Corrective Action Plans

FINDING 2022-008: ESSER REPORTING The ESSER Data Collection Repoti was submitted to the IDOE in 2022 within the compliance period. Three people, Superintendent, Treasurer, and Deputy Treasurer all worked on this report. There were no other employees in Central Office to review or cross check this report for internal control prior to submission. Corrective Action Plan: Central Office staff will print off the report, list the person that prepared the report, and sign the report for FY2023.

FINDING 2022-007: ESSER PAYROLL The School Corporation did not have a documented internal control over payroll claims in place relating to the Allowable Activities and Allowable Costs compliance requirements. Corrective Action Plan: Central Office staff will verify and sign reports for FY2023.

INDING 2022-006: ESSER PROCUREMENT Central Office was instructed by the IDOE to purchase the new cafeteria dishwasher from the Cafeteria Account and then file for reimbursement from the ESSER II grant. Five vendors were contacted by the Director of Operations to provide quotes to replace the cafeteria dishwasher. Two vendors, Stafford & Smith and C & T Design, provided quotes. Hobart Corporation and Commercial Parts declined to provide quotes. Best Kitchen did not respond to the email or phone call request. The school corporation did sign the quote provided by Stafford-Smith which was considered the contract between the two organizations. We have the contract on file. Corrective Action Plan: The school corporation will request certification from vendors regarding debarment, suspension, ineligibility of federal grants in excess of $50,000.000.

FINDING 2022-005: CAFETERIA NUTRITION CLUSTER REPORTING The Deputy Treasurer prints, verifies, initials the Employee Trial Balance Report (Payroll Report) every pay period. The Treasurer reviews these reports, but has not initialed them. Corrective Action Plan: The Treasurer will begin reviewing and initialing these reports for FY 2023. The Cafeteria Director will submit the child reimbursement form to Central Office for review and verification prior to submission for payment to the Indiana School Lunch Program for FY 2023.

