Corrective Action Plans

Finding 499794 (2023-004)

Material Weakness 2023

Town of Upland

IN

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

FINDING 2023-04 Finding Subject: COVID-19 Coronavirus State and Local Fiscal Recovery Funds- Suspension and Debarment Summary of Finding: Material Weakness, Noncompliance Contact Person Responsible for Corrective Action: Mary Fletcher Contact Phone Number and Email Address: (765) 998-7439, mfletcher...

FINDING 2023-04 Finding Subject: COVID-19 Coronavirus State and Local Fiscal Recovery Funds- Suspension and Debarment Summary of Finding: Material Weakness, Noncompliance Contact Person Responsible for Corrective Action: Mary Fletcher Contact Phone Number and Email Address: (765) 998-7439, mfletcher@uplandindiana.com Views of Responsible Officials: We concur with this finding Description of Corrective Action Plan: Although we do have a federal grant consultant that does check the suspension and debarment status of contractors, the Town of Upland will adopt a Suspension and Debarment policy to issue that no contractor being paid with Federal funds are Suspended or Debarred. Anticipated Completion Date: 11/15/2024

View Audit 322658

Finding 499793 (2023-003)

Material Weakness 2023

Town of Upland

IN

Questioned Costs Internal Control / Segregation of Duties Allowable Costs / Cost Principles § 200.302 § 200.303 § 200.328 § 200.329

FINDING 2023-003 Finding Subject: COVID-19 Coronavirus State and Local Fiscal Recovery Funds- Activities Allowed and Unallowed. Summary of Finding: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Mary Fletcher Contact Phone Number and Email Address: (765) 998-74...

FINDING 2023-003 Finding Subject: COVID-19 Coronavirus State and Local Fiscal Recovery Funds- Activities Allowed and Unallowed. Summary of Finding: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Mary Fletcher Contact Phone Number and Email Address: (765) 998-7439, mfletcher@uplandindiana.com Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: Although the funds were transferred to utilities and not paid directly from ARPA Funds, the funds were used to make necessary investments in utility infrastructure during 2023. We have been fully informed of the guidelines for the use of the ARPA funds since this transfer occurred and will use the remaining funds according to the ARPA guidelines. The Clerk-Treasurer has contacted the Department of the Treasury to get guidance on what can be done to rectify our misuse of the funds. Anticipated Completion Date: Unknown- When a resolution is reached with the Federal Government.

View Audit 322658 Questioned Costs: $1

Finding 499792 (2023-002)

Material Weakness 2023

Monroe Fire Protection District

IN

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

FINDING 2023-002 (Auditor Assigned Reference Number) Finding Subject: Coronavirus State and Local Fiscal Recovery Funds – Suspension and Debarment Summary of Finding: Material Weakness, Other Matters – no policy to check for suspension and debarment prior to entering into transactions with vendors C...

FINDING 2023-002 (Auditor Assigned Reference Number) Finding Subject: Coronavirus State and Local Fiscal Recovery Funds – Suspension and Debarment Summary of Finding: Material Weakness, Other Matters – no policy to check for suspension and debarment prior to entering into transactions with vendors Contact Person Responsible for Corrective Action: Dustin Dillard, Chief Contact Phone Number and Email Address: 812-331-1906; ddillard@monroefd.org Views of Responsible Officials: “We concur with the finding.” Description of Corrective Action Plan: The District will adopt a policy related to State and Local Fiscal Recovery Funds (SLFRF) suspension and debarment requirements, and develop a system of internal controls that addresses the need to verify suspension, debarment, or other exclusions prior to entering into transactions with vendors who may have transactions equal to or exceeding $25,000 of federal funds in one year. Policy will include verification by checking the Excluded Parties List System (ELPS), collecting a certification from that vendor, or adding a clause or condition to the covered transaction with that vendor. Anticipated Completion Date: December 31, 2024

View Audit 322653

Finding 499789 (2023-002)

Significant Deficiency 2023

Caminar Latino Inc.

