Corrective Action Plans

U.S. DEPARTMENT OF HOMELAND SECURITY 2022-002 COVID-19 - Disaster Grants ? Public Assistance (Presidentially Declared Disasters)- ALN No. 97.036 Recommendation: We recommend the Town enhance procedures and controls to ensure that payroll costs charged to the grant are adequately documented. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We agree with the auditor?s findings. Management will enhance procedures and controls to ensure that payroll costs charged to the grant are adequately documented. Name(s) of the contact person(s) responsible for corrective action: Sue Nickerson, Town Accountant. Planned completion date for corrective action plan: Immediately.

FINDING 2022-004 Subject: Child Nutrition Cluster ? Activities Allowed or Unallowed, Allowable Costs/Cost Principles Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program, After School Snack Program, Summer Food Service Program for Children Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY2021, FY2022 Pass-Through Entity: Indiana Department of Education Compliance Requirement: 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 to ensure compliance with the requirements related to the grant agreement and the Activities Allowed or Unallowed and Allowable Costs/Cost Principles compliance requirements. Context: The School Corporation had not designed or implemented adequate internal controls to ensure that payroll disbursements were only for food service-related services. Payroll disbursements comprise approximately 45% of the program costs charged to the Child Nutrition Cluster. One employee was responsible for processing payroll. Payroll reports were submitted to the School Board and Treasurer for review and approval; however, the reports only provided a total gross amount paid from each fund. The reports did not list the employees who were paid from the fund. In March 2021, the Treasurer implemented a review of the payroll distribution report, which is broken out by fund and individual employee. The lack of controls related to payroll disbursements was isolated to the 2020-21 year. Additionally, payroll disbursements for custodial employees were allocated to the Child Nutrition Cluster based on a percentage of the custodial employees? salaries. However, there were no time and effort logs or other documentation maintained to support the percentage of the custodial salaries allocated to the Child Nutrition Cluster. The custodial salaries make up approximately 3% of the total payroll disbursements charged to the Child Nutrition Cluster. This was an issue throughout the audit period. Views of Responsible Officials and Planned Corrective Actions: We concur with the finding. Description of Corrective Action Plan: The NJ-SP School Corporation will implement internal controls to ensure compliance with the activities allowed or unallowed and allowable costs/cost principles compliance requirements. This will consist of maintaining documentation to support that payroll disbursements are only for food service operating costs by having supporting timesheets and timecards or time and effort reports for all employees paid from the School lunch fund. These controls will be implemented by July 1, 2023. Responsible Party and Timeline for Completion: Dalton C. Tunis ? Corporation Business Manager/Treasurer Anticipated Completion Date: July 1, 2023

Finding 2022-001: Education Stabilization Fund??Governor?s Emergency Education Relief (GEER) and Elementary and Secondary School Emergency Relief (ESSER) Fund Semi-Annual Certification Procedures?Continued Pass-through entity: Michigan Department of Education (MDE) Assistance Listing Number(s): 84.425C and 84.425D Award Numbers: COVID-19 211202-2122, COVID-19 213712-2021, COVID-19 213722-2122 and COVID-19 213742-2122 Award Year End: September 30, 2023 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 prepared and certified by the appropriate program supervisor. Action taken: The School District will implement controls to ensure the appropriate time-and-effort documentation is completed timely and approved by the appropriate program supervisor by adding the topic to management meeting agendas and utilizing Outlook calendar events. Responsible Person and Anticipated Completion Date: Superintendent, December 2022. If the Michigan Department of Education has questions regarding this plan, please call Jim Nielsen at (231) 760-1309.

FINDING 2022-002 Contact Person Responsible for Corrective Action: Cortney Parrish, Corporation Treasurer Contact Phone Number: 765-240-2346 Views of Responsible Official: We agree with the finding Description of Corrective Action Plan: As of fiscal year 2022, the School Corporation no longer pays teachers or aides from the School Lunch Fund, with the exception of one teacher being paid from the School Lunch Fund until December of 2022. As of January 1, 2023, only cafeteria employees are paid from the School Lunch Fund. Anticipated Completion Date: Completed

FINDING 2022-009 Contact Person Responsible for Corrective Action: Andrew Nicodemus Contact Phone Number: 765-362-2342 Views of the Responsible Official: We agree with the finding. Description of Corrective Action Plan: Crawfordsville Community School Corporation plans to review all internal control procedures, including the control procedures over Activities Allowed or Unallowed & Allowable Costs/Cost Principles. After this review, we will implement a system to ensure that all costs are allowable for the program. Additional steps will be completed to ensure that Time and Effort documents are completed and maintained for audit. Anticipated Completion Date: We expect this Corrective Action to be implement by the end of April 2023 to allow for a full review of all internal control processes and procedures.

