Corrective Action Plans

FINDING 2022-003 Contact Person Responsible for Corrective Action: Gerri Ford Contact Phone Number: 812-937-2400 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Corporation Treasurer will prepare the annual reports and ensure the amounts agree to the accounting records. The annual reports prepared by the Corporation Treasurer will be provided to the Director of Learning who oversees the Elementary and Secondary School Emergency Relief (ESSER) grant to review and approve the amounts reported are accurate. After review and approval from the Director of Learning, the annual reports will be submitted by the Corporation Treasurer. Anticipated Completion Date: May 2023

Corrective Action Plan in Response to Single Audit Finding Year Ended December 31, 2022 Type of Finding: Internal Control - significant finding; Compliance ? significant finding Recommendation: The Organization should improve processes and procedures to ensure that quarterly reports required by the pass-through entity are completed and submitted on a timely basis. Reference Number: 2022-001 View of Responsible Officials: Management agrees with the finding and recommendation. Corrective Action Plan: Management will review reporting requirements on the contracts and develop a timetable to ensure that the reports are prepared and submitted to the funder in compliance with the deadlines in the contract. Contact Person: Brent Arakaki, Chief Financial Officer, Telephone number: (808)792-8585, Email: barakaki@higoodwill.org Anticipated Completion Date: August 31, 2023.

Finding 2022-005 Federal Agency Name: Department of Education Program Name: Education Stabilization Fund ALN 84.425 Finding Summary: During our testing, we noted the following issues over reporting: ? The financial data reported in the some of the quarterly reports posted for the institutional portion were not supported by the underlying trial balance activity. Responsible Individuals: Courtney Judah, Director of Institutional Effectiveness Corrective Action Plan: During internal audit of disbursements, the College identified several student disbursements that should have been recorded as emergency funds granted under the intuitional portion and not student portion. Journal entries were made to correct and change the award to the institutional portion, but failed to update the prior term report. To prevent future communication errors the team revisited the process and added a reviewing and updating of reports from prior periods. Management meet with the Grant Administrator and attended 2 webinars throughout the year to improve reporting process. Anticipated Completion Date: December 30, 2022

FINDING 2022-007 Contact Person Responsible for Corrective Action: Mary K. Kaczka, Assistant Director, Community Development Contact Phone Number: 574-322-4472 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Financial Reporting: Management has developed the following process to correct for the lack of evidence for review or approval for reports that are submitted: Staff responsible for preparing the report in IDIS and management responsible for review for accuracy and completeness will both sign appropriate documentation detail (PR 5 and PR 7, draw spread sheets, draw vouchers) supporting the Cash on Hand Report and the IDIS report. CDBG staff has consulted with HUD CPD staff for additional training on how to complete the PR 26 report. The training assisted staff in filing two (2) past due reports and resulted in changes to the reporting process utilized by staff. Performance Reporting: Management will address the performance reporting weaknesses by taking the following steps: The assistant director of community development will document the segregation of duties for the completion and submittal of the CAPER before submission to HUD. Documentation will consist of a clear and understandable workflow on City workpapers, and final submissions, evidenced by signature (ink or digital stamp), email string other generally acceptable audit trail. Additionally, as part of continuing education, CDBG staff participated in a workshop organized by our CDBG consultant this past June, 2023 to better understand the Section 3 reporting requirements. Special Reporting for Federal Funding Accountability and Transparency Act (FFATA): Management will address the weaknesses identified in Special Reporting for Federal Funding Accountability and Transparency (FFATA) by taking the following actions: Management will review and strengthen the current process in place for identification and timely submission of projects that qualify for FFATA reporting. Completed reports will show evidence of segregation of duty for completion, and review and approval. Anticipated Completion Date: August 31, 2023

FINDING 2022-003 Contact Person: Jo Ann Treon Phone Number (765)948-4632 Views of Responsible Official: We concur with the findings. Description of Corrective Action Plan: Forms RD 442-2 & RD Form 442-3 will be completed in August 2023. Anticipated Completion Date: Immediately

