Corrective Action Plans

Finding Summary: The Town did not have written policies, procedures, and standards of conduct relative to federal awards as required by the Uniform Guidance. Responsible Individual: Kathryn Lynch, Town Administrator Corrective Action Plan: The Town will be updating the Town?s procedures and policies to incorporate the requirements of Part 200 of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. Anticipated Completion Date: June 30, 2023

FINDING 2022-003 Subject: Special Education Cluster ? Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Findings: Material Weakness Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Activities Allowed or Unallowed and Allowable Costs/Cost Principles compliance requirements. Context: The School Corporation is a member of a joint service cooperative (Cooperative). The Cooperative operated the special education programs on behalf of the School Corporation and managed the special education grant funds. Because the grant agreements were between the Indiana Department of Education and the School Corporation, the School Corporation was ultimately responsible for compliance with the grant agreement and the Activities Allowed or Unallowed and Allowable Costs/Cost Principles compliance requirements. During fiscal year 2021, the School Corporation paid membership fees to the Cooperative out of federal Special Education funds. These membership fees made up approximately 48% of the total federal expenditures reimbursed during fiscal year 2021. The Cooperative accounted for state, local, and federal funds in a single fund. The fund did not separately account for each of the funding sources. This made it difficult to identify which expenditures were from federal funds, or to identify expenditures by federal program, award number, or years. Therefore, we could not test compliance for approximately 48% of the expenditures. The lack of internal controls and noncompliance were systemic issues, which occurred specifically during fiscal year 2021. No reportable findings were noted for fiscal year 2022. During fiscal year 2022, the School Corporation started paying membership fees to the Cooperative out of the General Education fund instead of the Special Education funds. All sampled expenditures paid from Special Education funds and requested for reimbursement were determined to be allowable under the Activities Allowed or Unallowed and Allowable Costs/Cost Principles compliance requirements. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Members of the cooperative are no longer paying their cooperative member fees with federal funds. This was resolved effective 7/1/2021. Responsible Party and Timeline for Completion: Zach Dennis, CFO, 7/1/2021

Views of Responsible Officials: District is reviewing the internal procedures related to documenting salaries and wages charged to federal programs and will work with our auditors to ensure we meet this requirement. Name of Responsible Person: Anne Marie Gordon, Interim Chief Financial Officer Implementation Date: Fiscal Year 2023-2024

EXECUTIVE OFFICE OF LABOR AND WORKFORCE DEVELOPMENT 2022-012 WIOA Cluster ? Assistance Listing No. 17.258, 17.259, 17.278 Action taken in response to the finding: EOLWD has policies and procedures in place to support consistency in charging employee absences. EOLWD will improve existing internal control policies and procedures to ensure that payroll costs charged to federal programs are based on records of actual work performed and such records be reviewed and certified by the employee and supervisor prior to allocation of payroll costs to the WIOA Cluster. In addition, the Department will maintain appropriate documentation to support the SWCAP and DOL indirect cost rates charged to eligible program costs for this Cluster. In response to an EOLWD prior year audit finding, MassHire Department of Career Services (MHDCS) has and will continue to issue a reminder to all senior managers to take extra care to verify that SSTAs they sign off on each week are completed with all required codes. Name of the contact person responsible for corrective action: Anna Yong, Deputy CFO, EOLWD Planned completion date for corrective action plan: June 30, 2023

Planned Corrective Action: As part of the ongoing review of procedures, all wage changes must now be approved in writing by the CEO or her designee for all subordinate staff, and by the Board of Directors for the CEO. All wage changes will be submitted to the payroll processor before any adjustments can be made in the system. Additionally, each payroll is reviewed by a second person to ensure compliance. All supporting documentation of compensation changes will also be placed in the employee's personnel file. Policies and procedures and/or the Financial Procedures Handbook will also be updated to reflect the changes.