FINDING 2022-008 Contact Person Responsible for Corrective Action: Andrew Nicodemus Contact Phone Number: 765-362-2342 Views of the Responsible Official: We agree with the finding. Description of Corrective Action Plan: Crawfordsville Community School Corporation plans to review all internal control procedures, including the control procedures over the Activities Allowed or Unallowed and the Allowable Costs/Cost Principles. After this review, we will implement a system to ensure that all costs are allowable for the program. Additional steps will be completed to ensure that the Time and Effort documents are completed and maintained for audit. Anticipated Completion Date: We expect this Corrective Action to be implement by the end of April 2023 to allow for a full review of all internal control processes and procedures.

FINDING 2022-007 Contact Person Responsible for Corrective Action: Andrew Nicodemus Contact Phone Number: 765-362-2342 Views of the Responsible Official: We agree with the finding. Description of Corrective Action Plan: Crawfordsville Community School Corporation plans to review all internal control procedures, including the control procedures over the Activities Allowed or Unallowed & Allowable Costs/Cost Principles. After this review, we will implement a system to ensure that all costs are allowable for the program. Additional steps will be completed to ensure that the Time and Effort documents are completed and maintained for audit. Anticipated Completion Date: We expect this Corrective Action to be implement by the end of April 2023 to allow for a full review of all internal control processes and procedures.

Tacoma Arts Live Response to Single Audit Findings: Tacoma Arts Live management acknowledges that a union worker?s pay was not calculated in accordance with the union contract guaranteeing a 4-hour minimum on the March 20, 2020 payroll. This resulted an underpayment of $97.68. This payroll occurred during the first week of a global pandemic that caused quarantine and all workers to move from working in the office to working in a remote environment. The underpayment was immediately paid upon notification of the mistake. We have received no complaints from the employee. On the March 20th, 2020 payroll, an employee received a disbursement from a tip pool derived from multiple events in the amount of $61.00. This compensation was not removed from the SVOG tracking spreadsheet. Therefore, it was erroneously allocated to payroll costs for the SVOG award. Overall, qualified SVOG spending by Tacoma Arts Live exceeded that which was submitted as proof of spending for our award. Management believes that such over-allocating would allow any small errors in our reports. We regret these two errors and have corrected accounting procedures to control for such items in the future, as noted below. Tacoma Arts Live Corrective Action Plan for Single Audit Finding: Management has implemented an additional internal review process of all over-hire payroll reports. Additionally, management will not balance minor errors by including an excess of legitimate costs when reporting on federal awards.

Finding 2022-003 Federal Agency Name: Department of Justice Program Name: Crime Victim Assistance FFAL #16.575 Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Finding Summary: Our testing over payroll expenditures charged to federal program identified nine instances in which percentage of VOCA hours worked per employee timesheet differed from the percentage of VOCA hours charged to the federal program. Responsible Individuals: Becky Simmons, President and CEO, Donna Nugteren, Director of Finance, Rachel Schartz, Director of Grants Management Corrective Action Plan: State payroll is submitted monthly in the grant drawdown process. The state reviews all payroll and processes for calculating hours. They have provided Call to Freedom with their calculator to assist in the recording of employees who are partially covered under the state grant. All state drawdowns are reviewed by the state prior to payment. The new grant begins 07.01.23. Call to Freedom has obtained the requirements from the state in their Grantee Guidelines document. The Director of Grants Management is a new addition to Call to Freedom and will assist in the review of the process. Call to Freedom will verify accuracy of hours recorded. The percentages are determined by the number of hours each employee records in the grant for the monthly drawdown. Call to Freedom will audit monthly and submit to the state for their review and approval. Anticipated Completion Date: July 2023

2022-003 Payroll Rates Approval Documentation Federal Program ? Emergency Solutions Grants Program Assistance Listing # 14.231 Significant Deficiency Category of Finding ? Allowable Costs/Cost Principles Name of contact person ? Laura Straw, Director of Finance Corrective action ? Management has reviewed the current practice for approval of raises and are implementing a new payroll system that will have authorizations built into the software which will correct this issue. Completion date ? Management and the Board of Directors implemented the above as of December 25, 2022.

