Corrective Action Plans

Contact Person Responsible for Corrective Action: Jessica Espinoza Contact Phone Number: (219) 836-9111 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We currently only have one employee who is partially paid through the federal lunch program. Moving forward, the employee will be keeping a log of the daily start and end time working on food service. These times will be entered into her timecard as a foodservice event. The supervisor will review the time card. This will ensure that she is only being paid with federal lunch funds while she is working on food service. Also, a grant distribution payroll report for all foodservice employees is signed off on by the Director of Operations after each payroll, verifying the amounts expended from the foodservice fund. Anticipated Completion Date: To be completed by the next payroll dated March 3, 2023.

FA 2022-001 Improve/Strengthen Controls over Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principle 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 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: $104,640.00 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 Appling County Board of Education. Estimated Completion Date: 5/5/2023 Contact Person: Adrienne Taylor, CFO Telephone: (912)367-8600 Email: Adrienne.taylor@appling.k12.ga.us

FINDING 2022-004 Contact Person Responsible for Corrective Action: Amanda M. Brackett, Chief Financial Officer Contact Phone Number: (765) 269-8218 Views of Responsible Official: We agree with the findings identified. Description of Corrective Action Plan: In order to mitigate future findings regarding earmarking within the Greater Lafayette Area Special Services cooperative, the TSC will implement procedures to ensure better internal controls which includes monitoring. The Chief Financial Officer will monitor the progress of the Corrective Action Plan to ensure that we fulfill our requirements of the CAP. Anticipated Completion Date: Summer 2023.

FINDING 2022-002 Contact Person Responsible for Corrective Action: Dan Scherry Contact Phone Number: (812) 937-2400 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: At each Co-Op Board Meeting, the Superintendent will request a copy of the reimbursement requests submitted indicating the amount in North Spencer?s non-public expenditures along with the supporting documentation (timesheets showing time spent with non-public students). Superintendent will make sure the two (requests and timesheets) agree in order to ensure a percentage is not used for the reimbursement requests. Anticipated Completion Date: March 15, 2023

Corrective Action Plan Year Ended June 30, 2022 Finding 2022-003: (Significant Deficiency) AL# 97.036: Disaster Grants - Public Assistance (Presidentially Declared Disasters), Passed Thru the Oklahoma Department of Emergency Management, U.S. Department of Homeland Security, Award# PA-06-OK-PW-00187, 2022 Condition: There were three instances in which an employee's pay rate used in calculating payroll expense was the current pay rate and not the pay rate in effective at the time the work was performed. Criteria or Specific Requirement: 2 CFR 200.403(g) states that costs must be adequately documented. Cause: Employees received pay increases between the time the service was performed and when costs were identified as being covered by the disaster grant. The pay rate used was the pay rate for those employees at the time the expenditures were identified. Effect: Not properly identifying the appropriate pay rates used in determining payroll expenses may cause the federal program to be overcharged. Corrective Action Plan: The City will implement the following steps: 1. The Parks and Recreation Department will immediately implement a process where the Parks & Grounds Superintendent (or designee) will review employee pay information that administrative staff prepares for entry into the federal grant website ensuring that it is properly formatted and accurately reflects the pay at the time the work was performed. 2. A procedure will be added to the FEMA section of the City's Grants Manual to include a second review to verify that the pay rates being used to determine payroll expenses are the rates that were in effect at the time the service was provided. This verification will be documented in the Grants database maintained by the Accounting Services Division.

