Corrective Action Plans

Views of Responsible Official: We concur with the audit finding with respect to the failure of having processes and procedures in place to prohibit from contracting with or making subawards under covered transactions to parties that are suspended and debarred or whose principals are suspended or debarred. Description of Corrective Action Plan: Currently, the County requires all new vendors to complete the attached “Vendor Registration Form”. On page 5 the vendor acknowledges they have not or are currently not suspended and debarred. A new step that Procurement implemented as of July 14, 2023 was verification of vendor’s status on sam.gov and attaching the screenshot to the LOW system. Procurement will update their vendor policy to specifically include this step. On July 14, 2023, County Attorney issued a statement enforcing the following verbiage to be added to all contracts. Debarment and Suspension: 1. Contractor certi¿es, by entering into this Agreement, that neither it nor its principals are presently debarred, suspended, proposed for debarment, declared ineligible, or voluntarily excluded from or ineligible for participation in any Federal assistance program by and Federal department or agency, or by any department, agency, or political subdivision of the State of Indiana. The term “principal” for purposes of the Agreement means an o¿cer, director, owner, partner, key employee, or the person with primary management or supervisory responsibilities, or a person who has a critical in¿uence on or substantive control over the operation of the Contractor. 2. Contractor certi¿es, by entering into this Agreement, that is does not engage in investment activities in Iran as more particularly described in IC 5-22-16.5. 3. Contractor shall provide immediate written notice to County if, at any time after entering into this Agreement, Contractor learns that its certi¿cations were erroneous when submitted, or Contractor is debarred, suspended, proposed for debarment, declared ineligible, has been included on a list or received notice of intent to include on a list created pursuant to IC 5-22-16.5, voluntarily excluded from or becomes ineligible for participation in any Federal assistance program. Any such event shall be cause for termination of this agreement as provided herein. 4. Contractor shall not subcontract with any party which is debarred or suspended or is otherwise excluded from on ineligible for participation in any Federal assistance programs by any federal department or agency, or by any department, agency or political subdivision of the State of Indiana. Next, the County Attorney provided guidance to all departments to verify vendors prior to engaging in a contract. Below is the verbiage from the County Attorney to staff on July 14, 2023. The state has asked us to verify that the entity we are contracting with is not debarred by visiting the following websites and running a search: https://sam.gov/content/exclusions https://www.in.gov/idoa/procurement/supplier-resource-center/supplier-responsibilities/ Termination for Failure of Funding: Notwithstanding any other provision of this Agreement, if funds for the continued fulfillment of this Agreement by County are at any time insufficient or not forthcoming through a failure of any entity to appropriate funds or otherwise, then the County shall have the right to terminate this Agreement without penalty by giving written notice documenting the lack of funding, in which instance this Agreement shall terminate and become null and void on the last day of the fiscal period for which appropriations were received. County agrees to make its best efforts to obtain sufficient funds, including but not limited to, requesting in its budget for each fiscal period during the term hereof sufficient funds to meet its obligations hereunder in full. For public works projects: Compliance with E-verify Program. Pursuant to IC 22-5-1.7, Consultant shall enroll in and verify the work eligibility status of all newly hired employees of Consultant through the E-Verify Program (“Program”). Consultant is not required to verify the work eligibility status of all newly hired employees through the Program if the Program no longer exists. Consultant and its subcontractors shall not knowingly employ or contract with an unauthorized alien or retain an employee or contract with a person that Consultant or its subcontractor subsequently learns is an unauthorized alien. If Consultant violates this Section, County shall require Consultant to remedy the violation not later than thirty (30) days after County notifies Consultant. If Consultant fails to remedy the violation within the thirty (30) day period, County shall terminate the contract for breach of contract. If County terminates the contract, Consultant shall, in addition to any other contractual remedies, be liable to County for actual damages. There is a rebuttable presumption that Consultant did not knowingly employ an unauthorized alien if Consultant verified the work eligibility status of the employee through the Program. If Consultant employs or contracts with an unauthorized alien but County determines that terminating the contract would be detrimental to the public interest or public property, County may allow the contract to remain in effect until County procures a new contractor. Consultant shall, prior to performing any work, require each subcontractor to certify to Consultant that the subcontractor does not knowingly employ or contract with an unauthorized alien and has enrolled in the Program. Consultant shall maintain on file a certification from each subcontractor throughout the duration of the Project. If Consultant determines that a subcontractor is in violation of this Section, Consultant may terminate its contract with the subcontractor for such violation. Pursuant to IC 22-5-1.7 a fully executed affidavit affirming that the business entity does not knowingly employ an unauthorized alien and confirming Consultant’s enrollment in the Program, unless the Program no longer exists, shall be filed with County prior to the execution of this Agreement. This Agreement shall not be deemed fully executed until such affidavit is filed with the County. Lastly, the Commissioner’s Assistant will check incoming contracts from departments to ensure proper documentation is attached that verifies the vendor has been checked through sam.gov and in.gov. Once the contract has been approved by the Commissioners, the Auditor’s office will then upload the contract and supporting documents onto Gateway. Completion Date: December 20, 2023

