Corrective Action Plans

FINDING 2022-002 Contact Person Responsible for Corrective Action: Andrea Phillips Contact Phone Number: (812) 663-4774 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Eligibility ? The Food Service Director is responsible for communicating/uploading information in regard to families who are eligible for Free/Reduced Benefits. This work is reviewed by the Cafeteria Bookkeeper and filed in her office. The students who are ?Directly Certified? by the state of Indiana are added to the electronic student data system. The Corporation Data Manager files all necessary documents for the October 1 count day, which is then signed off by the Superintendent and Treasurer. Once the state of Indiana approves this data, a copy will be provided to the Grant Administrator. The Treasurer and Grant Administrator will be able to verify the data matches with the Eligible School Summary page of Title I basic application by comparing the October 1 count data with the Title 1 application data and signing off to this. Reporting ? The Form 9 Financial Reports will be prepared by the Treasurer and then reviewed by the Accounts Payable Clerk. During the secondary review, the Accounts Payable Clerk will compare the Form 9 Financial Report to Komputrol Reports and/or calculations prepared by Treasurer, check mark or highlight numbers verified, and signoff on the reports to ensure expenditures are correctly reported. Matching, Level of Effort, Earmarking ? The Form 9 Financial Reports will be prepared by the Treasurer and then reviewed by the Accounts Payable Clerk. During the secondary review, the Accounts Payable Clerk will compare the Form 9 Financial Report to Komputrol Reports and/or calculations prepared by Treasurer, check mark or highlight numbers verified, and signoff on the reports to ensure expenditures are correctly reported. Special Tests and Provisions ? Annual Report Card, High School Graduation Rate ? The Guidance Department and School Administration will communicate with the Registrar to prepare all documentation needed prior to a student?s removal from a cohort. Once those documents are prepared, they will be given to the Corporation Data Manager. The Building Administrator will sign off that the proper exit code was entered and documentation is available. Anticipated Completion Date: June 2023

Assistance Listings number: 21.027 COVID-19 Coronavirus State and Local Fiscal Recovery Fund Contact Person(s): Jayson Vowell, Finance Director Anticipated completion date: June 30, 2023 Concur. During the audit period, fiscal year 21-22, the only reportable expenditure to the grantor was the $10 million standard deduction for revenue loss claimed by the County. The remaining reports did not include reportable expenditures as the projects identified had not begun as construction contracts are currently being negotiated between the County and contractors. Therefore, the County either did not perform a review or did so verbally between staff. To ensure County policy and procedures are followed, the County will require that all future program reports are reviewed for accuracy, agree to County records, and contain only allowable expenditures before submitting them to the federal agency. In addition, the County will ensure that this review process is documented.

Assistance Listings number: 17.258 WIOA Adult Program; Assistance Listings number: 17.259 WIOA Youth Activities; and Assistance Listings number: 17.258 WIOA Dislocated Worker Formula Grants Contact Person(s): Jeremy Flowers, WIOA Executive Director and Lisa Grannis, WIOA Board Clerk and Compliance Specialist Anticipated completion date: June 30, 2023 Concur. To help ensure the County meets the WIOA Cluster?s earmarking requirement to spend no less than 20 percent of WIOA Youth Activities funds allocated to the County to provide in-school and out-of-school youth with paid and unpaid work experiences (WEX), the County has revised its process for tracking work experience expenditures. The County will utilize the revised process and provide technical assistance to the sub-recipient, Chicanos Por La Causa (CPLC) to implement procedures that will lead to an increase in Youth enrollments and placement into WEX to ensure at least 20 percent of the WIOA Youth Activities funds allocated to the County are used to provide in-school and out-of-school youth with paid and unpaid WEX. County staff is currently working with CPLC staff to implement a different approach to attaining the WEX requirements. The recommended solutions include improved tracking and monitoring of the WIOA Youth WEX activities to include both paid and unpaid work experiences, increasing all youth outreach, partnering with other local youth programs, and enrolling youth with barriers pursuant to current policy. The County will be tracking Youth progress and will be revising strategies as needed. The County?s goal is to see a significant increase in Youth WEX program activities by the end of fiscal year 22-23.

