Corrective Action Plans

Identifying Number: 2022-009 Finding: Period of Performance: payroll costs Corrective Actions Taken or Planned: UCAN agrees with this finding and is committed to strengthening internal controls to ensure that amounts are properly recorded and reported. UCAN has already taken steps to insure that items are billed in the period incurred and only items that fall into the grant period are billed. We believe that significant turnover in the finance department led to this deficiency, so we are actively documenting procedures and cross-training employees, so we always have coverage. All vouchers will also go through a review process before they are sent to the funder. This is a repeat finding, with the original corrective action plan to be completed before June 30, 2023. We do believe that corrective actions that have been taken have resolved this issue. Contact person is Kimberly Parish, Chief Financial Officer and she can be reached at kim.parish@ucanchicago.org.

Finding 2022-002 - Controls Over Payroll Expenditures (Material Weakness): Criteria: 2 CFR 200.403 establishes principles and standards for determining costs for federal awards carried out through grants, cost reimbursement contracts, and other agreements with state and local governments. To be allowable, under federal awards, cost must meet certain criteria: a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. c) Be consistent with policies and procedures that apply uniformly to both federally- financed and other activities of the non-Federal entity. d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. g) Be adequately documented. h) Cost must be incurred during the approved budget period. Additionally, 2 CFR 200.303 indicates that non-Federal Entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award current staff initiates and monitors pay advices. These documents are being transmitted electronically for review by all parties and to preserve records.

FINDINGS ? FEDERAL AWARD PROGRAM AUDIT SIGNIFICANT DEFICIENCY 2022-002 Coronavirus State and Local Fiscal Recovery Funds ? Assistance Listing No. 21.027 Recommendation: YWCA should establish written policies and procedures to provide for timely and appropriate review and approval for period of performance. Action Taken: We concur with the recommendation and have developed the following plan. YWCA Madison, Inc., in compliance with guidance set forth in the Uniform Guidance 2 CFR section 200.303, will develop written policies and procedures on what, when, and who is responsible for review and approval for period of performance for YWC Madison funding. Additionally, YWCA Madison, Inc. will create a grant tracking checklist with key details for the funding including the performance period, total funding amount, allowable costs, the program or department funding is to be used for, etc. The checklist will also include an approval section for YWCA Madison finance team members to complete indicating their review of costs charged to the funding source at the beginning and the end of the performance period. The monitoring checklist will be updated to add a review of any new grant tracking checklists for the month as part of its internal controls checklist. The monitoring checklist will be reviewed monthly by the CEO and the review will be documented.

Policies, procedures and controls have been reviewed and revised to ensure all direct costs and indirect cost allocations are reviewed as part of the month end close process. The ERP system generated allocations, based on the negotiated indirect cost rate, will be reviewed monthly by the grant accountant and the lead accountant. This error occurred due to a staffing transition. A month end checklist will be created to ensure that all steps of the process are documented, irrespective of the responsible staff. This error did not result in any in appropriate reimbursement as it was corrected by management prior to seeking reimbursement for Q4 2022. APS implemented the corrective action plan on June 5th, 2023. Management's contact responsible for the implementation of the Corrective Action Plan: Name: Jane Hopkins Gould Position: Chief Financial & Operating Officer Telephone number: 301-209-3276

