Corrective Action Plans

Department: Labor Title: Internal control over UI claim payments needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Department will review the single case where the claimant received multiple consecutive two-week work-search waivers by answering they were starting new employment. We will review to formulate new controls once the initial two-week period ends and the claimant continues to file for benefits to determine why the new employment did not commence as reported. The Department will conduct refresher training for staff to address the findings that were the result of staff errors. Completion Date: December 31, 2024 and November 11, 2024 respectively Agency Contact: Laura Boyett, Director, Bureau of Unemployment Compensation, DOL, 207-621-5156

Department: Education Title: Internal control over CACFP eligibility determination and claim reimbursement procedures needs improvement Questioned Costs: Known: $19,362 Likely: Undeterminable Status: Corrective action in progress Corrective Action: The Department will create a property type form, using USDA Regulations, and will share the form with small facilities. The Department will add the form to the new application and will be stored throughout the year. The Department will add an enhancement request for a warning and attestation for the collection of “in and out” records to substantiate the claiming of meals over the licensed capacity. The Department will implement a two-step claim verification process for each sponsoring agency which requires a two-person internal approval prior to a claim submission. Completion Date: July 31, 2024, October 31, 2024, April 30, 2024 and August 31, 2024 respectively Agency Contact: Jane McLucas, Director of Child Nutrition, DOE, 207-624-6880

Department: Education Title: Internal control over CNC claim reimbursements needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Department will adjust the one-time exception procedure to include the procedure for downward adjustments and tracking of sponsor requested downward adjustments. The Department will adjust the SFSP application/site information sheet approval and update procedures to include instructions on documentation needs. Requests for site information sheet changes will be documented and maintained in CNPweb. CNPweb ticket requests have been submitted to ensure downward adjustments are tracked in CNPweb. CNPweb ticket requests have been submitted to ensure site information sheet changes are date stamped. Completion Date: March 12, 2024 (first and second items), March 1, 2025 (third item) and June 9, 2022 (fourth item) Agency Contact: Adriane Ackroyd, Assistant Director Child Nutrition, DOE, 207-592-1722

Department: Health and Human Services Title: Internal control over automated SNAP eligibility certification periods needs improvement Questioned Costs: Known: $18,090 Likely: Undeterminable Status: Corrective action in progress Corrective Action: The Department has the necessary policies and procedures in place regarding providing households with correct certification period lengths. The Department has previously identified that some household’s six-month reports would be withdrawn incorrectly, at times. Over the course of approximately three years the Department has identified the causes of this error, the final of which is scheduled to be completed June 7, 2024. Completion Date: June 7, 2024 Agency Contact: Ian Yaffe, Director, Office for Family Independence, DHHS, 207- 592-1481

Department: Health and Human Services Title: Internal control over Medicaid and SNAP deceased client cases needs improvement Questioned Costs: Known: $8,329 Likely: Undeterminable Status: Corrective action in progress Corrective Action: The Department will complete a follow up of cases noted in the "condition" section of the finding. Responsible party: MC Program Integrity and ES Special Project teams. The Department will review and update standard operating procedures (SOP) clarifying the Program Integrity team as responsible for working on DOD reports timely with enhanced oversight procedures. Responsible party: Program Manager team Completion Date: June 30, 2024 Agency Contact: Ian Yaffe, Director, Office for Family Independence, DHHS, 207- 592-1481

Department: Health and Human Services Title: Internal control over SNAP eligibility determinations and benefit calculations needs improvement Questioned Costs: Known: $7,491 Likely: Undeterminable Status: Corrective action in progress Corrective Action: The management of OFI will review the operating procedures to identify opportunities for improvement and distribute to all staff involved. Completion Date: June 1, 2024 Agency Contact: Ian Yaffe, Director, Office for Family Independence, DHHS, 207- 592-1481