Assistance Listings number: 17.258 WIOA Adult Program; Assistance Listings number: 17.259 WIOA Youth Activities; and Assistance Listings number: 17.258 WIOA Dislocated Worker Formula Grants Contact Person(s): Jeremy Flowers, WIOA Executive Director and Lisa Grannis, WIOA Board Clerk and Compliance Specialist Anticipated completion date: June 30, 2023 Concur. The nonprofit organization was created in part to serve as the administrative arm of the Local Board and to provide a location for a resource center where WIOA services would be provided. The County did not distinguish fiscal responsibilities between parties and therefore assumed that certain expenditures of the Local Board and nonprofit would be allowable and could be paid directly by the County. The County considered the expenditures of the nonprofit to be program related, even though they were not directly incurred by the County. The County will improve its accounts payable policies and procedures for processing invoices using established process within the Finance Department, including ensuring all invoices are addressed to the County prior to payment. In addition, the County will establish clear contractual agreements that establish fiscal responsibilities that follow the program?s requirements. Finally, the County will coordinate with the pass-through grantor for the repayment of the unallowable costs identified in the finding.

Assistance Listings number: 10.665 Schools and Roads ? Grants to States Contact Person(s): Catrina Jenkins, Emergency Management Manager Anticipated completion date: June 30, 2023 Concur. County staff has been educated on the 45-day comment period and proposal to the Resource Advisory Committee (RAC). The County has put into place corrective actions to negate these issues in the future. These actions have included a calendar reminder to publish the 45-day comment period in our paper of record and to submit the proposed use of fund to the local RAC prior to spending any funds. The County has reached out to the current coordinator of the local RAC to ensure the County will be able to coordinate our efforts efficiently in the future. The County will develop written policy and procedures for these funds to ensure that these action items are followed and will train all staff according to these policies as it is applicable.

Finding: 2022-004 Federal Agency name: Department of Agriculture Program Name: Communities Facilities Loans and Grants Cluster Federal Financial Assistance Listing: #10.766 Compliance Requirement: Reporting Finding summary: The fiscal year 2021 audit report and fiscal year 2022 operating budget were not submitted to USDA until requested during the audit. Responsible Individuals: Carmen Weber, Administrator and Joyce Schwingler, CFO Corrective Action Plan: Administrator will put reminders on her calendar to send the yearly budget approved by the board and the completed yearly audit reports to USDA. Anticipated Completion Date: January 2023

Finding: 2022-005 Federal Agency name: Department of Agriculture Program Name: Communities Facilities Loans and Grants Cluster Federal Financial Assistance Listing: #10.766 Compliance Requirement: Special Tests and Provisions Finding summary: Management maintained the reserve amount in the pooled investment fund account which was not established as a separate bookkeeping account nor as a separate bank account. Although the pooled investment funds includes marketable securities backed by the full faith and credit of the United States, based on the portfolio mix of the investment pool, additional cash balances on hand need to supplement the investment pool to adequately fund the reserve. The Organization has excess cash available. Further, there is no secondary level of review being performed over the monthly reconciliation of the reserve account. Responsible Individuals: Carmen Weber, Administrator and Joyce Schwingler, CFO Corrective Action Plan: The reserve amount was withdrawn from the pooled investment fund and deposited into an account at the First State Bank of Roscoe, Eureka Branch, which is FDIC insured. Administrator will review, sign and date all bank statements received for the reserve account at the First State Bank of Roscoe, Eureka Branch. Anticipated Completion Date: December 2022