FINDING 2020-002 Contact Person Responsible for Corrective Action: Shelly Harrison, Corporation Treasurer Contact Phone Number: 765-492-5102 Views of Responsible Official: We concur to the findings; however, while completing the ESSER Reports, some formatting errors of the provided spreadsheet created some questions by the North Vermillion officials prompting a clarification email to the DOE. Since the formatting errors were not addressed and all completed boxes on the North Vermillion ESSER Report spreadsheet turned green (indicating the correct amounts on the spreadsheet), the North Vermillion officials felt the ESSER report submitted was correct. Description of Corrective Action Plan: To correct the internal control issue, the Superintendent and Corporation Treasurer will work independently as well as collaboratively on the ESSER Reports. Prior to submitting any future report, the corporation officials will document their work by signing off and dating the report prior to submission to the DOE. To rectify the incorrect dollar amount on the Yearly ESSER Report Spreadsheet, the corporation treasurer and superintendent will work collaboratively to correct the amounts on either the ESSER I Year End Report and the ESSER II Year 2 and/or Year End Report. Anticipated Completion Date: Both the Internal Control and ESSER I corrective actions have been corrected, with the ESSER I Final Expenditure Report being completed and signed off on. The ESSER II corrective actions will be completed on the upcoming ESSER III Year End Report when that report is due.

FINDING 2022-003 Contact Person Responsible for Corrective Action: Jeff Gambill, Superintendent; Jennifer Barcus, Corporation Treasurer. Contact Phone Number: 812-665-3550 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Corporation Treasurer will begin reviewing all annual data reports completed by the Superintendent, prior to submission of the reports, to verify that all expenditures are reported in the correct reporting period. Anticipated Completion Date: Immediate review will begin of all annual data reports.

Finding 2022-001 (L - Reporting) US Department of Homeland Security, Federal Emergency Management Agency, Assistance Listing 97.036 Disaster Grants ? Public Assistance (Presidentially Declared Disasters) Name of contact person: Rob Tonkinson, Vice President, Corporate Finance Corrective action: The Vice President, Corporate Finance will review and approve all quarterly and other required reports prior to submission. Proposed completion date: November 30, 2023

FINDING 2022-001: Timelv Financial Close As noted in Finding 2022-001, the cause of the delay in closing was primarily a lack of staff and the inability to recruit sufficient knowledgeable staff. Since that time all vacant positions in the Finance Department have been filled. Planned Corrective Action: Landmark has analyzed its staffing level and determined that the current positions when fully staffed are sufficient to complete the financial closing in a timely manner. However, Landmark will continue to monitor its staffing and adjust as deemed necessary. FINDING 2022-002: Accurate Quarterly Reporting All HEERF quarterly reports were filed in a timely manner and in accordance with the guidance available at the time. As soon as Landmark became aware of the updated guidance, amendments were prepared. Planned Corrective Action: Landmark has amended and filed all HEERF reports as necessary to comply with current guidance.

2022-001 ? COVID-19 ? Education Stabilization Fund - Significant Deficiency in Reporting Recommendation: The School should assign an individual to monitor reporting requirements of HEERF awards to ensure the School is in compliance. Planned Action The School plans to review enhance processes related to HEERF reporting to ensure compliance with the requirement of Section 18004(e) of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), Section314(e) of the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) and 2 CFR sections 200.328 and 200.329. Proposed Completion Date: The School will review processes to ensure we are in compliance by March 15, 2023.

