Corrective Action Plans

Recommendation: The College should review the reporting requirements and implement procedures to ensure that all required reports are issued / posted in a timely manner. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A review of the Department of Education?s reporting requirements for the HEERF Student funding has been completed, by all parties involved. The missing reports are finalized and posted to the College?s internet. The Financial Aid and Financial Services-Grants departments will monitor communication from the Dept of Ed, sharing information received by each, thereby ensuring future reporting requirements are fulfilled. Name(s) of the contact person(s) responsible for corrective action: Christian Zimmerman Planned completion date for corrective action plan: April 20, 2022

FINDING 2022-008 Contact Person Responsible for Corrective Action: Danica Houze, Chief Financial Officer Contact Phone Number: 812-274-8001 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Documentation will be kept to ensure evidence of preparation, review, and approval of the Grant Reporting. Two individuals will sign off on all future reports and documentation will be kept on file. Anticipated Completion Date: 2/13/2023

FINDING 2022-003 (Auditor Assigned Reference Number) Contact Person Responsible for Corrective Action: Monica Kegerreis, Assistant Superintendent Contact Phone Number: 574-831-2188 Views of Responsible Official: We concur with the finding Description of Corrective Action Plan: The ESSER reports requested by IDOE will follow the same procedures of all FER reports. The ?data collection? for the ESSER grants was not identified as a financial report, and thus did not follow these processes. Now that we know this is a financial report, the steps below will be followed. The grant was initially not set up correctly and expenses were expended to and then transferred to the correct accounts once the grants were set up correctly. These changes were in flux when the report was requested, so what was reported at the time of the report is no longer what is reflected in grants? ledgers. The corrective action will require that the program director gathers the initial data, the data will be reviewed by the administrative assistant to the grants? director, and then reviewed by the Treasurer. All three employees will sign/initial a printed copy of the report before it is submitted. Data regarding students served by programs and staff reports will be reviewed by the program director and the data specialist and signed off on by both parties to ensure accuracy. Anticipated Completion Date: March 24, 2023

Finding 2022-01: COVID1-19 Education Stabilization Fund, Higher Education Emergency Relief Funds ? Reporting Program: COVID-19 Education Stabilization Fund Federal Agency: U.S. Department of Education Pass Through Entity: Not Applicable Assistance Listing Number: 84.425E, 84.425F Federal Award Number: P425E200445 Federal Award Year: June 30, 2022 Condition: The College did not post the required quarterly reports for the Student Portion. Additionally, during the audit, it was noted that the College was unable to provide a copy of the annual report and supporting documentation for the year ended December 31, 2021. Corrective Action Plan Management agrees with the finding, and is committed to strengthening its procedures to avoid similar issues in the future. Quarterly reports for the Student Portion have now been posted on the College website. Turnover in finance department staff resulted in difficulty locating copies of reports submitted by former staff. New staff will be trained on the Department?s HEERF requirements to ensure accurate and timely future reporting.

2022-033 Oregon Housing and Community Services Ensure financial reports are submitted Federal Awarding Agency: U.S. Department of Health and Human Services, Administration for Children and Families Assistance Listing Number and Name: 93.568 Low-Income Home Energy Assistance Program 93.568 Low-Income Home Energy Assistance Program (COVID-19) Federal Award Numbers and Years: 2002ORLIEA, 2020; 2102ORE5C6, 2021 (COVID-19) Compliance Requirement: Reporting Type of Finding: Material Weakness; Material Noncompliance Prior Year Finding: 2021 ? 012 Questioned Costs: N/A Criteria: 2 CFR ? 200.303(a), (c)-(d); 2 CFR ? 200.328 Department management is responsible for establishing and maintaining effective internal control that provides reasonable assurance the department is managing the federal award in compliance with the terms and conditions of the federal award. Additionally, management is responsible for evaluating and monitoring the department?s compliance with the terms and conditions of federal awards and taking prompt action when instances of noncompliance are identified. Federal Financial Reports, SF-425?s, are required to be submitted annually for each open grant award ninety days after the end of the federal fiscal year. The department did not submit SF-425?s for two of the four open grants for the federal fiscal period ended September 30, 2021. This is an improvement from the prior fiscal year when the department hadn?t submitted any of the SF-425 reports for open grants. Department management cited a federal reporting system issue where awards are not appropriately tied to the correct grant identification number, which has hindered their ability to submit financial reports. As a result, the department was not in compliance with financial reporting requirements in accordance with the terms and conditions of their grant agreements. We recommend department management work with their federal partners to determine if unsubmitted reports should be completed and to ensure reporting compliance in future fiscal periods. MANAGEMENT RESPONSE: We agree with this recommendation. OHCS submitted 2 of the 4 required reports but was unable to submit the remainder due to technical issues with the federal reporting system. OHCS compiled all requisite reporting information timely and is in correspondence with the federal funder to enable report submission. Anticipated Completion Date: December 31, 2023 Contact: Beth Brown, Accounting M

