Corrective Action Plans

FINDING 2025-005 Finding Subject: Contact Person Responsible for Corrective Action: Tracey Haas, Business Manager Contact Phone Number and Email Address: 219-873-2000 x 8346 thaas@mcas.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We will implement a system of internal controls to ensure allowable costs are documented and that receive board approval for all pay rates moving forward. However, we disagree with the finding on the allowable costs pertaining to the Financial Consulting Claims. We wrote them into the grant, and the grant was approved. There was also no Business Manager or Chief Financial Officer in place during the pandemic, resulting in the need for the consulting firm. Anticipated Completion Date: We anticipate that this correction will be in place by July 2026.

The Department of Environmental Services respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The finding from the schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U.S. Environmental Protection Agency Performance Partnership Grants – Assistance Listing No. 66.605 Disposition of Audit Finding: The Department of Environmental Services agrees with the audit finding. Corrective Action: According to (g),(vii),(B) Significant changes in the related work activity (as defined by the recipient's or subrecipient's written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; Many DES staff will work on multiple grants, and effort between grants may change from week to week. Reviewing the effort compared to amounts charged to a Federal grant for a single pay period may not be an accurate reflection of what the DES employees work over the life of that grant award. Reconciliations between payroll and effort occur over the life of the grant to ensure that all charges applied are reasonable and support the overall goal of the project on the longer term. To support this effort, budget staff will perform more periodic reviews of effort as compared to funding to identify situations where the difference between payroll and effort recorded are not on track to support the overall charges to a federal award. Anticipated Completion Date: Processed started July 1, 2025 and will ongoing. Simon Li will be responsible for corrective action: • Simon Li at 803-898-3443

FINDING 2025-006 Finding Subject: Title I Grants to Local Educational Agencies - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Findings: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Jennifer Felke & Jill VanDriessche Contact Phone Number and Email Address: 574-936-3115, jfelke@plymouth.k12.in.us, Views of Responsible Officials: We concur with the finding. We believe this finding to be the result of an isolated incident that was reported to SBOA and Title. Description of Corrective Action Plan: The Business Manager/Treasurer provides to the corporation grant administrator monthly grant reports, as well as a grant tracking spreadsheet. The appropriations for each grant are entered into Komputrol, according to the budget located in the approved grant documents. The appropriations are presented to the Grant Administrator for approval. All spending from each grant is approved by the corporation grant administrator. Any wages paid via the corporation payroll that is charged to grant funds is approved by the business manager/treasurer and the corporation grant administrator. The Payroll Specialist/Deputy Treasurer completes the payroll and sends the distribution account records to the Business Manager/Treasurer and Grant Administrator. Any payroll claims for payment via grant funds is required to have three signatures for approval. We believe the system of internal control in place has been strong and in compliance since March 2025. Anticipated Completion Date: March 1, 2025 and ongoing

FINDING 2025-004 Finding Subject: Child Nutrition Cluster, Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Findings: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Jennifer Felke & Amy Kraszyk Contact Phone Number and Email Address: 574-936-3115, jfelke@plymouth.k12.in.us, Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Since January 2025, the internal controls that resulted in this finding have been corrected. The finding stated that “The lack of internal controls and noncompliance over Allowable Activities and Allowable Costs/Cost Principles is an isolated incident.” The Food Service Director and the Business Manager/Treasurer meet monthly to review the school lunch accounts and to concur with the month end balances. The Deputy Treasurer approves all monthly fund transfers completed by the Business Manager. Anticipated Completion Date: January 1, 2025 and ongoing

Westminster College Corrective Action Plan (CAP) Federal Program: Economic Adjustment Assistance Program, Assistance Listing Number 11.307 Finding 2025-001: Questioned Costs – Allowable Costs/Costs Principles (material weakness) Name of Contact Person: Gerald J. Ganz, Jr., Vice President, CFO Specific Corrective Action: To prevent recurrence, the College is implementing the following measures: 1. Enhanced Funding Source Review Procedures: The College will develop and enforce a standardized review process requiring staff to verify and document the original funding source for any expenditure prior to charging it to a federal award. This process will include mandatory cross-checking between project accounting records, bond expenditures logs, and grant reimbursement requests. 2. Strengthened Internal Controls Over Capital Project Accounting: The College will implement additional controls within the accounting system to ensure expenditures tied to capital projects are flagged and reviews for potential dual funding before being charged to any federal program. 3. Training and Guidance for Staff: All personnel involved in grant management, accounting, and capital project administration will receive updated training on Cost Principles under 2 CFR 200.400-200.406, with emphasis on allocability, reasonableness, and the proper handling of applicable credits. 4. Ongoing Monitoring and Review: Quarterly internal compliance reviews will be conducted to confirm adherence to the new procedures, and corrective measures will be taken immediately if discrepancies are identified. The College is committed to ensuring full compliance with federal regulations and strengthening internal controls to safeguard all funding sources. We appreciate the opportunity to improve our processes and will implement the recommended procedures to ensure the integrity of future federal program expenditures. Anticipated Completion Date: June 30, 2026

