Corrective Action Plans

Finding Number: 2024-036 Audit Type: Single Audit Finding Title: Deficiencies in Equipment and Real Property Management Related Finding: 2024-021 (Yellow Book) 1. Contact Person Responsible for Corrective Action Name: Shannah Weaver Title: City Clerk Department: Finance Department 2. Planned Corrective Action The City will implement a centralized inventory tracking system and conduct annual reconciliations to ensure compliance with federal property management standards. 3. Anticipated Completion Date June 30, 2026 - plan already in place 4. Management1s Response Management concurs with the finding and will ensure staff are trained on property management procedures. 5. Status of Prior Year Finding This is a new finding.

Finding: 2024-044 - Auditors could not obtain sufficient and appropriate evidence to verify compliance with FWC’s equipment and real property management requirements. Questioned Costs: Indeterminate Assistance Listing Number: 15.605, 15.611 Assistance Listing Title: FWC Views of Responsible Officials (state whether your agency agrees or disagrees with the finding; if you disagree, briefly explain why): ADFG agrees that the policy and procedure for management of equipment, real property, and capital improvements are insufficient. Corrective Action (corrective action planned): ADFG will establish procedures and training to ensure that all equipment, real property, and capital improvements are managed in strict compliance with federal requirements. For equipment management, ADFG will take the following actions: 1. Ensure capital and sensitive equipment is accounted for in IRIS through a fixed asset transaction (FN, FA, FM, FT. or FD). Centralized data in IRIS will streamline inventory management and compliance. The IRIS fixed asset intent (FN) transaction, implemented July 1, 2024, ensures all equipment is tied to the purchasing document for better tracking of funding source information. 2. Develop and implement standardized procedures for inventory management in IRIS in coordination with the Office of Procurement and Property Management, Department of Administration. This creates consistent and accurate inventory management practices across the department. 3. Create and distribute inventory logs for staff to use in remote locations to address challenges in retrieving inventory items during seasonal months.. This will result in enhanced field equipment tracking and timely identification of equipment needs or disposal. 4. Develop comprehensive training for staff involved in equipment management to ensure staff are well-trained and knowledgeable about inventory management procedures and compliance requirements. 5. Establish clear guidelines for the timely disposal of broken, failed, or obsolete equipment and ensure efficient and compliant disposal of unnecessary equipment. This will result in reduced storage and maintenance costs. For real property and capital improvement projects, ADFG will take the following actions: 1. Collaborate with Alaska Department of Natural Resources and United States Fish and Wildlife Services on land certification in the federal application TRACS. Post-certification, ADFG will develop tracking logs to ensure annual site visits occur. 2. Develop department policies and procedures to ensure real property is managed according to federal requirements as authorized in grant awards. Provide training to program staff and administrative staff on the Code of Federal Regulations requirements and proper management of departmental record-keeping logs, including site visit dates and file location for site visit notations. Completion Date (list anticipated completion date): December 31, 2025 Agency Contact (name of person responsible for corrective action): Eric Verrelli, Procurement Specialist 5 Jessica Hood, Accountant 5

USSEC was following the FAS required process of obtaining all appropriate disposal documentation prior to removing these assets from the GL and the asset list. At year-end, USSEC was waiting on a memo from the China Regional Director explaining why there was no documentation of their disposal. Until that was available, USSEC did not feel they should request FAS approval to dispose and remove from our GL and asset listing. Therefore, the assets remained on USSEC’s year-end GL and asset listing. To date, that has not been received from the China office, though they are requesting it once again. FAS approval was requested May 20, 2025, and received June 5, 2025. The assets will be removed fromthe GL and assets list as of June 30, 2025.

2024-004 Contact Person: Duane Poitra, Business Manager Corrective Action Plan: The purchasing agent acquired verification that American Rescue Plan – Elementary and Secondary School Emergency Relief (ESSER III) may be used for IDEA B allowable special education purchases. Moving forward, prior approval will be acquired by District purchasing agents on the ND DPI Capital Expenditure Prior Approval For Use of Federal Funding form before capital purchase is made using federal funding. Anticipated Completion Date: Fiscal Year 2024-2025

Department of Public Instruction Response/Corrective Action Plan: DPI agrees with the finding. We have split the duties of subrecipient review among two employees. One person does the administrative functions and responses to subrecipients who have no findings. The other employee works on the more complex audit reviews. We feel that this change along with the increase to the audit threshold and the end of the COVID related federal funding will allow us to stay in compliance of federal regulations. Contact Person: Jamie Mertz, CFO Anticipated Completion Date: This was implemented January 2, 2025

FINDING #2024-002: EDUCATION STABILIZATION FUNDS – EQUIPMENT AND OTHER CAPITAL EXPENDITURES (5000) Corrective Action Plan: Compton USD will act with diligence and care. Under the new Director of Fiscal Services, a pre-approval checklist for all grant expenditures, including mandatory CDE approval for equipment and capital expenditures, has been implemented.

