Corrective Action Plans

CSC?s management concurs with the finding. See Section IV- Current Year Corrective Action Plan.2022-002 Allowable Costs/ Cost Principles Name of Contact Person: Brenda Chandler and Johnny Mammen Corrective Actions: CSC has implemented a policy as of July 10, 2023, that ensures that personnel are hired after the positive background compliances confirmations are obtained along with the modification of internal controls to ensure CSC?s compliance with Federal statutes, regulations, and the terms and conditions of the federal award as stated in the grant requirements. The Human Resources Director will be responsible for implementing and monitoring this policy. Due to the new personnel in finance effective July 17, 2023, CSC will be able to ensure that all grants? receipts are supported by appropriate documentation for expenses incurred. The Senior Accountant will be supervised by the Director of Finance who will be responsible for the implementation of the corrective action. Proposed Completion Date: July 10, 2023 and July 17, 2023 Telephone Number: 202-517-6737

Oversight Agency: U.S. Department of Health and Human Services Turning Point Behavioral Health Care Center respectfully submits the following corrective action plans for the year ended June 30, 2022. Auditor: Dugan & Lopatka, CPA?s 4320 Winfield Road Suite 450 Warrenville, IL 60555 Audit Period: For the year ended June 30, 2022 The finding from the schedule of finding and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. Findings ? Federal Award Programs Audit 2022-001 Auditor?s Recommendation: We recommend Turning Point Behavioral Health Care Center remind its employees that the personnel activity reports are required to be completed. Action Taken: We agree with the finding, and we will be implementing additional staff training for the Personal Activity Reports to be completed by February 24, 2023. In addition to staff training, we have also created a new process to review all Personal Activity Reports. This process will be completed monthly by payroll staff to ensure all personal activity reports are completed accurately. If the funding agency has questions regarding this plan, please call me at 847-933-0051 ext. 417.

Finding Number: 2022-003 Program Name/Assistance Listing Title: Indian School Equalization Program, Administrative Costs Grant for Indian Schools, Twenty-First Century Community Learning Centers Assistance Listing Number: 15.042, 15.046, 84.287 Contact Person: Irene Casias, Human Resources Anticipated Completion Date: March 31, 2023 Planned Corrective Action: The need for improved record keeping and scheduling of such action has been stressed to the new person responsible for such actions. The individual is aware and will strive to make sure that the School is in compliance with the requirements.

Finding 2022-002 Contact Person: Lily Rakness Parra, County Clerk Corrective Action Planned: Washakie County agrees with the finding of 2022-002. A Sams.gov account has been activated in order to verify that entities that are being utilized for County business are not excluded from or are ineligible for participation in Federal programs or activities. Also, the County is currently drafting a Procurement Policy for Washakie County to utilize for the use of Federal funding as well as in an everyday manor of purchasing and maintenance of county facilities in order to satisfy above finding.

Staff has initiated a process whereby ? for employees not using eSuites ? manual review and approval of bi-weekly hours is conducted by supervisors in the appropriate department (i.e., Transit, Police, etc.). Management believes this additional review and approval level will provide the necessary back-up to improve internal control over timecards/timekeeping. Responsible Person: Kevin Saycocie Expected Implementation Date: 07/01/2023

Corrective Action Plan The Troy City Board of Education (the Board) respectfully submits the following corrective action plan for the year ended September 30, 2022. Carr, Riggs & Ingram, LLC 1117 Boll Weevil Circle Enterprise, AL 36330 The finding from the September 30, 2022 schedule of findings and questioned costs is discussed below. The finding is numbered consistent with the number assigned in the schedule. FINDINGS ? FINANCIAL STATEMENT AUDIT No such findings in the current year. FINDINGS ? FEDERAL AWARDS PROGRAM AUDITS Item 2022-001 Activities Allowed/Allowable Costs & Costs Principles (Payroll) Recommendation: 2 CFR 200.303 requires the non-Federal entity to ?(a) establish and maintain effective internal controls over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal statutes, regulations, and the terms and conditions of the Federal award.? We recommend a more detailed and frequent review of the payroll register used to prepare the time and effort certifications should be performed and documented Action Taken: All late hires will be manually added to the review list as needed during the fiscal year for review. Tricia Norman, CSFO, will be responsible for the corrective action plan and anticipates completion of corrective action will be taken before 9/30/2023.

