Corrective Action Plans

Department: Labor Administrative and Financial Services Title: Internal control over CSLFRF expenditures needs improvement Questioned Costs: Known: $51,482,644 Likely: $51,482,644 Status: Management?s opinion is that corrective action is not required Corrective Action: We disagree with this finding. Likewise, we are unable to determine why the auditor has identified a questioned cost or includes a recommendation that only allowable costs are funded by CSLFRF. The transfer of $80 million to the Unemployment Trust Fund is completely allowable, with a portion categorized under the Public Health and Economic Impacts use category and a portion under the Revenue Loss - Provision of Government Services use category. All documentation to support the allowability of this transfer was provided to the auditor for review. There were errors in the original calculation of the total amount eligible under the Public Health and Economic Impacts category; however, we provided documentation to support that the total amount was eligible under the Revenue Loss - Provision of Government Services use category. Although we have identified a weakness in internal control over compliance, there was no actual noncompliance. Consequently, there is no cost that is considered unallowable; therefore, there should be no questioned cost. Completion Date: N/A Agency Contact: DOL Contact: Kimberly Smith, Deputy Commissioner, Department of Labor, 207-621-5096 DAFS Contact: Frank Wiltuck, Director of Internal Audit, OSC, 207-626-8420

Department: Labor Title: Internal control over UI claim payments needs improvement Questioned Costs: Known: $19,278 Likely: $2,700,000 Status: Management?s opinion is that corrective action is not required (first item) Corrective action in progress (remaining items) Corrective Action: The Department disagrees with the findings around the PUA program and the timing of the notices to provide Proof of Employment for continued eligibility. USDOL in its guidance acknowledged that it would take time to implement the new requirement from a systems and operational perspective. The Department worked diligently to implement the new requirement (along with other requirements from the CAA) as soon as possible. Furthermore, the PUA program was a one-time program created by the Federal government in response to the COVID-19 pandemic, to provide monetary support to those individuals who traditionally do not qualify for unemployment compensation benefits. All CARES Act programs, including PUA, ended in September, 2021. At this time there is no corrective action we can take, as the program no longer exists in its prior form. At most we may still see PUA eligibility as a result of a pending appeal, or court case. We will follow established processes at that time, which are based on Federal guidance provided. The Department will add a text field to obtain more information on the location of a job fair or the name of an activity when a claimant reports a CareerCenter job fair or other activity as a work search. Information will be provided to businesses through a new report for review. The Department will create a work search issue for fact-finding and possible adjudication when a claimant reports a CareerCenter Job Fair or other activity as a work search more than three times. The Department will review functionality of Vital Statistics Crossmatch to ensure that all data related to date of death for active claimants is received as timely as possible. The Department will add system controls when entering a date of birth, both for claimants and businesses to prevent avoidable data entry errors. Completion Date: June 30, 2023 (second and third items), June 30, 2024 (fourth and fifth items) Agency Contact: Laura Boyett, Director, Bureau of Unemployment Compensation, DOL, 207-621-5156

Department: Education Title: Internal control over CACFP claim reimbursements needs improvement Questioned Costs: Known: $11,222 Likely: Undeterminable Status: Management?s opinion is that corrective action is not required Corrective Action: The Department disagrees with this finding. As explained to OSA by DOE, DHHS, and USDA, Child Care Centers/Providers can enroll and claim over the licensed capacity. The claim edit check that was in place for SY22 for DCH Providers was Total Monthly Attendance x Approved Meal Types due to the fact that providers can enroll over the licensed capacity. Sponsors have been trained: Total Monthly Attendance equals the number of unique kids who attended during the day, are enrolled in CACFP and who ate at least one meal or snack during the day, then add up those daily totals for the month. To use licensed capacity as an edit check, which OSA did to calculate the costs in question, disallows provider reimbursement for eligible meals. CACFP Total Monthly Attendance is a better edit check as it only calculates attendance for enrolled participants. For the provider claims in question the CACFP Team tested them against the Total Monthly Attendance edit check and none suggest an overclaim. The CACFP Team discovered the missing enrollment edit check on 8/24/22 and immediately submitted a ticket to the web designers. This correction required multiple meetings with the web designers and in-depth system testing. The correction to the edit check was completed on 12/23/22. The claim edit checks now in place are: Attendance x Approved Meal Types (same as before) ? AND- Enrollment x Operating Days x Approved Meal Types. Completion Date: N/A Agency Contact: Jane McLucas, Director of Child Nutrition, DOE, 207-624-6880