Finding Number 2025-002 Condition: The District could not provide supporting documentation for one (1) invoice charged to the program. Management Response/Plan: The District acknowledges the finding and has strengthened internal controls over disbursements by implementing centralized invoice retention procedures and requiring verification of supporting documentation prior to payment approval. Staff have been retrained on documentation requirements, and periodic monitoring will be conducted to ensure all expenditures are properly supported and maintained. Anticipated Date of completion: June 2026 Name of Contact Person: Dr. Joe Mullikin

Finding Number 2025-001 Condition: The District was unable to provide documentation for three invoices charged to the program. The District was also unable to provide supporting documentation for one employee time card. Management Response/Plan: The District acknowledges the finding and has strengthened internal controls over disbursements by implementing centralized invoice retention procedures and requiring verification of supporting documentation prior to payment approval. Staff have been retrained on documentation requirements, and periodic monitoring will be conducted to ensure all expenditures are properly supported and maintained. Anticipated Date of completion: June 2026 Name of Contact Person: Dr. Joe Mullikin

The District will become more thoroughly aware of applicable compliance requirements and seek guidance in writing when necessary from the appropriate granting agencies. Anticipated Completion: January 1, 2026 Responsible Party: Lynette Thrasher, lthrasher@mcusd1.net 815-472-6477

FA 2024-002 Strengthen Controls over Journal Entries Compliance Requirement: Activities Allowed or Unallowed Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Federal Awarding Agency: U.S. Department of Agriculture Pass-Through Entity: Georgia Department of Education AL Numbers 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: Unknown Description: The policies and procedures of the School District were insufficient to ensure that journal entries made for the Child Nutrition Cluster were properly documented. Corrective Action Plan: All journal entries transferring cash from the School Nutrition Fund to the General fund will be done on a more frequent basis and include the detail of amounts used to arrive at the amount of the transfer. Estimated Completion Date: October 17, 2025 Contact Person: Danny Durham, Director of School Nutrition Telephone: 478-994-2031 Email: danny.durham@mcschools.org

VIEWS OF RESPONSIBLE OFFICIALS The PRDE does not agree with the Recommendation to establish an allocation method for TPFA invoices because TPFA services are overhead costs paid from administrative funds and are not tied to any specific federal grant. In addition, the PRDE does not agree that contract terms should be revised before the contract expiration to require a reconciliation of total hours and rates because again, payments to the TPFA are overhead costs not directly tied to any specific program. Finally, the PRDE does not agree with the recommendation that the TPFA submit supporting evidence for the reimbursement of expenses because (i) the TPFA contract is a fixed fee that is inclusive of all professional service fees and expenses and (ii) the TPFA provides an explanation of major expenses incurred within each monthly invoice. Auditor Comment on Management Response for Finding No. 2024-004 As stated in CONDITION 2., “…on invoice 830311-2023-32 the amount of $1,978,791 (85% of total invoice amount) was charged to several programs of ALN 84.425, although the services described in the invoice were not related only to these programs; therefore, the cost objective is not chargeable in accordance with the relative benefit received.” Further, the 2 CFR 200.1, establishes that: “Indirect [facilities & administrative (F&A)] costs mean those costs incurred for a common or joint purpose benefitting more than one cost objective, and not readily assignable to the cost objectives specifically benefitted, without effort disproportionate to the results achieved. To facilitate equitable distribution of indirect expenses to the cost objectives served, it may be necessary to establish a number of pools of indirect (F&A) costs. Indirect (F&A) cost pools must be distributed to benefitted cost objectives on bases that will produce an equitable result in consideration of relative benefits derived.” This information was not provided for our evaluation. Also, we made reference to the Program Determination Email for ALNs. 84.938 and 84.425 dated September 18, 2024 (Audit Control Number 02-21-39634), received from Ms. Catherine Miers of the Office of Elementary and Secondary Education of the US Department of Education (USDE), in which they required that the PRDE provide documentation for the following corrective actions: “revised the contract terms to include a reconciliation of total hours and rates to adjust the payments made to the vendor before the contract expiration; requested that adequate supporting evidence from the vendors be presented for any expenses to be reimbursed by the PRDE; and develop an adequate review of the vendors invoice to properly identify the actual hours of services that benefited the Federal programs so a correct allocation of the costs incurred can be made within Federal programs and state funds”. IMPLEMENTATION DATE None RESPONSIBLE PERSON Jullymar Octtaviani Vega Sub-Secretary of Administration María de los Angeles Lizardi Valdés Office of Federal Affairs Director