GA

Subrecipient Monitoring § 200.303

Condition: We reviewed all four subawards associated with the program during the audit period and noted that sub-award information for all four subrecipients was not submitted to the FSRS by the required submission deadline. Although all other compliance requirements were met, the late submission r...

Condition: We reviewed all four subawards associated with the program during the audit period and noted that sub-award information for all four subrecipients was not submitted to the FSRS by the required submission deadline. Although all other compliance requirements were met, the late submission represents a deficiency in reporting controls. Correction action: FSRS were submitted to the FFATA site. Responsible Person: Interim Co-CEO Anticipated completion date: Complete. Reports were submitted November 2023

View Audit 322640

Finding 499783 (2023-002)

Significant Deficiency 2023

Tri-County Senior Citizens and Housing, Inc.

CO

HUD Housing Programs Internal Control / Segregation of Duties Special Tests & Provisions § 200.303

Finding 2023-002: Section 8 Project-Based Cluster Federal Assistance Number: 14.182 and 14.195 U.S. Department of Housing and Urban Development (Repeat of Finding 2022-002) Compliance Requirements: Cash Management, El...

Finding 2023-002: Section 8 Project-Based Cluster Federal Assistance Number: 14.182 and 14.195 U.S. Department of Housing and Urban Development (Repeat of Finding 2022-002) Compliance Requirements: Cash Management, Eligibility, Reporting, Special Tests and Provisions Type of finding: Internal Control Over Compliance (significant deficiency) Recommendation: The Organization should strengthen its internal controls with adopted policies and procedures to ensure a review process is established through adequate segregation of duties. The Organization should consider assessing and realigning the duties and responsibilities of administrative staff allowing the administrator to act in a more supervisory position. Action Taken: The Operation Administrator is overall responsible the operation of Tri-County Senior Center and Housing; working together with the bookkeeping staff and Executive Director as partners to maintain financial records and budgets. The Executive Director will sporadically review tenant eligibility of new certifications and re-certifications, HAP Contracts, samples of monthly HAP Assistance Payment requests, and her presence when auditors are in-house as well any other assistance requested by Administrator. To ensure the health, safety, and well-being of the residents and staff, the Administrator oversees the responsibilities and duties of all other staff in their roles, (Administration Assistant/Program Administrator-Senior Center Activities; Administration Assistant-Membership, monthly newsletters, answer phones and any other duties requested by the Administrator), to guide them in their specific roles so they understand their duties and responsibilities as administrative staff, and ensuring the facility meets all regulatory compliance standards. If there are questions regarding this plan, please call the responsible party at (719) 852-5778. Sincerely yours, Monica Wolfe Executive Director Tri-County Senior Citizens and Housing, Inc.

View Audit 322625

Finding 499753 (2023-004)

Material Weakness 2023

City of Lawrence

IN

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Material Weakness § 200.1 § 200.303

FINDING 2023-004 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Reporting Contact Person Responsible for Corrective Action: Humphrey Nagila Contact Phone Number: 317-542-4554 Views of Responsible Official: We agree with this finding. The City will create a policy and procedu...

FINDING 2023-004 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Reporting Contact Person Responsible for Corrective Action: Humphrey Nagila Contact Phone Number: 317-542-4554 Views of Responsible Official: We agree with this finding. The City will create a policy and procedure to ensure appropriate segregation of duties and reviews, approvals, and oversight are in place for reporting. This policy will require that two staff members from the Controller's Office prepare the quarterly Project and Expenditure report (P&E report). One staff member shall be responsible for preparing the report and the other will complete a review and submission of the report. Anticipated Completion Date: 12/31/2024

View Audit 322579

Finding 499752 (2023-003)

Material Weakness 2023

City of Lawrence

IN

Procurement, Suspension & Debarment Subrecipient Monitoring Allowable Costs / Cost Principles § 200.303

FINDING 2023-003 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Suspension and Debarment Contact Person Responsible for Corrective Action: Humphrey Nagila Contact Phone Number: 317-542-4554 Views of Responsible Official: We agree with this finding. The City will create a pol...

