Corrective Action Plans

Housing Voucher Cluster – Assistance Listing No. 14.871 / 14.879 – Eligibility Recommendation: We recommend management to implement controls and policies to ensure compliance with eligibility requirements. Additional training for housing specialists would also improve accuracy. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Monitor and quality control documents as required by HUD. If quality control determines there is a pattern of the same type of discrepancy, then corrective actions will be taken. The finding is based on 2 late reexaminations and failure to automatically identify a client as disabled. This is marked as a repeat finding in the same category, but is not the same type of finding as last year.

The City will review the wage-rate testing prepared by the consultant and formally document their review

The City will review the reports prepared by the consultant and formally document their review

State of Missouri Single Audit Corrective Action Plan Year Ended June 30, 2023 State Agency: Department of Elementary and Secondary Education (DESE) Audit Finding Number: 2023-017 DESE FFATA Reporting Name of the contact person responsible for corrective action: Shelley Woods Anticipated completion date for corrective action: July 1, 2024 Corrective action planned is as follows: DESE expended over $2.5 billion in federal funds in FY23, of which approximately $1.8 billion was applicable to FFATA reporting. While this CCDF grant finding constitutes less than 1% of an error rate in FFATA reporting, DESE agrees with the auditor's conclusion and will strengthen internal controls surrounding FFATA reporting. The grant has been reported in FSRS as of November 2023 to meet FFATA requirements. While procedures were updated in FY24 to strengthen internal controls based on previous findings, DESE has made further revisions to the procedure and grant tracking forms to ensure FFATA compliance.

State of Missouri Single Audit Corrective Action Plan Year Ended June 30, 2023 State Agency: Office of Administration Audit Finding Number: 2023-010, SLFRF Program Subrecipient Monitoring Name of the contact person responsible for corrective action: Stacy Neal Anticipated completion date for corrective action: September 2024 Recommendation A.: Develop policies and procedures to determine whether recipients of SLFRF program funds are subrecipients or contractors. Work with the state agencies to ensure accurate and documented determinations are prepared for all recipients and modify subrecipient records as needed. OA partially agrees with the auditor’s finding. Corrective action planned is as follows: OA believes there are opportunities to improve the classification of subrecipient vs. contractor to ensure compliance with federal regulations. We concur that OA, as the responsible party, should modify a department determination of subrecipient when there is a conflict with the regulation. Finally, we agree that clear communication on roles and responsibilities of OA vs. departments related to compliance is essential and can be improved. Given this position, we disagree that OA needs to issue procedures that restate the rules the uniform guidance and SLFRF regulations already state. We will continue to have discussions with agencies and ensure compliance with federal regulations. Recommendation B.: Develop a subrecipient monitoring program in accordance with the Uniform Guidance, that including performing risk assessments for each subrecipient for the purposes of determining the appropriate subrecipient monitoring procedures; monitoring for compliance with federal requirements and subaward terms and conditions and ensuring subaward performance goals are achieved; and reviewing subrecipient single audit reports. Ensure tasks delegated to state agencies are adequately communicated and establish procedures to ensure those tasks are appropriately completed. OA agrees with the auditor’s finding. Corrective action planned is as follows: OA approached the SLFRF money to consider all spending (whether to subrecipients or any other payment) as high risk due to the large dollar amount of one-time funding that is subject to rules that have changed over time. We have continued to treat this unique and highly publicized funding as high risk for fraud and exercise due diligence to mitigate that risk. OA agrees however, that our universal determination related to the SLFRF does not meet the specific uniform guidance rules. OA agrees to provide additional communications to departments to ensure agencies understand their responsibilities for sub-recipient monitoring including sub-recipient specific risk assessments and monitoring. Finally, OA will implement random reviews of the sub-recipient monitoring compliance.

