Corrective Action Plans

CORRECTIVE ACTION PLAN JUNE 30, 2022 REFERENCE: 2022-101 CFDA NUMBER 84.425D ? COVID 19 ? EDUCATION STABILIZATION FUND CFDA NUMBER 84.425U ? COVID 19 ? EDUCATION STABILIZATION FUND U.S. DEPARTMENT OF EDUCATION ? 2021 PASSED THROUGH ARIZONA STATE DEPARTMENT OF EDUCATION GRANT NUMBER: S425D210038 & S425U210038 CLIENT RESPONSE AND CORRECTIVE ACTION PLAN We concur with the condition. 1. Name of the contact person responsible for corrective action: Wendi Allardice - Superintendent Karen Hancock - Title I/ESSER Grants Manager 2. Corrective action planned: A. Protocols developed to obtain at least 3 vendor quotes for any items over 10,000 with an analysis and justification of vendor chosen. B. Protocol in place for checking for vendor suspensions or debarment prior to purchase approval. C. Monthly meeting for comparison of proposed and estimated purchases and actual purchases and charges to the Grant. 3. Anticipated completion date: Anticipated completion date for above listed plan: 08/31/2022

Unallowable Costs Planned Corrective Action: This finding occurred due to the fact that hours entered on a form-stack form by several contractors on our Community Navigator Program with the SBA were charged to the SBA before invoices were received from the contractor for those hours. This led to payment being received prior to the contractor being paid. Although this was officially approved by the SBA prior to submitting the quarterly bill for our services under the contract, we recognize that this is not how it should be done according to government and accounting rules. Thus, we will undertake the following corrective action to ensure that this does not occur again. 1. We will ensure that invoices for these identified charges are received from the contractors and the contractors are paid the full amount owed. 2. We will ensure that reimbursable expenses are not charged on government contracts and grants until they are actually paid or spent. This does not include expenses that are allowed by contract to be billed in advance. 3. Both the lead accounting person and the Compliance Officer will review and authorize all charges for allowability on all programs prior to submission of a request for payment. 4. A periodic review of the process and process adherence will be conducted by the finance committee of the Board of Directors. Person Responsible for Corrective Action Plan: Jamie Thomas, Compliance Officer Anticipated Date of Completion: October 15, 2023

Corrective Action Plan: VDH has updated its accounting structure and cost allocation plan to ensure that costs not otherwise eligible under federal grant awards are not attributed to the VDH administrative cost pool and allocated to federal grant programs. Scheduled Completion Date: 10/1/2022 Contacts for Corrective Action Plan: Megan Hoke, Financial Director, Vermont Department of Health Peter Moino, Director of Internal Audit, Vermont Agency of Human Services

Corrective Action Plan: The Department will review its procedures and internal controls and update as necessary to ensure that expenditures are incurred within the allowable period of performance for respective awards. Scheduled Completion Date of Corrective Action Plan: June 30, 2023 Contacts for Corrective Action Plan: Cameron Wood, UI Director Cameron.Wood@vermont.gov

Corrective Action Plan: The Department will review its procedures and internal controls to ensure that there is documented proof of appropriate signoff prior to payment processing and charging of program costs. Scheduled Completion Date of Corrective Action Plan: June 30, 2023 Contacts for Corrective Action Plan: Cameron Wood, UI Director Cameron.Wood@vermont.gov

Finding 2022-001 Management will develop and implement an additional layer of review in future Federal Emergency Management Agency (FEMA) project worksheet submissions to ensure expenditures reported for reimbursement are based on actual paid expenditures. Management will work with FEMA to refund the total overpayment of $904,020 and discuss the extent of additional courses of action. Management will ensure this is performed through the closeout process of the project worksheet with FEMA. Contact Person: Colette Boudreau, Vice President and Chief Accounting Officer Expected Completion Date: October 31, 2023

