Corrective Action Plans

All journal entries are entered by the CSFO and signed by the Superintendent.

Capital Area Community Action Agency's use of the Payroll Protection Program loan forgiveness resulted in unearned revenue from grantor. Capital Area Community Action Agency will pursue working with the Office of Head Start regarding use of those funds within the project period.

U.S Department of Health and Human Services FALN: 93.926 Federal Award Identification Number: 5 H49MC00119-21-00 / 6 H49MC00119-20-01 2022-006 – Period of Performance – Significant Deficiency Recommendation: We recommend that internal controls be strengthened and processes implemented to ensure all expenses include supporting documentation/invoice indicating period of performance. Grantee Response and Corrective Action Plan 2022-006: The Center for Black Women's Wellness has proactively updated our credit card policy in 2022. The CEO reviews the credit card statement monthly for discrepancies and allowable costs. Additionally, credit card holders are responsible for reviewing their credit card statements monthly for discrepancies and allowable costs. This measure aligns with our broader fiscal management improvements, which also involve the engagement of a Contractual CFO in April 2024 to oversee and refine our financial operations. These initiatives are part of our commitment to maintaining rigorous financial integrity and ensuring that all transactions are transparent and compliant with regulatory requirements. Additionally, we have resolved past documentation issues, such as those arising from the abrupt departure of an employee, by implementing robust procedures to avoid similar incidents in the future. Responsible Parties: Jemea Dorsey, CEO Date Corrected: April 30, 2024

At the onset of the pandemic, certain employees were sent to work remotely. During this period of time, the Organization experienced larger than usual turnover, including the CFO position, which remained unfilled for a significant period of time. Due to these factors, many employees were forced to handle new responsibilities for the first time in a new remote setting, as the Organization worked diligently to continue operations. Since many of the shows were being cancelled or modified from their traditional format, smaller projects related to design buildout, maintenance, and advertising were taken on. Many of these projects involved smaller retail purchases for which documentation was not properly retained. The Organization acknowledges the findings and has since hired a new CFO and instituted policies and procedures surrounding documentation of all cash disbursements and expenditures of federal awards.

1. The Center will retain evidence of competitive bidding, unless an emergency or other situation precluding the delay of competitive bidding has arisen (in which case, the Center will retain the evidence and rationale justifying the sole source contract). The Center will retain verification of suspension and debarment for all potential contract service providers. The Center notes that one of the contracts selected for testing arose during an emergency situation (flooding). 2. CFO will ensure that all invoices and supporting documentation are retained. ED and/or Director of Legal Services (depending on amount of expenditure, both may be required) will approve electronic payments in Bill.com. Approval of expenses paid with paper checks will be indicated by signature of checks after reviewing accompanying support.

The School System concurs with the auditor’s findings and recommendations. The Infants and Toddlers Supervisor will conduct monthly reviews of outstanding purchase orders in Oracle, addressing issues promptly with the Business Operation Officer/Financial Analyst. Professional development sessions will be attended to enhance invoice scrutiny for allowable expenses within the grant period. Quarterly reminders and Financial Quarterly Review meetings will be instituted for supervisors, ensuring timely action on outstanding purchase orders. Following will be implemented: 1. Infants and Toddler Supervisor will hold monthly meetings with the Financial Analyst and the secretarial staff to ensure consistent actions are taken when generating purchase orders and processing invoices. 2. The Infants and Toddler secretary will review invoice dates against contracts and purchase orders to ensure they fall within grant timelines before submitting them to the supervisor for signature. 3. Infants and Toddler Supervisor will confirm that purchases made with grant funds are allowable and within the designated grant period. The Supervisor will cross-reference invoice dates against grant periods before signing and sending to accounts payable. 4. The infants and Toddler Supervisor will confirm the work being invoiced has been completed and vendor details are checked, and dates verified. 5. Grant Accountants will provide transaction detail reports (at least quarterly). The Infant and Toddlers Coordinating Supervisor will review and sign-off on the quarterly transaction reports. 6. The Financial Analyst will meet monthly with the Infants and Toddler Supervisor and Coordinating Supervisor to ensure grant allowable expenses are adhered to and invoicing is updated and falls within grant-specific timelines.