FINDING 2022-0003 Contact Person Responsible for Corrective Action: Chris Richie Contact Phone Number: 219-987-4711 ext. 1113 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: 1) At the beginning of each school year, Cooperative School Services (CSS) will issue step by step instructions regarding documentation of services to any school personnel providing services for non-public school students with Service Plans for Special Education. The instructions will include but not be limited to a list of current nonpublic school students on his/her caseload, Time and Effort (T&E) logs with examples, etc. The building principal will be asked to review and co-sign the completed T&E logs. (If there are additional students identified over the course of the school year, CSS will provide the appropriate information to any new service providers.) 2) During each school year, CSS will obtain the hourly rate (salary, benefits and other appropriate expenditures) for school personnel providing Special Education or Related Services to non-public school students from the school corporation Treasurer. 3) On monthly basis, the signed T&E logs will be submitted to the CSS office. The amount of federal Proportionate Share funds that can be claimed for each participating school corporation will be calculated by CSS and the school corporation Treasurer. 4) The school corporation will submit a claim to CSS for reimbursement for the funds expended to provide services for non-public school students at least twice per school year. CSS will submit the claim to the Fiscal Agent school corporation for reimbursement. The reimbursement claim will be paid through the Fiscal Agent school corporation?s school board procedures from the IDEA Proportionate Share funds. Anticipated Completion Date: March 31, 2023

CAP for Finding: 2022-300 DATE: March 20, 2023 TO: Erin Scharlau, Financial Audit Director Legislative Audit Bureau FROM: Barry Kasten, Director Bureau of Fiscal Services Department of Health Services SUBJECT: Corrective Action Plan ? Disaster Grants ? Public Assistance (Presidentially Declared Disasters) ? Unallowable Costs Department staff has reviewed the Legislative Audit Bureau?s (LAB) interim audit memo for Finding 2022-300: Disaster Grants ? Public Assistance (Presidentially Declared Disasters) ? Unallowable Costs. This is the department?s Corrective Action Plan. ? Recommendation (2022-300): Disaster Grants ? Public Assistance (Presidentially Declared Disasters) ? Unallowable Costs We recommend the Wisconsin Department of Health Services: ? Work with the federal government to resolve the $855,368 in unallowable costs we identified. Wisconsin Department of Health Services Planned Corrective Action: DHS will reach out to the federal government as suggested to resolve this issue. Anticipated Completion Date: June 30, 2023 Person responsible for corrective action: Barry Kasten, Director Bureau of Financial Services, Division of Enterprise Services barry.kasten@dhs.wisconsin.gov

Reference Number: 2021-001 Program: COVID 19 ? Coronavirus State and Local Fiscal Recovery Funds Type of Finding: Noncompliance, Significant Deficiency Compliance Requirement: Allowability: Indirect and Direct Costs Recommendation: We recommend management strengthen its controls over the charges related to its indirect costs and ensure it has properly accounted for all direct and indirect costs. In addition, we recommend the organization reduce its next draw from the program by the overcharged amount. Action taken in response to finding: We agree with the finding and will develop a policy and procedure for identifying and properly accounting of all direct and indirect costs. Name of the contact person responsible for corrective action: Joyce Darling, Vice President for Finance and Administration, Delaware Community Foundation Planned completion date for corrective action plan: Effective ? 3/31/2023

FINDING 2022-003 Contact Person Responsible for Corrective Action: Tim Scott Contact Phone Number: 574-654-7273 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Corporation Treasurer will meet with representative/s from the South LaPorte County Special Education Cooperative to ensure compliance with the matching, level of effort, and earmarking requirements for federal grants. He will pay particular attention to acquire proof that the required level of expenditures for non-public school students with disabilities is met. Anticipated Completion Date: August 2024

Finding Type - Material weakness and material noncompliance with laws and regulations Condition ? The Authority disbursed a portion of its CARES Act funds to community partners; however, many of those partners offer only Section 5310 service for seniors and individuals with disabilities. Section 5310 program expenses are not allowable under the CARES Act. Identification of How Questioned Costs Were Computed ? Questioned costs represent the total amount of CARES Act funds passed through to community partners. Context - During the fiscal year, SMART passed through $1,146,291 to 35 community partners. Cause and Effect - The CARES Act award was new to SMART in fiscal year 2020. SMART's other federal awards have existed for many years and SMART is very familiar with their requirements and allowable uses. SMART sought to share the new award with its community partners but was not aware that most of them did not have expenditures allowable under the CARES Act until the matter was identified during SMART's most recent triennial review. Recommendation - When new awards are received, we recommend SMART thoroughly analyze the compliance requirements, including the allowable uses. Views of Responsible Officials and Corrective Action Plan ? SMART management is aware of the issue and has been diligently working with our FTA regional office to correct the issue. While certain community partner expenses were not eligible under CARES, they are certainly eligible under CRRSA and ARPA funding grants. We are in the process of finalizing a plan, with the FTA, where all community partner relief funding will be reprogramed under the CRRSA and ARPA grants. This correction plan, once finalized, will result in no reduction of federal relief funding to SMART or any of our community partners. Given extraordinary circumstances and expedited nature of the CARES funding, we do not believe that this issue will be a significant risk for future grant funding, however SMART has modified our grant policy manual to ensure a more thorough review of eligible expenses for subrecipients. Contact person responsible for corrective action: Ryan Byrne, CFO Anticipated Completion Date: 12/31/2022