Corrective action plan: DPS will update the profile setup process in CAPPS to ensure the Service/Receipt Date Indicator box is checked in CAPPS on all profile setups relating to Grants. DPS Grants staff will receive training on how to fill out a Profile Setup Form to ensure the Service/Receipt Date Indicator Box is checked at the time the project is setup in CAPPS. The Grants staff will run a monthly report from CAPPS to see if all active projects have the service date indicator box checked. Implementation date(s): March 1, 2023 Responsible persons: Grants Manager, Deputy Administrator, Financial Reporting

2022-024 Improve Controls over Period of Performance Federal Agency: U.S. Department of Health and Human Services State Entity: Department of Behavioral Health and Developmental Disabilities (DBHDD) Corrective Action Plans: The Department will continue to improve the internal controls to ensure that expenditures are liquidated within 90 days of the end of the period of performance as required. The Department will update processes and procedures associated with period of performance requirements and provide training that outlines close-out processes associated with the specific grant awards. DBHDD will update the internal controls related to period of performance no later than June 30, 2023. Estimated Completion Date: June 30, 2023 Contact Person: Kenneth Ward, Director of Internal Audit Telephone: 404-884-5486; E-mail: kenneth.ward@dbhdd.ga.gov

2022-002 ALLOWABLE COSTS AND ALLOWABLE ACTIVITIES ? COVID-19 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS Recommendation: We recommend that the County include consideration of any expenditures that may be part of other federal programs as part of their review. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County will review their procedures to ensure expenditures coded to federal grants are not already claimed by other grant programs. Name of the contact person responsible for corrective action plan: Deborah Erickson, Administrative Services Director Planned completion date for corrective action plan: December 31, 2023

FINDING 2022-003 Finding: During testing, it was found that 2 out of 25 employees selected in the payroll sample for allowable costs did not have a completed semi-annual certification form or time and effort log for their work within the Title I program. Controls were not effective in ensuring all hours worked or salaries charged to the grant had the proper supporting documentation. Contact Person Responsible for Corrective Action: Carrie McGuire Contact Phone Number: (574) 875-5161 Views of Responsible Official: We concur with the finding Description of Corrective Action Plan: In order to address the issue related to semi-annual certifications not be completed and filed in a timely manner, Concord Community Schools created a Grants and Assessment Coordinator position in May 2022. A person was hired to fill this position starting on July 1, 2022. One of the essential functions of this position is maintaining current and accurate records related to federal and state grants. Starting in January 2023, in addition to the Grants and Assessment Coordinator, a member of the business department will be a second reviewer and sign the semi-annual certifications. Anticipated Completion Date: July 15, 2023

Department: Health and Human Services Title: Internal control over P-EBT Food Benefits needs improvement Questioned Costs: Known: $61,507,558 Likely: None Status: Management?s opinion is that corrective action is not required Corrective Action: The Department disagrees with this finding and does not believe that corrective action is warranted. During the course of the audit, the Department provided the Office of the State Auditor (OSA) with the complete population of recipients as well as the supporting information necessary for OSA to conduct testing to verify compliance with federal program requirements. The only remaining action that is required is for OSA to perform their testing. Completion Date: N/A Agency Contact: Anthony Pelotte, Director, Office for Family Independence, DHHS, 207-624-4104

Grant expenditures that specify a period of coverage and/or performance will be amortized based on the service contract terms. Amortization costs that go beyond a grant?s expiration date will not be recorded against the expired grant.

