Corrective Action Plans

2022-003. Equipment and Real Property Management United States Department of Education, passed through New York State Department of Education Education Stabilization Fund COVID-19: Governor?s Emergency Education relief (GEER) Fund ALN: 84.425C COVID-19: Elementary and Secondary School Emergency Relief (ESSER) Fund ALN: 84.425D COVID-19: American Rescue Plan ? Elementary and Secondary School Emergency Relief (ARP ESSER) Fund 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 using Federal grant funds in its current year additions in the District?s capital assets inventory. Planned Corrective Action: Management agrees with the finding and will ensure that the equipment purchased with federal funds is captured, reconciled, and included in the District?s capital assets inventory records. Responsible Contact Person: Jeremy Feder Assistant Superintendent for Business and Operations Lawrence Union Free School District 2 Reilly Road Cedarhurst, NY 11516 Anticipated Completion Date: June 30, 2023.

Finding 2022-004 Federal Agency Name: Department of Health and Human Services Program Name: COVID-19 Testing and Mitigation for Rural Health Clinics FFAL #93.697 Compliance Requirements: Equipment and Real Property Management Finding Summary: Federal-funded equipment and real property is not distinguished separately from non-federal-funded equipment and real property within the Facility's fixed asset listing. Responsible Individuals: Phillip Husher, CFO, Freeman Regional Health Services Corrective Action Plan: Freeman Regional Health Services will review our fixed asset policies and procedures in order to identify expenditures for Federal-Funded equipment. We will update our current fixed asset listing to identify federally funded equipment. Anticipated Completion Date: December 31st, 2023.

FINDING 2022-001 Contact Person Responsible for Corrective Action: Annette Brown, Treasurer Contact Phone Number: (812)829-2233 Views of Responsible Official: We concur with Audit Finding Description of Corrective Action Plan: The School Corporation will implement procedures and processes to ensure that the School Corporation and 3rd Party Inventory Vendor includes all required information on all property purchased with federal funds that is outlined in 2 CFR 200.313(d)(1). The Treasurer will list items that are purchased with federal funds and forward that information to the 3rd Party Vendor. Once the report from the 3rd Party Vendor is received either the Treasurer/Deputy Treasurer/Grant Administrator will review the report to ensure all required information has been included on all items purchased with federal funds. Anticipated Completion Date: Will begin this process moving forward with any property purchased after February 2023.

2022-005 Federal Agency: U.S. Department of Education Pass Thru Entity: Oklahoma State Department of Education Program: COVID-19 Education Stabilization Fund Assistance Listing: COVID-19- 84.425D & 84.425U Grant Period: Year ending June 30, 2022 Recommendation: The auditor recommended that property be properly tracked. The auditor also recommended that procedures be put in place to properly identify property transaction and track property acquired with federal funds. Action Taken: District will hire an asset management company, which will complete an initial database of District property and barcode items. Afterwards, District will maintain database. Encumbrance clerk has implemented new procedures to monitoring the coding of items greater than $5,000 with lite longer than a year is properly coded in OCAS. Federal Programs Director will manage budgets and make sure if property/equipment will be purchased it is budgeted and proper approval to be obtained before purchase. Federal Program Director will also monitor during claim process, property items have been identified and tracked on District equipment listing. Anticipated Completion Date: May 2023 Responsible Official: Superintendent

The District will review current processes for purchasing equipment within Iowa Department of Education approval amounts or seek amendments when approval cost limits cannot be met. June 30, 2023 Cyndie Johnson

FINDING 2022-003 Contact Person Responsible for Corrective Action: Karen Zackfia, Director of Business and Finance Contact Phone Number: Karen Zackfia, 219-285-2228 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Because the COVID-19 pandemic caused the addition of new CARES and ESSER grants and various new additional data reporting requirements, the director of business and finance forgot to obtain the second review and appropriate documentation as is being done for each grant reimbursement request and the final expenditure report Effective immediately, all federal data reports will be reviewed by either the superintendent or deputy treasurer before submission. The review will be documented with the reviewer?s initials and date as well as the preparer?s initials and date of completion. Anticipated Completion Date: The corrective action plan was implemented on March 15, 2023.