Reference Number: 2022-018 Prior Year Finding: 2021-014 Federal Agency: U.S. Department of Health and Human Services State Department Name: Department of Health and Social Services State Division Name: Division of Medicaid and Medical Assistance Federal Program: Children?s Health Insurance Program (CHIP) Assistance Listing Number: 93.767 Award Number and Year: 2205DE5021 (10/1/2021 ? 9/30/2023) Compliance Requirement: Period of Performance Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Recommendation: The Division 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: DMMA will review reported expenditures based on the date of the federal draw to ensure that the expenditures occured within the period reported. Name(s) of the contact person(s) responsible for corrective action: Unkyong Goldie Planned completion date for corrective action plan: September 30, 2023

Identifying Number: 2022-009 Finding: Period of Performance: payroll costs Corrective Actions Taken or Planned: UCAN agrees with this finding and is committed to strengthening internal controls to ensure that amounts are properly recorded and reported. UCAN has already taken steps to insure that items are billed in the period incurred and only items that fall into the grant period are billed. We believe that significant turnover in the finance department led to this deficiency, so we are actively documenting procedures and cross-training employees, so we always have coverage. All vouchers will also go through a review process before they are sent to the funder. This is a repeat finding, with the original corrective action plan to be completed before June 30, 2023. We do believe that corrective actions that have been taken have resolved this issue. Contact person is Kimberly Parish, Chief Financial Officer and she can be reached at kim.parish@ucanchicago.org.

Finding 2022-002 - Controls Over Payroll Expenditures (Material Weakness): Criteria: 2 CFR 200.403 establishes principles and standards for determining costs for federal awards carried out through grants, cost reimbursement contracts, and other agreements with state and local governments. To be allowable, under federal awards, cost must meet certain criteria: a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. c) Be consistent with policies and procedures that apply uniformly to both federally- financed and other activities of the non-Federal entity. d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. g) Be adequately documented. h) Cost must be incurred during the approved budget period. Additionally, 2 CFR 200.303 indicates that non-Federal Entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award current staff initiates and monitors pay advices. These documents are being transmitted electronically for review by all parties and to preserve records.

FINDINGS ? FEDERAL AWARD PROGRAM AUDIT SIGNIFICANT DEFICIENCY 2022-002 Coronavirus State and Local Fiscal Recovery Funds ? Assistance Listing No. 21.027 Recommendation: YWCA should establish written policies and procedures to provide for timely and appropriate review and approval for period of performance. Action Taken: We concur with the recommendation and have developed the following plan. YWCA Madison, Inc., in compliance with guidance set forth in the Uniform Guidance 2 CFR section 200.303, will develop written policies and procedures on what, when, and who is responsible for review and approval for period of performance for YWC Madison funding. Additionally, YWCA Madison, Inc. will create a grant tracking checklist with key details for the funding including the performance period, total funding amount, allowable costs, the program or department funding is to be used for, etc. The checklist will also include an approval section for YWCA Madison finance team members to complete indicating their review of costs charged to the funding source at the beginning and the end of the performance period. The monitoring checklist will be updated to add a review of any new grant tracking checklists for the month as part of its internal controls checklist. The monitoring checklist will be reviewed monthly by the CEO and the review will be documented.