Finding Number: 2022-007 Finding Title: Reporting – LCTS Spending Report Program: 93.778 Medical Assistance Program Name of Contact Person Responsible for Corrective Action: Brian Ophus, Social Services Director Corrective Action Planned: LCTS recipients have been given education on the importance of timely reporting, Hubbard County has provided recipients with the proper tools and timelines in order to meet the deadlines. DHS was notified of the tardiness from recipients and issued a warning to them. Anticipated Completion Date: October 1, 2023

Finding Number: 2022-006 Finding Title: Activities Allowed and Unallowed, Allowable Costs/Cost Principles, and Reporting Program: 93.778 Medical Assistance Program Name of Contact Person Responsible for Corrective Action: Brian Ophus, Social Services Director Corrective Action Planned: Staff allocations have been re calculated per DHS guidelines in the new County Payroll system. Anticipated Completion Date: November 1, 2023

FINDING 2022-005 Craig Wright (765)747-4828 Views of Responsible Official: We concur with the findings. Description of Corrective Action Plan: Correcting the audit findings is ongoing. The city has implemented monitoring procedures to review and prevent reoccurring errors. Anticipated Completion Date: The internal control monitoring and checks and balances will be implemented immediately and continue going forward.

FINDING 2022-004 Craig Wright (765)747-4828 Views of Responsible Official: We concur with the findings. Description of Corrective Action Plan: Correcting the audit findings is ongoing. The city has implemented monitoring procedures to review and prevent reoccurring errors. Anticipated Completion Date: The internal control monitoring and checks and balances will be implemented immediately and continue going forward.

FINDING 2022-003 Craig Wright (765)747-4828 Views of Responsible Official: We concur with the findings. Description of Corrective Action Plan: Correcting the audit findings is ongoing. The city has implemented monitoring procedures to review and prevent reoccurring errors and have updated our policies and procedures. Anticipated Completion Date: The internal control monitoring and checks and balances will be implemented immediately and continue going forward.

FA 2022-001 Strengthen Budgetary Controls over Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principle Internal Control Impact: Material Weakness Compliance Impact: Material 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: S425D200012 (Year: 2020), S425D210012 (Year: 2021) S425U2120012 (Year: 2021) Questioned Costs: $31,131 Prior Year Finding: N/A Description: A review of expenditures charged to the Elementary and Secondary School Emergency Relief Fund program revealed instances in which expenditures had not be properly approved by the pass-through entity. Corrective Action Plans: The Calhoun County School System will ensure that all expenditures charged to the Elementary and Secondary School Emergency Relief Fund are properly approved by the pass-through entity. The Federal Programs Director will verify that all expenditures are reflected in the approved budget or subsequent amendments within the Consolidated Application as required. The Calhoun County School System will follow the procedures listed below to ensure that expenditures are reflected in the approved budget and/or subsequent amendments: The Federal Programs Director and the Finance Director will monitor all original budgets and subsequent amendments to ensure that expenditures have been approved. During monthly leadership meetings, the Federal Programs Director and the Finance Director will verify that all budgets and subsequent amendments have been properly signed off on by the Program Coordinator and the Superintendent in the Consolidated Application. In the event budgets and subsequent amendments are not found to be properly signed off on by the Program Coordinator and the Superintendent, the Federal Programs Director will take steps to ensure that proper sign off is initiated and completed. Estimated Completion Date: September 30, 2024 Contact Person: Pamela Quimbley Telephone: 229-545-7231 ext. 2005 Email: pamquimbley@calhoun.k12.ga.us

