Corrective Action Plans

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

Subrecipient Monitoring Questioned Costs 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

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles § 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

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

Finding 499547 (2023-001)

Significant Deficiency 2023

The Spero Project, Inc.

OK

Allowable Costs / Cost Principles Procurement, Suspension & Debarment § 200.302 § 200.303 § 200.305

CORRECTIVE ACTION PLAN The Spero Project, Inc. ( “Organization”), respectfully submits the following corrective action plan for the year ended December 31, 2023. Name and address of independent public accounting firm: HSPG & Associates, 5400 N. Grand Blvd., Suite 330, Oklahoma City, OK 73112. ...

CORRECTIVE ACTION PLAN The Spero Project, Inc. ( “Organization”), respectfully submits the following corrective action plan for the year ended December 31, 2023. Name and address of independent public accounting firm: HSPG & Associates, 5400 N. Grand Blvd., Suite 330, Oklahoma City, OK 73112. Audit period: As of and for the year ended December 31, 2023. The findings from the December 31, 2023, schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FEDERAL AWARDS FINDINGS – COMPLIANCE AND INTERNAL CONTROL Identifying Number: 2023-001; Lack of Written Policies and Procedures Recommendation: The Organization should develop and implement comprehensive written policies and procedures in accordance with the requirements of the Uniform Guidance. These should include, but not be limited to, the following areas: 1. Financial management, including procedures for payments and cash management. 2. Internal controls to ensure compliance with federal requirements. 3. Determination of allowable costs in accordance with federal regulations and the terms and conditions of the award. 4. Procurement standards and conflict of interest policies. 5. Time and effort reporting and compensation. The Organization should also ensure that staff are adequately trained in these policies and procedures to enhance compliance and operational efficiency. Action Taken: In response to the finding, management and will take action to develop and implement the necessary written policies and procedures by December 31, 2024. Comprehensive training will be provided to all relevant staff to ensure compliance with federal requirements. Anticipated completion date: December 31, 2024 Name of contact person and title: Ms. Kim Bandy, Executive Director

View Audit 322401

Finding 499544 (2023-005)

Material Weakness 2023

Town of Fountain City

IN

Procurement, Suspension & Debarment § 200.303

Finding 2023-005 – Coronavirus State and Local Fiscal Recovery Funds - Procurement and Suspension and Debarment (Material Weakness) Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides r...

Finding 2023-005 – Coronavirus State and Local Fiscal Recovery Funds - Procurement and Suspension and Debarment (Material Weakness) Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR section 200.303 states in part: "The non-Federal entity must use one of the following methods of procurement… (b) Simplified acquisition thresholds. The non-Federal entity is responsible for determining an appropriate simplified acquisition threshold based on internal controls, an evaluation of risk and its documented procurement procedures which must not exceed the threshold established in the FAR. When applicable, a lower simplified acquisition threshold used by the non-Federal entity must be authorized or not prohibited under State, local, or tribal laws or regulations. Context: For one procurement, it was noted that the Town did not have documented support of all quotes obtained. Management had support for one quote and noted that a second quote was obtained verbally. Management’s procurement policy states that three quotes must be obtained and the contract must be awarded to the lowest bid. Management did not document the basis for purchasing from the vendor that was utilized. Additionally, for one of the two procurements tested, management did not provide support indicating that the Town verified the vendor was not debarred or suspended. Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Management will ensure that the adopted procurement policy is followed and documents to support the process are maintained. Responsible Party and Timeline for Completion: The Clerk-Treasurer is the responsible party. The completion will go into effect in 2024.

View Audit 322400

Finding 499543 (2023-004)

Material Weakness 2023

Perry County

IN

Allowable Costs / Cost Principles Material Weakness Reporting § 200.1 § 200.303

FINDING 2023-004 Subject: COVID 19 - Coronavirus State and Local Fiscal Recovery Fund - Reporting Federal Summary of Finding: Perry County did not properly report period expenditures. The County submitted one P&E report during the audit period. Although the Deputy Auditor compiled the information fo...

FINDING 2023-004 Subject: COVID 19 - Coronavirus State and Local Fiscal Recovery Fund - Reporting Federal Summary of Finding: Perry County did not properly report period expenditures. The County submitted one P&E report during the audit period. Although the Deputy Auditor compiled the information for the report and the County Auditor reviewed and submitted the report, the internal controls were not effective in preventing, or detecting and correcting, errors. As a result, the P&E report contained errors. Contact Person Responsible for Corrective Action: Kristinia L. Hammack, Perry County Auditor Contact Phone Number: (812) 547-6427 Views of Responsible Officials: We concur with the audit finding. Description of Corrective Action Plan: The Auditor is now aware that the P&E Reporting Period is not calendar. All internal control will stay in place and this information will be noted for further SLFRF Reporting. The Auditor will review the reports prior to submission to ensure that the reporting period is not on a calendar year when reporting. Completion Date: March 1, 2025 INDIANA STATE

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Finding 499542 (2023-003)

Material Weakness 2023

Perry County

IN

Procurement, Suspension & Debarment Subrecipient Monitoring Allowable Costs / Cost Principles § 200.214 § 200.303

FINDING 2023-003 Subject: COVID 19 - Coronavirus State and Local Fiscal Recovery Funds - Suspension and Debarment Summary of Finding: The ineffective internal controls resulting in a failure of having processes and procedures in place to prohibit from contracting with or making subawards under cover...

