Corrective Action Plans

Finding 2023-001 – Equipment and Real Property Management The single audit report included the following recommendation: We recommend that Amtrak continue to work toward a full integration or reconciliation between Amtrak’s fixed asset system of record and the different equipment-tracking systems. We recommend that management consider redesigning one of its key controls to help ensure that the monitoring of the observations is occurring on a preventive basis to help identify any exposure to non-compliance before it occurs. For example, Amtrak should consider an automated system report that would flag an asset proactively when a 2-year inventory deadline is approaching. During the observation process, management should ensure there is a review control within the process to validate that the asset is accurately tagged and such identifying information matches the equipment-tracking system. Additionally, this review control should also be performed when the asset is first logged into the equipment-tracking system. In the interim, until such processes are fully implemented, Amtrak should enhance the current control procedures surrounding the asset documentation and ensure that field personnel are aware of and are consistently and carefully updating the asset records such that clerical/human errors are minimized and that the asset records contain the necessary asset details in order to properly track equipment by federal requirements. This would include enhancing the asset chain of custody recordkeeping so that such changes are identified and reported timely. Additionally, management should consider requiring the serial number and model number to be documented in the system of record at set up in addition to the asset tag number. This will help ensure that the equipment has a unique ID number that can help it be identified and matched to the system record should an asset number not get added timely. Finally, as it relates to condition #4 above, management should investigate the root cause of the asset that could not be located and determine if additional control changes or modifications need to be made in order to prevent reoccurrence. Identification as a repeat finding: This finding was identified as a repeat finding in the immediate prior year as Finding 2022-001. This finding was reported in prior years as well, beginning in at least FY2012. Management Response/Status of Action Plans: Amtrak agrees with the recommendation to redesign key controls to help ensure that the monitoring of the observations happens on a preventive basis to help identify any exposure to non-compliance before it occurs. Amtrak continues to progress on a multi-year effort to remediate this finding. Amtrak created the EAMDT which has been tasked to improve equipment record keeping which will resolve this finding. 1. In April 2024, Amtrak completed an engagement with an outside consulting firm that delivered three items: an updated Equipment Control Policy (ECP), standard operating procedures (SOPs) for equipment management based on the accountable property system of record, and a one-hour eLearning course that reinforces the importance of good equipment management practices and the need to follow the equipment tracking requirements of 2 CFR Part 200. These deliverables will improve policies and corporate governance over assets by providing training to the employees and improving the processes needed for oversight of equipment management, as well as to help ensure that assets are not capitalized without a complete record, which would include a unique asset identifier and the condition and location of the asset. The ECP was approved and published in the Amtrak Policy and Instruction Manual in May 2024. Amtrak will communicate the updated policy to all relevant personnel by the end of June 2024. The EAMDT is working with the Learning and Development team to identify the employees who will need to take the eLearning course, and these employees will be required to take the eLearning material beginning in the first quarter of FY25. 2. The EAMDT is implementing controls throughout the equipment lifecycle as it identifies improvement opportunities. For example, EAMDT has been added as an approver to the purchase requisition workflow for equipment purchases, and EAMDT is working with Capital Accounting to ensure that assets are recorded completely before being capitalized, which would include a unique asset identifier, condition, and location of the asset. EAMDT is reviewing assets currently in the system that do not have assigned asset IDs. EAMDT’s goal is to resolve and update existing records that are missing IDs and other information by the end of April 2025. Additionally, in August 2023, the Asset Disposition group began reporting into EAMDT which enables centralization of a more complete oversight of Amtrak’s assets. EAMDT is working to improve the record keeping for asset dispositions. 3. EAMDT is working with Amtrak’s Digital Technology (DT) Department to find ways to track equipment electronically. This includes installing location tracking technology on yard and Engineering Maintenance of Way equipment to better track and locate Amtrak assets. As of the end of April 2024, location tracking technology has been installed on over 1,500 pieces of equipment with the goal of having location tracking technology installed on approximately 2,400 assets by the end of June 2024. EAMDT is also coordinating with DT on an application accessible via a mobile device (e.g., cell phone, tablet) used by field personnel to perform audits and update equipment records. 4. EAMDT has developed trend reporting and operational reporting to help EAMDT and the departments track their compliance progress and identify assets that are out of compliance or soon-to-be out of compliance to both bring assets back into compliance, as well as to ensure an inventory is done and recorded within the two-year period. As of September 2023, two primary dashboards have been developed and can be used by all departments to help identify assets that are out of compliance and/or need to be audited. 5. EAMDT performs site visits to assist the equipment managers in performing equipment and vehicle audits. During these visits, equipment managers are educated on their responsibilities and tools available for performing audits. The contacts for this item are Ian Hinke, AVP Supply Chain Management and Robert Hoban, Director Asset Management. Amtrak anticipates the implementation of the above procedures, along with continual process monitoring and refinement, will fully remediate this finding by June 2026.

