Corrective Action Plans

2023-002 Special Education Cluster – Assistance Listing Numbers 84.027, 84.173 Recommendation: We recommend procedures be strengthened to document and maintain on file the management review of time and effort. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The School Department has reviewed the finding and is in the planning process with corrective actions. Name(s) of the contact person(s) responsible for corrective action: Amy Mistrot, NPS Director of Business Operations. Planned completion date for corrective action plan: NPS has completed the first of two required Time and Effort Certifications for FY24. We will add managerial review of the completed certifications as an additional level of oversight for both the first and second certifications this year and continue this practice henceforth.

Management will update time and effort documentation process with additional steps to ensure compliance and review requirements with applicable employees.

The University implemented a new grant management software that will provide greater functionality to complete the effort certification process within the time requirements as identified in the University's Time and Effort Reporting policy.

Action taken in response to finding: A comprehensive spreadsheet including all wages allocated to Federal Grants was created during the course of the Federal Awards program Audits. This spreadsheet allows SBCHC staff to track and verify all wages allocated to Federal Awards on a contemporary basis with internal checks and balances included. These verification processes now happen with every payroll cycle and are documented as such. Any revisions that are required now occur on a regular basis and correspond with the bi-weekly payroll cycle. Name(s) of the contact person(s) responsible for corrective action: Matt Gehri, CFO Planned completion date for corrective action plan: Currently deployed as of February 2024, and has been reviewed back to the beginning of the H80 Federal Grant year of May 1, 2023.

CORRECTIVE ACTION PLAN JUNE 30, 2023 REFERENCE: 2023-101 CFDA NUMBER 84.425D – COVID 19 – EDUCATION STABILIZATION FUND U.S. DEPARTMENT OF EDUCATION – 2023 PASSED THROUGH ARIZONA STATE DEPARTMENT OF EDUCATION GRANT NUMBER: S425D210038 CLIENT RESPONSE AND CORRECTIVE ACTION PLAN We concur with the condition. 1. Name of the contact person responsible for corrective action: Michelle Borja, Finance Director 2. Corrective action planned: Time and Effort documentation for employees who work solely on a single cost objective is prepared semi-annually and signed by the employee and/or a supervisor having firsthand knowledge of the work performed by the employee. Time and Effort documentation is collected semi-annually by the Accounting Office. The Finance Director will review forms to ensure the form is completed appropriately. Forms will be reviewed to ensure the period of performance is recorded accurately and signatures obtained from employees and/or supervisors are dated appropriately. 3. Anticipated completion date: Implemented immediately and completed by June 30, 2024

CORRECTIVE ACTION PLAN JUNE 30, 2023 REFERENCE: 2023-101 CFDA NUMBER 84.425D – COVID 19 – EDUCATION STABILIZATION FUND U.S. DEPARTMENT OF EDUCATION – 2023 PASSED THROUGH ARIZONA STATE DEPARTMENT OF EDUCATION GRANT NUMBER: S425D210038 CLIENT RESPONSE AND CORRECTIVE ACTION PLAN We concur with the condition. 1. Name of the contact person responsible for corrective action: Michelle Borja, Finance Director 2. Corrective action planned: Time and Effort documentation for employees who work solely on a single cost objective is prepared semi-annually and signed by the employee and/or a supervisor having firsthand knowledge of the work performed by the employee. Time and Effort documentation is collected semi-annually by the Accounting Office. The Finance Director will review forms to ensure the form is completed appropriately. Forms will be reviewed to ensure the period of performance is recorded accurately and signatures obtained from employees and/or supervisors are dated appropriately. 3. Anticipated completion date: Implemented immediately and completed by June 30, 2024

An automated reporting process of salaries through our payroll provider (ADP) has been established to eliminate the manual data entry of payroll amounts. This will eliminate the opportunity for errors in manual salary entries.

