Corrective Action Plans

COVID-19 EDUCATION STABILIZATION FUND ? ASSISTANCE LISTING 84.425U PASSED THROUGH THE PENNSYLVANIA DEPARTMENT OF EDUCATION; GRANT PERIOD ? YEAR ENDED JUNE 30, 2022. Management Response: An invoice was accidently allocated to both federal programs but was corrected before ARP final reporting was done. Corrective Action Plan: All final reporting will be reviewed, and any duplicate dollar figures will be reviewed to ensure expenditures are not duly list. Person Responsible: Christina Bason, Superintendent Anticipated Completion Date: Immediately

Management?s Response: FSA have selected ADP as a third-party payroll services that allows for Human Resource and Payroll to use the same employee information that will be entered by the Human Resource Department and does not had to be replicated by Payroll. This will ensure that all updates in payroll to be updated in real time with no documentation delays. FSA went into an agreement with ADP May 2022 to begin implementation development of a system that would meet our needs to prevent this delay between MIP system when the staff updates the NOVA time system after the personnel action form is reviewed and approved.

Management?s Response: In January 2022, during the processing of FSA payroll, the system had a major error that caused for an emergency payroll processing to take place to meet the Labor and Wages standards, so this payroll was processed not knowing that it was paid based on home allocation rather then time sheets allocations. However, the majority of FSA employees were allocated to one department program or grant. Reassigning of location only occur within staffing emergencies within the same program. Due to this occurrence, FSA started to investigated a third-party payroll servicing company that uphold our standard of functional time keeping and allocation and selected ADP. Gross pay information for each employee is extracted from the Payroll Journal and entered into the Labor Distribution. Periodically, time sheet information is entered into the Labor Distribution and percentages developed or functional time which are used to allocate gross pay to each program based on total time worked. The Labor Distribution is used to post the allocated payroll costs to the General Ledger, or billing worksheet, and the related costs then posted to the billing or reporting document.

Management?s Response: Effective fiscal year 2022-23, the Association will follow section 2 of the CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. The costs, for which the benefit can be directly identified, will be charged to the benefiting grant and category. Shared/Joint costs will be charged based on employees? time reported (timesheet and labor distribution), units of services (meals, care management units, number of-participants, hours of service, etc.), square footage, or other method that will result in an equitable allocation of costs. Currently, direct-shared costs for the Child Care and the Senior Services Programs are pooled by program area. The direct-shared cost pool and pooled facilities costs are then allocated to each funder within the respective program. We have immediately implemented a change in procedures to recalculate our Cost Allocation Plan on a quarterly basis, based on using the previous quarter's payroll labor distribution report by program to calculate the FTE for the upcoming quarter cost allocation. However, if a funder disallows a particular expense item, after the determination of their portion, it is applied to Unallowable and paid with unrestricted funds of program or agency.

Panthera implemented Chrome River which is a platform that enables electronic review and approval of invoices as part of Panthera?s expense management process. As Panthera expands its operations internationally we plan to implement more controls and procedures to ensure foreign affiliates are properly maintaining all required expenditures documentation and approvals on spending.

Significant deficiency in internal controls over compliance and instances of noncompliance related to allowable costs. Contact Person(s): Beth Mizushima, Chief Operating Officer, mizushimab@crhn.org; and Connie Sowa, Compliance, Governance and Contracts Officer, sowac@crhn.org. Explanation and specific reasons for disagreement with the audit finding or that corrective action is not required (if applicable): Not applicable. Corrective action planned: Paylocity, third party payroll processor, was implemented in October FY23. In FY23 we have reviewed payroll for each month to ensure the charge to the awards are the same as the actual allocation percentage to each grant, and have strengthened the internal controls over the complete, timely and accurate recording of payroll expenses for each payroll. The new internal controls include reconciling the Paylocity system reports to the bank reconciliations and the final journal entries to record the payroll expenses. Anticipated completion date: Completed September 2023.

