Corrective Action Plans

Corrective Action: The University agrees with this finding. As a result of the prior year finding, the University made significant improvements to its equipment management process. The University reviewed all equipment pieces in every building on campus and compared the items against the Ptag information in the Universities Banner System. Any noted discrepancies were updated accordingly. Additionally, the University provided additional training to its staff accountants and temporary workers. Lastly, the University’s internal auditor re-reviewed the equipment that was inspected during the prior year audit and verified that the item was property tagged with a Ptag and that the item was accurately recorded in the University’s Banner IT system. During the current year audit, there were 41 Ptag samples selected for inspection, which consisted of over 800 individual equipment items. The 5 equipment items noted during inspection that were not tagged equate to an error rate that is less than 1%. The University will continue to enhance it procedures to ensure all equipment items are tagged, including the use of a more durable adhesive tag. Management will also perform a monthly audit of various equipment items throughout the year across a variety of departments. The University will also review a virtual inspection of its inventory.

Management concurs that the required physical inventory of equipment acquired under Federal award was not performed for 5 departments at least once every two years for R&D related equipment. Management will implement enhanced control procedures to ascertain the physical inventory of equipment is performed bi-annually.

Finding – Internal control deficiencies over tracking equipment Name of contact person: Lane Millar, Finance Director Corrective action: Employees tasked with equipment tracking will receive training prior to commencing such assignments. Proposed completion date: March 1, 2024

CORRECTIVE ACTION PLAN U.S. Department of Education Thatcher Unified School District No. 4 respectfully submits the following corrective action plan for the year ended June 30, 2023. Audit period: July 1, 2022 – June 30, 2023 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS— FEDERAL AWARDS FINDINGS AND QUESTIONED COSTS Finding Number: 2023-001 Repeat Finding: Yes Program Name/Assistance Listing Title: Education Stabilization Fund Assistance Listing Number: 84.425D and 84.425U Federal Agency: U.S. Department of Education Federal Award Number: 23SSPCON-311221-01A, 21FESSII-111221-01A, 21FESIII-111221-01A Questioned Costs: None Type of Finding: Noncompliance, Significant Deficiency Compliance Requirement: Equipment/Real Property Management Condition/Context: The District did not tag and track the capital assets purchased with Education Stabilization Fund monies. Action planned in response to finding: Management will establish procedures to ensure all assets are properly tagged and tracked to prevent theft, fraud, or misuse of District assets. Planned completion date for corrective action plan: For the period ending June 30, 2024. Name of the contact person responsible for corrective action: Clay Bowman, Director of Finance

St. Elizabeth’s has recently hired a property and maintenance manager who will, among other things, be responsible for identifying and tracking all assets. Finance will work with this new hire to develop procedures and implement the necessary steps to track physical inventory.

Finding No. 2023-012 Department(s): New York City Fire Department Program(s): Assistance Listing Number 97.056, Port Security Grant Program Corrective Action(s): The department has established a very comprehensive compliance and operating standards program to monitor the administration of grants and federal awards, and to ensure compliance with applicable state and federal statutes, regulations, requirements and guidelines. Based on the results of over two dozen audits conducted over several years by various external oversight agencies, the department believes that the appropriate controls are already in place and will reiterate as part of our grants and federal awards compliance training curriculum. Anticipated Completion Date: July 31, 2024 Person(s) Responsible for Implementation: Domenick Loccisano, Executive Director Domenick.Loccisano@fdny.nyc.gov

Finding No. 2023-011 Department(s): New York City Police Department Program(s): Assistance Listing Number 97.056, Port Security Grant Program Corrective Action(s): While the one (1) piece of equipment that was identified as “active equipment” was in fact disposed of prior to the most recent inventory count, the equipment was not listed as disposed of due to the user (project manager) not completing the final step of the entry. Corrective Action(s): NYPD Grants Unit will schedule one-on-one virtual training with all end users of GTS providing a step-by-step approach on inputting and updating assets in GTS. Upon completion of this training all project managers should be able to successfully complete transactions in GTS maintaining accurate and up to date inventory records from the first (new) entry to the final entry (disposal). These one-on-one sessions will be scheduled and coordinated based on the availability of both individuals (users and trainers) over the course of the next six months. In addition, the NYPD has requested a programming update (to the developer of GTS) which would allow the system to prevent the user from exiting the screen/entry without completing all required fields by providing a prompt feature. Anticipated Completion Date: September 2024 and ongoing Person(s) Responsible for Implementation: Anthony Danna, Deputy Director, NYPD Grants Unit Anthony.Danna@nypd.org (718) 610-8691

