Corrective Action Plans

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 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 COVID-19 - 84.425W - American Rescue Plan Elementary and Secondary School Emergency Relief Fund - Homless Children and Youth Federal Award Number: S425D200012 (Year: 2020), S425U2120012 (Year: 2021) S425W210011 (Year: 2021) Questioner Costs: $30,180 Prior Year Finding: None Description: The polices and procedures of the School District were insufficient to provide and adequate internal controls over expenditures as it relates to the Elementary and Secondary School Emergency Relief Fund program. Corrective Action Plans: Revise Federal Programs Handbook to enhance internal controls in the area of contracts. Provide addendums to contracted services to provide for retention bonuses to contracted staff. Estimated Completion Date: June 30, 2023 Contact Person: Seth Taylor, Chief Financial Officer Telephone: 229-723-4337 Email: staylor@early.k12.ga.us

2022-004 ? Allowable Costs/Cost Principles Auditee?s Response and Planned Corrective Action JCHA will implement and follow a procurement policy that details documentation of authorized purchases made by the Authority. Planned Implementation Date of Corrective Action: On or by June 30, 2023. Person Responsible for Corrective Action: Executive Director with the assistance of Bedrock Housing Consultants.

Respectfully, the school corporation does not agree with several of the findings in regards to segregation of duties and purchases. First, the SBOA auditors' told the school corporation during the 2019 audit that operating the school lunch program through the extracurricular account was not legal. The school corporation was informed that this account must be transferred to Central Office and a Corrective Action Plan must be in place. This directive was incorrect and pointed out in the official response from November 5, 2019 under IC 20-26-5-4(a)(l l). Second, segregation of duties, oversight, and approval of functions existed in 2019 and are presently occurring daily, weekly, and monthly within the cafeteria program under the corporation accounts and supervision of Central Office. Cafeteria workers record and submit timesheets of duties performed during each payroll period. The Cafeteria Director verifies and signs timesheets to be submitted to the Treasurer and Deputy Treasurer for review and payment from the Cafeteria account. A payroll docket report is sent to the Superintendent prior to payment from the bank. Prior to the 2019 audit, the High School Treasurer spent approximately two hours per day counting cash received each day from school lunches purchased. She also receipted those funds it into the software system, made deposits to the bank, paid invoices for food expenses, and processed part of payroll. Tasks conducted by the High School Treasurer were segregated by a timesheet and supervised by the High School Principal. All those tasks were shifted to Central Office in 2020 and are now segregated to the Treasurer and Deputy Treasurer. The Treasurer documents hours spent on Cafeteria accounts on a timesheet for review and signature by the Superintendent. Financial reports of expenditures and revenues are provided for review and oversight to the Superintendent and School Board at monthly board meetings. Third, RSSC has a small Central Office consisting of a Superintendent, Treasurer, Deputy Treasurer, and Secretary. It has no Assistant Superintendents, Human Resources Director, or Business Manager. Each person in Central Office wears multiple hats and performs multiple duties each day. It was noted in the Audit Report filed from July 1, 2008 to June 30, 2010 that " ...Randolph Southern School Corporation is unable, due to financial limitations, to employ additional personnel to segregate duties in our receipts and cash and investment balances. This statement would apply to all of our internal controls. " The circumstances for RSSC have not changed in the audit periods from July 1, 2010 through June 30, 2022. Corrective Action Plan: The School Board had chosen not to add additional staffing due to costs. RSSC is still unable to segregate duties for financial transactions and reporting. Fourth, the Cafeteria Program only has one full-time staff member, the Cafeteria Director. Eight part-time cafeteria workers prepare and feed up to 300 students each day. This food service program is one of the best run programs in the State oflndiana. It has not had one food preparation or sanitation violation from IDOE or Department of Health in the last 12 years. Fifth, the Cafeteria Program is economically efficient and fiscally responsible. The account carries at least a 3-month cash balance at all times. This success is a direct result of oversight by the combination of the Superintendent, Treasurer, and Cafeteria Director. RSSC adopted board policy 6114 Cost Principles-Spending Federal Funds on May 9, 2016. RSSC has had an Indirect Cost Rate in place since 2013. The adopted