Corrective Action Plans

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

Name of Contact Person: Sue Nickerson, Town Accountant

Corrective Action Plan: The District has had turnover of personnel in the Business Office this past fiscal year. As the new Director of Business and Finance there will be procedures implemented to ensure that sufficient documentation for transactions for costs charged to federal programs is supported by documentation as required by the Uniform Guidance regulations. Additionally, there will be a review of current purchasing policies, to add or amend, which will further help support meeting the federal guidelines. Lastly, it should be noted that the Town/School financial system will be converting/upgrading to MUNIS ERP Solution for the Public Sector. This upgrade will be very instrumental in maintaining the necessary information to meet audit requirements.

Proposed Completion Date: Immediately

The Settlement agrees with the finding. The Assistant Controller prepares the form SF-425 reports and the Controller reviews and approves them for submission. These forms and supporting documentation are saved and retained in SharePoint. SF-425 due date reminders are posted in preparer’s calendar and adherence to the due dates is monitored by the Controller. Implementation began July 2022. Responsible parties: Assistant Controllers, Controller Completion date: 7/1/2022

The Settlement agrees with the finding. Fiscal and program staff will update CACFP Policies and Procedures to ensure that all CACFP records are retained for a minimum of three years. CACFP eligibility will be clearly documented and retained for three years by program staff. Fiscal and program staff will update CACFP Policies and Procedures to reflect subrecipient eligibility and related paperwork. Staff will be trained on completing and maintaining CACFP enrollment and eligibility paperwork via CACFP online workshops. Managers will complete management KidKare training to optimize electronic record-keeping of CACP documentation. The Compliance Director will complete an unannounced monitoring review of enrollment paperwork quarterly. Policies and Procedures will be edited to reflect rules and regulations for enrollment and eligibility paperwork. Implementation began October 2023. Responsible parties: Fiscal and Program staff, Compliance Director Completion date: 10/1/2023

The University concurs with the finding. The SNAP-Ed office experienced significant staff turnover during fiscal year 2022, and records could not be located. The University has established workflows and policies to ensure compliance and documentation currently and in the future.

The University concurs with the finding and has taken proactive measures to ensure compliance. Specifically, the University has established a digital folder dedicated to maintaining all records pertaining to HEERF funding and lost revenue calculations.

Finding: 2022-006: Significant Deficiency in Internal Controls over Compliance – Cash Management Name of Contact Person: Shema Jones CFO Catholic Community Service 1803 Glacier Highway Juneau, AK 99801 Corrective Action: Controller reviews and corrects billings received which includes backup by AR, then CFO reviews prior to submission to payment management system. Proposed Completion Date: 6/30/23

FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AUDIT Finding: 2022-003: Significant Deficiency in Internal Controls over Compliance – Reporting Name of Contact Person: Shema Jones CFO Catholic Community Service 1803 Glacier Highway Juneau, AK 99801 Controller reviews and corrects reports received which includes backup by the Staff Accountant, then CFO reviews reports created by Controller prior to submission. Proposed Completion Date: 6/30/23

US Department of Housing and Urban Development Federal Financial Assistance Listing #14.157 Supportive Housing for the Elderly (Section 202) Finding Summary: As a result of management transition, supporting documentation for expense transactions and tenant eligibility were destroyed and were unable to be recreated. The organization was lacking appropriate internal controls to ensure records were retained for the required period of time. Responsible Individual: Dawn Helmowski, Finance Director Corrective Action Plan: Subsequent to the audit period under review, the affiliated entity of Luther Social Services of North Dakota has been replaced with Beyond Shelter, Inc. Upon this change, the new LSS Jamestown Housing, Inc. Board of Directors, implemented a Document Retention and Destruction Policy that includes retention or required documents for the required time periods that will ensure documents are retained. This policy was put into place on April 19, 2023. Anticipated Completion Date: April 2023

Community Partners acknowledges that documentation to support expenditures was not consistently kept across all federal grants. Current leadership has addressed this issue by implementing documentation standards across all federal grants. Furthermore, through the implementation of NetSuite, expenditures will be fully supported and approved by staff before posting. 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.