2022-002 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, and that adequate supporting documentation for all federal program charges is maintained. Action Taken: The Board is taking adequate action to review and approve all charges to the federal programs. The Board’s steps have been reviewed with Workforce WV and has been approved our procedures. Supporting documentation is kept both in physical and electronic forms. Each check the Board distributes has an approved purchase order attached, (if applicable), invoice, or if it is a monthly recurring charge, statement or bill attached and once the bill is entered into our system and the bill is paid, the check has the Executive Director’s initials and date showing it is approved in our accounting system. Also, if the expenditures are questionable, we will receive approval before submission of the bill from our liaison in the Workforce WV office.

Significant Deficiency in Internal Control Over Compliance and Noncompliance – A. Activities Allowed or Unallowed and B. Allowable Costs/Cost Principles Recommendation: The auditor recommended FSA implement procedures for all employees who have payroll claimed under federal programs to maintain detailed timecards or time studies to support hours worked under each federal program. Planned Corrective Actions: Family Service Association of Howard County, Inc. (FSA) will implement procedures and maintain time cards and time studies for employees who have payroll claimed under the federal programs to be in compliance of federal grants beginning April 2024.

Community Partners acknowledges that documentation to support expenditures was not consistently kept across all federal grants. Current leadership has addressed this issue by implementing documentation standards across all federal grants. Furthermore, through the implementation of NetSuite, expenditures will be fully supported and approved by staff before posting. The person responsible for the corrective action detailed above will be Joyce Williams, Chief Financial and Operations Officer, (213) 346‐3202. We anticipate corrective action will be completed by June 30, 2024.

FA 2022-001 Improve Controls over Employee Compensation Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Agriculture Pass-Through Entity: Georgia Department of Education AL Numbers and Titles: 10.553 – School Breakfast Program 10.555 – National School Lunch Program Federal Award Number: 225GA324N1199 (Year: 2022) Questioned Costs: $41,309.92 Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over the employee compensation process as it relates to the Child Nutrition Cluster. Corrective Action Plans: The Hancock County School District has updated the internal controls over the employee compensation process as it relates to the Child Nutrition Cluster and has corrected the employee codes for the director and former director to ensure that the correct employees are paid from CNC. Estimated Completion Date: June 30, 2024 Contact Person: Matthias Jones, Finance Director Telephone: (706) 444-5775 Ext. 125 Email: mjones@hancock.k12.ga.us

The Board of Education has now regained control of the District and moving forward, the District will closely monitor grant funded expenditures. The District utilizes its Grants Council to review grant awards and develop plans for expenditures. This includes ensuring the expenditures are necessary and reasonable for the grant program in accordance with 2 CFR § 200.403(a) and allowable under the grant guidelines.

FA 2022-001 Improve Budgetary Controls over Expenditures Compliance Requirement: Activities Allowed/Unallowed Allowable Costs/Cost Principles Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: COVID-19 – 84.425D – Elementary and Secondary School Emergency Relief Fund COVID-19 – 84.425U – American Rescue Plan Elementary and Secondary School Emergency Relief Fund COVID-19 – 84.425W – Elementary and Secondary School Emergency Relief Fund Federal Award Number: S4250200012 (Year: 2020), S4250210012 (Year 2021), S425U210012 (Year 2021), S425W210011 (Year 2021) Questioned Costs: $279,314.22 Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over expenditures as it relates to the Elementary and Secondary School Emergency Relief Fund program. Corrective Action Plans: Thomasville City Schools has amended any contracts with companies that provide services to allow the District to pay ESSER retention supplements when the Thomasville City Schools employees receive them. Estimated Completion Date: August 10, 2023 Contact Person: Stella M. Smith, CPA Telephone: (229) 225-2600 Email: smiths@tcitys.org

