Corrective Action Plans

Federal Award - Finding Number: 2025-002 Responsible Person: Director of Finance Condition: The district charged to the food service fund the cost of an asset that was not included on the approved equipment list from Michigan Department of Education and did not obtain approval from Michigan Department of Education prior to purchase. Corrective Action Plan: All food service fund asset purchases made going forward will be compared to the approved equipment list or approved by the Michigan Department of Education prior to purchase. Anticipated Correction Date: Immediate and Ongoing

Condition: During testing it was noted that the Inventory tracking sheet was not updated to reflect items that were abandoned when EEC moved out of a leased property. Cause: EEC did not properly update the fixed asset schedule for disposals, which resulted in items included on the listing and depreciation calculation that were disposed of previously. Corrective Action: We have implemented the following corrective actions: - The finance department has reviewed and will uphold the methods set forth in its capital asset management plan. - All information required by Uniform Guidance has been consolidated into a central tracking system. - Proper asset disposal forms have been completed and will be reviewed by EEC’s Board of Directors at their next meeting to be approved for proper disposal Corrective Responsible Party: Gary Cox/CFO and Finance Department Estimated completion date: 06/30/2025.

Program: Port Security Grant Program Finding: 2024-004 Contact Person: Karen Rindone Assistant Fire Chief Long Beach Fire Department Phone: (562) 570-2544 Email: Karen.Rindone@longbeach.gov Planned Actions: The Fire Department will ensure that all grant funds are expended in compliance with grant guidelines, including the completion of a biennial Equipment Inventory and the submission of a certification letter verifying its accuracy to the grantor every other year. Effective June 16, 2025, the Fire Department will conduct an Equipment Inventory and submit a verification letter to the grantor confirming its completion on a biennial basis. The current Equipment Inventory will be completed by the Support Services Bureau by September 30, 2025. The Fire Department will ensure the accompanying verification letter is sent to the grantor along with the updated inventory list. This biennial requirement will be integrated into the Department’s annual calendar. Following the FY2025 inventory, the next cycle will occur in FY2027 and continue in every odd-numbered fiscal year thereafter. Expected Completion Date: 9/30/2025 Finding: 2024-004 Program: Port Security Grant Program Federal Award Number: EMW-2021-PU-00259 Contact Person: Don Kwok Assistant Director of Finance City of Long Beach Harbor Department Phone: (562) 283-7575 Email: Don.Kwok@polb.com Finding: The Harbor Department failed to properly record the disposition of a federally funded asset. The asset was still marked as “in service” within the equipment listing for FY2024. However, the item had in fact been disposed of during FY2024 after an accident. The asset had a $0 value prior to the accident which initiated the disposal. Corrective Action Plan: The Harbor Department will enhance its written procedures on equipment disposals and provide training to appropriate Finance, Security, and Maintenance Division staff in FY 2025 to ensure compliance and timeliness in following equipment disposal procedures.

Finding Number: 2024‐001 Program Name/Assistance Listing Title: Child Nutrition Cluster Assistance Listing Numbers: 10.553, 10.555, 10.559 Contact Person: Cliff Wadhams, Business Manager Anticipated Completion Date: August 31, 2025 Planned Corrective Action: The District will be requiring all District LEAs to take the necessary training through  the  Arizona  Department  of  Education  web  portal  and  related  classes  as  necessary  to  be  better informed on Capital Expenditures and required approval and form submission.

Corrective Action Plan and Views of Responsible Officials The project was identified in District plans and executed immediately prior to the change in administrative leadership. After review it was noticed that prior capital approval was not obtained prior execution of the project. Applications were subsequently submitted and under review by the CDE at the time of this report preparation. The District acknowledges and has provided professional development with staff, so all are aware of dealing with items that are obtained with federal funds. Pending final answer regarding the prior approval by the CDE will determine the next action of the District.

CONDITION: The Northern Cambria School District contracted Eber HVAC, Inc. for the School District’s RTU Replacement Project which constitutes a construction-related purchase respectively which requires prior approval from the Pennsylvania Department of Education (PDE). The School District did not obtain the required prior approval from PDE for this expenditure. This is a repeat finding (2023-001) for the prior fiscal year. CRITERIA: PDE and Section 2 CFR 200.439(b) of the Uniform Guidance require prior written approval by the federal or pass-through awarding agency for capital purchases including equipment, buildings, and land. Capital expenditures for special purpose equipment with a unit cost of $5,000 or more must also have prior approval. MANAGEMENT’S CORRECTIVE ACTION PLAN: Management will complete the Prior Approval Form for the Pennsylvania Department of Education (PDE) and obtain approval from PDE in advance of incurring any future federally funded expenditures, that meet PDE’s criteria as a capital purchase, to ensure compliance with PDE and Section 2 CFR 200.439(b) of the Uniform Guidance. This procedure will be implemented effective immediately for all future applicable capital purchases.