Respectfully, the school corporation does not agree with several of the findings in regards to segregation of duties and purchases. First, the SBOA auditors' told the school corporation during the 2019 audit that operating the school lunch program through the extracurricular account was not legal. The school corporation was informed that this account must be transferred to Central Office and a Corrective Action Plan must be in place. This directive was incorrect and pointed out in the official response from November 5, 2019 under IC 20-26-5-4(a)(l l). Second, segregation of duties, oversight, and approval of functions existed in 2019 and are presently occurring daily, weekly, and monthly within the cafeteria program under the corporation accounts and supervision of Central Office. Cafeteria workers record and submit timesheets of duties performed during each payroll period. The Cafeteria Director verifies and signs timesheets to be submitted to the Treasurer and Deputy Treasurer for review and payment from the Cafeteria account. A payroll docket report is sent to the Superintendent prior to payment from the bank. Prior to the 2019 audit, the High School Treasurer spent approximately two hours per day counting cash received each day from school lunches purchased. She also receipted those funds it into the software system, made deposits to the bank, paid invoices for food expenses, and processed part of payroll. Tasks conducted by the High School Treasurer were segregated by a timesheet and supervised by the High School Principal. All those tasks were shifted to Central Office in 2020 and are now segregated to the Treasurer and Deputy Treasurer. The Treasurer documents hours spent on Cafeteria accounts on a timesheet for review and signature by the Superintendent. Financial reports of expenditures and revenues are provided for review and oversight to the Superintendent and School Board at monthly board meetings. Third, RSSC has a small Central Office consisting of a Superintendent, Treasurer, Deputy Treasurer, and Secretary. It has no Assistant Superintendents, Human Resources Director, or Business Manager. Each person in Central Office wears multiple hats and performs multiple duties each day. It was noted in the Audit Report filed from July 1, 2008 to June 30, 2010 that " ...Randolph Southern School Corporation is unable, due to financial limitations, to employ additional personnel to segregate duties in our receipts and cash and investment balances. This statement would apply to all of our internal controls. " The circumstances for RSSC have not changed in the audit periods from July 1, 2010 through June 30, 2022. Corrective Action Plan: The School Board had chosen not to add additional staffing due to costs. RSSC is still unable to segregate duties for financial transactions and reporting. Fourth, the Cafeteria Program only has one full-time staff member, the Cafeteria Director. Eight part-time cafeteria workers prepare and feed up to 300 students each day. This food service program is one of the best run programs in the State oflndiana. It has not had one food preparation or sanitation violation from IDOE or Department of Health in the last 12 years. Fifth, the Cafeteria Program is economically efficient and fiscally responsible. The account carries at least a 3-month cash balance at all times. This success is a direct result of oversight by the combination of the Superintendent, Treasurer, and Cafeteria Director. RSSC adopted board policy 6114 Cost Principles-Spending Federal Funds on May 9, 2016. RSSC has had an Indirect Cost Rate in place since 2013. The adopted policy allows the school corporation to apply Indirect Costs to all federal funds including the Cafeteria account. On December 5, 2019, email communications between the Dr. Donnie Bowsman, Superintendent and Tina Herzog, IDOE Assistant Director of Operations and Food Distributions clearly state the school corporation can apply the Indirect Cost Rate to the Cafeteria account. The email communication clearly states that the high cash balance was a result of not applying the Indirect Cost Rate to the Cafeteria account (See Exhibit 1 Emails). The Indirect Rate was approved by the IDOE Office of School Finance and existed prior to the audit years being referenced in the finding. Technically, the prospective portion (going forward for the next school year) as referenced on pages 24-25 of USDA Indirect Cost Guidance Manual pertains to the 2013 Fiscal Year. Moreover, the fact was reiterated by the IDOE School Nutrition Office with email communications on December 5, 2019, not 2021 or 2022 as referenced in the finding. RSSC has not charged or recouped the Cafeteria Account the Indirect Cost rate for many years and has subsidized this account which should be independent and self-sufficient. The School Corporation did not apply the Indirect Cost Rate in 2020 or 2021 because we were not sure how many students would be eating and how fiscally sound the account would be due to students not attending school because of COVID. Corrective Action Plan: The Indirect Cost Rate will be applied and collected in the future prior to June 30 of each current fiscal year. It should also be noted that in 2021, RSSC purchased a new cafeteria dishwasher utilizing ESSER II funds. This unit was 20+ years old and needed to be replaced in order to continue feeding children and to run the food service program. This expense could have been and should have been a direct cost of $58,189 to the Cafeteria account. However, due to the unknown circumstances of COVID, the RSSC could not take a chance. The ESSER II grant is still open and we are now questioning whether this expense could be charged directly to the Cafeteria account. Those ESSER II fund could be utilized for staffing to support student learning loss and remediation. Sixth, COVID caused this financial account to increase exponentially from 2020 to 2021. ESSER funds were provided by the federal government to provide free lunches to every child which paid the food operations expenses for two school years. Student participation of eating school lunches increased during these time periods. Additionally, staff members were receiving hazard pay incentives on top of their regular hourly rate. Further, the School Corporation and Cafeteria Program took on the enormous task of feeding children over the summers of 2020 and 2021 when COVID cases were at its peak. The cafeteria personnel fed 5286 and 5740 students respectfully during those summers. The number of meals served during the summer almost equaled the total amount of meals served during the entire school year for each respective academic year. These additional meals created additional unexpected revenues for the fiscal year. The school corporation did not charge mileage for satellite lunches being delivered or indirect costs.

