Corrective Action Plans

2.1 Ensure timely reconciliation of inventory distributions in order to record the transactions in the correct accounting period. Responsible Official: Head of Operations, Supply Chain Managers, DRD Operations, SCM RTAs, Completion Date: September 30, 2025

FINDING 2024-003 Finding Subject: Child Nutrition Cluster – Activities Allowed or Unallowed, Allowable Costs/Cost Principles Summary of Finding: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Linda Zaborowski, CFO Contact Phone Number and Email Address: (219) 881-5536 lzaborowski@garycsc.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: Gary Community School Corporation is committed to strengthening internal controls to ensure compliance with federal regulations governing the Child Nutrition Cluster programs. To address the deficiencies identified in the audit, we will implement a structured system for reviewing and approving all financial transactions related to the food service program. Moving forward, all invoices submitted by the Food Service Management Company (FSMC) will require detailed supporting documentation before payment is processed. The Food Service Director will conduct thorough reviews to verify the accuracy and allowability of costs, ensuring that only eligible expenses are charged to the program. Additionally, a standardized checklist will be developed to confirm compliance with federal cost principles. To address payroll-related deficiencies, all employees whose salaries are funded by the Child Nutrition Cluster will be required to maintain detailed time and effort records that document their work on federal and non-federal activities. The Payroll Department will not process payments from federal funds without proper documentation, and approval from the CFO/Food Service Director. To prevent future occurrences of questioned costs, the Business Office Coordinator will carefully review all FSMC invoices to verify that adequate documentation is provided, and any unallowable costs, including sales tax, are identified and excluded before payment is made. Moving forward, internal procedures will include a detailed verification process to ensure that only allowable costs are charged to the program. Anticipated Completion Date: Gary Community School Corporation will implement this procedure by July 2025.

Action Taken: We have taken several steps to prevent this sort of error in the future:We immediately reviewed this error with the office in question and made sure they understood the correct process of capitalizing prepaid expenses and expensing each month  This is a transaction that was made in error, guidance for handling prepaid expenses already exists. We reviewed this existing guidance around the correct way to handle prepaid expenses with relevant finance staff.  At the end of each fiscal year offices will be required to complete a full check with finance signoff for prepaid expenses and agree that everything that is prepaid has been communicated to finance.  There is an existing process for grant closeout that provides additional review of expenses that would detect this sort of expense and ensure it is recorded correctly, however, in this instance it was a multi-year grant and so the grant was not closed out and fiscal year end.  As this is a multi-year grant, we corrected this error in FY25 and returned the funds to the grantor for the expense that had not yet been incurred.

Auditor’s Recommendation: The Auditor recommends that the procurement policy be updated to comply with all relevant federal procurement requirements and reviewed for necessary revisions regularly and retain backup documentation to support amounts charged to grant. Views of Responsible Officials and Planned Corrective Action: Purchasing has updated policy to reflect Federal Guidelines. In addition, the determination has been made to self-certify allowing the University to more closely align requirements from the State of New Mexico with Federal purchasing. Furthermore, additional training within the Purchasing Department has and will continue to be provided for staff to have the tools to identify all circumstances that require additional compliance. The update of Policy was completed in June 2024. Self-Certification was documented in October 2024. Training is ongoing but initial will be completed January 2025. Timeline and Estimated Completion Date: January 2025 Responsible Party: Director of Purchasing

Auditor’s Recommendation: We recommend the University strengthen the controls in place to provide assurance that proper review occurs and retain documentation needed for an audit. Views of Responsible Officials and Planned Corrective Action: Management agrees that there have been significant challenges with the Paycom system and the approval of the contracts. We are currently working on signature workflows to ensure proper approval for our student, staff and faculty employees. We have begun a team effort among staff in following offices : HR , ORSP, BO, AA, ITS and VPFA. We are working to ensure that all personnel in the chain of the workflow know what signatures are required on different types of contracts. We plan to train relevant staff to recognize when appropriate approvals are not in place and return contracts and timesheets for proper approval. Supervisor training is planned for January 27, 2025 to ensure that supervisors as well as employees take responsibility. In regards to the time and effort, we need a software solution that automatically generates these reports for us and payroll information ties to the payroll system and general ledger. At this time the majority of all the reports generated out of Paycom require intensive manual work in multiple offices. The BO and ORSP will be working on IDC identifying issues and determining solutions. Timeline and Estimated Completion Date: Changes will be implemented in January to be completed by June 30, 2025. Responsible Party: Office of Research and Sponsored Projects, Comptroller and Director of Human Resources