Policies, procedures and controls have been reviewed and revised to ensure all direct costs and indirect cost allocations are reviewed as part of the month end close process. The ERP system generated allocations, based on the negotiated indirect cost rate, will be reviewed monthly by the grant accountant and the lead accountant. This error occurred due to a staffing transition. A month end checklist will be created to ensure that all steps of the process are documented, irrespective of the responsible staff. This error did not result in any in appropriate reimbursement as it was corrected by management prior to seeking reimbursement for Q4 2022. APS implemented the corrective action plan on June 5th, 2023. Management's contact responsible for the implementation of the Corrective Action Plan: Name: Jane Hopkins Gould Position: Chief Financial & Operating Officer Telephone number: 301-209-3276

FINDING 2022-005 Subject: COVID-19 ? Education Stabilization Fund ? Activities Allowed or Unallowed, Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Program: COVID-19 ? Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425U200013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Findings: Material Weakness, Material Noncompliance Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with the requirements related to the grant agreement and the Activities Allowed or Unallowed and Allowable Costs/Cost Principles compliance requirements. Context: (a) During allowable cost testing for vendor disbursements, we noted a portion of ARP ESSER funds were utilized to repair the chiller at the middle and high schools. The School Corporation incurred a total of approximately $284,000 in chiller repair costs between September 2021 and May 2022 and requested reimbursement for those expenditures from ARP ESSER funds in full. In October 2021, the School Corporation received an insurance claim check in the amount of $106,755 to cover a portion of the repair costs. The School Corporation did not deduct the amount received through insurance from the amount requested for reimbursement from federal funds, resulting in an overpayment of federal funds during the audit period. (b) Additionally, the School Corporation had not properly designed or implemented internal controls over recording transactions for payroll and fringe benefit disbursements to ensure the accuracy and classification of the payroll disbursements. Payroll disbursements make up approximately 45% of the program costs charged to the Education Stabilization Fund. One employee was responsible for processing payroll. Payroll reports were submitted to the School Board and Treasurer for review and approval; however, the reports only provided a total gross amount paid from each fund. The reports did not list the employees who were paid from the fund. In March 2021, the Treasurer implemented a review of the payroll distribution report, which is broken out by fund and individual employee. The lack of controls related to payroll disbursements was isolated to the 2020-2021 year. Views of Responsible Officials and Planned Corrective Actions: We concur with the finding. Description of Corrective Action Plan: The NJ-SP School Corporation will implement internal controls to ensure a system is established for when insurance claim checks are received that they are properly receipted and funds are accounted for and deducted from necessary reimbursement grants. This will give better proper oversight, reviews, and approvals over the insurance claim checks received. These controls will be implemented by July 1, 2023. The NJ-SP School Corporation will also implement internal controls to oversee that financial transactions related to receipts and payroll and fringe benefits disbursements are reviewed and verified by proper management to ensure that accuracy and documentation is in place. These controls were implemented on March, 2021. Responsible Party and Timeline for Completion: Dalton C. Tunis ? Corporation Business Manager/Treasurer Anticipated Completion Date for (b): March 2021 Anticipated Completion Date for (a): July 1, 2023

FINDING 2022-008 Subject: Special Education Cluster (IDEA) ? Activities Allowed or Unallowed, Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Program: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Number: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 20611-109-PN01, 21611-109-PN01, 21619-109-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Findings: Material Weakness Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with the requirements related to the grant agreement and the Activities Allowed or Unallowed and Allowable Costs/Cost Principles compliance requirements. Context: The School Corporation had not properly designed or implemented internal controls over recording transactions for payroll and fringe benefit disbursements to ensure the accuracy and classification of the payroll disbursements. Payroll disbursements make up 100% of the program costs charged to the Special Education grants. One employee was responsible for processing payroll. Payroll reports were submitted to the School Board and Treasurer for review and approval; however, the reports only provided a total gross amount paid from each fund. The reports did not list the employees who were paid from the fund. In March 2021, the Treasurer implemented a review of the payroll distribution report by fund and individual employee. The lack of controls related to payroll disbursements was isolated to the 2020-2021 year. Views of Responsible Officials and Planned Corrective Actions: We concur with the finding. Description of Corrective Action Plan: The NJ-SP School Corporation will implement internal controls to oversee that financial transactions related to receipts and payroll and fringe benefits disbursements are reviewed and verified by proper management to ensure that accuracy and documentation is in place. These controls were implemented on March, 2021. Responsible Party and Timeline for Completion: Dalton C. Tunis ? Corporation Business Manager/Treasurer Anticipated Completion Date: March 2021

