Corrective Action Plans

RESPONSE TO AUDIT FINDING #2022-002: EDUCATION STABILIZATION FUND DISCRETIONARY GRANTS- SPECIAL TESTS AND PROVISIONS (50000) The charter has already submitted the capital expenditure request form to COE and is awaiting approval. The charter will review all required compliance requirements for all new federal funding before purchases are made. The charter anticipates receiving the approval by December 31, 2023.

2022-005 Equipment and Real Property Management Type of Finding: Noncompliance, Significant Deficiency Repeat Finding: Same as prior year financial statement finding 2021-003 Condition/Context: The School did not perform a full physical inventory within the two-year period ending June 30, 2022. Action planned in response to finding: The School will implement policies and procedures that ensure a full physical inventory at least every two fiscal years and the results of the inventory are reconciled with the records in the financial software. Additional training will be provided for staff responsible for inventory. Planned completion date for corrective action plan: For the period ending June 30, 2023. Name of the contact person responsible for corrective action: Frances Stevens, Business Technician; Lillian Benallie-Rock, Interim Principal

FINDING 2022-001 Contact Person Responsible for Corrective Action: Karen Scalf, Chief Financial Officer Contact Phone Number: (765)973-3406 Views of Responsible Official: Richmond Community Schools agrees with the finding. Departments under new leadership have not been maintaining the most appropriate records with regard to inventory of school equipment and technology. Description of Corrective Action Plan: The Chief Financial Officer will meet with Superintendent?s Cabinet, Directors of Grant Administration, and Technology to review the most appropriate record keeping practices and expectations for maintaining accurate and detailed inventories of school equipment, textbooks, technology, furniture, etc. The inventory list is to be provided to the Business Office on or before June 30 of each calendar year and will be used to improve the information contained in the corporation fixed asset report. The fixed asset report will be updated at least every other year per Board Policy. Anticipated Completion Date: April 7, 2023

District will review federal claims for equipment purchases items greater than $5,000 and life longer than a year and capture equipment items into the property records as they are received.

Finding 2022-001 Contact Person Responsible for Corrective Action: Matthew Irwin, Assistant Superintendent Contact Number: 812-876-7100 View of the Responsible Official: Richland-Bean Blossom C.S.C. concurs with finding 2022-001. Description of Corrective Action Plan: The School Corporation will develop Internal Control procedures over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statues, regulations, and the terms and conditions of the Federal award. The School Corporation will maintain and include detailed information of Equipment and Real Property records required per the federal compliance supplement document. This information will be reviewed and implemented by the Corporation Treasurer, Assistant Superintendent or another authorized staff member. Anticipated Complete Date: Implementation of Corrective Action Plan will be set in places as of March 2023. Signed: Dated: 2-8-23 Dr. Jerry Sanders Superintendent Signed: Dated: 2-8-23 Matthew Irwin Assistant Superintendent

As part of the Head Start program termination by the grantee, the capital assets subsidiary ledger has been updated by the Municipality?s finance department staff. It is important to comment that during the fiscal year 2021-2022, the Program employee in charge of the capital assets administration was removed from his position, as requested by the grantee, and, in an interim basis, another employee was assigned with such functions, in additions to his regular functions. Implementation Date: September 30, 2023 Responsible Person: Mrs. Yadixa Ramos Finance Department Director

The Strong - Huttig School District is committed to addressing and correcting these findings. The District will contact the Arkansas Division of Elementary and Secondary Education for guidance regarding this matter and implement proper controls over program expenditures. The District will also ensure all capital asset records are updated, and maintained moving forward. During the 2021-2022 school year the Bookkeeper and the Superintendent's Administrative Assistant both retired. Unfortunately the incoming replacements did not get a chance to train with them prior to their departure. Institutional knowledge, files, information, and procedures that should have been transferred to the new employees did not happen as planned. Our goal as a district is to ensure proper training for new employees, and administrative procedures and processes will be transferred better in the future.

FINDING 2022-003 Contact Person Responsible for Corrective Plan: Alva Sibbitt, Jr., Superintendent Contact Phone Number: 812-547-2637 Views of the Responsible Official: We concur with the findings. Description of Corrective Action Plan: The Superintendent will make sure to keep the Capital Asset listing up to date. Anticipated Completion Date: February 2023

For the fiscal year under audit, all federally funded items have been inventoried and tagged as required. In subsequent fiscal years, tangible items purchased with federal funds will be inventoried and tagged appropriately.