Corrective action plan The Organization is currently implementing a procedure to strengthen written policies and procedures to evidence its compliance with Federal Programs. Name (s) of person (s) responsible for corrective action Ms. Mabel Román, YMCA Executive Director YMCA Finance Director Anticipated completion date January 2024

Finding Number: 2022-002 Finding Title: Eligibility Program: Temporary Assistance for Needy Families (AL No. 93.558) Name of Contact Person Responsible for Corrective Action: Rhonda Porter, Director and Karen Syverson, Supervisor Corrective Action Planned: All five cases found to have errors are being reviewed and will be corrected as appropriate. All case errors will be reviewed with staff who are involved in administering this program. Case file reviews will continue to occur, and any errors found will continue to be reviewed with staff and training provided. Anticipated Completion Date: The five cases found in error will be corrected by December 31, 2023. Family Team will review these errors on Dec. 14, 2023. Case file reviews will continue monthly.

2022-004 – Classification of Consumer Goals – Significant Deficiency in Internal Controls over Compliance Recommendation: The auditor recommends LIFE strengthen policies and procedures over the classification of consumer goals to ensure that the goals in the ILS and DRS systems match and are recorded in the correct categories as defined by ILS Program Standards 5.6.1 Revision 19-1. Action Taken: LIFE Management will: • Conduct a comprehensive review of existing policies/procedures related to the classification of Consumer goals. • Outline the steps for correctly classifying Consumer goals in line with Program Standards. • Conduct mandatory training sessions for all relevant staff on the classification of Consumer goals to ensure understanding and compliance. • Working with the Purchased Services staff, review the goal status of each Consumer at closure, including comparing goals on both data collection systems. • Conduct monthly quality assurance checks and internal audits to ensure the correct classification of Consumer goals. Due Date of Completion: November 30, 2023 Responsible Official: Director of Programs

2022-003 – Payroll Time Approval – Significant Deficiency in Internal Controls over Compliance Recommendation: The Auditor recommends LIFE implement controls for documenting and retaining information to indicate the Entity follows the requirements over 2 CFR section 200.430(i), and that all time charged to the grant are reviewed for approval. Action Taken: LIFE Management will: • Review, update and adhere to established policies/procedures that align with the compliance of 2 CFR, 200.430(i). • Implement LIFE’s newly customized timekeeping system that enables accurate recording of time spent on grant-related activities and that ensures capabilities for supervisory review and approval. • Conduct training sessions for all staff to educate them about any updated policies regarding timekeeping procedures, the new online timekeeping portal and adherence to federal regulations. • Schedule internal audits and reviews, at minimum, once a fiscal quarter to ensure that the new timekeeping system is being used correctly and that all time charged to grants is appropriate and compliant with LIFE’s policies/procedures and federal regulations. Due Date of Completion: January 31, 2023 Responsible Official: Executive Director

2022-002 – Allocation Percentage Charged – Significant Deficiency in Internal Controls over Compliance Recommendation: The auditor recommends LIFE enhance the design of its control activities and procedures over the allocation percentage forms used throughout the year to ensure the staff know how to apply percentages and are using the correct approved allocation form for the period in the year. Action Taken: LIFE Management will: • Update its allocation form by clearly labeling the document used and the period and type of expense for which it applies. • Communicate the revision of all forms to staff involved in the allocation process, followed by a training session to ensure understanding and proper application of the form. • Establish a monthly review process, whereby allocation forms will be audited for current updates and application consistency. Due Date of Completion: November 30, 2023 Responsible Official: Executive Director

