Corrective Action Plans

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

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

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

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

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

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

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

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

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