policy allows the school corporation to apply Indirect Costs to all federal funds including the Cafeteria account. On December 5, 2019, email communications between the Dr. Donnie Bowsman, Superintendent and Tina Herzog, IDOE Assistant Director of Operations and Food Distributions clearly state the school corporation can apply the Indirect Cost Rate to the Cafeteria account. The email communication clearly states that the high cash balance was a result of not applying the Indirect Cost Rate to the Cafeteria account (See Exhibit 1 Emails). The Indirect Rate was approved by the IDOE Office of School Finance and existed prior to the audit years being referenced in the finding. Technically, the prospective portion (going forward for the next school year) as referenced on pages 24-25 of USDA Indirect Cost Guidance Manual pertains to the 2013 Fiscal Year. Moreover, the fact was reiterated by the IDOE School Nutrition Office with email communications on December 5, 2019, not 2021 or 2022 as referenced in the finding. RSSC has not charged or recouped the Cafeteria Account the Indirect Cost rate for many years and has subsidized this account which should be independent and self-sufficient. The School Corporation did not apply the Indirect Cost Rate in 2020 or 2021 because we were not sure how many students would be eating and how fiscally sound the account would be due to students not attending school because of COVID. Corrective Action Plan: The Indirect Cost Rate will be applied and collected in the future prior to June 30 of each current fiscal year. It should also be noted that in 2021, RSSC purchased a new cafeteria dishwasher utilizing ESSER II funds. This unit was 20+ years old and needed to be replaced in order to continue feeding children and to run the food service program. This expense could have been and should have been a direct cost of $58,189 to the Cafeteria account. However, due to the unknown circumstances of COVID, the RSSC could not take a chance. The ESSER II grant is still open and we are now questioning whether this expense could be charged directly to the Cafeteria account. Those ESSER II fund could be utilized for staffing to support student learning loss and remediation. Sixth, COVID caused this financial account to increase exponentially from 2020 to 2021. ESSER funds were provided by the federal government to provide free lunches to every child which paid the food operations expenses for two school years. Student participation of eating school lunches increased during these time periods. Additionally, staff members were receiving hazard pay incentives on top of their regular hourly rate. Further, the School Corporation and Cafeteria Program took on the enormous task of feeding children over the summers of 2020 and 2021 when COVID cases were at its peak. The cafeteria personnel fed 5286 and 5740 students respectfully during those summers. The number of meals served during the summer almost equaled the total amount of meals served during the entire school year for each respective academic year. These additional meals created additional unexpected revenues for the fiscal year. The school corporation did not charge mileage for satellite lunches being delivered or indirect costs.

Persons responsible for corrective action plan: Resty Rios, Staff Accountant Resty.rios@crihb.org Adrianna Davisson, Grants Manager Adrianna.davisson@crihb.org It is the standard practice for all IDC Entries to be reviewed and approved prior to posting. However, due to employee turnover the review and approval process lacked sufficient documentation. The Clinic will ensure that all IDC Entries will be clearly documented with the appropriate review and approval signatures prior to posting to the financial records. The anticipated completion date is 6/30/2023.

Finding Number: 2022-004 Condition: Unallowable costs incurred prior to the period of performance under the grant agreement were submitted and reimbursed by the granting agency. Additionally, these costs were initially included on the schedule of expenditures of federal awards. Planned Corrective Action: The personnel responsible for submitting reimbursement requests will review grant agreements with the personnel responsible for applying for the grants upon their award. Worksheets created for reimbursement and reporting will be reviewed against the grant schedules for accuracy. Contact person responsible for corrective action: Matt Zeilstra ? Financial Controller Anticipated Completion Date: 07/27/2023

Finding 2022-004 ? Unallowable Use of Public Housing Program Funds Public Housing Program ? Assistance Listing No. 14.850a, Grant Period: Fiscal Year-End June 30, 2022 Corrective Action The Authority review allowable Public Housing Program versus COCC expenditures in HUD Handbook 7575.1 and refrain from charging COCC expenditures to the Public Housing Program. The Authority?s Executive Director, Africa Porter, has assumed the responsibility of executing this corrective action as of April 1, 2023.