FINDING 2022-004 Contact Person Responsible for Corrective Action: Steve Snider, CFO Contact Phone Number: 260-920-1011 Views of Responsible Official: We disagree with the finding. The entire premise of the cooperative agreement and appointing a lead education agency is to have someone providing the services and managing the grants for those districts who participate. Description of Corrective Action Plan: DeKalb County Central United School District will work with the Northeast Indiana Special Education Cooperative to implement the procedures detailed below. The Northeast Indiana Special Education Cooperative (NEISEC) Treasurer will reach out to member schools during the writing process of the IDEA 611 and 619 grants in order for each member school to submit their plans for their allocation of proportionate share money. NEISEC will provide the allocation amounts to each cooperative school. These submissions will include a proportionate share budget and include proportionate share staff names and any necessary information for the budget categories. The NEISEC Treasurer will then compile the proportionate share information and include on the grant submission. The LEA Treasurer will be given a copy of the grant application and budget upon approval of the grant. Any NEISEC employee being paid out of proportionate share grant funds for salary and benefits will be paid from the LEA?s financial software. The LEA Treasurer will keep a spreadsheet of employee proportionate share expenses and this spreadsheet will be updated monthly based on time and effort logs that are submitted by all cooperative schools to the LEA and NEISEC. Any employee utilizing proportionate share funds that is not an employee of NEISEC, but rather a direct employee of a member school, will be paid directly by that member school. Time and effort logs will still be submitted to the LEA and NEISEC Treasurers for these employees in order to generate a direct reimbursement from the grant fund to the member school. For any expenses for a category outside of salary and benefits, a member school will need to submit an invoice and proof of purchase for equipment, supplies, etc. to NEISEC and the LEA in order to be directly reimbursed for those proportionate share expenses. If the request was not in the initial grant budget, the member school must submit all relevant information to NEISEC in order for a grant modification to be completed. Per IDOE the grant modification must be approved first prior to purchasing the items. Time and effort logs as well as invoice and proof of payment must be sent to the LEA Treasurer in order to completed the grant reimbursement requests. At the end of the grant period, any school with remaining proportionate share money will be required to complete a waiver. As of this date (2/10/2023) the LEA (DeKalb County Eastern CSD) and NEISEC are still in communication with SBOA and IDOE to review the proportionate share plan and ensure all necessary requirements will be satisfied. Anticipated Completion Date: Changes discussed above will be implemented for the remainder of the FY23 grant period starting 07/01/2023.

Contact Person Responsible for Corrective Action: Tyler Osenbaugh Contact Phone Number: 260-636-2175 Views of Responsible Official: Agree with the finding Description of Corrective Action Plan: Central Noble will work with the Northeast Indiana Special Education Cooperative to implement the procedures detailed below. The Northeast Indiana Special Education Cooperative (NEISEC) Treasurer will reach out to member schools during the writing process of the IDEA 611 and 619 grants in order for each member school to submit their plans for their allocation of proportionate share money. NEISEC will provide the allocation amounts to each cooperative school. These submissions will include a proportionate share budget and include proportionate share staff names and any necessary information for the budget categories. The NEISEC Treasurer will then compile the proportionate share information and include on the grant submission. The LEA Treasurer will be given a copy of the grant application and budget upon approval of the grant. Any NEISEC employee being paid out of proportionate share grant funds for salary and benefits will be paid from the LEA?s financial software. The LEA Treasurer will keep a spreadsheet of employee proportionate share expenses and this spreadsheet will be updated monthly based on time and effort logs that are submitted by all cooperative schools to the LEA and NEISEC. Any employee utilizing proportionate share funds that is not an employee of NEISEC, but rather a direct employee of a member school, will be paid directly by that member school. Time and effort logs will still be submitted to the LEA and NEISEC Treasurers for these employees in order to generate a direct reimbursement from the grant fund to the member school. For any expenses for a category outside of salary and benefits, a member school will need to submit an invoice and proof of purchase for equipment, supplies, etc. to NEISEC and the LEA in order to be directly reimbursed for those proportionate share expenses. If the request was not in the initial grant budget, the member school must submit all relevant information to NEISEC in order for a grant modification to be completed. Per IDOE the grant modification must be approved first prior to purchasing the items. Time and effort logs as well as invoice and proof of payment must be sent to the LEA Treasurer and NEISEC Treasurer in order to completed the grant reimbursement requests. At the end of the grant period, any school with remaining proportionate share money will be required to complete a waiver. As of this date (2/10/2023) the LEA (Central Noble) and NEISEC are still in communication with SBOA and IDOE to review the proportionate share plan and ensure all necessary requirements will be satisfied. Anticipated Completion Date: JUL 2023