FINDING 2022-005 Subject: COVID-19 ? Education Stabilization Fund ? Activities Allowed or Unallowed, Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Program: COVID-19 ? Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425U200013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Findings: Material Weakness, Material Noncompliance Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with the requirements related to the grant agreement and the Activities Allowed or Unallowed and Allowable Costs/Cost Principles compliance requirements. Context: (a) During allowable cost testing for vendor disbursements, we noted a portion of ARP ESSER funds were utilized to repair the chiller at the middle and high schools. The School Corporation incurred a total of approximately $284,000 in chiller repair costs between September 2021 and May 2022 and requested reimbursement for those expenditures from ARP ESSER funds in full. In October 2021, the School Corporation received an insurance claim check in the amount of $106,755 to cover a portion of the repair costs. The School Corporation did not deduct the amount received through insurance from the amount requested for reimbursement from federal funds, resulting in an overpayment of federal funds during the audit period. (b) Additionally, the School Corporation had not properly designed or implemented internal controls over recording transactions for payroll and fringe benefit disbursements to ensure the accuracy and classification of the payroll disbursements. Payroll disbursements make up approximately 45% of the program costs charged to the Education Stabilization Fund. One employee was responsible for processing payroll. Payroll reports were submitted to the School Board and Treasurer for review and approval; however, the reports only provided a total gross amount paid from each fund. The reports did not list the employees who were paid from the fund. In March 2021, the Treasurer implemented a review of the payroll distribution report, which is broken out by fund and individual employee. The lack of controls related to payroll disbursements was isolated to the 2020-2021 year. Views of Responsible Officials and Planned Corrective Actions: We concur with the finding. Description of Corrective Action Plan: The NJ-SP School Corporation will implement internal controls to ensure a system is established for when insurance claim checks are received that they are properly receipted and funds are accounted for and deducted from necessary reimbursement grants. This will give better proper oversight, reviews, and approvals over the insurance claim checks received. These controls will be implemented by July 1, 2023. The NJ-SP School Corporation will also implement internal controls to oversee that financial transactions related to receipts and payroll and fringe benefits disbursements are reviewed and verified by proper management to ensure that accuracy and documentation is in place. These controls were implemented on March, 2021. Responsible Party and Timeline for Completion: Dalton C. Tunis ? Corporation Business Manager/Treasurer Anticipated Completion Date for (b): March 2021 Anticipated Completion Date for (a): July 1, 2023

FINDING 2022-008 Subject: Special Education Cluster (IDEA) ? Activities Allowed or Unallowed, Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Program: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Number: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 20611-109-PN01, 21611-109-PN01, 21619-109-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Findings: Material Weakness Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with the requirements related to the grant agreement and the Activities Allowed or Unallowed and Allowable Costs/Cost Principles compliance requirements. Context: The School Corporation had not properly designed or implemented internal controls over recording transactions for payroll and fringe benefit disbursements to ensure the accuracy and classification of the payroll disbursements. Payroll disbursements make up 100% of the program costs charged to the Special Education grants. One employee was responsible for processing payroll. Payroll reports were submitted to the School Board and Treasurer for review and approval; however, the reports only provided a total gross amount paid from each fund. The reports did not list the employees who were paid from the fund. In March 2021, the Treasurer implemented a review of the payroll distribution report by fund and individual employee. The lack of controls related to payroll disbursements was isolated to the 2020-2021 year. Views of Responsible Officials and Planned Corrective Actions: We concur with the finding. Description of Corrective Action Plan: The NJ-SP School Corporation will implement internal controls to oversee that financial transactions related to receipts and payroll and fringe benefits disbursements are reviewed and verified by proper management to ensure that accuracy and documentation is in place. These controls were implemented on March, 2021. Responsible Party and Timeline for Completion: Dalton C. Tunis ? Corporation Business Manager/Treasurer Anticipated Completion Date: March 2021

FINDING 2022-004 Subject: Child Nutrition Cluster ? Activities Allowed or Unallowed, Allowable Costs/Cost Principles Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program, After School Snack Program, Summer Food Service Program for Children Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY2021, FY2022 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Findings: Material Weakness Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with the requirements related to the grant agreement and the Activities Allowed or Unallowed and Allowable Costs/Cost Principles compliance requirements. Context: The School Corporation had not designed or implemented adequate internal controls to ensure that payroll disbursements were only for food service-related services. Payroll disbursements comprise approximately 45% of the program costs charged to the Child Nutrition Cluster. One employee was responsible for processing payroll. Payroll reports were submitted to the School Board and Treasurer for review and approval; however, the reports only provided a total gross amount paid from each fund. The reports did not list the employees who were paid from the fund. In March 2021, the Treasurer implemented a review of the payroll distribution report, which is broken out by fund and individual employee. The lack of controls related to payroll disbursements was isolated to the 2020-21 year. Additionally, payroll disbursements for custodial employees were allocated to the Child Nutrition Cluster based on a percentage of the custodial employees? salaries. However, there were no time and effort logs or other documentation maintained to support the percentage of the custodial salaries allocated to the Child Nutrition Cluster. The custodial salaries make up approximately 3% of the total payroll disbursements charged to the Child Nutrition Cluster. This was an issue throughout the audit period. Views of Responsible Officials and Planned Corrective Actions: We concur with the finding. Description of Corrective Action Plan: The NJ-SP School Corporation will implement internal controls to ensure compliance with the activities allowed or unallowed and allowable costs/cost principles compliance requirements. This will consist of maintaining documentation to support that payroll disbursements are only for food service operating costs by having supporting timesheets and timecards or time and effort reports for all employees paid from the School lunch fund. These controls will be implemented by July 1, 2023. Responsible Party and Timeline for Completion: Dalton C. Tunis ? Corporation Business Manager/Treasurer Anticipated Completion Date: July 1, 2023