CORRECTIVE ACTION PLAN Finding 2022-001 Internal Control over Bank Reconciliation and Vendor Invoice Management Response: Management agrees with this recommendation and have taken steps to implement proper review and documentation for bank reconciliations and vendor invoice approvals. Person Responsible: President/CEO, Finance Officer, and Program Managers Finding 2022-02 Debarred and Suspended Vendors Management Response: Management agrees with this recommendation and have taken steps to develop and implement proper internal controls. Person Responsible: Finance Officer and Program Managers Finding 2022-03 Monitoring Subcontractor Performance Management response: Management agrees with the recommendation and have scheduled training for key personnel. Person Responsible: Program Managers Finding 2022-04 Written Approval of Subcontractors Management Response: Management agrees with this recommendation and have scheduled training for key personnel. Person Responsible: President/CEO and Program Managers Finding 2022-005 Indirect Cost Allocation ? Questioned Costs Management Response: Management agrees with the need for additional grant training, especially as it applies to calculating and allocating indirect costs. However, we do have issues with the classification of expenses within the original contract and hope we can reconcile those prior to the finalization of the grant award. Person Responsible: President/CEO Finance Officer

Condition found For the period that covers October 1, 2021, to January 31, 2022, two employees approved time and attendance reports did not agree with what was reflected within the payroll system and therefore petitioned to the federal program. Time charged to the federal program was not based on actual hours. Institution Response The University agrees with the finding. Corrective Action Plan This finding is for transactions that occurred before the payroll corrective action plan was implemented. The University payroll's internal controls, processes and procedures are undergoing changes because of extensive training provided to employees on ADP modules (from Feb- May 2022) and the implementation of a consultant recommendations on payroll processes and practices (in process). In addition, the University retained a public accounting firm to carry out an internal audit process which includes actions aimed at addressing this type of finding. Also, will perform, when applicable, recurring account reconciliations to ensure the amounts charged to the federal award and disbursed to the employees are accurate. Name (s) of the Contact Person (s) Responsible for Corrective Action Ramon L. Menendez, Chief Financial Officer Anticipated Completion Date October 2022.

Submit indirect cost rate and support the cost through tracking and allocating administrative costs/overhead for each grant, which O'Leary & Anick can support for Michael Fields Agricultural Institute. Contact person: Shannah Schmitt, MFAI, and Kevin O'Leary, O'Leary & Anick. Anticipated date of completion: December 2023.

Finding 2022-005 Contact Person Responsible for Corrective Action: Debbie Morton-Crum, County Auditor Contact Phone Number: 765-482-2940 View of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The County Commissioners are responsible for the American Rescue Plan project list along with that responsibility is to have a sub-recipient agreement in place with those outside entities that received American Rescue Plan grant monies from the County. An Internal Control is now in place that requires a sub-recipient agreement in place before a warrant can be paid to those outside entities. We will put procedures in place to ensure that money disbursed to sub-recipient is monitored. Anticipated Completion Date: October 1, 2023

Finding Number: 2022-004 Condition: During the year the Corporation incurred expenditures to hire a consultant to assist with the search of a Chief Financial Officer. The full cost was charged to ALN 17.258, 17.259 and 17.278 - WIOA Cluster. Since the Chief Financial Officer position benefits the entire Corporation, it should have been proportionately allocated to all programs. Planned Corrective Action: DESC has replaced and expanded the number of members on the fiscal/accounting team, including an experienced Accounting Manager and Senior Accountant, and implemented a training program to ensure each fiscal/accounting team member is aware of and understands their duties and responsibilities as it relates to the reconciliation of costs charged to their grants within their portfolios. DESC will be implementing purchase orders prior to the end of FY2022/2023 which will include Financial Analysts providing cost allocations coding in advance of receiving the invoice. Additionally, training has been provided to fiscal staff on cost allocation requirements.Contact person responsible for corrective action: Angela Smith, Neeyn Bland and Lynnette Robinson ? Accounting Manager, Fiscal Manger and Senior Fiscal Manager respectively. Anticipated Completion Date: 06/30/2023

Finding no.: 2022-002 Contact person(s) responsible: Sally Alworth, Controller Corrective action planned: As of April 1, 2023, MPD has adopted a new written policy for administrative cost allocation. Costs that are not allowable for federal grants are flagged both on timecards and on purchasing transactions with a subaccount code that segregates them from overhead allocations. Costs related to facilities ? rent, equipment leases, office insurance, shared supplies, depreciation, etc. ? are now allocated to departments based on the square footage occupancy of each department, calculated using the guidance referenced in 2 CFR 200. Administrative costs that serve the entire organization such as Human Resources, Accounting, outsourced IT support, etc., are allocated to each department based on headcount, as we consider the number of personnel per department to be the best estimate of supporting services required by each team. The Payroll Specialist generates a current employee roster by department at the end of each month, which is used to update the administrative allocation. Once all costs have been allocated to the department level, both facilities and administrative costs are allocated down to individual grants based on the proportion of total wage costs assigned to each grant within the department for that month. Anticipated completion date: May 15, 2023

The District will be developing procedures to include improved documentation of grant expenditures, create a uniform set of grant budget/revenue codes to track individual grants, and compare expenditures to the grant applications to confirm the grant funds are expended appropriately. These actions will be completed by Robyn Bhend, School Business Manager by June 30, 2023.