Finding: 2022-002 Material Weakness in Internal Control over Compliance and Material Noncompliance U.S. Department of Labor Federal Financial Assistance Listing 17.258/17.259/17.278 WIOA Cluster Activities Allowed or Unallowed Finding Summary: The County?s expenditures identified as eligible and claimed under the WIOA Cluster program were disallowed by the United States Department of Labor due the lack of appropriate documentation justifying specific costs charged to the program related to one vendor ? Garcia Professional Services, LLC. Also, the contract entered into with Garcia Professional Solutions, LLC. did not adequately address the required contract terms as follows: 1. Total dollar value of the contract to justify procurement method utilized. 2. Terms for payment to ensure payments are only made for verified services received and adequately documented. 3. Contract provisions stipulated in Appendix II to Part 200 of the Uniform Guidance, including Equal Employment Opportunity, Rights to Inventions Made Under a Contract or Agreement, Debarment and Suspension, and Byrd Anti-Lobbying Amendment. Responsible Individuals: Dana Aschenbrenner, Finance Director Corrective Action Plan: Johnson County disagrees with the underlying premises of this finding. The expenditures referred to above were expenditures of the East Central Iowa Workforce Development Board (ECIWDB) and not direct expenses of the County. The ECIWDB contracted with Johnson County to provide fiscal agent services. The ECIWDB then entered into a contract with Garcia Professional Solutions, LLC (?GPS?) to provide administrative support services for the Board. Iowa Workforce Development did not provide adequate guidance to ECIWDB as to the DOL-required terms and the terms of that services contract between ECIWDB and GPS did not contain any standards of documentation which DOL later claimed applied to said contract. The County had no input into the contract between the ECIWDB and GPS, nor was the County a party to said contract. Any alleged deficiencies within that contract between the ECIWDB and GPS are solely the responsibility of the ECIWDB Board and/or Iowa Workforce Development. In our fiscal agent role, the County was obliged to honor payment requests submitted to the Board; in that regard we had to make payments to GPS provided those payment requests were invoiced to ECIWDB consistent with the ECIWDB-GPS contract, which they were. Anticipated Completion Date: Ongoing

FINDING 2022-005 CONTACT PERSON RESPONSIBLE FOR CORRECTIVE ACTION: Ralph Shrader/Jim Beyer CONTACT PHONE NUMBER: 765-762-3364 VIEWS OF RESPONSIBLE OFFICIAL: We concur with the finding. DESCRIPTION OF CORRECTIVE ACTION PLAN: School Corporation will advertise and attain sealed bids for projects as required by Federal guidelines. Detailed contracts and invoices will be required by the bidder before payment is made. ANTICIPATED COMPLETION DATE: March 2023

FINDING 2022-002 CONTACT PERSON RESPONSIBLE FOR CORRECTIVE ACTION: Lacey Sturgeon/Melissa Bell CONTACT PHONE NUMBER: 765-762-2500 VIEWS OF RESPONSIBLE OFFICIAL: We concur with the finding. DESCRIPTION OF CORRECTIVE ACTION PLAN: All claims/invoices will be reviewed by the Food Service Director and validated by the Assistant Food Service Director for correct contractual prices. ANTICIPATED COMPLETION DATE: March 2023

Management is in agreement with this finding and was aware of the Organization?s manual process to approve and store physical copies of pay rate approval, which could potentially create risk of losing physical copies. In September 2022, the Organization has modified this process to allow managers to virtually approve and store digital copies of pay rate documentation.