FINDING 2022-004 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 Assistance Listing Number: 84.027, 84.173 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking Audit Finding: Significant Deficiency Condition and Context: The School Corporation is a member of the Daviess-Martin Special Education Cooperative (Cooperative). During fiscal year 2020-2021, 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 (!DOE) 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, 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. The Non-Public Proportionate Share expenditures for the 19611-007-PN01 and 19619-007-PN01 grant awards could not be verified for the individual member schools. Total grant expenditures were posted as expended. The non-public proportionate share expenditures were then determined by applying the budgeted percentage for non-public school expenditures to the total expenditures. These were the amounts reported to !DOE. As such, we were unable to identify if the minimum amount per the grant awards was expended and properly reported to !DOE as required. The lack of internal controls and noncompliance was isolated to the 19611-007-PN01 and 19619-007-PN01 grant awards. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and will take the following corrective action. The School Corporation will set internal controls in place to ensure that the required level of expenditures for non-public school students with disabilities was met for our school corporation. Earmarking requirements for the Matching, Level of Effort will be reviewed and reported. We have consulted with Daviess-Martin Special Education Co-Op and they have assured us additional Komputrol training has been completed on their part to ensure that we are all monitoring internal controls. Responsible party and timeline for completion: Federal regulation requires name and title of person overseeing corrective action plan and anticipated completion date. Mrs. Berry, Superintendent will work with the Daviess-Martin Special Education Co-Op to ensure our School Corporation is in compliance each school year.

FINDING 2022-002 Contact Person Responsible for Corrective Action: Cortney Parrish, Corporation Treasurer Contact Phone Number: 765-240-2346 Views of Responsible Official: We agree with the finding Description of Corrective Action Plan: As of fiscal year 2022, the School Corporation no longer pays teachers or aides from the School Lunch Fund, with the exception of one teacher being paid from the School Lunch Fund until December of 2022. As of January 1, 2023, only cafeteria employees are paid from the School Lunch Fund. Anticipated Completion Date: Completed

FINDING 2022-005 Contact Person Responsible for Corrective Action: Danica Houze, Chief Financial Officer Contact Phone Number: 812-274-8001 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Starting in FY 2021 Time and Effort logs were kept by employees working with non-public students. Logs are submitted to the Director of Student Services and the payroll department, then accounts are distributed to match time actually spent with the non-public time spent per the time and effort logs. Anticipated Completion Date: 2/13/2023

FINDING 2022-001 Contact Person Responsible for Corrective Action: Tammy Breedlove, Food Service Director Contact Phone Number: 765-569-4308 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The following internal control process has been added to the Business Office Handbook Effective February 1, 2023. The Food Service Director will follow all guidelines as contained in the Child Nutrition Procurement Plan and retain all documentation in compliance with Child Nutrition regulations and State Law. Furthermore, the Food Service Director will ensure that the following procedures are in place: 1. Each School year, the Food Service Director will prepare 5 binders- 1 for each Cafeteria, 1 for the Food Service Director, and 1 for the Business Manager. These binders will contain all approved bids and price changes/vendor correspondence. It is the responsibility of the Food Service Director & Cafeteria Site Managers to update these binders as price changes occur. Audit Evidence will be the contents in each binder for each school year. 2. When invoices for goods are received, the Food Service Director is responsible for ensuring that the invoices are reviewed and crosschecked to the original order/ approved pricing by the Cafeteria Site Manager. Furthermore, the Food Service Director will also review the invoices/pricing and sign off on the claim voucher sheet as approval for the Business Manager to pay the invoice. Audit Evidence: The Cafeteria Site Manager?s signature on the invoices & the Food Service Director?s signature on the claim voucher sheet. Anticipated Completion Date: Effective February 1, 2023