Planned Corrective Action: The District agrees with the finding. We will work with DOE and other district finance officers to ensure processes going forward are accurate and appropriate with no programs being overcharged. Anticipated Completion Date: 06/30/2025 Responsible Contact Person: Lindsay Laxton, CFO

Finding 2024-005 Finding Subject: Special Education Cluster (IDEA) - Earmarking Contact Person Responsible for Corrective Action: Beverly Hindes Contact Phone Number: 219-996-4771 x128 Views of Responsible Officials: We agree with the finding. Description of Corrective Action Plan: The Treasurer will work with the Special Education Co- op to ensure compliance with the Earmarking requirement. Anticipated Completion Date: March 31, 2025

FINDING 2024-006 Contact Person Responsible for Corrective Action: Rachel Dutoi Contact Phone Number: 574-254-4503 Views of Responsible Official: We concur with the audit finding. Description of Corrective Action Plan: The Business Departmental staff going forward will work with the Payroll department to account for all individuals that are to be paid from Federally Funded Grants and other funding sources. From these lists of employees, the Business Department staff will designate the individuals being paid from federally funded grants and other local or state funds. Time and Effort records will be kept for all employees along with documents listing the impacted employees. These lists will then be reviewed during the certification process by the person creating the listing with Payroll personnel, the Assistant Director of Business Services and the Director of Business Services to ensure that all employees are accounted for. Anticipated Completion Date: This new process will begin with the next impacted payroll cycle.

FINDING 2024-003 Contact Person Responsible for Corrective Action: Rachel Dutoi Contact Phone Number: 574-254-4503 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Exceptional Learner Departmental staff going forward will work with the Payroll department to account for all individuals that are to be paid from Federally Funded Grants and other funding sources. From these lists of employees, the EL Departmental staff will designate the individuals working public and non-public students. Time and Effort records will be kept for all employees along with documents listing the impacted employees. These lists will then be reviewed during the certification process by the person creating the listing with Payroll personnel, the Exceptional Learner Director and the Director of Business Services to ensure that all employees are accounted for. Anticipated Completion Date: This new process will begin with the next semi-certification process.

FINDING 2024-001 Contact Person Responsible for Corrective Action: Rachel Dutoi Contact Phone Number: 574-254-4503 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The amount transferred during the time period of July 1, 2024-December 31, 2024 will be transferred back to Fund 0800. This transfer will be done once the Form 9 for period 2 of 2024 is complete and the month of December is closed. An indirect cost rate for Fiscal Year 2026 has been applied for and this rate will be used to capture these costs from Fund 800 if approved beginning 7.1.2025. Anticipated Completion Date: The fund transfer back to Fund 0800 will occur by March 31, 2025. The claiming of the indirect cost rate will begin 7.31.2025 dependent upon the approval of the corporation’s indirect cost rate application.

FINDING 2024-003 Finding Subject: Special Education Cluster (IDEA) Summary of Finding: The non-public proportionate share expenditures for the preschool grant was not spent in full. Additionally, the corporation had not filed a waiver to move the funds to the corporation program. Contact Person Responsible for Corrective Action: Austin Fruits Contact Phone Number and Email Address: 317-535-7579; afruits@cpcsc.k12.in.us Views of Responsible Officials: We concur with the finding. Explanation and Reasons for Disagreement: N/A Description of Corrective Action Plan: We have formulated a plan to include the business office in Non-pub meetings moving forward so that open funds are being clearly communicated with the Non-public schools. If the funds are not spent, we will apply for the waiver to move the budget to the corporation. Anticipated Completion Date: March 1, 2025

FINDING 2024‐004 Finding Subject: Special education Cluster (IDEA) ‐ Earmarking Summary of Finding: Due to the timing of the Cooperative’s corrective action, the non‐public expenditures spent did not meet the earmarking requirements for grant award number 22611‐053‐PN01. From the beginning of the grant awards until March 2023, total grant expenditures were posted as expended. The non‐public proportionate share expenditures were determined by applying a percentage to the non‐public school budgeted expenditures. Beginning in March 2023, the Cooperative began tracking expenditures by member school for the non‐public services. As such, we were unable to identify if the minimum amount per the grant award was expended and properly reported to IDOE from the beginning of the grant awards through March 2023, as required. Contact Person Responsible for Corrective Action: Tim Scott Contact Phone Number and Email Address: 574‐654‐7273 tscott@npusc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Beginning in March 2023, the Cooperative began tracking expenditures by member school for the nonpublic services instead of applying a percentage. The minimum amount per the grant award will be expended and properly report to the IDOE. New Prairie also plans on requesting biannual reports from the Cooperative on expenditures for nonpublic services. Anticipated Completion Date: March 2023