2023-002 – Equipment and Real Property Management Policy Planned Corrective Action: Management is working on creating and implementing policies and procedures surrounding equipment and real property management. Name of Contact Persons: Darla Burkett, Executive Director, Angie Warren, Finance Manager and Teri Ortiz, Grants Specialist Anticipated completion date: June 30, 2024

11-087-0040-26 CORRECTIVE ACTION PLAN FOR CURRENT YEAR AUDIT FINDINGS Year Ending June 30, 2023 Corrective Action Plan Finding No.: 2023-_ 001__ Condition: The District's property records did not include all equipment purchased with Education Stabilization Funding. Plan: The District will assign an employee independent of the preparer, preferably with knowledge of applicable federal grant expenditures, to review the District's property records on a periodic basis to ensure the listing is complete and meets the requirements of 2 CFR section 200.313(d)(1). Anticipated Date of Completion: 06/30/2024 Name of Contact Person: Shane Schuricht Management Response: Management will implement the corrective action plan for the year ended June 30, 2024.

Health Center Infrastructure Support Equipment Physical Inventory Management’s Views and Corrective Action Plan Management’s View and Opinion Sunset Park agrees to establish a process, as required by OMB Uniform Guidance 2 CFR 200.313(d), to conduct a physical inventory of equipment and reconcile the results with the property records at least once every two years. Sunset Park is strongly committed to rectifying the oversight and will improve the internal control processes to prevent future occurrences. Corrective Action Plan Each year, between April and July, Sunset Park will conduct a physical inventory of equipment purchased with federal funding. The inventory listing will contain equipment records such as description, location, manufacturer's serial number, source of funding, purchase order/requisition information, cost, equipment condition, and disposition data. The Site Directors of Sunset Park will conduct and reconcile the results of the physical inspection with the inventory listing provided to them by the Grants Fiscal Department. Subsequently, the Site Directors will provide a dated and signed attestation to the Grants Fiscal Department and Director of Grants as evidence of the inventory. Any discrepancies will be further investigated and reported to the Director of Grants, the Site Director, and the Vice President of Finance for resolution. Timeline for Action Plan Date of Completion: 08/31/2024 Responsible Individual Leonardo Arias Email: Leonardo.Arias@nyulangone.org

The National Trail Local School District will be updating the School District’s inventory system to properly account for all property and equipment purchased using federal funds.

Personnel Responsible for Corrective Action: Policies and procedures will be supervised by Senior Accounting Specialist, Laura Froese, Facilities Operations Manager, Tiffany Durr, Grants Specialist, Westen Gehring Anticipated Completion Date: Equipment inventory listing of federally covered purchases will be completed by July 1, 2024 and reflected in the 2024 audit. Integration into Limble will start this fiscal year, but full installation of the new system has an anticipated completion date of January 1, 2025. Corrective Action Plan: The Land Institute will review grant expenses in the previous years and cross reference with existing equipment inventory to create a complete listing of equipment purchased with federal funds. Documentation demonstrating proper equipment procurement practices will be housed in the federal award folders for the grant covering the purchase cost. Additionally, The Land Institute is currently modernizing equipment tracking and inventory practices using Limble and will ensure that federal procurement tracking in compliance with uniform guidance standards is included in this practice. TLI purchased Limble on 10/20/2023 after a competitive review of similar CMMS’s (Computerized Maintenance Management Systems). Setup of the system will be completed by June 30, 2024. Beginning July 1, 2024 TLI will start implementation and training of new system with full adoption of the system tentatively planned for January 1, 2025.

