Corrective Action Plans

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.

Corrective Action: The District has communicated with all departments that pre-filled forms should not be utilized when documenting salaries and wages charged to federal awards. Additionally, the District has reviewed all employees with recurring federal time and effort requirements to ensure the proper forms are completed. Monitoring will occur at the beginning of each semester to ensure all required time and effort documentation has been completed and collected. Responsible Officials: Kevin Caskey, CPA - Chef Financial Officer - (843) 680-6013 Anticipated Completion: Immediately

The Hingham Public Schools’ general weekly payroll is approved on a weekly basis by Management. In the case of our summer programs a similar control has been put in place by Management to ensure all payroll records are approved before processing.

Hingham Public Schools has circulated training guides and templates to grant writers on the requirement to have time and effort reporting completed in a timely manner for staff assigned to specific grants. Grant accounting associates have also been provided with the training material to ensure that there is an additional review of time and effort reports as part of the grant accounting, review and finalization process.

Time & Reporting - Corrective Action Plan In order to strengthen the internal controls surrounding time and effort reporting, the Organization has modified its policies and procedures relating to time and effort reporting to align with any changes in payroll processes and any changes in personnel at the Organization to ensure that appropriate support is maintained at all times at the Organization. Further, the Organization plans to implement regular internal inspections of records to ensure completeness and adherence to the policies in place.

Finding #2023-001 – Allowable Costs relating to Time and Effort and Internal Controls Contact – Suzanne Tobin, Chief Financial Officer Telephone Number – (301)-832-3810 Completion Date – First Quarter of 2024 Information on the Major Federal Program: U.S. Department of Health and Human Services Name of Program: Substance Abuse and Mental Health Services Assistance Listing Number: 93.243 Grant Award Number: 1H79TI085239-01/6H79SM080760-03M001/1H79TI084237-01/ 1H79SM080760-01 Grant Award Period: September 30, 2022 to September 29, 2027, November 30, 2018 to November 29, 2023, September 30, 2021 to September 29, 2026/November 30, 2018 to November 29, 2023 U.S. Department of Veterans Affairs Name of Program: Veterans Supportive Housing Per Diem Program Assistance Listing Number: 64.024 Grant Award Number: VOAQ754-1291-558-PD-21, VOAQ754-2080-558-CM-22, VOAQ754-2286-565-CM-22 Grant Award Period: October 1, 2022 to September 30, 2023 Corrective Action Plan: Effective immediately, the Organization will strictly enforce its policy for employees to properly complete their timesheets and for supervisors to properly review and approve employees’ timesheets. To do this, the Organization will conduct a training for all employees and supervisors about how to properly complete and review timesheets. To ensure compliance with the policy, the Organization will conduct random checks of timesheets every pay period to verify that supervisory approval is performed. Appropriate disciplinary action will be implemented for non-compliance.

The Institute has implemented procedures to ensure all documents to support the salaries and wages charged to federal programs are prepared in accordance with the SCDE requirements.

The Institute has implemented procedures to ensure all budget estimates used for salaries and wages are reviewed quarterly and adjustments will be made to reflect actual cost for the activity performed in accordance with the SCDE requirements.

The School District recognizes the issue identified during the audit and has made all necessary adjustments to ensure compliance with spending down the remaining ESSER III funding.

The Assistant Superintendent of Curriculum & Instruction will work with the Business office and the Human Resources department to ensure that the Certification of Federal Awards forms accurately reflect the employee's time charged to the grant. The forms will be reviewed to ensure the costs are allowable and properly documented.

The District will implement a system of internal controls to ensure that all certifications are completed timley. Additionally, the District will ensure that time being charged to the grant agrees to actual time spent working in the grant for each employee.

Ashley Community Schools will immediately implement procedures to ensure documentation of distribution of salaries and wages is regularly completed, reviewed, authorized and maintained. The direct supervisor of all staff providing services under federal awards will ensure documentation is compiled, reviewed and authorized no less than quarterly. Original documentation will be maintained by the direct supervisor and copies of fully executed documentation will be shared with the superintendent’s office for storage for a minimum of five years.

Finding 2022-002 Lack of Internal Control Over Activities Allowed or Unallowed and Allowable Costs/Cost Principles Name of Contact Person: Dora Mathew, Tribal executive Director Mary Carl, Tribal Financial Officer Corrective Action Plan: Nunakauyarmiut Tribe concurs with the finding and has strengthened controls governing payroll and other expenditures charged to federal awards. The Tribe requires documentation demonstrating that payroll costs charged to a federal program are supported by actual work performed for that program and are necessary, reasonable, allocable, allowable, and consistent with the applicable award and Tribal policies. Timesheets and payroll records will be reviewed before payroll expenses are charged to federal awards. Finance will periodically reconcile payroll expenses to the general ledger, applicable grant or contract budgets, and supporting documentation. Unsupported or incorrectly allocated expenditures identified during review will be investigated and, when appropriate, corrected through properly documented accounting adjustments. Finance, Administration, supervisors, and program personnel will coordinate to ensure payroll and other costs are charged only to programs that benefited from the activity and that adequate supporting documentation is maintained. Proposed Completion Date: September 30, 2026.

