Corrective Action Plans

Finding Number: 2022-005 Condition: An internal control was not in place to document that the current rates of pay were approved. During our testing of payroll for ALN 17.258, 17.259 and 17.278 - WIOA Cluster and ALN 17.207 Employment Services Cluster, we determined that actual pay was charged to the federal grants tested. However, there was no documentation (within personnel files or other means) to support that the rates of pay were approved. Planned Corrective Action: DESC was unable to locate evidence due to turnover with the HR department. We have hired a new Director of Human Resources (Director), who has implemented an employee filing system that incorporates up to date employee information and salary information. This information is noted in offer letters, promotion letters and salary increase letter. All payroll updates are required in writing to evidence approval of the Director of Human Resources and another executive team members authorization (President or CFO). This confidential information is stored in the Director?s locked office. Contact person responsible for corrective action: Calethia Binion, HR Director Anticipated Completion Date: 06/30/2023

Management agrees that we should improve our timesheet input and approval process. The current process is manual, and the corrective action includes two elements: 1.Education process of proper timesheet reporting for new employees and an annual review. 2.Automate the process to increase efficiencies and make the review process more effective. Our 2024 budget submission will include a tool that can be used for these purposes. Name of the contact person responsible for corrective action: Sharon Pinder, President, (301)593-5860. Planned completion date for corrective action plan: December 31, 2023.

Funding Summary: The district was missing Time & Effort documentation details, and documents were signed and dated before the work period end date. Responsible Individual: Teresa Taylor, Business Manager Corrective Action Plan: Per our audit requirement, the current forms we were using for the Semi-Annual Certification and Time & Effort (PAR) have been updated to reflect the required information and proper signatures and date. In the past Time & Effort was not tracked for those paid a stipend for Mentoring, but as of this school year we are requiring that this time is tracked monthly as required per 2 CFR 200.430. Per the grant audit, we have retroactively completed forms for both FY21 & FY22. These records are filed with the respective grants. Anticipated Completion Date: January 20th, 2023

FINDING 2022-004 Contact Person Responsible for Corrective Action: Kasey Clark Contact Phone Number: 574-772-1604 Views of Responsible Official: We concur with the findings. Description of Corrective Action Plan: The bus rates will have in every weekly pay attached the rates for each route and submitted with their timecards. The bus rates will be prepared by the Transportation Director and will be reviewed by the Deputy Treasurer and then the Treasurer. Anticipated Completion Date: March 2023

View of responsible officials and planned corrective action: Due to inaccuracies in the preparation of the monthly payroll journal entry, the Agency is establishing new internal controls. The Agency Accountant has developed a spreadsheet that accurately logs the hours staff works in certain programs. This will result in percentage that will be used by the Accounting Assistant to accurately charge the correct program on the payroll journal entry spreadsheet. Once this is completed each month, the Agency Accountant will review the payroll journal entry for accuracy and that it matches the percent breakdowns given.

Department: Administrative and Financial Services Title: Internal control over monitoring of employee classification and compensation needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Department will require Service Center and Agency HR Directors to notify supervisors at least twice per year of overdue performance evaluations. The Department will require Service Center and Agency HR Directors to review Hiring Requests to ensure duties identified are consistent with classifications. The Department will require Service Center and Agency HR Directors and/or HR recruiters to review job vacancy postings to ensure duties are consistent with classifications. The Department will implement a 'review of classification specification date' on class specs (currently only note date when a change is made). Completion Date: October 1, 2023 (first item), and April 30, 2023 (remaining items) Agency Contact: Breena D Bissell, Director, Bureau of Human Resources, DAFS, 207-215-0886

