Corrective Action Plans

FINDING 2022-010Subject: COVID -19 - Education Stabilization Funding - ReportingFederal Agency: Department of EducationFederal Program: Education Stabilization FundAssistance Listings Numbers: 84.425D, 84.425UFederal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013,S425U200013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: ReportingAudit Findings: Material Weakness, Modified OpinionContact Person Responsible for Corrective Action: Chad Yencer, SuperintendentContact Phone Number: 76+5-348-7550Views of Responsible Official: We concur with this findingDescription of Corrective Action Plan:Internal Control:1. The grants specialist/data specialist will compile the information for state reporting in the ESSER grants.The grants specialist will maintain documentation to support the data being presented.2. The corporation treasure will review all compiled financial data for the reporting period and verify it foraccuracy prior to submitting to the superintendent.3. The Superintendent will review the information, supporting documentation and verify accuracy prior tosubmitting to the IDOE reporting.Anticipated Completion Date: July 2023

FINDING 2022-002Contact Person Responsible for Corrective Action: Allison Pund and Melissa BoeglinContact Phone Number: 812-683-3971Views of Responsible Official: We concur to the finding.Description of Corrective Action Plan: Southwest Dubois will develop a system of internal controls that will ensurereporting compliance requirements are met. The corporation will assure one individual is completing the reports andanother is verify the reports.Anticipated Date of Completion: March 2023

2022-003 Education Stabilization Fund ? Assistance Listing No. 84.425FCondition: The College was unable to provide supporting documentation that agreed to the quarterly and annual reports submitted for the grant.Recommendation: We recommend the College review current procedures to ensure documentation is maintained to support the amounts submitted on quarterly and annual reports.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: Management has reviewed their current procedures and has included additional controls to ensure the supporting documents are maintain with a copy of the submitted quarterly and annual reports.Name(s) of the contact person(s) responsible for corrective action: Dr. Heike Soeffker-Culicerto, Vice President of Administration and Finance, 240-500-2235Planned completion date for corrective action plan: March 31, 2023

Recommendation: The auditors recommend the University update previously posted reports to accurately reflect the actual expenditures during the time period covered by the report. The auditors recommend each report be posted to the University?s website on separate documents by quarter and should not be cumulative. The auditors also recommend that the University implement a process to ensure the submission dates and publication dates are maintained to ensure compliance with the reporting due dates and that the data submitted in the reports is properly supported by institutional records. Lastly, the auditors recommend each report be properly reviewed by someone other than the preparer and that the review be documented with a signature and date.Planned Corrective Action: Heritage University will update the previously posted reports to accurately reflect the actual expenditures during FY20 & FY21 on the University?s website by quarter. Going further it will be the Grant accountant?s practice that the submission dates and publication dates are maintained and documented with reporting due dates. All documents will be reviewed and approved by the VP of Administration/CFO with dated signatures.Name of Responsible Party:1. Yolanda Maltos, Grant Accountant2. Alysia Stevens, Controller3. Tom Richter, VP of Administration/CFOAnticipated Completion Date: May 18, 2023

Action Taken: During 2023, Range Mental Health Center, Inc. and Subsidiaries had experienced turnover in key financial functions. In addition, we were notified that current independent audit firm would no longer be performing the 2023 financial and single audits. In response to this we have outsourced its CFO function. We have also engaged a new independent audit firm, as this was a first-year audit there was an acclimation period delaying many processes. As a result, we anticipate an improvement in timeliness of our financial records.

The School System does not concur with the auditor’s findings and recommendations. The total expenditures for all federal programs recorded in the Schedule of Expenditures for Federal Awards are accurately presented and tie to the general ledger. The payroll sub-ledger is corrected before posting to the general ledger every two weeks. The resulting differences are most often immaterial, but can be traced to corrections made by the Accounting Office after payroll is reviewed by the grants Restricted Funds Supervisor to ensure payroll is not posted to expired grants. To ensure all employees are paid according to pay dates established in our various labor agreements and recorded correctly in the general ledger, we will continue the payroll transaction validation process that assures the payroll expenses recorded are allowable and accurately stated in the SEFA and balance to the general ledger. BDO Response – We have reviewed management’s response and our finding remains as indicated, since we could not validate the details of the differences.

