Corrective Action Plans

FINDING 2023-009 Finding Subject: COVID-19 - Education Stabilization Fund - Allowable Costs/Costs Principles Contact Person Responsible for Corrective Action: Ahnaf Tahmid & Marlaina Johns Contact Phone Number and Email Address: 574-393-6000, atahmid@sbcsc.k12.in.us, mjohns2@sbcsc.k12.in.us Views of Responsible Officials: We concur with the findings Description of Corrective Action Plan: Payroll Human Resources worked with Regional Data Services to identify the cause of the issue and made corrections to prevent the data being lost on the administrative side moving forward. This involved updates to software stores and archives. The Director of Federal Grants is responsible for ensuring that each grant fiscal officer reviews and signs the Payroll (Distribution) Certification Report. This report lists all individuals paid from the grant fund, the amount paid per paycheck, and the complete fund number. Fiscal officers are required to review the information and provide their signature to confirm its accuracy. The reports are then distributed to the fiscal officers for each grant. Each fiscal officer reviews the listed payments to confirm that the employees charged to the fund were appropriately paid from that grant and that the amounts are accurate. The fiscal officer signs the report to certify its accuracy or documents any discrepancies that require correction. After the report is signed, the Finance Department retains it for future audit purposes. Vendor Contracts All contracts and MOUs follow a controlled approval process to ensure proper oversight and legal compliance. Once drafted, each agreement is submitted for review, and the Legal Department evaluates any document requiring an Opinion of Counsel or involving a waiver of the Corporation’s or School Board’s legal rights. Legal also maintains electronic copies of all finalized agreements. Contracts may only be approved by the Superintendent or the School Board, and MOUs must first be reviewed and approved by the Superintendent before going to the Board. After all required reviews and approvals are completed, the agreement is formally executed and electronically filed by the Legal Department. All required documentation specified in the contract will be retained, along with all related vendor invoices. Correction Date October 5, 2023 payroll and December 2024 vendor

FINDING 2023-004 Finding Subject: Title I Grants to Local Educational Agencies - Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Ahnaf Tahmid & Marlaina Johns Contact Phone Number and Email Address: 574-393-6000, atahmid@sbcsc.k12.in.us, mjohns2@sbcsc.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: Human Resources worked with Regional Data Services to identify the cause of the issue and made corrections to prevent the data being lost on the administrative side moving forward. This involved updates to software stores and archives. Corrected Date 06/30/2025

FINDING 2023-003 Finding Subject: COVID-19 Emergency Rental Assistance Program - Period of Performance Contact Person Responsible for Corrective Action: Timothy A. Brown Contact Phone Number and Email Address: 219-755-3225 brownta@lakecountyin.org Views of Responsible Officials: We concur with the finding with reservations on a portion of the Finding. Description of Corrective Action Plan: \ This program is completed and the period of performance is over therefore there is not a need to formally adopt any Corrective Action Plan. The Subrecipient Contractor that administered the program has agreed that this finding was due to their internal error in submitting administration invoices too late to be properly processed and approved by the County. They will be reimbursing the ERA1 fund for the error in the amount of $154,812.56 that will be sent back to the US Treasury. Reservation: The US Treasury required the local grant recipient to prosecute ERA1 fraud activities. There were two fraud cases that were prosecuted by our local attorney. His fees were then deducted from the ERA1 fund as administration costs. The grant recipient should not be penalized for doing as directed to prosecute fraud cases without being able to pay for the services rendered. We do not control the timelines of the local courts nor the responses/actions of the defendants delaying the actions beyond the Period of Performance. Anticipated Completion Date: None, no corrective action plan is necessary.