2022-053 Oregon Health Authority Improve financial reporting accuracy Federal Awarding Agency: U.S. Department of Health and Human Services Assistance Listing Number and Name: 93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (COVID-19) Federal Award Numbers and Years: 6 NU50CK000541, 2020 (COVID-19); 6 NU50CK000541, 2021 (COVID-19) Compliance Requirements: Reporting Type of Finding: Significant Deficiency, Noncompliance Prior Year Finding: 2021-022 Questioned Costs: N/A Criteria: 2 CFR 200.328 In response to the COVID-19 pandemic, the Centers for Disease Control (CDC) awarded states substantial funds for the purpose of addressing the pandemic at the state level. Among other requirements, states are required to submit monthly financial reports to the CDC providing totals spent on travel, payroll, equipment, and other categories. During the fiscal year 2021 audit, we reported a material weakness relating to the accuracy of the amounts reported to the CDC. The same issue persisted throughout fiscal year 2022. As of June 30, 2022, the department had not taken the necessary actions to implement the prior recommendations and had not fully corrected the reports submitted in fiscal years 2021 and 2022. However, as of March 2023, the department had implemented the appropriate corrective actions and the previously inaccurate reports have been updated, including the reports for fiscal year 2022. Audit standards require that we report on the status as of June 30, 2022. We recommend department management maintain the necessary internal controls to ensure the monthly financial reports are accurate and agree to the accounting records. MANAGEMENT RESPONSE: We agree with this recommendation. As you note in your audit letter, our financial reporting accuracy had been remedied for all historical and current reports by March 2023. Unfortunately, these improvements were not in place by June 30, 2022 and, for that reason, a finding was noted. Corrective action plan: ? All monthly financial reporting has been assigned to our Fiscal Analyst ? The Fiscal Analyst submits monthly financial reports and the query used to generate the reports to the Office of Financial Services (OFS) for review and approval ? The Fiscal Analyst revises monthly financial reports based on OFS feedback ? Following OFS approval, monthly financial reports are entered into CAMP by an ELC administrative staff member and verified by a second team member Anticipated Completion Date: March 31, 2023 Contact: Merry Carlson, ELC Contracts Manager

Finding Number: 2022-002 Planned Corrective Action: The Business office has endeavored to keep pace with the shifting and changing guidance that is promulgated by the Department of Education. This has been a challenge. The Chief Financial Officer continues to monitor any guidance updates and make the appropriate changes to the reports to ensure their accuracy. There was only one report posted that contained one typographical error, but it is the University?s responsibility to ensure the accuracy of the reports and these reports will be monitored more closely going forward. Anticipated Completion Date: Continuing Responsible Contact Person: Eugene L. Munin

FINDING 2022-017 Contact Person Responsible for Corrective Action: Tricia Malone Hudson, District Curriculum Specialist Contact Phone Number: 812-279-3521 Views of Responsible Official: We concur with the audit finding. Description of Corrective Action Plan: The school corporation will develop a protocol for ensuring that all documentation and records regarding Federal Grants will be maintained for a period of three years. Anticipated Completion Date: North Lawrence Community Schools implemented this procedure beginning in September 2022.

FINDING 2022-014 Contact Person Responsible for Corrective Action: Tricia Malone Hudson, District Curriculum Specialist Contact Phone Number: 812-279-3521 Views of Responsible Official: We concur with the audit finding. Description of Corrective Action Plan: The school district has established a process for reviewing reimbursements and district expense records to ensure alignment. Anticipated Completion Date: North Lawrence Community Schools implemented this procedure beginning in January 2023.

FINDING 2022-003 Education Stabilization Fund-Internal Controls Contact Person Responsible for Corrective Action: Michele Fleck, Treasurer Contact Phone Number: 812-882-4844 Description of Corrective Action Plan: Effectively immediately, the Vincennes Community School Corporation will include the Federal Programs Coordinator when preparing any annual reports to confirm accuracy of the reporting. This will provide more internal controls. Anticipated Completion Date: 07/01/2023.