Respectfully, the school corporation does not agree with several of the findings in regards to segregation of duties and purchases. First, the SBOA auditors' told the school corporation during the 2019 audit that operating the school lunch program through the extracurricular account was not legal. The school corporation was informed that this account must be transferred to Central Office and a Corrective Action Plan must be in place. This directive was incorrect and pointed out in the official response from November 5, 2019 under IC 20-26-5-4(a)(l l). Second, segregation of duties, oversight, and approval of functions existed in 2019 and are presently occurring daily, weekly, and monthly within the cafeteria program under the corporation accounts and supervision of Central Office. Cafeteria workers record and submit timesheets of duties performed during each payroll period. The Cafeteria Director verifies and signs timesheets to be submitted to the Treasurer and Deputy Treasurer for review and payment from the Cafeteria account. A payroll docket report is sent to the Superintendent prior to payment from the bank. Prior to the 2019 audit, the High School Treasurer spent approximately two hours per day counting cash received each day from school lunches purchased. She also receipted those funds it into the software system, made deposits to the bank, paid invoices for food expenses, and processed part of payroll. Tasks conducted by the High School Treasurer were segregated by a timesheet and supervised by the High School Principal. All those tasks were shifted to Central Office in 2020 and are now segregated to the Treasurer and Deputy Treasurer. The Treasurer documents hours spent on Cafeteria accounts on a timesheet for review and signature by the Superintendent. Financial reports of expenditures and revenues are provided for review and oversight to the Superintendent and School Board at monthly board meetings. Third, RSSC has a small Central Office consisting of a Superintendent, Treasurer, Deputy Treasurer, and Secretary. It has no Assistant Superintendents, Human Resources Director, or Business Manager. Each person in Central Office wears multiple hats and performs multiple duties each day. It was noted in the Audit Report filed from July 1, 2008 to June 30, 2010 that " ...Randolph Southern School Corporation is unable, due to financial limitations, to employ additional personnel to segregate duties in our receipts and cash and investment balances. This statement would apply to all of our internal controls. " The circumstances for RSSC have not changed in the audit periods from July 1, 2010 through June 30, 2022. Corrective Action Plan: The School Board had chosen not to add additional staffing due to costs. RSSC is still unable to segregate duties for financial transactions and reporting. Fourth, the Cafeteria Program only has one full-time staff member, the Cafeteria Director. Eight part-time cafeteria workers prepare and feed up to 300 students each day. This food service program is one of the best run programs in the State oflndiana. It has not had one food preparation or sanitation violation from IDOE or Department of Health in the last 12 years. Fifth, the Cafeteria Program is economically efficient and fiscally responsible. The account carries at least a 3-month cash balance at all times. This success is a direct result of oversight by the combination of the Superintendent, Treasurer, and Cafeteria Director. RSSC adopted board policy 6114 Cost Principles-Spending Federal Funds on May 9, 2016. RSSC has had an Indirect Cost Rate in place since 2013. The adopted policy allows the school corporation to apply Indirect Costs to all federal funds including the Cafeteria account. On December 5, 2019, email communications between the Dr. Donnie Bowsman, Superintendent and Tina Herzog, IDOE Assistant Director of Operations and Food Distributions clearly state the school corporation can apply the Indirect Cost Rate to the Cafeteria account. The email communication clearly states that the high cash balance was a result of not applying the Indirect Cost Rate to the Cafeteria account (See Exhibit 1 Emails). The Indirect Rate was approved by the IDOE Office of School Finance and existed prior to the audit years being referenced in the finding. Technically, the prospective portion (going forward for the next school year) as referenced on pages 24-25 of USDA Indirect Cost Guidance Manual pertains to the 2013 Fiscal Year. Moreover, the fact was reiterated by the IDOE School Nutrition Office with email communications on December 5, 2019, not 2021 or 2022 as referenced in the finding. RSSC has not charged or recouped the Cafeteria Account the Indirect Cost rate for many years and has subsidized this account which should be independent and self-sufficient. The School Corporation did not apply the Indirect Cost Rate in 2020 or 2021 because we were not sure how many students would be eating and how fiscally sound the account would be due to students not attending school because of COVID. Corrective Action Plan: The Indirect Cost Rate will be applied and collected in the future prior to June 30 of each current fiscal year. It should also be noted that in 2021, RSSC purchased a new cafeteria dishwasher utilizing ESSER II funds. This unit was 20+ years old and needed to be replaced in order to continue feeding children and to run the food service program. This expense could have been and should have been a direct cost of $58,189 to the Cafeteria account. However, due to the unknown circumstances of COVID, the RSSC could not take a chance. The ESSER II grant is still open and we are now questioning whether this expense could be charged directly to the Cafeteria account. Those ESSER II fund could be utilized for staffing to support student learning loss and remediation. Sixth, COVID caused this financial account to increase exponentially from 2020 to 2021. ESSER funds were provided by the federal government to provide free lunches to every child which paid the food operations expenses for two school years. Student participation of eating school lunches increased during these time periods. Additionally, staff members were receiving hazard pay incentives on top of their regular hourly rate. Further, the School Corporation and Cafeteria Program took on the enormous task of feeding children over the summers of 2020 and 2021 when COVID cases were at its peak. The cafeteria personnel fed 5286 and 5740 students respectfully during those summers. The number of meals served during the summer almost equaled the total amount of meals served during the entire school year for each respective academic year. These additional meals created additional unexpected revenues for the fiscal year. The school corporation did not charge mileage for satellite lunches being delivered or indirect costs.

