Corrective Action Plans

The Board will require approval for such expenditures made in short succession and for the bid process to be followed as required by law when the ultimate result of the transaction is a purchase of goods or services of an amount exceeding $20,000.

Planned Corrective Action: A former Board member with finance and operations experience has been tasked with reviewing financial policies and procedures to ensure compliance in all areas. Policies and procedures will be updated with new processes. To date there have been two changes implemented. Finance staff must now attach electronic copies of invoices within the accounting system to corresponding transactions in order to process payment. In addition, a report of credit card charges missing required documentation is circulated to management monthly, with follow-up to the individual purchasers. Training for all members of the department will occur on an ongoing and regular basis to ensure best practices are being upheld. Policies and procedures and/or the Financial Procedures Handbook will also be updated to reflect the changes.

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 Federal Award Number: S425D200012 (Year: 2020) Questioned Costs: $129,375.00 Repeat of Prior Year Finding: None Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over expenditures as it relates to the Elementary and Secondary School Emergency Relief Fund program. Corrective Action Plans: The Whitfield County School District does not concur with the finding; therefore, no corrective action is necessary. Estimated Completion Date: The expense was approved and paid in the fiscal year 2022. Contact Person: Kelly Coon Telephone: 706-217-6704 Email: Kelly.coon@wcsga.net

The bulk cable contract was cancelled effective 9/1/22. On March 15th, 2023 the Board of Commissioners made a motion to end the contract. According to the contract we had to honor a 60-day notice and that ends officially on Monday May 15th.

Alluma, Inc. Single Audit Corrective Action Plan Year Ending December 31, 2022 Audit Finding 2022-002: Contact Person Tammy Hickel Zola, CFO Corrective Action Plan Ensure specific CFR training to employees responsible for managing federal grant requirements as well as implementing additional procedures to ensure compliance with necessary and reasonable costs. Completion Date Alluma will expand training and internal controls in 2023.

FINDING 2022-002 Contact Person Responsible for Corrective Action: Dr. William Stitt, Superintendent Contact Phone Number: 260-495-5005 Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding. Fremont Community Schools will work with NEISEC to ensure proper oversight and internal controls are in maintained. Anticipated Completion Date: Corrective action plan will be implemented by June 30, 2023.

FINDING 2022-002 Contact Person Responsible for Corrective Action: John Szabo, Director of Business Affairs Contact Phone Number:812-443-4461 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: In order to monitor allowable costs, the Food Services Director (currently Patricia Woolery) will review billing statements and insure that costs being billed to the school corporation are consistent with purchasing agreements that are in place. Food Services Director will communicate with vendors and review any communication from vendors in regards to price variance of items. Even though it may not be reasonable to double check each individual item ordered, Food Services Director will spot check an appropriate number of items to insure accuracy of costs. Anticipated Completion Date: August 1, 2023

FA 2022-001 Improve 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 Federal Award Number: S425D210012 (Year: 2021) Questioner Costs: $119,600 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: The Superintendent and HR Director have contacted the temporary placement vendor (ESS) to obtain an amendment for the additional bonuses that were paid. The new amendment has been received. In addition, an amendment will be obtained for any future payments that are given in addition to the original contracted amount. Estimated Completion Date: Completed May 24, 2023 Contact Person: Tomecka Woody, CFO Telephone: 706-441-0601 (x1007) Email: tomecka.woody@mcssga.org

2022-006: Internal Control Over Compliance and Compliance with Period of Performance Management is emphasizing prompt period closing to ensure that know Items are recorded in the wrong period. New layers of internal control have been added to ensure detailed review of accounting transactions. The ERM department is in the process of hiring an international compliance director, whose team will work as the second set of eyes (internal audit function) to ensure compliance. Individual(s) Responsible for Corrective Action Plans: Simon Peter Kabogoza, Controller, Heartland Alliance International skabogoza@heartlandalliance.org Anticipated Completion Date: 12/2023 Anticipated Completion Date:

Finding 2022-005: Internal Control Over Compliance and Compliance with Period of Performance Management through the local offices has already developed a policy to ensure that the period of performance is adhered too. Management is in the process of hiring another international compliance officer in both US and Iraq to particularly focus on grants performance requirements and sub-recipient grants management. Management through its Enterprise risk management is planning to schedule trainings for various departments concerning period of performance. Individual(s) Responsible for Corrective Action Plans: Simon Peter Kabogoza, Controller, Heartland Alliance International skabogoza@heartlandalliance.org Anticipated Completion Date: 12/2023

