Corrective Action Plans

FINDING 2023-002 Finding Subject: Child Nutrition Cluster- Allowable Activities, Allowable Costs/Cost Principals Summary of Finding: A portion of the wages for the CFO/Treasurer, the Director of Operations, the Director of Finance, and two School Secretaries were paid from the School Lunch Fund. The wages charged to the School Lunch fund were based on fixed percentages and did not provide adequate information to determine if the percentage charged was appropriate. Total wages charged to the program for the above noted employees was $31,617. Contact Person Responsible for Corrective Action: Camden Parkhurst Contact Person Phone Number and Email Address: 765-457-8101 camden.parkhurst@nwsc.k12.in.us View of Responsible Official: We concur with the finding. There was a substantial amount of turnover within the finance department. It was understood that the mentioned salaries were removed from the 0800 fund following the last audit. During review it was discovered only the Director of Operations and Assistant Treasurer salaries were removed from the child nutrition cluster. Upon discovery the Operations Assistant and Director of Finance were still having a portion of the salary paid from the 0800 fund, they were immediately removed. Description of Corrective Action Plan: The Director of Finance and the Operations Assistant’s salaries have been removed from the 0800 fund and returned to the 0300 fund. Anticipated Completion Date: Immediate and has been completed.

Eagle Academy PCS agrees with the findings and has made the necessary corrections to address the payroll allocation. The school has hired a new Human Resources Manager, and the school also contracted with a third-party vendor that will be responsible for managing all grant reporting, applications, amendments, and reconciliations. This will strengthen the school year-end closing process and tighten internal controls in the human resources department. Management has also added an additional layer to the time & effort verification which will ensure that all reimbursement requests submitted will be based on actual expenses incurred and not estimates. This will eliminate the unpaid leave of the findings identified in the audit. This will strengthen internal controls and enhance Eagle Academy PCS reporting and grant tracking system.

Finding 2023-005: Activities Allowed and Allowable Costs Federal Agency Name: Department of Health and Human Services FFAL #93.958 Program Name: Block Grants for Community Mental Health Services Finding Summary: The Center’s controls did not detect or correct the errors identified, which results in a reasonable possibility that the Center could submit disallowed costs under the federal awards and would not be able to detect and correct noncompliance in a timely manner. Employees did not enter all nonfederal hours within the ClickTime system and the secondary review of the employee ClickTime timecards did not identify the missing hours. In addition, the secondary review of federal grant expenditure tracking spreadsheet did not identify the missing pay periods. During testing of expenditures, the following items were identified: a) ClickTime timecard, which tracks federal and nonfederal hours for employees, did not properly reflect the employees total federal and nonfederal hours being paid within the payroll register (2 instances). b) The tracking spreadsheet did not reflect the entire months payroll and instead only included 2 weeks of payroll and benefits which resulted in a calculation error for expenses allocated to the grant (1 instance). Responsible Individuals: Staff Supervisors (Missy Martini, Billie Jo Hovick, Taylor Prather, Kari Anderson) and Project Accounts Manager (Marsha Bomgaars) Corrective Action Plan: Staff supervisors are to compare ClickTime entries with payroll system entries to ensure they match. The Project Accounts Manager will compare all ClickTime reports and payroll reports to ensure they match and are accurate. Anticipated Completion Date: Beginning in January 2023, the Center began reconciling ClickTime reports with payroll reports using an excel spreadsheet to identify discrepancies between the ClickTime timecards and the payroll register to help ensure all hours are accurately reported.