Contact Person Responsible for Corrective Action: Patsy Hess, Corporation Treasurer, and Lindsey Goshorn, Special Education Director Contact Phone Number: 812-358-4271 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: During fiscal year 2020-2021, Brownstown Central Community School Corporation (School) was a member of Orange-Lawrence-Jackson-Martin-Greene Joint Services Cooperative (Cooperative). The Cooperative operated the special education programs and spent the federal money on behalf of all its member schools. At the end of fiscal year 2020-2021 the Cooperative disbanded. Subsequent to fiscal year 2020-2021, the School has operated the special education programs. The Special Education Director maintains records ensuring that the required level of expenditures for nonpublic school students with disabilities has been met. The records involving level of expenditures for nonpublic school students with disabilities will be reviewed by the Corporation Treasurer or other employee with knowledge of the compliance requirement. Anticipated Completion Date: Immediate

Period of Performance ? Assistance Listing No. 93.224/93.527 Recommendation: We recommend that only costs incurred during the period of performance be charged to the grant. For payroll in which periods extend over multiple budget periods, we recommend prorating the amount charged to the grant by days worked within the grant period. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: ? LMC staff will review all expense applied toward federal funds to ensure that all dates fall within the period of performance. ? CFO will work with grant management staff to further train and support review of all expenses allocated to grant funding. Name(s) of the contact person(s) responsible for corrective action: Melissa D?Onorio, CEO, and Emily Faricy, CFO. Planned completion date for corrective action plan: 1/31/2023

FINDING 2022-008 Contact Person Responsible for Corrective Action: Whitney Dixon, Treasurer Contact Phone Number: 574-533-8631 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Vendor claims with supporting documentation will be retained by the business office. Requests for reimbursements including supporting documentation, including financial and programmatic records, will be retained to verify allowable activities or costs. Anticipated Completion Date: May 2023

FINDING 2022-003 Contact Person Responsible for Corrective Action: Christopher Dixon, Director of Nutrition Contact Phone Number: 574-533-8631 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The School Corporation will document the review/oversight of disbursements from program funds prior to payment. Claims will be prepared and reviewed by Christopher Dixon, Director of Nutrition, or designee, and submitted to the Accounts Payable Specialist for payment. Claims will be initialed or signed demonstrating approval of disbursements. Accounts Payable Specialist enters claims into the financial software and pays claims after approval by the Chief Financial Officer and School Board. Documentation for claims will be kept in the business office. GCS will obtain prior written approval from IDOE and approval documents will be maintained by the Director of Nutrition. Assistant Superintendent, Dr. Barry Younhans, retired from GCS in July 2022. This corrected the finding. To ensure compliance, the payroll distribution report is reviewed and signed by the Treasurer and applicable program administrators prior to the completion of payroll by the payroll specialist. The report is reviewed to verify that employees are paid out of the correct accounting line. This process was implemented in December 2022. Anticipated Completion Date: April 2023 INDIANA STATE

2022-002 Community Services Block Grant? CFDA No. 93.569 Noncompliance: Out of the forty expenditures tested, one expenditure included FY2022 and FY2023 amounts. The expenditure included amounts related to October 2022, which is after the federal award period of performance, but was expensed in full to the award as of September 30, 2022. Recommendation: We recommend that Management strengthen their processes, controls, and review over direct federal award expenditures and ensure compliance with Uniform Administrative Requirements. In addition, management should seek appropriate training for financial department staff to ensure proper cutoff of program expenditures. Responsible Person for Corrective Action: Megan Hannan, Executive Director Corrective Action to be Taken: Management and the fiscal agent will review end of year invoices for dates of service as they are processed for necessary accruals between fiscal years to validate charges to appropriate federal awards. Financial training will be provided as needed and requested to avoid future findings. The anticipated completion date for this corrective action is 9.30.23

Views of Responsible Official: Management of Canopy NWA concurs with the audit finding. The individual preparing the report this year did not realize that the disbursement date was outside of the recipient's grant period. The individual has been informed of the proper requirements, and management will perform a quality control review over future report submissions to ensure proper cutoff for reporting purposes. In addition, the funder has been notified and will receive $1,190 from Canopy to correct the error.