State of Missouri Single Audit Corrective Action Plan Year Ended June 30, 2023 State Agency: Office of Administration Audit Finding Number: 2023-011 OA Statewide SEFA Name of the contact person responsible for corrective action: Stacy Neal Anticipated completion date for corrective action: September 30, 2024 Corrective action planned is as follows: We agree. DOA completed a materially correct SEFA within historically consistent timeframes including providing the document 3 weeks earlier than last year. However, after recent discussions with SAO, DOA does acknowledge a materially correct draft is needed by October to support an efficient single audit and we will provide the document on that timeframe next audit. DOA further recognizes that there are always opportunities for improved training, reduced turnover, and efficient communications.

State of Missouri Single Audit Corrective Action Plan Year Ended June 30, 2023 State Agency: Missouri National Guard (MONG) Audit Finding Number: 2023-018 – MONG Cooperative Agreement Extensions and Final Accounting Name of the contact person responsible for corrective action: Lindsey Hedges Anticipated completion date for corrective action: October 2024 Recommendation: The MONG establish controls and procedures to ensure a final accounting of all funding and disbursements and/or a written request(s) for extension is filed for each CA appendix in compliance with National Guard regulations. Corrective action planned is as follows: Missouri National Guard will implement internal controls and procedures for ensuring final accounting and extension requests are filed timely through regular monitoring of Cooperative Agreement (CA) appendices to identify upcoming lapses in completion of final accounting of all funding and disbursements or for extension request.