Significant Deficiency 2024-001. Equipment and Real Property Management United States Department of Education, Passed Through New York State, Department of Education: Education Stabilization Fund COVID-19: Elementary and Secondary School Emergency Relief Fund ALN: 84.425D COVID-19: American Rescue Plan - Elementary and Secondary School Emergency Relief ALN: 84.425U Condition: The District did not include COVID grants-funded capital improvements in its capital assets inventory records. Planned Corrective Action: The District’s Assistant Superintendent for Business will put procedures in place to ensure that capital spending of federal funds are included in the District’s capital assets inventory reports. The federally-funded capital improvements cited in this report will also be added to the capital assets inventory records for financial reporting purposes. Responsible Contact Person: Mr. Idowu K. Ogundipe, CPA Assistant Superintendent for Business Freeport Union Free School District 235 North Ocean Avenue Freeport, New York 11520 Tel: (516) 867-5212 Email: iogundipe@freeportschools.org Anticipated Completion Date: September 1, 2025.

Significant Deficiency 2024-001. Equipment and Real Property Management United States Department of Education, passed through New York State Department of Education Education Stabilization Fund COVID-19: Governor's Emergency Education Relief Fund ALN: 84.425C COVID-19: Elementary and Secondary School Emergency Relief Fund ALN: 84.425D COVID-19: American Rescue Plan – Elementary and Secondary School Emergency Relief ALN: 84.425U COVID-19: American Rescue Plan – Elementary and Secondary School Emergency Relief – Homeless Youth and Children ALN: 84.425W Condition: The District did not include the capital expenditures for the “Unit Ventilators Replacement Project” paid with CRRSA ESSER 2 funds in its current year’s capital assets inventory additions. Planned Corrective Action: The District’s Assistant Superintendent for Business and Operations will review and update existing procedures relating to the recording and tracking of capital assets purchased with federal funds. The cost of the unit ventilators replacement project and pertinent information will be added to the District’s capital assets inventory report. Responsible Contact Person: Brian Phillips Assistant Superintendent for Business and Operations West Hempstead Union Free School District 252 Chestnut Street West Hempstead, NY 11552 Anticipated completion date: September 1, 2025.

At the time of the purchase for this particular building, the district had several prior approval applications for HVAC replacment submitted to DESE for approval. We believe this one had been submitted as well but was unable to confirm that with DESE. We will develop a better checklist for items submitted to DESE for prior approvals so nothing is overlooked.

Significant Deficiency 2024-001. Equipment and Real Property Management United States Department of Education, Passed Through New York State, Department of Education: Education Stabilization Funds COVID-19: Elementary and Secondary School Emergency Relief Fund ALN: 84.425D COVID-19: American Rescue Plan - Elementary and Secondary School Emergency Relief Fund ALN: 84.425U Condition: The District did not include capital expenditures paid with federal awards in its capital assets inventory records. Planned Corrective Action: The Deputy Superintendent will put procedures in place to ensure that equipment and capital spending of federal funds are included in the District’s fixed assets inventory. The federally-funded project noted in this report will also be added to the fixed assets inventory records for financial reporting purposes. Responsible Contact Person: Ms. Diane Castonguay, CPA Deputy Superintendent East Williston Union Free School District 11 Bacon Road Old Westbury, New York 11568 Anticipated Completion Date: August 15, 2025.

CONDITION: The Northern Cambria School District contracted Eber HVAC, Inc. for the School District’s RTU Replacement Project which constitutes a construction-related purchase respectively which requires prior approval from the Pennsylvania Department of Education (PDE). The School District did not obtain the required prior approval from PDE for this expenditure. This is a repeat finding (2023-001) for the prior fiscal year. CRITERIA: PDE and Section 2 CFR 200.439(b) of the Uniform Guidance require prior written approval by the federal or pass-through awarding agency for capital purchases including equipment, buildings, and land. Capital expenditures for special purpose equipment with a unit cost of $5,000 or more must also have prior approval. MANAGEMENT’S CORRECTIVE ACTION PLAN: Management will complete the Prior Approval Form for the Pennsylvania Department of Education (PDE) and obtain approval from PDE in advance of incurring any future federally funded expenditures, that meet PDE’s criteria as a capital purchase, to ensure compliance with PDE and Section 2 CFR 200.439(b) of the Uniform Guidance. This procedure will be implemented effective immediately for all future applicable capital purchases.

View of Responsible Officials: IW has implemented enhanced procedures for capital expenditures allocated to Federal awards. These procedures include an additional compliance review before the capital cost is incurred to ensure adherence to all applicable rules and regulations, including obtaining a written prior approval from a granting agency. To further strengthen IW internal controls over Federal award management, IW has instituted regular quarterly meetings to review projected expenses to be charged to the Federal awards and discuss specific award compliance requirements applicable to these projected expenditures.