Finding 2022-003 Activities Allowed or Unallowed, Allowable Costs/Cost Principles and Period of Performance Material Weakness in Internal Control over Compliance and Material Noncompliance Finding Summary: Through testing of operational expenditures of the College, it was determined; o Payroll expenditures charged to the award were not for costs newly associated with the coronavirus, a requirement communicated within the supplemental guidance in the Higher Education Emergency Relief Fund III Frequently Asked Questions published May 11, 2021 and updated May 24, 2021. Through testing of disbursements to students, it was determined; o No support could not be provided to substantiate a secondary level of review was completed prior to disbursement of funds. o 26 instances identified in which the College directly controlled how student?s use their emergency financial aid grant. o 8 instances identified in which college discharged outstanding balance on student account for costs incurred prior to March 13, 2020. o 2 instances identified in which the College charged coronavirus vaccine incentive payments under the student portion of HEERF award. Responsible Individuals: Dr. Lane Azure, President Corrective Action Plan: o In response to the payroll finding, this was funded through MSI (no Student or Institutional funds were used for payroll). SWC president attended weekly meetings with American Indian Higher Education Consortium (AIHEC) who assisted and advocated for these HEERF monies for all Tribal Colleges and Universities (TCU). Handouts (attached) of slides were given to each institution and Payroll was an allowable cost with the exception of the President. The college president believed in order to allow the college to stay open and not lose students and staff, subsidies had to be included in payroll. There were no predictions on how long this world-wide pandemic was going to last or how much funds the government was going to give to IHE. SWC is a small tribal college where hiring and maintaining qualified personnel has been difficult long before the pandemic and now even more so. SWC could not afford to hire new staff even if it was feasible to find someone to fill new positions. Therefore, SWC used HEERF to make payroll on many employees whose job duties changed so they could assist the college in staying open and transition to a completely different method of delivering education to SWC students. SWC president was told by the Department of Education and AIHEC that these funds had to be exhausted in a limited amount of time. In addition, there was a limited number of items that the funds could be spent on, but it was changing every day to be more liberal. In March 2020, SWC had to begin offering courses via distance delivery which was a completely new method for this college. In summer 2020, the college did not offer classes and in fall 2020 SWC had to begin offering a hybrid method of delivery. Every single employee of this college had to do their day to day duties differently in order to support the new delivery method for education ranging from contact tracing, hyflex delivery, social distancing, hygiene, masking up, staff meetings, parking, teaching, and etc. The range of employees went from admissions, student services, academic staff, faculty, and the business office. All employees were coming in at different shifts, and/or working remotely, while social distancing. o The College will ensure documented secondary level of review and approval is retained. o For grant payments funded by institutional portion, Grant payments were applied to student accounts and if no outstanding balance, a check was given to the student. For grants funded by MSI, a formula was used to distribute $125 per credit and an allowance for books and fees. The COARS was a financial aid grant to the student who applied for the relief. o Any debt relief provided for students was for those students who could not attend the current academic year because of a prior balance. In order to attend college during the pandemic, MSI funds were used to discharge the student?s balance at the discretion of the student. o The checks for these instances were given directly to the student to defray costs of going to get the vaccine, for transportation, for cost of the office visit, or whatever it may have been they needed in order to get the vaccine. It was emergency aid to the student. Anticipated Completion Date: July 1, 2022