Significant Deficiency 2023-001. Payroll (Allowable Costs/Cost Principles) United States Department of Education, Passed Through New York State Department of Education: Title I Grants to Local Education Agencies ALN 84.010A English Language Acquisition State Grants ALN 84.365 Education Stabilization Funds (ESF) COVID-19: American Rescue Plan – Elementary and Secondary School Emergency Relief (ARP ESSER) ALN. 84.425U Condition: Subpart I, 2 CFR §200.430 of the Uniform Guidance requires that charges to “Federal awards for salaries and wages must be based on records that accurately reflect the work performed.” The documentation should support the distribution of the employee’s compensation among specific activities if the employee works on more than one Federal award, or a Federal award and non-Federal award. The preparation of personnel activity reports (PARs) or periodic certifications or the equivalent is the most effective way to comply with this requirement. During the current year, it was noted that in some instances, the District PAR forms were either not available, or did not accurately reflect the allocation or the grant that the employee was charged to in order to comply with Subpart I, 2 CFR §200.430. Planned Corrective Action: The District will properly review and maintain the federal personnel activity reports (PARS) to ensure the employee’s salary, or other form of compensation is correctly coded to the grant and the form accurately reflects the federal program in which the employee’s earnings were allocated to support the compliance with Subpart I, 2 CFR §200.430. Responsible Contact Person: Lawrence Luce Anticipated Completion Date: June 30, 2024 Contact Information: Lawrence Luce Assistant Superintendent for Finance & Operations Hampton Bays Union Free School District 86 Argonne Road East Hampton Bays, NY 11946

Management has implemented a policy and process whereby all corrected time cards are required to be approved by a supervisor prior to payroll being generated.

2023-005: Payroll Timecard Approval Federal Departments: Department of Health and Human Services Assistance Listing #: 93.612 and 93.939 Compliance and Internal Controls Significant Deficiency Category of Finding – Allowable Costs/ Cost Principles Name of contact person – Sharon Day, Executive Director Corrective action – Management will review policies and procedures to ensure all timecards are reviewed by responsible individual. Completion date – Management and the Board of Directors implemented the above as of January 2024.

2023-004: Lack of Payroll Documentation Federal Departments: Department of Health and Human Services Assistance Listing #: 93.612 and 93.939 Internal Controls Significant Deficiency Category of Finding – Allowable Costs/ Cost Principles Name of contact person – Sharon Day, Executive Director Corrective action – Management will review policies and procedures to ensure information is complete and up-to-date. Completion date – Management and the Board of Directors implemented the above as of January 2024.

Type of Finding: Significant Deficiency in Internal Control over Compliance relating to inadequate allocation of wages to federal programs may result in noncompliance with grant regulations. Views of Responsible Officials: Management accepts the finding. Effective internal control over the allocation of wages to federal programs, which can be attributed to how employees and cost centers were initially set up in the payroll software (ADP) to achieve the desired allocation splits. In one region, employees in ADP were not being consistently set up correctly to ensure the proper allocation of hours worked per the timesheets to their associated job cost centers. More thorough training of staff, along with careful supervisory review of employees’ allocations of wages and documented time and effort spent on each program would likely have prevented this error. Corrective Action: The setup for all employees has been corrected. In addition, each pay period, the setup for all new employees will be reviewed by the Controller to ensure consistency. The Controller will also pull samples of timecards monthly and verify the allocation percentages. A training is being developed along with a procedure guide for all current payroll staff and will be continued with all new payroll staff.

2023-004 - Written Policies Required by the Uniform Grant Guidance U.S. Environmental Protection Agency – Clean Water State Revolving Fund (ALN 66.458); Passed through the Michigan Department of Energy, Great Lakes, and Environment; All project numbers Auditor Description of Condition and Effect. Although the City has processes in place to cover these areas, there are no formal written policies covering payments, procurement, allowability of costs, compensation, and travel costs in accordance with the Uniform Guidance. As a result of this condition, the City was exposed to increased risk that grant requirements under 2 CFR 200 would not be followed. Auditor Recommendation. We recommend that the City develop and implement the required policies as soon as practical. Corrective Action. A written policy was developed and implemented in February 2024 that meets the requirements under Federal guidance. Responsible Person: Bobbi Schoon, Director of Finance and Administration