State of Missouri Single Audit Corrective Action Plan Year Ended June 30, 2023 State Agency: Department of Health and Senior Services Audit Finding Number: 2023-013 CACFP Subrecipient Monitoring Name of the contact person responsible for corrective action: Sarah Walker, Bureau Chief Anticipated completion date for corrective action: The agency does not agree with the audit findings or believes that corrective action is not required. Explanation and specific reasons are as follows: A- Risk Assessments DHSS disagrees with this recommendation because the risk assessment process performed by BCFNA is in compliance with the substance and spirit of federal regulations – both of the federal funding agency, USDA, and 2 CFR 200, Uniform Grant Guidance. BCFNA risk assessments consider relevant information and are used to determine the extent and timing of monitoring as set out in the Nutritionist Manual. The BCFNA risk-based monitoring approach already allows for monitoring subrecipients more frequently than required by USDA. 2 CFR 200.332 states pass-through entities are to evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). The BCFNA formal risk assessment process takes into consideration the results of current and previous experience with the same subaward (item 1 in the suggested criteria) as well as whether the subrecipient has new personnel or new or substantially changed systems (item 3 in the suggested criteria). These observations are made when performing onsite monitoring by Nutritionists who are familiar with the program, its requirements and its participants, and are trained in recognizing significant issues. BCFNA also takes into consideration the results of the subrecipient’s prior experience with similar subawards in other programs such as SFSP, NSLP and Child Care Licensing Reviews (item 1 in the suggested criteria), audit results (item 2 in the suggested criteria) as well as the results of Technical Assistance Reviews offered to new subrecipients which could move up the planned monitoring schedule. B- Subrecipient Monitoring Procedures DHSS disagrees with this recommendation. The State Auditor’s Office (SAO) states in this finding, “While our review found the sample monitoring reviews were performed in accordance with the policies and procedures outlined in the Internal Nutritionist Manual we identified areas where these policies and procedures could be strengthened and improved...” The SAO has not noted any specific noncompliance with federal requirements regarding subrecipient monitoring. The SAO’s finding noted the DHSS could enhance or improve it’s process but not that it is out of compliance with federal requirements for subrecipient monitoring. The SAO is trying to hold DHSS to a higher standard than what is federally required. Throughout the SAO’s finding they repeatedly acknowledge that the BCFNA monitoring process is in compliance with Nutritionist Manual which is based on USDA requirements, but is somehow not in compliance with broader federal requirements. This is incongruent with the accepted hierarchy of federal compliance guidance which says that 2 CFR 200 Uniform Grant Guidance is broader and less specific than the higher-ranking requirements set forth by specific federal grant funders and awards. In addition, the DHSS has a strong system of internal controls documented in the Nutritionist Manual which is in compliance with federal regulations and is used as a best practice by the USDA for other states. The report from the most recent USDA Management Evaluation Report for Fiscal Year 2023 issued November 2023 stated “The FNS determined that the SA Monitoring of Sponsors and SA Oversight of Sponsor Monitoring’s has adequate management controls in place for administering the CACFP in accordance with Federal regulations. The FNS staff reviewed SA practices that included detailed SA review forms, spreadsheets that provided extra oversight, and written procedures detailing the monitoring process. The SA provides online CACFP trainings along with a handbook to institutions that detail policies and procedures governed by the SA. The SA developed an extensive tracking system in addition to a very thorough review tool that contains meal component and pattern calculation. The SA conducts oversight of the review process and tracks each step to confirm completion of any follow up required of institution. The SA CACFP training resources and online modules were reviewed and evaluated to ensure it contained the correct information and up to date policies and procedures. The FNS staff reviewed the SA policies and procedures and interviewed key SA staff regarding procedures for each respective area of this Section. All files reviewed are compliant with Program requirements. The FY 2023 CACFP ME review did not identify any significant reportable issues.” The DHSS through BCFNA has and will continue to review, strengthen and enforce subrecipient monitoring procedures in accordance with federal program requirements and management evaluation. BCFNA has and continues to exceed what is required by the federal awarding agency by implementing a risk-based monitoring plan that allows for more frequent onsite monitoring than required by the USDA. In addition, even though COVID waivers allowed for monitoring to be suspended during the COVID Public Health Emergency, the BCFNA continued to monitor through the use of desk reviews. BCFNA also returned to onsite monitoring months before it was required by the USDA. Furthermore, BCFNA