CONDITION: During the calendar year 2023, the City did not record the necessary adjustments to the various ‘Fund’ general ledgers of the City to properly reconcile certain balance sheet accounts, such as interfund receivables and payables, and payroll-related liabilities to the underlying supporting documentation available at the City. This included the City’s Community Development Block Grant (CDBG) Program. As a result, the financial position and results of operations as shown throughout the calendar year were inaccurately stated. CRITERIA: Prudent internal control procedures in the areas of general ledger management and financial reporting include the reconciliation of all general ledger account balances to underlying supporting documentation monthly with independent oversight and approval as part of the process. In specific as it relates to federal programs, Section 2 CFR 200.403(g) of the Uniform Guidance requires that federal costs must be adequately documented which would include the City’s Federal Programs general ledger which accounts for the financial activity of the City’s Community Development Block Grant Program.MANAGEMENT’S CORRECTIVE ACTION PLAN: Management of the City is reviewing the options as presented by the Audit Firm’s recommendation for feasibility considering current manpower, expertise, and budgetary constraints. In addition, the City plans to ensure that written procedures for all accounting functions are implemented, reviewed and updated as necessary with the objective of ensuring that all applicable balance sheet account balances are accurate and supported by the underlying documentation available at the City. The City is currently in continuous communication with the Audit Firm for specific recommendations regarding the handling of interfund receivables and payables, and payroll-related liabilities, so as to ensure the accuracy of the City’s financial reporting. The timeframe for completion of this review will occur during the first six months of calendar year 2026 with the intention of having the City be in full compliance with Section 2 CFR 200.403(g) of the Uniform Guidance which requires federal costs to be adequately documented which would include the applicable general ledgers of the City.

Item 2023-006 Activities Allowed or Unallowed/Allowable Costs/Cost Principles Head Start ALN# 93.600 US Department of Health & Human Services (Repeat 2022- 008) Federal Grant/Contract Number: 10CH011215-03-03; 10CH011215-03 C3; 10CH011215-04; 10HE000901-01-C6 Grant period – 2022 & 2023 The HS program has established an internal process of requester/approver in place to review transaction requested. Documents then get reviewed again by HR or Finance staff based on the transaction type before getting processed.

Reference Number: 2023-011 Finding: Improve Controls and Compliance with Approval of Allowable Costs Name of Contact Person: Lorina Esposito Corrective Active Plan: The City will implement a policy mandating documented approval for all invoices before they are paid or charged to federal programs. In addition, the City will conduct regular, scheduled reviews of invoice processing to verify compliance with allowable cost procedures and address any deviations promptly. Training will be provided to staff involved in invoice approval and payment processes to ensure understanding and adherence to these internal control requirements. Proposed Completion Date: 6/30/26

Contact Person – Benjamin Schafer, Executive Director Corrective Action Plan – Training will be provided for all employees involved with the grant if the Cooperative receives a similar grant in the future. Completion Date – As needed.

FA 2023-003 Strengthen Controls over Expenditures Compliance Requirement: Internal Control Impact: Compliance Impact: Federal Awarding Agency: Pass-Through Entity: AL Numbers and Titles: Federal Award Numbers: Questioned Costs: Repeat of Prior Year Finding: Period of Performance Procurement and Suspension and Debarment Material Weakness Material Noncompliance U.S. Department of Education Georgia Department of Education 84.027 - Special Education Grants to States 84.173 - Special Education Preschool Grants HO27A210073(Year: 2022), HO27A220073 (Year: 2023), HO27X220073 (Year: 2023) $28,390.10 FA 2022-003 Description: A review of expenditures and journal entries charged to the Special Education Cluster revealed that the School District's internal control procedures were not operating to ensure that appropriate reviews and approvals occurred and the School District's procurement procedures were followed. Corrective Action Plans: All journal entries related to the grant will be submitted by the Finance Director to the Director in charge of the grant for approval. Estimated Completion Date: June 30, 2026 Contact Person: Dr. Angela Williams, Superintendent Telephone: 706-554-5101 Email: amwilliams@burke.k12.ga.us

FA 2023-001 Improve/Strengthen Controls over Expenditures Compliance Requirements: Internal Control Impact: Compliance Impact Federal Awarding Agency: Pass-Through Entity: Assistance Listing Number and Title: Federal Award Number: Questioned Costs: Repeat of Prior Year Finding: Activities Allowed or Unallowed Allowable Costs/Cost Principles Period of Performance Procurement and Suspension and Debarment Material Weakness Material Noncompliance U.S. Department of Education Georgia Department of Education 84.371C - Comprehensive Literacy Development S371C190016-19A (Years: 2017-21) $124,399.84 FA 2022-002 Description: A review of expenditures and journal entries charged to the Comprehensive Literacy Development program revealed that the School District's internal control procedures were not operating to ensure that appropriate reviews and approvals occurred and the School District's procurement procedures were followed. Corrective Action Plans: The School District will review established internal controls and procedures with pertinent staff to ensure all are being followed. Expenditures related to the grant will be reviewed by the Director in charge of the grant to ensure proper approvals are maintained and packing slips are submitted with the invoice for payment. In the event a packing slip is not received, a note will be included to indicate such. All journal entries related to the grant will be submitted by the Finance Director to the Director in charge of the grant for approval. The School District will review established internal controls and procedures with pertinent staff to ensure all are being followed. Procurement transactions related to the grant will be reviewed by the Director in charge of the grant to ensure proper supervisor review and approvals are maintained. The Director in charge of the grant will review and update the current procedures to ensure that the required procurement methods are properly identified and followed and that required procurement documentation is properly identified, safeguarded, and retained. Estimated Completion Date: June 30, 2026 Contact Person: Dr. Angela Williams, Superintendent Telephone: 706-554-5101 Email: amwilliams@burke.k12.ga.us

