Corrective Action Plans

District subsequently sought and obtained CDE approval for the expenditures identified in finding 2022-003.District has initiated a procedure where any requisitions for purchases utilizing Federal funds are routed through the Director of state and federal programs prior to being approved. The director of state and federal programs, prior to approving the purchase requisition, will obtain approval from the CDE. All contracts utilizing federal funds will include language related to Federal wage rate requirements. The supervisor of Purchasing will be tasked with ensuring the contract language is present in agreements for services utilizing Federal funds.

The University has reviewed and enhanced its procedures and internal controls surrounding physical inventory of equipment and real property acquired with federal funds to ensure the physical inventory is performed at least biennially to meet the two-year requirement.

FINDING 2022-003Contact Person Responsible for Corrective Action: John Kenny and William LutherContact Phone Number: (812) 330-7700Views of Responsible Official: We concur with this finding. This finding has been remediated as of the completion dateshown below.Description of Corrective Action Plan:The asset mentioned in the finding now includes the source of funding. All future capital assets purchased with EducationStabilization Funds will include the source of the funding on the capital asset listing. The MCCSC will perform a physicalinventory during the current audit period.Completion Date: March 22, 2023

FINDING 2022-009Subject: COVID -19 - Education Stabilization Funding - Equipment and Real PropertyManagementFederal Agency: Department of EducationFederal Program: Education Stabilization FundAssistance Listings Numbers: 84.425DFederal Award Number and Year (or Other Identifying Number): S425D210013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: Equipment and Real Property ManagementAudit Findings: Material Weakness, Modified OpinionContact Person Responsible for Corrective Action: Chad Yencer, SuperintendentContact Phone Number: 765-348-7550Views of Responsible Official: We concur with this findingDescription of Corrective Action Plan:Each building principal shall maintain an up-to-date inventory on prescribed forms orelectronic format supplied by the business office. Each teacher shall maintain an up-to-dateinventory of equipment and supplies in his/her shop, laboratory, or classroom. The teachershall submit a complete inventory on the prescribed form (paper or electronic) to the buildingprincipal prior to the teacher?s leaving at the end of the school year. The building principal shallcertify to the business office that the inventory has been checked and approved. There shall betwo copies of the inventory: one filed with the building principal and one filed with the businessoffice, or an electronic copy and a paper copy.An equipment inventory will be maintained on all computers and capital outlay items exceeding$1000.00 in value. The inventory will serve the functions of both control and conservation.The technology coordinator shall be responsible for assuring the maintenance of acomprehensive inventory of administrative and instructional computer hardware and software.The coordinator should work with the corporation technology department to developprocedures to be followed in maintaining such an inventory.The librarian for each building shall be responsible for keeping a complete inventory of allaudio-visual items in his/her building and providing the inventory information to the buildingprincipal, or by using electronic entry.INDIANA STATE BOARD OF ACCOUNTS50The running inventory shall be maintained on 1) building and grounds equipment; 2) furniture;3) administrative equipment; 4) educational equipment; 5) vehicles; and 6) textbooks andsupplementary books.The maintenance supervisor and business manager shall be responsible for inventories relativeto buildings and grounds equipment and vehicles. The building principal and business managershall be responsible for the inventories relative to furniture, administrative equipment,educational equipment, and textbooks and supplementary books.The superintendent will ensure that the capital asset inventory records will be updated uponreceipt of equipment, and that the proper identification and records will be maintained. BCS willengage Ad-Tech as well to annually perform an audit of assets and update the inventory recordsand necessary property records.Anticipated Completion Date: July 2023

