Corrective Action Plans

Views of Responsible Officials The Organization agrees with this finding. Corrective Action Plan The Organization has strengthened its internal controls over non-payroll transactions such that all expenditures can be properly explained with supporting documentation, and all expenditures are reviewed and approved prior to payment. Additionally, the Organization only submits expenditures for reimbursement that have been paid. While the Office of Management and Budget allows the reimbursement of expenditures that have been incurred, the pass-through entity will only reimburse expenditures that have been paid. Name(s) of Responsible Individuals Lacy Kimes, Board President Anticipated Completion Date Already implemented.

Finding No. 2022-003 KCHC agrees with the finding and understands the importance of maintaining robust recordkeeping and documentation procedures to comply with federal cost principles. We acknowledge the discrepancies noted in the audit findings regarding non-payroll expenditures. To address these issues, KCHC has implemented the following actions: • Strengthening Documentation Controls: KCHC has reinforced its recordkeeping procedures, requiring that all expenditures be fully supported by accurate documentation before approval. The accounting department has implemented additional review layers to ensure that all supporting documents, including receipts and invoices, are properly matched and retained. • Enhanced Training for Staff: Staff responsible for processing and documenting expenditures have undergone training to improve awareness of federal cost principles and documentation requirements. This training will ensure that all expenditures are supported by accurate, complete, and timely documentation. • Monitoring and Oversight: KCHC has introduced regular internal audits to monitor compliance with documentation standards. These audits will help identify any potential discrepancies early and ensure timely corrective action. Implementation Timeline: KCHC began implementation of these changes in FY 2025 under the CFO. The organization remains confident that these measures will address the audit findings and improve compliance with 2 CFR section 200.403(e). KCHC is committed to maintaining the highest standards of financial management and accountability. Responsible person: Arlene DeleonGuerrero, CFO

The Municipality Administration is committed to identify the control of deficiency that allowed for the deficiency to happen. Additionally, the administration is committed to implementing the correct control structure to prevent the situation from happening in the future. The Municipality Management will continue the search of supporting documentation of the highlighted transactions. New proposed control structure to be evaluated by Municipality for adequacy.

The accounting staff will continue searching for supporting documentation related to the disbursements amounting $17,565. The Coronavirus State & Local Fiscal Recovery Funds (CSLFR) Department of Treasury Final Rule of January 2022., offers a standard allowance for revenue loss of $10 million, allowing recipients to select between a standard amount of revenue loss or complete a full revenue loss calculation. Recipients that select the standard allowance may use that amount, in many cases their full award, for government services. The Municipality’s management selected the standard allowance, since the amount awarded of CSLFR funds were less than $10 million ad determined that the use of these funds was for governmental services, which are services traditionally provided by recipient governments. The Municipality determined that the payroll expenditures of several departments of the Municipality’s General Fund will be charged to the CSLFR fund as government services. The transfer of $1,468,197 of CSLFR to other Municipality’s bank accounts was to cover the payrolls related to governmental services accounted in the Municipality’s General Fund during the fiscal year 2021-2022. Due to an involuntary omission, these transfers were not recorded as expenditures in the CSLFR fund in the accounting system of the Municipality. To correct this accounting error the Municipality’s management gave instructions to the accounting staff to start reclassifying in the accounting system as soon as possible, these transfers to payroll expenditures accounts in the CSLFR fund. Municipality’s management believes that this finding should be related to an issue of reporting because the Municipality complied with the requirements of activities allowed or unallowed and allowable costs, since the Municipality disbursed CSLFR funds related to governmental services in accordance with the Department of Treasury Final Rule of January 2022. No actions are required related to this finding.

Evidence of AAFAF Funds closeout report was provided, there is no issue.

Corrective Action: Management of the Institute did not provide any planned corrective actions for this finding. Person Responsible: Management of the Institute did not identify an individual responsible for corrective action for this finding. Completion Date: Management of the Institute has not established a completion date for corrective action for this finding.

