Corrective Action Plans

FEDERAL AWARD FINDINGS 2022-002 - ALLOWABILITY Recommendation: We recommend that the Council implement controls to ensure that expenditures are properly reviewed and approved before being charged to a federal award and that adequate supporting documentation is maintained. Action Taken: In February 2023, the current Fiscal Officer received formal training from the National Endowment for the Humanities' grants management staff on allowable costs and proper documentation procedures for federal grants and grant-making entities, under 2 CFR 200. The Fiscal Officer and all staff involved with federal grants subsequently reviewed the Council's internal procedures, to ensure that all expenditure paperwork is received, approved, and filed with the grant documentation.

FINDING 2022-003 Subject: Special Education Cluster - Earmarking Audit Finding: Significant Deficiency Condition: The School Corporation is a member of the Northeast Indiana Special Education Cooperative (Cooperative). The School Corporation did not have adequate internal controls in place to ensure that the Cooperative complied with the earmarking requirements. Context: The School Corporation is a member of the Northeast Indiana Special Education Cooperative (Cooperative). During fiscal year 2021-2022, the Cooperative operated the special education programs and spent the federal money on behalf of all its members. As the grant agreements were between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. However, there was inadequate oversight performed by the School Corporation in order to ensure compliance with the Matching, Level of Effort, Earmarking compliance requirement. The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the earmarking requirements. The Cooperative did not have adequate procedures in place to ensure that the required level of expenditures for non-public students with disabilities was met for each member school. The Cooperative did not have effective internal controls to ensure non-public school expenditures were appropriately identified and reported. The Non-Public Proportionate Share expenditures for 19611-042-PN01 and 20611-042-PN01 grant awards could not be verified for the individual schools to verify the minimum amount per the grant awards was expended and properly reported to IDOE as required. The School Corporation?s minimum earmarking requirements for the 19611-042-PN01 and 20611-042-PN01 grant awards were $1,095 and $1,791, respectively. The lack of internal controls and noncompliance were isolated to the 19611-042-PN01 and 20611-042-PN01 grant awards. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Hamilton Community Schools will work with the Northeast Indiana Special Education Cooperative to ensure proper oversight and internal controls are maintained of awarded monies. Responsible Party and Timeline for Completion: Brittany Taylor, Business Manager Completion Date: 6/30/2023

Finding 2022-005 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services Assistance Listing: Various ? Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Summary of finding: Management does not track expenses by budget period for Corewell East federal Research and Development (R&D) grants and is therefore unable to support that expenses are recorded in the appropriate period of performance. Corrective action plan: The hierarchy and functionality of the prior Corporate financial management system (prior to July 1, 2023) did not support separate budget periods during a single award project period. This was managed manually by the CHE Sponsored Programs Administration via a customized internal report. Effective July 1, 2023, the institution transitioned Corewell Health East onto Workday, the common financial management system already used by Corewell Health West. The Workday financial management system includes a separate grant module that has the capability to establish defined budget periods under a single award. CHE successfully transitioned to Workday beginning July 1, 2023. With the functionality now enabled by Workday, we do not anticipate any barriers to maintaining defined budget periods within an award funding cycle to assure that expenses are recorded in the appropriate period of performance. Individuals responsible for corrective action: Giacomo DeChellis, Sr. Director, Research Operations, Corewell Health East Timing of corrective action: July 1, 2023 and going forward.

FINDING 2022-002 Finding Subject: Child Support Enforcement - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Summary of Finding: An effective internal control system was not in place at the County to ensure compliance with the requirements related to the grant agreement and the Activities Allowed or Unallowed and Allowable Costs/Cost Principles compliance requirements. The payment of the Deputy Court Clerk?s wages and benefits out of the Clerk?s Incentive Fund supplanted not supplemented the employee?s salary which is unallowable. Contractual payment did not match the amount stated in the contract. The County did not have an allowable cost policy. 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 concur with the finding. Description of Corrective Action Plan: Internal control procedures will be evaluated to determine needed changes to correct the above noted compliance requirements over Child Support. Changes will be made to the 2024 budget to correct the payroll related issue so the Clerk?s Incentive Fund. Contracts will be reviewed to ensure the contract amounts are current. The County will develop an allowable cost policy. Anticipated Completion Date: January 1, 2024