In September 2023, a "AP Processing Guidelines & Concur Reference Guide" document was introduced to ensure timeliness, completeness and propriety of books and records. Full dissemination to all Program Managers in connection with in-depth training sessions is still work in process and a result of the number of personnel to be trained, combined with limited bandwidth by resources assigned to training. The Concur Expense reporting module is being integrated within the ERP environment, enabling detailed chart of accounts to reflect GL coding by Segment, Grant, and Program. All journal entry support is attached to accounting entry in the ERP. The journal entry is entered by someone on the accounting team and approved by the Controller. Responsible: Annette Nastri, Timing: June 30, 2024

Finding 2022-003: Costs Incurred Outside Period of Performance (Significant Deficiency over Internal Control and Instances of Noncompliance – Period of Performance; Allowable Costs/Cost Principles) Response and Corrective Action Plan: Management agrees with finding. The Health System will review and modify policies and procedures over the program to ensure management implements policies, procedures, and processes to make sure that the costs incurred are appropriately charged based on the contracts’ performance periods. Anticipated Completion Date: by March 31, 2024 Responsible Person: Ann Metzger, Vice President Finance

Finding No. 2022-006 Area: Allowable Costs/Cost Principles Views of Auditee and Planned Corrective Action Disagree with the finding. Condition 1. For 1 or (2%) sample, identified as employee no. 21199, evidence of fair allocation of the employee’s payroll cost was not provided. We disagree. Evidence of fair allocation document reflecting the payroll cost (amount) was provided to the Ernst & Young audit team. Condition 2. For 2 (or 40%) transactions identified as PS-067026-US and PS-078607-US with a total cost of $131,490, evidence of prior approval of the acquisition by the federal agency was not provided. We disagree. Prior approval documents of PS-067026-US and PS-078607 were provided to the Ernst & Young audit team. Anticipated Completion Date N/A Name of Contact Person and Title Contact Person – Arlene Lizama, Director of Finance Contact – arlene.lizama@cnmipss.org

Finding No. 2022-005 Area: Allowable Costs/Cost Principles Views of Auditee and Planned Corrective Action Condition 1. Disagree with the finding. The Education Stabilization Fund (ESF) of the Public System was awarded to and was designed to provide additional funding (supplement) support to the local school system (PSS) as a result of the impact of the COVID-19 pandemic. Background: On March 16, 2020 PSS suspended classroom instruction, ease central office operation to a certain level, implemented furloughs, and effectuated cost- containment initiatives, among drastic measures to mitigate the crisis brought about by the pandemic. Of the public elementary, middle, and high schools on Saipan, Tinian, and Rota, only one school - Kagman Elementary School - was provided limited instruction (during summer of 2020). Kagman Elementary School was the first to reconfigure its facilities to maintain a safe (social distancing) facility for in-person student learning. The $802,789 as cited (Condition 1) was an ESF-approved and sanctioned funding allocation. However, the change in funding source was initiated after the payroll processing. And in order to reflect the correct funding source, the JE adjustment was initiated. Due to JE limitation these entries are not reflected to “subsidiary” ledgers. Condition 2. Disagree with the finding. 2. Retention incentive The Public School System maintains that both the Education Stabilization Fund (ESF) and American Rescue Plan Act (ARPA) spending plans were approved by the federal grantor. The Retention Incentive Plan in question is a component of both ESF and ARPA spending plans. Further, an additional communication from the U.S. Department of Education affirms the PSS authority in the ESF and ARPA spending plans, including the Retention Incentive Plan in question. Ernst and Young in its 2021 audit report (issued on April 26, 2023) on the same condition (issuance of retention incentive, see page 66) does acknowledge that “PSS sought and received prior grantor approval.” Background: The Commissioner of Education has the sole expenditure authority vested as the chief state school superintendent to come up and produce a spending plan. As such, the Commissioner of Education proposed the funding disbursements and presented it with the State Board of Education. The BOE is the governing body of PSS. The BOE approved the COE’s spending plan. Condition 3. PSS agrees with the finding. However, as of FY2023, the Federal Programs Office has instituted a stringent Standard Operating Procedure for seeking prior approval for equipment costing over $5,000.00. Anticipated Completion Date: N/A Name of Contact Person and Title Contact Person – Arlene Lizama, Director of Finance Contact – arlene.lizama@cnmipss.org