Name of Auditee: Town of Alexander, New York Name of Audit Firm: EFPR Group, CPAs, PLLC Period Covered by the Audit: Year ended December 31, 2022 CAP Prepared by: David Miller, Supervisor Phone: 585-591-2455 (2) Audit Finding 2022-002 - The Town did not have accurate capital asset records. (a) Implementation Plan of Actions - The Town is looking into capital asset software and is having a physical inventory performed. (b) Implementation Date - This will be implemented for the year ended December 31, 2023. (c) Persons Responsible for Implementation - The Town Board and Supervisor of the Town of Alexander.

FINDING # 2022-001 U.S. Department of Education ? Passed-through the NYS Education Department COVID-19 Elementary and Secondary School Emergency Relief Fund; Assistance Listing Number 84.425D; Grant Period ? Fiscal Year Ended June 30, 2022 Non-Compliance Criteria: According to 2 CFR section 200.313(d)(1), detailed property records must be maintained for equipment acquired under a federal grant award. Records should include a description of the property, a serial number or identification number, the source of funding (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, use and condition of the property, and ultimate disposition data. Condition: During our audit, we noted the District?s fixed asset records were incomplete for some of the assets acquired with federal grant funding during the fiscal year. Cause: The timing of fixed asset additions to the District?s fixed asset records did not align with the acquisition date. Effect: If the District?s fixed asset records are incomplete, they may not be properly safeguarded, and the District may not comply with the aforementioned federal regulations. Recommendation: We recommend that the District update their fixed asset records to include required information for assets purchased with federal awards and that a system of communication and a review process be implemented to ensure completeness and timing of fixed asset addition records. District?s Response: The District reviewed the federal guidelines with the grant administrator, requisitioner, and purchasing agent/fixed asset keeper on capital asset acquisitions through grants. The District has placed new internal controls to identify capital asset acquisitions through grants; those internal controls include but are not limited to review of minor remodeling, supplies and materials and equipment account codes, identification upon requisition, approval from grant administrator, and review by grant administrator. Before finalizing capital assets reports, the purchasing agent, fixed asset keeper, and current accounting consultant will review the purchase orders for anything above the District's capitalization policy. These controls will ensure the District is compliant and within requirements for capital asset acquisitions through grants. Individual Responsible for Implementing Corrective Action Plan: Brigid Siena, Assistant Superintendent for Business and Operations Implementation Date: March 15, 2023

AL Numbers: Various Program: Research and Development Cluster Corrective Action: All departments of the University will be reminded by the Central Accounting department that tagging is an integral part of the internal control process for capital assets. The Central Accounting team will send a memo to all equipment coordinators and Finance Managers at the campus units. The memo will be emailed by April 30, 2023. In addition, the Central Accounting team will schedule a virtual training to go over asset tagging procedures. All equipment coordinators will be invited to the training and it will be scheduled prior to June 30, 2023. Contact: Kathy Conrad and Maru Mendoza Expected Implementation: June 30, 2023

Corrective Action Plan: The AOE will require each participating independent school complete an inventory webform every two years for each piece of equipment that has been reimbursed or purchased by VTAOE for use by the independent school under CRRSAA. The Equipment will be tagged as property of the State of Vermont, and we will require a picture of the item for our records to ensure the item is in a good condition. We will maintain a list of equipment items including all that is required in 2 CFR section 200.313(d) (1). Our Administrative Services Director will add equipment and maintain our equipment list. Updates will be provided to this position by the EANS program team following the process below. The AOE EANS Program team will review each Equipment inventory submission for completeness including: the current condition and if the item is still being used for its intended purpose. Once the inventory is complete, the Program team will provide the inventory updates to the AOE Finance Team. As long as an independent school continues to use the equipment for an approved purpose, they will be asked to complete the inventory every two years. The Administrative Services Director will work with the State of Vermont?s Department of Buildings and General Services when equipment items need to be disposed of. We will provide them a list of the items and they will instruct us how to proceed. Position Responsible for Implementation of Corrective Action Name: Sean Cousino Position: Deputy Chief Financial Officer Email: sean.cousino@vermont.gov Phone Number: 802 595-3693 Date of Implementation of Corrective Action: 7/1/2023

FINDING: The Board used money from the COVID-19 Education Stabilization Fund to Purchase a computer server in excess of $5,000 and failed to include the server in the fixed asset inventory as required. 2CRF Sections 200.313 (c) through (e) require equipment having a useful life of more than one year and a per-unit acquisition cost which equals or exceeds $5,000 must be maintained in the Board's property records. A computer server costing $40,440 was not properly classified as capitalized equipment and as such, was omitted from the Board's Fixed Asset Inventory. Recommendation: The Board should ensure that all equipment is properly recorded in the accounting records Fixed Asset Inventory. RESPONSE/VIEWS: The Board agrees with this finding. CORRECTIVE ACTION PLAN: The management of the Board was notified of the error and made the adjusting entries to correct the financial statements. Expenditures for non-capitalized equipment will be reviewed more carefully by the Technology Coordinator and CSFO. ANTICIPATED COMPLETION DATE: This finding has already been corrected as of 06/30/2023. CONTACT PERSON: Thomas Osborne (thomas.osborne@scsboe.org) (256-249-7007).

