Corrective Action Plans

FINDING 2023-002 Finding Subject: Subject: COVID-19 - Education Stabilization Fund - Reporting Summary of Finding: Reports submitted were not substantiated by the ledgers. Contact Person Responsible for Corrective Action: Kellie Romer (Corporation Treasurer/Finance Director) Contact Phone Number and Email Address: 765-653-9771 Ext. 1010, kromer@greencastle.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: The school corporation will establish a proper system for internal controls and develop procedures to ensure reports are supported by the financial records. Anticipated Completion Date: Immediately 2/8/2024

FINDING 2023-002 Finding Subject: COVID-19 – 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 annual data reports 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 submitted two ESSER I reports, two ESSER II reports and two ESSER III reports, for a total of six reports. The annual data reports were complied, prepared and submitted by the Assistant Superintendent without an oversight or review process in place to prevent, or detect and correct, errors. Furthermore, the reported data on two of the reports could not be traced back to records that accumulate or summarize the data; therefore, the accuracy and completeness of the reports could not be verified. Contact Person Responsible for Corrective Action: Jim Diagostino, Superintendent, and Lori Bennett, Treasurer Contact Phone Number: 317-539-9200 Views of Responsible Officials: We agree with the finding. Description of Corrective Action Plan: The Superintendent, or designee, will prepare the annual data reports to be reported to the IDOE by using records that accumulate or summarize the data. Prior to the submission of the reports, the Treasurer will review the records and annual data report. The Treasurer will initial and date a hard copy of the report to ensure accuracy and completeness. Anticipated Completion Date: March 31, 2024

The University filed four quarterly HEERF reports for the year that accurately reflected the spending and accounting of federal funds. The report in question is the annual report, which, by its design (it cannot be saved prior to submission, and the only way to print it is to print a screen shot of each of the 48 pages) makes review before submission extremely difficult. There were literally hundreds of entries in this report, and there were three errors, each of which reflected information that was reported accurately in the quarterly reports posted on the University’s website. Despite the unfortunate design constraints, the University will endeavor to identify a practical way to conduct a review of the annual report before submission next spring. Anticipated Completion Date: Continuing Responsible Contact Person: Eugene L. Munin

Corrective Action Planned: This was first brought to the Authority’s attention in the current year. The Authority is working towards submitting appropriate reports. Anticipated Completion Date: Ongoing Contact Person Responsible: Jennie Weary, Treasurer/Secretary

Identifying Number: 2023-002 Finding: For 2 out of the 8 reports selected for the COVID-19 Coronavirus State and Local Fiscal Recovery Funds program, the reports were not submitted within the required timeframe. For 3 out of the 8 reports selected, there was no evidence of submission. For 2 out of the 5 reports selected for the Transitional Living for Homeless Youth program, the reports were not submitted within the required timeframe. For 2 out of the 5 reports selected for the Basic Grant program, the reports were not submitted within the required timeframe. Corrective Action Plan for Audit Finding 2023-002: Calendar reminders will be created for both financial and performance reports. Director Finance & Business will follow up with the program for the status of performance report submissions. Chief of Staff, The Relatives will maintain a PDF of performance report submission emails. Responsible for Corrective Action Plan: Julie Pool, Director of Finance & Business, Program Director, Youth Focus and Chief of Staff, The Relatives

2023-006 – Reporting – Material Weakness in Internal Controls over Compliance and Material Noncompliance Recommendation: The auditors recommend the University create an internal control to obtain reporting requirements for each award received by the University. The auditors recommend a standard process be implemented for each award to track the due dates to ensure they are completed timely. Planned corrective actions: The university will create an internal control policy to ensure that it has the necessary paperwork for each award it receives. This will be the routine procedure followed for every award in order to keep track of the deadlines and finish on time. Name of Responsible Party: 1. Grant P.I’s 2. Terri Slack, Fiscal Officer 3. Yolanda Maltos, Grant Accountant 4. Melissa Hill, Provost 5. Alysia Stevens, Controller 6. VP of Administration, CFO 7. Dr. Andrew Sund, President Anticipated completion date: 6/30/2024