CORRECTIVE ACTON PLAN December 31, 2022 Finding No. 2022-001; Name of Responsible Official James Haislip, VP System Office Finance; Management?s Response to Findings - Management agrees with the finding. The issue results from BayCare tracking contract labor time in its timekeeping system and then submitting the hours worked to the contract labor firms to pay the individual. BayCare?s timekeeping system also included hourly rates for each contracted position. Due to fluctuating market conditions, pay rates for contract labor were changing frequently but not updated timely in our timekeeping system. Allowable costs submitted for Provider Relief Funds were based on information from our timekeeping system. Description of Corrective Action - Allowable cost submitted for Provider Relief Funds were based on information from our timekeeping system. The finding was first identified in Reporting Period 2 (RP2) and communicated to management after RP3 was prepared. RP3 included PRF expenses through Q2 of 2022. RP4 included PRF expenses through Q4 2022. Management implemented the prior year Corrective Action Plan (CAP) and as a result the error rate on contract labor incurred in Q3 of 2022 decreased compared to prior year with minimal errors identified. There were no errors identified for Q4 2022. Anticipated Completion Date - CAP was completed in RP5.

Finding 2022-002 Federal Agency Name: Department of Health and Human Services Program Name: COVID-19 Provider Relief Fund (PRF) and American Rescue Plan (ARP) Rural Distribution Federal Award Number and Year: Period 4 TIN #411948604 CFDA #93.498 Finding Summary: The Organization?s calculation of lost revenue claimed under the federal program as an allowable cost was not subjected to formal review or approval by a separate individual outside of the preparer. Responsible Individuals: Caroline Hood, President & CEO Paul Puerzer, Chief Financial Officer Corrective Action Plan: When summarizing lost revenue for submission, a secondary review of the summary spreadsheet prepared from the underlying supporting spreadsheets will be documented. Anticipated Completion Date: 12/31/23

Finding 2022-004 Federal Agency Name: Department of Housing and Urban Development Program Name: Continuum of Care Program CFDA #14.267 Finding Summary: The Organization claimed a portion of expenses that benefited the period outside of the period of performance which was November 1, 2021 to October 31, 2023. During our testing, there was no documentation of review and approval of expenses for a portion of the sample selected. Responsible Individuals: Caroline Hood, President & CEO Paul Puerzer, Chief Financial Officer Jessica Johnson, VP of Assets & Operations Corrective Action Plan: Management will review the current active review process and implement a formal documentation of the review including the appropriate level of management sign off and date of review on the supporting documentation. Anticipated Completion Date: 12/31/2023

Finding 2022-004 Contact Person: Shelley Mawhorter Contact Phone #: 260-636-2658 Views of Responsible Official: We concur with finding RE: Policy for Internal Controls / 2022-004 Noble County Auditor?s Office has set internal controls in reference to all grants overseen by Noble County. All grants in Noble County will have the Auditor?s Office oversite. A person in the Auditor?s Office will oversee expenditures and receipts and all reports that are required by the State or Federal government. Estimated completion date: 10/1/23

Finding 2022-003 Contact Person: Shelley Mawhorter Contact Phone #: 260-636-2658 Views of Responsible Official: We concur with finding RE: Policy for Internal Controls / 2022-003 Description of Corrective Action Plan: Noble County Auditor?s Office has set internal controls in reference to all suspension debarment practices. A form for each person who hires and uses grant money to pay will be required to fill out and show proof that they checked on line with sam.gov/content/exclusions/federal that all persons working are in good standing. Estimated completion date: 10/1/23

Explanation of disagreement with the audit finding: There is no disagreement with the audit finding. CCBC did not timely post the quarterly reports to its website. Action taken in response to finding: The finance department is in the process of enhancing business processes and strengthening internal controls to ensure timely posting of the quarterly reports on the College?s website. The Accounting Director is doing a review of each accountant?s grant responsibilities in order to reallocate grant responsibilities to balance the workload. Since FY 2019 there has been a 40% increase in grant funds. The Accounting Director will work more closely with the grant accountants and provide more grant reporting oversight. The Director will create a detailed grant reporting database to monitor the reporting deadlines of each grant. On a monthly basis, the Director will review grant reporting deadlines with each grant accountant to ensure that reports are timely filed/posted. If needed, workload will be reallocated to accommodate tight reporting requirements, or a request for extension of time to file/post will be made to the grantor. Name(s) of the contact person(s) responsible for corrective action: Director of Accounting Planned completion date for corrective action plan: The Director of Accounting has already begun meeting with the grant accountants to reallocate workload, establish the new controls and begin gathering the necessary data for the creation of the database. The initial completion of the database will be no later than January 13, 2023. Plan to monitor completion of correction action plan: The Assistant Controller will monitor the completion of the database and grant reporting status to ensure timely filing of financial reports.

