thus should have been reported on a subsequent period's expenditure report. Plan: Management will review its policies and procedures to ensure that potential expenditures are deemed to be allowable in the proper reporting period before spending federal funds. In addition, the District will consider implementing a monitoring process to ensure that control procedures are being followed. Anticipated Date of Completion: 6/30/2025. Name of Contact Person: Dr. Dwayne E. Evans, Superintendent of Schools. Management Response: Management is currently strengthening internal control procedures over grant reporting and monitoring.

FINDING 2024-005 Subject: Child Nutrition Cluster –Reporting Audit Finding: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Linda Zaborowski, CFO Contact Phone Number and Email Address: (219) 881-5536 lzaborowski@garycsc.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: Gary Community School Corporation (GCSC) is taking immediate action to strengthen internal controls over meal count reporting. The district will fully utilize the Skyward Student Information System to track all meals, including those processed through the Point of Sale (POS) system and a la carte items, ensuring a standardized process across all schools. To improve accuracy and prevent over-claiming, GCSC is implementing a unique student ID system where each student will either scan their ID card or manually enter their assigned ID number when receiving a meal. The CFO/Food Service Director will conduct daily reconciliations of meal counts with the Food Service Management Company (FSMC) and verify all claims against source records to prevent errors. Monthly claims will be reviewed for accuracy, ensuring that second student meals and staff meals are excluded. Additionally, GCSC will establish clear policies and procedures requiring the FSMC to provide complete and accurate data for all claim submissions. Regular internal audits and staff training will be conducted to enforce compliance, and an oversight process will be implemented to detect and correct discrepancies before submission. Anticipated Completion Date: Gary Community School Corporation will implement this procedure by March 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 II and ESSER III amounts reported for the reports covering the FY22 time period ($0 and $0, respectively) did not agree to the underlying expenditure records ($79,112 and $99,245 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 ($178,829 and $874,154, respectively) did not agree to the underlying expenditure records ($159,450 and $789,489), 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: Abigail Lindsey Contact Phone Number: 765-853-5464 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Corporation will make sure all expenditures match annual data reports. Anticipated Completion Date: 05/01/2025

The University acknowledges the audit finding and remains committed to maintaining compliance with the cash management requirements outlined in 2 CFR 200.302(b)(3), which stipulates that recipients must maintain records that sufficiently identify Federal awards and ensure that drawdowns are properly supported and authorized prior to submission. During the audit period, the University experienced a transition in leadership within the Office of Research Administration. As part of this transition, the Associate Vice President for Research Administration was responsible for reviewing and approving drawdown requests. However, due to staffing adjustments and process changes during this period, at least two drawdowns were processed without prior approval from the Associate Vice President. Additionally, at least one drawdown was approved retroactively after submission. To address these issues and strengthen compliance, the University has implemented several corrective actions. A new Assistant Vice President of Post-Award Services and Financial Compliance has been hired on January 8, 2024 to provide dedicated oversight and ensure adherence to compliance standards. Furthermore, the Executive Director of Cash Management, the Assistant Vice President of Post-Award Services and Financial Compliance, and the Associate Vice President of Research Administration have all received targeted training in May of 2024 to reinforce the requirement for supervisory approval prior to drawdown submission. The University has also conducted a comprehensive review of its cash management processes, implementing enhanced internal controls to ensure all drawdown requests are reviewed, verified, and approved by designated leadership before submission. Lastly, a formalized transition plan has been developed to ensure continuity and compliance during future changes in leadership if such events were to occur. These corrective actions underscore the University’s commitment to maintaining the accuracy and integrity of its financial management processes. While no questioned costs were identified, the steps outlined above will help ensure ongoing compliance with Federal cash management requirements. Primary responsibility for implementing the correction action plan for this finding rests with Angela Tagliaferri, Assistant Vice President of Post-Award Services and Financial Compliance, 216-368-6269.

FINDING 2024-003 Finding Subject: COVID-19 - Education Stabilization Fund - Reporting Summary of Finding: Annual Report for ESSER grants were all submitted but there was no supporting documentation showing internal controls of another person reviewing the information that was submitted was accurate. Contact Person Responsible for Corrective Action: Ginger Schenks Contact Phone Number and Email Address: 812-749-4755 ext 1143; gschenks@corp.egsc.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: The Treasurer will work with the Superintendent and/or Grant Administrator ensuring that annual financial reporting for federal grants is completed on time with review by the Superintendent. The Treasurer will supply the financial data for the time period of reporting to the Grant Administrator and/or Superintendent for their approval and submission of the annual financial report. The Superintendent and/or Grant Administrator will ensure that expenses align with the grant application prior to submission. The report and supporting documentation will be downloaded and the Treasurer and Superintendent will sign and date that report. This document will be in the grant folder in the Treasurer’s Office. Anticipated Completion Date: This process will begin with the next annual financial report due date.

Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and will take the following corrective action. The ESSER annual Data Collection reports will need to be reviewed more closely to ensure that they are matching to the disbursement detail in the accounting software. Once the superintendent has entered numbers into the report, there should be a second review of those numbers to the accounting software numbers by the corporation treasurer. In addition, detail of full-time equivalent employees needs to be documented by the deputy treasurer and retained with each report going forward. Responsible party and timeline for completion: Responsible party is Theresa Robbins, Corporation Treasurer. The timeline for completion is spring of 2025.

Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: This is isolated to FY23 reporting. Internal controls over ESSER reporting were not implemented by previous business office personnel. Corrective action involves the Treasurer preparing the reporting, reviewing the reports with the Superintendent, and confirming accuracy before submitting to the Department of Education. The approval is documented. This was implemented for Year 4 reporting submitted April 23, 2024. Completion Date: 4/23/2024

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 ($90,217 and $238,439, respectively) did not agree to the underlying expenditure records ($81,958 and $400,439 respectively, for the period of July 1, 2021 through June 30, 2022). Contact Person Responsible for Corrective Action: Michele Harrison/ Corporation treasurer Brian Byrum I Superintendent Contact Phone Number: M. Harrison:765-492-5101 B. Byrum: 765-492-5102 Views of Responsible Official: We concur with the finding. De cription of Corrective Acti0n Pl an: Our management team noted that the ESSER 1 and ESSR II spreadsheet submitted to the state was incorrect; however, the actual expenditures were correct every month. The spreadsheet was corrected in the following annual submission to the DOE (which is outside this audit window). The next Audit will show the corrected spreadsheet for ESSER I and ESSER II. It is also noted that the management team will implement more internal controls with regard to the preparer and reviewer being different personnel. For year 5 collection, the corporation treasurer will provide the expenditure reports, an outside consultant will prepare the spreadsheet, and have the current superintendent review before submitting. Anticipated Completion Date: 3/7/2025

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, ESSER II, and ESSER III amounts reported for the reports covering the FY22 time period ($3,000, $0 and $0, respectively) did not agree to the underlying expenditure records ($0, $207,168, and $104,885, 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 ($328,359 and $334,119, respectively) did not agree to the underlying expenditure records ($121,193 and $229,234, respectively, for the period of July 1, 2022 through June 30, 2023). Contact Person Responsible for Corrective Action: Melissa Dempsey Contact Phone Number: 812-546-2000 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Business Manager and Assistant will jointly review all expenditures or fedral grant awards with in the fiscal year that are to be reported to ensure accuracy of reporting. Anticipated Completion Date: July 2025

Management will review the SFDS protocols and processes with the appropriate staff in order enable the consistent application of sliding fees. This will be completed by June 30, 2025.

Management reviewed the process and determined that the error was self-identified and the necessary step were taken to be corrected by the fiscal year-end June 30, 2024. Management will further review the procedures that are in place to track available contract funding balances and implement adjustments in order to allow for the prevention, or timely detection and correction of, errors in federal draw-down requests. This will be completed by June 30, 2025.

We continue to review and update our procedures and process to insure that all financial transactions are properly allocated to programs/ properties funded with federal funds - Anticipated Completion Date-April 30, 2025.Responsible Contact Person-Kathleen Boyce, CFAO

FINDING 2024-003 Finding Subject: Education Stabilization - Reporting Summary of Finding: The School Corporation had not designed, nor implemented, a system of internal controls to ensure that the annual Elementary and Secondary School Emergency Relief (ESSER) Data Collection reports (Reports) were complete and accurately submitted. The Reports were prepared by one employee without a documented oversight, review, or approval process in place to prevent, or detect and correct, errors. Contact Person Responsible for Corrective Action: Trina Huff Contact Phone Number and Email Address: (812) 689-4114, thuff@jaccendel.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: Moving forward treasurer will provide even more information to the reviewer specifically pertaining to the findings and any other pertinent information for that person to have a better idea of what they are looking for and will keep documentation of the review being done and signed off on. Anticipated Completion Date: This will be corrected with the next round of ESSER reporting due January 2025.