U.S. Department of the Treasury Passed through State of Arizona, Maricopa County (Maricopa County), Federal Financial Assistance Listing #21.027, PE386182260A4 2022 Coronavirus State and Local Fiscal Recovery Funds Finding Summary: The Foundation’s internal controls were not designed to properly ensure a review over program expenditures occurred that expenses being incurred and the basis for ultimate reimbursement were incurred within the grant award’s period of performance. Management’s Response and Corrective Action Plan: Televerde Foundation has experienced significant growth from inception in March 2020 to fiscal year ended December 31, 2022. We have grown from contributions and grants of $83 thousand and $50 thousand, respectively, in March 2020 to contributions and grants of $236 thousand and $978 thousand, respectively, as of December 31, 2022. During this same period, Televerde Foundation went from 3 employees to 21 employees and experienced significant turnover in finance staff including 2 CFO’s, 2 Controllers, and four staff accountants. The growth combined with lack of a consistent finance team is the primary cause of this deficiency. To address the deficiency, management will perform the actions below. Management will implement controls that address whether expenses incurred have a basis for reimbursement and are incurred within the period of performance. Responsible Individuals: Michelle Cirocco, Executive Director Anticipated Completion Date: March 2024

U.S. Department of the Treasury Passed through State of Arizona, Maricopa County (Maricopa County), Federal Financial Assistance Listing #21.027, PE386182260A4 2022 Coronavirus State and Local Fiscal Recovery Funds Finding Summary: The Foundation’s existing controls over federal award reporting did not identify and correct that reports submitted to the grantor were submitted with inaccurate information and that the supporting documentation used to prepare the reports were utilizing budgeted expensed amounts rather than actual. Furthermore, the budgeted expensed amounts from the supporting documentation that were the basis for the amounts to report, did not agree with the ultimate amount reported. Management’s Response and Corrective Action Plan: Televerde Foundation has experienced significant growth from inception in March 2020 to fiscal year ended December 31, 2022. We have grown from contributions and grants of $83 thousand and $50 thousand, respectively, in March 2020 to contributions and grants of $236 thousand and $978 thousand, respectively, as of December 31, 2022. During this same period, Televerde Foundation went from 3 employees to 21 employees and experienced significant turnover in finance staff including 2 CFO’s, 2 Controllers, and four staff accountants. The growth combined with lack of a consistent finance team is the primary cause of this deficiency. To address the deficiency, management will perform the actions below. Management will leverage our general ledger to retain documentation for approval and review of expenditures. We will utilize actual amounts for expenditures and in circumstances where budgeted amounts are needed, we will perform a true-up on a quarterly basis. Management will perform quarterly reviews over financial reporting. Responsible Individuals: Michelle Cirocco, Executive Director Anticipated Completion Date: July 2023

U.S. Department of the Treasury Passed through State of Arizona, Maricopa County (Maricopa County), Federal Financial Assistance Listing #21.027, PE386182260A4 2022 Coronavirus State and Local Fiscal Recovery Funds Finding Summary: The auditors identified certain expenditures tested lacked proper documentation of review and approval and those expenditures submitted for reimbursement were based on budgeted amounts expended rather than actual with no true up performed. They also identified one expenditure deemed potentially unallowable. Management’s Response and Corrective Action Plan: Televerde Foundation has experienced significant growth from inception in March 2020 to fiscal year ended December 31, 2022. We have grown from contributions and grants of $83 thousand and $50 thousand, respectively, in March 2020 to contributions and grants of $236 thousand and $978 thousand, respectively, as of December 31, 2022. During this same period, Televerde Foundation went from 3 employees to 21 employees and experienced significant turnover in finance staff including 2 CFO’s, 2 Controllers, and four staff accountants. The growth combined with lack of a consistent finance team is the primary cause of this deficiency. To address the deficiency, management will perform the actions below. Management will leverage our general ledger to retain documentation for approval and review of expenditures. We will utilize actual amounts for expenditures and in circumstances where budgeted amounts are needed, we will perform a true-up on a quarterly basis. Responsible Individuals: Michelle Cirocco, Executive Director Anticipated Completion Date: July 2023