FINDING 2022-004 Subject: Child Nutrition Cluster ? Activities Allowed or Unallowed, Allowable Costs/Cost Principles Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program, After School Snack Program, Summer Food Service Program for Children Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY2021, FY2022 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Findings: Material Weakness Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with the requirements related to the grant agreement and the Activities Allowed or Unallowed and Allowable Costs/Cost Principles compliance requirements. Context: The School Corporation had not designed or implemented adequate internal controls to ensure that payroll disbursements were only for food service-related services. Payroll disbursements comprise approximately 45% of the program costs charged to the Child Nutrition Cluster. One employee was responsible for processing payroll. Payroll reports were submitted to the School Board and Treasurer for review and approval; however, the reports only provided a total gross amount paid from each fund. The reports did not list the employees who were paid from the fund. In March 2021, the Treasurer implemented a review of the payroll distribution report, which is broken out by fund and individual employee. The lack of controls related to payroll disbursements was isolated to the 2020-21 year. Additionally, payroll disbursements for custodial employees were allocated to the Child Nutrition Cluster based on a percentage of the custodial employees? salaries. However, there were no time and effort logs or other documentation maintained to support the percentage of the custodial salaries allocated to the Child Nutrition Cluster. The custodial salaries make up approximately 3% of the total payroll disbursements charged to the Child Nutrition Cluster. This was an issue throughout the audit period. Views of Responsible Officials and Planned Corrective Actions: We concur with the finding. Description of Corrective Action Plan: The NJ-SP School Corporation will implement internal controls to ensure compliance with the activities allowed or unallowed and allowable costs/cost principles compliance requirements. This will consist of maintaining documentation to support that payroll disbursements are only for food service operating costs by having supporting timesheets and timecards or time and effort reports for all employees paid from the School lunch fund. These controls will be implemented by July 1, 2023. Responsible Party and Timeline for Completion: Dalton C. Tunis ? Corporation Business Manager/Treasurer Anticipated Completion Date: July 1, 2023

FINDING 2022-004 Information on the federal program: Subject: Special Education Cluster - Earmarking Federal Agency: Department of Education Federal Program: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Number: 84.027, 84.173 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking Audit Finding: Significant Deficiency Condition and Context: The School Corporation is a member of the Daviess-Martin Special Education Cooperative (Cooperative). During fiscal year 2020-2021, the Cooperative operated the special education programs and spent the federal money on behalf of all its member schools. As the grant agreements were between the Indiana Department of Education (!DOE) 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 school 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 the 19611-007-PN01 and 19619-007-PN01 grant awards could not be verified for the individual member schools. Total grant expenditures were posted as expended. The non-public proportionate share expenditures were then determined by applying the budgeted percentage for non-public school expenditures to the total expenditures. These were the amounts reported to !DOE. As such, we were unable to identify if the minimum amount per the grant awards was expended and properly reported to !DOE as required. The lack of internal controls and noncompliance was isolated to the 19611-007-PN01 and 19619-007-PN01 grant awards. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and will take the following corrective action. The School Corporation will set internal controls in place to ensure that the required level of expenditures for non-public school students with disabilities was met for our school corporation. Earmarking requirements for the Matching, Level of Effort will be reviewed and reported. We have consulted with Daviess-Martin Special Education Co-Op and they have assured us additional Komputrol training has been completed on their part to ensure that we are all monitoring internal controls. Responsible party and timeline for completion: Federal regulation requires name and title of person overseeing corrective action plan and anticipated completion date. Mrs. Berry, Superintendent will work with the Daviess-Martin Special Education Co-Op to ensure our School Corporation is in compliance each school year.

