Corrective Action Plans

Finding 2022-001 Equipment and Real Property Contact: Crystal Simmons, Senior Fixed Assets and Taxation Manager Telephone number: 240-694-2168 Estimated Completion Date ? September, 2023 HJF will implement the following increased measures in FY 2023: 1) Property control staff will continue the increased use of inventories by exception. This will include reviewing maintenance records for laboratory equipment from both vendors and military installations performing these tasks on HJF?s behalf. Maintenance performances are considered physical touches and may be used for inventory counting purposes. 2) Property control staff will continue to prioritize inventories by dollar amount with a secondary emphasis on units. 3) Program managers and or supervisors will be added to the distribution of the monthly inventory deficiency reports currently received by property custodians and will be responsible for reviewing any deficiencies. 4) Finance will enhance alignment of transaction coding and screening associated with equipment recording to ensure that all acquisitions are captured at the time of initial entry and provide associated training to fixed assets, procurement and accounting staff.

FINDING 2022-003 Contact Person Responsible for Corrective Action: Kyle Zahn Contact Phone Number: 765-883-5576 ext. 5112 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Director of Finance will conduct an internal audit of capital assets purchased and sold from 6/30/2022 to the current date in order to update the corporation?s capital assets records. New staff will also be trained on tracking capital assets transactions and completing the necessary documentation for future capital assets transactions. It is noted, a number of construction projects are scheduled in the near future which will result in capital assets being added. As such, after the completion of these projects, leadership will consider having the school?s contracted third-party capital assets consultant conduct an onsite inquiry visit to ensure the school?s records are accurate. Anticipated Completion Date: April 2023

Finding No.: 2022- 006 Condition: The District does not currently maintain a detailed accounting of its capital assets, including Federal assets. The District does not have a recent replacement cost valuation for insurance purposes. Plan: Management is in the process of determining the most efficient way to handle these processes and is evaluating the cost-benefit of implementing various processes and procedures. Anticipated Date of Completion: June 30, 2022 Name of Contact Person: Dennis Forst, CSBO

FA 2022-003 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 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 Federal Award Number: S425D200012 (Year: 2020), S425D210012 (Year: 2021) S425U2120012 (Year: 2021) Questioner 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 Elementary and Secondary School Emergency Relief Fund program. Corrective Action Plans: We concur with this finding. The District is developing corrective actions to strengthen internal controls, policies, and procedures and ensure adherence through improved monitoring. Estimated Completion Date: Fiscal Year 2024 Contact Person: Dr. Myisha Warren, Executive Director of Federal Programs Telephone: 678-676-1200 Email: Myisha_Warren@dekalbschoolsga.org

District Response: A. What corrective action will be taken: District will review and follow policies and procedures outlining safeguarding equipment purchased with federal grant dollars. B. Who is responsible (name and position): Nathan Wells, Technology and Fixed Assets Clerk C. When will the plan be implemented? Corrective action started May 5, 2023, and will continue.

Finding Number: 2022-003 Planned Corrective Action: The Treasurer will add new capital assets to Inventory promptly. Anticipated Completion Date: 06/30/2023 Responsible Contact Person: Teresa McGinnis

RESPONSE: Dr. Ryan Bergeson will execute the following plan by February 3, 2023 . ? Staff and Program Directors will be provided the Board Administrative Procedure DID-AP (1): Inventory Management and be required to follow the procedure as stated. ? All future federal equipment and supplies will be tagged with an identification number immediately after it is acquired by the Federal Program Director, Special Education Director, Administrator or Staff member receiving the grant so that it can be easily tracked. ? Along with the end of the year required inventory list from each teacher/director, they will need to provide a separate list of all current inventory purchased with federal funds. Documentation will include: 1. A description of the equipment. 2. The serial or other identification number. 3. The funding source, including the federal award identification number when applicable. 4. The name and the title holder, when applicable. 5. The acquisition date. 6. The original cost of the equipment. 7. The location, use and condition of the equipment.

