Corrective Action Plans

Contact Person Responsible for Corrective Action: Michelle Keene Contact Phone Number: (812) 384-4386 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Schedule of Expenditures of Federal Awards will include all Federal Awards. The SEFA will be verified with a sign-off by the Superintendent and compared to the supporting funds ledger. Anticipated Completion Date: FY23 SEFA

FINDING 2022-003 Contact Person Responsible for Corrective Action: Jason R. Watson, Assistant Superintendent Contact Phone Number: O?ce 812-866-6244 Cell: 812-599-0627 Contact Email: jwatson@swjcs.us Views of Responsible O?cial: We concur with this audit finding. Description of Corrective Action Plan: Action taken in an e?ort to remedy finding 2022-003 includes, but is not limited to, the following: ? Beginning December 27, 2022, an e?ective internal control system was implemented related to grant agreement and the reporting compliance requirements. ? The Assistant Superintendent prepares and formats the data for required reporting. ? The prepared and formatted data, and supporting documentation is shared via a DocuSign Envelope to be reviewed for accuracy. ? The DocuSign Envelope is routed to the Treasurer for the initial review. His/her eSignature indicates its completion. ? It is then routed to the Deputy Treasurer for a second review. His/her eSignature indicates its completion. ? The DocuSign envelope is then routed back to the Assistant Superintendent for submission, barring any required corrections. ? In the event that corrections to the report are required, the Assistant Superintendent?s eSignature in the appropriate location indicates that corrections are needed prior to submission. ? A second DocuSign Envelope, with the needed corrections, is then generated and proceeds through the process again. ? When the report is o?cially submitted, the Assistant Superintendent indicates its completion by eSignature in the appropriate location. ? The Superintendent monitors the internal controls by confirming that both the Treasurer and Deputy Treasurer have completed their review and indicates as such via eSignatures. ? The Chief Financial O?cer receives a carbon copy of the completed DocuSign Envelope. Anticipated Completion Date: December?27,?2022?

FINDING 2022-009 Contact Person Responsible for Corrective Action: Kasey Clark Contact Phone Number: 574-772-1604 Views of Responsible Official: We concur with the findings Description of Corrective Action Plan: Internal controls will be in place for ESSER funds so that Treasurer and Superintendent or Title I specialist will sign off on annual reports to ensure accuracy of ESSER dollars spent. Anticipated Completion Date: March 2023

FINDING 2022-006 Contact Person Responsible for Corrective Action: Kasey Clark Contact Phone Number: 574-772-1604 Views of Responsible Official: We concur with the findings Description of Corrective Action Plan: We will take the set aside amount and make a specific line in the financial software and report the amount that is needed as needed to be reported. The Treasurer will prepare the final expenditure report and the Title I Specialist will review the report to ensure the set asides are accurately reported. Anticipated Completion Date: March 2023

FINDING 2022-006 Contact Person Responsible for Corrective Action: Schauna Relue Contact Phone Number: 260-665-2854 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: Effective Immediately; Completion will occur when the next report is requested.

CORRECTIVE ACTION PLAN FINDING 2022-002 Contact Person Responsible for Corrective Action: Tamara Swartzentruber, Treasurer Contact Phone Number: 812-486-3220 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Treasurer has worked with management and will implement better controls when preparing the Annual Data Report on the COVID-19 Education Stabilization Fund. We will work to get the report reviewed and submitted on the correct due date. Anticipated Completion Date: April 2023

Condition: For the annual report covering January 1, 2021 through December 31, 2021, a number of the HEERF section (a)(1) and (a)(3) amounts reported as institutional portion spending were incorrect based on supporting documentation provided by the University. In addition, for the fourth quarter 2021 (quarter ending December 31, 2021) and the first quarter 2022 (quarter ending March 31, 2022) institutional portion reports, the University reported the full amount of section (a)(1) student portion of HEERF awarded to the University on the section (a)(3) line, when the amount on the section (a)(3) line should have been the total Fund for the Improvement of Postsecondary Education (FIPSE) funding awarded to the University. Also, for the quarterly student portion reports, the University reported the incorrect number of students who were eligible to receive a CRRSAA emergency financial aid grant during the fall of 2021. Corrective Action: We have updated our procedure for preparing and reviewing the required reports, and we have established a team from the finance department to discuss issues that arise. The team will handle the identified discrepancies through their resolution. The team will meet at least monthly, and as requested by the Senior Accountant of Grants or the Director of Finance and Accounting (DFA). The team is receiving training on procedures, guidelines, and terminology to ensure accuracy on completed reports to ensure compliance. The updated procedure is that the Senior Accountant of Grants will prepare the quarterly and annual reports based on data provided in the accounting system and from the Office of Financial Aid and assure that the reported data ties to the University?s records. The completed reports will be reviewed by the Director of Finance and Accounting. When needed, the finance team will meet to handle apparent discrepancies. Approved reports will be returned by the DFA to the Senior Accountant who will then post the reports for public viewing and submit a copy to the funder. Person Responsible For Corrective Action: Cedric Lewis, Director of Finance & Accounting Anticipated Completion Date: June 30, 2023