Condition: As of the March 31, 2022, reporting date, the Town reported obligations of $5,044,950 while actual obligations were only $1,134,400. Corrective Action Planned: With the reporting due on 4/30/23 the method of reporting on the obligated funds will be utilized when submitting the report. Anticipated Completion Date: 4/30/23 Contact: Kristine Russell, Town Accountant

Finding 2022-002 Information on the federal program: Subject: Education Stabilization Fund ? Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 ? Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Significant Deficiency 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 compliance requirements. Context: 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. We noted for both reports that were submitted, there was no documented review by someone other than the preparer of the report to ensure the information submitted was complete and accurate. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and will take the following corrective action?Argos Community Schools will ensure that going forward, all documents will be overseen by at least two parties in the Business Office, with signed documentation. Responsible party and timeline for completion: Federal regulation requires Kelli VanDerWeele, Corporation Treasurer/Director of Business Services and Ned Speicher, Superintendent, will be overseeing and putting corrective action plan in place immediately.

Views of Responsible Officials and Planned Corrective Action - Administration concurs with the findings. The College has corrected the website disclosure of number of students receiving Aid Grants under the program. The College will review and confirm accuracy of any future report submissions. Anticipated Completion Date: May 31, 2023

FINDING 2022-004 Contact Person Responsible for Corrective Action: Kyle Zahn Contact Phone Number: 765-883-5576 ext. 5112 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: As ESSER reports and reimbursements are completed the supporting documents will be kept with the reports. Prior to submission, reports completed and documentation compiled by the Director of Finance will be reviewed by the Director of Exceptional Learners and Testing and vice versa. Anticipated Completion Date: February 2023

Federal Schedule Audit Comment: County Response Emergency Rental Assistance Program Timely Reporting: The County made every attempt through communications with the Treasury to upload annual reports for ERA 1, without being able to do so by the due date. The County did submit the documents manually by e-mail through dumps of the system. County staff worked with the US Treasury to address these issues. A resolution to the problem did not occur until second quarter of 2023. The Final report for ERA 1 has been submitted through the portal. Cumulative Expenditure/ Obligation Amounts: There was some misinterpretation on the part of County staff on whether the cumulative amounts to be reported was for the quarter or cumulatively for the grant program. It is to be noted that amounts in the County system were properly recorded and no exceptions were noted in the actual expenses/ obligations being for a valid grant purposes. Corrected on Final Report for ERA 1. State/ Local Federal Relief Funds Program Cumulative Expenditures/ Obligations Incorrectly Reported: There was some misinterpretation on the part of County staff on reporting the election of the $10,000,000.00 Revenue Replacement Funds for the SLFRF. It was thought that you could only show the $10,000,000.00 as obligated and expended once the election was made. This resulted in a net overstatement of obligations for any revenue replacements funds that were not yet obligated by resolution by the Board of Mahoning County Commissioners. The County tracked the individual projects by notes in the Treasury system to note the actual obligations. The County?s financial system tracks grants by fund, department and project codes. The funds in the County?s financial system were and are correctly obligated and tracked. The County will make the necessary corrections to the 2023 second quarter report to make sure the report agrees with the County?s financial system. It is to be noted that no exceptions were noted in funds being used for the stated purposes of the grant. Senior management will provide additional oversight to the reports prior to submitting to the US Treasury.

Corrective Action Plan - Finding 2022-002 We agree with the finding and observations, which are consistent with Finding 2021-002, and specifically note the following coorective actions that were implemented subsequent to June 30, 2022: - The Chief of Staff will contact the DOE to determine if past reports not filed should be submitted at this time and if reports filed with incorrect amounts should be corrected. - The Associate VP for Finance & Controller will review HEERF repoting requirements to ensure any future reporting required is submitted on a timely basis. - The Associated VP for Finance & Controller will review any future reporting for HEERF funds before submission to ensure they reconcile to the College's accounting records. Responsible Official - Gillian King, Chief of Staff Anticipated Completion Date: Completed

REPORTING West Virginia Division of Rehabilitation Services (WVDRS) Assistance Listing Number 84.126 WVDRS will review current RSA-17 approval procedures by April 2023 and make appropriate modifications as necessary to ensure all evidence of report approval is maintained within our records.

Finding 2022-006: Reporting Federal Agency Name: Department of Health and Human Services CFDA #93.829 Program Name: Section 223 Demonstration Programs to Improve Community Mental Health Services Finding Summary: Through testing of one programmatic report, the number of adults and children served during the reporting period included six individuals twice. As a result of a software change during the grant year, management combined the listing of adults and children served from two electronic health record systems and did not identify these six individuals were duplicates in the listings. Responsible Individuals: Project Directors (Missy Martini, Rebecca McCrackin) and CEO (Dan Ries) Corrective Action Plan: CEO will review reports prior to submission and will do random testing of numbers included in the report to ensure numbers reported have supporting documentation. Documentation used to complete the required reports will be retained by the Center. Anticipated Completion Date: This process was implemented beginning January 2023.