View ofResponsible Officials and Planned CorrectiveActions:Managementacknowledges anisolated payrollprocessingerrorduringfiscalyear2023in which overtime hours werenotproperlyenteredforoneemployee.Thiserrordidnotresultinquestionedcosts,asreimbursedpayrollexpenseswere less thanactualpayrollcosts incurred. We retrained staffonpayrollprocessingwithemphasis onovertimeentry andverification.Weupdatedpayrollprocesses toensurepayrollstaffarenotifiedwhen overtime isapproved.Weimplementedpre-processingpayrollreconciliation andsupervisoryreviewpriortofinalsubmission.Payrollentries are subjectto supervisory reviewand periodic spotchecks.Correctiveactions havebeenimplementedand are operating onanongoingbasis.

View ofResponsible Officials and Planned CorrectiveActions:Managementacknowledges this findingrelatedtoinconsistentretentionoflease extensionsorrenewals forrentalassistanceprovided beyond originallease terms duringfiscalyear2023.Originalleases were retained forallparticipants;however,extensionswerenotconsistently obtained. We implementedalease trackingprocess to monitorlease expirationdates.Weupdatedproceduresto requirelease renewalsorextensions priorto issuingassistancebeyondtheoriginallease term.Weimplementedstandardizedfile checklists.Supervisorystaffconductperiodic filereviewsto confirmleasedocumentation coverage.Corrective actionshavebeenimplementedand are operatingonanongoingbasis.

View of Responsible Officials and Planned Corrective Actions: Management acknowledges this finding related to documentation retention for a single participant-related expense during fiscal year 2023. While isolated in nature, management recognizes the importance of complete documentation to support allowability under Uniform Guidance. We updated procedures to require receipt and verification of all required documentation prior to charging costs to federal awards. We implemented standardized documentation checklists to support consistent compliance. We reinforced documentation standards through staff training and supervisory review to ensure proper adherence. Supervisory staff conduct periodic file reviews prior to reimbursement and drawdown activity. Corrective actions have been implemented and are operating on an ongoing basis.

The Department of Human Services (DHS) adopted the electronic Timeforce (STATS) system for payroll, replacing manual processes. Time and attendance are approved through management levels, with payroll based on Notice of Personnel Action (NOPA) cost centers. Financial Analysts reconcile payroll, and a workflow ensures accurate NOPA listings for payroll purposes. Additionally, in order to ensure that Notice’s of Personnel Actions are updated on a timely basis, ensuring that salaries are charged to the respective account, DHS has implemented the following process: (1) Provisional Payroll Codes are requested prior to the close of the Fiscal Year by the Department of Finance through the Office of Management and Budget through the established process. (2) Once the codes are received, the Division of Human Resources will update the most current Personnel Distribution Sheets to reflect active employees. (3) The sheets will be submitted to Fiscal certification by the CFO, (4) NOPAS are updated with the provisional codes.

Once payroll is processed by the Department of Finance, on the payday, a Flex Earnings Report is generated by the staff. A reconciliation is performed to ensure that all employees and their respective fringe benefits are captured and drawn. The Department of Finance posts said payroll. Staffing continues to identify deficiencies in the posting which occur in varying periods after the actual pay day. DHS has incorporated into its internal controls a step to ensure that the accounts, in retrospect, are reconciled to the actual Flex earning report. DHS intends on meeting with the Department of Finance to identify the nuances that create postings to occur contrary to the Flex Earning Report account coding.

VIDE acknowledges the audit findings regarding the Special Education Cluster payroll discrepancies and concurs with the recommendation. VIDE is taking immediate action to align payroll controls with established fiscal improvement plan. To address the pay rate discrepancies between NOPAs and the payroll register, the Budget Team and the Deputy Commissioner of Fiscal and Administrative Services will review and approve every personnel action in the ERP prior to the NOPA being executed. This review matches the action against the approved grant application or staffing list to ensure the pay rate is accurate before the payroll cycle begins.

