Corrective Action Plans

FINDING 2023-011 Finding Subject: Education Stabilization Fund - Reporting Summary of Finding: During the audit period the School Corporation submitted two ESSER I reports, two ESSER II reports, and two ESSER III reports, for a total of six reports. The annual data reports were compiled, prepared, and submitted by the Director of Curriculum without oversight by another individual. All six of the submitted reports were selected for testing. One of the reports, ESSER II, Year 2; was not supported by the School Corporation's records. The School Corporation had expenditures of $583,415 from the ESSER II grant which was not included in this report. Contact Person Responsible for Corrective Action: Drew Cooper, Business Manager Contact Phone Number and Email Address: 765-425-7889 dcooper@shenandoah.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Business Manager and Director of Curriculum will review the annual data reports together before submittal. Anticipated Completion Date: September 30, 2024􀀃

Plan of Action: To correct deficiencies in the preparation and submission of the SF-425 Federal Financial Report, the organization has established SOP F1.03: Submission and Recordkeeping of Federal Financial Reports (SF-425). This procedure outlines the steps for accurately completing the SF-425 using verified financial data, submitting it through the appropriate federal systems by required deadlines, and maintaining supporting documentation in compliance with federal recordkeeping standards. It applies to all staff involved in financial reporting on federally funded grants.

Finding Number: 2023-002 Planned Corrective Action: The Chief Financial Administrator will ensure all ARPA expenditures are included on the Project and Expenditure Reports. Anticipated Completion Date: March 31, 2025 Responsible Contact Person: Ben Cowdery, Chief Financial Administrator

2023‐009 Reporting Annual Project and Expenditures Report (Material Weakness): The City did complete the Project and Expenditures Report but just not timely as a result of staff turnover during the actual fiscal year. Since taking office in fiscal year 2024, the current Finance Director has prioritized compliance with federal reporting requirements. As of fiscal year 2025, all required project and expenditures reporting has been completed and submitted in accordance with U.S. Department of Treasury guidelines. To prevent future occurrences, the Finance Department has implemented internal controls ensuring multiple staff members are responsible for federal reporting. Specifically, both the Finance Director and the Financial Analyst now share the responsibility and authority to complete and submit these annual reports. This new process ensures continuity in reporting, even in the event of staff turnover, and strengthens the City’s commitment to compliance with federal funding requirements. In addition, The City’s Procurement officer now maintains responsibility for grants from award to reversion date. A tracking file is maintained for all active grants at the point it is awarded, expended, and reimbursement received to ensure this process is properly managed. Additionally, the Finance Director oversees this responsibility so there are now multiple controls to ensure timely completion.

The Department has ramped up recruiting efforts by advertising positions on external websites such as indeed. The accounting department has recently increased the wages of existing staff and the starting wages of all positions in an effort to attract and retain qualified staff.

Finding Number: 2023-010 Planned Corrective Action: The Treasurer will use the district’s general ledger to complete Final Expenditure Reports. The Treasurer will also reconcile the General Ledger Budget for each individual grant to the CCIP budget. This process will assure accurate data is provided. Anticipated Completion Date: September 30, 2025 Responsible Contact Person: Ashley Miller

This was an oversight and has been corrected.

FINDING 2023 - 004 Finding Subject: Water and Waste Disposal System for Rural Communities - Reporting Summary of Finding: Material Weakness, Modified Opinion 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 were of the understanding that Commonwealth filed these reports. Going forward the Clerk will submit the reports after review by the Deputy-Clerk and the Town Council. Anticipated Completion Date: January 2025

We concur with the finding and understand the importance of establishing appropriate internal controls. Staff was aware of this condition prior to the beginning of the audit process and, therefore, acquired a consultant to prepare the Project and Expenditure Reports for review prior to submission.

Views of Responsible Officials and Planned Corrective Actions The Grants Administrator and the Finance Department will work closely to compare all expenditures incurred by quarter to the expenditures as reported to the grantor in the quarterly reports. The Grants Administrator and Finance Department have been working to make any corrections as needed for reporting purposes and to address the timing and presentation issues of expenditures as incurred versus as reported. Going forward, the Grants Administrator will be more involved in communicating with the Finance Department, at a minimum on a monthly basis, as related to the reporting of expenditures that are being funded by federal, state, and local awards.