Finding 2023-004: Activities Allowed and Allowable Costs Federal Agency Name: Department of Health and Human Services FFAL #93.829 Program Name: Section 223 Demonstration Programs to Improve Community Mental Health Services Finding Summary: The Center’s controls did not detect or correct the errors identified, which results in a reasonable possibility that the Center could submit disallowed costs under the federal awards and would not be able to detect and correct noncompliance in a timely manner. Employees did not enter all nonfederal hours within the ClickTime system and the secondary review of the employee ClickTime timecards did not identify the missing hours, the incorrectly tracked hours, and double tracked time. Also, the secondary review of federal grant expenditure tracking spreadsheet did not identify the calculation errors. In addition, the grant was overcharged for nonpayroll as it relates to a gym membership claimed for a customer of the grant. During testing of expenditures, the following items were identified: a) ClickTime timecard, which tracks federal and nonfederal hours for employees, did not properly reflect the employees total federal and nonfederal hours being paid within the payroll register (2 instances). b) Calculation errors for expenses allocated to the grant (2 instances). c) Employee’s overtime hours were not properly tracked in ClickTime (2 instances). d) Employee tracked paid time off under PTO and CCBHC lines in ClickTime (1 instance) causing it to be double tracked. e) Grant was overcharged as it relates to a client’s gym membership (1 instance). Responsible Individuals: Project Directors (Rebecca McCrackin, Missy Martini, Billie Jo Hovick), Project Accounts Manager (Marsha Bomgaars) and CEO (Dan Ries) Corrective Action Plan: Staff supervisors are to compare ClickTime entries with payroll system entries to ensure they match. The Project Accounts Manager will compare all ClickTime reports and payroll reports to ensure they match and are accurate. The CEO will review all client assistance payments for accuracy when doing monthly expense review/approval. Anticipated Completion Date: Beginning in January 2023, the Center began reconciling ClickTime reports with payroll reports using an excel spreadsheet to identify discrepancies between the ClickTime timecards and the payroll register to help ensure all hours are accurately reported.

Finding 2023-003: Activities Allowed and Allowable Costs Federal Agency Name: Department of Health and Human Services FFAL#93.087 Program Name: Enhance Safety of Children Affected by Substance Abuse Finding Summary: The Center’s controls did not detect or correct the errors identified, which results in a reasonable possibility that the Center could submit disallowed costs under the federal awards and would not be able to detect and correct noncompliance in a timely manner. Employees did not enter all nonfederal hours within the ClickTime system and the secondary review of the employee ClickTime timecards did not identify the missing hours. In addition, the secondary review of federal grant expenditure tracking spreadsheet did not identify the calculation errors. During testing of expenditures, the following items were identified: a) ClickTime timecard, which tracks federal and nonfederal hours for employees, did not properly reflect the employees total federal and nonfederal hours being paid within the payroll register (3 instances). b) Calculation errors for expenses allocated to the grant (1 instance). Responsible Individuals: Staff Supervisors (Christina Eggink-Postma, Sarah Heinrichs, Stephanie Pohar) and Project Accounts Manager (Marsha Bomgaars) Corrective Action Plan: Staff supervisors are to compare ClickTime entries with payroll system entries to ensure they match. The Project Accounts Manager will compare all ClickTime reports and payroll reports to ensure they match and are accurate. Anticipated Completion Date: Beginning in January 2023, the Center began reconciling ClickTime reports with payroll reports using an excel spreadsheet to identify discrepancies between the ClickTime timecards and the payroll register to help ensure all hours are accurately reported.

Condition: The School District’s controls did not prevent or detect and correct, in a timely manner, an employee’s time being charged to the Special Education Cluster that did not have adequate documentation. Additionally, the School District’s controls did not prevent or detect and correct, in a timely manner, updates to an employee status upon termination for employees charged to the Special Education Cluster and the Education Stabilization Fund. Planned Corrective Action: The School District concurs with the audit finding. The District has worked to strengthen internal controls to eliminate errors. The District will review its internal controls and provide additional training to staff. The School District is in the process of filling a Project Manager role on the Payroll Team who will be responsible for reviewing employee terminations and identifying potential overpayments. Until the role is filled, the Senior Director of Payroll and CFO will review employee exits quarterly to identify any potential overpayments and move funds to the general fund. New procedures for employee exit were rolled out in July in an effort to improve timely exiting of employees. Contact person responsible for corrective action: Jeremy Vidito, Chief Financial Officer Anticipated Completion Date: June 30, 2024

Recommendation: Additional training should be provided to individuals responsible for the development of written policies and procedures in accordance with the Uniform Guidance. Action Taken: One City Schools is in the process of identifying a required training program for all staff members involved in the submission, review and/or approval of the schedule of expenditures of federal awards. This includes One City’s Executive Chef, Executive Director of K-8, COO and VP of Government Relations (who oversees compliance). Designated staff will take advantage of all DPI-provided training seminars and resources available, and we will track attendance of relevant staff members. This process will be in place by June, 2024.

