Corrective Action Plans

Corrective Action: Management will review all cost allocations and implement documented policies and procedures to ensure sufficient support of any allocations of costs is maintained as required by 2 CFR §200.403. In addition, Management has developed a cost allocation worksheet and framework and is in the process of implementing a new procedure to ensure it is reviewed by accounting and grant managers to ensure accurate reporting. Name of Responsible Individual(s): Jason Brenier, CFO Anticipated Completion Date: March 2024

FA 2022-002 Strengthen Controls over Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principle Internal Control Impact: Material Weakness Compliance Impact: Material 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 Awars Numbers: S425D210012 (Year: 2021), S425U2120012 (Year: 2021) Questioner Costs: $193,631 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: Although the School District does not agree with this finding, management will continue to ensure federal fund program guidelines and Board-approved policies and procedures are followed. Estimated Completion Date: Ongoing Contact Person: Kyla M. Milton, Finance Director Telephone: 229-868-5661 Email: kmilton@telfairschools.org

Following the Auditor's recommendations and as a corrective action, the staff or department in charge locate and document all required reports that were filed according to the requirements of the grant agreement, including the reconciliation thereof with the official Municipality’s accounting subsidiaries. In addition, the Municipality will design, document, establish and provide the necessary and required training, including guidelines and procedures, to all personnel who work directly or indirectly with the management of these federal funds.

Following the Auditor's recommendations and as a corrective action, the staff or department in charge locate and document all required reports that were filed according to the requirements of the grant agreement, including the reconciliation thereof with the official Municipality’s accounting subsidiaries. In addition, the Municipality will design, document, establish and provide the necessary and required training, including guidelines and procedures, to all personnel who work directly or indirectly with the management of these federal funds.

Following the Auditor's recommendations and as a corrective action, the staff or department in charge locate and document all required reports that were filed according to the requirements of the grant agreement, including the reconciliation thereof with the official Municipality’s accounting subsidiaries. In addition, the Municipality will design, document, establish and provide the necessary and required training, including guidelines and procedures, to all personnel who work directly or indirectly with the management of these federal funds.

Following the Auditor’s recommendations and as a corrective action, the staff or department in charge locate and document all required reports that were filed according to the requirements of the grant agreement, including the reconciliation thereof with the official Municipality’s accounting subsidiaries. In addition, the Municipality will design, document, establish and provide the necessary and required training, including guidelines and procedures, to all personnel who work directly or indirectly with the management of these federal funds.

Finding No. 2022-007 -Activities Allowed or Unallowed, Eligible Uses - FEMA Condition During the closeout procedures, the Cenh·al Office of Recovery, Reconstruction and Resiliency (COR3) office performed a 100% validation on Rental Equipment, supporting documents including conh"act smmnary record, invoices, and proofs of payment. As a result of the validation, the total validated amount is $979,259 from an original amount of $1,260,775 submitted by the Corporation for reimbursement. Corporation response The Corporation agrees with the finding. Corrective Action Plan Upon receiving the audit findings, we initiated an immediate review of our FEMA-funded projects and expenditures. We are implementing immediate corrective actions to address the identified deficiencies and ensure strict compliance with FEMA guidelines regarding eligible uses. • Policies and Procedures Review - Simultaneously, the Corporation is reviewing our existing policies and procedures related to FEMA funds, with a specific focus on eligible activities. Any necessary revisions will be made to strengthen our policies and ensure rigorous adherence to FEMA guidelines and regulations. • Enhance Internal Controls - We are enhancing our internal controls related to FEMA fund utilization. This includes implementing additional checks and balances to improve the accuracy and reliability of our project management processes, ensuring they align with FEMA guidelines. ■ Communication Protocols Enhancements - We understand the importance of transparent communication regarding the use of FEMA funds. To address this, we are enhancing our communication protocols to ensure that all relevant stakeholders are informed of FEMA guidelines, project eligibility requirements, and any changes to procedures. • Return of Funds - Initiate the communication process with the Central Office of Recovery, Reconstruction, and Resiliency to obtain instructions for returning the funds to FEMA. Follow FEMA's specific guidelines on the return of funds, including the appropriate documentation, timelines, and c01mnunication procedures. ■ Finance Team - The Corporation has made changes to its management staff structure in the finance and budget department, with the mission of improving the monitoring process and compliance with federal and local regulations and the support of independent consultants. A new Finance and Budget Director and the Associate Director of Finance and Budget have been appointed. Names of the contact persons responsible for corrective action plan Jesus A. Rodrfguez Aviles - Financial Planning and Analysis Associate Director Cecilia Robles Kakiuchi - Financial Planning and Analysis Director Anticipated Completion Date Fiscal Year 2024

