Corrective Action Plans

Corrective Action: The district concurs and understands the importance of maintaining internal controls related to Education Stabilization Fund requirements. However, due to turnover of half the Business Office staff in June 2023, the district procedures could not be effectively followed. That said, by September 1, 2024, the Assistant Superintendent for Business will, together with the pertintent Business Office staff, review the existing procedures for these internal controls to ensure all are being implemented properly for the coming fiscal year. Additionally, the Assistant Superintendent for Business will have monthly reviews with the Treasurer to ensure these internal control processes are being correctly followed.

Corrective Action: The district concurs and understands the importance of maintaining internal controls related to Education Stabilization Fund requirements. However, due to turnover of half the Business Office staff in June 2023, the district procedures could not be effectively followed. That said, by September 1, 2024, the Assistant Superintendent for Business will, together with the pertintent Business Office staff, review the existing procedures for these internal controls to ensure all are being implemented properly for the coming fiscal year. Additionally, the Assistant Superintendent for Business will have monthly reviews with the Treasurer to ensure these internal control processes are being correctly followed.

Berrien County BOE FA 2023-001 Strengthen Controls over Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principle Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Agriculture Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: 10.553 - School Breakfast Program 10.555 - National School Lunch Program Federal Award Number: 225GA324N1199 (Year: 2023), 225GA324N1199 (Year: 2023) Questioned Costs: $3,381 Description: A review of expenditures charged to the Child nutrition Cluster revealed that the School District's internal control procedures were not operating appropriately to ensure that expenditures were reviewed and approved and that the School District's procurement and suspension and debarment procedures were followed. Corrective Action Plans: The new program director will attend training and review compliance requirements to ensure appropriate documentation is maintained. Estimated Completion Date: 30-Jun-24 Contact Person: Jolyn Schultz, Finance Director Telephone: 229-686-2081 Email: jolyn.schultz@berrien.k12.ga.us

Status: Corrective action in progress Corrective Action: The City agrees with the finding. DDPHE will implement additional trainings and guidance for contract monitoring including invoice review and encourage a standard template in Excel to avoid calculation errors. The City is also currently implementing a city-wide grants management system and we hope to include invoice review and tracking in this new system by 2025. Person(s) Responsible for Implementing: DDPHE – Paige Cheney Implementation Date: September 2024 and potentially January 2025

ALN: 84.010, 84.365, 84.367, 84.424, Corrective Action Plan: Inadequate Support for Federal Reimbursement - Title I-IV - OPI - The Internal Control Auditor of the Montana Office of Public Instruction will perform quarterly sampling reviews to determine which receipts and additional data should be requested to ensure the agency's compliance. Person(s) Responsible for Corrective Measures: April Grady, Chief Financial Officer, Montana Office of Public Instruction, Target Date: 12/31/2024

ALN: 97.042, 97.047, Corrective Action Plan: Inadequate Support for Federal Reimbursement - DMA - The Montana Department of Military Affairs, Disaster and Emergency Services Division, has improved and implemented internal control procedures to ensure proper supporting documentation is sufficient at the time of reimbursement and continues to work with the Federal Emergency Management Agency (FEMA) to ensure compliance with grant guidance. The department reviews and updates the current internal control process to ensure sufficient documentation is received and maintained. Person(s) Responsible for Corrective Measures: Delila Bruno, Administrator, Montana Department of Military Affairs, Target Date: Completed

ALN: 84.010, Corrective Action Plan: Inadequate Supporting Documentation - Title 1 - OPI - The Montana Office of Public Instruction management will provide staff training on how to track time and effort functions in the manner required. The training will be performed by the Centralized Services Manager and Payroll Manager. Person(s) Responsible for Corrective Measures: April Grady, Chief Financial Officer, Montana Office of Public Instruction, Target Date: 10/31/2024

ALN: 84.010, Corrective Action Plan: Inadequate Supporting Documentation - Title I - OPI - The Montana Office of Public Instruction program staff will document specific and detailed purposes for expenditures. Accounting staff will review and ensure that expenditures are in accordance with federal regulations prior to purchase. Person(s) Responsible for Corrective Measures: April Grady, Chief Financial Officer, Montana Office of Public Instruction, Target Date: 09/30/2024

ALN: 93.658, Corrective Action Plan: Inadequate Supporting Documentation - Foster Care - DPHHS - The Montana Department of Public Health and Human Services started completing and documenting risk assessments for subrecipients in 2024 and will fully implement in 2025. The department believes the subrecipients that have the questioned costs are low risk and the department is confident the reimbursements were made for allowable activities. During July 2024, the department requested receipt-level documentation for questioned costs and the reviews have indicated all costs are allowable. Program staff will ensure monitoring procedures align with risk assessments and obtain additional documentation from its subrecipients, as needed. Training was provided on subrecipient risk assessments and the correlation with monitoring procedures in April 2024. Person(s) Responsible for Corrective Measures: Nicole Grossberg, Administrator, Montana Department of Public Health and Human Services, Target Date: 12/31/2024