Corrective Action Plan: The Agency of Administration Financial Services Division recognizes the need for a refresher training for all staff on existing procedures to minimize keystroke errors in the future. This training will be completed by May 31, 2023. An additional process will be added to the existing procedures. On a quarterly basis, the General Ledger will be reviewed by program staff to check for reasonableness and the review will be confirmed by a Supervisor. Scheduled Completion Date of Corrective Action Plan: Expected: May 31, 2023: Training for FSD Staff on existing procedures Expected: June 30, 2023: Procedure for General Ledger Review implemented Contacts for Corrective Action Plan: Doug Farnham Deputy Secretary, Agency of Administration Douglas.Farnham@vermont.gov (802) 585-8119 Holly S. Anderson Chief Financial Officer, Agency of Administration ? Financial Services Division Holly.S.Anderson@vermont.gov (802) 505-1177

Finding 2022-102 ? Improve Controls over Allowable Costs (Material Weakness) FAL Numbers: 15.042 Program Titles: Indian School Equalization COVID-19 Indian School Equalization Condition and Context: During 2022, the School provided stipends to employees for recruiting and retention. These stipends ranged from $1,800 to $16,700 per employee. The recruiting and retention stipends had no supporting documentation justifying the amount paid. Recommendation: The auditors recommended that the School establish a written policy on the stipends for recruiting and retention that is reasonable and comparable to other similar organizations in the area. Contact Name: Renee Ramirez, Business Manager Corrective Action Planned: HBCS will develop, in conjunction with the Governing School Board, a recruitment and retention policy that is reasonable and comparable to other schools on Hopi. Anticipated Completion Date: June 30, 2023

Management acknowledges the importance of ensuring that payroll costs charged to the program are consistent between the payroll system and the employee?s timesheet. The Finance Department plans to provide training to program staff on how to properly report their time worked on the grant to ensure that hours worked are both reported correctly on the timesheets and are following the funding allocations that are approved by the grant.

Boston Public Schools (BPS) will revert back to the previously approved Google Form process for daily sign-in and sign-out procedures. This form is authenticated through IT and managed in a centralized repository making it easier to recall data for auditing and validate for weekly time reporting. BPS created a new office of Compliance and Risk Management. The office will audit and review the established process quarterly to ensure integrity of the process. Anticipated Completion Date: June 30, 2023 Responsible Contact Person: Scott Finn, Assistant City Auditor, Grants Monitoring Unit scott.finn@boston.gov

Boston Public Schools (BPS) will revert back to the previously approved Google Form process for daily sign-in and sign-out procedures. This form is authenticated through IT and managed in a centralized repository making it easier to recall data for auditing and validate for weekly time reporting. BPS created a new office of Compliance and Risk Management. The office will audit and review the established process quarterly to ensure integrity of the process. Anticipated Completion Date: June 30, 2023 Responsible Contact Person: Scott Finn, Assistant City Auditor, Grants Monitoring Unit scott.finn@boston.gov

Corrective action plan: TCEQ will provide refresher training to staff and supervisors and review its standard operating procedures to ensure that staff record time and charge to grants accurately, and that calculated allocations of staff time are accurate. The overall objective will be to ensure that salaries and wages are based on records that correctly reflect the work performed. Implementation date(s): March 1,2023 Responsible persons: Yolanda Davis, Deputy Director of Financial Administration Division

All employees are paid based on budget allocations assigned in our position control system. The Director of LCAP, Curriculum & Instruction, Innovation and Special Projects and/or their designee will reconcile the actual time & effort reported to the budget allocations prior to each fiscal year end close. Any necessary adjustments will be communicated to the Fiscal Services department to be processed.

The Darke County Educational Service Center?s management will continue to review payroll calculations and believes this was an isolated error.

2022-002 INTERNAL CONTROL OVER COMPLIANCE WITH ACTIVITIES ALLOWED OR UNALLOWED, ALLOWABLE COST/COST PRINCIPLES ? PAYROLL ACTIVITIES The National Trust has implemented new procedures in fiscal year 2023 requiring supervisors to review and approve time charged to federal awards through the ADP timekeeping system in addition to the reviews performed by finance staff as part of ongoing monitoring of federal awards, including approval of time incurred during the fiscal year prior to implementation of new procedures. Individual(s) Responsible for Corrective Action Plan: Laura Bracis Chief Financial Officer 202-588-6153 Anticipated Completion Date: June 30 , 2023

The District Department of Health (DC Health) concurs with the finding, causes and recommendations cited in the fiscal year 2022 single audit for the HIV Emergency Relief Project Grants (HIVER) program. Corrective action plan objectives are to have the following completed in fiscal year 2023: (1) a regular schedule of payroll data runs and reports of budget-to-actual time migrated to a certification platform managed by the Office of Grants Management, (2) full utilization of a uniform navigable tool and one-stop document for supervisors to certify time and effort and to request next actions if actual costs do not align with personnel budgets, (3) to create an IT solution or mechanism to route and track submissions between supervisors, the Office of Grants Management and the Office of the Chief Financial Officer (OCFO), and (4) the SOP will also be updated to integrate any procedural changes resulting from full implementation. See Corrective Action Plan for chart/table

