Corrective Action Plans

Reporting requirements are flagged in the University’s financial systems and manually tracked for completion where sponsor systems do not provide systematic alerts of pending and delinquent reports. The Early Head Start program reporting requirements are tracked via the U.S. Department of Health and Human Services Payment Management System (PMS). The Grants Management Specialist (GMS) for the applicable awards has informed the University that technical issues within PMS are preventing reports from automatically being made available for preparation and subsequent certification. The GMS requested the University institute a procedure to request report access when identified as unavailable. The appropriate staff in Sponsored Projects Accounting have been informed of the PMS technical issue resulting in reports not being released for preparation and instructed to contact the GMS immediately to release the reports, if they are not readily available. Anticipated completion date: March 2024 Names of contact person(s) responsible for corrective action: Dave Laffey, Director of Sponsored Projects Accounting

Finding 2023-010 Finding Subject: COVID-19 - Education Stabilization Fund - Reporting Summary of Finding: During the audit period the School Corporation submitted two ESSER I reports, two ESSER II reports and one ESSER III report, for a total of five reports. A single employee prepared and submitted each annual data report without a review or oversight process in place to prevent, or detect and correct, errors. All five reports were selected for testing, two of which were not supported by the School Corporation's records. Contact Person Responsible for Corrective Action: Terry Richey and Chrystal Street Contact Phone Number and Email Address: 812.793.2061 trichey@crothersville.k12.in.us cstreet@crothersville.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The corporation treasurer and superintendent will review current internal controls policies especially segregation of duties and the areas in which we are lacking. We will consider rotation of duties in which employees will learn different roles when possible. We will also consider using technological solutions to enhance the reliability and integrity of processes. Another individual will start to review the information entered into the required ESSER reports prior to submission and supporting documentation will be retained. Anticipated Completion Date: April 1, 2024

FINDING 2023-006 Finding Subject: Title I Grants to Local Educational Agencies - Reporting Summary of Finding: During the audit period the School Corporation submitted three final expenditure reports. The final expenditure reports were completed and submitted by the Treasurer without an oversight or review process in place to prevent, or detect and correct, errors. In addition, the final expenditure report for the Title I School Improvement for program year 2021, due December 30, 2021, was submitted March 7, 2024. Contact Person Responsible for Corrective Action: Terry Richey and Chrystal Street Contact Phone Number and Email Address: 812.793.2061 trichey@crothersville.k12.in.us cstreet@crothersville.k12.in.us Views of Responsible Officials: We concur with the finding. INDIANA STATE BOARD OF ACCOUNTS 39 Description of Corrective Action Plan: The corporation treasurer and superintendent will review current internal controls policies especially segregation of duties and the areas in which we are lacking. We will consider rotation of duties in which employees will learn different roles when possible. We will also consider using technological solutions to enhance the reliability and integrity of processes. Another individual will start reviewing the final expenditure reports prior to submission to IDOE. Anticipated Completion Date: April 1, 2024

We agree that in previous years, there were deficiencies in compliance with reporting requirements related to the receipt and disbursement of federal funds. There has been turnover in Business Office staff, but now that staffing has stabilized, the following procedures will be implemented regarding the management of federal funds:  The Senior Accountant will be responsible for the receipt and disbursement of federal funds, and for monitoring reporting requirements  The Associate Vice President for Finance and Controller will oversee the process and ensure that spending guidelines are followed and that all deadlines for reporting are met

FINDING 2023-002 Finding Subject: COVID 19 – Education Stabilization Fund - Reporting Summary of Finding: Material Weakness, Other Matters. Contact Person Responsible for Corrective Action: Steve Nauman, Treasurer Contact Phone Number and Email Address: Phone: 812-522-3340 Email: naumans@scsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The SCSC management team will design and implement a proper system of internal control, including policies and procedures that would provide segregation of duties to ensure appropriate reviews, approvals and oversight are taking place prior to filing required reports. Anticipated Completion Date: The projected date of completion is February 29, 2024.