FINDING 2023-003 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Suspension and Debarment Contact Person Responsible for Corrective Action: Humphrey Nagila Contact Phone Number: 317-542-4554 Views of Responsible Official: We agree with this finding. The City will create a policy and procedure to ensure compliance with Federal procurement laws. Additionally, our updated policy shall ensure that the City adheres to all procurement procedures outlined in Federal awards received by the City. This policy will ensure that contractors and subrecipients are not suspended, debarred, or otherwise excluded prior to entering any contracts or subawards. Anticipated Completion Date: 12/31/2024

View Audit 322579

Finding 499738 (2023-003)

Significant Deficiency 2023

National Network to End Domestic Violence, Inc.

DC

Internal Control / Segregation of Duties Reporting Matching / Level of Effort / Earmarking § 200.303

The process for cash draws has been updated to include preparation by a supervisor at the outsourced accounting firm, review by the manager at the outsourced accounting firm and by an individual at the organization, and draws are made by the manager at the outsourced accounting firm. The federal fin...

The process for cash draws has been updated to include preparation by a supervisor at the outsourced accounting firm, review by the manager at the outsourced accounting firm and by an individual at the organization, and draws are made by the manager at the outsourced accounting firm. The federal financial reports are entered into the system by the manager at the outsourced accounting firm based on a file created by the supervisor at the outsourced accounting firm. Before being submitted they are printed to PDF and sent to the VP of Finance for review. In the absence of a VP of Finance, the partner in charge of the engagement at the outsourced accounting firm will review. The above corrective actions will be taken by the end of this year, December 31, 2024.

View Audit 322559

Finding 499730 (2023-003)

Material Weakness 2023

City of Richmond

IN

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

FINDING 2023-003 Subject: Coronavirus State and Local Fiscal Recovery Funds - Suspension and Debarment Federal Agency: U.S. Department of Treasury Assistance Listing Number: 21.027 Federal Award Number: FY 2021 Pass-Through Entity: Direct grant Compliance Requirements: Procurement and Suspension and...

FINDING 2023-003 Subject: Coronavirus State and Local Fiscal Recovery Funds - Suspension and Debarment Federal Agency: U.S. Department of Treasury Assistance Listing Number: 21.027 Federal Award Number: FY 2021 Pass-Through Entity: Direct grant Compliance Requirements: Procurement and Suspension and Debarment Audit Findings: Material Weakness Condition: The City elected to receive the standard revenue loss allowance, allowing them to claim its total State and Local Fiscal Recovery Funds (SLFRF) allocation as revenue loss to use for government services. As such, all SLFRF program funds were expended under the revenue loss eligible use category. The U.S. Department of the Treasury (Treasury) determined that there are no subawards under this eligible use category, and that recipients’ use of revenue loss funds would not give rise to subrecipient relationships given that there is no federal program or purpose to carry out in the case of the revenue loss portion of the award. Prior to entering into subawards and covered transactions with SLFRF award funds, recipients are required to verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded. “Covered transactions” include, but are not limited to contracts for goods and services awarded under a non-procurement transaction (i.e. grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the Excluded Parties List System (EPLS), collecting a certification from that person, or adding a clause or condition to the covered transaction with that person. Due to the Treasury’s determination that the revenue loss eligible use category does not give rise to subawards, the City was only required to comply with suspension and debarment requirements related to covered transactions. Context: We noted there was one vendor that the City entered into contract with in the current year that exceeded $25,000 paid from SLFRF funds. This transaction, totaling $364,374 was selected for testing. The City was not able to provide support proving that the City had verified the vendor was not suspended or debarred prior to entering into the contract. Management asserts that this is being done, but support is not maintained. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The City will include a suspension and debarment clause into our federal contracts going forward. Responsible Party and Timeline for Completion: The Controller, Deputy Controller and the Director of Strategic Initiatives. The Corrective Action will be implemented in January 2025.