FINDING 2022-003 Contact Person Responsible for Corrective Action: M. Celita Green Contact Phone Number:219-881-1363 Views of Responsible Official: We concur Description of Corrective Action Plan: While it has been confirmed that most of the firefighters are currently receiving the corrected overtime wages as calculated by Department of Labor, it has recently been learned that the formula that was used to calculate the corrected wages has not been shared with the Fire Department. We will be working with the Fire Department in obtaining the corrected formula to use, so that Fire Staff will be able to approve the correct pay, prior to it being paid by payroll. Anticipated Completion Date: December 31, 2024

FINDING 2022-002 Finding Subject: Allowable Costs/Cost Principles Summary of Finding: Indirect costs are expenses that are incurred by other County offices, which indirectly benefit the County Title IV-D offices. Indirect expenses are allocated to the County Title IV-D offices through an indirect Cost Allocation Plan (CAP) which is submitted to the Department of Child Services’ Child Support Bureau. Indirect costs charged are based on twoyear prior expenditures; therefore, indirect costs charged in 2022 were based on expenditures from 2020. A sample of 25 expenditures, totaling $27,077, from the department cost pools from the CAP were selected for testing. For 1 of the 25 expenditures examined, the County was unable to provide the contract; therefore, we were unable to verify if the correct rate for the contract payment was charged. For an additional 2 contracts requested, the contract could not be provided at the initial time of request. The contracts were provided nine months later at which time we verified the contract payment charged. In addition, the County did not have written procedures for determining the allow ability of costs in accordance with Subpart E of 2CFR200. Contact Person Responsible for Corrective Action: James W. Bramble Contact Phone Number and Email Address: 812-462-3361 james.bramble@vigocounty.in.gov Views of Responsible Officials: We disagree with the finding Explanation and Reasons for Disagreement: Of the three contracts that were found to be non-compliant, one contract was a 2014 contact with a one year termination that provided for courthouse cleaning services. After the termination date of contract the agreement was verbally continued by the County Commissioners. The examiners were provided copies of that contract and signed copies of the other two contracts that were in effect during the audit period. The County Auditor was provided information by the examiners on the specific contracts in question on June 4, 2024 and copies of the contracts were provided on June 7, 2024. That is three days later, not nine months as alleged in the finding. Description of Corrective Action Plan: The County currently has a signed contract with a different contractor for courthouse cleaning services than the one in 2014. The current contract has a provision that it is to be continued until terminated by either party. Contracts will be reviewed to ensure the contract amounts are current. The County will develop an allowable cost policy. Page 2 Corrective Action Plan, Vigo County Anticipated Completion Date: January 31, 2025

Criteria or specific requirement: 2 CFR 200.403(b) states that costs must "Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items". Per the Federal award (contract 2018-51300-28430, PTEIN C0535A-A), there was no specific allowability for “Fees”, and the budget indicated $0 allocated to “Fees”. 2 CFR 200.303(a) requires non federal entities receiving Federal awards to "Establish and maintain internal controls over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award." 2 CFR 200.430(i)(1) states that "Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed." Condition: (10.307) During testing of general disbursements, it was noted that the Organization did not retain documentary evidence of review and approval of disbursements for 4 out of 17 samples tested. In addition, for 1 sample, the Organization charged unallowable costs (bank fees) to the major program. During testing of payroll, it was noted that inadequate time and effort documentation was retained for 2 out of 26 samples tested, resulting in wages being charged erroneously between programs. (10.311) During testing of general disbursements, it was noted that the Organization did not retain documentary evidence of review and approval of disbursements for 5 out of 14 samples tested. During testing of payroll, it was noted that inadequate time and effort documentation was retained for 2 out of 21 samples tested, resulting in wages being charged erroneously between programs. During testing of indirect costs, it was noted that direct costs used to calculate the applied indirect cost rate were not supported by underlying documentation of costs incurred. Questioned costs: None Context: (10.307) For testing of general disbursements, a sample of 17 was made from a population of 113 disbursement transactions. Of the 17 sampled, 4 did not include documentary evidence of review and approval of the disbursement. In addition, 1 sample was found to be out of compliance with the provisions for 2 CFR 200.403(b). For testing of payroll, a sample of 26 was made from a population of 168 unique employee paychecks. Of the 26 sampled, 2 had inadequate documentation of time and effort spent on the major program, resulting in an overbilling in one sample and an underbilling in the second sample. (10.311) For testing of general disbursements, a sample of 14 was made from a population of 90 disbursement transactions. Of the 14 sampled, 5 did not include documentary evidence of review and approval of the disbursement. For testing of payroll, a sample of 21 was made from a population of 139 unique employee paychecks. Of the 21 sampled, 2 had inadequate documentation of time and effort spent on the major program, resulting in an overbilling in one sample and an underbilling in the second sample. For testing of indirect costs, a sample of 6 was made from a population of 21 monthly reimbursement invoices. Of the 6 sampled, 3 did not include sufficient documentation to support the direct costs used to apply the indirect cost rate. Cause: The Organization does not have adequate controls around the documentation of the supervisor review and approval process. Supervisory review and approvals are currently being communicated verbally. In addition, inadequate documentation is retained to document the time and effort of employee time spent on grants and the total direct costs that should be considered when applying the indirect cost rate. Effect: Without adequate records retained, the Organization is at risk of noncompliance with Federal programs and grant regulations, which could result in penalties or repayment obligations. Without adequate documentation and controls in place to ensure costs are reasonable and intended for the program charged, the Organization could incorrectly charge expenditures to the Federal program, report fraudulent expenditures, or not request appropriate reimbursement that the Organization is entitled to under the terms of the grant. Repeat Finding: No Recommendation: CLA recommends for the Organization to evaluate its current policies and procedures to implement an additional layer of review, and to formally document such review and approval procedures for all transactions affecting federal funds (i.e. approval of general expenditures, approval of timesheets, approval of indirect cost allocations). In addition, the Organization should emphasize the importance of detailed reviewed timesheets, including a second level review by the Finance Manager to ensure the accuracy and documentation of time and effort billed to each Federal program. Views of responsible officials: Management agrees with the finding. Action Taken in Response to Finding: In response to these findings, OSA has reviewed its formal review and approval procedures to ensure that documentation of review and approval occurs with payroll time cards and wage reporting to grants. In response to this review, OSA has implemented the following: ● Adherence to a current and accurate Financial Management Policy Manual. The manual documents OSA’s policy and procedures regarding this finding: ○ Monthly close/reconciliation reviewed by Executive Director and Board of Directors. ○ Review and approval of all allowable federal expenditures including payroll wage reporting to federal programs, and invoices by OSA Executive Director or federal program Director. ○ Archiving a digital copy of review and approvals for every invoice submitted, including review and approval for all supporting documentation including approved timesheets. Name(s)of the Contact Person Responsible for Corrective Action: Laurajean Lewis, Executive Director, at laurajean@seedalliance.org Planned Completion Date for Corrective Action Plan: 06/01/2024