Criteria: In accordance with 2 CFR 200.403(g), costs must be adequately documented in order to be allowable under Federal awards. Condition: The School was unable to provide documentation for three (3) out of sixty (60) non-payroll expenses. Cause: The School failed to follow its own policies for documentation of expenses and document retention. Effect: The costs were not allowable under the Federal award because they were not adequately documented. Questioned costs: $2,412 Context: Three (3) out of sixty (60) non-payroll expenditures tested did not have original invoice or payment support. Recommendation: We recommend the School implement a document retention system whereby invoices and payment support are retained for the appropriate time period. Action Plan: The school has maintained receipts for these non-payroll expenditures but were not found within the audit timeline. Better organization of receipts will be implemented. The School will scan receipts and electronically store documents including invoices and payments together. The School will consider multiple platforms including server or a cloud document storage platform. Receipts will be maintained and reported in the appropriate period. Persons Responsible: Yvonne Bullock, CEO/Head of School Gulen Hicks, Consultant Administrative Assistant Consultant

FA 2022-001 Strengthen Budgetary Controls over Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principle Internal Control Impact: Material Weakness Compliance Impact: Material 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: $31,131 Prior Year Finding: N/A Description: A review of expenditures charged to the Elementary and Secondary School Emergency Relief Fund program revealed instances in which expenditures had not be properly approved by the pass-through entity. Corrective Action Plans: The Calhoun County School System will ensure that all expenditures charged to the Elementary and Secondary School Emergency Relief Fund are properly approved by the pass-through entity. The Federal Programs Director will verify that all expenditures are reflected in the approved budget or subsequent amendments within the Consolidated Application as required. The Calhoun County School System will follow the procedures listed below to ensure that expenditures are reflected in the approved budget and/or subsequent amendments: The Federal Programs Director and the Finance Director will monitor all original budgets and subsequent amendments to ensure that expenditures have been approved. During monthly leadership meetings, the Federal Programs Director and the Finance Director will verify that all budgets and subsequent amendments have been properly signed off on by the Program Coordinator and the Superintendent in the Consolidated Application. In the event budgets and subsequent amendments are not found to be properly signed off on by the Program Coordinator and the Superintendent, the Federal Programs Director will take steps to ensure that proper sign off is initiated and completed. Estimated Completion Date: September 30, 2024 Contact Person: Pamela Quimbley Telephone: 229-545-7231 ext. 2005 Email: pamquimbley@calhoun.k12.ga.us

Prior to the completion of this audit, EmployIndy already made a number of changes to its financial operations. It parted ways with its Chief Financial Officer and procured the services of an outside Certified Public Accounting firm to begin the process of reviewing and updating its financial operations. In addition, it recently hired an Executive Vice President of Finance and Operations to lead the final development and implementation of updated financial processes. The Executive Vice President of Finance and Operations has worked with EmployIndy’s Board of Directors and Finance Committee to document a plan for improving EmployIndy’s financial operations across the board by the 2nd quarter of Calendar Year 2024. EmployIndy currently provides training to all staff on properly documenting work hours within the time management and payroll system. There is an existing process for correcting and documenting any changes within the time management and payroll system after time has been submitted. In scenarios where it is necessary and allowable to shift EmployIndy staff time charged from one funding stream/cluster to another, Financial Operations staff, under the direction of the Controller, will make updates, including supporting documentation, in both the time management/payroll and financial management systems. Reconciliations between the payroll system and the financial management system will be completed monthly in order to ensure that the information in each system matches and that there is documentation showing that the expenses are allowable and supported. Finally, the Director of Human Resources will ensure that offer letters with pay rates and any subsequent salary adjustments will be documented with approval signatures and retained in personnel files, with proper amounts being updated within the time reporting/payroll system.

Prior to the completion of this audit, EmployIndy already made a number of changes to its financial operations. It parted ways with its Chief Financial Officer and procured the services of an outside Certified Public Accounting firm to begin the process of reviewing and updating its financial operations. In addition, it recently hired an Executive Vice President of Finance and Operations to lead the final development and implementation of updated financial processes. The Executive Vice President of Finance and Operations has worked with EmployIndy’s Board of Directors and Finance Committee to document a plan for improving EmployIndy’s financial operations across the board by the 2nd quarter of Calendar Year 2024. As a part of this plan, EmployIndy’s Financial Operations Team, led by the Controller, has already begun to update the expenditure approval process. This process requires that supporting documentation be retained within the financial management system. Additionally, the review and approval process consists of multiple review and approval steps by program management and financial operations staff with specific focus on retention of supporting documentation and clear connections between expenditures being allocated to WIOA and other funding clusters and documentation supporting such allocations. All EmployIndy staff will be retrained on the updated expenditure submission, review, approval, and documentation processes. Additionally, EmployIndy’s Financial Operations, Grants & Contracts, and Program Management teams will provide guidance and training to EmployIndy’s subrecipients and contractors covering the proper process for submitting supporting documentation with invoices or accrued expenditure reports. These documentation requirements will ensure that supporting information directly and clearly ties back to invoices and/or accrued expense reports.