Finding 2022-002 ? Child Nutrition Cluster ? Reporting Contact Person Responsible for Corrective Action: Tonia Batesole Contact Phone Number: 219-477-4933 x2141 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: When entering the Monthly Food Service Claim, a second person will check what has been entered correctly on the screen for reimbursement before submission. This will be signified by initials by both the checker and submitter. Anticipated Completion Date: Already in place.

2022-005 - Impact Aid Grant - Impact Aid Wage Rate Requirements - ALN 84.041 - Material Weakness Condition: Oberon Public School District did not have any procedures in place relating to the internal controls surrounding the Wage Rate Requirements applicable to the Impact Aid Grant funds for the construction of the new school. Corrective Action Plan: We agree, business manager will ensure that all wage rate reports are received for all future construction. Anticipated Completion Date: FY 2022-2023

FINDING 2022-008 Contact Person Responsible for Corrective Action: Dan Durrwachter Contact Phone Number: 765-473-3081 Views of Responsible Official: We agree with these findings. Description of Corrective Action Plan: The financial specialist will prepare a report the data for the reports and will be approved by the treasure to ensure accurate FTE is reported before submitting the reports. Anticipated Completion Date: : 6/01/2023

FINDING 2022-007 Contact Person Responsible for Corrective Action: Dan Durrwachter Contact Phone Number: 765-473-3081 Views of Responsible Official: We agree with these findings. Description of Corrective Action Plan: We will have our Financial Assistant become the point person for the management of equipment and real property. We will have a semiannual update to our inventory and keep an active identification number, a source of funding for the property, and a use and condition of the property. This report will be signed semiannually as well by the corporation treasurer. Anticipated Completion Date: : 6/01/2023

FINDING 2022-006 Contact Person Responsible for Corrective Action: Dan Durrwachter Contact Phone Number: 765-473-3081 Views of Responsible Official: We agree with these findings. Description of Corrective Action Plan: Corporation Test Coordinator will train the site test coordinators. The STCs will then train staff and have staff sign they have been trained. The STC will then give all signed agreements to the CTC who will then check with all signed agreement to all employees who work in the testing schools. Anticipated Completion Date: 6/01/2023

2022-004 Department of Housing and Urban Development Emergency Solutions Grants Program, Federal Financial Assistance Listing 14.231 Earmarking Significant Deficiency in Internal Control Over Compliance Finding Summary: The Organization has documented procurement procedures that conform to applicable federal standards; however, the procedures were not followed regarding maintaining documentation of obtaining three bids for simplified acquisition small purchases and the conclusion as to which item was selected. In addition, the Organization was not testing vendors for suspension and debarment. Responsible Individuals: David Senior, Finance Director Corrective Action Plan: This deficiency was due to staff transitions in our finance office. All monthend administrative cost allocations will have a documented second review by the Finance Director. We anticipate this finding to be resolved in fiscal year 2023.