Finding Number: 2023-001 Planned Corrective Action: The Emergency Prepardness Program Manager position has been turned over twice in the two-year period in which the physical inventory was to be performed. This last vacancy was four months and filled near the end of the two-year inventory cycle. During the audit it was discovered the physical inventory was i nthe planning stages but due to transition, the inventory was not completed. The schedule for completion did not get transferred to the new program manager. When it was discovered that the physical inventory had not been completed, plans were made to complete the physical inventory. To ensure ongoing compliance, the program manager has created an inventory calendar and plans to perform half the physical inventories in year one and the second half in the second year. The calendar is published in the ASPR Grant Teams site. Anticipated Completion Date: June 30, 2024 Responsible Contact Person: Christina Fozio, Emergency Preparedness Program Manager

Condition - The District did not maintain the proper property records as required under CFR Title 2, part 200.313(d). Plan - The District's Inventory Control sheet will be updated to include all of the required elements related to the Equipment and Real Property Management compliance requirements. Anticipated Date of Completion - 6/30/2024. Name of Contact Person - Tony Shinall, Superintendent. Management Response - There is no disagreement with this finding and the District will update the invenory control sheet to include all of the required elements to ensure the District is complying with the Equipment and Real Property compliance requirements.

51-084-0150-26 CORRECTIVE ACTION PLAN FOR CURRENT YEAR AUDIT FINDINGS Year Ending June 30, 2023 Corrective Action Plan Finding No.: 2023-_ 002__ Condition: The District is not maintaining property records required by 2 CFR section 200.313(d)(1). Plan: The District will assign an employee, preferably with knowledge of applicable federal grant expenditures, to prepare and maintain the District's property records and ensure the listing is complete and meets the requirements of 2 CFR section 200.313(d)(1). Anticipated Date of Completion: 06/30/2024 Name of Contact Person: Tip Reedy Management Response: Management will implement the corrective action plan for the year ended June 30, 2024.

The School District will add the renovations to the health center to the inventory records.

Response: The District concurs with this finding. Deficiencies in the internal control activities adversely affected the District’s ability to record program expenditures in the District’s equipment subsidiary ledger. District management recognizes the importance of recording such expenditures so that these assets can accurately be tracked over time.

Corrective Action Taken: Corrective action has been implemented by the District to establish an internal control process for recording such assets. The Business Manager ensures that items are coded correctly upon purchase and that related documentation is forwarded to the District’s fixed asset supervisor, who then records the items to the equipment subsidiary ledger in a timely manner. Periodic reports are run by the Business Manager to verify that all required items have been entered.

Finding No.: 2023 – 005 Condition: The District does not currently maintain a detailed accounting/list of its capital assets, including Federal assets. The District does not have a recent replacement cost valuation for insurance purposes. Plan: The district has allocated internal business office resources to perform a detailed inventory and accounting of capital assets and Federal assets. Anticipated Date of Completion: May 31, 2024 Name of Contact Person: Christopher Blomquist, CSBO Management Response: See plan above

Finding Number: 2023-002 Planned Corrective Action: Management will update the District’s inventory records to include the six new school buses. Anticipated Completion Date: June 30, 2024 Responsible Contact Person: Dan Russomanno, Treasurer