Department: Health and Human Services Title: Internal control over EBT reconciliation procedures needs improvement Questioned Costs: Known: $80,555 Likely: $80,555 Status: Corrective action is completed regarding controls over EBT reconciliations Corrective action in progress regarding the correction of an error Corrective Action: Since May of 2022, the reconciliations in question have been completed each day, per Federal regulations. Additionally, the FY 2022 reconciliations that were due prior to April 2022 were completed retrospectively. The auditor did not note any deviations in the current process; therefore, no additional corrective action is required. There is no current deficiency in the Department's EBT reconciliation processes. While performing reconciliations, the Department detected an $80,555 error where benefits were charged to the incorrect program. Upon the completion of revisions to reports dating as far back as October 2020, the Department will move any incorrectly charged amounts to the correct program to include the $80,555 of questioned costs. Completion Date: May 2022 and April 2023 Agency Contact: Anthony Pelotte, Director, Office for Family Independence, DHHS, 207-624-4104

Department: Health and Human Services Title: Internal control over the issuance of SNAP benefits needs improvement Questioned Costs: None Status: Management?s opinion is that corrective action is not required Corrective Action: A Corrective Action Plan is not necessary. Additional standard operating procedure development was implemented on November 17, 2021. Completion Date: N/A Agency Contact: Anthony Pelotte, Director, Office for Family Independence, DHHS, 207-624-4104

Department: Health and Human Services Title: Internal control over automated SNAP eligibility determinations and benefit calculations needs improvement Questioned Costs: Known: $2,952 Likely: $7,686,166 Status: Corrective action in progress Corrective Action: The management of OFI will review the standard operating procedures to identify opportunities for improvement and distribute to all staff involved. Completion Date: June 1, 2023 Agency Contact: Anthony Pelotte, Director, Office for Family Independence, DHHS, 207-624-4104

FA 2022-001 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 COVID-19 - 84.425W - American Rescue Plan Elementary and Secondary School Emergency Relief Fund Federal Award Number: S425D200012 (Year: 2020), S425D210012 (Year: 2021) S425U2120012 (Year: 2021), S425W210011 (Year: 2021) Questioner Costs: 99,748 Prior Year Finding: No 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 School District will work with all entities to confirm that all existing internal controls are adhered to by developing and implementing an improved monitoring process. This process will ensure that all expenditures are compliant with all applicable policies and regulations. Estimated Completion Date: June 30, 2023 Contact Person: Tammy McDonald, Executive Finance Director Telephone: 770-748-3821 Email: tammy@polk.k12.ga.us

Finding Reference 2022-008 Contact Person: Emily Matis Views of Responsible Officials and Planned Corrective Action: Adjustments have been made to drawdowns in April and June of 2022 in order to correct for these overdraws. However, even after these corrections, $694.47 was still overdrawn from FY22. This amount will be corrected in a future Title V draw for this amount. Salary drawdowns will be required to have backup payroll documentation for each draw in the future. Anticipated Completion Date: January 2023