Department: Health and Human Services Title: Internal control over P-EBT Food Benefits needs improvement Questioned Costs: Known: $4,271 Likely: $4,862,998 Status: Management’s opinion is that corrective action is not required Corrective Action: The Department disagrees with the following Conditions: For 22 students, MDOE was not able to identify the specific student whose continuous absence established those students’ schools’ eligibility date. The P-EBT state plan required at least one student to be absent or remote for at least five consecutive days to establish a school eligibility date and MDOE in fact applied this test and established a school eligibility start date at the time the eligibility files were generated. While the school eligibility start date was captured and preserved in the original files provided to OSA, no student was named. The name of the student was not relevant to other students’ eligibility, and creating or preserving a record of the particular student whose absence conferred eligibility was not a requirement of Maine’s P-EBT plan with FNS, the Department’s MOU with MDOE, or federal P-EBT policy. Further attaching that kind of Personal Identifying Information (PII) to other students’ records would not be appropriate. Additionally, since local educational agencies (LEAs) update the core database throughout the school year and beyond, the results could not be replicated in the course of this audit to retrospectively identify the particular students whose absences conferred eligibility. Neither the omission of the students’ names in the original file nor DOE’s inability to identify such students during the audit establishes that it was improper to issue P-EBT benefits in connection with those students. These students were found eligible based on the best data available to MDOE at the time. Likewise, the Department acknowledges that for four students, MDOE was unable – when requested to do so by the OSA – to locate their economically disadvantaged status in the database updated by LEAs throughout the school year. That does not mean, however, that it was improper to issue P-EBT benefits in connection with those students. These students’ economically disadvantaged status was verified by MDOE and captured in the files at the time of issuance. The Department disagrees that tracking benefit issuance by child identification number is inadequate to monitor benefit issuances and ensure benefits are not duplicated. Child identification numbers are the most reliable way to track and deduplicate issuance. As pointed out in this finding, many households had more than one child. Additionally, some children may have moved from one household to another during the period in question. The Department disagrees with the Context and Likely Questioned Costs: For the reasons detailed above, only three – not 29 – of the students sampled were established to have been issued benefits in error. OSA’s calculations should be adjusted accordingly. The Department disagrees with the Causes: OSA is incorrect to conclude that OFI should have reviewed, reconciled, and verified data provided by MDOE prior to issuance for at least two reasons. First, contrary to OSA’s characterization of the partnership, the Department and MDOE were jointly responsible for administering the P-EBT program, with delegated duties defined in the state plan. That federally approved plan considered MDOE data to be accurate and actionable, and it did not contemplate OFI independently validating such data. Second, the Department is not permitted access to the local educational agency data that would have been necessary for the type of review and reconciliation proposed. The Department disagrees with the Recommendations: The three bulleted recommendations cannot be implemented. The P-EBT program ended December 31, 2023. It will not be possible to take corrective action in the implementation of a program that no longer exists. The State is confident that all issuances in the audit period, including those raised by OSA, were issued correctly based on the best information available at the time by the Departments responsible for implementing the P-EBT program. As such and following FNS guidance that no benefits are to be recouped unless the household applied for them directly, OFI will not revisit prior P-EBT decisions as suggested in OSA’s additional recommendation. Completion Date: N/A Agency Contact: Ian Yaffe, Director, Office for Family Independence, DHHS, 207- 592-1481

Finding 2022-004 – Coronavirus State and Local Fiscal Recovery Funds – Allowable Cost/Cost Principles (Significant Deficiency) Management’s Response or Department’s Response Management agrees with the finding and recommendation. Views of Responsible Officials and Corrective Action The County processed a transfer of revenues to ISD in anticipation of the expenses to be incurred for cybersecurity improvements in FY 2022-2023; however, the fund was not fully spent. The Auditor-Controller’s office will work with the CAO’s office to review and address the inefficiencies in the County’s internal control system. We will review the identified transactions and will work with ISD to reclassify the identified expenditures to the appropriate period. Going forward, the County will ensure that proper documentation, such as receipts, invoices, and proof of payments, are received from departments prior to processing. This implementation will be effective immediately. Anticipated Completion Date March 2024 Contact Information of Responsible Official Name: George Uc Title: Principal Administrative Analyst Phone: 559-600-1231

We agree with the recommendation that expenses should have been reviewed not only in total but should also been reviewed under the two categories of expenses (1) General and Administrative Expenses and (2) Health Care-Related Expenses and the additional subcategories of expenses as defined in HRSA’s Post-Payment Notice of Reporting Requirements for PRF grants to ensure that individual expenses were not double counted. While management will attempt to see if we can refile expenses in the HRSA PRF portal to clearly show that more than enough qualified expenses exist to apply to funding received under both PRF grants and FEMA awards, our understanding is that the PRF portal is closed and restatements cannot be made. Management believes while expense reporting was duplicated for both of these funding sources, because more than enough expenses exist in total to be applied to both sources of funding, this is a reporting matter only and no funds need to be returned under either program. Further, there was numerous and changing guidance from HRSA as to whether expenses needed to be applied to PRF grants prior to applying lost revenue to these grants. Effective with PRF Reporting Period 2, lost revenue was first applied to PRF grants. Fresno did not apply expenses incurred to PRF grants after the date of June 30, 2021, thus this issue does not exist for costs incurred during periods subsequent to June 30, 2021.