Lawton Public Schools failed to identify ?Construction in Progress? paid for with federal funds as federal. Procedures will be updated to ensure ?Construction in Progress? paid with federal funds is identified and recorded as federal immediately rather than at the completion of the construction. While this finding is identified as a repeat finding from FY2021 (2021-006), the prior year was in reference to fixed assets while this year?s finding is in reference to ?Construction in Progress?.

FINDING 2022-010 Contact Person Responsible for Corrective Action: Nicole Wolverton, CFO Contact Phone Number: 219-881-5536 Views of Responsible Official: We concur with the audit finding. Description of Corrective Action Plan: A policy and procedure will be created to ensure that all equipment and real property is recorded in an asset management system for capital improvements. Assets will be entered based on funding source, acquisition date, cost, and federal award number. Anticipated Completion Date: Gary Community School Corporation will implement this procedure by September 2023.

The City has not, in recent years, purchased any inventory with CFDA# 14.228 Disaster CDBG funding and has disposed of all but three (3) inventory items purchased with this funding. The City provided to the auditors the completed physical inventory documentation and the auditors deemed the issue as resolved. The City will continue to implement and execute its controls in place to ensure that a physical inventory is taken at least once every two years. Responsible Party Ronald Fornerette, Jr. ? Director of Compliance. Completion Date: January 30, 2023

Auditors? Recommendation - We recommend the College 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 and that they create a tool to assist in tracking and maintaining equipment purchased with federal funds. Views of Responsible Officials and Planned Corrective Action - The College does maintain a listing of inventory purchased with federal funds; however, the inventory was not sufficiently and accurately maintained due to staff turnover. The College is reviewing current policies and will modify those as needed. The College plans to conduct a physical inventory of all capital assets and those assets procured with federal sources. Responsible Official - Denise Montoya, Vice President for Finance & Administration, Theresa Storey, Chief Financial Officer, Scott Stokes, Chief Information Officer, and Josephine Velasquez, Procurement Timeline and Estimated Completion Date - June 30, 2024

17-020-0180-26 CORRECTIVE ACTION PLAN FOR CURRENT YEAR AUDIT FINDINGS Year Ending June 30, 2022 Corrective Action Plan Finding No.: 2022-_ 002__ Condition: The District's property records did not include the date purchased and serial numbers for equipment purchased with Education Stabilization Funding. Plan: The District will assign an employee independent of the preparer, preferably with knowledge of applicable federal grant expenditures, to review the District's property records on a periodic basis to ensure the listing meets the requirements of 2 CFR section 200.313(d)(1). Anticipated Date of Completion: 06/30/2023 Name of Contact Person: Hillary Stanifer Management Response: Management will implement the corrective action plan for the year ended June 30, 2023.

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 and that they create a tool to assist in tracking and maintaining equipment purchased with federal funds. Action Taken: Management agrees with the finding. We need to create an Asset Policy manual that will address procedures for managing and recording equipment inventory. Property records must include a description of the property, program location, serial number or other identification number, source of funding for the property, who holds the title, the acquisition date, cost of property, percentage of federal participation in the project costs for the federal award under which the property was acquired, use and condition of the property as well as the ultimate disposition data including the date of disposal and sale price of the property. Physical inventory must occur at least every two years and be reconciled with the property records. The Asset Policy will also include a control system to ensure adequate safeguards to prevent loss, damage, and/or theft of the property as well as adequate maintenance procedures to keep the property in good condition. Any loss, damage and/or theft must be investigated. Proper sales procedures will also be included in the Asset Policy. Due Date of Completion: June 30, 2023 Responsible Official: Katie Rodriguez, Accountant and Michael Bartlett, CFO

Planned Corrective Action: The Expo is bound by their management agreement with Bell County. Corrective action can not be taken in response to this finding. Person Responsible for Corrective Action Plan: Tim Stephens, Executive Director Anticipated Date of Completion: Not applicable

FINDING 2022-001 ? Equipment and Real Property Management ? Significant Deficiency in Internal Controls and Instance of Non-Compliance. Corrective Action Plan: The College will perform a physical inventory of equipment purchased with federal funds annually to ensure we meet the compliance requirement of performing a physical inventory once every two years. the College's schedule for performing physical inventories was interrupted by the pandemic. Contact Person Responsible for Corrective Action: Barbara Valiente, Associate Vice President for Finance and Controller. Anticipated Completion Date: We completed the physical inventory on November 8, 2022, however we had not completed an inventory since 2019. Sincerely, Barbara Valiente, Associate Vice President for Finance and Controller, Occidental College, 1600 Campus Rd., Los Angeles, CA 90047, (323) 259-1417

