Corrective Action Plans

Finding No. 2022-010 Department(s) New York City Police Department Program(s) Assistance Listing Number 16.922, Equitable Sharing Program Corrective Action(s) The NYPD has, and continues to, implement policies and procedures to ensure that there are multiple levels of inventory asset verification and validation completed in accordance with Federal requirements. To that end, the NYPD is in the midst of discussions to utilize the NYPD?s Grants Unit?s Grants Tracking System (GTS) for equipment purchased with Asset Forfeiture funds. Currently, the GTS only tracks the inventory for a subset of equipment purchased with federal grant funding. While these discussions have not yet been finalized, the GTS has the ability to provide the type of robust inventory oversight necessary. This includes features such as an automatic email to the command points of contact (POC) for each item that needs to be inspected and checked into the system at least one month prior to the expiration of the inventory due date. If this solution is not deemed feasible, however, the NYPD will look to obtain a system exclusively for Asset Forfeiture item inventorying purposes. In addition, on a regular basis, the Management and Budget Analysis Unit will email the command POCs reminding them of their Asset Forfeiture Inventory responsibilities. For the four items referenced above, inventory verifications were indeed performed; however, the NYPD was unable to provide tangible date-specific documentation. As such, a standardized protocol is being developed for use by all commands with Asset Forfeiture equipment items to ensure that this documentation will exist going forward, and will be distributed upon any new Asset Forfeiture equipment purchases. In addition, this documentation will be the basis for updates/entries into the GTS or any other future system. Once the standardized protocol and systems are fully established, we do not anticipate any further Inventory Verification issues as long as the period referenced is after implementation. Anticipated Completion Date Spring/Summer 2023 Person(s) Responsible for Implementation Kristine Ryan Deputy Commissioner, Management and Budget (646) 610-6670

Finding No. 2022-009 Department(s) New York City Department of Investigation Program(s) Assistance Listing Number 16.922, Equitable Sharing Program Corrective Action(s) Based on the recommendations outlined in the audit report, we have developed the following corrective action plan to address the deficiencies and improve our equipment and real property management compliance requirements. The following steps will be taken: ? Strengthen Controls over the Inventory Process: We will develop and implement additional controls over the inventory process to ensure that equipment dispositions are updated in the equipment records, inventories performed are reconciled back to equipment records, and biennial inventory counts are consistently performed over all equipment within the required timeframe. ? Develop and Implement a Standard Operating Procedure: We will develop and implement a standard operating procedure that outlines the process for conducting physical inventory counts, reconciling the inventory records with the equipment records, and documenting the review and approval of each inventory performed. ? Training for Personnel: We will provide training to all personnel involved in the equipment and real property management process, including property officers and program managers, to ensure they are aware of the new controls and standard operating procedure, and understand their roles and responsibilities related to compliance requirements. ? Continuous Monitoring: We will implement a continuous monitoring program to ensure that the new controls and procedures are being followed, and to identify any areas for improvement. The agency is actively pursuing a centralized inventory management system to improve the effectiveness of inventory management. These corrective actions will help to ensure that federally funded equipment is accurately recorded on inventory records, and that inventory is not misplaced, misappropriated, or otherwise disposed outside of the requirements of federal guidelines. We appreciate the opportunity to address the audit findings, and we are committed to implementing these corrective actions. Anticipated Completion Date September 2023 Person(s) Responsible for Implementation Caspar Barrow Director of Finance (212) 825-0666 Orane Gordon Internal Auditor (212) 825-0123

11-012-003C-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 all equipment purchased with federal funds as per 2 CFR section 200.313(d)(1) for equipment purchased with Education Stabilization Funding. Plan: The District will assign an administrative employee with knowledge of applicable federal grant expenditures to maintain a complete list of property records that meets the requirements of 2 CFR section 200.313(d)(1). Anticipated Date of Completion: 06/30/2023 Name of Contact Person: Jill Rogers Management Response: Management will implement the corrective action plan for the year ended June 30, 2023.

The District will enhance inventory records and procedures to ensure that all property items are properly recorded in order to maintain accountability of items purchased with federal funds. Additionally, the District will consult with the grantor agency regarding the allowability of the questioned costs.

The Managing Director of Operations will compile all current inventories into one document that includes all required identifiers. We will research, invest and implement an asset management inventory system to accelerate this process and ensure the efficiency of a sustainable system moving forward. The Executive Director will perform inventory audits, as needed, verifying, and updating the data contained in the Fixed Asset Tracking List. The Fixed Asset Tracking List will be reconciled to the General Ledger by the Director of Finance. The Finance Working Group will also work in partnership with the Executive Director and Director of Finance to review our current capitalization policy and make recommendations to begin implementation for FY24.