Finding No. 2022-004 Area: Allowable Costs/Cost Principles Views of Auditee and Planned Corrective Action Condition 1. Disagree with the finding. For the 25 or (63%) samples, Notice of Personnel Action (NOPA) forms were not provided for differential payments paid to employees. We disagree. There is no need for the issuance of Notice of Personnel Action (NOPA) nor is it required for the issuance and or granting of pay differential. The PSS is granted by virtue of the State BOE Policy, Rules and Regulation that in paying pay differential the requesting department should/can only issue a memorandum (memo), and must be fully signed by and approved by the Commissioner of Education, before it is provided to the Payroll division of the PSS Finance department for the payment of pay differential. Condition 2. For 2 or (40%) equipment transactions identified as PS-049031-US and PS-055730-US which were acquired within fiscal year 2022 totaling $14,299, evidence of prior approval was not provided. We agree. However, as of FY2023, the Federal Programs Office has instituted a stringent Standard Operating Procedure for seeking prior approval for equipment costing over $5,000.00. Anticipated Completion Date: N/A Name of Contact Person and Title Contact Person – Arlene Lizama, Director of Finance Contact – arlene.lizama@cnmipss.org

Finding No. 2022-003 Area: Allowable Costs/Cost Principles Views of Auditee and Planned Corrective Action Condition 1. Disagree with the finding. The Education Stabilization Fund (ESF) of the Public System was awarded to and was designed to provide additional funding (supplement) support to the local school system (PSS) as a result of the impact of the COVID-19 pandemic. Background: On March 16, 2020 PSS suspended classroom instruction, ease central office operation to a certain level, implemented furloughs, and effectuated cost-containment initiatives, among drastic measures to mitigate the crisis brought about by the pandemic. Of the public elementary, middle, and high schools on Saipan, Tinian, and Rota, only one school - Kagman Elementary School - was provided limited instruction (during summer of 2020). Kagman Elementary School was the first to reconfigure its facilities to maintain a safe (social distancing) facility for in-person student learning. The $480,743 as cited (Condition 1) was an ESF-approved and sanctioned funding allocation. However, the change in funding source was initiated after the payroll processing. And in order to reflect the correct funding source, the JE adjustment was initiated. Due to JE limitation these entries are not reflected to “subsidiary” ledgers. Condition 2. Disagree with the finding. Cited in this finding were three (3) 190-day employees. The 190-day employees worked for ten months, however, their pay is stretched out over a period of twelve months. Further, these pay periods are inclusive of the days that they are not supposed to report to work including summer months. Hence, no timesheet(s) is/are required. Anticipated Completion Date: N/A Name of Contact Person and Title Contact Person – Arlene Lizama, Director of Finance Contact – arlene.lizama@cnmipss.org

FINDING 2022-006 Finding Subject: COVID-19 - Education Stabilization Fund - Allowable Costs/Cost Principles Summary of Finding: Finding: Documentation for 3 employees was not available to verify the contract amounts. Recommendation: Documents be retained to support amounts paid. Contact Person Responsible for Corrective Action: Kareemah Fowler, Assistant Superintendent of Business and Finance Contact Phone Number and Email Address: (574) 393-6088; kfowler@sbcsc.k12.in.us Views of Responsible Officials: We disagree with the finding. Explanation and Reasons for Disagreement: While we agree that the single source document used by the State to validate a teacher’s contract was not available for 3 employees. We provided sufficient alternate documents that would allow the State to validate the contract amount being paid, and whether the proper employees were paid from or should have been paid from the Education Stabilization Funds. The documents provided sufficient data to support the questioned cost of $26,207 outlined in the finding. We will be working with our software vendor to rectify the glitch that prevented us from providing the documentation requested by the State for future audit. Description of Corrective Action Plan: We will be working with our software vendor to rectify the glitch that prevented us from providing the documentation requested by the State. Anticipated Completion Date: January 2024