FINDING 2023-002 (Auditor Assigned Reference Number) Finding Subject: Child Nutrition Cluster - Eligibility Summary of Finding: The School Corporation had not properly designed or implemented a system of internal control, which, would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting noncompliance related to the eligibility determination of a child receiving meals. Any child enrolled in a participating school or summer camp, who meets the applicable program’s definition of “child”, may receive meals under applicable programs. A child belonging to households meeting nationwide income eligibility requirements may receive meals at no charge or at a reduced price. Children that have been determined ineligible for free or reduced-price meals pay the fun price for their meals. A child’s eligibility for free and reduced-priced meals under a Child Nutrition Cluster program may be established by the submission of an annual application or statement which furnished such information as family income and family size. The School Corporation determines eligibility by comparing the data reported by the child’s household to published income eligibility guidelines. Annual eligibility determinations may also be based on the child’s household receiving benefits under SNAP, FDPIR, the Head Start Program, or, under most circumstances, the TANF program. A household may furnish documentation if its participation in one of those programs, or the School Corporation may obtaine the information directly from the State or local agency that administers those programs. Certain foster, runaway, homeless, and migrant children are categorically eligible for free school lunches and breakfasts. Direct Certified households do not need to complete an application. The School Corporation’s child nutrition program software company, Skyward, automatically imported the eligibility parameters into the system., There was no evidence of an oversight, review, or approval process to ensure that the eligibility parameters entered into the Skyward system were accurate and that eligibility statuses were being correctly determined. A Sample of students receiving free or reduced lunches as selected for testing. The following issues were noted with the first students tested: 1.) Six of the 14 students were determined to be processed at the incorrect eligibility. Errors noted were: a. Three students had an eligibility determination of free; however, their eligibility determination should have been reduced. b. One student had an eligibility determination of reduced; however, the eligibility determination should have been paid. c. Two students were determined to be reduced; however, their eligibility determination should have been free. 2.) One of the 14 students did not have a completed application on file; thus, a determination of eligibility could not be made. 3.) Two students were direct certified; however, the School Corporation did not retain the monthly direct certification reports ran to support this determination, nor could the reports be recreated. Due to the number and magnitude of exceptions, per auditor judgement, we concluded it would not be appropriate to examine the remaining 26 students. The lack of internal controls and noncompliance were isolated to the 2022-2023 school year. We recommended that the School Corporation's management establish a proper system of internal controls and develop policies and procedures to ensure student eligibility for free or reduced price lunches is accurately determined and that all documentation is retained. Contact Person Responsible for Corrective Action: Contact Phone Number and Email Address: Stefanie Grandstaff, Director of Business Services stefanie.grandstaff@epulaski.k12.in.us Views of Responsible Officials: We concur with the finding . Description of Corrective Action Plan: The Food Service Director has been in contact with Skyward to find which reports can help with the Eligibility compliance requirements. The corporation has found a few more reports that can be of assistance with this finding. The Director of Business Services has also reached out to other Skyward users who use the food service module to ask for suggestions on what reports should be pulled and how to locate supporting documentation of students that received free or reduced-priced meals. At the end of each year when the corporation completes the roll-over process, all the reports are saved to a Google Drive folder. The Direct Certified Reports will be kept upon processing for future use and documentation purposes. An additional review of the applications will be performed to verify that the system is calculating properly. The Food Service Director and Director of Business Services are going to continue to reach out to other Skyward food service users and ask if any other reports should be saved, printed or kept for future audits. Anticipated Completion Date: Projected completion date of major tasks for the planned corrective actions is June 30, 2024

Views of Responsible Officials and Planned Corrective Actions: MARR will retain a CPA consultant to implement a document retention policy that is consistent with federal document retention requirements.

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.

FINDING 2022-007 Finding Subject: COVID-19 - Education Stabilization Fund - Reporting Summary of Finding: Finding: No oversight of reports and supporting documentation did not agrees to report submitted Recommendation: Provide oversight of reports submitted and retain supporting documentation that agrees to reports submitted Contact Person Responsible for Corrective Action: Kareemah Fowler, Assistant Superintendent of Business and Finance Deb Martin, Director of Student Learning & Title I Contact Phone Number and Email Address: Kareemah Fowler (574) 393-6088; kfowler@sbcsc.k12.in.us Deb Martin (574) 393-6053; dmartin@sbcsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: All reports and supporting documentation, which supports each report submitted, will be reviewed/approved by the program director. All supporting documentation will be retained for future audits. Anticipated Completion Date: December 8, 2024

FINDING 2022-006 Finding Subject: COVID-19 - Education Stabilization Fund - Allowable Costs/Cost Principles Summary of Finding: Finding: Documentation for 3 employees was not available to verify the contract amounts. Recommendation: Documents be retained to support amounts paid. Contact Person Responsible for Corrective Action: Kareemah Fowler, Assistant Superintendent of Business and Finance Contact Phone Number and Email Address: (574) 393-6088; kfowler@sbcsc.k12.in.us Views of Responsible Officials: We disagree with the finding. Explanation and Reasons for Disagreement: While we agree that the single source document used by the State to validate a teacher’s contract was not available for 3 employees. We provided sufficient alternate documents that would allow the State to validate the contract amount being paid, and whether the proper employees were paid from or should have been paid from the Education Stabilization Funds. The documents provided sufficient data to support the questioned cost of $26,207 outlined in the finding. We will be working with our software vendor to rectify the glitch that prevented us from providing the documentation requested by the State for future audit. Description of Corrective Action Plan: We will be working with our software vendor to rectify the glitch that prevented us from providing the documentation requested by the State. Anticipated Completion Date: January 2024

