Corrective Action Plans

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

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

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

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

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

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

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

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

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

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

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

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

FINDING 2022-012 Contact Person Responsible for Corrective Action: Casey Brewster Contact Phone Number: 812-752-8935 INDIANA STATE BOARD OF ACCOUNTS 69 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Refresher training will be completed by staff, including the Director of Special Education in the area of IDEA Matching, Level of Effort, and Earmarking/MOE requirements with follow-up collaboration with the CFO. Additional training and implementation of controls to verify compliance internally is being developed and will include a monthly and quarterly checklist that requires documentation at the time of the review and it shall also remain on file for inspection during a future audit. This comprehensive checklist includes items beyond those addressed in this written plan and has also been referenced within other actions of this plan. Anticipated Completion Date: June 2023

FINDING 2022-010 Contact Person Responsible for Corrective Action: Casey Brewster Contact Phone Number: 812-752-8935 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Instead of utilizing journal entries for corrections or adjustments in generic form, corrections to large or for multiple disbursements or receipts should be completed by reversing the action within the financial software and then correctly processing the disbursements or receipts. The on-going training and the related corrective actions which ensure more frequent and more in-depth reviews of reports on a monthly basis will also reduce the need for corrections in general. However, in the event there must be journal entries for corrections, documentation supporting and related to any journal entry will be input into the financial management software, as will any related notes, and any journal entry will have documented approval contained in that software, all completed by separate people ? the Treasurer and CFO. Additional, related training will also be sought to ensure related processes and controls are understood and followed. Anticipated Completion Date: June 2023

Finding No. 2022-007: Inaccurate Stipend Expenditure- Control Deficiency Federal Agency: U.S. Department of Education CFDA Number and Title: 84.362 ? Title VII Native Hawaiian Education Questioned Costs: $10,911 Responsible Individuals: Hye-Jin Park, CDS. Hokulani Project Director Lisa Uyehara, CDS, Ho`oku`i III Project Director Kory Yonemoto, CDS, Administrative Officer Keiki Kawai?ae?a, Director, Ka Haka ?Ula O Ke?elikolani Paula Gealon, Fiscal/Post Award Administrator, RAPID Hokulani and Ho`oku`i III Responses: Hokulani Questioned Costs: $944 Ho`oku`i III Questioned Costs: $7,350 Date Action Taken: November 10, 2022 The Principal Investigators were reminded that any changes or variations to project stipend payments must be communicated to all participants prior to the changes or variations taking effect. They were also reminded to formally document payments made and the criteria used to formulate payments. Failure to comply could result in inconsistencies and further audit findings. Ka Haka ?Ula O Ke?elikolani Response: Questioned Costs: $2,617 Date Action Taken: November 15, 2022 The audit consisted of 2 samples from the Kukulu Kumuhana K-3 project. We provided adequate documentation and justification for the stipend expenditures excluding an $18.83 discrepancy. Going forward, we will take immediate corrective action to ensure that future calculations and documentation are further formalized. The process will include: 1. Streamline the calculation process for stipends. 2. Ensure we have the proper documentation in the files. 3. Process all tuition stipends with the UHCO2 form using budget code 6500. 4. Process non-tuition stipends through KFS using budget code 7245 and ensure that the award letter is signed.

Finding No. 2022-008: Inaccurate Stipend Expenditure- Control Deficiency Federal Agency: U.S. Department of Education CFDA Number and Title: 84.047 ? TRIO Cluster Questioned Costs: $25 Responsible Individuals: Shayna Fuerte, Interim Director, Upward Bound Programs Paula Gealon, Fiscal/Post Award Administrator, RAPID Date Action Taken: January 1, 2022 The University of Hawaii Upward Bound Program streamlined their record keeping function used to track student participation in program activities by only using the Blumen database to record data. This method of tracking student participation went into effect for all five of the Upward Bound Programs on January 1, 2022. The use of the Blumen database will greatly minimize human error in our record keeping process and eliminate the need for various spreadsheets that were previously being used [Student Assignment Log, College Preparatory Saturday Academy (CPSA) Attendance Log, Participant and Parent Cumulative Service (PPCS) Log, Report Card Log, and Tutoring Log]. Information from the Blumen database will be summarized in our Stipend Statement by our Program Coordinators. Points are allocated to the students based off of our Participation and Points Rubric. Prior to payment being issued to student participant, there will be a second level of review of Stipend Statements by either our Director, Associate Director, or Assistant Director to ensure accuracy of point distribution. Once stipend amounts are verified to be accurate with a second level review, stipend payments will be distributed to participants by the Fiscal Specialist.