has recently hired a financial manager to help identify red flags with new and returning sponsors and recently enhanced training and technical assistance opportunities based on issues found during monitoring. Corrective Action Plans Due to the size of the CACFP program it is imperative that a risk-based approach be used in performing monitoring and follow up activities. DHSS through BCFNA follows up and ensures that subrecipients take timely and appropriate action on all deficiencies detected through on-site reviews of the subrecipient using a risk-based approach approved by the USDA. Standard practices are in compliance with federal regulations. Physical verification or review of supporting documentation immediately at the time of submission to verify the CAP is not a federal requirement. Follow-up during the next scheduled review is in accordance with USDA regulations and BCFNA policy and procedure. BCFNA reviews Corrective Action Plans (CAPs) submitted by subrecipients to ensure they are acceptable and correct noted issues. Supporting documentation of CAP implementation may be reviewed by BCFNA’s trained Nutritionist performing the monitoring reviews prior to the next monitoring visit if deemed necessary, or during the next onsite monitoring visit. This follow up is timely and appropriate because the scheduling of the next monitoring visit is determined by the USDA-approved risk-based approach. For example, subrecipients that had significantly deficient issues in their monitoring will be reviewed onsite within 90 days to verify whether corrective actions have been taken and if not, move towards termination. The corrective action plans of other subrecipients that were deemed to not be as significant by the Nutritionist, such as using the wrong percent of milk, are verified at the next monitoring review which could range from 1 to 3 years. The criteria used by the SAO do not specify what is timely or appropriate and allows for BCFNA’s professional judgement and discretion of what is timely and appropriate. Claims testing BCFNA standard practice is test only the selected month(s) claim(s) per USDA requirements, although when warranted, additional reviews are conducted beyond the test month. Actual noncompliance has not been noted in regards to testing. The BCFNA Nutritionist Manual allows for expanded testing if needed and BCFNA does perform expanded testing if deemed necessary. However, the USDA risk-based monitoring approach implemented by BCFNA sets prompt follow-up standards for significant deficiencies to determine if addressed, and if not, move on to termination. Overclaim recoupment BCFNA standard practice is to pursue recoupment of overclaims of only the test month per USDA requirements, although when warranted, additional reviews are conducted beyond the test month. In addition, BCFNA officials pursue recoupment of overclaims for facilities/sponsors with terminated contracts on a case-by-case basis, taking into consideration various factors. BCFNA strives to maintain an appropriate balance between adequate monitoring and not creating barriers to program participation per USDA and the Paperwork Reduction Act. Starting the termination process is more effective than performing additional testing and pursuing historically unsuccessful recoupment of overclaims. CACFP is an important program that provides healthy meals to children and adults. The CACFP plays a vital role in improving the quality of day care and making it more affordable for many low-income families. This entitlement program provides reimbursements for nutritious meals and snacks to organizations that serve eligible children and adults who are enrolled for care at participating child care centers, day care homes, emergency shelters and adult day care centers. CACFP processes an average of 700 claims per month and provided healthy meals in Missouri to over 31 million children and adults in 2023. USDA prohibits creating barriers to program participation and provision of services. The steps over and above the USDA requirements suggested by the SAO would place significant barriers to participation in the CACFP program and in turn cause harm to needy children and adults. The USDA established an acceptable level of risk with respect to the CACFP program and provided approved risk management processes and requirements. DHSS disagrees with the methodology the SAO used in its calculations. Out of the SAO’s test sample of 60 monitoring reviews, only 9 of the overclaims were over the $600 threshold of acceptable risk set by the USDA. 7 CFR 226.8(f): In conducting management evaluations, reviews, or audits in a fiscal year, the State agency, FNS, or OIG may disregard an overpayment if the overpayment does not exceed $600. A State agency may establish, through State law, regulation or procedure, an alternate disregard threshold that does not exceed $600. The SAO left the inflated error percentage in the body of the finding despite repeated requests and only included the lower suggested rates in footnote 4. The SAO also did not explain how their test of monitoring reviews performed by BCFNA, instead of a sample of claims submitted, was representative of CACFP reimbursements that would lend to projecting to the total population. BCFNA monitors using a risk-based approach as required in response to known erroneous claims and to proactively address issues. A sample of monitoring reviews is proportionally more likely to include a higher number of claims with discrepancies.

