Corrective Action Plans

As of October 8, 2024, the Executive Director of Business & Human Resources, Kevin J. Polunci has reached out to Questar III BOCES to ensure the equipment purchased with federal funds is clearly denoted in the report ending June 30, 2025.

Implementation plan of action: The Business Manager will review these requirements with the Account Clerk responsible for tracking fixed assets to ensure that purchases made with federal dollars are recorded in the database with all the necessary information to meet the compliance requirements. In addition, we will establish a process to perform a physical inventory as required every two years. Person Responsible for Implementation: Jodi Birch, Business Manager and Kristie Smith, Account Clerk Anticipated Completion Date: June 30, 2025

Cause: While policies were in place, detailed written procedures for consistent grant administration had not been developed or formally documented. Corrective Action Taken: A procedure manual has been written to incorporate required compliance areas, including allowability of costs, procurement, equipment management, cash management, time and effort reporting, suspension and debarment, and record retention. Planned Corrective Actions / Preventive Measures: 1. Procedure Development: Document clear written procedures including requisitioning, approvals, reimbursements, reporting, and monitoring. 2. Training and Implementation: Provide training to all staff involved in grant administration on the new procedures. Establish a schedule for periodic refresher training and updates when regulations or program requirements change. 3. Ongoing Monitoring: Designate the Business Administrator (or designee) to monitor compliance and review procedures annually. Update policies and procedures as needed to reflect changes in federal requirements or internal practices. Timeline: Procedures completed: September 2024. Staff training and implementation: June 2026. Ongoing monitoring: Annually, beginning March 2026 Responsible Parties: Lori Schmidt, Business Administrator: Oversight of policy and procedure revision, implementation, and monitoring. Scott LaFortune, Finance Manager/Grant Manager: Day-to-day adherence to procedures and reporting. School Board: Formal policy approval.

Reference Number: 2023-009 Finding: Improve Controls and Compliance with Equipment and Real Property Management Name of Contact Person: Lorina Esposito Corrective Active Plan: Over the past year staff has ensured that the inventory is up-to-date and accurate. Inventories were performed in 2024 in preparation for the single audit. Now that the division of housing and community development is fully staffed, the inventory can be shared amongst staff as well as uploaded to the shared drive to ensure it can be accessed in the event of staff turnover. Proposed Completion Date: 3/31/26

Name of Contact Person Responsible for Corrective Action Plan: Marcee Pool, Interim Superintendent Corrective Action Plan: Dublin City Schools concur with the finding and are working to implement appropriate internal controls to alleviate the finding. Anticipated Completion Date: December 31, 2026

2023 – 007: Equipment and Real Property Management (Compliance; Internal Controls Over Compliance) Material Weakness Condition: During our review of the Organization’s internal controls over compliance related to the Title V major program, we noted that the Organization did not obtain prior written approval from the funding agency for the purchase of land and a building with Title V funds, with the purchase exceeding the $20,000 threshold included in the Title V contract. Additionally, the Organization did not have an approved budget that included these capital expenditures. The Organization also does not have an adequate system of controls established to identify, mark, record, or maintain equipment and real property purchased with federal funds, and no periodic physical inventory of such assets is being performed. Corrective Action Plan: Management will review internal control policies and procedures to ensure that prior written approval is obtained for all capital expenditures with federal funds. A procedure will be set up for maintaining property records, conducting periodic physical inventories, and ensuring all staff are trained on these requirements.

The School has hired a consultant for training.