FINDING 2022-004 Finding Subject: Title I Grants to Local Educational Agencies - Reporting Summary of Finding: Finding: Detail data on the Form 9 and Reimbursement Request was not provided to knowledgeable individuals for review. Recommendation: Design control that provides sufficient data to knowledgeable individuals for review. Contact Person Responsible for Corrective Action: Kareemah Fowler, Assistant Superintendent of Business and Finance Contact Phone Number and Email Address: (574) 393-6088; kfowler@sbcsc.k12.in.us Views of Responsible Officials: We concur with the findings. Description of Corrective Action Plan: Form 9 Data The Human Resources Department has added a second review to verify all employee distribution codes are correct when recording/updating employee requisitions. Additionally, detailed expense reports and payroll distribution reports that support each reimbursement request are being provided to knowledgeable employees to review. Anticipated Completion Date: Completed December 8, 2023, and May 2023 Reimbursement Requests Summary level payroll data is no longer being used to support reimbursement requests. Detailed expense reports and payroll distribution reports that support each reimbursement request are being provided to knowledgeable employees to review. Anticipated Completion Date: Completed May 2023.

FINDING 2022-003 Finding Subject: Title I Grants to Local Educational Agencies - Allowable Costs/Cost Principles Summary of Finding: Finding: Documentation for 10 employees was not available to verify the contract amounts. Recommendation: Documents be retained to support amounts paid. Contact Person Responsible for Corrective Action: Kareemah Fowler, Assistant Superintendent of Business and Finance Contact Phone Number and Email Address: (574) 393-6088; kfowler@sbcsc.k12.in.us Views of Responsible Officials: We disagree with the finding. Explanation and Reasons for Disagreement: While we agree that the single source document used by the State to validate a teacher’s contract was not available for 10 employees. We provided sufficient alternate documents that would allow the State to validate the contract's amount being paid, and whether the proper employees were paid from or should have been paid from the Title I funds. The documents provided sufficient data to support the questioned cost of $203,488 outlined in the finding. We will be working with our software vendor to rectify the glitch that prevented us from providing the documentation requested by the State for future audit. Description of Corrective Action Plan: We will be working with our software vendor to rectify the glitch that prevented us from providing the documentation requested by the State. Anticipated Completion Date: January 2024

In December 2022, the Office of Financial Aid strengthened its internal control over the reporting requirements for the Higher Education Emergency Relief Fund (HEERF), by adding the report due dates to the internal operational calendar. Additional level reviews were also added to the submission process before the required reports will be sent to the Department of Education and posted on the financial aid website.

Condition: Administrative costs are submitted to the state monthly for reimbursement on the Record of Expenditures under the TEFAP Financial Assistance form ("FD-32D"). The State reimburses the Organization for administrative costs as determined by the state on a monthly basis. Typically, the monthly reimbursement amount is significantly less than the actual amount of allowed administrative expenses incurred by the Organization. During our procedures, we noted that certain expenditures, amounting to approximately $3,290, which were included on the FD-32D of which supporting documentation the Organization is required to retain under 2 CFR part 200 was lacking. As such, we could verify these costs related to activities allowed for reimbursement under 2 CFR part 200. Views of Responsible Officials and Corrective Actions: We agree with the auditor's comments and the following action will be taken to improve this situation. The Finance and Administration Manager and the Director of Logistics, who prepare the FD-32D, will work together to ensure that all supporting documentation is retained for all allowable expenses monthly. The corrective actions will be implemented by July 1, 2023.

FINDING 2022-016 Contact Person Responsible for Corrective Action: Casey Brewster Contact Phone Number: 812-752-8935 Views of Responsible Official: We concur with the finding Description of Corrective Action Plan: The approved grant budgets for all federal grants will be input into the financial management system and with all expenditures reported monthly from the Treasurer to the Director overseeing the federal grant for review and final approval. The Director shall be one of the approvers within the approval chain of federal grant funds the Director oversees. The Director shall be responsible for reviewing and utilizing actual expenditure reports to complete the annual reports, or any other reports, prior to another documented review by the Treasurer or CFO. All documentation related to the reports shall be maintained for future audit purposes. Anticipated Completion Date: April 2023.