FINDING 2023-004 (Auditor Assigned Reference Number) 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 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. During the audit period the School Corporation was required to submit two ESSER I reports, two ESSER II reports and two ESSER III reports, for a total of six reports. However, the School Corporation failed to submit all six required reports. The lack of internal controls and noncompliance were systemic issues throughout the audit period. We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure reports are submitted timely and accurately. Contact Person Responsible for Corrective Action: Stefanie Grandstaff, Director of Business Services Contact Phone Number and Email Address: (574)-946-4010 ext. 230, stefanie.grandstaff@epulaski.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: In the future when there is a multiyear federal grant given to Eastern Pulaski Community School Corporation, the final expenditure reporting will be completed on a yearly basis to ensure annual reporting is accurate. Determination of grant requirements for reporting will be determined and procedures put into place upon acquiring a new grant. When submitting grants for reimbursements each month, the Director of Business Services and Superintendent review the reports pulled from Skyward, sign the reimbursement form and then the Director of Business Services will submit it for reimbursement. The same internal controls will be put in place for final expenditure reporting for grants requesting this information. Anticipated Completion Date: June 30, 2024

Views of Responsible Officials and Planned Corrective Actions: MARR will retain a CPA consultant to implement a full-range of controls relating to reporting, including federal program reporting. MARR will take such steps as necessary to ensure that reports are timely and accurately prepared, reviewed, and approved prior to filing. All controls, including review and approval will be documented in such documentation to be maintained.

Finding 2022-007: Reporting – Significant Deficiency. Response: 1. Staff are being trained to understand the significance of meeting deadlines. 2. New system that includes grant reporting requirements will be implemented in 2024. 3. Reporting tasks are being redistributed to assure tasks are completed by their due dates.

FINDING 2022-003 Finding Subject: COVID-19 - Education Stabilization Fund - Reporting Summary of Finding: An effective internal control system was not designed, nor implemented at the School Corporation to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirements. The annual Elementary and Secondary School Emergency Relief (ESSER) Data Collection reports were complied, prepared and submitted by three different staff members; however, this process was not properly designed or implemented to prevent, or detect and correct, errors. The School Corporation completed and submitted three annual Data Collection reports (Reports) for the ESSER grants. For two of the three reports tested, the report was not supported by the unit’s records. The financial information provided did not agree to the data submitted in the Reports, therefore we could not determine their accuracy. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Contact Person Responsible for Corrective Action: Matthew Miles, CFO Contact Phone Number and Email Address: 317-423-8380 mattmiles@msdlt.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The School District will work to ensure the ESSER report amounts tie to the accounting records and will improved record keeping of supporting documentation. If the amounts do not match, District will document support for all claims. Anticipated Completion Date: The School District will implement changes described in the Corrective Action Plan in February 2024.

Planned Corrective Action: We will review existing reporting procedures and ensure appropriate adjustments are made for any new federal awards’ specific reporting compliance requirements or when any existing federal awards’ specific reporting requirements are updated. Name of Contact Person: Rachel Watson, Business Office Director/Controller, watson.rachel@occ.edu Anticipated completion date: Immediate implementation of corrective action, only applicable when new funds are awarded or existing federal awards’ reporting requirements change.

FINDING 2022-007 Finding Subject: COVID-19 - Education Stabilization Fund - Reporting Summary of Finding: Finding: No oversight of reports and supporting documentation did not agrees to report submitted Recommendation: Provide oversight of reports submitted and retain supporting documentation that agrees to reports submitted Contact Person Responsible for Corrective Action: Kareemah Fowler, Assistant Superintendent of Business and Finance Deb Martin, Director of Student Learning & Title I Contact Phone Number and Email Address: Kareemah Fowler (574) 393-6088; kfowler@sbcsc.k12.in.us Deb Martin (574) 393-6053; dmartin@sbcsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: All reports and supporting documentation, which supports each report submitted, will be reviewed/approved by the program director. All supporting documentation will be retained for future audits. Anticipated Completion Date: December 8, 2024

FINDING 2022-004 Finding Subject: Title I Grants to Local Educational Agencies - Reporting Summary of Finding: Finding: Detail data on the Form 9 and Reimbursement Request was not provided to knowledgeable individuals for review. Recommendation: Design control that provides sufficient data to knowledgeable individuals for review. Contact Person Responsible for Corrective Action: Kareemah Fowler, Assistant Superintendent of Business and Finance Contact Phone Number and Email Address: (574) 393-6088; kfowler@sbcsc.k12.in.us Views of Responsible Officials: We concur with the findings. Description of Corrective Action Plan: Form 9 Data The Human Resources Department has added a second review to verify all employee distribution codes are correct when recording/updating employee requisitions. Additionally, detailed expense reports and payroll distribution reports that support each reimbursement request are being provided to knowledgeable employees to review. Anticipated Completion Date: Completed December 8, 2023, and May 2023 Reimbursement Requests Summary level payroll data is no longer being used to support reimbursement requests. Detailed expense reports and payroll distribution reports that support each reimbursement request are being provided to knowledgeable employees to review. Anticipated Completion Date: Completed May 2023.