Finding 2022-002 Equipment and Real Property Management Significant Deficiency in Internal Control over Compliance and Compliance Federal Agency Name: Department of Education and Passed through State of South Dakota Department of Education Program Name: COVID-19 Education Stabilization Fund - Governor's Emergency Education Relief (GEER) Fund Federal Financial Assistance Listing #84.425C Finding Summary: In the sample of expenditures selected for testing, no support to substantiate a physical inventory of federal-funded equipment was performed within the last two years. In addition, Federal-funded equipment is not distinguished separately from non-federal-funded equipment within the Club's fixed asset listing. Responsible Individuals: Jody Hernandez, Chief Executive Officer; Darcie Bien, Chief Financial Officer Corrective Action Plan: A physical inventory of federally-funded equipment will be completed annually to assure that all federally funded equipment and real property is accounted for. All federally-funded assets are now identified on the fixed asset listing. Anticipated Completion Date: June 30, 2023

03-026-2020-26 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 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: Travis Portz Management Response: Management will implement the corrective action plan for the year ended June 30, 2023.

The fever scanner had not been opened at the time of the equipment information submission from the facilities director?s secretary. The serial number had been submitted for the laptop that was purchased from a separate vendor and the cost was well below the capital assets threshold. Since fever scanners were no longer in use, the laptop had been given to an employee and could not be located. The fever scanners are all in storage but could not be identified because the serial number was for the laptop. The District will try and maintain proper records for all equipment. Misti Flowers, District Treasurer June 1, 2023 Action Started June 30, 2023 Action completed

RESPONSE: The following is Food Service Director Deanna Gilbert?s response: Not going in and adding the addition meals until the end of the month to keep from the meals being added twice. The Management company director handed out the right completed meals but the paperwork did not back up the components in the meal. Double check all paperwork to make sure the meal components are all listed on the Production record. Deanna Gilbert, Child Nutrition Director June 1, 2023 Action started June 30, 2023 Action completed

FINDINGS?FEDERAL AWARDS FINDINGS AND QUESTIONED COSTS 2022-004: Equipment/Real Property Management Program: Education Stabilization Fund CFDA Number: 84.425D Federal Agency: U.S. Department of Education Pass-Through Agency: Arizona Department of Education Grantor Number: 21FESSII-111389-01A Questioned Costs: $-0- Type of Finding: Noncompliance, significant deficiency Compliance Requirement: F. Equipment/Real Property Management Condition/Context: The District did not properly update its capital assets listing to include equipment purchased under the ESSER program. Criteria: The District must follow 2 CFR sections 200.313 which requires that: Property records must be maintained that include a description of the property, a serial number or another identification number, and the source of funding for the property (including the federal award identification number), who holds the 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 any ultimate disposition data including the date of disposal and sales price of the property. Repeat Finding: This finding is a repeat of a finding in the immediately prior year. The prior year finding number was 2021-006. Action planned in response to finding: The District will ensure the capital assets listing is properly updated for all assets and stewardship items in the upcoming fiscal year. Planned completion date for the corrective action plan: For the period ending June 30, 2023. Name of the contact person responsible for corrective action: Judy James, Business Manager

EDSD24722-001 Contact Person: Andrew Hill, Business Manager Completion Date: January 1, 2023 and on going Corrective Action: The District will more closely monitor the activities of personnel operating fund-raising and donation-based ventures to diminish or completely eliminate the opportunity of fraud. The District will further emphasize training with individuals involved in receipting and depositing monies along with a review of proper procedures for intake of funds. Activity Account and Fundraising training will continue to be made mandatory for those individuals that are involved in receipting and depositing monies and greater emphasis will be placed on the importance of attendance at these mandatory meetings.

MATERIAL WEAKNESS IN INTERNAL CONTROL OVER COMPLIANCE AND MATERIAL NONCOMPLIANCE ? U.S. DEPARTMENT OF EDUCATION ? PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, COVID-19 ? EDUCATION STABILIZATION FUND, FEDERAL ALN 84.425 2022-002 Internal Control Over Compliance and Material Noncompliance With Equipment and Real Property Management Requirements Finding Summary 2 CFR ? 200.313 (c)(1) and (d)(1) requires that Aurora Charter School (the School) obtain approval from the federal funding agency or pass-through agency prior to the purchase of equipment with federal funding. During our audit, we noted the School did not have sufficient controls in place within the COVID-19 ? Education Stabilization Fund federal program to assure compliance with federal equipment and real property management requirements, resulting in material noncompliance. Corrective Action Plan Actions Planned ? This condition and the resulting material 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 School?s adopted internal capitalization threshold being lower than the federal threshold. The School 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 ? Matthew Cisewski, Executive Director. Planned Completion Date ? June 30, 2023. Disagreement With or Explanation of Finding ? The School agrees with this finding. Plan to Monitor ? The School?s Executive Director, Matthew Cisewski, 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 School to ensure future compliance with federal equipment and real property management requirements.