Explanation of disagreement with the audit finding: There is no disagreement with the audit finding. Action taken in response to finding: In April of 2022, after the Single Audit for 2021 was completed, the Financial Aid Director implemented a 100% secondary review of all R2T4 calculations. On September 6, 2022, during this secondary review the return of funds error was identified and returned on that day. The amount that was returned has been adjusted to reflect the correct amount that should have been returned. This was all adjusted, before the close-out and reconciliation of the 2021-2022 aid year. Name(s) of the contact person(s) responsible for corrective action: Virginia Zawodny, Director of Financial Aid Planned completion date for corrective action plan: Several staff have been trained to assist with the 100%, secondary review of all R2T4 calculations. Plan to monitor completion of corrective action: The Director of Financial Aid will closely monitor the progress of the secondary review and address any errors that may be identified.

2022-003 ? Internal Controls over Compliance ? (Significant Deficiency) Agency?s Response: The District?s payroll office will work more closely with Federal Programs to ensure proper compliance when additional compensation is requested. Amounts will be verified prior to processing payment and ensure amounts fall within compliance. Person responsible for corrective action: Jade Kittrell, Payroll Specialist, Valeryia Gauthier, Federal Programs Director. Timeframe: Immediate as of November 2022.

FINDING 2022-004 Finding Subject: Reporting Summary of Finding: Internal Controls over Reporting for the SLFRF Grant Contact Person Responsible for Corrective Action: Koren Gray Contact Phone Number: 765-436-2205 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Town will establish a series of internal controls for the SLRF reporting process. The Town will follow the following procedures: - The Clerk-Treasurer and Town Council will maintain a calendar of SLRF required reporting; - The Clerk-Treasurer, with the assistance of the Town?s municipal advisor and counsel, will prepare the required reporting; and - The Town Council President will review all requisite reports prior to submission. Anticipated Completion Date: Beginning October 1, 2023