We agree with the finding, This was due to the modification of assistance listing number for two awards. We will strengthen our controls for review of all grant documents before issuing the SEFA report.

Finding Reference Number: 2022-003 Description of Finding: Per Title 2 CFR section 200.328, financial information and reports must be collected with the frequency required by the terms of the federal award. CDBG quarterly Cash on Hand financial reports are due within 30 days after the end of the reporting period. Statement of Concurrence of Non-compliance: During this period, there were zero cash amounts to report and the department personnel did not report. As such, we agree with this finding. Corrective Action: The employee understands that even if there is zero dollars to report, it must be reported regardless. This has been documented and will be done quarterly even if zero dollars.

FINDING 2022-002 (Auditor Assigned Reference Number) Contact Person Responsible for Corrective Action: Micah Williams Contact Phone Number: 765-832-2426 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Director of Finance and Facilities and Payroll Personnel Director will work together to confirm the information to be submitted in regards to the ESSER/GEER Funds. Both will sign off on the information. The information will then be reviewed by the Director of Curriculum and Superintendent to ensure that the reporting is accurate. Additionally, one of those individuals will sign off on the reporting. Anticipated Completion Date: Implemented Immediately

2022-004: Higher Education Emergency Relief Funds ? Assistance Listing No. 84.425F, 84.425M Recommendation: We recommend the University review its policies and procedures for the filing of the HEERF to ensure that there is sufficient time in the process to meet the due date in accordance with the stated criteria. The evidence of submission should include the original supporting documentation for the information published. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University has scheduled data gathering and reconciling processes to ensure timely 2023 filing. Name(s) of the contact person(s) responsible for corrective action: Michael Moos Planned completion date for corrective action plan: 06/30/2023

Finding 2022-002 ? Education Stabilization Fund ? Reporting Contact Person Responsible for Corrective Action: Kylie Enochs Contact Phone Number: (812) 659-1424 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Moving forward with the corporation?s ESF reporting, all data will be reviewed and have a formal sign-off, either by the superintendent or the other co-treasurer to ensure all data being reported is accurate. NOTE: The treasurer was in her first month in her position and was not a part of this filing. Moving forward, we are adjusting personnel to put the treasurer into the internal controls loop of the Title 1 program (which was responsible for filing the first ESF report. Anticipated Completion Date: Effective Immediately

FINDING 2022-005 Information on the federal program: Subject: Education Stabilization Fund - Annual Data Report Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Number: 84.425C, 84.425D, 84.425U Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness FINDING 2022?005 (Continued) Condition: The School Corporation did not have a documented review control in place to ensure the annual data report was reviewed by someone other than the preparer. Context: There was no documented review by someone other than the preparer of the Annual Data Report to ensure the information submitted was complete and accurate. Additionally, the School Corporation was not able to provide support for the total expenditures reported on the Year 1 Annual Report. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and will take the following corrective action ... Responsible party and timeline for completion: Brian L Christner, will ensure that all data reports and reviewed and signed by a third party. Completion date is April 30, 2023.

Finding No. 2022-002 Corrective Action Plan University Response: The University concurs with the finding concerning quarterly reporting of HEERF funds. Corrective Action: Rockhurst will conduct an additional review of the released guidance and reporting requirements to ensure compliance of any published, missing or future reports. In accordance with HEERF guidance, any reports with expenses that were incorrectly reported will be revised and publicly published, if applicable. Responsible Official: Kris Pace, Controller Anticipated Completion Date: June 30, 2023