#2022-002: Material Weakness in Controls over Compliance: Administrative Requirements of Uniform Guidance -Administrative Policies Recommendations: Grand Rapids Christian Schools should consider the following written policy additions or updates: ? Financial Management (2 CFR 200.302) The financial management policy should include records documenting compliance, and the tracking of funds to determine that expenditures are in accordance with the terms and conditions of the federal awards. The financial management and reporting system must provide the following : ? Identification - Title of the award, CFDA number ? Complete disclosure of accurate and current financial results of each federal award ? Source and application of funds for federal award activity ? Record retention and access - define the time period for which records must be kept (can vary by grant agreement), and who has the ability access the records (?200.333 - ?200.337) ? Written procedure to implement cash management requirements (see below) ? Written procedures for determining the allowability of costs (see below) ? Cash Management (2 CFR 200.305) A written policy is required by Uniform Guidance detailing the Organization's procedures to minimize the time that elapses between draw and expenditure of federal dollars. ? Allowable Costs (2 CFR 200.302(b)(7)) The Organization must have written procedures for determining the allowability of costs in accordance with Subpart E - Cost Principles of Uniform Guidance and the terms and conditions of the Federal award. This includes the determination of allowable costs and the review of this determination. The standard assumes policies and procedures are in place for disbursements, and the allowable cost policy will demonstrate how the Organization ensures compliance. The criteria for costs to be considered allowable are documented within 2 CFR 200.403. ? Procurement Standards (2 CFR 200.317 - 200.326) The Organization must have a written policy that promotes full and open vendor competition, conflict of interest policies should cover employees as well as the organization, and general purchase requirements with specific thresholds as set forth by the Uniform Guidance. There are five allowable procurement methods as described in ?200.320, depending upon the dollar value of the purchase or contract. Views of Responsible Officials and Planned Corrective Actions: ? Grand Rapids Christian Schools follows procurement and record retention standards provided by the USDA. ? GRCS does not have actual written policies and procedures for Financial Management, Cash Management, Allowable Costs, and Procurement Standards, but do have practices in place to follow USDA guidelines. In the case of cash management, the only location that takes cash is GRCHS. In that instance, along with Meal Magic, cash registers are zeroed out and balanced to Meal Magic and cash deposits are made daily. ? GRCS Business Office will work with the Food Service Director to begin formulating written policies and procedures specific to Grand Rapids Christian Schools. GRCS will utilize the resources from Uniform Guidance and Code of Federal Regulations (CFR) to develop policies that are compliant with those requirements prior to June 30, 2023.

Finding: The Department of Children, Youth, and Families did not have adequate internal controls over and did not comply with requirements to ensure payments to child care providers paid with Temporary Assistance for Needy Families funds were allowable and properly supported. Questioned Costs: Assistance Listing # 93.558 Amount $67,699,429 Status: Corrective action in progress Corrective Action: The Working Connections Child Care (WCCC) program was previously managed by the Department of Social and Health Services (DSHS) and the Department of Early Learning. Since the program transitioned in 2019, the Department has been making efforts to strengthen internal controls over payments to child care providers and other grant requirements. The Department implemented grant-level management of all federal funds, including the Temporary Assistance for Needy Families (TANF) grant. The Department allocated the TANF grant to eligible clients and allowable activities in compliance with 45 CFR 98.67. For the fiscal year 2021 program audit, the State Auditor?s Office (SAO) issued a finding with $32 questioned costs for non-compliance with the CCDF eligibility requirement. No other findings, management letters, or exit items were reported in this compliance area or the cost allocation of funds based on eligibility for the CCDF or TANF grants. Given that eligibility or cost allocation has not been an area of concern, and transfers were processed between TANF and CCDF source of funds with the same eligibility criteria, the Department is assured that TANF funding was spent appropriately within federal regulations. The Department is committed to improving internal controls. The Department does not currently have the resources to develop and maintain the business process redesign, as well as the information technology initiatives necessary to meet the level of assurance recommended by SAO. In response to prior year?s audit recommendations, the Department has submitted a budget request to the Legislature in the 2023-2025 biennial budget for additional resources to process adjustments to include transaction-level data. As part of the audit resolution process, the Department of Health and Human Services (HHS), which oversees the CCDF program at the federal level, reviews all SAO findings and issues management decision letters. The letters will reflect the grantor?s determination of whether an audit finding is sustained, the reasons for the decision, and the required actions by the auditee. When a management decision is issued for the fiscal year 2021 finding, the Department will work with HHS and follow the audit resolution process. Completion Date: Agency Contact: The conditions noted in this finding were previously reported in finding 2021-028. Estimated December 2024 Stefanie Niemela Audit Liaison PO Box 40970 Olympia, WA 98504-0970 (360) 725-4402 stefanie.niemela@dcyf.wa.gov