Significant Deficiency in Internal Control over Compliance and Other Matters 2022-004 Unallowable Costs U.S. Department of Health and Human Services Child Care and Development Fund Block Grant (CCDF) ? CRSSA (Coronavirus Response and Relieve Supplemental Act) Assistance Listing Numbers: 93.575 Recommendation: We recommend the program work closely with ASD to ensure expenditures are tracked and mapped to the appropriate federal award. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The ECECD ASD Director, CFO and Grants Manager will work with the Federal Program Team to develop formal policies and procedures for grant management to ensure compliance with programmatic grant requirements and track expenditures to ensure costs charged to grants are allowable, necessary, and reasonable. Name(s) of the contact person(s) responsible for corrective action: Ron Lucero, ASD Director; Carmel Pacheco-Aragon, Chief Financial Officer; Grants Manager (TBA); ECECD Program Managers. Planned completion date for corrective action plan: June 30, 2023

FINDING 2022-002 (Auditor Assigned Reference Number) Contact Person Responsible for Corrective Action: Austin Fruits Contact Phone Number: 317-535-7579 Views of Responsible Official: We concur with the finding that there was not an effective internal control system in place to ensure compliance with the Matching, Level of Effort, and Earmarking requirements in the Special Education grant. Description of Corrective Action Plan: The school corporation will continue to hold regular meetings with the nonpublic schools in our district to ensure they spend their allocations appropriately and timely. If the non-public schools do not spend their allocations within the grant period, Clark-Pleasant will request a waiver from the DOE to repurpose those funds in the grant. Anticipated Completion Date: 4/30/23

If an award is identified as originating from federal funds the Seaway Valley Prevention Council has put measures in place that trigger a system of trainings for involved personnel that require, they thoroughly review the Uniform Guidance 2 C.F.R. Part 200. Involved personnel are also provided a "Allowable Costs and Activities" desk reference. SVPC has also reviewed our internal control's structure and is implementing changes to comply with the Uniform Guidance. SVPC has also performed a thorough review of agency cost allocation methodologies to identify and correct inconsistencies with expense accounts reviewed and reclassified as necessary. Indirect/admin expense accounts have been grouped accordingly in our chart of accounts streamlining our expense review process.

The discrepancies in payroll reporting were identified by Youthprise during 2023. Management discovered that reports downloaded from the third-party processor were not accurately coding salary based on timecard reports submitted by some of its employees. Youthprise is working with its Human Resources consultant, who is working with the 3rd party payroll processor, to correct the reporting issues going forward. Youthprise will review its internal controls going forward to ensure sufficient oversight is maintained over its payroll processes to prevent or detect and correct misstatements on a timely basis.

Finding 2022-007 Personnel Responsible for Corrective Action: Assistant Comptroller ? Brian Huggins Anticipated Completion Date: June 2023 Corrective Action Plan: The University's current process is to collect and retain procurement documents for no less than five years. The institution will work to strengthen the current process in place relevant to securing adequate documentation. Supporting documentation was provided for data selection relating to the upgrades to the HVAC, ventilation, and the spacing of the academic facilities which were all completed in accordance with Covid guidelines. The University is working with our third-party payroll provider to automate time and effort reporting.. We are currently using paper forms for reporting until we can implement Time & Effort through ADP. The Director of Title III & Finance Compliance officer to further discuss time and effort.

Finding 2022-003 Personnel Responsible for Corrective Action: Director of Title III and Compliance ? Dr. Neidra Butler Anticipated Completion Date: July 2022 Corrective Action Plan: The University is working with our third-party payroll provider to automate time and effort reporting.. We are currently using paper forms for reporting until we can implement Time & Effort through ADP. The Director of Title III & Finance Compliance officer to further discuss time and effort.

