Corrective Action Plans

2024-007 Research and Development Cluster – Federal Assistance Listing Nos. 84.017 and 47.081 – Period of Performance Recommendation: We recommend that the University review and revise their current procedures in place and provide training to employees within the grant and finance functions related to the grant reconciliation and recording process to ensure expenses are reflected prior to the grant ending and recorded in the correct period on the SEFA. Explanation of disagreement with audit finding: There is no disagreement to the audit finding. Action taken in response to finding: Restricted Funds Accounting (RFA) team has restructured with new leadership and added all new staff. RFA will train new staff, develop and update policies and procedures, and automate processes within ERP systems, as appropriate. RFA is creating current and updated SOPS for each task and making sure the current staff is learning processes the correct way; this includes reconciliation and recording in the correct period. Name(s) of the contact person(s) responsible for corrective action: Director of Accounting, Tonya Cardwell. Planned completion date for corrective action plan: December 2026

Matching Federal Agency Name: Department of Health and Human Services FFAL #93.087 Program Name: Enhance Safety of Children Affected by Substance Abuse Finding Summary: During testing of match expenditures, testing noted 5.15 hours identified as Medicaid hours for one employee were not removed from the employee’s total hours when calculating the amount of match for the federal program. The Center’s controls did not detect or correct the errors identified, which results in a reasonable possibility that the Center could claim as match disallowed costs under the federal award and would not be able to detect and correct noncompliance in a timely manner. The employee’s Medicaid hours were not properly included within a revenues report due to the employee’s provider number not being included within the report parameters. Responsible Individuals: CEO (Dan Ries) Corrective Action Plan: CEO will double check and confirm that all revenue reports run have data for the correct staff to ensure that the accurate information is being used to calculate match hours. Anticipated Completion Date: September 2024.

Mr. Waguespack: I am in receipt of the letter dated January 24, 2025 from Angel Cavaretta, Audit Manager, related to the misappropriation of research and development cluster funds. Louisiana Tech concurs with the recommendation. The misappropriation of funds occurred as a result of a sophisticated cyber fraud scheme in which perpetrators submitted fraudulent email requests directing that funds be deposited via electronic funds transfer (EFT) into accounts purportedly affiliated with the out-of-state University. However, the accounts were later discovered to have no connection to the institution. These deceptive actions exploited the University's payment processing systems and evaded detection at the time. Upon information a d belief, the data breach originated with the out-of-state University, and it is also noted that the out-of-state University did not detect discrepancies in its invoicing processes, including non-payment or fraudulent communications, which may have contributed to the fraud's success. Upon discovering the fraud, the University promptly reported the incident to appropriate law enforcement authorities, the Legislative Auditor, and the federal grantor. The University immediately reviewed all suppliers with an EFT payment type and has temporarily suspended the approval of any supplier requests related to the EFT payment option. As stated in the finding, the University is evaluating internal and external opportunities to further enhance its internal controls and verification procedures to better safeguard against increasingly sophisticated cyber threats targeting payment remittance processes.

Dear Mr. Waguespack, Please find below the University's management response to the audit finding titled “Noncompliance with Period of Performance Requirements." Management Response: The University concurs with the audit finding. Expense Posting Delay ($28,833): This salary charge reflects work performed within the approved award period. The delay occurred because the Personnel Action Form was received after the June payroll run, resulting in disbursements in July and August. Although the work was completed on time, the payroll posting did not align with the period of performance requirements. We are reviewing our processes to ensure all required documentation is received and processed promptly. Liquidation of Obligations ($34,957): The University failed to liquidate obligations totaling $34,957 within 120 days following the period of performance. This shortfall is due to staffing challenges in the Sponsored Programs Finance Administration and Compliance (SPFAC) Department. The University is actively exploring strategies to attract and retain qualified grant accountants to improve timely fund closeouts. Additional Mitigation Measures 1. Engaging External Consultants: o The University will engage an outside consultant to assess the university's research and administration structure, identifying opportunities to enhance processes and ensure compliance. o The University is retaining interim professional staffing to assist with invoicing and pre-audit review and to provide functional and technical expertise. 2. Deployment of an Electronic Research Administration System (eRA) o The University has begun identifying and implementing an electronic research administration system to transform grant management by offering a centralized platform that automates the entire lifecycle from proposal to closeout, minimizing manual errors while ensuring policy compliance and providing clear portfolio visibility through comprehensive reporting capabilities. The SPFAC Director will oversee the implementation of these corrective actions.

