Corrective Action Plans

FINDING 2022-006: CRIME VICTIM ASSISTANCE (16.575) ? ALLOWABLE COSTS AND COST PRINCIPLES ? PAYROLL CHARGES AND COST ALLOCATION CONTACT PERSON: Robyn Young, Executive Director CORRECTIVE ACTION: Safenet, Inc. has implemented procedures to ensure that reimbursement requests for wages are supported by documentation that supports the amounts requested. Backup for payroll requests will be based off time and effort spent on each award using a new time keeping system that records time spent on each award. Management will routinely review payroll reports for accuracy and adjust when necessary. The Board of Directors for Safenet, Inc. approved a revised cost allocation plan on August 18, 2022 and a revised version on January 30, 2023 that have been reviewed by the auditor. This plan will support equitable allocation of costs across all sources. PROPOSED COMPLETION DATE: Immediately

Reference Number: 2022-001 Prior Year Finding: No Federal Agency: U.S. Environmental Protection Agency Federal Program: Water Pollution Control Assistance Listing Number: 66.419 Award Number and Year: I-98339417 (10/1/2021 ? 9/30/2022) Compliance Requirement: Allowable Cost/Cost Principles ? Time and Effort Reporting Type of Finding: Significant Deficiency in Internal Control Over Compliance, Noncompliance Recommendation: The Commission should reevaluate its current process and update internal controls related to time and effort reporting. The Commission should not seek federal reimbursement unless it can substantiate that the time and effort was dedicated to the federal program. Explanation of disagreement with audit finding: There is no disagreement with the audit finding that $582 was improperly charged to EPA 106 Account #802 on one timesheet and not caught because of a change in personnel. ICPRB notes that EPA 106 Account #802 was not overcharged because ICPRB spent $80,000 more on this project than was charged to the federal government. Action taken in response to finding: Hiring of Office Manager to review the formulas used in timesheet entries [Completed February 2023]; Blocking of employees from adding accounts directly into their monthly timesheets without first including the account into the YTD portion of the timesheet software [Underway]. Name(s) of the contact person(s) responsible for corrective action: Michael Nardolilli, Executive Director Planned completion date for corrective action plan: March 2023 If the U.S. Environmental Protection Agency has questions regarding this plan, please call Michael Nardolilli, Executive Director at 301-274-8105.

The District will implement internal controls to monitor and ensure that the appropriate time and effort documentation of those employees paid in whole or in part with federal funds is on file to support the amount of time an employee works on a federal program. Compliance will be achieved by: 1)Develop a set of internal controls for time and effort documentation which provides reasonable assurance that charges are accurate, allowable, and allocable. (CFO/Treasurer) 2)Require time and effort documentation be filed in a timely manner with the CFO/Treasurer and maintained for records. (CFO/Treasurer ? Superintendent ? Direct Supervisor) 3)Require Direct Supervisor of employees to maintain time and effort documentation in accordance with District policies and procedures, as well as federal laws and guidelines. (Direct Supervisor) 4)Periodically monitor time and effort documentation in relationship to the percentage of time the employee spends on a federal program vs. non-federal. (CFO/Treasurer ? Superintendent - Direct Supervisor)

2022-006 Epidemiology and Laboratory Capacity for Infectious Diseases and Support of Immunization Initiative-Focusing on Childhood Vaccination Programs ? Assistance Listing No. 93.323 and 93.268 ? Allowable Costs Recommendation: We recommend the County review time and effort records to ensure overtime is not charged to Federal grants on days in which vacation and sick time is used. More detailed reporting of the days in which the vacation and sick days are used and the overtime days would assist with this process. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The public health department is in the process of training new employees that are responsible for payroll and grant allocations. The Finance Manager has begun conversations with the new employee and the public health administrator on documentation and review. It was discussed that no benefit time such as vacation or sick be charged to a grant. If there are allowances within a grant for benefit time to be charged, there must be proper documentation and detailed approval by the public health board. This will be implemented immediately. Name of the contact persons responsible for corrective action: Jill Johnson, Finance Manager, and Department Heads and Elected Officials Planned completion date for corrective action plan: Immediate implementation

The district has hired an additional person to help with grant reporting. Part of the job is to keep track of the grant funded employees making sure we are receiving either timecards, PARS, or Semi-certifications for the employee's time worked in the grant. Name of Contact Person and Completion Date: Name 1: Heidi Duford Anticipated Completion Date - 6/30/2024

Huron Intermediate School District respectfully submits the following corrective action plan for the year ended June 30, 2022 Auditor: Anderson, Tuckey, Bernhardt, & Doran, P.C. 715 E. Frank St. Caro, MI 48723 Audit Period: Year ended June 30, 2022 District Contact Person: Candice Halifax, Director of Finance and Carrie Brabant, Special Education Accountant The finding from the June 30, 2022 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. Finding ? Federal Award Programs Audit Finding 2022-001 ? Significant Deficiency in Internal Control over Compliance Recommendation: The District should adhere to documented time and effort reporting procedures and maintain effective internal controls that ensure salaries and wages allocated to federal cost objectives are based on records that accurately reflect the work performed. Action to be taken: The School District will review the time and effort reporting and align it with the staff federal cost objectives on a quarterly basis to ensure the documentation accurately reflects the work performed.