Finding No. 2023-009 Department(s): New York City Department of Investigation Program(s): Assistance Listing Number 16.922, Equitable Sharing Program Corrective Action(s): Based on the recommendations outlined in the audit report, we have developed the following corrective action plan to address the deficiencies and improve compliance with equipment and real property management requirements. • Strengthen Controls over the Inventory Process: We developed and implemented additional controls over the inventory process to ensure that equipment dispositions are updated in the equipment records, inventories performed are reconciled back to equipment records, and biennial inventory counts are consistently performed over all equipment within the required timeframe. • Training for Personnel: We provide training to all personnel involved in the equipment and real property management process, including property officers and program managers, to ensure they are aware of the new controls and standard operating procedure, and understand their roles and responsibilities related to compliance requirements. • Continuous Monitoring: We developed a continuous monitoring program to ensure that the new controls and procedures are being followed, and to identify any areas for improvement. • We developed Equitable Sharing Program Standard Operating Procedures (“SOPs”) for the New York City Department of Investigation (“DOI” or “Department”) apply to the Department’s use of U.S. Department of Justice (“DOJ”) Equitable Sharing Program (“Program”) funds. These SOPs are intended to complement, not replace, the required guidance found in the “Guide to Equitable Sharing for State, Local, and Tribal Law Enforcement Agencies” (July 2018) (“Guide”) and Equitable Sharing Wires (“Wires”), as well as any relevant Department and City policies and procedures. The agency is actively pursuing a centralized inventory management system to improve the effectiveness of inventory management. These corrective actions will help to ensure that federally funded equipment is accurately recorded on inventory records and that inventory is not misplaced, misappropriated, or otherwise disposed of outside of the requirements of federal guidelines. We appreciate the opportunity to address the audit findings, and we are committed to implementing these corrective actions. Anticipated Completion Date: March 31, 2025 Person(s) Responsible for Implementation: Caspar Barrow, Executive Director of Finance/CFO CBarrow@doi.nyc.gov (212)-825-0666 Orane Gordon, Internal Auditor OGordon@doi.nyc.gov (212)-825-0123

Condition and Context: While the School completed a physical observation of its assets, it did not reconcile its detailed fixed asset listing to the physical observation. Recommendation: The auditors recommend that in addition to conducting a physical inventory of the School's capital assets on at least a biennial basis, that the School update its accounting records based on the results of the physical inventory. Contact Name: Anastacia Europa Ruiz, Chief Operating Officer Corrective Action Planned: Moving forward, the management team will change from a bi-annual to an annual fixed-asset inventory as a part of our annual strategic and budget planning which is reviewed quarterly. Additionally, we are recommending a quarterly board update to provide the status on addressing the FY23 audit findings. Anticipated Completion Date: June 30, 2024

Name of Contact Person: David Swarner Finance Director 907-283-8227 Finding 2023-001 – Equipment and Real Property Management - Significant Deficiency in Internal Controls over Compliance Corrective Action Plan Complete an annual reconciliation of disposals against sales of assets. The reconciliation is to be completed by the Controller and reviewed by the Finance Director. Conduct a biannual asset inventory and review of asset inventory procedures. The corrective action plan is expected to be implemented in FY2024 and incorporated in the year end checklist. Expected Completion Date: Already implemented.

Condition: The District did not maintain adequate property records to comply with 2 CFR section 200.313(d)(1). Plan: The District engaged a third party fixed asset vendor to ensure annual updating of property records, including the tagging and marking of items of Federal origin. Date of Completion: January 1, 2024 Name of Contact Person: Dennis Forst, Assistant Superintendent of Business & Operations Management Response: Management concurs with the finding and has developed applicable procedures.