2023-002 Activities Allowed or Unallowed and Allowable Costs/Costs Principles Program Community Services Block Grant Name of Contact Person Kelly Wessels, Executive Director Corrective Action Plan As of July 1, 2023 the following behaviors and standards were implemented: • CAPNC moved from an archaic, unsupported software system to Sage Intaact. This software provides the ability to modernize and deploy the levels of internal controls missing from previous fiscal personnel oversight and technical capability. Current staff have trained under Sage Intaact and Wipfli consultants to properly track A/P, A/R, payroll and grant management to ensure the integrity of data entry and compliance is observed. Board membership have access to accounting software through Board portal for further oversight. • Payroll services were outsourced to ADP payroll services in order to provide real time features and accountability for time. This allows recording of time more accurate, reliable and allocable. Payroll records are reviewed and time studies are being performed for all staff to ensure allocation methodology, once selected is appropriate, consistent and in alignment with staff performance. o Time entry occurs electronically in real time; hourly employees are assigned a schedule, and salaried staff are monitored o Time cards are electronically submitted and approved electronically to ensure time is recorded as it occurs. o Time off records are also submitted for approval electronically and leave is approved based on County personnel guidance. • Wipfli Consulting is providing technical assistance over a 10 month period to develop/deploy updated policies and procedures for fiscal area, in accordance with Uniform Guidance. Curriculum includes: o Internal controls o Allowable compensation and employee benefits o Cost allocation methods o Governing body financial responsibilities o Budgeting o Financial reporting o Financial management systems o Documentation and record retention o Financial policies and procedures o Allowable costs • All administrative leadership staff received, and will continue to receive annually, fiscal oversight training including but not limited to, Uniform Guidance training, grants management and compliance training. Allocations are reviewed regularly by leadership team to ensure that we have appropriate methodology and that we are consistent with grant expectations and regulations. Proposed Completion Date June 30, 2024

2023-001 Activities Allowed or Unallowed and Allowable Costs/Costs Principles Program Emergency Rental Assistance Program Name of Contact Person Kelly Wessels, Executive Director Corrective Action Plan • CAPNC moved from an archaic, unsupported software system to Sage Intaact. This software provides the ability to modernize and deploy the levels of internal controls missing from previous fiscal personnel oversight and technical capability. Current staff have trained under Sage Intaact and Wipfli consultants to properly track A/P, A/R, payroll and grant management to ensure the integrity of data entry and compliance is observed. Board membership have access to accounting software through Board portal for further oversight. • Payroll services were outsourced to ADP payroll services in order to provide real time features and accountability for time. This allows recording of time more accurate, reliable and allocable. Payroll records are reviewed and time studies are being performed for all staff to ensure allocation methodology, once selected is appropriate, consistent and in alignment with staff performance. o Time entry occurs electronically in real time; hourly employees are assigned a schedule, and salaried staff are monitored o Time cards are electronically submitted and approved electronically to ensure time is recorded as it occurs. o Time off records are also submitted for approval electronically and leave is approved based on County personnel guidance. • Wipfli Consulting is providing technical assistance over a 10 month period to develop/deploy updated policies and procedures for fiscal area, in accordance with Uniform Guidance. Curriculum includes: o Internal controls o Allowable compensation and employee benefits o Cost allocation methods o Governing body financial responsibilities o Budgeting o Financial reporting o Financial management systems o Documentation and record retention o Financial policies and procedures o Allowable costs • All administrative leadership staff received, and will continue to receive annually, fiscal oversight training including but not limited to, Uniform Guidance training, grants management and compliance training. Allocations are reviewed regularly by leadership team to ensure that we have appropriate methodology and that we are consistent with grant expectations and regulations. Proposed Completion Date June 30, 2024