Corrective action plan: Management is implementing a job/cost time and labor system as part of the current Paylocity system currently in place. This new time tracking system will allow individuals working directly on contracts to record time spent on grants on their individual weekly timecards. This system will allow management to report time spent by person by contract within our current payroll and financial system. This enhancement will not be in place until January 2023. In the meantime, management has formalized a quarterly manual review process to document actual time spent per employee per contract along with any needed adjustments to allocation percentages. Personnel responsible for corrective action: Stephanie Cawby, Senior Accountant and Alex Laprade-Velasco, Financial Analyst Estimated corrective action completion date: December 2022 ? Manual quarterly review of contract time spent and adjustments. January 2023 ? Implementation of Paylocity Job Cost Time tracking and roll out to employees

FINDING 2022-004 (Auditor Assigned Reference Number) Contact Person Responsible for Corrective Action: Todd VanDerWeele Contact Phone Number: 574.223.2159 Views of Responsible Official: We concur with the finding. We have adjusted our retention practices to keep all employee records according to statute. After employees listed on the personnel report for hiring or reclassification are approved, the HR Director will provide the approved personnel report, salary schedule or CBA salary schedule, employee contract, and screen shot of the entries into the school?s financial software to the Business Manager to review and approve. Anticipated Completion Date: March 31, 2023

FINDING 2022-003 (Auditor Assigned Reference Number) Contact Person Responsible for Corrective Action: Todd VanDerWeele Contact Phone Number: 574.223.2159 Views of Responsible Official: We concur with the finding. We have adjusted our retention practices to keep all employee records according to statute. After employees listed on the personnel report for hiring or reclassification are approved, the HR Director will provide the approved personnel report, salary schedule or CBA salary schedule, and screen shot of the entries into the school?s financial software to the Business Manager to review and approve. Anticipated Completion Date: March 31, 2023

Contact Person Responsible for Corrective Action: Tina Gross Contact Phone Number: 317-945-4327 Views of Responsible Official: We concur with this finding, but would like to offer the following explanation: When ESSER funds first become available, there were no guidelines or restrictions that were made available. Instead, the districts were assigned swift deadlines in getting their spending plans submitted. The advice was, if you can link the request to COVID, and IDOE approves the request, then ESSER funds can be used. Months later, in an attempt to tighten things up, the school districts were presented with guidelines. This took place after all of the planning had already been done for all three grants and costs had already been incurred. The renovation cost in question was included in our spending plan submitted to IDOE through the Title Application Center. The following narrative was also submitted with the budget to IDOE as follows: ?We are also requesting $472,962.87 for a renovation project at our local Career Center, Central Nine in Greenwood. Franklin High School is one of eight sending schools for this career center. These renovations will add necessary classroom and lab space for the Diesel, Welding, and Dental programs. The renovations also include meeting space and restrooms. The total cost of Franklin Community Schools? portion of the project is estimated at $652,400, however, we are only requesting a portion of that in ESSER III funds and will cover the difference using district funds? IDOE approved the budget submitted, including this specific transaction. There was no reason for the district to think that this was an unallowable transaction. Description of Corrective Action Plan: The district is willing to transfer this expense to rainy day or operating funds if necessary. Anticipated Completion Date: 2-22-23