Dear Mr. Waguespack, In conjunction with the Single Audit for FY 2023, we concur with the finding addressed in the letter dated January 26, 2024, concerning an unlocated asset on an oil rig in the Gulf of Mexico. Property Management has already begun addressing the finding by reviewing current written procedures and training material. As requested in the letter, the following responses are given regarding the finding. Finding: Noncompliance with Federal Equipment Management Regulations at LSU A&M Compliance Efforts and Response to Finding: As noted in the finding, one asset (LSU# 723337) could not be located during testing. This equipment is a GPS transmitter/receiver and part of a network of Continuously Operating Reference Stations (CORS) in Louisiana for the LSU Center for Geolnformatics, in the College of Engineering. It was deployed on an oil platform (EI337A) in the Eugene Island region of the Gulf of Mexico. Multiple factors contributed to the loss of this equipment, including: • The isolation of the oil platform. Access is by chartered flight, and security clearance is required. Thus, LSU must rely upon employees of the operating company for completion of any on-site tasks. • When operational, this equipment can be observed online in real time, and identified by serial number which corresponds to our asset records. This is sufficient for our annual inventory verification process. If the equipment is offline for any reason, then a representative of the operating company would be needed to provide in-person verification for inventory purposes. • In 2020, the device began exhibiting intermittent connectivity issues. Plans to send a new antenna cable to be installed were interrupted by a pandemic-related shutdown of EI337A, the eventual bankruptcy of the platform operator, Fieldwood Energy, and turnover among Fieldwood staff related to same. • Extensive efforts were made to identify and contact the current operator of El337A, including traveling to the Broussard and Lafayette areas and cold calling several oil platform operators. Once successful, a representative of Arena Offshore advised that someone recalled the equipment having been removed and sent to an onshore storage warehouse. LSU has been unsuccessful thus far in learning its location and recovering the equipment. • As LSU continued to pursue retrieval of the equipment, the department incorrectly reported the asset as located for annual inventory purposes under the belief that (due to its isolated/remote installation) the equipment remained in its last known location. LSU# 723337 has been reported as unlocated on our most recent inventory certification on December 12, 2023. Efforts continue to locate the asset and, if found, it will be reactivated and placed back in service, or properly disposed. Inventory procedures are being re-written to provide greater clarity of the standards for reporting an asset located, including how to handle when there are extenuating circumstances. Campus departments will receive training on the revised standards. Anticipated Completion Date: June 30, 2024. Persons Responsible: Toliver Bozeman, Director Property Management Jason Whitfield, Associate Director of Property Management

FINDING 2023-004 Finding Subject: COVID‐19 Education Stabilization Fund – Equipment and Real Property Management Summary of Finding: Assets missing from Fixed Asset Inventory Contact Person Responsible for Corrective Action: Carrie Alford Contact Phone Number and Email Address: (812)254-5536 calford@wcs.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Washington Community Schools hired a fixed asset company to give a good “starting point” since the Fixed Asset listing hadn’t been properly maintained over the years. WCS officials didn’t know that they missed labeling and recording several recently purchased assets. Expenditure reports will be ran to determine what was missed and those assets will be added to the inventory listing. Anticipated Completion Date: 06/30/2024

FINDING 2023-007 Finding Subject: Special Education Cluster - Equipment and Real Property Management Summary of Finding: The School Corporation had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance. A property record or capital asset listing which would include a description of the property, a serial number or other identification number, the source of funding for the property (including the federal award identification number (FAIN)), 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, and use and condition of the property is to be maintained for assets purchased that exceed the School Corporation's capitalization threshold. The School Corporation purchased on piece of equipment in the amount of $75,387 with Special Education Funds. The listing did not include all the required elements for the one piece of equipment purchased. The required elements are the description of the property, a serial number or other identification number, the source of funding for the property (including the FAIN), who holds title, the acquisition date, and 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, and any ultimate disposition data including the date of disposal and sale price of the property. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Contact Person Responsible for Corrective Action: Amy K. Sivley Contact Phone Number and Email Address: 260-563-2151; sivleya@apaches.k12.in.us Views of Responsible Officials: We concur with the finding. Explanation and Reasons for Disagreement: n/a Description of Corrective Action Plan: Develop processes and procedures to ensure that purchases made with federal dollars are correctly recorded on capital asset ledger. Anticipated Completion Date: To begin immediately, March 2024

The HPU Business Office will initiate and ensure the completion and reconciliation of the physical inventory of all fixed assets which were acquired using federal funds at least every two years, to include the tagging of items in accordance with the university’s inventory and fixed-asset related policy. Person Responsible: Controller and Associate Vice President; Principal Investigator; Deans, Directors, and Department Heads; Fixed Asset Accountant; General Ledger Manager, with the assistance and support of the Assistant Vice President of the Office of Sponsored Projects and the Manager of the Office of Sponsored Projects. Targeted correction date: June 30, 2024.

Finding 2023‐004 Personnel Responsible for Corrective Action: Charles Ellis, SLPS Fiscal Control Director Anticipated Completion Date: August 30, 2024 Corrective Action Plan: The finance department will engage an asset services firm to perform a physical inventory of the District’s capital assets for fiscal year 2024.