FINDING: DYER COUNTY SCHOOL DEPARTMENT HAD DEFICIENCIES IN THE USE OF EPIDEMIOLOGY AND LABORATORY CAPACITY FOR INFECTIOUS DISEASED (ELC) GRANT FUNDS, WHICH RESULTED IN QUESTIONED COSTS Response and Corrective Action Plan Prepared by: Cheryl Mathis, Director of Schools & Jeremy Gatlin, School Board Chairman Person Responsible for Implementing the Corrective Action: Cheryl Mathis, Director of Schools & Jeremy Gatlin, School Board Chairman Anticipated Completion Date of Corrective Action: October 11, 2022 ? Repeat Finding: No Reason Corrective Action was Not Taken in the Prior Year: NIA Planned Corrective Action: The school system will strengthen its internal controls by requiring that any future bonus paid to any member of the administrative staff be approved by the school board before the funds are disbursed to ensure that duties are adequately segregated. /l

Finding #2022-001 Condition: The School District did not maintain proper time and effor records for employees who were partially funded with ESSER federal funds. Timesheets did not contain a certification clause that the information submitted accurately reflects the time and effor distribution, and the timesheet was not dated by the employee and/or supervisor. Corrective Action Plan: A similar finding was noted during the October 20, 2022 Federal Fiscal Monitoring visit by the New Hampshire Department of Education (DOE) regarding Washington School District (another SAU #34 District). As a result of the visit, we updated our bi-weekly time sheets for time and effort documentation. The timesheets now include the required certification clause, ensure proper documentation of hours worked under the grant, and require signatures and dates for the employee and supervisor. Individual Responsible: Grant Geisler, Business Manager Anticipated Implementation Date of Corrective Action: January 2023

Hope House concurs with the auditor?s recommendations. Effective October 2022, the Executive Director will print and store personnel action forms in the employee?s file.

With regard to Federal Award Finding 2022-001, Documentation of Personnel Expenses Charged to Federal Awards, in the audit report for Mountain Home Montana, Inc. for the year ended December 31, 2022, we offer the following response. We understand that Single Audit standards require documentation of personnel expenses charged to multi-funding sources to include the specific activities performed and adequate authorization in accordance with the individual grant agreements. We plan to review and develop our policies as recommended in the audit report to achieve an acceptable time-tracking process for our federal funds. We anticipate starting and implementing this process in the current fiscal year with the goal of being in compliance for next year's audit.

Finding 2022-003 Federal Agency Name: Department of Education and Passed through State of South Dakota Department of Education Program Names: COVID-19 Education Stabilization Fund- Governor?s Emergency Education Relief (GEER) Fund and Twenty-First Century Community Learning Centers Program FFAL # 84.425C and 84.287C Finding Summary: The amount of payroll taxes allocated to the GEER program exceeded the amount of payroll taxes actually paid for two of two employees tested. Additionally, one instance in which an employee?s overtime hours was not charged to the Twenty First Century Program. Lastly, one instance in which one employee?s biweekly wages were not charged to the Twenty First Century Program. Responsible Individuals: Scott Hupke CFO Corrective Action Plan: We have added an additional person in the review of the manual process for accuracy and to eliminate the errors. We will also continue to explore ways to automate the process from our payroll provider to the accounting software. Anticipated Completion Date: October 2022 for the manual process review and ongoing for the ways to automate the process.

The Community Builders, Inc. 185 Dartmouth Street Boston, MA 02116 CORRECTIVE ACTION PLAN September 21, 2023 Federal Audit Clearinghouse The Community Builders, Inc. (the Company) respectfully submits the following corrective action plan for the year ended December 31, 2022. Name and address of independent accounting firm: CohnReznick 7501 Wisconsin Ave, Suite 400E Bethesda, Maryland 20814 Audit period: January 01, 2022-December 31, 2022 The findings from the December 31, 2022 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Findings and Questioned Costs - Major Federal Program Audit MATERIAL WEAKNESS Hope VI Cluster 14.889 2022-002 ? Allowable Costs/Cost Principles Recommendation: The Company should establish a system of internal controls to provide reasonable assurance that salary and wage costs are accurate, allowable, and properly allocated by basing salaries and wages charged to federal awards on underlying records that accurately reflect all work performed on a daily basis in accordance with 2 CFR 200, Subpart E, Subsection 430. Action Taken: The Company has procedures in place to provide reasonable assurance that salaries and wages are accurate. The Company has managed several federal award programs and has a billing tracking system already implemented in ADP. When implementing this new program with a different department, it was identified that three staff were not following the payroll billing policies already put in place. The Company has notified the staff and effective September 1, 2023, the department has started tracking their time directly in ADP. Management will review this billing as part of draw submissions to confirm the process is being followed. If the Federal Audit Clearinghouse has questions regarding this plan, please call Alexa DuCote at 857-221-8753. Sincerely, Alexa DuCote Vice-President of Corporate Finance and Accounting