ALN No. 97.036, Disaster Grants ? Public Assistance (Presidentially Declared Disasters); Award Number: 033-UECF5-00; Award Year: January 1, 2020 to July 1, 2022; Pass-Through Entity: State of Washington Military Department Emergency Medicine Division; Award Number: D20-368 Finding: Activities Allowed or Unallowed ? The controls were not sufficient to ensure that purchase orders issued for capital purchases were fully fulfilled and paid prior to submission for program reimbursement. Status: Corrective action in progress. Corrective Action: Internal controls will be strengthened in future periods to ensure that costs are incurred prior to submission for program reimbursement. Instead of tracking purchase orders issued we will utilize general ledger details ensuring only purchase orders with receipts and subsequent invoices are included in reimbursement requests. The accounting team will pull invoice and payment support which will be reviewed by the Director of Finance prior to submission to ensure all expenditures have been paid prior to submitting a request for reimbursement. Person(s) Responsible for Implementing: Jenna Bevilacqua, Director of Finance and Lindsey Soboloski, Controller Implementation Date: March 20, 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 Listings Numbers: 84.027, 84.173 Federal Award Number and Year (or Other Identifying Numbers): 19611-042-PN01, 19619-042-PN01, 20611-042-PN01, 20619-042-PN01, 21611-042-PN01, 20619-042-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking Audit Finding: Significant Deficiency Condition: The School Corporation is a member of the Northeast Indiana Special Education Cooperative (Cooperative). During fiscal year 2021-2022, the Cooperative operated the special education programs and spent the federal money on behalf of all its members. 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. 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 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 19611-042-PN01, 19619-042-PN01, 20611-042-PN01, 20619-042-PN01, 21611-042-PN01, 20619-042-PN01 grant awards could not be verified for the individual schools to verify the minimum amount per the grant awards was expended and properly reported to IDOE as required. The lack of internal controls and noncompliance were isolated to the 19611-042-PN01, 19619-042-PN0l, 20611-042-PN01, 20619-042-PN01, 21611-042-PN01, 20619-042-PN01 grant awards. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and will take the following corrective action ... Responsible party and timeline for completion: Brian L Christner, director of finance, will follow-up with the Northeast Indiana Special Education Cooperative to ensure that nonpublic expenditures are properly reported. Completion date will be April 30, 2023.

Finding 2022-003 Contact Person: Peter Gray Contact Phone: 765-775-5150 Views of Responsible Official: 1. The US Treasury uses the term ?Subrecipient? in multiple ways. It has multiple meanings in the SLFRF reporting structure. ?Beneficiary?, ?Contractor?, and ?Subrecipient? are all entity types under the broader category of ?Subrecipient?. In the ?Expenditures? area, the only field to record the entity that receives funds is labeled as ?Subrecipient Name?. 2. The City did prepare a letter concerning the employees over the threshold. When the SBOA was asked where the letter should be sent, the response was that they did not have an address, so to keep the letter on file and be prepared to present it during an audit. We concur with the finding. Corrective Action: A. An additional layer of review has been initiated. The Director of Development is familiar with the requirements of the SLFRF guidance and will review and sign off on future reports. Anticipated Completion Date: 30 June 2022

FINDING 2022-004 Contact Person Responsible for Corrective Action: Barbara Fought Contact Phone Number: 260-260-3191 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: West Noble School Corporation 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 member schools during the writing process of the IDEA 611 and 619 grants in order for each member school to submit their plans for their allocation of proportionate share money. NEISEC will provide the allocation amounts to each cooperative school. 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 fiscal agent?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 all cooperative schools to the LEA and NEISEC. Any employee utilizing proportionate share funds that is not an employee of NEISEC, but rather a direct employee of a member school, will be paid directly by that member school. 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 the member school. For any expenses for a category outside of salary and benefits, a member school 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, the member school 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 and NEISEC in order to complete the grant reimbursement requests. INDIANA STATE BOARD OF ACCOUNTS 29 TELEPHONE (260) 894-3191 - 5050 N US HIGHWAY 33 - LIGONIER, IN 46767-9606 - FAX (260) 894-3260 - 1-800-488-3191 - WNSC@WESTNOBLE.K12.IN.US At the end of the grant period, any school with remaining proportionate share money will be required to complete a waiver. As of this date (2/10/2023) 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.

