Corrective Action Plans

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

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