Anticipated Completion Date: January 31, 2025 Responsible Contact Person: Andrew Szalay The root of this “significant finding” has been among the Program staff capturing receipts for small expenditures, such as water and ice, and such, from convenient stores, during construction with Habitat volunteers. These were all credit card receipts. In the fall of 2024, Habitat management have conducted two types of meetings to ensure source documentation is collected and submitted with financial records: 1. Individual conversations with every credit card holder about the importance of turning in receipts, no matter how small, documentation is critical. 2. Goup meeting with the “frequent offenders” and further emphasized the importance of turning in receipts. Credit card holders were warned that credit card privileges may be revoked if the problem continues. In addition, additional tools may be put into place to capture and retain documentation. This may include vendor apps and digital upload tools. Policies will also be reviewed to ensure practices and terms are consistent and clear for both credit card holders and other staff that submit expense reimbursement forms.

Reconciliations and Material Adjustments Corrective Action Plan Umatilla Morrow Head Start, Inc. recently added capacity and experience to the finance department by hiring two new staff members, a Payroll Specialist and an AP and Procurement Specialist. In addition, best practices and reconciliation timelines and guidance are being captured in financial policies and procedures being updated at this time. UMHS has also implemented new software tools that will assist in automating the department, providing additional time for staff members to implement a monthly review that includes reconciliations and tracking. This "internal auditing" process is relatively new to the department and will add a layer of accountability and accuracy in the recording and processing of the organization's financial activity. In addition, UMHS initiated recruitment for a permanent Director of Finance in summer 2024 and the search to hire for this position is open and ongoing. To supplement and support the current staff, UMHS will continue to provide additional training and guidance to the finance team to stay ahead of changes to federal and state guidelines, and to build on the knowledge and experience of the team. Adding a permanent Director of Finance will be essential as that staff member will be a member of the Senior Leadership Team and working in supporting and staffing the monthly Finance Committee meetings and supporting the UMHS Board of Directors' Treasurer. UMHS Senior Leadership Team will review and approve year-end financial schedules being provided to the auditors, as well as provide additional oversight and approval of year-end entries and closing processes. Timing for Implementation: Immediate and Ongoing Person(s) Responsible: Executive Director, Director of Finance, or Designee

Auditor recommendation: We recommend that the City establish policies and procedures for requesting reimbursement of grant expenditures on a monthly basis, including reconciliation of the expenditures and reimbursements under each grant. Views of Responsible Officials and Planned Correc􀀁ve Ac􀀁on: The City agrees with this finding. Vacancies in key posi􀀁ons including the Airport Manager and the Transit Director of Administra􀀁on meant that there was not sufficient exper􀀁se in the program areas to ensure that reimbursement requests were prepared and submi􀀂ed 􀀁mely. These key posi􀀁ons have now been filled. The City now has an Airport Manager with substan􀀁al experience managing municipal airports and overseeing federal funding for airports. The City also hired a Transit Director of Administra􀀁on with extensive federal and state grant management experience, and exper􀀁se in Transit programs. The Accoun􀀁ng Officer, Grants Manager and Accoun􀀁ng Financial Analyst posi􀀁ons in the Finance Department have been filled, and the Grants Division is now fully staffed. More robust staffing is allowing Finance to perform more oversight in addi􀀁on to working more closely with Transit and Airport program staff. Filling these key posi􀀁ons and retaining qualified staff is essen􀀁al to establishing a process for 􀀁mely requests for reimbursement, and reconcilia􀀁on of expenditures and reimbursement under each grant. The Transit Division is working with a contractor provided by the FTA on establishing policies and procedures to ensure compliance with federal grant requirements. This contractor is also providing training and technical assistance to the Transit program. The scope of this work includes ensuring requests for reimbursement of grant expenditures are submi􀀂ed 􀀁mely, and reconcilia􀀁ons of grant expenditures and reimbursements are completed 􀀁mely and accurately. The Airport Department is in the process of contrac􀀁ng with a vendor to assist with federal compliance and provide training for Airport staff on relevant Uniform Guidance requirements. The vendor’s scope of work will include helping with developing and documen􀀁ng policies and standard opera􀀁ng procedures for requests for reimbursement, and reconcilia􀀁on of expenditures and reimbursements. Addi􀀁onally, the Airport Department plans to create a Grant Accountant posi􀀁on which will be responsible for reconciling grant expenditures monthly and processing reimbursement requests quarterly. In CY25 the City plans to provide Uniform Guidance training for staff which will include internal controls related to cash management. Responsible Official:Emily Oster, Finance Director, James Harris, Airport Manager, Airport Heavy Equipment Mechanic, Gabrielle Chavez, Transit Director of Administration, Matthew Bonifer, Accounting Officer, Erika Lujan, Grants Manager Timeline and Es􀀁mated Comple􀀁on Date: June 30, 2025

