Corrective Action Plans

2022-059 Department of Human Services Ensure issued benefits are accurate Federal Awarding Agency: U.S. Department of Agriculture Assistance Listing Number and Name: 10.542 Pandemic EBT Food Benefits (COVID-19) Federal Award Numbers and Years: Not available (COVID-19) Compliance Requirement: Activities Allowed or Unallowed Type of Finding: Significant Deficiency; Noncompliance Prior Year Finding: N/A Questioned Costs: $3,692,215 (known); $13,554,666 (likely) (COVID-19) Criteria: Public Law 116-127; 2 CFR 200.303 The federal requirements for the Pandemic EBT (P-EBT) program require state agencies follow their approved state plan. Part of Oregon?s simplifying assumptions in their state plan was that the benefit amount was determined at the school level, not the individual level, based on the school?s operating status, for October 2020 ? May 2021. As part of Oregon?s Ready Schools, Safe Learners program, schools were required to weekly report their operating status/instructional model to the Oregon Department of Education (ODE). In fiscal year 2022, the Department of Human Services (department) paid retroactive P-EBT benefits for children related to the 2020-2021 school year. This sample population consisted of institutions (schools and other educational facilities) and months in which children at the institutions received benefits, totaling $391 million. We selected a random sample of 40 institutions and a random month to determine if the benefits provided to the children, based on the status reported by the institution, were accurate. We identified 4 institutions, for April/May, where the benefit paid status of the institution was not the same as reported by the institution to ODE. In all 4 cases, the benefits paid were at a higher level resulting in questioned costs of $38,931 and likely questioned costs of $9.2 million. One of the simplifying assumptions for the P-EBT program, approved in Oregon?s state plan, was ?Oregon will have a limited reconsideration process to revisit benefit allotments at a school level.? However, the department allowed institutions to update their status without additional review, explanation, or documentation. The department could not provide the auditors any support for the changes made by the institutions. Furthermore, the Oregon Governor issued a directive to schools, on March 5, 2021, to begin a phased approach to require all public schools to provide in-person instruction through either a fully on-site or hybrid model on or before the week of April 19, 2021, for all schools. Although benefits issued continued to decrease as the school year end approached, in May 2021, 26% of the institution?s benefits paid were for fully virtual totaling $17 million. We judgmentally selected 36 institutions classified as fully virtual in May with benefits totaling $7.9 million. For 25 institutions, the benefit paid status did not agree to the status reported by the institution to ODE resulting in questioned costs of $3,653,284 and likely questioned costs of $4.4 million. We recommend DHS perform review to identify any additional discrepancies between benefits paid and the institutions reported status, to determine if payments were appropriate, and communicate with the federal awarding agency to determine if repayment is necessary. MANAGEMENT RESPONSE: We respectfully disagree with the findings that schools were not able to directly update their learning mode according to the guidance provided in the P-EBT state plan. The department has included emails and documents that support the actions/decisions taken in the delivery of the Oregon P-EBT school year 2020-2021 state plan was in accordance with federal approval from Food and Nutrition Service (FNS). According to the USDA FNS approval letter received on May 7, 2021, and posted to the FNS website, FNS confirms that Oregon will ?develop(ed) a centralized database to collect student eligibility information and school status? to determine the monthly benefit level for each school (6th bullet on page 2). This information is also confirmed in email correspondence with FNS on April 29, 2021, and May 3, 2021. Within the email the Department details that Oregon will develop a database to collect school status, this is then confirmed by FNS. As part of Oregon?s federally approved simplified assumptions, the state plan allows the school points of contact to update their predominate learning model for each month of the 2020-2021 school year, which may be different than the Ready Schools, Safe Learners (RSSL) Weekly Status Report. An email communication was shared with all identified school points of contact on June 28, 2021. This email requested that school points of contact update their schools predominate learning mode into the Oregon School Meals Benefit (OSMB) system used by the Oregon Department of Human Services to issue P-EBT benefits no later than July 13, 2021. Information reported through the RSSL weekly status report was used to determine the predominate learning mode only in the event that the school point of contract did not update a learning mode manually within OSMB prior to July 13, 2021. On May 9, 2023, the P-EBT policy team confirmed school operating status during the selected months with 5 schools for SOS audit. Email responses from the schools are summarized below: ?See Corrective Action Plan for Table? At the recommendation of the auditors the Department has reached out to FNS Child Nutrition Program about the finding and we are waiting for a response. Anticipated completion date: N/A Contact: Heather Miles, SNAP, CSFP, and TEFAP Program Manager

FINDING 2022-002 Contact Person Responsible for Corrective Action: LaGrange County Auditor Contact Phone Number: (260) 499-6310 Views of Responsible Official: We concur with the findings from SBOA The County will establish a internal control system of checking Excluded Parties List System, collecting a certification from that person or adding a clause or condition to the covered transaction with that person for all vendors equal to or in excess of $25,000 for SLFRF award funds to ensure such contractors and subrecipients are not suspended, debarred or otherwise excluded. Copies of supporting documents to be retained. Anticipated Completion Date: Implementation will begin immediately.