U.S. Department of the Treasury Passed through State of Arizona, Maricopa County (Maricopa County), Federal Financial Assistance Listing #21.027, PE386182260A4 2022 Coronavirus State and Local Fiscal Recovery Funds Finding Summary: The Foundation did not retain documentation to support performance of a price analysis nor provide the opportunity for open competition. Additionally, the Foundation did not review for suspension or debarment and required contract provisions were not followed. Management’s Response and Corrective Action Plan: Televerde Foundation has experienced significant growth from inception in March 2020 to fiscal year ended December 31, 2022. We have grown from contributions and grants of $83 thousand and $50 thousand, respectively, in March 2020 to contributions and grants of $236 thousand and $978 thousand, respectively, as of December 31, 2022. During this same period, Televerde Foundation went from 3 employees to 21 employees and experienced significant turnover in finance staff including 2 CFO’s, 2 Controllers, and four staff accountants. The growth combined with lack of a consistent finance team is the primary cause of this deficiency. To address the deficiency, management will perform the actions below. Management will retain and catalog documentation related to price quotes for certain Foundation expenditures. We will update our procurement policy to be consistent with federal guidelines to assist in streamlining the procurement process. We have hired a Grant Administrator and Analyst who is responsible for reviewing contractors against the System for Award Management for suspension or debarment, including subrecipients. Responsible Individuals: Michelle Cirocco, Executive Director Anticipated Completion Date: January 2024

CONDITION: The ROE did not have sufficient internal controls over the preparation of the Schedule of Expenditures of Federal Awards (SEFA) to ensure all federal expenditures during the fiscal year were reported and information in the SEFA was accurately reported. PLAN: The ROE will work with their contracted accounting firm to review financial statements, including the schedule of expenditures of federal awards, to ensure program titles, assistance listing numbers and other pertinent information is accurate for financial statement presentation. ANTICIPATED DATE OF COMPLETION: The anticipated date of completion is December 2023. CONTACT PERSON: Ms. Jill Reedy, Regional Superintendent

CONDITION: The ROE did not have adequate controls over subrecipient monitoring in compliance with the Code. PLAN: The ROE retroactively conducted monitoring of the subrecipients of the ARP - Social Emotional Learning grant passed through the ISBE. The subrecipients of this grant were all other ROEs in the Area IV hub (ROEs 9, 17, 32, and 54) with funds going out for administration costs. Since it is common knowledge that each ROE is audited annually by the Illinois Auditor General, further audit consideration was unnecessary. The ROE will draft subrecipient monitoring policies and procedures to align with standards. Future monitoring will be scheduled in December 2023. ANTICIPATED DATE OF COMPLETION: New policy and procedures implemented partially in FY23 and fully for FY24. CONTACT PERSON: Ms. Jill Reedy, Regional Superintendent

CONDITION: The ROE did not ensure costs or expenditures were adequately documented, reviewed, and approved to ensure allowability under the federal award. PLAN: Past practice and policy during the FY22 audit, allowed for the Business Manager to sign off on purchase orders and requisitions related to monthly, reoccurring bills. New management is working on updated fiscal policies. A new Accounts Payable employee was hired in March 2023 by ROE management and trained by the Business Manager, along with Program Directors, on procedures for expenditures. Procedures have been put into place to ensure that all expenditures are signed by the Program Director or Assistant/Regional Superintendent to indicate review and approval of expenditures. After being signed by a Program Director or Assistant/Regional Superintendent, the expenditure goes to the Business Office where the Business Manager will check for appropriate signatures and will pass on to Accounts Payable for a final check for appropriate signatures and supporting invoices prior to payment. ANTICIPATED DATE OF COMPLETION: This was implemented in March 2023. CONTACT PERSON: Ms. Jill Reedy, Regional Superintendent