Compliance requirement ? Allowed Cost /Cost Principle Institutional Comments on Findings and Recommendations: 1. The institution does not concur with the auditor finding because the referenced transaction was below the "Micro-purchase" threshold and does not require a quotation. The FAR increase the "Micro-purchase" threshold for natural disasters and national emergencies, among others. The invoice amount of $5899 was a continuation of an initial project under this contractor which have the unique security passwords, IT protocols and other IT requirements for the uniform implementation of intelligent classrooms for remote distance education. Accordingly, the institution does not request a quote. The institution followed the referenced guidelines in the determining the allowability of costs. Additionally, an external consultant reviewed the transaction and costs prior to request reimbursement. The 2 CFR Part 200, Appendix XI Compliance Supplement guide, issued April 2022, makes referenced to the FAQ's and Other Guidance containing information pertinent to the compliance requirements described in the document and encouraged auditor to regularly check the HERF Websites for updated FAQ's and other pertinent guidance and reporting information. The institution followed those referenced FAQ's and guidelines, among other sound administration practices, in the use of the grants. The referenced Compliance Supplemental, under "Activities Allowed or Unallowed" states: "Institutions must demonstrate that costs incurred are allowable under the relevant statutory provision and consistent with the purpose of the ESF "to prevent, prepare for, and respond to coronavirus"". The institution used $5,899 paid to the guidelines as indicated to contractor, to continue enhancing the distance learning program in preventing the spread and contamination of the coronavirus among professors and students by enabling remote distance education. The direct charges for this transaction to the federal award was for allowable costs under the instructions, federal grant and FAQs guidelines as indicated. 2. The institution does not concur with the auditor finding because of what is discussed in No 1 above. In the two cases mentioned, the cost quote may not agree with the invoice, because of some additional services requested, but the amount of the invoice was the correct amount paid and actual cost used to draw the HEERF funds. These invoices were for furniture and partitions divisions, to enable the remote distance education, avoiding physical contact of students and professors, to prevent, prepare for and respond to the COVID-19 emergency. Once again, these incurred and direct charges to the federal award complied with the HEERF objectives and were allowable costs under the authorized uses in the grant award and HEERF guidelines. 3. The institution does not concur with the auditor finding. The referenced three cases may not have a specific or expressed "acknowledgement of receipt" statement, but the acknowledgement was validated by UTC management and with the signatures when the check was issued. Nevertheless, the costs incurred in these invoices were authorized and incompliance with HEERF program and ESF purpose. The direct charges for this transaction to the federal award was for allowable costs under the instructions, federal grant and FAQs guidelines as indicated. 4. Institution does not, firmly, concurs with the auditor finding. This should not even be a finding because the institution strictly followed the FAQs published on March 19, 2021 to calculate the lost revenue and using a comparison between FY-20 and FY 21. That guideline described "Loss of Revenue" as "...those revenues and institution of higher education otherwise expected but were reduced or eliminated as a result of the novel coronavirus 2910 (COVID-2019) pandemic. As such, lost revenues can only be estimated". Nerveless, the result would have been relatively the same if we have use FY21 audited financials. Given the many factors and complexities of the unusual process, the institution followed a conservative approach and reduced those revenue items that have an increase between fiscal year from those with a loss of revenue. Therefore, the institution netted the potential amount of lost revenue to claim. Accordingly, the net amount resulted in $280,929.84. The potential loss of revenue amount could be greater but the institution decided to only claim the referenced estimated amount. These calculations and analysis were further discussed and evaluated by an officer of the Department of Education, with no recommendation on claiming a higher amount because the amount claimed was less than the estimated potential. The guideline indicates: "Reimbursement for lost revenue is allowable for the Institutional Portion program...". The institution claimed this loss of revenue amount from their institutional portion, complying with the HEERF guidelines and the authorized use of the funds. The direct charges for this transaction to the federal award was for allowable costs under the instructions, federal grant and FAQs guidelines as indicated. a. The institution used unaudited figures for FY21 because the audited financial statements were not completed at the time of the calculation. The institution revised the calculations with the audited financial statements, and the results were the same and the claimed estimated amount did not changed. Once again and in accordance with the guidelines, we were estimating the lost revenue with the data available at the moment. b. The institution followed the recommended HEERF guidelines for this complex and novel exercise. The institution considered under the analysis; those revenues otherwise expected but that were reduced as a result of the novel COVID-2019. The contributions as "Support Revenue" from related entities, which were a significant source of revenue for the institution, was not claimed as loss of revenue. The institution specifically claimed those lost revenue items as authorized in the guidelines. Therefore, once again, the UTC was in compliant with the lost revenue referenced guidelines. The direct charges for this transaction to the federal award was for allowable costs under the instructions, federal grant and FAQs guidelines as indicated. c. As explained above, the institution followed a conservative approach and only claimed a net amount of all lost revenue items. The institution only claimed those estimated revenue items, as authorized in the guideline, that suffer a loss between the two fiscal years considered in the evaluation. This was further evaluated by an officer of the DOE. As the guidelines described, since the lost revenues can only be estimated, the institution correctly, analyzed and calculated the best conservative/reasonable estimate of loss revenue with the available data at the moment. Even if we used the auditors' recommended items, the results would have been the same and no revenue item was claim out of the authorized or allowable costs from the guidelines. The direct charges for this transaction to the federal award was for allowable costs under the instructions, federal grant and FAQs guidelines as indicated. Actions Taken or Planned: The institution understands that the incurred and direct charges to the federal award complied with the HEERF objectives and were allowable costs under the authorized uses in the grant award and HEERF guidelines and no further was required.