FINDING 2022-005 Contact Person Responsible for Corrective Action: Dan Durrwachter Contact Phone Number: 765-473-3081 Views of Responsible Official: We agree with these findings. Description of Corrective Action Plan: The Title 1 treasurer will review all expenditures that are reported at the end of year report. The title 1 treasurer will then have the corporation treasurer review the final report to help ensure that the required level of expenditures for Parental Involvement were spent. Anticipated Completion Date: 6/01/2023

FINDING 2022-004 Contact Person Responsible for Corrective Action: Dan Durrwachter Contact Phone Number: 765-473-3081 Views of Responsible Official: We agree with these findings. Description of Corrective Action Plan: Our Food Service Director will receive the poverty status application and review them as they are inputted into skyward. Our Food Service Treasurer will review to make sure the application was completed correctly and calculated accurately. Additionally, the food service treasurer will review and approve the uploaded direct certification and income guidelines. Anticipated Completion Date: 6/01/2023

FINDING 2022-003 Contact Person Responsible for Corrective Action: Dan Durrwachter Contact Phone Number: 765-473-3081 Views of Responsible Official: We agree with these findings. Description of Corrective Action Plan: Our Food Service Director will collect food service amounts that have been collected at each school building through our online management system in skyward. Our Food Service Director will then give the numbers to our Food Service Treasurer where she will review the data and approve the numbers as she submits them for reimbursement through the state. Anticipated Completion Date:6/01/2023

Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Financial Assistance Listing Number: 21.027 Federal Agency: U.S. Department of Treasury Award Year: 2021/22 Grant Number: N/A Compliance Requirement: Reporting Type of Finding: Significant Deficiency in Internal Control Cause: The City prepared the Project and Expenditure Report and submitted without retaining evidence that the report was reviewed and approved by a separate individual prior to submission. Recommendation: We recommend the City enhance internal controls to ensure supporting documentation, including evidence of review, is retained for the Project and Expenditure Report. Management Response and Corrective Action: The City's Finance Manager was responsible for submitting the Project and Expenditure Report for the COVID-19 - Coronavirus State and Local Fiscal Recovery Funds award. Prior to submission, the report underwent a comprehensive review by the Assistant City Manager/CFO, which was documented through a calendar invitation between the Finance Manager and Assistant City Manager/CFO. Furthermore, to ensure transparency and accountability, the appropriation of COVID-19 - Coronavirus State and Local Fiscal Recovery Funds was presented to the City Council, and the funding was included in the FY 2021-22 City Adopted Budget. Additionally, multiple presentations were made during City Council meetings regarding the appropriation and expenditure of these funds, which are public meetings. For future submission, management will formally document the review of the submission process with a signed memo from the Assistant City Manager/CFO and City Manager. Name of Responsible Official: Julie Nemes Director of Finance and Technology Services Implementation Date: June 2023