Significant Deficiency 2023-001. Payroll (Allowable Costs/Cost Principles) United States Department of Education, Passed-through New York State Department of Education: Education Stabilization Funds (ESF) COVID-19: American Rescue Plan – Elementary and Secondary School Emergency Relief (ARP ESSER) Assistance Listing No. 84.425U Condition: Subpart I, 2 CFR §200.430 of the Uniform Guidance requires that charges to “Federal awards for salaries, wages and other forms of compensation 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), timesheets, or periodic certifications or the equivalent is the most effective way to comply with this requirement. During the current year, the District inadvertently charged resource officers payroll costs to a federal grant, however, it was determined that these payroll costs were not budgeted in the federal grant and should not have been charged to the federal grant. Planned Corrective Action: The District implemented a new summer program utilizing federal grant funds approved by the NYSED. The District charged resource officers payroll costs that occurred during the scheduled approved summer program, however it was determined that these payroll costs were not budgeted in the federal grant, per the FS-10. Since the grant funding period of this grant is still open, the District contacted NYSED to determine the necessary course of action to rectify this matter. It was determined that the District will prepare and submit an FS-10A amending the original FS-10, to include the resource officer’s payroll costs in the grant as it relates to the approved summer program. In addition, the District will review its internal review procedures to ensure that payroll costs charged to federal grants are supported by the proper documentation for each employee and are allowable per the approved budget of the federal grant. The FS-10A will be prepared and filed prior to the June 30, 2024 by the Assistant Superintendent for Curriculum. Responsible Contact Person: Denise Gillis Assistant Superintendent for Finance & Operations West Babylon Union Free School District 200 Old Farmingdale Road West Babylon, NY 11704 Anticipated Completion Date: June 30, 2024

Name of Contact Person: Amy Dixon, Superintendent. Recommendation: We recommend that for employees that work on multiple cost objectives, the employee complete a semi-annual certification verifying the percentage worked on the applicable grant, and then have the certification signed by both teh employee and the Superintendent. Corrective Action: The District will begin completing the necessary semi-annualcertification and will have both the employee and superintendent sign the certification. Proposed Completion Date: Immediately.

2023-002 Crime Victim Assistance – Assistance Listing No. 16.575 Recommendation: WON should implement a process to complete time and effort certifications and reconcile those certifications to ensure the costs reported to the grantor are accurate. All additional amounts paid contain documentation that they are properly authorized. All employees should have timesheets to support the hours worked and charged to the grant. These timesheets should be formally approved by a supervisor. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Women of Nations has updated its payroll policies and procedures to ensure that time and effort certifications are completed correctly and approved in a timely manner by supervisors. Name(s) of the contact person(s) responsible for corrective action: Charles Nelson Planned completion date for corrective action plan: June 1, 2023

Planned Corrective Action: Management has engaged a third-party vendor for a new time and attendance software that will allow all hours worked and related programs to be tracked accurately. A contract has been signed and the software is actively being implemented. Responsible Person: Lynda Paris, JD, MSA Anticipated Completion Date: February 2024

Management’s response/corrective action plan: Trust staff created a new timesheet that addresses the shortcomings identified during the FY23 audit. The new timesheet allows staff to record daily hours spent working on Federal grants directly to the individual funding sources. In addition, the Director of Finance will be auditing FY23 timesheets of those staff members that had time assigned to the Federal grants to determine if we can identify, through other means, a way to account for all hours charged to the grants in FY2023.

2023-002 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Material Weakness in Internal Controls over Compliance and Material Noncompliance Recommendation: The auditors recommend the University implement an internal control policy that requires employees whose compensation is charged to a federal award to complete time and effort reporting to accurately reflect the work performed on each federal award and ensure supporting documentation is maintained for those who do charge time and agrees to amount allocated to the award. Planned Corrective Action: Heritage University will implement a new internal control policy that requires employees whose compensation is charged to federal awards to complete time and effort to accurately reflect the work performed on each federal award. Heritage University is using the time and effort forms to allocate the correct hours to each federal award during the payroll process period. Each pay period an employee must fill out the time and effort to show actual hours worked. The form is signed by the employee and supervisor before turning it in to the payroll department. An email will be sent out to all employees outlining the new process required by employees whose hours are charged to a federal award. Name of Responsible Party: 1. Yolanda Maltos, Grant Accountant 2. Terri Slack, Fiscal Agent 3. Melissa Hill, Provost 4. Alysia Stevens, Controller 5. VP of Administration/CFO 6. Dr. Andrew Sund, President Anticipated Completion Date: 6/30/2024

In 2022-23, ail staff salary, wages and benefits were updated to the work completed and charged to the appropriate grants. The funding for the district changed during the year, and pars were not updated. When MDE finalized the allocations/ the Director of Finance updated the sources staff were paid from based on the work performed. In 2023-24, the district will have staff paid with federal funds sign each semester they were paid with federal dollars.

