Corrective Action Plans

Audit Finding Reference: 2022-002 Improve Controls Over Equipment Planned Corrective Action: An electronic inventory system is in place for all electronics. The product used is SNIPE IT. All electronics are asset tagged and updated by technicians in each school building. A field has been added to the inventory system database to record funding source of asset. On a biennial basis the inventory database will be queried to provide a list of all assets by funding source and location. Grant administrators will identify staff to physically inventory each of the assets purchased through grant funds with support from district and school-based IT staff. Non-electronic equipment will be inventoried by individual grant administrators. Name of Contact Person and Completion Date: Kyle White, System Administrator and Operations Leader, kyle.white@leominsterschools.org, 978-534-7700 x l336 Anticipated date of completion -6/30/23

Finding 2022-003 – Head Start Cluster – Equipment Contact Person Responsible for Corrective Action: Brenda Overton Contact Phone Number: 574.393.5866 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We will add the equipment to our capital asset listing and ensure inventories are performed at least every two years. Anticipated Completion Date: April 2024

Significant Deficiency in Internal Control Over Compliance and Noncompliance – F. Equipment and Real Property Management Recommendation: The Auditor recommends FSA implement procedures to ensure equipment and real property purchased with federal funding is appropriately capitalized and tracked. Planned Corrective Actions: Family Service Association of Howard County Inc. (FSA) will implement procedures to ensure equipment and real property purchased with federal funding is appropriately capitalized and tracked beginning April 2024.

FINDING 2023-003 (Auditor Assigned Reference Number) Finding Subject: Education Stabilization Fund - Equipment and Real Property Management Summary of Finding: An effective internal control system was not designed, nor implemented at the School Corporation to ensure compliance with requirements related to the grant agreement and the Equipment and Real Property Management compliance requirement. The School Corporation paid for various items of equipment with Education Stabilization Funds. Although these assets were added to a detailed listing of capital assets, this list did not include a serial number or other identification number, the 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, the location, and the use and condition of the property. The lack of internal controls and noncompliance were systemic issued throughout the audit period. We recommended that the School Corporation's management establish internal controls to ensure compliance and comply with the grant agreement and the Equipment and Real Property Management compliance requirement. Contact Person Responsible for Corrective Action: Stefanie Grandstaff, Director of Business Services Contact Phone Number and Email Address: (574)-946-4010 ext. 230, stefanie.grandstaff@epulaski.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: The Director of Business Services is going to get in contact with CBiz, who was on site helping us create an asset list to see if they can help the school add a column to distinguish which capital assets were purchased with federal dollars. The Director of Business Services has scheduled an annual walk around for March with the Director of Operations to find serial or identification numbers to add to the capital assets list. Anticipated Completion Date: June 30, 2024

FA2022-001: Improve Controls over Equipment Compliance Requirement: Equipment and Real Property Management Internal Control Impact: Significant Deficiency Compliance Requirement: Nonmaterial Noncompliance Federal Award 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: 225GA324N1199 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 Federal Award Number: S425D200012 (Year: 2020), S425D210012 (Year: 2021), S425U120012 (Year: 2021), S425W210011 (Year: 2021) Questioned Costs: None Identified Repeat of Prior Year Findings: FA2021-001, FA2020-001, FA2019-003, FA2018-002, FA2017-004 Description: The policies and procedures for 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 Plan: We concur with this finding. Management has strengthened controls over equipment to ensure that the records are complete, accurate and reflect all required information. We are currently 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 the 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 date for each piece of equipment. A complete physical inventory will be performed each year and reconciled with the equipment listing. Estimated Completion Date: June 30, 2024 Contact Person: Christopher Stephens Telephone: 229-268-4761 Email: Christopher.stephens@dooly.k12.ga.us