Finding 2022-003: Cash Management - Material Noncompliance Management?s Response: Our commitment to maintaining strong financial controls and compliance with grant reporting requirements remains unwavering. In response to the audit finding and in our ongoing efforts to continually improve our internal controls and procedures, we have taken the following corrective actions to address the identified noncompliance and strengthen our cash management controls: Development and Implementation of Control Process: We have developed a formal control process to ensure the independent review of all cost reimbursement reports and submissions to the PMS. This process includes assigning qualified individuals who possess the necessary expertise and knowledge to conduct a thorough review of the reports and submissions. Reviewer Qualifications and Training: We have identified individuals within our organization who have the required knowledge and experience in cash management processes and grant reporting. These reviewers have undergone specialized training to enhance their understanding of the Uniform Guidance requirements, compliance regulations, and relevant policies. Documentation and Tracking: To ensure accountability and transparency, we have implemented a system for documenting and tracking the review activities performed on each cost reimbursement report and submission. This enables us to monitor the completion of reviews, track identified issues or errors, and maintain an audit trail for future reference. Timely Review and Reporting: We have established a specific timeline for completing the review of cost reimbursement reports and submissions. This ensures that any errors or discrepancies are identified and rectified promptly, minimizing the risk of incorrectly filed reports and cost reimbursements. Ongoing Monitoring and Improvement: We recognize the importance of continuous monitoring and improvement of our cash management controls. We will conduct periodic reviews and assessments of the control process to identify areas for enhancement and ensure its effectiveness and adherence to the required standards. Anticipated Completion Date: Already Implemented Responsible Contact Person: Dr Malik Mamoon Munir, Global Operations Officer, +1 678-580-0853

Finding 2022-001: Reporting - Material Weakness/Material Noncompliance Management?s Response: Our commitment to maintaining strong financial controls and compliance with grant reporting requirements remains unwavering. In response to the audit finding and in our ongoing efforts to continually improve our internal controls and procedures, we have taken the following corrective actions to address the identified lack of a formal review process for the FFR SF-425 prior to filing the report with the U.S. Department of Health and Human Services, Centers for Disease Control: Design and Implementation of Review Process: We have developed a structured review process for all FFR SF-425 reports before their submission to the U.S. Department of Health and Human Services, Centers for Disease Control. The process includes a comprehensive review by an independent party who possesses the necessary expertise and knowledge in grant reporting requirements. Reviewer Qualifications and Training: We have identified individuals within our organization who possess the requisite knowledge and experience to conduct a thorough review of the FFR SF-425 reports. These reviewers have received specialized training to ensure they understand the specific grant reporting requirements, compliance regulations, and relevant policies. Documentation and Tracking: To ensure accountability and a transparent review process, we have implemented a system for documenting and tracking the review activities performed on each FFR SF-425 report. This allows us to monitor the completion of reviews, track any identified issues or concerns, and maintain an audit trail for future reference. Review Completion Timeline: We have established a specific timeline for completing the review of FFR SF-425 reports. This ensures that the review process occurs in a timely manner, minimizing any delays in submitting accurate and compliant reports to the funding agency. Continuous Improvement and Monitoring: We recognize the importance of continuously improving our processes and maintaining ongoing compliance. Therefore, we will conduct periodic reviews and assessments of our review process to identify any areas for enhancement. Additionally, we will closely monitor the effectiveness of the new process to ensure its efficiency and adherence to the required standards. Anticipated Completion Date: Already Implemented Responsible Contact Person: Dr Malik Mamoon Munir, Global Operations Officer, +1 678-580-0853

Corrective Action Plan For the Year Ended December 31, 2022 Finding: 2022?001 Inaccurate SEFA reporting Responsible Official: Michelle Maddox, CFO Corrective Action Plan: Management will implement additional controls to ensure the completeness and accuracy of amounts reported for expenditures of the Federal Transit Administration grants in the schedule of federal awards. These additional controls include the annual review of new implementation guides. Anticipated Completion Date: December 31, 2023

To address the problem and avoid future lapses, we'll take the following steps: Clear Reporting Policies: We'll create straightforward rules for submitting financial reports, like the SF-425, on time and accurately. These policies will outline deadlines, roles, and why accuracy matters. Reporting Schedule: We'll make a calendar that shows when different reports are due. Everyone will know when reports are expected. Who's Responsible? We'll assign specific people to handle each report. They will be responsible for ensuring reports are correct and sent on time. Manager Check: Before sending a report, it will get checked by a manager or a designated person to make sure it's accurate and follows the rules. Training: We'll offer training for those who prepare reports to make sure they know what to do and why it's important. Watch and Fix: We'll set up a system to keep an eye on report deadlines and compliance. If there are issues or delays, we'll act quickly to fix them. Record Everything: We'll keep records of all reports, their preparation, review, approval, and submission. This helps us keep track and prove we're following the rules. By following these steps, we'll ensure that our financial and special reports are always submitted on time and accurately. This will help us stay in compliance with reporting requirements. We'll review and update this plan regularly to make sure our reporting process keeps improving and stays compliant with reporting rules.