Finding # 2023-022 Title of Finding Activities Allowed or Unallowed Contact Person Jody Johnson, Sarah Wills and Christine Miller Anticipated Completion Date FY 2024 Corrective Action planned to be taken: The Board has developed procedures to ensure that all purchase orders are approved before orders are placed, all expenditures are properly authorized by the respective program director and supporting documentation is adequately maintained. The Board is using a requisition form in Droplet to achieve this goal. All employees authorized to make or approve purchases have been trained on purchasing procedures outlined in the Purchasing Policies and Procedures Manual for Local Educational Agencies in the State of West Virginia by the WVDE Office of School Finance on 2/23/2024.

Planned Corrective Action: Meals on Wheels of the Monterey Peninsula (MOWMP) will address the finding by taking the steps outlined below: 1. Expenditure Allocation: Controller and/or bookkeeper will allocate expenditures based on the number of meals prepared each month and the percentage of meals prepared for each program and funding. Yearly reviews of the allocation process will be conducted to ensure accuracy and relevance. Adjustments may be made based on changes in meal demand, program requirements, funding sources, or other factors affecting meal preparation costs. 2. Payroll Reporting: On a yearly basis, Managers and/or Directors will allocate the amount of time each employe works based on tasks performed and the amount of time worked on federal award activities. This allocation will be expressed as a percentage of total work hours performed. Periodic adjustments to time allocations may be necessary to reflect changes in project priorities, staffing levels, or other factors affecting workload distribution. Person Responsible for Corrective Action Plan: Leadership Oversight – Christine Winge, Executive Director Operational Oversight – Kay Smith, Controller Anticipated Date of Completion: MOWMP will complete the Corrective Action Plan by June 1, 2024. We will implement the Corrective Action Plan beginning July 1, 2024.

2023-002 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. 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 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.

Finding 2023-006 Period of Performance Condition: Northern Illinois University (the University) charged an expenditure to the grant whereby a portion of the expenditure had a service period extending beyond the grant's period of performance, and the University’s controls did not detect the error. Corrective Action Plan: University has taken the following corrective actions that will eliminate all material exceptions: 1) The University will provide additional training on cost allocation to staff. 2) University is taking immediate steps to resolve the questioned cost. Individual(s) Responsible for Corrective Action: Sponsored Programs Staff Anticipated Completion Date: June 30, 2024

FINDING 2023-007 Subject: Title I Grants to Local Educational Agencies - Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listing Number: 84.010 Federal Award Numbers and Years (or Other Identifying Numbers): S010A190014, S010A200014, S010A210014, S010A220014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Allowable Costs/Cost Principles Summary of Finding: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Terri Chance Contact Phone Number and Email Address: 219-924-4250 tchance@griffith.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Griffith Public Schools will be developing, implementing, and documenting, a system of internal controls, including policies and procedures that provide segregation of duties to ensure appropriate reviews, approvals and oversight are taking place. Anticipated Completion Date: June 30, 2025

FINDING 2023-003 Subject: Child Nutrition Cluster - Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Special Tests and Provisions - Non-Profit School Food Service Accounts Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, COVID-19 National School Lunch Program; Summer Food Service Program for Children Assistance Listings Numbers: 10.553, 10.555, 10.559 Federal Award Number and Year (or Other Identifying Numbers): FY2021-2022, FY2022-2023 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Special Tests and Provisions - Non-Profit School Food Service Accounts Audit Finding: Material Weakness, Modified Opinion Summary of Finding: Material Weakness, Modified Opinion Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2021- 003. Contact Person Responsible for Corrective Action: Terri Chance Contact Phone Number and Email Address: 219-924-4250 tchance@griffith.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Griffith Public Schools will be developing, implementing, and documenting, a system of internal controls, including policies and procedures that provide segregation of duties to ensure appropriate reviews, approvals and oversight are taking place to ensure compliance. Anticipated Completion Date: June 30, 2025