FINDING 2022-001 Contact Person Responsible for Corrective Action: LaGrange County Auditor Contact Phone Number: (260) 499-6310 Views of Responsible Official: We concur with the findings from SBOA. Description of Corrective Action Plan: We will work towards segregation of duties to ensure preventing, or detecting and correcting noncompliance. Once the P & E report is prepared, a separate employee will review the report prior to submission. Anticipated Completion Date: When the next report is filed we will implement these procedures.

Audit Finding Reference Number: 2022-002 Recommendation - South Shore should enhance its internal control processes related to preparation and review of the monthly claim for reimbursement. Corrective Action Plan - We have adjusted our policies and procedures to assure that every claim submission is reviewed by both the Controller and CFO prior submission. Claim form and appropriate documentation will be submitted to the Controller who will give initial review. Review will consider timeliness of items claimed as well as appropriateness for the particular federal grant. CFO will then provide final authorization in writing to both grants accountant and controller at which time claim for reimbursement can be submitted by grant accountant.

Student Financial Aid Cluster: Federal Pell Program ? Assistance Listing No. 84.063 Recommendation: We recommend the College review its current procedures for awarding Title IV funds and implement changes necessary to ensure federal funds are awarded and disbursed in accordance with federal regulations. We also recommend the College disburse the proper Pell award to these students. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: This was a Pell error due to COA calculation and assignment error. Procedures will be implemented to review COA components to confirm accuracy of COA which will result in correct Pell awards. Name(s) of the contact person(s) responsible for corrective action: Laura Hughes, Travis Osburn and John Bender. Planned completion date for corrective action plan: Immediate

FINDING: 2022-002 Contact Person Responsible for Corrective Action: Deborah A. Longer, Clerk-Treasurer Contact Phone Number: (219) 942-1940 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The special purchase procurement of the CNG refuse haulers was done by Resolution of the Board of Public Works and Safety. This Resolution included references to the State Statutes permitting acquisitions of this type but did not include any reference to the Federal statutes and requirements. In addition, the Employee in Responsible Charge (ERC) and the agency assisting with the grants and purchasing failed to verify that the vendor was neither suspended nor debarred to assure they would be a qualified vendor. The City Attorney has been appraised of both of these issues. In the future, any special purchase of equipment that utilizes Federal funding will include a reference to the State and Federal statutes governing such in the City?s official action prior to moving forward and will meet all of the requirements of same. In addition, the City Attorney has included in all City contracts that the Vendor is required to provide assurances that they are a qualified vendor and not currently suspended or disbarred from doing business. In addition, each ERC will be provided a copy of the Finding 2022-02 to serve as a reminder of their responsibilities and the necessary procedures and activities related to the overseeing of the grants and direct them to review the Internal Control Policies regarding the responsibilities, procedures and activities to assure the proper reporting in all areas of the SEFA in future years. Anticipated Completion Date: April 30, 2023 Signed: Deborah A. Longer Deborah A. Longer, Clerk-Treasurer Date: April 19, 2023

Finding 2022-002: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Federal Agency Name: Department of Health and Human Services Program Name: COVID-19 Testing and Mitigation for Rural Health Clinics Federal Financial Assistance Listing/CFDA Number: 93.697 Finding Summary: The Medical Center?s listing of expenses claimed under the Testing and Mitigation for Rural Health Clinics program as an allowable cost had more expenses than funds received. Some of these excess funds related to a different period and would have been reported on the Schedule in a different year. This should have been caught with an effective secondary review of expenses. Responsible Individuals: Nathan Pickel, Chief Financial Officer Corrective Action Plan: Management agrees with the finding. Controls will be put into place for a more thorough review of the expense detail to ensure expenditures being claimed pertain to the year in which they were incurred. For the current year, the expense detail was ran by accounting date as opposed to service date. Anticipated Completion Date: June 30, 2023

Finding 2022-002 Procurement and Suspension and Debarment Management?s or Department?s Response: Management agrees. Views of Responsible Officials and Corrective Action: On October 19, 2022, CPMM proactively conducted a check on all active procurements to ensure a SAM report was pulled. If one was not present in the file, CPMM pulled a SAM report. Going forward, CPMM will use the checklist to ensure a SAM report is pulled for all future procurements. SCRRA has already implemented the use of the checklist for all the required documents associated with a procurement. The checklist includes all required documents to complete a procurement including the verification of suspension and debarment documentation. Name of Responsible Person: Cynthia Minix Implementation Date: June 30, 2023

Finding 2022-002 Condition A sample of 40 items were selected for testing. During our testing, we noted one item selected for testing did not contain support of authorization. This was not a statistically valid sample Corrective Action Plan Corrective Action Planned: The Company agrees with the finding and will implement procedures to ensure all invoices approved via email will be stored in our document management and workflow software. Name(s) of Contact Person(s) Responsible for Corrective Action: Daniel Murray, CEO and Timothy McQuaid, CFO Anticipated Completion Date: completed

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