FINDING 2022-004 Contact Person Responsible for Corrective Action: Jami Parks Joe Smith and Stacey Teipen Contact Phone Number: 812-794-8750 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: In the summer of 2023 the corporation will do a physical inventory and add or delete any physical items that need added to the asset inventory listing. Anticipated Completion Date: August 1, 2023

Finding Number: 2022-002 Planned Corrective Action: The HVAC capital assets will be documented in the capital asset records. Anticipated Completion Date: September 30, 2023 Responsible Contact Person: Stacy Bolden, Treasurer

FINDING 2022-003 Contact Person Responsible for Corrective Action: Shawn Spindler, Business Manager/Treasurer Contact Phone Number: 812.926.2090 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We will ensure that any future capital equipment gets included on our inventory list. This will be reviewed by the Superintendent to be sure all equipment is added. Anticipated Completion Date: March 2023

FINDING 2022-001 Contact Person Responsible for Corrective Action: Dr. Michael Galvin, Superintendent Contact Phone Number: 812-874-2243 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Metropolitan School District of North Posey County has been seeking companies to complete asset management. We had a Google Meet with AdTec Incorporated on February 7, 2023 to understand the process and receive a bid for completing the project. We plan to take this proposal during the March 13, 2023 School Board meeting. Ad Tec would be able to begin the asset mapping during the summer of 2023 for completion in August 2023. Anticipated Completion Date: According to AdTec, they will visit the District schools during the summer of 2023 to complete the asset log, and then provide a report in August 2023.

2022-019 Oregon Housing and Community Services Controls are needed to ensure subrecipients? compliance with equipment and real property requirements Federal Awarding Agency: U.S. Department of Housing and Urban Development Assistance Listing Number and Name: 14.231 Emergency Solutions Grants Program (COVID-19) Federal Award Numbers and Years: E-20-DW-41-0001, 2020 (COVID-19) Compliance Requirement: Equipment and Real Property Management Type of Finding: Material Weakness; Material Noncompliance Prior Year Finding: N/A Questioned Costs: N/A Criteria: 2 CFR 200.311; 2 CFR 200.313 There are specific requirements when equipment is purchased using federal funds and in use. At a minimum, procedures for managing equipment must meet the following requirements: Property records must be maintained that include key details (e.g. property description, ID number, Title, etc);? A physical inventory of the property must be taken, and the results reconciled with the property records at least once every two years;? 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; and? Adequate maintenance procedures must be developed to keep the property in good condition.? Real property purchased must be used for the originally authorized purpose as long as needed for that purpose. When real property is no longer needed for the originally authorized purpose, the non-federal entity must obtain disposition instructions from either the federal awarding agency or pass through entity. During our review, we determined OHCS was not monitoring its subrecipients to ensure the equipment and real property requirements were being met. Because subrecipients were not being monitored, we were unable to determine if there was a population of equipment and real property on which to perform our audit testing procedure. As a result, the department may not be in compliance with federal equipment and real property requirements. We recommend department management develop internal controls to ensure compliance with federal requirements for equipment and real property. MANAGEMENT RESPONSE: We agree with this recommendation. OHCS has instituted a procedure for State FY23 which is on track to be completed for all ESG recipients; this procedure currently includes a notification and approval process for the tracking of the acquisition, rehabilitation, renovation, or conversion of property and separately a vehicle purchase and equipment purchase. We are in the process of refining a control system to ensure adequate safeguards are in place to prevent loss, damage, or theft. Additionally, we are reviewing our maintenance procedures to ensure properties are in good condition. Anticipated Completion Date: December 24, 2023 Contact: Jill Smith, Director of Housing Stabilization Division

Finding Summary: The Town did not have written policies, procedures, and standards of conduct relative to federal awards as required by the Uniform Guidance. Responsible Individual: Jake Roger, Town Administrator. Corrective Action Plan: The Town will produce policies, procedures, and standards of conduct relative to federal awards as required by the Uniform Guidance. Completion Date: December 31, 2023.