FINDING 2023-008 Finding Subject: Education Stabilization Fund - Reporting Summary of Finding: 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 complied, prepared and submitted by one employee without an oversight or review process in place to prevent, or detect and correct, errors. In addition, the six reports submitted during the audit period contained errors. The errors were as follows:  The ESSER I, Year 2 and ESSER II, Year 1 reports did not contain expenditures for the reporting period, however according to the School Corporation's records there were expenditures for ESSER I and ESSER II during this period.  The ESSER I, Year 3, ESSER II, Year 2, ESSER III, Year 1, and ESSER III, Year 2 reports were not supported by the School Corporation's records, was not accurate and complete, and was not mathematically accurate. Recommendation: We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure supporting documentation is used and retained for all required reports submitted on behalf of the Education Stabilization Fund program funds. Contact Person Responsible for Corrective Action: Dr. Tim Garland Contact Phone Number and Email Address: 574-626-2525 / garlandt@lewiscass.net Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: During the audit period, internal control opportunities were in place but not followed. Lewis Cass Schools has an internal control process that is in place but was not followed by the treasurer who in the position during the audit period. The treasurer who did not follow the internal control process is no longer employed by Lewis Cass Schools. To address and ensure Education Stabilization Funds are properly reported by the treasurer the treasurer will print out the form that was completed by the treasurer and must be signed by the superintendent or department head for review before submittal and filed for record keeping. Anticipated Completion Date: 3/11/2024

Description of Corrective Action Plan: The Director of Grants will continue to prepare the reports and then the Superintendent and Corporation Treasurer will review and sign off on the reports to ensure they agree to the underlying detail. The Director of Grants will make sure this is done in a timely manner to comply with the reporting deadlines for each fiscal year. Responsible Party and Timeline for Completion: Treasurer, Jill Wagoner, Superintendent, Dr. Angela Piazza and the Director of Grants, Eric Knebel. The corrective action will be implemented starting immediately.

For the first three quarters of the fiscal year, the reports were timely completed and published online, per the grant requirements with a direct link to the documents. The fourth quarter has now been completed and published there, as well. There was a change in the Business Office, where the person responsible for management of this series of awards resigned from the College. We are actively searching to fill the position, Director of Finance, whose responsibilities will include grant management, overall. Though the awards are fully spent and ended at, June 30, 2023, still responsibilities to the grant for record-keeping and final annual reporting, exist. We acknowledge this and have incorporated these items into the calendar of reporting events for these awards.

Condition: Obligations were overstated by $144,923 on the March 31, 2023 Project and Expenditure report. Corrective Action Planned: All of the grant funds have been obligated and will be reflected as such in the next U.S. Treasury report. Anticipated Completion Date: April 2024 Contact: Victoria Rose, Town Accountant

Corrective Action Plan 2023‐001: The Controller and Associate Vice President of Compliance are working together to correct the previously filed reports to reflect the updated format. The initial due date for the required file form update was missed and the correct form is now completed and provided on the University’s website. Completion Date: March 25, 2024 Contact Person: Donna Ferguson, Controller, and Carrie Stevens, Associate Vice President of Compliance

FINDING 2023-010 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Number: 84.425D Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Reporting Summary of Finding: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Terri Chance Contact Phone Number and Email Address: 219-924-4250 tchance@griffith.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Griffith Public Schools will be developing, implementing, and documenting, a system of internal controls, including policies and procedures that provide segregation of duties to ensure appropriate reviews, approvals and oversight are taking place. Anticipated Completion Date: June 30, 2025

Condition and Context: In testing reconciliations of financial records to periodic expense reports submitted for Economic Stabilization Funds, it was noted that previously reported expenditures and year-to-date expenditures were inaccurate. Recommendation: We recommend that the School Board reconcile their financial records to the periodic expense reports before submission. Management’s response: Typically management does reconcile these reports. This was an error that will be corrected from this point forward.

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.

