Corrective Action Plans

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.

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.