Corrective Action Plans

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

FINDING 2022-003 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 income guidelines will be uploaded into the food service system after printing off the government site and two people will have eyes on them and this has started for 2022/2023. Anticipated Completion Date: March 2023

Department: Administrative and Financial Services Title: Internal control over expenditure processing needs improvement Questioned Costs: Known: 59,759 Likely: Undeterminable Status: Corrective action complete Corrective Action: The Department will reverse the unallowable charge to the HSGP grant. The Department will provide additional training for data entry and invoice approval processes. Completion Date: March 1, 2023 and March 31, 2023 respectively Agency Contact: Marilyn Leimbach, Director, Service and Employment Service Center, DFPS, DAFS, 207-248-2556

Department: Defense, Veterans and Emergency Management Administrative and Financial Services Title: Internal control over the submission and review of DG ? PA Schedule of Expenditures of Federal Awards information needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Maine Emergency Management Agency (MEMA) will develop and implement a procedure for the review of the following sources to ensure the accuracy of the ALN: award documents, the OMB Compliance Supplement, and other authoritative resources. Where written resources do not clearly identify the ALN, MEMA will seek technical assistance from awarding agency staff, the Office of State Controller, and the Office of State Auditor. MEMA will develop and implement a procedure for the review of Assistance Listing Numbers (ALN) coding in the Advantage financial system. MEMA will develop and implement a procedure for the review of SEFA data before submission to the Office of State Controller. MEMA's procedures will provide for staff training. The training will be documented. MEMA's procedures will provide for the review and approval by a second staff person. The review and approval will be documented. The Office of the State Controller will update or clarify guidance as necessary and will consult with service center and agency financial personnel to help ensure their compilation/review systems are designed to provide accurate information for the SEFA. Completion Date: June 30, 2023 (first through fifth items), and September 1, 2023 (sixth item) Agency Contact: Joe Legee, Deputy Director, MEMA, 207-624-4400 Sandra Royce, Director of Financial Reporting, OSC, 207-626-8451

Department: Defense, Veterans and Emergency Management Title: Internal control over DG ? PA program special reporting needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Department will develop an estimate of the number of FY23 subawards. The Department will identify staff to input entries to FFATA. Completion Date: March 15, 2023 and October 31, 2023 respectively Agency Contact: Joe Legee, Deputy Director, MEMA, 207-624-4400

Finding 2022-002 Federal Agency Name: U.S. Department of Agriculture Program Name: Community Facilities Loans and Grants CFDA #10.766 Finding Summary: The Center does not have an internal control system designed to provide for review and approval of the quarterly form RD 442-2, Statement of Budget, Income, and Equity (OMB No. 0575-0015) reports submitted. Responsible Individuals: Will Grant, Interim Chief Financial Officer Corrective Action Plan: The center is in the process of revising internal controls to ensure the Center?s quarterly reporting is reviewed and approved prior to submission. Anticipated Completion Date: Ongoing

Department: Defense, Veterans and Emergency Management Title: Internal control over DG ? PA program cash management needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Maine Emergency Management Agency (MEMA) and the Security and Employment Service Center (SESC) will work jointly to develop and implement a cash management procedure that meets the Federal and State requirements. MEMA and SESC will seek technical assistance as appropriate. Completion Date: June 30, 2023 Agency Contact: Joe Legee, Deputy Director, MEMA, 207-624-4400

Item 2022-001 ? Eligibility Contact person: Jeanne Garrett Management?s Response ? Management has provided an additional group training for County Coordinators, Assistants, and Contractors for determining eligibility criteria and calculating the awards for the LW-010-CONS grant on June 30, 2023. County Coordinators and Assistants will take more time and verify that the preset awards are correct prior to sending them to the central office for processing. Contractors will verify award accuracy when received from the counties and initial these awards. The Service Manager will also double check applications during the batching process.

Item 2022-002 ? Reporting Contact person: Jeanne Garrett Management?s Response ? The SF-429 Real Property is filed annually on the Grant Solutions Website. The report was filed as a ?no change in property? status report without the attachments. Training provided by a fellow Fiscal Officer on July 31, 2023 showed Attachment A for each property with Federal Interest had to be attached to the report annually even with no changes. The Grants Solution help desk added the current years so the information can be properly released and manually added to the reports. The reports are electronically signed with the preset signature of the Fiscal Officer. The report will in the future be printed and signed by the Executive Director to ensure the report is filed timely and accurately.