Federal Awards Finding 2022-006 - Emergency Rental Assistance Eligibility Corrective Action Plan: Please see responses to 2022-002, 2022-004, and 2022-005. Responsible Official: Devon Manning, Director of Policy & Planning and Brian Rossello, Director of Housing Finance Completion Date: August 2021 Financial Statement Finding 2022-002 - Internal Control Over Compliance - United States Emergency Rental Assistance Program Corrective Action Plan: DSHA has implemented a Corrective Action Plan which it believes fully addresses the internal control weaknesses identified in connection with the audit finding of a material weakness related to DSHA?s operation of the Emergency Rental Assistance (?ERA?) program. The Corrective Action Plan is comprised of three key elements: 1. Implementation of a new software system that fully addresses certain process issues encountered with its existing software application. 2. Implementation of new process workflows and approvals performed by DSHA personnel to ensure proper approval of case applications and payment of approved applications to proper vendors. 3. Engaging an external consultant to analyze, verify and remediate, as required, applications processed in the predecessor software system. Each of these three elements is further discussed below. In August 2021, DSHA implemented a new software application to accept and process applications for the ERA program and replace its existing application. DSHA implemented this system as a means to correct and resolve the issues it was experiencing with respect to timely and accurate payment processing. The new system included significant improvements in workflow related to payment processing and account verification, as well as other needed program features. With the new software application, one of the root causes of DSHA?s application payment issues was immediately addressed, by eliminating the need to manually upload vendor payment information from its predecessor application to DSHA?s accounting system for payment. The prior manual upload process resulted in various vendor payment issues and erroneous payments. The new software application is a completely self-contained application, with workflow approvals that span from application submittal and approval to vendor payment. Each week all approved applications are automatically batched and sent to DSHA for approval prior to payment. This workflow has resolved previous issues where payments were not made timely for approved applications. The new software application incorporates significant improvements to payment processing and account verification. As mentioned above, there is no need to transfer or upload data between new software application and the accounting system to effect payments of approved applications. The new software application includes a verification process whereby the vendor ACH information is verified by a ?penny test? or small deposit that the user must verify. ACH payments can only be made to accounts that are verified. Once payments are made through new software application, batch details are imported to the accounting software via a custom interface for accounting system transaction reporting. Implementation of New Process Workflows, Approvals and Verifications by DSHA Coupled with the new software application implementation, DSHA implemented updated ERA Program Guidelines and new internal policy and process manuals to ensure its internal controls and processes appropriately addressed the compliance requirements of the ERA program and to ensure properly approved applications are paid to proper vendors. All cases in Approved Status are batched each week by the new software application and sent to DSHA for approval. DSHA reviews each of the approved applications within the batch and approves the batch once verified. At that point, requested funds are wired and payments issued by the new software application. This process has resolved previous instances of non-payment of approved cases. DSHA has developed new Case Auditor and Case Supervisor Process Guides and Checklists, which now standardize the processes used to review, verify and approve applications prior to payment. The new software application case management workflow requires separate Case Auditor and Case Supervisor verification of program requirements and payments prior to approval and payment of an application. Remediation of Prior Case Applications Processed in the predecessor application DSHA has engaged a third-party external consultant to assist it in ensuring that the applications processed in the predecessor application system resulted in payments to appropriate vendors for proper, compliant applications. The objective of this assessment is to identify any applications processed within predecessor application that resulted in either over or under payment to the vendor recipient. Once identified, these over and/or under payments will be remediated. These action plans have been implemented beginning August 2021 for the 2022 Fiscal Year and will remain in effect going forward. Responsible Official: Marlena Gibson, Director of Policy and Planning. Responsible Official: Marlena Gibson, Director of Policy and Planning. Financial Statement Finding 2022-004 ? Internal Control Over Compliance ? United States Emergency Rental Assistance Program Corrective Action Plan: DSHA will take these recommendations under advisement, and review program policies and procedures to ensure they are in accordance with statutory requirements. DSHA will ensure that staff responsible for processing DEHAP applications are training effectively in how to interpret and apply program policies and procedures, and will clearly communicate the expectation that review staff adhere to program policies and procedures consistently. DSHA would like to request clarification on Belfint's interpretation of the statutory requirement around security deposits. To our knowledge, UST has suggested applying a limit of one month's rent as guidance, but has not made this an actual requirement of the federal Emergency Rental Assistance Program. Responsible Official: Marlena Gibson, Director of Policy and Planning.

