Corrective Action Plans

Elementary and Secondary School Emergency Relief – Assistance Listing No. 84.425D, 84.425U Recommendation: Auditor recommends that the District establish and implement procedures to ensure that a physical inventory of equipment is conducted at least once every two years. This should include assigning responsibility for the inventory process, setting a schedule for inventory counts, and ensuring that the results are reconciled with the equipment records. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We will work with the Building and Grounds Director to create a schedule for the inventory process. Name(s) of the contact person(s) responsible for corrective action: Frank Neve Planned completion date for corrective action plan: 06/30/2025. U.S. Department of Agriculture

Management agrees with the recommendation and has already contracted with an asset appraiser to physically inventory the research funded assets. We are also planning to do a full physical inventory of all property in the Spring of 2026 as part of our Facilities and Administrative Rate proposal base year activities.This is expected to be completed prior to the close of FY2025.

Town management concurs with the finding, and while audit staff were still onsite for field work, Town staff implemented and added tracking and documentation information for all federally funded capital assets, to include unique descriptors, Catalog of Federal Domestic Assistance grant number, funding source and amount. In addition, inventory counts for federally funded assets will be conducted and recorded at least once every two years.

Corrective Action Plan: The District has developed and implemented a Federal Funds Manual. Anticipated Corrective Action Plan Completion Date: November 18, 2024 Contact Information: For additional information regarding this finding please contact Blaise Paul, Chief Business & Finance Officer, at 414-768-6140.

Identifying Number: 2024-004 Equipment Management—Material Weakness U.S. Department of Education Passed through Missouri Department of Elementary and Secondary Education Education Stabilization Fund, Assistance Listing No. 84.425C (COVID-19—Governor’s Emergency Education Relief Fund), 84.425D (COVID-19—Elementary and Secondary School Emergency Relief Fund), 84.425U (COVID-19—American Rescue Plan-Elementary and Secondary School Emergency Relief), 84.425W (COVID-19—American Rescue Plan-Elementary and Secondary School Emergency Relief-Homeless Children and Youth) Federal award year 2023-2024 Summary of Finding: Criteria: The Uniform Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance retirements. Also, in accordance with 2 CFR section 200.313(d)(1), 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. In accordance with 2 CFR section 200.313(d)(2), a physical inventory of equipment and property must be taken, and the results reconciled with the property records at least once every two years. Condition: The District’s controls were not operating effectively to reasonably ensure the District had maintained property records with the above required information, and performed the required physical inventory of equipment within the two previous years. As a result, the District did not comply with the compliance requirements for equipment and property. Cause: The District does not have processes and procedures in place related to equipment management, tracking and required physical inventories. Effect or potential effect: The District is not in compliance with federal grant requirements over the tracking and physical inventory of equipment. Improper equipment procedures could result in actions taken by oversight agencies which could impact future funding. Questioned costs: None Context: For all sample selections tested in the major program, there was no process of tagging and tracking equipment purchased with federal funding, nor evidence that any physical inventories had been performed. Identification as a repeat finding, if applicable: Not applicable.   Corrective Action: District personnel do not normally make capital purchases from federal grants. ESSER III was unusual in this regard. Management has prepared a spreadsheet that will be used to track the capital purchases made from ESSER dollars. We will send this spreadsheet to Operations and Academic Services personnel so that they can populate the data. Once this is complete, we will schedule an inventory of these items. Anticipated Completion Date: June 2025 (for the year ending June 30, 2025). Contact Person: Steve Marriott, Controller 816-321-5000 Steve.marriott@nkcschools.org

CORRECTIVE ACTION PLAN Nov 6, 2024 Higher Institute for Arts and Technology (the School) provides its Corrective Action Plan for the fiscal year ended June 30, 2024. FINDING 2024-001 – RECONCILIATION OF PHYSICAL INVENOTRY – Significant Deficiency Planned corrective action: The School through the educational service provider agreement with Entrepreneurial Ventures in Education (EVE) will implement procedures and provide additional training to school staff that are responsible for taking physical inventory to ensure results are reconciled with fixed asset property records maintained by EVE. Responsible officers: Jeffrey Larkins, Director of Finance and Accounting; Javier Dimas, Vice-President of Operations Estimated completion date: May 15, 2025 22

As of October 8, 2024, the Executive Director of Business & Human Resources, Kevin J. Polunci has reached out to Questar III BOCES to ensure the equipment purchased with federal funds is clearly denoted in the report ending June 30, 2025.