Finding Number: 2022-001 Program Names/Assistance Listing Titles: Assistance Listing Numbers: Indian School Equalization 15.042 Education Stabilization Fund 84.425 Contact Person: Vada Begay, Business Manager, Sylvia Largo, Homeliving Department Supervisor, and School Board Members Anticipated Completion Date: March 31, 2023 Planned Corrective Action: All financial activities were processed per 2 CFR 200.403 to ensure they were allowable, necessary, and reasonable. WRHI as a Tribally Controlled Organization did expend funds under a self-determination contract in support of a residential program servicing students during the COVID-19 pandemic. Management did communicate with the Board to ensure that the proper expenditure of allocated funds for the board was paid out of the Administrative cost grant.

The Office of Vice President of Research and the Controller?s Office worked with the University?s Workday Finance team to configure its accounting system with an automated control that prevents general (nonpayroll) expenditures from being charged to the grant after the period of performance end date, one root cause of cost transfers. In addition, for payroll expenditures, the above teams updated grant labor costing allocations in its accounting system to contain an end date that coincides with the period of performance end date which restricts labor costs from being charged after the period of performance. The post award specialists will begin reviewing the labor costing allocations on a periodic basis. Also implemented in fiscal year 2023, before each payroll is processed by the Director of Payroll within the accounting system, grants that have ended are identified by the Assistant Controller and Director of Sponsored Program Accounting and the payroll expenditures are removed from the feed and not charged to the grant. The University has also hired individuals whose sole responsibility is to review general (non-payroll) expenditures charged to grants. Further, the University?s post award specialists are continually trained on the importance of allowed and unallowed expenditures and are now reviewing grant level budget versus actual reporting on a periodic basis to identify noncompliance. Tara Thomason, Controller and Assistance Vice President, is responsible for addressing the above items by December 2023.

The Authority will limit funding the COCC from the Public Housing Program, to allowable Fees only. The Authority?s Executive Director, Trey George, has assumed the responsibility of executing this corrective action as of November 1, 2023.

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 - 84.4250 - Elementary and Secondary School Emergency Relief Fund COVID-19 - 84.425U - American Rescue Plan Elementary And Secondary School Emergency Relief Fund Federal Award Number: S425D210012 (Year: 2021) S45U210012 (Year: 2021) Questioned Costs: $116,610 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: We concur with the auditor?s reasoning that the contract terms for services should have been modified to reflect the one-time retention payments for contracted custodial personnel. Retention of contracted custodial staff members was deemed by the District to be an essential part of its effort to ensure clean, sanitary facilities in response to COVID-19 pandemic. ? The District has several internal controls in place to determine and verify the allowability of ESSER expenditures, which include: ? Authorization by the Hall County Board of Education. ? Authorization by the Georgia Department of Education through the ESSER program?s consolidated application. ? Approval of all ESSER payments and purchase orders by relevant personnel familiar with the allowability requirements of the ESSER program. ? Approval of all ESSER contract agreements by relevant personnel familiar with the allowability requirement of the ESER program. ? Documented protocols for determining District personnel eligible to be paid through ESSER funds. The District will conduct a review of its contract with third party service providers to ensure compliance with Uniform Grant Guidance. The District currently has no further plans for the provision of additional retention payments to contracted personnel using ESSER funds, and no additional corrective action is anticipated to be required for the isolated instance. Estimated Completion Date: March 31, 2023 Contact Person: Jonathan C. Boykin Telephone: 770-534-1080 Email: jonathan.boykin@hallco.org