View Audit 322539

Finding 499726 (2023-002)

Significant Deficiency 2023

Nevada Test Site Historical Foundation

NV

Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking § 200.303

To ensure that only proper labor costs are included in grant funding requests, the invoice reported to the grant issuing agency is reviewed by the Project Manager and evidenced by his signature. This review includes reviewing the individual labor charges prior to signing the invoice. All individual...

To ensure that only proper labor costs are included in grant funding requests, the invoice reported to the grant issuing agency is reviewed by the Project Manager and evidenced by his signature. This review includes reviewing the individual labor charges prior to signing the invoice. All individuals who support the grant purpose and are funded by a grant will be separately identified and the ratio of allowable time to total time will be determined for each pay period. Allowable cost for each individual will be aggregated to the total labor cost for the period and be included in the invoice requesting fund draws. These procedures will be in effect as of the date of this writing.

View Audit 322531

Finding 499684 (2023-006)

Material Weakness 2023

St. Vincent De Paul Village, Inc.

CA

Questioned Costs Subrecipient Monitoring Matching / Level of Effort / Earmarking § 200.303

Corrective Action: Management will enhance and enforce existing policies and procedures over monitoring of rental reasonableness in compliance with HUD-determined fair market rent requirements. Management and Tenant Services team will perform a thorough review of all tenant files, a task executed in...

Corrective Action: Management will enhance and enforce existing policies and procedures over monitoring of rental reasonableness in compliance with HUD-determined fair market rent requirements. Management and Tenant Services team will perform a thorough review of all tenant files, a task executed in partnership with landlords and property management companies. Perform internal compliance checks with sub-recipients by FJV compliance staff on a quarterly basis. Finally, develop additional oversight procedures for accounting and documentation of tenant rents to guarantee accuracy within our accounting general ledgers. Name of Responsible Individual(s): Jason Brenier, Maria Rafanan, Jesse Casement, Christina Madriles, Ann Wieczorek, and Judy Bokhari Anticipated Completion Date: December 2024

View Audit 322528 Questioned Costs: $1

Finding 499667 (2023-005)

Material Weakness 2023

St. Vincent De Paul Village, Inc.

CA

Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking § 200.303 § 200.430

Corrective Action: Management is in the process of updating its written procedures to ensure that allowable costs and cost principles comply with 2 CFR 200.403. This includes Grants Accounting implementing a manual process that empowers program employees to submit and approve Time & Allocation Exce...

Corrective Action: Management is in the process of updating its written procedures to ensure that allowable costs and cost principles comply with 2 CFR 200.403. This includes Grants Accounting implementing a manual process that empowers program employees to submit and approve Time & Allocation Excel Sheets. These sheets include attestations certifying actual labor costs monthly. This information is then taken to input by the grants accounting team into the Request for Reimbursement (RFR). This measure ensures that labor costs are accurately reflected and compliant with regulatory requirements. In addition, Management will implement policies and procedures regarding regular review of allocations for workers compensation and other similar expenses to ensure accuracy. Name of Responsible Individual(s): Jason Brenier and Judy Bokhari Anticipated Completion Date: December 2024

View Audit 322528

Finding 499659 (2023-004)

Significant Deficiency 2023

St. Vincent De Paul Village, Inc.

CA

Subrecipient Monitoring Allowable Costs / Cost Principles Cash Management § 200.303 § 200.430

Corrective Action: Management will review all cost allocations and implement documented policies and procedures to ensure sufficient support of any allocations of costs is maintained as required by 2 CFR §200.403. In addition, Management has developed a cost allocation worksheet and framework and is...

Corrective Action: Management will review all cost allocations and implement documented policies and procedures to ensure sufficient support of any allocations of costs is maintained as required by 2 CFR §200.403. In addition, Management has developed a cost allocation worksheet and framework and is in the process of implementing a new procedure to ensure it is reviewed by accounting and grant managers to ensure accurate reporting. Name of Responsible Individual(s): Jason Brenier, Judy Bokhari, and Luz Gonzales-Toscano Anticipated Completion Date: December 2025

View Audit 322528

Finding 499644 (2023-003)

Significant Deficiency 2023

St. Vincent De Paul Village, Inc.

