Corrective Action Plans

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 2022-006 Programs: All Material Weakness over Schedule of Expenditures of Federal Awards (SEFA) Reporting Repeat Finding: Yes Auditee?s Corrective Action Plan: The City has purchased Workday, an Enterprise Resource Planning (ERP) system, and implemented the software with the assistance of Accenture consultants. Although Workday is ?live? as of August 2022, the City is currently working to refine the software and fully utilize functionality. The Workday grants modules requires the grant funding source be defined prior to grant approval and fields are available for the AL titles and numbers and sub-recipients? information. The implementation of the Workday grants modules centralizes much of the grant management function by requiring the agencies to upload the grant documents into Workday. The City has: ? Held weekly meetings for two years with agency grant representatives to design and configure the Workday grant module. ? Uploaded the grant award, sponsor information and grant budget data into a Workday. ? Implemented a ?new grant? request which uses a Workday business process. ? In the process of reviewing and correcting recoverable costs per grant award so it is properly reported. Contact Person: Michael Moiseyev, Chief Financial Officer, Baltimore City. Completion Date: June 2024

Name of Responsible Individual(s): Jason Penegar, BGCA Vice President ? Controller Shelby Mahoney, Accounting Manager - State Alliances Corrective Action: The fiscal team will enhance its procedures and internal controls with respect to preparation and review of the SEFA. Grant agreements will be reviewed to confirm if expenditures from pass-through entities are related to federal or state grants, and appropriately include applicable federal grants and pass-through funds in the SEFA. Anticipated Completion Date: December 31, 2023

During 2023, the newly elected County Auditor took on an active role in tracking the Coronavirus State and Local Fiscal Recovery Funds by preparing and maintaining spreadsheets so that the Commissioners have the most current information for making decisions. The County Auditor attends or watches/listens to the Commissioners’ meetings to make sure that she is updating the spreadsheets with all action taken by the Commissioners. Before submitting the Schedule of Expenditures of Federal Awards for the 2023 audit, we will consult with the Commissioners’ Office and the County Auditor to make sure that we are reporting the transactions correctly based on the spreadsheets prepared and maintained for such purposes.

Views of Responsible Officials: Mary's Center now has a robust process where the agreed upon provisional indirect rate or (if applicable) the specific rate included in the final Grant agreement is the governing default rate used for each Grant. In any scenarios where a change in rate is being requested, the Program Manager alerts the Senior Grant Accountant assigned to the grant and provides supporting documentation from the Grant funder of an addendum to the existing Grant agreement. If for any reason the Finance team is using an upward or downward adjustment to the provisional indirect rate or what was agreed upon in the Grant agreement the EVP Finance and Director of Grants must approve this change and notify the EVPs of Health and Programs and Development prior to implementing this change. All changes are documented. In addition, to ensure the rate in the agreement is the same rate being used when invoicing Grant funders, the Finance team conducts a thorough reconciliation process during the year.

Individuals Responsible for Corrective Action Plan: Jason Penegar, BGCA Vice President – Controller Shelby Mahoney, Accounting Manager - State Alliances Corrective Action: The fiscal team will enhance its procedures and internal controls with respect to preparation and review of the SEFA. Grant agreements will be reviewed to confirm if expenditures from pass-through entities are related to federal or state grants, and appropriately include applicable federal grants and pass-through funds in the SEFA. Anticipated Completion Date: December 31, 2023

Agency: National Center for the Advancement of STEM Education, Inc. (nCASE) Person Responsible for Corrective Action: Name: Nancy Priselac Title: Executive Director Anticipated Completion Date: December 8, 2023 Response to Finding: Management concurs with audit recommendation. Correction Action to be Taken: nCASE has written policies and procedures that detail how management is to review and approve documentation relating to payroll and how reports are created that confirm charges are accurate, allowable, and properly allocated as well as allow for clear comparisons to estimates. Management created timekeeping documents to track employee labor, time and effort. nCASE’s accounting system matches charges listed to documentation used to collect and record time and effort by employees and apply designations to its respective project/label. The system can track direct, indirect, and fringe benefit designations. Accounting data now allows management to create clear reports on payroll. nCASE has implemented documentation that allows employees to track time and labor in detail of project. Management has written policies and procedures that direct employees on how to record time and labor. DoD has reviewed the matters covered in the audit report thoroughly, and the grant was closed out without any repayment of funds to DoD. Upon subsequent review and reconciliation, amounts were not overcharged.