FINDING #2024-002: EDUCATION STABILIZATION FUNDS – EQUIPMENT AND OTHER CAPITAL EXPENDITURES (5000) Corrective Action Plan: Compton USD will act with diligence and care. Under the new Director of Fiscal Services, a pre-approval checklist for all grant expenditures, including mandatory CDE approval for equipment and capital expenditures, has been implemented.

Finding 2023-002 - Equipment and Real Property Management Responsible Individual: Arlene Dickens, Chief School Financial Officer Corrective Action: All capital expenditures will require documented prior approval from the grantor agency before encumbrance. Property records will be updated and maintained in accordance with 2 CFR 200.313 and 200.439. A physical inventory will be conducted and reconciled at least once every two years. Anticipated Completion Date: October 1, 2025

Finding Number: 2023-009 Planned Corrective Action: The Treasurer will monitor future grants for this requirement. At the writing of this response ARP ESSER grants for the district have been completely expended. Anticipated Completion Date: March 1, 2025 Responsible Contact Person: Ashley Miller

We have reviewed the qualifications for allowable expenses classified as supplies versus capital expenditures that of a 600 code with ODE CCIP representatives for project relate cash requests as well as getting pre-approval if varying from the budget details request.

The District will ensure that all proposed capital expenditures originating from any Federal sources that are in excess of $5,000 are pre-approved by CDE prior to executing the proposed transaction.

Views of Auditee and Planned Corrective Actions: Being in constant financial constraints facing vendor delivery holds and discontinuing critical services, the Department of Administration (DOA) directly paid certain GMHA vendors. With the urgency of need and insufficient information about the source of funds’ eligibility requirements, an amount owed for an equipment purchase was included in the invoices DOA paid. Moving forward, GMHA will be more proactive in obtaining grants’ eligibility requirements to ensure compliance. In addition, accounting personnel directly involved in reviewing and approving federal grant expenditures will continuously participate in training related to Uniform Guidance Updates. On August 28, 2024, the Chief Financial Officer and the General Accounting Supervisor attended an OMB Uniform Guidance Updates training. Proposed Completion Date: Completed. Name of Contact Person: Yukari Hechanova, Chief Financial Officer

In response to Material Weakness 2023-02, the Superintendent will contact the Division of Elementary and Secondary Education (DESE) , for guidance regarding this matter. The District Superintendent will follow the guidance from DESE to ensure compliance with Federal regulations and commissioner memos to ensure the district follows allowable costs and principles . The contact person is Bill Mizaur who is the superintendent of DMJ.

Further, the partnership DMJ now has with the Arkansas Public School Resource Center for financial services will help establish proper internal controls and management over program expendi tures. The date of completion for this corrective action plan is immediate. The corrections have been made and new internal control procedures are in place.

Similar to the corrective actions mentioned in the item above, the District will conduct a training for all supervisors indicating and sharing what forms are required for each item purchased or purchased service prior to releasing any funds from this point forward.

Links to required Work Force forms(Davis Bacon Forms; Bond Contractor Form, etc. )will be shared with all supervisors to use during collaboration with contractors and subcontractors. We are currently working with the company to determine how best to obtain these records from past services. All federal installations will include needed forms from this point forward.

May 28th, 2024 Christy White, Inc. 348 Olive Street San Diego, CA 92103 Response to Find in #2023-003: The Business Office, in coordination with the Purchasing Department, is developing a process to ensure that the appropriate approvals are obtained in the event that capital expenditures are charged to federal programs. The corrective action is expected to be implemented by June 30, 2023.

Item 2023-002- Equipment and Real Property Management Recommendation: 2 CFR 200.303 requires the non-Federal entity to "(a) establish and maintain effective internal controls over the Federal award that provides reasonable assurance that the non­ Federal entity is managing the Federal statutes, regulations, and the terms and conditions of the Federal award." 2 CFR 200.313 and 2 CFR 200.439 requires that the following rules of allow ability must apply to equipment and other capital expenditures "Capital expenditures for special purpose equipment are allowable as direct costs, provided that items with a unit cost of $5,000 or more have the prior written approval of the Federal awarding agency or pass-through entity. The Chief School Financial Officer, Jessica Pettway, should review documentation for proper approval of equipment and real property prior to encumbrance. Action Taken: Management has reviewed the requirements of 2 CFR Section 200.13 and CFR 200.439 relating to capital expenditures and agrees with the recommendation. Effective July 1, 2024, the Chief School Financial Officer, Jessica Pettway, will review for proper approval of equipment and real property prior to encumbrance.

Had it not been for the transition between superintendents, I do not believe we would have had this finding. Since being in this position, I have contacted DESE (Jayne Green) numerous times for prior approval for things, including those that she stated didn't require the prior approval. Based on the recommendation by the audit or, I contacted Mrs. Green who had me submit a prior approval letter to Mr. Eric James, also in DESE. I submitted that request on Tuesday, June 18, 2024 and received an approval email back from DESE and Mr. James on Wednesday, June 19, 2024, which is attached.