2023-004 – Reporting – Material Weakness in Internal Controls over Compliance and Material Noncompliance 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 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 actions: Heritage University will update the previously posted reports to accurately reflect the actual expenditures during FY21, FY22 & FY23 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 Accountant 2. Alysia Stevens, Controller 3. VP of Administration/CFO 4. Dr. Andrew Sund, President Anticipated completion date: 6/30/2024

Planned Corrective Action: We agree with the auditor’s comments, and the following action will be taken to improve the condition. Director Will Triplett and Manager Clarissa Lostaunau will implement a written policy included in the HSP Policy and Procedure Manual outlining accurate process and completion of the HSP 14 monthly reporting. The manual will include written steps on obtaining, verifying and storing all backup documentation for all data on the HSP 14. The team will also include a verification process before the submission of the report where two employees approve the monthly report as an internal control, one being from management. This will be completed by December 31, 2023 and led by Director of Transformational Services, Will Triplett.

Donovan CPAs 9292 N. Meridian St, Ste 150 Indianapolis, IN. 46260 Attn: Jacob Stephenson Re: Response to Audit - 7/1/22 - 6/30/23 Single Audit December 21, 2023 Regarding Finding 2023-001 Reporting Significant Deficiency occurred as a result of inadequate controls to ensure accurate reporting to eh DOE. Correct 1.Regarding Finding 2023-001 Reporting Significant Deficiency occurred as a result of inadequate controls to ensure accurate reporting to the DOE. Corrective Action Plan as Follows: a. Deborah Czmiel (CFO) will request grant reports which include total expenses for each federal grant from BPI for the reporting period. b. Deborah Czmiel (CFO), Deborah Snedden (Superintendent) and Jeff Wood (Asst Superintendent) will compare grant reports from BPI to financial statements. Any discrepancies will be addressed and resolved by Deborah Czmiel (CFO) prior to submission of final report. c. Deborah Czmiel (CFO) will complete and submit the final reports, after the expense totals have been confirmed and reconciled. With collaboration of the administrative team and the proper checks and balances as identified above any future inaccurate submissions will not occur. Respectfully, Deborah s. Czmiel CFO/Business Manager

Failure to Properly Track Grant Expenditures Recommendation: We recommend that the Clinic maintains an effort to track federal and state funding and expenditures separate from regular program expenditures, inquiring of granting agencies if needed. Action Taken: Management is now properly tracking grant expenditures and can accurately state quantities of grant expenditures.

Finding 2023-002 Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing: 21.027 Federal Agency: U.S. Department of the Treasury Passed-through: N/A Award Year: 2022-2023 Compliance Requirement: Reporting Grant Award Number: Applies to all awards with findings and no specific grant award. Type of Finding: Material Instance of Noncompliance, Material Weakness in Internal Controls over Compliance Management’s Response: We concur. Views of Responsible Officials and Corrective Action: Management agrees with the finding and understands the importance of properly reporting federal and will institute a multi-step review system before such reporting is finalized and submitted. Name of Responsible Person: Terri Willoughby, CFO Name of Department Contact: Finance Projected Implementation Date: January 1, 2024

Finding #2023-003 - Major Federal Award Finding - Reporting Significant Deficiency-in Internal Controls over Compliance Corrective Action Plan: Procedure(s) were drafted covering data collection, storage, and reporting of HEERF data, including setting alerts to comply with the reporting due dates, however, the VP of Finance did not adhere to them. The VP of Finance will meet with the Executive Vice President to set up an accountability structure to ensure that quarterly reports are reviewed and filed on or before the due date. A revised annual report for calendar 2022 will be submitted to the Department of Education.

The University filed four quarterly HEERF reports for the year that accurately reflected the spending and accounting of federal funds. The report in question is the annual report, which, by its design (it cannot be saved prior to submission, and the only way to print it is to print a screen shot of each of the 48 pages) makes review before submission extremely difficult. There were literally hundreds of entries in this report, and there were three errors, each of which reflected information that was reported accurately in the quarterly reports posted on the University’s website. Despite the unfortunate design constraints, the University will endeavor to identify a practical way to conduct a review of the annual report before submission next spring. Anticipated Completion Date: Continuing Responsible Contact Person: Eugene L. Munin

The College did not report total expenditures on the quarterly reports for the ALN 84.425M (SIP). The College will revise procedures to ensure amounts reported on the reports are accurate.

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