The position of Grants Coordinator has been created and filled to handle grants management functions which will ensure proper quarter end dates and expenditures appropriate for the period are reported. Under the new process, the Grant Coordinator collaborates with the Construction Financial Administrator to complete forms which are then reviewed with the Director of Grants and CFO prior to submission.

Personnel changes, including the introduction and departure of a new Director of Grants position, resulted in vulnerabilities in the College’s master calendar strategy, leading to missed deadlines in isolated and unique circumstances. To mitigate this situation, the College will implement a new master calendar policy that includes cross-checks to ensure that critical deadlines are met and to provide better oversight of key dates. In addition, we will create a backup resource who will be granted access to Grant Solutions system. In addition, the College will seek written documentation to any amendments related to filing deadlines. Patrick Grimes is the individual responsible for oversight of this corrective action plan.

The Municipality established procedures to submit the required report on time.

FINDING 2023-001 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance, and Procurement and Suspension and Debarment Summary of Finding: (copied from SBOA Findings document provided) The Allen County Department of Health (Department of Health), a department within Allen County, was awarded the Health Issues and Challenges grant through the Indiana Department of Health financed through the American Rescue Plan Act (ARPA) for the purpose of funding programs that focus on the improvement of chronic disease, specifically, elevated blood lead level reduction. The Health Issues and Challenges grant is a reimbursable grant, whereby the County received reimbursement on a percase basis at a stated rate for Case Management and Environmental Investigation activities performed. The Department of Health received federal receipts related to the grant in the amount of $130,479 during 2023. As part of sound management of the Federal award, the Department of Health was responsible for implementing a system of internal control that would ensure compliance with the applicable requirements. The Department of Health did not properly design or implement such a system. Receipts of the program were adequately identified through the use of an account number within the County Health Fund (285) in the Allen County's ledger (ledger) which was unique to the Health Issues and Challenges grant receipts. However, the ledger did not adequately identify the expenditures of the grant program within the County Health Fund. Through inquiry with the Department of Health employees and review of unitprepared support of grant expenditures, we determined expenditures were made with grant funds during the audit period, however, we were unable to distinguish between the expenditures of the Health Issues and Challenges grant and all other activities of the Department of Health in the County Health Fund. Due to the lack of separate identification of expenditures in the financial records, we were not able to establish a population from which to audit the Health Issues and Challenges grant for compliance with the following compliance requirements of the program: 􀁸 Activities Allowed or Unallowed 􀁸 Allowable Costs/Cost Principles 􀁸 Period of Performance 􀁸 Procurement and Suspension and Debarment As such, the full award amount of $130,479, as reported on the Schedule of Expenditures of Federal Awards, was determined to be questioned costs. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Recommendation: We recommend that management of the Health Department establish a system of internal controls to ensure that grant award funds are adequately accounted for and tracked in such a manner as to determine the activity, receipts and disbursement, associated with the grant. ………………………… Contact Person Responsible for Corrective Action: JENNIFER MILLER (Finance Director) Contact Phone Number and Email Address: 260-449-7358 (Jennifer.miller@allencounty.us) Views of Responsible Officials: We concur with the finding Explanation and Reasons for Disagreement: N/A Description of Corrective Action Plan: When we were informed of the outcomes of the SBOA audit and the subsequent needs for a corrective action plan (CAP) relative to their findings, we moved quickly to begin the development of the CAP. We feel this finding/issue could be easily remedied by following our normal procedure for grants, whereby we develop a new fund, craft a Fund Ordinance for approval by the Allen County Commissioners to establish said new fund, and then subsequently track all expenditures and reimbursements in the separate fund vs. utilizing a line item for deposits in the main Health Fund as was done with this grant (which lacked the ability to denote exact salary expenditures and such next to each payment as it was all done within the larger fund for all staff and expenses. We were not aware of this need. THE PLAN (which will be added as a new “Grants” section in our existing Finance Internal Controls policies): For all grants (reimbursable or deliverables-based), once a contract is near completion or upon execution, a separate fund will be created through development and approval of a local fund ordinance. All expenditures allowed by said grant and all reimbursements received by the grant funder will be tracked solely and only within the separate grant fund that is tied to the signed contract from the funder. If there are staff payments for salaries or benefits being reimbursed by a grant, we will ensure that: (1) the hours/minutes per staff member per pay period for all work associated with these grant duties are tracked appropriately so as to ensure we are invoicing the grant funder for the exact and accurate work hours (regardless of whether or not the grant contract specifies this be tracked or reimbursed per minute/hour, as most do not require this); and (2) these amounts will be noted alongside the expenditures in the grant fund for clarity upon invoicing or auditing. Anticipated Completion Date: We will follow this practice for any new grants accepted by the Allen County Department of Health effective 9/17/2024. This is the standard practice for most grants we have accepted, and therefore, we will not vary from this practice in the future even if given permission to do so.