Implementation plan of action: The Business Manager will review these requirements with the Account Clerk responsible for tracking fixed assets to ensure that purchases made with federal dollars are recorded in the database with all the necessary information to meet the compliance requirements. In addition, we will establish a process to perform a physical inventory as required every two years. Person Responsible for Implementation: Jodi Birch, Business Manager and Kristie Smith, Account Clerk Anticipated Completion Date: June 30, 2025

Finding 2023-005: Condition 1: The State’s capital asset register reflected no Compact Sector–funded capitalized infrastructure additions since FY 2016, despite completed contracts during 2016 through 2021. The State was unable to provide supporting documentation evidencing capitalizable values, project ownership, or other required details. Conditional 2: Four (4) assets or batches of assets that met the State’s capitalization requirements were not capitalized until corrected through audit adjustments Root Cause Analysis For both conditions there is a lack of internal control monitoring over fixed asset capitalization. Corrective Actions 1. For Condition 1, the State should obtain documentation to support capitalizable values and confirm ownership. 2. For Condition 2, all assets related to health-sector acquisitions, the State should improve coordination between the Department of Health and Human Services and the State Treasury to ensure eligible items are capitalized at requisition or purchase order stage. Responsible Parties For Corrective Action Plan 1: Director of DOTA and Procurement Officer For Corrective Action Plan 2: Director of Health and his administrative officers Director of DOTA, Certification and Procurement officer Timeline Verification of Effectiveness Conduct regular assessments to ensure the implementation of the aforementioned action plans.

FA 2024-001 Improve 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 Agriculture Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: 10.553 - School Breakfast Program 10.555 - National School Lunch Program Federal Award Number: 235GA32N1199 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 COVID-19 - 84.425W - American Rescue Plan Elementary and Secondary School Emergency Relief Fund - Homeless Children and Youth Federal Award Number: S425D200012 (Year: 2020), S425D210012 (Year: 2021) S425U210012 (Year: 2021), S425W210011 (Year: 2021) Questioned Costs: None identified Prior Year Finding: FA 2022-001, FA 2021-001, FA 2020-001, FA 2019-003, FA 2018-002, FA 2017-004 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 Child Nutrition Cluster and Elementary and Secondary School Emergency Relief Fund programs. Corrective Action Plans: Management has strengthened controls over equipment to ensure that the records are complete, accurate and r reflect all required information. We are in the process of developing a physical inventory list of equipment. The inventory listing will have all identifying information such as an item description, an identifying number, the source of funding, the title holder, the acquisition date, the cost, the percentage of federal participation in the project costs, the location of the equipment, the use and condition of the equipment, and any ultimate disposal data for each piece of equipment. A complete physical inventory will be performed each year and reconciled with the equipment listing. Estimated Completion Date: 12/31/2025 Contact Person: Christopher Stephens, Chief Financial Officer Telephone: 229-268-4761 Email: christopher.stephens@dooly.k12.ga.us

Finding 2023-003 Information on the federal program: Subject: Water and Waste Disposal Systems for Rural Communities – Equipment and Real Property Management Federal Agency: U.S. Department of Agriculture Assistance Listing Number: 10.760 Federal Award Number: N/A Pass-Through Entity: N/A Compliance Requirements: Equipment and Real Property Management Audit Finding: Material Weakness, Noncompliance Condition: An effective internal control system was not in place at the District to ensure compliance with requirements related to the grant agreement and the Equipment and Real Property Management compliance requirement. Context: The District did not maintain an updated asset listing that reflects the construction in process balance related to the project funded with federal funds. There was approximately $10.9 million of disbursements from federal funds related to the project as of December 31, 2023. Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The third-party accounting firm will compile a capital asset listing that lists out the District’s capital assets and notes the required information, which will include the federal funding source (if applicable). The capital asset listing will be updated on an annual basis. The Board of Directors will review the capital asset listing. Responsible Party and Timeline for Completion: The third-party accounting firm and the Board of Directors will implement the corrective action plan, which will go into effect immediately.