Finding 2022-003 Lack of Internal Control Over Activities Allowed or Unallowed and Allowable Costs/Cost Principles Name of Contact Person: Dora Mathew, Tribal executive Director Mary Carl, Tribal Financial Officer Corrective Action Plan: Nunakauyarmiut Tribe concurs with the finding and has implemented additional controls over expenditures charged to federal transportation awards. Payroll and other costs charged to transportation programs must be supported by documentation demonstrating the relationship of the expenditure to the applicable project or federal award. Employee time charged to transportation projects must reflect actual work performed and be supported by approved time and payroll documentation. Finance will reconcile transportation program expenditures to the general ledger, approved award budget, and supporting documentation. Costs that cannot be adequately supported or determined to be allocable to the applicable transportation award will not remain charged to that award. The Tribe will maintain supporting documentation for payroll, purchases, contracts, invoices, travel, and other expenditures associated with transportation awards to provide an adequate audit trail and demonstrate compliance with applicable award requirements. Proposed Completion Date: September 30, 2026.

Finding 2022-008 Lack of Internal Controls Over Activities Allowed or Unallowed and Allowable Costs/Costs Principles Name of Contact Person: Noelle George, Tribal Administrator Corrective Action Plan: Management will strengthen internal controls over payroll and review personnel files for adequate pay rate documentation. Proposed Completion Date: October 31, 2026.

View of Responsible Officials: Management response and corrective action Personnel responsible for corrective action: Evan Heath, CFO Anticipated completion date for corrective action: April 30, 2026 In response to Finding No. 2022-SA3, management agrees with the finding. Corrective actions will be implemented in subsequent fiscal years. Unallowable costs will be identified and documented in the Accounting Policies and Procedures Manual and communicated to the Finance Department and the Organization’s employees. The CFO will regularly communicate these requirements to directors and staff through weekly and monthly meetings to ensure a clear understanding of allowable versus unallowable costs. In addition, quarterly budget-to-actual analyses will be prepared and reviewed to monitor expenditure and ensure costs remain within approved budget limitations.

Department of Housing and Urban Development and Department of Veterans Affairs 2022-008 Federal Program Name: Emergency Solutions Grant Program and VA Homeless Providers Grant and Per Diem Program Assistance Listing Number: 14.231 and 64.024 Recommendation: We recommend the Organization develop a system of internal controls to ensure that salaries and related payroll expenses are tracked to reasonably reflect the actual time spent working on the programs. In addition we recommend that management retain all documents including evidence of review and approval for all expenditures of federal funds until the latter of the legally required retention period or completion of required audits. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management has implemented internal control procedures to strengthen payroll allocation practices and documentation retention for federally funded expenditures. The Organization has established a process to ensure that salaries and payroll-related costs charged to federal programs are supported by appropriate time tracking and allocation documentation that reasonably reflects actual time worked on each program. Supervisory review and approval requirements have been implemented to validate payroll allocations and supporting documentation. Additionally, the Organization has reinforced documentation retention standards by requiring retention of all federal expenditure support, including invoices, approvals, reconciliations, and evidence of review, in accordance with federal retention requirements and audit availability standards. Name(s) of the contact person(s) responsible for corrective action: Ryan Ross, Executive Director Planned completion date for corrective action plan: March 31, 2026

Item 2022.003 - Activities Allowed or Unallowed Recommendation We recommend that the Center consistently enforce its internal controls over payroll to ensure that the timesheet and payrates are reviewed and approved by the appropriate supervisor. Additionally, we recommend that the Center consistently reinforces its internal controls over nonpayroll expenditures to ensure all expenditures were approved by the appropriate supervisor. Repeat Finding Yes Action Taken Island Health Care will take the following actions to address this recommendation: Timesheet and Payrate Review and Approval: • Standardize timesheet submission and approval process • Utilize an electronic timesheet system to document the verification of employee payrates and ensure there is a detailed audit trail that records all submissions, reviews, and approvals by supervisors • Conduct regular audits to verify timesheets and payrates are reviewed and approved by supervisors NonPayroll Expenditures: • Evaluate and improve upon existing processes to ensure internal controls over nonpayroll expenditures are working. This includes enforcement of approval policies with mandatory documentation and regular monitoring throughout the process for a clear audit trail • Conduct regular audits to verify nonpayroll expenditures have been reviewed and approved by supervisors

During this period, Hope the Mission experienced rapid organizational growth in which our internal infrastructure had not yet caught up to support the significant growth in programs and funding. Since then, management changed our 3rd party payroll provider in order to better support our payroll and reporting needs. As part of this transition, we worked closely with our new payroll provider to implement job-costing functionality that will accurately track time across grants funded programs. In addition, we have established a process requiring department leads to review and approve all timesheets prior to submission. We also partnered with our new 3rd party payroll provider to set up time allocation for salaried employees.