Finding 2023-004 – Education Stabilization Fund – Equipment Contact Person Responsible for Corrective Action: Nathaniel Day Contact Phone Number: 317-462-4434 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We will engage a third-party vendor to complete a Capital Asset Inventory every fiscal year. Anticipated Completion Date: 6-30-2024

DEA Asset Forfeitures – Assistance Listing No. 16.922 Recommendation: Procedures should be updated to ensure all assets purchased with federal funds go through a physical inventory count every 2 years. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Waltham Police Department Policy Chapter 17 – Fiscal Management – has been updated/amended adding a stand-alone paragraph mandating a physical annual audit of any assets purchased with federal funding. Name(s) of the contact person(s) responsible for corrective action: Deputy Police Chief Steven R. Champeon Planned completion date for corrective action plan: On or about April 5, 2024, the policy should be finalized and distributed department wide.

CORRECTIVE ACTION PLAN: For the findings and questioned costs relating to federal awards of fiscal year ended June 30, 2023, Finding No. 2023-001 - Equipment and Real Property Management: Criteria: 2 CFR section 200.313(d), Equipment Management Requirements, states that: Procedures for managing equipment (including replacement equipment), whether acquired in whole or in part under a Federal award, until disposition takes place will, as a minimum, meet the following requirements: (1) Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the FAIN), who holds title, the acquisition date, and 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, and any ultimate disposition data including the date of disposal and sale price of the property. (2) A physical inventory of the property must be taken, and the results reconciled with the property records at least once every two years. (3) 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. (4) Adequate maintenance procedures must be developed to keep the property in good condition. (5) If the non-Federal entity is authorized or required to sell the property, proper sales procedures must be established to ensure the highest possible return. Condition: The last physical inventory of the property was taken on July 13, 2021, with the property subsidiary as of August 2020. A physical inventory should have been performed on or before July 13, 2023. Cause: The Inventory would be done during fiscal 2022-2023, but the employee in-charge of fixed assets got a chronic condition diagnostic. After the diagnostic the employee is underperforming. The beginning of the inventory was postponed as stated in the corrective action section of this document. Effect: Conducting physical inventory ensures compliance with regulations and helps maintain accountability for the use of federal expenditures, prevents fraud and abuse, and helps identify surplus or underutilized equipment, leading to more efficient allocation of resources. In addition, the condition above resulted in assets that could not be found in the facilities due to disposal after the date of the inventory observation, items relocated to other areas and items purchased after the date of the last inventory observation. Questioned Cost: None. Corrective action: The Foundation duly complies with four of five requirements of 2 CFR section 200.313(d). Management is committed to fully complying with the regulations. A plan is being developed to begin a physical inventory by the end of the fiscal year ending Juen 30, 2024. Finance staff will perform the inventory, along with the staff of the Foundation departments. The inventory plan will include the following: • Establish time schedules. • Identify responsible parties. • Detail description of entire inventory process. • Send to research laboratories, clinical research, clinical laboratory and administrative offices, the subsidiary list of the inventory as per the subsidiary, along with instructions. • Establish a deadline to departments send to finance the certified list of inventories. • Upon receipt of department inventories the finance staff will schedule a visit to each department, to confirm the inventory certification received. • Reconcile the inventory with general ledger and make the necessary adjustments in general ledger and the subsidiary. • Prepare an inventory report, for record, and for audit purposes. The report’s total dollar amount will be reconciled with the general ledger, including all equipment certified in the inventory. Submitted on March 15, 2024, by: Alejandro Ramírez Chief Financial Officer

Finding 2023-009 Finding Subject: COVID-19 - Education Stabilization Fund - Equipment and Real Property Management Summary of Finding: The School Corporation made one purchase of equipment with grant funds, a school bus in the amount of $204,961. The school bus was acquired in June 2021, late in the prior audit period, and the expenditure was reimbursed under the ESSER II award in July 2021 in the current audit period. The lack of internal controls resulted in material noncompliance with the equipment requirements of the federal award. The School Corporation did not maintain a capital asset ledger during the audit period, so the equipment purchased was not maintained in the property records as required. Additionally, the School Corporation did not perform a physical inventory of equipment at least once every two years as required. The School Corporation did comply with the requirements to appropriately safeguard and maintain the equipment, but no key control was identified that would prevent, or detect and correct, noncompliance with these requirements if it were to occur. Contact Person Responsible for Corrective Action: Terry Richey and Chrystal Street Contact Phone Number and Email Address: 812.793.2061 trichey@crothersville.k12.in.us cstreet@crothersville.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The corporation treasurer and the superintendent will investigate a capital asset program that we will be able to maintain ourselves. This might include reaching out to districts similar in size to see what they utilize or to work with an agency that can get us started. Anticipated Completion Date: April 1, 2024