FINDING 2024-003 Finding Subject: Special Education Cluster - Earmarking Contact Person Responsible for Corrective Action: Shelly Leifer Contact Phone Number and Email Address: 260.306.3359 shelly_leifer@mcs.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: 1. A proportionate Share Working Spreadsheet was developed and is distributed annually to service providers working with non-pub students. 2. Service providers document the following information for each corporation: Student name, Date of service, Time of Service, Number of hours, Type of Service, and any other required information. 3. Documentation is reviewed monthly. 4. Reimbursement for non-pub services is requested when reimbursement amounts reach $1,000.00 or annually, whichever comes first. Anticipated Completion Date: March 1, 2024

FINDING 2024-005 (Auditor Assigned Reference Number) Finding Subject: Special Education Cluster (IDEA)- Period of Performance Contact Person Responsible for Corrective Action: Julie Remschneider Contact Phone Number and Email Address: julie.r@nn.k12.in.us, 219-285-2228 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We will ensure the Special Education Co-op will have controls in place to make sure payments are made within the period of performance. Anticipated Completion Date: September 30, 2025

FINDING 2024-003 Finding Subject: Special Education Cluster (IDEA) Activities Allowed or Unallowed, Allowable Costs/Cost Principles Summary of Finding: During the fiscal year 2023-2024, the School Corporation was part of Cooperative School Services, which managed special education programs and finances for its schools. There were recognized issues where non-public schools received direct reimbursements. It is recommended that the School Corporation implement internal controls to prevent direct reimbursements, ensuring compliance with grant requirements and financial regulations. Contact Person Responsible for Corrective Action: Chris Richie Business Manager/Treasurer Contact Phone Number and Email Address: 219 987 4711, crichie@kv.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We will work with Cooperative School Services to ensure allowable cost requirements are met. Reports tracking expenditures will be reviewed semiannually for compliance. Anticipated Completion Date: June 1, 2025

FINDING 2024-002 Finding Subject: Special Education Cluster (IDEA) Earmarking Summary of Finding: As a member of Cooperative School Services, special education funding was administered by the Cooperative. The School Corporation only partially spent required funds for some grants. It is recommended that the School Corporation creates written policies to track non-public expenditures to meet earmarking requirements. Contact Person Responsible for Corrective Action: Chris Richie Business Manager/Treasurer Contact Phone Number and Email Address: 219 987 4711, crichie@kv.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Kankakee Valley School Corporation will work with Cooperative School Services to ensure that Earmarking requirements are met. Reports tracking expenditures will be reviewed semiannually for compliance. Anticipated Completion Date: June 1, 2025

Information on the federal program: Subject: Education Stabilization Fund (ESSER) – Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Allowable Costs/Cost Principles Audit Finding: Material Weakness Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Allowable Costs/Cost Principles compliance requirements. Context: During testing of the Allowable Costs/Cost Principles compliance requirements, there were two vendor vouchers in a sample of 60, where the School Corporation was unable to locate any supporting documentation. These two selections totaled $1,530 charged to the grant. It was further noted that during our testing of payroll costs charged to the COVID-19 – Education Stabilization Fund, for 2 selections in a sample of 40, the School Corporation was unable to provide any support to validate the amount of payroll charged to the grant. These two selections totaled $414 charged to the COVID-19 – Education Stabilization Fund. Corrective Action Plan: The School Corporation will establish a system of internal controls to ensure that documentation is maintained and that expenditures charged to the grant comply with the grant agreement and are allowable. Person responsible for implementation and projected implementation date: The Business Manager will be responsible for overseeing the implementation of the corrective action plan, which will go into effect immediately.

CONDITION: During my review of a random sample of eleven (11) invoices related to the District’s expenditure of federal funds, I noted that there was not an approved purchase order issued in eight (8) of those instances. This is a repeat Finding (2023-003) from the prior fiscal year. CRITERIA: In accordance with the District’s Procurement Policy for Federal Programs (#626.5), the District shall use properly prepared and approved purchase orders for federal purchases. In addition, Section 2 CFR 200.403(g) of the Uniform Guidance requires that all expenditures (costs) must be adequately documented. RECOMMENDATION: I recommend that the District utilize properly prepared and approved purchase orders for all future federal program purchases in compliance with its Procurement Policy for Federal Programs (#626.5) and Section 2 CFR 200.403(g) of the Uniform Guidance. MANAGEMENT’S PLANNED CORRECTIVE ACTION: The School District’s will ensure that purchase order documentation is maintained as part of internal purchasing procedures. Regarding the timeframe for completion, the District has already implemented procedures regarding the documentation of costs and will continue to follow and improve them going forward. The District has contracted J. Martin & Associates, LLC (JMA) to provide business office accounting services. Representatives from JMA and the rest of the business office staff will monitor documentation procedures to ensure that they are followed appropriately.