State of Missouri Single Audit Corrective Action Plan Year Ended June 30, 2023 State Agency: Department of Health and Senior Services Audit Finding Number: 2023-012 CACFP Subrecipient Reimbursements Name of the contact person responsible for corrective action: Sarah Walker, Bureau Chief Anticipated completion date for corrective action: The agency does not agree with the audit findings or believes that corrective action is not required. Explanation and specific reasons are as follows: CACFP Subrecipient Reimbursements DHSS disagrees. The DHSS through BCFNA maintains a strong system of internal controls over meal reimbursements to CACFP facilities/sponsors to ensure costs are allowable and supported. The system is in compliance with Uniform Guidance and USDA program requirements. The system includes subrecipient monitoring based on risk assessments per the substance and spirit of Uniform Guidance, initial and ongoing training and technical assistance opportunities, and reviews of invoices. Throughout the SAO’s finding they repeatedly acknowledge that the BCFNA monitoring process is in compliance with Nutritionist Manual which is based on USDA requirements, but is somehow not in compliance with broader federal requirements. This goes against the accepted hierarchy of federal compliance guidance which says that 2 CFR 200 Uniform Grant Guidance is broader and less specific than the higher ranking requirements set forth by specific federal grant funders and awards. The SAO has not noted any specific noncompliance with federal requirements regarding subrecipient monitoring. The SAO’s finding noted the DHSS could enhance or improve its process but not that it is out of compliance with federal requirements for subrecipient monitoring. The SAO is trying to hold DHSS to a higher standard than what is federally required. The DHSS’ strong system of internal controls which is documented in the Nutritionist Manual is in compliance with federal regulations and is used as a best practice by the USDA for other states. The report from the most recent USDA Management Evaluation Report for Fiscal Year 2023 issued November 2023 stated “The FNS determined that the SA Monitoring of Sponsors and SA Oversight of Sponsor Monitoring’s has adequate management controls in place for administering the CACFP in accordance with Federal regulations. The FNS staff reviewed SA practices that included detailed SA review forms, spreadsheets that provided extra oversight, and written procedures detailing the monitoring process. The SA provides online CACFP trainings along with a handbook to institutions that detail policies and procedures governed by the SA. The SA developed an extensive tracking system in addition to a very thorough review tool that contains meal component and pattern calculation. The SA conducts oversight of the review process and tracks each step to confirm completion of any follow up required of institution. The SA CACFP training resources and online modules were reviewed and evaluated to ensure it contained the correct information and up to date policies and procedures. The FNS staff reviewed the SA policies and procedures and interviewed key SA staff regarding procedures for each respective area of this Section. All files reviewed are compliant with Program requirements. The FY 2023 CACFP ME review did not identify any significant reportable issues.” This entitlement program provides reimbursements for nutritious meals and snacks to organizations that serve eligible children and adults. CACFP processes an average of 700 claims per month and provided healthy meals in Missouri to over 31 million children and adults in 2023. The increased claim testing and recoupment suggested by the SAO would create a significant barrier to participation for sponsors/facilities (many of which are small child care centers, day care homes, emergency shelters and adult day care centers) which is prohibited by USDA. Reviewing supporting documentation with every individual reimbursement claim at the time of submission as suggested in the finding is not feasible given the number of reimbursement claims processed monthly by program staff already functioning at capacity. Neither is it required by Uniform Guidance, the USDA or standard subrecipient monitoring procedures. The BCFNA already requires claims to be paid on a reimbursement basis rather than in advance and performs various reviews of the claims in CNPWeb, so the additional step of requiring supporting documentation with every reimbursement claim at the time of submission is unnecessary and is intended as a specific condition to remedy high risk subrecipients per 2 CFR 200.208. Furthermore, BCFNA offers technical assistance training and reviews in addition to regular monitoring reviews. In addition to the edit checks within the CNPWeb system which validate such things as capacity limits and licensing, BCFNA staff has, and continues to perform, additional verification such as spot-checks for inconsistencies (i.e. a greater number of enrolled participants as compared to licensed or total capacity or suspicious claim irregularities or patterns). Each claim submitted also requires a certification of truthfulness, accuracy, completeness with potential criminal, civil or administrative penalties in accordance with U.S. Code Title 18, Section 1001 and Title 31, Sections 3729-3730 and 3801-3812. As noted by the SAO, the risk based monitoring approach implemented by BCFNA has been effective in identifying significant issues and claim errors in recent years. The USDA established an acceptable level of risk with respect to the CACFP program and provided approved risk management processes and requirements. DHSS disagrees with the methodology the SAO used in its calculations. Out of the SAO’s test sample of 60 monitoring reviews, only 9 of the overclaims were over the $600 threshold of acceptable risk set by the USDA. 7 CFR 226.8(f): In conducting management evaluations, reviews, or audits in a fiscal year, the State agency, FNS, or OIG may disregard an overpayment if the overpayment does not exceed $600. A State agency may establish, through State law, regulation or procedure, an alternate disregard threshold that does not exceed $600. The SAO left the inflated error percentage in the body of the finding despite repeated requests and only included the lower suggested rates in footnote 4. The SAO also did not explain how their test of monitoring reviews performed by BCFNA, instead of a sample of claims submitted, was representative of CACFP reimbursements that would lend to projecting to the total population. BCFNA monitors using a risk-based approach as required and in response to known erroneous claims and to proactively address issues. A sample of monitoring reviews is proportionally more likely to include a higher number of claims with discrepancies. For example, fifty five percent of the monitoring reviews completed during fiscal year 2023 were graded as a B or C and were give additional technical assistance and/or monitoring follow up as a result.