Audit Finding Number: 2024-001 Agency: Town of Oakland, Maryland Person Responsible for Corrective Action: Name: Valerie Stemac Title: Business Coordinator 15 South Third Street Oakland, Maryland 21550 Anticipated Completion Date: 06/30/2025 Response to Finding: Management concurs with audit recommendation. Corrective Action to be Taken: Management will work with funding agency to conduct a thorough review of reimbursement records to confirm the duplication and determine if an overpayment occurred. If an overpayment is identified, coordinate with the Maryland Department of Housing and Community Development (DHCD) to correct the error and issue any necessary reimbursement or adjustment.

FINDING 2024‐003 Subject: Special Education Cluster (IDEA) – Earmarking Summary of Finding: Lack of effective internal controls to ensure earmarking requirements were met for grants that began prior to September 2022 Contact Person Responsible for Corrective Action: Adam C. Minth Contact Phone Number: 219-374-3504 Views of Responsible Official: The school corporation concurs with the finding and will be implementing corrective procedures by the end of this fiscal year. Description of Corrective Action Plan: As a member of the Northwest Indiana Special Education Cooperative (NISEC), Hanover Community School Corporation reported their proportionate share based on a percentage of expenditures and have successful audits in doing so. When Hanover was notified that this process was no longer acceptable, we immediately implemented an internal control process with NISEC which included detailed reporting of staff work hours for nonpublic schools related to only our school corporation. The report is then reviewed and signed by the NISEC staff working for the nonpublic school and their supervisor. The employee detailed time and effort report are then provided to the NISEC finance department for a second review and signature before being provided to payroll. NISEC payroll then charges the proportionate share to the IDEA Part B grant in the payroll system bi-weekly based on the time and effort report pertinent to just School Corporation Non-public schools. The time and effort reports are then used to submit the reimbursement request to the Department of Education for Hanover’s proportionate share. Anticipated Completion Date: 4/30/2025

FACTORS AFFECTING ALLOWABILITY OF COSTS Brevard Health Alliance requested reimbursement for $8,978 of expenditres under two differentfederal grants. One grant is requested based upon clinic hours and another based on an individual's time and effort. Recommendation: The client should verify that reimbursement request do not include payroll expenditures submitted for other grants. The allocation of payroll should be done monthly. Responsible Party: Shelley Jackson, Director of Accounting Corrective Action: Brevard Health Alliance will ensure allocationof payroll expenditures submitted for grants is done monthly to ensure stronger internal controls regarding grant funds.

FINDING 2024-003 Finding Subject: Special Education Cluster (IDEA) - Earmarking Summary of Finding: Lack of Internal Controls in Place to Ensure the Cooperative Complied with Earmarking Requirements The Cooperative did not have adequate procedures in place to ensure that the required level of expenditures for non-public school students with disabilities was net for each member school. The Cooperative did not have effective internal controls to ensure non-public school expenditures were appropriately identified and reported. The non-public proportionate share expenditures were determined by a percentage to the non-public school budgeted expenditures. Beginning in March 2023, the Cooperative began tracking expenditures by member schools for the non-public services. Contact Person Responsible for Corrective Action: Greg Hunt Contact Phone Number: (219) 362-7056 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Corrective actions have already been taken beginning in March 2023. The Cooperative began tracking expenditures by member schools for the non-public services. Anticipated Completion Date: March 2023

Management's Response: The Organization acknowledges the finding and agrees with the auditors' recommendations. We recognize the importance of maintaining accurate documentation and financial controls to ensure compliance with federal regulations. To address the finding, the Organization will implement the following corrective actions: 1) Journalizing administrative allocations - effective March 31, the Organization will implement a procedure to allocate administrative costs to each applicable federal award program through monthly journal entries within the general ledger. 2) Improved documentation retention - the Organization will establish a process to retain supporting documentation for all costs submitted for reimbursement, ensuring alignment between the general ledger and reimbursement requests. 3) Internal controls for expense classification - the Organization will implement additional controls to prevent expenses from being reclassified within the general ledger after reimbursement requests have been submitted. Any necessary adjustments will be documented with a clear audit trail. These corrective actions will be fully implemented by March 31, 2025, will include and cover all such costs from the start of the fiscal year which began October 1, 2024, and management will monitor compliance to ensure ongoing adherence to these procedures.