The Crenulated will request a quarterly in-kind contribution report from DOE and will ensure the in-kind contributions are recorded in the financial statements. The Crenulated plans to hire an in-house Controller with expertise in accounting for grants, and review its existing contract with current third-party accounting provider.

2024-001 Activities Allowed or Unallowed U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Recommendation: We recommend that the Board design and implement controls to ensure that all charges to federal programs are adequately reviewed and approved prior to payment. Action Taken: Region III will create a detailed workflow of the approval process that includes the following: Initial request, review by finance department, and approval by designated individuals. Ensure that no single individual has control over all aspects of the charge approval process. We will schedule quarterly internal audits to review samples of transactions for compliance.

Boston Public Schools will take a multi-step approach to ensure accuracy of spending to the grant award period. Anticipated Completion Date: January 31, 2025 Responsible Contact Person: Colin Musto, Assistant City Auditor, Grants Monitoring Unit colin.musto@boston.gov

FINDING 2024-003 Information on the federal program: Subject: COVID-19 – Education Stabilization Fund – Activities Allowed or Unallowed/Allowable Costs Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425C, 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425C200018, S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Finding: Material Weakness, Other Matters Condition: An effective internal control system was not in place at the School District to ensure compliance with requirements related to the Education Stabilization Fund and Activities Allowed or Unallowed. Context: During the testing of vendor and payroll disbursements charged to Education Stabilization Fund grant awards during the audit period, the following exceptions were noted:  Management was unable to provide an approved accounts payable voucher and supporting invoice for one vendor disbursement in a sample of 12 vendor disbursements.  For one salaried employee selected out of a sample of 40 payroll disbursements, the employee was charged to Education Stabilization Fund grants for 50% of their time worked in a pay period. The School Corporation did not maintain any time-and-effort logs to support the employee’s partial allocation to Education Stabilization Fund grants. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Management will implement control processes surrounding expenditures of federal funds to ensure documents are retained to support expenditures and their allocations to federal grants. Responsible Party and Timeline for Completion: Gretchen Berger, Corp Treasurer - 6-1-2025

Substance Abuse and Mental Health Services Projects - Assistance Listing No. 93.243 Recommendation: Perform a review policies and procedures regarding proper monitoring of period of performance related to grant end dates. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: MURC will perform a review of policies and procedures to ensure recorded transactions are within the proper period of performance related to grant end dates. Name(s) of the contact person(s) responsible for corrective action: Jennifer Wood Planned completion date for corrective action plan: June 30, 2025

Research and Development Cluster- Assistance Listing Nos. 93.323, 93.847 Recommendation: Perform a review policies and procedures regarding proper monitoring of period of performance related to grant end dates. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: MURC will perform a review of policies and procedures to ensure recorded transactions are within the proper period of performance related to grant end dates. Name{s) of the contact person(s) responsible for corrective action: Jennifer Wood Planned completion date for corrective action plan: June 30, 2025

The School Corporation will establish an internal control process to esnure detailed records are maintained and an audit trail is evident to comply with federal compliance requirements. The Treasuer and the Deputy Treasurer will oversee the implementation of the corrective action plan, which will go into effect immediately.

FINDING 2024-002 Finding Subject: Special Education Cluster (IDEA) - Earmarking Contact Person Responsible for Corrective Action: Bethany Cmar Contact Phone Number and Email Address: 765-641-2126 (Bcmar@acsc.net) Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: When it comes to expenditures for non-public schools, ACS will assign a unique tracking number to each school, allowing expenditures to be easily traced for this requirement. The overall earmarking requirements will be compiled annually by the Special Education Director and sent to the CFO for review and approval, ensuring compliance with the requirements. Anticipated Completion Date: March 31, 2025

Finding 2024-003, Unallowable Expense (Assistance Listing 93.696) Persons Responsible: Irene Math, Chief Financial Officer, Jessica Schneibolk, Controller Comment: Per 2 CFR § 200.403, costs charged to a federal award must be necessary, reasonable, and allocable to the program. Assistance Listing Number 93.696, Certified Community Behavioral Health Clinic, requires that costs allocated to the program meet these criteria to ensure compliance with federal regulations. Response: WJCS acknowledges the audit finding related to an unallowable expense charged to the Certified Community Behavioral Health Clinic program. We agree with the recommendation to strengthen internal controls and have identified the cause as an isolated error due to invoices posting in the ledger prior to approval. To address this, we updated the accounts payable system so invoices will not post to the general ledger until approved. Estimated Completion Date: These corrective actions were implemented in February 2025.