Finding Number: 2022-002 ? Significant Deficiency ? Internal Control Over Payroll The Alliance hired an organization that specialized in helping non-profits with accounting services. This organization has reviewed the payroll process and made suggestions for improvements. These suggestions have been implemented and will continue to be refined to ensure that allocations are made correctly based on time and effort. Additionally, formal reviews of time and effort will be made prior to posting expenses to the ledger. Person(s) Responsible: Ruth Allen-Kermish Timing for Implementation: Complete

Finding 2022-003 Allowable Costs, Allowable Activities, and Matching ? Significant Deficiency in Internal Control Over Compliance Federal/State Agency Name: Department of Justice and State of South Dakota Department of Public Safety Program Name: Crime Victim Assistance CFDA # 16.575, 2022-COMBO-00022, 2022-COMBO-00011 Finding Summary: Audit testing over expenditures noted the following items: -Three instances were noted where hours used to allocate payroll to the grant differed from the actual hours worked and paid resulting in deficiencies in allowable costs, allowable activities, and matching. -One instance was noted where the hours used to allocate payroll to the grant differed from the actual hours worked and paid resulting in deficiencies in allowable costs and allowable activities. -One instance was noted where a non-payroll expenditure where costs charged to the grant that were paid within the service period but related to services outside of the service period resulting in deficiencies in allowable costs, allowable activities and matching. Responsible Persons: Shannon Clark, Chief Financial Officer; Lynn Peterson, Controller; Amy Carter, Program Director; Janice Lee, Finance Administrator Corrective Action Plan: This has been an ongoing issue and we are revising how our draws are prepared and reviewed. We plan to have one person familiar with the process prepare all the draws then a detailed review by the Controller before the draw will be submitted. Anticipated Completion Date: June 30, 2023

Finding 2022-002 ? Allowable Cost/ Cost Principles Planned Corrective Action: In November 2022, the University removed all unallowable salary and related fringe benefits costs off the affected grants, returned funds to USDA through the ASAP drawdown process, and corrected the SEFA. Additionally, the Office of Human Resources (HR) and Office of Grants and Contracts (OGCA) have implemented and strengthen monthly review procedures for Personnel Action Forms. In January 2023, Human Resources granted the OGCA query and view access to the Person?s Pay Distribution Module for employees working on grants and contracts. This will allow the OGCA staff to compare the PAFs to HR and Payroll data and identify errors, if any, for correction. Upon receipt of PAFs in the OGCA, the following steps will occur: A. (1) Verify that the faculty and or staff can be specifically identified with the sponsored project; (2) Verified the position in the budget and/or have the prior written approval of the funding agency; (3) Compare the grant period to the personnel action form (PAF) start and end date; and (4) ensure that required approved signatures (Principal Investigator, Department Head and/or Dean) are present. C. Once the above conditions have been met, the Financial Analyst signs the PAF, forward to the Budget Officer and the VP for Business Affairs/CFO, for approval. The approved document is then submitted to the Office of the President and finally, Human Resources for review, approval, and compliance with university employment guidelines and policies. Once approved, HR enters the PAF into the Colleague System. An employment contract is generated as applicable. D. Monthly Review of the Grants General Ledger Summary Report (GLSA) and the General Ledger Trial Balance (GLTB) and or General Ledger Budget Status (GLBS) are completed by the Grants Financial Analysts. This monthly review is to verify that amounts charged are allowable and accurately posted to the correct departmental account and object codes. Payroll charges are compared to the PAFs. E. The OGCA, HR, and Payroll Offices collaborate on any discrepancies or errors and resolve immediately. Anticipated Date of Completion: Corrective action completed as of the date of this report. Person Responsible for Corrective Action Plan: Mr. Dexter Odom, Chief Financial Officer

Department of Health and Human Services FINDING ? FEDERAL AWARD PROGRAMS AUDITS 2022-001 Documentation of Personnel Expenses (Timesheets) Material Weakness Recommendation: Require all employees to complete a contemporaneous timesheet which includes all required Uniform Guidance requirements. Action Taken: On January 1, 2023, an electronic time reporting function was put into effect through ADP (?Automatic Data Processing?), the company?s payroll processing system. This improvement allows employees to enter their time and select a cost center (?department code?) at the time of entry. It then routes the timesheet for approval by the supervisor before reaching the accounting department for payment initiation, resulting in an automated review and approval.