FINDING 2023-004 Finding Subject: Child Nutrition Cluster – Allowable Activities & Allowable Costs / Cost Principals Summary of Finding: Internal controls were not in place to ensure compliance with requirements related to the grant agreement, specifically the requirement: Allowable Activities & Allowable Costs / Cost Principals. Contact Person Responsible for Corrective Action: Scott Weltz, Amanda Brackett Contact Phone Number and Email Address: 765-654-5585, weltzs@frankfort.k12.in.us, bracketa@frankfort.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Internal controls will be established and followed to ensure compliance with requirements related to the grant agreement. The Deputy Treasurer or designee will provide payroll distribution reports to the Director for review of payroll claims against the grant. Anticipated Completion Date: Effective immediately and ongoing

Program: AL 21.027 – COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Allowability & Subrecipient Monitoring Corrective Action Plan: Payments to Developmental Disability Providers, Assisted-Living Facilities, and Nursing Facilities for Employee Retention and Recruitment: DHHS is in the process of obtaining affidavits from all Developmental Disability Providers, Assisted-Living Facilities, and Nursing Facilities who received payments under LB1014 stating that funds were used for allowable purposes. Premium Pay: We do not believe any corrective action is warranted as our files were corrected with the Auditor’s guidance and assistance in accordance with all CSLFRF eligibility requirements. Assistance to Nonprofits: For Shovel-Ready awards that have already been granted, DED will confirm prior to close-out of the grant that there is sufficient supporting documentation showing the awardee suffered a harm related and reasonably proportional to the award. Sufficient supporting documents must prove that the nonprofits suffered an economic harm, such as a decrease in revenue or an increase in expenses due to COVID-19. The evidence may include but is not limited to: • Profit and loss statements showing a decrease in revenue or an increase in expenses • Audited financial statements showing a decrease in review or an increase in expenses • Change in a line of credit • Increase in costs for projects related to COVID-19, such as construction cost data, • Decrease in written pledges related to COVID-19 • Decrease in donations related to COVID-19 • Historical fundraising comparisons University of Nebraska: The University project is ongoing. In the next six months, Military/NEMA will initiate monitoring activities to include the review and validation of expenditures for allowability as required under 2 C.F.R. part 200. Nursing Scholarships: DHHS’ current internal controls for the Nursing Scholarship program have minimized the risk of fraud as they correctly identified this case of fraud and have identified others prior to any payment being made. DHHS will continue to review payments for the Nursing Scholarship program, which uncovered the $5,000 identified in the finding. Contact: Payments to Developmental Disability Providers, Assisted-Living Facilities, and Nursing Facilities for Employee Retention and Recruitment: Heather Arnold, CPA, CFE DHHS Deputy Director of Financial Services Premium Pay: Nicole Zimmerman, Finance Director Assistance to Nonprofits: Audrey Sautter, DED Compliance Team Manager University of Nebraska: Erv Portis, Assistant Director-Nebraska Emergency Management Agency (NEMA) Nursing Scholarships: Heather Arnold, CPA, CFE DHHS Deputy Director of Financial Services Anticipated Completion Date: Payments to Developmental Disability Providers, Assisted-Living Facilities, and Nursing Facilities for Employee Retention and Recruitment: June 2025 Premium Pay: N/A Assistance to Nonprofits: DED will draft a policy to place the above into effect within the next 7 days. University of Nebraska: July 2024 Nursing Scholarships: June 2025