U.S. Department of Education 2022-004 Special Education Cluster ? Assistance Listing No. 84.027 and 84.173 Recommendation: The Board should review and enhance internal controls and procedures to ensure that it charges expenditures to the program that are incurred within an award?s allowable period of performance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Office of Fiscal Services will improve internal controls over the procedures that ensure expenditures to a program are incurred within an award?s allowable period of performance. During the year-end close out process, the Lead Restricted Funds Accountant will review the close out of all restricted funds against the grant periods. If expenditures are inadvertently incurred outside of the grant period, the expenditures will be reclassified to an existing like grant if allowable or to the operating budget. If the Lead Restricted Funds Accountant is unavailable or has closed out grants themselves, this review will be done by the Budget Manager. The school district will implement a new financial system in July 2023. The implementation of this new system will allow for more automated internal controls. Name(s) of the contact person(s) responsible for corrective action: Rosa Aquino and/or Sherri Fisher-Davis Planned completion date for corrective action plan: December 31, 2022

Views of Responsible Officials and Planned Corrective Action: Aging expense reported did receive proper approval, however there no approval on actual invoices. Aging Services Director will make sure all invoices have approval by signature and receipt of goods, when signing checks and approval for purchases of any items to be purchased. Director of Aging Services to follow this protocol: 1. Give approval for the purchase of any items to staff to purchase items. 2. Make sure when either an invoice comes in the mail or is put with a check for signature that Director makes sure that she signs both the check and invoice. As a back-up, the accountant will check all invoices for the Director?s signature before completing any Aging Services check.

FA2O22-001 Improve/Strengthen Controls over 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 - 84.4250 - Elementary and Secondary School Emergency Relief Fund COVID-19 - 84.425U - American Rescue Plan Elementary And Secondary School Emergency Relief Fund Federal Award Number: 5425D2000L2 (Year: 2020), 5425U2L0072 (Year: 202L) Questioned Costs: $61,000.00 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: We concur with this finding. The process used to pay retention pay to staff has been reviewed and will only be a paid to staff employed by the Atkinson County Board of Education. Estimated Completion Date: 3/13/2023 Contact Person: Lessie Youngblood Telephone: 912- 422-7878 Email: lyoungblood@atkinson.k12. ga.us

Corrective Action: Management will review all cost allocations and implement documented policies and procedures to ensure sufficient support of any allocations of costs is maintained as required by 2 CFR §200.403. In addition, Management has developed a cost allocation worksheet and framework and is in the process of implementing a new procedure to ensure it is reviewed by accounting and grant managers to ensure accurate reporting. Name of Responsible Individual(s): Jason Brenier, CFO Anticipated Completion Date: March 2024

Corrective Action: Management will review all cost allocations and implement documented policies and procedures to ensure sufficient support of any allocations of costs is maintained as required by 2 CFR §200.403. In addition, Management has developed a cost allocation worksheet and framework and is in the process of implementing a new procedure to ensure it is reviewed by accounting and grant managers to ensure accurate reporting. Name of Responsible Individual(s): Jason Brenier, CFO Anticipated Completion Date: March 2024

FA 2022-002 Strengthen Controls over Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principle 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 Federal Awars Numbers: S425D210012 (Year: 2021), S425U2120012 (Year: 2021) Questioner Costs: $193,631 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: Although the School District does not agree with this finding, management will continue to ensure federal fund program guidelines and Board-approved policies and procedures are followed. Estimated Completion Date: Ongoing Contact Person: Kyla M. Milton, Finance Director Telephone: 229-868-5661 Email: kmilton@telfairschools.org

Following the Auditor's recommendations and as a corrective action, the staff or department in charge locate and document all required reports that were filed according to the requirements of the grant agreement, including the reconciliation thereof with the official Municipality’s accounting subsidiaries. In addition, the Municipality will design, document, establish and provide the necessary and required training, including guidelines and procedures, to all personnel who work directly or indirectly with the management of these federal funds.