Cross training will occur between the BA, Assistant BA and the Senior Accountant. In the event of extended vacancies or absences, multiple staff members will be trained on filing correct final reports.

Corrective Action Plan for Current Year Findings June 30, 2024 Finding 2024-001: Activities Allowed or Unallowed Research and Development Cluster Award Period: July 1, 2023 – June 30, 2024 Responsible Person: Karen Miller, Controller 609-771-2203 Jeanette Vega, Director of Grant Financial Administration 609-771-2847 Corrective Action Plan: For the fiscal year ending June 30, 2024, the College had 7 employees with a combined total of 10 payroll instances with no effort verification form certified for any of the transactions from July 1, 2023, to December 31, 2023, in the fiscal year being audited. The effort was certified after the fiscal year, as part of the year-end process which was not in line with the semi-annually time frames as historically done with guidance in our Effort Verification Operating Policy. The College recognizes the importance of ensuring that labor costs charged to federal awards are based on accurate and timely records and certifications, as required under 2 CFR 200.430(g). The timing delays occurred due to staffing vacancies and knowledge transfer of current staff as well as misalignment of staffing. Once the staffing was realigned, trained, and vacant positions filled, the time and effort certification for the fiscal year labor costs were completed. This task occurred during the months between August 2024 and November 2024 which was outside the policy time frames. The College is committed to improving its internal controls over time and effort reporting for research and development grants to ensure compliance by taking corrective action steps to improve monitoring and oversight, strengthen training and communications, and develop an action plan for corrective timing. The College implemented part of the corrective action on August 01, 2024, retroactive to July 1, 2023, and will complete the remaining items by the end of the next fiscal year. Anticipated Completion Date: June 30, 2025

FINDING 2024-004 Finding Subject: Special Education Cluster (IDEA) - Earmarking Summary of Finding: The Non-Public Proportionate Share expenditures for the 22611-048-PN01 grant award could not be verified for the individual member schools. The non-public school share funds for the participating member schools were allocated based on the yearly budget for certified staff instead of time charged to the non-public schools. These allocations were the amounts reported to IDOE. As such, we were unable to identify which expenditures were for each school in order to verify the minimum amount per the grant award was expended and properly reported to IDOE as required. Contact Person Responsible for Corrective Action: Trina Huff Contact Phone Number and Email Address: (812) 689-4114, thuff@jaccendel.k12.in.us INDIANA STATE BOARD OF ACCOUNTS 27 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Expenses for non-public schools are tracked and charged to the appropriate corporation. Staff record time spent at each non-public school, sign and date the form and turn it into the treasurer. The expenses are then moved to the correct expense line on the grant after receiving this information. Materials that are purchased are charged to the correct expense account when paid. Anticipated Completion Date: July 1, 2023

Recommendation: Independent contractors are to be recorded to a contractor general ledger account per policies and procedures. A review of personnel costs to identify changes in personnel, ensure transactions are recorded per policies and procedures, and that award budgets are amended if necessary. Action Taken: Boys & Girls Clubs of Dane County will establish grant budgets at the time of a grant application. If awarded, this is the budget a PI/Program Manager will be trained on with instruction from Finance as to the respective general ledger codes that coincide with each budget line. If a diversion is necessary, budget modifications will be sought out. The individuals responsible are: Sr. Director of Grants & Compliance, Grant Writers, Controller, Finance Operations Administrator, PI’s/Program Managers over respective grants. The anticipated completion date is March 31, 2025.