FINDING 2022-007 Contact Person Responsible for Corrective Action: Dan Durrwachter Contact Phone Number: 765-473-3081 Views of Responsible Official: We agree with these findings. Description of Corrective Action Plan: We will have our Financial Assistant become the point person for the management of equipment and real property. We will have a semiannual update to our inventory and keep an active identification number, a source of funding for the property, and a use and condition of the property. This report will be signed semiannually as well by the corporation treasurer. Anticipated Completion Date: : 6/01/2023

17-020-0150-26 CORRECTIVE ACTION PLAN FOR CURRENT YEAR AUDIT FINDINGS Year Ending June 30, 2022 Corrective Action Plan Finding No.: 2022-_ 004_ Condition: District personnel were unaware of the requirement to maintain property records for equipment purchased with Education Stabilization Funding. Plan: Annually, District personnel will read the 2 CFR Part 200, Appendix XI, Compliance Supplement for all federal programs received by the District to ensure they are aware of all applicable compliance requirements. Anticipated Date of Completion: 06/30/2023 Name of Contact Person: Drew Goebel Management Response: Management will implement the auditor's recommendation in the year ended June 30, 2023.

17-020-0150-26 CORRECTIVE ACTION PLAN FOR CURRENT YEAR AUDIT FINDINGS Year Ending June 30, 2022 Corrective Action Plan Finding No.: 2022-_ 003_ Condition: The District did not maintain property records for equipment purchased with Education Stabilization Funding. Plan: The District will assign an employee to prepare the District's property records in accordance with the requirements of 2 CFR section 200.313(d)(1). Anticipated Date of Completion: 06/30/2023 Name of Contact Person: Drew Goebel Management Response: Management will implement the auditor's recommendation in the year ended June 30, 2023.

Finding Control Number: 22-07 Financial Reporting Equipment and Real Property Management - ALN 21.019 Response by Department of Federal Programs ? Finding Control Number 22-06: We do not concur with this finding. CFR 200.313(d)(2) requires that a physical inventory of equipment be made at least once every two years, not annually. The property indicated in the finding was acquired during the fiscal year ended June 30, 2022, therefore, the physical inventory for this property acquired with the Coronavirus Relief Fund is not applicable in the current fiscal year. In addition, the Municipality of Las Piedras has recently completed a physical inventory of personal property, which includes furniture, equipment, licensed vehicles and all other personal property capital assets acquired with federal and non-federal financial sources. Anticipated completion date: Not applicable Contact person: Ms. Omayra Agosto Santiago, Director of Finance Telephone: (787) 733-2160, ext. 407 Email: recaudacionesmlp@gmail.com

FINDING 2022-001 (Auditor Assigned Reference Number) Contact Person Responsible for Corrective Action: Robert McIntire, Director of Business Contact Phone Number: 765-455-8000 We concur with the finding. Equipment was purchased with a total value of $438,016 and was incorrectly purchased and recorded and reimbursed as supplies and the inventory did not correctly reflect the purchase of these items. Description of Corrective Action Plan: Kokomo School Corporation will update its internal controls process to address this issue. All staff who are a part of grant administration and purchasing will be retrained on the internal controls process and on the details of property records that must be maintained. Additionally, Kokomo School Corporation staff will review inventory records for items purchased since July 2021 to ensure that the Equipment and Real Property Management compliance requirement is met. Anticipated Completion Date: Retraining will be completed by 8/1/2023. Review of purchases and inventory updates will be completed by 7/1/2024.

In response to audit finding reference number 2022-001, our planned corrective action for the finding is to perform a physical inventory of any property purchased with federal funds as required. Said tasks will be listed as an action item on the business office annual calendar. Karrine Montaque can be contacted at kmontaque@owncs.org regarding said task. The anticipated completion date is March 31, 2023.