Upon start of employment of a new City Administrator/Treasurer on October 9, 2023, that employee will be reviewing such reports and financial documents on a regular basis as part of his job duties.

FINDING 2023-001 Material Weakness – Procurement, Suspension, Debarment Contact Person Responsible for Corrective Action: Dana Gault Contact Phone Number: 765-382-3762 Views of Responsible Official: Agree with finding Description of Corrective Action Plan: The City Controller will search the SAM website for vendors the City has entered into a covered transaction with over $25,000 or more and print out the results. A debarment and suspension certification letter from the prospective third-party contractor, that are not in SAM’s system, will be collected or a clause included in the third-party contract regarding disclosure which will be reviewed by the Department Director and City Controller. The Department Directors will monitor throughout the year for debarment and suspension of thirdparty contractors that are not in SAM’s system. Anticipated Completion Date: Completion date for the planned corrective action is November 1, 2024

Finding 2023-002 Subject: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Summary of Finding: Material Weakness, Non-Compliance The County did not have controls in place to verify and ensure that an entity with which it plans to enter a covered transaction is not suspended or debarred. INDIANA STATE BOARD OF ACCOUNTS 21 Contact Person Responsible for Corrective Action: Dennis Spaeth Contact Phone and Email: 765-458-5464 auditor@unioncountyin.us Views of Responsible Official: Official concurs with finding. Description of Corrective Action Plan: Any vendor that Union County uses in the future, will be researched to make sure they are eligible to receive federal funds for transactions exceeding $25,000. This will be accomplished by having the County Auditor along with the Deputy Auditor perform one of the following to verify that potential vendors are eligible for the receipt of federal funds: 1) check the Sam.gov website 2) obtain a certification from the vendor, or 3) ensuring a clause or condition is included in the contract with the vendor for the covered transaction. Anticipated Completion Date: A new procedure is in place effective August 2024. The documented oversight will be available and provided for review with the 2024 annual audit.

Federal Agency Name: Department of Homeland Security Pass-Through Entity: State of Iowa Homeland Security & Emergency Management Federal Financial Assistance Listing #97.039 Program Name: Hazard Mitigation Grant Program Finding Summary: In three of three quarterly reports tested, the Cooperative improperly excluded information on the total funds expended to date lines for the federal, state, local and total categories. Corrective Action Plan: Future quarterly reporting will include reporting of total funds expended for applicable line items. General Manager will review quarterly submissions before submitting to Homeland Security. Responsible Individuals: Mark Vander Pol, Office Manager and JeffTenNapel, General Manager Anticipated Completion Date: October 2024

FINDING 2023-003 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds – Procurement and Suspension and Debarment Summary of Finding: The City did not obtain price or rate quotes for the one vendor tested that was less than the simplified acquisition threshold of $150,000 but exceeded the $10,000 micro-purchase threshold. The micro-purchase threshold may be increased, but the City did not provide documentation that the threshold had been increased. Documentation detailing the history of procurement, which must include the reason for the procurement method used, was not available for audit. A population of 9 covered transactions for goods or services were paid from Coronavirus State and Local Fiscal Recovery Fund funds during the audit period. A sample of 3 transactions were selected for testing. Of the 3 transactions tested, 1 vendor was not verified to not suspended nor debarred, or otherwise excluded or disqualified from participating in federal assistance programs or activities. Contact Person Responsible for Corrective Action: Craig Wright - Controller Contact Phone Number and Email Address: 765-747-4828 cwright@muncie.in.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Correcting the audit findings is ongoing. The city has implemented monitoring procedures to review and prevent reoccurring errors. Anticipated Completion Date: The internal control monitoring and checks and balances will be implemented immediately and continue going forward.

