Corrective Action Plans

Planned Corrective Action(s): SIG-NAL will enhance internal controls by implementing formal review and approval processes for payroll, expenses, and financial reporting. The organization will require documented evidence (digital or written) of all reviews and approvals and will maintain these records in a standardized, centralized system. The Finance Team will ensure that all controls are performed and documented in accordance with 2 CFR Part 200 requirements. Updated internal control policies and procedures adopted in 2025 address these requirements and are being fully implemented. Anticipated Completion Date ● March 2026 Responsible Party ● Director of Operations, with support from the Finance Team and Executive Director

Management has contracted with a contract accountant who has already started audit preparation services for future audits. The 2022 has been started and will be completed shortly. The 2023 audit will be started shortly. The Native Village expects to be fully caught up by their fiscal year 2025 audit.

Management will ensure that all required grant reporting, both financial and/or narrative/programmatic will be prepared and submitted timely. The final reporting for the Treasury CARES ACT has been completed and submitted subsequent to year end.

All FFR and PPR reporting requirements for all federal grants and agreements are tracked in a master spreadsheet, with reminders to all program and project managers at least 2 weeks in advance of reporting due dates.

Individual(s) Responsible: Chelsea BadHawk, Chief Financial Officer Action: Management will prepare and implement an internal control system that provides effective oversight of operations, reporting, and compliance. The systems and controls will be designed based on standards set forth in the Government Accountability Office Green Book. Anticipated Completion Date: 12/31/2025.

FINDING 2022-003 Information on federal program: Subject: Water and Waste Disposal Systems for Rural Communities - Reporting Federal Agency: U.S. Department of Agriculture Assistance Listing Number: 10.760 Federal Award Number: 92-02 92-03 Pass-Through Entity: N/A Compliance Requirements: Reporting Audit Findings: Significant Deficiency Condition: The City did not have proper controls in place to ensure that the annual report was accurately filled out and agreed to underlying detail. Context: Variances to key line items were noted when comparing the Form RD442-2 and Form RD442-3 to supporting documents. Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Management will ensure that reports agree to underlying detail. Responsible Party and Timeline for Completion: The Clerk-Treasurer is the responsible party. The completion will go into effect during 2025.

The Morgan County Economic Development Office acknowledges status reports submitted by the required due date for the CDBG program.

Management agrees with the finding and is implementing the accompanying corrective action plan. Views of Responsible Officials: Jacy Hyde, Executive Director Joel Rusco, Chief Financial and Administrative Officer Jessica Martinez, Deputy Director Contact Person: Jessica Martinez, Deputy Director Corrective Action Plan: In response to the FY21 Corrective Action Plan, CFSC implemented an updated Reporting Policy in June 2024 to ensure compliance with timely and accurate reporting to funders. This policy includes defined responsibilities for grant reporting and procedures for tracking report deadlines. To further strengthen compliance and eliminate late submissions, CFSC will implement the following corrective actions: 1.Report Deadline Tracking: CFSC will enhance its report tracking to flag upcoming report due dates and set reminder alerts for responsible staff. 2.Late Submission Justification: Any delays in submission (whether approved by funder or not) must be documented in the grant file. 3.Quarterly Compliance Audits on Reporting: CFSC will conduct quarterly internal audits to review: a.Timeliness of report submissions (ensuring they met funder deadlines) b.Accuracy & completeness of reports filed in the Master Grant File. c.Corrective actions for any delayed or missing reports. Anticipated Completion Date: These corrective actions will be fully implemented by the end of Quarter 2 of FY25.

2021-108 Lack of Documentation Related to Reporting Condition: The Organization did not maintain proper documentation in support of reporting requirements. Corrective Action Planned: The Organization has hired a new Chief Financial Officer as well as additional supporting staff within the finance department. Source documentation for grant reporting is retained and maintained in grant folders on the shared drive for future reference. The corrective action for this finding has been approved and implemented by the Organization. Person Responsible for Corrective Action: Joe Derry, Chief Financial Officer Anticipated Completion Date: Implemented

Management acknowledges the need to address and enhance this finding. We are committed to implementing new procedures for recording and tracking program income, including documenting its source, amount, and application. These procedures will be put in place within three months, with oversight provided by senior management to ensure proper compliance and effective implementation.

Management will be more vigilant and will review future filings before they are published.