CORRECTIVE ACTION PLAN December 7, 2023 Kansas State Department of Education and Kansas State Department of Administration Unified School District Number 214 respectfully submits the following corrective action plan for the year ended June 30, 2023. Dirks, Anthony & Duncan, LLC Po Box 885 Ulysses, KS 67880 Audit Period: June 30, 2023 FINDINGS – FEDERAL AWARD PROGRAMS AUDIT U.S. Department of Education Passed Through Kansas State Department of Education Program Name: Education Stabilization Fund Cluster Federal Assistance Listing Numbers: 84.425W, 84.425U, 84.425D Finding 2023-001 Recommendations: The Board of Directors, the Director and key positions of management should adequately document internal control procedures for equipment inventory, log maintenance, and dispositions requirements consistent with 2 CFR sections 200.313(c) through (e). Board should then periodically check that all procedures agreed upon are operational and effective, and adjust procedures as needed. Action Taken: We agree with the recommendation. Our targeted implementation date is March 2024. If the Kansas State Department of Education and/or Kansas State Department of Administration has questions regarding this plan, please call Corey Burton at 620-356-3655. Sincerely yours, Corey Burton Superintendent

Finding 2023-002. Inventory Management Corrective Action: Due to staff turnover at the school, this task was not completed. Management will undertake the inventory of fixed assets. Responsible Person/Position: Rod Iberg/COO

Finding Number: 2023‐001, 2022‐002 Program Name/Assistance Listing Titles: COVID‐19 Education Stabilization Fund, COVID‐19 Emergency Connectivity Fund Program Assistance Listing Numbers: 84.425C, 84.425D, 84.425U, 84.425W, 32.009 Contact Person: Ricky Hernández, Chief Financial Officer Anticipated Completion Date: December 31, 2024 Planned Corrective Action: The physical inventory that was to be completed by June 30, 2022, was only partially completed, and only included technology equipment and no other assets. The District will begin a full physical inventory on or by June 1, 2024, with a planned completion date of December 31, 2024.

Staff members have received updated training to become more familiar with the inventory process to ensure equipment is properly tracked.

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 2023-003 Compliance Requirement(s): Equipment and Real Property Management Audit Findings: Material Weakness, Other Matters Summary of Finding: An effective internal control system, which would include segregation of duties, was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the following compliance requirements: Equipment and Real Property Management The Unit did not have an internal control system and procedures in place to ensure property records are properly maintained, and include all the required information. The property records do not contain the following information about the equipment: description (including serial number or other identification number), source of funding for the property (including the federal award identification 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, location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property (2 CFR 200.313(d)(1)). A physical inventory of equipment was not performed at least once within the last 2 years. The Unit did not have an internal control system and procedures in place to ensure equipment is appropriately safeguarded and maintained. Views of Responsible Officials: We Concur with this finding. Description of Corrective Action Plan: Internal controls will be put in place to ensure property records contain proper information about the equipment. The grant manager and treasurer will work on the documentation as equipment meeting requirements is ordered to ensure updated records. We will also contract another outside entity to do biannual updates of our capital assets. Anticipated Completion Date: Immediately

The Treasurer will work with the GAAP compiler to ensure that all assets purchased with federal funds are properly accounted for on the financial statements for subsequent fiscal years. Additionally, beginning in late FY24, capital assets are tracked using an inventory management system. This will help ensure that all future assets purchased with state and federal funds are identified properly.

Highway Planning and Construction - Assistance Listing No. 20.205 Recommendation: Expand capital asset inventory policies and procedures to ensure equipment purchased with Federal funds include all required information, is accurate, updated and certified for accuracy. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Transportation Management Services staff will perform an initial review to be maintained annually thereafter of equipment inventory purchased with federal funds to ensure all required information by Federal rule is accurate and up to date. The County will expand its policies and procedures over equipment inventory records funded by Federal funds including the Grant Administration Handbook. The County will engage its Consultant to incorporate additional fields in its existing asset management module within the electronic financial system. A separate communication regarding grant-funded inventory will be created and distributed to staff for review and certification. Name(s) of the contact person(s) responsible for corrective action: Trinity Scott, Transportation Management Services Department Head, 239-252-5873; Therese Stanley, Grants Compliance Manager, 239-252-2959. Planned completion date for corrective action plan: September 30, 2024

The City recognizes the importance of internal controls and plans to enhance procedures to ensure that all capital equipment is captured at time of purchase and receipt and properly entered in the property records. The City has actively reviewed its procedures of purchasing and disposition of fixed assets and will make the necessary adjustments to ensure the fixed assets system remains up the date. Covid interruptions with related illnesses, early retirements, and hiring difficulties all contribute to a negative impact on productivity.