Management disagrees with the following A) Management determined the expenditures charged to the 2021-#3 project MSOC Security Sustainment Costs, for camera, installation and project management were clearly related to the Investment justification which requested sustainment and upgrade to the existing MSOC the IJ states : “Investment provides maintenance and upgrades of software/hardware (I.e. servers/workstations), video surveillance management systems, operating systems, cameras systems, access control and communication systems for Plaquemines Port Harbor and Terminal District B) Management determined the questioned cost charged to the 2023-#3 project GIS for the cameras and the conference room were supported with the investment justification however management agrees the invoices for Survey totaling $95,900 should not have been changed to the grant. C) Management determined the expenditures charged to the 2023-#4 project Cybersecurity Network and IT: For Datto Backup, which is the name of the program, and cyber security training are valid expenses and align with the investment justification Management will ensure the following processes are added to the financial management policies and procedures over federal and state funds • The District will establish formal procedures requiring that all PSGP expenditures be cross-checked against the approved Investment Justification (IJ) and verified for compliance with the grant’s period of performance prior to payment. No disbursement of federal funds will occur unless documentation demonstrates that the expenditure directly aligns with the approved grant scope and timing. • This documentation will be required within the system in order to process payments to the vendor. • The District will consult with FEMA to assess the allowability of identified questioned costs. Management will follow FEMA’s guidance to resolve any discrepancies and ensure that all expenditures meet federal standards. • Mandatory training sessions are being scheduled for staff involved in grant administration and financial management. These sessions will cover Uniform Guidance requirements, documentation standards, and procedures for verifying expenditure eligibility under PSGP. These actions reflect the District’s commitment to regulatory compliance, fiscal responsibility, and continuous improvement in federal grant management practices.

Corrective Action Taken Management concurs with the finding. The Organization transferred $151,099.42 from its operating funds back into the SFSP program account prior to the financial statements being available to be issued, thereby restoring the unallowable charge. Additionally, to prevent recurrence, the Organization obtained competitive bids and received approval for a written payroll services contract before June 2025, in advance of the start of the camp season (i.e. the Organization’s operating period). This process was conducted in accordance with federal procurement requirements. Planned Ongoing Corrective Action: The Organization has strengthened its procurement and contract approval procedures to ensure all future contracts funded by the SFSP are subject to competitive bidding, documented in writing, and approved by the State agency prior to charging costs to the program. Responsible Official: Chaim Mendel Friedman, Camp Program Administrator, is responsible for overseeing corrective actions and ensuring compliance with procurement standards and cost allowability requirements. Completion Date of Corrective Actions: Corrective actions were completed prior to the date the financial statements were available to be issued, with continuing oversight in subsequent program years.

COVID-19-Coronavirus State and Local Relief Funds (CSLRF)-Assistance Listing No. 21.027 Allowable Activities/Costs Recommendation: The Town should review and enhance controls and procedures where necessary. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Town will continue to review and enhance controls where necessary to ensure that all State and Local Fiscal Recovery Funds (SLFRF) expenditures support an eligible COVID-19 public health or economic response. Name(s) of the contact person(s) responsible for corrective action: Tyler Home, Director of Finance Planned completion date for corrective action plan: 07/01/2024

Georgia Tech management agrees that internal audit reports demonstrated departmental deficiencies in knowledge of policies and procedures that needed to be addressed. Upon disclosure of Internal Audit’s recommendations, the departments and central offices immediately responded with additional training, proactive compliance reviews, and re-enforcement of existing policies and procedures via Institute wide communications and enhanced reviews of support. New system controls regarding spend authorizations were put in place, with Georgia Tech’s Internal Audit department continuing to test these controls through the month of February. Central and departmental units within Georgia Tech will continue to work together to further enhance guidance and training to faculty and staff and to identify and test controls in our systems that will mitigate these issues.

The County Commission will work directly with the vendor to ensure future payment requests properly align with payment information listed on the federal contract.