Prior to the completion of this audit, EmployIndy already made a number of changes to its financial operations. It parted ways with its Chief Financial Officer and procured the services of an outside Certified Public Accounting firm to begin the process of reviewing and updating its financial operations. In addition, it recently hired an Executive Vice President of Finance and Operations to lead the final development and implementation of updated financial processes. The Executive Vice President of Finance and Operations has worked with EmployIndy’s Board of Directors and Finance Committee to document a plan for improving EmployIndy’s financial operations across the board by the 2nd quarter of Calendar Year 2024. As part of the improvement to financial operations, EmployIndy will provide updated training to all staff covering the proper process for submitting, reviewing, approving, and retaining supporting documents for expenditures. The existing procedure includes a multi-step review and approval process for all expenditures, including those in the WIOA and other federal funding clusters. Additionally, EmployIndy’s Financial Operations, Grants & Contracts, and Program Management teams will provide guidance and training to EmployIndy’s subrecipients and contractors covering the proper process for submitting supporting documentation with invoices or accrued expenditure reports. These documentation requirements will ensure that supporting information directly and clearly ties back to invoices and/or accrued expense reports.

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 - 84.425C - Coronavirus Aid, Relief and Economic Security Act-Governor's Emergency Education Relief Fund 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: S425C200012 (Year: 2021), S425D200012 (Year: 2020), S425D210012 (Year: 2021), S425U2120012 (Year: 2021), S425W210011 (Year: 2021) Questioner Costs: $101,681 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: Director of Finance will follow rules regarding federal expenditures. The finance officer will work with federal programs personnel to ensure that all rules are being met and that budgets are entered into the Consolidated Application timely. The finance officer will offer training to those work with federal grants. Estimated Completion Date: June 30, 2023 Contact Person: Carrie Gay, Director of Finance Telephone: 229-588-2340 Email: cgay@brooks.k12.ga.us

Logan Acres will increase documentation with employee time charts by dual confirmation of employee’s time record demonstrating the differential compensation which will include dual verification of employee and staff supervisor.

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. Federal Communications Commission Assistance Listing Number and Title: COVID-19-32.009-Emergency Connectivity Fund Federal Award Number: ECF202105452 (Year: 2022) 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: S425D210012 (Year: 2021) Questioner Costs: $63,399 Description: A review of expenditures charged to the Emergency Connectivity Fund and Elementary and Secondary School Emergency Relief Fund programs revealed that the School District's internal control procedures were not operating appropriately to ensure that expenditures were allowable. Corrective Action Plans: The district will contact each Federal Program to determine the appropriate action to take to ensure the funds are appropriately allocated. Moving forward, Finance will review all reimbursements as well as work with other Departments to ensure that expenses are being allocated to the correct program. Estimated Completion Date: June 30, 2023 Contact Person: Betty Corbitt, Finance Director Telephone: 912-699-6009 Email: betty.corbitt@jeff-davis.k12.ga.us

Finding Numbers 2022-002 and 2022-003 Planned Corrective Action: To date, management has already started additional training with the team responsible for grants and any communications between them and HRSA. The accounting department has also been advised to insist on more written documentation prior to assigning expenses to grants. Anticipated Completion Date: November 30, 2023 Responsible Contact Persons: Jillian Hudspeth, CEO Christopher Bernardi, CFO

• Condition: During our testing of reimbursement requests, we identified an invoice that included expenses outside the period of performance for a grant in the federal program. • Response MHA relies on our accounting representative to ensure that the invoices submitted to the accountant each week are added to the appropriate GL account to ensure the account is being invoiced for the correct expenses during the proper timeframe • Planned Corrective Action: During the newly established monthly meetings that will take place, MHA and Accounting Rep will review the expenses being submitted for reimbursement together to ensure no invoices are submitted outside the grant period.

• Condition: A prepayment for a 2023 training conference was recorded as an expense and reimbursed from a grant in the federal program. • Response This expense was recorded incorrectly and subsequently reimbursed due to miscommunication. • Planned Corrective Action: MHA will have staff attend additional training.

The County plan has been implemented.