Planned Corrective Action: Family First Health did update their internal policies around time and effort reporting as well as implemented an attestation form that is sent to employees through Paycom. Employee profiles have been updated to include the recognition of if/which grants their time is attributed to. Employees are required to attest to their time for every payroll prior to their supervisor’s approval. We have had success in obtaining signed attestation statement from employees in recognition of the connection between their work and respective grants. Completion Date 4/1/23 Accounting Name of Contact Person: Jenny Englerth, President/CEO; Brent Doores, CFO

By bringing the payroll back into the District from FEH BOCES, allows better oversight of the payroll functions. The District continues to work on improving and developing systems to enhance the payroll disbursements which are supported by documentation and approvals. It is the goal of the District to continue to improve on systems by which timesheets are obtained promptly and maintained. The District purchased a timesheet enhancement software that works in conjunction with WINCAP software through FEH BOCES that is waiting to be implemented by the FEH BOCES Shared Business. Brandon Pelkey, superintendent ofschools is responsible for implementing this corrective action plan. We plan to rectrify all action by June 30, 2024.

Finding 2023-005 Name of Responsible Individual: Tonya Kilpatrick, AVP Finance and Compliance Corrective Action: We experienced a system glitch resulting in records that remained in validation tables and did not move to the process reporting tables which prevented proper reporting of work hours performed. The system did not generate the required certification reports to allow the selected employee to certify their effort. We are reviewing our processes to implement an automated comparison reports of individual employees paid from federal grants and the system generated effort certification report to ensure that the system generates the required effort report to allow the employee to properly certify their effort. We will also ensure that all employees approve/certify actual time worked allotted to federal funds within our time and attendance system to provide another level of certification. This report will be produced quarterly to ensure that system errors are corrected before the required semiannual effort reporting requirement. Anticipated Completion Date: March 1, 2024

Dec 19, 2023 Donovan CPAs 5151 E. U.S. HWY 36 Avon, IN 46123 Detailed below is the Official Response to Audit Results and Comments relative to the review of Muncie Public Charter School of Inquiry, Inc.’s (“the School”) compliance with provisions of the Accounting and Uniform Compliance Guidelines Manual for Indiana Charter Schools issued by the Indiana State of Accounts. Audit Results and Comment: III. Federal Award Findings and Questioned Costs FINDING 2023-001 TIME AND EFFORT RECORDS SIGNIFICANT DEFICIENCY Federal Program: Education Stabilization Fund Assistance Listing Numbers: 84.425D and 84.425U Condition: The School applied employee salary expenses to the program. While employees were applied to the grant in line with the approved budget, proper time and effort records were not maintained. Semi-annual certification forms did not reflect a six-month period and were not signed at the end of the six-month period. Criteria: Charges for Federal awards for salaries and wages must be based on records that accurately reflect work performed (2 CFR 200.430(i)). Cause: The School was not aware of the requirement outlined in the Criteria section above. Effect: The School is unable to document certification of employee time spent in the program. Recommendation: We recommend the School develop internal controls to ensure that proper semi-annual certifications are maintained. Views of Responsible Officials and Planned Corrective Actions: The School’s Corrective Action Plan is included on page 2. Response: The financial manager, Ana Maric, will submit completed semi-annual certification forms for all employees paid from Title I, Part A; IDEA, Part B (611), and ESSER III for the period of July 01, 2023 to Dec 31,2023 to Donovan CPA for review by January 15, 2024. In addition, semi-annual certification forms will be completed for individuals paid by federal grants and will reflect six-month certification periods to be signed by the employee’s supervisor at the end of the six-month period. In order to maintain this, there will be internal checks and balances every six months to review with the Executive Director, Leslie Draper. Leslie Draper Executive Director Inspire Academy- A School of Inquiry 2801 E. 16th St. Muncie, IN 47302