Corrective Action Plan: SOR II grant leadership evaluated its process for preparing and reviewing time tracking for this award and has implemented procedures to ensure appropriate documentation of personnel costs are complete and accurate. Coordination with Payroll staff begin and was validated with current pay period ending 9/23/23. Hourly staff are clocking into appropriate cost center and salaried staff are submitting hours to payroll to ensure appropriate time tracking Contact Person(s): Heather Hintz/Kathy Dams Anticipated Completion: 12/31/2023

FINDING NUMBER: 2022-002 Condition: The Organization is either lacking or has non-conforming written policies and procedures for the following administrative functions, required by the Uniform Guidance: 1. Financial Management - 2 CFR 200.302(b)(6) 2. Allowable Costs - 2 CFR 200.302(b)(7) 3. Federal payment - 2 CFR 200.305(b)(1) 4. Procurement - 2 CFR 200.318(a) and 2 CFR 200.318(c)(1) 5. Competition - 2 CFR 200.319(d) 5. Competition ? 2 CFR 200.319(d) 6. Methods of procurement to be followed - 2 CFR 200.320 7. Compensation (Personal Services) - 2 CFR 200.430(a)(1) 8. Compensation (Fringe Benefits - Leave) - 2 CFR 200.431(b)(1) 9. Relocation costs of employees - 2 CFR 200.464(a)(2) 10. Travel costs - 2 CFR 200.474 Planned Corrective Action: Management agrees with the finding and plans to review Uniform Guidance, modify and create policies and procedures where necessary to meet administrative Uniform Guidance requirements. The adopted policies and procedures will be reviewed and approved by the School Board of Directors at the organization?s next scheduled Board meeting. School Representative Responsible for Corrective Action: Carlos Perez, Executive Director Anticipated Completion Date: June 14, 2023

Identifying Number: 2022-002 Finding: The following discrepancies and inconsistencies were identified: administrative procedures and requirements of the grantor were not followed; there were no proper review or approval of required reporting prior to submission. Contact person responsible for corrective action: Kevyn Harmon, Senior Director of Finance & Administration Corrective Action: All personnel involved with the Title programs undergo training on the all the processes and requirements to administer the programs, and management will perform proper review of all claims for reimbursement. In additional, an annual update on the procedures and the requirements to ensure propriety and accuracy. Proposed Completion Date: EPIC Academy will complete implementation of the above procedures by November 30, 2022.

Finding: 2022-004 Corrective Action Plan: The District?s payroll process is significantly lacking proper control procedures. With the hiring of a new financial manager, policies, procedures and controls will be implemented immediately, including the proper tracking of time and effort for employees charged to federal grants as required. Anticipated Completion Date: September 1, 2023 Contact Person: Amanda Raymond, Director of Finance

Finding Number 2022-005 Education Stabilization Fund: Elementary and Secondary School Emergency Relief (ESSER) Assistance Listing Number 84.425D Allowable Costs/Cost Principles ? Documentation of Employee Time and Effort Immaterial Noncompliance Criteria: Per Federal regulations 2 CFR section 200.430(i)(1)(vii), the School District must maintain time and effort distribution records for an employee who works in part on the consolidated administrative cost objective and in part on a federal program whose administrative funds have not been consolidated or on activities funded from other revenue sources. Condition: The School District did not maintain time and effort distribution records for employees who were partially funded with ESSER Federal funds. Cause: Oversight. Effect: Time and effort reports were not completed. Questioned Costs: None. Recommendation: Time and effort reports should be completed throughout the year listing the employees name, position or job title, and percentage of time spent on each Federal award and signed by the employee?s supervisor. Management's Response and Corrective Actions: The Director of Finance and Superintendent completed time and effort reports for the ESSER funds expended for fiscal year ending June 30, 2022 and will continue to complete time and effort reports going forward. Person Responsible for Corrective Action: Justin Weston, Director of Finance, and Amiee Erfourth, Superintendent Completion Date: November 21, 2022.

