Corrective Action Plans

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

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