2022-004 Head Start Cluster, Federal Assistance Listing No. 93.600 Allowable Payroll Costs and Controls Over Payroll (Repeat) Recommendation: The auditors recommend that the Organization establish policies and procedures to support a system of internal controls, which provides a reasonable assurance that the charges to federal awards for salaries and other payroll related costs are accurate, allowable and properly allocated. Documentation of all employees? approved pay rates, hours worked and support for the allocation percentages (or actual hours worked) should be maintained. Actions Taken or Planned: The Organization terminated our professional relationship with our financial services provider in FY23, Quatrro BSS. We established a financial services contract with Metropolitan Family Services (MFS) that began July 1, 2022. MFS manages over 130 million dollars in revenue each year and the current finance team has over 50+ years of combined experience managing government and private contracts. MFS is a Professional Employer Organization (PEO) for five organizations averaging four million dollars in annual revenue and has established back-office and finance service contracts with those organizations. MFS has policies and procedures to support a system of internal controls which provides a reasonable assurance that charges to federal awards for payroll related costs are accurate, allowable, and properly allocated. Budget estimates are used for interim accounting purposes provided the estimates produce reasonable approximations of activity performed. The MFS finance team and the Organization's executive team review payroll allocations each quarter. Allocations are supported by an after-the-fact accounting of employee time and effort in a Personal Activity Report (PAR), significant changes in work activity are identified and entered into the record, and the after-the-fact review is completed to make all necessary adjustments to the final amount charged to the Organization's federal awards to help ensure charges are accurate, allowable, and properly allocated. Person Responsible: The Howard Area Community Center Executive Director, Jason Kaiser and the Metropolitan Family Services finance team including CFO James Baldwin, Controller Kelly Kelly, Director of Budget Don Pzynarski, and Assistant Budget Director Emilia Vargas. Estimated Date of Completion: April 2023.

2022-001. 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 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 failed to prepare periodic certification equivalents, to comply with Subpart I, 2 CFR ?200.430. Planned Corrective Action: The District replaced the employee that left the District, and the new employee is being trained on ensuring the appropriate documentation will be prepared to support the compliance with Subpart I, 2 CFR ?200.430. Responsible Contact Person: Lawrence Luce Anticipated Completion Date: June 30, 2023 Contact Information: Lawrence Luce Assistant Superintendent for Finance & Operations Hampton Bays Union Free School District 86 Argonne Road East Hampton Bays, NY 11946

Finding 2022-002 Allowable Costs/Cost Principles (Material Weakness) Condition: Compensation ? personal services: For this program, there was no evidence that actual employee time was tracked, reviewed and approved, or the actual time spent was used as a basis for allocating personnel charges to the grant. Correction Action Planned: ? Each location will use a time sheet for tracking actual hours worked on grants. This time sheet will include all grants that the employee worked on and non-grant time. The time sheet will be signed bythe employee and reviewed and approved by the employee?s supervisor ensuring time spent on grant is accurately recorded. ? The grant accountants will retain completed time sheets together with other expenditure support for grant reimbursement. The grant accountants will review the actual salary expense against initial budgeted grant expense and make necessary adjustments to charges to reflect accurate salary expense for each grant. The Grant Accounting Manager will review and approve grant accounting adjustments prior to completion of changes. Anticipated Completion Date: September 30, 2023 Name of Contact Person Responsible for the Plan: Kevin T. Hodges

Texas Office of the Governor ? Criminal Justice Division and Children?s Advocacy Centers of Texas, Inc. Henderson County HELP Center, Inc. respectfully submits the following corrective action plan for the year ended August 31, 2022. Frank Campos & Associates, PLLC P.O. Box 2918 Palestine, Texas 75802 Audit Period: August 31, 2022 The finding from the August 31, 2022 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. Federal Awards Program Audit Significant Deficiency 2022-001 Allowable Costs Recommendation: The Organization should review timesheets before coding salaries and wages in QuickBooks and preparing requests for reimbursement. In addition, the Organization should be updating its FTE calculation for its cost allocation plan and certifying it monthly to determine monthly grant expenditures. Action Taken: The Henderson County HELP Center, Inc. (the Organization) will ensure each employee timesheet is reviewed and approved monthly prior to payroll being paid. The Organization will also ensure the cost allocation plan based on full-time equivalents (FTE) is reviewed and certified monthly prior to preparation of requests for reimbursement. If the Texas Office of the Governor ? Criminal Justice Division or Children?s Advocacy Centers of Texas, Inc. have any questions regarding this plan, please call Leslie Saunders at (903) 675-4357.