Maintain documentation of entity-wide physical inventory of capital assets, minimum of every 2 years. Person responsible: Facilities/Transp. Mgr.-Wendy Wells, Finance Director-Collice Martens Timing for Implementation: Fiscal Year 23-24

Finding 2023-002 - Equipment and Real Property Management Responsible Individual: Arlene Dickens, Chief School Financial Officer Corrective Action: All capital expenditures will require documented prior approval from the grantor agency before encumbrance. Property records will be updated and maintained in accordance with 2 CFR 200.313 and 200.439. A physical inventory will be conducted and reconciled at least once every two years. Anticipated Completion Date: October 1, 2025

Finding 2023-003: Establish and maintain effective internal control over the Federal award Plan: We have ensured all policies and procedures have been vetted by an attorney and approved by the River View Board of Trustees and the Claremont Learning Partnership Board of Directors. Moving forward, the Executive Director will ensure that all policies and procedures stay current and are reviewed by the Board annually. FY-22 & FY-23 Audits were completed in tandem, all corrections were made as soon as the issue was identified. Expected Implementation Date: RiverView amended the policy on June 17, 2025, CLP amended the policy on July 3, 2025. Contact: Cathy Pellerin Executive Director, Claremont Learning Partnership 169 Main Street; Claremont, NH 03743 603-287-7120

Finding Number 2023-045 Subject Heading (Financial) or AL no. and program name (Federal) AL #84.425 – EDUCATION STABILIZATION FUND (ESF - AL #84.425D; #84.425U) Planned Corrective Action The Office of Title Services (OTS) has reviewed the inventories in question that were submitted in the FY23 ESEA Grant Performance Review and agree there were several items above a $5000.00 unit cost that were not properly recorded on the inventories reviewed. The expectations for inventory compliance were not followed for two districts. The Office of Title Services (OTS) program director will continue to address the expectations of inventory compliance during the ESEA Grant Performance Review internal training process with the project managers to ensure accuracy during the review process. OTS has included an attachment of the current OTS training presentation that includes several slides of the inventory expectations. • For materials and supply items, the Office of Title Services (OTS) staff will review the district’s inventory procedures for compliance with 2 C.F.R. 200.302(b)(4). • For equipment items ($5,000 later $10,000 or greater unit cost) OTS staff will review the district’s inventory procedures for compliance with the requirements of 2 C.F. R. 200.313 (d)(1) Anticipated Completion Date August 2025 Responsible Contact Person Amber Polach

2023-009 – Equipment and Real Property Management (Significant Deficiency in Internal Controls over Compliance) Recommendation: We recommend the College enhance the design of its control activities and create a tool to assist in tracking and maintaining equipment purchased with federal funds. Additionally, the employees responsible for the inventory should be trained to ensure understanding of the Uniform Guidance requirements relevant to equipment and real property management. Action Taken: The 2022-2023 fiscal year was entirely encompassed by the separation Memorandum of Understanding (MOU) of March 2022 and then the final release settlement in December 2023. It is important to note that Southeast New Mexico College was a newly established independent community college, having formally separated from New Mexico State University (NMSU) as of April 2022. During this transition period, many administrative processes, including federal grant compliance procedures, were in the process of being developed, transitioned, and implemented independently from NMSU systems. As a result, certain policies, procedures, and documentation processes were not yet fully established or operational at the time of the audit. Unfortunately, due to the untimely receipt of the completed audit report, the College did not have the opportunity to review and begin addressing several of the findings until well after the end of the audit period. While the College is committed to corrective action, the delayed delivery of the audit limited the ability to implement corrective measures earlier. The College is working proactively to ensure that these issues are resolved going forward. Corrective Action Taken / Planned: • Policy Development and Revision o The institution will update its property management policies and procedures to comply with 2 CFR §200.313 and §200.311. Updates will address:  Accurate and complete property records, including required data elements (description, serial number, location, use, acquisition cost, federal grant information, etc);  Biennial physical inventory procedures, including reconciliation with property records  Safeguarding and maintenance protocols  Requirements for disposition of federally funded property • Inventory Process Implementation o A full physical inventory of all federally funded equipment and real property will be conducted by August 31, 2025, and discrepancies will be investigated and resolved. • Training o All personnel responsible for managing equipment and real property will be trained on the updated policies, inventory procedures, and compliance requirements. • Monitoring and Oversight: o The institution will implement an internal review process to ensure ongoing compliance with equipment and real property management standards. Monitoring will include:  Periodic spot checks of property records  Documentation of follow-up on any missing or unaccounted for items  Regular reviews to ensure appropriate safeguarding and maintenance of property. • Documentation of Federal Interest o For any real property acquired or improved with federal funds, the institution will ensure proper recording of the federal government’s interest in accordance with federal regulations. Due Date of Completion: August 31, 2025 Responsible Official: Carolyn Kasdorf, Vice President for Business and Finance (or appropriate official), Karla Volpi, Dean of Business and Finance, Rebecca Silva, Director of Finance, Lisa Ryan, Restricted Funds Manager, Inventory Control