Management’s Response: The College will strengthen its policies and procedures to ensure documentation of review and approvals for reporting to ensure reporting compliance. Anticipated Completion Date: February 28, 2024

Higher Education Emergency Relief Funds – Assistance Listing No. 84.425 Recommendation: We recommend the University review their reporting procedures to ensure reports are being uploaded and submitted timely. University of Maine at Farmington Condition: During our testing of 11 quarterly reports, it was noted that University of Maine at Farmington (UMF) had two reports of two sampled that were not submitted timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The upcoming reporting requirements have been added to the calendar and invoicing spreadsheet of UMF’s Director of Finance. Additionally, due dates and requirements are noted by both UMF’s Chief Business Officer (CBO) and its Vice President for Student Affairs and Enrollment Management. The CBO will continue to perform a final review prior to submission. Name(s) of the contact person(s) responsible for corrective action: Kathleen Falco, Director of Finance for the University of Maine at Farmington Planned completion date for corrective action plan: Completed

Audit Finding Reference: 2023-001 Improve Controls Over Reporting Planned Corrective Action: 1. Request a list from DHHS of definitions of income types by program in the Quarterly Reports. Ensure that this list provides clarity on how to report income that is not explicitly tied to a single program. 2. Review AFY23 and AFY24-to-date reports against these criteria (once received), and re-submit any reports which may need to be modified to comply with the guidance. 3. Going forward, the Quarterly Reports will be generated differently. The Client Services Manager will prepare actuals by program for number of clients and units. The Director of Administration will prepare actuals by program for income and expense. The Executive Director will compile the final report, which will not be submitted until both the Client Services Manager and Director of Administration have both checked the reports and electronically signed them. In the absence of specific guidance from DHHS to the contrary, any non-program-specific income will be allocated to programs by share of service units delivered. Planned Implementation Date of Corrective Action: 1. 3/29/24. 2. 6/30/24. 3. 4/15/24. Person Responsible for Corrective Action: Tim Diaz, Executive Director

FINDING 2023-003 Finding Subject: COVID-19 - Education Stabilization Fund - Reporting Summary of Finding: The School Corporation had not designed nor implemented a system of internal control to ensure that the six Elementary and Secondary School Emergency Relief (ESSER) annual data reports required to be filed during the audit period were complete and accurate prior to submission. The Reports were prepared by one employee without an oversight or review process in place to prevent, or detect and correct, errors. Contact Person Responsible for Corrective Action: Greg Walker, Superintendent Contact Phone Number and Email Address: 812-723-4717 and walkerg@paoli.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Superintendent will enter information into the annual data report required for ESSER and once completed the Corporation Treasurer will review the information entered for accuracy. The Corporation Treasurer will sign off that the information entered is correct and then the Superintendent will submit the data report. Anticipated Completion Date: Projected date of completion is April 2024.

FINDING 2023-001 Finding Subject: COVID-19 - Education Stabilization Fund - Reporting Summary of Finding: The annual reports provided for audit did not tie back to supporting records. One annual report, ESSER III Year 2, was not filed. Contact Person Responsible for Corrective Action: Superintendent Contact Phone Number and Email Address: (812) 649-2591 / brad.schneider@sspencer.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: In the future, the School Corporation will ensure all required annual reports for grant reporting are submitted and supported by school records. The required annual reports will be completed by the Corporation Treasurer and reviewed and approved by another knowledgeable employee for accuracy and completeness. Anticipated Completion Date: June 2024

FINDING 2023-010 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, which would include appropriate 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. Additionally, the ESSER I, Year 2, ESSER I, Year 3, ESSER II, Year 1, ESSER III, Year 1, and ESSER III, Year 2 reports were not supported by the School Corporation's records. Contact Person Responsible for Corrective Action: Todd Balmer, Assistant Superintendent/CFO and Allison Vanover, Corporation Treasurer Contact Phone Number and Email Address: 812-246-3375 tbalmer@scsc.school avanover@scsc.school Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We are currently meeting with a Grants Management Consultant that will be working with us on how to properly complete the ESSER reports to ensure submission moving forward is accurate. Prior to submission, the grants person will review to ensure the report is complete and the information is correct. We will also send the reports to the consultant for review. Anticipated Completion Date: April 2024