Recommendation: Reconciliation of not only the total federal expenditures reported to the general ledger, but by budget line item and general ledger accounts. A review process of the reconciliation should be designed and implemented to ensure that both expenditures in total and by budget line item are reported accurately and are supported by the accounting records. Award budgets should be prepared and approved with the actual costs expected per the general ledger accounts to be incurred. Action Taken: Boys & Girls Clubs of Dane County will establish grant budgets at the time of a grant application. If awarded, this is the budget a PI/Program Manager will be trained on with instruction from Finance as to the respective general ledger codes that coincide with each budget line. If a diversion is necessary, budget modifications will be sought out. The individuals responsible are: Sr. Director of Grants & Compliance, Grant Writers, Controller, Finance Operations Administrator, PI’s/Program Managers over respective grants. The anticipated completion date is March 31, 2025.

WHPCA has hired a third-party accountant as well as implemented additional monitoring and review and approval procedures to strengthen its financial management.

WHPCA has hired a third-party accountant as well as implemented additional monitoring and review and approval procedures to strengthen its financial management.

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 on the Year 3 report ($572,289) did not agree to the underlying expenditure records ($558,956) for the period of July 1, 2021 through June 30, 2022. Additionally, we noted that the ESSER I, ESSER II, and ESSER III amounts reported on the Year 4 report ($105,506, $510,158, and $1,156,254, respectively) did not agree to the underlying expenditure records ($138,662, $316,236, and $1,158,054, respectively) for the period of July 1, 2022 through June 30, 2023. Contact Person Responsible for Corrective Action: David Rowe, Business Manager Contact Phone Number: 765-298-6505 Views of Responsible Official: We concur with the finding, while noting that all expenditures and revenue from reimbursements balance within our system. Description of Corrective Action Plan: Verify that all expenditure account numbers match those utilized by AFR and Gateway reporting. Anticipated Completion Date: Begin immediately, ongoing.

2024-002 Filing of Federal Financial Reports Federal Departments: Department of Justice, Office on Violence Against Women Assistance Listing #: 16.526 Compliance and Internal Controls Significant Deficiency Category of Finding – Reporting Name of contact person: Vivian Huelgo, President and CEO Corrective Action: Esperanza has assigned the contract accountant to be responsible for preparing these reports and implemented review processes to ensure these reports are accurate. Completion Date: The Organization has already adopted this corrective action.

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, S425U200013 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 and ESSER III amounts reported on the Year 3 report ($397,392 and $294,138, respectively) did not agree to the underlying expenditure records ($498,259 and $1,509,413, respectively, for the period of July 1, 2021 through June 30, 2022). Additionally, we noted that the ESSER II and ESSER III amounts reported on the Year 4 report ($400,501 and $294,129, respectively) did not agree to the underlying expenditure records ($412,324 and $287,065, respectively, for the period of July 1, 2022 through June 30, 2023). We noted that the 195 number of Full-time equivalent (FTE) positions on September 30, 2023 on the second report did not agree to the underlying records supporting number of 274 Full-time equivalent (FTE) positions on September 30, 2023. Contact Person Responsible for Corrective Action: Dawn Ray Contact Phone Number: 812.988.6601 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We will have someone other than the preparer of the report perform a documented review prior to submission to validate the accuracy and completeness of the data submitted. Anticipated Completion Date: Immediately upon the completion of the audit.

The Corporation will have a secondary review process in place to assure the information and timeline are correct before submission.

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 on the Year 3 report ($347,591 and $337,851 respectively) did not agree to the underlying expenditure records ($135,355 and $159,811 respectively). Additionally, we noted that the ESSER II amount reported on the Year 4 report ($233,093) did not agree to the underlying expenditure records ($267,310) of the School Corporation. Contact Person Responsible for Corrective Action: Vicki Jones Contact Phone Number: 765-793-4877 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Annual report data will be submitted with the requested information and will be verified with a sign-off by the Superintendent. Anticipated Completion Date: July 2025