FA 2022-001 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 Education Pass-Through Entity: Georgia Department of Education AL Numbers and Titles: `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 Federal Award Numbers: .S425D200012 (Year: 2021), S425U2100012 (Year: 2021) Questioned Costs: None Identified 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 Education Stabilization Cluster. Corrective Action Plans: The Executive Director of Operations will develop, and share with the Federal Programs Director, 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 Executive Director of Operations will further coordinate with the Federal Programs Director to ensure that all equipment is accounted for by conducting a complete physical inventory at least once every two years beginning in the Fall of 2024. Estimated Completion Date: December 30, 2024 Contact Person: Angela Williams, Superintendent Telephone: 706-554-5101 Email: amwilliams@burke.k12.ga.us

Finding No. 2022-011 Area: Equipment and Real Property Management Views of Auditee and Planned Corrective Action Condition. For 5 (or 100%) transactions, no evidence of custodian signature at inception of the fixed asset was provided. However, printed copies of the property master information record from the JD Edwards system were signed and dated by the custodian and a verifier as evidence of the most recent physical inspection in September 2022. We agree. This is an asset accountability procedure that the Public School System is currently improving– as part of an encompassing improvement work on its standard operating procedures. Anticipated Completion Date: September 30, 2024 Name of Contact Person and Title Contact Person – Arlene Lizama, Director of Finance Contact – arlene.lizama@cnmipss.org

Finding No. 2022-010 Area: Equipment and Real Property Management Views of Auditee and Planned Corrective Action Condition 1. As of September 30, 2022, the total amount of equipment acquired under ALN 84.425X per equipment schedule or subsidiary ledger was lower by $18,147 as compared to the total amount of equipment expenditures identified in the general ledger journal entry details supporting the SEFA. We agree. The Public School System is already in the process of improving its standard operating procedures (SOPs) and asset management system pertaining to and relating with equipment and real property management. Condition 2. For 10 (or 100%) transactions, no evidence of custodian signature at inception of the fixed asset was not provided. We agree. The Public School System is already in the process of improving its standard operating procedures (SOPs) and asset management system pertaining to and relating with equipment and real property management. Anticipated Completion Date: September 30, 2024 Name of Contact Person and Title Contact Person – Arlene Lizama, Director of Finance Contact – arlene.lizama@cnmipss.org

Finding No. 2022-009 Area: Equipment and Real Property Management Views of Auditee and Planned Corrective Action Condition 1. For 5 (or 100%) transactions, no evidence of custodian signature at inception of the fixed asset was not provided. However, printed copies of the property master information record from the JD Edwards system were signed and dated by the custodian and a verifier as evidence of the most recent physical inspection in September 2022. We partially agree. This is because the Public School System is in the process of improving its standard operating procedures (SOPs) pertaining to and relating with equipment and real property management. Condition 2. 2 (a) The custodian’s name was not indicated on the property master information record from the JDE system. Evidence that custodian records were matched and updated after physical inspection was not obtained. We agree. The Public School System is already in the process of improving its standard operating procedures (SOPs) pertaining to and relating with equipment and real property management. 2 (b) The property master information record states that the asset is in working condition, however evidence obtained of a survey performed has concluded that the asset is no longer useful for PSS operations and is recommended for destruction or scrapping. The same evidence showed that the destruction/scrapping occurred in September 15, 2022. We agree. This is because the Public School System is in the process of improving its standard operating procedures (SOPs) pertaining to and relating with equipment and real property management. Anticipated Completion Date: September 30, 2024 Name of Contact Person and Title Contact Person – Arlene Lizama, Director of Finance Contact – arlene.lizama@cnmipss.org

Finding No. 2022-008 Area: Equipment and Real Property Management Views of Auditee and Planned Corrective Action Condition 1. For 5 (or 100%) transactions, no evidence of custodian signature at inception of the fixed asset was not provided. We partially agree. This is because the Public School System is in the process of improving its standard operating procedures (SOPs) pertaining to and relating with equipment and real property management. Condition 2. For 2 (or 40%) transactions identified as PS-012478-US and PS-047509-US, with a total cost of $12,636, the custodian’s name and the condition of the equipment was not indicated on the property master information record. We partially agree. This is because the Public School System is in the process of improving its standard operating procedures (SOPs) pertaining to and relating with equipment and real property management. Anticipated Completion Date: September 30, 2024 Name of Contact Person and Title Contact Person – Arlene Lizama, Director of Finance Contact – arlene.lizama@cnmipss.org

The finding was corrected for future efforts related to the area of the property. A private company was hired to conduct the inventory. Appropriate seizures of disused equipment were carried out and an annual inventory of all existing equipment is being carried out, with ownership number, location and required information.