CA

Questioned Costs Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking § 200.303 § 200.430

Corrective Action: Management, in the immediate term, will review its oversight and controls on the manual process Grants Accounting implemented for obtaining Time & Allocation Excel Sheet and calculating payroll and benefits costs accurately onto the Request for Reimbursement (RFR). Furthermore, ma...

Corrective Action: Management, in the immediate term, will review its oversight and controls on the manual process Grants Accounting implemented for obtaining Time & Allocation Excel Sheet and calculating payroll and benefits costs accurately onto the Request for Reimbursement (RFR). Furthermore, management plans to collaborate with its Payroll Service Provider to capitalize on software upgrades, aiming to enhance the accuracy of Time & Allocation to grants and reduce errors by designing straight-through-process improvements. Name of Responsible Individual(s): Jason Brenier, Judy Bokhari, and Luz Gonzales-Toscano Anticipated Completion Date: October 2024 – immediate term and December 2025 - software implementation.

View Audit 322528 Questioned Costs: $1

Finding 499643 (2023-005)

Material Weakness 2023

City of New Castle

IN

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Material Weakness § 200.303

FINDING 2023-005 Finding Subject: COVID-19 STATE AND LOCAL FISCAL RECOVERY REPORTING Summary of Finding: There were deficiencies in the internal control system of the City over the grant’s reporting requirements. Contact Person Responsible for Corrective Action: Ashley Huffman Contact Phone Number a...

FINDING 2023-005 Finding Subject: COVID-19 STATE AND LOCAL FISCAL RECOVERY REPORTING Summary of Finding: There were deficiencies in the internal control system of the City over the grant’s reporting requirements. Contact Person Responsible for Corrective Action: Ashley Huffman Contact Phone Number and Email Address: 765-521-6803 nccityclerk@gmail.com Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Beginning Sept. 1, 2024, procedures put in place include the Clerk Treasurer and Deputy Clerk Treasurer verifying each other with the reporting. Internal controls are the Clerk Treasurer will review and include the information to prepare the required reports. Monthly receipt detail and disbursement detail reports will be included, with the Deputy reviewing that. Both will sign off after reviews and communication. Additionally, the monthly detail reports will be provided to the City's Finance Committee and Council who oversees the ARP funds. Anticipated completion date: September 1, 2024

View Audit 322522

Finding 499642 (2023-004)

Material Weakness 2023

City of New Castle

IN

Procurement, Suspension & Debarment Subrecipient Monitoring Allowable Costs / Cost Principles § 200.303

FINDING 2023-004 Finding Subject: COVID-19 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY - PROCUREMENT AND SUSPENSION AND DEBARMENT. Summary of Finding: There were deficiencies in the internal control system of the City resulting in noncompliance with the grant’s procurement and suspension and debarme...

FINDING 2023-004 Finding Subject: COVID-19 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY - PROCUREMENT AND SUSPENSION AND DEBARMENT. Summary of Finding: There were deficiencies in the internal control system of the City resulting in noncompliance with the grant’s procurement and suspension and debarment requirements. Contact Person Responsible for Corrective Action: Ashley Huffman Contact Phone Number and Email Address: 765-521-6803 nccityclerk@gmail.com Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The City Attorney will include certification language in contracts. The Clerk Treasurer will be overseeing by reviewing the contracts and checking SAM.gov. The Deputy Clerk Treasurer will be verifying. Anticipated completion date: September 1, 2024

View Audit 322522

Finding 499641 (2023-003)

Material Weakness 2023

City of New Castle

IN

Procurement, Suspension & Debarment § 200.1 § 200.303 § 200.317 § 200.318 § 200.319

FINDING 2023-003 Finding Subject: COVID-19 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY - PROCUREMENT AND SUSPENSION AND DEBARMENT. Summary of Finding: There were deficiencies in the internal control system of the City resulting in noncompliance with the grant’s procurement and suspension and debarme...