Title of result and comment:: Frankton FINDING 2023‐006 Contact person Responsible for Corrective Action: First Name: Timothy Last Name: Detrick Contact’s Phone Number:: (765) 754‐7285 Contact’s Email Address:: tdetrickct@gmail.com Views of Responsible Official: We concur with the finding Description of Corrective Action Plan:: We have started a ledger that will keep track of all funds/grants that may not appear on our bank Rec. They will be check every month by the board to make sure they are accurate. Anticipated Completion Date: Year: 2024 Month: 6 Day: 14 If applicable: Document reason issue will NOT be corrected within 6 months::

Title of result and comment:: Frankton FINDING 2023‐005 Contact person Responsible for Corrective Action: First Name: Timothy Last Name: Detrick Contact’s Phone Number:: (765) 754‐7285 Contact’s Email Address:: tdetrickct@gmail.com Views of Responsible Official:: We concur with the finding. Description of Corrective Action Plan:: Same as before CAP ‐ Any contract we establish we are goign to make sure they are now excluded or disquali ed by: (a) Checking SAM Exclusions; or (b) Collecting a certi cation from that person; or (c) Adding a clause or condition to the covered transaction with that person" We will also have a clause in our contracts that state they will Buy America Preference material. Anticipated Completion Date: Year: 2024 Month: 6 Day: 1 If applicable: Document reason issue will NOT be corrected within 6 months:: INDIANA STATE BOARD OF ACCOUNTS 34 Unit Name: Town of Frankton County: Madison Report period beginning date: Year: 2023 Month: 1 Day: 1 Report period ending date: Year: 2023 Month: 12 Day: 31

Title of result and comment:: Frankton FINDING 2023‐004 Contact person Responsible for Corrective Action: First Name: Timothy Last Name: Detrick Contact’s Phone Number:: (765) 754‐7285 Contact’s Email Address:: tdetrickct@gmail.com Views of Responsible Official:: We concur with the finding. Description of Corrective Action Plan:: We are making an Asset Ledger this year. And we will keep it updated every two years and add to it when we purchase a asset that exceeds $5,000. I will also have our Town Administrator double check. Anticipated Completion Date: Year: 2024 Month: 7 Day: 1 If applicable: Document reason issue will NOT be corrected within 6 months:: INDIANA STATE BOARD OF ACCOUNTS 33 Unit Name: Town of Frankton County: Madison Report period beginning date: Year: 2023 Month: 1 Day: 1 Report period ending date: Year: 2023 Month: 12 Day: 31

Title of result and comment:: Frankton FINDING 2023‐003 Contact person Responsible for Corrective Action: First Name: Timothy Last Name: Detrick Contact’s Phone Number:: (765) 754‐7285 Contact’s Email Address:: tdetrickct@gmail.com Views of Responsible Official:: We concur with the finding. Description of Corrective Action Plan:: All contract we make will start going through, Checking SAM Exclusions; or Collecting a certification from that person; or Adding a clause or condition to the covered transaction with that person". We will also add a clause that any Federal Government Grant will buy America Preference Material. Anticipated Completion Date: Year: 2024 Month: 5 Day: 14 If applicable: Document reason issue will NOT be corrected within 6 months:: INDIANA STATE BOARD OF ACCOUNTS 32 Unit Name: Town of Frankton County: Madison Report period beginning date: Year: 2023 Month: 1 Day: 1 Report period ending date: Year: 2023 Month: 12 Day: 31

FINDING 2023-06 Finding Subject: Child Support Enforcement - Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Cash Management, Period of Performance Summary of Finding: No documented oversight Contact Person Responsible for Corrective Action: Amy L. Glackman Contact Phone Number: 317-392-6310 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Control procedures will be put into place effective immediately. The Auditor will meet with every department that has state grants and make sure that all invoices are double check for proper expenditures and have both employees sign off on the claim. Anticipated Completion Date: August 30, 2024