Management feels that the SEFA wasprepared in accordance with guidance that was available at the time. We will continue to evaluate all federal programs’ expenditures and include on the SEFA as necessary. All federal expenditures will continue to be reconciled to College ledgers.

California Business, Consumer Services and Housing Agency (BCSH) The California Interagency Council on Homelessness (Cal ICH), an entity under the BCSH, would like to acknowledge a finding from the fiscal year 2020-21 Statewide Federal Compliance Audit of the State of California. This audit finding identifies lack of communication of required subaward information to Cal ICH subrecipients of the Coronavirus Relief Fund (CRF) program at the time of the subaward, or when the State became aware of changes in subaward information, including identification that the subaward funds represented federal funding. Cal ICH agrees with this finding and the recommendation to review all subawards provided which were funded using CRF program funds and determine whether the subrecipients properly reported their CRF awards and related expenditures in their respective schedule of expenditures of federal awards pursuant to Title 2 Code of the Federal Regulations 200.502. Additionally, while formal communication identifying that the subaward fund represented federal funding was not provided, many informal conversations were had with CRF grantees. These conversations were held during bi-weekly online Office Hours and through one-on-one calls with individual subrecipients and discussions of the substitution of federal awards with grantees originally provided with State funds could have occurred. Cal ICH will conduct review of the CRF subawards during mandatory desk reviews to verify that subrecipients properly reported their CRF awards and that expenditures of the federal awards were made pursuant to Title 2 Code of Federal Regulations 200.502. Additionally, Cal ICH has developed an improved communication system between leadership and program staff that will ensure changes are clearly communicated. This will also ensure the Council’s subrecipients are notified in a timely manner upon any changes in subaward information, such as identifying if subaward funds represent federal funding so that expenditures are spent in accordance with Federal statutes, regulations, and the terms and conditions of federal awards. Additionally, if in the future funding is changed, CDE will provide updated information to all recipients; this will ensure that expenditures are in line with the terms and conditions of the grant and/or funding source. Estimated Implementation Date: May 2023 Contact: Ellen Meuchel, Monitoring Unit Cal ICH Grant Operations and Suppor California Department of Education Concur. Education will review the relevant subawards funded under the CRF program and determine whether the subrecipients properly reported their CRF awards pursuant to 2 CFR 200.501. Estimated Implementation Date: July 31, 2023 Contact: Kelly Levario, External Audits Coordinator Audits and Investigations Division California Department of Social Services The California Department of Social Services (CDSS) acknowledges the Single Audit finding regarding the delayed communication of subaward information to the Department’s subrecipients of the Coronavirus Relief Fund (CRF) program. On December 21, 2022, CDSS released County Fiscal Letter 22/23-31 on the subject of “Federal Coronavirus Relief Funds That Replaced General Fund for COVID-19 Related Activities for Fiscal Years 2019-20 and 2020-21” to County Welfare Departments (CWDs) and federally recognized Tribal governments in California. This letter served as a formal documentation of the portion of expenditures that were funded with federal CRF. Additionally, although formal notice was not provided until December 21, 2022, informal notices and conversations took place between CDSS and the County Welfare Directors Association, as well as with CWDs, regarding possible situations in which the substitution of federal awards with grants originally provided with State funds could occur. On September 21, 2021, CDSS sent a notice to subrecipients requesting for their Data Universal Number System for the purpose of CRF federal subawards; thereby, communicating the use of CRF on the subrecipients’ behalf. CDSS will conduct a review of the CRF subawards during on-site fiscal monitoring reviews to verify that subrecipients properly reported their CRF awards and that expenditures of the federal awards were made pursuant to Title 2 Code of Federal Regulations 200.502. Moreover, CDSS will ensure that the Department’s subrecipients are notified in a timely manner upon any changes in subaward information, such as identifying if subaward funds represent federal funding so that expenditures are spent in accordance with Federal statutes, regulations, and the terms and conditions of federal awards. Estimated Implementation Date: April 2023 through June 2024 Contact: Elisa Tsujihara, Chief Fiscal Policy and Analysis Bureau