(A) Management agrees with the recommendation. Procedures have been initiated with cross campus partners and will be fully implemented by March 2023. The proposed corrective action plan is as follows: - Escalation procedures will be implemented in collaboration with campus partners so that action items identified in inventory reviews are addressed timely. - The Campus Controller?s Office will work with campus partners to increase physical monitoring procedures to ensure tags are affixed and maintained on equipment. (B) Management agrees with the recommendation. Procedures have been initiated with cross campus partners and will be fully implemented by March 2023. The proposed corrective action plan is as follows: - Escalation procedures will be implemented in collaboration with campus partners so that action items identified in inventory reviews are addressed timely. - The Campus Controller?s Office will work with campus partners to increase physical monitoring procedures to ensure tags are affixed and maintained on equipment.

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

12-013-2050-26 CORRECTIVE ACTION PLAN FOR CURRENT YEAR AUDIT FINDINGS Year Ending June 30, 2022 Corrective Action Plan Finding No.: 2022-_ 002__ Condition: The District's property records did not include serial numbers for 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 meets the requirements of 2 CFR section 200.313(d)(1). Anticipated Date of Completion: 06/30/2023 Name of Contact Person: Travis Wyatt Management Response: Management will implement the corrective action plan for the year ended June 30, 2023.

The District will update the fixed asset policy to include required information purchased with Federal awarded monies. The District will communicate the new policy to all staff to ensure fixed assets will be recorded in the correct manner.

Finding: 2022-002 Federal Agency Name: Department of Health and Human Services Program Name: National Bioterrorism Hospital Preparedness Program Federal Financial Assistance Listing #93.889 Compliance Requirement: Equipment and Real Property Management Finding Summary: No independent secondary level of review or approval is performed relating to compliance. One employee is involved in preparing, reviewing and approving information. Additionally, property records lack descriptive elements as required by 2CFR 200.313(d)(1), including source of funding, acquisition date and cost. Lastly, a physical inventory of equipment has not been performed within the last two years. Responsible Individuals: Greg Santa Maria, Executive Director Corrective Action Plan: The SDHCC Executive has updated the SDHCC fixed asset listing to include recommended components listed in the findings above. This includes an updated physical inventory of all listed equipment. Anticipated Completion Date: March 16, 2023

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE ? PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION ? COVID-19 ?EDUCATION STABILIZATION FUND (FEDERAL ALN 84.425) 2022-002 Internal Controls Over Compliance With Equipment and Real Property Finding Summary 2 CFR ? 200.313(d)(1) requires the Academy to designate fixed assets purchased under federal programs and to maintain related property records, including a description of the property, a serial number or other unique identification number, the source of funding for the property (including the federal Assistance Listing Number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use, and condition of the property, and any ultimate disposition data, including the date of disposal and sale price of the property. During our audit, we noted that the Academy did not have sufficient controls in place within the COVID-19 ? Education Stabilization Fund federal program to specifically identify federally-funded fixed assets and maintain the required records as noted above to assure compliance with federal equipment and real property management requirements. Corrective Action Plan Actions Planned ? The Academy plans to review its internal control procedures to ensure future compliance with the federal compliance requirements specific to equipment and real property management for the COVID-19 ? Education Stabilization Fund federal program. Official Responsible ? The Academy?s Executive Director, Farhiya Einte. Planned Completion Date ? June 30, 2023. Disagreement With or Explanation of Finding ? The Academy agrees with this finding. Plan to Monitor ? The Academy?s Executive Director, Farhiya Einte, will ensure that federally-funded fixed assets are distinguishable within the Academy?s finance system. The Academy also intends to review its control procedures relating to equipment and real property management requirements to ensure compliance for future federal awards expenditures.