●      The superintendent was provided with a statement of liability coverage from the company's insurer, which was assumed to suffice as a performance bond, but going forward, only proper performance bonds will be accepted. The District has properly recorded the assets obtained through these funds. The Arkansas Division of Elementary and Secondary Education (DESE) has been consulted regarding the documentation of Davis-Bacon wages, and the District will require weekly wage reports from future contractors when federal funds are used for construction projects. The District will also ensure that all future capital improvement projects adhere to federal and state requirements, including obtaining appropriate performance bonds and incorporating prevailing wage rate provisions in contracts. Additionally, the Capital Assets Clerk will receive specific training on the proper documentation and recording of capital improvements and equipment. Anticipated Completion Date: July 1, 2024.

May 28th, 2024 Christy White, Inc. 348 Olive Street San Diego, CA 92103 Response to Find in #2023-003: The Business Office, in coordination with the Purchasing Department, is developing a process to ensure that the appropriate approvals are obtained in the event that capital expenditures are charged to federal programs. The corrective action is expected to be implemented by June 30, 2023.

The district will develop a check list to be used when projects are approved. The checklist will include making sure contracts are obtained when the project is being paid from a federal fund. In addition, it will note that weekly certified payrolls are to be submitted. Additional training will be provided to our Facilities Director on the Davis­ Bacon Act. The district will adjust the current procedure for identifying expenditures which need to be included on capital asset inventory. 7/31/2024- Completion of new form, training, and flooring improvement added to fixed assets.

2023-015 Oregon Housing and Community Services Fully implement controls to ensure subrecipients are in compliance with program requirements MANAGEMENT RESPONSE: We agree with this recommendation. OHCS has hired an outside contractor to complete the requested work. Contractor was not in place in time to complete action prior to end of audit work, however work will be finalized prior to the end of the current fiscal year. Anticipated Completion Date: June 30, 2024 Contact person: Dean Criscola, Controller

FINDING #2023-004: EDUCATION STABILIZATION FUNDS (ESF)- EQUIPMENT AND OTHER CAPITAL EXPENDITURES (50000) Corrective Action Plan: If the district would like to use Elementary and Secondary School Emergency Relief Ill (ESSER Ill) Fund (Resource 3213) to support capital expenses, the district will seek prior approval from the California Department of Education. The district will keep the approval on file.

The District's procedure for purchases utilizing federal funds for goods in excess of $5,000 are submitted to the California Department of Education prior to purchase for approval. The District utilized COVID relief funds to upgrade classrooms with equipment consistent in the SVI classroom project. While the components of the SVI project are under the $5,000 threshold for prior approval collectively they are over this threshold. The components being under the $5,000 threshold resulted in an oversight of the needed preapproval for these purchases. Fiscal Services is developing a checklist of required steps in the procurement process when federal funds are being considered to ensure prior approval, if needed, is sought prior to purchase. The checklist will include an area where each component is listed to include delivery cost and installation and will include acknowledgement of whether these components collectively create one asset. This will allow other staff reviewing the checklist to determine if preapproval based on cost may be needed. The checklist will require approval of the department head of the requesting department acknowledging understanding of the federal purchasing requirements for capital expenditure as well as, approval of the Director, Fiscal Services and the District's Assistant Superintendent of Business Services.

District subsequently sought and obtained CDE approval for the expenditures identified in finding 2022-003.District has initiated a procedure where any requisitions for purchases utilizing Federal funds are routed through the Director of state and federal programs prior to being approved. The director of state and federal programs, prior to approving the purchase requisition, will obtain approval from the CDE. All contracts utilizing federal funds will include language related to Federal wage rate requirements. The supervisor of Purchasing will be tasked with ensuring the contract language is present in agreements for services utilizing Federal funds.