FINDING 2022-005 (Auditor Assigned Reference Number) Contact Person Responsible for Corrective Action: Greg Hunt, Assistant Superintendent of Business & Operations Contact Phone Number: (219) 362-7056 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: LaPorte Community School Corporation will review more closely the submission of costs of the Federal Special Education Grant to ensure that earmarking requirements of the Matching, Level of Effort, Earmarking compliance is followed. Anticipated Completion Date: May 15, 2023

2022 ? 001 ? Emergency Rental Assistance ? Assistance Listing No. 21.023 Condition: The County incorrectly processed a benefit payment that included an overpayment of $30 by inadvertently including utilities on top of base rent. Recommendation: We recommend the County review its procedures and controls over the processing of beneficiary payments to ensure amounts are properly paid and reimbursed. Views of responsible officials and planned corrective actions: The county agrees with the finding. The county will improve the controls over processing beneficiary payments to ensure that the proper amounts are paid to beneficiaries. ERAP program management, who review and determine eligibility, will pay closer attention to process allowable benefit payments based on base rent and not include utilities. Corrective action was taken in the spring of 2023 when this issue was identified during the 2022 audit. Responsible Official: Ramona Farineau, Chief Financial Officer Planned completion date for corrective action plan: May 31, 2023

FINDING 2022?003 Contact Person Responsible for Corrective Action: Maria Conwell Contact Phone Number: 260-868-2125 Views of Responsible Official: We agree with the finding. Description of Corrective Action Plan: DeKalb County Eastern Community School District 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 DeKalb Eastern during the writing process of the IDEA 611 and 619 grants in order for DeKalb Eastern to submit their plans for their allocation of proportionate share money. NEISEC will provide the allocation amounts to DeKalb Eastern. 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 DeKalb Eastern to the LEA and NEISEC. Any employee utilizing proportionate share funds that is not an employee of NEISEC, but rather a direct employee of DeKalb Eastern, will be paid directly by DeKalb Eastern. 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 DeKalb Eastern. For any expenses for a category outside of salary and benefits, DeKalb Eastern 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, DeKalb Eastern 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 completed 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.