2023 – 008: Activities Allowed and Unallowed, Allowable Costs, Period of Performance (Compliance; Internal Controls Over Compliance) (Repeat Finding: 2018-006, 2019-008, 2020-008, 2021-007 and 2022-009) Significant Deficiency ALN 93.441 Indian Self Determination ALN 20.205 Highway Planning & Construction ALN 93.575 Child Care and Development Block Grant Condition: During compliance requirement testing for Activities Allowed and Unallowed, Allowable Costs and Period of Performance for the above noted major programs, the auditors selected 120 transactions for testing from each major program. The following number of transactions were not provided for review during the audit: ALN 93.441 – Indian Self Determination – 18 transactions ALN 20.205 – Highway Planning and Construction – 16 transactions ALN 93.575 – Child Care and Development Block Grant – 7 transactions Corrective Action Plan: The Finance Department will become familiar with the requirements of 2 CFR, Part §200.313(a) and establish appropriate internal control policies and procedures to ensure compliance with the requirements of Uniform Guidance and each major program. In addition, all staff will be trained on those policies and procedures, so they are familiar with the requirements. The Finance Department will not process payment for disbursements that does not contain sufficient, appropriate supporting documentation and necessary approvals. The Finance Department will implement and execute an internal audit, by pulling random vouchers packets to test for compliance mid-year. An internal audit process is being developed and personnel assigned. Forms will be developed to assist with the internal audit process to ensure a timely and consistent process will be followed.

FA 2023-002 Improve Controls over Equipment Compliance Requirement: Internal Control Impact: Compliance Impact: Federal Awarding Agency: Pass-Through Entity: AL Numbers and Titles: Federal Award Numbers: Questioned Costs: Repeat of Prior Year Finding: Equipment and Real Property Management Significant Deficiency Nonmaterial Noncompliance U.S. Department of Education Georgia Department of Education 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 S425D200012 (Year: 2021), S425U2100012 (Year: 2021) None Identified FA 2022-001 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 Finance Director will develop an equipment listing for ESSERS and ARP equipment that consists of all required information, including a description, an identifying number, the source of funding, the title holder, the acquisition date, the cost, the percentage of federal participation in the project costs, the location, the use and condition, and any ultimate disposal data for each piece of equipment. The Superintendent and Finance Director will further coordinate with Principals and Directors to ensure that all equipment is accounted for by conducting a complete physical inventory at least once everytwo years. Estimated Completion Date: June 30, 2026 Contact Person: Dr. Angela Williams, Superintendent Telephone: 706-554-5101 Email: amwilliams@burke.kl2.ga.us

The MOF is actively recruiting two dedicated staff members to strengthen asset management, including ensuring the full utilization of the FMIS asset module for tracking, reporting, and monitoring capital assets. These positions will provide technical oversight and support for proper recording, classification, and reconciliation of assets. Furthermore, the MOF continues to coordinate with line Ministries to update and reconcile capital asset records, ensuring accuracy and completeness across all government entities.

The Government concurs with the auditor’s findings and recommendations. VIDE plans to improve management and documentation of federally funded equipment by enhancing its asset tracking system and maintaining centralized records with detailed asset information. The Procurement Division will conduct quarterly inventory audits to reconcile records with actual inventory, resolving discrepancies promptly. The Fixed Asset Director will establish communication protocols among Programs/Divisions, requiring monthly status reports to ensure data accuracy and timely updates.

VIDE acknowledges the recurring finding regarding Equipment and Real Property Management and concurs with the recommendation. VIDE recognize that while a dual-control workflow exists, high staff turnover and a lack of strict adherence have led to gaps in compliance, and to address this, VIDE is moving to strictly enforce its established protocols and provide targeted training to new personnel in the Procurement and Fixed Asset divisions. VIDE is enforcing strict adherence to its established collaborative dual-control process to ensure timely identification of federally funded equipment, specifically reinforcing the requirement that the Procurement Warehouse must tag assets immediately upon physical receipt so that no asset is permitted to leave the warehouse or enter the ecosystem without a unique identifier. Additionally, VIDE is clarifying the role of the Fixed Asset Management Division to ensure they perform the mandatory post-delivery validation as a secondary check to confirm the location, condition, and accuracy of the data recorded by Procurement, thereby ensuring the hand-off between divisions is complete and documented. Due to recent staffing changes, VIDE will conduct mandatory “Roles and Responsibilities” training wherein the Assistant Commissioner will oversee training for Fixed Asset staff regarding validation protocols and the Deputy Commissioner of Fiscal and Administrative Services will oversee training for Procurement staff regarding intake and tagging. VIDE is also updating the data fields within its asset tracking system to strictly mandate the inclusion of all data points required by 2 CFR 200.313, including acquisition date, cost, percentage of federal participation, and ultimate disposition data. Furthermore, the Procurement Division and Fixed Asset Division will conduct quarterly inventory reconciliations to ensure the physical assets match the property records, with any discrepancies identified resolved within 30 days of the audit. Finally, the Fixed Asset Director will submit a “Monthly Asset Status Report” to the Assistant Commissioner for operational review, with a copy submitted to the Deputy Commissioner of Fiscal and Administrative Services for audit compliance tracking, detailing new acquisitions, validation status, and explicitly reporting on any instances where the dual-control process was not followed.