ALN: 20.509, Corrective Action Plan: Noncompliance with Federal Procurement Requirements - MDT - The Montana Department of Transportation has hired new leadership for the Transit Section, who are actively working with the Federal Transit Administration (FTA) and the subrecipients to formalize procedures, document oversight measures, and correct the deficiencies. Person(s) Responsible for Corrective Measures: Rob Stapley, Administrator, Montana Department of Transportation, Target Date: 06/30/2025

ALN: 93.323, Corrective Action Plan: Inadequate Supporting Documentation - ELC - DPHHS - The Montana Department of Public Health and Human Services is in the process of collecting additional documentation for the Epidemiology and Laboratory Capacity for Infectious Diseases program from our subrecipients to support allowable costs. The department will continue to enhance its internal controls and documentation related to its review process. Person(s) Responsible for Corrective Measures: David Gerard, Executive Director, Montana Department of Public Health and Human Services, Target Date: 12/31/2024

ALN: 84.425, 84.425D, 84.425U, Corrective Action Plan: Inadequate Support for Federal Reimbursement - ESSER - OPI - The Internal Control Auditor of the Montana Office of Public Instruction will review cash requests and determine if the subrecipient grant expenditures comply with the Elementary and Secondary School Emergency Relief Fund (ESSER) requirements and ensure costs are related to the pandemic, reasonable and necessary. Additional documentation will be requested of the subrecipient as needed. The Internal Control Auditor will also monitor subrecipient compliance with construction and capital expenditures including wage certifications for construction projects. Person(s) Responsible for Corrective Measures: April Grady, Chief Financial Officer, Montana Office of Public Instruction, Target Date: 09/30/2024

ALN: 84.371, Corrective Action Plan: Inadequate Support for Federal Reimbursement - Literacy - OPI - The Internal Control Auditor of the Montana Office of Public Instruction will review cash requests and determine if the subrecipient grant expenditures comply with federal program requirements. Additional documentation will be requested of the subrecipient as needed. Person(s) Responsible for Corrective Measures: April Grady, Chief Financial Officer, Montana Office of Public Instruction, Target Date: 09/30/2024

CONDITION: The District did not comply with the laws and regulations related to its participation in it’s various federal grant program reporting requirements. Personnel did not complete and submit the required ‘quarterly cash on hand reports’ and ‘final expenditure report’ (FER) for the grant programs based on supporting accurate general ledger expenditures as required by Section 2 CFR 200.403(g) of the Uniform Guidance. CRITERIA: The PA Department of Education (PDE) and Section 2 CFR 200.403(g) of the Uniform Guidance requires the completion and submission of a ‘quarterly cash on hand report’ quarterly as needed and a ‘final expenditure report’ (FER) at the conclusion of each grant program year (including any carryover period) based on information contained in the School District’s financial management system and supported by all underlying documentation. MANAGEMENT’S CORRECTIVE ACTION PLAN: The School District concurs with the above noted finding. The School District has employed a new Business Manager whose responsibilities include the oversight of accounting records and preparation of all required financial reports related to PDE federal grant programs in a timely manner, and to ensure that the information reported to PDE is supported by the underlying documentation contained in the District’s general ledger. Procedures will be put into place during the remaining months of the 2023-2024 fiscal year, and all subsequent years, for ensuring federal program reports are prepared accurately and agree with the financial management system and supported by all underlying documentation.

NCHE implemented a new policy in January 2024 regarding missing receipts. In October 2023, a new policy was instituted requiring receipt of vendor invoice before payment approval by the Accountant and Executive Director. All copies of approvals, receipts, and invoices, are now attached to each expense transaction in QuickBooks Online.