Finding 2022-004 Lack of Internal Control over Activities Allowed or Unallowed and Allowable Costs/Cost Principles Name of Contact Person: Tracy Bye, CFO Response: Launch Alaska takes exception to the auditors’ findings. Launch Alaska codes expenses in accordance with the Launch Alaska Policy and Procedures for Uniform Guidance, GAGAS and FAR Part 31. Only those supported expenses that are allowable and allocable to Federal grants are charged to grant GL accounts. FY22 has examples of costs being segregated and posted to appropriate accounts based upon these cost principles. The CFO has over 30 years of GAGAS and FAR Part 31 experience and has final authority over which costs are coded for Federal reimbursement. Records for the transactions reside within QBO and the former CPAs JE files. All transactions for the covered period were reviewed by the CEO and CPA prior to entry into QBO. The CFO reviewed the postings monthly and requested changes to the GL coding when required. These changes were recorded by the CPA via AJE. We agree that the CPA did not post corrections in a timely manner in most cases. The Business Manager and new CPA review the expense entries weekly and at the close of each monthly period. The CEO/CFO have final authority on GL coding and are required to approve each expense entry prior to payment to ensure that the Policy and Procedures for Uniform Guidance is adhered to. This process takes place in both Ramp and QBO. Proposed Completion Date: Launch Alaska updated its Policy and Procedures for Uniform Guidance in early FY22 and is completing a second review at this time to incorporate the system and internal process changes discussed above. A final draft of the changes is expected to be reviewed for adoption by the Launch Alaska Finance Committee Board members in November 2023.

REFERENCE # 2022-005 PERIOD OF PERFORMANCE – SIGNIFICANT DEFICIENCY- NONCOMPLIANCE Program Name/ALN Emergency Food and Shelter National Board Program (ALN # 97.024) Criteria: Compliance Supplement Requirement: A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass-through entity made the federal award that were authorized by the federal awarding agency or pass-through entity (2 CFR sections 200.308 200.309 and 200.403(h)). A period of performance may contain one or more budget periods. Condition/Context: Division receive Emergency Food and Shelter National Board Program funds from the U.S. Department Homeland security/FEMA and various pass-through entities. The Division’s pass-through Contract requires period of performance and also requires funds must be expended by certain date. Of the Sixty (60) files selected for testing We noted that the Division: • For 4 samples, we noted that Division program expenses were recorded prior to Contract starting date. Questioned Costs: Cannot be determined Recommendation: We recommend Division charge only allowable costs incurred during the approved budget period of a pass-through award’s period of performance and any costs incurred before the pass-through entity made the federal award that were authorized by the pass-through entity. Corrective Action Plan: The Division will charge only allowable costs incurred during the approved budget period of a pass-through award’s period of performance and any costs incurred before the pass-through entity made the federal award that were authorized by the pass-through entity. Step 1 Action Date: Ongoing Final Implementation Date: 12/31/2023 Name and Phone # Of Person Responsible for Implementation: Jeanne Stromberg, Major, Divisional Finance Secretary (916) 563-3710

The AOS team has already contacted CCJFS. They are aware of the issue and will take the necessary steps to avoid making this mistake in the future. The Auditor’s office will closely monitor the reporting and coding of expenditures against grant resources.

Information on Federal Program(s) - Department of Health and Human Services, Assistance Listing Number 93.498 COVID-19 - Provider Relief Fund and American Rescue Plan Rural Distribution, Schedule of Expenditures of Federal Awards Reporting Periods 2 and 3, Agency Fiscal Year-Ended June 30, 2022. Management’s Corrective Action Plan In response to the deficiency identified, the Agency will modify its existing internal control protocols in the following ways: • Develop emergency internal control protocols to be implemented during emergency situations whereby all items recoded by accounting staff are reviewed and signed off by the Controller or Director of Finance to ensure appropriate treatment. Train all accounting staff on this expectation. • Ensure adherence of record retention policies and procedures which are consistent with regulatory requirements. • Modify its petty cash protocols to include the review and adequate documentation of all receipts to verify allowability prior to reimbursement. Train all petty cash reviewers on this expectation. Individual Responsible for Corrective Action Plan Auston Johnson Controller 215-386-3838 Anticipated Completion Date: October 31, 2023

Contact Person: Begay, Business Manager Anticipated Completion Date: December 31, 2023 KRCI policy and procedure was reviewed and revised beginning November 2021 and completed in July 2022 at a Board retreat. The KRCI Business Office was reorganized to ensure separation and segregation of duties in August 2022. KRCI is fully staffed and returned staff that were not working during the closure to return the Campus to full improvement. KRCI now employs a Clerk for Accounts Receivable, a Business/HR Tech for Human Resources and Accounts Payable, a Facilities/Property Tech for receiving and inventory, and a Business Manager in July 2022.

Recommendation: See finding 2022-001, specifically the recommendation relating to appropriate oversight in the finance department. We recommend that the finance department continue to hire and train its employees on various programmatic requirements and resources, to ensure compliance with both existing and new federal compliance requirements. Planned Corrective Action: We agree with the recommendation. Since year end the Agency has hired a COO, and CFO to fill vacancies within the Agency. Under this new leadership structure, the Agency will continue to work on establishing appropriate controls.