FINDING 2022-002 Contact Person Responsible for Corrective Action: Cortney Parrish, Corporation Treasurer Contact Phone Number: 765-240-2346 Views of Responsible Official: We agree with the finding Description of Corrective Action Plan: As of fiscal year 2022, the School Corporation no longer pays teachers or aides from the School Lunch Fund, with the exception of one teacher being paid from the School Lunch Fund until December of 2022. As of January 1, 2023, only cafeteria employees are paid from the School Lunch Fund. Anticipated Completion Date: Completed

FINDING 2022-005 Contact Person Responsible for Corrective Action: Danica Houze, Chief Financial Officer Contact Phone Number: 812-274-8001 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Starting in FY 2021 Time and Effort logs were kept by employees working with non-public students. Logs are submitted to the Director of Student Services and the payroll department, then accounts are distributed to match time actually spent with the non-public time spent per the time and effort logs. Anticipated Completion Date: 2/13/2023

FINDING 2022-001 Contact Person Responsible for Corrective Action: Tammy Breedlove, Food Service Director Contact Phone Number: 765-569-4308 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The following internal control process has been added to the Business Office Handbook Effective February 1, 2023. The Food Service Director will follow all guidelines as contained in the Child Nutrition Procurement Plan and retain all documentation in compliance with Child Nutrition regulations and State Law. Furthermore, the Food Service Director will ensure that the following procedures are in place: 1. Each School year, the Food Service Director will prepare 5 binders- 1 for each Cafeteria, 1 for the Food Service Director, and 1 for the Business Manager. These binders will contain all approved bids and price changes/vendor correspondence. It is the responsibility of the Food Service Director & Cafeteria Site Managers to update these binders as price changes occur. Audit Evidence will be the contents in each binder for each school year. 2. When invoices for goods are received, the Food Service Director is responsible for ensuring that the invoices are reviewed and crosschecked to the original order/ approved pricing by the Cafeteria Site Manager. Furthermore, the Food Service Director will also review the invoices/pricing and sign off on the claim voucher sheet as approval for the Business Manager to pay the invoice. Audit Evidence: The Cafeteria Site Manager?s signature on the invoices & the Food Service Director?s signature on the claim voucher sheet. Anticipated Completion Date: Effective February 1, 2023

Corrective action plan: Management is implementing a job/cost time and labor system as part of the current Paylocity system currently in place. This new time tracking system will allow individuals working directly on contracts to record time spent on grants on their individual weekly timecards. This system will allow management to report time spent by person by contract within our current payroll and financial system. This enhancement will not be in place until January 2023. In the meantime, management has formalized a quarterly manual review process to document actual time spent per employee per contract along with any needed adjustments to allocation percentages. Personnel responsible for corrective action: Stephanie Cawby, Senior Accountant and Alex Laprade-Velasco, Financial Analyst Estimated corrective action completion date: December 2022 ? Manual quarterly review of contract time spent and adjustments. January 2023 ? Implementation of Paylocity Job Cost Time tracking and roll out to employees

FINDING 2022-004 (Auditor Assigned Reference Number) Contact Person Responsible for Corrective Action: Todd VanDerWeele Contact Phone Number: 574.223.2159 Views of Responsible Official: We concur with the finding. We have adjusted our retention practices to keep all employee records according to statute. After employees listed on the personnel report for hiring or reclassification are approved, the HR Director will provide the approved personnel report, salary schedule or CBA salary schedule, employee contract, and screen shot of the entries into the school?s financial software to the Business Manager to review and approve. Anticipated Completion Date: March 31, 2023

FINDING 2022-003 (Auditor Assigned Reference Number) Contact Person Responsible for Corrective Action: Todd VanDerWeele Contact Phone Number: 574.223.2159 Views of Responsible Official: We concur with the finding. We have adjusted our retention practices to keep all employee records according to statute. After employees listed on the personnel report for hiring or reclassification are approved, the HR Director will provide the approved personnel report, salary schedule or CBA salary schedule, and screen shot of the entries into the school?s financial software to the Business Manager to review and approve. Anticipated Completion Date: March 31, 2023