Department of Health and Human Services 2023-005 Value-Based Medical Student Education Training Program – Assistance Listing No. 93.680 Condition: Indirect cost expense was improperly calculated. Auditors’ Recommendation: We recommend the institution strengthen its internal controls to ensure that calculations are reviewed and adjusted for, if necessary, in a timely manner. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: UMMC’s transition to Workday resulted in the need for multiple F&A bases to be created in Workday to accommodate our DHHS negotiated agreement. However, since our go-live we have only been using one modified total direct cost base to calculate F&A. UMMC is in the process of engaging a Workday Certified consulting firm to review the operational efficiency of Workday for Post-Award Accounting. The scope of this engagement will be to align our usage of Workday to industry best practices, including best practices for F&A calculation. During the scope of this project, we will review these established bases to ensure they meet the needs of our negotiated rate agreement provisions. In the meantime, we are reviewing the F&A calculations on existing projects when an invoice or financial report is prepared to ensure accuracy. F&A will be recalculated with each invoice and/or financial report and any necessary adjustments will be made before the invoice or financial report is submitted to the sponsor. Name(s) of the contact person(s) responsible for corrective action: Julie Schwindt, Director, Post-Award Accounting Planned completion date for corrective action plan: June 30, 2024 If the Department of Health and Human Services has questions regarding this plan, please call Julie Schwindt at 601-984-1058.

Views of Responsible Officials and Planned Corrective Action: ASBO has entered a contract with a new 3rd party administrator to provide oversight for all subgrant awardees. This contact is active now. We developed our contract to ensure improved monitoring for expenditures and verification of receipts. Also, we are in the process of developing a portal which will allow this contractor and ASBO to have full access to all documents from subgrantees. Our new vendor does have prior experience with subgrants management. In addition, ASBO commits internally to the following: • We will monitor all capital purchases when the invoices are received at our office. • We will pull a random sample of five invoices per month and conduct our own review of expenses. Views of Responsible Officials and Planned Corrective Action (Continued): Highlights for the Baker contract: ASBO’s broadband grant program management vendor-partner, Michael Baker International (MBI), is contracted for the following activities and deliverables: • Developing the workflow, process, and online forms that facilitate project monitoring and expense reimbursement. • Responsible for pursuing and documenting additional information required for project monitoring and reimbursement activities. These activities shall be completed within the framework of the Broadband Grants Project Monitoring and Reimbursement System (see below for details) and not through external email or other document exchange system. • Develop and apply standardized naming conventions for all project documents that will be maintained throughout the life of the project. Documents shall be stored in a manner that promotes transparency and facilities ease of use by auditors. • Take all reasonable measures to ensure grant activities are implemented in a manner that ensures transparency, accountability, and oversight sufficient to (1) minimize the opportunity for waste, fraud, and abuse; (2) ensure that subrecipients use funds to further the objectives of Federal programs and the Arkansas State Broadband Office; and (3) allow the public to understand and monitor subgrants awarded under the program. • Ensuring all reimbursement activity complies with Federal requirements, including Section 60102 of the Infrastructure Act, 2 C.F.R. Part 200 and any supplemental guidance issued by the Federal government. • Responsible for knowing what constitutes eligible and ineligible expenses under both state and Federal rules. • Provide education and guidance to subrecipients and the ASBO on key oversight and compliance requirements. • Ensure payment activities follow all state and Federal policies and procedures. Contractor acknowledges policies may change over the life of the contract. • Identify policies the ASBO is required to adopt and assist in drafting those policies to ensure ASBO compliance with Federal regulations. • Assist the Arkansas State Broadband Office in enforcing program rules and laws and imposing penalties for nonperformance, failure to meet statutory obligations, or wasteful, fraudulent, or abusive expenditure of funds. Such penalties include, but are not limited to, imposition of additional award conditions, payment suspension, award suspension, grant termination, de-obligation/clawback of funds, and debarment of organizations and/or personnel. Views of Responsible Officials and Planned Corrective Action (Continued): • Conduct audits of subrecipients as are necessary and appropriate. Contractor shall report the results of any audits it conducts to the Arkansas State Broadband Office. • Develop a template contract for subrecipients, specifying key terms including contract length, performance standards, construction and service rollout schedules, competitive access requirements, regulatory compliance requirements, environmental controls, grant reporting and data sharing requirements, monitoring and oversight procedures, and penalties for non-compliance. • Retain and provide to the Arkansas State Broadband Office upon request all records, documents, and communications of any kind that relates in any manner to grant awards and project procurement, performance, and reimbursement. This data shall be labeled and stored in a manner that promotes transparency and facilitates ease of use by auditors. Additionally, MBI is building two new systems for ASBO and subgrantee use: 1. Broadband Grants Project Monitoring and Reimbursement System 2. Grant Application Submission, Evaluation, Award, and Appeal System These systems will have the following features: • Facilitate inputs, responses, data gathering, analysis, and adjudication decision recommendations and subsequent documentation of payment decisions for the Arkansas State Broadband Office’s final approval. • Provide a secure mechanism for grant applications and safeguard protected, proprietary, and other confidential information. • Assign a unique identifier to each application and each project. Contractor shall develop and apply a standardized naming convention to all applications and associated documents that will be maintained throughout award, technical review, project monitoring, and project closing. Documents shall be named and stored in a manner that facilitates ease of use by auditors. • System shall exhibit built-in quality controls, such as pre-screening, that assist applicants in submitting applications that meet all minimal requirements for consideration (such as requiring a SAM number). • MBI shall be responsible for pursuing and documenting additional information required for clarification of submitted applications, technical reviews of applications, and project monitoring Views of Responsible Officials and Planned Corrective Action (Continued): • and reimbursement activities. These activities shall be completed within the framework of the Grant Application Submission, Evaluation, Award, and Appeal System or the Broadband Grants Project Monitoring and Reimbursement System and not through external email or other document exchange systems. Anticipated Completion Date: System anticipated go live Date: April 26, 2024 Contact Person: Name: Glen Howie Title: Director Agency: Department of Commerce, Arkansas State Broadband Office Address: 1 Commerce Way, Suite 601 City, State, Zip: Little Rock, AR 72202 Phone Number: 501-682-1123 Email Address: Glen.howie@arkansasEDC.com