FINDING 2022-003 Contact Person Responsible for Corrective Action: Jessica Secrease Contact Phone Number: 765-456-2804 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The County will maintain adequate property records for the State and Local Fiscal Recovery Funds. In the future, the Auditor?s Office will request that the County Commissioners and County Attorney provide all necessary information in order for records to be maintained properly. The County Commissioners will also be reminded that they need to follow the agreements that they approve. Anticipated Completion Date: 06/15/2023

Finding 2022-103 ? Improve Controls over Capital Assets (Significant Deficiency) ? (Repeat Finding) FAL Numbers: 15.042 Program Titles: Indian School Equalization COVID-19 Indian School Equalization Condition and Context: The School has not performed a comprehensive inventory of capital assets in several years. Accordingly, the School has not reconciled a physical observation to its detailed capital asset listing. Recommendation: The auditors recommended that the School perform a physical inventory of the School's capital assets on at least a biennial basis. In addition, the Finance Department should update the School's accounting records based on the results of the physical inventory. Contact Name: Renee Ramirez, Business Manager Corrective Action Planned: HBCS is planning to perform a physical inventory of the school?s capital assets every two years. A system will be designed to ensure that this occurs. The Business Department will update the School?s accounting records based on the results of the biennial inventory. Anticipated Completion Date: June 30, 2023

Finding Number: 2022-001 Planned Corrective Action: The School District will review all purchases made with federal funds to ensure they are properly capitalized and input into the EIS system for tracking purposes. Anticipated Completion Date: April 30,2023 Responsible Contact Person: Samantha Hamilton, Treasurer

Finding Number: 2022-001 Planned Corrective Action: The district will put procedures in place to ensure that all additions to the fixed assets are updated fully each year. Anticipated Completion Date: June 30, 2023 Responsible Contact Person: Sandi Hurd, Treasurer

FINDING 2022-003 Contact Person Responsible for Corrective Action: Shannon Fritz, Corporation Treasurer, Cathy Rowe, Superintendent Contact Phone Number: 219-567-9161 Views of Responsible Official: We concur with the audit findings. We have initiated corrective action as referenced below. Description of Corrective Action Plan: The district will be soliciting a capital assets tracking vendor that will ensure all capital assets are tracked and updated. Anticipated Completion Date: March 15, 2023 Cathy Rowe, Superintendent Shannon Fritz, Corporation Treasurer Date: 2-27-23 Date: 2-27-23

Charter Schools ? AL #84.282 Education Stabilization Fund ? AL #84.425C, 84.425D & 84.425U 2022-002 Equipment and Real Property Management (Repeat Finding 2021-002) Significant Deficiency Recommendation: The Auditor recommended the Organization develop a system of internal controls aligned with the applicable compliance requirements to properly track equipment acquisitions in the accounting records and to ensure a physical inventory is appropriately documented when completed. Planned Corrective Action: The Organization has implemented a location software for student devices that tracks the majority of the required information for devices that are live on the network. The Organization concurs that additional internal controls are necessary to ensure all compliance requirements are met. These controls will include exports from the location software for a periodic inventory as well as additional procedures for tracking defective devices. Further controls will be implemented to ensure that the inventory records are easily traced to the invoices retained in the financial records. Similar controls will be implemented to ensure proper tracking and inventory of all assets purchased with federal funds. The reorganization of the Business Office described above in 2022-001 will allow the Controller oversee the implementation of these controls and periodic internal audits to ensure adherence to all compliance requirements.