Compliance requirement ? Reporting Institutional Comments on Findings and Recommendations: 1. The institution does not concur with the auditor finding because the institution strictly followed and used the recommended HEERF methodology and reporting guidelines to prepare the quarterly and annual reports. Since the institution used the reimbursement method, the drawdown were the actual expenditures/costs incurred and requested for reimbursement. The HEERF reporting requirement does not make any indication nor reference to GAAP. The Institutional aid portion expenditures were supported by the proper invoice or check. The evidence was available to the auditors. 2. The institution concurs with the auditor finding. The institution inadvertently, did not include a line item from one of the quarterly reports. The period to make corrections was closed and we sent an e-mail to the department to amend this annual report. 3. The institution concurs with the auditor finding. The annual report contains detail statistical information that not necessarily is supported by our institutions data base and programs. As the ED expressed, this information was unique and challenging, and accordingly, the institution made some reasonable estimates and derivatives in the information provided. As you may notice in the referenced table by the auditor, the differences were minimal. 4. a. The institution concurs with the auditor finding on the difference in Item #5 of the quarterly report. The institution will accordingly amend the report. b. The institution does not concur with the auditor finding on the timely and accurate reporting in publicly posting the quarterly Student Aid Portion. The four quarterly reports were timely submitted with an e-mail to the HEERF reporting staff and timely posted in the institution web page as required by the HEERF reporting instructions. The reports were further reviewed by an officer of the Department of Education (ED). The ED expressed that this information may be unique and challenging to an audit, and indicated that for these public reporting requirements, the auditors may accept as evidence of compliance, contemporarily produced e-mails, webmaster logs, or other relevant documentation establishing good-faith indication that the institution posted the required information at approximately the timelines established by the public reporting requirements. Copy of the e-mails were available to the auditors as evidence of compliance. ED understands that this information may be unique and challenging to audit, particularly because auditors are asked to verify information posted on a webpage which may not be accessible during audit fieldwork. For these public reporting requirements, auditors may accept as evidence of compliance, contemporarily produced emails, webmaster logs, or other relevant documentation establishing a good-faith indication that the institution posted the required information at approximately the timelines established by the public reporting requirements (HEERF Grant Program Auditing Requirements, General Requirements and Information - All HEERF Grantees). 5. The institution does not concur with the auditor finding because the referenced payment was made in accordance with the Institution's fund distribution and the student financial needs, among other factors, at the time of the evaluation and distribution of the funds. The student financial circumstances may have change after the distribution and payments of the financial aid. Additionally, this is an immaterial amount as compare to the total amount of the funds distributed ant the quantity of students served (1 out of 460). Actions Taken or Planned: The institution understands that no further is needed or required.

FINDING 2022-004 (Auditor Assigned Reference Number) Contact Person Responsible for Corrective Action: Greg Hunt Contact Phone Number: (219) 362-7056 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: LaPorte Community School Corporation will review the Education Stabilization Fund schedule of disbursements more closely prior to submission. Anticipated Completion Date: May 15, 2023

Significant Deficiency ? Item No. 2022-003 Criteria: The Hospital must establish and maintain effective internal control over federal awards that provides reasonable assurance that the Hospital 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 9 months of fiscal year-end, as well as quarterly internal financial statements. Condition: The Hospital 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 Hospital was not asked for the information after they failed to submit it. The audit 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: Nate Thompson, Chief Executive Officer

COLEGIO LA MILAGROSA, INC. (A nonprofit organization) CORRECTIVE ACTION PLAN JUNE 30, 2022 FINDING NO. CORRECTIVE ACTION COMPLETION DATE CONTACT PERSON 2022-001: FINANCIAL STATEMENTS ? The Organization, Colegio La Milagrosa, hired a new employee. This employee is being trained to comply with the recommendations and apply them to the school year of 2021-2022. ? The Food Service area hired a new accounting company, LRR Services as of July 1, 2018 and implemented the recommendation provided by the company RRC CPA Group, PSC, and to comply with the financial processes required in the 2 CRF 200. ? Also, subsequent to June 30, 2022, an internal accountant was hired, who among other responsibilities, is coordinating and supervising the record keeping and compilation of interim and year end closing and reporting process. ? As part of our internal controls, the Food Service area has created an implemented an internal guide with procedures related for accounting processes (attached in this report). June 30th 2022 Liz M. Santiago/ Odette Y. Pacheco Torres / Lizzette Ruiz / Hector Rodriguez

Corrective Action Purchased orders will be prepared with the correct accounting code to reflect expenditures in the right budget line items. Person(s) Responsible Shontell McQueen, Finance Coordinator; Leslie Baynes,Chief Finance Office; Bima Baje, School Business Administrator Planned Completion Date As of July 2022, corrective action has been implemented.