VIDE acknowledges the audit findings regarding the Special Education Cluster payroll discrepancies and the unreported fraud incident and concurs with the recommendation. VIDE is taking immediate action to align payroll controls with the established fiscal improvement plan and to institutionalize a mandatory federal reporting protocol for fraud. To address the pay rate discrepancies between NOPAs and the payroll register, the Budget Team and the Deputy Commissioner of Fiscal and Administrative Services will review and approve every personnel action in the ERP prior to the NOPA being executed. This review matches the action against the approved grant application or staffing list to ensure the pay rate is accurate before the payroll cycle begins. To address fraud reporting, VIDE will implement a Federal Mandatory Disclosure Policy in strict accordance with 2 CFR §200.113 that designates the Office of the Commissioner and the Internal Audit Division as the responsible parties for reporting any credible evidence of fraud, bribery, or gratuity violations to the Federal awarding agency and the OIG. Accordingly, the specific incident cited in the finding regarding the $5,221 theft related to bus driver timesheets will be immediately reported to the U.S. Department of Education’s Office of Inspector General via the online hotline and formal written correspondence to cure the non-compliance. Furthermore, to prevent recurrence of the specific falsified timesheet scheme, VIDE will implement a Service Verification Log for bus drivers and similar service staff wherein supervisors will be required to cross-reference timesheets against daily trip logs or service logs before approving time in the payroll system. Finally, to ensure ongoing compliance, the Office of Fiscal and Administrative Services will conduct monthly spot checks of ERP logs to ensure pre-execution reviews are occurring, and the Internal Audit Division will maintain a log of all investigations to verify that a Notification of Federal Disclosure is attached to any file involving federal funds.

We acknowledge that some timesheets were currently unavailable because the employees in question are no longer employed at DPNR, and as a result, their user profile is no longer active within the system. We have requested assistance from the Department of Finance in retrieving the necessary timesheets unfortunately, the required information has not yet been provided. DPNR will continue to collaborate with the Department of Finance to ensure the retrieval of any relevant files or reports, and we remain committed to resolving all the findings. We recognize that these findings highlight areas where improvements are necessary to ensure better compliance with applicable policies and regulations governing payroll and grant management. We are committed to implementing corrective actions and enhancing internal controls to prevent recurrence.

The Government concurs with the finding. OTAG implemented enhanced payroll controls including a dual manual and electronic timesheet system, verification of pay rates against NOPA forms, and separation controls to discontinue benefit charges upon employee separation or retirement.

VIDE acknowledges the audit finding regarding the Child Nutrition Cluster payroll and concurs with the recommendation. Because this is a recurring finding from prior year 2022-023, VIDE will develop and institute stricter fiscal controls to address the root causes of documentation and allocation discrepancies for this program. To prevent discrepancies including unapproved project codes and pay rate mismatches between NOPAs and payroll registers, the Fiscal Team will take the lead in preparing and maintaining the official staffing list for federally funded personnel within this program, an effort that involves reviewing the grant application for all positions and informing HR of required action entries. Furthermore, VIDE will implement a control where the Budget Team and the Deputy Commissioner of Fiscal and Administrative Services will review and approve every personnel action in the ERP prior to the NOPA being executed to match the action against the approved grant application or staffing list and ensure the project code and pay rate are accurate before the payroll cycle begins. To address the unavailability of timesheets, the program will implement a strict reconciliation protocol wherein the Program Director or designee will verify that the payroll register aligns with approved timesheets prior to performing the drawdown and posting. These timesheets will then be digitally archived in a centralized SharePoint repository organized by pay period to ensure that time and effort documentation is securely retained and immediately available for audit review. To support these new protocols, mandatory training will be conducted for relevant staff and supervisors on these new timesheet procedures, federal time and effort requirements, and the new NOPA reconciliation workflow. Finally, the Office of Fiscal and Administrative Services will conduct monthly spot checks of the SharePoint repository and ERP logs to measure the effectiveness of these controls.

The Department of Human Services (DHS) adopted the electronic Timeforce (STATS) system for payroll, replacing manual processes. Time and attendance are approved through management levels, with payroll based on Notice of Personnel Action (NOPA) cost centers. Financial Analysts reconcile payroll, and a workflow ensures accurate NOPA listings for payroll purposes. Additionally, in order to ensure that Notices of Personnel Actions are updated on a timely basis, ensuring that salaries are charged to the respective account, DHS has implemented the following process: Provisional Payroll Codes are requested (1) Provisional Payroll Codes are requested prior to the close of the Fiscal Year by the Department of Finance through the Office of Management and Budget through the established process.(2)Once the codes are received, the Division of Human Resources will update the most current Personnel Distribution Sheets to reflect active employees. (3) The sheets will be submitted to Fiscal for certification by the CFO. (4) NOPA's are updated with the provisional codes.