U.S. DEPARTMENT OF EDUCATION Significant Deficiency 2022-01: Education and Secondary School Emergency Relief Fund ? CFDA #84.425D and #84.425U Grant Period: Year Ended June 30, 2022 Condition and Context: The District purchased equipment greater than the Uniform Guidance capitalization threshold and failed to complete a listing of equipment containing all pertinent data. The lack of compliance did not result in any material noncompliance, fraud, or abuse with respect to the major program. Criteria: The Uniform Guidance requires entities to follow equipment procedures set out at 2 CFR sections 200.313(c) through (e) and real property procedures set out at 2 CFR section 200.311(b). Entities must retain a listing of equipment greater than or equal to the capitalization policy of either the entity or Uniform Guidance with relevant data including, a description of the property, a serial number or other identification number, the source of funding for the property (including the federal award number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, a and any ultimate disposition data including the date of disposal and sales price of the property. Property records must be maintained and include the name, part number and description, and other elements as necessary and required in accordance with the terms and conditions of the contract, quantity received, unit acquisition cost, unique-item identifier, accountable contract number, location, disposition, and posting reference and date of transaction. Cause: The District was unaware of the requirements set out by Uniform Guidance. Effect: An important component of equipment policies is retaining information to ensure that the award is used for authorized purposes, complies with the terms and conditions of the award, and achieves performance goals. Without equipment policies, there is a higher risk of noncompliance with program requirements. Recommendation: Management should determine procedures for equipment purchases and apply them to all equipment purchases equal to or exceeding the threshold to comply with the Uniform Guidance. Grantee Response: Management agrees with the finding and recommendation. The District will establish policies and procedures for future grant awards to comply with Uniform Guidance requirements.

2022-019 Oregon Housing and Community Services Controls are needed to ensure subrecipients? compliance with equipment and real property requirements Federal Awarding Agency: U.S. Department of Housing and Urban Development Assistance Listing Number and Name: 14.231 Emergency Solutions Grants Program (COVID-19) Federal Award Numbers and Years: E-20-DW-41-0001, 2020 (COVID-19) Compliance Requirement: Equipment and Real Property Management Type of Finding: Material Weakness; Material Noncompliance Prior Year Finding: N/A Questioned Costs: N/A Criteria: 2 CFR 200.311; 2 CFR 200.313 There are specific requirements when equipment is purchased using federal funds and in use. At a minimum, procedures for managing equipment must meet the following requirements: Property records must be maintained that include key details (e.g. property description, ID number, Title, etc);? A physical inventory of the property must be taken, and the results reconciled with the property records at least once every two years;? A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated; and? Adequate maintenance procedures must be developed to keep the property in good condition.? Real property purchased must be used for the originally authorized purpose as long as needed for that purpose. When real property is no longer needed for the originally authorized purpose, the non-federal entity must obtain disposition instructions from either the federal awarding agency or pass through entity. During our review, we determined OHCS was not monitoring its subrecipients to ensure the equipment and real property requirements were being met. Because subrecipients were not being monitored, we were unable to determine if there was a population of equipment and real property on which to perform our audit testing procedure. As a result, the department may not be in compliance with federal equipment and real property requirements. We recommend department management develop internal controls to ensure compliance with federal requirements for equipment and real property. MANAGEMENT RESPONSE: We agree with this recommendation. OHCS has instituted a procedure for State FY23 which is on track to be completed for all ESG recipients; this procedure currently includes a notification and approval process for the tracking of the acquisition, rehabilitation, renovation, or conversion of property and separately a vehicle purchase and equipment purchase. We are in the process of refining a control system to ensure adequate safeguards are in place to prevent loss, damage, or theft. Additionally, we are reviewing our maintenance procedures to ensure properties are in good condition. Anticipated Completion Date: December 24, 2023 Contact: Jill Smith, Director of Housing Stabilization Division

Re: 2021-2022 Corrective Action Plan Kirby School District will correct the following reportable findings for the 2021-2022 school year. The District, Pike Palmer and Melissa Turner, will ensure that all contracts are obtained and all applicable construction contracts contain the required notification regarding compliance with the Davis-Bacon Act. We will make sure to get copies of the weekly certified payrolls for applicable projects. We will be in contact with ADE for guidance and implementation of proper controls over program expenditures by June 30, 2023. Kirby School District will correct the following supplemental findings for the 2021-2022 school year. All activity receipts will be written correctly according to the check/cash composition by Jessica Pinkerton. All capital assets lists will be accurately updated every year by Jessica Pinkerton and Melissa Turner. Melissa Turner will maintain detailed documentation for all expenditures. Pike Palmer will make sure to follow proper bidding procedures provided by the Arkansas Code. All stale dated checks will be handled by Melissa Turner and Jessica Pinkerton in accordance with the unclaimed property laws.