Corrective action plan: Management is implementing a job/cost time and labor system as part of the current Paylocity system currently in place. This new time tracking system will allow individuals working directly on contracts to record time spent on grants on their individual weekly timecards. This system will allow management to report time spent by person by contract within our current payroll and financial system. This enhancement will not be in place until January 2023. In the meantime, management has formalized a quarterly manual review process to document actual time spent per employee per contract along with any needed adjustments to allocation percentages. Personnel responsible for corrective action: Stephanie Cawby, Senior Accountant and Alex Laprade-Velasco, Financial Analyst Estimated corrective action completion date: December 2022 ? Manual quarterly review of contract time spent and adjustments. January 2023 ? Implementation of Paylocity Job Cost Time tracking and roll out to employees

FINDING 2022-004 (Auditor Assigned Reference Number) Contact Person Responsible for Corrective Action: Todd VanDerWeele Contact Phone Number: 574.223.2159 Views of Responsible Official: We concur with the finding. We have adjusted our retention practices to keep all employee records according to statute. After employees listed on the personnel report for hiring or reclassification are approved, the HR Director will provide the approved personnel report, salary schedule or CBA salary schedule, employee contract, and screen shot of the entries into the school?s financial software to the Business Manager to review and approve. Anticipated Completion Date: March 31, 2023

FINDING 2022-003 (Auditor Assigned Reference Number) Contact Person Responsible for Corrective Action: Todd VanDerWeele Contact Phone Number: 574.223.2159 Views of Responsible Official: We concur with the finding. We have adjusted our retention practices to keep all employee records according to statute. After employees listed on the personnel report for hiring or reclassification are approved, the HR Director will provide the approved personnel report, salary schedule or CBA salary schedule, and screen shot of the entries into the school?s financial software to the Business Manager to review and approve. Anticipated Completion Date: March 31, 2023

In response to Finding #2022-001, the Foundation will implement two additional mitigating efforts into the existing processes and procedures to address the conditions in this finding. (1) A Missed Approval report will be generated from the payroll system to identify which hourly employee timecards have not been approved after each pay period. Supervisors will be required to provide approvals on timecards of hourly employees identified in this step. (2) The Foundation will develop a time allocation form to document an after-the-fact review of any budgeted payroll costs allocated to awards to ensure they are reflective of actual time incurred. Such time allocation forms will be required on at least a quarterly basis. These steps will be in place by December 31, 2022. Implementation will be overseen and ensured by Dr. Luis Chiappe, Senior Vice President, Research & Collections, 213-763-3361.

Identifying Number: 2022-007 Finding: Unallowable cost-salary allocation Corrective Actions Taken or Planned: UCAN agrees with this finding and is committed to strengthening internal controls to ensure that amounts are properly reported to the funder. We believe that significant turnover in the finance department led to this deficiency, so we are actively documenting procedures and cross-training employees. All vouchers will also go through a review process before they are sent to the funder. This is a repeat finding, with the original corrective action plan to be completed before June 30, 2023. We do believe that corrective actions that have been taken have resolved this issue. Contact person is Kimberly Parish, Chief Financial Officer and she can be reached at kim.parish@ucanchicago.org.