FINDING 2023-009 Finding Subject: COVID -19 - Education Stabilization Fund – Cash Management Summary of Finding: The School Corporation had not properly designed or implemented a system of internal control, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting noncompliance related to the Cash Management compliance requirement. Reimbursement requests for the programs were prepared by an employee and reviewed by another employee. While the School Corporation did have a process in place to review and approve reimbursement requests, not all reimbursement requests were traceable to the fund ledger and no audit evidence was provided to indicate the reviewer verified disbursements to the School Corporation records. Three of five reimbursement requests filed during the audit period were not traceable to the Schools Corporation’s fund ledger. Due to the lack of supporting documentation it was not possible to determine if grant payments were reimbursements of expenditures or advance payment of grant funds. The lack of internal controls and noncompliance were systemic issues throughout the audit period. The noncompliance was isolated to three of the five reimbursement requests filed during the audit period. Contact Person Responsible for Corrective Action: Todd Balmer, Assistant Superintendent/CFO and Allison Vanover, Corporation Treasurer Contact Phone Number and Email Address: 812-246-3375 tbalmer@scsc.school avanover@scsc.school Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The same process will be in place to review and approve grant reimbursements. The Deputy Treasurer will verify with the person preparing the reimbursement that the proper accounting information is on the receipt and that it is then receipted into the correct account in the FMS System and sign off. The Corporation Treasurer will review all receipts and be the second signature. Each month the accounts will be checked for accuracy by the grants person and the Corporation Treasurer will again be the second check for accuracy. The grant person will verify that the reimbursements of expenditures or advance payments are clearly marked and accounted for in the FMS System and sign off. The Corporation Treasurer will be the second signature. When reimbursements are prepared, these entries will also be reviewed. Anticipated Completion Date: March 2024

􀀃 Finding􀀃2023􀍲002􀀃 􀀃 Finding􀀃Subject:􀀃COVID􀍲19􀀃–􀀃Education􀀃Stabilization􀀃Fund􀀃􀍲􀀃Reporting􀀃 Summary􀀃of􀀃Finding:􀀃Internal􀀃Controls􀀃were􀀃not􀀃effective􀀃and􀀃did􀀃not􀀃prevent,􀀃nor􀀃allow􀀃for􀀃 detection􀀃and􀀃correction􀀃of􀀃errors􀀃prior􀀃to􀀃submission.􀀃 Contact􀀃Person􀀃Responsible􀀃for􀀃Corrective􀀃Action:􀀃Director􀀃of􀀃Business􀀃 Contact􀀃Phone􀀃Number􀀃and􀀃Email􀀃Address:􀀃(260)431􀍲2030,􀀃msnyder@sacs.k12.in.us􀀃 􀀃 Views􀀃of􀀃Responsible􀀃Official:􀀃We􀀃concur􀀃with􀀃the􀀃finding.􀀃 Description􀀃of􀀃Corrective􀀃Action􀀃Plan:􀀃 Once􀀃the􀀃Deputy􀀃Treasurer􀀃completes􀀃the􀀃report,􀀃they􀀃will􀀃give􀀃the􀀃report􀀃and􀀃all􀀃 supporting􀀃documentation􀀃to􀀃the􀀃Asst.􀀃Director􀀃of􀀃Business􀀃for􀀃review.􀀃􀀃After􀀃thorough􀀃 review,􀀃the􀀃report􀀃and􀀃supporting􀀃documentation􀀃will􀀃be􀀃signed􀀃by􀀃both􀀃the􀀃Asst.􀀃Director􀀃 of􀀃Business􀀃and􀀃the􀀃Deputy􀀃Treasurer.􀀃􀀃Once􀀃reviewed,􀀃the􀀃report􀀃and􀀃supporting􀀃 documentation􀀃will􀀃be􀀃given􀀃to􀀃the􀀃Director􀀃of􀀃Business􀀃for􀀃final􀀃approval􀀃and􀀃signature.􀀃􀀃􀀃 Anticipated􀀃Completion􀀃Date:􀀃3/18/24􀀃

The following corrective actions are being taken by Criminal Justice Coordinating Council (CJCC), effective for all federal reporting for the performance and financial period ending March 31, 2024: Federal Financial Report (FFR) Processes are updated as follows: • Federal Financial Report responsibilities are distributed on a per grant basis to the members of the CJCC Budget Team. • Because the US DOJ Just Grants system does not allow for review or secondary viewers in the financial reporting items the FFRs are to be printed digitally by the completing analysts/director. • FFR’s will be reviewed with written certification of review by a budget team member that was not responsible for primary submission of the report for each grant. • Any corrections will be made within the period of correction for the report to prevent a misstated report from becoming a permanent record. Prepared Federal Funding Accountability and Transparency Act (FFATA) and Performance Measures Tool (PMT) reports processes are updated as follows: • All PMTs and FFATA data will be routed for review through the Victims Assistance Division – Director of Operations for certification of completeness and accuracy.