Finding 2023-006 – Education Stabilization Fund – Reporting Contact Person Responsible for Corrective Action: Matthew Parkinson, CFO Contact Phone Number: 317-869-4364 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: MSD Warren will submit a revised ESSER data report to DOE. Anticipated Completion Date: Completed as of the date of this report.

The Mental Health and Recovery Board of Portage County will submit program final expenditures in the GFMS system within the grant close-out reporting period.

CONDITION: The District did not properly record its federal program expenditures for the ESSER and ARP ESER federal grant programs using the various funding source expenditure codes as prescribed by the Chart of Accounts for PA Local Educational Agencies maintained by the PA Office of the Budget, Office of Comptroller Operations and well as Section 2 CFR 200.302(a) of the Uniform Guidance. CRITERIA: The financial management system of the District must provide for 1) identification in it’s accounts, of all Federal awards received and expended and the Federal programs under which they were received, and 2) accurate, current and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in sections 200.328 and 200.329 of the Uniform Guidance. 74CORRECTIVE ACTION PLAN: The School District concurs with the above noted finding. The School District has employed a new Business Manager whose responsibilities include the oversight of the financial management system and the posting of all transactions into that system. Procedures will be put into place during the remaining months of the 2023-2024 fiscal year, and all subsequent years, for ensuring federal program expenditures are properly coded within the District’s financial management system so as allow for proper reporting related to those expenditures.

This is repeat Finding from 2022. Key personnel have since been replaced at the RPC and those in in the new positions understand the importance of proper and timely reporting and accurate financial records. The Auditor’s Office will meet with the new executive director, the current (new) finance director, and board members to emphasize the importance of deadlines and financial accountability when working with Grants. Additional Controls will be emphasized to assist with timely filing, as well as Invoice Entry to ensure duplicate payments are not made.

The position of Grants Coordinator has been created and filled to handle grants management functions which will ensure proper quarter end dates and expenditures appropriate for the period are reported. Under the new process, the Grant Coordinator collaborates with the Construction Financial Administrator to complete forms which are then reviewed with the Director of Grants and CFO prior to submission.

FINDING 2023-007 Finding Subject: COVID-19 – Education Stabilization Fund – Reporting Summary of Finding: The School Corporation had not properly designed or implemented a system of internal controls that would likely be effective in preventing, or detecting and correcting, noncompliance for the reporting requirement. Not all EESER reports submitted by the School Corporation during the audit period were not supported by the School Corporation's records. Contact Person Responsible for Corrective Action: Tracey Haas, Deputy Treasurer Contact Phone Number and Email Address: thaas@mcas.k12.in.us (219)873-2000 ext. 8346 Views of Responsible Officials: We concur with this finding. We are implementing a proper system of internal controls and developing policies and procedures to ensure all reports are submitted accurately. Description of Corrective Action Plan: We are implementing a proper system of internal controls and developing policies and procedures to ensure all reports are submitted accurately. Moving forward we will ensure all ledgers are attached to the reports that have been submitted. Anticipated Completion Date: The anticipated date of correction for this finding is January 1, 2025.