Higher Education Stabilization Fund (HEERF) Reporting Planned Corrective Action: Corrected quarterly reports will be completed and the practice will be maintained for any future funding received. Person Responsible for Corrective Action Plan: Cindy L. Weaver, Interim CFO/Director of Finance Anticipated Date of Completion: July 25, 2023

Finding Number: 2022-004 Condition: The University did not file accurate and timely reports throughout the fiscal year. Planned Corrective Action: 1. The 9/30/21 HEERF institutional report was posted on the University?s website 10 days late. This was due to the staff member responsible going out on medical leave and miscommunication within the area on required filings. There were no additional quarterly reports to be filed so no further controls were put in place for this reporting. The annual report was filed timely. 2. The 9/30/21 institutional report has been removed from the University website as it indicated a duplicate expense that was reported on the 6/30/21 quarterly report. The 06/30/21 report has been marked as the final institutional report. 3. The Student Financial Aid (SFA) office agrees that the March 31, 2022, student website report did not include language regarding eligible students, and the reported student count was incorrect. SFA will amend the March 31, 2022, quarterly student report to reflect the correct number, add language regarding eligible students, and send the correction to the appointed HEERF email address by June 1, 2023. The Associate Director of Compliance and Training will perform a secondary review of any future reports to ensure the completeness and accuracy of the information. 4. The Student Financial Aid (SFA) office agrees that the 2021 annual report included the incorrect number of part-time graduate students who received an award, impacting the total number of students reported. The error was due to incorrectly inputting the information from the supporting data onto the annual report. SFA will amend the 2021 annual report by correcting the number of part-time graduate students by March 24, 2023. The Associate Director of Compliance and Training will perform a secondary review of the data on the annual report and compare it with the supporting documentation. 5. As indicated in the report, the University did comply with earmarking requirements. However, the categories used to report the expenditures on the 12/31/21 annual report were not the specific earmarked categories. The 12/31/21 annual report filed through the Department of Education website has just recently been made active again and the University will make necessary category reporting corrections. As the 12/31/21 annual report was the final report for institutional expenses no additional actions are required. Contact person responsible for corrective action: Colleen Scarff, Assoc VP for Business and Finance and Lana Greaves, Senior Associate Director, Student Financial Services Anticipated Completion Date: 3/24/23

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 2022-002 Program: COVID-19: Coronavirus State and Local Fiscal Recovery Funds CFDA No.: 21.027 Federal Grantor: United States Department of the Treasury Passed-through: N/A Compliance Requirements: Reporting Auditor Recommendation: We recommend the City enhance internal controls to ensure Interim and Project and Expenditure Reports are prepared in accordance with program requirements. Views of Responsible Officials and Corrective Action: We concur with the recommendation and will enhance internal controls to ensure that the Interim and Project and Expenditure Reports are prepared in accordance with program requirements. During this reporting period, there was no clear direction from the State on how to submit prior period corrections, so to achieve this action, City staff submitted a zero ?current expenditure? and then included the prior period adjustment in the cumulative total. Since the audit found that this was the wrong process and a deficiency in reporting, the City will reach out to the State for assistance in reporting prior period corrections. The City will ensure a thorough review prior to submitting to ensure the report is accurate. The City also encountered reporting difficulties for the quarter ending 6/30/2022 with entering vendor information. City staff contacted the State to request assistance, however the State was overwhelmed with requests from agencies state-wide and was not able to respond to the City?s request in a timely manner. The State was aware of the issues and had allowed Cities to submit their report late. The City has not had any issue subsequent to the 6/30/2022 report and has been submitting its report timely. Name of Responsible Person: Kim Sao, Finance Director Implementation Date: 6/30/2023

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.

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.

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

FINDING 2022-001 Program: COVID-19: Coronavirus State and Local Fiscal Recovery Funds CFDA No.: 21.027 Federal Grantor: United States Department of the Treasury Passed-through: N/A Award No. and Year: Various Compliance Requirements: Reporting Management?s or Department?s Response: We concur. Views of Responsible Officials and Corrective Action: The City reported expenditures for the entire award amount based on the guidance available at the time of the initial reporting period for the award. This resulted in over reporting expenditures for the audit period since only half of the award was remitted to the City during the period under audit. The City has put measures in place to ensure only expenditures for the amount received in a particular period are reported. Name of Responsible Person: Kofi Antobam, Director of Administrative Services Implementation Date: June 30, 2022

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.