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE AND REPORTABLE NONCOMPLIANCE ? U.S. DEPARTMENT OF EDUCATION ? PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, COVID-19 ? EDUCATION STABILIZATION FUND, FEDERAL ALN 84.425 2022-001 Internal Control Over Compliance With Equipment and Real Property Management and Reportable Noncompliance Finding Summary 2 CFR ? 200.313 (c)(1) and (d)(1) requires that Higher Ground Academy (the Academy) obtain approval from the federal funding agency or pass-through agency prior to the purchase of equipment with federal funding. The Academy must also maintain property records adequate to identify and track equipment purchased with federal funding, including the federal award under which the equipment was purchased. During our audit, we noted the Academy did not have sufficient controls in place within the Education Stabilization Fund federal program to assure compliance with federal equipment and real property management requirements, resulting in reportable noncompliance. Corrective Action Plan Actions Planned ? This condition and the resulting noncompliance was caused by a misunderstanding of the cost threshold at which federal equipment and real property management compliance requirements must be applied, due to the Academy?s adopted internal capitalization threshold being lower than the federal threshold. The Academy intends to revise its internal capitalization threshold to align with the federal threshold, and to review its other control procedures relating to equipment and real property management requirements to ensure compliance for future federal awards expenditures. Official Responsible ? Samuel Yigzaw, Executive Director. 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, Samuel Yigzaw, will oversee the implementation of proposed corrective actions and verify that appropriate controls are in place and understood by individuals responsible for federal program oversite at the Academy to ensure future compliance with federal equipment and real property management requirements.

FINDING 2022-001 Contact Person Responsible for Corrective Action: Dr. Eric Goggins Contact Phone Number: 812-385-4851 Views of Responsible Official: Agreement with Finding Description of Corrective Action Plan: North Gibson School Corporation will maintain an asset inventory to ensure an accurate recording of all capital assets are maintained and accurately include the following: Description of Property Serial Number Source of Funding for the Property (including federal award number) Who Holds the Title Acquisition Date Cost of Property Percentage of Federal Participation in the Project Use and Condition of the Property Anticipated Completion Date: The corrective action plan will be implemented immediately and continue moving forward when a capital asset is purchased and/or dispositioned.

2022-004 Equipment & Property Management - ESSER Recommendation: We recommend the District should consider having another individual, besides the one Performing the data entry, perform a review after the data is entered into the software. Explanation of disagreement with audit finding: There is no disagreement with this finding. Action planned/taken in response to finding: The district will have either the superintendent or district bookkeeper look over the entries that were performed during the school year for the fixed assets. Name(s) of the contact person(s) responsible for corrective action: Stacy Rasmussen Planned completion date for corrective action plan: Ongoing.

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. 1. Amtrak has completed on-time its Phase I engagement with an outside consulting firm that delivered a baseline assessment of Amtrak?s enterprise asset management program and high-level corrective action plans to address observations that were identified across the equipment life cycle. Corrective action plans (CAPs) were developed across process areas with key impact recommendations to address policy and governance around single auditable assets; the people and processes needed for a complete lifecycle oversight of equipment management; and the technology needed to support more robust internal controls, compliance, and timely audits. Amtrak is currently in discussion with this firm for Phase II that involves the implementation of these CAPs. 2. The Asset Management team will pursue enterprise-wide governance through new policies, procedures, and controls throughout the equipment lifecycle. For instance, the Asset Management team, as of February 2023, has been added as an approver to the PR workflow whenever a requester indicates that the PR contains equipment greater than or equal to $5,000 per unit as defined in the Equipment Control policy 3.19. This has helped to ensure that an asset record is created in the asset management system, that it is purchased using a capital code, and it has provided visibility to help ensure that once a purchase order has been created and the asset is received, the asset number that is physically placed on the asset is the same as what was created for the PR. 3. The Asset Management team will train and assist the Capital Accounting team to be able to detect issues with our equipment at the time the asset is placed in service. One goal of this training is to help ensure that at the time the asset is placed in service, it has a complete record, including, but not limited to the asset?s condition and location. We expect to complete this training by July 2023. 4. A technology solution needs to be adopted to better track and locate Amtrak?s assets, as well as support field personnel in ensuring compliance with federal regulations. Amtrak plans to utilize existing tracking technology on assets whenever possible and is exploring adding tracking technology to asset classes, such as yard equipment (e.g., forklifts and golf carts) that currently have no technology in a risk/cost effective manner at an enterprise level, and subsequently integrate with the existing systems to the maximum extent possible. Asset Management is also coordinating with the Company?s Digital Technology department to prioritize the development of a mobile application to help field personnel with performing audits. In the short-term, Asset Management has developed a SharePoint site to support other departments and divisions in completing and submitting audits specifically for single auditable assets. Currently, Procurement and the Automotive group utilize this SharePoint site for completing audits. Asset Management will be expanding this to the Operations & Transportation and Engineering departments. The Company expects to complete this roll out to these departments by June 2023. The Asset Management team is also working on enhanced reporting specific to the Mechanical department to assist with their observations. This new reporting is expected to be completed by September 2023. 5. Since June 2022, the Asset Management team has consistently been working with Capital Accounting to improve the non-compliant single audit equipment report. The Asset Management team is in the process of automating the Capital Accounting report. The team is managing the distribution of the report and assisting with data review. 6. Additionally, over this same period the Asset Management team has worked with the various departments that are responsible for single audit equipment. These actions have reduced the out of compliance assets in each of the departments. The Asset Management team will continue to actively work with the departments that manage these assets and assist these departments with ensuring their assets are physically inspected, tracked for location, and listed in the appropriate condition within the Company?s systems of record for asset tracking. 7. The Asset Management team is actively engaged with the various departments and divisions and continues to go on site visits to perform, as well as assist the equipment managers in performing, observations and audits of equipment and vehicle assets. The contacts for this item are Ian Hinke, AVP Supply Chain Management, and Carol Hanna, VP Controller. The Company anticipates the implementation of the above procedures, along with continual process monitoring and refinement, will fully remediate this finding by June 2026.