Finding 2022-003: Internal Control over Compliance and Compliance with Allowable Costs/Cost Principles Management has developed a policy in the Iraq local office to aid in time & Effort allocation. The HR leadership is exploring on maximizing the existing Local HR software (Bamboo) to provide more automated allocation and to store all back up information/supporting documentation for the payroll payments for our international offices more especially Iraq. Our Colombia office working with a software company developed a timesheet application that has allowed them to automate their time sheets. Since everything from entering time, approval and reviews are automated; the office is now able to compliance with internal controls in the timesheet allocation area. Individual(s) Responsible for Corrective Action Plans Tatiana Herrera, Director of Finance & Operations ? Colombia therrera@heartlandalliance.org Simon Peter Kabogoza, Controller, Heartland Alliance International skabogoza@heartlandalliance.org Anticipated Completion Date: 07/2023

Finding 2022-002: Internal Control over Compliance and Compliance with Allowable Costs/Cost Principles Management through the local offices has already developed a policy to ensure that the period of performance is adhered too. Management is in the process of hiring another international compliance officer in both US and Iraq to particularly focus on grants performance requirements and sub-recipient grants management. Management through its Enterprise risk management is planning to schedule trainings for various departments concerning period of performance. Individual(s) Responsible for Corrective Action Plan: Rebecca Obrock, COO-HAI robrock@heartlandalliance.org Regina Trillo, Director of grants Compliance ?ERM rtrillo@heartlandalliance.org Simon Peter Kabogoza, Controller, Heartland Alliance International skabogoza@heartlandalliance.org Anticipated Completion Date: 12/2023

FA 2022-001 Strengthen Controls over Federal Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principles Period of Performance 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 COVID-19 84.425W ? American Rescue Plan Elementary and Secondary School Emergency Relief Fund Federal Award Number: S425D20012 (Year: 2020), S425D210012 (Year:2021), S425U2120012 (Year:2021), S425W210011 (Year: 2021) Questioned Costs: $117,383 Repeat of Prior Year Finding: None Description: A review of expenditure charged to the American Rescue Plan Elementary and Secondary School Emergency Relief Fund program (Assistance Listing Number 84.425U) revealed that the School District?s internal control procedures were not operating appropriately to ensure that expenditures were allowable for the program. Corrective Action Plans: The district administration will reach out to a program specialist when additional guidance is needed on a purchase regarding ESSER federal grants. Moving forward the Board of Education will not make purchases, using ESSER funds, that extend past the end of the period. Estimated Completion Date: July 1, 2022 Contact Person: Steve Loughridge Telephone: 706-695-4531 Email: steve.loughridge@murray.k12.ga.us

Contracts charged for expenses outside of the period of performance have been credited for ineligible expenses. Share's Director of Finance, Christopher Brox will provide training to accounting staff responsible for expense entry, expense review and approval, and invoicing by June 30, 2023 that include the following topics: - Allowability of expenses based on both contract criteria and the period of performance. - key identifiers that could flag an exception in allowability based on period of performance, and how to catch this in the review of expenses. - General ledger transactions that require further review for period of performance allowability during monthly review of expenses prior to preparing invoices. This training will highlight this being a specific area of focus for review during periods when a contract terms and a new contract starts. This training will happen with all new accounting staff responsible for expense entry and review and will be incorporated as refresher trainings if contract and grant administrator expense reviews identify this as being a continued issue by staff performing expense data entry.