Corrective Action Plan - FEDERAL AWARD FINDINGS AND QUESTIONED COSTS FA 2022-001 Improve Controls over 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 - 84.4250 - 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: $358,390 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: We acknowledge this finding, however the School District relied on the advance, written approval of Georgia Department of Education Federal Programs staff that our request was a proper use of federal funds and that we had all the documentation needed for this cost to be allowable. It was pointed out to us during the audit that the contract with the custodial staff did not have the language needed to cover the bonus to our custodial contract staff in the view of the Department of Audits. The Department took this position even though both parties agreed to these payments, the Board of Education voted to approve this expenditure, the agreement was documented and the Board of Education General Counsel concluded this was permissible under the Contract. In order to accommodate the Department?s concerns, the School District will monitor contracts to ensure that all expenditures are compliant with the School District?s purchasing policies and procedures as well as compliance requirements for the ESSER program. Estimated Completion Date: May 2023 Contact Person: Jennifer Houston Telephone: 770-867-4527 Email: Jennifer.houston@barrow.k12.ga.us

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) Questioner Costs: $265,630 Description: The polices 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 wages to staff has been reviewed and will only be paid to staff employed by the Colquitt County Board of Education. Estimated Completion Date: Contact Person: Jeremy Jones, CFO Telephone: 229-890-6224 Email: jeremy.jones@colquitt.k12.ga.us

FINDING 2022-002 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 $5,368. Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Our corrective action plan is following the AWSSC plan of: 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: The Superintendent and Corporation Treasurer will work with the Adams Wells Special Services Cooperative to monitor and verify those expenditures are allocated appropriately across all school corporations with a non-pub proportionate share allocation.

2022-049 Oregon Health Authority Return overdraw of reclassified FEMA expenditures Federal Awarding Agency: U.S. Department of Health and Human Services Assistance Listing Number and Name: 93.268 Immunization Cooperative Agreements (COVID-19); 93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (COVID-19) Federal Award Numbers and Years: 93.268: 5 NH23IP922626 (COVID-19); 93.268: 6 NH23IP922626 (COVID-19); 93.323: 6 NU50CK000541 (COVID-19) Compliance Requirement: Activities Allowed or Unallowed Type of Finding: Significant Deficiency, Noncompliance Prior Year Finding: N/A Questioned Costs: 93.268 - $36,783 (known) (COVID-19) 93.323 - $73,333 (known) (COVID-19) Criteria: 2 CFR 200.403 During the COVID-19 pandemic, the Oregon Health Authority (department) spent money from Federal Emergency Management Agency (FEMA) awards to address needs in addressing the pandemic. Due to delays in receiving federal reimbursement for the expenditures, the department reclassified the expenditures to other programs where reimbursements would occur timelier. In our testing of Activities Allowed or Unallowed, we reviewed two individually significant items in the accounting system reclassifying 398 and 914 individual expenditures from the FEMA grants to the Immunization Cooperative Agreements program and Epidemiology and Laboratory Capacity program, respectively. Based upon the account coding of the original transactions, all of the reclassifications were allowable and consistent with program requirements. However, we found several transactions were reclassified twice, resulting in an excess of $36,783 charged to the Immunization program and $73,333 charged to the Epidemiology program. The reclassifications were completed in two batches and the managerial review of the reclassifying transactions failed to detect some transactions were included in both batches. We recommend department management correct the entries and reimburse excess cash drawn to the federal agency for unallowable costs. We also recommend department management revise the review procedures to verify that the same expenditure transactions are not duplicated in multiple batches. MANAGEMENT RESPONSE: We agree with this recommendation. Corrective action plan: ? The agency has reviewed the questioned costs and has corrected the entries with BTCL7084 and reimbursed the federal programs. ? The department has regular processes to review for duplicate adjusting entries. However, this process was missed for this entry. ? Department management will work with department staff to reinforce their understanding of the need to follow these processes to ensure transactions are not adjusted more than once. Anticipated Completion Date: June 1, 2023 Contact: Nichole Petersen, Division Liaison ? PH/ HP&A/ OEBB/ PEBB