FINDING 2023-003 Finding Subject: COVID-19 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY - PROCUREMENT AND SUSPENSION AND DEBARMENT. Summary of Finding: There were deficiencies in the internal control system of the City resulting in noncompliance with the grant’s procurement and suspension and debarment requirements. Contact Person Responsible for Corrective Action: Ashley Huffman Contact Phone Number and Email Address: 765-521-6803 nccityclerk@gmail.com Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The City did not follow its policy for Federal Grant Disbursements. The Clerk Treasurer's office will ensure compliance with the Procurement requirement. The City has implemented maintaining contract files with the Deputy Clerk Treasurer reviewing to ensure they contain documentation of the history of the procurement, including the rationale for the method of procurement and selection of the vendor. Anticipated completion date: September 1, 2024

View Audit 322522

Finding 499635 (2023-005)

Material Weakness 2023

Floyd County

IN

Subrecipient Monitoring Internal Control / Segregation of Duties § 200.303 § 200.332

FINDING 2023-005 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Subrecipient Monitoring Summary of Finding: Both of the County’s subrecipients submitted quarterly reports for Quarter 2 of 2023, covering the time period from April 1st through June 30th. No other quart...

FINDING 2023-005 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Subrecipient Monitoring Summary of Finding: Both of the County’s subrecipients submitted quarterly reports for Quarter 2 of 2023, covering the time period from April 1st through June 30th. No other quarterly financial and performance reports were submitted to the County during the fiscal year. As part of the monitoring the County performed on the subrecipients in March 2023, they noted the subrecipients had been missing quarterly reports. Despite communications made by the County to obtain the missing quarterly reports, no other quarterly reports were submitted by the subrecipients. Contact Person Responsible for Corrective Action: Don Lopp, Director of Operations and County Planning Contact Phone Number and Email Address: 812-948-4110 and dlopp@floydcounty.in.gov Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: Staff will continue to work with Water companies regarding audit of projects and submission of all required quarterly reports. Anticipated Completion Date: Quarterly Reports will be collected until final December 2024 reporting. All subrecipient awards are required to be completed by December 2024.

View Audit 322513

Finding 499634 (2023-004)

Material Weakness 2023

Floyd County

IN

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Material Weakness § 200.1 § 200.303

FINDING 2023-004 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Reporting Summary of Finding: The County submitted four P&E reports during the audit period; however, the errors as identified below were noted on all four reports.  Quarterly Report: October 1, 2022 to...

FINDING 2023-004 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Reporting Summary of Finding: The County submitted four P&E reports during the audit period; however, the errors as identified below were noted on all four reports.  Quarterly Report: October 1, 2022 to December 31, 2022 Current period expenditures reported 7 projects with errors totaling $77,234. Cumulative expenditures reported 22 projects with errors totaling $3,955,669.  Quarterly Report: January 1, 2023 to March 31, 2023 Current period expenditures reported 7 projects with errors totaling $173,169. Cumulative expenditures reported 25 projects with errors totaling $2,633,217.  Quarterly Report: April 1, 2023 to June 30, 2023 Current period expenditures reported 2 projects with errors totaling $0, since expenditures were posted to the incorrect project. Cumulative expenditures reported 24 projects with errors totaling $2,372,744.  Quarterly Report: July 1, 2023 to September 30, 2023 Current period expenditures reported 3 projects with errors totaling $13,412. Cumulative expenditures reported 26 projects with errors totaling $2,273,749. Contact Person Responsible for Corrective Action: Don Lopp, Director of Operations and County Planning Contact Phone Number and Email Address: 812-948-4110 and dlopp@floydcounty.in.gov Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: As Director of Operations and Planning, the American Rescue Plan quarterly reports are submitted through the office. During the last two audit, it appears data input errors have occurred with the reporting of total expenditures. The initial corrective action of review was not sufficient to correct the data input errors. During the recent July 2024 quarterly report, staff reviewed the items on line and believe that all reporting has been corrected. Starting with the September reporting, two staff members will review the data input Anticipated Completion Date: September 2024 – For the third quarter reporting period.