Views of Responsible Officials: During an audit process of our federal fund expenditures on October 19,2022. The auditors found our district is not keeping records to specifically track property and equipment acquired with Federal Awards, nor is an inventory performed as required. On October 20, 2022 and October 21, 2022 an inventory was developed to include all capital projects and a notation for items purchased with Federal Awards. The spreadsheet was created by Superintendent Tara Lewis and with the document shared with Bookkeeper Julie Cragen. Previous to the audit finding our district used a video inventory to capture visual evidence of items purchased for insurance purposes. Additionally, invoices were reviewed from Stewart Refrigeration and found that the invoices did not breakdown the bill for supplies and wages/labor. In the bidding process the Prevailing Wage order was used, but it is not documented on the bid nor the invoice. As of December 1, 2022 we will insure all bids and invoices are specific when prevailing wage is required.

2022-002 Equipment and Real Property Management Contact/s: Luther Lau, CFO (202) 462-5282 Mark Mackey, Controller (202) 298-5942 Completion Date: February 2023 Corrective Action: AUI maintains systems of internal controls of physical property to safeguard government assets from the risk of theft or loss. During the height of the COVID pandemic, the ALMA Observatory was necessarily staffed with a reduced number of personnel as a result of heightened restrictions on travel and cohabitation. The reduced staff ? in combination with the remote location of the Observatory ? resulted in the theft of a box of copper mesh at the Multicancha construction site. This copper mesh had a purchase price of approximately $3,200. Despite the theft being an isolated incident, AUI immediately reviewed its physical controls in place and took action to further improve monitoring and security at the site. Additional measures put in place include the following: ? During holidays and in-between shifts, valuable material was stored in a local locked warehouse. ? It was requested to ALMA to increase the frequency of guards patrolling. This is particularly important during the time the construction site is unoccupied for holidays or in-between shifts and nights. ? In Chile, the transportation of good requires an official paper called "Guia de despacho", which is a Chilean-IRS-certified document that demonstrates ownership of goods. Failing to show this paper to a local police officer may result in the detention of the driver under the alleged crime of theft. Since the incident, the Observatory is requesting this paper for all vehicles leaving the site carrying visible items. A visual inspection is performed to corroborate the paper and the cargo. ? A project to install CCTV cameras at the entrance and common areas is being developed. This is expected to mitigate risk of theft as well as having available records of events, if needed. The above internal controls over physical property, in combination with the controls already in place prior to the incident, have mitigated the risk of this type of occurrence from happening in the future.

The Controller?s Office is amending our capital equipment policy to include the escalation for violations of noncompliance to Deans and/or Vice Presidents. In addition, we are improving our processes and internal controls to ensure additions, transfers and disposals are appropriately recorded in Workday. We continue to improve our utilization of Workday Financials to ensure timely updates are made to the property records and are exploring additional automation tools. These changes are expected to be in place by December 2023. Tara Thomason, Controller and Assistance Vice President, is responsible for addressing the above items by December 2023.

Corrective Action: Management will enhance and enforce existing policies and procedures regarding Equipment and Real Property Management to segregate equipment purchased by state, local, and federal grants. Additionally, the CAPEx Committee will provide oversight on fixed asset expenditures purchased through government grants so accounting can identify and reconcile to its fixed asset schedule. Name of Responsible Individual(s): Jason Brenier, CFO Anticipated Completion Date: January 2024

FA 2022-002 Strengthen Controls over Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principle Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: COVID-19 - 84.425D - Elementary and Secondary School Emergency Relief Fund COVID-19 - 84.425U - American Rescue Plan Elementary and Secondary School Emergency Relief Fund Federal Awars Numbers: S425D210012 (Year: 2021), S425U2120012 (Year: 2021) Questioner Costs: $193,631 Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over expenditures as it relates to the Elementary and Secondary School Emergency Relief Fund program. Corrective Action Plans: Although the School District does not agree with this finding, management will continue to ensure federal fund program guidelines and Board-approved policies and procedures are followed. Estimated Completion Date: Ongoing Contact Person: Kyla M. Milton, Finance Director Telephone: 229-868-5661 Email: kmilton@telfairschools.org

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

The Town will be updating the Town's procedures and policies to incorporate the requirements of Part 200 of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. Responsible Individual: Patricia Chaffee, Executive Assistant. Anticipated Completion Date: January 30, 2024.