Finding: The Employment Security Department did not have adequate internal controls over and did not comply with requirements to ensure it submitted complete and accurate quarterly performance reports for the Workforce Innovation and Opportunity grant. Questioned Costs: Assistance Listing # 17.258 17.259 17.278 Amount $0 Status: Corrective action in progress Corrective Action: In response to the finding, the Department is in the process of developing a comprehensive system and set of protocols to strengthen internal controls over the completion and submission of quarterly performance reports for the Workforce Innovation and Opportunity Act (WIOA) grant. The Department: ? Executed a Workforce Integrated Technology Replacement Project that focuses on improving case management and data management internal controls. The Department estimates the project will be completed by December 2024. ? Initiated and is in the process of a statewide implementation of the U.S. Department of Labor (DOL) Quarterly Report Analysis data integrity and data quality internal controls system. The Department will: ? Continue to execute the Data Element Validation policy update for the Participant Individual Record Layout (PIRL) report per DOL expectations. ? Continue to provide technical assistance, training, and one-on-one coaching for the local areas, which cover WIOA Title I and WIOA Title III, PIRL reporting, data management, validation, quality, and integrity systems and processes. The conditions noted in this finding were previously reported in findings 2021-007 and 2020-012. Completion Date: Estimated December 2024 Agency Contact: Jay Summers External Audit Manager PO Box 9046 Olympia, WA 98507-9046 (360) 529-6718 Joshua.Summers@esd.wa.gov

All federal Project and Expenditure reports were filed timely and all actual expenditures were also reported correctly according to the report overview page. This finding deals with the body of the report which incorrectly listed the Justice Center Project twice, with the obligation amount of $880,00 listed for the project. This duplicated project has been removed from future reports. The finding noted for $175,741, once again has all the correct totals in project overview report, which should be the summation of the report. We have been rehiring staff with American Rescue Plan funds since 2021, and this has been an ongoing project. Once again, the report overview page lists the correct expenditures, however the body of the report has the project listed twice. This duplicated project has been removed from future reports. The reporting software gives a total of expenditures before you hit submit on each report, this total has always displayed the correct cumulative expenditure total. If projects were entered twice, the total expenditures should of been over by these dollar amounts, and they were not.

Criteria: The Hospital must establish and maintain effective internal control over federal awards that provides reasonable assurance that the Hospital 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 reserve fund at specified balance levels. Condition: During 2022, the accounts that represented the reserve fund had a balance below that required by the loan resolution agreements and required deposits were not being made to restore the balances to required levels. Planned Corrective Action: Management agrees with the finding and will deposit required amounts into the reserve fund. Planned Completion Date: Ongoing Person Responsible: Jeremy Bauer, CEO

The finance office will ensure proper education and administration of HEERF grant requirements. Cross training and education will occur with the College?s administration and business office to ensure regulatory standards and requirements are met. Future grant requirements will be noted on planning calendars, discussed at monthly meetings, and reviewed for assignment and compliance. Cross coverage will be planned with the financial aid office and senior accountant as needed for reporting deadlines.

SIGNIFICANT DEFICIENCY 2022-011 Education Stabilization Fund ? Higher Education Emergency Relief Fund ? 84.425 ? Reporting Condition Evidence of the date that quarterly reports were uploaded to the College?s website were not saved, and during inquiry with key personnel, it was determined that not all of the reports were uploaded within 10 days following the quarter end. The reports later had to be amended to add required information and update expense amounts, and the changes were not conspicuously noted or dated. In addition, errors were noted within the annual report. Recommendation We recommend that the institution implement controls to ensure that reports are completed timely and accurately, and that evidence of submission or upload dates is saved. Actions Taken As of March 23, 2023, evidence of public posting dates will be saved during the publishing process. In addition, a reconciliation has been implemented in which an individual other than the preparer will review the report for accuracy prior to submission or publication.

No yellow book findings noted in the current year. Single Audit Finding 2022-001 Federal Agency Name: Department of Education Federal Financial Assistance Listing: 84.425E, 84.425F Program Name: COVID-19: Higher Education Emergency Relief Student Aid Portion, COVID-19: Higher Education Emergency Relief Institutional Portion Reporting Significant Deficiency in Internal Controls over Compliance Finding Summary: During the testing over the reporting for the HEERF student and institutional funds, the reports that were required to be filed during the fiscal year were not filed by the required timeframe. Responsible Individuals: Director of Budgeting; HEERF Operations and Policy Analyst Corrective Action Plan: Management agrees with this finding. The University has resolved the delinquent status of the reporting for periods during fiscal year 2020-21 as of September 2021. In October 2021, the University hired a HEERF Operations and Policy Analyst (Analyst) to oversee the HEERF compliance requirements including reporting. Additionally, the Director of Budgeting is responsible to monitor the timely reporting of subsequent reports. Anticipated Completion Date: Completed in October 2021.