Department: Health and Human Services Title: Internal control over Medicaid paid medical claims needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Department will require the vendor to create a procedure to be used to prepare this report which will be tested and validated by the vendor and the Office of MaineCare Services. Completion Date: June 1, 2025 Agency Contact: Michelle Probert, Director, Office of MaineCare Services, DHHS, 207-287-2093

Department: Health and Human Services Title: Internal control over Medicaid cost of care assessments and deductions needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Office of MaineCare Services will request an update to the Retroactive Cost of Care report to correct the logic that resulted in a missed cost of care change. Completion Date: June 1, 2025 Agency Contact: Ian Yaffe, Director, Office for Family Independence, DHHS, 207- 592-1481

Department: Health and Human Services Administrative and Financial Services Title: Internal control over the Foster Care – Title IV-E and Adoption Assistance – Title IV-E programs FMAP rates needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Information Services Unit Manager will organize an annual meeting to include the OCFS COO, the OCFS PFO and appropriate representatives from DAFS, on or about August 1st to formally discuss the FMAP and agree on its implementation. Meeting will be set as an auto reoccurring meeting updated annually to include the appropriate staff to attend. A Placeholder for the Annual FMAP update will be entered annually into Katahdin's life cycle management system (Octane) to allow the FMAP update activity to be formally tracked. A screenshot of the entered FMAP rate from Katahdin will be sent out to the same group after the meeting when the rate is entered into the Katahdin system. Completion Date: April 1, 2025, first and second item, and August 15, 2025, third item Agency Contact: Robert Blanchard, Associate Director, OCFS, DHHS, 207-624-7955

Department: Health and Human Services Title: Internal control over the Adoption Assistance – Title IV-E eligibility and benefit determination process needs improvement Questioned Costs: Known: ALN 93.659 $10,860 Likely: Undeterminable Status: Corrective action in progress Corrective Action: The Adoption Program Manager will continue to review the final Adoption Assistance Packet for completeness before approval. The Adoption Manager will review the most current Level of Care in foster care in the Child Welfare System to verify proper subsidy rates prior to approval. The Adoption Manager will work with the OCFS team on implementing and training on the updated Adoption Policy. The Office of Child and Family Services will organize a workgroup to evaluate how to improve the financial review process and define any changes needed to be implemented in Katahdin to support validating payments are processed appropriately. All children entering adoption must have a completed determination by the District FRS for verification of third-party benefits/Social Security. Effective date of last audit 2024, the documentation procedure was changed to clearly shows any determination. This is documented within the adoption application for all cases. This verification is used to determine an appropriate adoption assistant rate. Completion Date: March 1, 2025, first, second and fifth items, September 1, 2025, third item, and November 1, 2025, fourth item Agency Contact: Karen Benson, Adoption Program Manager, OCFS, DHHS, 207-561-4208

Department: Health and Human Services Title: Internal control over the Foster Care – Title IV-E and Adoption Assistance – Title IV-E eligibility and benefit determination process needs improvement Questioned Costs: Known: ALN 93.658 $4,647 ALN 93.659 $9,367 Likely: Undeterminable Status: Corrective action in progress Corrective Action: The Title IV-E Program Manager will continue to educate and train the FRS on the proper completion of the Title IV-E initial determination checklists for their FRS files, including the importance of signing off on those checklists for the initial determinations that they have completed. The Title IV-E Program Manager will conduct quarterly quality assurance (QA) reviews in the District that this issue was found, randomly pulling 10 cases to ensure compliance. When FRS staff conduct QA reviews, they will continue to be advised to monitor if signatures are present on the Title IV-E initial determination checklist. Reviewing if a checklist is signed is an existing question within our internal QA review document. The Department will establish a work group to identify the challenges of managing overpayments made to foster parents and to develop a process to minimize this problem. The Department will finalize and receive approval of the protocol/process form managing overpayments. The Department will implement the new overpayments management procedures. Completion Date: March 26, 2025, March 31, 2025, July 1, 2025, September 1, 2025, and November 1, 2025 respectively Agency Contact: Robert Blanchard, Associate Director, OCFS, DHHS, 207-624-7955

Department: Health and Human Services Administrative and Financial Services Title: Internal control over CCDF period of performance needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The DHHS Financial Service Center will enhance policies and procedures for the CCDF grant by modifying the FSR Reviewer Checklist. Completion Date: April 30, 2025 Agency Contact: Sarah Gove, Director, DHHS Service Center, DAFS, 207-458-6626