Department: Education Title: Internal control over ESF subrecipient monitoring procedures needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: During the review of ESF applications, the Office of Federal Emergency Relief Programs (OFERP) team will confirm that equipment purchases are denoted in the equipment budget category of the application. Equipment inventories and real property lists will be collected during the subrecipient monitoring process from school administrative units (SAUs) and reviewed for compliance by the OFERP team. Completion Date: Ongoing and July 1, 2024 respectively Agency Contact: Shelly Chasse-Johndro, Director of OFERP, DOE, 207-458-3180

Significant Deficiency 2023-001. Equipment and Real Property Management Education Stabilization Fund (ESF) COVID-19: Elementary and Secondary Emergency Relief Fund ALN: 84.425D COVID-19: American Rescue Plan – Elementary and Secondary School Emergency Relief ALN: 84.425U COVID-19: American Rescue Plan – Elementary and Secondary School Emergency Relief – Homeless Children and Youth ALN: 84.425W Condition: The District did not include equipment purchased with Federal awards with its current year additions in the District’s capital assets inventory records. Planned Corrective Action: The District will adopt procedures to ensure that equipment purchased with Federal funds is included and differentiated in the District’s capital assets inventory records. Responsible Contact Person: Dr. Rubie R. Harris, Assistant Superintendent for Finance & Management Services Huntington Union Free School District 50 Tower Street Huntington Station, New York 11746 Anticipated Completion Date: June 30, 2024.

FINDING 2023-007 Finding Subject: Education Stabilization Fund - Equipment and Real Property Management Summary of Finding: Finding: Education Stabilization Funds may be used to purchase equipment. Capital expenditures for general and special purpose equipment purchases are subject to prior by ED or the pass-through entity. In addition, with prior approval by the ED or the passthrough entity, recipients and subrecipents may use ESF funds to purchase real property and perform construction or minor remodeling, and for improvements to land, buildings, or equipment that meet the overall purpose of the ESF program, which is "to prevent, prepare for, and respond to" the COVID-19 pandemic. The School Corporation had not established policies or procedures to ensure compliance with requirements related to the grant agreement and the Equipment and Real Property Management compliance requirements. The School Corporation purchased two servers and completed a HVAC project using ESF funds however those items were not included on property records that included all the required information (including a description, source of funding, percentage of federal participation, location, and use and condition of the property). In addition, a physical inventory was not completed after the equipment was purchased. Recommendation: We recommended that management of the School Corporation design and implement a proper system of internal control, including policies and procedures that would provide segregation of duties to ensure property records are maintained for equipment and real property purchased with federal funds and a physical inventory to be completed at least every two years. Contact Person Responsible for Corrective Action: Dr. Tim Garland Contact Phone Number and Email Address: 574-626-2525 / garlandt@lewiscass.net Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Lewis Cass does have an asset management documentation but it has not been updated since October 2020. Lewis Cass has been actively pursuing an asset management vendor to perform a thorough review and update our current property. The items listed on this finding have been add to the property records. Lewis Cass has the task of finding a new asset management firm and update property records. This task will be completed by fiscal year 2025. Anticipated Completion Date: 6/30/2024

Finding # 2023-023 Title of Finding Equipment and Real Property Management Contact Person Sarah Wills and Christine Miller Anticipated Completion Date FY 2024 Corrective Action planned to be taken: The Board will establish procedures that will ensure compliance with requirements of the United States Department of Education's equipment management requirements and the requirements applicable to the ESSER program.

Description of Corrective Action Plan: The Superintendent, Corporation Treasurer, Director of Grants and the Director of Facilities and / or Director of Technology will monitor equipment purchases larger than $5,000. Once the purchase is made, the Director of Facilities and / or Director of Technology will tag the equipment and notify the Director of Grants, Treasurer and Superintendent when the fixed asset inventory is completed and updated. Responsible Party and Timeline for Completion: Treasurer, Jill Wagoner, Director of Grants, Eric Knebel, Director of Technology Brandon Shafter, Director of Facilities Zac Moore, Superintendent, Dr. Angela Piazza. The corrective action will be implemented starting immediately.