FINDING 2022-004 Subject: COVID-19 ? Education Stabilization Fund ? Reporting, Equipment and Real Property Management Federal Agency: Department of Education Federal Program: COVID-19 ? Education Stabilization Fund Assistance Listing Number: 84.425D Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting, Equipment and Real Property Management Audit Finding: Material Weakness Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Reporting and Equipment and Real Property Management compliance requirements. Context: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirements. Reporting The School Corporation was required to submit two Annual Data Reports to the Indiana Department of Education (IDOE) to meet federal reporting requirements for ESSER grant awards. The first report was for the period of March 13, 2020 to September 30, 2020 and was due by January 21, 2021. The second report was for the period of October 1, 2020 to June 30, 2021 and was due by May 13, 2022. For both reports that were submitted, there was segregation of duties between the preparation of the report and the review and submission of the report by someone other than the preparer. However, the review was not sufficient to prevent the following error: ? In the second report, the amounts reported as expended did not agree to the underlying expenditure records of the School Corporation for ESSER I and ESSER II awards. Per discussion with the Treasurer, the amount in the report included expenditures through the report due date of May 13, 2022 rather than through the reporting period end date of June 30, 2021. This resulted in an overstatement of expenditures of $83,000 for ESSER I and $184,000 for ESSER II. Equipment and Real Property Management During our testing of equipment and real property management, it was noted that the School Corporation had not conducted a physical inventory during the last two years as required. Views of Responsible Officials and Planned Corrective Actions: We concur with the finding. Description of Corrective Action Plan: For the upcoming year 3 ESSER report that is due by April 7th, the corporation treasure will ensure that the data provided for the completion of this report only includes the correct time period information for July 1, 2021 through June 30, 2022. Southwestern superintendent, Josh Edwards, will verify the correct dates and amounts for the requested time period before submitting the report. Both the treasurer and the superintendent will review the form and sign a printed copy to be kept on file at the administration building. Inventory has in the past only been taken within certain departments. A more complete inventory will be scheduled. Southwestern superintendent, Josh Edwards, and treasurer Bonnie Thopy will research the required criteria to become compliant. Once these parameters have been established they will work within the guidelines to ensure an inventory will be completed before the next audit period. Responsible Party and Timeline for Completion: Treasurer, Bonnie Thopy, and Superintendent, Josh Edwards ? these changes will be implemented for FY2023.

FINDING 2022-016 Contact Person Responsible for Corrective Action: Casey Brewster Contact Phone Number: 812-752-8935 Views of Responsible Official: We concur with the finding Description of Corrective Action Plan: The approved grant budgets for all federal grants will be input into the financial management system and with all expenditures reported monthly from the Treasurer to the Director overseeing the federal grant for review and final approval. The Director shall be one of the approvers within the approval chain of federal grant funds the Director oversees. The Director shall be responsible for reviewing and utilizing actual expenditure reports to complete the annual reports, or any other reports, prior to another documented review by the Treasurer or CFO. All documentation related to the reports shall be maintained for future audit purposes. Anticipated Completion Date: April 2023.

FINDING 2022-014 Contact Person Responsible for Corrective Action: Casey Brewster Contact Phone Number: 812-752-8935 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The approved grant budgets for all federal grants will be input into the financial management system and with all expenditures reported monthly from the Treasurer to the Director overseeing the federal grant for review and final approval. The monthly reports will then be used by the Director to generate a reimbursement request for actual expenditures. The reimbursement request must then be reviewed and signed by the Treasurer or the CFO prior to submission to the State by the Director. Anticipated Completion Date: April 2023

FINDING 2022-006 Contact Person Responsible for Corrective Action: Casey Brewster Contact Phone Number: 812-752-8935 Views of Responsible Official: We concur with the finding. INDIANA STATE BOARD OF ACCOUNTS 67 Description of Corrective Action Plan: Additional training related to grant budgets entered into and monitored within the financial software will occur, as will the new practice of having the program directors initiating monthly reimbursement requests informed by the accurate reports from the software (ledger), with documented review by the Treasurer or CFO. Additional training over the reporting requirements is taking place with the Treasurer, CFO and Directors overseeing federal funds provide accurate reporting. Anticipated Completion Date: June 2023

FINDING 2022-011 Contact Person Responsible for Corrective Action: Casey Brewster Contact Phone Number: 812-752-8935 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Additional training related to grant budgets entered into and monitored within the financial software will occur, as will the new practice of having the program directors initiating monthly reimbursement requests informed by the accurate reports from the software (ledger), with documented review by the Treasurer or CFO. Additional training over the reporting requirements is taking place with the Treasurer, CFO and Directors overseeing federal funds provide accurate reporting. Anticipated Completion Date: June 2023