FINDING 2022-003 Finding Subject: Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance Summary of Finding: Noncompliance regarding the above compliance requirements Contact Person Responsible for Corrective Action: Koren Gray Contact Phone Number: 765-436-2205 Views of Responsible Official: No corrective action is required. The Town?s use of funds was appropriate under the law effective at the time of their actions. While the FAQs and fact sheets seem fairly clear that ARPA funds cannot be used to pay for any debt, including, specifically, BANs and tax anticipation warrants, the language in the actual Interim Final Rule seems to allow ARPA funds to be used for new debt. The Interim Final Rule, issued in May 2021, states: ?Contributions to rainy day funds and similar financial reserves would not address these needs or respond to the COVID?19 public health emergency but would rather constitute savings for future spending needs. Similarly, this eligible use category would not include payment of interest or principal INDIANA STATE BOARD OF ACCOUNTS 27 Per Uniform Guidance: 2 CFR ? 200.511(a) ? ?The auditee is responsible for follow-up and corrective action on all audit findings. . .The auditee must also prepare a corrective action plan for current year audit findings. . . The corrective action plan and summary schedule of prior audit findings must include findings relating to the financial statements which are required to be reported in accordance with GAGAS. ? 2 CFR ? 200.511(c) ? ?At the completion of the audit, the auditee must prepare, in a document separate from the auditor's findings described in ? 200.516, a corrective action plan to address each audit finding included in the current year auditor's reports. The corrective action plan must provide the name(s) of the contact person(s) responsible for corrective action, the corrective action planned, and the anticipated completion date. If the auditee does not agree with the audit findings or believes corrective action is not required, then the corrective action plan must include an explanation and specific reasons.? on outstanding debt instruments, including, for example, short-term revenue or tax anticipation notes, or other debt service costs. As discussed below, payments from the Fiscal Recovery Funds are intended to be used prospectively and the interim final rule precludes use of these funds to cover the costs of debt incurred prior to March 3, 2021. Fees or issuance costs associated with the issuance of new debt would also not be covered using payments from the Fiscal Recovery Funds because such costs would not themselves have been incurred to address the needs of pandemic response or its negative economic impacts.? The Final Rule, issued in 2022, summarizes the Interim Final Rule, including that the Interim Final Rule did not allow for ?payment of interest or principal on outstanding debt instruments; ? [or] fees or issuance costs associated with the issuance of new debt?? The issue date of these bond anticipation notes is the same as the actual date of delivery, which is after March 3, 2021. Under all federal laws, debt does not exist until it is actually issued ? that is to say, debt does not exist at the time of approval of the PER, the time of adoption of the authorizing documents, or at any point before it is actually issued. The Thorntown BANs were issued after March 3, 2021, making them ?new debt,? not ?outstanding debt? for the purposes of the Rules. The Interim Rule does not allow for debt service payments on outstanding debt as it is not a prospective use of the funds. It does, however, seem to allow for debt service payments on ?new debt,? just not for issuance costs, which were covered by the SRF. The Final Rule also includes this statement: ?Specifically, use of funds for debt service, to replenish financial reserves, or to satisfy an obligation arising from a judicial settlement or judgment were ineligible uses of funds under the eligible use categories for public health and negative economic impacts and revenue loss. These restrictions apply to all recipients. Recipients should note that restrictions on use of funds for debt service, to replenish financial reserves, or to satisfy an obligation arising from a judicial settlement or judgment apply to all eligible use categories, not just the eligible use categories in which they were discussed in the interim final rule.? The Final Rule clarifies several times that all debt service, including short term debt issued after the beginning of the pandemic in response to the lack of revenue, was intended to be an ineligible use. However, because the Final Rule seems to make it clear that the Interim Final Rule was unclear on this point, the Town can make a strong argument based on the points above that this BAN was an eligible use under their interpretation of the Interim Final Rule and should be allowed under the Treasury?s Statement Regarding Compliance with the Coronavirus State and Local Fiscal Recovery Funds Interim Final Rule and Final Rule. Description of Corrective Action Plan: Not Applicable. However, as final guidance and the final rule are now available, the Town would not use ARPA funds to pay for any new debts moving forward. INDIANA STATE BOARD OF ACCOUNTS 28 Per Uniform Guidance: 2 CFR ? 200.511(a) ? ?The auditee is responsible for follow-up and corrective action on all audit findings. . .The auditee must also prepare a corrective action plan for current year audit findings. . . The corrective action plan and summary schedule of prior audit findings must include findings relating to the financial statements which are required to be reported in accordance with GAGAS. ? 2 CFR ? 200.511(c) ? ?At the completion of the audit, the auditee must prepare, in a document separate from the auditor's findings described in ? 200.516, a corrective action plan to address each audit finding included in the current year auditor's reports. The corrective action plan must provide the name(s) of the contact person(s) responsible for corrective action, the corrective action planned, and the anticipated completion date. If the auditee does not agree with the audit findings or believes corrective action is not required, then the corrective action plan must include an explanation and specific reasons.? Anticipated Completion Date: Not Applicable.