COIVD-19: Coronavirus State and Local Fiscal Recovery – Assistance Listing No. 21.027 Recommendation: We recommend that the Organization consider updating its salaries, wages, and employee benefit cost allocation methodology and process to reduce the frequency of manual adjustments based on review of individual time records and expense data and maximize the use of automated allocations based on employees’ time and effort records, effective compensation during work periods, and that are calculated in a consistent manner. We also recommend that the Organization maintain contemporaneous documentation supporting all cost allocations. Explanation of disagreement with audit finding: There is no disagreement with this finding. Action taken in response to finding: The Organization is updating the segregation of duties in order to improve the preparation, review and sign steps of the process. Name of the contact person responsible for corrective action: Silvia Zelaya, Finance Director Planned completion date for corrective action plan: January 2025

Legal Services Corporation Grants – Assistance Listing No. 09.706060 Recommendation: We recommend that the Organization consider updating its employee benefit cost allocation methodology and process to reduce the frequency of manual adjustments based on review of expense data and maximize the use of automated allocations that are calculated in a consistent manner that ensure costs are applied uniformly to respective benefited activities. Explanation of disagreement with audit finding: There is no disagreement with this finding. Action taken in response to finding: The Organization will review this finding and current methodology and propose corrections as part of a broader review of its technologies. Name of the contact person responsible for corrective action: Silvia Zelaya, Finance Director Planned completion date for corrective action plan: January 2025

To ensure compliance with grant regulations the school district will implement the following: ● Conduct a comprehensive assessment of existing procedures to identify gaps that led to non-compliance with grant regulations. ● Ensure timely submission of grant applications. ● Maintain detailed documentation of all award dates and expenditures to provide a clear compliance record. ● Ensure all documentation is easily accessible and systematically organized for audit purposes. ● Ensure pre-award costs are allowable only to the extent they would have been allowable if incurred after the effective date and ONLY with written approval from the Federal awarding agency (as per 2 CFR 200.458). ● Establish a process for obtaining and documenting written approval for pre-award costs. ● Provide comprehensive training on compliance with Uniform Grant Guidance to all relevant staff. ● Review and update policies and procedures related to grant expenditures regularly to ensure they are current and compliant with federal regulations. ● Assign accountability for monitoring and reporting compliance to specific roles within the organization. This implementation of this plan shall be the responsibility of the Russ Kaubris, Business Manager. Starting with the Fiscal Year 2025 grant cycle, procedures to comply will be implemented.

DEPARTMENT OF ELEMENTARY PUBLIC HEALTH 2023-003 WIC Special Supplemental Nutrition Program for Women, Infants, and Children – Assistance Listing No. 10.557 Action taken in response to the finding: The Department and the WIC Nutrition Program will have all fiscal staff review the Operating Procedures to refresh themselves of the procedures surrounding Purchase Orders and Expenditures. (Excerpt from Operating Procedures) All Staff should complete a “Request for Purchase” form with all pertinent information such as quotes, renewal notices, conference registration, etc. and submit it to supervisor or Director for initial approval. Once the request is approved, the form is given to a fiscal staff to start the process of encumbering funds through MMARS and preparing a PURCHASE ORDER. At the very least, staff will identify that the service performed is correct and that funds are available and already encumbered to process the payment. All federal payments require a Program Code, and so the fiscal staff need to be sure the appropriate one is entered based on the dates of service or the date of the Purchase Order. Once all documents have been uploaded and submitted, then either the WIC State Director or the Fiscal Director will need to electronically approve the transaction in the Tracking System. The Fiscal Director and the State Director will more thoroughly review the assignment of Program Codes as they pertain to the Federal grant award dates before approving payment documents. This review will involve verifying: • The type of service • Date of service or receipt of item • Date of Purchase Order • Program Codes Name of the contact person responsible for corrective action: Beverly Andrew and Rachel Colchamiro Planned completion date for corrective action plan: April 30, 2024

Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. The Health System will review, modify, and implement policies and procedures over the program to ensure that costs incurred are appropriately charged based on the contracts’ performance periods.

Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. The Health System will review, modify, and implement policies and procedures over the program to ensure that costs incurred are appropriately charged based on the contracts’ performance periods.

Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. The Health System will review, modify, and implement policies and procedures over the program to ensure that costs incurred are appropriately charged based on the contracts’ performance periods.

Management agrees with the finding. Our current federal project is substantially completed, however, should the Township receive additional federal grants, the Township will adopt the required written procedures. The anticipated completion date is prior to receiving another federal award.

Finding 2023-001 U.S. Department of Education Condition: Tuition invoices and payroll costs were charged to a 2023 grant that were for services rendered prior to the grant start date. Corrective Action Planned: The School will implement procedures to review all manual journal entries for period of performance compliance before posting to the general ledger. Anticipated Completion Date: Immediately Contact: Gilbert Lefort III, Director of Finance, North Attleborough Public Schools

Planned Corrective Action: The District confirms the audit finding and will implement policies and procedures, as well as staff training, to ensure compliance with the Federal Hurricane Education Recovery Program. Anticipated Completion Date: October 1, 2024 Responsible Contact Person: Marleni Bruner, Director of Finance; Jaelen Jackson, Assistant Director of Finance