Management’s Response/Corrective Action Plan (Unaudited): Management agrees to address the finding in its capital asset tracking schedule. The Organization and its outsourced accountant have discussed the finding and will implement procedures on tracking capital assets funded with federal grants. This tracking will be incorporated to the current capital asset tracking schedule. Planned Completion Date: June 2025 Contact Person Responsible for Correction Action: Adam Courtney

Property and Equipment Management Federal Agency: Various Federal Program Name: Research and Development Cluster Assistance Listing Number: Various Recommendation: We recommend management implement procedures for physical inventory to be taken within a two‐year time frame as well as maintain evidence of assets possession such as photos of the property and equipment. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Led by the Director of Capital Planning and Facilities Management, KSU has hired an inventory specialist to improve physical inventory documentation and maintenance. In addition, The Controller is in the process of reevaluating and designing internal controls surrounding capital and non‐capital inventory in conjunction with the President. Name(s) of the contact person(s) responsible for corrective action: Melissa Hicks – Controller in coordination with Jennifer Linton, Director of Capital Planning and Facilities Management. Planned completion date for corrective action plan: June 30, 2026

Finding No 2023-003 “ALN #20.106 Equipment and Real Property Management” Name of Contact Person(s): Sheryl Sizemore, Comptroller Ida S. De Brum, Accounting Manager Zack A. Diaz, Internal Auditor Alex Tudela, Procurement Officer Corrective Action: CPA agrees with this finding. CPA has implemented Equipment Management Standard Operating Procedures (SOPs) in June 2022 and trained staff involved in Equipment Management in August 2022. Because trainings on the newly developed SOPs were first conducted in August 2022, CPA noted and FAA acknowledged that repeat findings may be found in this audit report. CPA emphasizes that SOP trainings are continuing and mandatory for all of CPA Management, and CPA expects that the SOPs and related training will resolve this issue moving forward. Equipment SOP trainings occur twice per year and will continue indefinitely. In July 2023, CPA issued the inventory and property records to all CPA Department Heads to review, verify and confirm details of each fixed asset and provide additional identifying information for entry. These updates will be submitted to the Procurement Division in August 2023 for verification and entry into the Equipment Management System. Condition 1: CPA will ensure that count sheets are dated to reflect timing of the approval of fixed asset inventory performed. Condition 2: The fixed asset schedule provided to the auditors included a column that listed all contributed fixed assets as funded by the Federal Aviation Administration (FAA). The FAA column was mistakenly entered into the schedule. CPA Accounting verified that the details of all assets that were identified as non-FAA assets indicate funding through other federal or local programs. The fixed asset schedule will go through verification by the Accounting Manager and Comptroller to ensure that only the program assets requested are listed. Condition 3a: CPA will write off the asset from its fixed asset system. Condition 3b: CPA will write off assets 000015, 000040, 000047 as they have been already replaced with an existing asset. For assets 000091, 000589, and 000791: we will create maintenance logs for these assets as well as all assets that require maintenance in the fixed asset system. Condition 3c: CPA will write off the asset from its fixed asset system. Condition 3d: CPA will write off the asset from its fixed asset system and adjust and reclassify for any remaining depreciation still left on the books. CPA has developed the following corrective action plan for this finding: 1. Establish Standard Operating Procedures (SOP) for Equipment Management CPA has established Equipment Management SOPs that were implemented and effective on June 30, 2022. The SOPs detail the equipment management requirements, details, and responsibilities. In addition, the SOPs include an annual mandatory schedule for inventory, disposals, and reconciliation. The Department Heads are reviewing their equipment listings to verify the accuracy of equipment details, provide additional identifying information and confirm existence of all assets listed. The Department Heads will be providing monthly updates to the Procurement Department for entry into the Equipment Management System. 2. Implement Standard Equipment Management Forms Standard procurement forms have been developed to establish additional controls and reviews for all equipment. These standard forms include requirements such as identifying details for all fixed assets. 3. Develop a Training Plan for Equipment Management Procedures CPA developed an Equipment Management training plan that was implemented on June 17, 2022. The training plan includes annual requirements for training on equipment management and compliance requirements. The training is based on the established SOPs and best practices and is mandatory for all staff involved in equipment management. 4. Internal Auditor Position An internal auditor position was created on May 16, 2022 and hired on August 29, 2022. Part of the internal auditor’s responsibilities include reviewing inventory records and equipment management files for compliance. The internal auditor reports directly to the CPA Board of Director and provides monthly reports. The internal auditor monthly reports are used as a tool to identify areas of equipment management non-compliance for immediate correction. Proposed Completion Date: June 30, 2025