Finding 2022-011 Personnel Responsible for Corrective Action: Senior Accountant ? Trish Dinovelli Anticipated Completion Date: April 2023 Corrective Action Plan: The University has scheduled an inventory check for early April 2023. For the first year after the initial inventory check inventory checks will be completed semi-annually to ensure compliance. The University is seeking an asset management system to house all asset information and checks.

2022-001- We will give instructions to the Property Division to continue with the physical inventory of the machinery, equipment and vehicle of the Municipality in order to update the capital assets subsidiary and the property module in our accounting system. Also, we are considering engaging with an external consultant to support the Property Division in the process of gathering the necessary information to support the cost, completeness and ownership of its capital assets, necessary to comply with the requirement of the GASB Statement 34. Implementation Date: June 30, 2023 Responsible Person: Mrs. Irma M. Vargas Aguirre, Finance Department Director. 2022-002- On January 17, 2023 the State Employees Retirement System Administration (ERS), issued the Financial Reporting Valuation Report for the GASB 73 and 75m for the reporting year July 1, 2021 to June 30, 2022. However, this report was not audited. In the meanwhile, we proceeded to adjust the pension and OPEB liabilities and the deferred outflow/inflows of resources as of June 30, 2022, using the most recent Financial Reporting Valuation Report issued by the ERS. Implementation Date: Partially Implemented Responsible Person: Mrs. Irma M. Vargas Aguirre, Finance Department Director. 2022-003- During the fiscal year 2021-2022 the General Fund closed its operation with a positive net change of $865,178 which help reduced the accumulated deficit to $2,233,578. We have the commitment to continue reducing the accumulated deficit of the General Fund, by taking expenditure control measures that allow actual expenditures does not exceed the revenue collected, improving the budget control process, maximizing the use of the non-recurrent resources that have been allocated to the Municipality, implementing plan to increase the collection efforts over the municipal license taxes, the property taxes, and the sales and uses taxes among others. Implementation Date: July 31, 2023 Responsible Person: Mrs. Irma M. Vargas Aguirre, Finance Department Director. 2022-004- We will give instructions to the Head Start Program to prepare immediately, a report including a full description of the capital assets. This report must include the location, use, responsible person, cost, and any other pertinent data. In addition the Program should establish a property control account and a subsidiary ledger to provide for the reconciliation of the property. Implementation Date: June 30, 2023 Responsible Person: Mrs. Irma M. Vargas Aguirre, Finance Department Director, and Mr. Heriberto Rivera, Head Start Program Director