Fiscal Year Audit Report: Corrective Action Plan Year ended June 30, 2022 Finding 2022-002: Education Stabilization Fund (5000) Federal Agency: U.S. Department of Education Pass through Entity: California Department of Education Program Names: Elementary and Secondary School Emergency Relief I, II, III (ESSER, ESSER II, ESSER III) (Assistance Listing 84.425D) Criteria: Consistent with 2 CFR Section 200.311 (real property), Section 200.313 (equipment), and Section 200.439 (equipment and other capital expenditures) Education Stabilization Funds may be used to purchase equipment. Capital expenditures for general and special-purpose equipment purchases are subject to prior approval by the Department of Education or the pass-through entity. Finding: The District purchased numerous equipment items above the capital threshold for federal purchases but did not obtain approval from the California Department of Education. Questioned Costs: Purchases totaling $329,699.90, were made for equipment above the capital threshold without CDE approval. Context: The finding is limited to purchases above the capital threshold requiring approval. Cause: The District was unaware of the requirement. Effect: The funds spent on this purchase may be subject to review or return to the awarding agency. Recommendation: We recommend the District submit requests for approval for the equipment or find another allowable funding source for the purchases. Action: Staff and Management will ensure that the District submits requests for approval for capital expenditures from the California Department of Education prior to purchases. Completion Date: Effective immediately Contact: Zach Klemish, Director of Fiscal Services, Adelanto Elementary School District, (760) 246-8691

FINDING 2022-004 CORRECTIVE ACTION PLAN Contact Person Responsible for Corrective Action: Jason R. Watson, Assistant Superintendent Contact Phone Number: O?ce: 812-866-6244 Cell: 812-599-0627 Contact Email: jwatson@swjcs.us Views of Responsible O?cial: We concur with this audit finding. Description of Corrective Action Plan: Action taken in an e?ort to remedy finding 2022-004 includes, but is not limited to, the following: ? Beginning March 8, 2023, an e?ective internal control system will be implemented related to equipment and real property management compliance requirements. ? In November of 2021, Southwestern Je?erson County Consolidated Schools (SWJCS) contracted with Asset Control Solutions, Inc. (ACS), a professional fixed asset inventory and management services that creates and maintains an accurate and detailed record of our corporation?s property, and ensures that SWJCS is properly insured with an on-site and in-depth insurance valuation for our agent. ? ACS provides the corporation with a SharePoint site to access and manage all of the equipment and real property data. This site allows for the addition and deletion of inventory by selected corporation sta? to ensure its accuracy. ? The smart boards mentioned in this finding had not been received at the time of the November assessment by ACS and the corporation was advised not to include these items in the inventory until they had actually been received on site. ? These items have been added to the inventory, properly tagged, and are reflected in updated reports recently received. ? Beginning March 8, 2023, SWJCS will begin the use of Boyce School Financial (BSF) for our financial software. This cloud-based system provides import and export abilities that were not available in the DOS based system that was in use at the time of the audit period. ? As a result of the capabilities of the BSF System, we will begin March 8th with the most current data from ACS in BSF. ? Moving forward, the process for items meeting the capital assets threshold will include, but is not limited to, the following: > When item(s) meeting the capital assets threshold are received, the recipient will a?x the proper inventory sticker to the item(s) and complete the inventory change form either digitally or hard copy and submit to the Treasurer for processing.FINDING 2022-004: Corrective Action Plan Continued > The Treasurer will enter the data provided by the recipient into the BSF System and provide the inventory change form to the Assistant Superintendent. > The Assistant Superintendent will confirm that the item(s) have been accurately entered into BSF and enter the information in the ACS system through SharePoint. > The inventory change form will then be provided to the Deputy Treasurer. > The Deputy Treasurer will confirm that the item(s) have been accurately entered into BSF and SharePoint. > Every two years, tentatively scheduled for November of 2023, ACS will return and complete a thorough GASB 34 Compliant Capital Asset Inventory and provide the corporation with the resulting reports. > The Assistant Superintendent will complete a change form for any resulting corrections needed and update BSF with these changes. The change form be routed to the Treasurer. > The Treasurer will confirm that the item(s) have been accurately entered into BSF and send the form to the Deputy Treasurer. > This process will be documented using DocuSign by following a similar process as outlined in Finding 2022-001 and 2022-003. Anticipated Completion Date: March?31,?2023?