Finding: The Department of Children, Youth, and Families did not have adequate internal controls over and did not comply with some Public Assistance Cost Allocation Plan requirements. Questioned Costs: Assistance Listing # 93.658 93.658 COVID-19 93.659 93.659 COVID-19 Status: Corrective action complete Corrective Action: The Random Moment Time Study (RMTS) is a federally approved cost allocation methodology to claim allowable federal funds. The Department?s use of the RMTS is included in its Public Assistance Cost Allocation Plan (PACAP) with the federal grantor. The Department maintains that the sampling universe is accurate and complete and complies with federal requirements. There is no known deficiency with the integrity of the RMTS, nor are unallowable costs allocated to federal programs. Effective October 2022, the Department contracted with the University of Massachusetts (UMass) for the design and implementation of the RMTS mechanism. UMass has updated the RMTS instructions for the new quarterly process, which remains in compliance with federal law while alleviating the department-imposed restrictions. It also addresses the auditor?s concerns regarding the internal controls applicable to the RMTS worker types included in the sampling universe. The Department has also taken additional actions to address system limitations caused by high staff turnover rates within the cost pools. These include: ? The Headquarters (HQ) RMTS Coordinator pulls an InfoFamLink worker list report that shows all workers with access to the FamLink system. The list is then reviewed by job class to verify the accuracy of RMTS group assignment and to identify the workers that are eligible to be included in the sample. ? The Cost Allocation and Grants Management Unit pulls a job classification report from the Human Resource Management System (HRMS) at the end of every pay cycle. The HQ RMTS Coordinator compares the HRMS report to the InfoFamLink worker list report to verify if they are eligible to be sampled and properly allocated in HRMS. The HRMS has additional information related to job class to assist in sample eligibility determination and strengthen the internal controls around RMTS samples pulled. ? The HQ RMTS Coordinator pulls a workload report from InfoFamLink to view worker caseloads and primary assignments. This is an additional tool to determine if a worker is eligible and assigned to the correct RMTS sample pool. The Department will continue to maintain internal controls over the monthly update process to ensure the RMTS sampling populations are complete. The Department will also work with the federal partners to ensure continued compliance with the PACAP. The conditions noted in this finding were previously reported in finding 2021-042, 2020-044 and 2019-044. Completion Date: October 2022 Agency Contact: Stefanie Niemela Audit Liaison PO Box 40970 Olympia, WA 98504-0970 (360) 725-4402 stefanie.niemela@dcyf.wa.gov

The Office of Vice President of Research and the Controller?s Office will collaborate to ensure effort verification reports are returned no later than 30 calendar days after they have been distributed, including escalating noncompliance to appropriate University leadership. These improvements are expected to be completed by December 2023. Tara Thomason, Controller and Assistance Vice President, is responsible for addressing the above items by December 2023.

The Office of Vice President of Research and the Controller?s Office will collaborate to ensure effort verification reports are returned no later than 30 calendar days after they have been distributed, including escalating noncompliance to appropriate University leadership. These improvements are expected to be completed by December 2023. The Controller?s Office will review its indirect costs configurations within the grants module of Workday to ensure the automated calculation of indirect costs is correct. In addition, the Sponsored Programs Accounting team will manually reconcile indirect costs periodically at the grant level. These improvements are expected to be completed by December 2023. The University continues to have cost transfers in fiscal year 2023 as it reconciles its grants. However, to limit cost transfers in the future, the Office of Vice President of Research and the Controller?s Office worked with the University?s Workday Finance team to configure its accounting system with an automated control that prevents general (non-payroll) expenditures from being charged to the grant after the period of performance end date, one root cause of cost transfers. In addition, for payroll expenditures, the above teams updated grant labor costing allocations in its accounting system to contain an end date that coincides with the period of performance end date which restricts labor costs from being charged after the period of performance. The post award specialists will begin reviewing the labor costing allocations on a periodic basis. Also implemented in fiscal year 2023, before each payroll is processed by the Director of Payroll within the accounting system, grants that have ended are identified by the Assistant Controller and Director of Sponsored Program Accounting and the payroll expenditures are removed from the feed and not charged to the grant. The University has also hired individuals whose sole responsibility is to review general (non-payroll) expenditures charged to grants. Further, the University?s post award specialists are continually trained on the importance of allowed and unallowed expenditures and are now reviewing grant level budget versus actual reporting on a periodic basis to identify noncompliance. Tara Thomason, Controller and Assistance Vice President, is responsible for addressing the above items by December 2023.