Finding Number: 2022-004 Planned Corrective Action: Management will review expenditures allocated to grant funds for allowability. The District is able to provide expenditures for these funds that were determined to be unallowable. Anticipated Completion Date: 06/30/23 Responsible Contact Person: Eric Smeltzer, CFO/Treasurer

The district will implement procedures to ensure that personnel paid from federal funding complete single funding certifications and/ or time and effort logs.

FINDING 2022-003 Contact Person Responsible for Corrective Action: Sharon Fowler Contact Phone Number: (765) 358-4006 Views of Responsible Official: The Superintendent and Corporation Treasurer felt that expenses of $15,787.31 were justifiable due to the lack of fund raiser dollars for prom because of COVID. Part of that expense amount was for Esports Club chairs. These chairs are used for Esports only after school, and used during the day in regular classrooms. As for the Freshman Class Sponsor, Assistant Wrestling Coach, and Elementary Talen Show Sponsor, these contracts were paid from ESSER. The ECA positions were inadvertently added to teachers? contracts, as usual, and not taken out of the Education Fund. Description of Corrective Action Plan: Beginning with the 2022-23 fiscal year, we will be more careful with what we spend from ESSER Funds. Anticipated Completion Date: July 2023

Finding 2022-003: Payroll Records Documentation Organization?s Response: We concur Views of Responsible Officials and Corrective Action: Additional payroll documentation procedures will be initiated as future Federal funding is received. Name of Responsible Official: Leah Ladd Projected Implementation Date: August 2023

FEDERAL AWARD FINDINGS 2022-002 - ALLOWABILITY Recommendation: We recommend that the Council implement controls to ensure that expenditures are properly reviewed and approved before being charged to a federal award and that adequate supporting documentation is maintained. Action Taken: In February 2023, the current Fiscal Officer received formal training from the National Endowment for the Humanities' grants management staff on allowable costs and proper documentation procedures for federal grants and grant-making entities, under 2 CFR 200. The Fiscal Officer and all staff involved with federal grants subsequently reviewed the Council's internal procedures, to ensure that all expenditure paperwork is received, approved, and filed with the grant documentation.

FINDING 2022-003 Subject: Special Education Cluster - Earmarking Audit Finding: Significant Deficiency Condition: The School Corporation is a member of the Northeast Indiana Special Education Cooperative (Cooperative). The School Corporation did not have adequate internal controls in place to ensure that the Cooperative complied with the earmarking requirements. Context: The School Corporation is a member of the Northeast Indiana Special Education Cooperative (Cooperative). During fiscal year 2021-2022, the Cooperative operated the special education programs and spent the federal money on behalf of all its members. 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. 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 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 19611-042-PN01 and 20611-042-PN01 grant awards could not be verified for the individual schools to verify the minimum amount per the grant awards was expended and properly reported to IDOE as required. The School Corporation?s minimum earmarking requirements for the 19611-042-PN01 and 20611-042-PN01 grant awards were $1,095 and $1,791, respectively. The lack of internal controls and noncompliance were isolated to the 19611-042-PN01 and 20611-042-PN01 grant awards. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Hamilton Community Schools will work with the Northeast Indiana Special Education Cooperative to ensure proper oversight and internal controls are maintained of awarded monies. Responsible Party and Timeline for Completion: Brittany Taylor, Business Manager Completion Date: 6/30/2023

Finding 2022-005 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services Assistance Listing: Various ? Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Summary of finding: Management does not track expenses by budget period for Corewell East federal Research and Development (R&D) grants and is therefore unable to support that expenses are recorded in the appropriate period of performance. Corrective action plan: The hierarchy and functionality of the prior Corporate financial management system (prior to July 1, 2023) did not support separate budget periods during a single award project period. This was managed manually by the CHE Sponsored Programs Administration via a customized internal report. Effective July 1, 2023, the institution transitioned Corewell Health East onto Workday, the common financial management system already used by Corewell Health West. The Workday financial management system includes a separate grant module that has the capability to establish defined budget periods under a single award. CHE successfully transitioned to Workday beginning July 1, 2023. With the functionality now enabled by Workday, we do not anticipate any barriers to maintaining defined budget periods within an award funding cycle to assure that expenses are recorded in the appropriate period of performance. Individuals responsible for corrective action: Giacomo DeChellis, Sr. Director, Research Operations, Corewell Health East Timing of corrective action: July 1, 2023 and going forward.