FINDING 2023-05 Finding Subject: COVID-19 Coronavirus State and Local Fiscal Recovery Funds – Procurement and Suspension and Debarment Summary of Finding: No procurement policy is in place and vendors were not confirmed to not be suspended or debarred. Contact Person Responsible for Corrective Action: Amy L. Glackman Contact Phone Number: 317-392-6310 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Control procedures will be put into place effective immediately. The Auditor will start checking all vendors paid from grants for suspension, debarred or excluded from being able to enter into contracts. Additionally, a procurement policy will be put into place. Anticipated Completion Date: August 30, 2024

FINDING 2023-04 Finding Subject: COVID-19 Coronavirus State and Local Fiscal Recovery Funds – Reporting Summary of Finding: Reports were incorrectly completed, excluded amounts for the report period. Contact Person Responsible for Corrective Action: Amy L. Glackman Contact Phone Number: 317-392-6310 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Control procedures will be put into place effective immediately. The Auditor will have the Deputy Auditor start signing off on all reports to verify the dates are correct for the reporting period. Anticipated Completion Date: August 30, 2024

The Board of County Commissioners will work with all County Officials to go over all grants and federal monies that Comanche County receives to ensure that proper internal controls are implemented.

Management recognizes the importance of maintaining proper documentation for grant expenditures and has implemented the following corrective measures to address the deficiency: 1. Development of Comprehensive Documentation Guidelines: We have developed detailed guidelines outlining the specific documentation requirements for all grant-related expenditures. This includes mandatory documentation such as receipts, invoices, contracts, and timekeeping records, as well as detailed descriptions of each expense. 2. Centralized Repository for Grant Documentation: A centralized, secure digital repository has been established to store all grant-related documentation. All departments are now required to upload supporting documents immediately after incurring expenses, ensuring they are readily accessible for review and audit purposes. 3. Staff Training on Documentation Requirements: We have initiated a mandatory training program for all fiscal staff involved in grant management. This training covers the specific documentation and reporting requirements for federal, state, and private grants, emphasizing the importance of complete and accurate records. 4. Strengthened Review and Approval Process: We have enhanced the internal review process for grant expenditures. All grant-related transactions will be subject to a secondary review by the controller and Chief Financial Officer to ensure that the necessary supporting documents are included and expenditures are properly classified and documented. Management will closely monitor adherence to the new documentation policies and conduct quarterly audits to assess the completeness and accuracy of the records. Any discrepancies or missing documentation will be addressed promptly, and corrective actions will be taken to prevent recurrence. Management is fully committed to maintaining detailed and accurate records for all grant expenditures. The actions outlined above are designed to strengthen internal controls, ensure compliance with grant requirements, and support future audits with comprehensive documentation.

2023-004 Federal Grants Management – Procurement Policy Recommendation: We recommend County use sam.gov or the ELPS listing to review clients at the beginning of the year or before a transaction is incurred in accordance with the Uniform Guidance requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: Train staff on 1. Sam.gov and ELPS sites 2. Collecting a certification from entity (SBA Form 1624, Certification Regarding Debarment, Suspension, Ineligibility and Voluntary Exclusion Lower Tier Covered Transactions) 3. Adding a clause or condition to the covered transaction with entity (2 CFR section 180.300) Name(s) of the contact person(s) responsible for corrective action: Kim Merrill, Finance Manager Planned completion date for corrective action plan: Staff Training – November 2024

FINDING 2023-003 Finding Subject: Town of Kingman Summary of Finding: The auditor found a lack of internal controls related to the grant agreement. Also, the RD-442-3 was not submitted. Contact Person Responsible for Corrective Action: Kendal Buker Contact Phone Number and Email Address: 765-397-3921; utilities@kingmanin.com Views of Responsible Officials: 􀀃 I concur with the finding of the lack of submission of the RD 442-3. Description of Corrective Action Plan: I will work with official from USDA-RD to complete the RD 442-3. Anticipated Completion Date: I anticipate to have the RD 442-3 completed by 12/31/2024. Sincerely, Kendal Buker Clerk-Treasurer Town of Kingman