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

Item 2023-006 Activities Allowed or Unallowed/Allowable Costs/Cost Principles Head Start ALN# 93.600 US Department of Health & Human Services (Repeat 2022- 008) Federal Grant/Contract Number: 10CH011215-03-03; 10CH011215-03 C3; 10CH011215-04; 10HE000901-01-C6 Grant period – 2022 & 2023 The HS program has established an internal process of requester/approver in place to review transaction requested. Documents then get reviewed again by HR or Finance staff based on the transaction type before getting processed.

Grants are looked at for compliance and ensures proper spending and documentation.

FINDING 2023-003 Finding Subject: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Tyler Pearson, Clerk Treasurer Contact Phone Number and Email Address: 574-739-1416 clerktreasurer@cityoflogansport.org Views of Responsible Officials: We concur with the findings. Description of Corrective Action Plan: As a measure of corrective action, I will be implementing a check sheet that will be attached to every claim sheet. This new procedure requires that you go through the check sheet and initial each item to ensure that all procedures have been followed correctly before submission. Additionally, I will also maintain a check sheet in my office since I am the last person to review each claim. This will help to ensure thoroughness and accuracy in our claims processing. Furthermore, moving forward, any grant funds will be placed into their own individual funds and distributed through an individual account. This approach will allow us to track payments for any expenses associated with these funds more effectively. Additionally, the BOT expenditure is done and in the future we will do a better job. Anticipated Completion Date: October 31,2025

Finding Number 2023-109 Subject Heading (Financial) or AL no. and program name (Federal) ALN: Multiple Federal Program name: Multiple Planned Corrective Action The finding states two ongoing concerns: “1) there are no policies and procedures in place for the people on [the pilot program] Statewide Contracts [as is required by 2 CFR § 200.317], and 2) these vendors are not being vetted to ensure state agencies are getting contracts that are reasonable per 2 CFR 200.404.” On the first issue, Section 200.317 of Title 2 of the Code of Federal Regulations requires states to “follow the same policies and procedures it uses for procurements with non– Federal funds” when “conducting procurement transactions under a Federal award.” 2 CFR § 200.317. Our publicly available CPO training explains the process for purchasing off Statewide Contracts (See Attachment 1 and 2). Also, we provided agencies with procedures related to the pilot program to give guidance on ordering off those specific Statewide Contracts (See Attachment 3). Additionally, OMES reiterates that Recipients of federal funds are ultimately charged with ensuring and documenting compliance with specific requirements under the federal award. However, in an attempt to assist agencies in understanding requirements of spending federal dollars, OMES issued a Procurement Information Memorandum and a new contract attachment to be utilized by agencies. (See Attachments 4 and 5). Therefore, OMES disagrees that we do not have the required policies and procedures in place to comply with Section 200.317. On the second issue, Section 200.404 of Title 2 of the Code of Federal Regulations explains, “A cost is reasonable if it does not exceed an amount that a prudent person would incur under the circumstances prevailing when the decision was made to incur the cost.” All our Statewide Contracts are evaluated on specific criteria, including pricing. If a bidder’s pricing appears to be unreasonable, they do not receive an award. Additionally, in Attachment 3 it is demonstrated that when an agency ordered from the pilot program Statewide Contracts, the Information Services Division (“ISD”) of OMES works with the agency and the supplier to develop a Scope of Work (“SOW”). The SOW is comprised of detailed deliverables and pricing for the relevant goods and/or services. ISD stakeholders are subject matter experts in the relevant work and ensure that all pricing on SOWs is fair, competitive and reasonable. Therefore, OMES also disagrees with the assertion that the vendors on contract are not vetted to ensure that state agencies are getting reasonable costs on their contract. OMES further reiterates that we believe the relevant solicitations were conducted pursuant to the requirements of the Statewide Contract pilot programs and meet competitive bidding requirements. The Statewide Contract pilot programs utilized the same initial procedures as all other Statewide Contracts prescribed in statute. Vendors are required to agree to standard state terms and submit competitive pricing for the goods and/or services within scope of the solicitation. OMES identifies evaluators for every solicitation to conduct an evaluation process relevant to the particular scope of services and to negotiate price when choosing responsive and responsible suppliers. In conclusion, OMES respectfully disagrees with the concerns of the State Auditor’s Office and invites any member of the State Auditor’s team to meet with OMES personnel to further clarify our processes and standards for ensuring fair and competitive procurement practices. Anticipated Completion Date Sine Die Responsible Contact Person

Plan: BCPN confirms that indirect costs are calculated in accordance with government guidelines outlined in 2 CFR Part 200. Anticipated Date of Completion: 4/26/2025 Name of Contact Persons: Ieesha Jones Management Response: Due to adopting to use a calendar year instead of a fiscal year, BCPN's indirect costs for FY24 will be reflected in the financial statements for the period ending June 30, 2024, rather than December 31, 2023. We confirm that the indirect costs are being billed and spent in compliance with the guidelines outlined in the government contract and there is no need for funds to be returned.