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

We agree with the finding that CAC could not provide evidence in some instances that required demographic information, monthly, quarterly, or cumulative annual reports were submitted or submitted in a timely manner. In order to ensure that CAC maintains evidence of timely submission of all required reports in adherence to the requirements of 2 CFR 200.328, the following corrective action plan will be implemented. Beginning in the FY2025 fiscal year, CAC will add a senior level staff position designated as Director of Compliance. The Director of Compliance will review and update current policies and procedures regarding Compliance Reporting and Eligibility. The Director of Compliance will work with the CPO and CFO to develop and ensure reporting guidelines are established and applied. The Director of Compliance will maintain listings of all reporting requirements and work with the CPO and Program Directors to ensure timely reporting for grant award agreements, in accordance with the terms of each agreement. The projected date for full implementation of the corrective action plan for this finding is June 30, 2025. The contact persons for this corrective action are: Barbara Kelly, Executive Director, Windie Wilson CAC Human Resources Director, Misty Goodwin, CAC Chief Program Officer, CAC Director of Compliance, to be selected.

Finding No. 2022-007 We agree and acknowledge the audit findings related to the reporting discrepancies identified in Finding No. 2022-007, associated with our Federal Awards: H8031624, H8F41048, and H8D36529 under the U.S. Department of Health and Human Services (AL Program 93.224). To address this issue and ensure that future SF-425 reports are accurately aligned with the underlying accounting records, KCHC has implemented the following corrective actions: 1. Enhanced Reporting Procedures: A rigorous review process has been put in place to reconcile the SF-425 reports with the underlying accounting records before submission. The finance team will reconcile program expenditures and income monthly, ensuring that all figures match the accounting system's data. 2. Monthly Reconciliations: To maintain accurate and up-to-date records, we have implemented a monthly reconciliation schedule for all federal grants. This practice allows us to monitor the program's financial data consistently, reducing the possibility of variances between the reported and actual figures. 3. Training and Education: Our finance personnel have undergone additional training on SF-425 reporting requirements and reconciliation processes. This ensures that they are fully aware of federal guidelines and capable of handling reporting tasks accurately. 4. Improved Internal Controls: To further ensure compliance, we have enhanced our internal controls by requiring dual approval of all SF-425 reports. Both the preparer and the Chief Financial Officer (CFO) will review the reports to verify that the data aligns with the accounting records before final submission. We have also incorporated periodic internal audits to detect potential errors early. 5. Use of Integrated Software Systems: To improve accuracy and tracking, KCHC has integrated its accounting and procurement systems (ProcurementExpress) to facilitate real-time data entry and reconciliations for grants. These systems enhance the workflow and reduce the risk of manual errors. Implementation Timeline: Implemented in August 01, 2024 and by the end of Fiscal Year in April 30, 2025, KCHC will be in full compliance with the SF425 reporting requirements. Responsible person: Arlene Deleon Guerrero, CFO

Finding Number: 2022-005 Planned Corrective Action: AMHA and our accounting firm are working diligently to meet deadlines. Completed bank recs and financial documents are finished more timely. Anticipated Completion Date: January 1, 2023 Responsible Contact Person: Sherrie Boudinot

The County Clerk is in the process of perparing the needed documentation to document their internal control structure in conformity with the Uniform Guidance. The County will work diligently to comply with and to fully understand the proper procedures of completing the SEFA. As the state does not provide SEFA training, advice may be sought from Certified Public Accountants with SEFA knowledge and local governments.

FINDING 2022-005Contact Person Responsible for Corrective Action: Lynn Leininger, Business ManagerContact Phone Number: (260) 367-3677Whitko Community Schools concurs with the finding and will implement internal controls for all grantrequirements and reporting compliances of the Education Stabilization Funds. All reporting will be a jointeffort between the Business Manager preparing the reports with the assistance of the business officepersonnel. Supporting paperwork and calculations will be maintained to support all report informationsubmitted. Prior to submission of Education Stabilization Funds, all information will be reviewed andsigned by the Deputy Treasurer to insure reporting compliance.The completion date for this corrective action will be May1, 2023.INDIANA STATE

FINDING 2022-005Contact Person Responsible for Corrective Action: William LutherContact Phone Number: (812) 330-7700Views of Responsible Official: We concur with this finding. This finding has been remediated as of the completion dateshown below.Description of Corrective Action Plan:All Education Stabilization Funds applicable to the reporting in this finding have been expended as of the completion datebelow. We will continue to submit all future Education Stabilization Funds annual reports with evidence to support thesubmission.Completion Date: September 30, 2022

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