Management Response/Corrective Action Plan: A formal procedure will be drafted between the city and school to ensure the city is made aware of any assets that are federally funded so they can be designated as such in Munis. The school department will continue to provide the annual asset list to the city and will now include funding source notations for each asset.

Management Response and Corrective Action Plan Finding 2023-001 Federal Agency: United States Department of Health and Human Services Program Name: Research and Development (R&D) Assistance Listing Number: Various Responsible Individual: Jarod Kohr, Director, Research Finance Contact Information: jkohr@bidmc.harvard.edu; 617-667-4136 A review of the Beth Israel Deaconess Medical Center’s (BIDMC) property records maintenance revealed incomplete biennial physical inventory and incomplete tagging of new equipment purchased on federal awards. Management agrees with the recommendation and will update the asset tagging system to support completing the biennial inventory and resume tagging new equipment according to established policy. Corrective Action Plan: Tagging System • Director of Operations and Director of Research Computing will complete work with vendor to update scanning devices and software (complete) • Director of Operations will develop plan to complete inventory and new tagging (complete) Tagging New Equipment • Complete update to equipment list including identifying new (untagged) equipment (complete) • Tag all new items received (complete) • Maintain list of new pending equipment to be tagged Physical Inventory • Establish inventory schedule with clear notification to Research community • Identify all equipment on current inventory • Identify any equipment in lab spaces not on current inventory and tag if appropriate • Reconcile all inventory including any disposition discrepancies Expected Completion Date: June 30, 2024 Status of Completion: In Process

FINDING 2023 - 003 Finding Subject: Water and Waste Disposal System for Rural Communities - Equipment Summary of Finding: Material Weakness, Other Maatters Contact Person Responsible for Corrective Action: Pamela Whitener Contact Phone Number and Email Address: 765-981-4591 clerk@lafontaine.in.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We have purchased the Silversmith Program to track Capital Assets. All equipment purchased with federal money will be listed in the program and reviewed yearly. Anticipated Completion Date: January 2025

Corrective Action Planned: Capital Assets will be entered into BusinessPlus in a timely manner which is within 30 days of physical receipt of the asset. BusinessPlus was adjusted to accept the source of funding information and account code used. This will be updated in the policies and procedures. Name(s) of Contact Person(s) Responsible for Corrective Action: Chief Financial Officer, Facilities and Maintenance Director and General Accounting Manager Anticipated Completion Date: April 2025

Views of responsible officials and planned corrective actions: Management agrees with this finding and will put procedures in place to perform a physical inventory of property at least once every two years. See 2023-004 for management’s detailed action plan, timeline, and the responsible parties for all Education Stabilization Fund findings.

View of responsible officials and planned corrective actions: Management agrees with this finding and will put procedures in place to maintain adequate property records. See 2023-004 for management’s detailed action plan, timeline, and the responsible parties for all Education Stabilization Fund findings.