Corrective Action Plans

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.

Management agrees with finding 2021-002 and will implement internal control procedures to perform inventory inspections of federally funded equipment and reconcile the results of the inspections to our equipment listing on a bi-annual basis. We will also implement procedures to add physical tags to federally funded equipment. This inventory will be performed by Storefront’s Technology Supervisor and reported back to the Director of Operations and Financial Consultant for review.

The Authority recognize the importance of maintaining accurate and complete property records for fixed assets purchased with federal funding. A complete fixed asset inventory was conducted in 2023 and is now performed annually. In addition, the integration of the fixed asset system will provide a listing of federally funded assets. System testing is ongoing, with implementation planned for Q2 2026.

Persons responsible for corrective action: Bob Harmon, Superintendent Corrective Action: For a significant portion of the 2021 fiscal year the Quileute Tribe implemented an emergency order as a result of the COVID-19 pandemic. The School was subject to this emergency order and operations were limited to essential activities. The taking of physical inventories was not considered essential. Training relating to the Federal physical inventory requirements will be provided. A physical inventory will be completed in the 2024-2025 fiscal year. Implementation date: June 30, 2025

Finding No.: 2021-018 AL Program: 15.875 - Economic, Social, and Political Development of the Territories Area: Equipment and Real Property Management Questioned Costs: $0 Contact Person(s): Nerissa Benavente Karakaya, CIP COTR Corrective Action Plan: Condition 1: The Division of Procurement Services agrees with this finding. The Division of Procurement Services, Property Management will conduct inventories differently, persons accountable for property will actually perform the Annual Physical Inventory of property under their control based upon printouts furnished by PS - Property Management. Condition 2: The Division of Procurement Services agrees with this finding. A property listing has always been provided to the Agency by Property Management. However, information such as the federal award identification number, source of property, who holds title, percentage of federal participation in the cost of the property, and use of the property relies solely on the Agency. Condition 3: The Division of Procurement Services disagrees with this finding The Division of Procurement Services, Property Management wasn't informed of this audit parameter. For FY2021 number of Transactions/Units processed was 4970 units and the dollar value is $9,526,239. Proposed Completion Date: Ongoing

Recommendation: We recommend the College implement policies and procedures to ensure all property and equipment purchased with federal funds includes such information in the property records to comply with the requirement. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The College has begun to explore the Asset Module in the Jenzabar platform, with the goal that Procurement is the first stage of our property tracking. Work continues to be a challenge in this area as we are short staffed. The Business Office Staff will continue to work with the Purchasing staff to identify how best to proceed with this requirement. The College currently has Policies that speak to Assets and the recording of such. The College will strengthen the specifics of what an Asset listing is to include. Name of the contact person responsible for corrective action: Raquel Vigil, Chief Financial Officer, Clarissa Salhus, Finance Manager, Charles Roberts, Purchasing Manager, and Paul Roberts, Fiscal Technician/Receiving Planned completion date for corrective action plan: March 31, 2025

2021-007 – Equipment and Real Property Management Corrective Action: CBNHC will implement the following corrective actions: • CBNHC will immediately conduct a physical inventory of all items listed on its fixed asset lists. • Once a physical inventory has been taken, CBNHC will create an effective property record which includes the description of the property, a CBNHC serial number, the funding source for the acquisition of the property (including the CDFA number), and the relevant title information, acquisition date and cost. • CBNHC will thereafter assign department managers responsible for the custodianship of the said equipment/property. • At the end of each fiscal year, CBNHC will conduct a physical inventory and maintain evidence in its files. Person Responsible: The following individuals will be responsible for the above corrective action plan: • Interim Finance Director (Volelle Zamora) – Is responsible for ensuring the completion of the physical inventory on an annual basis. • Accounting Supervisor (Candyce Guerro) – Is responsible for coordinating the custodial assignment of the CBNHC’s property and equipment. • Accounting Technician (Charlotte Sandoval) – Is responsible for scheduling and performing the physical inventory inspection. Completion Date: CBNHC will perform its physical inventory immediately, with completion by March 31, 2024. Thereafter, the annual inventory will be performed annually before the last day of the calendar year.

We will work the federal government to obtain retroactive approval of the bus purchases as of July 1, 2021. Additionally, going forward any equipment purchases will be reviewed to ensure compliance with all applicable federal equipment pre and post procurement requirements for inventory and maintenance of equipment. See anticipated timeline of the procedures below.

Finding No.: 2020-012 CFDA Program: 93.323 Epidemiology and Laboratory Capacity for Infectious Diseases Area: Equipment and Real Property Management Questioned Costs: Undeterminable Contact Person(s): Director of Procurement and Supply and Chief Financial Officer Corrective Action Plan: CHCC concurs with the findings. CHCC will update its Capital Assets policy to comply with the requirements of 2 CFR 200.313. Furthermore, CHCC will ensure that there is a clear crosswalk between the Preventive Maintenance Record with our Facilities Department and the Capital Assets listing that is revised pursuant to the requirements of 2 CFR 200.313. CHCC would like to clarify that although the documentation fell short of the Uniform Guidance documentation, all the physical existence and working conditions were verifiable during the audit. Proposed Completion Date: 09/30/2026

Finding No.: 2020-007 CFDA Program: 93.243 Substance Abuse and Mental Health Services Administration Area: Equipment and Real Property Management Questioned Costs: Undeterminable Contact Person(s): Director of Procurement and Supply and Chief Financial Officer Corrective Action Plan: CHCC concurs with the findings. CHCC will update its Capital Assets policy to comply with the requirements of 2 CFR 200.313. Furthermore, CHCC will ensure that there is a clear crosswalk between the Preventive Maintenance Record with our Facilities Department and the Capital Assets listing that is revised pursuant to the requirements of 2 CFR 200.313. CHCC would like to clarify that although the documentation fell short of the Uniform Guidance documentation, all the physical existence and working conditions were verifiable during the audit. Proposed Completion Date: 09/30/2026

Finding No.: 2020-004 CFDA Program: 15.875 Economic, Social, and Political Development of the Territories Area: Equipment and Real Property Management Questioned Costs: Undeterminable Contact Person(s): Director of Procurement and Supply and Chief Financial Officer Corrective Action Plan: CHCC concurs with the findings. CHCC will update its Capital Assets policy to comply with the requirements of 2 CFR 200.313. Furthermore, CHCC will ensure that there is a clear crosswalk between the Preventive Maintenance Record with our Facilities Department and the Capital Assets listing that is revised pursuant to the requirements of 2 CFR 200.313. CHCC would like to clarify that although the documentation fell short of the Uniform Guidance documentation, all the physical existence and working conditions were verifiable during the audit.