Corrective Action Plans

FINDING 2024-002 Finding Subject: Special Education Cluster (IDEA) - Earmarking Contact Person Responsible for Corrective Action: Bethany Cmar Contact Phone Number and Email Address: 765-641-2126 (Bcmar@acsc.net) Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: When it comes to expenditures for non-public schools, ACS will assign a unique tracking number to each school, allowing expenditures to be easily traced for this requirement. The overall earmarking requirements will be compiled annually by the Special Education Director and sent to the CFO for review and approval, ensuring compliance with the requirements. Anticipated Completion Date: March 31, 2025

Finding 2024-003, Unallowable Expense (Assistance Listing 93.696) Persons Responsible: Irene Math, Chief Financial Officer, Jessica Schneibolk, Controller Comment: Per 2 CFR § 200.403, costs charged to a federal award must be necessary, reasonable, and allocable to the program. Assistance Listing Number 93.696, Certified Community Behavioral Health Clinic, requires that costs allocated to the program meet these criteria to ensure compliance with federal regulations. Response: WJCS acknowledges the audit finding related to an unallowable expense charged to the Certified Community Behavioral Health Clinic program. We agree with the recommendation to strengthen internal controls and have identified the cause as an isolated error due to invoices posting in the ledger prior to approval. To address this, we updated the accounts payable system so invoices will not post to the general ledger until approved. Estimated Completion Date: These corrective actions were implemented in February 2025.

Department: Health and Human Services Title: Internal control over Medicaid paid medical claims needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Department will require the vendor to create a procedure to be used to prepare this report which will be tested and validated by the vendor and the Office of MaineCare Services. Completion Date: June 1, 2025 Agency Contact: Michelle Probert, Director, Office of MaineCare Services, DHHS, 207-287-2093

Department: Health and Human Services Title: Internal control over Medicaid cost of care assessments and deductions needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Office of MaineCare Services will request an update to the Retroactive Cost of Care report to correct the logic that resulted in a missed cost of care change. Completion Date: June 1, 2025 Agency Contact: Ian Yaffe, Director, Office for Family Independence, DHHS, 207- 592-1481

Department: Health and Human Services Administrative and Financial Services Title: Internal control over the Foster Care – Title IV-E and Adoption Assistance – Title IV-E programs FMAP rates needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Information Services Unit Manager will organize an annual meeting to include the OCFS COO, the OCFS PFO and appropriate representatives from DAFS, on or about August 1st to formally discuss the FMAP and agree on its implementation. Meeting will be set as an auto reoccurring meeting updated annually to include the appropriate staff to attend. A Placeholder for the Annual FMAP update will be entered annually into Katahdin's life cycle management system (Octane) to allow the FMAP update activity to be formally tracked. A screenshot of the entered FMAP rate from Katahdin will be sent out to the same group after the meeting when the rate is entered into the Katahdin system. Completion Date: April 1, 2025, first and second item, and August 15, 2025, third item Agency Contact: Robert Blanchard, Associate Director, OCFS, DHHS, 207-624-7955

Department: Health and Human Services Title: Internal control over the Adoption Assistance – Title IV-E eligibility and benefit determination process needs improvement Questioned Costs: Known: ALN 93.659 $10,860 Likely: Undeterminable Status: Corrective action in progress Corrective Action: The Adoption Program Manager will continue to review the final Adoption Assistance Packet for completeness before approval. The Adoption Manager will review the most current Level of Care in foster care in the Child Welfare System to verify proper subsidy rates prior to approval. The Adoption Manager will work with the OCFS team on implementing and training on the updated Adoption Policy. The Office of Child and Family Services will organize a workgroup to evaluate how to improve the financial review process and define any changes needed to be implemented in Katahdin to support validating payments are processed appropriately. All children entering adoption must have a completed determination by the District FRS for verification of third-party benefits/Social Security. Effective date of last audit 2024, the documentation procedure was changed to clearly shows any determination. This is documented within the adoption application for all cases. This verification is used to determine an appropriate adoption assistant rate. Completion Date: March 1, 2025, first, second and fifth items, September 1, 2025, third item, and November 1, 2025, fourth item Agency Contact: Karen Benson, Adoption Program Manager, OCFS, DHHS, 207-561-4208