FA 2022-001 Strengthen Controls over Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principle 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 - Homeless Children and Youth Federal Award Number: S425D210012 (Year: 2021), S425U2120012 (Year: 2021) S425W210011 (Year: 2021) Questioned Costs: $108,220 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 for the program. Corrective Action Plans: We concur with this finding. A new Federal Programs Director began work during the period of the audit. The change in personnel coupled with the influx of new grants, large awards of grant dollars and new regulations and requirements contributed to the finding. To correct, staff meet and attend training on all federal grant funds received to ensure compliance on all reporting requirements. The federal programs director enters and monitors all grant budgets into the consolidated application and supplies all prior approval forms for those items for which it is required. The federal programs director also approves all purchase requisitions using federal funds before items can be purchased; she also reviews and approves request for reimbursement of federal funds before those funds are drawn down. (Superintendent approves as well.) Estimated Completion Date: June 30, 2023 Contact Person: Debbie Driggers Powell Telephone: (912) 557-3327 Email: dpowell@tattnall.k12.ga.us

CORRECTIVE ACTION PLAN FINDING 2022-005 Contact Person Responsible for Corrective Action: Special Education Cluster/Heidi Sprunger Contact Phone Number: 260-589-3133 Views of Responsible Official: We concur with the finding. The district is working with Special Education Cluster to obtain the corrective action plan that was submitted previously. Description of Corrective Action Plan: We will monitor this with Adams-Wells Special Services Co-op to ensure that the corrective action plan that was submitted will be followed. Anticipated Completion Date: Immediately

CORRECTIVE ACTION PLAN FINDING 2022-002 Contact Person Responsible for Corrective Action: Heidi Sprunger Contact Phone Number: 260-589-3133 Views of Responsible Official: We concur with the finding the documentation supporting employees? time charged to the Child Nutrition Cluster program for custodians and grant specialist was not properly maintained. However, we disagree that they would be considered an indirect cost according to the definition of indirect cost: (Indirect costs are sometimes referred to as ?overhead costs? and more recently as ?facilities and administrative costs.?) Examples include executive oversight, accounting, grants management, legal expenses, utilities, technology support, and facility maintenance. Description of Corrective Action Plan: The district will evaluate and determine which employees will continue to be charged under the Child Nutrition Cluster Program. Only those employees spending direct physical time in the cafeteria doing work will continue to be under the Child Nutrition Cluster Program. Once identified those employees will be required to fill out a separate time sheet for hours worked under the Child Nutrition Cluster program. Those time sheets will then be approved by the Food Service Director. Once approved they will be submitted to Payroll Coordinator. Anticipated Completion Date: March 20, 2023

FINDING 2022-011 Contact Person Responsible for Corrective Action: Tricia Malone Hudson, District Curriculum Specialist Contact Phone Number: 812-279-3521 Views of Responsible Official: We concur with the audit finding. Description of Corrective Action Plan: The district has established a process for tracking expenses for homeless and parental involvement funds. In addition, a process has been established to ensure all expenses are coded properly. Anticipated Completion Date: North Lawrence Community Schools implemented this procedure beginning in March 2023.

FINDING 2022-010 Contact Person Responsible for Corrective Action: Tricia Malone Hudson, District Curriculum Specialist Contact Phone Number: 812-279-3521 Views of Responsible Official: We concur with the audit finding. Description of Corrective Action Plan: The school district will develop a plan for tracking employee pay and timecard alignment. The district will ensure that these documents are available to auditors. All expenditures will have a cover sheet with identifying information, will be attached to the proper invoice(s), signed by 2 parties, and hard copies will be kept on file for audit purposes in folders attached to each grant. Anticipated Completion Date: North Lawrence Community Schools will implement this procedure by June 2023.

FINDING 2022-006 Contact Person Responsible for Corrective Action: Melissa Hinds, Director of Special Education Contact Phone Number: 812-279-3521 Views of Responsible Official: We concur with the audit finding. Description of Corrective Action Plan: As it relates to retaining proper documentation for an audit for Activities allowed or un-allowed, and allowable cost/costs, a policy and procedure will be implemented regarding the documentation and retention of records. Review and approval of activities reimbursed by the Special Education Grants to States and Special Education Preschool Grants will have the appropriate backup documentation (e.g. invoices, purchase orders, contracts, receipts) to ensure alignment to the IDOE grant, as well as documentation that funds were encumbered within the financial system by the respective period of performance end date. As of July 2022, these activities began being reviewed and approved by two separate individuals. Anticipated Completion Date: July 2022