The Department of Property and Procurement (DPP) acknowledges the findings and is actively implementing measures to strengthen compliance with federal equipment requirements.

DPNR concurs with the auditor’s findings and recommendations. The Asset Management Division (AMD) adheres to Federal equipment guidelines. Assets are tagged, and records are created using the Tyler Munis Resource Planning system (ERP). In 2022, AMD inventoried four agencies, ensuring compliance with Federal regulations. The completed Standard Operation Policies and Procedures (SOPP) are pending approval, crucial for enhancing internal controls. Training sessions for fixed assets employees are planned, and additional staff will be needed to support the initiative effectively.

2023-3 –Equipment and Real Property Management Contact Person: Kaitlin M. Rosselli, Business Manager Recommendation: We recommend that the District implement procedures to ensure prior written approval is obtained for applicable equipment purchases funded by federal grants and that fixed asset records include all required information in accordance with Uniform Guidance. The District should also provide appropriate training to personnel involved in grant purchasing and asset management to ensure ongoing compliance. Action: ARP-ESSER III was the first time the District purchased equipment over the $5,000 threshold with federal funding, so processes and procedures for doing so were not in place at the time of the purchases. In the future, the District will implement procedures to ensure written approval is obtained for applicable equipment purchases funded by federal grants prior to purchasing. We will also provide appropriate training to personnel involved in grant purchasing and asset management to ensure ongoing compliance. Date for Completion: These steps have already been put into place and will continue to be built upon.

Finding 2023-005: Condition 1: The State’s capital asset register reflected no Compact Sector–funded capitalized infrastructure additions since FY 2016, despite completed contracts during 2016 through 2021. The State was unable to provide supporting documentation evidencing capitalizable values, project ownership, or other required details. Conditional 2: Four (4) assets or batches of assets that met the State’s capitalization requirements were not capitalized until corrected through audit adjustments Root Cause Analysis For both conditions there is a lack of internal control monitoring over fixed asset capitalization. Corrective Actions 1. For Condition 1, the State should obtain documentation to support capitalizable values and confirm ownership. 2. For Condition 2, all assets related to health-sector acquisitions, the State should improve coordination between the Department of Health and Human Services and the State Treasury to ensure eligible items are capitalized at requisition or purchase order stage. Responsible Parties For Corrective Action Plan 1: Director of DOTA and Procurement Officer For Corrective Action Plan 2: Director of Health and his administrative officers Director of DOTA, Certification and Procurement officer Timeline Verification of Effectiveness Conduct regular assessments to ensure the implementation of the aforementioned action plans.

• Maintain tailored Fixed Asset Register (FAR) for applicable programs. • Deploy staff to conduct physical asset counts and quarterly monitoring for compliance. • Note: Tailored FAR was provided during audit; full national FAR outside scope. 9/30/2026 Mr. Marcus Samo, Secretary of FSMNG Health Email: marcus.samu@fsmhealth.gov.fm

Finding 2023-005: Condition 1: The State’s capital asset register reflected no Compact Sector–funded capitalized infrastructure additions since FY 2016, despite completed contracts during 2016 through 2021. The State was unable to provide supporting documentation evidencing capitalizable values, project ownership, or other required details. Conditional 2: Four (4) assets or batches of assets that met the State’s capitalization requirements were not capitalized until corrected through audit adjustments Root Cause Analysis For both conditions there is a lack of internal control monitoring over fixed asset capitalization. Corrective Actions 1. For Condition 1, the State should obtain documentation to support capitalizable values and confirm ownership. 2. For Condition 2, all assets related to health-sector acquisitions, the State should improve coordination between the Department of Health and Human Services and the State Treasury to ensure eligible items are capitalized at requisition or purchase order stage. Responsible Parties For Corrective Action Plan 1: Director of DOTA and Procurement Officer For Corrective Action Plan 2: Director of Health and his administrative officers Director of DOTA, Certification and Procurement officer Timeline Verification of Effectiveness Conduct regular assessments to ensure the implementation of the aforementioned action plans.