Department: Health and Human Services Title: Internal control over the Foster Care – Title IV-E and Adoption Assistance – Title IV-E eligibility and benefit determination process needs improvement Questioned Costs: Known: ALN 93.658 $4,647 ALN 93.659 $9,367 Likely: Undeterminable Status: Corrective action in progress Corrective Action: The Title IV-E Program Manager will continue to educate and train the FRS on the proper completion of the Title IV-E initial determination checklists for their FRS files, including the importance of signing off on those checklists for the initial determinations that they have completed. The Title IV-E Program Manager will conduct quarterly quality assurance (QA) reviews in the District that this issue was found, randomly pulling 10 cases to ensure compliance. When FRS staff conduct QA reviews, they will continue to be advised to monitor if signatures are present on the Title IV-E initial determination checklist. Reviewing if a checklist is signed is an existing question within our internal QA review document. The Department will establish a work group to identify the challenges of managing overpayments made to foster parents and to develop a process to minimize this problem. The Department will finalize and receive approval of the protocol/process form managing overpayments. The Department will implement the new overpayments management procedures. Completion Date: March 26, 2025, March 31, 2025, July 1, 2025, September 1, 2025, and November 1, 2025 respectively Agency Contact: Robert Blanchard, Associate Director, OCFS, DHHS, 207-624-7955

Department: Health and Human Services Administrative and Financial Services Title: Internal control over CCDF period of performance needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The DHHS Financial Service Center will enhance policies and procedures for the CCDF grant by modifying the FSR Reviewer Checklist. Completion Date: April 30, 2025 Agency Contact: Sarah Gove, Director, DHHS Service Center, DAFS, 207-458-6626

Department: Health and Human Services Title: Internal control over payments made to TANF clients needs improvement Questioned Costs: Known: $1,014 Likely: Undeterminable Status: Corrective action in progress Corrective Action: The Department will increase monitoring procedures over payments, specifically the tracking of required receipts, by the ASPIRE Team. The Department will review and update Standard Operating Procedures to ensure that payments made to TANF clients are accurate, allowable, and adequately documented. Completion Date: June 30, 2025 Agency Contact: Ian Yaffe, Director, Office for Family Independence, DHHS, 207-592-1481

Department: Education Administrative and Financial Services Title: Internal control over Special Education period of performance needs improvement Questioned Costs: Known: ALN 84.027 $7,303 Likely: ALN 84.027 $31,678 Status: Corrective action in progress Corrective Action: The Office of Special Services & Inclusive Education (OSSIE) fiscal team will perform a detailed review of all expenses charged to the closing grant during the 120-day liquidation period beginning October 1 of each year. The OSSIE fiscal team will notify GGSC to no longer allocate expenses to the closed grant period as of the review date. Any expenditure identified that do not fall within the period of performance of the grant will be journaled to the appropriate account. Completion Date: January 28, 2026 Agency Contact: Barbara McGowen, Director of Financial Management for the Office of Special Services & Inclusive Education Birth to 22, DOE, 207-624-6645

Department: Education Title: Internal control over CNC claim reimbursements needs improvement Questioned Costs: Known: ALN 10.555 $1,605 ALN 10.582 $9,535 ALN 10.559 $117,259 Likely: Undeterminable Status: Corrective action in progress Corrective Action: Child Nutrition Services will create a procedure for reviewing applications and making sure they are approved prior to participation. For the Summer Food Service Program (SFSP), the Child Nutrition Services will create an additional application, outside of CNPWeb to further assess non-congregate operations and eligibility to prevent duplicative services. Child Nutrition Services has submitted a ticket to create an edit check on the SFSP Application to ensure that all specific eligibility information is submitted. Child Nutrition Services will create a procedure to address that session specific information is received prior to claim approval for sites. Child Nutrition Services will require a site sheet for SFSP applications for each location and each enrollment period. Child Nutrition Services will submit a ticket to CNPWeb to allow for documentation to be added to the site information sheet when revisions are made to the system. Child Nutrition Services will add documentation to the activities tab, while we wait for the enhancement to be completed. Child Nutrition Services will create a procedure to ensure that allocations to schools fall between $50.00 - $75.00. Child Nutrition Services has provided training to the National School Lunch Program reviewers on the Fresh Fruit and Vegetable Program questions within the Administrative Review process to ensure that those questions are asked during the Administrative Review. Completion Date: May 1, 2025, first and fourth items, April 1, 2025, second, fifth, sixth, and seventh items, June 1, 2025, third item, March 1, 2025, eight item, and February 10, 2025, for nineth item Agency Contact: Jane McLucas, Director of Child Nutrition, DOE, 207-624-6880

