Corrective Action Plans

Name: Community Services Office of Hot Springs and Garland County Arkansas Contact: Leslie P. Barnes Contact Phone Number: (501) 538-5626 Audit Period Ending: 05/31/2022 Anticipated Completion Date: May 5, 2025 Finding 2022-004: Management concurs with the finding. The Organization has implemented a process where a staff accountant will prepare the necessary reports and the chief financial officer will review such reports. Alternatively, if the chief financial officer must prepare such reports, the review will be performed by the executive director.

Recommendation: We recommend the College review the reporting requirements and implement procedures to ensure that all required reports are issued/posted in an accurate and timely manner. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Collaborative workflow was developed between Grant PI's and IS department personnel to ensure that all reports are posted to the website in a timely manner. Name of the contact person responsible for corrective action: Clarissa Salhus, Finance Manager, Duane VanderGriend, CFO Planned completion date for corrective action plan: Completed as of January 14, 2026

Chairman of the Board of County Commissioners: This issue originated under the prior County Clerk’s administration where key reporting processes were not followed. The Board of County Commissioners and the other elected officials have made correcting this a top priority. Together, we are: • developing a comprehensive SOP to ensure accurate and timely tracking and reporting of federal funds, • improving communication and oversight between all county offices to ensure consistent reporting standards, • and ensuring annual compliance with federal reporting requirements. Our collective goal is to implement the policies and structures that will keep Osage County operating with the highest standard of accountability and excellence. County Clerk: I was not the County Clerk in office at this time. To correct this issue, the County plans to develop a SOP to timely and accurately track and report on federal funds. The SOP will be reviewed, adopted, and monitored by the Board of County Commissioners. County Treasurer: The County was under the understanding that once we established we were reporting as revenue loss, we would not have to submit the report annually. The final reporting was submitted prior to deadline.

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.

The Board of County Commissioners, with the cooperation and participation of all elected officials, reviews, develops and implements policies and procedures to create a strong internal control environment. The Board of County Commissioners will work with all elected officials, the third-party administrator, and federal, state and local partners to develop policies, procedures, and internal controls designed to accurately track grants, including the application process, verification, oversight, and reporting of grant requirements. To assist in this process, the Board of County Commissioners engaged a third-party administrator to oversee the grant process, including application, eligibility, review, requirements, contracting, recipient tracking and oversight, and documentation and reporting. The Board of County Commissioners will work with the third-party administrator to ensure proper grant administration.

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.

The Auditors Office will take the lead on tracking and reporting on any future programs such as Coronavirus State and Local Fiscal Recovery Fund.

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.

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

While discussing this issue with the USDA over email it was agreed that other expenses that were previously paid by the district and not covered by the USDA loan would be acceptable to use instead of the miscalculated, overage of the interest expense. The district had spent several hundred thousand dollars in funds above the originally budgeted district contribution towards the Water Storage Tank Project previous to acquiring the loan with the USDA.

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

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

Recommendation: The auditors recommend the University create an internal control to obtain reporting requirements for each award received by the University. They recommend a standard process be implemented for each award to track the due dates to ensure they are completed timely. Lastly, they recommend the data in the reports be supported to ensure the data is complete and accurate.Planned Corrective Action: Heritage University agrees to ensure that it meets the reporting requirements for each award it receives, and the university will establish internal controls. For each award, Heritage University will place a regular procedure to keep track of the deadlines and make sure everything is finished on time. Finally, to guarantee the data is complete and reliable, Heritage University will add support to the reports' data.Name of Responsible Party:1. Dr. Andrew Sund, President2. Thomas Richter, VP of Administration/CFO3. Melissa Hill, Interim Provost4. Corey Hodge, Interim VP of Academic AffairsAnticipated Completion Date: June 30, 2023

Reporting – Assistance Listing No. 93.224/93.527 Recommendation: We recommend that Promise Healthcare maintain supporting documentation for all reports required to be filed to the federal agency. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: 1. Create procedure to deposit all supporting files and schedules in a shared and accessible location: in progress a. Develop steps in the UDS process that outlines where working and final supporting schedules will be stored for future access b. Identify role or job that will handle responsibility for following the procedure. c. Formalize the process into a written procedure and add to the UDS Report or other relevant policy. d. After UDS submission, review data folders to check that all relevant supporting schedules and documents have been deposited.

Community Partners acknowledges that while performance reports were maintained for internal Community Partners grants, prior practice did not ensure that performance reports for fiscally sponsored programs were maintained by Community Partners. Current management will ensure that Community Partners maintains records to illustrate all required reporting is completed per funder requirements. The person responsible for the corrective action detailed above will be Joyce Williams, Chief Financial and Operations Officer, (213) 346‐3202. We anticipate corrective action will be completed by June 30, 2024.

The Board of County Commissioners will take measures to ensure future compliance with all requirements of federal grants

FINDING 2023-004 (Auditor Assigned Reference Number) Finding Subject: Education Stabilization Fund - Reporting Summary of Finding: The School Corporation had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance. The School Corporation was required to submit an annual data report to the Indiana Department of Education (IDOE) via JotForm, a form/report builder. Data to be submitted included, but was not limited to current period expenditures, prior period expenditures, and expenditures per activity. During the audit period the School Corporation was required to submit two ESSER I reports, two ESSER II reports and two ESSER III reports, for a total of six reports. However, the School Corporation failed to submit all six required reports. The lack of internal controls and noncompliance were systemic issues throughout the audit period. We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure reports are submitted timely and accurately. Contact Person Responsible for Corrective Action: Stefanie Grandstaff, Director of Business Services Contact Phone Number and Email Address: (574)-946-4010 ext. 230, stefanie.grandstaff@epulaski.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: In the future when there is a multiyear federal grant given to Eastern Pulaski Community School Corporation, the final expenditure reporting will be completed on a yearly basis to ensure annual reporting is accurate. Determination of grant requirements for reporting will be determined and procedures put into place upon acquiring a new grant. When submitting grants for reimbursements each month, the Director of Business Services and Superintendent review the reports pulled from Skyward, sign the reimbursement form and then the Director of Business Services will submit it for reimbursement. The same internal controls will be put in place for final expenditure reporting for grants requesting this information. Anticipated Completion Date: June 30, 2024

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

The Board of County Commissioners will take measures to ensure future compliance with all requirements of federal grants.

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

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