All invoices and documentation related to expenditure of federal funds are now scanned and attached to the accounting entry recording the payable. With regards to the Client Acknowledgement of Receipt of Direct Assistance Forms, we have taken steps to ensure that the documentation is signed at the time assistance is given and continue to work with the refugees as to the importance of having the proper paperwork on file.

Finding Number: 2022-006 Planned Corrective Action: The Executive Director no longer performs any accounting duties. An accounting firm was hired to bring everything up to date and an Accounting Assistant was hired. A new Fiscal Procedures Manual has been approved by the board. Only one Housing Assistance Payment bank account is now used; fraudulent checks were written out of the “general account” that checks are not normally written from, this account has been closed. Anticipated Completion Date: January 1, 2023 Responsible Contact Person: Sherrie Boudinot

CORRECTIVE ACTION PLAN Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing No.: 21.027 Federal Agency: Department of the Treasury ? Pass-through from the State of California Award No.: WWID 4SSO10370 & CA 1910156 Award Year: Fiscal year 2021-2022 Category of Finding: Activities Allowed or Unallowed, Allowable Costs Name responsible for correction action plan: Emily Armstrong, Revenue Services Manager The corrective action planned: Payments applied to the 93 water bills and 81 wastewater bills will be reversed on the customer?s accounts. A notice will be issued to customers via mail and email (where possible) of the discrepancy. The funds will be returned to the State pursuant to their outlined procedures. Moving forward, the City will ensure that there is a multi-layered approval process to review the eligibility period of any State funding to identify the correct eligible applicants prior to disbursement. For future funding related to water and/or waster bills, the list of eligible applicants will be compiled by an analyst within the department and will be reviewed by the Revenue Services Manager and Assistant Finance Director prior to disbursement. Anticipated completion date: March 24, 2023

Responsible: Thomas Hoover, CFO Corrective Actions: Update Finance policies to specify that documentation of review and approval of both the costs charged and the allocation methods of costs charged to federal grants be maintained. Completion Date: March 29, 2023 Explanation: Policies have been in place over the coding of costs allocated to federal grants in compliance with CFR 200 and were enhanced in 2023 in response to an OJJDP/OCFO recommendation. Review and approval of costs after being approved by an authorized signer takes place in multiple steps and concludes with preparation of reimbursements and financial grant reports (FFR). In order to further demonstrate compliance as recommended, Management has updated Finance policies to capture the documentation and maintenance of such documentation of Supervisory review and approval.