CORRECTIVE ACTION PLAN YEAR ENDED JUNE 30, 2022 We have prepared the following corrective action plan as required by the standards applicable to financial audits contained in Government Auditing Standards and by the audit requirements of Title 2 U.S Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Specifically, for each finding we are providing you with the names of the contact people responsible for corrective action, the corrective action planned, and the anticipated completion date. Financial Statement Findings 2022-001: Significant Deficiency in Internal Controls Over Payroll Recommendation: To help ensure that charges to payroll expenses are properly supported and accurate, the Organization should implement internal control policies and procedures that requires periodic reviews of employee records as it relates to payrates, amounts recorded on timesheets, and time off approvals. Action Taken: The Organization concurs and has implemented the recommendation. Completion Date: During fiscal year ending June 30, 2023 Contact Person: Ivan Gilreath, President and CEO 2022-002: Significant Deficiency in Financial Statements Presented in Accordance with GAAP Recommendation: We recommend that the Organization implements procedures to help ensure the completeness of pledges receivable recorded in the financial statements and to document the methods required to record lease liabilities in accordance with GAAP as part of the financial closing process. Action Taken: The Organization concurs and has implemented the recommendation. Completion Date: During fiscal year ending June 30, 2023 Contact Person: Ivan Gilreath, President and CEO Federal Awards Findings and Questioned Costs 2022-101: Significant Deficiency in Internal Controls Over Payroll Recommendation: To help ensure that charges to payroll expenses are properly supported and accurate, the Organization should implement internal control policies and procedures that requires periodic reviews of employee records as it relates to payrates, amounts recorded on timesheets, and time off approvals. Action Taken: The Organization concurs and has implemented the recommendation. Completion Date: During fiscal year ending June 30, 2023 Contact Person: Ivan Gilreath, President and CEO

Our Katahdin will implement a process for accurate tracking of time through timecards or other time-tracking methods and will adopt a policy for maintaining those records. Responsible official: Nancy DeWitt, Treasurer (207) 618-9187 Expected completion date: October 31, 2023

Radiant Health Centers has recently transitioned to a new Human Resources Information System, PayCom, that will better help the organization track timesheets, including a more accurate reflection of time staff worked and electronic documentation of review and approval by supervisors of their staff.

Finding No. 2022 ? 001, Payroll (Renewal of Personnel Action) Auditee Response: Contact Person: David Attao, CFO Contact Information: david.attao@marianas.edu Completion Date: December 2023 The College partially agrees with this finding as the situation is unique to disputes that arise between the employee and supervisor during the employee personnel action renewal process. Personnel Actions are implied as renewed per employee contract terms. In order to resolve this finding, the College will update and revise NMC Procedure No. 5101.7: Employee Evaluations and NMC Procedure No. 5006.1: Employee Grievances to provide the supervisor and employee a 90 day grace period to conduct the evaluation, to add and engage a grievance process as needed, and to provide time for any dispute resolutions or negotiations. After such actions take place, a final decision must be reached at least 30 days prior to the contract's expiration date in the event of a non-renewal or renewal of personnel actions. Finding No. 2022 ? 002, Payroll (Contract Renewals) Auditee Response: Contact Person: David Attao, CFO Contact Information: david.attao@marianas.edu Completion Date: December 2023 The College partially agrees with this finding as the three contracts were implied as renewed per employee contract terms. To resolve this finding, the College will update and revise NMC Procedure No. 5101.7: Employee Evaluations and NMC Procedure No. 5006.1: Employee Grievances to provide the supervisor and employee a 90 day grace period to conduct the evaluation, to add and engage a grievance process as needed, and to provide time for any dispute resolutions or negotiations. After such actions take place, a final decision must be reached at least 30 days prior to the contract's expiration date in the event of a non-renewal or renewal of contracts. Finding No. 2022 ? 003, Payroll Auditee Response: Contact Person: David Attao, CFO Contact Information: david.attao@marianas.edu Completion Date: December 2023 The College partially agrees with this finding as it is related to Finding No. 2022-002. The three contracts were implied as renewed per employee contract terms. To resolve this finding, the College will update and revise NMC Procedure No. 5101.7: Employee Evaluations and NMC Procedure No. 5006.1: Employee Grievances to provide the supervisor and employee a 90 day grace period to conduct the evaluation, to add and engage a grievance process as needed, and to provide time for any dispute resolutions or negotiations. After such actions take place, a final decision must be reached at least 30 days prior to the contract's expiration date in the event of a non-renewal or renewal of contracts.