Department: Health and Human Services Title: Internal control over the outsourced medical claims coding process needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Department obtained and provided the RISSNET files to the vendor. The Department completed the processing of RISSNET data in the MIHMS system with the vendor. The Department will validate the RISSNET data was processed correctly. The UAT team will validate all steps are complete to ensure compliance. Completion Date: September 30, 2022 (first and second items), June 15, 2023 (third item) and June 30, 2023 (fourth item) Agency Contact: Michelle Probert, Director, Office of MaineCare Services, DHHS, 207-287-2093

Department: Health and Human Services Title: Internal control over deceased client cases and claims analysis needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Department will complete a review of claims identified by OSA and if that analysis suggests that procedures need to be enhanced, the Department will do so. Completion Date: May 31, 2023 Agency Contact: Anthony Pelotte, Director, Office for Family Independence, DHHS, 207-624-4104

Department: Health and Human Services Title: Internal control over cost of care assessments needs improvement Questioned Costs: Undeterminable Status: Management?s opinion is that corrective action is not required Corrective Action: The Department agrees with the two exceptions found by the Office of the State Auditor. However, we believe that the Department has reasonable assurance with the controls in place that results in a 97% compliance rate with the COC calculations, which is a 2% increase from last year. In the prior year's finding the Department committed to continuing to achieve a 95% compliance rate and CMS agreed with the Department and closed the prior finding. No corrective action is necessary as a result of an error rate of only 3%. The Department will continue to actively manage and monitor the Cost of Care system in compliance with federal regulations. Completion Date: N/A Agency Contact: Anthony Pelotte, Director, Office for Family Independence, DHHS, 207-624-4104

Department: Health and Human Services Administrative and Financial Services Title: Internal control over Medicare Part B premium payments needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Office for Family Independence (OFI) will incorporate the CMS business change processes (ELMO portal) into the Buy-In Reconciliation standard operating procedures. OFI will implement technology improvements in support of reducing manual data entry and increased regulatory compliance. Completion Date: September 30, 2023 and June 1, 2024 respectively Agency Contact: Anthony Pelotte, Director, Office for Family Independence, DHHS, 207-624-4104

Department: Health and Human Services Title: Internal control over cases opened due to potential fraud, abuse, or questionable practices needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Program Manager will continue to run a quarterly report to identify any cases assigned to former staff and will evaluate the cases for closure or reassignment. The Program Manager will establish a separate quarterly meeting with the Director of Compliance to review and document the results of the quarterly report. The Program Manager will use best efforts to fill the staffing vacancies that contributed to this finding. Completion Date: March 29, 2023, May 7, 2023 and June 1, 2023 respectively Agency Contact: Michelle Probert, Director, Office of MaineCare Services, DHHS, 207-287-2093

Department: Health and Human Services Title: Internal control over Long Term Care Facility audits needs improvement Questioned Costs: None Status: LTCF - Nursing Facilities: Corrective action in progress LTCF ? ICF/IIDs: Management?s opinion is that corrective action is not required Corrective Action: LTCF - Nursing Facilities: The staff currently assigned to working on outbreak reconciliations resulting from COVID will be reassigned back to LTC audits at the end of the Public Health Emergency. The Director will work with Human resources to recruit candidates to fill the vacant audit positions. The Director and Audit Program Manager for LTCF audits will meet bi-weekly to monitor the completion of audit within identified timelines and reassign staff as necessary. LTCF ? ICF/IIDs: The Department disagrees with this finding in regard to LTCF - ICF/IID's. The ICF/IID audits do not have a specific time requirement in the MBM for completion. The federal regulations only require that periodic audits of financial records occur. All ICF/IID cost reports submitted to the Department are recorded in a database and tracked for audit purposes. All cost reports are audited as resources are available. We have worked with our Federal partners who have agreed with our interpretation of the regulation and the timing of our audits for the ICF/IIDs. Completion Date: May 31, 2023 (first item), and June 30, 2023 (second and third items) Agency Contact: Herb Downs, Director, Division of Audit, DHHS, 207-287-2778