Department: Health and Human Services Title: Internal control over automated SNAP eligibility certification periods needs improvement Questioned Costs: Known: ALN 10.551 $3,973 Likely: Undeterminable Status: Corrective action in progress Corrective Action: The Department believes the necessary corrective action has been taken and will be reflected in the SFY25 audit. The Department implemented the following corrective action steps: 1) Returned to normal batch processing following the suspension of closures and pushing out of renewal dates related to the PHE and unwinding period. 2) Enhanced renewal appointment functionality in ACES to allow each program to be processed independently. 3) Runs monthly queries to identify cases that had their periodic reports withdrawn in error and reestablish them. Completion Date: October 1, 2024, first and second item, and June 30, 2024, third item Agency Contact: Ian Yaffe, Director, Office for Family Independence, DHHS, 207-592-1481

Department: Health and Human Services Title: Internal control over SNAP deceased client cases needs improvement Questioned Costs: Known: ALN 10.551 $11,080 Likely: Undeterminable Status: Corrective action in progress Corrective Action: The MaineCare Program Manager will assign Death Match work to their team. The MaineCare Program Manager and their team will develop a Standard Operating Procedure for matches with vital statistics at Maine CDC. Completion Date: July 16, 2025 Agency Contact: Michael E. Downs, Senior Program Manager — SNAP, DHHS, 207-592- 4850

Department: Health and Human Services Title: Internal control over SNAP eligibility determinations and benefit calculations needs improvement Questioned Costs: Known: ALN 10.551 $12,335 Likely: Undeterminable Status: Corrective action in progress Corrective Action: The Department will automate the issuance of the TANF funded resource guide at Application and Recertification (existing ticket AO-4039). (Business Technology Lead) The Department will keep SNAP applications from being opened in batch runs such as mid-month and end-of-month mass change. (Business Technology Lead) The Department will provide updated training/reminders about start and end dating records including income records to retain the information used for benefit runs. (Training Team and Senior SNAP Program Manager) Completion Date: August 31, 2025, first item, and September 30, 2025, second and third items Agency Contact: Michael E. Downs, Senior Program Manager — SNAP, DHHS, 207-592- 4850

Finding Number: 2024-001 Planned Corrective Action: Meals on Wheels of the Monterey Peninsula (MOWMP) will address the finding by taking the steps outlined below: 1. Expenditure Allocation: Controller and/or bookkeeper will allocate expenditures based on the number of meals prepared each month and the percentage of meals prepared for each program and funding. Yearly reviews of the allocation process will be conducted to ensure accuracy and relevance. Adjustments may be made based on changes in meal demand, program requirements, funding sources, or other factors affecting meal preparation costs. 2. Payroll Reporting: On a yearly basis, Managers and/or Directors will allocate the amount of time each employe works based on tasks performed and the amount of time worked on federal award activities. This allocation will be expressed as a percentage of total work hours performed. Periodic adjustments to time allocations may be necessary to reflect changes in project priorities, staffing levels, or other factors affecting workload distribution. Person Responsible for Corrective Action Plan: Leadership Oversight – Christine Winge, Executive Director Operational Oversight – Kay Smith, Controller Anticipated Date of Completion: MOWMP will complete the Corrective Action Plan by June 1, 2024 and these new policies and procedures will be in full effect throughout fiscal year 2025 and beyond. We will continue to review effectiveness and make changes as necessary.