Following the Auditor's recommendations and as a corrective action, the staff or department in charge locate and document all required reports that were filed according to the requirements of the grant agreement, including the reconciliation thereof with the official Municipality’s accounting subsidiaries. In addition, the Municipality will design, document, establish and provide the necessary and required training, including guidelines and procedures, to all personnel who work directly or indirectly with the management of these federal funds.

Following the Auditor's recommendations and as a corrective action, the staff or department in charge locate and document all required reports that were filed according to the requirements of the grant agreement, including the reconciliation thereof with the official Municipality’s accounting subsidiaries. In addition, the Municipality will design, document, establish and provide the necessary and required training, including guidelines and procedures, to all personnel who work directly or indirectly with the management of these federal funds.

Following the Auditor’s recommendations and as a corrective action, the staff or department in charge locate and document all required reports that were filed according to the requirements of the grant agreement, including the reconciliation thereof with the official Municipality’s accounting subsidiaries. In addition, the Municipality will design, document, establish and provide the necessary and required training, including guidelines and procedures, to all personnel who work directly or indirectly with the management of these federal funds.

Finding No. 2022-007 -Activities Allowed or Unallowed, Eligible Uses - FEMA Condition During the closeout procedures, the Cenh·al Office of Recovery, Reconstruction and Resiliency (COR3) office performed a 100% validation on Rental Equipment, supporting documents including conh"act smmnary record, invoices, and proofs of payment. As a result of the validation, the total validated amount is $979,259 from an original amount of $1,260,775 submitted by the Corporation for reimbursement. Corporation response The Corporation agrees with the finding. Corrective Action Plan Upon receiving the audit findings, we initiated an immediate review of our FEMA-funded projects and expenditures. We are implementing immediate corrective actions to address the identified deficiencies and ensure strict compliance with FEMA guidelines regarding eligible uses. • Policies and Procedures Review - Simultaneously, the Corporation is reviewing our existing policies and procedures related to FEMA funds, with a specific focus on eligible activities. Any necessary revisions will be made to strengthen our policies and ensure rigorous adherence to FEMA guidelines and regulations. • Enhance Internal Controls - We are enhancing our internal controls related to FEMA fund utilization. This includes implementing additional checks and balances to improve the accuracy and reliability of our project management processes, ensuring they align with FEMA guidelines. ■ Communication Protocols Enhancements - We understand the importance of transparent communication regarding the use of FEMA funds. To address this, we are enhancing our communication protocols to ensure that all relevant stakeholders are informed of FEMA guidelines, project eligibility requirements, and any changes to procedures. • Return of Funds - Initiate the communication process with the Central Office of Recovery, Reconstruction, and Resiliency to obtain instructions for returning the funds to FEMA. Follow FEMA's specific guidelines on the return of funds, including the appropriate documentation, timelines, and c01mnunication procedures. ■ Finance Team - The Corporation has made changes to its management staff structure in the finance and budget department, with the mission of improving the monitoring process and compliance with federal and local regulations and the support of independent consultants. A new Finance and Budget Director and the Associate Director of Finance and Budget have been appointed. Names of the contact persons responsible for corrective action plan Jesus A. Rodrfguez Aviles - Financial Planning and Analysis Associate Director Cecilia Robles Kakiuchi - Financial Planning and Analysis Director Anticipated Completion Date Fiscal Year 2024

Criteria: In accordance with 2 CFR 200.403(g), costs must be adequately documented in order to be allowable under Federal awards. Condition: The School was unable to provide documentation for three (3) out of sixty (60) non-payroll expenses. Cause: The School failed to follow its own policies for documentation of expenses and document retention. Effect: The costs were not allowable under the Federal award because they were not adequately documented. Questioned costs: $2,412 Context: Three (3) out of sixty (60) non-payroll expenditures tested did not have original invoice or payment support. Recommendation: We recommend the School implement a document retention system whereby invoices and payment support are retained for the appropriate time period. Action Plan: The school has maintained receipts for these non-payroll expenditures but were not found within the audit timeline. Better organization of receipts will be implemented. The School will scan receipts and electronically store documents including invoices and payments together. The School will consider multiple platforms including server or a cloud document storage platform. Receipts will be maintained and reported in the appropriate period. Persons Responsible: Yvonne Bullock, CEO/Head of School Gulen Hicks, Consultant Administrative Assistant Consultant

