Corrective Action Plans

Finding: 2022-002 Material Weakness in Internal Control over Compliance and Material Noncompliance U.S. Department of Labor Federal Financial Assistance Listing 17.258/17.259/17.278 WIOA Cluster Activities Allowed or Unallowed Finding Summary: The County?s expenditures identified as eligible and claimed under the WIOA Cluster program were disallowed by the United States Department of Labor due the lack of appropriate documentation justifying specific costs charged to the program related to one vendor ? Garcia Professional Services, LLC. Also, the contract entered into with Garcia Professional Solutions, LLC. did not adequately address the required contract terms as follows: 1. Total dollar value of the contract to justify procurement method utilized. 2. Terms for payment to ensure payments are only made for verified services received and adequately documented. 3. Contract provisions stipulated in Appendix II to Part 200 of the Uniform Guidance, including Equal Employment Opportunity, Rights to Inventions Made Under a Contract or Agreement, Debarment and Suspension, and Byrd Anti-Lobbying Amendment. Responsible Individuals: Dana Aschenbrenner, Finance Director Corrective Action Plan: Johnson County disagrees with the underlying premises of this finding. The expenditures referred to above were expenditures of the East Central Iowa Workforce Development Board (ECIWDB) and not direct expenses of the County. The ECIWDB contracted with Johnson County to provide fiscal agent services. The ECIWDB then entered into a contract with Garcia Professional Solutions, LLC (?GPS?) to provide administrative support services for the Board. Iowa Workforce Development did not provide adequate guidance to ECIWDB as to the DOL-required terms and the terms of that services contract between ECIWDB and GPS did not contain any standards of documentation which DOL later claimed applied to said contract. The County had no input into the contract between the ECIWDB and GPS, nor was the County a party to said contract. Any alleged deficiencies within that contract between the ECIWDB and GPS are solely the responsibility of the ECIWDB Board and/or Iowa Workforce Development. In our fiscal agent role, the County was obliged to honor payment requests submitted to the Board; in that regard we had to make payments to GPS provided those payment requests were invoiced to ECIWDB consistent with the ECIWDB-GPS contract, which they were. Anticipated Completion Date: Ongoing

FINDING 2022-005 CONTACT PERSON RESPONSIBLE FOR CORRECTIVE ACTION: Ralph Shrader/Jim Beyer CONTACT PHONE NUMBER: 765-762-3364 VIEWS OF RESPONSIBLE OFFICIAL: We concur with the finding. DESCRIPTION OF CORRECTIVE ACTION PLAN: School Corporation will advertise and attain sealed bids for projects as required by Federal guidelines. Detailed contracts and invoices will be required by the bidder before payment is made. ANTICIPATED COMPLETION DATE: March 2023

FINDING 2022-002 CONTACT PERSON RESPONSIBLE FOR CORRECTIVE ACTION: Lacey Sturgeon/Melissa Bell CONTACT PHONE NUMBER: 765-762-2500 VIEWS OF RESPONSIBLE OFFICIAL: We concur with the finding. DESCRIPTION OF CORRECTIVE ACTION PLAN: All claims/invoices will be reviewed by the Food Service Director and validated by the Assistant Food Service Director for correct contractual prices. ANTICIPATED COMPLETION DATE: March 2023

Management is in agreement with this finding and was aware of the Organization?s manual process to approve and store physical copies of pay rate approval, which could potentially create risk of losing physical copies. In September 2022, the Organization has modified this process to allow managers to virtually approve and store digital copies of pay rate documentation.

Finding 2022-002 ? Special Education Cluster - Earmarking Contact Person Responsible for Corrective Action: Brittany Treesh Contact Phone Number: 260-357-3185 Views of Responsible Official: The school corporation concurs with the finding. Description of Corrective Action Plan: Garrett-Keyser-Butler Community School District (GKB) will work with the Northeast Indiana Special Education Cooperative to implement the procedures detailed below. The Northeast Indiana Special Education Cooperative (NEISEC) Treasurer will reach out to GKB during the writing process of the IDEA 611 and 619 grants in order for GKB to submit their plans for their allocation of proportionate share money. NEISEC will provide the allocation amounts to GKB. These submissions will include a proportionate share budget and include proportionate share staff names and any necessary information for the budget categories. The NEISEC Treasurer will then compile the proportionate share information and include on the grant submission. The LEA Treasurer will be given a copy of the grant application and budget upon approval of the grant. Any NEISEC employee being paid out of proportionate share grant funds for salary and benefits will be paid from the LEA?s financial software. The LEA Treasurer will keep a spreadsheet of employee proportionate share expenses and this spreadsheet will be updated monthly based on time and effort logs that are submitted by GKB to the LEA and NEISEC. Any employee utilizing proportionate share funds that is not an employee of NEISEC, but rather a direct employee of GKB, will be paid directly by GKB. Time and effort logs will still be submitted to the LEA and NEISEC Treasurers for these employees in order to generate a direct reimbursement from the grant fund to GKB. For any expenses for a category outside of salary and benefits, GKB will need to submit an invoice and proof of purchase for equipment, supplies, etc. to NEISEC and the LEA in order to be directly reimbursed for those proportionate share expenses. If the request was not in the initial grant budget, GKB must submit all relevant information to NEISEC in order for a grant modification to be completed. Per IDOE the grant modification must be approved first prior to purchasing the items. Time and effort logs as well as invoice and proof of payment must be sent to the LEA Treasurer in order to complete the grant reimbursement requests. At the end of the grant period, any remaining proportionate share money will require that a waiver be completed. As of this date (2/10/2023) the LEA (DeKalb County Eastern CSD) and NEISEC are still in communication with SBOA and IDOE to review the proportionate share plan and ensure all necessary requirements will be satisfied. Anticipated Completion Date: Changes discussed above will be implemented for the remainder of the FY23 grant period starting 07/01/2023.

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.