Corrective Action Plan - FEDERAL AWARD FINDINGS AND QUESTIONED COSTS FA 2022-001 Improve Controls over Federal Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principles Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: COVID-19 - 84.425D - Elementary and Secondary School Emergency Relief Fund COVID-19 - 84.425U - American Rescue Plan Elementary And Secondary School Emergency Relief Fund Federal Award Number: S425D200012 (Year: 2020), S425D210012 (Year: 2021) S45U210012 (Year: 2021) Questioned Costs: $221,797 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: Newton County Board of Education will amend contracts with appropriate vendors to ensure that the proper verbiage is contained for us of federal funds. The School District will monitor contracts to ensure that all expenditures meet compliance requirements for the ESSER federal program. Estimated Completion Date: June 30, 2023 Contact Person: Erica Robinson Telephone: 770-787-1330 Email: robinson.erica@newton.k12.ga.us

Finding Number: 2022-004 Condition: The billing procedures review process did not ensure charges to federal awards were incurred prior to billing the grantor. Planned Corrective Action: Management understands the importance of incurring costs that are charged to federal awards. Management will follow its existing policy to ensure that expenditures charged to grants accurately reflect the costs incurred. In addition, management will return the overage amount to the awarding agency no later than July 31, 2023. Contact person responsible for corrective action: James D. Hagestad Anticipated Completion Date: July 31, 2023

Finding Reference Number: 2022-001 Federal Agency: U.S. Department of Labor Program Name: WIOA Cluster Assistance Listing Number: 17.258, 17.259, 17.278 Responsible Official: Patricia Rogers, Executive Director Views of Responsible Individuals: Based on the discussion we had with you regarding COPIC audit draft report, we have a plan of action moving forward to ensure these issues do not continue: ? COPIC (Josh) and Schmidt Associates (Mary) will work together to do monthly reconciliation of the tracker to the general ledger and staff billing reports. ? The spreadsheet you provided will be used as the reconciliation "tool" and will be available for your review when performing the audit. ? This will provide a monthly, program status of revenue versus expenditures as backup to the CPR submitted to the CWDB. ? The accrued vacation will be subtracted out each month as a line item on the staff billing invoice and a line will be added showing the amount transferred between the leave account and the regular checking account. This should clarify and resolve duplication of accrued vacation expenses. ? The workers compensation for work experience participants has been added back to the tracker and will only be recorded when premiums are paid. ? A line item has been added to the staff billing invoice to show the amount of employee health insurance being deducted from the employee checks each month. To clarify the amount paid by COPIC and the amount paid by the employee. ? The monthly reconciliation to be conducted, using the spreadsheet you provided, should eliminate audit adjustments and ensure the Payment Tracker, the General Ledger and the CPR match each month.

Finding Number: 2022-001 Condition: Controls in place did not identify a portion of expenditures, related to summer school stipends, incurred in fiscal year 2023 that were applied to the federal award in fiscal year 2022. Planned Corrective Action: The error was the result of a misunderstanding with the pass-through entity regarding the reimbursement process. Going forward, a review will be performed to ensure federal revenue is recorded in the same period as the corresponding expense. Contact person responsible for corrective action: Chief Executive Officer Anticipated Completion Date: Effective Immediately

This finding resulted from a misinterpretation of guidance the District received from the Ohio Department of Education regarding the allowability of certain expenditures. The information has since been clarified and similar expenditures will not be charged to the ESSER fund going forward.

