Corrective Action Plans

Finding 2022-004 Subrecipient Monitoring and Special Tests and Provisions Material Weakness in Internal Control Over Compliance and Material Noncompliance Federal Agency Name: Department of Health and Human Services Program Name: Immunization Cooperative Agreements CFDA Number: 93.268 Finding Summary: The County did not formally communicate the required information to the subrecipient. No subrecipient agreement was executed. In addition, no monitoring activities were documented, including monitoring of the program?s special tests and provisions. Responsible Individuals: Allie White, County Health Department Executive Director Corrective Action Planned: Dubuque County is working with the Dubuque Visiting Nurse Association on implementing a subrecipient agreement and will put a control process in place to monitor. Anticipated Completion Date: June 30, 2023

Single Audit Corrective Action Plan FY 2022 / Finding: / AFG acknowledges that an internal control deficiency existed within the credit card process and procedures, during Fiscal Year 2022. The process required staff to forward credit card documentation to the finance department, via email, in person, or using an accounts payable mailbox. The finance staff would then collect and maintain all receipts and other supporting documents pending the monthly credit card review and reconciliation. After receiving the approved credit card statements from cardholders, the finance staff would undertake the task of matching the receipts and other support documentation to the appropriate staff person?s credit card. / In the current period, Fiscal Year 2023, the finance team has developed and implemented controls to ensure program expenditures on agency credit cards and supporting documents are: / 1. Reviewed and approved by a supervisor, to ensure that expenditures are allowable costs within the program and grant guidelines. / 2. Supported by the appropriate and required documentation. / 3. Submitted timely both internally to the finance department, as well as externally to funding sources. / 4. Stored and maintained for future refence, by the finance department and the program staff responsible for credit card purchase. / 5. Reviewed for financial recording accuracy by the finance department's grants manager and controller. / In January 2023, AFG management, including the finance team, revised and streamlined the credit card process by eliminating multiple modes of submission for credit card required documentation, reducing the occurrence of misplaced documents. The new process also includes the development and implementation of an electronic shared filing system. The credit card expenditures and supporting documents are maintained in the electronic files by the cardholders' names and are also uploaded to the accounting software. / Additionally, effective March 31, 2023, AFG revised the agency's Credit Card Policy and Procedures to include fixed deadlines for the submission of credit card required documentation. The revision also outlined more specifically the required process for submitting credit card documents. As stated, in the revised procedures, monthly credit card packages must be submitted to the finance department on or before the established deadline, via email. The Credit Card Packages include the approved Staff Credit Card Statement, legible copies of credit card receipts, and any other required documentation that supports the purchase. / Additional enhancements to the credit card process include reviews for accuracy by the grant manager and controller of credit card reconciliations and financial postings. The credit card packages are uploaded and maintained on AFG's accounting software, and the finance department's shared files. Credit Card Packages are only submitted to and accepted by the finance department via email. The AFG staff member who is responsible for the credit card purchase must maintain the hard copy of the purchase receipt and any other support documents received directly. / AFG's management appreciates the efforts of the George Johnson & Company auditing staff, as well as this opportunity to strengthen the internal control structure and procedures. We are confident that the revised credit card procedures will significantly reduce the occurrences of misclassifications of program expenditures and misplacement of required support documentation.

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

#2022-002: Material Weakness in Controls over Compliance: Administrative Requirements of Uniform Guidance -Administrative Policies Recommendations: Grand Rapids Christian Schools should consider the following written policy additions or updates: ? Financial Management (2 CFR 200.302) The financial management policy should include records documenting compliance, and the tracking of funds to determine that expenditures are in accordance with the terms and conditions of the federal awards. The financial management and reporting system must provide the following : ? Identification - Title of the award, CFDA number ? Complete disclosure of accurate and current financial results of each federal award ? Source and application of funds for federal award activity ? Record retention and access - define the time period for which records must be kept (can vary by grant agreement), and who has the ability access the records (?200.333 - ?200.337) ? Written procedure to implement cash management requirements (see below) ? Written procedures for determining the allowability of costs (see below) ? Cash Management (2 CFR 200.305) A written policy is required by Uniform Guidance detailing the Organization's procedures to minimize the time that elapses between draw and expenditure of federal dollars. ? Allowable Costs (2 CFR 200.302(b)(7)) The Organization must have written procedures for determining the allowability of costs in accordance with Subpart E - Cost Principles of Uniform Guidance and the terms and conditions of the Federal award. This includes the determination of allowable costs and the review of this determination. The standard assumes policies and procedures are in place for disbursements, and the allowable cost policy will demonstrate how the Organization ensures compliance. The criteria for costs to be considered allowable are documented within 2 CFR 200.403. ? Procurement Standards (2 CFR 200.317 - 200.326) The Organization must have a written policy that promotes full and open vendor competition, conflict of interest policies should cover employees as well as the organization, and general purchase requirements with specific thresholds as set forth by the Uniform Guidance. There are five allowable procurement methods as described in ?200.320, depending upon the dollar value of the purchase or contract. Views of Responsible Officials and Planned Corrective Actions: ? Grand Rapids Christian Schools follows procurement and record retention standards provided by the USDA. ? GRCS does not have actual written policies and procedures for Financial Management, Cash Management, Allowable Costs, and Procurement Standards, but do have practices in place to follow USDA guidelines. In the case of cash management, the only location that takes cash is GRCHS. In that instance, along with Meal Magic, cash registers are zeroed out and balanced to Meal Magic and cash deposits are made daily. ? GRCS Business Office will work with the Food Service Director to begin formulating written policies and procedures specific to Grand Rapids Christian Schools. GRCS will utilize the resources from Uniform Guidance and Code of Federal Regulations (CFR) to develop policies that are compliant with those requirements prior to June 30, 2023.

Views of Responsible Officials and Corrective Action: Us Helping Us has developed the proper systems to ensure proper filing and maintenance of documentation supporting various expenditures. Of note, Us Helping Us has developed a process to track income receipts from various sources, including donors, and will be able to verify any donor mandated restrictions, and that contributions conform to said donors/payees. Us Helping Us has made progress in implementing systems for documentation, and as with expenses, documentation will be maintained electronically on the organization’s server, in the financial software used and filed in the Fiscal Manager’s office. The Executive Director and the Deputy Executive Director, Development will be responsible for developing, implementing, and maintaining the plan, which will be effective immediately.

Views of Responsible Officials and Corrective Action: Us Helping Us has developed the proper systems to ensure proper filing and maintenance of documentation supporting various expenditures. In addition, Us Helping Us will maintain the appropriate internal controls to sure that the appropriate documentation for general expenditures is maintained. In this regard, copies of contracts will be maintained electronically on the organization’s server, in the financial software used and filed in the Fiscal Manager’s office. The Executive Director and the Deputy Executive Director for Finance and Administration will be responsible for developing, implementing, and maintaining the plan, which will be effective immediately.