FA 2024-001 Improve 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 Agriculture Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: 10.553 - School Breakfast Program 10.555 - National School Lunch Program Federal Award Number: 235GA32N1199 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 COVID-19 - 84.425W - American Rescue Plan Elementary and Secondary School Emergency Relief Fund - Homeless Children and Youth Federal Award Number: S425D200012 (Year: 2020), S425D210012 (Year: 2021) S425U210012 (Year: 2021), S425W210011 (Year: 2021) Questioned Costs: None identified Prior Year Finding: FA 2022-001, FA 2021-001, FA 2020-001, FA 2019-003, FA 2018-002, FA 2017-004 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 Child Nutrition Cluster and Elementary and Secondary School Emergency Relief Fund programs. Corrective Action Plans: Management has strengthened controls over equipment to ensure that the records are complete, accurate and r reflect all required information. We are in the process of developing a physical inventory list of equipment. The inventory listing will have all identifying information such as an item description, an identifying number, the source of funding, the title holder, the acquisition date, the cost, the percentage of federal participation in the project costs, the location of the equipment, the use and condition of the equipment, and any ultimate disposal data for each piece of equipment. A complete physical inventory will be performed each year and reconciled with the equipment listing. Estimated Completion Date: 12/31/2025 Contact Person: Christopher Stephens, Chief Financial Officer Telephone: 229-268-4761 Email: christopher.stephens@dooly.k12.ga.us

Finding 2023-003 Information on the federal program: Subject: Water and Waste Disposal Systems for Rural Communities – Equipment and Real Property Management Federal Agency: U.S. Department of Agriculture Assistance Listing Number: 10.760 Federal Award Number: N/A Pass-Through Entity: N/A Compliance Requirements: Equipment and Real Property Management Audit Finding: Material Weakness, Noncompliance Condition: An effective internal control system was not in place at the District to ensure compliance with requirements related to the grant agreement and the Equipment and Real Property Management compliance requirement. Context: The District did not maintain an updated asset listing that reflects the construction in process balance related to the project funded with federal funds. There was approximately $10.9 million of disbursements from federal funds related to the project as of December 31, 2023. Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The third-party accounting firm will compile a capital asset listing that lists out the District’s capital assets and notes the required information, which will include the federal funding source (if applicable). The capital asset listing will be updated on an annual basis. The Board of Directors will review the capital asset listing. Responsible Party and Timeline for Completion: The third-party accounting firm and the Board of Directors will implement the corrective action plan, which will go into effect immediately.

Maintain documentation of entity-wide physical inventory of capital assets, minimum of every 2 years. Person responsible: Facilities/Transp. Mgr.-Wendy Wells, Finance Director-Collice Martens Timing for Implementation: Fiscal Year 23-24

Finding 2023-002 - Equipment and Real Property Management Responsible Individual: Arlene Dickens, Chief School Financial Officer Corrective Action: All capital expenditures will require documented prior approval from the grantor agency before encumbrance. Property records will be updated and maintained in accordance with 2 CFR 200.313 and 200.439. A physical inventory will be conducted and reconciled at least once every two years. Anticipated Completion Date: October 1, 2025

Finding 2023-003: Establish and maintain effective internal control over the Federal award Plan: We have ensured all policies and procedures have been vetted by an attorney and approved by the River View Board of Trustees and the Claremont Learning Partnership Board of Directors. Moving forward, the Executive Director will ensure that all policies and procedures stay current and are reviewed by the Board annually. FY-22 & FY-23 Audits were completed in tandem, all corrections were made as soon as the issue was identified. Expected Implementation Date: RiverView amended the policy on June 17, 2025, CLP amended the policy on July 3, 2025. Contact: Cathy Pellerin Executive Director, Claremont Learning Partnership 169 Main Street; Claremont, NH 03743 603-287-7120

