Corrective Action Plans

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