FA 2024-001 Strengthen Controls over Transfers 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 Agriculture Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: 10.553 - School Breakfast Program 10.555 - National School Lunch Program COVID-19-10.555 - National School Lunch Program Federal Award Number: 245GA324N1199 (Year: 2024), 225GA324N1099 (Year: 2024) Questioned Costs: $803,845.92 Prior Year Finding: None Identified Description: The polices and procedures of the School District were insufficient to provide adequate internal controls over transfers of Child Nutrition Cluster funds. Corrective Action Plans: The School District will review current internal control procedures related to School Nutrition Fund transfers. Development and/or modification of current policies and procedures will be determined as needed to ensure that all expenditures, including transfers, are used for allowable purposes. In addition, the School District will implement a monitoring process to ensure that all expenditure activity is compliant with the School District's policies and procedures. Estimated Completion Date: June 30, 2025 Contact Person: Debbie Woerner, Finance Director/Asst Superintendent Telephone: 770-567-8489 ext. 1030 Email: woerned@pike.k12.ga.us

FINDING 2024-004 Finding Subject: Special Education Cluster – Earmarking Contact Person Responsible for Corrective Action: Marcia Fullenkamp, Treasurer Contact Phone Number and Email Address: (812) 623-2212; mfullenkamp@rodspecialed.org Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Expenses for non-public schools are tracked and charged to the appropriate corporation. Staff record time spent at each non-public school, sign and date the form and turn it into the treasurer. The expenses are then moved to the correct expense line on the grant after receiving this information. Materials that are purchased are charged to the correct expense account when paid. Anticipated Completion Date: July 1, 2023

FINDING 2024-005 (Auditor Assigned Reference Number) Finding Subject: Special Education Cluster (IDEA)- Period of Performance Contact Person Responsible for Corrective Action: Julie Remschneider Contact Phone Number and Email Address: julie.r@nn.k12.in.us, 219-285-2228 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We will ensure the Special Education Co-op will have controls in place to make sure payments are made within the period of performance. Anticipated Completion Date: September 30, 2025

FINDING 2024-005 Finding Subject: Special Education Cluster (IDEA) – Earmarking Contact Person Responsible for Corrective Action: Carolyn Wallace Contact Phone Number and Email Address: 812-738-2168, extension 102 and WallaceC@shcsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The failure to expend all of the funding set aside for nonpublic schools was caused by several factors, including significant changes within the leadership of the nonpublic schools being served and parents’ refusal of services in lieu of vouchers being received to provide private services. The following corrective actions will be implemented with the intentions to fully expend the set-aside funding, account for the expenditures by location, and to document those efforts:  Attain documentation from the nonpublic schools being served to document the discussions about planned and allowable spending.  When it is projected that the nonpublic proportionate share will not be fully expended, documentation will be requested from the nonpublic school detailing the cause so that the waiver can be submitted.  Attend updates offered from the Indiana Department of Education for Special Education. Retain appropriate documentation from these meetings to support decisions made regarding the grants.  Account for all expenditures by nonpublic school location and prepare proportionate share reports utilizing the location-specific information. Anticipated Completion Date: April 1, 2025

FINDING 2024-004 Finding Subject: Special Education Cluster (IDEA) – Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Carolyn Wallace Contact Phone Number and Email Address: 812-738-2168, extension 102 and WallaceC@shcsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Personnel involved in the purchasing process will review materials prepared by the Indiana Department of Education related to allowable costs. The specific questioned cost was for the provision of classroom snacks for the developmental preschool students. These have been provided as they are food costs above or and beyond routine school food costs. However, based upon guidance provided by the State Board of Accounts, reimbursement for snacks provided to the developmental preschool students will be sought. Anticipated Completion Date: April 1, 2025

Condition: Of the 40 samples included in our sample selected for testing in the Research and Development Cluster (R&D), the University included two invoices for a total of $2,618 that were incurred prior to the beginning of the grant period. Planned Corrective Action: The university has implemented a new grant financial and billing software that provides improved controls over operational transactions, including an Award Calendar control that recognizes the award end date in the invoice posting process. The costs described in this finding, which occurred before the new system was implemented have been removed from the existing grant and replaced by other allowable costs that were incurred within the proper award period. Contact person responsible for corrective action: Associate Controller, Brenda Lindberg Anticipated Completion Date: The new grants module, which includes grant billing and award calendar schedule became operational at July 1, 2024.