FA 2022-001 Strengthen Controls over Equipment Compliance Requirement: Equipment and Real Property Management Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: COVID-19 - 84.425D - Elementary and Secondary School Emergency Relief Fund COVID-19 - 84.425U - American Rescue Plan Elementary and Secondary School Emergency Relief Fund Federal Award Number: S425D210012 (Year: 2021), S425U2120012 (Year: 2021) Questioner Costs: None Identified Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over equipment and real property management as it relates to the Elementary and Secondary School Emergency Relief Fund program. Corrective Action Plans: The Superintendent and CFO for Ben Hill County Schools will assign a lead person to be responsible for ESSER requirements and to assure procedures over real property and equipment are being met. Estimated Completion Date: June 30, 2024 Contact Person: Natalie King, CFO Telephone: 229-409-5500 x 5510 Email: natalie.king@benhillschools.org

The YWCA will implement inventory policy and procedures to verify the existence and condition of assets acquired with federal awards at least every two years.

REFERENCE # 2022-002 EQUIPMENT AND REAL PROPERTY MANAGEMENT – SIGNIFICANT DEFICIENCY- NONCOMPLIANCE Program Name/ALN Emergency Solution Grant Program (ALN # 14.231) Compliance Requirements- Equipment Management -- Grants and Cooperative Agreements Equipment means tangible personal property, including information technology systems, having a useful life of more than one year and a per-unit acquisition cost which equals or exceeds the lesser of the capitalization level established by the non-federal entity for financial statement purposes or $5,000 (2 CFR section 200.1). Title to equipment acquired by a non-federal entity under grants and cooperative agreements vests in the non-federal entity subject to certain obligations and conditions (2 CFR section 200.313(a)). Non-federal entities other than states must follow 2 CFR sections 200.313(c) through (e) which require that: (b) Property records must be maintained that include a description of the property, 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, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property (2 CFR section 200.313(d)(1)). (c) A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years (2 CFR section 200.313(d)(2)). Condition/Context: Based on our review of the Equipment and Real Property Management compliance requirements, we noted that the Division has written policies regarding Equipment and Real property management. We noted that, Division’s property records did not include all required elements as required by (2 CFR section 200.313(d)(1)). We also noted that, physical inventory of the property was not performed and thus the results were not reconciled with the property records at least once every two years (2 CFR section 200.313(d)(2)). Questioned Costs: Cannot be determined Recommendation: We recommend that the Division must: • include a description of the property, 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, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property. • A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years. Corrective Action Plan: Divisional Headquarters and the local units will include all relevant information on the master vehicle list and take a physical inventory at leas once every two years. Step 1 Action Date: Ongoing Final Implementation Date: 12/31/2023 Name and Phone # Of Person Responsible for Implementation: Jeanne Stromberg, Major, Divisional Finance Secretary (916) 563-3710

The management of the Board was notified of the error and made the adjusting entries to correct the financial statements. The Technology Coordinator and CSFO will review expenditures for non-capitalized equipment more carefully.

The District has contracted with a 3rd party to complete a full inventory of the District’s assets. Regular updates to this inventory will now be completed on an annual basis. Anticipated Completion Date: June 30, 2024 Responsible Contact Person: Lee Elliott, Treasurer

Agency: National Center for the Advancement of STEM Education, Inc. (nCASE) Person Responsible for Corrective Action: Name: Nancy Priselac Title: Executive Director Anticipated Completion Date: December 8, 2023 Response to Finding: Management concurs with audit recommendation. Correction Action to be Taken: nCASE has written policies and procedures that detail how management is to review and approve documentation relating to payroll and how reports are created that confirm charges are accurate, allowable, and properly allocated as well as allow for clear comparisons to estimates. Management created timekeeping documents to track employee labor, time and effort. nCASE’s accounting system matches charges listed to documentation used to collect and record time and effort by employees and apply designations to its respective project/label. The system can track direct, indirect, and fringe benefit designations. Accounting data now allows management to create clear reports on payroll. nCASE has implemented documentation that allows employees to track time and labor in detail of project. Management has written policies and procedures that direct employees on how to record time and labor. DoD has reviewed the matters covered in the audit report thoroughly, and the grant was closed out without any repayment of funds to DoD. Upon subsequent review and reconciliation, amounts were not overcharged.