Finding #2022-002 ? Grant Program: Department of Transportation Airport Improvement Program ? Assistance Listing #20.106 The Great Falls International Airport Authority agrees with the audit recommendations. This was a unique program that unlike other grants allowed us to be reimbursed for operating expenses and likely will never be seen again. The Authority normally receives grants for capital projects each year through the Airport Improvement Program (?AIP?). The Airport employee?s professional construction managers for these projects, such that the normal process is that a contractor invoice is submitted, reviewed and recommended for payment by our construction manager and then submitted for reimbursement from AIP. The COVID relief grants used to reimburse operating costs did not follow this normal process and controls. We will correct the issue identified by re-structuring the process of handling and reconciliation of the grant funds. Airport Accountant, Chayleen Person, will be the one handling the federal funding reimbursement requests. Actions, responsible individuals, and anticipated completion date: - Airport Accountant, Chayleen Person, will handle the reimbursement requests and the review of the federal funding. - Airport Accountant, Chayleen Person, will reconcile these funds monthly to ensure the federal account matches our GL account.

2022-004 ? Allowable Costs/Activities Allowed or Unallowed: Indirect Cost Name of Responsible Individual(s): Pamela Aguilera, Chief Financial Officer. Corrective Action: Safe & Sound?s Finance team implemented policies and procedures to ensure the indirect cost rate is calculated based on modified total direct costs, which excludes amounts over $25,000 for subawards. We updated our formulas to ensure that we properly calculated indirect costs on a monthly basis, ensuring the exclusion of subawards over $25,000. Date Completed: 7/31/2023

2022-003 ? Allowable Costs/Activities Allowed or Unallowed: Fringe Benefits and Shared Costs Name of Responsible Individual(s): Pamela Aguilera, Chief Financial Officer Corrective Action: During the initial year of receiving our first direct federal grant, Safe & Sound calculated fringe benefits based on a percentage of the salaries allocated to the grant. Salaries were calculated based on time and effort. Safe & Sound has reviewed the current practices related to allocating fringe benefits and shared costs. Safe & Sound?s Finance team reviewed and verified that we have the adequate fringe benefit and shared costs to meet the costs allocated to this grant. To ensure we have the proper supporting documentation to meet the Uniform Guidance requirements in 2 CFR Sections 200.303 and 200.403, we will implement time and effort documentation for benefit and shared cost allocations on a monthly basis and will review for any necessary budget to actual adjustments. Date Completed: 8/31/2023