Finding 2022-002 Program: Formula Grants for Rural Areas, COVID-19 Formula Grants for Rural Areas Finding Summary: 2 CFR section 200.430, Compensation ? personal services, states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. The records must be support by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Responsible Individuals: Cheri Holsclaw, General Manager Corrective Action Plan: Basin Transit will review the Federal grants management procedures to ensure that costs incurred due to error or other types of unallowable costs are not included in subsequent reimbursement requests. Anticipated Completion Date: January 27, 2023 Cheri Holsclaw, General Manager

CORRECTIVE ACTION PLAN FINDING 2022-002 Contact Person Responsible for Corrective Action: Heidi Sprunger Contact Phone Number: 260-589-3133 Views of Responsible Official: We concur with the finding the documentation supporting employees? time charged to the Child Nutrition Cluster program for custodians and grant specialist was not properly maintained. However, we disagree that they would be considered an indirect cost according to the definition of indirect cost: (Indirect costs are sometimes referred to as ?overhead costs? and more recently as ?facilities and administrative costs.?) Examples include executive oversight, accounting, grants management, legal expenses, utilities, technology support, and facility maintenance. Description of Corrective Action Plan: The district will evaluate and determine which employees will continue to be charged under the Child Nutrition Cluster Program. Only those employees spending direct physical time in the cafeteria doing work will continue to be under the Child Nutrition Cluster Program. Once identified those employees will be required to fill out a separate time sheet for hours worked under the Child Nutrition Cluster program. Those time sheets will then be approved by the Food Service Director. Once approved they will be submitted to Payroll Coordinator. Anticipated Completion Date: March 20, 2023

Re: 2022 Single Audit Finding Hi Ron, Below is our response to the 2022 Single Audit finding listed in Part 3: Findings and questioned costs ? Major Federal Award Programs Audit; Finding # 2022-001; Criteria: According to 2 CFR 200.430 i(i)(vii) charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed and there should be support to the distributions of the employee?s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award. Condition: In gaining our understanding of controls over payroll, we noted the following control: the majority of the employees at Housing Forward and Subsidiary work for only one grant with the exception of management that may work for two. We viewed 40 timesheets related to the CoC program of which twelve showed the employee working for multiple grants but did not include the number of hours worked for each program on the timesheet, it was tracked through management and staff. Cause: The timesheets that were missing a breakdown of time and effort applied to each grant did not have a detailed tracking of hours by grants to remind employees to allocate their time by grant. The allocation was made based on a percentage rather than the actual time worked. Effect: The hours charged to a program could be under or overstated based budget compared to actual hours that should be documented on the timesheets. Response ? Management Employees have transitioned to submitting time and effort bi-weekly within the ADP payroll system to ensure timeliness of allocation of wages. Hours will be reported based on actual time worked in projects, even when employees are working in a single project. These hours are used to allocate salaries and wages and unpaid time off bi-weekly. Fringe benefits will be allocated on a monthly basis using the allocation of hours for that month. Allocation of hours and coding is reviewed by the Finance department for accuracy and allowance before submittal of payroll. If changes are needed after processing, Finance staff will work with staff to correct time and effort reporting through a manual time and effort report. If you have any questions, please feel free to contact me at mfaust@housingforward.org or 708.338.1724 ext. 263

FINDING 2022-010 Contact Person Responsible for Corrective Action: Tricia Malone Hudson, District Curriculum Specialist Contact Phone Number: 812-279-3521 Views of Responsible Official: We concur with the audit finding. Description of Corrective Action Plan: The school district will develop a plan for tracking employee pay and timecard alignment. The district will ensure that these documents are available to auditors. All expenditures will have a cover sheet with identifying information, will be attached to the proper invoice(s), signed by 2 parties, and hard copies will be kept on file for audit purposes in folders attached to each grant. Anticipated Completion Date: North Lawrence Community Schools will implement this procedure by June 2023.

Item: 2022-004 Assistance Listing Number: 14.241 Programs: Housing Opportunities for Persons with Aids Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Agencies: City of Phoenix Pass-Through Grantor Identifying Number: 144347 Award Year: July 1, 2021 ? June 30, 2022 and July 1, 2022 ? June 30, 2023 Compliance Requirement: Allowable Activities and Costs Criteria: Under cost principles established by 2 CFR 200.430, compensation for personal services includes all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. Condition: In our sampling of payroll expenditures charged to the program, we noted one employee's wage rate charged to the grant was not updated consistent with the employee's wage rate increase paid in their payroll. As a result, the incorrect amount of payroll costs was charged to the program (undercharged). Name of Contact Person: Mike Fett, CFO Phone Number: (602) 265-8338 Anticipated Completion Date: September 30, 2023 Views of Responsible Officials and Corrective Actions: Southwest Behavioral Health Services, Inc. and Subsidiaries will implement controls to ensure payroll costs charged to the grant properly reflected payroll changes and that amounts charged to the grant were properly supported by current wage rates.