Corrective Action Plan Audit Finding Reference: 2022-001 Planned Corrective Action: In response to audit finding 2022-001, the University has established a system of controls. When the prior- year finding was identified, the responsible reporting officials for the institutional and student portions of HEERF funding combined report information into a single web posting request prior to the deadline each quarter. This single request provided another check for the posting official to confirm the quarterly report is comprehensive. Date of Remediation: September 2021 Contact Person Responsible: Christina Pikla

Criteria: The Partnership must establish and maintain effective internal control over federal awards that provides reasonable assurance that the Partnership is managing the federal awards in compliance with federal statutes, regulations and terms and conditions of the federal award. 2 CFR 200.327 and 2 CFR 200.328 require the auditee to collect financial information and monitor its activities under federal awards to assure compliance with applicable federal requirements and performance expectations are being achieved and report these items in accordance with program requirements. Terms and conditions of the federal award require the Hospital to maintain a debt service reserve fund as bookkeeping accounts or as separate bank accounts. Condition: During 2022, the certificate of deposit that represented the debt service reserve fund matured and the proceeds were commingled with an existing money market fund. Planned Corrective Action: Management agrees with the finding and will deposit the required debt service reserve funds in a separate bank account. Planned Completion Date: June 30, 2023 Person Responsible: Daris Rosencrance, CFO

Criteria: The Partnership must establish and maintain effective internal control over federal awards that provides reasonable assurance that the Partnership is managing the federal awards in compliance with federal statutes, regulations and terms and conditions of the federal award. 2 CFR 200.327 and 2 CFR 200.328 require the auditee to collect financial information and monitor its activities under federal awards to assure compliance with applicable federal requirements and performance expectations are being achieved and report these items in accordance with program requirements. Terms and conditions of the federal award require the audited financial statements to be provided to the federal agency annually within 150 days of fiscal year-end, as well as quarterly internal financial statements. Condition: The Partnership did not submit the audited financial statements within the prescribed period or request an extension and did not submit any quarterly reports to the federal agency. The Partnership was not asked for the information after they failed to submit it. The audited financial statements are readily available to the federal agency through the federal clearinghouse website. Planned Corrective Action: Management agrees with the finding and are implementing procedures to ensure that the required financial reports are submitted in a timely manner in accordance with the terms and conditions of the federal award. Planned Completion Date: June 30, 2023 Person Responsible: Daris Rosencrance, CFO

FINDING 2022-001 Material Weakness - Reporting Contact Person Responsible for Corrective Action: Julie Flores Contact Phone Number: 765-382-3779 Views of Responsible Official: Agree with finding Description of Corrective Action Plan: The Controller?s Office will send the monthly appropriation reports for transportation to the Administrative Assistant (AA) and to the Transportation Manager to review and reconcile. After the monthly report has been reconciled by the transportation Administrative Assistant, it will be initial and dated by the AA, the work will be forwarded to the grant administrator, transportation manager and controller?s office. The Controller?s Office will review to ensure accurate information was forwarded to the grant administrator. These changes will be reflected in the City of Marion?s Internal Control Policy. Anticipation Completion Date: 09/01/23

Contact Person Responsible for Corrective Action: Jessica Espinoza Contact Phone Number: (219) 836-9111 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: There has been turnover in the finance department and the past employees who would have been responsible for this are no longer here. There are already internal controls in place to ensure that the monthly sponsor claims submitted match the school?s meal count reports. The Treasurer will continue to ensure that everything is correctly entered before submission. Anticipated Completion Date: March 2023

The College will update the September 30, 2021 quarterly report currently posted on the website to include the estimated number of students eligible for HEERF funds. The College will post an additional report for the quarter ending June 30, 2021, indicating the receipt of funds and that no funds were distributed during the quarter.

Material Weakness: Criteria: RWHS must establish and maintain effective internal control over federal awards that provides reasonable assurance that RWHS is managing the federal awards in compliance with federal statutes, regulations and terms and conditions of the federal award. 2 CFR 200.327 and 2 CFR 200.328 require the auditee to collect financial information and monitor its activities under federal awards to assure compliance with applicable federal requirements and performance expectations are being achieved and report these items in accordance with program requirements. Terms and conditions of the federal award require the quarterly revenue on an actual and budgeted basis to be reported to the federal agency by March 31, 2023. Condition: RWHS submitted instances of inaccurate actual revenue for quarters 3 and 4 of 2021 and 2022 and inaccurate budgeted revenue for quarters 2 and 3 of 2021. Planned Corrective Action: Management will implement procedures to ensure that the required revenue totals are reported accurately in accordance with the terms and conditions of the federal award. Contact Person: Alan Townsend, CFO Anticipated Completion Date: December 31, 2023