2022-002 COVID-19 Provider Relief Fund ? Assistance Listing Number 93.498 Recommendation: We recommend that management implement procedures to ensure budget approvals are received timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A process of more comprehensive review of program requirements will be put in place. Name of the contact person responsible for corrective action: Lisa Katz, Program Manager Planned completion date for corrective action plan: Currently underway and planned to be completed by May 2023.

The County does check Sam.gov for suspension and debarment transactions. We will be more diligent in documenting our reviews. The three companies referred to in this finding have been doing business with the County for years and are local.

Finding 2022-004 ? Reporting ? Significant Deficiency in Internal Control over Compliance Cluster/Grantor: Department of Health and Human Services ? Health Resources and Services Administration (?HRSA?) Award Name: COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distributions Award Year: January 1, 2021 - December 31, 2021 Assistant Listing Number: 93.498 The management of Loretto Health have reviewed finding 2022-004: Reporting ? Significant Deficiency in Internal Control over 2Compliance. We present the following corrective action plan: Loretto Health will adopt the recommendation from the auditor to implement a control process which includes a documented secondary review and approval of the Provider Relief HRSA submission.

Management Response and Planned Corrective Action 1. While the current Internal Controls Manual allows for certain expenditures to be made with verbal and/or written approval from the Executive Director, the control does not state a dollar amount or specific circumstance for verbal approval and therefore the control has been clarified as follows: All funds to be expended must be approved by the Executive Director, either verbally or in writing, prior to the expenditure. Program staff may then request that the FA, OM or Administrative Associate purchase the needed expense either by debit card or credit card or produce a check for the ED?s signature. All requests for purchase must follow the same backup paperwork procedures outlined in the AP Procedures section. For all routine essential office supply individual item purchases $250 and under, the OM or FA has approval to make these purchases without ED verbal or written approval prior to the expenditure. All expenditures for individual items above $250 must be verbally approved by the ED prior to purchase and documented via email which then should be attached to the purchase documentation. Purchases $1,500 and above should follow the procurement policy outlined below in Control No. 21. In addition, the procurement control has been clarified with updated language as follows: For goods and services $1,499 and under, Executive Director approval is required as per the purchase policy above referenced in Control No. 17. 2. NBCC maintains an onboarding process and checklist which includes the completion of the I-9 for each employee. This process is strictly followed. The three employees identified during the testing that lacked a completed I-9 on file were for one employee who was hired during the initial period of the COVID lockdown when all processes were significantly impacted by the initial COVID quarantine, and the remaining two were onboarded by a staff member serving temporarily in the human resources position after the exiting human resources staff member did not return from a medical leave of absence. All current staff have completed I-9?s on file and there is every expectation that this control will continue to be enforced. As an additional guarantee of having a completed I-9 in place, NBCC has asked our external accounting firm, Vista Financial, to create an additional control where a new employee is not onboarded into Quickbooks for payroll without the completed I-9.

Identifying Number: 2022-003 Finding: While testing reporting, we noted that there were not controls or approvals over the reporting requirement for the HEERF program. Corrective Actions Taken or Planned: Student funds for HEERF have been exhausted so no additional reporting should be required for them. For all institutional HEERF funds reporting, both the Financial Aid Director and the Controller review the information and complete the Institutional reporting PDF. Once posted, the PDF is emailed to the Department of Educations as a time stamp to show it was completed on time. Contact Person: Nick Anderson Director of Financial Aid ? Deb Kessler Controller Anticipated Completion Date: 7/10/2022