View Audit 322513

Finding 499630 (2023-003)

Material Weakness 2023

Hamilton County Economic Development Corporation

IN

Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking Cash Management § 200.303

Condition: During our testing, we noted that expenses submitted on forms for reimbursement were allocated to the wrong budget category line items and did not agree to the underlying accounting records. Response: The Organization’s Board, CEO, and key HCEDC staG acknowledge the importance of refining...

Condition: During our testing, we noted that expenses submitted on forms for reimbursement were allocated to the wrong budget category line items and did not agree to the underlying accounting records. Response: The Organization’s Board, CEO, and key HCEDC staG acknowledge the importance of refining internal controls to ensure expenses are used as approved. In this case, the funding agency, Indiana Department of Education, classified some expenses in ways that the auditor and organization leadership felt did not align with the approved final use. This use was reiterated by organization leadership in the grant submission to the funding agency. The funding agency indicated that the response was forwarded to their finance team but provided no further instructions for amending budget categories within the project. All expenditures under the grant project complied with allowable uses within the approved grant submission scope. Organization leadership continued to request reimbursement according to the categories assigned by the funding agency while achieving the project objectives and operating within the established framework. Moving forward, organizational leadership has implemented additional checks and balances through the onboarding of a Grants Management System engagement of CliftonLarsonAllen LLP to better align assigned categories with approved use. Timeline for Implementation: • Grant Management Software – October 2024 • CliftonLarsonAllen LLP engaged – March 2024

View Audit 322512

Finding 499629 (2023-002)

Material Weakness 2023

Hamilton County Economic Development Corporation

IN

Questioned Costs Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking § 200.303

Condition: During our testing of federal expenditures, we noted that certain expenses were submitted twice for reimbursement. Response: The Organizations’ Board and Chief Executive Officer (CEO) and key HCEDC Staff recognize the need to further refine internal controls. Management recognized one ins...

Condition: During our testing of federal expenditures, we noted that certain expenses were submitted twice for reimbursement. Response: The Organizations’ Board and Chief Executive Officer (CEO) and key HCEDC Staff recognize the need to further refine internal controls. Management recognized one instance in which duplicate reimbursement occurred. The duplication was reported to the funding agency (Indiana Department of Education) upon discovery and reconciled in order to place grant expenditures in good standing. Corrective Actions Taken: HCEDC staff has been working with CliftonLarsonAllen since March 2024 to design and implement new controls to prevent these types of errors occurring in the future. HCEDC is also onboarding a Grants Management Software to provide additional tracking and reporting transparency for funders and audit purposes. Timeline for Implementation: • Grant Management Software – October 2024 • CliftonLarsonAllen LLP engaged – March 2024

View Audit 322512 Questioned Costs: $1

Finding 499559 (2023-001)

Significant Deficiency 2023

Nonprofit Finance Fund and Affiliate

NY

Questioned Costs Matching / Level of Effort / Earmarking Allowable Costs / Cost Principles § 200.303 § 200.430

Planned Corrective Action: NFF revised current year SEFA for expenses which did not meet the compliance requirement. In addition, management implemented review control whereby the expenditures will be reviewed to ensure compliance with federal agency requirements. Beginning in August 2024, NFF wil...

Planned Corrective Action: NFF revised current year SEFA for expenses which did not meet the compliance requirement. In addition, management implemented review control whereby the expenditures will be reviewed to ensure compliance with federal agency requirements. Beginning in August 2024, NFF will update its time and effort management and review of employees who perform work related to federal grants. This includes circulating a tracking spreadsheet monthly to relevant staff to certify their time and effort spent on eligible activities allowable for grant expenditure relative to their overall work performed, which will be used for salary and benefit allocations. The Finance team will circulate the spreadsheet first to relevant staff members for certification, and then department heads for management review and approval. For department head time and effort review and approval, the executive suite will review and approve. The spreadsheet and approvals will be saved as back up for the allocations each month.

View Audit 322416 Questioned Costs: $1

Finding 499556 (2023-005)

Material Weakness 2023

Fulton County

IN

Procurement, Suspension & Debarment § 200.1 § 200.214 § 200.303 § 200.317 § 200.318

FINDING 2023-005 Finding Subject: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Procurement and Suspension and Debarment Summary of Finding: Procurement - Policy The County had not established a purchasing policy that would reflect applicable state laws and regulations including pro...