Finding Number 2023-045 Subject Heading (Financial) or AL no. and program name (Federal) AL #84.425 – EDUCATION STABILIZATION FUND (ESF - AL #84.425D; #84.425U) Planned Corrective Action The Office of Title Services (OTS) has reviewed the inventories in question that were submitted in the FY23 ESEA Grant Performance Review and agree there were several items above a $5000.00 unit cost that were not properly recorded on the inventories reviewed. The expectations for inventory compliance were not followed for two districts. The Office of Title Services (OTS) program director will continue to address the expectations of inventory compliance during the ESEA Grant Performance Review internal training process with the project managers to ensure accuracy during the review process. OTS has included an attachment of the current OTS training presentation that includes several slides of the inventory expectations. • For materials and supply items, the Office of Title Services (OTS) staff will review the district’s inventory procedures for compliance with 2 C.F.R. 200.302(b)(4). • For equipment items ($5,000 later $10,000 or greater unit cost) OTS staff will review the district’s inventory procedures for compliance with the requirements of 2 C.F. R. 200.313 (d)(1) Anticipated Completion Date August 2025 Responsible Contact Person Amber Polach

2023-009 – Equipment and Real Property Management (Significant Deficiency in Internal Controls over Compliance) Recommendation: We recommend the College enhance the design of its control activities and create a tool to assist in tracking and maintaining equipment purchased with federal funds. Additionally, the employees responsible for the inventory should be trained to ensure understanding of the Uniform Guidance requirements relevant to equipment and real property management. Action Taken: The 2022-2023 fiscal year was entirely encompassed by the separation Memorandum of Understanding (MOU) of March 2022 and then the final release settlement in December 2023. It is important to note that Southeast New Mexico College was a newly established independent community college, having formally separated from New Mexico State University (NMSU) as of April 2022. During this transition period, many administrative processes, including federal grant compliance procedures, were in the process of being developed, transitioned, and implemented independently from NMSU systems. As a result, certain policies, procedures, and documentation processes were not yet fully established or operational at the time of the audit. Unfortunately, due to the untimely receipt of the completed audit report, the College did not have the opportunity to review and begin addressing several of the findings until well after the end of the audit period. While the College is committed to corrective action, the delayed delivery of the audit limited the ability to implement corrective measures earlier. The College is working proactively to ensure that these issues are resolved going forward. Corrective Action Taken / Planned: • Policy Development and Revision o The institution will update its property management policies and procedures to comply with 2 CFR §200.313 and §200.311. Updates will address:  Accurate and complete property records, including required data elements (description, serial number, location, use, acquisition cost, federal grant information, etc);  Biennial physical inventory procedures, including reconciliation with property records  Safeguarding and maintenance protocols  Requirements for disposition of federally funded property • Inventory Process Implementation o A full physical inventory of all federally funded equipment and real property will be conducted by August 31, 2025, and discrepancies will be investigated and resolved. • Training o All personnel responsible for managing equipment and real property will be trained on the updated policies, inventory procedures, and compliance requirements. • Monitoring and Oversight: o The institution will implement an internal review process to ensure ongoing compliance with equipment and real property management standards. Monitoring will include:  Periodic spot checks of property records  Documentation of follow-up on any missing or unaccounted for items  Regular reviews to ensure appropriate safeguarding and maintenance of property. • Documentation of Federal Interest o For any real property acquired or improved with federal funds, the institution will ensure proper recording of the federal government’s interest in accordance with federal regulations. Due Date of Completion: August 31, 2025 Responsible Official: Carolyn Kasdorf, Vice President for Business and Finance (or appropriate official), Karla Volpi, Dean of Business and Finance, Rebecca Silva, Director of Finance, Lisa Ryan, Restricted Funds Manager, Inventory Control