Riverside Educational Center respectively submits the following corrective action plan for the year ended June 30, 2022. Name and address of independent public accounting firm: Chadwick, Steinkirchner, Davis & Co., P.C. 2499 Hwy 6&50 Grand Junction, CO 81505 Audit Period: Year ended June 30, 2022 The findings from the Schedule of Findings and Questioned Costs for the year ended June 30, 2022, are discussed below. The findings are numbered consistently with the number assigned in the Schedule. Findings ? Financial Statement Audit Significant Deficiency in Financial Reporting 2022-001 Criteria: The Center is responsible for establishing and maintaining a system of internal control that will prevent, detect and correct errors in the financial statements in a timely manner to safeguard assets and allow for timely and accurate financial reporting. Recommendations: We recommend that the Center creates a process where reconciliations of the financial records are performed regularly and reviewed by someone other than the person who performed the reconciliation. We also recommend that the staff acquire the training necessary to be able to complete a set of GAAP-compliant financial statements. We agree with the recommendation that reconciliations of financial records be completed regularly and be subsequently reviewed by someone other the person who performed the reconciliation. As of February 2021, our process for all bank and credit card activities changed from being completed by the Financial Manager and not reviewed to being completed by the Operations Director and being reviewed by the Executive Director, with documentation of this approval being retained in a shared drive on a monthly basis. A process has also been enacted, as of 3/15/2021, that ensures all supporting documentation for credit card activities are reviewed by program administrators prior to reconciliation. These approvals are retained in REC's receipt tracking software (Hubdoc). An update to this policy and process was enacted on 1/1/23 that provides further assurance that all required documentations and approvals have been received and retained; with backup documentation being held in Hubdoc and approvals being documented through manager signature and retained in REC?s google drive. 2022-002 Federal agency: Department of Education Federal program title: 21st Century Community Learning Centers CFDA Number 84.287 Award Period: 7/1/2021-6/30/2022 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria: 2 CFR 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements (the Uniform Guidance), section 200.403(g), requires that charges to Federal awards must be adequately documented. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Context: A sample of forty charges allocated to the program, totaling $7,078, were selected for audit from a population of general expenditures allocated to the program totaling $303,054. There were 5 charges that lacked sufficient documentation of review and approval per the Center?s policies. Questioned Costs: Known questioned costs total $951. Recommendation: Proper control activities should be implemented to allow for a consistent, accurate, and allowable method to support distribution of general expenditures to federal programs. The Center should develop a means to adequately track approvals for expenditures. We agree with the recommendation that approval for all expenditures should be tracked with documentation of the approval being maintained. As of 1/1/2023, REC has implemented a policy and procedure for approval of all expenditures on credit cards (which are the expenditures that have led to this finding) that requires all cardholders and their direct supervisors to sign their monthly credit card statement for approval of all expenditures. This procedure also requires the Financial Manager?s signature to verify that either, all backup documentation has been submitted and retained, or that any charges without the correct backup documentation is not charged to any of REC?s grants or restricted funds. This policy caps the total amount of missing documentation to a total of $9,000 per year and ensures that all expenditures without documentation are not charged to grants or otherwise restricted funds. If any agency, stakeholder or other party has any questions regarding this plan, please call Landen Fledderjohn at 970-279-1595. Sincerely, Landen Fledderjohn, Financial Manager Riverside Educational Center

2022-004 Allowable Costs/Costs Principles Recommendation: We recommend the organization charge compensation for personnel services to the federal grant based on approved hours worked in the program. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: Plainfield Community School Corporation will implement practices to ensure compensation for personnel services to the federal grant is based on approved hours worked in the program. Temporary employees will document hours worked by signing in and out each day worked. Name(s) of the contact person(s) responsible for corrective action: Elizabeth Shepperd Planned completion date for corrective action plan: April 2023

Program: AL 21.023 ? COVID-19 Emergency Rental Assistance ? Allowability & Eligibility Corrective Action Plan: N/A Contact: Lee Will Anticipated Completion Date: N/A

Program: AL 21.023 ? COVID-19 Emergency Rental Assistance ? Allowability & Earmarking Corrective Action Plan: N/A Contact: Lee Will Anticipated Completion Date: N/A