Corrective Action Plans

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

Program: AL 20.509 ? Formula Grants for Rural Areas ? Allowability & Subrecipient Monitoring Corrective Action Plan: The Controller Division, Audit Section, will provide support through continued engagement and work collaboratively as an additional resource to the NDOT Transit staff and transit recipients. NDOT Transit staff in collaboration with the Controller Division will be improving the standard operating Procedures which will be utilized for the in-depth review of monthly invoices moving forward. Contact: Khalil Jaber Anticipated Completion Date: Ongoing

Program: Various, including AL 93.778 ? Medical Assistance Program ? Allowable Costs/Cost Principles Corrective Action Plan: The Print Shop will complete a detailed analysis on the analyzed data, and update rates. State Accounting will offset rates to spend down its fund balance to a 60-day operating level. Contact: Philip Olsen / Ann Martinez Anticipated Completion Date: June 30, 2025

Program: AL 84.010 ? Title I Grants to Local Educational Agencies ? Allowability and Subrecipient Monitoring Corrective Action Plan: The Department will contact the two subrecipients noted to provide one-on-one technical assistance and will also provide additional technical assistance regarding proper time and effort documentation to all subrecipients. Additionally, time and effort guidance is available to all subrecipients on the Department?s website, will be discussed at upcoming subrecipient training opportunities and supported by a dedicated Grants Management Training Specialist. The Department will ensure the identified written deficiencies noted in the subrecipient fiscal monitoring exit letter clearly identifies a finding vs. technical assistance needed; whereas a finding is supported by follow-up in accordance with federal UGG regulations and technical assistance provides knowledge of the Department?s training and resources available. Contact: Jen Utemark, Budget and Grants Management Anticipated Completion Date: December 31, 2023

Program: AL 93.558 ? Temporary Assistance to Needy Families; AL 10.561 ? State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; AL 93.658 ? Foster Care Title IV-E ? Allowable Cost/Cost Principles Corrective Action Plan: DHHS will continue to train staff on the proper RMTS procedures, which includes correct method of validation. Contact: Patrick Werner Anticipated Completion Date: 06/30/2023

Program: Various, including AL 10.561 ? State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; AL 93.558 ? Temporary Assistance for Needy Families; AL 93.566 ? Refugee and Entrant Assistance State/Replacement Designee Administered Programs; AL 93.575 ? Child Care and Development Block Grant ? Allowable Costs/Cost Principles Corrective Action Plan: Several areas within DHHS are currently working to improve upon the process of determining how staff are paid during the hiring process and when turnover occurs. Contact: Patrick Werner Anticipated Completion Date: 02/01/2024

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

FA 2022-001 Improve/Strengthen Controls over Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principle Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: COVID-19 - 84.425D - Elementary and Secondary School Emergency Relief Fund COVID-19 - 84.425U - American Rescue Plan Elementary and Secondary School Emergency Relief Fund Federal Award Number: S425D200012 (Year: 2020), S425D210012 (Year: 2021) S425U2120012 (Year: 2021) Questioned Costs: $104,640.00 Prior Year Finding: None Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over expenditures as it relates to the Elementary and Secondary School Emergency Relief Fund program. Corrective Action Plans: We concur with this finding. The process used to pay retention pay to staff has been reviewed and will only be a paid to staff employed by the Appling County Board of Education. Estimated Completion Date: 5/5/2023 Contact Person: Adrienne Taylor, CFO Telephone: (912)367-8600 Email: Adrienne.taylor@appling.k12.ga.us

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

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

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

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

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

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

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

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

Reference Number: 2022-018 Prior Year Finding: 2021-014 Federal Agency: U.S. Department of Health and Human Services State Department Name: Department of Health and Social Services State Division Name: Division of Medicaid and Medical Assistance Federal Program: Children?s Health Insurance Program (CHIP) Assistance Listing Number: 93.767 Award Number and Year: 2205DE5021 (10/1/2021 ? 9/30/2023) Compliance Requirement: Period of Performance Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Recommendation: The Division should review and enhance internal controls and procedures to ensure that it charges expenditures to the program that are incurred within an award?s allowable period of performance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: DMMA will review reported expenditures based on the date of the federal draw to ensure that the expenditures occured within the period reported. Name(s) of the contact person(s) responsible for corrective action: Unkyong Goldie Planned completion date for corrective action plan: September 30, 2023