FINDING 2023-003 Subject: COVID 19 - Coronavirus State and Local Fiscal Recovery Funds - Suspension and Debarment Summary of Finding: The ineffective internal controls resulting in a failure of having processes and procedures in place to prohibit from contracting with or making subawards under covered transactions to parties that are suspended and debarred or whose principals are suspended or debarred. Contact Person Responsible for Corrective Action: Kristinia L. Hammack, Perry County Auditor Contact Phone Number: (812) 547-6427 Views of Responsible Official: We concur with the audit finding. Description of Corrective Action Plan: Currently, the County requires all new vendors to complete a “Vendor Registration Form”. A new step that Procurement implemented as of September 30, 2024 will be verification of vendor’s status on sam.gov and attaching the screenshot to the LOW system. Procurement will update their vendor policy to specifically include this step. The Auditor’s Office will check incoming contracts from departments to ensure proper documentation is attached that verifies the vendor has been checked through sam.gov and in.gov. Once the contract has been approved by the Commissioners, the Auditor’s office will then upload the contract and supporting documents into Gateway. Anticipated Completion Date: September 30, 2024

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Finding 499533 (2023-004)

Significant Deficiency 2023

Hennepin County Minnesota

MN

Reporting Matching / Level of Effort / Earmarking Subrecipient Monitoring § 200.303 § 200.502 § 200.510

Subject: Hennepin County’s 2023 Corrective Action Plan Finding# 2023-004 Significant Deficiency in Internal Control—Schedule of Expenditures of Federal Awards (SEFA) Program(s): National Bioterrorism Hospital Preparedness Program (ALN 93.889); Immunization Cooperative Agreements (ALN 93. 268); COV...

Subject: Hennepin County’s 2023 Corrective Action Plan Finding# 2023-004 Significant Deficiency in Internal Control—Schedule of Expenditures of Federal Awards (SEFA) Program(s): National Bioterrorism Hospital Preparedness Program (ALN 93.889); Immunization Cooperative Agreements (ALN 93. 268); COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)(ALN 93. 323); Child Support Services (ALN 93. 563); State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (ALN 10.561) Type of Finding: Significant Deficiency in Internal Control over Compliance; Other Matter Compliance Finding Condition: While testing the SEFA, we noted that internal controls were not operating effectively over the preparation of the SEFA. In addition, we noted the following errors in the original SEFA we received for the audit: • $1,284,631 of expenditures were improperly included in ALN 93.889 when the amount should have been included in ALN 93.268. • $30,394 of expenditures was improperly included in ALN 93.889 when the amount should have been included in ALN 93.323. • $626,894 of expenditures related to ALN 93.563 was missing from the schedule. • $61,290 of expenditures related to ALN 10.561 was missing from the schedule. Hennepin County’s Corrective Action Planned in Response to Finding: The County will continue to strengthen controls over the preparation of the SEFA. Hennepin County Employee Responsible for the CAP: Elena Doran Planned Completion Date for CAP: September 30, 2024

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Finding 499527 (2023-008)

Significant Deficiency 2023

Hennepin County Minnesota

MN

Allowable Costs / Cost Principles Eligibility Student Financial Aid § 200.303

Subject: Hennepin County’s 2023 Corrective Action Plan Finding# 2023-008 Activities Allowed or Unallowed; Allowable Costs/Cost Principles; Eligibility Program: Foster Care Title IV-E (ALN 93.658) Type of Finding: Significant Deficiency in Internal Control over Compliance Condition: While we were...

Subject: Hennepin County’s 2023 Corrective Action Plan Finding# 2023-008 Activities Allowed or Unallowed; Allowable Costs/Cost Principles; Eligibility Program: Foster Care Title IV-E (ALN 93.658) Type of Finding: Significant Deficiency in Internal Control over Compliance Condition: While we were able to test manual compensating controls over activities allowed or unallowed, allowable costs/cost principles and eligibility, we were not able to review and test the automated application controls and the related ITGCs within the MAXIS and SSIS systems that reside within the State of Minnesota, but are utilized by the County, to determine whether the system controls are adequately designed and implemented and operating effectively. Hennepin County’s Corrective Action Planned in Response to Finding: Hennepin County will encourage the State to provide an independent audit of the design and implementation of MAXIS and SSIS system controls for the benefit of all counties. Hennepin County Employee Responsible for the CAP: Andra Roethler Planned Completion Date for CAP: December 31, 2024

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