Finding 2023-002 - Corrective Action Plan CHSD - 2022-2023 Audit Findings Finding 2023-002 – EQUIPMENT Type: Material Weakness in Internal Control / Noncompliance Program: COVID 19 Education Stabilization Fund (ALN 84.425D – ESSER II Formula) Condition: The District was unable to locate all Chromebooks selected for testing that were purchased with ESSER II Formula funds. Also, some Chromebooks that were located did not have adequate identification tags Corrective action to be taken: A. Improved device inventory management – to include ESSER Funded Chromebooks: Consistent with the goal of improved technology device tracking, CHSD will expand the scope of end-user identification information collected and monitored via existing Technology Management Systems. By leveraging and expanding the use of available resources within our Google Administrative Console and GoGuardian, including deployment of a GoGuardian check-in/check-out functionality, CHSD will possess the details and tracking information necessary to provide improved device management and tracking in real time. The following actions, consistent with the goal of this CAP, will be executed as part of the expanded device monitoring project deployment:  Complete a full review of CHSD Technology Device inventory.  Decommission and/or disable any lost, damaged, stolen, or broken Technology Devices (to include Chromebooks) and document the outcome of each event (i.e. unsalvageable, returned to use, lost/stolen, etc.) prior to recycling or further deployment.  Perform routine internal audits of device inventory: o Per trimester o Annual summer audit. B. Proper identification tags on Chromebooks: This is an ongoing corrective action to address devices which were deployed prior to the purchase of an etching device for the District. Deficient devices are in the process of being identified, pulled from operations, properly asset tagged via laser engraving, and returned to operations as time and resources are available. The full review of CHSD Technology Device Inventory, noted in the first bullet of Section A above, will serve as a secondary compliance review opportunity to ensure the current efforts provided full compliance with the asset tag requirements. Additionally, with the purchase of the laser engraver, new Chromebooks/devices are required to have their asset ID and funding source etched as part of the device set up process which is completed prior to deployment. The corrective action timeline is as follows: A. Improved device inventory management – to include ESSER Funded Chromebooks – Noted corrective actions are scheduled to be in place and complete by September 1, 2024. B. Proper identification tags on Chromebooks - Noted corrective action regarding proper Asset Tag being applied to deficient devices is scheduled to be complete by June 30, 2024. District Leader Responsible for Corrective Action Plan: The Technology Administrator will be responsible for ensuring compliance with this corrective action and will provide the results of the noted routine internal inventory and audit events to the Superintendent for review and data warehousing. Respectfully submitted, Marc Forrest, Director of Finance

I believe we did enter all the details of the items. Part of entering items into the inventory system includes entering the description, serial number where available/applicable, source of funding (If purchased from Federal Funds those Funds were identified in the system, we also identified the FAIN when possible), acquisition date, cost, use and location. When items are disposed of, we enter the disposal date, any proceeds and reason in the system. We did attempt to enter all the items by scanning purchases periodically throughout the year, however, we must have missed a couple items. Although we apparently missed a couple, we made an honest attempt to pick up and enter all items. We plan to correct this by reviewing purchases each week as purchase orders are paid and compiling the assets continuously throughout the year, rather than at periodic times during the year. For the duplicated items entered, we had one person being trained on the process and both the trainer and trainee entered these four items into the inventory system. Going forward, we will only have one person entering items utilizing one list and individual fixed asset addition worksheets. This process will be a better way of double checking to ensure items are not duplicated in the inventory asset records.