2024-002 - Activities Allowed or Unallowed; Allowable Costs/Cost Principles UWGC does not have specific policies and procedures in place as to how monthly personnel costs across federal programs will be aggregated and charged to federal programs. Management’s Corrective Action Plan:UWGC has developed a procedure as outlined below in “Payroll Allocation Grants” to ensure that prior to submission of invoices to federal awarding agencies, management prepares a monthly analysis based on 211 call logs to support the actual amounts allocated across all programs and invoiced to the awarding agencies that are reconciled to payroll reports, which then will allow UWGC to present evidence that all hours submitted for reimbursement are supported with the appropriate allocation. The process will include management staff from both 211 and finance departments thus maintaining internal controls. Additionally, this procedure will be reviewed at least annually by both departments as it relates to the allocation methodology to ensure that its appropriate given changes in the program and workforce. PROCEDURE: Payroll Allocation Grants Purpose UWGC requires the practice of responsible and reasonable procedures related to methods of allocated staff time and costs to 211 grants and/or contract funded initiatives/programs which is effective as of April 15, 2024. This procedure describes the steps that will be implemented and adhered to when allocating staff salary costs to 211 programs. The goal of this process is to ensure that consistent, adequately documented, and all appropriate materials are generated and reviewed monthly. Procedure 211 Call Logs: at the end of each month the 211 Manager will generate a monthly call log which tracks 211 calls by categories that coincide with specific programs and/or geographic area for services. The report is then emailed monthly to the Finance Senior Director who then utilizes the report to create a percentage of time spent on each program and then attributes staff salaries and benefits in line with the percentage of calls for each month. Staff who work on isolated call programs, for example 311, Utilities,OHIZ programs, will be excluded from the call log allocation method as the calls for these teams are specifically driven. Supervisors who oversee more than one program will perform a time allocation study at least annually or when there is a change in program supervision responsibility. Program Billing: The Finance Manager and/or responsible Program Billing Manager will utilize the call log percentages journal to allocate time to programs for reporting information in the appropriate monthly, quarterly, or annual report to the funding source.

FINDING 2024-003 Finding Subject: Child Nutrition Cluster (School Lunch) – Allowable Cost Summary of Finding: The payroll for non-certified employees for the 2023-2024 school year has not been approved by the board, leading to a lack of verification for salaries paid from fund 800. As a result, any payroll for non-certified employees paid after August 1, 2023 from fund 800 cannot be verified. Contact Person Responsible for Corrective Action: Robin Popejoy Contact Phone Number and Email Address: 317.758.4172 – rpopejoy@sheridan.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The salary schedules will be submitted to the board for approval. Anticipated Completion Date: May – August 2025

The City concurs with the finding. Albuquerque Police Department (APD) Grant Administrator will meet with the City Grant Administrator to review and prepare the necessary payroll corrections, ensuring that all payroll charges allocated to the grant are accurate. The APD Grant Administrator will be responsible for submitting correcting payroll reclassifications to the City's Grants Management Section for review, entry and approval no later than January 31, 2025. APD will work directly with the City's Grants Management Section to establish new reconciliation, reclassification and validation processes to ensure that only eligible officers and pay types are charged to the grant.

Susquehanna Township School District respectfully submits the following corrective action plan for the year ended June 30, 2024. The finding from the schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the numbers assigned in the schedule: A. Compliance Findings Finding 2024-001: Procurement Federal Agency: U.S. Department of Education Pass-through agency: Pennsylvania Department of Education Assistance Listing Number: 84.425 Education Stabilization Fund; 84.027 IDEA Recommendation: The Subrecipient must implement procedures to fully comply with Uniform Guidance Procurement requirements. View of Responsible Officials and Corrective Action Planned: The District will require all payments to have either a purchase order or request for payment form completed. The Accounts Payable Coordinator is responsible for ensuring the form is signed for all disbursements. For the particular item cited by our monitors the Superintendent and Business Manager signed off on the invoice instead of a request for payment form. The District Accountant / Business Office Manager discussed with the Accounts Payable Coordinator that going forward this is insufficient. All payments must have either a purchase order or request for payment form. The District Accountant / Business Office Manager reviews backup documentation for check disbursements. During their review if any payments are discovered to be missing a purchase order or request for payment form, he will notify the Accounts Payable Coordinator to complete the form. This is effective immediately. The District has also reviewed the applicable Uniform Guidance Procurement requirements and has developed an electronic procurement process that all staff member making the purchase with federal funds, must complete a form prior to the procurement being made. Then the Business Manager approves the form. There is a box to check if the procurement is a sole source. If this is checked the Business Manager will require justification. This process was presented by the Business Office to Leadership Personnel on 5/9/24 and is effective now. Person Responsible: Oslwen C. Anderson, Jr., Business Manager OCA Completion Date: June 30, 2024