Auditors? Recommendation: The auditor recommends that the District implement controls for documenting and retaining information to indicate the District follows the requirements over 2 CFR section 200.430(i). Action Taken: The district will expand the internal controls over the timekeeping and payroll processes by requiring all employee pay applications for the Child Nutrition program be reviewed and approved by the Human Resources Department. A schedule of Pay Rates will be created and submitted to the Board of Education for formal approval, along with the other Salary Schedules approved with the annual budget. In addition, the district is moving to an electronic timekeeping system that will eliminate the use of paper timesheets that must be manually processed for payroll purposes. All Board approved pay rates will be programmed into the electronic timekeeping system so that the need for manual pay rate entry and gross pay calculations will be eliminated. Due Date for Completion: July 1, 2023 Responsible Party: Lisa Rhoades, Food Service Manager Lisa Robinson, Assistant Superintended for Talen Acquisition, and Laura Garcia, Chief Financial Officer

Southern Huntingdon County School District 10339 Pogue Road ? Three Springs, PA 17264-9730 (814) 447-5529 ? FAX (8 14) 447-3967 CORRECTIVE ACTION PLAN YEAR ENDED JUNE 30, 2022 Southern Huntingdon County School District submits the following corrective action plan in response to the finding listed in Section III of the Schedule or Findings and Questioned Costs for Federal Awards for the year ended June 30, 2022: Significant Deficiency in Internal Control and Compliance Finding: Finding 2022-001-Allowable Costs/Cost Principles Condition: Lack of time and effort distribution records for payroll expense charged to ESSER Views of Responsible Officials: Hillary Lambert, Business Manager is the Responsible Official for the ESSER grants. She was unaware of the required time and effort documentation that was needed to support the employee's payroll allocation. Planned corrective action: A biannual time and effort certification has been completed for the first half of the 22?23 school year for the ESSER grants. Procedures have been put into place to ensure time and effort certifications are part of the grant paperwork that is completed at the beginning of every fiscal year. Person Responsible for Corrective Action Plan: Hillary Lambert, Business Manager Anticipated Completion Date: December 20, 2022

Views of Responsible Officials, Corrective Action Plans, and Contact Information 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) Accounting Controls team will coordinate with the MyPLN team regarding the implementation of the annual Mandatory Time & Effort Training. This is a required 30-minute training of administrators, timekeepers, and supervisors with review questions at the end of the course, and requires a 100% correct answers before a certificate of completion will be issued. Name: Timothy Rosnick Title: Deputy Controller Telephone: (213) 241 -7989

The allocation of costs between our two federal programs and other programs are made by the Program Director or after discussion between the Program Director and the Federal Grant Manager; then communicated to the accountant. In addition, our accountant has the program knowledge and ability to question cost allocations. Beginning mid-September, 2023, the basis for allocations will be documented on an invoice or other supporting documents. Effective June 2023, weekly payroll time records allocating hours to projects and programs are prepared by each employee. Those time records are approved by the Program Director or the Treasurer, as appropriate. The allocations are then reviewed by the Federal Grant Manager and entered bi-weekly into the accounting records.

FINDING 2022-002 ? ELEMENTARY AND SECONDARY SCHOOL EMERGENCY RELIEF FUND ACTIVITIES ALLOWED OR UNALLOWED AND ALLOWABLE COSTS/COST PRINCIPLES Contact Person Responsible for Corrective Action: Lisa Baker, Business Manager Contact Person's Phone Number: 765-664-0624 Views of Responsible Official: There is no disagreement with the audit finding. Description of Correction Action Plan: The following phrase will be added to payroll time cards and bus trip sheets when ESSER funds will be used to pay wages and payroll-related expenses: "I hereby certify that this is a true and accurate representation of all hours worked on behalf of ESSER-funded Summer Academy (or ESSER-funded After-School Tutoring) and that duties performed were only for Summer Academy (or After-School Tutoring)." Contract addendums will include the phrase "ESSER-funded Summer Academy" as well. Anticipated Completion Date: March 24, 2023