FINDING 2023-005 Finding Subject: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Procurement and Suspension and Debarment Summary of Finding: Procurement - Policy The County had not established a purchasing policy that would reflect applicable state laws and regulations including procedures to avoid acquisition of unnecessary or duplicative items, procedures to ensure that all solicitations incorporate a clear and accurate description of the technical requirements for the material, product, or service to be procured and did not maintain written standards of conduct covering conflicts of interest and governing actions of its employees engaged in the selection, award, and administration of contracts. Procurement – Small Purchases The County had one vendor that was identified as being less than the simplified acquisition threshold of $150,000 but exceeding the $50,000 micro-purchase threshold. The one vendor was selected for testing. For the one vendor, the County did not obtain price or rate quotes nor was there documentation detailing the history of procurement, which must include the reason for the procurement method used. Suspension and Debarment One covered transaction paid with SLFRF grant funds was identified during the audit period. The covered transaction totaled $66,000 with $46,752 paid in the audit period. Upon review, the County had not performed procedures to ensure the vendor was not suspended or debarred, or otherwise excluded or disqualified, from participation in federal assistance programs or activities at any time during the audit period Contact Person Responsible for Corrective Action: Bryan Lewis Contact Phone Number and Email Address: 574-223-4764 and blewis@co.fulton.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The County will work on establishing a purchasing policy which will address federal procurement requirements. Before entering into contracts we will ensure the procurement procedures in the policy are followed and obtain quotes for vendors that meet the small purchase threshold as well as verify the suspension and debarment status. The Commissioners and Auditor’s office will work together to ensure requirements are met before payment is processed. Anticipated Completion Date: No later than December 31, 2024

View Audit 322411

Finding 499555 (2023-004)

Material Weakness 2023

Fulton County

IN

Reporting § 200.1 § 200.303

FINDING 2023-004 Finding Subject : COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Reporting Summary of Finding: The County submitted the P&E report on June 16, 2023, which was 47 days after the due date. Additionally, the report was not mathematically accurate and complete. The key l...

FINDING 2023-004 Finding Subject : COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Reporting Summary of Finding: The County submitted the P&E report on June 16, 2023, which was 47 days after the due date. Additionally, the report was not mathematically accurate and complete. The key line items of "Total Cumulative Expenditures" and "Current Period Expenditures" as reported on the P&E report did not agree to the County's ledger. Contact Person Responsible for Corrective Action: Christina Sriver Contact Phone Number and Email Address: 574-223-2912 and auditor@co.fulton.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Upon initial discussion of the Coronavirus State and Local Fiscal Recovery Funds report with State Board of Accounts a deputy auditor began to review the files and financial tracking. This employee will work to update all expenditures of the CSLFR funds to ensure accuracy on the upcoming report and submit timely. Anticipated Completion Date: No later than December 31, 2024

View Audit 322411

Finding 499553 (2023-002)

Material Weakness 2023

Putnam County

IN

Internal Control / Segregation of Duties Reporting Allowable Costs / Cost Principles § 200.1 § 200.303

FINDING 2023-002 Finding Subject: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds - Reporting Summary of Finding: The SLRF report did not include project information or amounts. Contact Person Responsible for Corrective Action: Auditor Contact Phone Number and Email Address: 765-653-551...

FINDING 2023-002 Finding Subject: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds - Reporting Summary of Finding: The SLRF report did not include project information or amounts. Contact Person Responsible for Corrective Action: Auditor Contact Phone Number and Email Address: 765-653-5513, auditor@putnam.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: We have reached out to Baker Tilly, who does the reports for the County, regarding our audit finding so they know the reporting requirements that will need to be done for the next project and expenditure report which is due to be filed by April 30, 2025. Once we receive the report from Baker Tilly we will have a county employee review for accuracy of the report. Anticipated Completion Date: April 30, 2025

View Audit 322406

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