We acknowledge that the purchase of gift cards was not an allowable expense under federal grant guidelines. During the COVID-19 pandemic, our staff were tasked with responding to urgent and overwhelming public health demands, particularly as the New Mexico Department of Health became overextended. To recognize staff who went above and beyond to ensure timely case reporting and investigations for tribal communities, gift cards were used as a form of appreciation. Moving forward, we will ensure full compliance with federal grant requirements. Specifically: 1. We will adhere strictly to the cost principles and allowability guidance outlined in federal regulations and the terms of each Notice of Award. 2. In instances where the allowability of an expense is unclear, we will proactively seek guidance and written approval from our Federal Grant Management Officer before incurring the cost. 3. We will provide refresher training to program and fiscal staff on allowable costs under federal awards to prevent recurrence of similar findings. These corrective actions will ensure future expenditures are fully compliant with federal guidelines and that staff recognition practices remain appropriate, allowable, and consistent with award terms. • Immediate (Already in Effect): Ceased use of gift cards and other unallowable incentives. • Within 30 Days: Finance and program leadership will review current grant guidance and distribute a written summary of allowable/unallowable costs to all program managers. • Within 60 Days: Refresher training on federal cost principles (2 CFR 200) and Notice of Award guidance will be provided to all program and fiscal staff. • Ongoing: When ambiguity exists regarding allowable costs, staff will consult with the Federal Grant Management Officer prior to obligating or expending funds. Designation of Employee Position Responsible for Meeting Deadline Program Managers/Directors, Finance Officer, and Accounting Manager.

Personnel Responsible for Corrective Action: Jim Keeney, CFO Anticipated Completion Date: Completed. Review and Approval continue consistently. Corrective Action Plan: Management has implemented a time and activity method that meets the requirements of federal regulations. It includes the use of JIRA Software and an Excel Spreadsheet. Staff are entering time on an ongoing and consistent basis, including both actual and allowable time, for federal and non-federal contracts/agreements. These tools are reviewed and approved by executive management before any billing has transpired. Management is providing ongoing training for existing staff and new staff on an annual basis. This includes review and analysis from the accounting department to ensure proper expense accrual and revenue recognition. Management has also written an improved and detailed policy and procedure on recording actual and allowable time.

Recommendation: We recommended the City enhance its subrecipient monitoring activities and establish a formal record-keeping policy to ensure complete and timely documentation of expenses. Views of Responsible Officials: Management concurs with the finding. The City of Adelanto experienced higher than expected staff turnover in the finance department during the timeframe noted in this audit, which caused a backlog in audit preparation and submission, along with certain financial controls implementation interruption. At the time of this audit publishing, Management believes that implementation of such procedures is in compliance with the noted recommendation. Persons Responsible for Corrective Action: City Finance Staff (various) City Department Heads applying for grant funding (various) Anticipated Completion Date for Corrective Action: Corrective action has been immediately implemented in response to the auditors’ recommendation. As financial reporting is still in the process of becoming current, the City anticipates finding to be removed in future fiscal years.

SAOP will establish more robust internal contols to guarantee that all non-payoll charges are incurred within the tauthoized period of performance. This should involve consistent monitoring of gran periods, providing staff training on the perfoormance period, and conducting periodic reviews of expenditure documentation.

2023-003 Compliance and Internal Controls over Matching (Material Weakness) Internal Controls over Period of Performance and Earmarking (Material Weakness) U.S. Department of Housing and Urban Development 14.267 – Continuum of Care Program 2023 Funding Recommendation: We recommend that part of the review process for payroll include verification that the cost charged to the grant does not exceed the grant hours reported on employee timesheet. Corrective Action: In response to the first finding, we have implemented a comprehensive payroll review process that addresses both the initial concern and the subsequent finding. The new payroll process that has been established will ensure that costs charged to the grant do not exceed the hours reported on employee timesheets, effectively eliminating both issues: Responsible Parties: Sandra Robicheaux – Executive Director Claudia Dixon – CFO Tyler Starkel - YPTC Date to be Corrected: Implementation for above changes went into effect 6/01/2024