Program: AL 20.509 – Formula Grants for Rural Areas – Allowability & Subrecipient Monitoring Corrective Action Plan: NDOT recently updated the Invoicing Reimbursement Acceptable Documentation Requirement Guidelines. These guidelines offer comprehensive instruction, best practices, and a clearer definition of allowable expenses for subrecipients. The updated guide was distributed to subrecipients in February 2024. Over the next six months, NDOT plans to conduct additional training sessions through opportunities such as the monthly Transit Manager meetings, on-site visits, or webinars with subrecipients. The objective is to ensure a thorough understanding of required documentation and the identification of eligible federal reimbursement expenses. To assist with transit subrecipient monitoring, NDOT management has designated an internal auditor within the Transit Section. The auditor’s focus will be assessing reimbursement documentation, reviewing time studies, evaluating cost allocation plans, developing risk assessment, and helping to intensify monitoring efforts over all subrecipients. NDOT is also in the process of improving and updating the invoice review process to provide consistency for reviewing and approving invoices to enhance accuracy within the Transit Section. Additionally, NDOT has established a dedicated unit “Financial Oversight” within the Transit Section solely focusing on Subrecipient reimbursements. The four staff members in this unit will report directly to Financial Aid Administrator III, this oversight will enhance the quality checks and consistency among subrecipient reimbursements. The Financial Oversight unit will continue to evaluate and refine the operations to ensure federal regulation and required documentation is in place prior to any subrecipient reimbursement. Contact: Jodi Gibson Anticipated Completion Date: On-going

Audit Finding Reference: 2023-001 Planned Corrective Action: Onboarding procedure is being changed where employees are not able to start working until a signed contract is on file in their HR file. Name of Contact Person and Completion Date: Brian Cisneros (Business Administrator) Michael Hatfield (HR Director) Anticipated Completion Date – 4/1/24

Significant Deficiencies 2023-001. Allowable Costs/Cost Principles Special Education Cluster Special Education Grants to States: IDEA Part B ALN: 84.027A Special Education Grants to States: IDEA 611 ARP Allocations ALN: 84.027X Special Education Preschool Grants: IDEA Preschool ALN: 84.173A Special Education Preschool Grants: IDEA 619 ARP Allocations ALN: 84.173X Condition: Subpart E, 2 CFR §200.430 of the Uniform Guidance requires that charges to “Federal awards for salaries and wages must be based on records that accurately reflect the work performed.” The documentation should support the distribution of the employee’s compensation among specific activities if the employee works on more than one Federal award, or a Federal award and non-Federal award. The preparation of personnel activity reports (PARs) or periodic certifications or the equivalent is the most effective way to comply with this requirement. During the current year, the District prepared periodic certification equivalents, but it did not comply with Subpart E, 2 CFR §200.430. Planned Corrective Action: The District will adopt procedures that ensure that time performed will be used to support costs charged to the Federal award, and comply with Subpart E, 2 CFR §200.430. Responsible Contact Person: Ms. Sharon Donnelly, Assistant Superintendent for Business Harborfields Central School District 2 Oldfield Road Greenlawn, New York 11740 Anticipated Completion Date: June 30, 2024.

Finding 2023-009: Time Accounting We agree with the auditor's comments, and the following actions will be taken to ensure the district comply with 2 CFR, section 200.303, and CSAM Procedure 905, which require that employee time certification forms be maintained for employees who charge time to federal program. The State and Federal Programs Department at the recommendation of FPM began Time and Effort Procedures training on December 6, 2023, with the Office Managers and Administrative Secretaries to emphasize the critical importance of accurate time certification records for federal fund.

The Business Office, in coordination with the Human Resources Department, is developing a process to ensure timely reviews and approvals of employee time and effort charged to federal programs is documented on a periodic basis. The corrective action is expected to be implemented by June 30, 2024.

Finding 2023-002 Contact Person: Lily Rakness Parra, County Clerk Corrective Action Planned: Washakie County agrees with the finding of 2023-002. Washakie County is currently working on implementing a more thorough tracking procedure in order to document all of the significant processes for our federal awards. Also, in order to further track funds disbursed, a sams.gov account has been set up and is currently utilized in order to determine if an entity is eligible for disbursement of federal funds. An amendment to implement sams.gov utilization will be produced in order to add it to our current Procurement Policy.