Finding 2022-004: Reporting Federal Agency Name: Department of Health and Human Services CFDA #93.087 Program Name: Enhance Safety of Children Affected by Substance Abuse Finding Summary: Through testing of one programmatic report, amounts reported did not agree to supporting documentation. Programmatic information included within the report were included in the wrong category for services provided to adults and children and amounts were included in two categories for services in which no adults or children were provided services. The preparer of the report improperly input the case sizes within the incorrect column within the report and entered incorrect information in two instances. The report included programmatic information in the wrong categories for services provided and services not provided to adults and children. Responsible Individuals: Project Directors (Christina Eggink-Postma, Sarah Heinrichs) and CEO (Dan Ries) Corrective Action Plan: CEO will review reports prior to submission and will do random testing of numbers included in the report to ensure numbers reported have supporting documentation. Documentation used to complete the required reports will be retained by the Center. Anticipated Completion Date: This process was implemented beginning January 2023.

Recommendation: We recommend that the University post and maintain the Student Aid Quarterly reports on the University?s website, as required. In addition, in order to prevent similar instances in the future, we recommend the University ensure interpretation of guidance is accurate through use of trainings, consultations and direct correspondence with the regulatory agency, when necessary, to ensure full understanding of reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The university agrees. OSU reported the HEERF student aid portion quarterly on our reporting webpage. We initially interpreted the guidance to mean that at each quarter we should update the report the total student portion on the webpage to be cumulative and the previous quarter report was removed from the website. OUS will go back and report each quarter separately instead of as one aggregate total. We will post this data on the current reporting page by February 10, 2023. Name of the contact person responsible for corrective action: Keith Raab, Director of Financial Aid Planned completion date for corrective action plan: February 10, 2023

2022-002 Internal Control over Compliance and Compliance with Reporting (Preparation of Schedule of Expenditures of Federal Awards) Auditor Recommendation: We recommend management attend Federal award trainings and information to ensure the documented policies and procedures can be performed as described. This will ensure the Federal funds are reported accurately on the SEFA and that programs are reported under the correct assistance listing number. Corrective Action: The year ended August 31, 2022 was the first year in which the Center expended federal awards in excess of the limit that requires a Single Audit. Since receiving the EIDL loan, the Center maintained detailed tracking and documentation of all disbursements associated with the loan and understood such expenditures exceeded the $750,000 threshold for a Singe Audit during the fiscal year ended August 31, 2022. With the clarification of the specific rules surrounding the disclosure of EIDL loans on the SEFA, management will continue to review Federal Award guidance and requirements to ensure compliance with current and future federal awards. Name of Responsible Contacts: Larry Goodpaster, Director of Finance & Operations, and Kelly Martin, Accounting Manager Projected Implementation Date: May 1, 2023 and ongoing

Finding Number: 2022-001 Untimely and Inaccurate Reporting - Planned Corrective Action: Management met with assigned Department of Education grant representative via telephone and received instructions for submitting revised quarterly HEERF reports. The Controller will revise all applicable quarterly reports for review and approval by the Chief Financial Officer. Management will re-submit the reports to the Department and post on the College's website as required. Person Responsible for Corrective Action Plan: Quintress Hollis (Controller). Anticipated Date of Completion: April 30, 2023.

FINDING 2022-005: CAFETERIA NUTRITION CLUSTER REPORTING The Deputy Treasurer prints, verifies, initials the Employee Trial Balance Report (Payroll Report) every pay period. The Treasurer reviews these reports, but has not initialed them. Corrective Action Plan: The Treasurer will begin reviewing and initialing these reports for FY 2023. The Cafeteria Director will submit the child reimbursement form to Central Office for review and verification prior to submission for payment to the Indiana School Lunch Program for FY 2023.

FINDING 2022-008 Contact Person Responsible for Corrective Action: Dan Durrwachter Contact Phone Number: 765-473-3081 Views of Responsible Official: We agree with these findings. Description of Corrective Action Plan: The financial specialist will prepare a report the data for the reports and will be approved by the treasure to ensure accurate FTE is reported before submitting the reports. Anticipated Completion Date: : 6/01/2023

FINDING 2022-004 Contact Person Responsible for Corrective Action: Danny Yost Contact Phone Number: 812-285-6221 We concur with this finding. The Auditor's Office will work with the County Attorney to add an extra layer of control to ensure the accuracy of the reporting. Anticipated Completion Date: Jan. 2024