Contacts: Alex Antkowiak, David Kilpatrick, and Katherine Robinson Titles: VP Accounting and Senior Director, Education Programs & Productions, and Payroll Manager, respectively Anticipated Completion Date: September 2024 Corrective Action: The Center is committed to ensuring the appropriate documentation is in place to adhere to federal regulations regarding activities allowed or unallowed and allowable costs. In response to the audit finding, the Center is taking the following corrective actions to address the audit recommendations: • Accounting will convene meetings with Production and Operations Managers to communicate the Fiscal Year 2023 Federal Award Findings, study and strengthen internal controls in place, review the general criteria within 2 CFR Section 200.403 for manager awareness, and reinforce the importance of accuracy and timeliness of pay rates. • Production and Operations Managers will enact recommendations from Accounting Personnel to strengthen internal controls, proactively communicate with Unions throughout the year and prior to year-end to stay informed of any changes to rates established in Collective Bargaining Agreements and apply changes in pay rates prospectively from date of notice and retrospectively when required. • The Payroll Department, in collaboration with Accounting, will establish a schedule to sample support from managers for compliance with transparency initiatives. Status as of February 2024: The Theater for Young Audience Touring Production and Operations Manager in charge of payroll processing has updated processes to create an audit trail for pay rate calculation, update payroll submission form to include a PDF copy of the audit trail for Payroll Department’s inspection.