National Park Service Conservation, Protection, outreach, and Education – Assistance Listing No. 15.954 and Research and Development Cluster – Assistance Listing No. 15.608 and 15.945 Recommendation: We recommend management incorporate review control procedures to ensure the 10 percent de minimis rate is properly applied in accordance with UG and ensure appropriate costs are charged to the awards consistent with their federally approved budgets. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Upon conducting the FY21 audit TAS was informed that the inclusion of the Biological Expertise line item on federal budgets (approx. 7.5% additional uplift) was not allowable as it was currently being calculated. TAS is allowed a 10% de minimus rate on noted FY21 Federal awards some of which also included a Biological Expertise line item that is budgeted as an hourly rate. TAS had been calculating uplift amounts owed by simply adding the Biological Expertise (7.5%) to the de minimus rate (10%) for a total uplift of 17.5%. This was done at the direction and approval of our federal partners. However, due to Biological Expertise being entered in the federal and approved budgets as an hourly line item and not a percentage TAS was considered out of compliance by using this method of calculation. Moving forward TAS will be billing the de minimus rate (10%) as a percentage and will calculate the Biological Expertise line item as an hourly rate. Name(s) of the contact person(s) responsible for corrective action: Kim Lopez, Director of Finance & Operations Planned completion date for corrective action plan: effective immediately / in progress

Planned Corrective Action: The Fiscal Agent and Board Management will review all grant and loan award documents in order to execute policies and procedures which help ensure compliance with grant agreements, including Schedule reporting requirements. The Consortium will implement a system to track all federal expenditures and related information separately from other expenditures and report federal expenditures with proper support including, but not limited to, grant agreements, calculation of the expenditures, and any federal reporting requirements. Anticipated Completion Date: March 31, 2024 Responsible Contact Person: Crystal Keaton

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. OCADSV is developing a formal cost allocation plan to recover direct and indirect costs using the 10% de minimis of Modified Total Direct Cost. The allocation will be applied monthly and incorporated into the annual budgeting process. Anticipated completion date: Effective 6-21-23 and ongoing

Contact person(s) responsible: Executive Director Vanessa Timmons, Associate Director Keri Moran-Kuhn Corrective Action planned: OCADSV will ensure that all future federal subawards will contain the information required by CFR §200.332. All contracts, sub-grantees, and MOU’s, will include information required. Anticipated completion date: Effective 6-1-2023 and ongoing

Planned Corrective Action: The Fiscal Agent and Board Management will review all grant and loan award documents in order to execute policies and procedures which help ensure compliance with grant agreements, including Schedule reporting requirements. The Consortium will implement a system to track all federal expenditures and related information separately from other expenditures and report federal expenditures with proper support including, but not limited to, grant agreements, calculation of the expenditures, and any federal reporting requirements. Anticipated Completion Date: March 31, 2024 Responsible Contact Person: Crystal Keaton

Planned Corrective Action: The Fiscal Agent and Board Management will review all grant and loan award documents in order to execute policies and procedures which help ensure compliance with grant agreements, including Schedule reporting requirements. The Consortium will implement a system to track all federal expenditures and related information separately from other expenditures and report federal expenditures with proper support including, but not limited to, grant agreements, calculation of the expenditures, and any federal reporting requirements. Anticipated Completion Date: March 31, 2024 Responsible Contact Person: Crystal Keaton