FINDING # 2022-024No finding in prior yearThe New Jersey Department of Labor and Workforce Development (DLWD) has a policy in place for processing tuition reimbursements that are performed by the Department?s Accounts Payable unit. The policy was reviewed by the Office of Finance & Accounting (F&A) and internal control procedures were enhanced to ensure that fiscal cutoff measures were appropriately addressed. Tuition reimbursement procedures include having the requests forwarded to the responsible Supervising Analyst in the Appropriations/Accounting unit for final review and approval to ensure the proper fiscal period is charged. The correcting transactions were completed during the Single Audit timeframe to remediate the findings by charging and reimbursing the proper fiscal year accounts. The DLWD will continue its efforts to ensure compliance and that all charges applied to Federal awards are within the specified period of performance going forward.COMPLETION DATE/CONTACT PERSON December 31, 2023Ruslana Nagorniak(609) 984-7678Ruslana.Nagorniak@dol.nj.gov

FINDING # 2022-021No finding in prior yearThe Department of Children and Families (DCF) will review and enhance its procedures and controls to ensure that expenditures charged to the program are incurred within each grant award?s specified period of performance.Further, as the federal SSBG grant award cited has a period of performance that remains open through September 2023, DCF has adjusted the four transactions that were posted incorrectly to another available funding source and ensured that all transactions presently recorded are now in compliance and within the specified period of performance.COMPLETION DATE/CONTACT PERSON Fiscal Year 2024Steven M. Dodson(609) 888-7555Steven.Dodson@dcf.nj.gov

FINDING # 2022-016No finding in prior yearDue to the COVID-19 pandemic and the resulting remote teleworking period that was in place at DOH during the FY 2022 audit period, some payment documents were approved remotely without physical documents in hand, and the payment documentation for the 17 of 60 ELC general disbursement transactions examined were either not delivered to the office to be filed yet or have been delivered but misfiled. DOH Central Accounts Payable will review and improve its current procedures and controls to ensure all physical payment documents are reviewed, approved, and filed correctly under the current hybrid remote working conditions in place now since the pandemic ceased.COMPLETION DATE/CONTACT PERSON April 11, 2023Michael Palasciano(609) 376-8518Michael.Palasciano@doh.nj.gov

FINDING 2022-003Contact People Responsible for Corrective Action: Lynn Leininger, Business Manager and AllisonKellogg, Director of Special EducationContact Phone Number: (260) 367-3677Whitko Community Schools concurs with the finding and will implement a dual check system with theBusiness Manager and the Director of Special Education. All proportionate money earmarked fornonpublic school expenditures under the Special Education Cluster will be continually monitored from theapproval through the end of the grant to insure all compliance requirements are met.The completion date for this corrective action will be July 1, 2023.

Finding Number: 2022-002Planned Corrective Action: Cleveland Play House had extensive turnover during the 2022 fiscal yearwhich resulted in several vacancies, including the Director of Finance position, for a significant portion ofthe year. As a result, many of the reports that are standard practice in our organization were not beingcompleted. In addition, the filing of certain documentation to support expenditures was not being doneconsistently. The Director of Finance position was filled in the fall of 2022. As a result, documentationof allowable expenditures is being addressed for the fiscal 2023 audit.In addition to turnover, the organization transitioned to a new general ledger system with a new chartof accounts in fiscal year 2022. As a result of this transition and the vacancies mentioned above, certaindata pertaining to the federal programs was not being captured. Management has informed all staff ofthe requirements to track federal programs within the general ledger accounts.Anticipated Completion Date: June 30, 2023Responsible Contact Person: Erica Tkachyk, Director of Finance

Finding 2022-003Subject: Child Nutrition Cluster ? Allowable Costs/ Cost PrinciplesFederal Agency: Department of AgricultureFederal Programs: School Breakfast Program, COVID-19 School Breakfast Program, National School LunchProgram, COVID-19 National School Lunch Program, Summer Food Service Program for Children, COVID-19Summer Food Service Program for ChildrenAssistance Listings Numbers: 10.553, 10.555, 10.559Compliance Requirement: Allowable Costs/ Cost PrinciplesAudit Findings: Material Weakness, Other MattersContact Person Responsible for Corrective Action: Julie Dodd, TreasurerContact Phone Number: 765-348-7550Views of Responsible Official: We concur with the finding of the auditorDescription of Corrective Action Plan:This was a one time occurrence attempting to correct a previous year oversight. Moving forward, noindirect costs will be charged or paid outside of the correct time period for the fiscal year.Anticipated Completion Date: Completed