FINDING 2023-004 Finding Subject: Twenty-First Century Community Learning Centers – Cash Management, Program Income and Reporting. Summary of Finding: The School Corporation had not established an effective system of internal controls related to the grant agreement and the Cash Management, Program Income and Reporting compliance requirements. Cash Management The school submitted reimbursement requests without taking into considering the program income or reducing the request by the program income earned due to the lack of adequate program income. Program Income Controls had not been designed or implemented adequately to ensure that the proper fees were assessed and that the cash collections remitted were accurate. Additionally, the school-maintained program income in a separate fund and comingled with other non-grant funded program revenues. The unit did not deduct program income from allowable costs prior to claiming reimbursement. Reporting The total requested reimbursements for the audit period were understated by $32,605 when compared to the ledger. Of the two End of Year reports selected for testing neither properly included program income that was received during the year due to inadequate tracking of program income. Contact Person Responsible for Corrective Action: Tracey Haas, Deputy Treasurer Contact Phone Number and Email Address: thaas@mcas.k12.in.us (219)873-2000 ext. 8346 Views of Responsible Officials: We concur with this finding. We are implementing a system of internal controls to strengthen our policies and procedures and ensure the proper tracking of Program Income is reported and submitted accurately for Twenty First Century Learning center grant funds. Description of Corrective Action Plan: We have reached out to our liaison at the Department of Education to determine if program income should be reported monthly or annually. Management will be working with the Safe Harbor Director to implement a system to ensure separation of the Twenty first Century grants and other funds that are under the Safe Harbor program. Anticipated Completion Date: The anticipated date of correction for this is January 1, 2025.

Finding: The County’s reported expenditures incurred in fiscal year 2022 were incorrectly reported. Cause: Internal controls and review processes were not in place to ensure the accuracy of expenditures reported on the annual SEFA. Recommendation: Management should implement procedures to help ensure that controls are in place that will allow for the accurate preparation of the SEFA. We recommend that the County perform a detailed analysis of expenditures for all significant awards on an annual basis. Corrective Action Plan: Effective immediately, the County will put in additional controls and verify all grants are monitored under additional scrutiny and are reported accurately in quarterly reports and the County’s Annual Comprehensive Financial Report (ACFR). Staff Responsible for Implementation: Matt Davis, County Auditor; Mike Sloan, Senior Associate; Jordan Wilson, Grant Associate Implementation Date: December 31, 2024 Status: In progress

FINDING 2023-006 Finding Subject: Education Stabilization Fund - Reporting Summary of Finding: The School Corporation had not properly designed or implemented a system of internal controls, which would include proper segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance. The School Corporation was required to submit annual data reports to the Indiana Department of Education (IDOE) via JotForm, a form/report builder. Data to be submitted included, but was not limited to, current period expenditures, prior period expenditures, and expenditures per activity. During the audit period the School Corporation submitted two ESSER I reports, two ESSER II reports and two ESSER III reports, for a total of six reports. The annual data reports were complied, prepared and submitted by one employee without documentation to support an oversight or review process in place to prevent, or detect and correct, errors. In addition, because the unit was unable to provide supporting documentation for the information contained in the six reports submitted during the audit period, three of these reports contained errors. Contact Person Responsible for Corrective Action: Kelly McPike Contact Phone Number:765-689-9131 Views of Responsible Official: We concur with the finding Description of Corrective Action Plan: An effective internal control will be developed to ensure supporting documentation is used and retained for all required reports submitted on behalf of the Education Stabilization Program Funds. The reports will be compiled, prepared, and submitted by more than one employee to support any possible oversight or errors. Anticipated Completion Date: April 2024

The audit testing in question related to transactions that occurred from October 1, 2020, to December 31, 2021. At this time, due to COVID and the use of Charity CFO, an outside accounting organization, to record and manage our transactions, 9/11 Day chose to track federal expenditures independently and internally through accounting spreadsheets. Although these transactions were included in 9/11 Day Quickbooks software as well, Charity CFO did not separate them under categories that identified them as federal grant expenses. At the request of the Auditor, 9/11 Day reviewed and reconciled these federal transactions in Quickbooks, without discrepancies. Beginning in 2023, we began tracking federal grant expenses and revenue in Quickbooks. In response to Auditor recommendations, we are reviewing and will update our written procedures for tracking, reviewing, approving and retaining documentation of federal expenses consistent with Federal Financial Reports submitted to the Agency.

2023-001 Name of Contact Person: Matthew Roy Corrective Action: After the September 2023 staffing changes, the Finance Director and the Accounting Manager reviewed the FFR reports prior to filing. The Finance Director provided verbal approval to file. For all reports going forward, Greenheart will document approval of filing via email exchanges from the Accounting Manager to the Director of Finance. Proposed Completion Date: Management considers this finding resolved as of August 2024.