CONDITION: The ROE did not submit or timely submit the required reports to the Illinois State Board of Education. PLAN: New ROE management is providing close oversight for the timely submission of grant expenditure and performance reports. The Regional Superintendent has created a shared calendar of submission due dates with the Business Manager and Program Directors. Reminders are sent out via email in advance of the due dates, and then management reviews the grant report submissions in IWAS for accuracy and completion before approving and submitting to ISBE. ANTICIPATED DATE OF COMPLETION: This plan was initiated during the new Regional Superintendent’s appointment to office in October 2022 and has been fully implemented since January 2023. CONTACT PERSON: Ms. Jill Reedy, Regional Superintendent

FA 2022-001 Strengthen Controls over Equipment Compliance Requirement: Equipment and Real Property Management 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), S425U2120012 (Year: 2021) Questioner Costs: None Identified Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over equipment and real property management as it relates to the Elementary and Secondary School Emergency Relief Fund program. Corrective Action Plans: The Superintendent and CFO for Ben Hill County Schools will assign a lead person to be responsible for ESSER requirements and to assure procedures over real property and equipment are being met. Estimated Completion Date: June 30, 2024 Contact Person: Natalie King, CFO Telephone: 229-409-5500 x 5510 Email: natalie.king@benhillschools.org

Management concurs with the audit finding. The County’s Subrecipient Monitoring Policy and our compliance review project, initiated in 2022, has allowed us to continue to ensure that all subrecipient’s are monitored during the contract period noted in the contractual agreements. We have identified and updated the annual monitoring plan to ensure that all subrecipient are monitored and incompliance with the 2 CFR 200.331 federal standards.

Rural Communities Opioid Response Program – Medication Assisted Treatment (MAT) Expansion – Assistance Listing No. 93.912 Recommendation: We recommend that management implement more formal control process surrounding the use of federal awards where there is segregation between individuals identifying or proposing expenditures/uses of funds and an individual reviewing and approving that expenditure/use. We also recommend for any formal reporting required under federal awards that there be a formal review process where an individual is reviewing and approving the report who did not prepare the report. Documentation of review and approval should be retained in both cases. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: Health System implemented a formal grant management policy in November 2022. Name(s) of the contact person(s) responsible for corrective action: Collette Johnson, CFO Planned completion date for corrective action plan: November 1, 2022

Corrective actions: i. Documented approval of expenditures 1. Approval of expenditures will be documented and retained. 2. Responsible individuals: Kenny Lee (Treasurer), Shaina Gonsalves (Office Manager) 3. Anticipated completion date: June 30, 2024

Prior to the completion of this audit, EmployIndy already made a number of changes to its financial operations. It parted ways with its Chief Financial Officer and procured the services of an outside Certified Public Accounting firm to begin the process of reviewing and updating its financial operations. In addition, it recently hired an Executive Vice President of Finance and Operations to lead the final development and implementation of updated financial processes. The Executive Vice President of Finance and Operations has worked with EmployIndy’s Board of Directors and Finance Committee to document a plan for improving EmployIndy’s financial operations across the board by the 2nd quarter of Calendar Year 2024. EmployIndy currently provides training to all staff on properly documenting work hours within the time management and payroll system. There is an existing process for correcting and documenting any changes within the time management and payroll system after time has been submitted. In scenarios where it is necessary and allowable to shift EmployIndy staff time charged from one funding stream/cluster to another, Financial Operations staff, under the direction of the Controller, will make updates, including supporting documentation, in both the time management/payroll and financial management systems. Reconciliations between the payroll system and the financial management system will be completed monthly in order to ensure that the information in each system matches and that there is documentation showing that the expenses are allowable and supported. Finally, the Director of Human Resources will ensure that offer letters with pay rates and any subsequent salary adjustments will be documented with approval signatures and retained in personnel files, with proper amounts being updated within the time reporting/payroll system.