CORRECTIVE ACTION PLAN February 16, 2023 Community Action Association of Pennsylvania respectfully submits the following corrective action plan for the year ended June 30, 2022. Cognizant or Oversight Agency for Audit: Community Service Block Grant Program Name and address of independent public accounting firm: Hamilton & Musser, PC 176 Cumberland Parkway Mechanicsburg, PA 17055 Audit Period: July 1, 2021 ? June 30, 2022 The findings from the June 30, 2022 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the number assigned in the schedule. Findings ? Financial Statement Audit Significant Deficiencies #2022-001 ? Significant Deficiency ? Segregation of Duties Recommendation We recommend someone other than the Finance Director, preferably the CEO or another office staff, open the mail and record/scan the checks received into a check log. View of responsible officials and planned corrective action The Executive Administrative Assistant is now tasked with and responsible for opening the mail and recording the checks into a check log. The Executive Administrative Assistant will forward checks to the financial services team for additional action steps. #2022-002 ? Significant Deficiency ? Authorization and Approval Recommendation We recommend that all credit card charges are matched to a receipt and reviewed and approved by both the Board President and Board Treasurer, as is the policy with other payables/disbursements. This eliminates the risk associated with having the CEO issue approval over his own credit card charges. View of responsible officials and planned corrective action All credit card receipts will be submitted by the CEO or appropriate staff member to the financial services team. Credit card reconciliation documentation and appropriate receipts will be provided to the Board Treasurer for regular review. -28- Findings ? Financial Statement Audit (Continued) #2022-003 ? Significant Deficiency ? Authorization and Approval Recommendation Non-cash journal entries make it easy for organizations to overstate their revenue or understate their expenses with unsubstantiated accruals/deferrals. We recommend that all journal entries be authorized and approved by the CEO prior to entry. View of responsible officials and planned corrective action As noted, this is no longer an issue with internal controls having been corrected as of December 31, 2021. All non-recurring journal entries will be approved by the CEO. Findings ? Federal Award Programs Audit Community Service Block Grant, CFDA #93.569 #2022-004 ? Significant Deficiency ? Allowable Costs Recommendation We recommend maintaining weekly timesheets with CEO approval, itemized by time allocated per grant. The financial statement records should be supported by direct time allocated to the grant as indicated on the approved timesheets. View of responsible officials and planned corrective action CAAP will do its due diligence in appropriately allocating costs should similar costs be incurred. If the Community Service Block Grant Program has questions regarding this plan, please call Community Action Association of Pennsylvania Chief Executive Officer Beck Moore at 717-233-1075 extension 12.

The District will ensure that all employees not on a formal allocation plan or entirely allocated to a single source complete daily activity reports.

2022-001 Crime Victim Services - Assistance Listing No. 16.575 Recommendation: The Organization should implement internal controls to ensure that time and effort is reviewed on a timely basis. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Women's Advocates has systematized time and effort within the payroll system whereby employees and their supervisors approval timecards with the appropriate grant coding. Name(s) of the contact person(s) responsible for corrective action: Yulanda Williams Planned completion date for corrective action plan: 1/23/2023

Item 2022-001 Written policies, procedures, and standards of conduct Recommendation: Grantees should have written policies, procedures, and standards of conduct as required by 2 CFR 200, Subparts D & E of the Uniform Guidance. 2 CFR 200, Subparts D & E requires the non-Federal entity to establish and maintain written policies, procedures, and standards of conduct including internal controls over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal statutes, regulations, and the terms and conditions of the Federal award. Specific requirements relate to the following: ? ? 200.302 Financial management ? ? 200.305 Payment ? ? 200.319 Competition ? ? 200.320 Methods of procurement to be followed ? ? 200.430 Compensation?personal services ? ? 200.431 Compensation?fringe benefits We recommend that the Board implement the required written policies and procedures. Action Taken: The Board?s management, namely Stacey Parker, CFO and General Manager, acknowledges the finding and will implement the necessary written policies to comply with the UG. Management anticipates completion by September 30, 2023. Audit finding 2022-001 relates to prior year 2021-001 finding. Updated reference number to current audit year 2022.

December 20, 2022 Finding: 2022-001 Allowable Cost/Cost Principal Agency: U.S. Department of Education AL Number: 84.425D Grant: Education Stabilization Fund Under the Coronavirus Aid, Relief and Economic Security Act Name of contact person and title: Crista Perkins, Business Manager Anticipated completion date: 06/30/2023 Agency's response: Concur The Department agrees with this finding and will implement the following: ? ?Review policies and procedures that require time and effort records for employees working in federal grants are properly documents according to grant requirements ? ?Distribute policies and procedures ? ?Train/Update staff on the policies and procedures ? ?Grant manager will review and approve time and effort records to be sure they are covering a six month period per the Compliance Supplement

View of responsible officials and planned corrective action The Association will conduct reconciliation of payroll allocation twice each year at the end of the second quarter and at the end of the third quarter to actual time recorded to ensure salary expense allocated to the federal awards is supported by actual time worked. A budget revision based on actuals will be implemented effective the fourth quarter.

2022-002 Research and Development Cluster ? Assistance Listing No. 93.310 Recommendation: We recommend the Blood Bank implement procedures to ensure all personnel charges to the program are supported by the minimum time and effort documentation outlined within 200 CFR 200.430. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Blood Bank added review and approval processes to compare actual vs budgeted vs allowable time and effort. Names of the contact persons responsible for corrective action: Bryan Eleazar, CFO; Lisa Alexander, Direct of Grant Accounting; Jeanette Lysse, Controller Planned completion date for corrective action plan: October 29, 2021

Federally funded employees will have their timecards regularly evaluated to ensure amounts charged to federal programs are substantiated.

Findings and Questioned Costs Related to Federal Awards Finding Number: 2022-001 Program Name/Assistance Listing Title: Child Nutrition Cluster Assistance Listing Numbers: 10.559 Contact Person: Venessa Beecroft, Business Manager Anticipated Completion Date: June 30, 2023 Planned Corrective Action: The District will implement a tracking tool to ensure that all new hires return their work agreements as they are hired on throughout the year.

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.