FINDING 2023-004 Finding Subject: Special Education Cluster (IDEA) - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Summary of Findings: The School Corporation was a member of the Clark County Joint Services Program (Cooperative) during fiscal year 2021-2022. The Cooperative did not have internal controls in place over payroll transactions to ensure expenditures were allowable and in conformance with the cost principles. The Treasurer reviewed a report which showed the total amount paid from each fund and account; however, a detailed payroll report was not reviewed which would have identified the employee being paid from the grant fund. For vendor disbursements, although the Deputy Treasurer matched the invoice to the purchase order and provided it to the Corporation Treasurer for review and signature of the accounts payable voucher prior to payment, the control was not effective and did not detect or allow correction of errors. In the initial sample of 6 vendor disbursements, one claim was unable to be provided. Contact Person Responsible for Corrective Action: Ashley Compton, Director of Special Education, Tamara Swarens, Director of Elementary Curriculum and Allison Vanover, Corporation Treasurer Contact Phone Number and Email Address: 812-246-3375 alcompton@scsc.school tswarens@scsc.school avanover@scsc.school Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Silver Creek School Corporation does not operate under the Special Education Coop any longer. The AP Specialist makes sure that there is an appropriate claim for each payment we make, there are two signatures on each claim and the claims are approved by the Treasurer. Check processing is completed by the Deputy Treasurer as the third check. The AP Specialist now scans each invoice to the FMS accounting system to ensure that we have all back up for the claims. With the new Directors of Curriculum and Special Education, we only reimburse for positions that are charged to the federal grant that have gone through a multi-step process to ensure that they get coded to the right place. The process is also reviewed at the time a request for reimbursement is made. Anticipated Completion Date: March 2024

FINDING 2023-003 Finding Subject:􀀃Special Education Cluster (IDEA) - Earmarking Summary of Finding: The School Corporation was a member of the Clark County Joint Services Program (Cooperative) during fiscal year 2021-2022. The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the earmarking requirements. The Non-Public Proportionate Share expenditures for all grant awards were not expended as required by IDOE for the individual member schools. The Cooperative categorized each expenditure by location and the total amount did not meet or exceed the required proportionate share as outlined on the award letter. The Cooperative was required to spend a total of $59,633 for 20611-158-PN01 and $35,470 for 20619-158- PN01. $32,798 was identified as being spent for 20611-158-PN01, which was less than the required proportionate share. The Cooperative was unable to provide documentation to identify the expenditures spent for 20619-158-PN01. Contact Person Responsible for Corrective Action: Ashley Compton, Director of Special Education and Allison Vanover, Corporation Treasurer Contact Phone Number and Email Address: 812-246-3375 alcompton@scsc.school avanover@scsc.school Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Silver Creek School Corporation does not operate under the Special Education Coop any longer. The Special Education Director has a beginning of the year consultation with the private school principal to discuss and finalize the proportionate share budget. The Corporation Treasurer and Special Education Director will review and co-complete the semi-annual prop share workbook to ensure that private school funding is expended in a timely manner. Anticipated Completion Date: March 2024

􀀃 Finding􀀃2023􀍲004􀀃 􀀃 Finding􀀃Subject:􀀃Child􀀃Nutrition􀀃Cluster􀀃–􀀃Allowable􀀃Activities,􀀃Allowable􀀃Cost/Cost􀀃 Principles􀀃 Summary􀀃of􀀃Finding:􀀃Internal􀀃Controls􀀃were􀀃not􀀃effective􀀃and􀀃did􀀃not􀀃prevent􀀃unallowable􀀃 activities/cost􀀃 Contact􀀃Person􀀃Responsible􀀃for􀀃Corrective􀀃Action:􀀃Director􀀃of􀀃Food􀀃Service􀀃 Contact􀀃Phone􀀃Number􀀃and􀀃Email􀀃Address:􀀃(260)431􀍲2030,􀀃msnyder@sacs.k12.in.us􀀃 􀀃 Views􀀃of􀀃Responsible􀀃Official:􀀃We􀀃concur􀀃with􀀃the􀀃finding.􀀃 Description􀀃of􀀃Corrective􀀃Action􀀃Plan:􀀃 All􀀃claims􀀃shall􀀃be􀀃created􀀃by􀀃the􀀃Assistant􀀃Food􀀃Service􀀃Director􀀃and􀀃reviewed􀀃for􀀃 compliance􀀃within􀀃the􀀃allowable􀀃cost􀀃category􀀃prior􀀃to􀀃payment􀀃by􀀃the􀀃Director􀀃of􀀃Food􀀃 Service.􀀃In􀀃the􀀃event􀀃that􀀃the􀀃Director􀀃of􀀃Food􀀃Service􀀃must􀀃initiate􀀃a􀀃claim􀀃first,􀀃the􀀃 Assistant􀀃Food􀀃Service􀀃Director􀀃would􀀃then􀀃review􀀃the􀀃claim􀀃prior􀀃to􀀃issuance.􀀃All􀀃claims􀀃are􀀃 returned􀀃to􀀃the􀀃Assistant􀀃Food􀀃Service􀀃Director􀀃for􀀃review􀀃of􀀃accuracy􀀃after􀀃the􀀃payment􀀃 method􀀃has􀀃been􀀃authorized􀀃to􀀃ensure􀀃accuracy􀀃and􀀃compliance.􀀃Both􀀃parties􀀃will􀀃initial􀀃 documents􀀃appropriately,􀀃as􀀃well􀀃as􀀃maintain􀀃all􀀃copies􀀃of􀀃proof􀀃of􀀃purchase/service􀀃with􀀃 original􀀃claim􀀃form􀀃documents.􀀃􀀃 Anticipated􀀃Completion􀀃Date:􀀃3/18/24􀀃