FINDING 2022-002 Finding Subject: Child Support Enforcement - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Summary of Finding: An effective internal control system was not in place at the County to ensure compliance with the requirements related to the grant agreement and the Activities Allowed or Unallowed and Allowable Costs/Cost Principles compliance requirements. The payment of the Deputy Court Clerk?s wages and benefits out of the Clerk?s Incentive Fund supplanted not supplemented the employee?s salary which is unallowable. Contractual payment did not match the amount stated in the contract. The County did not have an allowable cost policy. Contact Person Responsible for Corrective Action: James W. Bramble Contact Phone Number and Email Address: 812-462-3361 james.bramble@vigocounty.in.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Internal control procedures will be evaluated to determine needed changes to correct the above noted compliance requirements over Child Support. Changes will be made to the 2024 budget to correct the payroll related issue so the Clerk?s Incentive Fund. Contracts will be reviewed to ensure the contract amounts are current. The County will develop an allowable cost policy. Anticipated Completion Date: January 1, 2024

#2022-002: Material Weakness in Controls over Compliance: Administrative Requirements of Uniform Guidance -Administrative Policies Recommendations: Grand Rapids Christian Schools should consider the following written policy additions or updates: ? Financial Management (2 CFR 200.302) The financial management policy should include records documenting compliance, and the tracking of funds to determine that expenditures are in accordance with the terms and conditions of the federal awards. The financial management and reporting system must provide the following : ? Identification - Title of the award, CFDA number ? Complete disclosure of accurate and current financial results of each federal award ? Source and application of funds for federal award activity ? Record retention and access - define the time period for which records must be kept (can vary by grant agreement), and who has the ability access the records (?200.333 - ?200.337) ? Written procedure to implement cash management requirements (see below) ? Written procedures for determining the allowability of costs (see below) ? Cash Management (2 CFR 200.305) A written policy is required by Uniform Guidance detailing the Organization's procedures to minimize the time that elapses between draw and expenditure of federal dollars. ? Allowable Costs (2 CFR 200.302(b)(7)) The Organization must have written procedures for determining the allowability of costs in accordance with Subpart E - Cost Principles of Uniform Guidance and the terms and conditions of the Federal award. This includes the determination of allowable costs and the review of this determination. The standard assumes policies and procedures are in place for disbursements, and the allowable cost policy will demonstrate how the Organization ensures compliance. The criteria for costs to be considered allowable are documented within 2 CFR 200.403. ? Procurement Standards (2 CFR 200.317 - 200.326) The Organization must have a written policy that promotes full and open vendor competition, conflict of interest policies should cover employees as well as the organization, and general purchase requirements with specific thresholds as set forth by the Uniform Guidance. There are five allowable procurement methods as described in ?200.320, depending upon the dollar value of the purchase or contract. Views of Responsible Officials and Planned Corrective Actions: ? Grand Rapids Christian Schools follows procurement and record retention standards provided by the USDA. ? GRCS does not have actual written policies and procedures for Financial Management, Cash Management, Allowable Costs, and Procurement Standards, but do have practices in place to follow USDA guidelines. In the case of cash management, the only location that takes cash is GRCHS. In that instance, along with Meal Magic, cash registers are zeroed out and balanced to Meal Magic and cash deposits are made daily. ? GRCS Business Office will work with the Food Service Director to begin formulating written policies and procedures specific to Grand Rapids Christian Schools. GRCS will utilize the resources from Uniform Guidance and Code of Federal Regulations (CFR) to develop policies that are compliant with those requirements prior to June 30, 2023.