Finding 2022-002 ? Special Education Cluster - Earmarking Contact Person Responsible for Corrective Action: Brittany Treesh Contact Phone Number: 260-357-3185 Views of Responsible Official: The school corporation concurs with the finding. Description of Corrective Action Plan: Garrett-Keyser-Butler Community School District (GKB) will work with the Northeast Indiana Special Education Cooperative to implement the procedures detailed below. The Northeast Indiana Special Education Cooperative (NEISEC) Treasurer will reach out to GKB during the writing process of the IDEA 611 and 619 grants in order for GKB to submit their plans for their allocation of proportionate share money. NEISEC will provide the allocation amounts to GKB. These submissions will include a proportionate share budget and include proportionate share staff names and any necessary information for the budget categories. The NEISEC Treasurer will then compile the proportionate share information and include on the grant submission. The LEA Treasurer will be given a copy of the grant application and budget upon approval of the grant. Any NEISEC employee being paid out of proportionate share grant funds for salary and benefits will be paid from the LEA?s financial software. The LEA Treasurer will keep a spreadsheet of employee proportionate share expenses and this spreadsheet will be updated monthly based on time and effort logs that are submitted by GKB to the LEA and NEISEC. Any employee utilizing proportionate share funds that is not an employee of NEISEC, but rather a direct employee of GKB, will be paid directly by GKB. Time and effort logs will still be submitted to the LEA and NEISEC Treasurers for these employees in order to generate a direct reimbursement from the grant fund to GKB. For any expenses for a category outside of salary and benefits, GKB will need to submit an invoice and proof of purchase for equipment, supplies, etc. to NEISEC and the LEA in order to be directly reimbursed for those proportionate share expenses. If the request was not in the initial grant budget, GKB must submit all relevant information to NEISEC in order for a grant modification to be completed. Per IDOE the grant modification must be approved first prior to purchasing the items. Time and effort logs as well as invoice and proof of payment must be sent to the LEA Treasurer in order to complete the grant reimbursement requests. At the end of the grant period, any remaining proportionate share money will require that a waiver be completed. As of this date (2/10/2023) the LEA (DeKalb County Eastern CSD) and NEISEC are still in communication with SBOA and IDOE to review the proportionate share plan and ensure all necessary requirements will be satisfied. Anticipated Completion Date: Changes discussed above will be implemented for the remainder of the FY23 grant period starting 07/01/2023.

The Board will require approval for such expenditures made in short succession and for the bid process to be followed as required by law when the ultimate result of the transaction is a purchase of goods or services of an amount exceeding $20,000.

Planned Corrective Action: 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.

FA 2022-001 Improve Controls over Federal Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principles Procurement and Suspension and Debarment 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 Federal Award Number: S425D200012 (Year: 2020) Questioned Costs: $129,375.00 Repeat of Prior Year Finding: None 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: The Whitfield County School District does not concur with the finding; therefore, no corrective action is necessary. Estimated Completion Date: The expense was approved and paid in the fiscal year 2022. Contact Person: Kelly Coon Telephone: 706-217-6704 Email: Kelly.coon@wcsga.net

The bulk cable contract was cancelled effective 9/1/22. On March 15th, 2023 the Board of Commissioners made a motion to end the contract. According to the contract we had to honor a 60-day notice and that ends officially on Monday May 15th.

Alluma, Inc. Single Audit Corrective Action Plan Year Ending December 31, 2022 Audit Finding 2022-002: Contact Person Tammy Hickel Zola, CFO Corrective Action Plan Ensure specific CFR training to employees responsible for managing federal grant requirements as well as implementing additional procedures to ensure compliance with necessary and reasonable costs. Completion Date Alluma will expand training and internal controls in 2023.

FINDING 2022-002 Contact Person Responsible for Corrective Action: Dr. William Stitt, Superintendent Contact Phone Number: 260-495-5005 Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding. Fremont Community Schools will work with NEISEC to ensure proper oversight and internal controls are in maintained. Anticipated Completion Date: Corrective action plan will be implemented by June 30, 2023.