Assistance listing numbers and program names: 21.023 COVID-19 - Emergency Rental Assistance Program 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Agency: Arizona Department of Economic Security (DES) Name of contact person and title: Molly Bright, DES CCSD Assistant Director Anticipated completion date: June 30, 2026 Agency’s Response: Concur The Department of Economic Security will address the audit recommendations as follows: 1. Ensure benefit payments are for allowable costs paid to or on behalf of eligible program applicants. The Department will review and confirm that benefits payments paid to or on the behalf of eligible program applicants are allowable expenditures of the federal funding being disbursed. 2. Follow existing policies and procedures to obtain required documentation to support requirements related to where the applicant lives and their income to ensure program applicants are eligible to receive benefit payments. The Department will abide by the existing adjudication policies and procedures that require the submission of substantiating documentation supporting the claims made by applicants regarding where they live and their household income to confirm that applicants are eligible to receive benefit payments under the program and to verify the amount of benefits they shall receive. 3. Allocate sufficient staffing resources to perform a thorough evaluation of program benefits applications and provide training on eligibility requirements and allowable benefit payments. The Department will attempt to obtain or allocate additional resources to staffing to support the program benefits application evaluation process and will provide additional training to staff on eligibility requirements and allowable benefit payment regulations. 4. Update the checklist Division personnel use to perform a post-review of eligibility determinations to include detailed guidance for verifying the determinations aligned with the Division’s written policies and procedures and supported by adequate documentation. The Department will update the checklist being used by staff to perform post-review of eligibility determinations to include detailed guidance on verifying the applicant benefits determinations in alignment with the divisional policies and procedures and evidenced by adequate substantiating documentation.

2023-002 Approval of Living Allowance Payments: Management Response: Management will include others on correspondence regarding approval of payroll, which will help detect when an approval of payroll is not made timely. If payroll is not approved before paid, then Management will perform a documented review to ensure payroll payments are proper. Management will also develop a policy to stop living allowance payments timely when a member will not meet their service hour obligation. Responsible Person: Lisa Moore, Executive Director Anticipated Remediation Date: Fiscal year ending August 31, 2024

Finding # 2023-004 Title of Finding Allowable Costs/Costs Principles Contact Person Jeremy Young Anticipated Completion Date 06/30/2024 Corrective Action planned to be taken: The County Commission will seek reimbursement for the amounts paid in excess of contractually stipulated prices directly from the vendor.

DOC will institute internal controls to review and monitor, on a quarterly basis, medical costs billed from the pharmaceutical vendor to ensure the billing is consistent with contract language. The review will be done by a Fiscal Management Specialist (FMS). The internal control will consist of the following: - Beginning with the December 2023 invoice, DOC will request fully executed procurement documents from the pharmaceutical contractor to verify acquisition costs. - The current contract language states that pharmaceuticals are billed at actual acquisition costs plus a dispensing fee. Therefore, the FMS will match the acquisition cost for the vendor for a sample of transactions to the invoices received from the vendor. - DOC will conduct this review on the pharmaceutical invoices for March, June, September, and December in each year continually. - DOC will document the review using an excel spreadsheet that has the universe of pharmacy orders by patient – matching the records and recording the date the review was done. All documents will be saved in an internal medical invoice folder. - Reviews will be completed by the last day of the month after the invoice is submitted. - Training on the new process will be done by March 31, 2024. Findings (or lack thereof) will be reported to DDAP by April 30th, July 31st, October 31st, and January 31st of each year via email. - If there are discrepancies, the vendor will be contacted immediately and a true-up will be requested in the next month’s invoices (either a credit or a debit depending on the discrepancy). DOC will continue to utilize PACE to complete full audits on reasonability of drug prices. DOC acknowledges, due to purchasing and distribution practices for the pharmaceutical vendor, Sublocade was not on prior reports. However, in the third and fourth quarter of 2023, Sublocade was added to the quarterly PACE audits for reasonability of drug prices. DOC has spoken with PACE and will now receive all quarterly audits and will be invited to all meetings between PACE and the contracted pharmaceutical vendor to discuss any findings. Anticipated Completion Date: 03/31/2024 Contact Names: Erica Benning, Director, Healthcare Services; Jodilynn Jacob-Byrd, Fiscal Management Specialist