FINDING 2022-003 Contact Person Responsible for Corrective Action: Jessica Secrease Contact Phone Number: 765-456-2804 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The County will maintain adequate property records for the State and Local Fiscal Recovery Funds. In the future, the Auditor?s Office will request that the County Commissioners and County Attorney provide all necessary information in order for records to be maintained properly. The County Commissioners will also be reminded that they need to follow the agreements that they approve. Anticipated Completion Date: 06/15/2023

Finding Number: 2022-001 Planned Corrective Action: The School District will review all purchases made with federal funds to ensure they are properly capitalized and input into the EIS system for tracking purposes. Anticipated Completion Date: April 30,2023 Responsible Contact Person: Samantha Hamilton, Treasurer

RESPONSE TO AUDIT FINDING #2022-002: EDUCATION STABILIZATION FUND DISCRETIONARY GRANTS- SPECIAL TESTS AND PROVISIONS (50000) The charter has already submitted the capital expenditure request form to COE and is awaiting approval. The charter will review all required compliance requirements for all new federal funding before purchases are made. The charter anticipates receiving the approval by December 31, 2023.

Planned Corrective Action: The Expo is bound by their management agreement with Bell County. Corrective action can not be taken in response to this finding. Person Responsible for Corrective Action Plan: Tim Stephens, Executive Director Anticipated Date of Completion: Not applicable

Fiscal Year Audit Report: Corrective Action Plan Year ended June 30, 2022 Finding 2022-002: Education Stabilization Fund (5000) Federal Agency: U.S. Department of Education Pass through Entity: California Department of Education Program Names: Elementary and Secondary School Emergency Relief I, II, III (ESSER, ESSER II, ESSER III) (Assistance Listing 84.425D) Criteria: Consistent with 2 CFR Section 200.311 (real property), Section 200.313 (equipment), and Section 200.439 (equipment and other capital expenditures) Education Stabilization Funds may be used to purchase equipment. Capital expenditures for general and special-purpose equipment purchases are subject to prior approval by the Department of Education or the pass-through entity. Finding: The District purchased numerous equipment items above the capital threshold for federal purchases but did not obtain approval from the California Department of Education. Questioned Costs: Purchases totaling $329,699.90, were made for equipment above the capital threshold without CDE approval. Context: The finding is limited to purchases above the capital threshold requiring approval. Cause: The District was unaware of the requirement. Effect: The funds spent on this purchase may be subject to review or return to the awarding agency. Recommendation: We recommend the District submit requests for approval for the equipment or find another allowable funding source for the purchases. Action: Staff and Management will ensure that the District submits requests for approval for capital expenditures from the California Department of Education prior to purchases. Completion Date: Effective immediately Contact: Zach Klemish, Director of Fiscal Services, Adelanto Elementary School District, (760) 246-8691

Person responsible for corrective action: Clerk Staff, under County Clerk supervision Corrective action planned: Necessary columns required for equipment purchased/disposed of were added to the spreadsheet. County offices notification sent reminding ALL add/delete information must be completed for proper data entry into the inventory system Anticipated completion date: August 31, 2023

Re: Reference 2022-001 Davis-Bacon Act Contact: Opal Anderson, Superintendent The Lafayette County School District will comply with the Davis-Bacon Act provisions utilizing sound accounting policies and maintain internal controls that will initiate, authorize, record, process, and report transactions consistent with management?s assertions embodied in the financial statements and that will safeguard District assets. We will also review our Risk Assessment and Monitoring controls as they pertain to our operational processes. Periodic internal control reviews are conducted by the Superintendent and/or District Treasurer to ensure all procedures are properly implemented.

RESPONSE: The following is Food Service Director Deanna Gilbert?s response: Not going in and adding the addition meals until the end of the month to keep from the meals being added twice. The Management company director handed out the right completed meals but the paperwork did not back up the components in the meal. Double check all paperwork to make sure the meal components are all listed on the Production record. Deanna Gilbert, Child Nutrition Director June 1, 2023 Action started June 30, 2023 Action completed