FINDING 2023-002 Finding Subject: COVID-19 – Education Stabilization Fund – Reporting Summary of Finding: ESSER III, Year 2 report contained material errors in the amounts reported Contact Person Responsible for Corrective Action: Tanya Pearson Contact Phone Number and Email Address: 765-522-6218 tpearson@nputnam.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We will have one person complete the ESSER report and one person review the ESSER report for accuracy. Anticipated Completion Date: Immediately with the next ESSER report submission

Finding 2023-002 — Current Year — Major Federal Award — Significant Deficiency Award No.: 15.507 WaterSMART; Federal Grantor: US Department of the Interior — Bureau of Reclamation, Direct Program Condition: Compliance reporting didn't started until 9+ months after grant agreement was signed due to no progress waiting for the Bureau of Reclamation's notice to proceed. This was initially based on grant manager's feedback, who subsequently corrected herself and requested our no activity quarterly reports. Management will adhere to Uniform Guidance even in the event progress reports are to be filed with no activity described. Procedures will require staff to submit the reports, regardless of feedback received from the grant program's manager, to avoid future issues. All performance reports have been filed to date following the Uniform Guidance. All above corrective action items will be implemented by the Finance department at Yuba Water Agency no later than June 30, 2024.

FINDING 2023-003 Finding Subject: Covid-19 Education Stabilization Fund- Reporting Summary of Finding: Annual Data Report The School Corporation had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance. The School Corporation was required to submit an annual data report 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. The School Corporation was required to submit six annual data reports during the audit period. None of the annual data reports were submitted. Upon inquiry of the School Corporation to determine why the reports were not submitted, the School Corporation explained they had interpreted the reports to be final reports submitted upon completion of the grant not annual reports of expenditures. Reimbursement Requests To gain an understanding of how the School Corporation spent their Education Stabilization Fund award, all reimbursement requests submitted to the Indiana Department of Education (IDOE) were requested. Five of the ten reimbursement requests submitted to IDOE could not be located. As such, we determined reimbursement requests for the audit period should be further tested. The School Corporation’s process was to complete reimbursement requests on a periodic basis to obtain reimbursement for expenditures paid. Although the reimbursement requests were prepared by the Treasurer utilizing various ledger reports and were reviewed by a second knowledgeable employee; the process did not prevent, or detect and correct, errors. Of the ten reimbursement requests received, as noted above, five could not be provided for audit. Therefore, we were unable to substantiate the expenses reimbursed by those requests or if the requests were mathematically accurate or fairly presented. The remaining five reimbursement requests were tested without issue. Contact Person Responsible for Corrective Action: Andrew Schoff, Business Manager Contact Phone Number: 219-767-2263 Ext 1003 SOUTH CENTRAL COMMUNITY SCHOOL CORPORATION 9808 S 600 W Union Mills, IN 46382 219-767-2263 or 219-733-2311 Fax 219-767-2260 INDIANA STATE BOARD OF ACCOUNTS 34 Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: Beginning March 2024 the Business Manager will submit Annual Data Reports for any Federal Grant issued when stated in the Grant contract. The Annual Data Report will be reviewed by the Superintendent for accuracy. Also, the Business Manager will request reimbursement timelier for Federal Grants collecting supporting documentation to ensure correct amounts are being requested. Documentation will be maintained with a copy of the submitted reimbursement requests to provide support for the amounts being requested. Anticipated Completion Date: These corrective actions will go into effect immediately and will be utilized with the March 31, 2024 for any Federal Grant reimbursement.