FINDING 2022-003 Finding Subject: Title I Grants to Local Educational Agencies - Allowable Costs/Cost Principles Summary of Finding: Finding: Documentation for 10 employees was not available to verify the contract amounts. Recommendation: Documents be retained to support amounts paid. Contact Person Responsible for Corrective Action: Kareemah Fowler, Assistant Superintendent of Business and Finance Contact Phone Number and Email Address: (574) 393-6088; kfowler@sbcsc.k12.in.us Views of Responsible Officials: We disagree with the finding. Explanation and Reasons for Disagreement: While we agree that the single source document used by the State to validate a teacher’s contract was not available for 10 employees. We provided sufficient alternate documents that would allow the State to validate the contract's amount being paid, and whether the proper employees were paid from or should have been paid from the Title I funds. The documents provided sufficient data to support the questioned cost of $203,488 outlined in the finding. We will be working with our software vendor to rectify the glitch that prevented us from providing the documentation requested by the State for future audit. Description of Corrective Action Plan: We will be working with our software vendor to rectify the glitch that prevented us from providing the documentation requested by the State. Anticipated Completion Date: January 2024

2022-005 Significant Deficiency in Controls over Compliance: Administrative Requirements of Uniform Guidance-Administrative Policies The schools have documented their administrative policies effective 3/1/2023.

Condition: Administrative costs are submitted to the state monthly for reimbursement on the Record of Expenditures under the TEFAP Financial Assistance form ("FD-32D"). The State reimburses the Organization for administrative costs as determined by the state on a monthly basis. Typically, the monthly reimbursement amount is significantly less than the actual amount of allowed administrative expenses incurred by the Organization. During our procedures, we noted that certain expenditures, amounting to approximately $3,290, which were included on the FD-32D of which supporting documentation the Organization is required to retain under 2 CFR part 200 was lacking. As such, we could verify these costs related to activities allowed for reimbursement under 2 CFR part 200. Views of Responsible Officials and Corrective Actions: We agree with the auditor's comments and the following action will be taken to improve this situation. The Finance and Administration Manager and the Director of Logistics, who prepare the FD-32D, will work together to ensure that all supporting documentation is retained for all allowable expenses monthly. The corrective actions will be implemented by July 1, 2023.

FA 2022-001 Improve Controls over Federal Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principles Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: COVID-19 - 84.425D - Elementary and Secondary School Emergency Relief Fund COVID-19 - 84.425U - American Rescue Plan Elementary And Secondary School Emergency Relief Fund Federal Award Number: S425D200012 (Year: 2020), S45U210012 (Year: 2021) Questioned Costs: $16,384 Repeat of Prior Year Finding: None Description: A review of expenditures charged to the Elementary and Secondary School Emergency Relief Fund program revealed instances in which expenditures had not been properly approved by the pass-through entity. Corrective Action Plans: The School District will work with all entities to confirm that all existing internal controls are adhered to by developing and implementing an improved monitoring process. This process will ensure that all expenditures are compliant with all applicable policies and regulations. Estimated Completion Date: June 30, 2023 Contact Person: Daniel Oldham Telephone: 706-677-2222 Email: Daniel.oldham@banks.k12.ga.us

FINDING 2022-013 Contact Person Responsible for Corrective Action: Casey Brewster Contact Phone Number: 812-752-8935 Views of Responsible Official: We concur with the finding Description of Corrective Action Plan: Supporting documentation and a second approval is now required within the local financial management system for transfers and journal entries. Relevant notes and uploaded documents will be housed within the financial management system so future audits shall have ease of access to the documentation in order to properly test allowable activities and costs. Anticipated Completion Date: March 2023.

FINDING 2022-005 Contact Person Responsible for Corrective Action: Casey Brewster Contact Phone Number: 812-752-8935 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Instead of utilizing journal entries for corrections or adjustments in generic form, corrections to large or for multiple disbursements or receipts should be completed by reversing the action within the financial software and then correctly processing the disbursements or receipts. The on-going training and the related corrective actions which ensure more frequent and more in-depth reviews of reports on a monthly basis will also reduce the need for corrections in general. However, in the event there must be journal entries for corrections, documentation supporting and related to any journal entry will be input into the financial management software, as will any related notes, and any journal entry will have documented approval contained in that software, all completed by separate people ? the Treasurer and CFO. Additional, related training will also be sought to ensure related processes and controls are understood and followed. Anticipated Completion Date: May 2023