FA 2022-001 Strengthen Controls over Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principle 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 Federal Award Number: S425D200012 (Year: 2020), S425D210012 (Year: 2021) Questioner Costs: $187,246 Prior Year Finding: No Description: A review of expenditures charged to the Elementary and Secondary School Emergency Relief Fund program revealed that the School District's internal control procedures were not operating appropriately to ensure that expenditures were allowable. Corrective Action Plans: The questioned cost noted above was considered for financial reporting purposes, and a prior period adjustment to classify the expenditure to the appropriate grant was made in March 2023. In addition, the questioned cost amount was not included in the Schedule of Expenditures of Federal Awards for the year-ended June 30, 2022. In the future, the School District will review all federal expenditures for appropriateness appropriateness and allowability including a budget to actual comparison and follow-up on any significant differences. In addition, the program manager of each grant will review the details of all grant activity as part of the year-end process to ensure completeness. Estimated Completion Date: Effective with June 30, 2023 Year-End Process Contact Person: Melanie James, Assistant Superintendent of Business and Finance Telephone: 912-851-4000 Email: mjames@bryan.k12.ga.us

Certain one-time COVID funds required several departments to make purchases. The lack of specific and clear guidance as to which department was directly responsible resulted in questioned expenditures. District Financial procurement procedures have been updated and implemented that require all federal expenditures to be approved through Lawton Public Schools? Federal Programs office. In addition, all supporting invoices for said expenditures must be provided to and approved by Lawton Public Schools? Federal Programs office. Lawton Public Schools will reimburse the State Department of Education for the total of these questioned costs.

FINDING 2022-007 Contact Person Responsible for Corrective Action: Nicole Wolverton, CFO Contact Phone Number: 219-881-5536 Views of Responsible Official: We concur with the audit finding. Description of Corrective Action Plan: A policy and procedure will be created to ensure that all supporting documenation of employee?s time and effort logs are reviewed and retained when paying salary from Federal Title I grant allocations, including review and approval of pay rates and fund distributions that are entered by the payroll department, reviewed by Federal Programs, with final review of accuracy and completeness by the Chief Financial Officer. Anticipated Completion Date: Gary Community School Corporation will implement this procedure by September 2023. INDIANA STATE

FINDING 2022-002 Contact Person Responsible for Corrective Action: Nicole Wolverton, CFO Contact Phone Number: 219-881-5536 Views of Responsible Official: We concur with the audit finding. Description of Corrective Action Plan: As it relates to activities allowed or unallowed for Child Nutrition, a new policy and procedure will be implemented for requiring appropriate documentation from the Food Service Vendor. The policy will require the vendor to provide all supporting invoices for food purchased and time sheets for time and labor records. In addition, this policy and procedure will ensure the correct indirect cost allocation when submitting the application and required documentation to the Office of School Finance. This application submission will be prepared by the Chief Financial Officer and reviewed by the GCSC Manager to ensure accuracy and completion. The policy will contain language specific to the consideration of direct and indirect cost calculations and providing all supporting documentation for the determination of allowable and unallowable costs. GCSC will ensure indirect costs are charged according to the approved indirect cost rate. As it relates to special test and provisions to the School Food Accounts, a procedure will be implemented for the recording of receipts and expenditures within the food service accounts and the timeliness of the account reconciliations to be completed by the District Treasurer. Anticipated Completion Date: Gary Community School Corporation will implement this procedure by September 2023.

Finding 2022-003: Reportable Finding ? Disbursement Cutoff Description: The Distilled Spirits Council of the U.S. acknowledges the need to improve our processes regarding the recording and reconciliation of grant expenses. We are taking proactive steps to address this issue and ensure accurate tracking and reporting of grant spending. Our dedicated teams, including the international team and the finance team, will implement enhanced procedures to review, record, and reconcile grant disbursements. These measures include thorough reviews by our Controller, meticulous recordings by our Accounting Associate, and regular reconciliations between the international and finance teams to ensure invoices are recorded in the proper period when services are performed. Anticipated Completion Date: October 1, 2023 Responsible Contact Person: Name: Kyna Ricks Position: Controller Email: kyna.ricks@distilledspirits.org Phone: 202-682-8869

Submit indirect cost rate and support the cost through tracking and allocating administrative costs/overhead for each grant, which O'Leary & Anick can support for Michael Fields Agricultural Institute. Contact person: Shannah Schmitt, MFAI, and Kevin O'Leary, O'Leary & Anick. Anticipated date of completion: December 2023.

Management Response: Hibiscus is using eCR data verifying time value related services based on VOCA allowable cost. In addition, updates were made on time sheet for providers detailing actual percentage of services. Cost reimbursements submitted were reviewed, verified, and approved by VOCA.