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.

This is a repeat finding from FY2021 (2021-004). The finding was identified during our 2021 audit and corrected in March of 2022. It is important to note that, the United States Department of Education?s ?Frequently Asked Questions Elementary and Secondary School Emergency Relief Programs Governor?s Emergency Education Relief Programs? dated May 26, 2021 stated on page 19 that ?An LEA must maintain time distribution records (sometimes called ?time and effort? reporting) only if an individual employee is splitting his or her time between activities that may be funded under ESSER or GEER and activities that are not allowable under the applicable program.? After the 2021 was complete and 2022 was significantly underway, the auditor indicated that time-and-effort was required and the auditor stated that SDE agreed. Therefore, the district began obtaining time-and-effort for employees paid with federal funds in March of 2022, regardless of SDE and USDE guidance stating otherwise.

Department: Grants Condition: The District did not maintain adequate support documentation to substantiate salaries and wages charged to the Title I, Part A grant. Corrective Action: At the start of the 2022-23 school year BHAS implemented a new process to monitor staff salaries funded using title funds. An online platform was created for staff to fill out and submit ?Time and Effort? logs to their building principals for signature All staff funded in this manner were required to attend a 30-minute PD about how to fill out their logs each week and how to submit online to their principals. Once principals reviewed logs, they upload them to a shared drive folder created by building, month, and weekending. Grant Coordinator and Grant Account then reviews folders on a monthly basis and if individual logs are missing a notice is sent to that building principal and individual to complete and submit missing ?Time and Effort? sheet. Person(s) Responsible for Executing Corrective Action: ? Grant Coordinator ? Grant Accountant ? Building Principals ? Funded Staff Member Anticipated Completion Date: 12/31/22

FINDING 2022-007 Contact Person Responsible for Corrective Action: Nicole Wolverton, CFO Contact Phone Number: 219-881-5536 Views of Responsible Official: We concur with the audit finding. Description of Corrective Action Plan: A policy and procedure will be created to ensure that all supporting documenation of employee?s time and effort logs are reviewed and retained when paying salary from Federal Title I grant allocations, including review and approval of pay rates and fund distributions that are entered by the payroll department, reviewed by Federal Programs, with final review of accuracy and completeness by the Chief Financial Officer. Anticipated Completion Date: Gary Community School Corporation will implement this procedure by September 2023. INDIANA STATE

FINDING 2022-002 Contact Person Responsible for Corrective Action: Nicole Wolverton, CFO Contact Phone Number: 219-881-5536 Views of Responsible Official: We concur with the audit finding. Description of Corrective Action Plan: As it relates to activities allowed or unallowed for Child Nutrition, a new policy and procedure will be implemented for requiring appropriate documentation from the Food Service Vendor. The policy will require the vendor to provide all supporting invoices for food purchased and time sheets for time and labor records. In addition, this policy and procedure will ensure the correct indirect cost allocation when submitting the application and required documentation to the Office of School Finance. This application submission will be prepared by the Chief Financial Officer and reviewed by the GCSC Manager to ensure accuracy and completion. The policy will contain language specific to the consideration of direct and indirect cost calculations and providing all supporting documentation for the determination of allowable and unallowable costs. GCSC will ensure indirect costs are charged according to the approved indirect cost rate. As it relates to special test and provisions to the School Food Accounts, a procedure will be implemented for the recording of receipts and expenditures within the food service accounts and the timeliness of the account reconciliations to be completed by the District Treasurer. Anticipated Completion Date: Gary Community School Corporation will implement this procedure by September 2023.

Auditors? Recommendation - We recommend the College enhance the design of its control activities and develop procedures to ensure that employee documentation is retained and updated within the employee file and the payroll system.Views of Responsible Officials and Planned Corrective Action - The College agrees with the finding and will instruct supervisors and payroll officials to receive and document all authorizations before payroll is run. Accordingly, Human Resources staff will review each contract with the rate of pay in the payroll system to ensure validation. Responsible Official - Denise Montoya, Vice President for Finance & Administration, Theresa Storey, Chief Financial Officer, and Ken Lucero, Director of Human Resources Timeline and Estimated Completion Date - June 30, 2023