FINDING 2022-001 Contact Person Responsible for Corrective Action: Dianne Lacy Contact Phone Number: 812.282.7753 Views of Responsible Official: We concur with the finding Description of Corrective Action Plan: An effective internal control system, which would include the segregation of duties was not in place to ensure compliance with requirements related to the federal grant agreement and the Equipment and Real Property Management compliance requirement. The Corporation Treasurer is going to contact vendors that work with school corporations to collect documentation that is incorporated to support the Capital Assets Ledger (Form 369). A vendor will be selected to provide the following: a. Collect and archive invoices for capital purchases according to district guidelines. Record assets that meet or exceed the inventory threshold amount. b. Validate land/property descriptions/documents as recorded in the County Assessor?s Office. c. Verify accuracy of Corporation owned vehicles (buses, trucks, etc.) including model, year, VIN, purchase date, purchase price. d. Conduct on-site inventory of each building/location. e. Affix bar code labels to pertinent assets that meet the threshold. f. Incorporate accumulated depreciation calculations as required by SBOA. g. Assemble information into a Capital Assets Ledger, using the SBOA Form 369 format. Anticipated Completion Date: August 31, 2023

The District of Columbia Public Schools (DCPS) agrees with the conditions and recommendations of this finding. The DCPS corrective action plan includes the following: ? DCPS will establish a link between the various systems to ensure purchasing and receiving records are attached to individual asset tags or other identifiable information in our asset management system. Effective March 23, 2023, TIPWeb has been updated reflect these changes. See Corrective Action Plan for chart/table

This was the first year for a new person to control the tracking of assets that need to be added or deleted from the inventory list. The issue has been corrected and all assets are tracked as invoices are paid for inventory or improvements over $5,000. The assets noted from FY2022 will be added to the inventory list for FY2023.

Views of Responsible Officials and Planned Corrective Action The HPU Fixed Asset Accountant, Federal Grant Project Investigator and Office of Sponsored Projects will work collaboratively to ensure that the physical inventory of all fixed assets which were acquired using federal funds are conducted and completed periodically. This physical inventory monitoring will be done at least, every two years. The team will work on getting all departments covered in the periodic inventory to confirm that the fixed asset listing is complete, updated and maintained. Person Responsible: Fixed Asset Accountant, Respective Project Investigator, Assistant VP of Office of Sponsored Projects and Manager of Office of Sponsored Projects. Targeted Correction Date: June 30, 2023.

Patriot Preparatory Academy will implement an inventory management system to classify and track all capital assets.

Name of Contact Person: Alyssa McDermott Corrective Action Plan: Over the past year staff has ensured that the inventory is up-to-date and accurate. Inventories were performed in 2022 and 2023 in preparation for the single audit. Now that the division of housing and community development is fully staffed, the inventory can be shared amongst staff as well as uploaded to the shared drive to ensure it can be accessed in the event of staff turnover Proposed Completion Date: 6/30/23

FINDING 2022-004 Subject: Special Education Cluster ? Equipment Management Audit Findings: Material Weakness Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the equipment requirements of the Equipment and Real Property Management compliance requirement. Context: The School Corporation is a member of a joint service cooperative (Cooperative). The Cooperative operated the special education programs on behalf of the School Corporation and managed the special education grant funds. Because the grant agreements were between the Indiana Department of Education and the School Corporation, the School Corporation was ultimately responsible for compliance with the grant agreement and the Equipment and Real Property Management compliance requirement. During fiscal year 2021, the School Corporation paid membership fees to the Cooperative out of federal Special Education funds. These membership fees made up approximately 48% of the total federal expenditures reimbursed during fiscal year 2021. The Cooperative accounted for state, local, and federal funds in a single fund. The fund did not separately account for each of the funding sources. This made it indeterminable whether equipment purchases were made by the Cooperative with federal funds, or to identify equipment expenditures by federal program, award number, or years. Therefore, we could not test compliance for approximately 48% of the expenditures. The Cooperative did not have adequate procedures in place to ensure that equipment purchased with grant funds was properly recorded and maintained in the School Corporation's equipment records. The Cooperative also did not maintain records for the disposition of equipment purchased with federal grant funds. The lack of internal controls and noncompliance were systemic issues, which occurred specifically during fiscal year 2021. No reportable findings were noted for fiscal year 2022. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Members of the cooperative are no longer paying their cooperative member fees with federal funds. This was resolved effective 7/1/2021. Responsible Party and Timeline for Completion: Zach Dennis, CFO, 7/1/2021

FINDING 2022-007 Contact Person Responsible for Corrective Action: Julia Smith, Business Manager Contact Phone Number: 317-788-4481 Views of Responsible Official: We concur with the findings Description of Corrective Action Plan: The Director of Operations and the Business Manager will implement internal controls to verify all equipment purchased with federal dollars will be marked on the documentation. Anticipated Completion Date: January 2023