Brookwood School District 167 07-106-1670-02 CORRECTIVE ACTION PLAN FOR CURRENT YEAR AUDIT FINDINGS Year Ending June 30, 2022 Corrective Action Plan Finding No.: 2022-002 Condition: The District's expenditure population was less than amounts claimed by $5,617. The District was unable to identify and support expenditures for this difference. Plan: The District will implement additional review procedures to ensure that expenditure claims submitted for reimbursement agree to supported transactions within the accounting system for allowable costs under the award. Anticipated Date of Completion: June 30, 2023 Name of Contact Person: Mr. Kevin Slattery, C.S.B.O. Business Manager

Finding Number: 2022-003 Condition: The Corporation transferred $70,590 of expenditures to ALN 17.258, 17.259 and 17.278 - WIOA Cluster from another grant. There was no support to document the rationale for the transfer or to support allowability. Planned Corrective Action: DESC has updated fiscal policies and procedures requiring supporting documentation for all journal entries which has been reviewed with all fiscal staff. Additionally, a review of the supervisor requirements to review the support documentation prior to approval has been completed. Additionally, the Abila MIP financial accounting system has been updated to allow for supporting documentation to be attached to each individual journal entry. Finally, a SharePoint site has been created for all supporting documentation to be stored for access by the appropriate staff members. Contact person responsible for corrective action: Angela Smith, Neeyn Bland and Lynnette Robinson ? Accounting Manager, Fiscal Manger and Senior Fiscal Manager respectively. Anticipated Completion Date: 06/30/2023

FINDING 2022-001 Information on the federal program: Subject: Special Education Cluster (IDEA) - Earmarking Federal Agency: Department of Education Federal Program: Special Education Grants to States Assistance Listing Number: 84.027 Federal Award Number: 20611-001-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking Audit Findings: Significant Deficiency Condition: The School Corporation is a member of the Adams Wells Special Services Cooperative (Cooperative). During fiscal year 2021-2022, 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 (IDOE) and each member school, the school corporation was responsible for ensuring and providing oversight of the Cooperative. 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. Context: The Non-Public Proportionate Share expenditures for the 20611-001-PN01 grant award could not be verified for the individual member schools. Total non-public expenditures were posted as expended. The member school proportionate share expenditures were then determined by applying a budgeted percentage to the total non-public expenditures. These were the amounts reported to IDOE. As such, we were unable to identify if the minimum amount per member school was expended and properly reported to IDOE as required. The School Corporation?s Non-Public Proportionate Share for the 20611-001-PN01 grant application was $10,523. Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Co-ops cannot combine proportionate share funds. Funds must be spent within each LEA?s geographic boundary. We will not receive a repeat finding for FY21. We will correct for FY22 and forward. Time & Effort Logs are being completed to show how many hours personnel are servicing Non-Pub school students with a service plan. If materials and Equipment are purchased for a specific student?s need, per the service plan, then those expenditures are 100% school specific. Per the DOE, Materials used by our Speech Language Pathologist for Speech Therapy for all six school corporations, those expenditures are split evenly across all school corporations with a non-pub proportionate share allocation. Responsible Party and Timeline for Completion: Adams-Wells Special Services Cooperative is the responsible party for the timeline completion. No later than January 2023, the Cooperative will have corrected proportionate share monitoring workbooks for FY22 and the ARP grants.

Assistance Listings number: 17.258 WIOA Adult Program; Assistance Listings number: 17.259 WIOA Youth Activities; and Assistance Listings number: 17.258 WIOA Dislocated Worker Formula Grants Contact Person(s): Jeremy Flowers, WIOA Executive Director and Lisa Grannis, WIOA Board Clerk and Compliance Specialist Anticipated completion date: June 30, 2023 Concur. The nonprofit organization was created in part to serve as the administrative arm of the Local Board and to provide a location for a resource center where WIOA services would be provided. The County did not distinguish fiscal responsibilities between parties and therefore assumed that certain expenditures of the Local Board and nonprofit would be allowable and could be paid directly by the County. The County considered the expenditures of the nonprofit to be program related, even though they were not directly incurred by the County. The County will improve its accounts payable policies and procedures for processing invoices using established process within the Finance Department, including ensuring all invoices are addressed to the County prior to payment. In addition, the County will establish clear contractual agreements that establish fiscal responsibilities that follow the program?s requirements. Finally, the County will coordinate with the pass-through grantor for the repayment of the unallowable costs identified in the finding.