2024-001 – Internal Control over Compliance and Compliance with Activities Allowed or Unallowed and Allowable Costs/Cost Principles Contacts: Regina Frazier Title: Payroll Manager Anticipated Completion Date: September 2025 Corrective Action: The Center is dedicated to maintaining compliance with federal regulations concerning allowable and unallowable activities and costs. In response to the recent audit finding, the Center’s payroll department will proactively engage with key stakeholders in high-risk areas prior to the start of the fiscal year. This engagement will involve reviewing payroll submission templates and ensuring that the rates align with the most current employment agreements. Status as of March 2025: All affected employees have been reimbursed, and key stakeholders in high-risk areas have been informed of the corrective action plan.

FINDING 2024-005 Subject: COVID-19 - Education Stabilization Fund - Allowable Costs/Cost Principles and Allowable Activities Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425C, 84.425U Federal Award Numbers and Year (or Other Identifying Numbers): S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Allowable Costs/Cost Principles Audit Findings: Material Weakness, Modified Opinion Person Responsible for Corrective Action: Chad Yencer - Superintendent Contact Phone Number: 765-348-7550 Views of Responsible Official: Agree Description of Corrective Action Plan: This was a singular occurrence where the rate for a remedial program was not approved by the BCS school board, and where the payments did not tie back to an allowable cost. This program and fund are no longer active. Anticipated Completion Date: Completed

Finding 2024‐003 Subject: Child Nutrition Cluster – Allowable Costs/ Cost Principles Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children Assistance Listings Numbers: 10.553, 10.555, 10.559 Compliance Requirement: Allowable Costs/ Cost Principles Audit Findings: Material Weakness, Other Matters Contact Person Responsible for Corrective Action: Julie Dodd, Treasurer Contact Phone Number: 765-348-7550 Views of Responsible Official: We concur with the finding of the auditor Description of Corrective Action Plan: This was a singular occurrence in which indirect costs were applied in the wrong year. Moving forward, no indirect costs will be charged or paid outside of the correct time period for the fiscal year. Anticipated Completion Date: Completed

Reference Number: 2024-010 Prior Year Finding: 2023-008; 2022-017 Federal Agency: U.S. Department of Labor State Agency: Vermont Department of Labor Federal Program: Unemployment Insurance Assistance Listing Number: 17.225 Award Number and Period: Admin 24A55UI000063 (10/1/2023-12/31/2026), DUA 23A60UD000013 (7/14/2023 - 7/14/2026) Compliance Requirement: Period of Performance Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Recommendation: We recommend the Department review and enhance its procedures and controls to ensure that prior to charging costs to the program, they are incurred within an award’s allowable period of performance. Views of responsible officials: Management agrees with the finding. Corrective Action Plan: The Department will review its procedures and internal controls and update as necessary to ensure that expenditures are incurred within the allowable period of performance for respective awards. It should be noted that during the period of performance for which this audit was conducted there were a large number of personnel changes and shifts. The position that was responsible for the majority of these duties retired in January 2024. We proactively hired for her replacement a year before she retired. Over the course of the year our replacement took over more and more duties. In the process of this replacement, we have completed a tremendous amount of evaluation of our assigned duties, processes, workflow, training, and documentation. Not only in this role, but we are also undergoing a division and business unit wide analysis of our internal controls and workflow. It should also be noted that the UI admin funds are considered ‘formula funds’ from the US DOL. We are expected to run this program year-round with no gaps in service or performance. The funding that we receive from US DOL is based on an antiquated formula that breaks down the amount that is budgeted by Congress between 52 state and territories. We generally do not receive enough funding for the entire year. Also, with the recent trend of Congress to utilize the tool of the Continuing Resolution our funding is often ambiguous until most of the program year is over. We have at times seen our funding cut once a budget had been passed by Congress even though there was only about 3 months left in the program year. We are still expected to run this program and ‘find other sources of funding’. This does make the adherence to the period of performance challenging. However, as we evaluate our internal controls and procedures over the coming months, we will make note of every opportunity to strengthen this function to ensure that all charges applied to program funds are relevant, within the period of performance of the award, and are correctly reviewed and signed. Scheduled Completion Date of Corrective Action Plan: April 1, 2025 Contacts for Corrective Action Plan: Chad Wawrzyniak, Financial Director II chad.wawrzyniak@vermont.gov