FINDING 2022-008 Contact Person Responsible for Corrective Action: Kasey Clark Contact Phone Number: 574-772-1604 Views of Responsible Official: We concur with the findings Description of Corrective Action Plan: The HVAC will be documented with all appropriate information via Adtec in 2023 which is our biannual update. The Treasurer will review and approve this documentation for accuracy. A spreadsheet will be kept to document all capital expenditures as they occur. Equipment will be appropriately safeguard and maintained by the School Corporation?s Maintenance Director. Anticipated Completion Date: March 2023

Department: Education Title: Internal control over ESF subrecipient monitoring procedures needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: During the review of ESF applications, the Office of Federal Emergency Relief Programs (OFERP) team will confirm that equipment purchases are denoted in the equipment budget category of the application. Equipment inventories and real property lists will be collected during the subrecipient monitoring process from school administrative units (SAUs) and reviewed for compliance by the OFERP team. Completion Date: December 31, 2023 Agency Contact: Shelly Chasse-Johndro, Director of OFERP, DOE, 207-458-3180

Person responsible for corrective action: Clerk Staff, under County Clerk supervision Corrective action planned: Necessary columns required for equipment purchased/disposed of were added to the spreadsheet. County offices notification sent reminding ALL add/delete information must be completed for proper data entry into the inventory system Anticipated completion date: August 31, 2023

FINDING 2022-002 Contact Person Responsible for Corrective Action: Tracey R. Bolin, Director of Business Services Contact Phone Number: 574.254.4503 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Accounts Payable Specialist will create a google spreadsheet that will include all capital assets that are paid in a docket. This spreadsheet will be shared with the Purchasing Coordinator and Assistant Director of Business Services. The Purchasing Coordinator will verify the assets are in the fixed asset program with the required information. A physical inventory will be conducted at least once every two years to prevent loss, damage, or theft of the assets and signed by the Purchasing Coordinator and the Assistant Director of Business Services. The Assistant Director of Business Services will verify the spreadsheet by using the Form 9 ? Schedule of Capitalized Equipment Detail. The Assistant Director of Business Services and the Purchasing Coordinator will both sign the schedule. Anticipated Completion Date: ? Implementation: March 2023

Finding No.: 2022-_ 003__ Condition: The District's property records did not include the required information for equipment purchased with Education Stabilization Funding. Plan: The District will assign an employee independent of the preparer, preferably with knowledge of applicable federal grant expenditures, to review the District's property records on a periodic basis to ensure the listing meets the requirements of 2 CFR section 200.313(d)(1). Anticipated Date of Completion: 06/30/2023 Name of Contact Person: Adam Clapp Management Response: Management will implement the corrective action plan for the year ended June 30, 2023.

Finding No. 2022-002 Department(s) New York City Police Department Program(s) Assistance Listing Number 97.056, Port Security Grant Program Corrective Action(s) Since the original finding in the FY2020 Single Audit, the NYPD has and continues to implement policies and procedures to ensure there are multiple levels of inventory asset verification and validation are completed in accordance with Federal requirements. The Grants Unit works closely with project managers to ensure they have continued access to the Grant Tracking System (GTS) and provide hands on training on the system. As previously mentioned, GTS has been updated, and access has been provided to at least two individuals within each command to ensure compliance and redundancy. The newer version of GTS will automatically email the project manager for each individual item that needs to be inspected and checked into the system at least 1 month prior to the expiration of the inventory due date. The Grant Units is also notified of this upcoming deadline and a follow up email is sent to the project manager again. In addition, on a regular basis, the Grants Unit manager will email the command points of contact reminding them of their Asset Inventory requirement as a follow up to the alerts automatically received from GTS. For the 3 items referenced above, an inventory verification was performed February 25, 2021. While the NYPD was unable to provide confirmation of a biannual inventory between the purchase date (April 2018 and May 2018) and a prior inventory date, we can confirm these assets were inventoried in November 2022. In addition, all assets currently listed in GTS are currently up to date and have been so since the FY2020 Single audit. Because all equipment entries are now being monitored regularly by the Grants Unit, in addition to the individual commands receiving automatic emails instructing them to update their inventory, we do not anticipate any further Inventory Verification issues as long as the period referenced is after February 2021. Anticipated Completion Date March 2023 Person(s) Responsible for Implementation Kristine Ryan Deputy Commissioner, Management and Budget (646) 610-6670