Finding 2023-005 Activities Allowed or Unallowed – Child Nutrition Cluster Material Weakness in Internal Control Over Compliance and Material Noncompliance Finding Summary: The District does not have an internal control system designed to review and maintain documentation for federal expenditures, specifically documentation of changes to contract wage rates or evidence of approved timesheets. Responsible Individuals: Shannon Hunstad, Superintendent Corrective Action Plan: The District will review and strengthen the controls surrounding the review and approval of allowable costs in the Child Nutrition Cluster to ensure they are supported, approved, and accurate. Anticipated Completion Date: June 30, 2024

Condition: Semi-annual time and effort certifications were not maintained for a grant employee whose salaries and wages were not supported by detailed time records. Corrective Action Planned: Management is aware of the missing time and effort certifications for the single grant employee. This error was in part due to the transition of both the Payroll Coordinator and Budget Analyst positions within Canton Public Schools. Controls have been put in place to ensure all time and effort certifications are completed and submitted to the business office in a timely manner. Anticipated Completion Date: Completed Contact: Stephen Marshall, Assistant Superintendent of Finance & Operations

1. Accounting Controls team will continue to coordinate with Central Office/program coordinators to: a) Communicate the impact of questioned cost resulting from current year’s audit findings. b) Follow through on the sample testing performed on payroll documentations as a secondary control twice a year; and c) Provide feedback and training to the schools based on the result of sample testing. 2. The Accounting controls team will continue to collaborate with the MyPLN team to ensure effective monitoring and timely completion of the annual Mandatory Time and Effort Training. This essential training is mandatory for administrators, timekeepers, and supervisors. Successful completion involves answering review questions at the conclusion of the course, with a 100% correct response rate necessary to obtain certification. 3. Each July, the LAUSD organizes the Principals' Leadership Institute, during which the Accounting Controls team and Central Office/program coordinators will present to principals and assistant principals the significance of completing Time and Effort documentation in a timely and accurate manner. 4. The Accounting Controls team will work with Organizational Excellence and Central Office/program coordinators to present to School Administrative Assistants at their scheduled meetings/trainings, at least once a year. Name: Bryant Gonzalez Title: Deputy Controller Email: bryant.gonzalez1@lausd.net

Views of Responsible Officials: Educare DC is an educational non-profit organization. We have consistently used weekly timesheets to document the total time spent by teaching and administrative staff. However, considering that it is difficult for teaching and administrative personnel to accurately charge time to specific awards, management has consistently used estimates based on the role of each employee. These estimates are reconciled and updated regularly based on after-the-fact effort in consultation with staff. Management will make sure this process is officially documented going forward. Management has noted the auditor’s recommendation and will ensure documentation of its allocation process to support time charged to federal program is strengthened. In addition, a formal policy and procedure will be documented and include responsible parties for preparing, reviewing, approving, and adjusting any noted variances between estimates and actuals incurred on a regular basis. Name and Title of Responsible Official: Barbara Ledyard, Vice President of Finance and Administration Anticipated Completion Date: January 31, 2024

Finding 2023-002: Special Education Cluster Semi-Annual Certification Procedures Recommendation: The School District should provide training to educate all employees working in federal programs of the requirements for documenting personnel expenses under Uniform Grant Guidance, and the School District should require proper time-and-effort documentation to be timely reviewed and approved by the appropriate program supervisor. Action Taken: Trainings will be provided to all directors of federally funded programs regarding the semi-annual certification process. Certifications will be performed by all federally funded staff two times each year. The first certification is due to the Director of Fiscal Services no later than January 15 of each year. The second certification is due to the Director of Fiscal Services office no later than July 15 of each year. Certification records will be verified and maintained by the Director of Financial Services. Responsible Person and Anticipated Completion Date: Director of Financial Services, November 2023. If the Michigan Department of Education has questions regarding this plan, please call Jesse Rickard at (231) 767-7209.