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 ALN: 84.027, 84.173 Federal Award Numbers and Years: 19611-045-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Matching, Level of Effort, Earmarking Audit Findings: Material Weakness Context: The School Corporation is a member of the Northwest Indiana Special Education Cooperative (Cooperative). During fiscal years 2020-2021 and 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, and Earmarking compliance requirements. 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 lack of internal controls and noncompliance was isolated to the 19611-045-PN01 and 20611-045-PNO1 grant awards. The Non-Public Proportionate Share expenditures for the 19611-045-PN01 grant award could not be verified for the individual member schools. The non-public school share funds for all member schools were comingled and the aggregate amount of expenditures was then allocated to the member schools ona percentage basis. These allocations were the amounts reported to IDOE. As such, we were unable to identify which expenditures were for each school in order to verify the minimum amount per the grant award was expended and properly reported to IDOE as required. The School Corporation?s minimum earmarking requirement for the 19611-045-PNO1 grant award was $6,228. The Non-Public Proportionate Share expenditures for the 20611-045-PN01 and 21611-045-PNO1 grant awards could not be verified for the individual member schools. The non-public school share funds for all member schools were comingled and the aggregate amount of expenditures was then allocated to the member schools on a percentage basis. These allocations were the amounts reported to IDOE. As such, we were unable to identify which expenditures were for each school in order to verify the minimum amount per the grant award was expended and properly reported to IDOE as required.Views of Responsible Officials and Planned Corrective Actions: The district agrees with the finding and notes as a member of the Northwest Indiana Special Education Cooperative (NISEC), Tri-Creek School Corporation reported their proportionate share based on a percentage of expenditures and had successful audits in doing so. When the Tri-Creek School Corporation was notified that this process was no longer acceptable, we immediately implemented an internal control process with NISEC which included a detailed reporting of staff work hours for nonpublic schools related to only our school corporation. The report is then reviewed and signed by the NISEC staff working for the nonpublic school and their supervisor. The employee's detailed time and effort report is then provided to the NISEC finance department for a second review and signature before being provided to payroll. NISEC payroll then charges the proportionate share to the IDEA Part B grant in the payroll system bi-weekly based on the time and effort report pertinent to just Tri-Creek Non-Public schools. The time and effort reports are then used to submit the reimbursement request to the Department of Education for Tri Creek?s proportionate share. Additionally, any IDEA Part B nonpublic material expense is broken out in detail with Tri-Creek?s proportionate share for approval by the NISEC finance office prior to vendor payment and the reimbursement request is submitted to the Department of Education. Responsible party and timeline for completion: Responsible parties: Lisa Rosinko, Northwest Indiana Special Education Cooperative Chief Financial Officer Anticipated Completion Date: The Northwest Indiana Special Education Cooperative discontinued reporting nonpublic proportionate share expenditures by percentage as of the 2022-2023 school year. An internal control procedure to report nonpublic proportionate share expenditures by detailed time and effort work and expenditures was implemented as of the 2022-2023 school year.

Finding 2022-003 ? Allowable Costs (Significant Deficiency and Non-compliance) Corrective Action: The ARPA?s stated purpose is for housing provision, stabilization services, and eviction prevention. The rental assistance funds may be used for arrearage, forward payments, deposits, late fees, and utilities. The grant provides separate application forms for rental assistance and utilities assistance. The grant does not require maximizing the amount paid on behalf of applicants. Every disbursement involves obtaining documents from the applicant and the landlord. The landlord signs an agreement stating they will allow the client to remain housed by accepting the payment. It is common to negotiate the agreed upon amount because some landlords include fees in their amounts that are not allowable under the grant or ask for more months of assistance that is allowed. The disbursements tested included agreements that were all signed and accepted by the landlords. LSA documented the costs which were reimbursed by the funder. One of the payments included a document that had not been updated. The payment included an additional month?s rent due to the time lag between the start of the application and the completed documents and the revised total amount was included on the signed landlord agreement. In this case, the agreement did not include an additional late fee that would have been expected per the terms of the lease. The landlord accepted the payment less the late fee. LSA staff will document negotiated amounts that are different from the support and provide explanation and the amount included or excluded. A second payment did not include a beginning ledger balance. The landlord charges an insurance fee that is not covered by the grant. Rather than attempting to determine if the balance forward was due to eligible charges or ineligible charges, the amount was excluded from the total. The documentation attached did not specifically mention that the amount was excluded, but a handwritten total of the included charges was included. LSA staff will document negotiated amounts that are different from the support and provide explanation and the amount included or excluded. The third payment was deemed an exception because the reimbursement did not include the client?s utilities charges. Although the charges are eligible under the grant, the applicant and landlord did not request assistance with utilities. LSA staff will document negotiated amounts that are different from the support and provide explanation and the amount included or excluded. Regarding employee time for the program, LSA staff will look for solutions to help prevent time entry errors, and the Finance Department will conduct a review of every grant report. LSA will review if changes can be made in the timekeeping system to restrict certain fund sources from being applied to programs, to enhance controls over time attributed to particular funding. The grant report review will also include a review of program reports when new staff join the program to ensure the time activity is correct and can be allocated as reported. LSA will complete a review of the timekeeping system and procedures by the end of the second quarter 2023 and implement changes by the third quarter of 2023. The grant report review will commence as of the date of this audit report. Contact Person: David Roberson, Director of Finance; (334) 223-0251; droberson@alsp.org