Corrective Action Plan - FEDERAL AWARD FINDINGS AND QUESTIONED COSTS FA 2022-001 Improve Controls over Federal Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principles Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: COVID-19 - 84.425D - Elementary and Secondary School Emergency Relief Fund COVID-19 - 84.425U - American Rescue Plan Elementary And Secondary School Emergency Relief Fund Federal Award Number: S425D210012 (Year: 2021) S45U210012 (Year: 2021) Questioned Costs: $26,460 Repeat of Prior Year Finding: None Description: A review of expenditures charged to the Emergency Connectivity Fund and Elementary and Secondary School Emergency Relief Fund programs revealed that the School District?s internal control procedures were not operating appropriately to ensure that expenditures were allowable. Corrective Action Plan: The District will contact each Federal Program to determine the appropriate action to take to ensure the funds are appropriately allocated. Moving forward, Finance will review all reimbursements as well as work with other Departments to ensure that expenses are being allocated to the correct program. Estimated Completion Date: April 28, 2023 Contact Person: Samantha Jenkins Telephone: 478-456-3362 Email: Samantha.jenkins@baldwin.k12.ga.us

FINDING 2022-010 Contact Person Responsible for Corrective Action: Kasey Clark Contact Phone Number: 574-772-1604 Views of Responsible Official: We concur with the findings Description of Corrective Action Plan: Wage Rate Requirements compliance requirement. Construction contracts in excess of $2,000 financed by federal assistance funds must pay wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) to their laborers and mechanics. This will be documented in any construction contracts going forward. The School board and Superintendent will make sure that all certified payroll reports are submitted to the School Corporation timely by contractors. The Superintendent will review all contracts and certified payroll reports to ensure accuracy. Anticipated Completion Date: March 2023

FINDING 2022-009 Contact Person Responsible for Corrective Action: Kasey Clark Contact Phone Number: 574-772-1604 Views of Responsible Official: We concur with the findings Description of Corrective Action Plan: Internal controls will be in place for ESSER funds so that Treasurer and Superintendent or Title I specialist will sign off on annual reports to ensure accuracy of ESSER dollars spent. Anticipated Completion Date: March 2023

FINDING 2022-008 Contact Person Responsible for Corrective Action: Kasey Clark Contact Phone Number: 574-772-1604 Views of Responsible Official: We concur with the findings Description of Corrective Action Plan: The HVAC will be documented with all appropriate information via Adtec in 2023 which is our biannual update. The Treasurer will review and approve this documentation for accuracy. A spreadsheet will be kept to document all capital expenditures as they occur. Equipment will be appropriately safeguard and maintained by the School Corporation?s Maintenance Director. Anticipated Completion Date: March 2023

FINDING 2022-007 Contact Person Responsible for Corrective Action: Kasey Clark Contact Phone Number: 574-772-1604 Views of Responsible Official: We concur with the findings Description of Corrective Action Plan: The time and effort for the stipends was not documented. The time and effort for all stipends will be documented for any stipend. All stipends will be reviewed and approved by the Treasurer. Anticipated Completion Date: March 2023

FINDING 2022-006 Contact Person Responsible for Corrective Action: Kasey Clark Contact Phone Number: 574-772-1604 Views of Responsible Official: We concur with the findings Description of Corrective Action Plan: We will take the set aside amount and make a specific line in the financial software and report the amount that is needed as needed to be reported. The Treasurer will prepare the final expenditure report and the Title I Specialist will review the report to ensure the set asides are accurately reported. Anticipated Completion Date: March 2023

FINDING 2022-005 Contact Person Responsible for Corrective Action: Kasey Clark Contact Phone Number: 574-772-1604 Views of Responsible Official: We concur with the findings Description of Corrective Action Plan: We will look closer at the parental involvement piece of our grant and will comply with what the total cost are and spend them on parental involvement. The Treasurer will prepare a spreadsheet to track the parental involvement expenditures and the Title I Specialist will review spreadsheet to ensure parental involvement expenditures are being spent. Anticipated Completion Date: March 2023

FINDING 2022-004 Contact Person Responsible for Corrective Action: Kasey Clark Contact Phone Number: 574-772-1604 Views of Responsible Official: We concur with the findings. Description of Corrective Action Plan: The bus rates will have in every weekly pay attached the rates for each route and submitted with their timecards. The bus rates will be prepared by the Transportation Director and will be reviewed by the Deputy Treasurer and then the Treasurer. Anticipated Completion Date: March 2023