FINDING 2023-007 Finding Subject: Education Stabilization Fund – Allowable Costs/Cost Principles Summary of Finding: Material Weakness, Other Matters The Elementary and Secondary School Emergency Relief (ESSER) Fund provided funding to States and school districts to combat the effects of the coronavirus, help safely reopen and sustain the safe operation of schools, and to address the impact of the coronavirus pandemic on the nation’s students. States were required to subgrant a portion of their ESSER allocation to local educational agencies (LEA). Prior to LEAs receiving their respective subgrants, LEAs were required to complete an application for ARP ESSER funding, which was submitted to the Indiana Department of Education (IDOE), the pass-through entity for approval. The application included a district level budget identifying how the LEA intended to spend program funds. The School Corporation did not have internal controls in place over payroll disbursements charged to the ESSER grant funds. Payroll disbursements were paid without evidence that the detailed report of payroll disbursements was reviewed and approved by another person not involved in the original payroll process. Contact Person Responsible for Corrective Action: Bengamin Mann Contact Phone Number and Email Address: 765-536-0008 bmann@mgusc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Quarterly grant meetings will be held between the CFO, Deputy Treasurer, and Grant writer. This will ensure compliance requirements continue to be met. The CFO now reviews the Org Charge report and signs off before the payroll batch being released to the bank. This report is generated by Payroll and Benefits. Also, this entire report is now included with board claims for board approval rather than a final summary sheet. Anticipated Completion Date: February 2024

FINDING 2023-005 Finding Subject: Special Education Cluster (IDEA) – Allowable Costs/Cost Principles Summary of Finding: Material Weakness, Other Matters The Individuals with Disabilities Act (IDEA) Special Education – Grants to States program provides grant to states, and through them to Local Educational Agencies (i.e. the School Corporation), to assist them in providing special education and related services to eligible children with disabilities ages 3-21. IDEA’s Special Education – Preschool Grants program provides grants to states, and through them to LEAs to assist them in providing special education and related services to children with disabilities ages three to five and, at the state’s discretion, to twoyear- old children with disabilities who will turn three during the school year. The School Corporation did not have internal controls in place over payroll disbursements made from the special education funds. Payroll disbursements were paid without evidence that the detailed report of payroll disbursements was reviewed and approved by another person not involved in the original payroll process. Contact Person Responsible for Corrective Action: Bengamin Mann Contact Phone Number and Email Address: 765-661-8807 bmann@mgusc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Quarterly grant meetings will be held between the CFO, Deputy Treasurer, and Grant writer. This will ensure compliance requirements continue to be met. The CFO now reviews the Org Charge report and signs off before the payroll batch being released to the bank. This report is generated by Payroll and Benefits. Also, this entire report is now included with board claims for board approval rather than a final summary sheet. Anticipated Completion Date: February 2024

FINDING 2023-002 Finding Subject: Child Nutrition Cluster – Allowable Costs/Cost Principles Summary of Finding: Material Weakness, Other Matters A cash reimbursement is provided to the School Corporation based on meals served under the School Breakfast Program, National School Lunch Program, and Summer Food Service Program for Children. The cash reimbursement is to be used for the benefit of the food service program. The School Corporation did not have internal controls in place over payroll disbursements charged to the food service program. Payroll disbursements were paid without evidence that the detailed report of payroll disbursements was reviewed and approved by another person not involved in the original payroll process. Contact Person Responsible for Corrective Action: Bengamin Mann Contact Phone Number and Email Address: 765-536-0008 bmann@mgusc.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: The CFO now reviews the Org Charge report and signs off before the payroll batch being released to the bank. This report is generated by Payroll and Benefits. Also, this entire report is now included with board claims for board approval rather than a final summary sheet. Anticipated Completion Date: February 2024.

FINDING 2023-002 Finding Subject: COVID-19 - Education Stabilization Fund – Allowable Cost/Cost Principles Summary of Finding: Time and Effort logs were not maintained for grant Contact Person Responsible for Corrective Action: Todd Nobbe Contact Phone Number: 812-934-2194 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The School Corporation will have the individuals paid by this grant complete time and effort documentation for the grant. Documentation will be kept for the audit. Completion Date: Immediately 2/26/2024