DHS agrees with the finding. DHS will institute a policy and procedure to support payroll expenditures. This will include pulling a sample on a quarterly basis to perform a reconciliation of employees? pay per the Personnel Action Form to the payroll amount posted in the PeopleSoft payroll system. See Corrective Action Plan for chart/table

The Department of Human Services (DHS) concurs with the finding. Moving forward, DHS will follow the guidance set forth by the District Personnel Manual (DPM) issuance regarding pre-approval documentation for overtime. The plan is as follows: ? An e-mail will be sent to senior leadership quarterly to remind staff of the requirement and to share with the respective division/office overtime approving officials regarding the written pre-approval documentation requirement, to include the link to the DPM issuance. ? On a quarterly basis, select a random sample of staff working overtime. ? E-mail the respective overtime approving officials to obtain copies of all the supporting documentation to confirm that the pre-authorization of overtime that has been worked is being completed. See Corrective Action Plan for chart/table

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. Findings - Financial Statement Audit 2022-001: Significant Deficiency in Internal Controls: Payroll Recommendation: To help ensure that when changes are made to compensation levels employees are accurately paid, the School should implement internal control policies and procedures that require updates being adequately documented in the employee's personnel file. Action Taken: Ethos Academy concurs and has implemented the recommendation. Completion Date: During fiscal year 2023. Contact Person: Tamara Garcia, Director Federal Awards Findings and Questioned Costs 2022-101 Significant Deficiency in Internal Controls Over Compliance: Payroll Recommendation: To help ensure that when changes are made to compensation levels employees are accurately paid, the School should implement internal control policies and procedures that require updates being adequately documented in the employee's personnel file. Action Taken: Ethos Academy concurs and has implemented the recommendation. Completion Date: During fiscal year 2023. Contact Person: Tamara Garcia, Director

FINDING 2022-003 Finding: During testing, it was found that 2 out of 25 employees selected in the payroll sample for allowable costs did not have a completed semi-annual certification form or time and effort log for their work within the Title I program. Controls were not effective in ensuring all hours worked or salaries charged to the grant had the proper supporting documentation. Contact Person Responsible for Corrective Action: Carrie McGuire Contact Phone Number: (574) 875-5161 Views of Responsible Official: We concur with the finding Description of Corrective Action Plan: In order to address the issue related to semi-annual certifications not be completed and filed in a timely manner, Concord Community Schools created a Grants and Assessment Coordinator position in May 2022. A person was hired to fill this position starting on July 1, 2022. One of the essential functions of this position is maintaining current and accurate records related to federal and state grants. Starting in January 2023, in addition to the Grants and Assessment Coordinator, a member of the business department will be a second reviewer and sign the semi-annual certifications. Anticipated Completion Date: July 15, 2023

The District Department of Health (DC Health) concurs with the finding, causes and recommendations cited in the fiscal year 2022 single audit for the Immunization Cooperative Agreements (ICA) program. Corrective action plan objectives are to have the following completed in fiscal year 2023: (1) a regular schedule of payroll data runs and reports of budget-to-actual time migrated to a certification platform managed by the Office of Grants Management, (2) full utilization of a uniform navigable tool and one-stop document for supervisors to certify time and effort and to request next actions if actual costs do not align with personnel budgets, (3) to create an IT solution or mechanism to route and track submissions between supervisors, the Office of Grants Management and the Office of the Chief Financial Officer (OCFO), and (4) the SOP will also be updated to integrate any procedural changes resulting from full implementation. See Corrective Action Plan for chart/table

FINDING 2022-002 Name of Responsible Individual For Finding(s): Bryan Soady, Former Alliance Executive Director Name of Responsible Individual For Correction(s): Awisi Bustos, Current Alliance Executive Director Corrective Action: The Alliance employees will implement a policy and procedures, as well as grant requirements, to ensure that timesheets are completed and certified by both the employee and their supervisor. All Alliance employees will begin to record and submit grant time physical Timesheets. The Timesheets will be used to determine the appropriate amount of the employee?s payroll and payroll related costs that should be allocated to the grant(s) that receive the benefit of the employee?s time and effort. This finding was identified by the Alliance prior to audit when new Executive Director Awisi Bustos began her leadership at the Alliance in January of 2023. It was identified that the prior years corrective action plan was determined to be ineffective. The corrective action plan laid out here has already taken effect. Anticipated Completion Date: September 30, 2023

Management is in agreement with this finding and was aware of the Organization?s manual process to approve and store physical copies of pay rate approval, which could potentially create risk of losing physical copies. In September 2022, the Organization has modified this process to allow managers to virtually approve and store digital copies of pay rate documentation.

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