2022-017 Finding: - ALN 93.914 ? HIV Emergency Relief Project Grants (Non-Major) / Department of Health and Human Services / Award Number: H89HA00027-28-00, H89HA00027-28-01/ Award Year: 2021 Status: Corrective action in progress Corrective Action: The City agrees with the finding. The review of personnel costs that are not 100% allocated to the grant will be reviewed annually as a part of the annual budget planning process. Allocation decisions will be documented and attached to budget planning documents. Person(s) Responsible for Implementing: DDPHE ?Tristan Sanders, Robert George Implementation Date: October 2023

SIGNIFICANT DEFICIENCY 2022-010 Education Stabilization Fund ? Higher Education Emergency Relief Fund ? 84.425 ? Allowable Costs or Cost Principles Condition Admin expenses reported under the program did not have proper supporting documentation to reflect the salary or wages associated with the specific grant activities. Recommendation We recommend that the College review its controls and ensure that controls are implemented that meet Federal requirements related to payroll documentation. Actions Taken As of March 23, 2023, all personnel working on federal grants whose salary or wage expenses will be paid wholly or in part by the federal funding will be required to prepare a Personnel Activity Report to track time spent on grant vs non-grant activities.

2022-001 MATERIAL WEAKNESS Condition: The District's internal control system did not prevent or detect material errors in the financial accounting records, which are utilized to prepare the District's financial statements. The District failed to transfer dedicated maintenance and operation millage revenues of $725,843 from the general fund to the capital projects fund which is included in the other aggregate funds. The financial statements were subsequently corrected by adjusting entries during audit fieldwork. District Response: The District concurs with this finding. The District has debriefed internally and established a plan complete with appropriate action steps and safeguards to ensure that the dedicated maintenance and operation millage revenues are transferred from the general fund to the capital project fund in a timely manner. The District will ensure due care is exercised to ensure accurate and reliable financial reporting. The point of contact for this would be Kelvin Gragg, Rose Smith, and Ashley Granberry. This Correction should be corrected on or before June 30, 2022. 2022-002 PAYROLL EXPENDITURES Condition: In our sample of payroll expenditures, we identified undocumented compensation of $7,685 and improperly awarded incentive pay of $4,700 paid from Federal funds without proper documentation or requirements. District Response: The District acknowledges the finding and would take this opportunity to explain the circumstances surrounding this material weakness. While not an excuse, it in part explains the conditions under which these instances of undocumented compensation occurred. The District has been impacted by multiple staff changes in the Business Office. The District has employed and/or contracted for payroll services with four (4) persons and for the role of Business Manager with three (3) persons just during this calendar year alone. The District has taken steps to stabilize the workforce in the Business Office. In addition to addressing the human capital issues, the District will provide additional monitoring support to ensure the implementation of the existing internal controls over program expenditures. The district has already taken steps to recoup compensation that was improperly awarded and paid. As recommended, the district will contact the Arkansas Division of Elementary and Secondary (DESE) for guidance regarding this matter. The district began addressing these is July 2022 and have since made the necessary changes as of September 2022. The point of contact for this would be Rose Smith, Ashley Granberry, Lucretia James and Kelvin Gragg.

Restore noted that 3 out of the 19 timesheets that were dated after Restore implemented its new process (i.e., after May of 2022) were missing documented supervisory reviews. This oversight was due to role changes and administrative transitions. To further strengthen the internal controls supporting time tracking, in addition to executing against the corrective action plan note in the prior year findings, in FY23 Restore also created a checklist to track all grant funded timesheets to ensure documented approvals and accurate time tracking.

Individuals Responsible for Corrective Action Plan: Jason Penegar, Vice President - Controller Nisha Eberhart, Accounting Manager Blanca Ramos, Sr. Manager, Compensation and Benefits Accounting Corrective Action Plan: Management will implement a new quality review process to ensure that correct default fund codes are assigned to staff for the DOL WPY grant. In addition, Management will implement a complete oversight review of all grant time charges in advance of the execution of a drawdown of DOL funds. Anticipated Completion Date: June 30, 2023

Corrective Action Plan Fiscal Year Ended December 31, 2022 Finding: 2022-1 Contact: Duane Landon, CFO duane@byrdbarr.place 206.812.4947 Finding: Timesheets did not support payroll allocations for ERAP versus LIHEAP. Corrective Action: Time will be allocated based on the number of files processed per program and timesheets will be completed to reflect this allocation. Proposed Completion Date: This has already been implemented for 2023.

Corrective Action: Management, in the immediate term, will review its oversight and controls on the manual process Grants Accounting implemented for obtaining Time & Allocation Excel Sheet and calculating payroll and benefits costs accurately onto the Request for Reimbursement (RFR). Furthermore, management plans to collaborate with its Payroll Service Provider to capitalize on software upgrades, aiming to enhance the accuracy of Time & Allocation to grants and reduce errors by designing straight-through-process improvements. Name of Responsible Individual(s): Jason Brenier, CFO Anticipated Completion Date: April 2024