2022-002 Equipment and Real Property Maintenance ? Education Stabilization Fund CFDA No. 84.425 Contact Person: Colette Vickers, Business Manager Recommendation: The District has developed a specific set of procedures to ensure the proper inventorying and safeguarding of real property and equipment. We recommend the District adhere to these procedures, and have written policies in place to ensure this is not overlooked in the event of changes in personnel. Action: The District will review the equipment and real property maintenance procedure with appropriate personnel. These employees will be required to review the policy at a minimum once a year and acknowledge through signature that they have been made aware of the procedure. These signature records will be maintained with their annual training records. Inventory updates and lists will be reviewed at least quarterly by administration to ensure compliance. Date for Completion: June 30, 2023

FINDING 2022-015 Contact Person Responsible for Corrective Action: Casey Brewster Contact Phone Number: 812-752-8935 Views of Responsible Official: We concur with the finding INDIANA STATE BOARD OF ACCOUNTS 70 Description of Corrective Action Plan: The Capital Asset Ledger updated in June 2022 is being updated and will remain up-to-date with categorization of assets to identify those assets purchased in part or in whole by federal funds. The updated capital asset ledger shall include a description, serial/id number, source of funds (federal award #) and percentage of total, cost, date, location, etc. In June of each year, this update will be completed and documented by the Treasurer and CFO. Anticipated Completion Date: June 2023.

FINDING 2022-003 Contact Person Responsible for Corrective Action: Joanna Trueblood Contact Phone Number: 812-967-3926 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Corporation Treasurer will update the list of property assets, which will include a description of the property, a serial number or other identification number, the source of funding for the property (including the federal identification number), who holds the 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 that is to be maintained for assets purchased that exceed the School Corporation?s capitalization threshold. A physical inventory of the School Corporation?s capital assets will be updated. Anticipated Completion Date: July 2023

Views of responsible officials and planned corrective actions: Management agrees with this finding and will put procedures in place to maintain adequate property records.

Finding No.: 2022-_ 004__ Condition: The District's property records did not include serial numbers for 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 meets the requirements of 2 CFR section 200.313(d)(1). Anticipated Date of Completion: 06/30/2023 Name of Contact Person: Shannon Cheek Management Response: Management will implement the corrective action plan for the year ended June 30, 2023.

The District is in agreement that certain assets were not added to the fixed asset records in a timely manner. These assets were placed into service at the end of the 2021-22 school year but were not included in the District?s fixed asset inventory system until July 2, 2023. Beginning with February 2023 month-end the account clerk will continue with the procedure of reviewing all asset purchases made for the month, however, now the Treasurer, who handles all grants, will now review the monthly listing to ensure all grant purchases are properly included in the correct month and fiscal year. The Assistant Superintendent for Business will be the second level reviewer each month to ensure the asset addition listing each month is complete and accurate.

FINDING 2022-0004 Contact Person Responsible for Corrective Action: Chris Richie Contact Phone Number: 219-987-4711 ext. 1113 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: In the future, the treasurer will maintain a list of capital assets that includes serial number or other identification number, the 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, the location, and the use and condition of the property. The list will be verified by a central office employee each December and June. Individuals will initial and date a hard copy of final the report. Anticipated Completion Date: June 30, 2023

Management response: Management agrees with the finding. We identified previously and working on a project to reconcile property and equipment schedule with physical inventory previously to record the data in the accounting system. Due to employee turnover in the finance department the project has been delayed. During the second quarter of this year the Organization engaged a third party company to perform an inventory count for property and equipment in all locations, excluding Head Start locations. Physical counts in these location will be performed during the 4th quarter of fiscal year 2023. During this process items numbers, serial numbers and other important information was updated. Management expects to have these assets reconciled by the fiscal year ended June 30, 2022. Corrective action plan: 1. Management will review the equipment inventory and subsidiary and reconcile them. 2. Management will proceed to use the tool provided by London Consulting to track equipment inventory. 3. Management will established a physical count every two years. Contact person: Manuel Joglar Team: Purchasing Officer, Operations Manager, Accounting Manager Anticipated completion date: Not later than June 30, 2023