The Department has instituted additional internal controls to ensure that expenditures are liquidated within 90 days of the end of the period of performance as required. This includes a monthly reconciliation of all federal sources performed by the Grants Manager and reviewed by the respective Budget Manager and Finance Director to address any identified issues before the liquidation date. As a redundancy measure, the Budget Manager reviews AP contract activity associated with federal fund sources via the Provider Utilization Report to monitor the liquidation rate in correlation with the liquidation date to ensure all expenditures are captured within the period of performance. Post-liquidation date journal activity is mainly aligned with transactional code cleanup, not necessarily new expense posting outside the period of performance. As such, it doesn’t include or constitute changes to previously submitted federal reporting. To mitigate transactional errors, the Budget Manager, in coordination with the Grants Manager, thoroughly reviews the coding of procurement requests that utilize federal funds for the appropriateness of use and accuracy. This includes deactivating federal fund sources in the statewide accounting system to prevent transactions posting outside of the period of performance. These additional internal controls related to the period of performance were implemented in July 2023. The Office of Internal Audit will perform a review of the updated processes to ensure they are effective in correcting the above findings no later than March 31, 2024.

The Department has instituted additional internal controls to ensure that expenditures are liquidated within 90 days of the end of the period of performance as required. This includes a monthly reconciliation of all federal sources performed by the Grants Manager and reviewed by the respective Budget Manager and Finance Director to address any identified issues before the liquidation date. As a redundancy measure, the Budget Manager reviews AP contract activity associated with federal fund sources via the Provider Utilization Report to monitor the liquidation rate in correlation with the liquidation date to ensure all expenditures are captured within the period of performance. Post-liquidation date journal activity is mainly aligned with transactional code cleanup, not necessarily new expense posting outside the period of performance. As such, it doesn’t include or constitute changes to previously submitted federal reporting. To mitigate transactional errors, the Budget Manager, in coordination with the Grants Manager, thoroughly reviews the coding of procurement requests that utilize federal funds for the appropriateness of use and accuracy. This includes deactivating federal fund sources in the statewide accounting system to prevent transactions posting outside of the period of performance. These additional internal controls related to the period of performance were implemented in July 2023. The Office of Internal Audit will perform a review of the updated processes to ensure they are effective in correcting the above findings no later than March 31, 2024.

We concur with this finding. Although the Wagner-Peyser Program transitioned to TCSG in December of 2022, related activities also continued at GDOL. Staff at the career centers continued to serve Georgia taxpayers in need of employment services rather than turning them away. As a result, staff continued to charge the Wagner-Peyser grant, and there were Wagner Peyser grant funds still remaining at GDOL. Journal vouchers were entered to allocate indirect costs to the Wagner-Peyser grant pursuant to GDOL's federally approved cost allocation plan. Journal vouchers were also used to correct other expenditures that should have been charged directly to Wagner Peyser. GDOL will ensure that all journal vouchers are properly supported by documentation, either attached directly to the journal voucher or the journal voucher will reference the supporting documentation which can be retrieved either electronically or manually.

Finding Number: 2023-001 – Period of Performance Planned Corrective Action: The item in question was a deposit for an event that took place in August 2023. It was made in June 2023. While the $24k payment was a valid payment within the grant terms, it was inadvertently recorded as an expense item in our 2023 schedule of expenditures of federal awards instead of as a prepaid asset. Upon discovery we implemented new procedures whereby payments made at year end will be subjected to an additional review to ensure they are recorded in the proper period. Person Responsible: Stephen Mack, Chief Financial Officer Expected Completion Date: Immediately