FINDING 2022-004Contact Person Responsible for Corrective Action: Timothy LaGrangeContact Phone Number: 812-683-3971Views of Responsible Official: We concur to the finding.Description of Corrective Action Plan: Southwest Dubois and the DSP Exceptional Child?s Co-op have created a systemof internal controls that will ensure reporting compliance requirements are met. The Co-op has developed a shared file foreach of their staff that is participating gin the requirements for the proportionate share. This will be a detailed list of datesand duties that were applied to the proportionate share of each member school corporation. This list will be printed andattached to the grant records and can also be provided to each member corporation if requested.Anticipated Date of Completion: May 2023

FINDING 2022-003Contact Person Responsible for Corrective Action: Kim DeVaney/Robin PopejoyContact Phone Number: 317.758.4172Views of Responsible Official: We concur with the finding.Description of Corrective Action Plan: Those procedures and errors were discussed and adjustments have beenmade. To prevent errors the Payroll Specialist will make sure the employee timesheets that was signed off by the Directormatches with the hours they were approved to work when hired.Anticipated Completion Date: February 2023

Finding 2022-003 - Allowable Activities or Unallowed, Allowable Costs/Cost Principles and CashManagementMaterial Weakness in Internal Control over Compliance and Material Noncompliancefinding Summary: During the audit, the appropriate documentation for grant expenditures to supportthe drawdown from grant funding was not readily provided. In addition, the process to ensure thatgrant expenditures are allowable and reconciled was not clearly communicated to appropriate partiescausing expenditures to be inappropriately claimed in the wrong fiscal year.Responsible Individual: Chief Financial OfficerCorrective Action Plan; We have designated a member of management to participate in monthly,quarterly, or annual reconciliations as proposed by the auditors. The existing controls will be clearlycommunicated to ensure that program expenditures are made prior to requesting reimbursement offunds.Anticipated Completion Date: Ongoing

Finding 2022-003Material weakness in internal controls over compliance for allowable activities and costs and material non-compliance inthe Coronavirus State and Local Fiscal Recovery Fund program.Contact Person(s):Nicholas Lee, Chief Financial OfficerCorrective action planned:The Organization will provide additional training to employees responsible for incurring costs in accordance with 2 CFR200.403. Additional resources have been assigned to review and ensure documentation and policies are retained to supportthe distribution of charges between projects. Anticipated completion date:June 30, 2023

View of Responsible Officials: A former Board member with finance and operations experience has been tasked with reviewing financial policies and procedures to ensure compliance in all areas. Policies and procedures will be updated with new processes. To date there have been two changes implemented. Finance staff must now attach electronic copies of invoices within the accounting system to corresponding transactions in order to process payment. In addition, a report of credit card charges missing required documentation is circulated to management monthly, with follow-up to the individual purchasers. Training for all members of the department will occur on an ongoing and regular basis to ensure best practices are being upheld. Policies and procedures and/or the Financial Procedures Handbook will also be updated to reflect the changes.

2022-007 – TITLE I – INADEQUATE SUPPORTING DOCUMENTATION– ALN 84.010 – SIGNIFICANT DEFICIENCY & OTHER NONCOMPLIANCE FINDING TYPE: SIGNIFICANT DEFICIENCY & OTHER NONCOMPLIANCE Finding 2022-007 Federal Program: Title I ALN: 84.010 Federal Award Number(s) and Year(s): S010A200034, 2022 Federal Agency: U.S. Department of Education Questioned Cost: $7,591 Condition: We were unable to verify whether 6 of 60 expenditures totaling $7,591 were for costs allowed under the Title I grant. When projected against the total population of $1,628,283, the total projected error is $15,939. Corrective Action Plan: Agreed. WBSD#7 created a new Grants Coordinator position in July 2023 with one of the specific responsibilities for that position being oversight of all Federal Title programs. This oversight responsibility includes monitoring expenditures to ensure all expenditures are allowable within the parameters of each program and also that proper documentation for those expenditures has been maintained. Anticipated Completion Date: • Fiscal Year 2024