FA 2022-001 Strengthen Budgetary Controls over Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principle 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 Federal Award Number: S425D200012 (Year: 2020), S425D210012 (Year: 2021) S425U2120012 (Year: 2021) Questioned Costs: $31,131 Prior Year Finding: N/A Description: A review of expenditures charged to the Elementary and Secondary School Emergency Relief Fund program revealed instances in which expenditures had not be properly approved by the pass-through entity. Corrective Action Plans: The Calhoun County School System will ensure that all expenditures charged to the Elementary and Secondary School Emergency Relief Fund are properly approved by the pass-through entity. The Federal Programs Director will verify that all expenditures are reflected in the approved budget or subsequent amendments within the Consolidated Application as required. The Calhoun County School System will follow the procedures listed below to ensure that expenditures are reflected in the approved budget and/or subsequent amendments: The Federal Programs Director and the Finance Director will monitor all original budgets and subsequent amendments to ensure that expenditures have been approved. During monthly leadership meetings, the Federal Programs Director and the Finance Director will verify that all budgets and subsequent amendments have been properly signed off on by the Program Coordinator and the Superintendent in the Consolidated Application. In the event budgets and subsequent amendments are not found to be properly signed off on by the Program Coordinator and the Superintendent, the Federal Programs Director will take steps to ensure that proper sign off is initiated and completed. Estimated Completion Date: September 30, 2024 Contact Person: Pamela Quimbley Telephone: 229-545-7231 ext. 2005 Email: pamquimbley@calhoun.k12.ga.us

Prior to the completion of this audit, EmployIndy already made a number of changes to its financial operations. It parted ways with its Chief Financial Officer and procured the services of an outside Certified Public Accounting firm to begin the process of reviewing and updating its financial operations. In addition, it recently hired an Executive Vice President of Finance and Operations to lead the final development and implementation of updated financial processes. The Executive Vice President of Finance and Operations has worked with EmployIndy’s Board of Directors and Finance Committee to document a plan for improving EmployIndy’s financial operations across the board by the 2nd quarter of Calendar Year 2024. EmployIndy currently provides training to all staff on properly documenting work hours within the time management and payroll system. There is an existing process for correcting and documenting any changes within the time management and payroll system after time has been submitted. In scenarios where it is necessary and allowable to shift EmployIndy staff time charged from one funding stream/cluster to another, Financial Operations staff, under the direction of the Controller, will make updates, including supporting documentation, in both the time management/payroll and financial management systems. Reconciliations between the payroll system and the financial management system will be completed monthly in order to ensure that the information in each system matches and that there is documentation showing that the expenses are allowable and supported. Finally, the Director of Human Resources will ensure that offer letters with pay rates and any subsequent salary adjustments will be documented with approval signatures and retained in personnel files, with proper amounts being updated within the time reporting/payroll system.

Prior to the completion of this audit, EmployIndy already made a number of changes to its financial operations. It parted ways with its Chief Financial Officer and procured the services of an outside Certified Public Accounting firm to begin the process of reviewing and updating its financial operations. In addition, it recently hired an Executive Vice President of Finance and Operations to lead the final development and implementation of updated financial processes. The Executive Vice President of Finance and Operations has worked with EmployIndy’s Board of Directors and Finance Committee to document a plan for improving EmployIndy’s financial operations across the board by the 2nd quarter of Calendar Year 2024. As a part of this plan, EmployIndy’s Financial Operations Team, led by the Controller, has already begun to update the expenditure approval process. This process requires that supporting documentation be retained within the financial management system. Additionally, the review and approval process consists of multiple review and approval steps by program management and financial operations staff with specific focus on retention of supporting documentation and clear connections between expenditures being allocated to WIOA and other funding clusters and documentation supporting such allocations. All EmployIndy staff will be retrained on the updated expenditure submission, review, approval, and documentation processes. Additionally, EmployIndy’s Financial Operations, Grants & Contracts, and Program Management teams will provide guidance and training to EmployIndy’s subrecipients and contractors covering the proper process for submitting supporting documentation with invoices or accrued expenditure reports. These documentation requirements will ensure that supporting information directly and clearly ties back to invoices and/or accrued expense reports.