The Authority will limit funding the COCC from the Public Housing Program, to allowable Fees only. The Authority?s Executive Director, Trey George, has assumed the responsibility of executing this corrective action as of November 1, 2023.

2022-002 – Allocation Percentage Charged – Significant Deficiency in Internal Controls over Compliance Recommendation: The auditor recommends LIFE enhance the design of its control activities and procedures over the allocation percentage forms used throughout the year to ensure the staff know how to apply percentages and are using the correct approved allocation form for the period in the year. Action Taken: LIFE Management will: • Update its allocation form by clearly labeling the document used and the period and type of expense for which it applies. • Communicate the revision of all forms to staff involved in the allocation process, followed by a training session to ensure understanding and proper application of the form. • Establish a monthly review process, whereby allocation forms will be audited for current updates and application consistency. Due Date of Completion: November 30, 2023 Responsible Official: Executive Director

Management and accounting personnel will create procedures to ensure that direct cost is charged at the actual amounts incurred and will develop a payroll cost allocation and allocable direct cost allocation methodology that ensures costs are charged in compliance with the applicable federal costs principles.

Contact person(s) responsible: Executive Director Vanessa Timmons; Associate Director Keri Moran Kuhn; Accounting Manager Linda Koonce. Corrective action planned: OCADSV added an Administrative Cost Center to its General Ledger effective 10-01-22, the beginning of FY23, and began costing administrative payroll costs to that cost center. Additionally, the organization re-trained administrative staff on direct cost-allowable activities vs. administrative activities relative to timekeeping and timesheet preparation and the necessity of daily work descriptions supporting the hourly allocation. The Payroll policy that requires supervisors to review and sign off on timesheets and hourly allocations to cost centers was also reviewed. Audit Costs for FY22 will be allocated in accordance with 2 CFR 200.405 requirements. Beginning with FY23, all accounting and other admin payroll-related costs will be costed to the administration cost center with the exception of time spent in activities related to a specific grant or other cost centers. FY22 Grants expenditures were reviewed post year-end, and a line-by-line review was conducted to bring the direct and indirect expense cumulative total into compliance with audit findings. Any outstanding reports were adjusted to reflect the adjusted Life of Grant to the current date reporting. Executive, Financial, and Grant Management staff will, during FY24, complete the Online Grants Financial Management Training available at onlinegfmt.training.ojp.gov to improve knowledge and compliance with 2 CFR 200 guidance and requirements. The said training will be incorporated into onboarding processes for any newly hired employees who have direct responsibilities related to Grant management and/or reporting. Said training requirements will be added to hire letters and work plans. Anticipated completion date: Effective 6/21/2023 and ongoing

In response to finding number 2021-SA3, management agrees with the finding and will design, implement, and maintain policies and procedures that ensure expenditures are reviewed for allowability before being charged to Federal awards. Management will also design, implement, and maintain policies and procedures that ensure costs are reviewed for allowability before being charged to Federal awards. Further, management will perform budget-to-actual analysis on a periodic basis to ensure costs do not exceed limitations.

2020-108 Lack of Controls over Costs Submitted for Reimbursement Condition: The Organization included an invoice for reimbursement under the program for which a vendor credit memo for the full amount of the invoice had been received due to miscoding of the credit memo to the correct COVID-19 class on the general ledger. In addition, the Organization did not include an applicable invoice for COVID-19 expenses for reimbursement due to the same miscoding of the COVID-19 class to the general ledger. Corrective Action Planned: The Organization has hired a new Chief Financial Officer as well as additional supporting staff within the finance department. Management understands the importance of reviewing the posting of credit memos or applicable invoices to ensure they are posted correctly. We will update our policy to include a process for review of credit memos prior to posting. The planned corrective action for this finding is currently in the process of development, approval, and implementation. Person Responsible for Corrective Action: Robert Thompson, Chief Operating Officer Anticipated Completion Date: March 1, 2023