Management?s View and Corrective Action PlanThe following is Novant Health?s response to the audit of Federal programs in accordance with the Uniform Guidance for year ending December 31, 2022.2022-003: Evidence of physical inspection of equipment purchased with federal funds was not maintained ? Significant deficiencyCluster: Not applicableFederal Granting Agency: Health Resources and Services Administration (?HRSA?)Award Name: COVID-19 National Bioterrorism Hospital Preparedness Program (?Bioterrorism Program?)Award #: N/AAssistance Listing #: 93.889Award Year: Fiscal year 2022Pass-through entity: North Carolina Healthcare Foundation; North Carolina Department of Health and Human Services ? Division of Health Service Regulation, Office of Emergency Medical ServicesPass-through award #: U3REP 200659; 42705; 44024Management understands the importance of inspection and maintenance of equipment purchased utilizing funding under this grant, as well as the requirement of a physical inventory and reconciliation to property records at least bi-annually. Novant Health receives a notification of award and contract from the North Carolina Office of Emergency Medical Services (NCOEMS), Healthcare Preparedness Program (HPP) that outlines a summary of the financial information, specific grant terms, scope of work, and inventory management requirements.Corrective Action Plan and Anticipated Completion DateNovant Health management?s corrective action plan includes:? Update internal inventory management system, iCams, with needed information required to meet applicable Federal requirements? Create a formal process to update the maintenance and inventory of assets that meet this requirement that can be appropriately carried out by both paid and volunteer staff.? Complete a full inventory of all equipment purchased with federal fundsNovant Health will determine and implement a best practice to properly capture the necessary information to meet the applicable Federal requirements by October 31, 2023. We will also have the inventory management system updated by March 31, 2024, with maintenance and inspection dates required for hard supplies and equipment purchased under this grant to meet applicable Federal requirements, as well as a full inventory of federally-funded equipment, completed on a rolling basis moving forward, by June 30, 2024.Additionally, the program manager will provide an email confirming completion of the above steps to the Grants Director and team.For follow-up questions and information, please contact Randy Brantley, Novant Health Grants Director at rlbrantley@novanthealth.org.Sincerely,Randy BrantleyGrants Directorrlbrantley@novanthealth.org

FINDING 2022-006Contact Person Responsible for Corrective Action: Robin PopejoyContact Phone Number: 317.758.4172Views of Responsible Official: We concur with the finding.Description of Corrective Action Plan: Those procedures and errors were discussed and adjustment will be made. TheDirector of Business will conduct and internal audit of capital assets records. New staff will also be trained on trackingcapital assets transitions and completing the necessary documentation for future capital assets transaction. There is aconstruction project that will result in capital assets being added.Anticipated Completion Date: June 2023

2022-003 Federal Agency: U.S. Department of EducationPass Thru Entity: Oklahoma State Department of EducationCOVID-19 Education Stabilization Fund-Elementary & Secondary School Emergency Relief (ESSER II & American Rescue Plan (ARP) Elementary & Secondary School Emergency Relief (ESSER III) FundAssistance Listing: COVID-19 84.425D & 84.425U (OCAS Projects 793 & 795)Recommendation: The Auditor recommended that all property purchased with federal funds be tracked as required by federal regulations. The Auditor also recommended that controls be implemented to properly maintain records for property obtained with federal funds.Action Taken: All federal inventories have been reviewed and updated as necessary with with additional information to bring the district into compliance. An additional control has been added at the end of the fiscal year to ensure all federal purchases have been identified and recorded on inventories.Anticipated Completion Date: October 6, 2022Responsible Official: Brandi Naylor

Corrective Action PlanYear Ended June 30, 2022Finding 2022-002: EquipmentCondition Found:The University did not complete its physical inventory counts for 10 departments out of the 15 sampled University departments. The University has a total of 70 departments monitoring federal equipment. In addition, for one item in our sample of 40 physical inspections, we noted the property was not appropriately tagged for identification.Recommendation:The auditors recommend the University enhance its internal control over compliance around establishing property records of newly acquired federally funded equipment in accordance with applicable Federal regulations and completing the necessary physical inventories and reconciliations.University of Delaware Corrective Action Plan:The University agrees with the finding and will strengthen processes including unit and senior leadership accountability around the tagging and surveying of federally funded equipment. The University will implement management and escalation procedures with executive leadership to ensure that accountability for all completed surveys resides with the senior leader. The entire process is being evaluated and controls will be enhanced where needed and training will be expanded to include the importance of timely compliance.Anticipated Completion Date:June 2023Contact Person:Lisa Marra Kelly, Controller, Controller?s Office

Name of Contact Person: Sue Nickerson, Town Accountant

Corrective Action Plan: The District will review current policies and procedures relating to the purchasing and maintaining of equipment and real property, in particular, when purchasing with Federal funds. Currently, the District does maintain a record of all purchases, including Federally funded equipment. Moving forward, the records will be maintained in accordance with the Requirements for Equipment and Real Property Management from the 2023 Compliance Supplement. It should be noted that the Town/School financial system will be converting/upgrading to MUNIS ERP Solution for the Public Sector. MUNIS has a much more robust and sophisticated Fixed Asset module and will be invaluable for the District to meet this requirement.

Proposed Completion Date: Immediately

Auditor's Recommendation: We recommend the Entity enhance the design of its control activities and policies and procedures should be developed to ensure physical inventories are taken at least once every two years. Action Taken: The Organization understands the importance of regular physical inventories and will implement this control activity for the June 30, 2023 fiscal year end. Responsible Person: John Clemons, Chief Financial Officer Timeline for Implementation: July 31, 2023

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.